IMO CORRESPONDENCE GROUP ON LIFE-SAVING APPLIANCESPROPOSED AMENDMENTS TO SOLAS CHAPTER III

=> ILAMA- comments added in RED

Regulation 3Definitions

For the purpose of this chapter, unless expressly provided otherwise:

. . .

PROPOSAL 1.1 (USA)

25 Unfavourable conditions of trim and list is the worst combination of maximum list and trim angles for a ship in the intact or survivable damaged stability condition, taking into consideration a wind and sea state associated with force 6 on the Beaufort scale and the final damaged waterline of the ship.

Reason: See discussion under regulation 16.

(Finland) Finland still believes that the launching systems for survival craft; rescue boat and marine evacuation system has to function in all respect to the functionality of the system in the unfavourable conditions of trim of up to 10º and list of up to 20º either way. It is not only a design criteria, but it is also a function criteria. In that respect Finland suggest a new text for regulation III/16.6. 6 Falls, where used, shall be long enough for the survival craft or rescue boat to reach the water with the ship in its lightest seagoing condition, under unfavourable conditions either to a of trim of up to 10° and list of up to 20° either way or to the maximum designed list and trim of the ship whichever is less.

Finland can support the text in regulation III/3.25.

(Republic of Korea) We agree that in some cases 20 ˚heel/10˚trim results is unrealistic. However, having one definition as suggested by USA seems also unrealistic. For the purpose of each regulation which should refer this definition, the worst unfavorable ship condition is different. Furthermore, finding the "survivable damaged stability condition" (maybe using stability criteria and damage scenarios defined in various conventions) which is also unfavorable for the purpose of each regulation will require huge/unrealistic amount of design calculations.(many calculations for Reg.III/16.6 and many other for other reg. etc.). Therefore, we suggest not to have one definition as new para. 3.25 but handle this issue in each applicable regulation with appropriate modifications.

(ILAMA) SOLAS only requires damaged stability calculations for ships above 80 m, therefore the required data will not be available for ALL SOLAS- ships.

SOLAS only requires wind influence calculations for damaged stability calculations for passenger ships, high speed ferries and similar, therefore the required data will not be available for most SOLAS- ships. If included: it should be stated if the wave height associated with "wind Bf 6" should be added to heights which have to be determined acc. to this definition or if only the wind influence on the list and trim of the ship shall be considered. Wave behavior is unique for Seas. The North Sea shows a different wave behavior compared with the Atlantic Ocean. This will make the change of this requirement difficult.

(IACS) It is noted that the current regulations citing a prescriptive 10 deg trim/20 deg list for unfavourable conditions of trim and list can, in some cases, result in unrealistic LSA arrangements. However, we feel the proposed definition may not improve the situation. To require finding the "survivable damaged stability condition" as a condition for the approval of every ships' LSA arrangements could result in an unrealistic amount of design calculations. It might be more appropriate to allow, in cases where it may be unrealistic to meet the requirement considering a 10 degree trim and/or 20 degree list, an alternative approach to be taken. One alternative approach could be the application of the worse trim and heel angles based on the

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intact and damage equilibrium waterlines that result from applying the requirements of the relevant Conventions. When LSA arrangements are approved using this alternative approach, the same parameters should also be used to determine compliance for all components of the system.

(Norway) Sea state of minimum 3 metre significant waves should also be included in the text, in accordance MSC 81(70) 12.6.2.

(Coordinator) There appears to be substantial agreement, in principle, with the concept of allowing the worst-case trim and list conditions for a particular ship to be used as an alternative to the current static 10° trim/20° list criterion. The latest specific proposal is as follows:

3.25 Unfavourable conditions of trim and list is trim of up to 10 degrees and list of up to 20 degrees either way; or alternatively, the worst combination of maximum list and trim angles for a ship in the intact or survivable damaged stability condition, taking into consideration a wind force associated with force 6 on the Beaufort scale and the final damaged waterline of the ship.

Existing references to 10 degrees trim/20 degrees list in SOLAS would be replaced by "unfavourable conditions of trim and list". As proposed, the amendment would not affect the design criteria for lifesaving appliances in the LSA Code--which would remain at 10/20--but only the criteria for installation of an approved system on board a particular ship. For the larger ships which would be most likely to employ the alternative criteria, the necessary stability information is generally available.

. . .

Regulation 6Communications

. . .

4 Onboard communications and alarm systems

. . .

PROPOSAL 2.1 (JAPAN)

4.3 A loud speaker or an electronic alarm transducer, e.g. a buzzer or similar, should be installed in cabins.

Reason: Purpose of LSA Code is stated in preamble, basically the Code to provide performance standard and construction requirement. Installation requirement should be stated in the regulation. Installation requirement of general alarm and public address stated in last sentence of LSA Code 7.2.1.2 should be moved to SOLAS chapter III Regulation 6.

4.34 On passenger ships the general emergency alarm system shall be audible on all open decks.

4.45 On ships fitted with a marine evacuation system communication between the embarkation station and the platform or the survival craft shall be ensured.

(Finland) Finland supports the suggestion made by Japan under proposal 2.1.

(USA) We agree the current division of requirements between the Code and Chapter III is a little awkward. We support the proposal 2.1 with some editorial refinements, and with the addition of moving the penultimate sentence of LSA Code 7.2.1.1 into regulation III/6 as follows:

7.2.1.1 . . . The general emergency alarm system shall be audible throughout all the accommodation and normal crew working spaces. The alarm shall continue to function

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after it has been triggered. . .

(III/6.)4.3 The general emergency alarm system shall be audible throughout all the accommodation and normal crew working spaces. On passenger ships, the general emergency alarm system shall also be audible on all open decks. In cabins without a loudspeaker installation, an electronic alarm transducer, e.g., a buzzer or similar, shall be installed.

(Norway) A minimum level of the sound should be stated.

(Coordinator) There appears to be general agreement with the proposal by Japan, perhaps with some editorial refinements.

With regard to the comment by Norway, the minimum sound levels for alarm systems and public address systems are specified in the LSA Code and associated IMO instruments.

. . .

Regulation 13Stowage of survival craft

1 Each survival craft shall be stowed:

.1 so that neither the survival craft nor its stowage arrangements will interfere with the operation of any other survival craft or rescue boat at any other launching station;

.2 as near the water surface as is safe and practicable and, in the case of a survival craft other than a liferaft intended for throw over board launching, in such a position that the survival craft in the embarkation position is not less than 2 m above the waterline with the ship in the fully loaded condition under unfavourable conditions of trim of up to 10° and listed up to 20° either way, or to the angle at which the ship's weather deck edge becomes submerged, whichever is less;

PROPOSAL 3.1 (NORWAY)

The term “weather deck” used in SOLAS regulation III/13.1.2 is not defined in SOLAS, only in the International Convention on Load Lines. This lack of clear definition in SOLAS related to stowage location of survival craft may result in different understanding and application of this term.

(Finland) Norway is absolutely right about that there is no definition for “weather deck” in the SOLAS Convention. Would it be possible just to have a reference to the Load Line Convention and not write it out again in chapter III?

(IACS) See IACS comments to proposal 1.1 (USA) above.

(USA) The term used in the Load Line Convention is “freeboard deck” rather than “weather deck”, and reference to the Load Line Convention would be complicated by some of the alternatives for identifying the freeboard deck allowed by that document. We suggest instead incorporating the basic definition from the Load Line Convention as follows:

.2 as near the water surface as is safe and practicable and, in the case of a survival craft other than a liferaft intended for throw over board launching, in such a position that the survival craft in the embarkation position is not less than 2 m above the waterline with the ship in the fully loaded condition under unfavourable conditions . . . or to the angle at which the ship's weather deck edge of the ship’s uppermost complete deck exposed to weather and sea becomes submerged, whichever is less;

. . .

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Regulation 16Survival craft launching and recovery arrangements

1 Unless expressly provided otherwise, launching and embarkation appliances complying with the requirements of paragraph 6.1 of the Code shall be provided for all survival craft except those which are:

. . .

.5 provided for use in conjunction with a marine evacuation system, complying with the requirements of paragraph 6.2 of the Code and stowed for launching directly from the stowed position under unfavourable conditions of trim of up to 10º and list of up to 20º either way.

. . .

6 Falls, where used, shall be long enough for the survival craft to reach the water with the ship in its lightest seagoing condition, under unfavourable conditions of trim of up to 10° and list of up to 20° either way.

. . .

10 If partially enclosed lifeboats complying with the requirements of paragraph 4.5 of the Code are carried, a davit span shall be provided, fitted with not less than two lifelines of sufficient length to reach the water with the ship in its lightest seagoing condition, under unfavourable conditions of trim of up to 10° and list of up 20° either way.

PROPOSAL 4.1 (NORWAY)

Another effect from the increased size of passenger ships is that the reference to “unfavourable conditions of trim of up to 10 ° and list of up to 20 ° either way” in SOLAS regulations III/16.1.5, 16.6 and 16.10, lead to significantly larger freeboard interval in which the different survival craft are intended to be launchable.

The intentions of SOLAS regulations III/16.6 and 16.10 are clear in the fact that they require increased length of falls or lifelines. However, considering the geometry of existing passenger ship designs it is alleged that the necessary length in order to comply may be unrealistic.

Regarding SOLAS regulation III/16.1.5 with respect to marine evacuation systems, it is experienced that it is particularly difficult to assess compliance. The current SOLAS text does not specify clearly whether the mentioned regulations apply only to the equipment as a component or system which is to be type approved, or to the functionality of the systems in the resulting geometrical conditions when installed on board a ship. Consequently it is not clear whether the marine evacuation systems are intended to be operable in the specified conditions of list and trim or if it is only required that the associated liferafts shall be possible to release from their stowage location in those conditions.

It is our understanding that clarifications or additional definitions with respect to the referenced regulations are needed in order to address the problems discussed above and achieve uniform application of the requirements in IMO instruments related to survival craft.

(USA) With regard to Norway’s comment in proposal 4.1, III/16.1.5 does not address MES performance at all, but is rather only one of the conditions under which liferafts need not be provided with launching appliances. We suggest that regulation 15 (Stowage of marine evacuation systems) is a more appropriate location for an MES requirement, as follows :

Regulation 15Stowage of marine evacuation systems

1 Each marine evacuation system shall be stowed in such a position that it remains usable under all unfavourable conditions of trim and list. The ship’s side shall not have any openings between the

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embarkation station of the marine evacuation system and the waterline in the lightest seagoing condition and means shall be provided to protect the system from any projections.

. . .

In addition, on the basis of some of the comments concerning our proposal 4.2, we suggest some further refinements to our proposed definition of unfavourable conditions of trim and list (below) as follows:

3.26 Unfavourable conditions of trim and list is trim of up to 10 degrees and list of up to 20 degrees either way; or alternatively, the worst combination of maximum list and trim angles for a ship in the intact or survivable damaged stability condition, taking into consideration a wind force and sea state associated with force 6 on the Beaufort scale and the final damaged waterline of the ship.

This would allow continued application of the current criterion, but would provide an alternative that could be used. The alternative method would most likely be applied to larger ships for which the stability and wind loading data are readily available, and where the 10 degree trim/20 degree list criterion reflects an unrealistic situation and results in excessive ranges of freeboard.

(Coordinator note – see related comment by China under LSA Code 6.2.2.1.5.)

PROPOSAL 4.2 (USA)

(ILAMA) ILAMA supports this proposal.

Norway points out two areas where we strongly agree that amendments to SOLAS and/or the LSA Code are needed:

1. Since marine evacuation systems are provided as an alternative to launching appliances, we need to ensure that the trim and list conditions applicable to launching appliances apply to MES as well. Although the intent is clear to us, and we have always interpreted the provision in SOLAS governing length of falls as applying to the length of MES as well, it appears that specific application of the list and trim requirements to MES was overlooked during preparation of the 1996 SOLAS amendments.

2. It is unrealistic, particularly for installations on very large ships, to require that installed LSA be sized to operate at 20 degrees list and 10 degrees trim, since these angles are substantially outside the ship's operating envelope in any realistic intact or survivable damaged stability condition. While we believe these angles should remain in the Code as a useful and conservative design parameter for equipment manufacturers, to ensure that approved equipment will be operable over a wide range of list and trim angles, sizing for a particular installation should be appropriate for that installation, taking into account the stability characteristics of the ship. A possible approach for SOLAS would be (using regulation III/16.6 as an illustrative example):

6 Falls, where used, shall be long enough for the survival craft to reach the water with the ship in its lightest seagoing condition, under unfavourable conditions of trim of up to 10° and list of up to 20° either way.

in combination with a proposed new definition of "unfavourable conditions of trim and list" in regulation III/3 as follows:

3.25 Unfavourable conditions of trim and list is the worst combination of maximum list and trim angles for a ship in the intact or survivable damaged stability condition, taking into consideration a wind and sea state associated with force 6 on the Beaufort scale and the final damaged waterline of the ship.

(ILAMA) This addition to the definitions of regulation 3 may cause impractical problems for the manufacturers. 20 degrees list – 10 degrees trim is a definition a manufacturer can work from. It is suggested to add the 20 degrees list – 10 degrees trim to the definition and add “whichever is the most unfavorable”. Not all ship designers will be able to provide damage conditions and associated sea states

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easily. Nor is sea state a condition defined for all seas. (see previous remarks)

(IACS) See IACS comments to proposal 1.1 (USA) above.

PROPOSAL 4.3 (FINLAND)

In Finland’s opinion the stowage of the survival craft; rescue boat; or marine evacuation system has to function in all respect to the functionality of the system in the “unfavorable conditions of trim of up to 10º and list of up to 20º either way.

(Finland) See Finland’s comments under Proposal 1.1.

(Japan) Japan does not support the proposal by USA.

Reason: Although we recognize a way of thinking may be right, but in practical situation, we cannot obtain fixed result of maximum list and trim angles for a ship in the intact or survivable damaged stability condition in most cases. And also we do not have a reasonable calculating method for a wind and sea state associated with force 6 on the Beaufort scale.

(Norway) Proposal 4.2 (USA) and 4.3 (Finland)In our opinion the approach proposed by USA with a new Reg. III/3.25 and removing the references to 10 and 20 degrees in Reg. III/16 is the best way to solve this issue. The proposal from Finland should not be supported.

(China) 1. In SOLAS III/16.1, it requires that in certain conditions, liferafts should be served by launching and recovery arrangements. This may cause some contradictions with the requirements in III/21.1 and in III/31.1 which also have or don't have requirements relating to liferaft launching and recovery arrangements.  To solve this problem, I suggest to delete the requirements for equipping liferaft launching and recovery arrangement either from III/16.1 or from III/21.1 and III/31.1. By doing this, we may also solve the problem that different equipping requirements for liferaft launching and recovery are required in same ship for liferafts within 100% and over 100%.

2. Some port state control officer requires that the rescue boat davit be equipped with a span and two lifelines. We should make it clear by correct SOLAS III/16.10 if necessary.

3. Some port state control officer requires that the surroundings of the liferaft equipped according to SOLAS III/31.1.4 be lighted. We should make it clear by correct SOLAS III/16.7.

(Coordinator) See comments under proposal 1.1. There appears to be substantial agreement, in principle, with the concept of allowing the worst-case trim and list conditions for a particular ship to be used as an alternative to the current static 10° trim/20° list criterion. The practical effect on regulation III/16 would be to replace references to "unfavourable conditions of trim of up to 10° and list of up to 20° either way" with "unfavourable conditions of trim and list", in conjunction with a suitable definition of the term.

Comments are specifically requested on the proposal for regulation III/15 to explicitly require MES to stowed so as to remain usable under unfavourable conditions of trim and list. Note that the LSA Code 6.2.2.1.5.2 already requires that slide-type MES remain at an operable angle at "the final stage of flooding set by the requirements in regulation II-1/8".

. . .Regulation 20

Operational readiness, maintenance and inspections

. . .

(Finland – new proposal)

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6 Weekly inspection

.2 all engines in lifeboats and rescue boats shall be run for a total period of not less than 3 min, provided the ambient temperature is above the minimum temperature required for starting and running the engine. During this period of time, it should be demonstrated that the gear box and gearbox train are engaging satisfactorily. If the special characteristics of an outboard motor fitted to a rescue boat would not allow it to be run other than with its propeller submerged for a period of 3 min, it should be run for such period as prescribed in the manufacturer's handbook or at least [1,5] min. In special cases the Administration may waive this requirement for ships constructed before 1 July1986;

(ILAMA): we understand that an outboard engine which not running 3 minutes under condition as prescribed in the manufacturer's handbook shall run only [1,5] minutes with propeller NOT submerged: if this understanding is correct, ILAMA does not agree to the change due to possible engine impeller damage as described in our comments to same subject in the LSA- code

. . .

8 Servicing of inflatable liferafts, inflatable lifejackets, marine evacuation systems, and inflated rescue boats

8.1 Every inflatable liferaft, inflatable lifejacket, and marine evacuation system shall be serviced:

.1 at intervals not exceeding 12 months, provided where in any case this isimpracticable,the Administration may extend this period to 17 months;

.2 at an approved servicing station which is competent to service them, maintains proper servicing facilities and uses only properly trained personnel.*********

PROPOSAL 5.1 (ILAMA)

With regard to inflatable lifejackets, ILAMA proposes a requirement (location unspecified) that “The approved service station shall issue a Certificate of Test and Inspection”, consistent with the requirements for inflatable liferafts.

PROPOSAL 5.2 (USA)

In our view such a document would be meaningless in the absence of established test and inspection procedures. We propose that an IMO instrument similar to Res. A.761(18) for inflatable liferafts be developed to address requirements for servicing of inflatable lifejackets and approval of servicing stations for them.

(Finland) In the heading of regulation 20 it is mentioned inflatable lifejackets; marine evacuation systems and inflated rescue boats, but in the text itself there is nothing saying about servicing intervals of inflatable rescue boats or semi rigid rescue boats. Finland supports the view of USA in Proposal 5.2 with the addition for inflatable - or semi rigid rescue boats, but at the same time we believe that the ILAMAS proposal in 5.1, it is a good idea to have the approved service station to issue a certificate for test and inspection for the inflatable lifejackets and inflatable- and semi rigid rescue boats.

(Republic of Korea) We agree with the proposal from ILAMA.Reason : The test and inspection of inflatable lifejackets are very simple rather than lifeboat and inflatable liferaft. Therefore we think it is not needed he qualified persons by the manufacturer for test and inspection. And we think also the “Certificate of Test and Inspection” issued by service station approved by Administration is enough.

********* Refer to the Recommendation on the Conditions for the Approval of Servicing Stations for Inflatable Liferafts adopted by the Organization by resolution A.761(18).

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Proposal 5.1 (ILAMA) and 5.2 (USA)We support the view of USA in this issue. Guidelines similar to testing and control of immersion suits (MSC circ 1047 and 1114) should be worked out.

. . .

11 Periodic servicing of launching appliances and on-load release gear

11.1 Launching appliances shall be:

.1 maintained in accordance with instructions for on-board maintenance as required by regulation 36;

.2 subject to a thorough examination at the annual surveys required by regulations I/7 or I/8, as applicable; and

PROPOSAL 6.1 (GERMANY and ILAMA)

.3 upon completion of the examination referred to in .2 subjected to a dynamic test of the winch brake at maximum lowering speed. The load to be applied shall be the mass of the lifeboat without persons on board, except that, at intervals not exceeding five years, the test shall be carried out with a proof load of equal to 1.1 times the maximum working load of the winch launching arrangement.

Reasons: for compliance with resolution MSC.81(70), paragraph 6.1.5 to prevent overload to launching system by use of possible higher working loads of winches

(ILAMA) ILAMA supports this proposal IF survival crafts are NOT allowed to be used for this test.REASON: boat is only tested for its own weight, but deck structure for davits are designed and tested for the SWL of the launching appliance. Safe Working Load of launching arrangement may be higher than actual boat weight. This may damage the boat.

PROPOSAL 6.2 (NETHERLANDS)

.3 upon completion of the examination referred to in .2 subjected to a dynamic test of the winch brake at maximum lowering speed. The load to be applied shall be the mass of the lifeboat without persons on board, except that, at intervals not exceeding five years, the test shall be carried out with a proof load of 1.1 times the maximum working load of the winch weight of the boat and full complement.

Reason: Instead of maximum working load of launching arrangement it is safer to use actual maximum working load, eg weight of boat and full complement. Sometimes heavier launching arrangement as necessary has been installed, which might result in overloading boat or deck structure.

(ILAMA) ILAMA supports this proposal IF survival crafts are allowed to be used for this test.REASON: to prevent overload to boat.

(Finland) Finland supports the Netherlands proposal in 6.2 with a small change.

.3 upon completion of the examination referred to in .2 subjected to a dynamic test of the winch brake at maximum lowering speed. The load to be applied shall be the mass of the lifeboat without persons on board, except that, at intervals not exceeding five years, the test shall be carried out with a proof load of equal to 1.1 times the maximum working load of the winch weight of the boat and full complement.

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(Japan) Japan fully supports the proposal 6.2 made by Netherlands.

PROPOSAL 6.3 (IACS)

With regard to the DE's CG on LSA terms of reference (item .4 of your first mailing), IACS agrees with the proposal contained in DE 48/5/2 (item 6.5) and DE 48/5/3 (item 4) to revise SOLAS reg. III/20.11.1.3, as amended by MSC.152(78). This would be based on the reasoning provided in the papers - the winch may be designed and certified for a higher maximum working load than the launching appliance it is dedicated to. Testing with a proof load of 1.1 times the maximum working load of the winch might overload the launching appliance and may cause serious damage.

In addition, we wish to seek clarification from the CG as to whether reg. III/20.11.1 applies to the launching appliances of just lifeboats only or to those for survival craft and rescue boats.

IACS applies the current reg. III/20.11.1 to the launching appliances of any survival craft or rescue boat required to be launched by an approved launching appliance. There is no limitation currently in the regulation to limit its application to just lifeboat launching appliances. However, MSC.152(78), introduced confusion by using the term "lifeboat" in sub-paragraph .3 instead of the leaving the text that referred to LSA Code paragraph 6.1.2.5.2.

If it is concluded that III/20.11.1 is applicable to both survival craft and rescue boat launching appliances, we would propose that the term "lifeboat" in III/20.11.1.3, as amended by MSC.152(78), be replaced with "survival craft or rescue boat".

(Finland) Finland fully support the suggestion made by IACS in Proposal 6.3.

(ILAMA) ILAMA supports this proposal.

(USA) We generally support a combination of the Netherlands and IACS proposals, as follows:

.3 upon completion of the examination referred to in .2 subjected to a dynamic test of the winch brake at maximum lowering speed. The load to be applied shall be the mass of the lifeboat survival craft or rescue boat without persons on board, except that, at intervals not exceeding five years, the test shall be carried out with a proof load of equal to 1.1 times the maximum working load of the winch weight of the survival craft or rescue boat and full complement.

(Coordinator) There appears to be general agreement, in principle, with the original proposal by Germany and ILAMA for some adjustments to the provision to reflect the weight of the actual craft served vs. the maximum safe working load of the appliance. Comments on the preferred specific wording are requested. An additional issue is whether the requirements for on-load release gear should be specified as applying to both lifeboats and rescue boats (since the default requirement for rescue boats remains the same as for lifeboats).

(ILAMA): 20.11 is not restricted to lifeboats, therefore the above US- change of lifeboat to survival craft or rescue boat is correct

PROPOSAL 7.1 (GERMANY)

11.2 Lifeboat on-load release gear shall be:(ILAMA): 20.11 is not restricted to lifeboats, therefore as above wording should be changed: lifeboat survival craft or rescue boat on-load release gear shall be:

.1 maintained in accordance with instructions for on-board maintenance as required by regulation 36;

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.2 subject to a thorough examination and operational test during the annual surveys required by regulations I/7 and I/8 by properly trained personnel familiar with the system. This examination and test shall be done after the annual winch brake test with the empty boat as under 20.11.1.3; and

Reason: to guarantee safe condition and function of the lifeboat AFTER the davit brake test, rules to be amended to execute an inspection of release gear and hook fastening AFTER the annual winch brake test with empty boat to detect any possible damages (not foreseen in current rules).

(USA) We believe the proposal has some merit, but is too detailed to include in SOLAS. If it is agreed to specify the procedure further, we suggest that MSC/Circ. 1093 (referenced by footnote to III/20.3.1) would be a more appropriate location.

.3 operationally tested under a load of 1.1 times the total mass of the lifeboat when loaded with its full complement of persons and equipment whenever the release gear is overhauled. Such over-hauling and test shall be carried out at least once every five years.*

(ILAMA – new proposal)

Release systems of free-fall lifeboats added to provide same safety and maintenance level as for davit- launched boats.REASON: Currently there is no common interpretation in the industry if free- fall boats have also to comply with this rule or not):

11.3 Lifeboat on-load release gear and free-fall lifeboat release systems shall be:(ILAMA): 20.11 is not restricted to lifeboats, therefore as above wording should be changed: lifeboat survival craft or rescue boat on-load release gear and free-fall lifeboat release systems shall be:

.1 maintained in accordance with instructions for on-board maintenance as required by regulation 36;

.2 subject to a thorough examination and operational test during the annual surveys required by regulations I/7 and I/8 by properly trained personnel familiar with the system.

.3 operationally tested under a load of 1.1 times the total mass of the lifeboat when loaded with its full complement of persons and equipment whenever the release gear is overhauled. Such over-hauling and test shall be carried out at least once every five years.*.

PROPOSAL 8.1 (JAPAN)

11.4 Davit-launched liferaft automatic release hook shall be:

.1 maintained in accordance with instructions for on-board maintenance as required by regulation 36;

.2 subject to a thorough examination and operational test during the annual surveys required by regulations I/7 and I/8 by properly trained personnel familiar with the system; and

.3 operationally tested (off-load operation) under a load of 1.1 times the total mass of the liferaft when loaded with its full complement of persons and equipment or equivalent weight whenever the automatic release hook is overhauled. Such over-hauling and test shall be carried out at least once every five years.*

Reason: An automatic release hook for davit launched liferaft should be maintained as same level as the lifeboat on-load/off-load release system. It is necessary to provide maintenance requirement for the hook in the regulation.

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(Finland) Finland fully support the new regulation suggested by Japan in Proposal 8.1.

(Republic of Korea) Basically, we do not agree with the idea.Reason : Especially, the over-hauling of the release gear is not desirable and may make the situation worse depending on the type of the release gear. However, if inclusion of the new requirement is agreed in the CG, the following three functions should be tested without over-hauling (LSA Code 6.1.5 referred) ;  - lowering test : to confirm prevention of premature release during lowering(test load: 1.1 times the total mass of the liferaft when loaded its full complement of persons and equipment or equivalent weight)- off-load release test (automatic): to confirm automatic release when waterborne(test load: no weight applied)-  on-load release test(manual): to confirm manual release when the raft is dragged on water surface(test load: 150 kg)

(ILAMA) Requirements are now drafted for life boat on-load release gear and life raft hooks. It is suggested to extend to off load hooks and hooks for rescue boats (not required to be on-load but in case of a tensioning system it is required to be an on-load hook too).

(IACS) We do not agree with this proposal. Especially, the over-hauling of the release gear is not desirable and may make the situation worse depending on the type of release gear. However, if inclusion of the new requirement is agreed by the CG, we propose that the following three functions should be tested without over-hauling (LSA Code 6.1.5 referred): - lowering test: to confirm prevention of premature release during lowering(test load: 1.1 times the total mass of the liferaft when loaded its full complement of persons and equipment or equivalent weight)- off-load release test(automatic): to confirm automatic release when waterborne(test load: no weight applied)- on-load release test(manual): to confirm manual release when the raft is dragged on water surface (test load: 150 kg).

(USA) We do not agree with the proposed amendment. While the proposal may have some merit, we need to keep in mind that the new requirements for examination and testing of on-load lifeboat release gear were added to address a history of problems with such gear resulting in lifeboat accidents. We are not aware of any similar history with liferaft automatic release hooks (probably because such hooks are not often used in drills). Addition of new requirements for liferaft automatic release hooks is not included in our terms of reference.

(Norway) Proposal 8.1 (Japan)We agree with the proposal but recommend to consider a reference to IMO Res. MSC.81(70), part 2, item 6.2.3 with respect to the testing proposed in Reg III/20.11.3.3.

(Coordinator) There are some differences of opinion on this issue. Members are invited to consider the comments that have been submitted with a view to establishing consensus on the appropriate course of action.

(ILAMA) Comments as requested by the coordinatorHooks for rafts are very complicated pieces of equipment.Reference is made to MSC.81(70) part 1 – paragraph 8.2.We cannot agree with the comment “the overhauling of release gear is not desirable and may make the situation worse depending on the type of release gear”.Although raft hooks have a better track record than on-load release gear manufacturers are frequently confronted with hooks causing an immediate danger to persons when being used.Overhauling or in some cases replacement of hooks is then required.In case hooks are used for multiple raft launching a non functioning hook may render a complete launching station useless.

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We therefore request to add to the Regulation 20 also a requirement for service and testing of Liferaft Automatic Release hooks as proposed by JAPAN.

We propose on overhaul to do following tests;- static overload test- actuating force- automatic release- non-accidental release- manual release- securing force

Although testing is extensive the information of these tests will prove the hooks to be fully functional.

Amendment of MSC/Circ. 1093 is therefore proposed. We propose to add the details of the maintenance and servicing procedures in the appendix of MSC/Circ. 1093 c/w the tests.Chapter III should make reference to the hook maintenance as proposed by Japan. A footnote will be required.

SECTION II - PASSENGER SHIPS(ADDITIONAL REQUIREMENTS)

Regulation 21Survival craft and rescue boats

(ILAMA – new proposal)

Include a adapted copy of 26.4 (Requirement for MOR- systems on RoRo- passenger ships into Reg. 31 or transfer 26.4 to a suitable place within Reg. 1 – 20).Reason: The ability to pick up survivors from the sea should not be restricted to RoRo ships but be applicable to ALL ships. Several published incidents for example to rescue survivors from damaged yachts- sometimes causing fatalities- show the need for such systems.

(Coordinator) Comments are invited on this proposal to require means of rescue for all passenger ships, however such a new carriage requirement does not appear to be within our terms of reference.

1 Survival craft

. . .

PROPOSAL 9.1 (FINLAND)

1.2 Passenger ships engaged on short international voyages and complying with the special standards of subdivision prescribed by regulation II-1/6.5 shall carry:

Reason: Paragraphs III/21.1.2 and III/21.1.3 concern the passenger ships engaged on short international voyages and they refer to regulation SOLAS II-1/6.5, which does no more exists in the new draft chapter II-1. Ships constructed in accordance with the subdivision standards in the new draft chapter II-1 may be considered to correspond to those meant in paragraph III/21.1.2.

. . .

1.3 Passenger ships engaged on short international voyages and not complying with the special

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standard of subdivision prescribed by regulation II-1/6.5, shall carry survival craft complying with the requirements of paragraph 1.1. The provisions of regulation II-1/6.2 shall be taken into account, when considering the number of survival craft in passenger ships.

Reason: As the ships comply with the subdivision standards of the new draft chapter II-1, the present text in paragraph III/21.1.3 may be deleted. Instead a new text may be inserted referring to the new regulation II-1/6.2 so as to give information that this regulation has an influence to the choice of survival craft.

PROPOSAL 9.2 (USA)

We do not support the proposed new III/21.1.3. The number and type of survival craft required is fixed by regulation III/21.1.2, and does not vary based on the subdivision index R. While the mix of survival craft actually carried forms an argument in the formula for the subdivision index, we do not agree that it is appropriate or intended to work the same formula backward to affect a change in the required mix of survival craft. III/21.1.3 should simply be deleted.

(IACS) Passenger ships engaged on short international voyages receive not only the benefit of III/21.1.2 but also of III/21.3.2 (marshalling of liferafts) when meets II-1/6.5. Therefore, the consideration given to III/21.1.2 in this regard should also be given to III/21.3.2 similarly.

(USA) We agree with IACS’ comment concerning III/21.3.2, and propose revision of that paragraph accordingly:

(III/21.)3.2 The number of lifeboats and rescue boats that are carried on passenger ships engaged on short international voyages and complying with the special standards of subdivision prescribed by regulation II-1/6.5 shall be sufficient to ensure that in providing for abandonment by the total number of persons on board not more than nine liferafts need be marshaled by each lifeboat or rescue boat.

(Coordinator) We have two different proposals, from Finland and the U.S. Comments are requested as to which is the appropriate direction to take.

. . .

PROPOSAL 10.1 (FINLAND)

2.3 A lifeboat rescue boat may be accepted as a rescue boat lifeboat provided it also complies with the requirements for a rescue boat lifeboat.

(Republic of Korea) We do not agree with this proposal.Reason : We not understand why they need to change the “lifeboat” to “rescue boat” and the “rescue boat” to “lifeboat”. The title of Reg.21.2 is “rescue boat” and not the “lifeboat”.

(ILAMA) Not supported, no real change.

(IACS) The need to change the "lifeboat" to "rescue boat" and the "rescue boat" to "lifeboat" is not understood. This regulation should remain as it is.

PROPOSAL 11.1 (ILAMA)

2.4 At least one of the rescue boats on a passenger ship shall be a fast rescue boat approved by the Administration having regard to the recommendations adopted by the Organization.

2.5 Each fast rescue boat shall be served by a suitable launching appliance approved by the Administration. When approving such launching appliances, the Administration shall take into account that the fast rescue boat is intended to be launched and retrieved even under severe adverse weather conditions, and also shall have regard to the recommendations adopted by the Organization.

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2.6 At least two crews of each fast rescue boat shall be trained and drilled regularly having regard to the Seafarers Training. Certification and Watchkeeping (STCW) Code and recommendations adopted by the Organization, including all aspects of rescue, handling, manoeuvring, operating these craft in various conditions, and righting them after capsize.

Reason: Compliance with the requirements for RoRo passenger ships: the risk for persons falling over board or other tasks for a fast rescue boat on passenger ships are at least identical or higher than on RoRo passenger ships. Requirements should therefore be at least identical.

(Finland) Finland supports the new subparagraphs suggested by ILAMA in regulation 21. (2.4, 2.5 and 2.6)

(Japan) Japan does not support the proposal to require fast rescue boat on passenger ships by ILAMA.

(Republic of Korea) We do not agree with these proposal.Reason : As we all know, many of the additional safety measures had been taken by IMO after the accidents of RO-RO passenger ships such as Herald of Enterprise, Estonia, etc. because of the special vulnerable features such as long bulkhead deck without transverse bulkhead, bow/stern door, etc which is not the case in normal passenger ships. In addition, the safety of (large) passenger ships are under review now in all aspects by the MSC and sub-committees. Therefore, introducing such new requirements for passenger ship is not desirable at this point.

(IACS) We do not agree with this proposal, at this time. Passenger ship safety is currently under review by MSC and its subcommittees, the results of which may affect LSA requirements for passenger ships Any amendments should be made in light of these results.

(USA) We do not support his proposal. First, our terms of reference do not include such extensive changes in ship carriage requirements. However, the premise itself is flawed in that the FRB requirement for Ro-Ro ships was introduced because Ro-Ros are more susceptible than conventional passenger ships to rapid flooding and capsizing/sinking. This means there is a higher probability that survival craft will not be successfully launched. Ro-Ros are generally ferries on fixed routes, which makes other Ro-Ros on the same route a prime rescue resource in the event that a Ro-Ro sinks or capsizes. The FRBs were required to enable other Ro-Ros to respond more effectively.

(Coordinator) There appears to be little agreement with the proposal by ILAMA.

PROPOSAL 12.1 (ILAMA)

3 Marshalling of liferafts

3.1 The number of lifeboats and rescue boats that are carried on passenger ships shall be sufficient to ensure that in providing for abandonment by the total number of persons on board not more than six liferafts need be marshalled by each lifeboat or rescue boat.

3.2 The number of lifeboats and rescue boats that are carried on passenger ships engaged on short international voyages and complying with the special standards of subdivision prescribed by regulation II-1/6.5 shall be sufficient to ensure that in providing for abandonment by the total number of persons on board not more than nine liferafts need be marshalled by each lifeboat or rescue boat.

Reason: Conflict with SOLAS III/3. 19 “Rescue boat is a boat designed to rescue persons in distress and to marshal survival craft”, and SOLAS III/3.23 “Survival craft is a craft capable of sustaining the lives of persons in distress from the time of abandoning the ship”, and LSA Code 4.4.6.8: “The speed of a lifeboat when proceeding ahead in calm water, when loaded with its full complement of persons and equipment and with all engine powered auxiliary equipment in operation, shall be at least 6 knots and at least 2 knots when towing a 25 person liferaft loaded with its full complement of persons and equipment or its equivalent.”

1. A lifeboat is a survival craft and therefore NOT designed to marshal survival craft. It should therefore NOT be included into the crafts able to tow liferafts.

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2. The lifeboat has engine power to pull a 25- person liferaft, however the raft on the passenger mother ship can have a capacity of up to 150 persons.

When having to maneuver under sea conditions to establish towing line connection, to tow the raft away from ship etc, ILAMA expects that conventional lifeboats will rarely be able to fulfill that duty for which they are not designed for. For such duty (fast) rescue boats should be used. Further have in mind that currently each life- or rescue boat shall marshal up to NINE liferafts (SOLAS III.31.3) which would only work one by one. Assuming 20 minutes for each tow, these are 3 additional hours after launching to tow all rafts away from ship. During this time the rafts are waiting beside the damaged ship without any possibility to leave the danger zone by own force. If the lifeboats fail to tow the rafts, this already long time might double or more.

(Republic of Korea) We cannot agree with these proposal.Reason : Furthermore, the proposal is in conflict with ILAMA's other proposal made with regard to LSA Code para. 4.4.6.8. If the lifeboat can have a capacity to tow the largest liferaft according to the proposal by ILAMA, there is no problem to marshal liferaft of up to 150 persons.

(Finland) Finland do NOT support the proposed amendments in regulation 21.3.

(IACS) IACS understands that a lifeboat is not designed for marshalling liferafts and that the proposed revision would lead to the fitting of additional rescue boats, is not clearly understandable. An alternative to the above proposal would require a corresponding improvement to the "towing capability of lifeboats and LSA Code para. 4.4.6.8 should be revised accordingly.

(USA) We do not support this proposal. We are not aware of any reason why a lifeboat cannot perform the marshalling function as it historically has. If adopted, the proposed change would require many ships to carry numerous rescue boats for the sole purpose of marshalling liferafts. If there is a concern about the ability of a lifeboat to tow larger liferafts, we should consider addressing that in the lifeboat requirements (4.4.6.8 of the Code).

(Coordinator) There appears to be no support for the proposal by ILAMA, however we may need to look at whether changes are needed to 4.4.6.8 of the LSA Code to address the identified issue.. . .

Regulation 31Survival craft and rescue boats

(ILAMA- new proposal)

Include a adapted copy of 26.4 (Requirement for MOR- systems on RoRo- passenger ships into Reg. 31 or transfer 26.4 to a suitable place within Reg. 1 – 20).Reason: The ability to pick up survivors from the sea should not be restricted to RoRo ships but be applicable to ALL ships. Several published incidents for example to rescue survivors from damaged yachts- sometimes causing fatalities- show the need for such systems.

(Coordinator) Comments are invited on this proposal to require means of rescue for all cargo ships, however such a new carriage requirement does not appear to be within our terms of reference.

. . .

PROPOSAL 13.1 (FINLAND)

2 Rescue boats

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Cargo ships shall carry at least one rescue boat complying with the requirements of paragraph 5.1 of the Code. A lifeboat except free-fall lifeboats may be accepted as a rescue boat, provided that it also complies with the requirements for a rescue boat.

Reason: It will be impractical to recover the free fall lifeboat in open sea condition without serious injury and accidents to the crew members. Some administrations accept that a free fall lifeboat can also be a rescue boat. By doing that they will increase the accidents with the lifeboats and rescue boats

(ILAMA) ILAMA supports this proposal.

(Finland) After a second thought Finland has come to the conclusion that the last sentence should be deleted.

(USA) We agree in principle, although we question whether such a change is necessary. We are not aware of any intention to use free-fall boats as rescue boats, and doubt that the secondary means of launching for a free-fall lifeboat could comply with the launching and recovery requirements for rescue boats (e.g., list and trim requirements) in any case.

Regulation 32Personal life-saving appliances(as amended by MSC.152(78))

. . .

(IACS – new proposal)

3 Immersion Suits

3.1 This paragraph applies to all cargo ships. However, with respect to cargo ships constructed before 1 July 2006, paragraphs 3.2 to 3.5 shall be complied with not later than the first safety equipment survey on or after 1 July 2006.

3.2 An immersion suit complying with the requirements of section 2.3 of the Code shall be provided for every person on board the ship. If the suit is not of universal size, designed to fit all personnel, suits of the appropriate size for each crewmembers are to be provided. However, for ships other than bulk carriers, as defined in regulation IX/1, these immersion suits need not be required if the ship is constantly engaged on voyages in warm climates** where, in the opinion of the Administration, immersion suits are unnecessary.

IACS Comment: IACS proposes the above addition to reg. III/32.3.2 and, additionally, requests clarification on the sizes of the additional immersion suits, required by 3.3 below, considering that the additional suits could be used by different crewmembers of various stature.

3.3 If a ship has any watch or work stations which are located remotely from the place or places where immersion suits are normally stowed, additional immersion suits shall be provided at these locations for the number of persons normally on watch or working at those locations at any time.

(Coordinator) Would wording similar to regulation III/7.2.3 (e.g., "An immersion suit complying with the requirements of section 2.3 of the Code, of an appropriate size, shall be provided…") adequately address the issue?

IACS Comment: Amended reg. III/32.3.3, which enters into force on 1 July 2006, indicates that, "If a ship has any watch or work stations which are located remotely from the place or places where immersion suits are normally stowed, additional immersion suits shall be provided at these locations for the number of persons normally on watch or working at those locations at any time." During discussions within IACS on how this regulation should be applied, it was generally agreed that additional immersion suits are to be provided at the same locations where the additional lifejackets are positioned to meet SOLAS reg.

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III/7.2.1.2, but the need of providing additional immersion suits at forward and/or aft liferaft (remote) location(s) was questioned.

In fact, it was noted that the wording of reg. III/32.3.3 is different from that of reg. III/7.2.1.2. While III/32.3.3 uses the wording, "any watch or work stations which are located remotely from the place or places where immersion suits are normally stowed", reg. III/7.2.1.2 refers to additional lifejackets to be carried for "persons on watch and for use at remotely located survival craft stations". It is also required that the lifejackets carried for persons on watch should be stowed at the locations specifically mentioned in reg. III/7.2.1.2 (i.e., the bridge, the ECR and any other manned watch station).

With the view of facilitating uniform implementation, IACS requests that clarification of the remote location and the additional amount of immersion suits as per reg. III/32.3.3 be developed.

Additionally, IACS also requests clarification on the size(s) of the additional immersion suits, considering that potential users may be of different sizes (as these suits are not assigned to an individual crew member), as there may be situations where a suit could not be worn.

3.4 Immersion suits shall be so placed as to be readily accessible and their position shall be plainly indicated.

3.5 The immersion suits required by this regulation may be used to comply with the requirements of regulation 7.3.

** Refer to the Guidelines for assessment of thermal protection (MSC/Circ.1046).

. . .

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