Circulars
  • Date: 10/17/2016
  • Series: RSR
  • Number: RSR 14 - 2016
  • Case number: 2014/23224-34/JKS

Amendments to the Regulations on life-saving appliances on ships and the Regulations on supervision and certificates for Norwegian ships and mobile offshore units

Introduction

The Norwegian Maritime Authority has laid down amendments to the following regulations:

  • Regulations of 1 July 2014 No. 1019 on life-saving appliances on ships; and
  • Regulations of 22 December 2014 No. 1983 on supervision and certificates for Norwegian ships and mobile offshore.

The amendments include, inter alia, changes to the requirements for life-saving appliances on cargo ships and passenger ships. The amendments enter into force on 17 October 2016. See the notes to each provision for more information about the transitional provisions.

Consultation

The proposed amendments were circulated for review from 12 March to 11 July 2016. A total of 13 consultative statements came in from 13 different consultative bodies. Nine consultative bodies had no comments. One of the bodies asked for extended response time.

Background for the amendments

The Regulations of 19 December 2014 No. 1853 on the construction and supervision of small cargo ships, i.e. cargo ships of 8 metres and above in overall length, but of less than 24 metres in length (L), in the following referred to as Regulations 2014/1853, entered into force on 1 January 2015.

After 1 January 2015, the supervision of cargo ships of less than 15 metres in overall length has indicated that the requirements for life-saving appliances may be made more appropriate for such ships.

The amendments relate to, inter alia, requirements for the carriage of life-saving appliances and for design and testing standards for liferafts.

The amendments also involve requirements for ships with a one-man crew to be equipped with a dead man's switch and a rescue ladder. This part of the proposal will take effect from 1 January 2017, which allows the companies some time to adapt.

Notes on the provisions

Amendments to the Regulations on life-saving appliances on ships

To section 1

Section 1 (d) is amended so that the provisions on scope of application give a more precise indication of barges covered by the Regulations on life-saving appliances on ships. The amendments do not involve any real change to current law, but are laid down in order to minimise any doubts about which barges are covered by the Regulations on life-saving appliances on ships.

To section 5

Some editorial changes have been made to the first paragraph of section 5 to reduce any interpretation doubts.

The requirement of section 5 first paragraph new (f) is a continuation of a requirement laid down in section 8 (g) of the now repealed Regulations of 11 October 2004 No. 1341 on life-saving appliances on passenger ships. The requirement for a two-way portable VHF radiotelephone apparatus applies to ships certified to carry 12 passengers or less.

To new section 5a

The Regulations on life-saving appliances on ships also apply to cargo ships of less than 8 metres in overall length. New section 5 includes requirements better adapted to such cargo ships.

The life-saving appliances as set out in section 5a are covered by the harmonised requirements for performance and testing standards in the Regulations of 20 August 2016 No. 1042 on marine equipment.

To section 6

Section 6 first paragraph has been amended in order to minimise any doubts about interpretation compared to the previous wording.

The table in section 6 includes a reference to section 8 fifth paragraph which allows for cargo ships to carry one liferaft, provided that it is capable of being launched on either side of the ship. The table has also been amended as regards the requirement for lifebuoys on cargo ships of less than 15 metres in overall length as a consequence of the requirements of section 11 second paragraph, which are addressed below.

Prior to these amendments to the Regulations, cargo ships of between 100 and 300 gross tonnage and of less than 30 metres in overall length (L) engaged on foreign voyages were required to carry a rescue boat. The requirement for a rescue boat on equivalent cargo ships engaged on domestic voyages was repealed with effect from 1 January 2009.

It is our opinion that the requirement for smaller cargo ships engaged on foreign voyages to carry a rescue boat has not contributed to improved safety. Companies that have applied for exemptions from the rescue boat requirement have also been granted exemptions. Therefore, cargo ships of between 100 and 300 gross tonnage and of less than 30 metres in overall length (L) engaged on foreign voyages are no longer required to carry a rescue boat.

It is currently set out in the table that cargo ships of more than 15 metres in overall length and of less than 100 gross tonnage and cargo ships of between 100 and 500 gross tonnage are required to have four projectiles with four lines, cf. section 7.1 of the LSA Code. On cargo ships of less than 15 metres in overall length, two projectiles with two lines are required. This is related to the requirements of section 17 (2) of the previous Regulations of 15 September 1992 No. 700 on life-saving appliances on passenger ships, which read: "For non-convention ships, the following shall apply: Passenger ships of 300 gross tonnage and above and cargo ships of 50 gross tonnage and above shall be equipped with a line-throwing appliance complying with the requirements of Regulation III/49. No more than two lines and two projectiles need be kept on board."

The line-throwing apparatus shall be type-approved. If the line-throwing apparatus is sold separately, the certificate is likely to refer to the fact that SOLAS presupposes a purchase of a set of four apparatus in accordance with the LSA Code. With the adjustment for the smallest ships, two such type-approved apparatus are sufficient. This is also the reason why we do not refer to SOLAS III/19 as regards the smallest cargo ships.

To section 7

Some editorial changes have been made to the first paragraph of section 7 to minimise any doubts about interpretation.

The table in section 7 has been amended to clarify the carriage requirements for thermal lifejackets or thermal suits in combination with lifejackets for children. The requirement arises from SOLAS regulation III/7.2.1.3. Pursuant to current law, only the option of 0.1 of the number of passengers on board is laid down. The requirement for one child's lifejacket for every child on board now appears clearly.

The amendment of the table in section 7 that applies to line-throwing apparatus illustrates the requirement that follows from section 7.1 of the LSA Code, which requires the possibility to fire four projectiles with four lines.

To section 8

Section 8 third paragraph now sets out that the requirements of SOLAS regulation III/21 apply to passenger ships engaged on foreign voyages regardless of the year of construction. The amendment reflects the NMA's practice and the way the provision has been interpreted. Compared to earlier versions of SOLAS, the NMA presupposes that it will be both easier and less onerous for the industry to comply with SOLAS 1974 regulation III/21. The final sentence of section 8 third paragraph is deleted, as the sentence is redundant after the above-mentioned amendments.

The amendments of section 8 seventh paragraph provide, on specified terms, an alternative to wheel-marked liferaft for cargo ships of 8 to 15 metres in overall length. An equivalent regulation applies to fishing vessels of less than 15 metres in overall length (see section 38 second paragraph of the Regulations of 22 November 2014 No. 1404 on fishing vessels of less than 15 metres in overall length). Liferafts manufactured in accordance with ISO 9650-1 are mainly aimed at the recreational craft market. The ISO standard is based on a body mass of 75 kg, cf. section 3.1. The LSA Code (MSC.48(66)) assumes an average mass of 82.5 kg per person on cargo ships, cf. section 4.2.2.1 (amended by Resolution MSC.277(85) with effect from 1 January 2012). In order to take into account the LSA Code's standardised body weight as well as equipment and clothing used in professional context, the Norwegian Maritime Authority introduces a safety margin expressed by the three-person limit.

Section 8 seventh paragraph (c) introduces a regulation on the location of liferafts, which mirrors equivalent requirements of ISO 9650-1. As long as the location of a liferaft is not limited by certification, a liferaft shall not be located more than six metres above the waterline in the least favourable loading condition.

ISO 9650-1 does not require buoyancy of packed liferafts. The requirements of section 4.2.6.1 of the LSA Code and the test requirements of section 5.13 and 5.19 of MSC.81(70) are applicable. The liferaft shall also be provided with a float-free arrangement in accordance with section 4.1.6 of the LSA Code. If the liferaft is capable of being launched from either side of the vessel, one liferaft is sufficient, cf. section 8 fifth paragraph.

In section 8 eighth paragraph, formerly seventh paragraph, the word «manned» has been deleted. The amendment is a consequence of the amendments of section 1 (d).

To section 9

Section 9 third paragraph also gives passenger ships in trade area 3 or lesser trade area the opportunity to include rescue boats in the survival craft capacity. A similar possibility was laid down in the repealed Regulations of 11 October 2004 No. 1341 on life-saving appliances on passenger ships.

SOLAS regulations III/21.1.4.3 and III/31.1.3.3 allow a rescue boat to be regarded as survival craft. Based on safety assessments by the Norwegian Maritime Authority, the amendment that enabled rescue boats to be regarded as survival craft has been harmonised for cargo ships and passenger ships in trade area 3. Cargo ships may therefore include rescue boats in the survival craft capacity in trade area 3, whereas previously only in trade area 2.

To new section 9a

New section 9a includes requirements for a rescue ladder and a dead man's switch.

The provisions of the new section 9a first paragraph are retrieved from Nordic Boat Standard C13, item 7.1. It is the NMA's assessment that the requirement for rescue ladder is appropriate, especially on board ships with a one-man crew. The requirement is also in line with the requirements of section 9 fifth paragraph (d). The requirement shall be made applicable not later than 1 January 2017.

To new section 10a

In the new section 10a, ro-ro passenger ships certified for trade area 2 or lesser trade area are exempt from the requirement for a helicopter landing area, cf. SOLAS Regulation III/28. The state of the law following the now repealed Regulations of 11 October 2004 No. 1341 on life-saving appliances on passenger ships is therefore continued.

To section 11

The first and second paragraphs of section 11 have been amended as a result of inspiration from provisions on the number and location of lifebuoys on smaller fishing vessels. The table in section 6 is also modified as a result of these amendments.

To section 12

The new fourth paragraph of section 12 continues the state of the law pursuant to the now repealed Regulations of 11 October 2004 No. 1341 on life-saving appliances on passenger ships. With the amendment laid down in this Circular, the Norwegian Maritime Authority want to make it clear that the requirement for immersion suits applies to all crew members who are assigned tasks when the ship needs to be evacuated, or related to manning of survival craft/MES.

Amendments to the Regulations of 22 December 2014 No. 1893 on supervision and certificates for Norwegian ships and mobile offshore units

The Norwegian Maritime Authority corrects a typographical error in the Regulations of 22 December 2014 No. 1983 on supervision and certificates for Norwegian ships and mobile offshore units. Annex I, section 50 (5). Annex I contains transitional provisions for towing. The Norwegian word "sjakter" shall be replaced with "sjakler".

Administrative and financial implications

The amendments to sections 1, 5, new 5a, 6, 7 and 8 are partly editorial and partly clarifications of current law. The amendments do not imply stricter requirements, and therefore do not trigger any increased costs, neither for the public sector, nor for the industry.

The amendments of sections 6 and 7 that apply to the requirement for line-switching apparatus are a clarification of current law and will not, in the opinion of the NMA, lead to increased costs for ships that have adapted to the requirement. For smaller cargo ships, this will imply reduced costs, as there will be a change from four lines and projectiles to two lines and projectiles.

The amendments of section 8 that apply to liferafts on smaller cargo vessels and imply that certain liferafts may be manufactured in accordance with ISO 9650-1 are a relaxation compared to current law. This relaxation will not lead to increased costs, more likely the opposite.

The amendments stipulated in section 9 that apply to the requirements for a rescue ladder and a dead man's switch, may trigger purchase costs in the range of NOK 2.000 for rescue ladder and NOK 5.000 for dead man's switch. Installation and any adaptation of hull is an additional factor.

Immersion suits for all crew members who are assigned tasks related to the evacuation the ship and the manning of survival craft/MES may be interpreted as if the requirements imply a tightening of the regulations. The requirements are a continuation of current law of the now repealed Regulations of 11 October 2004 No. 1341 on life-saving appliances on passenger ships. The Norwegian Maritime Authority therefore assumes that such immersion suits are, in general, already in place. The financial consequences of the amendments of section 12 fourth paragraph will therefore be small.

By and large, the Norwegian Maritime Authority judge the benefits of the measures imposed by the amendments to outweigh the costs.

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