Round 6 Discussion: Many thanks for all your Round 4 comments – this is getting very complicated - let’s hope we can find a way through
3) For “small” dry cargo ships discussed in the penultimate paragraph of 13.1 and the second paragraph of 13.2 above, do you:
a) prefer to reduce the “s=1” requirement in reg. 9.8 or b) allow some flexibility of application or
c) not apply reg. 9.6, 9.7 and 9.8 at all or d) have an alternative suggestion?
4) In general do you accept the new proposals at the end of this document for altering reg. 4.1 together with all the individual “applicability” changes shown thus [x] either:
a) fully b) in part c) not at all?
If your answer is b) please indicate which items you disagree with using [x] as
the reference number and/or suggest improvements in the box below.
If your answer is c) please indicate an alternative for clarifying the applicability of the regulations in part B-2 to B-4 (for example Table 4.1 in the EN).
5) Finally, if you agree to the changed text in reg. 4.1 would you prefer the list of regulations deemed equivalent to SOLAS 2009 in 4.1.2 to be:
a) fully repeated in 4.1.3 or
b) simply referred to as “listed in paragraph 1.2” (to save undue repetition)?
1) a) or b)?
If b) specify alternative
a): Japan, Norway, Italy, RoK, EC (seems appropriate), China.
b): Germany, UK (the matter is best addressed in Reg. 2.19.), France, Denmark (we can use the definition in reg. 2.19)
RINA (In 10.4.1 the implication is that the term bulkhead deck and freeboard deck are interchangeable. The ICLL 1966/1988, regulation 3(9)(a) states that:
“ The freeboard deck is normally the uppermost complete deck exposed to weather and sea, which has permanent means of closing all openings in the weather part thereof, and below which all openings in the sides of the ship are fitted with permanent means of watertight closing. “
This is not compatible with the definition of bulkhead deck in regulation 2.19.
Furthermore the definition of freeboard deck is already provided in regulation 2.6 which states :
Freeboard deck is the deck as defined in the International Convention on Load Lines in force.
In regulation 2.19 we would propose to delete the last sentence “In a cargo ship the freeboard deck may be taken as the bulkhead deck. “)
US (Option b
Given the definition of bulkhead deck in reg 2.19 (and freeboard deck in reg 2.6), standardize all regulation text as follows:
• If a regulation or a specific provision within a regulation only applies to a cargo ship – use the term “freeboard deck”.
• If a regulation or a specific provision within a regulation only applies to a passenger ship or it applies to both passenger and cargo ships – use the term
“bulkhead deck”. )
No comment: CLIA (cargo ship issue)
2) a) b) c)?
If c) specify alternative
a): Japan, RoK, China
b): Norway, UK (a definition of this nature should be placed in Reg. 2), Denmark (to be consistent we should include all definitions in reg. 2.)
c): RINA (Re para 11 in the discussion we would comment on the italic text as follows:
1. It would seem that we should only apply the relevant parts of SOLAS to cargo ships of more than 500 gross tons AND 24 m L and upwards (or as expressly defined in each chapter)? Comment: It is our understanding that the 24m L criteria is an ICLL requirement and does not directly influence the SOLAS requirements.
2. That is, no cargo ship of less than 24 m in length but greater than 500 gross tons would need to comply with SOLAS Part B. Comment: It is our understanding that ships with a gross tonnage of 500 or greater would have a length greater that 24 m. Therefore this is not a valid argument.
Cargo ships over 500 gross tonnage and 80 metres, or over, in length are to comply with Reg 4 damage stability requirements. Cargo ships 500 gross tonnages and over, with a length less than 80 meters do not require to comply with these damage stability requirements.
3. nor would a cargo ship of less than 500 tons but more than 24 m L. Do you agree? Comment: Agreed. Chapter I Part A, Reg. 3 (a) (ii) states that the present regulations, unless expressly provided otherwise, do not apply to cargo ships of less than 500 gross tonnage.)
Germany: (Proposal : Similar to the proposal for 4.1, but excluding 24<=L<=
80m. Add an additional sentence: If not further specified in the regulation (this is to cover Reg. 5 for L> 24,m).)
US: (Option c (i.e. do not define “dry cargo ship” and “small dry cargo ship”)
We disagree with the statement in 5.2 above that “none of the regulations in part B-2 apply to cargo ships carrying liquids (e.g. tankers, IBC, IGC)”. We believe there are numerous regulations in part B-2 that apply to tankers and there is no need for a
“dry cargo ship” definition. We also do not support a definition for “small” cargo ships; we believe any length limits should be included directly in the regulation (e.g. as is currently done in reg 4.1 with the 80m limit)).
France (§2 : Is it necessary to introduce a new definition for small cargo ships? It should be sufficient to keep the present wording saying :
[ .3 the remaining regulations in Part B-1 shall apply to passenger ships of all sizes and, with the exception of regulations 8 and 8-1, to cargo ships having a length (L) of 80 m and upwards [ including combination carriers with type B freeboards as defined in SOLAS II-2/3.14 ] [but excluding small dry cargo ships.] [but they] [They] shall not apply to any vessels which are shown to comply with subdivision and damage stability regulations in [other]
[the] instruments[*] developed by the Organization [and listed in paragraph 1.2] )
3) a) b) c)
or d)? a): Italy, RoK (and b)), France, UK (prefers to have a minimum survivability requirement still be applied for “small” dry cargo ships, for this “s=0.5” which corresponds to about 2.0m survival in waves seems an adequate measure.), Denmark (or b) depending on further studies on very small dry cargo ships (tugs etc.)
b): RoK (and a)), Denmark (or a) depending on further studies on very small dry cargo ships (tugs etc.), China.
c): Japan (There were no requirements equivalent to Reg.9-6, 7, 8 in SOLAS90 for small cargo ships).
US (Option c (i.e. not apply reg. 9.6, 9.7 and 9.8 to cargo ships less than 80m) If regulations 9.6 and 9.7 were revised to indicate “...or a cargo ship of 80m in length and upwards...”, there would still be a DB requirement for cargo ships less than 80m but it would not require the reg 9.8 damage stability assessment if the Administration determined that a full DB was not “practicable and compatible with the design and proper working of the ship”.)
Note: We think this item is more appropriately addressed under regulation 9 than under regulation 4.)
d): Norway (see comments below) RINA (see comments below)
Germany (As smaller vessels tend to sink (particularly for LO-wells), s<1 is mostly not helpful for them. A reduced damage extent is required here, e.g not damaging the spaces adjacent to the parts without regular DB. But most of all, more detailed investigations about the effect of the regulation on smaller vessels are recommended.) applicability of Reg. 9.8 for small dry cargo ships are further considered under Reg.
9 itself).
b): Japan (Japan thinks that it is difficult to apply reg.12.2 to small dry cargo ships. (See also Q.39D-41D)), Norway (see comments below), France (see comments below)
b) [10]: RINA (Noted that there is a majority however RINA‘s comment remains as previously stated).
c): US (Option c; some items we do not agree with and the rest is too complicated.
We will work on an alternative but not sure if it will be ready in time...
Other Comments: Germany (To delete the footnote is appreciated by us, but there might be legal problems to do so, as some Codes have another legal status:
For example: The SPS-Code is not mandatory.) 5) a) or b)? b): RINA, Norway, RoK, UK, Denmark, China.
No comments: Japan
N/A: US (do not agree to the changed text in reg 4.1)
Comments / Alternative Proposals?:-
RINA on 3): As the regulations currently stand, a double bottom is required for all passenger and cargo ships, other than tankers. In which case cargo ships, 500 gross tonnages and over, require to be provided with a double bottom. This is consistent with current classification practice. It follows that any dispensations or unusual arrangements in the double bottom should comply with the requirements of Regulation 9.8. The text in square brackets .[This does not apply to small dry cargo ships.] [ 3 ] in paragraphs 9.6 & 9.7 can be deleted as the double bottoms requirements are applicable to ships 500 gross tonnages and greater.
It is noted that in 9.5 the Administration may permit a double bottom to be dispensed with if satisfied that the fitting of a double bottom would not be compatible with the design and proper working of the ship. We would consider that this is not consistent with the proposed EN which states in Regulation 9.1that the provision of a double bottom is intended to minimize the impact of flooding from a minor grounding. It is considered that where a ship is on short international voyages there is a higher probability of grounding and 9.5 should be reviewed.
It is noted that 9.9 states. “In case of large lower holds in passenger ships, the Administration may require an increased double bottom height of not more than B/10 or 3 m, whichever is less, measured from the keel line. Alternatively, bottom damages may be calculated for these areas, in accordance with paragraph 8, but assuming an increased vertical extent.” It is considered that this philosophy should be extended to cargo ships with large lower holds.
Norway on 3): Keep regulation as it is for all cargo vessels except oil tankers and those complying with IBC or IGC.
Norway on 4): Delete “damage stability” in first sentence in Reg. 4.1.
The application of part B-2 and B-4 should read: “In Parts B-2 and B-4, the regulations shall apply to passenger ships of all sizes and [dry] cargo ships except where expressly provided otherwise.”
France on 4): For regulation 5-1, proposed formulation excludes tankers. The purpose seems to be that for such ships, damage stability is much dependant on loading of cargo tanks, and so minimum GM curves may not be produced. However, such curves may be produced with specific assumptions. An alternative solution may be not to exclude tankers, but to modify regulation 5-1 to give the possibility for some types of ships not to produce minimum GM curves.
With proposed wording, application of remaining regulation in part B-1 is limited to dry cargo ship. During discussions to establish SOLAS 2009, this restriction had been deleted to cover tankers which may carry non dangerous cargo. So France would prefer to delete “dry” and reintroduce MARPOL, IBC code and IGC code in the list of instruments.
France on 5): If it is said that regulation 5-1 applies to all cargo ships, is it necessary to specify that this include ships covered by listed instruments? It should be sufficient to have the list in paragraph 4.1.3.
Q6 (FOR DISCUSSIONS AT SLF 54)
Co-ordinator’s Notes:- This question has become very complicated, involving changes that affect many regulations. We can only suggest that at SLF54 each proposed alteration is dealt with in turn at the particular point of occurrence. Also there are many opinions, meaning that decisions will have to be made by discussion rather than via a CG. To act as a start to these discussions, the co-ordinators have produced a draft version of the applicability of Reg. 4.1, which attempts to put the footnotes into the main text and eliminate the table in the EN to the footnotes whilst trying to incorporate as many of the points raised by members in the CG discussion as possible. Not easy! We apologise if we appear to have ignored some of your excellent comments but this was the only way we could think of trying to make progress.
We have actually produced 2 alternative versions for revising the applicability of parts B-1 through B-4 in reg 4.B-1 for consideration at SLF 54. The first option excludes proposed new definitions of “dry cargo ship” and “small dry cargo ship”, and relies on the definitions in reg. 2. Also new paragraph 4.1.3 does not repeat the list of regulations in 4.1.2 making the paragraph shorter. Not all members agree with either proposal and the US have produced a paper which gives us another option to look at (ref. SLF 54/8/5) based on its concern that the coordinator’s proposals have removed oil tankers from the equation. Shown below are clean copies of the two options proposed by the coordinators and it is hoped that these can be compared with the new option from the US during the discussions at SLF 54:-
[OPTION 1 - the shorter version; those accepting new Reg. 4.1 preferred the shorter version.] [Q6D(5)]
[1 The stability requirements in parts B-1 through B-4 shall apply as follows.
In Part B-1,
.1 regulation 5 shall apply to passenger ships of all sizes and every cargo ship (including oil tankers and vessels covered by the IBC and IGC Codes).
.2 regulation 5-1 shall apply to passenger ships of all sizes and every dry cargo ship including those vessels which are shown to comply with stability regulations in the following instruments developed by the Organization:
• Guidelines for the design and construction of offshore supply vessels, 2006 (MSC.235(82)); Q8 [See under Agenda Item 7 at SLF 54]
• Code of Safety for Special Purpose Ships, 2008(Resolution MSC.266(84);
Q9
• Damage stability requirements of regulation 27 of the 1966 Load Lines Convention as applied in compliance with resolutions A.320(IX) and A.514(13), provided that in the case of cargo ships to which regulation 27(9) applies, main transverse watertight bulkheads, to be considered effective, are spaced according to paragraph (12)(f) of resolution A.320(IX), except ships intended for the carriage of deck cargo; and
• Damage stability requirements of regulation 27 of the 1988 Load Lines Protocol, except ships intended for the carriage of deck cargo.
• [MODU Code] Q10 [Majority 8-4 in favour of adding to the list – accept?]
.3 the remaining regulations in Part B-1 shall apply to passenger ships of all sizes and, with the exception of regulations 8 and 8-1, to dry cargo ships including combination carriers with type B freeboards as defined in SOLAS II-2/3.14 but excluding small dry cargo ships. They shall not apply to any vessels which are shown to comply with subdivision and damage stability regulations in the instruments developed by the Organization and listed in paragraph 1.2.
In Parts B-2 and B-4, the regulations shall apply to passenger ships of all sizes and dry cargo ships except where expressly provided otherwise.
In Part B-3, the regulations shall apply to passenger ships of all sizes
. ]
[OPTION 2 - the longer version] [Q6D(5)]
[1 The stability requirements in parts B-1 through B-4 shall apply as follows, where:
Dry cargo ship is a cargo ship of any size but excluding oil tankers and vessels covered by the IBC and IGC Codes.
Small dry cargo ship is a dry cargo ship with 24<= L<= 80 m. and gross tonnage >= 500.
In Part B-1,
.1 regulation 5 shall apply to passenger ships of all sizes and every cargo ship (including oil tankers and vessels covered by the IBC and IGC Codes).
.2 regulation 5-1 shall apply to passenger ships of all sizes and every dry cargo ship including those vessels which are shown to comply with stability regulations in the following instruments developed by the Organization:
• Guidelines for the design and construction of offshore supply vessels, 2006 (MSC.235(82)); Q8 [See under Agenda Item 7 at SLF 54]
• Code of Safety for Special Purpose Ships, 2008(Resolution MSC.266(84);
Q9
• Damage stability requirements of regulation 27 of the 1966 Load Lines Convention as applied in compliance with resolutions A.320(IX) and A.514(13), provided that in the case of cargo ships to which regulation 27(9) applies, main transverse watertight bulkheads, to be considered effective, are spaced according to paragraph (12)(f) of resolution A.320(IX), except ships intended for the carriage of deck cargo; and
• Damage stability requirements of regulation 27 of the 1988 Load Lines Protocol, except ships intended for the carriage of deck cargo.
• [MODU Code] Q10 [Majority 8-4 in favour of adding to the list – accept?]
.3
the remaining regulations in Part B-1 shall apply to passenger ships of all sizes and, with the exception of regulations 8 and 8-1, to dry cargo ships including combination carriers with type B freeboards as defined in SOLAS II-2/3.14 but excluding small dry cargo ships. They shall not apply to any vessels which are shown to comply with subdivision and damage stability regulations in the following instruments developed by the Organization:• Guidelines for the design and construction of offshore supply vessels, 2006 (MSC.235(82)); Q8
• Code of Safety for Special Purpose Ships, 2008(Resolution MSC.266(84);
Q9
• Damage stability requirements of regulation 27 of the 1966 Load Lines Convention as applied in compliance with resolutions A.320(IX) and A.514(13), provided that in the case of cargo ships to which regulation 27(9) applies, main transverse watertight bulkheads, to be considered effective, are spaced according to paragraph (12)(f) of resolution A.320(IX), except ships intended for the carriage of deck cargo; and
• Damage stability requirements of regulation 27 of the 1988 Load Lines Protocol, except ships intended for the carriage of deck cargo.
• [MODU Code] Q10
In Parts B-2 and B-4, the regulations shall apply to passenger ships of all sizes and dry cargo ships except where expressly provided otherwise. In Part B-3, the regulations shall apply to passenger ships of all sizes
.]
[For either of the above options the old footnote to reg. 4.1 may be deleted]:-
_________________________
* Cargo ships shown to comply with the following regulations may be excluded from the application of part B-1:
.1 Annex I to MARPOL 73/78, except combination carriers (as defined in SOLAS II-2/3.14) with type B freeboards are not excluded;
.2 International Bulk Chemical Code;
.3 International Gas Carrier Code;
.4 Guidelines for the design and construction of offshore supply vessels (resolution A.469(XII));
.5 Code of Safety for Special Purpose Ships (resolution A.534(13), as amended);
.6
Damage stability requirements of regulation 27 of the 1966 Load Lines Convention as applied in compliance with resolutions A.320(IX) and A.514(13), provided that in the case of cargo ships to which regulation 27(9) applies, main transverse watertight bulkheads, to be considered effective, are spaced according to paragraph (12)(f) of resolution A.320(IX), except ships intended for the carriage of deck cargo; and.7 Damage stability requirements of regulation 27 of the 1988 Load Lines Protocol, except ships intended for the carriage of deck cargo.