IMO WORK PROGRAMME. Alternative arrangements for the bottom inspection requirements for passenger ships

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1 INTERNATIONAL MARITIME ORGANIZATION E IMO MARITIME SAFETY COMMITTEE 84th session Agenda item 22 MSC 84/22/10 5 February 2008 Original: ENGLISH WORK PROGRAMME Alternative arrangements for the bottom requirements for passenger ships Submitted by the Bahamas and Cruise Line International Association (CLIA) Executive summary: Strategic direction: 1, 2, 5, 8, 12 High-level action: 1.1, 1.3.5, Planned output: Action to be taken: Paragraph 28 Related documents: SUMMARY This document proposes that Guidelines be developed to ensure that sound technical judgement is exercised by Administrations which allow their passenger ships (other than ro-ro passenger ships) to have an of the outside of the ship s bottom carried out in water, rather than in dry dock. The proposal takes into consideration possible scope for misinterpretation between the Guidelines on HSSC resolution A.997(25) and the mandatory requirements of SOLAS 1974, as amended, regulation I/7(ii). Resolution A.997(25), paragraph 5.10; SOLAS 1974, as amended, regulation I/7(ii); MSC 83/28, paragraphs to 15.31; resolutions A.948(23), A.900(21), A.989(25) and A.990(25); MSC 83/15/5 Introduction 1 This document proposes a new item on the work programme for the relevant Sub-Committee in accordance with the provisions of items 2.10 to 2.30 of the Guidelines on the organization and method of work of the MSC and the MEPC and their subsidiary bodies (MSC-MEPC.1/Circ.1). 2 The twenty-fifth session of the IMO Assembly adopted resolution A.997(25) on Revised survey guidelines under the harmonized system of survey and certification (HSSC), paragraph 5.10, that recommends a minimum two of the s of the outside of the ship s bottom during any five-year period should be conducted in dry-dock. At the same time the Guidelines permit to carry out other renewal surveys with the ship afloat under certain conditions. 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.

2 MSC 84/22/ At the time of the approval of the draft revisions to resolution A.948(23) by MSC 83 for submission to the twenty-fifth session of the Assembly, the Bahamas and CLIA (MSC 83/15/5) proposed to introduce into the resolution the possibility of one dry-docking in a 5-year period. The proposal envisaged that a bottom in dry dock will be able to be substituted by the bottom with a vessel in water, under certain favourable conditions only. The proposal has received support from a number of Member States. 4 The Committee, having considered the proposal and having recognized its potential merit, subject to the detailed review and clarification of the elements contained therein and the possible development of additional guidance by relevant IMO bodies, invited Member States to consider proposing new items to be added to the work programmes of relevant sub-committees. This document is submitted under the above instructions. Scope of the proposal 5 SOLAS regulation I/7(ii) specifies the requirements for the renewal survey for passenger ships. In particular, the regulation requires an of the outside of the ship s bottom to ensure that the ship complies with the requirements of the present regulations and of the laws, decrees, orders and regulations promulgated by the Administration. Therefore it is clear that the mandatory instrument does not prescribe the method by which the flag Administration, or its recognized organization, shall carry out the required and this permits the Administration to make that decision. 6 It is recognized that several flag Administrations and their recognized organizations have developed, with the passenger ship industry, schemes for ship surveys where the one bottom in dry-dock in 5 years principle has been used. The schemes align the statutory requirement with those of classification societies for passenger ships less than 15 years of age where the bottom with vessel in water is carried out in lieu of the intermediate bottom in dry dock within the 5-year cycle. The schemes have been applied to passenger ships over several years and have proven successful. 7 The sponsors of this paper recognize that concern was expressed by several Administrations at MSC 83 that this scheme should not be intended to apply to ro-ro passenger ships. While these Administrations indicated they fully understood that the scheme would be subject to approval of the flag State, they also indicated that the possibility of including ro-ro passenger ships should not be implied within such a bottom scheme and that ro-ro passenger ships should be specifically excluded. 8 The immediate proposal is to develop guidelines on the technical justification for a one in five bottom in dry dock as an MSC circular. A proposed draft MSC circular is offered in the annex to this document. 9 It is also proposed to ultimately amend the HSSC Guidelines to explain the possibility of alternative arrangement where one bottom in dry dock may be substituted by bottom with vessel in water (BIIW) which is technically equivalent to an in dry dock. Identification of the need 10 Whilst it is acknowledged that the guidelines in resolution A.997(25) are of a recommendatory nature, it is recognized that in the absence of a different requirements,

3 - 3 - MSC 84/22/10 Member States are encouraged to follow the resolution, which may be construed as a mandatory requirement. 11 It is the view of the sponsors that the proposed Guidelines should facilitate compliance with, and an understanding of, the mandatory requirements of the Conventions. Taking into account what is said in paragraph 5 above, namely that SOLAS does not require two bottom s in dry dock in 5 years for passenger ships, the HSSC Guidelines may be amended in order to allow the possibility of the use of other means of of the outside of the ship s bottom during the intermediate survey which would take into account the MSC circular on technical justification. 12 If the HSSC Guidelines remain silent on this there is a possibility for different interpretation by port State control authorities leading to possible unjustified detention of passenger ships. It should be noted that there are some regions which obligate its members (and recognized organizations, if applicable) to apply resolution A.997(25) to ships flying their flag. It is not clear whether the PSC authorities of these States would display a uniform understanding of bottom requirements to all ships calling at ports within their region. With the absence of predictability or clear instructions through the international instruments, there is the possibility of significant negative impact on the passenger ship industry. Analysis of the issue involved, having regard to the costs to the maritime industry and global legislative and administrative burdens 13 There is evidence that with the increase in the number of ships, including passenger ships which are increasing in size and require use of specific facilities, the industry is challenged with the demand for docking space and this approach would free up the limited dry-docking spaces. 14 Therefore, if the BIIW is carried out at the second or third anniversary after the bottom in dry dock, the regime for the bottom of a passenger ship could be as follows: Year Survey in dry dock afloat afloat or BIIW afloat or BIIW afloat in dry dock 15 It should be noted that the BIIW is to be technically equivalent to an of the ship s bottom in dry dock, as set out in the Guidelines for Harmonized Survey and Certification (resolution A.997(25)). 16 It should be emphasized that any deficiencies discovered during a BIIW or any other surveys that require an of a tank or the hull (e.g., survey following grounding, etc.) would be evaluated and may require the vessel to be docked for repair. 17 As can be seen, there is a major benefit to harmonization arising from the proposal which will align the international requirements in various instruments. The sponsors are aware that a number of Administrations, classification societies and passenger ship operators have already developed, and are implementing, provisions relating to one bottom in dry-docking in 5 years. Consequently, for those stakeholders that are already taking action, it is not envisaged

4 MSC 84/22/ that the amendment of these internationally agreed guidelines will have a significant financial impact on operators. IMO guidelines on this issue will also not have a direct impact on the legislative and administrative burdens on Administrations, as it will be left to individual governments to decide if and how to implement these provisions to their ships. Benefits which would accrue from the proposal 18 The aim of the proposal is to bring clarity into the requirements within the international instruments and to avoid confusion amongst PSC authorities as to the extent of compliance of the affected ship with the HSSC Guidelines. The potential disputes on the interpretation delaying passenger ships in ports would have a significant impact of the international passenger ship industry. 19 The sponsors believe that the Administrations, recognized organizations and the passenger ship industry will benefit from the predictability afforded by the clear recognition of the present justified practice. 20 The proposal would free up dry-docking spaces which would enable a focus on those ships which do not have the one in five bottom in dry-dock programmes in place. Priority, target completion date and estimation of the number of sessions needed to complete the work 21 Noting the criteria provided in paragraph 2.14 of MSC-MEPC.1/Circ.1, the sponsors believe that this issue should be considered as a high-priority work programme item for the Organization. In particular, it is considered that the proposed measures will promote the widest possible implementation and enforcement of IMO instruments by the shipping community as a whole (paragraph ), will correct significant inadequacies identified in existing instruments (paragraph ), will align IMO rules and standards with those of other relevant international instruments and organizations (paragraph ) and will take into account the introduction of new technology and methods (paragraph ). 22 As instructed by MSC 83 (reference is made to paragraph 4 above), it is proposed that the issue should first be discussed by the relevant Sub-Committee from the technical point of view and, based on the proposals made in paragraph 23 below, thereafter referred to the next meeting of the FSI Sub-Committee for consideration and advice as the body responsible for keeping the Guidelines under review under the standing agenda item. Resolution A.997(25) could be amended by an appropriate MSC resolution, if so desired. The attached proposed draft Guidelines on assessment of technical provisions for the acceptance of one bottom in dry dock in five years for passenger ships other than ro-ro passenger ships, could also be reviewed and further developed by DE 52, anticipated completion at that session. The Guidelines on assessment of technical provisions for the acceptance of one bottom in dry dock in five years for passenger ships, other than ro-ro passenger ships could be approved by MSC 85. Specific indication of the action required including the draft texts of the proposed requirements, if possible 23 It is proposed that the relevant Sub-Committee develops the attached draft MSC circular on technical provisions for accepting the bottom carried out in water in lieu of the bottom in dry dock. If the MSC circular is approved, the MSC is requested to bring

5 - 5 - MSC 84/22/10 this to the attention of the FSI Sub-Committee with a view to amending paragraph 5.10 of the Guidelines in resolution A.997(25). Is the subject of the proposal within the scope of IMO s objectives and how is the proposed item related to the scope of the Organization s Strategic Plan and the High-level action plan? 24 Noting resolution A.900(21) on Objectives of the Organization in the 2000s, the sponsors consider that this proposal is consistent with the objectives of ensuring the effective uniform implementation of existing IMO standards and regulations relating to maritime safety and environmental protection, addressing safety and environmental policy issues, to the extent feasible, by ship types, with particular emphasis on passenger ships and avoiding excessive regulation. 25 In considering resolution A.989(25) on Strategic Plan for the Organization (for the six-year period ), the sponsors believe that the following Strategic Directions (SDs) are addressed in this proposal: SD1 enhancing the status and effectiveness of the IMO (especially that IMO is the primary international forum for technical matters of all kinds affecting international shipping ); SD2 fostering global compliance with its instruments governing international shipping and promoting their uniform implementation by Member States; SD5 developing and maintaining a comprehensive framework for safe, secure, efficient and environmentally sound shipping (especially ensuring that all systems related to enhancing the safety of human life at sea are adequate, including those concerned with large concentrations of people ); SD8 seeking to ensure that measures to promote safe, secure and environmentally sound shipping do not unduly affect the efficiency of shipping by constantly reviewing such measures to ensure their adequacy, effectiveness and relevance, using the best available tools; and SD12 encouraging the utilization of the best available techniques not entailing excessive costs, in all aspects of shipping. 26 Finally, the sponsors have reviewed resolution A.990(25) on High-level Action Plan of the Organization and priorities for the biennium. The following High-Level Actions (HLAs) have been identified as particularly relevant in the context of this proposal: HLA take the lead and actively promote its role as the primary international forum on matters within its purview; HLA harmonize IMO instruments with other relevant international instruments, as necessary noting that, in this instance, the harmonization is not with other international instruments but with a mandatory IMO instrument and a number of industry standards; and

6 MSC 84/22/ HLA keep under review the technical and operational safety aspects of all types of ships in particular Revised Survey Guidelines under the Harmonized System of Survey and Certification. Do adequate industry standards exist? 27 A number of flag Administrations have established schemes which are based on the requirements of the classification societies authorized to perform statutory services for passenger ships on their behalf. The rules of the affected classification societies prescribe the one dry-docking survey in five years and the conditions under which it can be accepted. Action requested of the Committee 28 The Committee is invited to consider the proposed action in paragraph 23 and decide accordingly. ***

7 MSC 84/22/10 ANNEX DRAFT MSC CIRCULAR GUIDELINES ON THE ASSESSMENT OF TECHNICAL PROVISIONS FOR THE ACCEPTANCE OF ONE BOTTOM INSPECTION IN DRY DOCK IN FIVE YEARS FOR PASSENGER SHIPS, OTHER THAN RO-RO PASSENGER SHIPS 1 The Maritime Safety Committee, at its [eighty-sixth session (TBA)], noted the inconsistency that exists between SOLAS regulation I/7(ii) and resolution A.997(25) on Survey Guidelines under the Harmonized System of Survey and Certification, concerning the use of methods to inspect the outside of the ship s bottom. 2 Recognizing the intent of SOLAS regulation I/7(ii) to not restrict the methods of of the outside of the ship s bottom in light of the technological developments which could provide solutions technically equivalent to the bottom in dry dock, the Committee confirmed that Administrations may consider alternative means of of the outside of the ship s bottom of passenger ships (e.g., survey with vessel in water) in lieu of one of the bottom s in dry dock specified in paragraph 5.10 of resolution A.997(25), subject to successful consideration by the Administration of the application in accordance with the provisions contained in the annex.

8 MSC 84/22/10 ANNEX Page 2 ANNEX Only passenger ships which have the classification notation for the bottom with vessel in water (BIIW) are normally considered for admission under the scheme. Classification requirements should be enforced at the new construction stage or for existing ships when the plans and information covering the below mentioned items are submitted to the classification society for approval. The bottom with vessel in water may be carried out in conjunction with a full classification survey, considered to be in lieu of one of the two dockings required for classification in a 5-yearly cycle, on ships with the relevant class notation confirming vessel s suitability to have bottom survey carried out in water. The Administration may permit to substitute one of the bottom s in dry dock specified in paragraph 5.10 by the bottom with vessel in water (BIIW), subject to close consideration of a vessel s technical suitability for the to be carried out in water. The request should be made to the Administration in advance of the survey and should demonstrate satisfactory compliance with the following technical and procedural provisions: 1 The appropriate plans showing the following details should be submitted to the Administration or its RO:.1 The ship must have a suitable 1 high-resistance paint applied to the underwater hull in accordance with the manufacturer s instructions;.2 It must be possible to measure 2 rudder stock, pintle and/or shaft and bush clearances, and verify the security of the pintles in their sockets with the ship afloat;.3 It must be possible to measure 3 stern bush clearances with the ship afloat. The measurement would not apply to podded propulsion system but if should be possible to;.4 The hull must be permanently marked to enable identification of the area being surveyed; A high resistant paint (HRP) coating is assessed on its paint properties, surface preparation and application requirements. [The following paint types are considered as HRPs epoxy and modified epoxy, coal tar epoxy, vinyl and vinyl tar, polyurethane and polyurethane tar, chlorinated rubber, bituminous aluminium and zinc silicate. Alkyd based paints and soft and semi-hard paints are not HRPS.] The conditions of the HRP are to be confirmed at each dry-docking. Access must be provided to enable the diver to measure pintle clearances in the afloat condition, this might be by design, by a permanent opening or via a bolted steel cover. Poker gauge readings/clearance should be measurable in the afloat condition, either by design, an access opening or bolted steel cover.

9 MSC 84/22/10 ANNEX Page 3.5 Maintenance and measurements required for propulsion train and all other equipment attached to, or protruding from, the underwater hull must be able to be carried out in accordance with manufacturers instructions, where due at the time of bottom in water. 2 Where it has been agreed than a BIIW may be held, the must be held using an Approved 4 Diving Company in an Approved 5 Location, with CCTV and still photos (if the latter is required) and the surveyor in attendance and 2-way communication with the diver. The hull below the waterline is to be clean. Pintle and stern bush clearances must be measured and recorded. The Administration or its RO is to maintain the lists of Approved Diving Companies. Additionally, lists are to be maintained of Approved 6 synthetic pintle bearing materials All firms providing services on behalf of the owner of a ship or a mobile offshore unit (such as measurements, tests, surveys or maintenance of safety systems and equipment), the results of which are used by the surveyors in making decisions affecting certification, are subject to approval by the Administration or RO. This includes Diving Companies, which will undergo an approval proves, and will be certified on a 5-yearly basis, subject to annual audit. The Administration or its RO will maintains a list of approved diving companies. An approved location is one where it has been satisfactorily demonstrated that the criteria for carrying out a satisfactory bottom survey of the vessel in water have been met, in particular with regard to in-water visibility, tidal and current conditions and a reasonably sheltered location. The approval of a location is based on its acceptance to the attending surveyor and diver taking into consideration any developed guidelines. All synthetic bearing materials are to be approved by the Administration or its RO before use and its acceptance of synthetic materials for rudder bearings is achieved in stages, from Provisional to Final approval, based on various factors including service experience. The Administration or its RO maintains lists of approved bearing materials. Technically equivalent to the bottom in dry dock, in that all the measurements required to be carried out are taken at a bottom survey with the vessel in water, and the requirements for visibility, tide and current, combined with an approved diving company and qualified and authorized surveyor ensure that the underwater shell and appendages are surveyed to a very high standard.