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Table of Contents
1 Introduction ..................................................................................................6
3 Classification................................................................................................9
3.1 The Routes to Classification ...................................................................10
3.2 New Construction to Class......................................................................11
3.3 Existing ship transfer of class/acceptance into class/reclassification13
3.3.1 General...............................................................................................................14
3.3.2 Transfer of Class (TOC) from an IACS Member or Associate.............................14
3.3.3 Re-classification from an IACS Member or Associate.........................................15
3.3.4 Re-classification from a non-IACS member ........................................................16
3.3.5 Acceptance into Class (AIC) ...............................................................................16
3.3.6 Frequently asked questions about transferring class ..........................................17
3.4 Class and descriptive notations .............................................................18
3.5 Class suspension and withdrawal ..........................................................20
3.6 Maintenance of Class...............................................................................23
3.6.1 Conditions of Classification.................................................................................24
3.6.2 Periodical Surveys and the Survey Cycle ...........................................................25
3.6.3 Thickness Measurement Requirements..............................................................34
3.6.4 Enhanced Surveys .............................................................................................36
3.6.5 Preparation for surveys.......................................................................................41
5 Consultancy Services................................................................................48
9 IMO Conventions........................................................................................62
9.1 SOLAS 1974 ..............................................................................................63
9.1.1 General...............................................................................................................63
9.1.2 Surveys, Certificates and Records......................................................................64
9.1.3 Applicability of SOLAS........................................................................................65
9.2 An Introduction to Marpol 73/78..............................................................66
9.2.1 General...............................................................................................................66
9.2.2 History ................................................................................................................67
9.2.3 The Marpol Annexes...........................................................................................68
9.2.4 Annex I - The Prevention Of Pollution By Oil ......................................................69
9.2.5 Annex II - The Control Of Pollution By Noxious Liquid Substances In Bulk ........98
9.2.6 Annex V – The Prevention of Pollution by Garbage from Ships........................110
9.2.7 Annex VI - The Prevention Of Air Pollution From Ships ....................................111
9.2.8 Recycling Of Ships ...........................................................................................132
9.2.9 Vapour Emission Control Systems (VECS) ......................................................133
9.2.10 Ballast Water Exchange ...................................................................................135
9.2.11 Anti-Fouling Systems On Ships ........................................................................137
9.3 The International Convention on Standards of Training, Certification and
Watch-keeping for seafarers (STCW) ...................................................141
9.3.1 Changes to STCW............................................................................................141
9.3.2 Companies’ responsibilities ..............................................................................142
9.4 Load Line.................................................................................................143
9.4.1 General.............................................................................................................144
9.4.2 History ..............................................................................................................146
9.4.3 Freeboard / Load Line Calculations ..................................................................148
1 Introduction
The origins of the Classification Societies date back to the middle of the 18th Century. World
trade was then almost entirely dependent on shipping which was a most hazardous
business. The technology available was very basic and there were no controls on the
condition of merchant ships many being in poor condition and frequently overloaded. As a
result of the high numbers of losses of both ships and cargoes many of those financing the
shipping business, particularly the insurers, agreed that there was a need to establish
objective safety criteria and regular inspections to reduce the frequency of shipwrecks.
As a result the first independent “Classification Society”, Lloyd's Register, was set up in the
18th century, to establish safety criteria, conduct regular inspections and classify ships
according to these criteria. Since those early days the number of Societies has increased but
their basic mission remains unchanged. Through their register books fundamental
information is recorded against each ship detailing items such as the IMO/LR number, call
sign, official number, owner, manager, ship type, class notation, dimensions, deadweight,
tonnage etc. In addition through the certificates they issue combined with memorandums and
conditions of class recorded against each ship the class society supplies a guide as to the
condition of the ship. The main benefit of Class still remains that an insurer can then assess
the risk and set an appropriate premium but there are many others who take an interest in
Classification Society activities – not least Port State Control.
Contact details
Lloyd's Register
71 Fenchurch Street, London EC3M 4BS, UK
Tel: +44 (0)20 7709 9166
Fax: +44 (0)20 7488 4796
Email: lloydsreg@lr.org
Lloyd’s Register Asia
South East Asia Area Office
456 Alexandra Road,
NOL Building #16-02,
Singapore,
119962
LR Structure
Currently LR's operational structure is as detailed below. The three regional operations Asia,
Europe/Middle East/Africa and the Americas are responsible for delivering the Society's
services within each region with the regional head offices being located in Hong Kong,
London and Houston respectively. The three business streams are responsible for
developing and supporting the services within the scope of their streams. In turn the regional
operations and business streams that form the matrix structure of the current organisation
are supported by the corporate departments including Legal Services, Finance etc.
LR Management Structure
Legal
Europe, Middle East &
Americas Region Asia Region
Africa Region
IT
Human
Marine Business
Resources
Stream
Corporate Secretary
Energy &
Transportation
Business Stream
Global Quality
Management
Management System
Business Stream
Corporate
Communications
Commercial Support
Line Responsibility
Close Co-operation
Functional Responsibility
The marine activities of LR can be divided into three main areas, these are:
• Classification
• Statutory services and
• Consultancy services
3 Classification
Ship classification in its purest sense is said to be the development and worldwide
implementation of a set of published rules and regulations which set and maintain
standards of quality and reliability. For ships classed with LR these standards are set out in
Lloyd’s Register’s Rules and Regulations for the Classification of Ships and it is the
compliance with the specific parts of these rules that determines the class notation that is
assigned to a ship and recorded in the Register Book. It must be stressed that classification
is a partnership between the class society, owner and operator and it is only with the
proper care and conduct on the part of the owner and operator in conjunction with the
correct application of the rules that classification as a process will provide for adequate:
• Structural strength of (and where necessary the watertight integrity of) all essential
parts of the hull and its appendages.
• Effectiveness of those features and auxiliary systems which have been built into the
ship in order to establish and maintain basic conditions on board whereby
appropriate cargoes and personnel can be safely carried whilst the ship is at sea, at
anchor, or moored in harbour.
Class ensures these provisions through periodical visits to the ships by its surveyors. The
surveyors carry out the corresponding periodical surveys in order to ascertain compliance
with the Rules and Regulations (see Section 3.6.2 on periodical surveys).
A ship is in class when the relevant rules and regulations have, in the opinion of the class
society, been complied with, or when it has been granted special dispensation from
compliance.
Generally, classification rules and regulations do not cover:
• Flotational stability.
• Life-saving appliances.
All of these are covered by internationally adopted statutory codes/conventions and class,
therefore, does not generally repeat these requirements in its Rules and Regulations except
in instances where it wishes to apply the provisions of such codes to additional vessels. An
example of this is where Part 6 Chapter 4 of LR's Rules for Ships contains regulations for
structural fire protection, detection and extinction arrangements. These, however, are only
applicable to vessels which are not required to comply with statutory requirements possibly
due to their size or service.
It should be noted that LR's Rules and Regulations contain requirements for the installation
and subsequent survey of items covered by the 1966 International Load Line Convention.
Items such as air pipes, ventilators, hatch covers etc. are required to be surveyed and found
satisfactory in compliance with Part 1, Chapter 3 Section 2.2 of LR's Rules for Ships. Hence
regardless of who is issuing the Load Line Certificate it is a class requirement that all Load
Line items are kept in order.
Lloyd’s Register’s commitment to safety at sea is continuous, likewise is its commitment to
building a partnership with the owners and operators of ships utilising LR's services.
Examples of this commitment include:
Once the costs and specifications have been agreed the prospective owner and ship yard
sign a contract, at this stage a further contract is signed between the ship yard and the
chosen class society. At this stage the class society's client in respect of the new building
concerned is the ship yard but this of course changes on delivery when the owner becomes
the client. The class surveyors role in the ship yard is to ensure that the ship, its
machinery and systems are constructed, installed and tested in accordance with the
society's rules and applicable statutory regulations (if the class society is authorised to
act on behalf of the ships' intended flag authority). It is not the class society's role to
verify that all items in the technical specification are met this being the responsibility of
the owner and shipyard.
• The ship being built under LR's Special Survey. All materials, workmanship
and arrangements to the satisfaction of an attending surveyor and in
accordance with the rules and approved drawings. Rectification of any
unsatisfactory workmanship or materials plus correction of deviations from
approved arrangements;
• The materials used in the construction of the hull and machinery are to be
manufactured at a works recognised by LR using approved processes. All are
to be good quality and free of defects;
Should novel arrangements/designs or new materials be used in the building of a ship then
LR may require additional testing to be carried out during construction and/or once the ship
is in service. If the ship is constructed in a yard with an LR approved Quality Assurance
scheme then the adopted procedures for survey and testing during construction can be
modified to take into account the ship yard's own management, organisation and quality
systems.
Prior to the delivery of the ship from the ship yard the class surveyors will, in addition to
having verified that all the class requirements have been met, ensure that all the statutory
requirements for which the class society is responsible have also been complied with. The
class society's statutory responsibility with respect to a specific ship will be governed by the
flag chosen by the owner for the ships' registration. The major class society's are authorised
in the majority of cases to carry out most statutory surveys, an example of LR's current
levels of statutory authorisation is given in Annex 1. Where the class society is authorised to
carry out the statutory surveys the society will issue both class and statutory certificates on
delivery and these will normally be valid for a five year period from the date of delivery.
The day of delivery is deemed to be the same as the date of completion of special survey of
ships built under LR's inspection and this date is entered in the Register book. If the ship is
layed up on completion, depending on the period of lay up, the class society may request
additional surveys possibly requiring docking. Subsequent special survey dates will be
referenced from the date of successful completion of the additional surveys.
Following successful completion of construction and sea trials the attending surveyor will
submit for each ship a number of reports and statements to LR's London office. These
documents are checked to ensure that all class requirements have been met, following
which the local surveyor is authorised to issue class and statutory certificates to the ship.
The certificates are usually valid for five years. The statements and check lists submitted are
as follows (see annex 2 for details):
It should be noted that the First Entry Report contains a signed declaration by the ship
yard that the ship has been built in accordance with the requirements of the class rules.
Following the additional receipt in London of copies of the "As-built" drawings and
certificates for essential items such as the anchors, chain cables, main engine, boiler/s
etc. the ship is endorsed for first entry into class and submitted to the Sub-Committee
of Classification for their acceptance. After acceptance by the committee the ship is
issued with a Certificate of First Entry into Classification and its details are entered in
the Register of Ships more commonly known as the Register Book.
3.3.1 General
The starting point for transferring class to LR is through the initial request. The owner
approaches a local LR office requesting classification of one or more of his existing ships.
The LR office will then review:
• Ship type, age, tonnage and service history
• Ownership and fleet details
• Flag state, Port state detention and casualty record
• Number of previous transfers
• Survey status and conditions or recommendations
For ships which are 15 years of age and above, a request for Transfer of Class will only be
allowed to proceed after a review and pre-inspection are carried out to assess the overall
condition of the ship. The scope of this survey is such that it should not disturb current
operations.
Following the initial request and a satisfactory outcome to the initial review and pre-
inspection the local office will present the owner with a Request for Class/Re-class of
Existing Ship/Vessel (Form 2548) for signature. This forms the formal request which allows
LR to approach the current class society and obtain details of survey status and other related
data. LR can then formalise surveys required for classification as well as any specific flag
state requirements. In most cases, a transfer can be combined with normal survey
requirements, minimising cost and disruption to operations.
Following the formal request the LR office overseeing the transfer of class will receive
general survey instructions to smooth the transfer process. As part of the TOC process LR
requires the owner to submit a number of plans plus supporting information which are
required for assessment of the condition of the ship, records, future maintenance of class,
repairs, etc.
All hull conditions of class or recommendations imposed by the losing class society will be
examined and dealt with as necessary at the time of the survey. Acceptance into LR class
will only be permitted with no outstanding conditions of class remaining from the losing
society this is to ensure that the possibility of "class hopping" to avoid carrying out necessary
maintenance is stopped. In addition to resolving any conditions of class surveys that are due
or overdue at the time of the TOC survey will also be held and resolved.
In terms of machinery survey requirements for TOC when the due date of the Complete
Survey of machinery is imminent or overdue, a full Engine Survey will be held in accordance
with the current LR Rules. The minimum machinery survey to be held will comprise a
General Examination of all essential machinery in accordance with the Annual Survey
Checklist form 2100 (see annex 3).
As per hull conditions of class any machinery conditions of class or recommendation
imposed by the losing society will be fully resolved by completion of the TOC survey.
Surveys, or survey items, that are due or overdue at the time of the TOC survey will also be
held and resolved.
It should also be noted that with effect from 1/1/2003, IACS procedures will require that for
ships 15 years of age and older, all overdue surveys and conditions of class shall be
completed to the satisfaction of the class society that assigned them.
• An inert gas installation has been retrofitted which requires the compulsory
assignment of an Inert Gas System (IGS) notation.
• The ship has been re-engined with either new main or auxiliary engine(s). If the re-
engining was during the last two years then Torsional Vibration Calculations (TVC's)
are to be submitted. If, however, the machinery was installed more than two years
ago then special consideration may be given on the basis of the type of machinery
installed combined with a good service record.
As part of the re-classification process an annual survey and general examination of the hull
and machinery respectively is to be carried out in accordance with the associated survey
checklists. As per the TOC procedures all conditions of class and recommendations from the
losing class society plus surveys due and overdue at the time of the change of class survey
are to be resolved before entry into LR class. It should be noted that LR may decline an
application for re-classification based on a poor previous classification record.
As stated previously, following a ships entry into class, the ships details are entered into the
Register Book including its notations. The notations assigned to a ship following her
classification with a society fall into two main categories, these categories are firstly the class
notations, recorded in column 4 of the register book and secondly the descriptive notations
recorded in column 6. Class notations assigned to a ship indicate that the specific
compulsory requirements of the rules have been both applied and met, e.g. if a ship has the
full class notation:
100A1 Double Hull Oil Tanker, ShipRight (FDA SDA CM), *IWS LI
LMC UMS
This would mean, breaking the class notation into its composite parts, that:
Notation: Meaning:
(type of notation)
The ship's hull was constructed under Lloyd’s Register's special survey
(complies with Pt1 Ch2 Sec 2.2 of LR's Rules for Ships)
(character symbol)
100 The ship is considered suitable for sea going service (complies with Pt1 Ch2 Sec
2.2 of LR's Rules for Ships)
(character symbol)
A The ship was constructed or accepted into Lloyd’s Register class and is
(character symbol) maintained in good and efficient condition (complies with Pt1 Ch2 Sec 2.2 of LR's Rules
for Ships)
1 The ship has good and efficient anchoring and mooring equipment in
(character symbol) accordance with the rules (complies with Pt1 Ch2 Sec 2.2 of LR's Rules for Ships)
Double Hull The ship's structure was designed and constructed in accordance with LR's
Oil Tanker Rules for double hull oil tankers (complies with Pt4 Ch9 of LR's Rules for Ships)
(hull type notation)
ShipRight The ship has met LR's ShipRight design and construction procedures
SDA FDA CM covering: Structural Design Assessment, Fatigue Design Assessment and
(hull special feature Construction Monitoring (complies with Pt1 Ch2 Sec 2.3 of LR's Rules for Ships)
notation)
*IWS The ship has met LR's rule requirements for In-Water Survey (complies with Pt1
Ch2 Sec 2.3.10 of LR's Rules for Ships)
(hull special feature
notation)
LMC The ship's propelling and essential auxiliary machinery has been
constructed, installed and tested under LR's special survey and in
(machinery type
notation)
accordance with LR's rules (complies with Pt1 Ch2 Sec 2.4.1 of LR's Rules for Ships)
UMS The ship's machinery and control equipment has been arranged, installed
(machinery type and tested in accordance with LR's rules such that the ship can be
notation) operated with an Unattended Machinery Space. (complies with Pt1 Ch2 Sec 2.4.2 &
Pt6 Ch1 Sec 4 of LR's Rules for Ships)
Notation: Meaning:
(type of notation)
ShipRight The ship's arrangements have met LR's rule requirements for the
SCM application of the ShipRight Screwshaft Condition Monitoring notation
(complies with Pt1 Ch3 Sec 17.3 & Pt5 Ch21 Sec 2.2 of LR's Rules for Ships)
(descriptive notation)
It should be noted that descriptive notations are not usually recorded on the ship's class
certificate unless specifically requested for inclusion by the owner prior to its delivery.
One fundamental difference between class notations and descriptive notations is the
consequence of any lapse from the rule requirements for the notation concerned. If the rule
requirements are not maintained for a class notation then a condition of class may be raised
against the ship. This in turn could result in class being withdrawn from the ship, by the
class society, if the deviation from the rule requirements is not corrected in a timely manner.
In the case of the rule requirements for a descriptive notation not being met, then, if this is
not corrected then the descriptive notation will simply be deleted from the Register Book. In
addition to descriptive notations, descriptive notes will be recorded in column 6 of the
Register Book with the purpose of solely providing additional information about a ship's
design and construction.
Comprehensive detail of how class notations are structured, the meanings of notations and
the corresponding rule references are contained in the additional document titled
"Classification Notations, including: Notation Structure, Class Notations and Descriptive
Notations).
The class and descriptive notations, in addition to being recorded in the Register Book, are
also recorded on LR's ClassDirect Live website at www.cdlive.org In addition the web site
provides instant access to ship class and survey status, details of conditions of class and
memoranda items, LR survey checklists and regulations, survey history and technical
updates amongst many other items.
Where a ship fails to meet rule requirements at survey it would rarely have its class
withdrawn immediately regardless of the seriousness of the non compliance. If a defect was
considered major enough then the ship may have its class suspended making the class
certificate invalid until the necessary corrective action has been taken. The effect of class
suspension is effectively to stop the ship from trading due to the implications with respect to
insurance for both the ship and its cargo. In many instances where a defect is found a
condition of class is recorded on the class certificate and against the ship.
A condition of class (COC) is a recommendation related to defects, damages or wasted
parts that may seriously affect the ship's maintenance of class and that the examination,
repair or replacement must be effected in a given time for class to be maintained. It may also
be considered as a recommendation made in the case of a defective or damaged survey
item which is not serious or urgent enough to necessitate immediate permanent repairs or
withdrawal of class but is sufficiently serious to be prescribed a maximum period for
rectification. In general conditions of class will not be agreed where proper facilities for full
permanent repairs are available. It should be noted that the rectification of a condition of
class can not be postponed beyond the date of the ship's special survey.
The owner/operator should be aware of the following reasons why the society would/may
suspend or withdraw class:
Reason: Consequence:
Annual/Intermediate surveys not Automatic suspension of class
complete within 3 months of due date
Special Survey not completed by due Automatic suspension if no agreed
date extension
Not complying with regulations Suspension at discretion of committee
COC not dealt with by due date Suspension at discretion of committee
Non reporting of damages, defects, Suspension at discretion of committee
breakdowns or groundings
Ship does not have valid convention Suspension at discretion of committee
certificates
Repairs made not acceptable to class Suspension at discretion of committee
Ship under tow and class not advised Suspension at discretion of committee
Ship operated with relevant freeboard Suspension at discretion of committee
mark submerged
Incorrectly located freeboard marks Suspension at discretion of committee
Inappropriate use of ship or operation Suspension at discretion of committee
in unsuitable environment
Inadequate remedial action of any of Class withdrawn at the discretion of the
the above committee
When the non compliance by the owner to meet the requirements of class is deemed major
enough it should be noted that class suspension or withdrawal may be extended to
additional ships in the fleet of the owner concerned.
Should the ship's owner/operator feel the surveyor's recommendations to be excessive then
they may appeal via the regional devolved classification executives (DCE's) or the London
office who may arrange an additional special examination to be carried out.
In addition to conditions of class held against a ship significant notes are held against the
ship in the form of memoranda. Again these can be most easily viewed via ClassDirect Live.
An example of a memoranda item would include a minor hull damage such as a plating
indentation with little distortion of the stiffening members, such an item being noted but
basically cosmetic can be left to repair at the owner's convenience. Other memoranda items
could include, for information purposes, the grades of steel other than grade 'A' used in the
ship's construction, the bearing materials used for the rudder and stern bushes, details of
areas, identified at survey, as having substantial corrosion.
• International Convention for the Safety of Life at Sea, 1974 and its
Protocol of 1978 (Safety Construction, Safety Equipment and
Safety Radio Certificates)
such as safety equipment, safety construction, Load Line and MARPOL on behalf of the flag
administration and this being the case they will be conducted at the same time as the class
surveys. All of the surveys detailed above will be discussed in greater detail later in this
document.
3.6.2 Periodical Surveys and the Survey Cycle
General
Compliance with the requirements of the class rules and regulations must be maintained if
the class status of a ship is not to be adversely affected. This is a fundamental condition of
classification. To ensure a ship meets these requirements a number of class surveys,
varying in scope of examination, are carried out over a period of five years. These surveys
are known as the class periodical surveys. During the five year period all the periodical
surveys will have been performed on the ship the number of times required by Part 1
Chapter 3 Section 1.1 of LR's Rules and Regulations for the Classification of Ships. The five
year period of prescribed surveys and how they are organised is known as the survey cycle
and it is at the end of the cycle that the Certificate of Class will be required to be re-issued
with validity for a further five years.
Today the structure of the survey cycle applied to a specific ship takes one of two main
forms with the essential difference being the timing of surveys covering the ship's hull and
machinery "Special Survey" items and the requirements for the individual surveys. The
special survey items may be examined on a continuous survey cycle basis known as
Continuous Survey Hull (CSH) for structural items (plus anchoring and mooring
equipment) and Continuous Survey Machinery (CSM) for propulsion and essential
auxiliary machinery. If CSH or CSM is adopted the special survey items are proportionally
surveyed throughout the five year survey cycle of the ship i.e. 20% of special survey items
per year with a maximum of five years between each consecutive survey of the same item.
The alternative to surveying special survey items on a continuous basis spread across the
five year cycle is to survey all the special survey items over a short period of time at a single
Special Survey held every five years. This is simply known as Special Survey Cycle (SS)
for hull surveys and Engine Survey (ES) for machinery.
There would, therefore, appear to be a choice in terms of the basis of survey a ship operator
may choose to adopt for his ship's surveys, this in many instances is not the case
particularly in respect of hull surveys. A CSH survey cycle for structural items of oil tankers,
combination carriers, chemical tankers, bulk carriers and ore carriers is not permitted as
ships of these types are obliged by IMO Resolution A744 (18), IACS Unified Requirements
and class rules to adopt an Enhanced Survey Program (ESP).
ESP requires close-up survey of defined structure in addition to an overall survey plus it
requires an enhanced number of scantling thickness measurements. In order for these to be
conducted properly it requires prior planning so that tanks/holds etc. are sufficiently clean,
well ventilated and suitable access arrangements provided. It should be noted that
thickness measurements are to be carried out by an LR approved thickness measurement
company with an LR surveyor onboard for sufficient time to control the process. Hence, it is
not acceptable for a ship to arrive for special survey and for the class surveyor to be simply
presented with a set of thickness measurements
Year: 1 2 3 4 5
AS AS AS AS AS
DS DS DS
DS IW S DS
Key:
AS: Annual Survey,
DS: Docking Survey
ITSS: Intermediate Survey (ship less than 15 years old)
ITMS: Intermediate Survey (ship 15 years or more old)
IWS: In-water Survey
The schematic diagram shown above details the periodical surveys and how they form a
typical hull survey cycle. The timing and survey requirements plus details of permitted
postponements for each of the periodical surveys are discussed in the following sections.
Annual Survey
An annual survey is to be carried out at each anniversary after the ships delivery, hence
there are to be in effect five annual surveys in each five year survey cycle, however, of the
five one will be incorporated with the intermediate survey and one with the special survey.
For practical reasons annual surveys may be carried out in a period spanning from three
months before the anniversary date to three months after the anniversary date effectively
giving a six month window. The dates at the beginning and end of the window are known as
the range dates.
For Annual Surveys (AS), as is the case for Periodical Load Line Inspection (PLI) and Safety
Construction Annual (SCA) surveys, no extension is permitted to the range date. Should
these surveys not be completed by the end of the six month range then class will be
automatically suspended and no postponements are permitted. One effect class
suspension would have would obviously be that confirmation of class to insurers would no
longer be possible if an incident occurred in this period.
The survey items required to be covered in an annual survey are as shown in the Annual
Survey checklist (see Annex 3).
• For vessels over 10 years of age, anchors are to be partially lowered and then raised
satisfactorily using the ship's windlass. In addition a general, internal examination of
all spaces used for salt water ballast is to be carried out. If such examinations reveal
no visible structural defects, the examination may be limited to a verification that the
protective coating remains effective. For spaces used for salt water ballast,
excluding double bottom tanks, if there is no protective coating, soft coating, or
POOR protective coating condition and it is not renewed, maintenance of class is to
be subject to the spaces in question being internally examined at annual intervals.
When such conditions are found in salt water ballast double bottom tanks,
maintenance of class may be subject to the spaces in question being internally
examined at annual intervals.
• In the case of dry cargo ships over 15 years old, other than bulk carriers which are
subject to enhanced survey requirements, an overall examination of a forward and
an after cargo hold is to be carried out. It should be noted that these requirements
will change on the introduction of IACS unified requirement Z10.6 which will require,
for non ESP ships in excess of 15 years old, that the scope of the intermediate
survey will be the same as that for the previous special survey.
• For ESP ship types including oil tankers, combination carriers, chemical tankers and
dry bulk cargo ships there are enhanced intermediate survey requirements which
become more onerous as the ship gets older (see annex 6). Once the ship is
greater than 15 years of age then the intermediate survey will be known as an
ITMS survey not an ITSS survey. The survey will be extended, in the following
ways, so that it is carried out to the same extent as the previous special survey
and no in-water survey is permissible in place of dry docking.
Dry Bulk Cargo Ships over 15 years old (ITMS additional requirements):
• Hull girder thickness measurements
• Overall survey, assessment of coatings, close-up survey and thickness
measurement of all salt water ballast tanks and cargo holds
• Overall survey of all remaining spaces within the cargo hold length, including voids,
duct keel, cofferdam spaces etc
• Examination of all piping systems passing through all spaces within the cargo hold
length.
Oil Tankers and Combination Carriers over 15 years old (ITMS additional
requirements):
• Hull girder thickness measurements
• Overall survey, assessment of coatings, close-up survey and thickness
measurement of all salt water ballast tanks and cargo tanks
• Overall survey of all remaining spaces within the cargo tank length, including the
pump room
• Examination of ballast piping within cargo tanks
• Examination of all other piping systems within the remaining spaces within the cargo
tank length, including the pump room.
The survey is to be held in sheltered waters with the ship at a suitable draught and the hull
below the water line is to be clean. The surveyor is to be satisfied with the pictorial
presentation of the hull and is to have good two way communication with the diver. The
diving firm carrying out the survey is to be approved by LR.
It should be noted that should the In-water survey reveal damage or deterioration requiring
early attention the surveyor may require the ship to be dry docked.
• Ship is to have an arrangement whereby rudder pintle and bush clearances can be
ascertained afloat along with a method of verifying the security of the pintles (Pt 3,
Ch.13, 2.5.7)
• High resistant paint is applied to the underwater portion of the hull, the application
having been in accordance with the manufacturers requirements (Pt 3, Ch.2, 3.5.4)
coating condition is confirmed at each dry docking
• Plans detailing all of the above have been submitted and approved and copies
placed onboard the ship (Pt 3 Ch 1, sections 5.2 and 5.3).
• Side shell plating, as for bottom plating with attention also drawn to the bilge keel
ends and butt welds
• Stern frame
• Rudder, typically looking for any fractures, leaks, fall and condition of stock bolts also
locking arrangements for pintle and rudder nuts.
• Rudder bearing clearances measured (pintles & stock (max 5mm + 0.002D mm)) in addition
both general and vertical movement
• Tail shaft/stern bush clearances to be measured (white metal bearing <2mm clearance)
• Chain cables to be ranged and both the cable and anchors examined. The diameter
of the chain cable links are to be checked as is the tightness of studs. In terms of the
anchor the "D"shackle should be examined including pin and shank clearance plus
the crown pin, locking pin and shell housing should be checked
• Examination of electrical equipment in hazardous zones on oil tankers five years old
and over.
its intended purpose for the next five (5) year period of class subject to proper maintenance,
operation and the periodical surveys being carried out at the due dates.
The examinations of the hull are to be supplemented by thickness measurements and testing
as deemed necessary, to ensure that the structural integrity remains effective and is to be
sufficient to discover Substantial Corrosion, significant deformation, fractures, damages or
other structural deterioration.
The anchors are to be examined. Chain cables are to be ranged, examined and the required
complement and condition verified for all ships over 5 years old. The chain locker, holdfasts,
hawse pipes and chain stoppers are to be examined and pumping arrangements of the chain
locker tested. Chain cables are to gauged and renewed in cases where their mean diameter
is worn by 12% or more of its nominal diameter.
All spaces including holds and their ‘tween decks where fitted; double bottom, deep, ballast,
peak and cargo tanks; pumprooms, pipe tunnels, duct keels, machinery spaces, dry spaces,
cofferdams and voids are to be internally examined including the plating and framing, bilges
and drain wells, sounding, venting, pumping and drainage arrangements. Internal
examination of fuel oil, lube oil and fresh water tanks may be specially considered.
Engine room structure is to be examined. Particular attention is to be given to tank tops, shell
plating in way of tank tops, brackets connecting side shell frames and tank tops, and engine
room bulkheads in way of tank top and bilge wells. Particular attention is to be given to the
sea suctions, sea water cooling pipes and overboard discharge valves and their connections
to the shell plating. Where wastage is evident or suspect, thickness measurements are to be
carried out, and renewals or repairs made when wastage exceeds allowable limits.
For spaces used for salt water ballast, excluding double bottom tanks, if there is no
protective coating, soft coating, or POOR protective coating condition and it is not renewed,
maintenance of class is to be subject to the spaces in question being internally examined at
annual intervals. When such conditions are found in salt water ballast double bottom tanks,
maintenance of class may be subject to the spaces in question being internally examined at
annual intervals.
Boundaries of double-bottom, deep, ballast, peak, and other tanks, including holds adapted
for the carriage of salt water ballast, are to be tested with a head of liquid to the top of
hatches for ballast/cargo holds or top of air pipes for ballast or fuel oil tanks. Special
consideration may be given to limit testing of fuel oil, lube oil and fresh water tanks to
representative tanks.
Hatch covers and coamings are to be examined to verify that no unapproved changes have
been made, that hatch covers are structurally sound and weathertight, and where
mechanically operated steel covers are fitted, satisfactory operation is to be verified.
Thickness measurements are to be carried out in accordance with Table 1. Additionally, any
part of the vessel where wastage is evident or suspect, the Surveyor may require thickness
measurements in order to ascertain the actual thickness of the material.
Table 1
Minimum Requirements for Thickness Measurements at Special Surveys
Special Survey Special Survey Special Survey Subsequent Special Surveys
No. 1 No. 2 No. 3
1) Suspect areas 1) Suspect areas 1) Suspect areas 1) Suspect areas throughout the
throughout the throughout the throughout the vessel.
vessel. vessel. vessel.
2) One transverse 2) Two transverse 2) A minimum of three
section of deck sections within transverse sections in way of
plating abreast a the amidships cargo spaces within the
cargo space within 0.5L abreast of amidships 0.5L.
the amidships 0.5L two different
cargo spaces.
3) Internals in 3) Internals in forepeak and
forepeak tank. after peak tanks.
4) All cargo hold 4) All cargo hold hatch covers
hatch covers and and coamings (plating and
coamings (plating stiffeners).
and stiffeners).
5) All exposed main deck
plating full length.
6) Representative exposed
superstructure deck plating
(poop, bridge, and forecastle
deck).
7) Lowest strake and strakes in
way of ‘tween decks of all
transverse bulkheads in cargo
spaces together with internals in
way.
8) All wind- and water strakes,
port and starboard, full length.
9) All keel plates full length.
Also, additional bottom plates in
way of cofferdams, machinery
space, and aft end of tanks.
10) Plating of seachests. Shell
plating in way of overboard
discharges as considered
necessary by the attending
surveyor
Notes:
1. Thickness measurement locations are to be selected to provide the best representative sampling of areas likely
to be most exposed to corrosion, considering cargo and ballast history and arrangement and condition of protective
coatings.
2. Thickness measurements of internals may be modified at the discretion of the Surveyor if the protective coating
is in GOOD condition.
3. For vessels less than 100 meters in length, the number of transverse sections required at Special Survey No. 3
may be reduced to one (1), and the number of transverse sections required at Subsequent Special Surveys may be
reduced to two (2).
4. For vessels more than 100 meters in length, at Special Survey No. 3, thickness measurements of exposed deck
plating within amidship 0.5 L may be required.
Table 2
Guidance for Additional Thickness Measurements in Way of Substantial Corrosion
STRUCTURAL MEMBER EXTENT OF MEASUREMENT PATTERN OF
MEASUREMENT
Plating Suspect area and adjacent 5 point pattern over 1 square
plates. meter.
Stiffeners Suspect area. 3 measurements each in line
across web and flange.
Protective Coatings
Usually epoxy coating or equivalent. Other coating systems may be
considered acceptable as alternatives provided that they are applied and maintained in
compliance with the manufacturer’s specification.
Representative Spaces
Those spaces which are expected to reflect the conditions of other spaces of
similar type and service and with similar corrosion protection systems. When selecting
representative spaces, account is to be taken of the service and repair history on board and
identifiable critical and/or Suspect Areas.
Spaces
Separate compartments including holds and tanks.
Substantial Corrosion
An extent of corrosion such that assessment of corrosion pattern indicates a
wastage in excess of 75% of allowable margins, but within acceptable limits.
Suspect Areas
Locations showing Substantial Corrosion and/or are considered by the Surveyor
to be prone to rapid wastage.
Transverse Section
Includes all longitudinal members such as plating, longitudinals and girders
at the deck, side, bottom, inner bottom, and longitudinal bulkhead. For transversely framed
vessels, a transverse section includes adjacent frames and their end connections in way of
transverse sections.
(These gauges use the multiple echo method and so discount the coating thickness in this
way).
The requirements of thickness gauging are given in the Rules & Regulations of Ships (or
Inland Waterway ships, Special Service craft, etc.), and the booklet ‘Thickness Measurement
and Close-up Survey Guidance – Rev. 6’. This information is further supplemented by
guidance to surveyors in MSPM and the extracts from above are also included in the ESP
booklets sent to owners to assist them with the planning their surveys (and to prepare Survey
programmes).
Thickness Measurement Reporting
It is a requirement of the Rules that thickness measurements are to be carried out by LR
approved service suppliers. The updated list of LR approved TM Service suppliers is
available from the ‘Approvals’ option of the CD-Live home page.
It is also a Rule requirement that the surveyor needs to be on board while the thickness
measurements are taken to the extent necessary to control the process. The intention of this
requirement is not to make the surveyor witness every reading that is taken, but to monitor
the thickness measurement to the extent he/she considers necessary.
Surveyors are no longer obliged to sign off any TMs that are not carried out under their
control (ie. TMs carried out during voyage without surveyor presence). Before the
introduction of this requirement (ie. Control of surveyor, etc), it was not uncommon for
surveyors to be presented with the complete TM report with very limited opportunity to verify
the reported readings very often due to non accessibility.
It is now a requirement that prior to commencing surveys involving thickness gauging, a pre-
inspection meeting be held with owners superintendent and TM operators to agree the
location and extent of TMs to be taken (for the initial assessment)
It should be made clear at this stage, that unless the gauging results from initial assessment
are reviewed, it is not possible to commit to the number of TM readings that will be required
to be taken.
It is common for surveyors to be requested to provide estimates about the number of TM
readings which will be required to be taken (used by owner's when estimating the cost of this
task – TM service suppliers quote on the basis of number of Tm readings, etc.). While there
is no objection to extending this help it must be remembered that the figure is only a rough
guide and the actual figure may be much greater depending on the initial readings and
additional TM's required.
It is strongly recommended that TM Service suppliers use LR TM Software. This software
has virtually become the industry standard. Use of this software allows easy exchange of TM
information between offices and is also helpful in identifying the substantial corrosion/
excessive diminution areas.
During the pre-inspection meeting, TM operators to be strongly advised that as soon as any
areas of substantial corrosion/ excessive diminution are identified (by them), this must be
immediately brought to the attention of the owners superintendent and attending surveyors.
This is essential for the necessary action to deal with the deficient structure to be to be
agreed at an early stage.
Owners should be reminded that delayed submission has the knock on effect of delaying
issue of ESP documentation. As TM service suppliers are engaged by the owners, the owner
should insist on timely completion and submission of TM reports to progress with updating of
records and issue of ESP documentation.
Approved TM Service suppliers
Approval of TM Service suppliers is under the control of Materials & NDE surveyors. In case
of any queries and feed back about these TM service suppliers get in touch with LR's
Materials and NDE Department (MNDE). In extreme cases, where the services provided by
the approved TM service suppliers are found seriously below the expected levels (e.g. use of
unqualified TM operators, absolutely no knowledge of ship’s structure, etc.) removal of these
TM service suppliers from the approved list may be considered by MNDE.
Procedure for approval is given under ‘Approvals Lists’ on the CD-Live home page. Any
queries in this regard to be directed to MNDE.
There are about 379 approved TM Service suppliers and of these most use the LR TM
software. There are some companies (HYDROSCAN, EM&I, etc.) who have their own
software and are using this to produce TM reports. This is acceptable (as long as the format
of reporting is in accordance with IACS guidelines given in URS Z10.1, 10.2, 10.3, etc. as
already stated earlier in the presentation)
It should be separately stressed that delayed submission of TM reports causes delay in
updating information and issue of ESP documentation. Delay in issue of ESP documentation
causes inconvenience to owners (financial implications for tanker owners – not getting
charter due to oil major vetting inspectors demanding to see the ESP documentation).
• According to Res. A744(18) they apply to Oil tankers and bulk carriers (to which
SOLAS and MARPOL73/78 apply as they are referenced in these)
• According to IACS Guidelines they apply to all sea going self propelled oil tankers
and chemical tankers (including combination carriers), and bulk carriers and ore
carriers.
They are therefore not applicable for oil tankers and bulk carriers and tankers that are not
seagoing (and therefore do not have SOLAS certificates (and IOPP certificates for tankers)).
By the same logic they are also not appplicable to ships below convention size (i.e. bulk
carriers below 500 Tons and Tankers below 150 Tons even though they may be seagoing,
etc.)
So what is different on these ships? Well, the survey requirements remain very much the
same as for oil tankers, bulk carriers, etc. depending on the ship’s type, etc. The only
difference is that ESP documentation is not issued/necessary.
The details of master list items for ESP ships are more detailed than on non ESP ships. For
e.g. for the master list item tank, on ESP ships the sub items include ‘overall survey’, ‘close
up survey’, TM verification, TM final report, ‘Protective coating’, etc. whereas for non ESP
ships there are generally only two items ‘Examination’ and ‘Test’. On the reports for ESP
ships too, for these sub-items more information is returned as compared to non ESP ships
(e.g. locations (i.e. frame nos.) of those tanks where single transverse web frame or deck
and bottom transverse is required to be examined and details reported.
Note: this information is to be reported only for ESP ships.
Which Rules and Conventions define the need and scope of these requirements?
Detailed requirements for survey of ESP ships are given in Res. A744(18) which is
referenced from both SOLAS Ch. XI and MARPOL Reg. 13
Similar requirements are also given in the LR Rules and Regulations (which in turn are kept
aligned with IACS Unified requirements)
Survey Programme
As part of ESP requirements, a survey programme (survey plannng document is required to
be submitted to (and agreed by) the local office at least six months before the survey due
date or before the surveys are commenced.
The local office is to process the document for completeness before submitting it to the
Devolved Classification Executive (DCE) office for review and agreement and then returned
to the owners.
A copy is also forwarded to the port of survey, if this is known at the time of returning the
agreed survey programme.
This survey programme is to be the reference document at the time pre survey meeting
between owners supdt., survey or and TM service supplier’s team that will be working on
board.
It is recognised that there will be occasions when ships arrive in port for commencing Special
survey without an agreed survey programme. In such cases the surveyors attending for
surveys will assist in preparing a survey programme and forward it for review/agreement (in
cases of there being insufficient time before the ship leaves surveyor may provisionally agree
the programme locally and forward a copy to local DCE for records)
We here consider the information required in Appendix 1 of the survey programme booklet to
be adequate for review/agreement and the remaining information (e.g. plans, etc. can then
be made available to the surveyor at the time of survey.
Executive Summary
Executive summary is part of the ESP documentation. ESP documentation is required to be
issued by the Class Rules and by IMO Res. A744(18) (referenced from within SOLAS Ch.
XI, reg. 2 and MARPOL reg.13 G)
This is issued as a complete survey file.
ESP documentation comprises of following:
• Survey file containing Survey reports, TM reports and Executive summary
• Previous repair history
• Cargo and Ballast history
• Report on structural defects/deterioration in general
• Reports on leakage in bulkheads and piping systems
• Condition of coatings or corrosion protection systems (where fitted)
• Information that may help to identify critical areas
• Agreed survey programme
Executive summary is issued following completion of every Special survey reflecting the
condition of the ship at the time of completion of survey
Executive summary issued after SS completed and all Reports received /reviewed and TM
reports received. ESP documentation must not be removed from the ship (to remain on
board for the life of the ship)
Close-up survey requires adequate access arrangements to get within arms reach of structure
to be inspected.
ESP Statement
Between the time of completion of SS and issue of ESP documentation, if required an ESP
statement can be issued. This is a statement to the owners confirming that SS has been
completed and stating that the requirements of IMO Resolution A744(18) are covered by LR
Rules.
Planning ahead in the ship's schedule to Ship may be at sea when surveys become
allow for forthcoming surveys. overdue or not in a location where a surveyor
can be made available in time. Surveys
becoming overdue may result in possible port
Ensuring the ship will be in suitable detentions and automatic class suspension
locations for surveys and requesting e.g. annual survey must be completed by not
surveyor's attendance in a timely manner. more than 3 months after the ships
anniversary date otherwise automatic class
suspension is imposed.
Discuss surveys with the surveyor in advance
who will have up to date information on
revised survey requirements and outstanding
survey items.
Know the scope of the surveys in advance, Not knowing the scope of the survey may
review the survey check lists, check lead to surveys being unable to be completed
memoranda items, check for Conditions of or causing ship delays.
Class. Be in a position to request additional
surveyors in advance if time is tight and
many surveys are to be conducted at the
same time.
Allow enough suitable time and crew for
surveys e.g. cargo operations may mean
ship's staff not available to demonstrate the
operation of required items or they may be
unable to demonstrate operation of
equipment without danger.
Night time may be unsuitable for inspections
of say cargo equipment, cranes etc., too
dangerous to climb, too dark to see, think
before calling in the surveyor.
Plan before carrying out repairs, advise Not reporting a damage or defect to class
class of the defects/ damages and prepare a may result in class suspension. Not
repair plan. Discuss the plan with class discussing defects with class may result in
and arrange a surveyor's attendance, this will more serious defects developing due to
ensure an adequate repair is carried out inadequate or poor repair. Defects may re-
utilising for example correct weld procedures, occur due to not correcting the root cause of
heat treatment, adequate NDT etc. the defect. Additional costly NDT may need
to be arranged if details of repair procedures
were not agreed with class prior to repair.
The repair may need to be carried out again
according to a revised more extensive repair
plan if class feel the repair was inadequate.
If a number of surveys are being carried out Resolving surveys one check list at a time is
at the same time using several check lists try inefficient and sometimes requires items to
to resolve the requirements into one checklist be tested more than once in order to confirm
and examine items across the lists in a an additional requirement for a different code.
logical order through the ship. Discuss the
order with the surveyor before starting, start
at the bridge and work down through the ship
and have necessary items for all surveys
available and layed out.
Have documentation ready for examination Untidy documentation and unclear markings
and verification i.e all certificates including of relevant dates slows down the survey.
class, statutory, test and servicing certificates
all filed logically with log books gathered
together for inspection.
Have the lifeboat inventory checked against Laying out of the lifeboat inventory next to
the SE check list and have it displayed in an each boat speeds up the confirmation
orderly fashion. process.
Prepare "Special Survey Planning Document" On many occasions ships arrive for special
for your ship at least 6 months in advance of survey without a plan leading to an inefficient
the survey and use it to plan for the survey. and prolonged process.
For structural testing of tanks, try to perform Arrival for special survey lay up without
as many boundary tests as possible prior to having progressed tank testing may cause
arrival at the dock for special survey lay up. considerable time delays in the completion of
Request surveys at ports when adjacent the survey and thereby incur unnecessary
tanks are full. Special survey can costs.
commence up to 15 months before the ships
5th anniversary date. Many boundaries can
be surveyed during this period and credited
towards special survey thus reducing lay up
time.
TM's to be carried out by an approved TM TM's carried out by a non approved company
company and with a surveyor in attendance. or without a surveyor controlling the process
will be required to be re-measured at
considerable cost.
TM's should be organised as far in advance Leaving TM's too late may cause delay in
of the special survey completion date as return to service plus additional steel costs if
possible to allow maximum time to plan for optimum scantling steel is not readily
steel renewals. available for use.
Checking continuously by ship's staff of By not carrying out frequent checks by ship's
structure, machinery and equipment in order staff of structure, machinery and equipment
to confirm their good order. and by relying on periodical surveys only, the
ship owner risks serious delays due to
Ship's staff should, with commitment, use
machinery breakdowns and emergency
copies of the class society's survey check
repair work. In addition if the serious defects
lists plus the SE1 and C11(IMO) to ensure
are found by PSC the owner risks port state
that all items are covered and are in good
detention and the ship being named in the
order.
press. Such detentions may also result in
class suspension and withdrawal if the owner
is found not to be maintaining the ship
Operational checks should be carried out at
adequately, this being a basic condition of
regular drills e.g. fire drills, boat drills,
classification.
emergency steering exercises etc.
Planning of repair periods will ensure that Major deficiencies are more likely to be found
required services are available (public for the first time during survey e.g. fire pumps
holidays/ Sunday's can be avoided). , emergency generator, life boat davits etc.
not working or serious cracks in structure. If
serious defects are found during survey this
may lead to increased down time of the ship
due to extended survey periods and
unexpected periods when the ship is not in
service.
• Quarterly listings
• ClassDirect Live
4 Statutory Services
It is essential to understand the difference between a class survey and a statutory survey.
The latter survey if carried out by a class surveyor is being conducted on behalf of the flag
administration for the country with which the ship is registered unlike the class survey which
is carried out on behalf of the class society itself. The requirements of the statutory survey
are governed by the statutory instruments adopted by the flag administration and not the
classification rules and regulations. As per statutory surveys all statutory services offered by
the class society are conducted on behalf of the flag administration e.g. approval of intact
and damage stability, approval of safety equipment arrangements etc.
Lloyd’s Register is authorised by more than 135 national administrations to undertake
surveys and approval work on their behalf. The exact degree of authorisation, however,
varies from country to country. Classification Societies have to work to more rigid guidelines
when it comes to dealing with ships that fail to meet the appropriate standards in Statutory
surveys as they are acting on behalf of the flag administation and are therefore applying a
country's law.
In most cases the statutory instruments used for the survey of ships are based on the
internationally adopted codes and conventions covering subjects such as safety construction,
safety equipment, safety of navigation, pollution prevention, Load Line and safety
management. It is worth noting that even countries which have adopted international codes
may in addition have their own national requirements known commonly as flag requirements.
The class society can assist the owner should he wish clarification on or interpretation of flag
requirements.
The introduction in the marine industry of internationally adopted codes and conventions has
been the result of the formation of the International Maritime Organization (IMO). The
organization has overseen the introduction of conventions including the 1966 International
Load Line Convention, The International Convention for Safety of Life at Sea (SOLAS), The
International Tonnage Convention plus others to name a few.
IMO including it's history, organization and function is detailed later in this document.
5 Consultancy Services
Lloyd’s Register has a range of specialist services aimed at helping ship builders, owners
and operators, which are not directly related to classification or Statutory issues. These
include specification and supervision services, Fuel and lubricant analysis, technical
investigations of damage and vibration, and emergency response for major problems such
as fires, groundings or collisions. It is involved in all areas of marine business from new
buildings through conversions, to yacht building and naval vessels. Details of all the current
services are available in LR's Marine Services brochure and are also outlined in the diagram
below.
• Extend to new • Trade and • Condition • Ship life • Shaft analysis & • Field & lab trials • FOBAS
products and operability surveys extension alignment • Sea trials • Drugs/alcohol
services studies • Condition • Future rules • Engine • Performance • Ballast water
• Feasibility monitoring • Due diligence mechanics testing • Environment
studies • CAP • Financing • Combustion • Material and
• Total risk • Life extension • Spec. review • Thermodynamic component
assessment studies • Tender review s failure
• Fleet evaluation • Crack • Sale & purchase • Propulsion
management • Ice interaction
162 Member
States
UN Agencies 57 Non-Governmental
organisations. OCIMF,
UNCTAD, WHO, IMO
ILO, etc. IACS, IMPA, IFSMA,
ICS, ISO. INTERTANKO etc.
37 Inter-Governmental
organisations
EC, IMSO etc.
The governing body of the IMO is the Assembly which meets every 2 years. Between
sessions it is run by the Council which, from November 2002, consists of 40 Member States
elected by the Assembly. There is also a Secretariat of some 300 people, working in six
technical divisions. The Organization is led by the Secretary-General.
Assembly
(meets every 2 years)
Council
40 Elected Members
Marine
Technical Maritime
Legal Facilitation Environment
Cooperation Safety
Committee Committee Protection
Committee Committee
Committee
Most of the IMO’s work is carried out by a number of Committees and Sub-committees. The
most senior of these is the Maritime Safety Committee or MSC. This is responsible for
issues relating to SOLAS (The International Convention for Safety of Life at Sea, 1974) and
for STCW 95 (The International Convention for Standards of Training, Certification and
Watchkeeping, 1995)
The Marine Environment Protection Committee, MEPC, was established in 1973 raised to full
constitutional status in 1985 and is responsible for co-ordinating the IMO’s activities in the
prevention and control of pollution of the marine environment from ships.
The MSC and the MEPC have nine sub-committees which report to them and develop
amendments to the SOLAS, MARPOL STCW Conventions and other IMO measures as
necessary.
The Legal Committee is another permanent committee responsible for considering any legal
matters within the scope of the IMO.
The Technical Co-operation Committee co-ordinates the IMO’s work in providing technical
assistance on maritime matters, especially to developing countries.
The Facilitation Committee is responsible for activities and functions that relate to facilitating
international maritime traffic. The aim is to reduce the formalities and simplify the
documentation required when ships enter or leave ports or terminals.
Apart from delegates from the member states, the IMO committees and sub-committees also
include representatives of a wide range of inter-governmental organizations , such as the
European Commission (EC), the International Mobile Satellite Organization (IMSO), and non-
governmental organizations , such as IACS and Intertanko. These organisations have been
granted consultative status to aid the committees’ work in an observer capacity. They may
provide information, documentation and expert advice, but they do not have any voting
powers.
Committee discussion
Agreement
Creating or amending the IMO Conventions and Codes can take considerable time. The
diagram shows what can be involved and the procedures that need to be undertaken in the
passage from an original submission to implementation.
Each convention includes appropriate provisions stipulating conditions which have to be met
before it enters into force. These conditions vary but generally speaking, the more important
and more complex the document, and the more stringent are the conditions for its entry into
force. For example, the 1974 SOLAS Convention required acceptance by 25 States whose
merchant fleets comprised not less than 50 per cent of the world’s gross tonnage. This is
called ‘positive acceptance’ In the case of some conventions which affect a few States or
deal with less complex matters, the entry into force requirements may not be so stringent.
In early conventions, amendments came into force only after a percentage of Contracting
States, usually two thirds, had accepted them. This often led to long delays. To remedy the
situation, a new amendment procedure was devised. This procedure is called ‘tacit
acceptance’. It provides that an amendment shall enter into force at a particular time unless
before that date, objections to the amendment are received from a specified number of
Parties.
This procedure has been used in the case of conventions such as the Convention on the
International Regulations for Preventing Collisions at Sea, 1972, the International Convention
for the Prevention of Pollution from Ships, 1973 and SOLAS 1974, all of which incorporate a
procedure involving the tacit acceptance of amendments by States.
As was expected the tacit acceptance procedure has greatly speeded up the amendment
process. The 1981 amendments to SOLAS 1974, for example, entered into force on 1
September 1984. Compared to this, none of the amendments adopted to the 1960 SOLAS
Convention between 1966 and 1973 received sufficient acceptance to satisfy the
requirements for entry into force.
As the pressure grows for improved standards of ship construction, maintenance and
operation, IACS members are going to play a crucial role in helping the industry achieve
better performance and eliminate many of the sub-standard ships that cause the majority of
the problems.
8.1 Glossary
Flag State: State in which a ship is registered and which undertakes to regulate its activities
under its own domestic laws and appropriate international treaties and conventions.
Port State: State in which a port visited by a foreign flagged ship is situated.
Port State Control: inspection and any necessary intervention, in respect of the standards on
board flagged ships by the authorities of the port State.
It is well established that the ultimate responsibility for the safe and civilised operation of a
ship lies with the owner, aided by the flag administration and classification society. Port State
control is regarded as a valuable adjunct to the activities of the flag and classification society
and as such, is fully supported by LR and all other IACS members. However, port State
control is not – nor was ever intended to be – a substitute for the proper exercise of flag
State responsibility.
Historically, sovereign States claimed the right and now, under international law, a State has
the duty to exercise jurisdiction and control in administrative, social and technical matters
concerning ships which it allows to fly its flag. A flag State is required to take all necessary
measures to ensure safety at sea and the protection of the environment with regard to
construction, maintenance and training, labour conditions and prevention of collisions of its
ships.
Sovereign and other self-governing States, of course, also have the right to control any
activities within their own borders, including those of visiting vessels.
The arguments regarding ‘open registers’, often called ‘flags of convenience’ (FOCs), have
raged over the past 50 years, principally between the International Transport Workers’
Federation (ITF) on the one hand and owners’ organisations, such as the International
Shipping Federation (ISF), and the flags themselves on the other.
However, there is general agreement that the huge inequalities between flag States and their
performance are behind many of the industry’s problems. Substandard flags allow
substandard ships and there are, as yet, no mandatory quality approval system for flag
States – nor is there likely to be.
Classification societies act on behalf of both national flags and FOCs on a wide range of
subjects, but apart from ISM matters, they are almost exclusively to do with construction and
equipment. The central matters of operation, manning and maintenance remain wholly the
responsibility of the owners under the direct supervision of the flag.
Crew costs are a major factor in the running costs of a ship and according to a major ship
manager, can vary by a multiple of six between a low cost FOC ship and a high cost national
crew. Once one owner in a particular trade switches to a FOC and the cheapest crews that
the manning market can provide, it is very difficult for the others to ignore the competitive
pressure that this creates. One result is the prevalence of mixed crews, mixed both in
nationality and language and decidedly mixed in competence. A study of members’ ships by
the UK P&I Club found that 56% had mixed nationality crews. As somebody said, in an
emergency, everyone panics in his or her own language.
A substandard ship is defined by IMO in ‘Procedures for Port State Control –2000 Edition’ as
‘a ship whose hull, machinery, equipment, or operational safety is substantially below the
standards required by the relevant convention or whose crew is not in conformance with the
safe manning document.’
The International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS 74),
the Protocol of 1988 relating to the International Convention for the Safety of Life at Sea,
1974 (SOLAS Protocol 1988), the International Convention on Load Lines, 1966 (Load Lines
66), the Protocol of 1988 relating to the International Convention on Load Lines, 1966 (Load
Line Protocol 88), the International Convention for the Prevention of Pollution from Ships,
1973 as modified by the Protocol of 1978 relating thereto, as amended (MARPOL 73/78), the
International Convention on Standards of Training, Certification and Watchkeeping for
Seafarers,1978, as amended (STCW 78), and the International Convention on Tonnage
Measurement of Ships, 1969 (Tonnage 69).
8.8.1 Origins
PSC was introduced (and is expanding) primarily for political reasons, responding to
commercial and environmental concerns. The major impetus was given by pollution following
the groundings of the ‘Amoco Cadiz’, Exxon Valdez’ and ‘Braer’ (none of them ‘substandard
ships’) and commercial pressures on higher cost countries from low cost competition.
Following the adoption, on 17 February 1978, of the Protocol to SOLAS 1974, eight countries
signed the Hague Memorandum on 2 March. This aimed at the general surveillance of
seagoing ships to ensure that requirements laid down in various international conventions
were met, not least regards living conditions. Two weeks later, on 17 March, the ‘Amoco
Cadiz’ grounded on the coast of France, spilling 230,000 tonnes of oil. This was a major
incentive for the European Commission to start working on means to strengthen the
effectiveness of control, leading to the Paris Memorandum of Understanding being adopted
in 1982. Others have followed since.
The lack of control by many flag States is, in part, compensated by port State control, which
could be described as a compulsory sharing of the costs of FOCs over the whole industry. It
is certainly true, however, that no flag State (or classification society), however reputable or
well-intentioned, can be represented everywhere. By definition, the port State always is.
PSC is mandated by the United Nations Convention of the Law of the Sea, and among
others, SOLAS Regs I/19 and XI/4 and guided by IMO Res. A.787 (19) ‘Procedures for port
State control.
Regional groupings are much more effective than single port States for the obvious reason
that ships move.
Paris MOU:
Operational 1982, the signatories are the EU littoral States plus Canada, Norway, Poland,
Russia, Croatia and the newest member Iceland. It is now heavily influenced by incorporation
in EU directive 95/21/EC.
www.parismou.org
United States:
The USCG has operated a ‘SOLAS’ PSC system since 1994, adding to its long-standing
regime of inspecting foreign flagged ships for compliance with the United States Code of
Federal Regulations. It co-operates with other PSC organisations.
www.uscg.mil/hq/g-m/pscweb/index
Signed 1992, it consists of 10 members, becoming more active. Brazil also operates a bulk
carrier structural inspection programme.
www.acuerdolatino.int.ar
Caribbean MOU:
Signed 1996, has 22 members, not yet very active.
A key element of the MOUs is the sharing of information and expertise, in order to obtain a
consistent approach to inspections. They also permit regional action to permit (or facilitate)
compliance.
In the early days, ships were inspected almost at random, the original Paris MOU referring
only to paying special attention to ships which may present a special hazard. The ‘random’
inspections gave a defensible set of data on deficiency types and differences between ship
types, owners and flags. From these has developed the concept of ‘targeting’, of assigning
priorities regarding which ships to be inspected.
Points systems are used by the USCG and the Paris MOU as an aid to targeting but priorities
for inspection can be summarised as:
In the Paris MOU system, credit points are awarded for a previous ‘no deficiencies’
inspection, which will offset debit points against the flag and so on.
More detailed information on Paris MOU and USCG Targeting Factors is available in
LRTA Paper No.3, Appendices A and B.
Before and on boarding, the PSCO should gain a general impression of the condition of the
ship. He will then examine the ship’s relevant certificates and documents, including the
crew’s papers. If the certificates are valid and the PSCO’s general impression and visual
observations on board confirm a good standard of maintenance, the PSCO should generally
confine the inspection to observed or reported deficiencies, if any. In short, the instructions
are ‘if it looks good and the papers are correct, go to another ship’.
If, however, from his general observations, the PSCO has ‘clear grounds’ for believing that
the ship, its equipment or its crew do not substantially meet the requirements of the relevant
conventions he should carry out a ‘more detailed inspection’. Examples of ‘clear grounds’
and guidelines for ‘more detailed inspections’, are given in IMO Resolution A.787 (19)
(this is reproduced on the Intranet web site – Marine/Technical Performance/Port State
Control and can also be found in CDLive and Rulefinder.)
The review of the operation of the industry, which led to the introduction of the ISM Code and
the amendments to the STCW, led also to a change in the approach to inspection to be
taken by port State control. The ‘clear grounds’ for a more detailed inspection were
expanded to include unsatisfactory control procedures under SOLAS, MARPOL and STCW,
cargo
operations, involvement in incidents, inadequate fire, boat and other drills and evidence that
the crew may not be able to communicate with each other or other people on board.
The Paris MOU adopted a coding system for deficiencies found and actions taken. This
system has been taken up by the other MOUs and lately also by the USCG. LR, too, uses
the codes in its port State control database. These are very useful in creating a standard set
of data for statistical purposes but the actual deficiency still has to be described, usually in
English, on the forms provided. Access to these descriptions, therefore, is essential for
anyone taking any sort of action on them and they are often less than clear to anyone but the
originator. Copies of a typical (invented) report are given as appendix C and Appendix D in
the LRTA paper. The code list can be found on the Intranet web site – Marine/Technical
Performance/Port State Control.
safety of personnel, the ship and the environment. If it doesn’t make money, it doesn’t get
done. These non revenue-earning items include life-saving equipment, fire prevention and
equipment, cleanliness (accommodation and machinery spaces), navigation equipment.
Meaningful onboard drills and maintenance and adherence to the approved safety
management system, where applicable, should enable the identification and correction, by
the crew, of many of these deficiencies. The latest version of the Maintenance Guide
Checklist can be obtained using the Intranet – Marine/Technical Performance/Port State
Control and can also be found on CDLive.
The most frequent deficiency of all is crew competence – both in terms of training and there
being insufficient number on board to deal with the maintenance or even to drive the ship.
Small and medium sized bulk carriers and general cargo ships are by far the types of ships
most frequently detained, with general cargo ships proportionally four times the rate for
tankers which have generally a good record, being subject to the greatest political and
environmental pressures. Container ships, carrying ‘clean’ cargoes, and on liner service
deadlines, are rarely in detention, although the rate may be expected to increase.
It is essential that all PSC detentions are attended and reported in accordance with MSPM
requirements. These can presently be found in the MSPM Part E, Chapter 7 Section 1.6.
8.9.7 Appeals
Until recently any appeal procedure (apart from USCG) was instigated by the Technical
Performance Group. This process has now been changed to allow greater involvement
locally.
Now the attending Surveyor will be able to appeal against detentions at source if they are felt
to be unfounded. This is especially important in relation to detentions which are assigned as
‘class responsibility’ in Form A of the PSC Boarding Report. Details of the criteria for appeals
can be found on the Intranet web site – Marine/Technical Performance/Port State Control
and can also be found on CDLive.
It is not easy for anyone, whether a potential shipper or insurer or flag or classification
society or even another PSC organisation, to find out what a ship’s or owner’s inspection
record is. Solving this problem of transparency of information is fundamental to the success
of port State control in enabling the responsible user community within the ‘circle of maritime
responsibility’ to discriminate against the substandard operator. The European Union’s
European Quality Shipping Information System (EQUASIS) is being developed to address
this problem.
It has been estimated that around 90% of PSC detentions are associated with poor crew
operational standards and lack of proper maintenance on board and are not directly
associated with a ‘survey failure’.
8.11 Conclusions
8.11.1 Is PSC driving the Substandard Operator out of Business?
There are many cases of ships being examined and sometimes detained and ‘put right’ by
PSC only to be detained elsewhere, shortly afterwards, with an even longer list of serious
deficiencies. This is primarily because, at present, a PSC inspection makes no claim to be a
thorough examination of the ship. The Port State does not have the amount of time and
access available to the owners and the flag State. The short time in port of most ships,
combined with problems of physical access to the structure and machinery, limit the extent of
examination of the ship and assessment of the capabilities of the crew. Thus, a PSC
inspection is usually just a spot check, although an increasingly targeted and informed check
and the report of deficiencies will accordingly be limited to those that are already observable.
When a ship is detained, the owner is required only to put right the deficiencies listed. They
are being made to do only what they should have done already. It is akin to a motorist, who
hasn’t paid their insurance and being stopped by the police, simply handing over the
premium due and being allowed to drive away.
We have no evidence, so far, to show that, except in the most extreme cases, PSC or the
classification societies are being successful in driving the substandard operator out of
business. Most ships detained are not delayed and it may well be cheaper to risk and suffer
a detention than to prevent it.
It can be argued that the present PSC regime of detaining but not delaying, and the efforts of
LR and other classification societies in carrying out additional surveys of problem ships may,
in fact, be counter-productive and prolong the problem by patching up ships which should
really have been put out of business. Additionally, the presence of a Surveyor on board has
ceased to be an event with any significant adverse consequences for the crew, thus it is rare
for safety equipment to be broken out, checked and ready for survey or even for tanks to be
open, ventilated and lit for examination. Disclassing or deleting from a flag’s register may
help the image of the individual classification society or flag but unless and until IMO
Resolution A.739 (18) is properly enforced, in relation to the issue of SAFCON certificates,
the ship will in all probability continue to be able to trade.
This situation will no doubt change. In the Paris MOU area, legislation is being prepared
which will come into force during 2003. When this takes affect vessels flying a targeted flag
may be liable to a banning order if the vessel has a number of PSC detentions in a given
period within the Paris MOU area. Other MOUs will obviously keep a close watch on this
development.
Port State control is not succeeding enough but has the disadvantage by substandard
operators, the present system does have to change. The industry must find ways to make
detention prohibitively expensive. The culture of expectation of postponement must be
changed to an expectation to repair. Coupled with this, owners demonstrating a good system
and record must be aided by a lightening of touch by the regulatory authorities.
Good owners must be helped by the elimination of the bad but these same good owners
must play a large part in their own battle. The resources of all the maritime authorities are
stretched. Few additional surveyors are available to carry out enhanced surveys, retrofit of
bulk carriers, the other extra surveys outlined above, (or even port State control) and the
good owners must realise that these resources are not going to be provided by the bad.
The United States Coast Guard has been instrumental in implementing a quality initiative
which goes part way to rewarding the good owner.
They have established the QUALSHIP 21 initiative. This initiative identifies high quality non-
US flagged vessels and then awards them with incentives, which include Qualship 21
Certificates, vessel names posted on the USCG web site, Qualship designation on EQUASIS
files and less frequent PSC examinations. There is also presently the possibility of a
reduction in port fees being implemented for qualifying vessels.
The USCG criteria for qualification are that these vessels are managed by well-run
companies, classed by organisations with a quality track record, have an outstanding PSC
record in US waters, and are registered with flag States that have a superior PSC record.
To date, it is noted that the highest number of vessels qualifying are LR class vessels (41%)
However, a Port State Control Officer does have one unique weapon. If he finds the first ship
on his list for the day in poor condition, he is able to concentrate on that ship and does not
have to go on to the others, an advantage, which could if used aggressively and with the full
co-operation of the flag, really make the operation of substandard ships not worth the game.
Only then will port State control truly have succeeded.
9 IMO Conventions
Member States that are signatories to one, more, or all of these Conventions are legally
obliged to enact them into their own laws and ensure that vessels registered under their flags
obey them. Some of the most important Conventions, Annexes, Agreements, Protocols are
shown in the Table.
S TC W C o nv e ntio n 7 8
S TC W -F C o nv e ntio n 9 5
S AR C o nv e ntio n 7 9 C L C C o nv e ntio n 6 9
From the diagram above SOLAS major deficiencies as a percentage of total deficiencies
breaks down as follows:
Fire safety 14%
Life Saving Appliances 12%
Safety in general 12%
Safety Navigation 9%
Safety radio 3%
Certificates and log books 3%
ISM related 3%
Total 56%
It should be noted that throughout SOLAS at the beginning of each chapter and in the case
of some regulations applicability is more precisely defined. E.g. Chapter IV
"Radiocommunications" Part A, Regulation 1 states that the chapter applies to "cargo ships
of 300 gross tonnage and upwards" not 500 gross tons as is the general case.
Application of SOLAS requirements are also often dependent on when the ship's keel was
laid or the ship was at a similar stage of construction which is defined as when:
It has been known for ship yards to produce a number of 50 tonne blocks prior to a known
date when application of new SOLAS requirements could thus avoided along with possible
associated additional cost.
Part 1 covers the articles relating to the Convention of 1974, and the Protocol of 1988, and
the consolidated text of the Annex to the 1974 SOLAS Convention. This consists of twelve
Chapters, plus an Appendix (showing the format of certificates)
V Safety of Navigation
VI Carriage of Cargoes
VII Carriage of Dangerous Goods.
VIII Nuclear ships
IX Management for the Safe operation of ships
X Safety measures for high-speed craft
XI Special measures to enhance maritime safety
XII Additional safety measures for bulk carriers
9.2.2 History
There has been concern about the pollution of the oceans by oil since the early part of the
20th century, when oil was first carried in bulk on the forerunners of today’s tankers, and
when oil powered engines became common.
In the early 1920’s both the US and UK Governments passed laws to ban illegal discharges
of oil, however, neither were very effective.
In 1926, the USA convened an International Conference on Oil Pollution Control, attended by
Japan the US and 11 European countries. Although a draft convention was prepared,
nothing came of it. In the 1930’s the UK Government, under strong pressure from
environmental groups, raised the question of oil pollution at the League of Nations (the
predecessor to the United Nations). In 1935 a draft convention was prepared, however, the
proposals were resisted by a number of countries, and with the approach of war in Europe no
further progress was made.
In 1945 the United Nations was established, shortly after that the UN established specialised
agencies with specific responsibilities, one of which, created in 1948, was the Inter-
Governmental Maritime Consultative Organisation, now known as the International Maritime
Organisation or IMO. At this stage, there was no mention of oil pollution; however, there was
concern about it. Because of resistance by some countries to the idea of an international
body regulating shipping, progress in getting any international agreement to a convention
was slow. The IMO met for the first time in 1959, eleven years after its creation
In 1954, the UK Government convened an International Conference on Oil Pollution, at which
the text of the International Convention for the Prevention of Pollution of the Sea by Oil was
agreed.
The IMO took over responsibility for the 1954 convention. A conference was called in 1962
to consider amendments to the 1954 convention, and this came into force in 1967. This
convention, as with the 1954 convention, dealt only with zones where the discharge of oil
was prohibited, and had little impact.
The next major development was the “load on top” system for tankers, where oily water
generated through cargo tank washing and ballasting was retained onboard to form part of
the subsequent cargo.
In 1969, the IMO adopted the “load on top” system as part of the 1954 convention. During
the early 1970’s there were further conferences and developments. The one that is of
particular interest is the 1973 conference that considered the proposed “International
Convention for the Prevention of Pollution from Ship, 1973” or MARPOL Convention.
This convention was slow to be ratified by Governments. A series of tanker accidents in the
late 1960’s and in 1976 and 1977, including the “Torrey Canyon” incident in 1967, when
100,000 tons of crude oil was spilt off the SW Coast of England, led to a further conference
in 1978. This conference produced the 1978 Protocol to the 1973 Convention, which took
care of some technical difficulties in adopting the 1973 Convention. The 1973 Convention as
amended by the 1978 Protocol is known as “MARPOL 73/78”.
The Convention finally came into force on 2 October 1983, which meant Annex I was now
internationally accepted and ships were required to comply.
Since 1978 there have been regular amendments to MARPOL 73/78 convention, which
includes the development of the other Annexes. Some of the most recent developments of
MARPOL 73/78 are a result of the “Exxon Valdez” incident in 1989 that lead to the
introduction of “Double Hull” requirements and the provision of Shipboard Oil Pollution
Emergency Plans.
The criterion for adoption of an Annex is normally that at least 15 countries must have
accepted it representing at least 50% of the world's fleet.
The extent of compliance with the regulations is determined by applying the following factors:
At this stage it is worth distinguishing between a new and existing ship, and a new and
existing oil tanker.
A new ship is one for which the building contract was placed on or after 31st December
1975, or in the absence of a building contract the keel of which was laid on or after 30th June
1976, or which was delivered on or after 31st December 1979, or which has undergone a
major conversion after these dates. These dates are applicable to all ships, including oil
tankers.
A new oil tanker is one for which the building contract was placed on or after 1st June 1979,
or in the absence of a building contract the keel of which was laid on or after 1st January
1980, or which was delivered on or after 1st June 1982, or which has undergone a major
conversion after these dates. These dates are applicable to oil tankers alone. It is therefore
possible for an oil tanker to be a 'new ship' but an 'existing oil tanker'.
These dates are very important in the application of the MARPOL Annex I regulations.
All vessels of 400 gross tons and above, and all oil tankers of 150 gross tons and above, are
required to be surveyed and to be issued with Certificates as evidence of their compliance
with the regulations. Smaller ships are required to comply with the regulations but are not
required to be surveyed or to be issued with certificates. However if requested by the
Owners or if required by the flag authority a Statement of Compliance can be issued
ii. the tanker is more than 50 nautical miles from the nearest land;
iv. the instantaneous rate of discharge of oil content does not exceed 30 litres per
nautical mile;
v. the total quantity of oil discharged into the sea does not exceed for existing tankers
1/15,000 of the total quantity of the particular cargo of which the residue formed part,
and for new tankers 1/30,000 of the total quantity of the particular cargo of which the
residue formed a part; and
vi. the tanker has in operation an oil discharge monitoring and control system and a slop
tank arrangement as required by Regulation 15 of MARPOL Annex I.
(b) For machinery space discharges from any ship of 400 tons gross tonnage and above
other than an oil tanker and from machinery space bilges excluding cargo pump room
bilges of an oil tanker unless mixed with oil cargo residue:
iii. the oil content of the effluent without dilution does not exceed 15 parts per million;
and
iv. the ship has in operation equipment as required by Regulation 16 of MARPOL Annex
I (oily water separator and bilge monitor).
The Regulations can now be conveniently split into two parts. Those Regulations which
apply to all vessels and those applying only to tankers
Regulation 14 - Segregation of oil and water ballast and carriage of oil in forepeak
tanks
This Regulation applies to new ships other than oil tankers of 400 grt and above and new oil
tankers of 150 grt and above.
No ballast is to be carried in oil fuel tanks, except in abnormal conditions (abnormal
conditions means severe weather conditions or certain vessels which need to carry large
quantities of fuel oil).
When ballast is carried in fuel oil tanks it should be discharged to shore reception facilities or
to the sea in compliance with regulation 9 using oil filtering equipment, and an entry made in
the Oil Record Book.
No oil shall be carried in the forepeak or any tank forward of the collision bulkhead. This
applied to all ships of 400 grt and above whose contracts are placed after 1st January 1982
or whose keels are laid after 1st July 1982. (Refer also to SOLAS Chapter II/2 regulation
15(5) and LR Rules Pt. 3 Ch.3 Sec.4).
All vessels not included in the above should comply with these requirements as far as is
reasonable and practicable.
Regulation 16 - Oil discharge monitoring and control system and oil filtering
equipment
This Regulation describes the equipment necessary to achieve the discharge limits of
15ppm, and the monitoring requirements enabling the ships staff to measure the oil content
of oil/water mixture being discharged.
There are three basic pieces of equipment involved:
1. Oil Water Separator - used to describe 100ppm equipment (not permitted after 1st
July 1998).
2. Oil Filtering Equipment - used to describe 15ppm equipment.
3. Monitoring Equipment - more commonly referred to as a bilge monitor or 15ppm alarm.
Used to describe equipment that can monitor the discharge, record the ppm of discharge
outflow and, where the regulations require, automatically stop the discharge when the
limit of 15ppm is reached or in the event of monitor failure.
Vessels of between 400 grt and 10,000 grt must be provided with 15ppm equipment to
process machinery space discharges. i.e. an oily water filter.
Vessels of 10,000 grt and over must be provided with a 15ppm oil filter with an alarm which
operates at 15ppm and an automatic stopping device. Any vessel that carries ballast in fuel
oil tanks must also be fitted with this equipment.
Vessels which require discharging within a Special Area should also be fitted with an
automatic stopping device, 15ppm filtering equipment and a 15ppm alarm to comply with
regulation 10, Special Areas.
All the equipment provided in compliance with Regulation 16 must be of an approved type.
Type approval certificates are issued by or on behalf of National Administrations. The type
approval standard is Resolution MEPC.60 (33) for all equipment fitted after 30 April 1994 and
Resolution A.393(X) for equipment fitted prior to that date. Different standards have been
developed over the years; the date on which the equipment was fitted will decide which
standard was applicable at that time. If replacement equipment is fitted then compliance with
the latest standard is necessary.
Some ships were fitted with separating or filtering equipment prior to Annex I coming into
force. However, the equipment did not always comply with the standards required. These
ships were allowed to use "add on" units (known as process units) to bring the equipment up
to the required standard. This also applied to equipment meeting the other older standards
mentioned above. The IMO books “Oily Water Separators and Monitoring Equipment” and
“Pollution Equipment under MARPOL 73/78” contains the relevant IMO resolutions.
A waiver is available from the requirements of Regulation 16 for vessels engaged solely in
voyages within Special Areas. In such cases all oily mixtures must be discharged to
reception facilities.
Standard
Discharge
Connection
15ppm
15pmm
alarm 3 Way
Pump filter
Valve
Overboard
215mm
22mm
TANKERS
Before considering the Regulations which apply to tankers, it is useful to understand how a
tanker operates.
Considering item 3 - where does the tanker put the ballast? The cargo tanks were
traditionally used as ballast tanks thus creating an oil/water mixture. The ballast containing
the oil/water mixture cannot be discharged at the loading port. To overcome this problem the
tanker washes a set of tanks and fills these with clean ballast which can be discharged at the
loading port. The “dirty” ballast is discharged to sea along with the residues from tank
cleaning - or that was how it was done historically, and still is on single hull tankers!
On tankers with Segregated Ballast Tanks (SBT) or double hulls sufficient ballast is taken
into the segregated ballast tanks for most ballast voyages. Only on rare occasions in the
event of extreme weather conditions or emergency situations would ballast be taken into
cargo tanks.
Concern about oil pollution led to the development of what is known as the “load-on-top”
system. This was developed by the tanker operators, not the IMO.
Instead of discharging the residues from the tank washings to sea, they are retained on
board in a slop tank. The oil/water mixture is allowed to settle, and then the water is pumped
off the bottom. This leaves the oil plus a small amount of water in the slop tank. The tanker
when proceeds to the loading port as before. Cargo is loaded into all tanks including on top
of the slops. The cycle is then repeated.
It should be noted that the load-on-top procedure only works with crude oil cargoes. For
product refined oil cargoes e.g. petrol, jet fuel or diesel oil, the slops are either retained on
board or discharged ashore.
Regulation 13 - Segregated Ballast Tanks, Dedicated Clean Ballast and Crude Oil
Washing.
This Regulation requires that every new Crude Oil Tanker of 20,000 DWT and above and
every new Product Tanker of 30,000 DWT and above must be provided with Segregated
Ballast Tanks (SBT).
The capacity of SBT tanks must be such that the vessels draft is a minimum of 2.0 + 0.02L
and a trim not exceeding 0.015L, where L = vessels length, and such that the propeller is
fully immersed. There must be sufficient segregated ballast capacity so that the vessel can
operate safely without using cargo tanks for ballast, except in exceptional circumstances e.g.
heavy weather.
Every new Crude Oil Tanker of 20000 DWT and above is required to be provided with a
Crude Oil Washing (COW) System.
Every Existing Crude Oil Tanker of 40000 DWT and above must be provided with a
Segregated Ballast Tank System, meeting the requirements referred to earlier, or, in lieu of a
segregated ballast system, a Crude Oil Washing System.
Every Existing Product Tanker of 40000 DWT and above must be provided with either a
Segregated Ballast Tank System or a Dedicated Clean Ballast Tank (DCBT) System.
These are the basic requirements as required by Regulation 13. There are three aspects of
Regulation 13 that require more explanation; they are Protective Location, Crude Oil
Washing and Dedicated Clean Ballast.
Segregated Ballast
A Segregated Ballast System is a system that is physically separated from the tankers cargo
oil and fuel oil systems, and is used only for the carriage of ballast. Completely separate
means that the SBT pipework must be physically separated from the oil system. Provision
may be made for the emergency discharge of ballast using a cargo pump, by means of a
connection through a portable spool piece and a non-return valve to prevent oil from passing
back to the ballast tanks. The spool piece must be removed when not in use and a
permanent notice displayed adjacent to it, restricting its use.
The arrangements and operational procedures for Dedicated Clean Ballast Tanks should
contain at least all the provisions of the Specifications for Oil Tankers with Dedicated Clean
Ballast Tanks, IMO Resolution A.495 (XII), the basic requirements of which are as follows:
• The DCBT must be isolated from the cargo system by at least two valves.
• The lines and pumps used should be arranged such that they can be effectively
flushed prior to loading/discharging the ballast without permitting any oily water to
enter the Dedicated Clean Ballast Tank.
• Any part of the DCBT piping system, whilst in use, must be isolated from the cargo
system by at least two valves, or equivalent. This isolation should also include inert
gas, tank venting and tank washing systems.
• The DCBT piping must be connected to the least practicable number of cargo
pumps.
• Piping to be anchored to the ships structure, provided with means to allow for
expansion, the anchoring to be such that hydraulic shock can be absorbed.
2. No part of the system is to enter the Engine Room and any tank cleaning heater is to be
fitted with double shut-off valves or clearly identifiable blanks to enable its effective
isolation.
• The number and location of the machines to be such that no more than 10% of the
horizontal surface and no more than 15% of vertical areas are in “shadow”. (this is
assessed by “Shadow Area Diagrams”, which must be approved).
• The pump supplying the Crude Oil Washing System (usually a cargo pump) to be of
sufficient capacity to operate the maximum permitted number of machines at the
required back pressure.
• The stripping system is to be capable of keeping the tank bottom dry when washing
the bottom of the tanks, and removing the oil at a rate of 1.25 times the maximum
discharge rate of the maximum number of machines operated simultaneously.
• Means to be provided to drain the entire cargo system and washing system, to a
cargo tank and ashore. For discharge ashore a small diameter line to be provided
leading to the outboard side of the manifold valves.
• An inert gas system must be fitted to vessels operating a Crude Oil Washing System.
This requirement is over and above any requirement under SOLAS to fit an inert gas
system.
• Sufficient tanks are to be Crude Oil Washed prior to each ballast voyage, in order
that ballast water is not put into tanks that have not been crude oil washed (this
means that heavy weather tanks must be washed at every discharge).
• An Approved Crude Oil Washing Operations and Equipment Manual which contains
instructions on how the system is to be operated to achieve the requirements for tank
cleanliness and safety.
For vessels under 5000 DWT, cargo tanks should be arranged such that the maximum
capacity of any tanks does not exceed 700m³ unless it has wing tanks complying with the
following:
w = 0.4 + 2.4 DW (m) where the minimum value of w is 0.76m
20000
The double bottom tanks or spaces are to have a minimum vertical depth of “h”.
For vessels of 5000 DWT and above, in lieu of Regulation 13E, h = B/15(m) or 2.0m
whichever is the lesser, the minimum value of h being 1.0m
For vessels under 5000 DWT, h = B/15(m) and the minimum value of h is 0.76m
Suction wells in cargo tanks may protrude into the double bottom below the boundary line
defined by the distance h provided that such wells are as small as practicable and the
distance between the well bottom and bottom shell plating is not less than 0.5h.
On crude oil tankers of 20,000 DWT and above, and product tankers of 30,000 DWT and
above, the aggregate capacity of the wing tanks, double bottom tanks, forepeak and after
peak tanks shall not be less than the capacity of segregated ballast required to meet the draft
and trim requirements of Regulation 13. These tanks should be located as uniformly as
practicable along the cargo tank length.
Ballast piping must not pass through cargo tanks and cargo piping must not pass through
ballast tanks.
Other methods of design and construction of oil tankers than those already described may be
accepted provided that they can provide the same level of protection against oil outflow in the
event of collisions or stranding. Such alternatives are to be approved and be in accordance
with IMO guidelines.
The damage stability requirements for oil tankers of 20000 DWT and above are also
increased under the requirements of Regulation 13F, such that bottom raking damage over a
larger area is taken into account.
Tables are used to determine, for each category of oil tanker, the date on which
regulation 13F becomes applicable.
A category 1 oil tanker can only trade beyond 25 years from it's date of delivery if it is
provided with wing or double bottom spaces offering at least 30% side or bottom
protection, or if it operates with hydrostatically balanced loading. It may then trade
up to the date on which regulation 13F becomes applicable.
In addition a category 1 oil tanker from the anniversary of its date of delivery in 2005,
and a category 2 oil tanker from 2010, is subject to compliance with a Condition
Assessment Scheme (CAS) adopted by the IMO. The requirements for CAS are
detailed in IMO resolution MEPC.94 (46).
This regulation is difficult to follow so LR have developed some flow diagrams to
guide Owners/Managers and surveyors through it. Reference is also made to Marine
Technical Notice 2002/20.
The IMO Marine Environmental Protection Committee (MEPC) at its 46th meeting, in April
2001, adopted an amended regulation 13G.
The attached flow charts are intended to provide guidance in establishing which 'category' a
tanker falls into, the phase out date, and the requirements of the Condition Assessment
Scheme (CAS).
1. Lloyd’s Register of Shipping (hereinafter referred to as ‘LR’), its officers, employees or agents (on behalf of each of whom
this notice is given) shall be under no liability or responsibility in negligence or otherwise howsoever to any person in
respect of any information or advice expressly or impliedly given in this [report, advice, etc.], or in respect of any
inaccuracy herein or omission herefrom or in respect of any act or omission which has caused or contributed to this
[report, advice, etc.] being issued with the information or advice it contains (if any).
2. Without derogating from the generality of the foregoing, neither LR, nor any of its officers, employees or agents
shall be liable to any person in negligence or otherwise howsoever for any special or indirect loss or damage
(including but not limited to, loss of production, loss of product, loss of use and/or loss of revenue, profit or
anticipated profit) howsoever the same may be caused.”
Further information
Contact: Sam James
Direct Dial: +44 20 7423 2683
Email: TGG-Stat@lr.org
ABCD
Classification and Statutory Surveys – Delegate Notes
New IMO regulation 13G flow charts
YES NO
YES
ABCD
Category 1
New IMO regulation 13G flow charts
A Category 1 oil tanker shall comply with the requirements of regulation 13F of MARPOL 73/78 Annex I
not later than the anniversary of the date of delivery of the ship in the year specified as follows:
2003 for ships delivered in 1973 or earlier
2004 for ships delivered in 1974 and 1975
2005 for ships delivered in 1976 and 1977
2006 for ships delivered in 1978, 1979 and 1980
When the tanker reaches the 25th anniversary of its date of delivery, it is to comply with either of the following
provisions to enable it to trade until the dates stipulated above: -
(a) the tanker is to be provided with wing tanks or double bottom spaces, not used for the carriage of oil and
meeting the width and height requirements of regulation 13E(4), covering at least 30% of Lt, for the full depth of
the ship on each side or at least 30% of the projected bottom shell area within the length Lt, where Lt is as
defined in regulation 13E(2); or
(b) the tanker is to operate with hydrostatically balanced loading, taking into account the guidelines developed
by the International Maritime Organization (MEPC.64(36))
When the tanker reaches the anniversary of its date of delivery in 2005, it shall comply with the Condition
Assessment Scheme (CAS) adopted by the MEPC, to enable it to trade until the dates stipulated above.
NOTE
The Administration of a State which allows, suspends, withdraws or declines the application of CAS to a
ship entitled to fly its flag shall communicate to the IMO details of the ship for circulation to other
Administrations for their information and appropriate action, if any.
ABCD
Category 2
New IMO regulation 13G flow charts
A Category 2 oil tanker shall comply with the requirements of regulation 13F of MARPOL 73/78 Annex I not
later than the anniversary of the date of delivery of the ship in the year specified as follows:
2003 for ships delivered in 1973 or earlier
2004 for ships delivered in 1974 and 1975
2005 for ships delivered in 1976 and 1977
2006 for ships delivered in 1978 and 1979
2007 for ships delivered in 1980 and 1981
2008 for ships delivered in 1982
2009 for ships delivered in 1983
2010 for ships delivered in 1984
2011 for ships delivered in 1985
When the tanker reaches the anniversary of its date of delivery in 2010, it shall comply with the Condition Assessment Scheme
(CAS) adopted by the MEPC, to enable it to trade until the dates stipulated above.
NOTE
The Administration of a State which allows, suspends, withdraws or declines the application of CAS to a ship entitled to fly its flag
shall communicate to the IMO details of the ship for circulation to other Administrations for their information and appropriate
action, if any.
OPTION 1 OPTION 2
In the case of a Category 2 oil tanker fitted with only In the case of a Category 2 oil tanker the Administration
double bottoms or double sides not used for the may allow continued operation of such a ship beyond
carriage of oil and extending to the entire cargo tank the dates specified above, provided that such continued
length or double hull spaces which are not used for the operation shall not go beyond the anniversary of the
carriage of oil and extend to the entire cargo tank date of delivery of the ship in 2017 or the date on which
length, the Administration may allow continued the ship reaches 25 years after the date of its delivery,
operation of such a ship beyond the dates specified whichever is the earlier, and also provided that either:
above, provided that:
(i) wing tanks or double bottom spaces, not used for the
(i) the ship was in service on July 1 2001; carriage of oil and meeting the width and height
(ii) the Administration is satisfied by verification of the requirements of regulation 13E(4), cover at least 30% of
official records of the ship that it complied with the Lt, for the full depth of the ship on each side or at least
conditions specified above; 30% of the projected bottom shell area within the length
Lt, where Lt is as defined in regulation 13E(2); or
(iii) the conditions of the ship specified above remain
unchanged; and (ii) the tanker operates with hydrostatically balanced
loading, taking into account the guidelines developed by
(iv) such continued operation does not go beyond the the Organization.
date on which the ship reaches 25 years after the date
of its delivery.
NOTE
(a) The Administration of a State which allows the application of either of the options above, to a ship entitled to fly its flag shall
communicate to the IMO details of the ship for circulation to other Administrations for their information and appropriate action, if any.
(b) A Party to the present Convention shall be entitled to deny entry of an oil tanker operating in accordance with Options 1 and 2 above
into the ports or offshore terminals under its jurisdiction. In such cases, that Party shall communicate to the Organization for circulation
to the Parties to the present Convention particulars thereof for their information. The European Community Member States, together
with Cyprus and Malta, have already indicated that they will not accept such ships.
Version 3.0 created on 17-Jul-03 Page 87 of 192
Marine Services
Category 3
A Category 3 oil tanker shall comply with the requirements of regulation 13F of MARPOL 73/78 Annex I
not later than the anniversary of the date of delivery of the ship in the year specified as follows:
2003 for ships delivered in 1973 or earlier
2004 for ships delivered in 1974 and 1975
2005 for ships delivered in 1976 and 1977
2006 for ships delivered in 1978 and 1979
2007 for ships delivered in 1980 and 1981
2008 for ships delivered in 1982
2009 for ships delivered in 1983
2010 for ships delivered in 1984
2011 for ships delivered in 1985
OPTION 1
OPTION 2
In the case of a Category 3 oil tanker fitted with only
double bottoms or double sides not used for the In the case of a Category 3 oil tanker the Administration
carriage of oil and extending to the entire cargo tank may allow continued operation of such a ship beyond
length or double hull spaces which are not used for the dates specified above, provided that such continued
the carriage of oil and extend to the entire cargo tank operation shall not go beyond the anniversary of the
length, the Administration may allow continued date of delivery of the ship in 2017 or the date on which
operation of such a ship beyond the dates specified the ship reaches 25 years after the date of its delivery,
above, provided that: whichever is the earlier, and also provided that either:
(i) the ship was in service on July 1 2001; (i) wing tanks or double bottom spaces, not used for the
carriage of oil and meeting the width and height
(ii) the Administration is satisfied by verification of the requirements of regulation 13E(4), cover at least 30% of
official records of the ship that it complied with the Lt, for the full depth of the ship on each side or at least
conditions specified above; 30% of the projected bottom shell area within the length
Lt, where Lt is as defined in regulation 13E(2); or
(iii) the conditions of the ship specified above remain
unchanged; and (ii) the tanker operates with hydrostatically balanced
loading, taking into account the guidelines developed by
(iv) such continued operation does not go beyond the the Organization.
date on which the ship reaches 25 years after the date
of its delivery.
NOTE
(a) The Administration of a State which allows the application of either of the options above, to a ship entitled to fly its flag shall
communicate to the IMO details of the ship for circulation to other Administrations for their information and appropriate action, if any.
(b) A Party to the present Convention shall be entitled to deny entry of an oil tanker operating in accordance with Options 1 and 2
above into the ports or offshore terminals under its jurisdiction. In such cases, that Party shall communicate to the Organization for
CATEGORY
circulation 1 OIL
to the Parties to theTANKERS - LIFE
present Convention EXTENSION
particulars thereof forBEYOND 25 YEARS
their information. The European Community Member
States, together with Cyprus and Malta, have already indicated that they will not accept such ships.
Whilst it is not explicit in the regulation, it would be prudent to isolate the designated tanks
from the cargo pumping and piping system by blank flanges. Also, these tanks should be
isolated from the cargo venting system.
A suitable means of draining these non-cargo carrying tanks must be provided, together with
suitable sounding and venting arrangements. Other than the fitting of blanks and providing
suitable venting arrangements no other work should be required. However, the cargo
handling system may require some modifications to the in-tank pumping and piping
arrangements in order to retain operational efficiency and flexibility.
It is emphasised that designated non-cargo carrying tanks may not be used for cargo or
ballast under any circumstances in order for this to be an acceptable option.
If the designated non-cargo carrying spaces are used for water ballast then the ballast
arrangements should at least be in compliance with the requirements for Dedicated Clean
Ballast Tanks as given in IMO Resolution A.495 (XII). In this case the vessel would then
have to comply with all the provisions of Option (b).
Option (b) Segregated Ballast Tanks (SBT) or Dedicated Clean Ballast Tanks (DCBT):
These options are similar and can be dealt with together.
The number and arrangements of tanks to be designated for SBT or DCBT are required to
be computed in the same was as for the previous option (a). However, in addition to meeting
the 30% side or bottom protective location requirements there are additional factors that
must be considered. If the non-cargo spaces are to be used for ballast then the ballast
arrangements must at least meet the requirements of IMO Resolution A.495 (XII) Revised
Specifications for Oil Tankers with Dedicated Clean Ballast Tanks in respect of pumping and
piping arrangements. It is suggested that the remaining requirements of A.495 (XII), including
the requirement to meet the draft and trim requirements of Regulation 13(2) are complied
with, although this is not mandatory.
Having decided on the optimum arrangement of tanks to meet the above requirements, the
pumping and piping arrangements need to be considered. In most cases a cargo pump or
pumps will be required to be dedicated to ballast handling purposes, thus removing them
from cargo handling duties. If the DCBT option is chosen then, in some cases, the pump(s)
can perform a dual role dependent upon whether a common or independent system is to be
used. Resolution A.495 (XII) addresses pumping and piping aspects and requires that:
(i) There must be at least two valves that isolate each DCB tank from the piping system(s)
serving that tank.
(ii) Arrangements must be such that discharges to sea from the DCBT can be monitored by
the Oil Discharge Monitoring and Control (ODM) System and that all the pumping and
piping can be flushed to the slop tank.
The system must also be such that discharges from the slop tank and any ballast water from
the cargo tanks can be monitored by the ODM system. Where cargo and ballast handling
are to take place simultaneously, there must be two valve separation between the cargo and
ballast systems. This can be achieved by the use of valves, blanks or a combination of both.
For a system to be considered SBT, there must be no physical connection between the
ballast system and the cargo system.
In many cases it is possible to achieve an SBT or DCBT system with minimal changes to the
existing pumping and piping systems. However additional cargo/ballast piping and
associated valves may be required to be installed to achieve a suitable SBT or DCBT system
which retains the required flexibility and efficiency for the intended trading pattern of the
vessel. Similar to Option (a), a new addendum to the loading manual will be required.
For either the installation of bulkheads or fitting of double bottoms there are a number of
considerations to be taken into account including the possible necessity to relocate cargo
and ballast piping, venting systems, tank cleaning systems including crude oil washing
machines, tank access hatches and tank gauging systems.
From structural considerations, it is preferable to fit longitudinal bulkheads rather than double
bottoms. The necessary structure to support the cargo tank contents above a void double
bottom will be complex and of substantial scantlings. Additionally, such structure will
probably necessitate the complete relocation of the piping systems located in the bottom of
the tanks. Access to the double bottom spaces will also be required, but not easy to provide.
Although installing longitudinal bulkheads would be the preferable option, it remains a major
task that will require much planning. To physically install a bulkhead would require the
removal of sections of deck or the removal of sections of side plating in order for the work to
be carried out.
Void spaces, whether created by the installation of bulkheads or double bottoms, must be
provided with suitable venting, sounding, draining and access arrangements.
Since another factor is the corresponding draught of the vessel, it is permitted to carry ballast
in segregated ballast tanks to increase the draught to a larger value.
The guidelines require that hydrostatic balanced loading provides an equivalent level of
protection against oil pollution in the event of collision or stranding as would the same ship
having wing or double bottom spaces meeting the 30% coverage requirement. Calculations
are required to be carried out to establish the equivalence of the actual conditions for
hydrostatic balanced loading.
The calculations require an Equivalent Oil Spill (EOS) number to be calculated for three
conditions. An EOS number is the hypothetical outflow for defined damage cases as a
percentage of the cargo being carried in its original configuration for each condition under
consideration.
Three EOS numbers are required to be calculated for the fully loaded ship in the following
configurations:
(b) The ship with non-cargo carrying side tanks meeting 30% coverage criteria,
The EOS number for hydrostatic balanced loading should not exceed the EOS number for
the ship with non-cargo side tanks and, additionally, should not exceed 85% of the EOS
number for the existing ship arrangements.
The total number of cargo tanks required to be loaded in the hydrostatic balanced mode
need only be of sufficient number to ensure that the same level of protection is provided to
that required by Regulation 13G(7). Therefore it may be that not all cargo tanks will be
required to be hydrostatic loaded.
MEPC.64 (36) requires that the Master must be provided with an approved operations
manual for the ship operating with hydrostatic balanced loading.
Hydrostatic balanced loading requires no alteration to the ship's structure or pumping and
piping system. However, there may be potential problems from the effects of sloshing.
Where oil cargo is carried in partially filled tanks, the possibility of the natural period of the
partial cargo resonating with the natural period of ship motions in a seaway and creating
sloshing forces should be investigated. Pre-MARPOL tanker designs were generally fitted
with maximum tank breadths of about 0.4B which would preclude significant sloshing forces
in the transverse mode. Although tank lengths could be up to 0.2L, the ships were usually
fitted with a wash bulkhead at mid-tank length to dampen cargo motion. However, as
designs of pre-MARPOL tankers began taking cognisance of the MARPOL legislation being
formulated at IMO, tanks became proportionally longer and narrower. This type of tank
geometry, especially when free of internal structure, is susceptible to sloshing motions.
15(3) (a) Oil Discharge Monitoring and Control System. (ODM System)
Waivers are available from the requirements of Regulation 15 for vessels engaged solely in
short coastal voyages. In such cases all dirty ballast and slops must be discharged to
reception facilities.
Slop Tanks
• An effective tank cleaning system is to be provided, and arrangements made to
enable dirty tank washings to be transferred to a slop tank or tanks.
• The slop tank(s) should have a minimum capacity of 3% of the total cargo carrying
capacity. A reduction in this percentage is allowed if certain conditions are me
• New oil tankers of 70,000 DWT and above are to be provided with at least two slop
tanks.
Interface Detector
Prior to discharge overboard of slops or ballast from a cargo tank the oil/water interface must
be determined, to ensure that the discharge is stopped prior to reaching the oil layer.
In its simplest from an interface detector consists of a steel tape with a brass, zinc tipped,
weight on the end, with a bonding wire between tape and weight to ensure electrical
continuity. A milliameter is fixed to the body of the tape and the tape reel is equipped with an
“earthing wire” which is attached to the ships steelwork.
When the zinc tip of the weight makes contact with the salt water beneath the oil an
electrolytic couple is produced between the zinc and steel of the cargo tank. The current
passes through the earthing wire and causes the needle of the ammeter to deflect. By
carefully adjusting the height of the weight in the tank the position of the oil/water interface
can be established. An accuracy of + 5 millimetres can be obtained. Modern interface
detectors are more complex and are often able to carry out other functions such as
temperature measurement; however the principle for interface detection is basically the
same.
By measuring the level of the top of the oil layer, the total contents of the tank can be
obtained from the vessels”ullage” tables. The amount of oil and water can then be obtained.
Only the discharge of machinery space drainage should be subject to MARPOL 73/78. The
remaining discharges from processing etc. are not covered by these regulations but may be
covered by National regulations.
It should be noted that Floating Storage Units and Floating Production Units are considered
as “other platforms”.
Compliance with regulations 13 to 13F (SBT, COW, double hull, etc.) is not required, but it is
always necessary to determine from both the Flag Administration and the government of the
sea area in which the vessel will be moored the exact application of MARPOL, as local
regulations may apply.
Requirements of Minimising Oil Pollution from Oil Tankers due to Side and Bottom
Damage
This group of Regulations, dealing with the requirements for minimising oil pollution from oil
tankers due to side and bottom damage, includes regulations 22, 23, 24, 25 and 25A.
Compliance with these regulations is verified in conjunction with structural and stability
aspects at the plan approval stage. A brief description of the regulations is as follows:
MARPOL 73/78 Annex II is arranged in a similar manner to the Chemical Codes, with the
exception that there are no special requirements. Vessels must comply fully with parts of the
Annex applicable to the category of pollutant carried. When the IMO originally developed the
MARPOL Convention, one of its main aims was to deal with the pollution created as a result
of ship’s operational practices.
The fundamental principles upon which the requirements of MARPOL 73/78 Annex I were
based was that given time, oil and water would naturally separate, and that the clean water
produced could subsequently be discharged to the sea, whilst the oil or oily residues could
be retained on board for disposal to shore reception facilities.
It was noted that many chemical cargoes were miscible and hence the principle of natural
separation could not be applied. The cargo residue disposal requirements of MARPOL 73/78
Annex II were therefore based on a different philosophy.
Due to the relatively high value of chemical cargoes, sophisticated chemical tankers have
traditionally been designed to ensure that virtually no cargo residue remains on board
following discharge. The IMO decided that the Regulations should be developed to take
advantage of this design feature, and the requirements were therefore based on the virtual
complete discharge of the cargo.
Note: Pollution Category D = safety and pollution hazard (IBC Code Chapter 17)
Pollution Category D1 = pollution hazard only (IBC Code Chapter 18)
Pollution Categories
Chemical cargoes considered to pose an environmental threat have been divided into four
MARPOL 73/78 Annex II pollution categories based on their potential impact. Category A
cargoes are considered to be the most severe, with Categories B, C and D posing
progressively lesser threats. It is the aim of Annex II to discharge all cargo, such that the
residue left onboard presents a negligible risk to the marine environment. This requirement is
coupled to the pollution category of the cargo with the net result that the higher the pollution
category, the lower the permitted cargo residue.
Category A Substances
When a vessel has finished the discharge of its cargo and has lost suction on the cargo
pump, there will be a residue of cargo left in the cargo tank and associated pumping and
piping system. This small residue is considered to present a severe hazard to the marine
environment. The vessel is therefore required to add water to the cargo tank by means of a
tank washing machine. The water is used to wash the tank boundaries and to provide
sufficient liquid to enable the cargo pump to gain suction. The water is continuously added
and discharged to shore until such time as the concentration of cargo in the discharged water
meets a prescribed level. This is known as a “prewash”. The concentration is measured by
use of probes in the discharge line ashore, or by chemical analysis.
For many cargoes, probes are not available. As an alternative to the measurement of
concentration it has been agreed that the same acceptable concentrations can be achieved
by washing the tank with a calculated minimum quantity of wash water whilst continuously
pumping the residues to shore.
Once it is agreed that the tank is clean, the vessel may proceed to sea. If the Master wishes
to add further water to the tank for ballasting, washing to commercial requirements, etc., this
will require that the water/cargo residue mixture generated must be discharged under the
following conditions:
• The ship is in water of 25m depth or more;
• The ship is en route at 7 knots or more;
• The ship is at least 12 miles from land;
• The mixture is discharged below the waterline using the “Underwater Discharge
Outlet”.
Any further water added to the tank can be discharged to sea without restriction.
• The mixture is discharged below the water line using the ‘underwater discharge
outlet’, or diluted
• Any further water introduced into the tank can be discharged to the sea without
restriction
Category D Substances
Category D substances are the least noxious of the chemical marine pollutants and therefore
have the least severe discharge requirements.
The cargo is discharged to the maximum possible extent prior to departure from the
unloading port. If the Master wishes to add water to the tank for any reason, this is in order
provided the following conditions are met before the cargo/water mixture is discharged:
• The cargo residue has been diluted in the ratio of 10 parts water to one part cargo;
• The ship is en route at 7 knots or more;
• The ship is at least 12 miles from land.
STRIPPING QUANTITIES
To ensure that the ship’s Certificate of Fitness contains the maximum possible number of
cargoes, it is usual to design the ship to satisfy the most onerous stripping criterion, that is
the 100 litres per tank associated with carriage of Category B substances.
To achieve this negligible residue quantity, modern chemical tankers are constructed with
smooth walled tanks which cannot entrap the cargo, and with a discharge and stripping
system which is designed such that virtually no cargo is retained within the pump and
associated piping system. The deepwell or submerged cargo pump is located in a recess or
sump within the tank. The discharge piping leads to the deck and finally to the tank’s
dedicated cargo manifold. The cargo discharge system on modern chemical tankers is very
simple whilst being highly efficient.
Sophisticated chemical tankers such as those currently building, easily achieve the maximum
permitted residue quantities, with some ships achieving residues as low as 20 litres per tank.
In order to verify that the vessel can achieve the maximum allowable quantities specified for
category B and C substances it is necessary to carry out a functional test of the cargo tank
stripping system. This test is called the “Stripping Test” and is carried out on all new vessels
(1/3 of tanks to be tested), and on existing vessels whenever they modify their pumping and
piping system (any tank modified to be tested) or carry out a MARPOL 73/78 Annex II
renewal survey (two selected cargo tanks to be tested). Stripping tests are only required on
vessels carrying category B and C substances, and full details of the requirements are
contained in the Survey Procedures Manual.
Stripping Tests
• Category A - No requirements
• Category D - No requirements
Sufficient water is introduced to the tank to be tested to enable the cargo pump to gain
suction. The ships trim and list are kept to the absolute minimum. A device, usually a
constant pressure valve, is provided to maintain a constant 1 bar back pressure throughout
the operation. The cargo tank is discharged and stripped, and lines blown as they would be
during a normal tank discharge operation. The manifold valve is then closed; all valves
opened and drain plugs removed. The stripping residue is the total volume taken from the
cargo tank suction well, the cargo pump and all pipelines including the manifold.
>=10m
Cargo piping
Ship’s deck
Ships side
Cargo piping
Pressure gauge
Ship’s deck
Ships side
Boundary layer
Underwater
discharge
outlet
The opening size is based on the discharge pump capacity and the distance of the outlet
from the bow.
• Contains full details for ship’s staff on how to comply with the operational
requirements of Annex II
The remainder of the Manual is made up of the vessels cargo list, flow charts, ventilation
procedures, details of the tank washing machines, compatibility charts, results of the
stripping test and plans of the vessel.
• Pollution category
• Melting point
• Viscosity
• Miscibility in water
The Manual contains a Table of the permitted cargoes, which reflects the cargo list attached
to the Certificate of Fitness. The information in this Table includes anything necessary to
discharge the residues properly and includes details on melting point, viscosity, suitability for
ventilation and miscibility in water.
This Manual must be approved by the Flag State and placed onboard the vessel.
When LR approves the Manual on behalf of the Administration, approval is subject to
verification of the arrangements onboard against those stated in the Manual, and satisfactory
completion of cargo tank stripping tests. When these items are completed by the attending
surveyors the Manual is endorsed accordingly on the approval page.
Approval of Manual written for the carriage of Pollution Category ‘D’ cargoes only would not
be subject to completion of stripping tests.
The Manual is also used by Port State officials to verify that the cargo tanks are being
discharged in the correct manner to achieve the required stripping quantities. This is why the
stripping test should be carried out under the most difficult conditions likely to be experienced
in practice. A failure to comply with the procedure laid down in the Manual would lead to the
vessel being required to carry out a pre-wash in port, and for all residues to be discharged
ashore, which is a very expensive operation.
ABCD
LR No.
APPROVED
for and on behalf of the Government of the vessel’s Registration as complying with the
Regulations stated below.
Signed Date:
Signed Date:
Signed Date:
LR No.
APPROVAL HISTORY
Original approval:
Changes:
Special Areas
For certain sea areas, identified as "Special Areas", more stringent discharge criteria are
given. Under Annex II the Special Areas are the Baltic Sea Area, the Black Sea Area and
the Antarctic Area.
MARPOL 73/78 Annex II defines these areas as follows;
• The Baltic Sea Area means the Baltic Sea proper with the Gulf of Bothnia, the Gulf of
Finland and the entrance to the Baltic Sea bounded by the parallel of the Skaw in the
Skagerrak at 57° 44.8’N.
• The Black Sea Area means the Black Sea proper with the boundary between the
Mediterranean and the Black Sea constituted by the parallel 41° N.
• The Antarctic Area means the sea area south of latitude 60° S.
d) Incinerators;
1 “Ship Constructed “means ships the keels of which are laid or which are at a similar stage of construction. See also IACS
interpretation MEPC 8.
2 A ‘ship’ is defined in Article 2 of the International Convention for the Prevention of Pollution from Ships, 1973 as “as vessel of
any type whatsoever operating in the marine environment and includes hydrofoil boats, air cushion vehicles, submersibles,
floating craft and fixed or floating platforms.”
3 Applies to diesel engines installed on ships constructed, or engines which undergo a major conversion, on or after 1 January
2000.
4 Conference resolution.6 of MP/conf.3/35 invites the MEPC to develop the harmonised system of survey and certification to
replace the existing regulations 5 & 6 of Annex VI if MARPOL 73/78 and initiate action to amend it immediately upon entry
into force.
To assist in completing the survey a draft provisional survey checklist has been developed.
Plan Appraisal
Fire fighting systems - Fire plans are to be examined for compliance with the requirements
of MARPOL Annex VI when they are examined for SOLAS and class requirements.
6 Some countries are known to have banned their manufacturers from supplying systems with certain refrigerants though they
may be acceptable to the Flag Administration. In such instances, installers may supply on site different gases to those
recommended by the manufacturer.
The approved Technical File provides details of the allowable engine; components, settings,
operating values and allowable adjustments which ensures the engine will continue to
operate within the acceptable NOx emission limits.
Each EIAPP certified engine is subject to an on-board verification survey after installation on-
board as part of the initial IAPP survey. This verification procedure, contained in the
Technical File, is approved from the following available methods:
Where an engine has no EIAPP certificate, (i.e. not pre-certified) certification will be required
prior to issue of the ship's IAPP certificate7. Normally this will entail emission testing of the
engine on-board in accordance with the full test bed requirements or, in extreme
circumstances removing to a test bed.
Note, it is the shipowner who nominates the method to be used to demonstrate compliance
not the flag state authority. The flag state is responsible for the acceptance and approval of
the method. The engine builder will need to supply the necessary supporting equipment,
facilities and information from the outset.
7 Note: prior to entry into force certification is not required, it is an owners option. After entry into force of MARPOL Annex
VI, EIAPP certification for engines installed on ships constructed on or after January 1, 2000, is mandatory.
Identifying which engines are required to be certified and have an approved NOx Technical
File, and that they all have NOx Emission pre-certification (EIAPP).
A review of the engine certificates and NOx Technical Files including ensuring that the NOx
Technical files have been approved.
Verifying:
• The engine, its components, settings, and operating values remain within the limits
specified in the approved NOx Technical File by performing the on-board verification
procedure.
• The duty stated on the EIAPP certificate equates to the installed duty, e.g. D2 =
constant-speed auxiliary application, etc.
• That the cooling system is in line with that approved for the installation.
• Verifying that an Engine Parameter Book is provided for each engine. This is used
to record all modifications and adjustments to an engine that effect its emission
characteristics including details of the replacement of parts.
• Verification that the engine data logging systems are in place and operational. The
data logging system will vary from ship to ship and engine to engine but may consist
of the engine room logbook, telegraph records both from the engine room and
bridge, and any automatic recording devices fitted to a particular engine.
• The on-board engine verification should take advantage of the engine installation
and commissioning periods to check the component marking and settings to
minimise the degree of inspection required later.
• That the exhaust cleaning or other NOx reduction system, where fitted, is
operational.
In service surveys
In service surveys will form part of the MARPOL Annex VI annual, intermediate and renewal
surveys. On satisfactory completion of the survey, the IAPP certificate will be endorsed to
show that the annual or intermediate survey has been completed. In the case of a renewal
survey, a new certificate valid for a maximum of five years will be issued.
The surveys will consist of:
• Identifying which engines are required to be certified and have an approved NOx
Technical File.
• A review of the engine certificates (EIAPP) and NOx Technical Files including
ensuring that the NOx Technical Files have been approved.
• Verifying that the Engine Parameter Book for each engine exists and is up to date
and relevant entries correctly completed. It should contain records of: work carried
out on the engine such as modifications, setting adjustments, component
replacements, and details of engine manufacturers technical notices appertaining to
the engine, details of approved modifications, etc., properly entered, signed by either
the Chief or Second Engineer or Manufacturer's Representative as appropriate and
dated.
• Verifying that any modification, adjustments, or replaced parts conform to the engine
specification and parameters in the NOx Technical file.
• Verification that the engine data logging systems are operational and that the data
records are current. Review engine data for trends, which may indicate possible
engine problems relating to NOx emission non-compliance.
• Verifying that the engine, components and settings are as detailed in the NOx
Technical File, i.e. that no modifications or adjustments have been made, by a
survey in accordance with the on-board engine verification method specified in the
approved NOx Technical File for the engine.
At this time the engine parameter method is the preferred route for verification surveys as
selected by the engine manufacturer and is the one currently provided for in the Technical
File.
The simplified method of on-board verification could be problematic since it is difficult to
obtain steady state conditions for each mode of the appropriate test cycle. The test
equipment must be calibrated in strict accordance with the NOx Technical Code.
The on-board direct measurement and monitoring method of on-board verification is not
yet available since the criteria for the recording equipment and its sensitivity have still to be
documented by IMO.
Where fitted, verify that the direct NOx measurement system is calibrated and operated in
accordance with the manufacturer's operational recommendations and that the records are
available.
Where fitted verify that the exhaust cleaning or other NOx reduction system is operational
and being operated in accordance with manufacturer's recommendations.
Surveys
Though this regulation is operational, the following initial and periodical verifications surveys
should be made.
Initial Survey
Confirm the approved arrangement used on board for compliance with this requirement and
verify it has been installed and commissioned.
This could be:
• Separate fuel tanks for the two sulphur grades of fuel (4.5% and 1.5%).
• An approved exhaust gas cleaning system.
• An alternative equivalent approved system.
In Service Survey
Confirm the approved arrangements used on board for compliance with this requirement
remain as installed and operational.
Verify records of fuel change over (times, position and fuel tank capacity) are recorded in the
official log book as relevant.
Review the bunker notes to verify the quality of fuel carried onboard is in compliance with the
requirements for sulphur content (see Reg. 18).
Plan Approval
If a Vapour Emission Control system is fitted, plan approval and a survey of the system is to
be carried out to verify its compliance with IMO MSC/Circ.585 in accordance with the
requirements of the Administration. This would be done in conjunction with verification of the
VEC system for the US Coastguards requirements. A VEC system consists of the following
main components:
• An inspection of the general condition of the incinerator and tests of the safety
systems. Refer to "Incinerator Test Report Rev 06" available from the LR web-site10
for the tests involved at the different stages.
Survey
The survey will consist of:
• Verifying that the bunker delivery notes are on board and retained for at least the
previous three years ( refer also to Reg. 14).
• That bunker samples are being retained onboard for a period of at least 12 months.
Introduction
This survey is carried out after installation on board the ship to verify the engine's
components, settings and adjustments remain within the limits established at the NOx
emission test bed trial (Pre-certification) as recorded in the approved Technical File.
Provided these conditions are maintained, the engine is considered to remain operating
within the NOx Emission limit for its category. It being accepted that if the NOx sensitive
components and settings remain the same, then the engine will remain compliant with the
NOx emission limits. Thus, it is not necessary to carry out another NOx emission test.
At each survey the engine would be inspected in accordance with the approved procedure in
the Technical File. The degree of stripping down would be sufficient to allow the NOx
sensitive components, settings and adjustments to be verified. In the real word this may not
always be possible, though still desirable, thus we need to consider the tools currently
employed for engine surveys and use them to our advantage without losing sight of our
responsibilities under our authorisation to carry out this statutory survey. Whichever
combination of methods are used, they must provide verification and confidence that the
engine remains in compliance.
The surveyor shall have the option of checking one or all of the identified components,
settings or operating values to ensure that the engine with no, or minor, adjustments or
modifications complies with the applicable emission limits and that only components of the
current specification are being used, Where adjustments and/or modifications in a
specification are referenced in the technical file, they must fall within the range
recommended by the manufacturer and approved by the Administration..
Where a combination of methods are used to verify compliance, such methods should be
applied with due care and diligence and only by surveyors who through experience
understand the techniques along with their limitations.
While looking at possible survey methods available, it is equally important to understand the
variations in components and settings which affect the engine emissions to appreciate their
limitations while maintaining full confidence in the surveys undertaken.
Survey Methods
Warning, this is not a list of acceptable alternatives to direct survey, but methods which may
be utilised periodically in conjunction with the direct surveys while still maintaining confidence
in the engine's compliance.
11 This is supplied by the Owner in which the Owner's representative records details of engine maintenance, modifications,
updates to the engines received from makers, etc.
The Technical Code Procedure (This will always be the preferred method)
The Technical Code specifies requirements for the on-board verification survey.
• Documentation Review. A review of the documentation for each engine which includes
the engine parameter book to ensure the components, settings and adjustments
recorded remain within the designated limits. This may be supported by the engine log
book.
• Carry out the on-board verification survey in accordance with the procedure provided in
the engine's NOx Technical File.
• Where an engine is provided with an after treatment device such as an SCR (Selective
Catalytic Reduction) system, a check of its operation forms part of the survey. This
holds true for other NOx abatement systems such as for injection of water, steam, etc.,
into the cylinder or fuel to aid combustion.
These may be used in conjunction with the direct survey procedure to limit the degree of
opening up at intermediate surveys. For renewal surveys, it is recommended the full survey
is conducted.
• Operational test under load Allows comparison and assessment of the engine
operating parameters against those in the approved NOx Technical File. This could be
used to limit the degree of opening up required after confirming the easily accessible
components and settings are acceptable. Useful for the smaller engines driving pumps,
etc. Also for generators which are in operation, where it is not feasible to carry out the
full direct inspection.
• Engine Log Book Reviewing the engine log book data for the past few months, can
provide an insight into the engine condition through trends or variations in temperature
and pressure records of coolants, exhaust gas, fuel and lubricating oils and scavenge air.
Similarly, with reviewing records of indicator cards or peak pressures, etc., taken from the
engine. From these sources, gradual or rapid changes in the operating conditions can
be identified to provide an indication of deteriorating conditions or changes in settings or
adjustments which could result in the engine operating outwith the emission limits.
The system considered here is the Engine Parameter Check Method (verification of the
NOx sensitive components), which at present the Technical Files are documenting as the
most likely system to be operated by the Owner.
The following provides a general guide for some of the main components, settings and
adjustments, which may be encountered during a survey12. When carrying out the survey,
the surveyor is to use the On-board NOx verification survey procedure provided in the
approved NOx Technical File, which lists the specific information and data for the engine
under survey.
The approved on-board survey method will define how to carry out the inspection/verification
of the various parameters or parts and can vary between manufacturers. The following are
provided as guidelines where this is not clear or alternatives may be considered.
Verifying the cylinder head, piston, piston rod (connecting rod) and shims where relevant,
would be the normal method used. However, the compression ration may be checked by
taking compression readings for each or selected cylinders. Other means are to check the
travel of the piston and to verify that the correct shims have been used where applicable.
Care must be taken, since the wrong type of cylinder head or piston could alter the
combustion space characteristic geometry, i.e. flow / swrill. This may not be easily observed
from travel measurements only. Variations in the combustion space / geometry can have an
effect on the NOx emissions produced due to changes in the combustion process.
Cylinder Head
Normally identified by its identification number (ID), which is usually in an accessible position
without opening up.
The NOx emissions may be altered if the combustion chamber geometry of the cylinder head
is modified, affecting NOx formation mechanism and therefore emission characteristics.
Turbo-chargers
Turbo-chargers are sized to suit the engine power and operating characteristics. Therefore
changes to their component parts (impellers, diffuser, etc.) will affect the combustion and
hence the NOx emissions. Each major component is marked and at classification surveys
their NOx identification number should be verified. Then at periodical Annex VI surveys it
would be sufficient to verify the correct type of turbo-charger is fitted provided no modification
had been carried out. Modification details can be confirmed from the records in the engine
book of engine parameters.
12 This information is for guidance only and therefore does not provide details for all types of engines which may be
encountered.
Note: The Technical File is approved for a particular cooling system and associated
temperature set points. Always consult the approved survey procedures for that engine.
Note: Fuel Pumps in the common rail system are not defined as NOx sensitive components.
Injection timing depends on the system employed. Many of the smaller engines (Member's
of family) use pre-set electronic timing, which cannot be adjusted by the ship's staff.
In other engines, (e.g. members of an engine group) the timing can be altered by re-
positioning the camshaft, the timing chain, drive wheels or fuel cam or its profile or software
parameters in common rail applications. These items are all marked with an identifier plus
the original settings to facilitate verification checks. They can normally be reviewed by the
removal of a cover and turning the engine to the correct position in accordance with the
approved procedure.
Frequently Asked Questions - MARPOL Annex VI And The NOx Technical Code
NOTE: Frequently asked questions relating to Regulation 13, Certification of Marine Diesel
Engines for compliance with the NOx Emission limits, are contained in a separate document,
"Emissions of Nitrogen Oxides from Marine Diesel Engines Questions and Answers, Sept
2001," available on LR Intranet or Internet : Path - www.lr.org / cdlive / Approval Lists / NOx
Emissions
certificate and valid for five years. To maintain its validity annual and
intermediate surveys will be required. At the end of the five-year period of
validity a renewal survey will be required in order for a new certificate or
statement to be issued. The surveys required can be shown on the ships
survey status on ClassDirectLive.
Q Can LR certify diesel engines for compliance with the NOx Technical Code?
A Yes. However, procedures for NOx code certification are not dealt with in these
guidelines13.
If a request is received for NOx Code certification, contact Engineering Systems,
London for instructions.
13Procedural documents are available on the LR web site at Path: www.lr.org / cdlive / Approvals List or www.lr.org / cdlive
/ login / information / Approvals. Note: By logging in to cdlive LR staff have access to all documents, whereas on front end of
cdlive only those accessible to clients are available..
Bunker Note
+ Sample
A Working Group met during the session and developed the following:
STUD
VAPOUR
MAST RISER
L H
h hh
LEVEL GAUGE
VAPOUR CARGO MANIFOLD
OIL
• Emptying and filling of the ballast holds of bulk carriers and ballast tanks in other
ships may require consideration of sloshing loads on the ballast hold/tank
boundaries. On existing bulk carriers in particular substantial structural
reinforcement may be required
• The structure of topside and hopper tanks adjacent to the ballast hold may require
enhancement and reinforcement if it was proposed to empty and fill these spaces
whilst maintaining a full ballast hold.
• The bending moments and sheer forces must be kept within the approved limits
and on some ship designs torsional stresses may also need to be considered.
• A ship must be operated within its allowable stability margins, to meet both intact
and damage stability criteria. The main effects on stability will be free surface
effects from slack tanks and with the "Flow Through" method, from free water on
deck. The effects of free surface must be carefully considered as it can easily be
underestimated.
• When using the "Flow Through" method water on deck poses additional hazards
particularly for ships with deck cargoes. Additional top weight can be added from
water on deck, water can be absorbed by deck cargo, and in cold weather by ice
formation. Adequate arrangements must be made to ensure crew safety when
working on deck where free water exists.
• The dangers of having to stop the complete exchange of ballast water before
completion, due to unfavourable weather conditions or other factors, must also be
taken into account.
• An adequate draft and propeller immersion must be maintained for the intended
voyage and the prevailing and expected weather conditions. The trim must also
be maintained to ensure bridge visibility is not affected and such that slamming is
avoided.
• An existing ship may need some modification to the ballast pumping and piping
system, particularly if the "Flow Through" method is used. For new ships the
requirements of ballast water exchange must be considered at the design stage of
the ballast system.
• The ship must at all times be operated within its allowable stability margins, both
intact and damage stability criteria.
• Other factors include the prevailing and predicted weather and crew safety when
working on wet decks.
In order to ensure ballast exchange can be carried out safely each ship is required to
have a “Ballast Water Management Plan” which details the procedures for the ship,
the hazards, limitation and contingency measures.
It can be seen that ballast water exchange needs to be very carefully considered by
owners and the ships staff to ensure the safety of the ship. This includes the need for
proper training. Carrying out ballast water management practice at sea should not
result in placing the ship and its crew in hazardous situations. Operationally ballast
water management practice will require ships staff to undertake procedures which
they may well not be familiar with. It is therefore very important that the ships staff
involved in ballast water management receive proper training and that sufficient
guidance is provided onboard concerning the possible hazards involved and the safe
practices to be followed to ensure the safety of the Ship and its crew.
The International Association of Classification Societies (IACS) are concerned about
the safety aspect of ballast water exchange and have undertaken a study to
investigate the possible problems that can be associated with ballast water exchange.
The first stage of this was presented to the IMO in 1998. IACS will continue to
monitor the progress of the regulations and advise the IMO on safety issues. Lloyds
Register has also been investigating the safety aspects of ballast water exchange and
has been working closely with IACS.
4. Active ingredient(s) and their Chemical Abstract Service Registry Number (CAS
number(s)).
Part A
Contains mandatory provisions to which specific reference is made in the annex to the
STCW Convention and which give, in detail, the minimum standards required to be
maintained by Parties in order to give full and complete effect to the provisions of the
STCW Convention.
Part B
Contains recommended guidance to assist Parties to the STCW Convention and
those involved in implementing, applying or enforcing its measures to give the STCW
Convention full and complete effect in a uniform manner.
Specialised Training is required for tankers. Additional training for officers and ratings
is:
i. Fire fighting, and,
ii. At least 3 months of approved seagoing service on tankers; or
iii. Attendance at an approved tanker familiarisation course.
Above An International Load Line Certificate with the grid to be marked on the ship's side shown shaded
on the front page and the corresponding freeboard dimensions detailed above it.
9.4.1 General
What is a Load Line and what is freeboard? Basically a Load Line is the horizontal
marking on the side of a ship indicating the maximum draught down to which it is
permitted to load. There may be a number of Load Lines marked on the side of a ship
at one time and these form what is commonly known as a Load Line grid as shown in
the illustration above. Each Load Line on a grid is annotated with grid letters relating
to the conditions under which it is permitted to be used. The use of the individual lines
is governed by the following (corresponding grid letters are shown in brackets):
1. The seasonal time of year in the location where the ship is operating in salt water
e.g. Summer (S), Winter (W)
2. The geographical zone in which the ship is operating in salt water e.g. Tropical
Zone (T)
3. A combination of seasonal time of year and geographical location when operating
in salt water e.g. Winter North Atlantic (WNA)
4. When the ship is not operating in salt water e.g. Fresh Water (F)
5. A combination of the geographical zone and when the ship is not operating in salt
water e.g. Tropical Fresh (TF)
6. In addition when a ship is carrying a timber cargo on deck which has been loaded
in accordance with the 1966 International Load Line Convention (1966 ILLC) it
can also be permitted to load down to one of a set of timber Load Lines. These
timber Load Lines allow the ship to load to a deeper draught than normal due to
the additional buoyancy afforded to the ship by the cargo and the protection it
offers to the upper deck from seas. If timber freeboards are assigned the
corresponding Load Lines are marked on an additional grid aft of the Load Line
disc. Timber Load Line grid designations are, in most cases, formed by the
standard grid letter prefixed with the letter 'L' e.g. Where 'S' is used to indicate the
summer Load Line 'LS' would be used to indicate the timber summer Load Line (L
meaning lumber).
Above an example of Load Line markings including timber Load Lines (grid shown left of disc)
The type of grid letters are used is ultimately dependent on the country of registration
of the ship and before any Load Lines are marked the flag requirements should be
established. In some instances the more commonly used grid letters are replaced by
letters corresponding to the national language e.g. for Danish flag ships 'W' for Winter
is replaced by 'V' for 'Vinter'.
In addition to the grid letters, designatory letters are marked above the horizontal line
through the Load Line disc, these indicate who was the assigning authority e.g. The
use of the letters 'LR' indicates that Lloyd's Register was the assigning authority. It
should be noted that, in some instances regardless of whether the Class Society
assigned the Load Lines on behalf of a flag administration, the assigning authority's
mark will remain that of the flag administration. LR assigns the freeboards for Danish
flag ships but instead of 'LR' being marked beside the Load Line ring the letters 'DL'
are marked instead thus indicating that the assigning authority was the Danish
Administration. As for grid letters the existence of flag requirements for assigning
authority markings should be established before marking Load Lines.
It is important to note that although Load Lines govern the maximum permissible
draughts in varyious operating conditions their primary purpose is in fact to ensure a
minimum freeboard is maintained. Generally speaking freeboard is the distance from
the sea level to the exposed weather deck of a ship and it is clear therefore, that a
minimum freeboard is required to ensure the integrity of the hull is maintained, thus
preventing ingress of sea water. In addition adequate freeboard will ensure that the
crew can go about their duties on deck safely and without fear of being washed
overboard. Adequate freeboards will also reduce the likelihood of cargo being
damaged.
In reality the actual freeboards of a ship are the distances from the deck line marked
on the side of a ship down to each of the horizontal Load Lines of the Load Line grid
as described previously. The deck line is a 300mm horizontal line 25mm deep
marked on the side of the ship at amidships. The top of the deck line is normally in
line with the top of the deck designated as the freeboard deck. Sometimes the deck
line is marked a known distance below the top of the freeboard deck for practical
marking reasons such as the ship having a rounded gunwhale.
The freeboard deck of a ship is normally the uppermost complete deck exposed to
weather and sea, which has permanent means of closing openings in the weather part
thereof, below which all openings in the sides of the ship are fitted with permanent
means of weathertight closing. The word 'normally' should be noted in the definition
of the freeboard deck as it is frequently the case in ships which are non deadweight
carriers such as Container Ships that a deck below the uppermost complete weather
deck is designated the freeboard deck. In the case of Container Ships the freeboard
deck quite often corresponds to the passageway deck.
Above arrangement of Load Line markings including grid, disc and deck line plus standard dimensions.
9.4.2 History
The subject of freeboards is as old as mans' attempts to conquer the seas and the
allowance for and provision of freeboard was initially based on a combination of the
best practice of the period based on the basic human instinct for self preservation
when confronting adversity. It is, however, of interest to note that ancient Venetians
took the subject of provision of freeboards more seriously than most and actually had
regulations covering the subject incorporated in their laws.
For a substantial period of history, as ships grew larger and longer journeys were
being made at sea, the loading of ships and provision of freeboard was usually still
governed by common sense and safety considerations. It is however fact, that
although the maximum load draught of ships was being recorded in Lloyd's Register
Book from 1774, there was no prescribed method of how the figure was determined.
Up until 1835 the maximum loading draught of a ship was decided by the ship's owner
who, in more and more cases, did not form part of the ships complement. The owner
did however, have a financial incentive to carry more cargo on each of his ships and
not surprisingly, the recorded load draughts and actual loading of ships was
excessive, leading to the losses of hundred of ships a year around the British Isles
alone.
In 1835 following conflicts between interested parties such as owners, shippers and
underwriters the Committee of Lloyd's introduced "Lloyd's Rule" which proposed a
freeboard of 3" (approx 75mm) per foot (approx 300mm) depth of hold and this rule
was used extensively up until 1880. The first compulsory regulations for the loading
of ships was introduced in the 1890 Merchant Shipping Act. Lloyd's Register had
made freeboard a condition of classification in 1873 and was, therefore, the first public
body to require a Load Line. The requirements for the compulsory marking of deck
lines and Load Line discs on the side of ships was introduced in the 1876 Merchant
Shipping Act but the formal tabulated minimum required freeboards setting the
location of the Load Lines was not introduced until 1890.
The tables of minimum freeboards were known as the "Board of Trade Tables" and
were formed as a result of a report issued by Lloyd's Register's Chief Surveyor Mr
Benjamin Martell in 1882 and the work done by Sir Digby Murray. The compulsory
marking of deck lines, a Load Line disc and draught marks on the side of ships can be
attributed to the, work of the famous Samuell Plimsoll from whom the name Plimsoll
Line is derived, and the equally important work of the almost unknown James Hall.
James Hall campaigned tirelessly on the subject and supplied Plimsoll with many
illustrations of cases of overloading and ideas for his reform programme.
The first international conference on Load Lines was held in 1930 and the findings
became known as the 1930 International Load Line Convention. It was with the
introduction of the 1930 Convention that, for the first time, there was an international
agreement between maritime nations on the method of calculating required
freeboards and the conditions for their assignment.
As a result of changes in ship design, defects seen in the 1930 Load Line Convention
and changes in philosophy the 1930 Load Line Convention was replaced by the 1966
International Load Line Convention which came into force on the 21st of July 1968.
The 1966 Convention which remains in force has been ratified by 142 countries which
represent 98.34% of the worlds merchant shipping fleet. The following criteria were
used as the basis for assessing the required freeboards:
• Prevention of entry of water through exposed parts of the ship
• Probability of deck wetness in relation to bow height
• Maintenance of sufficient reserve buoyancy in normal conditions of service
• Protection of crew when moving about the ship
• Adequate structural strength of the ship
• Stability and compartmentation
As a result of the 1966 Load Line Convention some of the changes included:
• Freeboard length of a ship fixed according to its depth
• Categories of ship types totally revised
• Ship's required to have a specified minimum bow height
• Ship's required to have both approved loading and approved stability
information
• Requirements for number, height and support of guard rails and bulwarks
The reduction in freeboards for type 'B-60' ships is based on the ship complying with
additional conditions laid down in the convention covering the following:
• The protection of crew
• freeing arrangements
• hatch coamings, covers and their height, strength, sealing and securing
• Damage stability requirements (single compartment standard)
For type 'B-100' ships they must comply with all the conditions for assignment of 'B-
60' freeboards plus additionally requirements covering the following as if the ship were
a type 'A' ship:
• Arrangements for machinery casings
• Arrangements for gangways and access
• Arrangements of open guard rails height of sheerstrake
• Damage stability requirements (two compartment standard)
Type 'B+' ships have had their freeboards increased because their hatch covers do
not comply with either regulation 15(7) (re. Pontoon hatch covers) or regulation 16 (re.
hatchway coamings, weathertight covers and means of securing covers and
maintaining weathertightness).
When the Load Line ship type has been established the tabular freeboard is simply
obtained by referencing the correct table, for type 'A' ships or for type 'B' ships and
reading of the freeboard that corresponds to that required for the ship according to its
freeboard length.
Freeboard length is defined is the greater of the following two measurements taken on
a waterline at 85% of the least moulded depth measured from the top of the keel:
• 96% of the total length from the fore side of the stem to the after side of the
stern, or
• The length from fore side of the stem to the centre line axis of the rudder
stock.
(Cb + 0.68)
1.36
L
D− .R
15
Where the depth is less than one fifteenth of the freeboard length then the freeboard
can be decreased provided the ship's arrangement provides superstructures and
trunks on the freeboard deck to the extent required by the Load Line Convention.
The sheer correction to the freeboard is then obtained by multiplying the deficiency or
excess of sheer by the result of the following formula:
S
0.75 −
2.L
Where S = The total length of enclosed superstructures as defined in Reg.34 of the
Load Line Convention.
Should the effective length of the superstructure be less than the freeboard length of
the ship then the deduction in freeboard is dependent on the proportion of the
freeboard deck covered by superstructures, the type of superstructure and the Load
Line type of ship i.e. type'A' or type'B'.
ft of
fitted a cated on
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Positio d on a sup e
locate recastl
even if such as a fo
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1 fre
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Posi
Freeboard Deck
Position 1 Upon exposed freeboard and raised quarter decks for their entire length,
and upon exposed superstructure decks situated forward of a point located a quarter
of the ship's length from the forward perpendicular.
Position 2 Upon exposed superstructure decks situated abaft a quarter of the ship's
length from the forward perpendicular.
It should be noted that for a opening to be classed as being in position 2 the then it
must be upon a deck the height of which is at least one standard superstructure
height (see table 9.4.3.1) above the freeboard deck.
A requirement for the satisfactory completion of the PLI is that the class annual survey
has been satisfactorily completed.
Ventilators
The ventilators surveyed are those required to comply with Regulation 19 of the 1966
Load Line Convention. In general ventilators lead to dry spaces such as holds, stores,
accommodation and machinery spaces.
Ventilators are frequently located in exposed positions and are subjected to sea water
spray possibly resulting in wastage both internally and externally on covers and flaps.
The surveyor will look inside the cover to check the condition of the gaskets and
retaining channels. Where vent ducts and casings are welded to the deck rather than
actually penetrating the deck grooving of the casing directly above the deck may
occur due to an accumulation of moisture.
When considering the dimensions of ventilators the minimum height from the deck on
which they are fitted to its effective downflooding point must equal a minimum of
900mm in position 1 and 760mm in position 2. Ventilators are to be substantially
constructed and have coamings made of steel. It should be noted that ventilators in
excess of 900mm in height are to be specially supported, typically brackets are fitted
and welded at the base of the ventilator and to the deck. It is most important that
when fitting the brackets to the deck they are correctly aligned with underdeck
structure such as longitudinals, it may be necessary to fit additional structure such as
carlings to prevent the brackets puncturing the deck.
Air Pipes
The air pipes surveyed are those required to comply with Regulation 20 of the 1966
Load Line Convention. Air pipes lead to tanks, cofferdams, void spaces and other
spaces which can be pumped out. As a result of air pipes being required to be fitted
with automatic closing devices and the fact that they serve spaces which are often
filled or emptied of liquids it is imperitive that the closing device is operative at all
times. Obviously the primary purpose of the automatic closing device is to prevent the
entry to the tank of sea water, however it must perform the function of allowing air out
during filling of the tank and air in when emptying the tank. Failure of the closing
device can lead to catastrophic failure of the tank due to excess pressure or vacuum.
Due to the importance of the closing device they are to be of an approved type with
removable access panels so that the float and seating can be easily examined. In
addition the devices are to be self draining with casings manufactured of an approved
metallic material adequately protected against corrosion. In addition air pipes leading
to cargo, fuel oil, diesel oil and lub oil tanks are required to be fitted with spark
arresting gauze to prevent explosions.
From the base of the air pipe at the deck level on which it is fitted up to the point
where water may flow into the tank which the air pipe is serving the minimum height of
the coaming must equal 760mm if the deck is the freeboard deck. If the deck on
which the air pipe is fitted is a superstructure deck then the minimum coaming height
is 450mm.
Air Pipe Types
As discussed earlier, if the closing devices are not working efficiently, tank over
pressurisation can occur with catastrophic results as illustrated below.
Similarly vacuums in ballast holds can result in severe damage (shown below).
Sounding Pipes
Clearly marked as to which space they serve these are fitted to all tanks plus dry
spaces such as cofferdams and cargo holds. Below the upper deck, inside the tanks,
holds or spaces the sounding pipes that run through them are normally examined
during the internal examination of the space concerned. The remaining section of the
sounding pipe above the upper deck is examined during the Load Line survey along
with the closing arrangement such as threaded steel cap.
Sounding Pipe with Screw Cap Flush Type with Threaded Plug
Below, Regulation 12 doors, gasketted and with clips. These can be fitted in Position 1.
Below, A selection of access hatches some of which are obviously in need of repair.
The primary function of hatch covers is to maintain the weathertight integrity of the
ship by effectively closing the hatchway used for loading and unloading cargo. The
basic types of hatch covers are:
• Mechanically operated weathertight steel covers including side rolling, single
pull, hinge and ram, folding and end rolling hatch covers
• Steel pontoon weathertight hatch covers
• Steel pontoon covers with tarpaulins
• Portable covers with tarpaulins
• Flush deck hatch covers
Testing for weathertightness of hatch covers during the Load Line survey is usually
confirmed by hose testing. During hose testing a jet of water from a 12mm
diameter nozzle with a pressure of 2Kg/cm² is directed at the joints and gasketted
areas of the hatch covers from a distance of not more than 1.5metres. Host tests
can be difficult to conduct satisfactorily. With only one surveyor available it is hard to
check for leaks whilst at the same time ensuring that the crew are directing the hose
jet correctly and from the correct distance. If a trickle of water is detected leaking
through the sealing arrangements the actual defect area can sometimes only be found
by chalk testing.
Above left, if the hatch cover is not tight then sound waves escaping the hold can be
detected with sensing equipment (above right)
Side Rolling Hatch Cover Single Pull Hatch Cover Side Coaming
Above, End Rolling Hatch Cover Open and Above, Portable Covers with Tarpaulins
Closed with Tarpaulins (top)
Above, Folding Flush Type Covers Open Above, Folding Flush Type Closed
Above, Quick Adjusting (QA) Cleats (NB Above, Hatch Cover with cardboard
painted compression rubber (left) and discovered covering a hole.
wasted shank (right)).
• Call an LR surveyor and carry out repairs as soon as possible when there are:
Indications of excessive corrosion e.g. holes or local buckling of the top plate
Cracks in main structural joints
Areas of significant indentation, other localised mechanical damage
• Rectify any steel-to-steel fault before renewal of rubber packing. Renewal will not
be effective if steel-to-steel contact points are defective and expensive rubber
packing will be ruined after only a few months of use
• Keep hatch coaming tops clean and the double drainage channels free of
obstructions. (Open hatch covers to clean coaming tops and the double drainage
channels after loading bulk cargo through grain or cement ports)
• Keep wheels, cleats, hinge pins, haul wires and chain tension equipment well
greased
• Ensure the oil tank of the hydraulic system is kept filled to the operating level and
with the correct oil
• Clean up oil spills. If the leak cannot be stopped immediately, construct a save-all
to contain the oil and empty it regularly
• Engage tween deck hatch cover cleats when the panels are closed
Never
• Treat temporary repairs as if these were permanent. The strength of the cover
and ultimately the ship will depend on the quality of repairs carried out
• Ignore serious corrosion, cracking or distortion in the covers and supports. These
are signs of weakness and are potentially hazardous
• Allow grooves to form in the coaming top, especially where the hatch side or end
panel rests when the hatch is closed
• Tighten down the cleats so that the hatch cover is unable to move on the coming
top
Drain valves are not important, it does not matter if they are blocked.
Drain valves are an essential feature of the double drainage system as they allow
water that has penetrated the hatch gasket (rubber packing) to drain away. If the
valve is blocked or closed, water will spill from the drainage channel into the cargo
hold.
When carrying a cargo on top of a hatch cover it is not necessary to fasten
cleats.
Cleats prevent excessive movement of the hatch covers as the ship bends and flexes
in a seaway. They allow a limited movement to ensure correct contact between the
cover and the coaming, preventing hatch cover damage. Cargo loaded on the hatch
does not secure the hatch cover to its coaming.
Tween deck cleats are not essential because the tween deck covers are not
weathertight.
Cleats on tween deck covers should always be engaged when the covers are closed.
This is because they stop tween deck panels from jumping when a ship pitches,
ensuring maintenance of tween deck strength. When cargo is stowed on a tween
deck panel, the panel must be secured to the ship's structure.
Any rubber gasket can be used provided the gasket fits the channel.
No, use only the gasket type recommended by the hatch cover manufacturer.
In certain waters enforcement of the laws will be the concern of the relevant
Coastal State. For example, vessels passing through the English Channel will
come under the jurisdiction of either France or the United Kingdom, even if they
are registered elsewhere and are not calling at ports in either country.
Above left an Emergency Escape Breathing Device (EEBD) and above right pyrotechnics, line
throwing appliance and distress signalling device
The applicability of the SOLAS requirements has been previously described in section
9.1.3 of these notes and the scope of the safety equipment surveys can be seen from
the Safety Equipment Survey Checklist (see Annex 7).
It is not intended in this section to run through all the requirements of SOLAS, the
LSA, FSS and FTP codes but only to highlight how safety equipment surveys can be
helped to progress more smoothly and to detail the more common deficiencies
resulting in safety equipment related detentions or problems with the validity of a
ship’s Safety Equipment Certificate.
It is worth emphasising at this point, however, that from a review of the Safety
Equipment Survey Checklist it can be seen that although the checklist is relatively
long the items to be examined are in general both simple to examine and
straightforward to test and maintain. It is therefore worth asking the question as to
why in excess of 50% of Port State Control detentions are year on year related to
safety equipment deficiencies?
With effective use of the Safety Equipment Survey Checklist and the Record of Safety
Equipment Fitted Onboard (SE1) as a basis for a continuous maintenance and test
regime of safety equipment onboard a ship it is fair to conclude that many deficiencies
could be avoided and the number one priority of ensuring the safety of the ship and its
crew would be better ensured. It is a fact that a methodical approach to both
inspection and maintenance of safety equipment is key to ensuring that all the
necessary equipment is present onboard and in good working order. In addition to a
methodical approach it should be ensured that checks by ship’s staff are carried out
as frequently as practical and not just prior to formal surveys.
Detailed below are examples of ways of preparing for a Safety Equipment Survey,
these will help to smooth the survey process and make it more efficient.
• Take out the life boat equipment for each boat and range it out on deck neatly.
This will make the checking of the inventory against the SE1 more efficient and
also give the surveyor clear access to the necessary spaces within the lifeboat
so that its structural condition can be checked.
• Be prepared to lower all life boats to at least the embarkation deck and
demonstrate use of bowsing tackle and hanging off arrangements. Boats may
be requested to be launched and shown to be fully operational. It should be
noted that sufficient crew members should be adequately trained to launch the
lifeboats so that in the event of injury to any member of the crew the boats can
still be launched. This scenario is quite often simulated during survey by the
surveyor requesting the person initially controlling launching operations to step
back and hand over operations to the remaining crew.
• Ventilation dampers including funnel dampers and any engine room skylight.
The status of funnel dampers (i.e. open/closed) should be indicated at the
operating location and engine room skylights should be gas tight and operable
from both inside and outside the engine room.
The list of items detailed above is by no means definitive and details only the most
basic items. The full list of items which will need to be surveyed will depend on the
actual as fitted shipboard arrangements and the type of survey being carried out i.e.
Annual (A), Intermediate (I), Periodical (P) or Renewal (R) survey the Chief Engineer
and Master should prepare accordingly referring to the Safety Equipment Survey
Checklist (see annex 7).
Comprehensive details of all detentions and their causes are recorded by both the
Classification Societies and Port State Control Organisations e.g. Paris MOU (see
Chapter 8). As a result of these records it can be seen that the most common safety
equipment related deficiencies are as a result of basic defects including:
• Life saving appliances – life boat and life boat inventory defects
• Fire safety measures – fire pump, ventilator, isolating valve, fire hydrant and
engine room remotely operated valve defects
Listed below are serious safety equipment defects which frequently compromise the
validity of a ship’s Safety Equipment Certificate:
• Excessive amount of oil found in bilges and defects with the bilge pumping
arrangements
• Absence or faults affecting the proper operation of the radio equipment for
distress and safety communication
11.2 The International Code for the Safe Operation of Ships and for
Pollution Prevention (The International Safety Management (ISM) Code)
11.2.1 History
During the 1980’s members of the International Maritime Organisation (IMO) voiced
concerns over a perceived deterioration in the professionalism of some shipboard
personnel and a reduction in care plus investment on the part of some ship owners
and operators. As a result, in 1989, IMO adopted the first “Guidelines on
Management for the Safe Operation of Ships and Pollution Prevention” (Res.
A647(16)). Following a number of revisions detailed in the following table IMO
adopted the “ISM Code” (Res. A741(18)) in 1993 and incorporated the code into the
SOLAS convention in 1994 through Chapter IX.
The application of the ISM Code was made mandatory to the ships covered by the
SOLAS convention in two phases. In phase 1 (1998) the requirements were made
applicable to Oil Tankers, Chemical Tankers, Liquefied Gas Carriers, Bulk Carriers,
Passenger Ships and High Speed Craft. In phase 2 the requirements of the code
were made mandatory to all the remaining ships required to comply with the SOLAS
Convention. Phase 2 came into force on the 1st of July 2002.
IMO adopts A647(16) “Guidelines on Management for the Safe Operation of Ships and Pollution
Prevention
1989
1995 IMO adopts resolution A788(19) “Guidelines on implementation of the ISM Code by Administrations”
1998 Phase 1
11.2.2 Background
After more than two centuries of detailed and prescriptive regulation aimed almost
entirely at the integrity and reliability of the ship and its equipment i.e. the technology,
the marine industry realised that 80% of all accidents at sea were caused by human
error. In fact 80% of all accidents at sea could therefore be attributed to the absence
or failure of a management system. The ISM Code, at last, focused the industries
minds on the people and systems used in the operation of ships and established
some minimum standards and goals.
The marine industry had realised that the condition and functioning of a ship and its
equipment was very much dependent on the way in which it was managed and
operated and that to separate condition from management was artificial and
misleading.
The introduction of the ISM code has succeeded in returning responsibility for the
maintenance of the ship and its equipment to where it belongs i.e. to the company –
the decision makers and resource allocators.
Simply put the ISM code is a model, which enables the development of documented
safety management systems that ensure there is a uniform minimum standard of care
with respect to safety and pollution prevention within all shipping companies both on
land and at sea. For a ship to trade it must be in possession of a valid Safety
Management Certificate (SMC) issued to the ship as a result of the ship’s safety
management system being shown to be effectively implemented onboard. Unlike
most other statutory certificates which stand alone the SMC is only valid if it
corresponds to a relevant, valid, Document of Compliance (DOC) issued to the ship’s
operator as a result of the safety management system being shown to be effectively
implemented ashore in the company’s offices. A copy of the appropriate up to date
DOC must therefore be kept onboard a ship together with the original SMC.
The code is not prescriptive and is therefore not a specification. The code does not
detail how the objectives are to be achieved only what objectives are to be met.
During the early implementation of the code it is fair to say that it was misunderstood.
Many of the safety management systems developed by shipping companies were
excessively documented, overly prescriptive and voluminous in size. These early
systems achieved the goals of the code but in a manner which was both unpopular
with sea staff and unnecessary to fulfil the requirements of the ISM code most
effectively.
A safety management system that satisfies the requirements of the ISM Code is a
system of prevention, a system designed to prevent pollution and improve safety. The
safety management system provides confidence that the company is complying with
safety and pollution prevention requirements and is systematically planning and
implementing its activities and operations. In addition the system provides evidence
of the application of controls with respect to safety and pollution prevention, plus
procedures for corrective action in order to prevent the repetition of problems. A
safety management system must include the following functional requirements:
A safety management system does not provide a guarantee that there will never
be another accident or technical defect.
The statement above may appear obvious, but there is an implication in the attitude of
many in the marine industry that certification is some kind of guarantee that this will be
the case. There appears to be a belief that an accident or technical defect or failure
is, per se, irrefutable evidence of the failure of the safety management system. This
attitude reflects a fundamental lack of understanding of the purpose, scope and
limitation of management systems – and the audit process. A management system
audit is not a technical inspection! It probably also reflects a difference in the level of
maturity of the shipping industry in matters of safety and pollution prevention when
compared to the airline and off-shore industries.
The ISM Code recognizes that, where there is risk, eventually something will go
wrong. When it does, it is the job of the management system to respond in a way that
minimises the consequences and identifies improvements that can be made. The
ISM Code also requires risk management comprising of four main activities as follows:
1. Hazard identification
2. Risk assessment
3. Risk control
4. Performance monitoring
Safety can be defined as “A perceived quality that determines the extent to which
the management, engineering and operation of a system are free from danger to
life, property and the environment.”
An important word here is perceived. Perceptions of risk and safety are inevitably
subjective and this has some very important implications for design and
implementation of safety management systems.
e.g. Some people feel much happier than others when swinging from a Bosun’s chair
despite the fact that the equipment used and the controls in place may be exactly the
same.
Risk management can be defined as “The process whereby decisions are made
to accept a known or assessed risk and/or the implementation of actions to
reduce the consequences or probability of occurrence” (ISO 8402:1995/BS 4778)
The ISM Code implies that risk assessment should be undertaken in the development
of plans for shipboard operations (Cl.7), in the preparation for emergencies (Cl.8) and
when reviewing shipboard technical systems plus equipment in order to identify critical
equipment the failure of which may result in hazardous situations (Cl.10.3).
In addition to identifying and controlling risk, the ISM Code requires the safety
management system of a company to be such that it provides for continuous
improvement. System elements that contribute to continual improvement are:
The above elements if effectively implemented help considerably in achieving the goal
of continual improvement in the safety management system by allowing it to be
adapted and improved in all parts including equipment, documentation and personnel.
80% of all accidents in the maritime industry are caused by human error!
LOSS
Incident
Direct Cause
Unacceptable acts and
Basic Cause conditions
Personal factors
Lack of Job factors
Control
Lack of, or inadequate planning and measurement
The commonly used term “no-blame culture” is often interpreted as meaning that
individuals should no longer be held accountable for their actions. This is dismissed
as a platitude because everyone knows that such a policy will never be applied in the
real world. An organization’s first reaction following a non-conformity or an accident
must not be to seek out and sever the nearest head. The temptation to demonstrate
quickly and dramatically that the incident has been taken seriously and that something
is being done can be very strong. Disciplinary action makes a clear distinction
between those who are said to be guilty and those who are pointing the finger,
sackings put a very comforting distance between the two.
It may be that, following an investigation, the conclusion is reached that someone was
lazy, negligent or incompetent but there are many management system questions to
be answered before such a conclusion is reached. Even if such an outcome is
reached following an investigation we need to ask how that person came to be
employed, whether there was a failure in supervision and why the problem was not
identified during appraisals, training reviews or internal audits. As for the 20% of
accidents caused by technical defects or breakdowns, here too, we should be asking
what were the management system failures that gave rise to them?
It is important to remember that the issue of a certificate means that the system meets
the requirements of the ISM Code. It is not a guarantee that it does so in the most
efficient and least irksome way possible. As stated previously some very over-blown
and inefficient systems have received ISM Certificates!
The design and drafting of instructions, forms and checklists is not as easy as it may
first appear and requires much thought and care. If done well, it will make life simpler,
easier and safer. The more concise a document, the more likely people are to read it,
and the easier it will be to understand. Flow charts and well-designed forms and
checklists can do much to reduce the number and size of the procedures.
The administration of the system will inevitably mean some additional tasks including,
for example, the conduct of internal audits and system reviews. If the system results
in a significant increase in the amount of work then it is likely that the company is now
doing things that it should have been doing before, but wasn’t, provided of course that
the increase is not the result of duplication or excessive requirements.
A straightforward review and approval process is essential for the efficiency of the
safety management system. To concentrate document authorization in one very
senior position, for example, is to invite delay. It may be better to approve documents
at lower levels more directly associated with the activities concerned plus the flexibility
of one or two alternative signatories. This also has the added advantage of increasing
the sense of ownership of those responsible for implementing the procedures.
Equally important is the flow of information from senior management down. Having
encouraged people to contribute, the company should ensure they receive a
response, even if only to explain why a suggestion or a recommendation has not been
implemented. If their contributions are ignored they will soon lose interest.
It should be noted that because there is a requirement that the DPA has “access to
the highest level of management”, the company’s senior managers may be assumed
to know what the DPA knows.
Compliance with the ISM Code is a statutory requirement and therefore like all other
statutory codes and conventions compliance is verified by representatives of either
the flag administration or a Recognized Organization (RO) acting on behalf of the flag
administration. Whether the verification of compliance with the requirements of the
ISM Code is actually carried out by the flag administration or by the RO is dependent
on the individual administration concerned and whether or not they have delegated
their ISM verification activities to a specific RO. Classification Societies such as LR
are often authorised to act as an RO but their representatives must always confirm
that they are actually authorised to carry out the ISM verification onboard the ship
concerned paying regard to the flag it is flying.
As stated previously, unlike other statutory certification, ISM requires the issuance of
two certificates i.e. The Document of Compliance (DOC) to the shipping company
and the Safety Management Certificate (SMC) to the ship. Verification of the correct
implementation of the safety management system for issuance/endorsement of the
ISM related certificates is carried out via an audit regime.
Although we talk about an SMC being issued to a ship, and the certificate has the
ship’s name on it, strictly speaking, it is not a ship’s certificate in the same way that
other statutory certificates are. The SMC refers to the effective operation of a
company’s management system onboard a referenced ship. Hence, if the ship
concerned leaves a company to be operated by another, the original SMC becomes
invalid the day the company changes. The new operating company’s management
system must then be audited on the ship concerned to see that it is running effectively
onboard for the issue of a new SMC certificate.
Interim ISM certificates may be and are issued to new companies and their ships,
ships brought under new management of an existing company (requiring an Interim
SMC), or an existing company that enters into the management of a ship type not
included in its existing certified safety management documentation (requiring an
interim DOC and an interim SMC).
The purpose of the initial audit is to establish the existence of a system that complies
with the requirements of the ISM Code, that the system is understood by those who
operate it and that it is being fully implemented. In most cases by the time of the initial
audit the existing records are only sufficient to demonstrate that the system is in
operation. Furthermore, experience has shown that the first verification audit does
little more than reassure the auditor there has been no relaxation in the
implementation of the system after the considerable effort involved in putting the
system into place. It is in the audit of the more mature systems that the effective audit
will show the requirement for continual improvement being achieved by highlighting
areas that have been identified for more attention and how changes have been made
to the system itself.
YEARS
0 1 2 3 4 5
YEARS
0 1 2 3 4 5
ISM Audit Regime
Having obtained certification following DOC and SMC audits followed by one or two
Periodical Verification Audits (PVA’s) many companies feel they know exactly what to
expect from a safety management system assessment. However, if audits are done
well, the emphasis during the audit of a more mature system will be quite different
from that of an initial or early verification audit.
It should be noted that certification is by no means the end of the process. A safety
management system must be “alive” and must adapt to changing requirements of the
company, developments in technology and operational practice, and changes in the
regulatory environment in which it operates. The system must be maintained by a
process of continual improvement.
Administration. The government of the state whose flag the ship is entitled to fly.
Company. The owner of the ship or any other organization or person such as a
manager, or the bareboat charterer, who has assumed responsibility for the operation
of the ship from the shipowner and who, on assuming such responsibility, has agreed
to take over all the duties and responsibility imposed by the code.
During the audits a number of non-conformities may be issued by the auditor. Many
people live in fear of non-conformities. In fact they are nothing more than
discrepancies between what is required and what is done and requires attention. In
themselves they have no impact on the certification although a situation can arise in
which a number of non-conformities are brought together to create a major non
conformity. A single major non-conformity prevents the issue of a new certificate or
the endorsement of an existing certificate.