IMO COMPATIBILITY OF LIFE-SAVING APPLIANCES. Result of abandon ship drills conducted with immersion suits donned. Submitted by the Republic of Korea

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1 INTERNATIONAL MARITIME ORGANIZATION E IMO SUB-COMMITTEE ON SHIP DESIGN AND EQUIPMENT 51st session Agenda item 9 DE 51/INF.8 14 December 2007 ENGLISH ONLY COMPATIBILITY OF LIFE-SAVING APPLIANCES Result of abandon ship drills conducted with immersion suits donned Submitted by the Republic of Korea Executive summary: Action to be taken: Paragraph 3 Related documents: SUMMARY This document provides information on the result of trial abandon ship drills conducted with participants donning immersion suits and proposals made thereto by the Republic of Korea for the improvement of relevant requirements and lifesaving appliances. DE 47/5/6, DE 50/13, DE 50/13/1, DE 50/13/2, DE 50/13/3 and DE 51/9/1 1 SOLAS regulation III/32.3 was amended by resolution MSC.152(78) at MSC 78. The amended regulation requires that an immersion suit shall be provided for every person on board cargo ships, except for ships other than bulk carriers as defined in regulation IX/1 which are constantly engaged on voyages in warm climates. 2 In this regard, to facilitate discussions on the issue of compatibility of life-saving appliances under consideration in the Sub-Committee, the Republic of Korea has analysed related SOLAS requirements, including associated standards, and conducted abandon ship drills with participants donning immersion suits to identify whether or not there are any associated problems and if so, propose a possible way forward to rectify the problems. The details of analysis and drills conducted as well as the proposals made thereto are set out in the annex to this document. Action requested of the Sub-Committee 3 The Sub-Committee is invited to consider the annex as attached, which is related to document DE 51/9/1 (Republic of Korea), and take action as appropriate *** For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.

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3 OUTCOME OF ABANDON SHIP DRILLS WITH IMMERSION SUIT DONNED 1 EXECUTIVE SUMMARY SOLAS regulation III/32.3 was amended by resolution MSC.152(78) at MSC 78. The amended regulation, which entered into force on 1 July 2006, requires that an immersion suit shall be provided for every person on board cargo ships, except for ships other than bulk carriers as defined in SOLAS regulation IX/1 which are constantly engaged on voyages in warm climates. In this regard, to identify areas for improvement and propose items for review by IMO, the Republic of Korea, in 2007, analysed related SOLAS requirements, including associated standards, and conducted abandon ship drills with participants donning immersion suits. 2 RESULT OF ABANDON SHIP DRILLS CONDUCTED 2.1 Subject ships and participants Case 1 1 Ship: training facility at the Korea Institute of Maritime and Fisheries Technology (KIMFT) 2 Lifeboat: 1 davit-launched (capacity: 28 persons) and 1 free-fall type (capacity: 15 persons) 3 Immersion suit type: non-buoyant type (all), universal size (all), weight 4.7 kg 4 Lifejacket type: yoke-type (all), knot-type, weight 0.65 kg 5 Participants: trainees at KIMFT (All 28 participants were in mid 20s to early 30s and of normal physique) Case 2 1 Ship: G/T 2,418, oil/chemical tanker 2 Lifeboat: 1 free-fall type (capacity: 16 persons) 3 Immersion suit type: non-buoyant type (all), universal size (all), weight 3.8 kg 4 Lifejacket type: vest-type (12), knot-type, weight 0.56 kg yoke-type (4), buckle-type, weight 0.65 kg 5 Participants: shipboard crew members (out of 14 participants, 2 were in their 20s, 5 were in their 30s, 2 were in their 40s and 5 were in their 50s. There were 8 Korean nationals and 6 Myanmar nationals. All were of normal physique) Case 3 1 Ship: G/T 9,522, container ship 2 Lifeboat: 2 davit-launched totally enclosed lifeboats (capacity: 18 persons) 3 Immersion suit type: non-buoyant (all), universal size (all), weight 4.6 kg 4 Lifejacket type: vest-type (28), knot-type, weight 0.56 kg yoke-type (14), buckle-type, weight 0.65 kg 5 Participants: shipboard crew members (out of 14 participants, 9 were Korean nationals, 3 were Myanmar nationals and 2 were Chinese nationals. 4 participants were in their 50s, 3 in their 40s, 2 in their 30s and 5 in their 20s) I:\DE\51\INF-8.DOC

4 Page 2 (Case 1) (Case 2) 2.2 Key items examined during the drills 1 Anthropometry (body weight, shoulder width and hip width were measured with or without wearing lifejacket and immersion suit over a work uniform: LSA Code regulations and 4.7.2) 2 Abandon ship drill (measured the time it took to abandon ship with immersion suits donned at different points in time. Also, measured the time it took to embark a lifeboat with or without donning an immersion suit: SOLAS regulations III/6.4.2, , , , 32.3 and 37) 3 Examination of compatibility of lifeboat with immersion suits and lifejackets donned (SOLAS regulations III/7, LSA Code regulations , and 4.7.2) 4 Other problems associated with donning immersion suit and lifejacket (SOLAS regulations III/11.6, LSA Code regulations , and ) 3 FINDINGS 3.1 Donning immersion suits during the abandon ship drills Even though SOLAS regulation III/32.3 requires that an immersion suit shall be provided for every person on board cargo ships, there is no stipulation in SOLAS about an obligation or timing for donning an immersion suit. According to LSA Code regulation , an immersion suit shall permit the person wearing it, and also a lifejacket if the immersion suit is to be worn in conjunction with a lifejacket, to climb up and down a vertical ladder at least 5 m in length; perform normal duties associated with abandonment; jump from a height of not less than 4.5 m into the water without damaging or dislodging the immersion suit or its attachments or being injured; and swim a short distance through the water and board a survival craft. By the very wordings of this regulation, one can assume that an immersion suit (and lifejacket where necessary) should be donned when conducting duties associated with abandoning ship. If such assumption is made, it is necessary to additionally examine the following:

5 Page Immersion suit donning requirement SOLAS regulation III/ requires checking that lifejackets are correctly donned at each abandon ship drill. However, there is no mention of immersion suits in the regulation. This regulation was established prior to 1 July 2006 the date on which the amended SOLAS regulation III/32.3, a requirement that an immersion suit shall be provided for every person on board cargo ships, became effective. With the newly amended regulation for immersion suit in force, lifejackets and/or immersion suits will have to be worn. Consequently, it is necessary to consider amending SOLAS regulation III/ as follows (see also paragraph of this document): Each abandon ship drill shall include checking that lifejackets and/or, if applicable, immersion suits are correctly donned Proper time for donning immersion suits LSA Code regulation requires that an immersion suit shall permit the person wearing it to perform normal duties associated with abandonment. This can be interpreted to mean that an immersion suit shall be donned at the time of initiating actions included in the muster list. However, there is no regulation stipulating when the normal duties associated with abandonment should be initiated. As a result, it is confusing as to when the crew should be donning their immersion suit. In this regard, SOLAS regulation III/6.4.2 requires that a general emergency alarm system shall be used for summoning passengers and crew to muster stations and to initiate the actions included in the muster list. However, this requirement does not clearly specify whether it is priority to summon passengers and crew to muster stations first and then initiate the actions included in the muster list. Consequently, in view of the requirements of SOLAS regulations III/ , III/6.4.2 and III/37, there may be three different timings for donning immersion suits as follows: a) when the general emergency alarm system is triggered, each crew member dons an immersion suit at a location where it is kept and then assembles at the muster station with EPIRB and SART, etc. Any normal duties associated with abandonment such as lowering of lifeboat are then initiated according to the master s instructions after assembling at the muster station. In case of most cargo ships, crew members tend to regard the activation of the general emergency alarm as an appropriate time to initiate the duties associated with abandonment. However, it is important to note that some immersion suit manufacturers warn against donning immersion suits in a submerged compartment because there is a risk of entrapment due to the suit s inherent buoyancy; or b) when the general emergency alarm system is activated, each person picks up his immersion suit from a place where it is kept and assembles at the muster station with EPIRB and SART, etc. Each crew member then dons the immersion suit at the muster station, proceeds to check the outfit and count the number of crew members assembled, and initiates the duties associated with the abandonment according to the instructions given by the master; or c) the crew members act according to another ship abandonment sequence specifically established for different emergency situations for an individual ship and don immersion suits accordingly.

6 Page 4 It is therefore necessary to review the merits associated with each scenario above, relevant requirements of SOLAS, locations of immersion suits including additional suits, emergency escape routes, etc., to establish a standard ship abandonment procedure which would provide the sequence of actions to be taken, a proper time for donning immersion suits, etc. 3.2 Time required to abandon ship (time required for launching survival craft(s)) SOLAS regulation III/ requires that all survival craft shall be capable of being launched with their full complement within 10 minutes from the time an abandon ship signal is given. However, with the adoption of SOLAS regulation III/32.3, which requires that an immersion suit shall be provided for every person on board cargo ships, it may be necessary to re-examine the appropriateness of this regulation since each crew member now needs to don immersion suits and launch a survival craft within 10 minutes (additional two minutes for donning an immersion suit as required by LSA Code regulation , additional time needed to abandon ship, etc.) During the ship abandonment drill, the time it takes to abandon ship was measured for scenarios a) and b) of paragraph above. Due to a number of safety issues, the actual launching of a lifeboat into the water was omitted. In both cases, it was possible for all crew members to embark on a lifeboat within 10 minutes from the time the abandon ship signal was given. As far as the time difference for donning an immersion suit at different locations is concerned, there was not much discrepancy between the two scenarios, but scenario a) took approximately 2 minutes longer to don immersion suits than scenario b). In both cases, if the time it took to assemble at the muster station is not accounted for, the embarkation time would become much shorter. However, the time it takes to fully launch a lifeboat into the water may exceed 10 minutes if proper donning of an immersion suit and lifejacket is checked and all crew members are seated with their safety belts securely fastened inside the lifeboat. Accordingly, the actual time it takes to fully launch survival craft may differ according to the launch type of the survival craft, its placement, lashing type, physique of crew members, etc. It is not clear as to whether the abandon ship signal referred to in SOLAS regulation III/ is a general emergency alarm referred to in SOLAS regulation III/6.4.2 or whether it refers to an abandon signal given by the master at the muster station like in passenger ships. In case of cargo ships, the crew members on board usually consider a general emergency alarm as an abandon ship signal. In case of passenger ships, MSC 82, by resolution MSC.216(82), adopted an amendment to SOLAS regulation III/ to clearly state that the 30 minute criteria starts when all persons have been mustered, with lifejackets donned, and the master gives the abandon ship signal. The newly amended regulation is as follows: SOLAS regulation III/ (previously ): All survival craft required to provide for abandonment by the total number of persons on board shall be capable of being launched with their full complement of persons and equipment within a period of 30 min from the time the abandon ship signal is given after all persons have been assembled, with lifejackets donned. Accordingly, there may be a need to amend SOLAS regulation III/ to apply the same principle to cargo ships as follows: SOLAS regulation III/31.1.5: With the exception of the survival craft referred to in regulation , all survival craft required to provide for abandonment by the total number of persons on board shall be capable of being launched with their full

7 DE 51/INF.8 Page 5 complement of persons and equipment within a period of 10 min from the time the abandon ship signal is given after all persons have been assembled, with lifejackets or/and immersion suits donned During the drills, with only lifejackets donned, the time it took for all crew members to embark on a lifeboat from the muster station was less than 3 minutes which is a time limit stipulated in LSA Code regulation However, when immersion suits were donned, it took more than 3 minutes to embark on a lifeboat (davit-launched lifeboat). Therefore, it can be assumed that the requirement of LSA Code regulation does not take into account the donning of immersion suits and thus, it may be necessary to review and amend the requirement as necessary. 3.3 Exemption of lifejackets and compatibility of immersion suits and lifejackets The LSA Code, as amended by resolution MSC.207(81), paragraphs and to , permits the use of an immersion suit with buoyancy which is designed to be worn without a lifejacket. However, SOLAS does not clearly stipulate whether the provision of lifejackets can be waived in cases where immersion suits with buoyancy which are designed to be worn without a lifejacket are provided on board for each crew member and in remotely located work stations, etc. This uncertainty may cause some confusion during PSC inspections. Consequently, the necessity of adding the following requirement in SOLAS regulation III/7 should be reviewed. A buoyant insulated immersion suit which is provided to comply with the requirements of regulation 32 meeting the requirements of section 2.3 of the Code may be accepted as a lifejacket. In this regard, a requirement for provision of lifejackets and immersion suits in the area where a remotely located survival craft is stowed, which is prescribed in the unified interpretation on SOLAS regulation III/ issued as MSC.1/Circ.1243, may also need to be reviewed In the case of an immersion suit to be worn in conjunction with a lifejacket, their compatibility should be ensured. This issue was discussed at DE and, as a result, the LSA Code was amended by resolution MSC.207(81) as follows: If an immersion suit is to be worn in conjunction with a lifejacket,... The immersion suit shall be marked to indicate that it must be worn in conjunction with a compatible lifejacket However, since the wording compatible lifejacket is not very specific, there may be some confusion as to how compatibility can be defined and confirmed. The examples of different interpretation are given below:.1 In some cases, as long as a lifejacket can be worn over an immersion suit, such a lifejacket is considered compatible. During the drills, a mix of yoke-type and vest-type lifejackets was provided on board. In the case of yoke-type lifejackets, the compatibility was not an issue as far as donning it over an immersion suit was concerned. However, in the case of vest-type lifejackets, it was difficult to wear them over the immersion suit and, in some cases, it was not possible to don a lifejacket completely because the top knot could not be tied (see paragraph 3.7.2, below). It is thought the problems occurred because these lifejackets were not

8 Page 6 designed to be worn over the immersion suits. Also, lifejackets, which were forcefully worn, significantly hindered the crew members from undertaking normal duties associated with the abandonment. In addition, there were doubts as to whether such lifejackets would function properly as required by the LSA Code in an actual emergency situation..2 In other cases, if a lifejacket meets the general requirements for immersion suits as stipulated, for example, in regulation of the revised LSA Code, can be met after it is worn over the immersion suit, such a lifejacket is considered compatible. However, it is difficult to confirm the compatibility of a lifejacket to an immersion suit to the extent prescribed by the Code during the field survey of ships in service. Consequently, there is a need to define the compatibility of lifejackets in a more detailed manner and find ways to practically confirm such compatibility in order to prevent lifejackets from becoming useless in times of emergency. Furthermore, it may also be necessary to retrospectively apply regulation of the LSA Code as amended by resolution MSC.207(81) to immersion suits which had been or will be manufactured and provided on board before its effective date of 1 July Immersion suit with yoke-type lifejacket Immersion suit with vest-type life jacket 3.4 Suitability of lifeboat design (compatibility of lifeboats and immersion suits) Seating space It was tentatively concluded previously at DE that the effect of immersion suit wear is marginal when it comes to seating space. However, as pointed out by China (DE 47/5/6) and by Japan (DE 50/13/3), the Republic of Korea was also able to confirm that donning an immersion suit has the negative effect of reducing the seating space inside a lifeboat. For example, in case of a lifeboat (davit-launched type) designed to accommodate 28 passengers, it was possible for all 28 persons, who wore lifejackets only, to be seated with their safety belts securely fastened. However, when the participants wore lifejackets over immersion suits, only 23 persons were able to embark on a lifeboat and they themselves were not able to fasten their safety belts. In other words, it was not possible to comply with the requirements of LSA Code regulation which prescribes that persons should be able to be seated in a normal position without interfering

9 Page 7 with the means of propulsion or the operation of any of the lifeboat s equipment. However, there were cases where the number of crew members on board was considerably smaller than the maximum capacity of a lifeboat, allowing every person on board to embark the lifeboat. On the other hand, in the case of a free-fall launched lifeboat, there were separate seats, so it was possible for all crew members to embark on the lifeboat and be seated with their hips and waist resting securely in their seats. However, even in these cases, the shoulders of the crew members protruded beyond the seats and it was not possible to fasten safety belts, putting the safety of crew members at risk at the time of free-fall launching. Inside a davit-launched lifeboat Inside a free-fall lifeboat Safety belt When the participants embarked on a lifeboat with immersion suits donned, it was not possible to fasten their safety belts while seated. In the case of a free-fall lifeboat, this will pose a significant safety risk to the occupants inside. However, it may be possible to fasten safety belts securely in a case where the number of crew members on board a ship is less than the maximum capacity of a lifeboat and the design of the safety belts allows their adjustment with the immersion suit donned Headrest of free-fall lifeboat To secure the compatibility of immersion suits and lifejackets, yoke-type lifejackets are usually preferred over vest-type lifejackets (refer to paragraph 3.3.2, above). However, in the case of yoke-type lifejackets, it is not possible to securely rest a person s head in the headrest, creating a significant risk for neck injury. In other words, it is difficult to satisfy the requirements of SOLAS regulation III/7.2.4 which prescribes that lifejackets selected for free-fall lifeboats, and the manner in which they are carried or worn, shall not interfere with entry into the lifeboat, occupant safety or operation of the lifeboat. Consequently, it may be necessary for occupants to take off lifejackets inside a free-fall lifeboat or wear different lifejackets inside the lifeboat, or have immersion suits with buoyancy which does not require the donning of lifejackets provided, or have the seating arrangement inside the lifeboat redesigned. Also, in the case of an immersion suit with buoyancy, there was still a problem with the thick pillow-like buoyant material attached to the back of the suit preventing the head of a person from resting securely in the head rest. Consequently, there is a pressing need to devise countermeasures against these problems.

10 Page 8 Headrest of free-fall lifeboat Carriage of stretcher case and its placement inside lifeboats SOLAS regulation III/11.6 requires that davit-launched and free-fall launched survival craft, muster station and embarkation stations shall be arranged as to enable stretcher cases to be placed in survival craft. To find out whether it is possible to comply with this requirement, a test involving a person carried in a stretcher case was conducted. The result of the test showed that it was possible to transport a person in a stretcher case and place him inside a lifeboat. However, there was insufficient space and no proper arrangements inside the lifeboat to secure down a person in a safe manner and in the case of a free-fall lifeboat in particular, this would be too dangerous. Carriage of stretcher case Summary.1 SOLAS regulation III/32.3 should be amended so that the following requirements which apply to lifejackets are equally applied to immersion suits (see paragraphs and above):

11 Page 9 SOLAS regulation III/7: 2.3 The lifejackets used in totally enclosed lifeboats, except free-fall lifeboats, shall not impede entry into the lifeboat or seating, including operation of the seat belts in the lifeboat. 2.4 Lifejackets selected for free-fall lifeboats, and the manner in which they are carried or worn, shall not interfere with entry into the lifeboat, occupant safety or operation of the lifeboat..2 It is necessary to carry out a review to assess whether or not LSA Code regulation as follows should be appropriately amended: The number of persons which a lifeboat to be launched by falls shall be permitted to accommodate shall be equal to the lesser of:.1 that the number of persons having an average mass of 75 kg, all wearing lifejackets, that can be seated in a normal position without interfering with the means of propulsion or the operation of any of the lifeboat s equipment (Since it is not possible to predict the type-approval requirements of a lifeboat or to know which ship the lifeboat will be provided to, the most severe condition of lifejackets donned in conjunction with immersion suit should be considered) (see paragraphs 3.4.1, and 3.5)..3 It is necessary to carry out a review to ensure that the headrests of free-fall lifeboat and lifejackets are compatible (see paragraph above)..4 There is a need to carry out a review to assess whether or not changes to design requirements are needed to enable stretcher cases to be placed in a lifeboat (SOLAS regulation III/11.6) and securely fastened down for safe launching of the lifeboat (see paragraph above). 3.5 Anthropometry Case A (shore-based training facility, trainees) a) Out of 28 participants in total, the body weight of 42.9% of the participants exceeded the average body mass of 75 kg stipulated in the LSA Code when measured without donning lifejackets and immersion suits (non-buoyant type). The average weight of participants was 75.6 kg. When the measurements were taken with lifejackets and immersion suits donned, the body weight of 75% of the participants exceeded the average mass of 75 kg. The average weight in this case was 80.9 kg. b) The average width of participants hips with immersion suits donned was mm which is within the design width of seating arrangement of 430 mm stipulated in the LSA Code. However, the average width of shoulders with immersion suits donned was mm, exceeding the design width of the seating arrangement of 430 mm.

12 Page 10 c) The sitting height of some of the participants exceeded 1,000 mm. However, this does not pose much of a problem due to the fact that the design height from the aisle to the ceiling of a lifeboat is usually 1,700 mm (in terms of sitting height 1,200 1,300 mm). It is to be noted that in some class rules, the sitting height of 1,000 mm and above is stipulated as a design requirement in the case of a free-fall lifeboat Case B (actual ship, crew members on board) a) Out of 14 participants in total, the body weight of 7.1% of the participants (1 person) exceeded the average mass of 75 kg stipulated in the LSA Code when measured without donning lifejackets and immersion suits (non-buoyant type). The average weight of the participants was kg. When the measurements were taken with lifejackets and immersion suits donned, the body weight of 35.1% of the participants (5 persons) exceeded the average mass of 75 kg. The average weight in this case was kg. b) The average width of participants hips with immersion suits donned was mm which is within the design width of seating arrangement of 430 mm stipulated in the LSA Code. However, the average width of shoulders, even without donning the immersion suits (average mm), exceeded the design width of the seating arrangement of 430 mm. With immersion suits donned, the measured width of shoulders increased to an average of mm. Based on the results obtained, it can be safely concluded that the width of shoulder, in most cases, exceeds the width of hip as well as the design width of seats inside a lifeboat. c) The measurement of the sitting height was omitted because the circumstances on board did not permit it. However, in looking at the results obtained in Case A above, it is safe to assume that there will be no problem associated with the ceiling height of lifeboats Case C (actual ship, crew members on board) a) Out of 14 participants in total, the body weight of 7.1% of the participants (1 person) exceeded the average mass of 75 kg stipulated in the LSA Code when measured without donning lifejackets and immersion suits (non-buoyant type). The average weight of the participants was kg. When the measurements were taken with lifejackets and immersion suits donned, the body weight of 48.25% of the participants (6 persons) exceeded the average mass of 75 kg. The average weight in this case was kg. b) The average width of participants hips with immersion suits donned was mm which is within the design width of seating arrangement of 430 mm stipulated in the LSA Code. However, the shoulder width of participants with immersion suits donned (average of mm), except for one person, exceeded the design width of seating arrangement of 430 mm. Based on the results obtained, it is evident that the width of shoulder, in most cases, exceed the width of hip and the design width of the seating arrangement. c) The measurement of sitting height was omitted because the circumstances on board did not permit it. However, in looking at the results obtained in Case A above, it is safe to assume that there will be no problem associated with the ceiling height of lifeboats (the height of lifeboat for Case 3 was higher than the ones provided on board the other ship).

13 Page Summary a) Even if the smaller physique of Asians is taken into account, some of the participants exceeded the average mass of 75 kg stipulated in the LSA Code, without donning immersion suits and lifejackets. With immersion suits and lifejackets donned, the body mass of many more persons would exceed the average mass of 75 kg. b) As pointed out previously by other Member States, it is evident that the shoulder width of a person is generally larger than the design width of the seating arrangement of 430 mm. c) In looking at the above findings, it is necessary to re-examine the seating space and arrangement of lifeboats. 3.6 Difficulties in staying inside a lifeboat with an immersion suit donned (habitability) The general consensus among the participants of conducted drills was that the crew members are usually very reluctant to embark on and stay inside a lifeboat with immersion suits donned. This is because staying inside a lifeboat for more than five minutes with its door closed while donning an immersion suit is physically difficult (sharp rise in body temperature due to insulation effect of immersion suit and high temperature inside the lifeboat due to lack of ventilation). In fact, drills could not be continued in some cases because some of the participants became extremely flushed and showed signs of vomiting (atmospheric temperature was 25 C at the time of the drill). In the case of fire-protected lifeboats surrounded by fire, the situation will likely get worse by the heat emanating from the fire burning outside. In the case of Case 3, because the weather was cloudy and rather cool with an atmospheric temperature around 23 C, the participants had no problem staying inside the lifeboat for 5 minutes after performing the drill with immersion suits donned. However, it is questionable as to how long they can actually remain inside the lifeboat. During the drill, the crew members expressed their fear of circumstances where immersion suits with buoyancy are provided on board and hence, no lifejackets are made available, leaving crew members no choice but to don immersion suits while performing drills and embarking on a lifeboat even in times of high atmospheric temperature. Therefore, it may be best if a situation allows the crew to embark on a lifeboat without their immersion suits donned in the case of totally enclosed lifeboats. In these cases, however, it is important to clarify when to don or take off immersion suits. It would also be prudent to devise an alternative measure in cases where a low temperature, not a high temperature, inside a lifeboat is a problem (refer to paragraph 4 below). 3.7 Other items The following are other problematic areas identified during the drills with immersion suits donned Donning immersion suits An immersion suit is to be provided to every person on board in compliance with the amended SOLAS regulation III/32.3 which became effective on 1 July However, no participant in the drills had ever executed abandon ship drills with an immersion suit donned. As a result, they were unfamiliar with how to properly put on a lifejacket in conjunction with an immersion suit. In recognition of the fact that prior exercises should be held to familiarize the crew with the proper donning of immersion suits and lifejackets, it may be necessary to amend the relevant

14 Page 12 sections of SOLAS to require future drills to be conducted with immersion suits donned (refer to paragraph above). Also, drills while donning immersion suits should be strongly encouraged at the time of an ISM audit or shipboard drills, except when the atmospheric temperature is too high to do so Design of immersion suits and lifejackets 1) When donning an immersion suit, it was sometimes difficult to slide a zipper up because the puller of zipper for some of the immersion suits was composed of a small leather ring, making it difficult to grab the puller with clumsy gloves of an immersion suit. However, in case of an immersion suit with a t shaped zipper puller as illustrated below, it was much easier to don an immersion suit. Consequently, it may be necessary to re-examine the design requirements of immersion suits to make further improvements. Leather puller T-shaped puller 2) In the case of a knot-type lifejacket that need to be tied, it took a considerable amount of time to securely tie the straps due to the clumsy gloves of the immersion suit (more than twice the time it takes in comparison with the buckle-type). Also, since it was not possible to tie the straps tightly, there was a possibility of the lifejacket slipping off in the water due to inherent buoyancy. The average time it took to don an immersion suit and a knot-type lifejacket was 3 minutes and 30 seconds and 12 participants out of 28 in total exceeded the time limit of 2 minutes. Consequently, the lifejackets which are to be donned in conjunction with immersion suits should be buckle-type to allow for appropriate donning to be completed within the time limit of 2 minutes. As a reference, it is anticipated that from 1 July 2010 only the buckle-type lifejackets will be manufactured to fulfil the requirement of LSA Code regulation which was amended by resolution MSC.207(81). However, the ones that have been or will be manufactured and provided on board prior to the said date may continue to pose problems.

15 Page 13 Knot-type lifejackets Buckle-type lifejackets) 3) In general, the immersion suits provided on board are universal type which are of same size. However, this is a problem in that, for crew members with small physique, the universal type immersion suits were too big in size and thus, hindered their mobility (for example, if a person of 1 m, 6 cm height dons a universal type immersion suit, the shoes of immersion suit were too big for him to walk properly refer to below photo). Also, if the same person is to close the zipper all the way up to prevent ingression of water, he will have obstructed field of vision. This problem will be more severe for a person who wears spectacles. It is, therefore, necessary to have immersion suits in different sizes. Moreover, there is a problem of buoyant material in the front part of lifejacket becoming apart, making it difficult to properly don the lifejacket. Lastly, for persons of small physique, there is also a need to attach flaps around wrist and ankle areas of immersion suit for adjusting the suit. Universal type immersion suit

16 Page Donning safety helmets When an immersion suit was donned, it was not possible to secure a safety helmet on a person s head because the neck cord of helmet could not be adjusted. Consequently, there is a danger of head injury at the time of conducting abandonment duties, when swept by waves, etc. Safety helmet 4 DONNING AN IMMERSION SUIT INSIDE A TOTALLY ENCLOSED LIFEBOAT There is no regulation in SOLAS on how and when immersion suits shall be donned (refer to paragraph 3.1 above). However, as mentioned in document DE 50/13/3 (Japan), since immersion suits are provided for each person on board, it is likely that the crew, upon the master s orders, will carry out emergency duties with their immersion suits donned. It is also highly probable that the crew will not take their immersion suits off either before or after embarking on a lifeboat. In this regard, it may be necessary to assess whether or not it is necessary to keep immersion suits donned inside a totally enclosed lifeboat. This is because there are many problems associated with immersion suits donned while inside a lifeboat as mentioned in paragraph 3 above. As one of the solutions to these problems, especially in regard to problems which occur inside totally-enclosed lifeboats, it may be necessary to change the design of immersion suits and lifeboats. However, changing the design of lifeboats alone may not be sufficient to resolve a problem associated with staying inside a totally enclosed lifeboat while donning an immersion suit (see paragraph 3.6 above). In this regard, it may be worthwhile to consider the option of not donning an immersion suit while inside a totally enclosed lifeboat. For this, following items were reviewed. 4.1 Amendment of requirement for thermal protective aids according to revision of requirement for immersion suits According to the 1996 edition of SOLAS regulation III/32.3, cargo ships shall carry for each lifeboat on the ship at least three immersion suits or, if the Administration considers it necessary and practicable, one immersion suit for every person on board the ship. It is also stated that the ship shall carry thermal protective aids for persons on board not provided with immersion suits, but these immersion suits and thermal protective aids need not be required if the ship has totally enclosed lifeboats. However, the requirement for provision of thermal protective aids on board cargo ships was deleted with the adoption of resolution MSC.152(78) which requires an immersion suit to be provided for each person on board a cargo ship. However, LSA Code regulations and still require thermal protective aids to be provided in a

17 Page 15 liferaft/lifeboat (sufficient for 10% of the number of persons the liferaft/lifeboat is permitted to accommodate or two, which is the greater). In summary, thermal protective aids are no longer required to be provided on board cargo ships, while they are still required to be provided in liferafts/lifeboats as their equipment. 4.2 Background on the adoption of a requirement for the provision of an immersion suit for every person on board It is clear that the main objective behind the adoption of resolution MSC.152(78), which requires that an immersion suit be provided for each person on board, was to raise the survivability of crew members in cold waters in times of ship casualty. What is not clear is whether the protection of crew on board a totally-enclosed lifeboat from low temperatures was one of the objectives behind the adoption of resolution MSC.152(78) (MSC 74/21/3 (Canada)). 4.3 Summary a) It is not clear whether the original objectives behind the adoption of resolution MSC.152(78) also included the protection of crew members while they are inside a lifeboat, in addition to raising the survivability of persons in cold water. Also, there is no regulation in SOLAS on whether or not an immersion suit need to be kept donned inside a lifeboat. Consequently, there is a need to review this matter further in the future to seek alternative solutions other than redesign of lifeboats. b) The thermal protective aids on board cargo ships is no longer required to be provided on board cargo ships due to the adoption of resolution MSC.152(78), but still need to be provided in lifeboats/liferafts as their equipment by the LSA Code. This can be interpreted to mean that as long as a lifeboat/liferaft is embarked with immersion suits donned there is no need to provide thermal protective aids in lifeboats/liferafts. As a result, this matter should also be looked into by DE in the future.