This Sub - Committee is now starting to address a number of significant issues within its remit. It is anticipated that the workload will steadily increase as more technical work is referred for detailed consideration from the Maritime Safety Committee (MSC). It is expected that a maximum of three IFSMA delegates will attend the meeting. Given that many of the Agenda Items will be subject to debate in Plenary, it is therefore essential that attention is paid to staffing throughout. There is no Plenary session scheduled for Thursday. Subjects were identified by the Sub–Committee at its 1st session and now form the following Working and Drafting Groups:

WG1 Subdivision and Damage Stability;
WG2 Intact Stability matters;
WG3 Fire Protection including review of the recommendations on evacuation analysis for the new and existing passenger ships;
DG1 Amendments to SOLAS regulation II-1/11 and developments of associated guidelines to ensure the adequacy of testing arrangements for watertight compartments;
DG2 Classification of offshore industry support vessels carrying more than 12 personnel on international voyages.

There are issues that will require an intervention, however, it is suggested that they are brief so as to be noted but not to attract possible counter arguments. Some of the issues appear complex but in reality relatively simple.

Agenda Item 1 – Adoption of the agenda
No substantive comment.

Agenda Item 2 – Decisions of other IMO bodies

Substantive issues are included in the main body of the agenda; however it is possible that issues may be subjected to detailed discussions. Increasingly, this is taking place and therefore, it is imperative that close attention is paid and intervention made as necessary.

Agenda Item 3 – SOLAS Chapter II-1 subdivision and damage stability regulations

SDC 2/3/1 submitted by Denmark, Germany and Netherlands, SDC 2/3/2, 2/3/3, 2/3/3 Add1 submitted by the UK as co-ordinator of the Correspondence Group. 2/3/4 submitted by the EU covers the same issue (resistance to raking damage). SDC 2/3/1 removed application to Passenger Ships but SDC 2/3/4 replaces this. SDC 2/3/6 submitted by the EU refers to the EMSA 3 study that will report shortly after SDC 2 and therefore any further work on passenger ship issues will be delayed until after the presentation of the study. This will not be until SDC 3 at the earliest. An intervention is unlikely. SDC 2/3/7 submitted by Germany on protection against crushing of people during the daily operation of watertight doors. This if agreed will be effective as from 2020 and is the first major change since 1914 where lights were added to supplement bells. This should be welcomed with a brief statement. SDC 2/3/9 submitted by the United States seeks to ensure the availability of power supply on passenger ships after damage. This Paper seeks to clarify the position as a consequence of a number of potentially serious incidents. The introduction of this Paper should be followed closely. A brief statement of support may be necessary. SDC 2/3/10 submitted by Denmark and the Netherland concerning applications of regulations for construction and testing of watertight doors to watertight hatches on cargo ships. An intervention is unlikely. SDC 2/3/11 submitted by the UK as co-ordinator of the Correspondence Group refers to the revision of subdivision index ‘R’. A brief statement of support may be necessary.

Agenda Item 4 – Guidelines on safe return to port for passenger ships

SDC 2/4 and 2/4/1 summited by the UK are the reports of the SDS Correspondence Group. There are issues concerning the availability of an on board stability computer software and remote sensors. A flawed concept is carried forward. Intervention will depend upon any discussion. A brief intervention may be necessary.

Agenda Item 5 - Second generation intact stability criteria

Separate Working Groups on intact and damage stability have been reinstated. SDC 2/5 is submitted by Japan as co-ordinator of the Correspondence Group and a number of Paper
submitted by China seek to address a number of issues. Attention is drawn to SDC 2/5/5 submitted by Japan that explains the rational of 15 degrees as the appropriate stable heel angle requirement for loss of stability in waves. It is expected that Prof Francescutto (Italy) will agree to chair the intact WG. Whilst acknowledging the value and applicability of the research under way, there
is concern that the highly academic approach makes the likely outcome for discussion to be of questionable practical use.

Agenda Item 6 – Amendment to the criterion for maximum angle of heel in turns of the 2008 IS Code

SDC 2/6 and SDC 2/INF.5 both submitted by IACS confirms we are in a mess and a way out is being sought. This is diplomatically referred to by stating, ‘further validation work is necessary before any changes to the 2008 IS Code are made.’ A brief intervention may be necessary.

Agenda Item 7 – Development of amendments to Part B of the 2008n IS Code on towing, lifting and anchor-handling operations

SDC 2/7/1 submitted by the Netherlands proposes to modify the requirements for the stability manual for ships in heavy lift operations. SDC 2/7/3 submitted by Germany supports the Netherlands’ distinction between lifting operations in exposed and not exposed waters, and have proposed that they, Germany, will carry out an impact assessment for exposed waters and report their results to SDC 3. It is reported that there is wide support for this approach.

Agenda Item 8 – Guidelines addressing the carriage of more than 12 industrial personnel on board vessels engaged in international voyages

Currently there is no definition of industrial personnel who do not fit in to the category of either passenger or crew. SDC 2/8 submitted by the UK as the report of the Correspondence Group which was dominated by the subject of industrial personnel, and that there has been no further progress since SDC 1. If a new class of personnel were to be designated this would require an amendment to SOLAS. This is a highly political matter that will be the subject of debate in Plenary. It is disappointing that all humans are not treated equally. Passenger, industrial personnel and seafarers in that order. It is reported the EU find this difficult, seeking only an outcome? An intervention may be necessary. (HUMAN RIGHTS)

Agenda Item 9 – Classification of offshore industry vessels and a review of the need for a non-mandatory code for offshore construction support vessels

SDC 2/9 and SDC 2/9/1 submitted by the UK as the report of the Correspondence Group. Progress remains slow.

Agenda Item 10 – Amendments to SOLAS regulation II-1/11 and development of associated guidelines the adequacy of testing arrangements for watertight compartments

SDC 2/10 submitted by Japan as the report of the Correspondence Group. There is a gulf between the reality of what is carried out by ROs and the requirements of SOLAS. The report of the Correspondence Group represents a move towards aligning regulation with reality. Some countries have agreed to the system of testing which accords with current practise rather than the strict SOLAS requirement which is impractical. A number of papers have been submitted and the discussion may be both interesting and hopefully pragmatic. Guidelines should resolve the issue.

Agenda Item 11 – Provisions to ensure the integrity and uniform implementation of the 1969 TM Convention

There are a number of papers seeking clarification on particular issues. Attention is drawn to SDC 2/11/2 submitted by Germany and proposes a draft resolution to encourage improved living conditions on board ships by means of a reduced gross tonnage for the purpose of assessing ports dues. All accommodation should be exempt for this reason. Trying to arrive at a definition of training accommodation will be somewhat torturous. An intervention in support of Germany may be necessary.

Agenda Item 12 – Guidelines for the use of Fibre Reinforced Plastics (FRP) within ship structures SDC 2/12 submitted by Sweden as the report of the Correspondence Group. There are issues with the use of FRP no least from fire with associated gas and smoke. Some composites are highly toxic materials when burnt, which has been shown in tests and exercises carried out in aircraft scenarios. A considerable amount of discussion is to be expected. While SOLAS Regulation 17 restricts the use of combustibles, it does not prohibit their use.

Agenda Item 13 – Amendments to SOLAS Chapter II-2, the FTP Code and MSC/Circ.1120 to clarify the requirements for plastic pipes on ships
SDC 2/13 submitted by Denmark provides for a revision of the fire endurance matrix.

Agenda Item 14 – Amendments to SOLAS and FSS Code to make evacuation analysis mandatory for new passenger ships and reviews of the Recommendation on evacuation analysis for new and existing passenger ships

Germany and the Netherlands were asked at SDC 1 to submit a paper with proposed amendments to SOLAS to make evacuation analysis mandatory for new passenger ships; this they have done with the submission of SDC 2/14/1 and SDC 2/14/2. Japan is the only other country to submit papers. An opportunity may arise to place on record the need for a full scale evacuation of first vessel of class, mindful that this Agenda Item may my held over to SDC 3.

Agenda Item 15 – Interpretation of SOLAS regulation II-s/13.6 on means of escape from ro-ro cargo spaces
SDC 2/15 submitted by IACS, again seeks clarification. No substantive comment to make.

Agenda Item 16 – 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

SDC 2/16 submitted by Canada and the US seeks to address preserved weakness in the current requirements. The UK and Norway have a reservation on the current guidelines and so can be expected to support Canada and the US. Should be supported if necessary.

Agenda Item 17 – Amendments to SOLAS Chapter II-1 and associated guidelines on damage control drills for passenger ships

Two papers have been submitted by RINA 2/17 and the US 2/17/1. It is anticipated that the US will receive support from the EU for monthly drills. Should be supported if necessary.

Agenda Item 18 – Guidelines for wing-in-ground craft

Four papers have been submitted, all of which can be ignored. No substantive comment to make.

Agenda Item 19 – Review of General Cargo Ship Safety
Despite the continued loss of these ships no papesr have been submitted.

Agenda Item 20 – Amendments to the 2011 ESP Code
Two papers submitted by IACS, both of an administrate nature.

Agenda Item 21 – Unified interpretation to provisions of IMO safety, security and environmental related Conventions

Nine papers have been submitted, all by IACS. While generally administrative there are possibly issues that may require an opinion.

Agenda Item 22 – Biennial agenda and provisional agenda for SDC 3
No substantive comment to make.

Agenda Item 23 - Election of Chairman and Vice Chairman for 2016

Chairman: Anneliese Jost (Germany), Vice Chairman: Nigel Campbell (South Africa) No substantive comment to make.

Agenda Item 24 - Any other business
Three papers referring to corrections of current documentation. No substantive comment to make.

INTERVENTIONS

Agenda Item 3 - Watertight Doors

“Thank you Chair. We [IFSMA] do not disagree with your summing up on this issue. There is no doubt a need to close watertight doors to overcome an obstruction in order to save both the vessel and life at sea. However, there is a need to ensure that watertight doors are safe when operated locally. The last major change was 106 years ago if this becomes effective in 2020; that was when lights were added to supplement bells. Now we have the opportunity with new technology to prevent life changing injuries and death of seafarers. Thank you Chair.”

Ref from Brief:
SDC 2/3/7 submitted by the EU [Germany] on protection against crushing of people during the daily operation of watertight doors. This if agreed will be effective as from 2020 and is the first major change since 1914 where lights were added to supplement bells. This should be welcomed with a brief statement.

Outcome – kicked into short grass.

Agenda Item 8 – Guidelines addressing the carriage of more than 12 industrial personnel on board vessels engaged in international voyages

Intervention made by IFSMA

“Madam Chair, Thank you. I shall be brief. We agree with the distinguished delegates of Australia and Argentina. These are human beings and have human rights. We are setting a dangerous precedent and if we are to proceed we should do so with extreme caution. Thank you, Chair.”

Agenda Item 14 – Amendments to SOLAS and FSS Code to make evacuation analysis mandatory for new passenger ships and review of recommendation on evacuation analysis for new and existing passenger ships

INTERVENTION made by IFSMA

“Thank you Madam Chair. And Good morning to everyone. We thank the distinguished delegates who submitted these papers; this is very welcomed. However, we request that a full scale realistic evacuation of the first ship of class, as in other modes of transport. Simulation has its use, but its limitations have to be appreciated. We request this intervention be recorded in the report of this sub-committee. Thank you Chair.”

Tags: IMO SDC