Lifeboat Release and Retrieval Systems Requirements

New IMO Requirements

Guidance for Ship Owners
 Background
The number of failures during drills
and inspections that result in
casualties or injured crew members
has been unacceptably high

At MSC 89, the IMO adopted

amendments to SOLAS Ch III and
the LSA Code as well as related
guidelines for the evaluation of
Existing On-load Release and
Retrieval Systems (RRS)

This presentation summarizes the

new requirements, explain their
implication for Ship owners and
describes the actions that need to be
taken.
 New Requirements
SOLAS regulation III/1.5 as amended
requires all ships fitted with lifeboat on-
load release mechanisms to be evaluated
to ensure compliance with the new LSA
requirements.

This evaluation requires:

An initial design assessment of each
release mechanism type by the
manufacturer
A design review of each release
mechanism before 1 July 2013 to be
carried out by the Administration and/or
Recognized Organisation and
an onboard one time follow-up verification
on each ship by not later than the first
scheduled dry-docking* after 1 July 2014
(but no later than 1 July 2019).
Reporting of the evaluation results to the
IMO
* this is the first scheduled out of water
survey of the ships outer bottom
 New Requirements continued.
For vessels/installations constructed (keel laid)
on or after 20 May 2011, but before 1 July
2014, it is encouraged by IMO -
MSC.1/Circular.1393 - that RRS comply with
the LSA Code as amended. Flag to be
contacted for further guidance.
For vessels/installations constructed (keel laid)
on or after 1 July 2014, it is required by IMO -
MSC.1/Circular.1393 - that RRS are to comply
with the LSA Code as amended.
For vessels/installations constructed (keel laid)
before 20 May 2011, RRS not complying with
the LSA Code, Ch IV, 4.4.7.6.4 to 4.4.7.6.6, as
amended by IMO - Resolution MSC.320(89) -
may continue to be fitted prior to delivery but
will have to be replaced (i.e., where `non-
compliant) or modified (i.e., where `compliant
after modification) not later than the first
scheduled dry docking (i.e., out of water survey
of the underwater portion of the hull) after 1
July 2014, but not later than 1 July 2019.
However Flag to be contacted for further
guidance.
 Implications
Significant capital cost to purchase.

Loss revenue from reduce passenger

carriage capacity if a lifeboat is taken
out of service and landed ashore for
retrofitting

Due to the large number of ships that

are expected to have to retrofit non-
compliant RRS, it is strongly
recommended that Shipowners contact
RRS manufacturers promptly to
determine the availability of
replacement equipment to if needed
and ensure compliance by the due
date.
 Steps to ensure compliance.
Identify the types of RRS installed
onboard.

Fall Preventer Devices (FPD) are to

be fitted to any existing RRS which are
pending evaluation. FPDs should be
fitted in accordance with the
MSC.1/Circ.1327.
Contact the RRS manufacturer and
confirm that the OEM is taking the
necessary steps for compliance.

NB: It is expected that a large number

of RRS installed onboard will not
satisfy the new design criteria without
modification.

All modifications needs to undergo

satisfactory design review and testing
by the Administration or Lloyds
Register acting on its behalf.
 Step to ensure compliance continued
Contact Lloyds Register LDSO ( Fire
and Safety section ) for guidance.

Lloyds Register is actively involved in

RRS design reviews and is ready to
assist OEMs and owners in ensuring
compliance.

Lloyds Register has significant

experience with surveying retrofitted
release gear systems and can assist
owners in preparing a procedure for the
replacement of non-compliant RRS. This
will ensure minimal impact to a ship
operations.

Consultation with flag at an early stage is

strongly advised.
 Things to consider
Where will the retrofit take place
in dry-dock or while the ship
continues in operation? How long
will it take to complete the retrofits.

Cargo ships rescue/life boats can

generally be retrofitted while the
ship is in dry-dock.

Passenger ships typically carry a

large number of rescue
boats/lifeboats and tenders that
may require retrofitting. It is likely
that the retrofit will take place while
the ship continues to operate.
 Things to consider continued
Are there adequate facilities
where the ship operates to
properly complete the repairs e.g.
acceptable quality control system
in place?

Is there an agreement between

the Lifeboat manufacturer and the
manufacturer of the RRS for the
retrofitting?

Does the new RRS comply with

the new IMO requirements?

Who can carry out the installation

of the new RRS ?

Have the Administration/RO been

advised of the retrofit ?
 Things to consider continued
Lloyds Register has identified
manufacturing and installation processes
as two vital steps. Both processes are
equally as important as the design review.

Manufacturing Processes:
Significant lead time for new RRS and
consequently some OEM may
manufacturer RRS
Production control techniques
Quality of material

NB: If OEM source other production facilities

there may be a risk of poor quality
materials used for production.

Installation Process:
OEMs may subcontract this work and the
workmanship may be questionable.
Installation test have to be performed in
accordance with the IMO requirements.
 Things to consider continued
Who pays for Lloyd's Registers services?

It is expected that this concern will be resolved

directly between the Ship owners and the OEM.
Generally, the party that submits the application
or signs the contract for Lloyds Register
services will be responsible for Lloyds
Registers fees.

An estimate of fees can be obtained from the

LR local office and is dependant on the service
required.

OEMs are urged to evaluate existing lifeboat

RRS at the earliest available opportunity ,
however they are not obligated to support an
existing RRS and may opt to only provide a next
generation of a previous RRS
 LR tools available
LR procedure for replacement
of lifeboat release mechanisms
LR Class News 09/11
LR guidance notes
Ad hoc consultancy
 Conclusion
Identify RRS installed onboard

Contact the OEM and determine if the

installed RRS comply with the latest
requirements.

Contact LR LDSO ( Fire and Safety

section ) for further guidance.

Agree a retrofit program for

submission to flag/RO.

It is important that Lloyds Register is

involved at key milestones, e.g.
design review, manufacturing, factory
testing, outfitting and production
testing of the new RRS.
 Any questions?
For further information please contact your local LR office or

Capt. Antonio Prestigiacomo

Master Mariner, CMarTech MIMarEST
Senior Specialist, Fire & Safety

Lloyd's Register
Mountbatten House,1 Grosvenor Square
Southampton,SO15 2JU
T. +44 ( 0 ) 2380 249667
E. Antonio.Prestigiacomo@lr.org