INTERNATIONAL ASSOCIATION OF DRILLING CONTRACTORS

Transcription

1 INTERNATIONAL ASSOCIATION OF DRILLING CONTRACTORS MEMORANDUM TO: FROM: Distribution Alan Spackman, Vice President, Offshore Technical and Regulatory Affairs SUBJECT: Report on the 56 th session of the IMO Sub-Committee on Ship Design and Equipment DATE: 19 March 2012 The 56 th session of IMO s Sub-Committee on Ship Design and Equipment (DE 56) was held from 13 to 17 February 2012 under the chairmanship of Mrs. Anneliese Jost (Germany). The session was attended by representatives of 65 member countries, two associate members, two inter-governmental organizations and 32 non-governmental organizations. IADC was represented at this session by Alan Spackman and John Pertgen (IADC) and Roderick Allan (Transocean). Tom Horan (Rowan) and Warren Weaver (Transocean) also attended as advisors to the Marshall Islands and Vanuatu, respectively. The following is a summary of issues addressed by the Sub-Committee that may interest of companies with offshore oil and gas operations: Approval of draft instruments and guidance The Sub-Committee approved the following draft instruments and draft guidance documents for action by the parent Committee(s) as indicated: Title / Subject Draft amendments to SOLAS chapter III on rescuing persons from the sea. Draft MSC resolution on Implementation of SOLAS regulation III/17-1 to ships other than those engaged in international voyages Draft Guidelines for development of plans and procedures for recovery of persons from water Draft MSC circular on Early implementation of the amendments to SOLAS regulation III/ (operational testing of free-fall lifeboat release systems). Draft MSC circular on Unified Interpretation to paragraph of the LSA Code concerning lifeboat exterior colour. Draft Code on noise levels on board ships. Draft new SOLAS regulation II-1/3-12 on Protection against noise. Draft MSC circular on Unified interpretation of SOLAS regulation II-1/3-2 (dedicated seawater ballast tanks). Draft MSC circular on Unified interpretation of SOLAS regulation II-1/48.3 (controls of emergency bilge suction valve in periodically unattended machinery spaces). Draft MSC circular on Unified interpretation of SOLAS regulations II-1/29.3 and 29.4 (steering gear tests). Next step(s) Approval at Maritime Safety Committee s 90 th session (MSC 90) with a view to adoption. Approval by MSC in conjunction with the above SOLAS amendment. Approval by MSC in conjunction with the above SOLAS amendment. Approval by MSC 90 in conjunction with the adoption of previously approved amendments to SOLAS regulation III/ Approval in principle by MSC 90, with a view to adoption in conjunction with the adoption of the associated SOLAS amendments (below). Approval by MSC 90 with a view to adoption.

2 Page 2 Title / Subject Draft MSC circular on Unified interpretation of SOLAS regulation II-1/3-5 (prohibition of new installation of materials which contain asbestos). Draft amendments to the Performance standard for protective coatings for cargo oil tanks of crude oil tankers (resolution MSC.288(87)). Next step(s) Approval by MSC 90 in conjunction with the adoption of previously approved amendments to SOLAS regulation XI-1/2. Amendments to SOLAS regulation III Recovery arrangements for rescuing persons from the sea and associated performance standards The Sub-Committee considered the draft SOLAS regulation on plans and procedures for recovery of persons from water and, having discussed whether the aforementioned regulation should be incorporated into SOLAS chapter III or V (where it would have significantly broader applicability) agreed to include it in SOLAS chapter III. It was noted that that this approach would require further deliberations on provisions of recovery of persons from water where LSA provisions are contained in other instruments applicable to certain types of ship (e.g., HSC Code, DSC Code, MODU Code and SPS Code). Having decided to incorporate the regulation into SOLAS chapter III, the Sub-Committee, recognizing that ships coming to rescue persons from water are not limited to those on international voyages, agreed to the draft MSC resolution on Implementation of SOLAS regulation III/17-1 to ships other than those engaged in international voyages. The Sub-Committee also agreed to the draft Guidelines for development of plans and procedures for recovery of persons from water, which are referenced in the draft SOLAS amendment. These guidelines are to be read in conjunction with the Guide to Recovery Techniques (MSC.1/Circ.1182) and the Guide for Cold Water Survival [(MSC.1/Circ.1185) or the new Guide expected to be finalized at the 16 th session of the Sub-Committee on Radiocommunications and Search and Rescue (COMSAR 16, for submission to MSC 91 for approval. Amendments to SOLAS regulation II-1/40.2 General requirements on electrical installations MSC 86 accepted a proposal by Denmark and The Faroes to develop amendments to SOLAS regulation II-1/40.2 concerning general requirements on electrical installations, and agreed to include this as a work item for the Sub-Committee. In considering a further proposal by Denmark and The Faroes, many delegations, acknowledging that the issue arose from a fire on a fishing vessel not covered by SOLAS requirements, raised various concerns with regard to the proposed SOLAS amendment: e.g., the relationship to SOLAS regulation II- 1/3-1, requiring that ships shall be designed, constructed and maintained in compliance with, inter alia, the electrical requirements of a classification society; regarding SOLAS regulations I/6 to 8 addressing surveys; the difficulty for the Administration to ensure that electrical equipment is suitable for use on board ships and is approved and maintained; and whether there was a compelling need to amend SOLAS regulations based on the investigation into an accident on a non-solas vessel. Nonetheless, the proposal to address the issue of electrical installations on ships being fit for purpose was generally supported, and it was recognized there was a need to further consider the matter taking into account the concerns raised, in particular the scope of application of the proposed amendments (new/existing ships), their location in the SOLAS Convention and maintenance issues. The Sub- Committee also noted that consequential amendments to the Harmonized System on Survey and Certification (HSSC) Guidelines may be necessary to address the problem, acknowledging the possibility that such amendments might be sufficient, without the need for amendments to SOLAS. The matter will be further considered at DE 57. Making the Measures to prevent accident with lifeboats (MSC.1/Circ.1206/Rev.1) mandatory The Sub-Committee noted there was substantive support for making some parts of the provisions of MSC.1/Circ.1206/Rev.1 and MSC.1/Circ.1277 mandatory. At the same time, many delegations expressed continued concerns since it was their experience that worldwide coverage of LSA service providers is not sufficient in some regions and varies considerably depending on ship types.

3 Page 3 The Sub-Committee agreed, in principle, to the development of a new non-mandatory circular containing those issues of MSC.1/Circ.1206/Rev.1 and MSC.1/Circ.1277 that are of recommendatory nature. The Sub-Committee agreed, in principle, to the first draft of a new mandatory instrument amalgamating MSC.1/Circ.1206/Rev.1 and MSC.1/Circ.1277 on requirements for periodic servicing and maintenance of lifeboats, launching appliances and on-load release gear. To continue work on this issue, the Sub-Committee established an LSA Correspondence Group, under the coordination of Japan 1, and instructed it to further develop the draft MSC resolution on Requirements for periodic servicing and maintenance of lifeboats, launching appliances and on-load release gear based on MSC.1/Circ.1206/Rev.1 and MSC.1/Circ.1277, and prepare associated draft amendments to SOLAS chapter III to make the MSC resolution mandatory, taking into account the: Possible conflict of mandating requirements that are not mandatory in SOLAS or the LSA Code (e.g. installation testing); Possible overlap in SOLAS chapter III; Relaxation for servicing of lifeboats in locations where no suitable service provider is available; Mandatory character of the draft text which should be reflected in the appropriate use of the IMO terminology; and those areas that could remain non-mandatory and that are to be included in the revised circular. Guidelines for evaluation and replacement of lifeboat release and retrieval systems (MSC.1/Circ.1392) The Sub-Committee considered a proposal by the International Life-saving Appliance Manufacturers Association (ILAMA), to amend MSC.1/Circ.1392, concerning release test, load test and towing test, since ILAMA members had experienced that the portions of the Guidelines were causing practical problems constituting potential hazards. Recognizing that the Guidelines had already been implemented and that further amendments at this stage would cause confusion with regard to their implementation, the Sub-Committee agreed to the following regarding paragraph 24.1 of the Guidelines and invited MSC 90 to endorse the above view: During the 1.1 x load and simultaneous release test according to the Revised recommendation on testing of life-saving appliances (resolution MSC.81(70)), part 2, paragraph 5.3.1, or an equivalent method acceptable to the Administration, it should be ensured that not only the hook assembly but also the fixed structural connections of the release mechanism of the lifeboat will be subjected to the test load. Public availability of the results of the evaluation of existing lifeboat release and retrieval systems The Sub-Committee agreed that viewing the results of evaluations of existing lifeboat release and retrieval systems, as contained in the new IMO Global Integrated Shipping Information System (GISIS) module, should be open to the public and invited the Committee to endorse this decision. Development of a new framework of requirements for life-saving appliances (LSA) The Sub-Committee considered and agreed to the following road map for the development of a new framework of requirements for ships' life-saving appliances: Timeline Action Outcome 2012 DE 56 Sub-Committee endorsement for further work on draft goal based guidelines on framework of requirements for ships' LSA as a base document Correspondence Group Review draft goal based guidelines 2012 MSC 90 Notify other interested/involved Sub-Committees Working Group Report with draft goal based guidelines Report with draft for the goal based guidelines 1 Dr. S. Ota (ohta@nmri.go.jp)

4 Page 4 Timeline Action Outcome 2013 DE 57 Finalize the draft goal based guidelines taking into account the human element in accordance with MSC MEPC.7/Circs.1, 2 and 4. Draft MSC circular for goal-based guidelines MSC 92 Commence work on comprehensive review of requirements for LSA, if considered appropriate, taking into account FMEA. Consider matters on lifeboat safety, taking into account the instructions from MSC and proposals submitted to the Organization. Approval of draft MSC circular for goal based guidelines. MSC circular for goal based guidelines 2014 DE 58 Continuation of the comprehensive review. Draft amendments to SOLAS chapter III including safety objectives and functional requirements in the style of SOLAS chapter II-2. Draft LSA Code amendments 2015 DE 59 Finalization of the comprehensive review and draft amendments to SOLAS chapter III and LSA Code. Final draft SOLAS chapter III amendments. MSC 95 Approval of amendments MSC96 Adoption of amendments. Final draft LSA Code amendments Entry into force. The LSA Correspondence Group was instructed to: Further develop the draft Goal-based guidelines on framework of requirements for ships' lifesaving appliances taking into account the human element in accordance with MSC- MEPC.7/Circs.1, 2, and 4 and the road map. Identify matters in the draft that relate to the work of other IMO bodies and advise the Sub- Committee accordingly. Evaluation of thermal performance of immersion suits The LSA Correspondence Group was instructed to: Consider the methodology for ensuring consistent outcomes of thermal testing using manikins instead of human test subjects and, if necessary, the appropriate application and specification of immersion suit Reference Test Devices (RTDs). Prepare relevant draft amendments to the LSA Code and the Revised recommendation on testing of life-saving appliances (MSC.81(70)). Development of a mandatory Code for Ships Operating in Polar Waters (Polar Code) The Sub-Committee: Agreed to urge the Marine Environment Protection Committee (MEPC) and the MSC to prioritize the discussion on how to make the Polar Code mandatory at their forthcoming meetings. Reaffirmed its decision that non-solas ships (e.g., fishing vessels) would be considered later. Noted concerns that the functional requirements of the Code should be flexible and that navigation in ice should not be limited by coastal States.

5 Page 5 Referred the various chapters of the draft Code to the Sub-Committees on Radiocommunications and Search and Rescue (COMSAR), Fire Protection (FP 56), Safety of Navigation (NAV), Stability and Load Lines and on Fishing Vessels' Safety (SLF), and Subcommittee on. Standards of Training & Watchkeeping (STW) together with relevant explanatory comments, requesting them to consider the parts of the Code under their respective remits and advise DE 57 of the outcome of their consideration. Endorsed the view that the Sub-Committee should not take decisions under the purview of established conventions without due scrutiny in accordance with those conventions. (The Sub- Committee has been placed in the awkward position of being asked to develop mandatory text on matters that it is not clear will ultimately be supported by the parent Committees.) Approved a working plan (including timeline) for overall development of the Code and referral of specific issues of environmental concern to MEPC or other Sub-Committees for their consideration. It was agreed to re-establish a correspondence group, coordinated by Norway 2, to further develop the draft International Code of safety for ships operating in polar waters (Polar Code) on the basis of the decisions made at the session regarding the Code and the decisions of other Sub-Committees. Draft amendments to the Code on Noise Levels on Board Ships Having given preliminary consideration to the report of the Correspondence Group established at the last session, the Sub-Committee agreed: On whether the minimum acceptable engine load, notwithstanding the normal service speed, should be set at 80 per cent MCR (maximum continuous rating) or 75 per cent MCR, agreed on 80 per cent MCR. In principle to the following text regarding ships equipped with dynamic positioning systems. In case of vessels with Dynamical Positioning (DP), which is intended for use in normal working condition, additional noise measurements at DP mode should be made at control stations, duty stations and accommodation areas to ensure that the maximum noise level limits in these spaces are not exceeded. The Administration, Class, Shipyard and DP designers shall agree on a process to simulate the operation of the DP thruster system under conditions which would approximate station-holding at or above 40% of maximum environmental conditions that the vessel has been designed to operate in. To use the symbols developed by ISO for warning notices. Re-confirmed its decision that the Code should apply to new ships of 1,600 gross tonnage and upwards. With regard to establishing limits on exposure of seafarers to high noise levels, agreed to keep them non-mandatory, taking into account the majority view that they were of an operational nature and difficult to implement as mandatory requirements. To make the onboard verification mandatory. To include mandatory provisions regarding provision of hearing protectors. That the Code should be made mandatory through a new SOLAS regulation II-1/3-12 on Protection against noise. The Sub-Committee agreed to a draft new SOLAS regulation II-1/3-12 on Protection against noise, and a draft Code on noise levels on board ships which will go to MSC 90 for approval with a view to their adoption by MSC 91. At this stage, neither the regulation or guidance apply to MODUs. Offshore wind farm construction vessels and service craft The majority of the delegations, while acknowledging the fast growth of the wind farm industry as one of the sources of renewable energy, were of the view that there was no need for the development of a separate Code for wind farm vessels and supported to further clarify the application of existing IMO instruments (e.g., the 2009 MODU Code and the 2008 SPS Code) to Offshore wind farm construction vessels (OWFCV) and Offshore wind farm service craft (OWFSC), in order to avoid the development of a multitude of different codes for different ship types with duplicating requirements. 2 Ms. Turid Stemre (tbs@sdir.no)

6 Page 6 With respect to the transport of industrial personnel by sea, which is not specifically covered in any IMO instrument, many delegations supported the need to further clarify relevant categories of personnel, e.g. passengers, seafarers, special personnel or other categories, in terms of applying relevant requirements, as well as competencies and training requirements. In this context, some delegations pointed out that the categorization used in the ILO Maritime Labour Convention may be referred to when considering this issue. The Sub-Committee agreed that there is an urgent need to further consider the application of existing IMO instruments to OWFCV and OWFSC, including a gap analysis, and to further clarify the application of relevant requirements concerning industrial personnel transported by sea. Means of access for inspections Having considered IACS UI SC 191, the Sub-Committee asked the Secretariat to prepare a draft MSC circular on Unified interpretation of SOLAS chapters II-1 and XII, and to the Technical provisions for means of access for inspections (resolution MSC.158(78)), amalgamating and consolidating MSC.1/Circ.1176 and MSC.1/Circ.1197, as a single document, including illustrations, for consideration at DE 57. Performance standard for protective coatings Having considered IACS UI SC 223, the Sub-Committee asked the Secretariat to prepare a draft MSC circular on Unified interpretation of the PSPC, amending and replacing MSC.1/Circ.1378, for consideration at DE 57. Greatest launching height for a free-fall lifeboat The Sub-Committee considered IACS UI SC 248 on the greatest launching height for a free-fall lifeboat (LSA Code, section 1.1.4, as amended by resolution MSC.218(82)), relating to SOLAS regulation III/3.13. Noting some concerns (e.g., greatest launching height of a free-fall lifeboat is not necessary relevant to the lightest seagoing condition; that this UI may necessitate amendments to SOLAS regulation III/3), invited the submission of comments and proposals to DE 57 regarding how to proceed with the matter. Testing arrangements for watertight bulkheads The Sub-Committee considered the concrete text for proposed amendments to SOLAS regulation II- 1/11, i.e., addition of a new paragraph 5 which refers to Guidelines for procedures for testing tanks and tight boundaries, along with the draft text of such Guidelines. Also considered were several submissions commenting on the proposed texts. The Sub-Committee agreed that the matter needed further consideration. It also generally agreed to the need to require shipyards to implement appropriate quality management systems, such as ISO 9001 or equivalent, in order to ensure an appropriate safety level. Revision of the Guidelines on Implementation of effluent standards and performance tests for sewage treatment plants The Sub-Committee agreed, in principle, to a draft MEPC resolution on 2012 Guidelines on Implementation of Effluent Standards and Performance Tests for Sewage Treatment Plants. It further agreed that the draft 2012 Guidelines should be applied from 1 January These new standards will only affect passenger ships operating in Special Areas established under MARPOL Annex VI. It was noted that there were still unresolved issues associated with the draft Guidelines, including the total nitrogen and phosphorous removal standards, and the concerns expressed by a number of delegations on the importance of applying a dilution compensation factor, agreed that further work on the Guidelines was needed. The matter will be further considered at DE 57. Development of requirements for onboard lifting appliances and winches MSC 89 agreed to develop SOLAS requirements and associated guidelines for the construction and installation of onboard lifting appliances and winches, and assigned DE as the coordinator. The Sub- Committee considered proposals from Norway (containing proposals addressing towing, anchor handling

7 Page 7 and stern lifting winches) and Japan (generally providing information to be used in future discussions). The matter will be further considered at DE 57. Noise from commercial shipping and its adverse impacts on marine life The Sub-Committee considered information provided by the United States on the issue of noise from commercial shipping and its adverse impact on marine life and offering recommendations and a framework concerning the development of non-mandatory, technical guidelines to minimize underwater noise, in particular identifying four specific high-focus areas that should be assessed for potential underwater noise reduction, i.e., propulsion, hull design, onboard machinery and operational modifications. ISO reported that ISO/TC8/SC2 was currently developing ISO "Measurement and reporting of underwater sound radiated from merchant ships." The standard is currently scheduled for the second half of It was agreed to re-establish a correspondence group, coordinated by the United States 3, to continue to examine available options for ship-quieting technologies and operational practices and develop nonmandatory draft guidelines for reducing underwater noise from commercial ships. Work program The proposed planned outputs for the Sub-Committee include the following: Description Number Parent Coordinating Involved Target Consideration of IACS unified interpretations MSC MEPC Ongoing Development of amendments to the 2011 ESP Code MSC DE Ongoing Review of the provisions for helicopters in SOLAS and the MODU Code Performance standard for protective coatings for void spaces on all types of ships Revision of the Standard specification for shipboard incinerators (resolution MEPC.76(40)) Development of amendments to SOLAS regulation II-1/40.2 concerning general requirements on electrical installations Development of requirements for onboard lifting appliances and winches MSC DE 2 sessions MSC DE 2 sessions MEPC DE MSC DE MSC DE 2014 Making the provisions of MSC.1/Circ.1206/Rev.1 mandatory MSC DE FSI, NAV, STW 2013 Development of a new framework of requirements for life-saving appliances Development of safety objectives and functional requirements of the Guidelines on alternative design and arrangements for SOLAS chapters II-1 and III Development of amendments to the LSA Code for thermal performance of immersion suits MSC DE MSC DE MSC DE Mr. Wayne Lundy (Wayne.M.Lundy@uscg.mil)

8 Page 8 Description Number Parent Coordinating Involved Target Development of amendments to the LSA Code for free-fall lifeboats with float-free capabilities MSC DE 2013 Mandatory instruments: Development of a mandatory Code for ships operating in polar waters MSC MEPC DE 2013 Classification of offshore industry vessels and consideration of the need for a non-mandatory Code for offshore construction support vessels MSC DE 2013 Development of guidelines for use of fibre reinforced plastic (FRP) within ship structures MSC DE FP 2 sessions Revision of the Recommendation on conditions for the approval of servicing stations for inflatable liferafts (resolution A.761(18)) Amendments to SOLAS regulation II-1/11 and development of associated Guidelines to ensure the adequacy of testing arrangements for watertight compartments Provision for the reduction of noise from commercial shipping and its adverse impacts on marine life MSC DE MSC DE MEPC DE 2013 Arrangements for the next session DE 57 is tentatively scheduled to be held from 18 to 22 March It was agreed that working groups would be established for: Development of a new framework of requirements for life-saving appliances; making the provisions of MSC.1/Circ.1206/Rev.1 mandatory; and Development of safety objectives and functional requirements of the Guidelines on alternative design and arrangements for SOLAS chapters II-1 and III;; Development of a mandatory Polar Code for ships operating in polar waters; Provisions for the reduction of noise from commercial shipping and its adverse impacts on marine life; Revision of the Standard specification for shipboard incinerators (resolution MEPC.76(40)); Development of amendments to the LSA Code for thermal performance of immersion suits; Revision of testing requirements for lifejacket RTDs; and Revision of the Recommendation on conditions for the approval of servicing stations for inflatable liferafts (resolution A.761(18)); Amendments to SOLAS regulation II-1/11 and development of associated Guidelines to ensure the adequacy of testing arrangements for watertight compartments; and Development of amendments to SOLAS regulation II-1/40.2 concerning general requirements on electrical installations. Elections The Sub-Committee unanimously re-elected Mrs. Anneliese Jost (Germany) as Chairman and Dr. Susumu Ota (Japan) as Vice-Chairman for The IMO report of this session is will be made available on the IADC website at: Please feel free to contact me by phone (+1 / ) or (alan.spackman@iadc.org) with any questions you may have regarding this summary report.