Working together for a safer world IMO Ship Design and Construction (SDC 2) Agenda Preview Introduction The 2nd session of the IMO Sub-Committee on Ship Design and Construction (SDC) will be held from the 16 to 20 February 2015, at the IMO headquarters in London. This briefing summarises subjects under discussion which are relevant to the work of Lloyd's Register out of documents submitted by 29 January 2014. Overview of agenda items The following agenda items are relevant to the work of Lloyd’s Register. Decisions of other IMO Bodies (Agenda item 2) SDC 2 will consider the outcome of PPR 1, MSC 93 and MSC 94 for the following subjects: - PPR 1 requested that SDC 2 considers two chapters of the draft OSV Chemical Code (a revision of Resolution A.673(16)), see also Any Other Business (Agenda item 24). MSC 93 required SDC 2 to: consider the issue of a double hull in passenger ship engine rooms and the index R for passenger ships under agenda item 3 amend SOLAS and the FSS Code to mandate evacuation analysis mandatory for new passenger ships, confirming that there should be no requirements on survey or certification, agenda item 14 consider damage control drills on passenger ships, agenda item 17 MSC 94 required SDC 2 to: consider the timing of a meeting of the FSA Experts Group, which is to review the results of the EMSA 3 study related to the survivability of passenger ships, agenda item 3 The outcome of CCC 1 and MEPC 67 concerning the Polar Code and IGF Code decisions will also be considered under this agenda item. Amendments to SOLAS chapter II-1 subdivision and damage stability regulations (Agenda item 3) Amendments to SOLAS chapter II-1 to harmonize cargo ship and passenger ship damage stability have been in force since 1 January 2009. These amendments made probabilistic damage stability the main method for calculating damage stability for passenger ships and general cargo ships. Since the amendments have entered into force the need for a number of revisions has become apparent. A major review of the subdivision and damage stability requirements contained in chapter II-1 of SOLAS has been undertaken. SDC 2 will consider progress with this review and the amendments which have been proposed. The below issues have been discussed in an intersessional correspondence group, which has finalized some amendments to SOLAS chapter II-1: - Regulations 21 & 22, to change text from “leaving port” to “the voyage commences” Regulation 35-1, whether to retain the use of the bilge pump numeral or if R should be used instead and the length limit which is used. The correspondence group has also extensively discussed amendments to the associated explanatory notes. Further discussion is needed in the following areas: Lloyd’s Register Briefing Note – SDC 2 Agenda Preview February 2015 1 Lloyd’s Register Briefing Note – SDC 2 Agenda Preview February 2015 - - - 2 Note for regulation 2.11, the definition of light service draught Notes for regulation 5-1, extensive revision is required particularly following the reordering of the regulation as previously agreed Notes for regulation 7, in particular concerning the calculation of index “A” for series sister ships with differing lightweights and the related issue of what to do when the inclined lightweight differs from the preliminary value used in the calculations. Additionally how to calculate the penetration depth with complex waterline shapes, the relative sizes of stiffeners and pipes/valves and issues surrounding cross-flooding. New notes for regulation 9, to include diagrams on arrangements of small wells / other wells and clarification on “all service conditions” New notes for regulation 12 covering pipes penetrating the collision bulkhead. New notes for regulation 12 for dealing with ships where the aft peak bulkhead and the aft ER bulkhead are coincident and for ships with a raised quarter deck when the freeboard deck does not extend to the aft peak bulkhead. Notes for regulation 17, in particular concerning the use of watertight, “semi-watertight” and/or “light watertight” doors in partial watertight bulkheads. Areas where further discussion is required relating to proposed SOLAS amendments are: - Regulation 8-1, to provide requirements for minimum double side protection of the main engine room Regulation 9, to clarify “small wells” and extend the application to passenger ships Regulation 13, to require an anti-crushing device to be fitted to watertight doors Regulation 16-1.2, concerning the head to which ventilation trunks should be tested ) Regulation 35-1, the damage cases which need to be considered under which the bilge pumps are required to be operable In addition there is a proposal for all passenger ships to be included in a database which will give the value of the attained index “A” and the required index “R”. Target completion date is 2015. Lloyd’s Register’s view Lloyd’s Register has been involved in the correspondence group and will continue to contribute to the work where practical. It should be noted that previous sessions of IMO Sub-Committees (SLF and SDC) have agreed amendments to SOLAS chapter II-1. Guidelines on safe return to port for passenger ships (Agenda item 4) Changes to SOLAS chapter II-1/8-1 (Resolution MSC.325(90)) entered into force on 1 January 2014. They required the provision of a computer either on board or ashore which can calculate stability after damage to any selection of compartments. Guidelines on the information which is to be provided have been given in MSC.1/Circ.1400 “Guidelines on operational information for Masters of passenger ships for safe return to port by own power or under tow”. Concern has been raised that existing guidance on the functionality of the computer programs is inadequate, and that further guidance is needed for these specific computers. There was not much discussion on this subject at SDC 1, but a correspondence group has discussed the guidelines and has developed some text for further consideration. The subject will be further considered at SDC 2. Lloyd’s Register’s view The proposed guidance for the system (onboard and ashore computers) is comprehensive. Systems are expected to be capable of calculating stability characteristics from any damage scenario. Information on the damage location and extent could be entered either manually or via sensors. It also needs to be able to use data from normal use (i.e. the intact condition prior to the damage) in the damage incident and handle free surface effects from entering water. Lloyd’s Register has concerns with the approval of software which accepts readings from tanks and draught reading systems. The mechanisms used to approve these systems will be very complex and a very clear acceptance standard will be needed. The extent that software is considered to be “the same or similar” will need to be clear and could be restrictive. An emergency response service could not be expected to have experts in the use of all the different computer systems which are currently available, and new systems would be very difficult to market. Lloyd’s Register Briefing Note – SDC 2 Agenda Preview February 2015 3 There are many different methods to calculate residual strength and requiring approval of this aspect will be challenging. Other legislation, e.g. OPA 90 and MARPOL Annex I, Reg. 37.4 does not require approval of the shorebased system or its methods. Target completion date is 2015. Second-generation intact stability criteria (Agenda item 5) This subject has been considered for a number of years. It is concerned with the assessment of dynamic intact stability. Progress has been slow due to the complexity of these issues. The IMO has planned a three tier approach to vulnerability assessment for each of these criteria with each level becoming more complex. A design must pass the assessment at one of these levels: - Level 1: simple calculation (possible by calculator) - Level 2: more involved calculation (may involve spreadsheets or small software program) - Level 3: direct assessment (by sophisticated software) Ships deemed ‘conventional’ are expected to pass level 1 and most other ships at level 2. A ship complying with the simplest level (level 1) will not have to carry out difficult calculations at levels 2 or 3. Further ‘operator guidance’ is envisaged as a natural output from level 3 assessments. A common format for the different criteria has been agreed. Each criterion should clearly state: - the data needed for the criteria (inputs) the format and content of the result (e.g. limiting value for KG, or yes/no assessment) possible counter measures detailed information on how to do the calculation with an example The Correspondence Group has made good progress this year. Draft amendments to Part B of the 2008 Intact Stability (IS) Code for parametric rolling, pure loss of stability and broaching failure modes have been provided. However, there are still some undecided elements for the calculations and this is even more so for the two remaining failure modes; excessive acceleration and dead ship criteria. Target completion date is 2015. Lloyd’s Register’s view Care is needed that the new criteria are understandable by those onboard ships that will be expected to use them. Amendments to the criterion for maximum angle of heel in turns of the 2008 IS Code (Agenda item 6) The current formula for assessing the maximum angle of heel in a turn assumes a diameter of turn equal to 10 ship lengths. This is inconsistent with the standards for ship manoeuvrability contained in Resolution MSC.137(76), which recommends 5 ship lengths as a maximum. The reason for this difference and possible solutions to making the two consistent have been discussed for a number of sessions at the IMO. Further discussion on the matter is expected at this session as details of an assessment of the effect of the turning coefficient on the calculated angle of heel in turns, which has been carried out on a number of ships, have been provided. Lloyd’s Register’s view Care needs to be taken to ensure that any changes to regulations are fully justified and will not have unexpected consequences. Target completion date is 2015. Amendments to part B of the 2008 IS Code on towing, lifting and anchor handling operations (Agenda item 7) Following the sinking of the “Bourbon Dolphin” the IMO has been reviewing requirements for ships which undertake towing, lifting and anchor handling operations. Draft criteria for towing are close to being agreed, however those for lifting and anchor handling still require further development work. Target completion date is 2015. Lloyd’s Register’s view Lloyd’s Register Briefing Note – SDC 2 Agenda Preview February 2015 4 Good operational practice should already include consideration of stability when undertaking towing, lifting or anchor handling operations. However having a single standard will make operations in different areas easier and will simplify training requirements. It is noted that the proposed criteria will be present in Part B of the 2008 IS Code which is nonmandatory. Flag Administrations should clearly state when they consider the criteria to be mandatory. Guidelines addressing the carriage of more than 12 industrial personnel on board vessels engaged on international voyages (Agenda item 8) This agenda item and agenda item 9 are closely related to each other. There has been an increase in the number of ships used to construct and maintain structures offshore, in particular wind farms, and there is much discussion about the designation of the people who are either working from the vessels or are transported to the structures by the vessels. This agenda item is concerned with the definition of industrial personnel who are carried on board the vessels and to provide guidance on how this definition is to be applied. Currently, under the SOLAS definitions, most Administrations consider these persons, if transported only, as passengers and the vessels concerned should be considered as passenger ships when the number of passengers exceeds 12. Also, where personnel are only working partly on board Administrations interpret things differently. Some would accept MODU Code compliance even though they are not drilling units; some would accept them as Special Purpose personnel under the SPS Code even though the persons are not necessarily working on board. During SDC 1 there were a large number of delegations of the view that the personnel carried onboard are generally more familiar with the vessel and will be fit and able bodied unlike a usual passenger. It is therefore considered unreasonable to consider the personnel as passengers. A draft circular including a definition for “industrial personnel” and when it should be used has been prepared. However a number of issues relating to the definition remain to be further discussed: - Whether the definition of “industrial personnel” is an interpretation of SOLAS I/2(e)(i) or introduces a change to SOLAS. The scope of application of the guidelines. Whether the development of such a definition requires further consideration of all aspects of SOLAS. Whether the personnel are “transported or accommodated” or “transported and accommodated”. Whether additional footnotes are justified or not. Target completion date is 2015. Classification of offshore industry vessels and a review of the need for a non-mandatory code for offshore construction support vessels (Agenda item 9) In association with the discussions under agenda item 8 there has been ongoing work on developing some guidelines for offshore service craft and offshore construction vessels. The former maintain offshore structures, the latter build them. For offshore service craft (OSC) the proposal is for vessels to meet either the SPS Code standard or the HSC Code standard. Decisions are still needed on the application criteria (some OSC will be less than 500 gt), a total limit for the number of people onboard and requirements for environmental protection. Draft text for guidelines is provided for discussion. For offshore construction vessels (OCV) no draft text has been developed. It is expected that when drafted these guidelines would cover vessels which were self-elevating, self-propelled and equipped with dynamic positioning systems. Target completion date is 2015. Amendments to SOLAS regulation II-1/11 and development of associated Guidelines to ensure the adequacy of testing arrangements for watertight compartments (Agenda item 10) It was noted that well established and proven practices used for testing the integrity of watertight compartments intended to contain liquids are at variance to a certain degree with both the previous requirements of SOLAS (which addressed the testing of subdivision boundaries for water-tightness) and the new requirements contained in Resolution MSC.194(80) that entered into force on 1 January 2009, which include additional requirements for testing the structural strength of tanks intended to contain liquids. Another element under discussion is dispensation of testing for sister ships, where shipyards provide evidence on their fabrication quality. Lloyd’s Register Briefing Note – SDC 2 Agenda Preview February 2015 5 A correspondence group has been discussing the issues and further intense discussion is expected. Target completion date is 2015. Lloyd’s Register’s view This is a contentious issue but it needs resolving. Provisions to ensure the integrity and uniform implementation of the 1969 TM Convention (Agenda item 11) A number of clarifications to the 1969 TM Convention have been made and released as Circular TM.5/Circ.6 but a number remain outstanding. In particular the following matters have been put to SDC for consideration: - The treatment of cooler pipework under the TM Convention The measurement of spaces in ships constructed of materials other than metal The implementation of a limit for re-measurement when there has been no alteration or modification A reduced gross tonnage to account for accommodation remains undecided from previous meetings. A proposal for a calculation and draft resolution has been submitted. Lloyd’s Register’s view Consistency in application is important with regulations which are to be applied internationally and the clarifications contained in TM.5/Circ.6 are welcome. Where further matters requiring clarity are identified it is important that these are discussed and agreed. Target completion date is 2015. Guidelines for use of Fibre Reinforced Plastic (FRP) within ship structures (Agenda item 12) SDC1 decided that regulation II-2/17 could be used as the basis for an assessment of FRP structure. However, a number of members expressed concerns about the use of FRP in ships. In particular the work so far has focused on the fire integrity and not the structural and thermal requirements. A correspondence group was established to continue working intersessionally. The work done by the correspondence group established by the FP Sub-Committee was discussed in some depth at SDC 1. It was agreed that use could be made of SOLAS II-2/17 as a basis for assessment of whether a structure was equivalent to steel or not. However there was some concern that issues other than fire integrity (which regulation II2/17 covers) are not being considered, e.g. the structural and thermal aspects. There may also be a need to review the requirements of SOLAS II-2/2 (fire safety objectives) to ensure that they adequately cover all aspects. There were still many who viewed the use of FRP as not acceptable. It was agreed to establish a correspondence group to continue the discussion with particular emphasis on developing the draft guidelines to be used for assessment and testing of FRP structures and report to SDC 2. It is important to emphasize that the draft guidelines are not to be regarded as a complete guide to FRP design but rather as a guide for the administrations when reviewing proposed alternative designs. Each individual design shall be individually investigated and reviewed and all possible concerns for all designs cannot be included in the guidelines. However, the intention is that the guidelines will give the necessary guidance for reviewing most of the anticipated FRP designs. The SDC Sub-Committee is also advised of a new standard, ASTM F3059, has recently become available which addresses safety requirements for FRP gratings. Lloyd’s Register’s view Use of a light weight material would help in designing energy efficient ships. However, it should be noted that IMO is taking a cautious approach to ensure the safety of ships and the personnel on board. Target completion date is 2015. Lloyd’s Register Briefing Note – SDC 2 Agenda Preview February 2015 6 Amendments to SOLAS chapter II-2, the FTP Code and MSC/Circ.1120 to clarify the requirements for plastic pipes on ships (Agenda item 13) At SDC 1 a proposal to amend the requirements for plastic pipes as contained in the International Code for the Application of Fire Test Procedures (FTP Code), SOLAS II-2/188.8.131.52 and MSC/Circ.1120 was presented and briefly discussed. No conclusions were reached and it was decided that further work was needed and that the subject would be further considered at SDC 2. The main discussion points covered were as follows: - The categorisation of pipes, whether the existing categories could be reduced or not, Which tests are required, i.e. should they cover low flame spread only or also smoke production and toxicity as well, and The possible application to existing ships. Lloyd’s Register’s view Manufacturers/suppliers of plastic pipes and plastic pipe penetrations should closely monitor these rule developments as there could be cost implications. Additional tests for plastic pipes may be necessary to comply with any new requirements that will be developed in relation to their fire endurance and low flame spread properties. Additional testing for plastic pipe penetrations may also be required to comply with any new test requirements that may be developed to verify their ability to prevent the downward spread of fire. Designers: The closing arrangements of penetrations may need to be reviewed in light of the new developments. The lay out/arrangements for plastic pipes (not permanently filled with water) may need to be amended to comply with any new requirements. There could also be restrictions in the use of plastic pipes in watertight compartments. Target completion date is 2015. Amendments to SOLAS and FSS Code to make evacuation analysis mandatory for new passenger ships and review of the Recommendation on evacuation analysis for new and existing passenger ships (Agenda item 14) At SDC 1 the following points were discussed: - Whether to mandate evacuation analysis to all passenger ships (currently mandatory for ro-ro passenger ships only) The development of guidelines for such an analysis. SDC 1 agreed that evacuation analysis should be mandated for all passenger ships. However care would be needed to ensure that there were appropriate requirements for smaller passenger ships as the methodologies for large cruise ships would not necessarily be applicable to small passenger ferries. SDC 2 will consider submissions which: - propose amendments to MSC.1/Circ.1238 such as those covering the consistency in travel speed and scenario for secondary evacuation cases provide a draft of an amendment to SOLAS regulation II-2/13 at annex; and propose the establishment of a Correspondence Group to review MSC.1/Circ.1238 in light of the proposed amendments to SOLAS vide the above referred paper. Lloyd’s Register’s view Designers of passenger ships should be prepared for mandatory evacuation analysis. Details on what will be required are still to be finalised but it is expected that existing procedures for evacuation will have to be reviewed and updated. Owners of passenger ships should be aware that an evacuation analysis will be required on existing ships as well as new designs. Target completion date is 2015. Interpretation of SOLAS regulation II-2/13.6 on means of escape from ro-ro cargo spaces (Agenda item 15) SDC 1 considered three different proposals for interpretations on SOLAS II-2/13.6. It was recognised that there was some similarity between them; two means of escape were required, one of which could be a vertical ladder and that emergency breathing apparatus should be provided. Views were also expressed that: - any enhanced measures should be appropriate for the risks and should be applied to new ships only, Lloyd’s Register Briefing Note – SDC 2 Agenda Preview February 2015 - 7 one of the means of escape should be protected against fire, any requirement for continuous fire shelter would be outside the scope of the agenda item, and escape routes should be clearly marked. SDC 2 will consider a submission paper which seeks clarification on the arrangement of a safe escape route from ro-ro spaces on cargo ships and provides a proposal on how to proceed with the matter. Lloyd’s Register’s view The design and arrangements for the escape routes from ro-ro spaces of cargo ships will need to be reviewed. If the proposals are accepted then the same level of protection as for passenger ships will be required to be provided for cargo ships with ro-ro spaces. This could have significant impact on the design of ships with ro-ro spaces. Target completion date is 2015. Review of conditions under which passenger ship watertight doors may be opened during navigation and development of amendments to SOLAS regulation II-1/22 and MSC.1/Circ.1380 (Agenda item 16) Certain watertight doors are permitted to be left open under certain circumstances by SOLAS with guidelines for assessing which doors can be considered acceptable for leaving open. The current guidelines (MSC.1/Circ.1380) separate watertight doors into four categories depending on the frequency and time of opening. “Category A” doors are permitted to remain open at all times. SDC 2 will consider proposed revisions to SOLAS II-1/22 and MSC.1/Circ.1380 to remove “Category A” watertight doors. Amendments to SOLAS chapter II-1 and associated guidelines on damage control drills for passenger ships (Agenda item 17) SDC 2 will consider this new work item for the first time. The MSC working group on passenger ship safety had considered a number of proposals for measures to improve the safety of passenger ships. One of these proposal was to require that passenger ships hold regular damage control drills and MSC 93 agreed that SDC should develop appropriate amendments to SOLAS II-1 and relevant guidelines. MSC 93 was clear that the scope should not be extended to ships other than passenger ships. SDC is to work with HTW on the development of appropriate amendments to SOLAS and associated guidelines. A proposal has been made for a new regulation (SOLAS II-1/19-1) requiring drills to be held every month. The proposal is that each drill would include the following: - summoning crew to damage control stations reporting to stations and preparing for the duties described in the muster list use of either onboard stability computer or the activation of shore-based support operation of watertight doors testing of flooding detection systems testing of cross-flooding or equalization systems operation of bilge pumps and associated systems instruction in damage survey, use of the ship’s damage control systems and passenger control in emergency situations. Lloyd’s Register’s view Passenger ship owners should make themselves aware of this development and carefully consider the potential consequences. If shore based support is used then there will be a need to review the support provided to ensure that it will cover drills of this sort. Lloyd’s Register supports the use of drills to help the crew become familiar with what actions they need to take in an emergency. Target completion date is 2016. Guidelines for wing-in-ground craft (Agenda item 18) In 2002 the IMO developed interim guidelines for wing-in-ground (WIG) craft, circular MSC/Circ.1054. This circular now needs reviewing to take into account experience in its use since its introduction. It was agreed that this was a difficult area and that the aviation industry should also be involved in any discussions. SDC 2 will consider submissions with proposed amendments to the circular. Target completion date is 2015. Lloyd’s Register Briefing Note – SDC 2 Agenda Preview February 2015 8 Review of general cargo ship safety (Agenda item 19) This agenda item considers the outcome of an FSA study which identified common causes of incidents involving general cargo ships. Previous sessions of IMO Sub-Committees have concluded that if the regulations are followed then the incidents should not happen. SDC 2 will consider whether any further measures are needed to strengthen the maintenance responsibilities for ship machinery and ship survey requirements. Target completion date 2015. Amendments to the 2011 ESP Code (Agenda item 20) The Enhanced Survey Programme (ESP) Code is a mandatory survey requirement for Oil Tanker and Bulk Carriers as required by SOLAS Regulation XI-1/2. The Code was adopted as A.1049 (27) which superseded the previous ESP programme (A.744(18)). The code has been regularly updated to maintain compatibility with the IACS requirements (UR Z10.1 and Z10.2) SDC 2 will consider further updates to the ESP Code based upon the submission from IACS. They reflect amendments made to UR Z10.1 (Rev.21), Z10.2 (Rev.21), Z10.4 (Rev.12), Z10.5 (Rev.14) which entered into force on 1 January 2015 for IACS member classification societies. The amendments addressed the following elements: - Revision to the procedure for entry into enclosed spaces including a reference to resolution A.1050(27) Editorial improvements This is a continuous agenda item. Unified interpretation to provisions of IMO safety, security, and environment-related Conventions (Agenda item 21) SDC 2 will consider unified interpretations on the following matters: - Provisions for means of access for inspections (SOLAS II-1/3-6) Continuous hatchways (Load Line regulation 36(6)) Prevention of heat transmission by insulation and structural details (SOLAS II-2/9.3.4 MSC.1/Circ.1120) SDC 2 will be asked to comment on the following matters where draft unified interpretations are presented: - Clarifications on the Noise Code Means of escape from machinery spaces on passenger ships (SOLAS II-2/13.4.1) Means of escape from machinery spaces on cargo ships (SOLAS II-2/13.4.2) Means of escape from accommodation spaces, service spaces and control stations on cargo ships (SOLAS II2/13.3.3) Ventilation ducts in B-Class divisions (SOLAS II-2/184.108.40.206) Two means of escape from machinery control rooms and main workshops (SOLAS II-2/13) Fire integrity of the boundaries of ro-ro/vehicle spaces on passenger and cargo ships (SOLAS II-2/220.127.116.11.2.1) This is a continuous agenda item. Lloyd’s Register’s view It is important that all regulations are implemented consistently by those responsible and unified interpretations are developed to help with this. Lloyd’s Register works with the other Classification Societies which are members of IACS for the development of unified interpretations and will implement them from the agreed dates. Any other business (Agenda item 24) SDC 2 will consider submissions on the following topics: - - Two chapters of the draft OSV Chemical Code (see also agenda item 2) covering ship survival capability and the location of tanks and requirements concerning cargo transfer. Some discussion on the appropriate stability standards is expected. Windows on passenger and special purpose ships and a possible error in SOLAS II-2/18.104.22.168.3. This is a continuous agenda item. 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