Lloyd's Register on the 53 rd session of IMO Sub- Committee on Ship Design and Equipment

Transcription

1 IMO DE 53 Report Lloyd's Register on the 53 rd session of IMO Sub- Committee on Ship Design and Equipment 9th March, 2010 Hot topics: Standards for corrosion resistant steel and epoxy coatings in cargo oil tanks agreed Guidelines to help prevent accidents with lifeboats agreed Work starts on mandatory Polar Waters Code IWS agreed for passenger ships other than ro-ro passenger ships

2 Lloyd's Register, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as the Lloyd's Register Group. The Lloyd's Register Group assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd's Register Group entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract. Lloyd s Register 2010 External Affairs 09/03/10 2 of 22

3 Contents Introduction 5 Agenda Item 2 - Decisions of other IMO bodies 5 Agenda Item 3 - Measures to prevent accidents with lifeboats 5 Agenda Item 4 - Compatibility of life-saving appliances 7 Agenda Item 5 - Revision of resolution A.760 (18) 8 Agenda Item 6 - Performance standards for recovery systems 9 Agenda Item 7 - Cargo oil tank coating and corrosion protection 9 Agenda Item 8 - Development of a new framework of requirements for lifesaving appliances 10 Agenda Item 9 - Guidance to ensure consistent policy for determining the need for watertight doors to remain open during navigation 11 Agenda Item 10 - Protection against noise on board ships 11 Agenda Item 11 - Thermal performance of immersion suits 12 Agenda Item 12 - Alternative arrangements for the bottom inspection requirements for passenger ships other than ro-ro passenger ships 12 Agenda Item 13 - Amendments to the Revised recommendation on testing of life-saving appliances 13 Agenda Item 14 - Safety provisions applicable to tenders operating from passenger ships 13 Agenda Item 15 - Classification of offshore industry vessels and consideration of the need for a code for offshore construction support vessels 14 Agenda Item 16 - Interpretation on application of SOLAS, MARPOL and Load Line requirements for major conversions of oil tankers 14 Agenda Item 17 - Consideration of IACS unified interpretations 15 External Affairs 09/03/10 3 of 22

4 Agenda Item 18 - Development of a mandatory Code for ships operating in polar waters 15 Agenda Item 19 - Application of amendments to SOLAS chapter III and the LSA Code 16 Agenda Item 20 - Guidelines for a visible element to general alarm systems on passenger ships 17 Agenda Item 21 - Improvement of existing pollution prevention equipment 17.1 Development of test standards for type approval of add-on equipment 17.2 Promotion of integrated bilge water treatment systems 17 Agenda Item 22 - Development of guidelines for a shipboard oil waster pollution prevention plan 18 Agenda Item 23 - Manually operated alternatives in the event of pollution prevention equipment malfunctions 18 Agenda Item 25 - Any other business 19 Date of the next session of the Sub-Committee 20 Summary of the decision (list of the finalized instruments) 20 External Affairs 09/03/10 4 of 22

5 Introduction The 53 rd session of the IMO Sub-Committee on Ship Design and Equipment was held from the 22 nd to 26 th February, 2010 in London, the United Kingdom. The outcome relevant to the work of Lloyd's Register is summarised below. Due attention is to be made to Implication and Application given under each item. Agenda Item 2 - Decisions of other IMO bodies Background: The Sub-Committee was informed of relevant decisions made and action taken by MSC 86 (DE 53/2); MEPC 59 (DE 53/2/1); and FSI 17, NAV 55, DSC 14, STW 41 and SLF 52 (DE 53/2/2) and took action, as appropriate, under the relevant agenda items. Implications: None, as substantial discussion will take place under respective agenda item. Application: N/A Agenda Item 3 - Measures to prevent accidents with lifeboats In 1986 on-load release hooks for lifeboats and rescue boats were made mandatory by SOLAS in response to the Norway s worst offshore accident in March Since 1986 when the IMO requirements for all new ships to be fitted with on-load release systems came into place, there have been a number of serious accidents during drills and servicing where the on-load hook apparently failed. At DE 52, the Sub-Committee developed the following amendments which have been subsequently approved by the Committee: - Draft amendments to the LSA Code paragraph (approved at MSC 86 for adoption at MSC 87) The Sub-Committee considered new criteria for safer lifeboat on-load release hooks, and agreed that existing hooks with poor and unstable design are to be replaced, but existing hooks which are of a safe design/have a good safety record may continue in service. - Draft amendments to the SOLAS Regulation III/1 (approved at MSC 86 for adoption at MSC 87) Draft amendments to SOLAS III/1 will require the lifeboat on-load release mechanisms of all ships to be replaced if they are assessed and identified as being of a poor and unstable design (as described above). These draft amendments will be submitted to MSC 86 for approval and subsequent adoption. - Draft MSC Circular on Guidelines for the fitting and use of fall prevention devices (subsequently approved by MSC 86 as MSC.1/Circ 1327) As this is an interim measure, until the launching mechanism (hook) is re-assessed and replaced, if necessary, the type approval of FPD is not required. Although the type approval of FPD is not mandatory, it is expected that FPD will satisfy the design criteria as specified in the circular and may be issued by a company acceptable to an Administration. The circular also specified the requirement for inspection and testing. - Authorization of independent service providers to lifeboats - amendments to MSC.1/Circ.1206 (Subsequently approved as MSC.1/Circ Rev.1 by MSC.86) External Affairs 09/03/10 5 of 22

6 A draft MSC Circular was prepared to update MSC Circ taking into account various developments since the approval of the circular. On load release mechanisms At this session the Sub-Committee established a working group to further progress the development of guidelines for the evaluation and replacement of lifeboat on-load release mechanisms referred to in SOLAS regulation III/1.5. There was extensive discussion about the use of an onboard hook stability test, with opinion divided about what the test will prove and whether it should be carried out before or after the servicing. There was also extensive discussion about proposals on reporting the results of the design review and the physical test. Under the proposals all existing on-load release hooks will require re-examination against the new requirements. This review should take into account anticipated wear of critical parts over the service life of the release mechanism. An MSC Circular was agreed with some reservations. Delegations who had comments on the draft text were encouraged to submit them to MSC 87 where the text would be further considered. Draft MSC Circular: Guidelines for evaluation and replacement of lifeboat on-load release mechanisms referred to in SOLAS regulation III/1.5 These guidelines provide further guidance to member governments when applying SOLAS regulation III/1.5. Testing of life saving appliances The working group also finalised amendments to the revised recommendation on testing of life-saving appliances (Resolution MSC.81(70)), as amended, and a draft MSC Resolution was prepared for submission to MSC 87 for adoption. Draft MSC Resolution: Amendments to the revised recommendation of testing of lifesaving appliances (Resolution MSC.81(70)), as amended These amendments provide prototype tests for the release mechanism for life-saving appliances. Implications: - Shipbuilders & boat manufacturers: The result of this discussion will affect design launching appliances of lifeboat. - Shipowners and managers: The result of this discussion will affect maintenance and inspection of launching arrangements of lifeboat. The result may trigger replacement of existing launching appliances, e.g., hooks. - Flag Administration and its RO: New survey and type approval instructions would be required. Training of surveyors will become very important to ensure consistent application. Overall, implementation of these initiatives will require significant resources. Application: All new and existing life boat launching arrangements used for ships subject to SOLAS Chapter III (ships engaged on international voyages - no-tonnage External Affairs 09/03/10 6 of 22

7 limitation for passenger ships and 500 tons or over for ships other than passenger ships). Unfavourable conditions of trim and list The Sub-Committee decided that no agreement was going to be reached on the issue of defining unfavourable conditions of trim and list and the matter would no longer be discussed. Use of FMEA The use of FMEA to assess on-load release hooks was briefly discussed and referred for further discussion under agenda item 8 Development of a new framework of requirements for life-saving appliances. Mandating all or part of MSC.1/Circ. 1206/Rev.1 Discussion in plenary on making all or parts of MSC.1/Circ. 1206/Rev.1 mandatory centred on the availability of approved service suppliers, particularly in remote parts of the world. The issue was further discussed in the working group who further identified insufficient compliance with MSC.1/Circ.1277 by manufacturers, including insufficient support of independent service providers, as another obstacle to making the circular mandatory. Delegations were encouraged to submit further information on service providers and any experience they have in applying the circular to the next session of DE. Counterfeit products The issue of counterfeit products, often provided with counterfeit certificates and markings were agreed to be a problem. Counterfeit goods would not necessarily meet the required level of safety and could be dangerous. However, the pursuit of criminal matters has to remain the responsibility of the various administrations. The problem would be raised with the MSC for further action. Lifeboat control arrangements Further progress was not possible on the guidelines for the standardization of lifeboat control arrangements. Agenda Item 4 - Compatibility of life-saving appliances The Sub-Committee considered the following issues under this agenda item: Guidance on the application of the new liferaft weight criteria agreed at DE 52 to passenger ship liferaft launching appliances When immersions suits should be worn Practical matters regarding the change of the weight of personnel in the design of liferafts The exterior colour of lifeboats Change in terminology in SOLAS. Application of the new liferaft weight criteria agreed at DE 52 to passenger ship liferaft launching appliances The Sub-Committee discussed the impact that the change in mass of crew members would have on launching appliances and agreed a draft MSC Circular on the subject for submission to MSC 88. External Affairs 09/03/10 7 of 22

8 Draft MSC Circular: Determination of the required safe working load of liferaft launching appliances on passenger ships The sub-committee agreed that even though the assumed mass of crew members in liferafts should be increased to 82.5 kg, the assumed mass of persons for the launching appliances would remain at 75 kg. Implications: This will have a minimal effect design and type approval of the lifesaving appliances. Application: To liferaft launching appliances required by SOLAS Chapter III & LSA Code (used onboard all passenger ships engaged on international voyages and cargo ships of 500 gt or more engaged on international voyages). Immersions suits A proposal to clarify when an immersion suit should be worn when abandoning ship was not supported. Practical matters regarding the change of the weight of personnel in the design of liferafts The proposal concerning the practical matter regarding the change of the weight of personnel in the design of liferafts was discussed under agenda item 19 Application of amendments to SOALS chapter III and the LSA Code. The exterior colour of lifeboats The discussion of the paper on the exterior colour of lifeboats was held with other related papers under agenda item 17 Consideration of IACS unified interpretations. Change in terminology in SOLAS The issues of the change in terminology used in SOLAS regulation III/6.2.2 to include AIS-SART which has not been reflected in the LSA Code, and that there is currently no upper limit on the size of liferafts were decided to be new work program items and the necessary paperwork needed to be submitted to MSC. Agenda Item 5 - Revision of resolution A.760 (18) The Sub-Committee continued its consideration of the revision of symbols related to life-saving appliances and arrangements (resolution A.760(18)). It was noted that the work on ISO would be in three parts which would be ready for publication later this year and in 2011: Part 1, covering design standards, e.g. numbering, arrows etc. will be ready to publish in the summer of Part 2, which will be a catalogue of standard signs would be ready to publish in 2011 Part 3, a code of practice covering installation requirements, would be complete in early The sub-committee agreed to take no further action and to postpone discussions on the changes to resolution A.760(18) until DE 55 (2011) Implications: Once the A. 760 (18) - Symbols Related to Life-Saving Appliances and Arrangements have been revised, it will affect signs posted onboard. External Affairs 09/03/10 8 of 22

9 Application: To all SOLAS Ships as a non-mandatory standard (but in general, a ship is expected to use these signs) Agenda Item 6 - Performance standards for recovery systems After much discussion in plenary about the need for mandatory requirements or recommendatory guidelines which could be the basis for later mandatory requirements following experience of using guidelines, the Sub-Committee tasked the working group established under agenda item 3 to prepare the final text of the draft amendments to SOLAS III/17-1 and the related performance standard concerning recovery systems. Due to time constraints this was not done and the matter was deferred to a later session of the Sub-Committee. Implications: Manufacturers will need to develop such a system meeting the requirement Builders will need to install and to adjust onboard arrangements for the new standard Shipowners & Managers will need to install new equipment and to train seafarers as appropriate Flag Administrations and their ROs (Classification Societies) will need to provide necessary instructions to surveyors for type approval and survey of the system. Application: To life saving appliances (recovery system) required by SOLAS Chapter III (passenger ship regardless of tonnage engaged on international voyages and cargo ships of 500 gt or above engaged on international voyages) Agenda Item 7 - Cargo oil tank coating and corrosion protection The Sub-Committee established a working group to finalize the draft amendments to SOLAS regulation II-1/3-11 Performance standard for protective coatings for cargo oil tanks of crude oil tankers and the Performance standard for alternative means of corrosion protection for cargo oil tanks of crude oil tankers. This was completed by the working group who also prepared two draft MSC resolutions for submission to MSC 87. The matter of guidelines on procedures for in-service maintenance and repair of coating systems for cargo oil tanks of crude oil tankers was not progressed as no draft text was available. Interested delegates were encouraged to submit proposed text to DE 55. A correspondence group will be established to develop guidelines for the performance standard for protective coatings for cargo oil tanks of crude oil tankers to report back to DE 55. Draft MSC Resolution: Performance standard for protective coatings for cargo oil tanks of crude oil tankers The performance standard contains requirements for the following items: Area of application Design of the coating system Primary and secondary surface preparation Inspection and verification requirements External Affairs 09/03/10 9 of 22

10 Test procedures for coating systems Alternative coating systems can also be considered under this standard. Details of text procedures are included in the standard. Draft MSC Resolution: Performance standard for alternative means of corrosion protection for cargo oil tanks of crude oil tankers This standard currently only contains requirements for corrosion resistant steel. As alternative means of corrosion protection (other than protective coatings covered in the above standard) are developed additional annexes may be written and added to this standard. The current annex includes requirements for the testing of corrosion resistance steel. Implications: Paint manufacturers will need to submit paint testing results, and may need to develop a new product to meet the requirement. Shipbuilders For shipyards which have already built to the WBT PSPC the increased levels of inspection and record keeping will be the only real effect of the COT PSPC. This will be reflected in an increase in the coating costs. In any case, there will be a need to review fabrication processes and make some modification to the design of some parts of cargo tanks in order to allow coatings in a most efficient manner. Shipowners and Managers the introduction of the COT PSPC will give them additional confidence in the coating system and it's application, but will inevitably result in an increase in coating costs. They will be required to look at maintenance aspect of the coating throughout ship s life. Flag Administration and its ROs will need to develop training, guidelines and instructions for surveyors. The introduction of the COT PSPC will increase the amount of information in the vessel Coating Technical File and require a slight increase in surveyor attendance. Compared to the change to all parties that was caused by the implementation of the Ballast water tank PSPC, the change introduced by these requirements for the Cargo oil tank PSPC will be much less for the ship builders, however substantial increase on the work will be envisaged. Application: To new crude oil tankers of 5,000 DWT (date for the application to be finalized at MSC 87) Agenda Item 8 - Development of a new framework of requirements for life-saving appliances The Sub-Committee was advised that the review of the requirements for life-saving appliances in SOLAS chapter III and the LSA Code through a systematic approach, developing a comprehensive framework for requirements for LSA and a procedure for the review and subsequent relocation of present requirements in SOLAS was ongoing and it was hoped that a document would be available for DE 54. Implications: At this stage, the outcome of the discussion is not visible yet. However, there may be impact on the design of life saving appliances and launching appliances. Application: To be developed. External Affairs 09/03/10 10 of 22

11 Agenda Item 9 - Guidance to ensure consistent policy for determining the need for watertight doors to remain open during navigation The Sub-Committee continued its work on the development of guidance for Administrations to ensure a consistent policy for determining the need for watertight doors to remain open during navigation, based on the report of the Correspondence Group (DE 53/9) and taking into account the SLF Sub-Committee s work on guidance on the impact of open watertight doors on existing and new ship survivability (DE 53/9/1). The Sub-Committee was advised that the SLF Sub-Committee had finalised their deliberations on the topic and had agreed that a single circular should be developed containing both Sub-Committee s work. To this end the SLF Sub-Committee was expecting to send stability experts to DE 54 to discuss the issue. After discussions in plenary over the two different approaches taken by the respective Sub-Committees it was agreed that further substantial discussion would be undertaken at DE 54. Delegations were encouraged to submit their comments on the draft documents (from DE and SLF) with proposals for alternative text where necessary. Implications: The guidelines will affect the consideration of leaving watertight doors open and may affect passenger ship design if the current approach is deemed to be unsatisfactory. Application: Currently watertight doors are only permitted to be left open on passenger ships. These guidelines will only be applicable to passenger ships. Agenda Item 10 - Protection against noise on board ships The Sub-Committee commenced work on the agenda item, taking into account the proposals made in document MSC 83/25/13. Currently, the discussion is limited to noise only, not vibration. There was much discussion in plenary about the need for making any limit mandatory and what the limit should be. It was pointed out that different sized ships would have different noise levels and that smaller ships in particular may have difficulty in complying with a standard. The issue of whether the requirements would apply to existing ships as well as new ships was also raised, and there was some discussion on that aspect as well. Concerns were also raised about the practicalities of measurement given that noise levels change, sometime significantly, depending on the weather and load condition of the ship. The Sub-Committee agreed that a review of A.468(12) Code on noise levels on board ships, should be undertaken and that a decision on mandating the revised code would be taken once the work on the revision was complete. Implications: At present, the implication is not certain, but there may be impact on ship design and equipment. Possible application to existing ship, if any, would require careful consideration on the actual implementation. External Affairs 09/03/10 11 of 22

12 Application: To be developed but limited to SOLAS ship only at this stage, i.e., MODU, High Speed Craft etc are not included. Agenda Item 11 - Thermal performance of immersion suits The Sub-Committee commenced consideration on testing of life-saving appliances relevant to the evaluation of the thermal performance of immersion suits. In particular the methods currently used to evaluate the thermal performance of immersion suits depends on the human tester s resistance to cold. This can lead to inconsistent evaluation. The current proposals were considered to have health risks associated with them and revised proposals will be presented at the next session of DE. Delegates were encouraged to submit their comments on other matters addressed in the submissions to DE 54. Implications: Specification and type approval standards of immersion suits. Application: Immersion suits required by SOLAS Chapter III. Agenda Item 12 - Alternative arrangements for the bottom inspection requirements for passenger ships other than ro-ro passenger ships The Sub-Committee continued its work on the item, taking into account the outcome of the related work of the FSI Sub-Committee on amendments to the Survey Guidelines under the HSSC (resolution A.997(25)) (DE 53/12), and established a working group to progress the matter. The working group were asked to develop text based on the UK submission (DE 53/12/1) and those matters on which plenary agreed from the US submission (DE 53/12/2). It was not to discuss the matters about which there was no agreement in plenary in the US submission the issue of in water removal of sea-inlet valves and of the clarity of water before the IWS is permitted to take place. In later discussions in plenary text concerning water clarity was agreed. The draft MSC Circular was agreed and will be submitted to MSC 87 for approval. It will also be sent to the FSI Sub-Committee (FSI 18) so that they may take any actions considered necessary in the context of the work on the review of the survey guidelines under the Harmonized System of Survey and Certification (HSSC) as appropriate. Draft MSC Circular: Guidelines for the assessment of technical provisions for the performance of an in-water survey in lieu of one bottom inspection in dry-dock to permit one dry-dock examination in any five year period Guidelines for the holding of an in water survey in place of one of the two required drydockings in five years have been developed. Implications: Survey scheme as well as ship arrangements for ships choosing in water bottom survey in lieu of dry docking may need to meet the technical requirements under development. External Affairs 09/03/10 12 of 22

13 Application: Passenger ships, of 15 years of age or less, other than ro-ro passenger ships to which in water survey will be applied, in lieu of dry docking. Agenda Item 13 - Amendments to the Revised recommendation on testing of life-saving appliances The Sub-Committee commenced the consideration of amendments to the Revised recommendation on testing of life-saving appliances, as amended by resolutions MSC.200(80) and MSC.226(82), in order to rectify inconsistencies. Although the majority of the changes proposed in DE 53/13 were agreed, concerns were raised over: point 1 the reference to the ISO standard point 8 whether the smoke is blown or drawn point 9 the swamp test requirements It was agreed that the secretariat would prepare a new document for formal discussion at the next session of the Sub-Committee. Implications: Manufacturers will be required to meet the new test procedures, however, such new procedure will be simple reflection of the amendments made to SOLAS and LSA Code. The majority of changes proposed are editorial and will not have significant impact on current practice. Application: To life Saving Appliances required by SOLAS and LSA Code. Agenda Item 14 - Safety provisions applicable to tenders operating from passenger ships The Sub-Committee commenced work on the development of provisions for the design, equipment and operation of tenders carrying passengers and crew from passenger ships to shore and established a drafting group to progress the matter. For number of years it has become a common practice for passenger ships to use their tenders to transfer passengers and crew from the ship to shore where there are no berthing facilities for the ship; however there are no internationally agreed and available standards that address operational procedures, performance standards, safety provisions and manning requirements (including training) for those boats when used as tenders. Boats which take passengers on coastal trips are not covered by this work, they will be covered by the appropriate National Administrations requirements for passenger ships. Equally inflatable boats would not be considered as tenders for this work. Draft guidelines covering the following areas were prepared: Construction and equipment Operational guidance It was recognised that other Sub-Committees would need to consider the guidelines and the secretariat was requested to ensure that the necessary actions were taken to ensure that the guidelines were considered at the earliest opportunity. External Affairs 09/03/10 13 of 22

14 The DE Sub-Committee will further consider the issue at a future session. Implications: Flag Administrations / Recognised Organisations: Approval, survey and certification of tenders will need to be done to a consistent standard. Manufacturers and builders will need to ensure that tenders are built to comply with the guidelines. Application: Tenders onboard passenger ships, but only those which transport passengers from the ship to the shore where shore facilities are not available. Agenda Item 15 - Classification of offshore industry vessels and consideration of the need for a code for offshore construction support vessels The Sub-Committee investigated the need for clarification of the classification of vessels in the offshore industry. Currently there is confusion in the industry and inconsistency between flags as to which requirements were applicable. Preliminary investigations have been done to identify problems with using the 2008 SPS Code and to identify differences in the stability (intact and damage), LSA, and Personnel requirements in the various applicable codes (2008 SPS, OSV, SOLAS, 2008 IS Code, MODU Code). There was no support in the Sub-Committee for the development of a new code. It was considered that some interpretation of the 2008 SPS Code was required and IACS was requested to do work on this matter. Implications: When developed the IACS interpretations will clarify matters in the 2008 SPS Code which are currently unclear. Application: The unified interpretations will be applied by IACS members to ships where compliance with the 2008 SPS Code is requested by the Flag Administration. Agenda Item 16 - Interpretation on application of SOLAS, MARPOL and Load Line requirements for major conversions of oil tankers The Sub-Committee commenced work on the development of an interpretation of the extent of the application of the SOLAS, MARPOL and Load Line Conventions to major conversions of oil tankers. A drafting group was established to draft an appropriate circular based on the submitted documents and discussions in plenary. Further discussion is required on this issue and this is planned to take place at the 54 th session of this Sub-Committee in October Delegations who had comments on the draft document were encouraged to submit them in writing. Implications: The uniform interpretations, if that is agreed by IMO, will assist uniform application of the requirements at conversions of ships. Currently, such decisions are left to the individual Flag Administrations. Ship owners, designers and builder are invited to note the interpretations once the MSC-MEPC Circular is approved. Application: Single hull oil tankers undergoing conversion to double hull oil tankers or bulk carriers/ore carriers. External Affairs 09/03/10 14 of 22

15 Agenda Item 17 - Consideration of IACS unified interpretations The Sub-Committee considered IACS unified interpretations submitted to the session with a view to developing relevant IMO interpretations, as appropriate. Exterior colour of lifeboats A substantial discussion took place regarding the exterior colour of lifeboat (DE 53/17, DE 53/17/3 and DE 53/4/3). It was agreed that the wording of paragraph of the LSA Code as proposed to be amended by resolution MSC.207(81) would be amended in accordance with the proposed text in document DE 53/4/3 and an appropriate amendment for submission to MSC 88 was prepared. This removed the need for the IACS unified interpretation. Implications: The use of white or grey will not be permitted or accepted as suitable colours on those parts of life saving appliances which are used to aid detection at sea. This may affect design (aesthetics) of lifeboats and other life saving appliances used onboard passenger ships. Applications: Life saving appliances required by SOLAS Chapter III. IACS Unified Interpretation on steam boilers and boiler feed systems (SOLAS regulation II-1/32.4) There was some discussion of this Unified Interpretation, with some delegations supporting it and some thinking that it was not acceptable. The Sub-Committee noted the interpretation but took no further action. Application of the Performance Standard for Protective Coatings (PSPC) for dedicated seawater ballast tanks in all types of ships and double-side skin spaces of bulk carriers resolution MSC.215(82) Assistant inspector A revision of IACS Unified Interpretation (UI) SC 223, which took into account the comments made regarding this UI during DE 52 had been submitted for the Sub- Committee s deliberation. After some discussion in plenary over potential conflicts of interest the Sub-Committee agreed that the text could be used as the basis of an IMO interpretation. A draft MSC Circular was prepared and agreed for submission to MSC 88. Load testing of hooks for primary release of free-fall lifeboats There was some clarification needed about the draft IACS Unified Interpretation on the load testing of hooks for primary release of free-fall lifeboats. The Unified Interpretation is only applicable to lifeboats launched by falls, not to those launched from ramps. It was agreed that a revised Unified Interpretation would be submitted to a future session of DE. Agenda Item 18 - Development of a mandatory Code for ships operating in polar waters The Sub-Committee discussed the development of a mandatory Code for ships operating in polar waters. After extensive discussion in plenary the following was agreed: The work was very important and timely. All submitted papers were supported and needed to be further considered. External Affairs 09/03/10 15 of 22

16 A correspondence group under the guidance of Norway would be established to report back to DE 54. It was anticipated that a working group would be established at DE 54 to further progress the work. A two part code with mandatory requirements in one part and recommendatory requirements in the other should be developed, the format of the ISPS Code was suggested as being a good format. The code should contain risk based functional requirements supported by prescriptive solutions where applicable. The code should have text which was relevant to both polar areas with specific area requirements as considered necessary. A decision on how to make it mandatory would be taken once a draft code was available. In the discussion there were a variety of opinions about which ships should be covered by the new code just convention ships (cargo ships greater than 500 GT and all passenger ships, but not fishing vessels or government ships) or all ships, including fishing vessels. It was clarified that ships which do not operate in polar waters would not need to comply with the code. The sensitivity of polar regions to environmental damage was noted, and relevant documents have been submitted to MEPC (MEPC 60/21/1). Implications: Although the current voluntary code (MSC/Circ.1056-MEPC/Circ.399. further updated by A.1025 (26)) has been widely implemented, this mandatory code will have further implication to concerned parties. Owners and builders will need to meet the new mandatory requirements, the degree of the change is yet to be determined. Flag Administration: will need to consider new approval, survey and certification scheme. Application: To be decided in the course of the discussion. Agenda Item 19 - Application of amendments to SOLAS chapter III and the LSA Code The Sub-Committee considered the scope of application of amendments to SOLAS chapter III and the LSA Code. The IACS paper DE 53/19/2 was welcomed and was to be used as a basis document to resolve the issue as a "quick fix". The need for a longer term fix was discussed and a number of different options were proposed. The Chairman of DE decided that the matter needed to be referred to MSC as it was not a subject which was limited to those items dealt with by the DE sub-committee. The problems with using "newly installed" was raised by some delegations, particularly when LSA equipment was circulated round a fleet as items were taken out for servicing. Unfortunately there was no resolution on this aspect. Implications: To be decided. However, there is a possibility that DE come up with clarifications/interpretations that will result wider scope of the application (e.g., application to existing ships), which was not envisaged at the time of the adoption of the resolutions in question. External Affairs 09/03/10 16 of 22

17 Application: To ships to which SOLAS chapter III and LSA code applies. (Passenger ships regardless of tonnage and non-passenger ships of 500 gt or over both engaged in international voyages) Agenda Item 20 - Guidelines for a visible element to general alarm systems on passenger ships The Sub-Committee commenced work on the development of non-mandatory guidelines regarding a visible element to the general emergency alarm on passenger ships to accommodate passengers who have hearing difficulties. During the discussions in plenary it was stated that the same base document had been used for both the submitted papers, only different versions had been used. It was agreed that further work would be done intersessionally by interested delegations and a single revised document would be submitted to the next session of DE (25-29 October 2010). Implications: As a non-mandatory guideline, the implication is not predictable at this stage. However, it could be industry/international standard. If that is the case, this will significantly affect design/installation of passenger ships. Application: To passenger ships on voluntary basis. Agenda Item 21 - Improvement of existing pollution prevention equipment.1 Development of test standards for type approval of add-on equipment.2 Promotion of integrated bilge water treatment systems The Sub-Committee continued, as instructed by MEPC 59, considering simplified test procedures for add-on equipment capable of breaking up emulsions that could supplement existing resolution MEPC.60(33)-compliant equipment; and the promotion of Integrated Bilge Water Treatment System (IBTS) as a holistic approach to address the perceived illegal oil discharges related to engine-room management, taking into account the relevant discussions at DE 52. Under sub-item 1 of this agenda item various system attributes had been identified as being necessary in any standard. Two approaches to testing could be considered and used as appropriate: 1. Add-on equipment is tested in conjunction with specific existing equipment and can then only be used with that equipment 2. Add-on equipment is tested in isolation and can then be used with any other equipment. Under sub-item 2 of this agenda item the need to treat bilge water first was identified. External Affairs 09/03/10 17 of 22

18 After discussion in plenary it was agreed that a correspondence group should be established to further progress the work intersessionally. This correspondence group would also consider matters raised under agenda items 22 and 23 as well. Implications: Equipment manufacturers may be required to producing a new add-on equipment meeting IMO guidelines, once such guideline is developed. Shipowner will need to consider the use of such add-on equipment and IBTS, which may affect training/management of the crew onboard. Flag Administration and its RO will need to consider survey and type approval instruction once the discussion is concluded. Application: To be developed once the discussions are concluded. Agenda Item 22 - Development of guidelines for a shipboard oily waste pollution prevention plan MEPC 59 had instructed the Sub-Committee to develop guidelines for a shipboard oil waste pollution prevention plan. It was agreed that work on this should be progressed intersessionally and a correspondence group was established (to consider matters under agenda items 21 and 23 as well as this one). Implications: Shipowners will need to revise and obtain approval of the ODMC manual. Flag Administrations and ROs will need to secure resources for timely implementation of the requirements. Application: To ODMC Manual onboard (required to oil tankers of 150 gt and above). Agenda Item 23 - Manually operated alternatives in the event of pollution prevention equipment malfunctions According to regulation 31 of Annex I there is a possibility of manual operation in case of equipment failure. The Committee considered the concern expressed by a member regarding manuals for this operation. MEPC 59 agreed to instruct DE Sub-Committee to consider this matter further, taking into account practical implementation related issues, such as: - an appropriate time frame for implementation, e.g., the first IOPP survey carried out on or after 6 months after the adoption date of any resolution/circular; - how such a revision should affect many ODME Manuals, e.g., to delete that provision if it is contained in the approved ODME Manual As instructed by MEPC 59, the Sub-Committee considered the development of appropriate amendments to the Revised Guidelines and specifications for oil discharge monitoring and control systems for oil tankers (resolution MEPC.108(49)). The was some discussion on the issue of the practicalities of the proposals. It was decided to request the correspondence group established to deal with agenda items 21 and 22 to discuss this issue as well. External Affairs 09/03/10 18 of 22

19 Implications: It is not clear at this stage however, the following implications are envisaged: Owners will need to revise the instructions as to the operation the Oil discharge monitoring and control system (ODME manual) as per required by MARPOL Annex I regulation 31 and have them approved by the flag Administration or by its RO. Flag Administration and its RO: will need to provide instructions to surveyors and secure resources for the approval job, as the conclusion may result in re-approval of all existing manuals onboard the ship. Application: To ships which are required to have an approved ODME manual onboard (Oil tankers of 150 gt and above) as per MARPOL Annex I regulation 31. Agenda Item 25 - Any other business As instructed by MSC 86, the Sub-Committee considered: 1. the development of a definition of new installation of materials (DE 53/25); 2. the investigation report on the fire on the fishing factory vessel Hercules (DE 53/25/1); 3. amendments to the 2008 SPS Code (MSC 86/26, paragraph 25.10, and MSC 86/25/2); and 4. the location of knives in liferafts (DE 53/INF.2). 1. Discussion in plenary on the definition of new installation of materials concluded that the definition proposed in paper DE 53/25 could be added as a footnote in SOLAS. Concerns were raised that some materials were being declared to be asbestos free which, when tested, were found to contain asbestos. The secretariat were requested to prepare a circular for submission to MSC 88 and the necessary footnote for SOLAS. 2. There was some discussion on the proposed review of IEC It was noted that the standard was extensive and a review of it would be a major undertaking with potentially significant impact on the industry. It was concluded that a circular to raise awareness of the need to install appropriately rated equipment when replacing items would be acceptable. A proposal to make MSC Circ.1120 Unified interpretations of SOLAS Chapter II-2, the FSS Code, the FTP Code and related fire test procedures (2 June 2004) applicable to ships built before 2004 was supported. The secretariat was requested to inform the FSI Sub-Committee accordingly. 3. The proposed changes to the 2008 SPS Code were agreed and will be sent to MSC 87 for adoption. 4. The issues raised about the location of knives in liferafts, which are provided so that the retaining painter may be cut, were discussed and noted. Implications: 1. definition of new installation of materials. This is an interpretation of the revised SOLAS regulation II-1/3-5 (MSC. 282 (86)) entering into force on 1 January Under the proposed definition, builders and owners will not be allowed to use spare parts containing asbestos and kept in their stores after the entry into force date. 2. circular MSC Circ.1120 currently applies to all equipment which is installed on board ships on or after 1 July It is assumed that the proposal to make it applicable will mean confirming application of the interpretations to existing External Affairs 09/03/10 19 of 22

20 installations and requiring amendment where necessary. This may involve a lot of reworking of existing installations. 3. amendments to the 2008 SPS Code. Although the majority of the changes are editorial the proposed change to Chapter 5.1 will require compliance with SOLAS II-1, Part E, regulation 46. Currently this is excluded. Application: 1. Ships which have to comply with SOLAS (cargo ships greater than 500 GT engaged on international voyages and all passenger ships). 2. All ships which have to comply with SOLAS chapter II-2 (cargo ships greater than 500 GT engaged on international voyages and all passenger ships). Fire safety systems which have to comply with the FSS Code and products which have to comply with the FTP Code. 3. The 2008 SPS Code is non-mandatory and is applicable to ships of not less than 500 GT which carry 12 or more special personnel. Correspondence groups established and date of the next session of the Sub-Committee The following correspondence groups were established at DE 53 and will report back to DE 54: CG1 Pollution prevention (agenda items 21, 22 and 23 of this session of DE) CG2 Mandatory polar waters code (agenda item 18 of this session of DE) The following correspondence group will be established at DE 54 and will report back to DE 55: CG3 Coatings (agenda item 7 of this session of DE) The next session of the sub-committee will be held from 25 th to 29 th October Summary of the decision (list of the finalized instruments) Among items introduced in this report, considerations on the following items were completed at DE 53. These texts will be forwarded to MSC 87 or MSC 88 for appropriate actions. Draft MSC Resolutions Title Amendments to the revised recommendation of testing of life-saving appliances (Resolution MSC.81(70)), as amended Performance standard for protective coatings for cargo oil tanks of crude oil tankers Performance standard for alternative means of corrosion protection for cargo oil tanks of crude oil tankers Adoption of amendments to the code of safety for special propose ships, 2008 (2008 SPS Code) Approval Effective date MSC 87 MSC 87 MSC 87 MSC 87 Ref. (Section) Agenda item 3 Agenda item 7 Agenda item 7 Agenda item 25 External Affairs 09/03/10 20 of 22

21 Draft MSC Circulars Title Guideline for evaluation and replacement of lifeboat on-load release mechanisms referred to in SOLAS regulation III/1.5 Determination of the required safe working load of liferaft launching appliances on passenger ships. Guidelines for the assessment of technical provisions for the performance of an in-water survey in lieu of one bottom inspection in dry-dock to permit one dry-dock examination in any five year period Unified interpretations of the performance standard for protective coatings (PSPC) for dedicated seawater ballast tanks in all types of ships and double-side skin spaces of bulk carriers adopted Approval Effective date MSC 87 MSC 88 MSC 87 MSC 88 To be determined by Resolution MSC.215(82) Unified Interpretation of SOLAS regulation II-1/3-5 MSC 88 1 January 2011 Ref. (Section) Agenda item 3 Agenda item 4 Agenda item 12 Agenda item 17 Agenda item 25 External Affairs 09/03/10 21 of 22

22 For further information, please contact any of the following offices External Affairs Lloyd s Register 71 Fenchurch Street London EC3M 4BS, UK Lloyd s Register EMEA 71 Fenchurch Street London EC3M 4BS, UK Lloyd s Register Asia Suite 3501 China Merchants Tower Shun Tak Centre Connaught Road Central Hong Kong, SAR of PRC Lloyd s Register Americas, Inc Enclave Parkway, Suite 200 Houston, Texas, 77077, USA Tel: +44 (0) Fax: +44 (0) external-affairs@lr.org Lloyd s Register Tel: + 44 (0) Fax: + 44 (0) emea@lr.org Services are provided by members of the Lloyd s Register Group. Lloyd s Register is an exempt charity under the UK Charities Act Tel: Fax: asia@lr.org Tel: Fax: americas@lr.org External Affairs 09/03/10 22 of 22