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Marine Services

Classification and Statutory Surveys – Delegate Notes

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Classification and Statutory Surveys – Delegate Notes

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Table of Contents

1 Introduction ..................................................................................................6

2 Lloyd's Register (LR) ...................................................................................7

3 Classification................................................................................................9
3.1 The Routes to Classification ...................................................................10
3.2 New Construction to Class......................................................................11
3.3 Existing ship transfer of class/acceptance into class/reclassification13
3.3.1 General...............................................................................................................14
3.3.2 Transfer of Class (TOC) from an IACS Member or Associate.............................14
3.3.3 Re-classification from an IACS Member or Associate.........................................15
3.3.4 Re-classification from a non-IACS member ........................................................16
3.3.5 Acceptance into Class (AIC) ...............................................................................16
3.3.6 Frequently asked questions about transferring class ..........................................17
3.4 Class and descriptive notations .............................................................18
3.5 Class suspension and withdrawal ..........................................................20
3.6 Maintenance of Class...............................................................................23
3.6.1 Conditions of Classification.................................................................................24
3.6.2 Periodical Surveys and the Survey Cycle ...........................................................25
3.6.3 Thickness Measurement Requirements..............................................................34
3.6.4 Enhanced Surveys .............................................................................................36
3.6.5 Preparation for surveys.......................................................................................41

4 Statutory Services .....................................................................................47

5 Consultancy Services................................................................................48

6 The International Maritime Organisation (IMO) ......................................49


6.1 IMO Structure............................................................................................49
6.2 Developing Legislation ............................................................................51

7 The International Association of Classification Societies (IACS) ........53

8 Port State Control (PSC) ...........................................................................54


8.1 Glossary ....................................................................................................54
8.2 Regulating Shipping.................................................................................54
8.3 The Price of Sovereignty .........................................................................54
8.4 The Role of the Flag State .......................................................................54
8.5 The ‘Circle of Maritime Responsibility’ ..................................................55
8.6 Mixed Crews..............................................................................................55
8.7 The Substandard Ship .............................................................................55
8.8 The Development of Port State Control .................................................56

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8.8.1 Origins ................................................................................................................56


8.8.2 Port State Control Organisations ........................................................................56
8.8.3 Co-operation and Consistency............................................................................57
8.9 Port State Control Inspections................................................................57
8.9.1 Targets for Inspection .........................................................................................57
8.9.2 ‘Clear Grounds’ to Conduct a More Detailed Inspection .....................................58
8.9.3 The Emphasis on Crews.....................................................................................58
8.9.4 Recording and Reporting of Deficiencies............................................................58
8.9.5 Most Frequent Deficiencies ................................................................................58
8.9.6 Attendance on board ..........................................................................................59
8.9.7 Appeals ..............................................................................................................59
8.10 Naming and Shaming...............................................................................59
8.10.1 Publications of Detentions ..................................................................................59
8.10.2 Comparison of Classification Societies ...............................................................60
8.11 Conclusions ..............................................................................................60
8.11.1 Is PSC driving the Substandard Operator out of Business?................................60
8.11.2 Rewarding Quality Shipping ...............................................................................61

9 IMO Conventions........................................................................................62
9.1 SOLAS 1974 ..............................................................................................63
9.1.1 General...............................................................................................................63
9.1.2 Surveys, Certificates and Records......................................................................64
9.1.3 Applicability of SOLAS........................................................................................65
9.2 An Introduction to Marpol 73/78..............................................................66
9.2.1 General...............................................................................................................66
9.2.2 History ................................................................................................................67
9.2.3 The Marpol Annexes...........................................................................................68
9.2.4 Annex I - The Prevention Of Pollution By Oil ......................................................69
9.2.5 Annex II - The Control Of Pollution By Noxious Liquid Substances In Bulk ........98
9.2.6 Annex V – The Prevention of Pollution by Garbage from Ships........................110
9.2.7 Annex VI - The Prevention Of Air Pollution From Ships ....................................111
9.2.8 Recycling Of Ships ...........................................................................................132
9.2.9 Vapour Emission Control Systems (VECS) ......................................................133
9.2.10 Ballast Water Exchange ...................................................................................135
9.2.11 Anti-Fouling Systems On Ships ........................................................................137
9.3 The International Convention on Standards of Training, Certification and
Watch-keeping for seafarers (STCW) ...................................................141
9.3.1 Changes to STCW............................................................................................141
9.3.2 Companies’ responsibilities ..............................................................................142
9.4 Load Line.................................................................................................143
9.4.1 General.............................................................................................................144
9.4.2 History ..............................................................................................................146
9.4.3 Freeboard / Load Line Calculations ..................................................................148

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9.4.4 Load Line Surveys ............................................................................................152


9.4.5 Hatch Cover Best Practice................................................................................171
9.4.6 Common false beliefs about hatch covers ........................................................173
9.4.7 Items affecting the validity of the Load Line Certificate .....................................174

10 Implementing the IMO Conventions ......................................................175

11 SOLAS Based Surveys............................................................................176


11.1 Safety Equipment Surveys ....................................................................177
11.1.1 Preparing for Safety Equipment Survey............................................................178
11.1.2 Most Common Safety Equipment Deficiencies .................................................179
11.1.3 Items Seriously Affecting Safety Equipment Certificate Validity........................180
11.2 The International Code for the Safe Operation of Ships and for Pollution
Prevention (The International Safety Management (ISM) Code) ........181
11.2.1 History ..............................................................................................................181
11.2.2 Background ......................................................................................................182
11.2.3 What is the ISM Code.......................................................................................183
11.2.4 Objectives of the ISM Code ..............................................................................183
11.2.5 What is a Safety Management System .............................................................184
11.2.6 What is Safety? ................................................................................................185
11.2.7 What is risk? .....................................................................................................185
11.2.8 Risk Management.............................................................................................186
11.2.9 Management System Failures ..........................................................................187
11.2.10 Documentation Design and Control ..................................................................188
11.2.11 Verification and Certification .............................................................................189
11.2.12 Maintenance of the Safety Management System..............................................192
11.2.13 ISM Terminology ..............................................................................................192

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1 Introduction
The origins of the Classification Societies date back to the middle of the 18th Century. World
trade was then almost entirely dependent on shipping which was a most hazardous
business. The technology available was very basic and there were no controls on the
condition of merchant ships many being in poor condition and frequently overloaded. As a
result of the high numbers of losses of both ships and cargoes many of those financing the
shipping business, particularly the insurers, agreed that there was a need to establish
objective safety criteria and regular inspections to reduce the frequency of shipwrecks.
As a result the first independent “Classification Society”, Lloyd's Register, was set up in the
18th century, to establish safety criteria, conduct regular inspections and classify ships
according to these criteria. Since those early days the number of Societies has increased but
their basic mission remains unchanged. Through their register books fundamental
information is recorded against each ship detailing items such as the IMO/LR number, call
sign, official number, owner, manager, ship type, class notation, dimensions, deadweight,
tonnage etc. In addition through the certificates they issue combined with memorandums and
conditions of class recorded against each ship the class society supplies a guide as to the
condition of the ship. The main benefit of Class still remains that an insurer can then assess
the risk and set an appropriate premium but there are many others who take an interest in
Classification Society activities – not least Port State Control.

Pictured above an LR Classed VLCC on sea trials

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2 Lloyd's Register (LR)


General
Lloyd's Register (LR) was the first Classification Society and its first Register of ships
dates from 1764. During the second half of the 19th Century the Society opened several
offices overseas in North America, Europe and Asia. At the present time there are
more than 200 offices around the world and the organisation has some 6000 staff
although not all of these are involved in the shipping industry. There are now about
1800 Lloyd’s Register surveyors. Today the organisation's expertise and activities
extend far wider than the shipping field. In addition to its marine activities, LR has
operations covering management systems, land-based industries, railways, and oil and
gas.
LR is an independent risk management organisation providing risk assessment and risk
mitigation solutions and management systems certification around the world. LR works to
improve its clients' quality, safety, environmental and business performance.
Through its constitution, LR is directed 'to secure, for the benefit of the community, high
technical standards of design, manufacture, construction, maintenance, operation,
and performance, for the purpose of enhancing the safety of life and property both at
sea and on land'.

Independence and integrity


LR operates independently of any government or other body and can assure absolute
commercial impartiality. It is a non-profit distributing organisation; income derived from
LR fees and the sale of publications is used for research and development, training LR
staff and to improve services.

Contact details

Lloyd's Register
71 Fenchurch Street, London EC3M 4BS, UK
Tel: +44 (0)20 7709 9166
Fax: +44 (0)20 7488 4796
Email: lloydsreg@lr.org
Lloyd’s Register Asia
South East Asia Area Office
456 Alexandra Road,
NOL Building #16-02,
Singapore,
119962

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LR Structure
Currently LR's operational structure is as detailed below. The three regional operations Asia,
Europe/Middle East/Africa and the Americas are responsible for delivering the Society's
services within each region with the regional head offices being located in Hong Kong,
London and Houston respectively. The three business streams are responsible for
developing and supporting the services within the scope of their streams. In turn the regional
operations and business streams that form the matrix structure of the current organisation
are supported by the corporate departments including Legal Services, Finance etc.

LR Management Structure

Chairman & CEO Corporate Support


Finance

Legal
Europe, Middle East &
Americas Region Asia Region
Africa Region
IT

Human
Marine Business
Resources
Stream

Corporate Secretary
Energy &
Transportation
Business Stream
Global Quality
Management

Management System
Business Stream
Corporate
Communications

Commercial Support

Line Responsibility
Close Co-operation
Functional Responsibility

The marine activities of LR can be divided into three main areas, these are:

• Classification
• Statutory services and
• Consultancy services

Each of these areas will be discussed in turn.

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3 Classification
Ship classification in its purest sense is said to be the development and worldwide
implementation of a set of published rules and regulations which set and maintain
standards of quality and reliability. For ships classed with LR these standards are set out in
Lloyd’s Register’s Rules and Regulations for the Classification of Ships and it is the
compliance with the specific parts of these rules that determines the class notation that is
assigned to a ship and recorded in the Register Book. It must be stressed that classification
is a partnership between the class society, owner and operator and it is only with the
proper care and conduct on the part of the owner and operator in conjunction with the
correct application of the rules that classification as a process will provide for adequate:

• Structural strength of (and where necessary the watertight integrity of) all essential
parts of the hull and its appendages.

• Safety and reliability of the propulsion and steering systems.

• Effectiveness of those features and auxiliary systems which have been built into the
ship in order to establish and maintain basic conditions on board whereby
appropriate cargoes and personnel can be safely carried whilst the ship is at sea, at
anchor, or moored in harbour.

Class ensures these provisions through periodical visits to the ships by its surveyors. The
surveyors carry out the corresponding periodical surveys in order to ascertain compliance
with the Rules and Regulations (see Section 3.6.2 on periodical surveys).
A ship is in class when the relevant rules and regulations have, in the opinion of the class
society, been complied with, or when it has been granted special dispensation from
compliance.
Generally, classification rules and regulations do not cover:
• Flotational stability.

• Life-saving appliances.

• Pollution prevention arrangements.

• Structural fire protection, detection and extinction arrangements.

All of these are covered by internationally adopted statutory codes/conventions and class,
therefore, does not generally repeat these requirements in its Rules and Regulations except
in instances where it wishes to apply the provisions of such codes to additional vessels. An
example of this is where Part 6 Chapter 4 of LR's Rules for Ships contains regulations for
structural fire protection, detection and extinction arrangements. These, however, are only
applicable to vessels which are not required to comply with statutory requirements possibly
due to their size or service.

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It should be noted that LR's Rules and Regulations contain requirements for the installation
and subsequent survey of items covered by the 1966 International Load Line Convention.
Items such as air pipes, ventilators, hatch covers etc. are required to be surveyed and found
satisfactory in compliance with Part 1, Chapter 3 Section 2.2 of LR's Rules for Ships. Hence
regardless of who is issuing the Load Line Certificate it is a class requirement that all Load
Line items are kept in order.
Lloyd’s Register’s commitment to safety at sea is continuous, likewise is its commitment to
building a partnership with the owners and operators of ships utilising LR's services.
Examples of this commitment include:

1. The ShipRight system based on a continual iterative process of research, development


and in service feedback. The system is designed to ensure the highest standards of
safety, quality and reliability are applied in the design, at construction and during
operation.
2. The Ship Emergency Response Service, known as SERS, which provides the owner
with a 24-hour, 365-days-a-year shore-based technical support service for ships in the
event of casualty. A team of experienced surveyors and naval architects using a
computer based model can predict the effects on stability, strength, oil outflow and
floatability of a damaged ship and how it will respond to various proposed remedial
actions. SERS is available to any owner for any ship regardless of the class and it is
worth noting that of the fifteen hundred ships currently utilising the service
approximately 30% are classed with classification societies other than LR. Following on
from SERS in cases of damage to an extent where the class of the ship is
required to be suspended by the society it will continue to assist the owner as
far as possible with technical advice in order to get the ship back in to service as
swiftly as possible so that the commercial cost to the owner is limited.
3. Other services cover risk management, maintenance management, technical
investigations, integrated management systems, ship life extension studies and
owner's project management to name but a few. The full list of LR's current services is
given in its Marine Services brochure. It should be noted that regardless of whether or
not a specific technical issue of concern to an owner is covered by the class rules the
society is always willing to give advice if possible.

3.1 The Routes to Classification


Ships normally enter class by one of two routes. Either they are new ships constructed and
subsequently classed on delivery with the same class society or they are ships in operation
and for one of a number of possible commercial reasons the owner decides to change class
of his ship from one society to another. The latter route of entering class is either known as
Transfer of Class (TOC) or Acceptance into Class depending on whether or not the losing
class society is a member of the International Association of Classification Societies (IACS).
It should be noted that not all ships that enter class have been previously classed with any
society, examples of this include, naval ships where classification services were never
previously sought or coastal vessels where all surveys were carried out by the national
administration.

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3.2 New Construction to Class


Once the ship owner has decided there is a commercial need to increase and/or renew his
fleets' tonnage he will seek tenders from ship builders supplying them with details of the
numbers, type and size of ships plus any other specification requirements he may have. It is
also at this stage that approximately 50% of owners specify their preference for which
classification society they want their ship to be classed with. Class notations are specified
based on one of the class societies sets of rules. If the owner has no preference regarding
the actual eventual class society with which his ship is registered he will state that the ship is
to be delivered with equivalent class notations.
The tenders from the interested ship builders will include a quotation of the cost
together with a technical specification on which the quote was based. In the 50% of
instances where no preferred class society was specified by the owner then the ship
builder will recommend class. The ship builders' recommendation of class will be based
on any number of the following factors:

Possible time delays in


building schedule due to the
need to have design drawings
approved by an additional
class society and the
additional costs which may
result e.g. plan approval fees,
cost of re-designing,
Maintaining balance of the additional steel etc. Technical competence of the
use of individual class individual classification
societies within the shipyard. societies as perceived by the
shipyard.

Local relationship between Perceived level of service


shipyard and class. given by class societies on
previous projects.

Difference in cost for class


services between societies.

Once the costs and specifications have been agreed the prospective owner and ship yard
sign a contract, at this stage a further contract is signed between the ship yard and the
chosen class society. At this stage the class society's client in respect of the new building
concerned is the ship yard but this of course changes on delivery when the owner becomes
the client. The class surveyors role in the ship yard is to ensure that the ship, its
machinery and systems are constructed, installed and tested in accordance with the
society's rules and applicable statutory regulations (if the class society is authorised to
act on behalf of the ships' intended flag authority). It is not the class society's role to
verify that all items in the technical specification are met this being the responsibility of
the owner and shipyard.

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Class requirements during new construction include the following:

• The approval, before work is commenced, of all constructional plans and


particulars relating to the hull, equipment and machinery as detailed in the
class rules;

• The approval of all alterations to the arrangements made to approved plans


and particulars;

• The ship being built under LR's Special Survey. All materials, workmanship
and arrangements to the satisfaction of an attending surveyor and in
accordance with the rules and approved drawings. Rectification of any
unsatisfactory workmanship or materials plus correction of deviations from
approved arrangements;

• When the machinery is constructed under LR's special survey, as is required


for the application of the LMC notation, then the survey is to start at the
commencement of materials used in the machinery's fabrication through to its
final test under working conditions;

• The materials used in the construction of the hull and machinery are to be
manufactured at a works recognised by LR using approved processes. All are
to be good quality and free of defects;

• Control equipment for the remote operation of essential machinery to be


arranged, installed and tested in accordance with LR's rules;

• Copies of approved plans showing the as-built arrangement of the completed


ship are to be made available for use when required by LR surveyors.

Should novel arrangements/designs or new materials be used in the building of a ship then
LR may require additional testing to be carried out during construction and/or once the ship
is in service. If the ship is constructed in a yard with an LR approved Quality Assurance
scheme then the adopted procedures for survey and testing during construction can be
modified to take into account the ship yard's own management, organisation and quality
systems.
Prior to the delivery of the ship from the ship yard the class surveyors will, in addition to
having verified that all the class requirements have been met, ensure that all the statutory
requirements for which the class society is responsible have also been complied with. The
class society's statutory responsibility with respect to a specific ship will be governed by the
flag chosen by the owner for the ships' registration. The major class society's are authorised
in the majority of cases to carry out most statutory surveys, an example of LR's current
levels of statutory authorisation is given in Annex 1. Where the class society is authorised to

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carry out the statutory surveys the society will issue both class and statutory certificates on
delivery and these will normally be valid for a five year period from the date of delivery.
The day of delivery is deemed to be the same as the date of completion of special survey of
ships built under LR's inspection and this date is entered in the Register book. If the ship is
layed up on completion, depending on the period of lay up, the class society may request
additional surveys possibly requiring docking. Subsequent special survey dates will be
referenced from the date of successful completion of the additional surveys.
Following successful completion of construction and sea trials the attending surveyor will
submit for each ship a number of reports and statements to LR's London office. These
documents are checked to ensure that all class requirements have been met, following
which the local surveyor is authorised to issue class and statutory certificates to the ship.
The certificates are usually valid for five years. The statements and check lists submitted are
as follows (see annex 2 for details):

• The First Entry Report


• The Construction of Ship Report (Hull Checklist for Ships Building to LR Class)
• The Report on Installation of Machinery (Sea Trials Data)
• The Installation of Machinery Report (Checklist for Ships Building to LR Class)

It should be noted that the First Entry Report contains a signed declaration by the ship
yard that the ship has been built in accordance with the requirements of the class rules.
Following the additional receipt in London of copies of the "As-built" drawings and
certificates for essential items such as the anchors, chain cables, main engine, boiler/s
etc. the ship is endorsed for first entry into class and submitted to the Sub-Committee
of Classification for their acceptance. After acceptance by the committee the ship is
issued with a Certificate of First Entry into Classification and its details are entered in
the Register of Ships more commonly known as the Register Book.

3.3 Existing ship transfer of class/acceptance into class/reclassification


Transfer of Class (TOC) is the process by which a vessel currently classed by a Member or
Associate Member of the International Association of Classification Societies (IACS) can gain
LR class. There are procedures laid down by IACS concerning the responsibilities of each
class society, for the TOC surveys, submission of plans and information.
Reclassification is the process by which a vessel formerly classed with LR can reinstate LR
class. TOC procedures apply for vessels currently classed by a Member or Associate
Member of IACS, with the advantage that LR will usually have all plans and information
available.
Acceptance into Class (AIC) is the process by which an unclassed vessel (including those
not classed by a Member or Associate Member of IACS) can gain LR class. Formal
submission of plans and information for design appraisal may be required in addition to a full
survey.

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3.3.1 General
The starting point for transferring class to LR is through the initial request. The owner
approaches a local LR office requesting classification of one or more of his existing ships.
The LR office will then review:
• Ship type, age, tonnage and service history
• Ownership and fleet details
• Flag state, Port state detention and casualty record
• Number of previous transfers
• Survey status and conditions or recommendations

For ships which are 15 years of age and above, a request for Transfer of Class will only be
allowed to proceed after a review and pre-inspection are carried out to assess the overall
condition of the ship. The scope of this survey is such that it should not disturb current
operations.
Following the initial request and a satisfactory outcome to the initial review and pre-
inspection the local office will present the owner with a Request for Class/Re-class of
Existing Ship/Vessel (Form 2548) for signature. This forms the formal request which allows
LR to approach the current class society and obtain details of survey status and other related
data. LR can then formalise surveys required for classification as well as any specific flag
state requirements. In most cases, a transfer can be combined with normal survey
requirements, minimising cost and disruption to operations.
Following the formal request the LR office overseeing the transfer of class will receive
general survey instructions to smooth the transfer process. As part of the TOC process LR
requires the owner to submit a number of plans plus supporting information which are
required for assessment of the condition of the ship, records, future maintenance of class,
repairs, etc.

3.3.2 Transfer of Class (TOC) from an IACS Member or Associate


Ships transferring from an IACS Member or Associate are covered by the IACS ’Transfer of
Class Agreement’. The transfer of a ship into LR class is considered by the Classing
Committee on a case-by-case basis and classification may be declined if the condition of the
ship or its documentation is not acceptable to LR.
The Losing Society will provide LR with the ship’s current survey status including copies of
certificates and records of the hull and machinery survey cycles as held on board.
The owner/operator will be advised by LR, immediately on receipt of a request for transfer of
class, of the survey requirements and the information/plans to be submitted. In addition an
appropriate place and time for the survey of the ship will be agreed noting that the ship has
to be prepared for survey. Preparation including holds and tanks being made available for
inspection and the crew being advised of the impending surveys so that their full co-
operation is ensured and thereby the process is as efficient as possible.
The ship’s arrangements will be verified as being in accordance with the plans/information as
supplied by the owner and losing class society and the hull survey will take the form of a
minimum of an Annual Survey in accordance with the Annual Survey Checklist form 2100
(see Annex 3).

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All hull conditions of class or recommendations imposed by the losing class society will be
examined and dealt with as necessary at the time of the survey. Acceptance into LR class
will only be permitted with no outstanding conditions of class remaining from the losing
society this is to ensure that the possibility of "class hopping" to avoid carrying out necessary
maintenance is stopped. In addition to resolving any conditions of class surveys that are due
or overdue at the time of the TOC survey will also be held and resolved.
In terms of machinery survey requirements for TOC when the due date of the Complete
Survey of machinery is imminent or overdue, a full Engine Survey will be held in accordance
with the current LR Rules. The minimum machinery survey to be held will comprise a
General Examination of all essential machinery in accordance with the Annual Survey
Checklist form 2100 (see annex 3).
As per hull conditions of class any machinery conditions of class or recommendation
imposed by the losing society will be fully resolved by completion of the TOC survey.
Surveys, or survey items, that are due or overdue at the time of the TOC survey will also be
held and resolved.
It should also be noted that with effect from 1/1/2003, IACS procedures will require that for
ships 15 years of age and older, all overdue surveys and conditions of class shall be
completed to the satisfaction of the class society that assigned them.

3.3.3 Re-classification from an IACS Member or Associate


In cases of reclassification of ships, original information and plans are normally available
within LR and a new submission is not required except where, during the period outside LR
class:
• Major alterations have been carried out during the period that the ship was not in
class with LR.

• Reduced freeboards have been assigned. In the case of reduced freeboards it is to


be confirmed that the maximum draught at which the ship operates is not greater
than the scantling draught for which the ship was originally approved by LR and that
the capacity plan remains correct with respect to tank configuration and use.

• Control equipment has been retrofitted and a UMS notation is requested.

• An inert gas installation has been retrofitted which requires the compulsory
assignment of an Inert Gas System (IGS) notation.

• The ship has been re-engined with either new main or auxiliary engine(s). If the re-
engining was during the last two years then Torsional Vibration Calculations (TVC's)
are to be submitted. If, however, the machinery was installed more than two years
ago then special consideration may be given on the basis of the type of machinery
installed combined with a good service record.

As part of the re-classification process an annual survey and general examination of the hull
and machinery respectively is to be carried out in accordance with the associated survey
checklists. As per the TOC procedures all conditions of class and recommendations from the
losing class society plus surveys due and overdue at the time of the change of class survey
are to be resolved before entry into LR class. It should be noted that LR may decline an
application for re-classification based on a poor previous classification record.

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3.3.4 Re-classification from a non-IACS member


For ships not currently in class with an IACS Member or Associate, but which have
previously been classed by LR the society will normally have available original information.
Plans and new submissions are not normally required except for the circumstances detailed
previously for a ship under reclassification from an IACS member. It should be noted that it
will be necessary to carry out all outstanding surveys in accordance with the Rules prior to
the ship being allowed into class. The hull and machinery surveys will be carried out as
required by the hull and machinery TOC checklists.

3.3.5 Acceptance into Class (AIC)


For ships not classed previously with LR and not currently in class with an IACS Member or
Associate acceptance into class is governed by the requirements of Part 1, Ch. 3, Section 19
of LR's Rules for Ships.
In brief plans covering the main scantlings and arrangements including: the midship section,
longitudinal section and decks are required to be submitted for approval along with plans
covering the essential machinery systems plus intact and damage stability manuals. In
addition to plans, the particulars of the processes used in the manufacture and testing of
materials utilised in the construction of the hull, boilers, air receivers and important forgings
are required to be submitted for examination. All plan approval is required to be completed
before the acceptance into class survey commences. If the ship was built under the survey
of, or at any time was classed by, an IACS Member or Associate, then LR may give special
consideration to the extent of plan approval required. The level of survey for an acceptance
into class corresponds to the completion of a full special survey in accordance with the age
and type of ship together with complete surveys of the machinery, boilers, electrical
equipment, screwshafts and, where applicable, Unattended Machinery Space (UMS) and
IGS requirements.

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3.3.6 Frequently asked questions about transferring class


When is the best time to transfer class?
The best time to transfer is within the regular classification and statutory survey range
dates. For ships over 15 years of age, it is best to transfer within the range date of
the Special or Intermediate survey. The regular classification surveys can then be
used to assess the condition of the ship for transfer, and also comply with IACS
requirements.
Which notations will be assigned to the vessel?
Equivalent LR notations to those assigned by the current class society will be
assigned on the basis of the evidence available. In some cases, it will be necessary
to confirm that the scope of the LR notation is the same as that of the current class
society.
How much will a transfer cost?
If a transfer is carried out within the range date of due surveys, there will be limited
additional costs and no disruption to planned operations.
How can I prepare for a TOC survey?
Contact the local LR office to arrange any necessary surveys, pre inspections in advance of
the planned TOC date. For ESP ships where a special survey is due, thickness
measurements should be arranged. Compile plans and information into a package for local
office.

Above LNG ship being built under LR special survey in Korea

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3.4 Class and descriptive notations

Pictured above The Register of Ships both old and new

As stated previously, following a ships entry into class, the ships details are entered into the
Register Book including its notations. The notations assigned to a ship following her
classification with a society fall into two main categories, these categories are firstly the class
notations, recorded in column 4 of the register book and secondly the descriptive notations
recorded in column 6. Class notations assigned to a ship indicate that the specific
compulsory requirements of the rules have been both applied and met, e.g. if a ship has the
full class notation:

100A1 Double Hull Oil Tanker, ShipRight (FDA SDA CM), *IWS LI

LMC UMS
This would mean, breaking the class notation into its composite parts, that:
Notation: Meaning:
(type of notation)

The ship's hull was constructed under Lloyd’s Register's special survey
(complies with Pt1 Ch2 Sec 2.2 of LR's Rules for Ships)
(character symbol)

100 The ship is considered suitable for sea going service (complies with Pt1 Ch2 Sec
2.2 of LR's Rules for Ships)
(character symbol)

A The ship was constructed or accepted into Lloyd’s Register class and is
(character symbol) maintained in good and efficient condition (complies with Pt1 Ch2 Sec 2.2 of LR's Rules
for Ships)

1 The ship has good and efficient anchoring and mooring equipment in
(character symbol) accordance with the rules (complies with Pt1 Ch2 Sec 2.2 of LR's Rules for Ships)

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Double Hull The ship's structure was designed and constructed in accordance with LR's
Oil Tanker Rules for double hull oil tankers (complies with Pt4 Ch9 of LR's Rules for Ships)
(hull type notation)

ShipRight The ship has met LR's ShipRight design and construction procedures
SDA FDA CM covering: Structural Design Assessment, Fatigue Design Assessment and
(hull special feature Construction Monitoring (complies with Pt1 Ch2 Sec 2.3 of LR's Rules for Ships)
notation)

*IWS The ship has met LR's rule requirements for In-Water Survey (complies with Pt1
Ch2 Sec 2.3.10 of LR's Rules for Ships)
(hull special feature
notation)

LI The ship has a loading instrument installed as a classification requirement


(complies with Pt1 Ch2 Sec 2.3.13 of LR's Rules for Ships)
(hull special feature
notation)

LMC The ship's propelling and essential auxiliary machinery has been
constructed, installed and tested under LR's special survey and in
(machinery type
notation)
accordance with LR's rules (complies with Pt1 Ch2 Sec 2.4.1 of LR's Rules for Ships)

UMS The ship's machinery and control equipment has been arranged, installed
(machinery type and tested in accordance with LR's rules such that the ship can be
notation) operated with an Unattended Machinery Space. (complies with Pt1 Ch2 Sec 2.4.2 &
Pt6 Ch1 Sec 4 of LR's Rules for Ships)

In addition to class notations a number of descriptive notations may be assigned to a ship. A


descriptive notation differs to a class notation in that it records ship's arrangements which
meet specific requirements of the class rules but these are met on a voluntary basis. An
example of descriptive notations could be:

Notation: Meaning:
(type of notation)

ShipRight The ship's arrangements have met LR's rule requirements for the
SCM application of the ShipRight Screwshaft Condition Monitoring notation
(complies with Pt1 Ch3 Sec 17.3 & Pt5 Ch21 Sec 2.2 of LR's Rules for Ships)
(descriptive notation)

It should be noted that descriptive notations are not usually recorded on the ship's class
certificate unless specifically requested for inclusion by the owner prior to its delivery.
One fundamental difference between class notations and descriptive notations is the
consequence of any lapse from the rule requirements for the notation concerned. If the rule
requirements are not maintained for a class notation then a condition of class may be raised

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against the ship. This in turn could result in class being withdrawn from the ship, by the
class society, if the deviation from the rule requirements is not corrected in a timely manner.
In the case of the rule requirements for a descriptive notation not being met, then, if this is
not corrected then the descriptive notation will simply be deleted from the Register Book. In
addition to descriptive notations, descriptive notes will be recorded in column 6 of the
Register Book with the purpose of solely providing additional information about a ship's
design and construction.
Comprehensive detail of how class notations are structured, the meanings of notations and
the corresponding rule references are contained in the additional document titled
"Classification Notations, including: Notation Structure, Class Notations and Descriptive
Notations).
The class and descriptive notations, in addition to being recorded in the Register Book, are
also recorded on LR's ClassDirect Live website at www.cdlive.org In addition the web site
provides instant access to ship class and survey status, details of conditions of class and
memoranda items, LR survey checklists and regulations, survey history and technical
updates amongst many other items.

3.5 Class suspension and withdrawal


There are a number of ways the class status of a ship may be changed and these status
changes will be reflected by the application of a notation firstly in the supplement to the
Register Book followed by an update to the Register Book itself.
Changes of status may be:
• Voluntary e.g. Where the condition of the ship meets all rule requirements but the
owner wishes to change class and asks for the class to be withdrawn (In this
instance LR will assign the status "Class withdrawn at Owner's Request" followed by
the date of withdrawal)
Or
• Enforced e.g. Where the condition of the ship fails to meet rule minimum
requirements and the class recommendations have not been complied with (in this
instance the notation assigned to the ship by LR would simply read "Class
Withdrawn" followed by the date).

Where a ship fails to meet rule requirements at survey it would rarely have its class
withdrawn immediately regardless of the seriousness of the non compliance. If a defect was
considered major enough then the ship may have its class suspended making the class
certificate invalid until the necessary corrective action has been taken. The effect of class
suspension is effectively to stop the ship from trading due to the implications with respect to
insurance for both the ship and its cargo. In many instances where a defect is found a
condition of class is recorded on the class certificate and against the ship.
A condition of class (COC) is a recommendation related to defects, damages or wasted
parts that may seriously affect the ship's maintenance of class and that the examination,
repair or replacement must be effected in a given time for class to be maintained. It may also
be considered as a recommendation made in the case of a defective or damaged survey
item which is not serious or urgent enough to necessitate immediate permanent repairs or
withdrawal of class but is sufficiently serious to be prescribed a maximum period for
rectification. In general conditions of class will not be agreed where proper facilities for full
permanent repairs are available. It should be noted that the rectification of a condition of
class can not be postponed beyond the date of the ship's special survey.

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The owner/operator should be aware of the following reasons why the society would/may
suspend or withdraw class:

Reason: Consequence:
Annual/Intermediate surveys not Automatic suspension of class
complete within 3 months of due date
Special Survey not completed by due Automatic suspension if no agreed
date extension
Not complying with regulations Suspension at discretion of committee
COC not dealt with by due date Suspension at discretion of committee
Non reporting of damages, defects, Suspension at discretion of committee
breakdowns or groundings
Ship does not have valid convention Suspension at discretion of committee
certificates
Repairs made not acceptable to class Suspension at discretion of committee
Ship under tow and class not advised Suspension at discretion of committee
Ship operated with relevant freeboard Suspension at discretion of committee
mark submerged
Incorrectly located freeboard marks Suspension at discretion of committee
Inappropriate use of ship or operation Suspension at discretion of committee
in unsuitable environment
Inadequate remedial action of any of Class withdrawn at the discretion of the
the above committee

TOC, scrapping Class withdrawn at owners request

When the non compliance by the owner to meet the requirements of class is deemed major
enough it should be noted that class suspension or withdrawal may be extended to
additional ships in the fleet of the owner concerned.
Should the ship's owner/operator feel the surveyor's recommendations to be excessive then
they may appeal via the regional devolved classification executives (DCE's) or the London
office who may arrange an additional special examination to be carried out.
In addition to conditions of class held against a ship significant notes are held against the
ship in the form of memoranda. Again these can be most easily viewed via ClassDirect Live.
An example of a memoranda item would include a minor hull damage such as a plating
indentation with little distortion of the stiffening members, such an item being noted but
basically cosmetic can be left to repair at the owner's convenience. Other memoranda items
could include, for information purposes, the grades of steel other than grade 'A' used in the
ship's construction, the bearing materials used for the rudder and stern bushes, details of
areas, identified at survey, as having substantial corrosion.

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Above and below damages are required to be reported to class

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3.6 Maintenance of Class


The relevant standards must be maintained if the ship is to remain in class and this means
that every part of the ship must conform to LR Rules, from the raw materials she is built from
to the plans and details of construction. Every aspect of the ship covered by the society's
rules is subject to a combined system of comprehensive plan approval and verification
through survey. The classification system extends its influence from initial design and steel
manufacture, block fabrication and the manufacture of machinery components onto the
delivery of the ship following it's erection of structure plus testing of tanks and installation of
machinery systems. On the day of delivery and the issuing of the ship's first certificate of
class until the day the ship is taken out of service the classification system aims to ensure
that the ship remains fit for purpose. As a requirement of maintaining class any
modifications or conversions during her life are always to be advised to the class
society and approved. Whether it is as major as lengthening/ re-engining, or whether it is a
seemingly minor structural modification the level of plan approval should be discussed and
agreed between class and owner.

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3.6.1 Conditions of Classification


Through the life of a ship for it to remain in class, the owner is to ensure the conditions of
classification are met, these include:
1. The ship being maintained to a standard where it is found to meet the required rule
requirements when examined at the prescribed periodical surveys;
2. Reporting all damages, defects, breakdowns or instances of groundings to class;
3. The ship having onboard valid convention certificates issued by the national
administration, LR or another member of the International Association of Classification
Society's (IACS) as authorised by the flag administration. The convention certificates are
those issued to show compliance with the following statutory codes and conventions (the
associated certificate title is shown in brackets):

• The International Conventions on Load Lines, 1966 (Load Line


Certificate)

• International Convention for the Safety of Life at Sea, 1974 and its
Protocol of 1978 (Safety Construction, Safety Equipment and
Safety Radio Certificates)

• The International Convention for the Prevention of Pollution from


Ships, 1973, as modified by the protocol of 1978 (International Oil
Pollution Prevention Certificate)

• International Code for the Construction and Equipment of Ships


Carrying Dangerous Chemicals in Bulk, IBC Code, (Certificate of
Fitness for the Carriage of Dangerous Chemicals in Bulk)

• International Code for the Construction and Equipment of Ships


Carrying Liquefied Gasses in Bulk, IGC Code, (Certificate of
Fitness for the Carriage of Liquefied Gasses in Bulk)

• The International Safety Management Code, ISM Code, (Safety


Management Certificate)

4. The ship being properly loaded and operated at all times.


5. The ship having onboard loading guidance in the form of a loading manual and loading
instrument as required by the rules. Where the loading instrument is an onboard computer
system with the capability to carry out longitudinal strength calculations the system is
approved by LR.
6. The ship being operated only in the environmental conditions used as the basis for its
design unless prior agreement was agreed with class.
7. Prior agreement being obtained by class for sea-going voyages to a service area or
between service areas defined in the class notation.
As stated above a condition of classification is for the ship to meet the requirements of the
rules at the time of periodical surveys. The periodical surveys required to be carried out are
the annual survey, intermediate special survey, docking survey and special survey. In
addition to the periodical class surveys the class society may perform the statutory surveys

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such as safety equipment, safety construction, Load Line and MARPOL on behalf of the flag
administration and this being the case they will be conducted at the same time as the class
surveys. All of the surveys detailed above will be discussed in greater detail later in this
document.
3.6.2 Periodical Surveys and the Survey Cycle
General
Compliance with the requirements of the class rules and regulations must be maintained if
the class status of a ship is not to be adversely affected. This is a fundamental condition of
classification. To ensure a ship meets these requirements a number of class surveys,
varying in scope of examination, are carried out over a period of five years. These surveys
are known as the class periodical surveys. During the five year period all the periodical
surveys will have been performed on the ship the number of times required by Part 1
Chapter 3 Section 1.1 of LR's Rules and Regulations for the Classification of Ships. The five
year period of prescribed surveys and how they are organised is known as the survey cycle
and it is at the end of the cycle that the Certificate of Class will be required to be re-issued
with validity for a further five years.
Today the structure of the survey cycle applied to a specific ship takes one of two main
forms with the essential difference being the timing of surveys covering the ship's hull and
machinery "Special Survey" items and the requirements for the individual surveys. The
special survey items may be examined on a continuous survey cycle basis known as
Continuous Survey Hull (CSH) for structural items (plus anchoring and mooring
equipment) and Continuous Survey Machinery (CSM) for propulsion and essential
auxiliary machinery. If CSH or CSM is adopted the special survey items are proportionally
surveyed throughout the five year survey cycle of the ship i.e. 20% of special survey items
per year with a maximum of five years between each consecutive survey of the same item.
The alternative to surveying special survey items on a continuous basis spread across the
five year cycle is to survey all the special survey items over a short period of time at a single
Special Survey held every five years. This is simply known as Special Survey Cycle (SS)
for hull surveys and Engine Survey (ES) for machinery.
There would, therefore, appear to be a choice in terms of the basis of survey a ship operator
may choose to adopt for his ship's surveys, this in many instances is not the case
particularly in respect of hull surveys. A CSH survey cycle for structural items of oil tankers,
combination carriers, chemical tankers, bulk carriers and ore carriers is not permitted as
ships of these types are obliged by IMO Resolution A744 (18), IACS Unified Requirements
and class rules to adopt an Enhanced Survey Program (ESP).
ESP requires close-up survey of defined structure in addition to an overall survey plus it
requires an enhanced number of scantling thickness measurements. In order for these to be
conducted properly it requires prior planning so that tanks/holds etc. are sufficiently clean,
well ventilated and suitable access arrangements provided. It should be noted that
thickness measurements are to be carried out by an LR approved thickness measurement
company with an LR surveyor onboard for sufficient time to control the process. Hence, it is
not acceptable for a ship to arrive for special survey and for the class surveyor to be simply
presented with a set of thickness measurements

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The Hull Survey Cycle

Year: 1 2 3 4 5

Special Survey (SS) ITSS or ITM S Special Survey (SS)

AS AS AS AS AS

DS DS DS

DS IW S DS

Continuous Survey H ull (CSH )

Key:
AS: Annual Survey,
DS: Docking Survey
ITSS: Intermediate Survey (ship less than 15 years old)
ITMS: Intermediate Survey (ship 15 years or more old)
IWS: In-water Survey
The schematic diagram shown above details the periodical surveys and how they form a
typical hull survey cycle. The timing and survey requirements plus details of permitted
postponements for each of the periodical surveys are discussed in the following sections.

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Annual Survey
An annual survey is to be carried out at each anniversary after the ships delivery, hence
there are to be in effect five annual surveys in each five year survey cycle, however, of the
five one will be incorporated with the intermediate survey and one with the special survey.
For practical reasons annual surveys may be carried out in a period spanning from three
months before the anniversary date to three months after the anniversary date effectively
giving a six month window. The dates at the beginning and end of the window are known as
the range dates.
For Annual Surveys (AS), as is the case for Periodical Load Line Inspection (PLI) and Safety
Construction Annual (SCA) surveys, no extension is permitted to the range date. Should
these surveys not be completed by the end of the six month range then class will be
automatically suspended and no postponements are permitted. One effect class
suspension would have would obviously be that confirmation of class to insurers would no
longer be possible if an incident occurred in this period.
The survey items required to be covered in an annual survey are as shown in the Annual
Survey checklist (see Annex 3).

Intermediate Survey (ITSS)


An Intermediate Survey is to be carried out either at and/or between the range dates of the
second and third Annual Surveys. The survey may be commenced as early as three months
before the 2nd anniversary date of the ships completion date or last special survey date and
can be completed any time up until 3 months after the 3rd anniversary. As per the
requirements for completion of annual survey, class will be automatically suspended if
the intermediate survey is not completed by 3 months after the 3rd anniversary. No
postponements are permitted.
The survey requirements for the intermediate survey are made up of the requirements for the
annual survey extended to include the following basic requirements across all ship types
(see annex's 4 and 6 for ship type specific requirements):
• The electrical generating sets being examined under working conditions.

• For vessels over 5 years of age, a general, internal examination of representative


spaces used for salt water ballast is to be carried out. If there is no protective
coating, soft coating, or POOR coating condition, the examination is to be extended
to other ballast spaces of the same type.

• For vessels over 10 years of age, anchors are to be partially lowered and then raised
satisfactorily using the ship's windlass. In addition a general, internal examination of
all spaces used for salt water ballast is to be carried out. If such examinations reveal
no visible structural defects, the examination may be limited to a verification that the
protective coating remains effective. For spaces used for salt water ballast,
excluding double bottom tanks, if there is no protective coating, soft coating, or
POOR protective coating condition and it is not renewed, maintenance of class is to
be subject to the spaces in question being internally examined at annual intervals.
When such conditions are found in salt water ballast double bottom tanks,
maintenance of class may be subject to the spaces in question being internally
examined at annual intervals.

• In the case of dry cargo ships over 15 years old, other than bulk carriers which are
subject to enhanced survey requirements, an overall examination of a forward and

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an after cargo hold is to be carried out. It should be noted that these requirements
will change on the introduction of IACS unified requirement Z10.6 which will require,
for non ESP ships in excess of 15 years old, that the scope of the intermediate
survey will be the same as that for the previous special survey.

• For ESP ship types including oil tankers, combination carriers, chemical tankers and
dry bulk cargo ships there are enhanced intermediate survey requirements which
become more onerous as the ship gets older (see annex 6). Once the ship is
greater than 15 years of age then the intermediate survey will be known as an
ITMS survey not an ITSS survey. The survey will be extended, in the following
ways, so that it is carried out to the same extent as the previous special survey
and no in-water survey is permissible in place of dry docking.

Dry Bulk Cargo Ships over 15 years old (ITMS additional requirements):
• Hull girder thickness measurements
• Overall survey, assessment of coatings, close-up survey and thickness
measurement of all salt water ballast tanks and cargo holds
• Overall survey of all remaining spaces within the cargo hold length, including voids,
duct keel, cofferdam spaces etc
• Examination of all piping systems passing through all spaces within the cargo hold
length.

Oil Tankers and Combination Carriers over 15 years old (ITMS additional
requirements):
• Hull girder thickness measurements
• Overall survey, assessment of coatings, close-up survey and thickness
measurement of all salt water ballast tanks and cargo tanks
• Overall survey of all remaining spaces within the cargo tank length, including the
pump room
• Examination of ballast piping within cargo tanks
• Examination of all other piping systems within the remaining spaces within the cargo
tank length, including the pump room.

Chemical Tankers over 15 years old (ITMS additional requirements):


As per the requirements for oil tankers.

Docking Survey (DS):


Two docking surveys are required to be completed within any 5 year survey cycle and the
maximum period between two successive dockings must not exceed 3 years. One of the two
docking surveys should coincide with the special survey. The intermediate docking survey
between special survey dockings (see schematic diagram of hull survey cycle) may be
replaced by an In-water Survey (IWS) where the ship meets the requirements of and has
been assigned the class notation *IWS.
The In-water Survey is to provide, so far as possible the information that would be provided
at a normal docking survey. In order to facilitate this survey details including the location of
survey are to be submitted for approval and the survey is to be witnessed by an LR surveyor.

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The survey is to be held in sheltered waters with the ship at a suitable draught and the hull
below the water line is to be clean. The surveyor is to be satisfied with the pictorial
presentation of the hull and is to have good two way communication with the diver. The
diving firm carrying out the survey is to be approved by LR.

It should be noted that should the In-water survey reveal damage or deterioration requiring
early attention the surveyor may require the ship to be dry docked.

In brief for a ship to obtain the *IWS notation:


• Ship is to have an arrangement whereby sternbush clearances can be ascertained
afloat (Pt 5, Ch 6, 3.12)

• Ship is to have an arrangement whereby rudder pintle and bush clearances can be
ascertained afloat along with a method of verifying the security of the pintles (Pt 3,
Ch.13, 2.5.7)

• High resistant paint is applied to the underwater portion of the hull, the application
having been in accordance with the manufacturers requirements (Pt 3, Ch.2, 3.5.4)
coating condition is confirmed at each dry docking

• Plans detailing all of the above have been submitted and approved and copies
placed onboard the ship (Pt 3 Ch 1, sections 5.2 and 5.3).

The basic requirements for docking surveys (DS) are as follows:

The ship is to be landed on blocks of sufficient height and staging is to be arranged as


necessary so that whilst the ship is in a dry dock or on a slipway the following structure can
be examined effectively:
• Bottom plating, typically looking for excess deformations, fractures and leakages

• Side shell plating, as for bottom plating with attention also drawn to the bilge keel
ends and butt welds

• Bow plating, typically looking for bulb indents, slamming deformations,


corrosion/wastage of welded seams

• Keel plating, as per bottom plating

• Stern plating, as per bottom plating

• Stern frame

• Rudder, typically looking for any fractures, leaks, fall and condition of stock bolts also
locking arrangements for pintle and rudder nuts.

In addition the following are to be carried out:

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• Rudder bearing clearances measured (pintles & stock (max 5mm + 0.002D mm)) in addition
both general and vertical movement

• Examination of sea connections, gratings at sea inlets, overboard discharges and


their connections to the hull

• Examination of the propeller for deformation, fractures or cavitation/impact damage


(and in the case of a controllable pitch propeller checking of hub tightness)
• Tightness check of stern seals/oil glands

• Tail shaft/stern bush clearances to be measured (white metal bearing <2mm clearance)

• Chain cables to be ranged and both the cable and anchors examined. The diameter
of the chain cable links are to be checked as is the tightness of studs. In terms of the
anchor the "D"shackle should be examined including pin and shank clearance plus
the crown pin, locking pin and shell housing should be checked

• Examination of electrical equipment in hazardous zones on oil tankers five years old
and over.

Special Survey (SS)


General
A special survey is required to be conducted every 5 years of a ship's operational life in order
that the Certificate of Class can be renewed with a validity for a further 5 years. The first
special survey is to be completed within 5 years from the date of the initial classification
survey (which is usually recorded as the same date as the day of delivery) and thereafter 5
years from the credited date of the previous special survey.
An extension of class, limited to a maximum of 3 months beyond the end of the 5th year, may
be granted by LR in exceptional circumstances. As a pre-requisite of this extension the 5th
annual survey (AS) and 5th periodical Load Line renewal (PLR) must have been successfully
completed by the 5th anniversary date. Hence the safety construction annual (SCA) survey
will be recorded as part held prior to the 3 month extension to the special survey (SS) being
given.
Should the special survey be completed after the 5th year, during the authorised 3 month
extension period, the next period of class will start from the expiry date of the Special Survey
before the extension was granted. The same requirement applies to the renewed statutory
certificates e.g Safety Construction Certificate these will also be valid for five years from the
original certificates expiry date. For surveys completed within 3 months before the expiry
date of the Special Survey, the next period of class will start from the expiry date of the
Special Survey. For surveys completed more than months before the expiry date of the
Special Survey, the period of class will start from the survey completion date.
The Special Survey may be commenced at the 4th Annual Survey and be progressed with a
view to completion by the 5th anniversary date. When the Special Survey is commenced prior
to the 4th Annual Survey, the entire survey is to be completed within 15 months if such work
is to be credited to the Special Survey.
The Special Survey is to include, in addition to the requirements of the Annual Survey,
examination, tests and checks of sufficient extent to ensure that the hull, equipment and
related piping are in satisfactory condition. The condition is to be such that the ship is fit for

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its intended purpose for the next five (5) year period of class subject to proper maintenance,
operation and the periodical surveys being carried out at the due dates.
The examinations of the hull are to be supplemented by thickness measurements and testing
as deemed necessary, to ensure that the structural integrity remains effective and is to be
sufficient to discover Substantial Corrosion, significant deformation, fractures, damages or
other structural deterioration.
The anchors are to be examined. Chain cables are to be ranged, examined and the required
complement and condition verified for all ships over 5 years old. The chain locker, holdfasts,
hawse pipes and chain stoppers are to be examined and pumping arrangements of the chain
locker tested. Chain cables are to gauged and renewed in cases where their mean diameter
is worn by 12% or more of its nominal diameter.
All spaces including holds and their ‘tween decks where fitted; double bottom, deep, ballast,
peak and cargo tanks; pumprooms, pipe tunnels, duct keels, machinery spaces, dry spaces,
cofferdams and voids are to be internally examined including the plating and framing, bilges
and drain wells, sounding, venting, pumping and drainage arrangements. Internal
examination of fuel oil, lube oil and fresh water tanks may be specially considered.
Engine room structure is to be examined. Particular attention is to be given to tank tops, shell
plating in way of tank tops, brackets connecting side shell frames and tank tops, and engine
room bulkheads in way of tank top and bilge wells. Particular attention is to be given to the
sea suctions, sea water cooling pipes and overboard discharge valves and their connections
to the shell plating. Where wastage is evident or suspect, thickness measurements are to be
carried out, and renewals or repairs made when wastage exceeds allowable limits.
For spaces used for salt water ballast, excluding double bottom tanks, if there is no
protective coating, soft coating, or POOR protective coating condition and it is not renewed,
maintenance of class is to be subject to the spaces in question being internally examined at
annual intervals. When such conditions are found in salt water ballast double bottom tanks,
maintenance of class may be subject to the spaces in question being internally examined at
annual intervals.
Boundaries of double-bottom, deep, ballast, peak, and other tanks, including holds adapted
for the carriage of salt water ballast, are to be tested with a head of liquid to the top of
hatches for ballast/cargo holds or top of air pipes for ballast or fuel oil tanks. Special
consideration may be given to limit testing of fuel oil, lube oil and fresh water tanks to
representative tanks.
Hatch covers and coamings are to be examined to verify that no unapproved changes have
been made, that hatch covers are structurally sound and weathertight, and where
mechanically operated steel covers are fitted, satisfactory operation is to be verified.
Thickness measurements are to be carried out in accordance with Table 1. Additionally, any
part of the vessel where wastage is evident or suspect, the Surveyor may require thickness
measurements in order to ascertain the actual thickness of the material.

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Table 1
Minimum Requirements for Thickness Measurements at Special Surveys
Special Survey Special Survey Special Survey Subsequent Special Surveys
No. 1 No. 2 No. 3
1) Suspect areas 1) Suspect areas 1) Suspect areas 1) Suspect areas throughout the
throughout the throughout the throughout the vessel.
vessel. vessel. vessel.
2) One transverse 2) Two transverse 2) A minimum of three
section of deck sections within transverse sections in way of
plating abreast a the amidships cargo spaces within the
cargo space within 0.5L abreast of amidships 0.5L.
the amidships 0.5L two different
cargo spaces.
3) Internals in 3) Internals in forepeak and
forepeak tank. after peak tanks.
4) All cargo hold 4) All cargo hold hatch covers
hatch covers and and coamings (plating and
coamings (plating stiffeners).
and stiffeners).
5) All exposed main deck
plating full length.
6) Representative exposed
superstructure deck plating
(poop, bridge, and forecastle
deck).
7) Lowest strake and strakes in
way of ‘tween decks of all
transverse bulkheads in cargo
spaces together with internals in
way.
8) All wind- and water strakes,
port and starboard, full length.
9) All keel plates full length.
Also, additional bottom plates in
way of cofferdams, machinery
space, and aft end of tanks.
10) Plating of seachests. Shell
plating in way of overboard
discharges as considered
necessary by the attending
surveyor

Notes:
1. Thickness measurement locations are to be selected to provide the best representative sampling of areas likely
to be most exposed to corrosion, considering cargo and ballast history and arrangement and condition of protective
coatings.
2. Thickness measurements of internals may be modified at the discretion of the Surveyor if the protective coating
is in GOOD condition.

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3. For vessels less than 100 meters in length, the number of transverse sections required at Special Survey No. 3
may be reduced to one (1), and the number of transverse sections required at Subsequent Special Surveys may be
reduced to two (2).
4. For vessels more than 100 meters in length, at Special Survey No. 3, thickness measurements of exposed deck
plating within amidship 0.5 L may be required.

When thickness measurements indicate Substantial Corrosion, the number of


thickness measurements is to be increased to determine the extent of Substantial
Corrosion. Table 2 may be used as guidance for additional thickness measurements.

Table 2
Guidance for Additional Thickness Measurements in Way of Substantial Corrosion
STRUCTURAL MEMBER EXTENT OF MEASUREMENT PATTERN OF
MEASUREMENT
Plating Suspect area and adjacent 5 point pattern over 1 square
plates. meter.
Stiffeners Suspect area. 3 measurements each in line
across web and flange.

Definitions of commonly used terms


Ballast Tank
A tank which is being used solely for salt water ballast. A tank which is used for both cargo
and salt-water ballast will be treated as a salt-water ballast tank when substantial corrosion
has been found in that tank.
A Close-up Survey
A survey where the details of structural of structural components are within the close visual
inspection range of the surveyor, i.e. normally within reach of hand.
Coating condition.
Defined as one of the following three levels:
GOOD condition with only minor spot rusting affecting not more than 20% of areas under
consideration e.g. on a deck transverse, side transverse, on the total area of platings and stiffeners on
the longitudinal structure between these components, etc.
FAIR condition with local breakdown at edges of stiffeners and weld connections and/or light rusting
affecting 20% or more of areas under consideration, but less than as defined for POOR condition.
POOR condition with general breakdown of coating affecting 20% or more of areas under
consideration or hard scale affecting 10% or more of the area under consideration.
An Overall Survey
A survey intended to report on the overall condition of the hull structure and to determine the
extent of additional Close-up Surveys.
A Prompt and Thorough Repair
A permanent repair completed at the time of survey to the satisfaction of the Surveyor,
therein removing the need for the imposition of any associated condition of classification.

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Protective Coatings
Usually epoxy coating or equivalent. Other coating systems may be
considered acceptable as alternatives provided that they are applied and maintained in
compliance with the manufacturer’s specification.
Representative Spaces
Those spaces which are expected to reflect the conditions of other spaces of
similar type and service and with similar corrosion protection systems. When selecting
representative spaces, account is to be taken of the service and repair history on board and
identifiable critical and/or Suspect Areas.
Spaces
Separate compartments including holds and tanks.
Substantial Corrosion
An extent of corrosion such that assessment of corrosion pattern indicates a
wastage in excess of 75% of allowable margins, but within acceptable limits.
Suspect Areas
Locations showing Substantial Corrosion and/or are considered by the Surveyor
to be prone to rapid wastage.
Transverse Section
Includes all longitudinal members such as plating, longitudinals and girders
at the deck, side, bottom, inner bottom, and longitudinal bulkhead. For transversely framed
vessels, a transverse section includes adjacent frames and their end connections in way of
transverse sections.

3.6.3 Thickness Measurement Requirements


Historically, thickness measurements for ships hull were carried out only after ships reached
a certain age (typically 20 years?). Measurement of thickness (including shell plating) was
carried out by drilling holes where other means of gauging (e.g. calipers etc.) could not be
used. The extent of gauging was at the discretion of the surveyor (to the surveyor’s
satisfaction). The most likely problem locations were in way of cargo hold bilge wells where
these extended up to the bottom shell or in way of machinery spaces not fitted with double
bottoms.
Clearly drilling holes and using calipers was not a desirable method of checking thickness'.
With increasing availability and reliability of modern Ultrasonic gauging equipment, this
method has completely replaced the drilling method of thickness assessment and has now
become the industry standard.
In the last decade, the whole concept of Thickness assessment has undergone a major
change. With the introduction of ESP requirements, minimum thickness gauging
requirements have become fairly prescriptive for each ship type, the scope of these TM
requirements increasing with age of the ship.
Thickness gauging is carried out nowadays almost entirely by UT gauging equipment.
Modern UT gauges do not require even removal of the protective coatings in tanks, etc.

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(These gauges use the multiple echo method and so discount the coating thickness in this
way).
The requirements of thickness gauging are given in the Rules & Regulations of Ships (or
Inland Waterway ships, Special Service craft, etc.), and the booklet ‘Thickness Measurement
and Close-up Survey Guidance – Rev. 6’. This information is further supplemented by
guidance to surveyors in MSPM and the extracts from above are also included in the ESP
booklets sent to owners to assist them with the planning their surveys (and to prepare Survey
programmes).
Thickness Measurement Reporting
It is a requirement of the Rules that thickness measurements are to be carried out by LR
approved service suppliers. The updated list of LR approved TM Service suppliers is
available from the ‘Approvals’ option of the CD-Live home page.
It is also a Rule requirement that the surveyor needs to be on board while the thickness
measurements are taken to the extent necessary to control the process. The intention of this
requirement is not to make the surveyor witness every reading that is taken, but to monitor
the thickness measurement to the extent he/she considers necessary.
Surveyors are no longer obliged to sign off any TMs that are not carried out under their
control (ie. TMs carried out during voyage without surveyor presence). Before the
introduction of this requirement (ie. Control of surveyor, etc), it was not uncommon for
surveyors to be presented with the complete TM report with very limited opportunity to verify
the reported readings very often due to non accessibility.
It is now a requirement that prior to commencing surveys involving thickness gauging, a pre-
inspection meeting be held with owners superintendent and TM operators to agree the
location and extent of TMs to be taken (for the initial assessment)
It should be made clear at this stage, that unless the gauging results from initial assessment
are reviewed, it is not possible to commit to the number of TM readings that will be required
to be taken.
It is common for surveyors to be requested to provide estimates about the number of TM
readings which will be required to be taken (used by owner's when estimating the cost of this
task – TM service suppliers quote on the basis of number of Tm readings, etc.). While there
is no objection to extending this help it must be remembered that the figure is only a rough
guide and the actual figure may be much greater depending on the initial readings and
additional TM's required.
It is strongly recommended that TM Service suppliers use LR TM Software. This software
has virtually become the industry standard. Use of this software allows easy exchange of TM
information between offices and is also helpful in identifying the substantial corrosion/
excessive diminution areas.
During the pre-inspection meeting, TM operators to be strongly advised that as soon as any
areas of substantial corrosion/ excessive diminution are identified (by them), this must be
immediately brought to the attention of the owners superintendent and attending surveyors.
This is essential for the necessary action to deal with the deficient structure to be to be
agreed at an early stage.
Owners should be reminded that delayed submission has the knock on effect of delaying
issue of ESP documentation. As TM service suppliers are engaged by the owners, the owner
should insist on timely completion and submission of TM reports to progress with updating of
records and issue of ESP documentation.
Approved TM Service suppliers

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Approval of TM Service suppliers is under the control of Materials & NDE surveyors. In case
of any queries and feed back about these TM service suppliers get in touch with LR's
Materials and NDE Department (MNDE). In extreme cases, where the services provided by
the approved TM service suppliers are found seriously below the expected levels (e.g. use of
unqualified TM operators, absolutely no knowledge of ship’s structure, etc.) removal of these
TM service suppliers from the approved list may be considered by MNDE.
Procedure for approval is given under ‘Approvals Lists’ on the CD-Live home page. Any
queries in this regard to be directed to MNDE.
There are about 379 approved TM Service suppliers and of these most use the LR TM
software. There are some companies (HYDROSCAN, EM&I, etc.) who have their own
software and are using this to produce TM reports. This is acceptable (as long as the format
of reporting is in accordance with IACS guidelines given in URS Z10.1, 10.2, 10.3, etc. as
already stated earlier in the presentation)
It should be separately stressed that delayed submission of TM reports causes delay in
updating information and issue of ESP documentation. Delay in issue of ESP documentation
causes inconvenience to owners (financial implications for tanker owners – not getting
charter due to oil major vetting inspectors demanding to see the ESP documentation).

3.6.4 Enhanced Surveys


What are enhanced surveys? The term enhanced surveys in the context of Enhanced
Survey Programme (ESP) refers to the more detailed hull survey requirements which are
applicable to oil tankers and bulk carriers.
Why are Enhanced surveys required?
Before the days of ESP requirements, the survey requirements were not detailed enough
and were not suitable for all ship types. There was a feeling that with the periodical survey
requirements being the way they were, uniform application of these was not possible on oil
tankers and bulk carriers.
To address this issue the requirements were made more specific regarding the extent of
examination required for different parts of the structure and depending on ship type and age
of ship.
These new more detailed requirements were incorporated into the Rules in 1993. Around the
same time (November 1993) they were also included as part of IMO requirements by the
adoption of resolution A744(18) and became applicable 2 years later as part of SAFCON
survey requirements
ESP notation
ESP requirements apply to all those ships that are assigned the notation ESP as part of the
class notation. IACS Unified requirement URS Z11 provides guidance about the ships that
are to be assigned this notation. These ships are also identified by a memo on class status,
stating that ESP is applicable to this ship. Essentially ESP requirements apply to oil tankers
and chemical tankers (including combination carriers) that carry oil in integral tanks and to
bulk carriers (including ore carriers). Examples of ships to which these requirements may not
apply are inland water ways ships, edible oil tankers. These requirements currently also do
not apply to the Liquified gas carriers.

What ship types are they applicable to?


ESP requirements are applicable to the following ships:

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• According to Res. A744(18) they apply to Oil tankers and bulk carriers (to which
SOLAS and MARPOL73/78 apply as they are referenced in these)
• According to IACS Guidelines they apply to all sea going self propelled oil tankers
and chemical tankers (including combination carriers), and bulk carriers and ore
carriers.
They are therefore not applicable for oil tankers and bulk carriers and tankers that are not
seagoing (and therefore do not have SOLAS certificates (and IOPP certificates for tankers)).
By the same logic they are also not appplicable to ships below convention size (i.e. bulk
carriers below 500 Tons and Tankers below 150 Tons even though they may be seagoing,
etc.)
So what is different on these ships? Well, the survey requirements remain very much the
same as for oil tankers, bulk carriers, etc. depending on the ship’s type, etc. The only
difference is that ESP documentation is not issued/necessary.
The details of master list items for ESP ships are more detailed than on non ESP ships. For
e.g. for the master list item tank, on ESP ships the sub items include ‘overall survey’, ‘close
up survey’, TM verification, TM final report, ‘Protective coating’, etc. whereas for non ESP
ships there are generally only two items ‘Examination’ and ‘Test’. On the reports for ESP
ships too, for these sub-items more information is returned as compared to non ESP ships
(e.g. locations (i.e. frame nos.) of those tanks where single transverse web frame or deck
and bottom transverse is required to be examined and details reported.
Note: this information is to be reported only for ESP ships.

Which Rules and Conventions define the need and scope of these requirements?
Detailed requirements for survey of ESP ships are given in Res. A744(18) which is
referenced from both SOLAS Ch. XI and MARPOL Reg. 13
Similar requirements are also given in the LR Rules and Regulations (which in turn are kept
aligned with IACS Unified requirements)

Which areas of the ship do these apply to?


ESP requirements are applicable to the hull structure within the cargo tank length and also
cover all ballast tanks even though these may be outside the cargo tank length. These
requirements also cover the cargo and ballast piping systems. According to IACS
requirements this applies to the cargo area, which would then also include pump rooms,
cofferdams, etc. adjacent to the cargo tanks.

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Survey Programme
As part of ESP requirements, a survey programme (survey plannng document is required to
be submitted to (and agreed by) the local office at least six months before the survey due
date or before the surveys are commenced.
The local office is to process the document for completeness before submitting it to the
Devolved Classification Executive (DCE) office for review and agreement and then returned
to the owners.
A copy is also forwarded to the port of survey, if this is known at the time of returning the
agreed survey programme.
This survey programme is to be the reference document at the time pre survey meeting
between owners supdt., survey or and TM service supplier’s team that will be working on
board.
It is recognised that there will be occasions when ships arrive in port for commencing Special
survey without an agreed survey programme. In such cases the surveyors attending for
surveys will assist in preparing a survey programme and forward it for review/agreement (in
cases of there being insufficient time before the ship leaves surveyor may provisionally agree
the programme locally and forward a copy to local DCE for records)

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Survey Programme content


According to the requirements following is required to be a provided on the survey
programme:
• Basic ship information
• Main structural plans including details of steel used
• Tank plan
• Information regarding the conditions for survey (e.g. tank cleaning, gas freeing,
lighting, ventilation, etc.)
• Provision and method of access.
• Equipment for surveys
• Owners proposals regarding location and extent of close-up survey and thickness
measurements. (Alternatively, the extent of close-up survey and thickness measurements
could be stated with the final selection of locations being left to be agreed between surveyor
and ship’s officers at the time of survey)
• Proposals for tank testing
• Damage experience related to the ship in question

We here consider the information required in Appendix 1 of the survey programme booklet to
be adequate for review/agreement and the remaining information (e.g. plans, etc. can then
be made available to the surveyor at the time of survey.

Executive Summary
Executive summary is part of the ESP documentation. ESP documentation is required to be
issued by the Class Rules and by IMO Res. A744(18) (referenced from within SOLAS Ch.
XI, reg. 2 and MARPOL reg.13 G)
This is issued as a complete survey file.
ESP documentation comprises of following:
• Survey file containing Survey reports, TM reports and Executive summary
• Previous repair history
• Cargo and Ballast history
• Report on structural defects/deterioration in general
• Reports on leakage in bulkheads and piping systems
• Condition of coatings or corrosion protection systems (where fitted)
• Information that may help to identify critical areas
• Agreed survey programme

Executive summary is issued following completion of every Special survey reflecting the
condition of the ship at the time of completion of survey
Executive summary issued after SS completed and all Reports received /reviewed and TM
reports received. ESP documentation must not be removed from the ship (to remain on
board for the life of the ship)

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Close-up survey requires adequate access arrangements to get within arms reach of structure
to be inspected.

ESP Statement
Between the time of completion of SS and issue of ESP documentation, if required an ESP
statement can be issued. This is a statement to the owners confirming that SS has been
completed and stating that the requirements of IMO Resolution A744(18) are covered by LR
Rules.

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3.6.5 Preparation for surveys


Detailed below are a few of the ways those concerned with the survey of ships in service see
how the process of preparing for surveys could be made more efficient. Also detailed are
some of the consequences of not planning.

Preparation Consequences of not preparing

Planning ahead in the ship's schedule to Ship may be at sea when surveys become
allow for forthcoming surveys. overdue or not in a location where a surveyor
can be made available in time. Surveys
becoming overdue may result in possible port
Ensuring the ship will be in suitable detentions and automatic class suspension
locations for surveys and requesting e.g. annual survey must be completed by not
surveyor's attendance in a timely manner. more than 3 months after the ships
anniversary date otherwise automatic class
suspension is imposed.
Discuss surveys with the surveyor in advance
who will have up to date information on
revised survey requirements and outstanding
survey items.

Know the scope of the surveys in advance, Not knowing the scope of the survey may
review the survey check lists, check lead to surveys being unable to be completed
memoranda items, check for Conditions of or causing ship delays.
Class. Be in a position to request additional
surveyors in advance if time is tight and
many surveys are to be conducted at the
same time.
Allow enough suitable time and crew for
surveys e.g. cargo operations may mean
ship's staff not available to demonstrate the
operation of required items or they may be
unable to demonstrate operation of
equipment without danger.
Night time may be unsuitable for inspections
of say cargo equipment, cranes etc., too
dangerous to climb, too dark to see, think
before calling in the surveyor.

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Preparation Consequences of not preparing

Plan before carrying out repairs, advise Not reporting a damage or defect to class
class of the defects/ damages and prepare a may result in class suspension. Not
repair plan. Discuss the plan with class discussing defects with class may result in
and arrange a surveyor's attendance, this will more serious defects developing due to
ensure an adequate repair is carried out inadequate or poor repair. Defects may re-
utilising for example correct weld procedures, occur due to not correcting the root cause of
heat treatment, adequate NDT etc. the defect. Additional costly NDT may need
to be arranged if details of repair procedures
were not agreed with class prior to repair.
The repair may need to be carried out again
according to a revised more extensive repair
plan if class feel the repair was inadequate.

Provide adequately certified spares or Lack of certification of spares and machinery


replacement pieces of equipment when may result in their rejection for use onboard
planning for repairs, maintenance or classed ships. It must not be assumed that
additional installation e.g. ship side valves, certification by any class society / body will
boiler mountings, anchor cable. always be acceptable e.g. MED certification
of equipment supplied to a ship of a non EU
flag may not be accepted.

If a number of surveys are being carried out Resolving surveys one check list at a time is
at the same time using several check lists try inefficient and sometimes requires items to
to resolve the requirements into one checklist be tested more than once in order to confirm
and examine items across the lists in a an additional requirement for a different code.
logical order through the ship. Discuss the
order with the surveyor before starting, start
at the bridge and work down through the ship
and have necessary items for all surveys
available and layed out.
Have documentation ready for examination Untidy documentation and unclear markings
and verification i.e all certificates including of relevant dates slows down the survey.
class, statutory, test and servicing certificates
all filed logically with log books gathered
together for inspection.

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Preparation Consequences of not preparing


Have test dates and data clearly marked on
machinery along with copies of any
corresponding certificates on display.

Have life boat falls renewal dates clearly


marked on davits.

Have the lifeboat inventory checked against Laying out of the lifeboat inventory next to
the SE check list and have it displayed in an each boat speeds up the confirmation
orderly fashion. process.

Ensure all service dates, dates of


manufacture, expiry dates are all visible and
valid.

Ensure machinery and spaces are suitably If machinery is not prepared, or is in an


prepared and ready prior to survey e.g. unsuitable condition, for survey e.g. boiler
boilers must be sufficiently cool, cleaned and steaming, mountings not removed, mud not
mountings opened. Tanks, holds and spaces washed out OR if tanks, hold, spaces are not
should be adequately vented, cleaned, vented, scale removed etc. then severe
staged (if necessary), and have sufficient delays may be unavoidable and surveys may
lighting provided. Calibrated equipment be cancelled but costs incurred in the form of
used to correctly monitor environmental chargeable expenses
conditions within the space plus rescue
equipment should also be provided.

Prepare "Special Survey Planning Document" On many occasions ships arrive for special
for your ship at least 6 months in advance of survey without a plan leading to an inefficient
the survey and use it to plan for the survey. and prolonged process.

For structural testing of tanks, try to perform Arrival for special survey lay up without
as many boundary tests as possible prior to having progressed tank testing may cause
arrival at the dock for special survey lay up. considerable time delays in the completion of
Request surveys at ports when adjacent the survey and thereby incur unnecessary
tanks are full. Special survey can costs.
commence up to 15 months before the ships
5th anniversary date. Many boundaries can
be surveyed during this period and credited
towards special survey thus reducing lay up
time.

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Ensure close-up survey and thickness As a result of TM measurement additional


measurements (TM's) are carried out at the clos-up survey work and TM's may be
same time. required on nearby structure. Carrying out
the close-up survey and TM's at different
times would require costly access
arrangements to be provided twice.

TM's to be carried out by an approved TM TM's carried out by a non approved company
company and with a surveyor in attendance. or without a surveyor controlling the process
will be required to be re-measured at
considerable cost.

TM's should be organised as far in advance Leaving TM's too late may cause delay in
of the special survey completion date as return to service plus additional steel costs if
possible to allow maximum time to plan for optimum scantling steel is not readily
steel renewals. available for use.

Preparation Consequences of not preparing


If rafting is being used for inspection of If only one boat is provided and this is
structure try to ensure a spare boat is at hand damaged time delays could be significant.
in case of damage.

Allow for suitable bunker transfer


arrangements if bunker tanks are to be
surveyed. If bunker tanks are to be tested
ensure enough bunkers are onboard for filling
the tank to be tested.

When repairing propellers, castings including


rudder horns, rudder stocks, chain cable etc.,
weldability, materials and heat treatment
should be considered by the owner, e.g.
welding of loose chain cable pins on U3
chain cable is not acceptable without post
weld heat treatment.

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Checking continuously by ship's staff of By not carrying out frequent checks by ship's
structure, machinery and equipment in order staff of structure, machinery and equipment
to confirm their good order. and by relying on periodical surveys only, the
ship owner risks serious delays due to
Ship's staff should, with commitment, use
machinery breakdowns and emergency
copies of the class society's survey check
repair work. In addition if the serious defects
lists plus the SE1 and C11(IMO) to ensure
are found by PSC the owner risks port state
that all items are covered and are in good
detention and the ship being named in the
order.
press. Such detentions may also result in
class suspension and withdrawal if the owner
is found not to be maintaining the ship
Operational checks should be carried out at
adequately, this being a basic condition of
regular drills e.g. fire drills, boat drills,
classification.
emergency steering exercises etc.

Opportunity should be taken to inspect


structure inside tanks, holds and other
spaces as often as possible so that any
structural defects are found as early as
possible and repairs can be planned.

Planning of repair periods will ensure that Major deficiencies are more likely to be found
required services are available (public for the first time during survey e.g. fire pumps
holidays/ Sunday's can be avoided). , emergency generator, life boat davits etc.
not working or serious cracks in structure. If
serious defects are found during survey this
may lead to increased down time of the ship
due to extended survey periods and
unexpected periods when the ship is not in
service.

Lack of crew commitment in carrying out


checks will have little effect in avoiding costly
repairs or periods when the ship is kept out of
service.

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Sources of Information for Surveys


Prior to carrying out surveys important information about the ship to be surveyed and the
requirements for the survey can be obtained, by the surveyor, from the following sources:

• Ship specific proforma from Ship Survey System (SSS)


• ClassDirect Live
• The Intranet where the following can be accessed:
Country Files
Marine Technical Notices (MTN)
The Rules and Regulations
The Survey Procedures Manual (SPM)
LR Technical Association (LRTA) Papers
• Office technical libraries
• Office network including local offices and plan approval centres
• Individual specialists

Owners can obtain information from:

• Quarterly listings
• ClassDirect Live

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4 Statutory Services
It is essential to understand the difference between a class survey and a statutory survey.
The latter survey if carried out by a class surveyor is being conducted on behalf of the flag
administration for the country with which the ship is registered unlike the class survey which
is carried out on behalf of the class society itself. The requirements of the statutory survey
are governed by the statutory instruments adopted by the flag administration and not the
classification rules and regulations. As per statutory surveys all statutory services offered by
the class society are conducted on behalf of the flag administration e.g. approval of intact
and damage stability, approval of safety equipment arrangements etc.
Lloyd’s Register is authorised by more than 135 national administrations to undertake
surveys and approval work on their behalf. The exact degree of authorisation, however,
varies from country to country. Classification Societies have to work to more rigid guidelines
when it comes to dealing with ships that fail to meet the appropriate standards in Statutory
surveys as they are acting on behalf of the flag administation and are therefore applying a
country's law.
In most cases the statutory instruments used for the survey of ships are based on the
internationally adopted codes and conventions covering subjects such as safety construction,
safety equipment, safety of navigation, pollution prevention, Load Line and safety
management. It is worth noting that even countries which have adopted international codes
may in addition have their own national requirements known commonly as flag requirements.
The class society can assist the owner should he wish clarification on or interpretation of flag
requirements.
The introduction in the marine industry of internationally adopted codes and conventions has
been the result of the formation of the International Maritime Organization (IMO). The
organization has overseen the introduction of conventions including the 1966 International
Load Line Convention, The International Convention for Safety of Life at Sea (SOLAS), The
International Tonnage Convention plus others to name a few.
IMO including it's history, organization and function is detailed later in this document.

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5 Consultancy Services
Lloyd’s Register has a range of specialist services aimed at helping ship builders, owners
and operators, which are not directly related to classification or Statutory issues. These
include specification and supervision services, Fuel and lubricant analysis, technical
investigations of damage and vibration, and emergency response for major problems such
as fires, groundings or collisions. It is involved in all areas of marine business from new
buildings through conversions, to yacht building and naval vessels. Details of all the current
services are available in LR's Marine Services brochure and are also outlined in the diagram
below.

LR Global Client Network

Condition Specification & Specialist Failure Specialist


New Activities Risk Assessment
Assessment Design Review Measurement Investigation Analysis

• Extend to new • Trade and • Condition • Ship life • Shaft analysis & • Field & lab trials • FOBAS
products and operability surveys extension alignment • Sea trials • Drugs/alcohol
services studies • Condition • Future rules • Engine • Performance • Ballast water
• Feasibility monitoring • Due diligence mechanics testing • Environment
studies • CAP • Financing • Combustion • Material and
• Total risk • Life extension • Spec. review • Thermodynamic component
assessment studies • Tender review s failure
• Fleet evaluation • Crack • Sale & purchase • Propulsion
management • Ice interaction

Expand strength and depth in existing activities in line with demand

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6 The International Maritime Organisation (IMO)


IMO is a specialised Agency of the United Nations and was the first ever international body
devoted exclusively to maritime matters. In 1948 an international conference in Geneva
adopted a Convention formally establishing IMO. (The original name was the Inter-
Governmental Maritime Consultative Organization, IMCO, but this was changed to IMO in
1982). IMO is based in London. The IMO Convention entered into force in 1958 and the
Organization met for the first time in 1959. Other long established UN Agencies include the
Food & Agriculture Organisation (FAO) based in Rome, the International Labour Office (ILO)
and the World Health Organisation (WHO), both based in Geneva.
From its earliest days, the IMO’s most important objectives have been the improvement of
maritime safety and the prevention of marine pollution. It is responsible for developing new
regulations and procedures for the shipping industry, or revising existing ones. Most of these
will subsequently be incorporated in national legislation. At present the IMO consists of 162
Member States, often referred to as Flag States, and two Associate Members.

6.1 IMO Structure

The International Maritime


Organization

162 Member
States

UN Agencies 57 Non-Governmental
organisations. OCIMF,
UNCTAD, WHO, IMO
ILO, etc. IACS, IMPA, IFSMA,
ICS, ISO. INTERTANKO etc.

37 Inter-Governmental
organisations
EC, IMSO etc.

The governing body of the IMO is the Assembly which meets every 2 years. Between
sessions it is run by the Council which, from November 2002, consists of 40 Member States
elected by the Assembly. There is also a Secretariat of some 300 people, working in six
technical divisions. The Organization is led by the Secretary-General.

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The IMO Committee Structure

Assembly
(meets every 2 years)

Council
40 Elected Members

Marine
Technical Maritime
Legal Facilitation Environment
Cooperation Safety
Committee Committee Protection
Committee Committee
Committee

Most of the IMO’s work is carried out by a number of Committees and Sub-committees. The
most senior of these is the Maritime Safety Committee or MSC. This is responsible for
issues relating to SOLAS (The International Convention for Safety of Life at Sea, 1974) and
for STCW 95 (The International Convention for Standards of Training, Certification and
Watchkeeping, 1995)
The Marine Environment Protection Committee, MEPC, was established in 1973 raised to full
constitutional status in 1985 and is responsible for co-ordinating the IMO’s activities in the
prevention and control of pollution of the marine environment from ships.

The MSC and MEPC


Marine Maritime
Environment Safety
Protection Committee
Committee (MEPC) (MSC)

Communications Dangerous Goods,


Bulk Liquid Fire
and Search Solid cargoes and
Gases Protection
and Rescue
(BLG) Containers (DSC) (FP)
(COMSAR)

Safety of Stability Standards of


Flag State Ship Design
Navigation loadlines & Training and
Implementation and Equipment
(NAV) Fishing vls Watchkeeping
(FSI) (DE)
safety (SLF) (STW)

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The MSC and the MEPC have nine sub-committees which report to them and develop
amendments to the SOLAS, MARPOL STCW Conventions and other IMO measures as
necessary.
The Legal Committee is another permanent committee responsible for considering any legal
matters within the scope of the IMO.
The Technical Co-operation Committee co-ordinates the IMO’s work in providing technical
assistance on maritime matters, especially to developing countries.
The Facilitation Committee is responsible for activities and functions that relate to facilitating
international maritime traffic. The aim is to reduce the formalities and simplify the
documentation required when ships enter or leave ports or terminals.
Apart from delegates from the member states, the IMO committees and sub-committees also
include representatives of a wide range of inter-governmental organizations , such as the
European Commission (EC), the International Mobile Satellite Organization (IMSO), and non-
governmental organizations , such as IACS and Intertanko. These organisations have been
granted consultative status to aid the committees’ work in an observer capacity. They may
provide information, documentation and expert advice, but they do not have any voting
powers.

6.2 Developing Legislation

Making potential legislation at the IMO


Original Submission

MSC/MEPC Review Approved Work Programme

Added to agenda for next session Papers submitted

Reviews by Technical Sub-Committees Submissions

Committee discussion

Agreement

Resolution, Amendment or Circular

Creating or amending the IMO Conventions and Codes can take considerable time. The
diagram shows what can be involved and the procedures that need to be undertaken in the
passage from an original submission to implementation.
Each convention includes appropriate provisions stipulating conditions which have to be met
before it enters into force. These conditions vary but generally speaking, the more important
and more complex the document, and the more stringent are the conditions for its entry into
force. For example, the 1974 SOLAS Convention required acceptance by 25 States whose
merchant fleets comprised not less than 50 per cent of the world’s gross tonnage. This is
called ‘positive acceptance’ In the case of some conventions which affect a few States or
deal with less complex matters, the entry into force requirements may not be so stringent.

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In early conventions, amendments came into force only after a percentage of Contracting
States, usually two thirds, had accepted them. This often led to long delays. To remedy the
situation, a new amendment procedure was devised. This procedure is called ‘tacit
acceptance’. It provides that an amendment shall enter into force at a particular time unless
before that date, objections to the amendment are received from a specified number of
Parties.
This procedure has been used in the case of conventions such as the Convention on the
International Regulations for Preventing Collisions at Sea, 1972, the International Convention
for the Prevention of Pollution from Ships, 1973 and SOLAS 1974, all of which incorporate a
procedure involving the tacit acceptance of amendments by States.
As was expected the tacit acceptance procedure has greatly speeded up the amendment
process. The 1981 amendments to SOLAS 1974, for example, entered into force on 1
September 1984. Compared to this, none of the amendments adopted to the 1960 SOLAS
Convention between 1966 and 1973 received sufficient acceptance to satisfy the
requirements for entry into force.

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7 The International Association of Classification Societies (IACS)


The International Association of Classification Societies, IACS, was established in 1968 and
now comprises of ten member societies and three associate members. Between them, these
Societies class some 46,000 ships comprising more than 90% of the world’s total merchant
tonnage.
The principal objectives of IACS are to maintain and improve standards throughout the
industry so as to make a major impact in improving the safety of ships and ensuring cleaner
seas through reducing pollution. In achieving these objectives IACS works closely with IMO
and with many other national regulatory bodies and industry groups.

The IACS Members are:


American Bureau of Shipping (ABS);
Bureau Veritas (BV);
China Classification Society (CCS);
Det Norske Veritas (DNV);
Germanischer Lloyd (GL);
Korean Register of Shipping (KR);
Lloyd's Register of Shipping (LR);
Nippon Kaiji Kyokai (NK);
Registro Italiano Navale (RINA);
Russian Maritime Register of Shipping (RS).

The IACS Associate Members are:


Croatian Register of Shipping (CRS);
Indian Register of Shipping (IRS).

As the pressure grows for improved standards of ship construction, maintenance and
operation, IACS members are going to play a crucial role in helping the industry achieve
better performance and eliminate many of the sub-standard ships that cause the majority of
the problems.

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8 Port State Control (PSC)

8.1 Glossary

Flag State: State in which a ship is registered and which undertakes to regulate its activities
under its own domestic laws and appropriate international treaties and conventions.

Port State: State in which a port visited by a foreign flagged ship is situated.

Port State Control: inspection and any necessary intervention, in respect of the standards on
board flagged ships by the authorities of the port State.

8.2 Regulating Shipping

It is well established that the ultimate responsibility for the safe and civilised operation of a
ship lies with the owner, aided by the flag administration and classification society. Port State
control is regarded as a valuable adjunct to the activities of the flag and classification society
and as such, is fully supported by LR and all other IACS members. However, port State
control is not – nor was ever intended to be – a substitute for the proper exercise of flag
State responsibility.

8.3 The Price of Sovereignty

Historically, sovereign States claimed the right and now, under international law, a State has
the duty to exercise jurisdiction and control in administrative, social and technical matters
concerning ships which it allows to fly its flag. A flag State is required to take all necessary
measures to ensure safety at sea and the protection of the environment with regard to
construction, maintenance and training, labour conditions and prevention of collisions of its
ships.

Sovereign and other self-governing States, of course, also have the right to control any
activities within their own borders, including those of visiting vessels.

8.4 The Role of the Flag State

The arguments regarding ‘open registers’, often called ‘flags of convenience’ (FOCs), have
raged over the past 50 years, principally between the International Transport Workers’
Federation (ITF) on the one hand and owners’ organisations, such as the International
Shipping Federation (ISF), and the flags themselves on the other.

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However, there is general agreement that the huge inequalities between flag States and their
performance are behind many of the industry’s problems. Substandard flags allow
substandard ships and there are, as yet, no mandatory quality approval system for flag
States – nor is there likely to be.

Classification societies act on behalf of both national flags and FOCs on a wide range of
subjects, but apart from ISM matters, they are almost exclusively to do with construction and
equipment. The central matters of operation, manning and maintenance remain wholly the
responsibility of the owners under the direct supervision of the flag.

8.5 The ‘Circle of Maritime Responsibility’

Owner – shipper – charterer – broker – financier – insurer – lawyer – ship manager –


classification society – flag: each can choose whom to do business with. A quality operation
should be seen to be associating with other quality organisations in the circle.

8.6 Mixed Crews

Crew costs are a major factor in the running costs of a ship and according to a major ship
manager, can vary by a multiple of six between a low cost FOC ship and a high cost national
crew. Once one owner in a particular trade switches to a FOC and the cheapest crews that
the manning market can provide, it is very difficult for the others to ignore the competitive
pressure that this creates. One result is the prevalence of mixed crews, mixed both in
nationality and language and decidedly mixed in competence. A study of members’ ships by
the UK P&I Club found that 56% had mixed nationality crews. As somebody said, in an
emergency, everyone panics in his or her own language.

8.7 The Substandard Ship

A substandard ship is defined by IMO in ‘Procedures for Port State Control –2000 Edition’ as
‘a ship whose hull, machinery, equipment, or operational safety is substantially below the
standards required by the relevant convention or whose crew is not in conformance with the
safe manning document.’

The relevant conventions are shown to be:

The International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS 74),
the Protocol of 1988 relating to the International Convention for the Safety of Life at Sea,
1974 (SOLAS Protocol 1988), the International Convention on Load Lines, 1966 (Load Lines
66), the Protocol of 1988 relating to the International Convention on Load Lines, 1966 (Load
Line Protocol 88), the International Convention for the Prevention of Pollution from Ships,
1973 as modified by the Protocol of 1978 relating thereto, as amended (MARPOL 73/78), the
International Convention on Standards of Training, Certification and Watchkeeping for
Seafarers,1978, as amended (STCW 78), and the International Convention on Tonnage
Measurement of Ships, 1969 (Tonnage 69).

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8.8 The Development of Port State Control

8.8.1 Origins

PSC was introduced (and is expanding) primarily for political reasons, responding to
commercial and environmental concerns. The major impetus was given by pollution following
the groundings of the ‘Amoco Cadiz’, Exxon Valdez’ and ‘Braer’ (none of them ‘substandard
ships’) and commercial pressures on higher cost countries from low cost competition.

Following the adoption, on 17 February 1978, of the Protocol to SOLAS 1974, eight countries
signed the Hague Memorandum on 2 March. This aimed at the general surveillance of
seagoing ships to ensure that requirements laid down in various international conventions
were met, not least regards living conditions. Two weeks later, on 17 March, the ‘Amoco
Cadiz’ grounded on the coast of France, spilling 230,000 tonnes of oil. This was a major
incentive for the European Commission to start working on means to strengthen the
effectiveness of control, leading to the Paris Memorandum of Understanding being adopted
in 1982. Others have followed since.

The lack of control by many flag States is, in part, compensated by port State control, which
could be described as a compulsory sharing of the costs of FOCs over the whole industry. It
is certainly true, however, that no flag State (or classification society), however reputable or
well-intentioned, can be represented everywhere. By definition, the port State always is.

PSC is mandated by the United Nations Convention of the Law of the Sea, and among
others, SOLAS Regs I/19 and XI/4 and guided by IMO Res. A.787 (19) ‘Procedures for port
State control.

Regional groupings are much more effective than single port States for the obvious reason
that ships move.

8.8.2 Port State Control Organisations

Paris MOU:
Operational 1982, the signatories are the EU littoral States plus Canada, Norway, Poland,
Russia, Croatia and the newest member Iceland. It is now heavily influenced by incorporation
in EU directive 95/21/EC.
www.parismou.org

Asia-Pacific (Tokyo) MOU:


Operational 1994, it comprises 18 countries including Canada and Russia, which are also
Paris MOU members. The newest member is Chile which is also a Vina del Mar member.
www.tokyo-mou.org

United States:
The USCG has operated a ‘SOLAS’ PSC system since 1994, adding to its long-standing
regime of inspecting foreign flagged ships for compliance with the United States Code of
Federal Regulations. It co-operates with other PSC organisations.
www.uscg.mil/hq/g-m/pscweb/index

Latin-American Agreement (Acuerdo de Vina del Mar):

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Signed 1992, it consists of 10 members, becoming more active. Brazil also operates a bulk
carrier structural inspection programme.
www.acuerdolatino.int.ar

Caribbean MOU:
Signed 1996, has 22 members, not yet very active.

South Mediterranean MOU:


Signed in July 1997 by 10 countries, including Cyprus and Turkey.
www.medmou.org

Indian Ocean MOU:


Signed in June 1998 by 15 countries with India, South Africa and Australia being the driving
force.

West and Central Africa MOU (Abuja MOU):


Signed in 1999 by 19 countries.

Black Sea Region (Black Sea MOU):


Signed in 2000 by 6 countries.

8.8.3 Co-operation and Consistency

A key element of the MOUs is the sharing of information and expertise, in order to obtain a
consistent approach to inspections. They also permit regional action to permit (or facilitate)
compliance.

8.9 Port State Control Inspections

8.9.1 Targets for Inspection

In the early days, ships were inspected almost at random, the original Paris MOU referring
only to paying special attention to ships which may present a special hazard. The ‘random’
inspections gave a defensible set of data on deficiency types and differences between ship
types, owners and flags. From these has developed the concept of ‘targeting’, of assigning
priorities regarding which ships to be inspected.

Points systems are used by the USCG and the Paris MOU as an aid to targeting but priorities
for inspection can be summarised as:

(i) ships not inspected previously;


(ii) ships or operators with a deficiency record;
(iii) ships of flags and/or classification societies with a worse than average detention
record;
(iv) ship types in ‘higher risk category’ because of detention records or nature of cargo
(including passengers) and
(v) ships not classed by an IACS member.

In the Paris MOU system, credit points are awarded for a previous ‘no deficiencies’
inspection, which will offset debit points against the flag and so on.

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More detailed information on Paris MOU and USCG Targeting Factors is available in
LRTA Paper No.3, Appendices A and B.

8.9.2 ‘Clear Grounds’ to Conduct a More Detailed Inspection

Before and on boarding, the PSCO should gain a general impression of the condition of the
ship. He will then examine the ship’s relevant certificates and documents, including the
crew’s papers. If the certificates are valid and the PSCO’s general impression and visual
observations on board confirm a good standard of maintenance, the PSCO should generally
confine the inspection to observed or reported deficiencies, if any. In short, the instructions
are ‘if it looks good and the papers are correct, go to another ship’.

If, however, from his general observations, the PSCO has ‘clear grounds’ for believing that
the ship, its equipment or its crew do not substantially meet the requirements of the relevant
conventions he should carry out a ‘more detailed inspection’. Examples of ‘clear grounds’
and guidelines for ‘more detailed inspections’, are given in IMO Resolution A.787 (19)
(this is reproduced on the Intranet web site – Marine/Technical Performance/Port State
Control and can also be found in CDLive and Rulefinder.)

8.9.3 The Emphasis on Crews

The review of the operation of the industry, which led to the introduction of the ISM Code and
the amendments to the STCW, led also to a change in the approach to inspection to be
taken by port State control. The ‘clear grounds’ for a more detailed inspection were
expanded to include unsatisfactory control procedures under SOLAS, MARPOL and STCW,
cargo
operations, involvement in incidents, inadequate fire, boat and other drills and evidence that
the crew may not be able to communicate with each other or other people on board.

The principal means of verifying crew competence and communication is to require a


practical demonstration of their skills. Details are given in Section 3.5 of IMO Res. A.787 (19)
– ‘Guidelines for the control of operational requirements’. This is reproduced on the Intranet
web site – Marine/Technical Performance/Port State Control and can also be found in
CDLive.

8.9.4 Recording and Reporting of Deficiencies

The Paris MOU adopted a coding system for deficiencies found and actions taken. This
system has been taken up by the other MOUs and lately also by the USCG. LR, too, uses
the codes in its port State control database. These are very useful in creating a standard set
of data for statistical purposes but the actual deficiency still has to be described, usually in
English, on the forms provided. Access to these descriptions, therefore, is essential for
anyone taking any sort of action on them and they are often less than clear to anyone but the
originator. Copies of a typical (invented) report are given as appendix C and Appendix D in
the LRTA paper. The code list can be found on the Intranet web site – Marine/Technical
Performance/Port State Control.

8.9.5 Most Frequent Deficiencies

PSC inspections frequently indicate inadequate maintenance or training on board,


particularly as regards non revenue-earning items, which, nonetheless, may be critical to the

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safety of personnel, the ship and the environment. If it doesn’t make money, it doesn’t get
done. These non revenue-earning items include life-saving equipment, fire prevention and
equipment, cleanliness (accommodation and machinery spaces), navigation equipment.
Meaningful onboard drills and maintenance and adherence to the approved safety
management system, where applicable, should enable the identification and correction, by
the crew, of many of these deficiencies. The latest version of the Maintenance Guide
Checklist can be obtained using the Intranet – Marine/Technical Performance/Port State
Control and can also be found on CDLive.

The most frequent deficiency of all is crew competence – both in terms of training and there
being insufficient number on board to deal with the maintenance or even to drive the ship.

Small and medium sized bulk carriers and general cargo ships are by far the types of ships
most frequently detained, with general cargo ships proportionally four times the rate for
tankers which have generally a good record, being subject to the greatest political and
environmental pressures. Container ships, carrying ‘clean’ cargoes, and on liner service
deadlines, are rarely in detention, although the rate may be expected to increase.

8.9.6 Attendance on board

It is essential that all PSC detentions are attended and reported in accordance with MSPM
requirements. These can presently be found in the MSPM Part E, Chapter 7 Section 1.6.

8.9.7 Appeals

Until recently any appeal procedure (apart from USCG) was instigated by the Technical
Performance Group. This process has now been changed to allow greater involvement
locally.

Now the attending Surveyor will be able to appeal against detentions at source if they are felt
to be unfounded. This is especially important in relation to detentions which are assigned as
‘class responsibility’ in Form A of the PSC Boarding Report. Details of the criteria for appeals
can be found on the Intranet web site – Marine/Technical Performance/Port State Control
and can also be found on CDLive.

8.10 Naming and Shaming

8.10.1 Publications of Detentions


The details of individual detentions are published in different formats by the different
organisations (many on the Internet) and emphasise different aspects but all try, in one way
or another, to indicate the relative degree of ‘substandard’.

It is not easy for anyone, whether a potential shipper or insurer or flag or classification
society or even another PSC organisation, to find out what a ship’s or owner’s inspection
record is. Solving this problem of transparency of information is fundamental to the success
of port State control in enabling the responsible user community within the ‘circle of maritime
responsibility’ to discriminate against the substandard operator. The European Union’s
European Quality Shipping Information System (EQUASIS) is being developed to address
this problem.

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8.10.2 Comparison of Classification Societies


The ship’s classification society is included in most of the published lists. A general caveat is
usually included that the stated deficiencies may not be under the certification of the
classification society. The USCG applies a defined set of ‘filtering criteria’ to establish
whether a particular deficiency was present when the item was last surveyed by class and
hence can be considered a ‘survey failure’ or ‘class non-conformity’ and held against the
classification society. A similar system has been introduced by the Paris MOU, with Tokyo
MOU now following as of this year.

It has been estimated that around 90% of PSC detentions are associated with poor crew
operational standards and lack of proper maintenance on board and are not directly
associated with a ‘survey failure’.

8.11 Conclusions
8.11.1 Is PSC driving the Substandard Operator out of Business?
There are many cases of ships being examined and sometimes detained and ‘put right’ by
PSC only to be detained elsewhere, shortly afterwards, with an even longer list of serious
deficiencies. This is primarily because, at present, a PSC inspection makes no claim to be a
thorough examination of the ship. The Port State does not have the amount of time and
access available to the owners and the flag State. The short time in port of most ships,
combined with problems of physical access to the structure and machinery, limit the extent of
examination of the ship and assessment of the capabilities of the crew. Thus, a PSC
inspection is usually just a spot check, although an increasingly targeted and informed check
and the report of deficiencies will accordingly be limited to those that are already observable.

When a ship is detained, the owner is required only to put right the deficiencies listed. They
are being made to do only what they should have done already. It is akin to a motorist, who
hasn’t paid their insurance and being stopped by the police, simply handing over the
premium due and being allowed to drive away.

We have no evidence, so far, to show that, except in the most extreme cases, PSC or the
classification societies are being successful in driving the substandard operator out of
business. Most ships detained are not delayed and it may well be cheaper to risk and suffer
a detention than to prevent it.

It can be argued that the present PSC regime of detaining but not delaying, and the efforts of
LR and other classification societies in carrying out additional surveys of problem ships may,
in fact, be counter-productive and prolong the problem by patching up ships which should
really have been put out of business. Additionally, the presence of a Surveyor on board has
ceased to be an event with any significant adverse consequences for the crew, thus it is rare
for safety equipment to be broken out, checked and ready for survey or even for tanks to be
open, ventilated and lit for examination. Disclassing or deleting from a flag’s register may
help the image of the individual classification society or flag but unless and until IMO
Resolution A.739 (18) is properly enforced, in relation to the issue of SAFCON certificates,
the ship will in all probability continue to be able to trade.

This situation will no doubt change. In the Paris MOU area, legislation is being prepared
which will come into force during 2003. When this takes affect vessels flying a targeted flag
may be liable to a banning order if the vessel has a number of PSC detentions in a given
period within the Paris MOU area. Other MOUs will obviously keep a close watch on this
development.

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8.11.2 Rewarding Quality Shipping


The targeting by port State organisations is getting better but still has some way to go. They
might consider whether their long-standing inspection quotas are still appropriate; in the case
of the Paris MOU, the objective of inspecting 25% of the ships arriving in any one country. It
surely would be better to expand the ‘more detailed inspection’, once properly detainable
deficiencies are found, into a ‘very detailed inspection’ and accept an overall reduction in the
number of ships inspected.

Port State control is not succeeding enough but has the disadvantage by substandard
operators, the present system does have to change. The industry must find ways to make
detention prohibitively expensive. The culture of expectation of postponement must be
changed to an expectation to repair. Coupled with this, owners demonstrating a good system
and record must be aided by a lightening of touch by the regulatory authorities.

Good owners must be helped by the elimination of the bad but these same good owners
must play a large part in their own battle. The resources of all the maritime authorities are
stretched. Few additional surveyors are available to carry out enhanced surveys, retrofit of
bulk carriers, the other extra surveys outlined above, (or even port State control) and the
good owners must realise that these resources are not going to be provided by the bad.

The United States Coast Guard has been instrumental in implementing a quality initiative
which goes part way to rewarding the good owner.

They have established the QUALSHIP 21 initiative. This initiative identifies high quality non-
US flagged vessels and then awards them with incentives, which include Qualship 21
Certificates, vessel names posted on the USCG web site, Qualship designation on EQUASIS
files and less frequent PSC examinations. There is also presently the possibility of a
reduction in port fees being implemented for qualifying vessels.

The USCG criteria for qualification are that these vessels are managed by well-run
companies, classed by organisations with a quality track record, have an outstanding PSC
record in US waters, and are registered with flag States that have a superior PSC record.

To date, it is noted that the highest number of vessels qualifying are LR class vessels (41%)

However, a Port State Control Officer does have one unique weapon. If he finds the first ship
on his list for the day in poor condition, he is able to concentrate on that ship and does not
have to go on to the others, an advantage, which could if used aggressively and with the full
co-operation of the flag, really make the operation of substandard ships not worth the game.
Only then will port State control truly have succeeded.

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9 IMO Conventions
Member States that are signatories to one, more, or all of these Conventions are legally
obliged to enact them into their own laws and ensure that vessels registered under their flags
obey them. Some of the most important Conventions, Annexes, Agreements, Protocols are
shown in the Table.

Some Major IMO Conventions


IM O C o nv e ntio n 4 8 C L C P ro to c o l 7 6
IM O a me ndme nts 9 1 C L C P ro to c o l 9 2
IM O a me ndme nts 9 3 INM AR S AT C o nv e ntio n 7 6 F UND C o nv e ntio n 7 1
S O L AS C o nv e ntio n 7 4 INM AR S AT O A 7 6 F UND P ro to c o l 7 6
S O L AS P ro to c o l 7 8 INM AR S AT a me ndme nts 9 4 F UND P ro to c o l 9 2
S O L AS P ro to c o l 8 8 INM AR S AT a me ndme nts 9 8 NUC L E AR C o nv e ntio n 7 1
F AC IL ITATIO N C o nv e ntio n 6 5
L O AD L INE S C o nv e ntio n 6 6 M AR P O L 7 3 /7 8 (Anne x I/II)
L O AD L INE S P ro to c o l 8 8 M AR P O L 7 3 /7 8 (Anne x III)
TO NNAG E C o nv e ntio n 6 9 M AR P O L 7 3 /7 8 (Anne x IV)
C O L R E G C o nv e ntio n 7 2 M AR P O L 7 3 /7 8 (Anne x V)
M AR P O L P ro to c o l 9 7 (Anne x VI)
O il P re pa re dne s s R e s po ns e

S TC W C o nv e ntio n 7 8
S TC W -F C o nv e ntio n 9 5
S AR C o nv e ntio n 7 9 C L C C o nv e ntio n 6 9

The main Conventions that affect most ships are:


1 The International Convention for the safety of Life at Sea, 1974. (SOLAS 1974) This
incorporates the International Safety Management (ISM) Code.
2 The International Convention for the Prevention of pollution from ships 1973/1978.
(MARPOL 73/78)
3 The International convention for Standards of Training, Certification and Watch-keeping
1978/95 (SCTW 1995)
4 Load Lines Convention 1966
5 Colreg Convention 1972

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9.1 SOLAS 1974


9.1.1 General
The International Convention for the Safety of Life at Sea (SOLAS) was adopted by the
International Conference on safety of life at sea, 1st November 1974 and entered into force
on 25th May 1980. It has been modified twice by means of Protocols in 1978 and 1988. The
introduction, maintenance and updating of SOLAS is the responsibility of the Maritime Safety
Committee (MSC) of the International Maritime Organisation (IMO).
From the very title of the convention its importance can not be over emphasised, however, it
can be seen from the diagram below that approximately 50% of all major deficiencies are
attributed to SOLAS related items. These deficiencies have been found as a result of Port
State Control inspections which in turn resulted in ship detentions.

From the diagram above SOLAS major deficiencies as a percentage of total deficiencies
breaks down as follows:
Fire safety 14%
Life Saving Appliances 12%
Safety in general 12%
Safety Navigation 9%
Safety radio 3%
Certificates and log books 3%
ISM related 3%
Total 56%

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9.1.2 Surveys, Certificates and Records


Detail of who is permitted to carry out surveys relating to ship certification in issues relating to
SOLAS, the scope of the surveys and the timing of the surveys is detailed in Chapter I Part B
of SOLAS.
In brief SOLAS based surveys will be carried out by surveyors working for either a National
Administration corresponding to the ships flag e.g Danish Maritime Administration (DMA) for
a Danish flag ship or by the surveyor of a Recognised Organisation (RO) e.g. A Class
Society. In the case of a Class Society surveyor carrying out the survey the society
concerned will have had authorisation given to it by the flag administration to conduct the
survey concerned. In many cases the Class Society will have blanket authority to carry out a
particular survey on all ships of that flag, however, sometimes the Society is given
authorisation on a case by case basis only and individual named surveyors are authorised by
the National Administration.

The main SOLAS based surveys are divided as follows:


Safety Construction Survey (SAFCON Survey) involving the survey of the structure,
machinery and equipment excluding items related safety equipment e.g. lifeboats, life
jackets, fire extinguishers etc. and safety radio e.g. Global Maritime Distress an Safety
Service (GMDSS) equipment, Emergency Position Indicating Radio Beacons (EPIRB's) etc.
On satisfactory completion of the SAFCON survey a Cargo Ship Safety Construction
Certificate would be issued or endorsed as applicable. The form of the certificate and the
information to be included on it are strictly laid down in the appendix to SOLAS. Following
the Initial Safety Construction Survey which is recorded as having been completed on the
ship's day of delivery compliance is required to be shown annually and this is effected
through successful completion of the Class Annual Survey Check List (see Annex 3) which is
deemed to incorporate all annual SAFCON items.
Safety Equipment Survey involving the survey of all life-saving appliances and fire safety
systems and appliances, also fire control plans, nautical publications, lights, shapes and
means of making sound and distress signals in accordance with collision regulations. On
satisfactory completion of the Safety Equipment Survey a Cargo Ship Safety Equipment
Certificate would be issued or endorsed as applicable. The Safety Equipment Certificate
would also be supplemented onboard by a Record of Equipment for the Cargo Ship
Safety Equipment Certificate (Form E). Following the Initial Safety Equipment Survey
which is recorded as having been completed on the ship's day of delivery compliance is
required to be shown annually and this is effected through successful completion of the
Annual Safety Equipment Survey the requirements of which are shown in the Safety
Equipment Survey Check List (see Annex 7).
Safety Radio Survey involving the survey of all radio installation equipment including those
used in life-saving appliances fitted in accordance with Chapters III and IV of SOLAS. On
satisfactory completion of the Safety Radio Survey a Cargo Ship Safety Radio Certificate
would be issued. The Safety radio Certificate would also be supplemented onboard by a
Record of Equipment for the Cargo Ship Safety Radio Certificate (Form R). Details of
the requirements for Radio Surveys can be found in Annex 8.
The surveys, certificates and records are those most commonly carried out and issued but
you should be aware of the existence of the Passenger Ship Safety survey and certificate
plus the Cargo Ship Safety certificate which is a combined Safety Construction, Safety
Equipment and Safety Radio certificate.

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9.1.3 Applicability of SOLAS


SOLAS 1974 and the Protocol of 1978 apply only to ships engaged on international voyages
except (as stated in Chapter I Part A Reg. 3):

1) Ships of war and troopships


2) Cargo ships of less than 500 GT
3) Ships not propelled by mechanical means
4) Wooden ships of primitive build
5) Pleasure yachts not engaged in trade
6) Fishing vessels

It should be noted that throughout SOLAS at the beginning of each chapter and in the case
of some regulations applicability is more precisely defined. E.g. Chapter IV
"Radiocommunications" Part A, Regulation 1 states that the chapter applies to "cargo ships
of 300 gross tonnage and upwards" not 500 gross tons as is the general case.

Application of SOLAS requirements are also often dependent on when the ship's keel was
laid or the ship was at a similar stage of construction which is defined as when:

• Construction identifiable with a ship begins and


• Assembly of that ship has commenced comprising at least 50 tonnes or 1% of the
estimated mass of all structural material, whichever is less.

It has been known for ship yards to produce a number of 50 tonne blocks prior to a known
date when application of new SOLAS requirements could thus avoided along with possible
associated additional cost.

Part 1 covers the articles relating to the Convention of 1974, and the Protocol of 1988, and
the consolidated text of the Annex to the 1974 SOLAS Convention. This consists of twelve
Chapters, plus an Appendix (showing the format of certificates)

Part 2 covers the three annexes as detailed below.

The twelve chapters of part 1 cover the following topics:


I General Provisions
II-1 Construction- Subdivision and stability and machinery and electrical installations.
II-2 Construction- Fire protection, fire detection, and fire Extinction.
III Life-Saving Appliances and arrangements
IV Radio Communications

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V Safety of Navigation
VI Carriage of Cargoes
VII Carriage of Dangerous Goods.
VIII Nuclear ships
IX Management for the Safe operation of ships
X Safety measures for high-speed craft
XI Special measures to enhance maritime safety
XII Additional safety measures for bulk carriers

The three annexes of Part 2 address:


Annex 1 Implementation of the harmonized system of survey and certification
Annex 2 Certificates and documentation to be carried on board ships
Annex 3 List of Resolutions adopted by the SOLAS Conferences

9.2 An Introduction to Marpol 73/78


9.2.1 General
What Is Marpol 73/78?
MARPOL 73/78 is an International Convention comprising a set of regulations aimed at
preventing pollution of the sea from ships. At present there are six different “sets” of
regulations known as the Annexes of MARPOL 73/78, each dealing with a different aspect of
marine pollution.

Where Do The Regulations Come From?


These regulations, like the SOLAS, Load Line, Tonnage conventions etc. are formulated and
agreed to by the International Maritime Organisation (IMO).

How Is Lloyd’s Register Involved?


Lloyd’s Register is authorised by over 140 national authorities to survey ships and issue
certification for compliance with the regulations of the various conventions on behalf of the
governments.

Which Ships Are Required To Comply With The Convention?


The MARPOL convention defines a ship as “a vessel of any type whatsoever operating in the
marine environment.” The only exceptions to this are warships, naval auxiliary ships or other
government controlled ships on non commercial service. This means that all vessels
regardless of type or size must comply with the requirements of the regulations in the various
annexes. The convention therefore applies to tankers, container ships; general cargo ships
gas carriers, oil platforms, barges, pleasure craft (yachts, speed boats etc), oil rigs, etc. As
the definition of a ship states the convention applies to any vessel, this is also regardless its
size or whether or not the particular annex requires the vessel to undergo surveys and be
issued with a certificate.

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Types of Pollution from Ships


Oil, noxious liquid substances (chemicals), packaged cargo, sewage, garbage and air. Other
sources of pollution currently under consideration are antifouling paints, unwanted aquatic
organisms in ballast water and pollution caused by the scrapping of ships.

9.2.2 History
There has been concern about the pollution of the oceans by oil since the early part of the
20th century, when oil was first carried in bulk on the forerunners of today’s tankers, and
when oil powered engines became common.
In the early 1920’s both the US and UK Governments passed laws to ban illegal discharges
of oil, however, neither were very effective.
In 1926, the USA convened an International Conference on Oil Pollution Control, attended by
Japan the US and 11 European countries. Although a draft convention was prepared,
nothing came of it. In the 1930’s the UK Government, under strong pressure from
environmental groups, raised the question of oil pollution at the League of Nations (the
predecessor to the United Nations). In 1935 a draft convention was prepared, however, the
proposals were resisted by a number of countries, and with the approach of war in Europe no
further progress was made.
In 1945 the United Nations was established, shortly after that the UN established specialised
agencies with specific responsibilities, one of which, created in 1948, was the Inter-
Governmental Maritime Consultative Organisation, now known as the International Maritime
Organisation or IMO. At this stage, there was no mention of oil pollution; however, there was
concern about it. Because of resistance by some countries to the idea of an international
body regulating shipping, progress in getting any international agreement to a convention
was slow. The IMO met for the first time in 1959, eleven years after its creation
In 1954, the UK Government convened an International Conference on Oil Pollution, at which
the text of the International Convention for the Prevention of Pollution of the Sea by Oil was
agreed.
The IMO took over responsibility for the 1954 convention. A conference was called in 1962
to consider amendments to the 1954 convention, and this came into force in 1967. This
convention, as with the 1954 convention, dealt only with zones where the discharge of oil
was prohibited, and had little impact.
The next major development was the “load on top” system for tankers, where oily water
generated through cargo tank washing and ballasting was retained onboard to form part of
the subsequent cargo.
In 1969, the IMO adopted the “load on top” system as part of the 1954 convention. During
the early 1970’s there were further conferences and developments. The one that is of
particular interest is the 1973 conference that considered the proposed “International
Convention for the Prevention of Pollution from Ship, 1973” or MARPOL Convention.
This convention was slow to be ratified by Governments. A series of tanker accidents in the
late 1960’s and in 1976 and 1977, including the “Torrey Canyon” incident in 1967, when
100,000 tons of crude oil was spilt off the SW Coast of England, led to a further conference
in 1978. This conference produced the 1978 Protocol to the 1973 Convention, which took
care of some technical difficulties in adopting the 1973 Convention. The 1973 Convention as
amended by the 1978 Protocol is known as “MARPOL 73/78”.
The Convention finally came into force on 2 October 1983, which meant Annex I was now
internationally accepted and ships were required to comply.

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Since 1978 there have been regular amendments to MARPOL 73/78 convention, which
includes the development of the other Annexes. Some of the most recent developments of
MARPOL 73/78 are a result of the “Exxon Valdez” incident in 1989 that lead to the
introduction of “Double Hull” requirements and the provision of Shipboard Oil Pollution
Emergency Plans.
The criterion for adoption of an Annex is normally that at least 15 countries must have
accepted it representing at least 50% of the world's fleet.

9.2.3 The Marpol Annexes


Annex I: Regulations for the Prevention of Pollution by Oil from Ships
This Annex, which entered into force on 2nd October 1983, requires that ships are designed,
constructed, equipped and operated to ensure that the allowable limits for the amount of oil a
ship may discharge to sea are complied with. Surveys and certification are required.
Annex II: Regulations for the Prevention of Pollution by Noxious Liquid Substances in
Bulk.
This Annex entered into force on 6th April 1987, and deals with chemical pollution.
Annex III: Regulations for the Prevention of Pollution by Harmful Substances Carried
by Sea in Packaged Form, or in Freight Containers, Portable Tanks or Road and Rail
Tank Wagons.
Came into in force on 1 July 1992, and is of an operational nature, no certification is required.
The regulations cover requirements for packing, marking, documentation, stowage and
quantity limitations of substances identified as “Marine Pollutants.” It is linked to the
International Maritime Dangerous Goods Code (IMDG Code).
Annex IV: Regulations for the Prevention of Pollution by Sewage from Ships.
This Annex will enter into force on 27 September 2003, sufficient signatories now having
ratified the Annex. This Annex covers the disposal of sewage, where it can be discharged,
methods for its treatment and storage, carrying out surveys and issuing certificates.
Statements of Compliance with this Annex can be issued pending entry into force, after
which Sewage Pollution Prevention Certificates will be issued.
The United States have requirements for the prevention of pollution by sewage that is in
force now. They require that sewage treatment plants or containment systems are fitted to
ships. Lloyd’s Register can issue a Statement of Compliance with the United States
requirements when specifically requested to do so by an Owner/Builder.

Annex V: Regulations for the Prevention of Pollution by Garbage from Ships.


This Annex came into force on 30th December 1988 and is applicable to all ships. It is of an
operational nature, and therefore the responsibility of the ship owner, master and crew to
ensure it is complied with. This Annex regulates how ship’s garbage is to be dealt with, what
can and cannot be dumped at sea, where it can be dumped, and how it is to be dumped.
Annex VI: Regulations for the Prevention of Pollution of Air from Ships.
This Annex was adopted by the IMO on 26th September 1997. It regulates NOx emissions
from main and auxiliary diesel engines, SOx content of marine fuel oil bunkers, bunker
quality, cargo vapours from tankers, shipboard incinerators and the use of ozone depleting
substances. Extensive guidance notes are under development which will be made available
in the near future.

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9.2.4 Annex I - The Prevention Of Pollution By Oil


Annex I consists, at present, of 26 Regulations which can be broken down into five main
areas:-
1. Applicability which ships applies to and how and when the regulations are to be applied.
2. Surveys and Certification - which ships are required to be surveyed and issued with
certification, how the surveys are to be conducted and certificates issued.
3. Equipment - what equipment has to be fitted.
4. Construction - how the vessel is to be built.
5. Operations - how the vessel and the equipment fitted is to be operated to prevent
pollution.

The extent of compliance with the regulations is determined by applying the following factors:

1. Type of vessel - tanker or ship other than a tanker;


2. Size of vessel - gross tonnage, deadweight and length;
3. Age of vessel - new ship or existing ship, new tanker or existing tanker, pre or post
double hull requirement dates.

At this stage it is worth distinguishing between a new and existing ship, and a new and
existing oil tanker.
A new ship is one for which the building contract was placed on or after 31st December
1975, or in the absence of a building contract the keel of which was laid on or after 30th June
1976, or which was delivered on or after 31st December 1979, or which has undergone a
major conversion after these dates. These dates are applicable to all ships, including oil
tankers.
A new oil tanker is one for which the building contract was placed on or after 1st June 1979,
or in the absence of a building contract the keel of which was laid on or after 1st January
1980, or which was delivered on or after 1st June 1982, or which has undergone a major
conversion after these dates. These dates are applicable to oil tankers alone. It is therefore
possible for an oil tanker to be a 'new ship' but an 'existing oil tanker'.
These dates are very important in the application of the MARPOL Annex I regulations.

To Which Vessels Do These Regulations Apply?


The Regulations apply to ALL ships including oil platforms, barges, private yachts and so on.
The MARPOL Convention defines a “ship” as a vessel of any type whatsoever operating in
the marine environment.
The regulations do not apply to warships, naval auxiliary vessels or other government owned
or operated vessels in non-commercial service.
Some exemptions may be given from certain Regulations for vessels such as hydrofoils and
hovercraft that are not able to comply due to the nature of their construction.

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All vessels of 400 gross tons and above, and all oil tankers of 150 gross tons and above, are
required to be surveyed and to be issued with Certificates as evidence of their compliance
with the regulations. Smaller ships are required to comply with the regulations but are not
required to be surveyed or to be issued with certificates. However if requested by the
Owners or if required by the flag authority a Statement of Compliance can be issued

How Are These Regulations Applied?


The Regulations are applied by individual governments surveying ships to ensure that they
are equipped and constructed in accordance with the regulations, and the appropriate
certificate issued. Lloyd’s Register is authorised by over 130 governments to act on their
behalf. In effect, Lloyd’s Register undertakes the work of the Government in applying these
Regulations.
After an Initial Survey, and provided the Regulations are complied with, a certificate is issued
valid for five years. During this five year period the vessel must undergo annual,
intermediate and periodical surveys. These are normally on an annual basis, i.e. the vessel
will have four surveys during the five year period. At the second or third annual survey an
intermediate survey is held, this survey being more onerous than an annual survey. On or
before the fifth anniversary of the initial survey, i.e. the expiry date of the certificate, a
renewal survey is held. The renewal survey is a very thorough examination of the pollution
prevention equipment. The five-year cycle starts again.
A certificate must be accompanied by a “Record of Construction and Equipment” which
details the construction of the vessel, the Regulations applicable to it, and the equipment
fitted.

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What Are The Sources Of Oil Pollution From Ships?


There are two main sources of oil pollution from ships, one is from waste oil created in the
machinery space (purification of fuel and lubricating oil, oil leakages from machinery and
water ballast in fuel oil tanks), and the other is from the cargo space of ships carrying oil in
bulk (water ballast in cargo tanks and cargo tank washings).
For operational reasons ships do make some discharges to sea, before the introduction of
the MARPOL Convention there was no control of these discharges.
Regulation 9 states exactly where and how oily water mixtures can be discharged to sea.
The remaining regulations deal with how such discharges are prevented, or kept within the
limits prescribed in Regulation 9, which may be by or a combination of operational measures,
equipment, or the design and construction of the vessel.
The discharge requirements stipulate that:
(a) for cargo area discharges from an oil tanker:
i. the tanker is not within a Special Area;

ii. the tanker is more than 50 nautical miles from the nearest land;

iii. the tanker is proceeding en route;

iv. the instantaneous rate of discharge of oil content does not exceed 30 litres per
nautical mile;

v. the total quantity of oil discharged into the sea does not exceed for existing tankers
1/15,000 of the total quantity of the particular cargo of which the residue formed part,
and for new tankers 1/30,000 of the total quantity of the particular cargo of which the
residue formed a part; and

vi. the tanker has in operation an oil discharge monitoring and control system and a slop
tank arrangement as required by Regulation 15 of MARPOL Annex I.

(b) For machinery space discharges from any ship of 400 tons gross tonnage and above
other than an oil tanker and from machinery space bilges excluding cargo pump room
bilges of an oil tanker unless mixed with oil cargo residue:

i. the ship is not within a Special Area;

ii. the ship is proceeding en route;

iii. the oil content of the effluent without dilution does not exceed 15 parts per million;
and

iv. the ship has in operation equipment as required by Regulation 16 of MARPOL Annex
I (oily water separator and bilge monitor).

The Regulations can now be conveniently split into two parts. Those Regulations which
apply to all vessels and those applying only to tankers

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Regulations Applying To All Ships


Regulations 1 to 8 contain definitions, the requirements for surveys and issue of certificates.
Regulation 9 deals with when and where oily water may be discharged and the allowable
limits. Regulation 10 defines “special areas” and the control of discharges in those areas.
The remaining regulations in this group deal with the construction of the ship and its
equipment rather than operational matters, and are therefore particularly relevant to the work
carried out by LR.

Regulation 14 - Segregation of oil and water ballast and carriage of oil in forepeak
tanks
This Regulation applies to new ships other than oil tankers of 400 grt and above and new oil
tankers of 150 grt and above.
No ballast is to be carried in oil fuel tanks, except in abnormal conditions (abnormal
conditions means severe weather conditions or certain vessels which need to carry large
quantities of fuel oil).
When ballast is carried in fuel oil tanks it should be discharged to shore reception facilities or
to the sea in compliance with regulation 9 using oil filtering equipment, and an entry made in
the Oil Record Book.
No oil shall be carried in the forepeak or any tank forward of the collision bulkhead. This
applied to all ships of 400 grt and above whose contracts are placed after 1st January 1982
or whose keels are laid after 1st July 1982. (Refer also to SOLAS Chapter II/2 regulation
15(5) and LR Rules Pt. 3 Ch.3 Sec.4).
All vessels not included in the above should comply with these requirements as far as is
reasonable and practicable.

Regulation 16 - Oil discharge monitoring and control system and oil filtering
equipment
This Regulation describes the equipment necessary to achieve the discharge limits of
15ppm, and the monitoring requirements enabling the ships staff to measure the oil content
of oil/water mixture being discharged.
There are three basic pieces of equipment involved:
1. Oil Water Separator - used to describe 100ppm equipment (not permitted after 1st
July 1998).
2. Oil Filtering Equipment - used to describe 15ppm equipment.
3. Monitoring Equipment - more commonly referred to as a bilge monitor or 15ppm alarm.
Used to describe equipment that can monitor the discharge, record the ppm of discharge
outflow and, where the regulations require, automatically stop the discharge when the
limit of 15ppm is reached or in the event of monitor failure.
Vessels of between 400 grt and 10,000 grt must be provided with 15ppm equipment to
process machinery space discharges. i.e. an oily water filter.
Vessels of 10,000 grt and over must be provided with a 15ppm oil filter with an alarm which
operates at 15ppm and an automatic stopping device. Any vessel that carries ballast in fuel
oil tanks must also be fitted with this equipment.

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Vessels which require discharging within a Special Area should also be fitted with an
automatic stopping device, 15ppm filtering equipment and a 15ppm alarm to comply with
regulation 10, Special Areas.
All the equipment provided in compliance with Regulation 16 must be of an approved type.
Type approval certificates are issued by or on behalf of National Administrations. The type
approval standard is Resolution MEPC.60 (33) for all equipment fitted after 30 April 1994 and
Resolution A.393(X) for equipment fitted prior to that date. Different standards have been
developed over the years; the date on which the equipment was fitted will decide which
standard was applicable at that time. If replacement equipment is fitted then compliance with
the latest standard is necessary.
Some ships were fitted with separating or filtering equipment prior to Annex I coming into
force. However, the equipment did not always comply with the standards required. These
ships were allowed to use "add on" units (known as process units) to bring the equipment up
to the required standard. This also applied to equipment meeting the other older standards
mentioned above. The IMO books “Oily Water Separators and Monitoring Equipment” and
“Pollution Equipment under MARPOL 73/78” contains the relevant IMO resolutions.
A waiver is available from the requirements of Regulation 16 for vessels engaged solely in
voyages within Special Areas. In such cases all oily mixtures must be discharged to
reception facilities.

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Regulation 17 - Tanks for Oil Residues (Sludge)


This regulation requires that sludge tanks are provided on all ships of 400 gross tons and
above, for waste oil, sludge, etc., which cannot be pumped overboard in accordance with
Regulation 9.
The capacity of the tanks required can be calculated using a formula based upon daily fuel
consumption, maximum length of voyage and type of fuel oil used (diesel or heavy).
These tanks should be designed and constructed so as to facilitate their cleaning and the
discharge of residues to reception facilities, they should be fitted with heating coils if used to
store heavy oil, must be provided with a designated pump for discharge ashore and have no
connection to any bilge system or overboard, other than to the Standard Discharge
Connection.
Ships may also use homogenisers, incinerators or burn the sludge in the ships boilers, a
reduction in the sludge tank size being allowed for vessels so equipped.
Refer all also to MEPC/circ.235 “Guidelines for Handling Oily Wastes in Machinery Spaces of
Ships”.

Standard
Discharge
Connection

15ppm
15pmm
alarm 3 Way
Pump filter
Valve

Overboard

Sludge Tank Bilge


Holding
Tank

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Regulation 19 - Standard Discharge Connection


This regulation requires that all vessels must be provided with a standard discharge
connection for discharging waste oils to shore reception facilities. The dimensions of the
Standard Discharge Connection are shown on the diagram.

STANDARD DISCHARGE CONNECTION

215mm
22mm

Regulation 20 - Oil Record Book


Every oil tanker of 150 gross tons and above and every ship of 400 gross tons and above
other than an oil tanker, are required to be provided with an Oil Record Book Part I
(Machinery Space Operations). This book is to be completed whenever bunkers or lub oil is
loaded, discharged or if the tanks are ballasted or cleaned, whenever dirty water involved in
this operation is discharged either to sea or to shore, whenever sludge is disposed of and
whenever bilges are discharged overboard or ashore.
Every oil tanker of 150 gross tons and above is required, in addition to Part I, ,to be provided
with an Oil Record Book Part II (Cargo/Ballast Operations). This book is a record of all cargo
operations including the loading and discharging of cargo, cleaning of cargo tanks, loading
and discharging of ballast and the disposal of tank washings either to sea or ashore, etc.

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Regulation 26 - Shipboard Oil Pollution Emergency Plan


Every oil tanker of 150 gross tons and above, and every ship other than an oil tanker of 400
gross tons and above, must have on board a “Shipboard Oil Pollution Emergency Plan”
(SOPEP).
The plan contains instructions to the master of the vessel detailing the reporting procedure to
be used in the event of an oil spill, and checklists or instruction to ensure that appropriate
action is taken to minimise or stop the outflow of oil.
This plan is of an operational nature but it is required to be approved by or on behalf of the
vessels Flag Administration.
Vessels carrying Noxious Liquid Substances are required to be provided with a further plan
known as a “Shipboard Marine Pollution Emergency Plan for Noxious Liquid Substances”
(SMPEP-NLS) or, as an alternative, a combined plan known as a “Shipboard Marine
Pollution Emergency Plan” (SMPEP).
The IMO has produced guidelines for the development of SOPEPS and SMPEPS which
should be read in conjunction with the “General principles for ship reporting systems and ship
reporting requirements, including guidelines for reporting incidents involving dangerous
goods, harmful substances and/or marine pollutants”.

TANKERS
Before considering the Regulations which apply to tankers, it is useful to understand how a
tanker operates.

1. A fully laden tanker arrives at a discharge port.


2. The cargo is pumped ashore.
3. Ballast is taken on board
4. The tanker sails back to a loading port.
5. It discharges the ballast.
6. A cargo is loaded.
7. It sails to a discharge port

Considering item 3 - where does the tanker put the ballast? The cargo tanks were
traditionally used as ballast tanks thus creating an oil/water mixture. The ballast containing
the oil/water mixture cannot be discharged at the loading port. To overcome this problem the
tanker washes a set of tanks and fills these with clean ballast which can be discharged at the
loading port. The “dirty” ballast is discharged to sea along with the residues from tank
cleaning - or that was how it was done historically, and still is on single hull tankers!
On tankers with Segregated Ballast Tanks (SBT) or double hulls sufficient ballast is taken
into the segregated ballast tanks for most ballast voyages. Only on rare occasions in the
event of extreme weather conditions or emergency situations would ballast be taken into
cargo tanks.
Concern about oil pollution led to the development of what is known as the “load-on-top”
system. This was developed by the tanker operators, not the IMO.

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Instead of discharging the residues from the tank washings to sea, they are retained on
board in a slop tank. The oil/water mixture is allowed to settle, and then the water is pumped
off the bottom. This leaves the oil plus a small amount of water in the slop tank. The tanker
when proceeds to the loading port as before. Cargo is loaded into all tanks including on top
of the slops. The cycle is then repeated.
It should be noted that the load-on-top procedure only works with crude oil cargoes. For
product refined oil cargoes e.g. petrol, jet fuel or diesel oil, the slops are either retained on
board or discharged ashore.

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Regulations Applicable To Tankers


In addition to the foregoing, the following regulations are applicable additionally to oil tankers.

Regulation 13 - Segregated Ballast Tanks, Dedicated Clean Ballast and Crude Oil
Washing.
This Regulation requires that every new Crude Oil Tanker of 20,000 DWT and above and
every new Product Tanker of 30,000 DWT and above must be provided with Segregated
Ballast Tanks (SBT).
The capacity of SBT tanks must be such that the vessels draft is a minimum of 2.0 + 0.02L
and a trim not exceeding 0.015L, where L = vessels length, and such that the propeller is
fully immersed. There must be sufficient segregated ballast capacity so that the vessel can
operate safely without using cargo tanks for ballast, except in exceptional circumstances e.g.
heavy weather.
Every new Crude Oil Tanker of 20000 DWT and above is required to be provided with a
Crude Oil Washing (COW) System.
Every Existing Crude Oil Tanker of 40000 DWT and above must be provided with a
Segregated Ballast Tank System, meeting the requirements referred to earlier, or, in lieu of a
segregated ballast system, a Crude Oil Washing System.
Every Existing Product Tanker of 40000 DWT and above must be provided with either a
Segregated Ballast Tank System or a Dedicated Clean Ballast Tank (DCBT) System.
These are the basic requirements as required by Regulation 13. There are three aspects of
Regulation 13 that require more explanation; they are Protective Location, Crude Oil
Washing and Dedicated Clean Ballast.

Segregated Ballast
A Segregated Ballast System is a system that is physically separated from the tankers cargo
oil and fuel oil systems, and is used only for the carriage of ballast. Completely separate
means that the SBT pipework must be physically separated from the oil system. Provision
may be made for the emergency discharge of ballast using a cargo pump, by means of a
connection through a portable spool piece and a non-return valve to prevent oil from passing
back to the ballast tanks. The spool piece must be removed when not in use and a
permanent notice displayed adjacent to it, restricting its use.

Regulation 13A - Requirements for Dedicated Clean Ballast Tanks


Regulation 13 requires that existing products tankers of 40,000 DWT and above, not fitted
with SBT, are provided with a Dedicated Clean Ballast Tank (DCBT) System.
A DCBT system could be described as a “temporary semi-segregated ballast system”, the
disadvantage of the system being that cargo carrying capacity is lost.
The system is achieved by using one (or more) of the vessels normal cargo pumps, part of
the in-tank piping system and a suitable number of tanks to enable the draft and trim
requirements of regulation 13 as for SBT to be met. The pumps, lines and tanks used are
“isolated” from the rest of the cargo system by existing valves plus, in some cases, additional
valves and /or blanks. Sections of line may need to be removed or added.

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The arrangements and operational procedures for Dedicated Clean Ballast Tanks should
contain at least all the provisions of the Specifications for Oil Tankers with Dedicated Clean
Ballast Tanks, IMO Resolution A.495 (XII), the basic requirements of which are as follows:

• The discharge must be monitored by an Oil Discharge Monitoring and Control


System. Maximum oil content 15ppm.

• The DCBT must be isolated from the cargo system by at least two valves.

• The lines and pumps used should be arranged such that they can be effectively
flushed prior to loading/discharging the ballast without permitting any oily water to
enter the Dedicated Clean Ballast Tank.

• Any part of the DCBT piping system, whilst in use, must be isolated from the cargo
system by at least two valves, or equivalent. This isolation should also include inert
gas, tank venting and tank washing systems.

• The DCBT piping must be connected to the least practicable number of cargo
pumps.

• The vessel to be provided with an approved Dedicated Clean Ballast Tank


Operations Manual, which contains full details of how the system operates, valves to
be opened/shut, pumps used, line flushing procedures, discharge and loading
procedures for ballasting.

Regulation 13B - Crude Oil Washing


Crude Oil Washing (COW) is a system where the cargo tanks are washed during discharge
with the crude oil cargo. Washing the tanks with the cargo has the effect of removing from
the tanks internal structure deposits which would otherwise remain on board. This means
that less oil is left on board, therefore less oil in dirty ballast and less oil that could be
discharged to sea.
The system works because crude oil has a solvent effect on the tar/waxy deposits which
settle out during the loaded voyage. There is an additional benefit in that cargo out-turns are
higher when COW is used, although there is a disadvantage in that cargo discharge times
can be increased.
The installation and associated equipment complies with the requirements of the IMO
Revised Specification for the Design, Operation and Control of Crude Oil Washing Systems.
(A.446 (XI)), which includes:

1. That the System, pipework, valves etc. are:

• Steel of other suitable material, properly joined and supported.

• Permanent and independent of any other system.

• Fitted with an over pressure device.

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• Fitted with pressure gauges.

• Tested to 1½ times the working pressure.

• Piping to be anchored to the ships structure, provided with means to allow for
expansion, the anchoring to be such that hydraulic shock can be absorbed.

2. No part of the system is to enter the Engine Room and any tank cleaning heater is to be
fitted with double shut-off valves or clearly identifiable blanks to enable its effective
isolation.

3. The tank washing machines:

• Are to be approved by the Administration.

• Each machine to be isolated by a stop valve.

• The number and location of the machines to be such that no more than 10% of the
horizontal surface and no more than 15% of vertical areas are in “shadow”. (this is
assessed by “Shadow Area Diagrams”, which must be approved).

4. Crude Oil Washing Surveys. The effectiveness of the system is to be confirmed by an


effectiveness survey.

The basic requirements for the control of the system are:

• The pump supplying the Crude Oil Washing System (usually a cargo pump) to be of
sufficient capacity to operate the maximum permitted number of machines at the
required back pressure.

• The stripping system is to be capable of keeping the tank bottom dry when washing
the bottom of the tanks, and removing the oil at a rate of 1.25 times the maximum
discharge rate of the maximum number of machines operated simultaneously.

• Level gauges, hand dipping points, suction/discharge pressure gauge on


pumps/eductors to be provided to monitor the system.

• Means to be provided to drain the entire cargo system and washing system, to a
cargo tank and ashore. For discharge ashore a small diameter line to be provided
leading to the outboard side of the manifold valves.

• The crew operating the system to be properly trained.

• An inert gas system must be fitted to vessels operating a Crude Oil Washing System.
This requirement is over and above any requirement under SOLAS to fit an inert gas
system.

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• Sufficient tanks are to be Crude Oil Washed prior to each ballast voyage, in order
that ballast water is not put into tanks that have not been crude oil washed (this
means that heavy weather tanks must be washed at every discharge).

• An Approved Crude Oil Washing Operations and Equipment Manual which contains
instructions on how the system is to be operated to achieve the requirements for tank
cleanliness and safety.

Regulation 13C - Existing tankers engaged in specific trades.


Refer to regulation for requirements. No LR Class tankers are operating to this regulation
none are likely to.

Regulation 13D - Existing oil tankers having special ballast arrangements


Refer to regulation for requirements. No LR Class tankers operating to this regulation none
are likely to.

Regulation 13E - Protective Location of Segregated Ballast Spaces


This regulation has been superseded by the requirements of regulation 13F for newer
tankers falling under the requirements of that regulation.
Every new Crude Oil Tanker of 20000 DWT and above, and every new product tanker of
30000 DWT and above must be fitted with SBT, this SBT must be “Protectively Located”.
This means that the Segregated Ballast Tanks required to be provided by Regulation 13 and
which are located within the cargo tank length, should be arranged to provide a measure of
protection against oil outflow in the event of grounding of collision.

Regulation 13F - Prevention of oil pollution in the event of collision or stranding


This regulation applies to all oil tankers of 600 DWT and above for which the building
contract is placed on or after 6 July 1993 or, in the absence of a building contract, whose
keels are laid on or after 6 January 1994 or which are delivered on or after 6 July 1996, or
which have undergone a major conversion after these dates.
All oil tankers of 5000 DWT and above are required to be constructed with ballast or other
spaces along the entire cargo tank length which extend the full depth and breath of the
vessel, i.e. a double hull.
The wing tanks are to be a minimum width “w”.

For vessels of 5000 DWT and above:


w = 0.5 + DW (m) or 2.0m which ever is the lesser, the minimum
20000 value of w is 1.0m

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For vessels under 5000 DWT, cargo tanks should be arranged such that the maximum
capacity of any tanks does not exceed 700m³ unless it has wing tanks complying with the
following:
w = 0.4 + 2.4 DW (m) where the minimum value of w is 0.76m
20000

The double bottom tanks or spaces are to have a minimum vertical depth of “h”.
For vessels of 5000 DWT and above, in lieu of Regulation 13E, h = B/15(m) or 2.0m
whichever is the lesser, the minimum value of h being 1.0m
For vessels under 5000 DWT, h = B/15(m) and the minimum value of h is 0.76m

Where B = Maximum breadth in metres.

Suction wells in cargo tanks may protrude into the double bottom below the boundary line
defined by the distance h provided that such wells are as small as practicable and the
distance between the well bottom and bottom shell plating is not less than 0.5h.
On crude oil tankers of 20,000 DWT and above, and product tankers of 30,000 DWT and
above, the aggregate capacity of the wing tanks, double bottom tanks, forepeak and after
peak tanks shall not be less than the capacity of segregated ballast required to meet the draft
and trim requirements of Regulation 13. These tanks should be located as uniformly as
practicable along the cargo tank length.
Ballast piping must not pass through cargo tanks and cargo piping must not pass through
ballast tanks.
Other methods of design and construction of oil tankers than those already described may be
accepted provided that they can provide the same level of protection against oil outflow in the
event of collisions or stranding. Such alternatives are to be approved and be in accordance
with IMO guidelines.
The damage stability requirements for oil tankers of 20000 DWT and above are also
increased under the requirements of Regulation 13F, such that bottom raking damage over a
larger area is taken into account.

Regulation 13G - Prevention of Oil Pollution in the event of Collision or Stranding


Measures for existing tankers
A revised regulation 13G entered into force on 1 September 2002. This regulation
applies to oil tankers of 5,000 tons deadweight and above, delivered prior to the
dates on which regulation 13F enters into force. It does not apply to ships already
complying with regulation 13F, or those having double bottoms complying with
regulation 13E and double sides satisfying the requirements for type 2 chemical
tankers.
Tankers are divided into three Categories depending on their size, the cargoes which
they carry (crude oil, persistent oils or product oil) and the extent to which they
comply with certain of the requirements of MARPOL Annex I (SBT, PL and COW).

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Tables are used to determine, for each category of oil tanker, the date on which
regulation 13F becomes applicable.
A category 1 oil tanker can only trade beyond 25 years from it's date of delivery if it is
provided with wing or double bottom spaces offering at least 30% side or bottom
protection, or if it operates with hydrostatically balanced loading. It may then trade
up to the date on which regulation 13F becomes applicable.
In addition a category 1 oil tanker from the anniversary of its date of delivery in 2005,
and a category 2 oil tanker from 2010, is subject to compliance with a Condition
Assessment Scheme (CAS) adopted by the IMO. The requirements for CAS are
detailed in IMO resolution MEPC.94 (46).
This regulation is difficult to follow so LR have developed some flow diagrams to
guide Owners/Managers and surveyors through it. Reference is also made to Marine
Technical Notice 2002/20.

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ABCD New IMO regulation 13G flow charts

MARPOL 73/78 ANNEX I


Regulation 13G - Revised 2001

The IMO Marine Environmental Protection Committee (MEPC) at its 46th meeting, in April
2001, adopted an amended regulation 13G.

The attached flow charts are intended to provide guidance in establishing which 'category' a
tanker falls into, the phase out date, and the requirements of the Condition Assessment
Scheme (CAS).

“NOTICE AND TERMS OF USE”

1. Lloyd’s Register of Shipping (hereinafter referred to as ‘LR’), its officers, employees or agents (on behalf of each of whom
this notice is given) shall be under no liability or responsibility in negligence or otherwise howsoever to any person in
respect of any information or advice expressly or impliedly given in this [report, advice, etc.], or in respect of any
inaccuracy herein or omission herefrom or in respect of any act or omission which has caused or contributed to this
[report, advice, etc.] being issued with the information or advice it contains (if any).

2. Without derogating from the generality of the foregoing, neither LR, nor any of its officers, employees or agents
shall be liable to any person in negligence or otherwise howsoever for any special or indirect loss or damage
(including but not limited to, loss of production, loss of product, loss of use and/or loss of revenue, profit or
anticipated profit) howsoever the same may be caused.”

Further information
Contact: Sam James
Direct Dial: +44 20 7423 2683

Fax: +44 20 7423 2060

Email: TGG-Stat@lr.org

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Classification and Statutory Surveys – Delegate Notes
New IMO regulation 13G flow charts

Was ship delivered


before 13F dates and
is ships deadweight
MARPOL definitions Regulation 13G
NO
≥ 5000? not applicable
Application dates for
13F are:
YES
building contract
placed on or after 6
July 1993, or
Was ship delivered Regulation 13G
in the absence of a before 13F dates but YES
not applicable
building contract, the still complies with 13F?
keel laying or similar
stage of construction is
on or after 6 Jan 1994,
NO
or
delivery on or after 6
July 1996 Does ship comply
with 13F(3)(a) and
(b) – full double Regulation 13G
YES not applicable
sides and double
bottom?
MARPOL definitions
NO
The requirement for
minimum distances
between the cargo tank
boundaries and the ship Does ship comply with
side and bottom plating 13F(4) – mid-deck tanker
need not be met in all or with 13F(5) – other Regulation 13G
YES
respects. In that event, approved method of design not applicable
the side protection and construction?
distances shall not be
less than those NO
specified in the IBC
Code for type 2 cargo
tank location and the
bottom protection Does ship carry
distances shall comply crude oil, fuel oil,
with regulation 13E(4) heavy diesel oil or
(b) of MARPOL Annex I lubricating oil?

YES NO

Is ships’ deadweight Is ships’ deadweight


NOTE 1
< 20,000 but < 30,000 but
Regulation 1(26) requires SBT
and PL (see reg 13), a COW
system (crude oil tankers only
[see reg 13B]) and a ‘small NO NO
diameter stripping line’ to the
manifold (see reg 18(4)).
Does ship comply YES
with requirements for
YES a new oil tanker as
defined in regulation
1(26)? NO

YES

Category 3 Category 2 Category 1 Category 3

Now refer to flow diagram appropriate to the ‘Category’ of oil tanker

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ABCD
Category 1
New IMO regulation 13G flow charts

A Category 1 oil tanker shall comply with the requirements of regulation 13F of MARPOL 73/78 Annex I
not later than the anniversary of the date of delivery of the ship in the year specified as follows:
2003 for ships delivered in 1973 or earlier
2004 for ships delivered in 1974 and 1975
2005 for ships delivered in 1976 and 1977
2006 for ships delivered in 1978, 1979 and 1980

When the tanker reaches the 25th anniversary of its date of delivery, it is to comply with either of the following
provisions to enable it to trade until the dates stipulated above: -
(a) the tanker is to be provided with wing tanks or double bottom spaces, not used for the carriage of oil and
meeting the width and height requirements of regulation 13E(4), covering at least 30% of Lt, for the full depth of
the ship on each side or at least 30% of the projected bottom shell area within the length Lt, where Lt is as
defined in regulation 13E(2); or
(b) the tanker is to operate with hydrostatically balanced loading, taking into account the guidelines developed
by the International Maritime Organization (MEPC.64(36))

When the tanker reaches the anniversary of its date of delivery in 2005, it shall comply with the Condition
Assessment Scheme (CAS) adopted by the MEPC, to enable it to trade until the dates stipulated above.
NOTE
The Administration of a State which allows, suspends, withdraws or declines the application of CAS to a
ship entitled to fly its flag shall communicate to the IMO details of the ship for circulation to other
Administrations for their information and appropriate action, if any.

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ABCD
Category 2
New IMO regulation 13G flow charts

A Category 2 oil tanker shall comply with the requirements of regulation 13F of MARPOL 73/78 Annex I not
later than the anniversary of the date of delivery of the ship in the year specified as follows:
2003 for ships delivered in 1973 or earlier
2004 for ships delivered in 1974 and 1975
2005 for ships delivered in 1976 and 1977
2006 for ships delivered in 1978 and 1979
2007 for ships delivered in 1980 and 1981
2008 for ships delivered in 1982
2009 for ships delivered in 1983
2010 for ships delivered in 1984
2011 for ships delivered in 1985

When the tanker reaches the anniversary of its date of delivery in 2010, it shall comply with the Condition Assessment Scheme
(CAS) adopted by the MEPC, to enable it to trade until the dates stipulated above.
NOTE
The Administration of a State which allows, suspends, withdraws or declines the application of CAS to a ship entitled to fly its flag
shall communicate to the IMO details of the ship for circulation to other Administrations for their information and appropriate
action, if any.

OPTION 1 OPTION 2
In the case of a Category 2 oil tanker fitted with only In the case of a Category 2 oil tanker the Administration
double bottoms or double sides not used for the may allow continued operation of such a ship beyond
carriage of oil and extending to the entire cargo tank the dates specified above, provided that such continued
length or double hull spaces which are not used for the operation shall not go beyond the anniversary of the
carriage of oil and extend to the entire cargo tank date of delivery of the ship in 2017 or the date on which
length, the Administration may allow continued the ship reaches 25 years after the date of its delivery,
operation of such a ship beyond the dates specified whichever is the earlier, and also provided that either:
above, provided that:
(i) wing tanks or double bottom spaces, not used for the
(i) the ship was in service on July 1 2001; carriage of oil and meeting the width and height
(ii) the Administration is satisfied by verification of the requirements of regulation 13E(4), cover at least 30% of
official records of the ship that it complied with the Lt, for the full depth of the ship on each side or at least
conditions specified above; 30% of the projected bottom shell area within the length
Lt, where Lt is as defined in regulation 13E(2); or
(iii) the conditions of the ship specified above remain
unchanged; and (ii) the tanker operates with hydrostatically balanced
loading, taking into account the guidelines developed by
(iv) such continued operation does not go beyond the the Organization.
date on which the ship reaches 25 years after the date
of its delivery.

NOTE
(a) The Administration of a State which allows the application of either of the options above, to a ship entitled to fly its flag shall
communicate to the IMO details of the ship for circulation to other Administrations for their information and appropriate action, if any.
(b) A Party to the present Convention shall be entitled to deny entry of an oil tanker operating in accordance with Options 1 and 2 above
into the ports or offshore terminals under its jurisdiction. In such cases, that Party shall communicate to the Organization for circulation
to the Parties to the present Convention particulars thereof for their information. The European Community Member States, together
with Cyprus and Malta, have already indicated that they will not accept such ships.
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ABCD New IMO regulation 13G flow charts

Category 3

A Category 3 oil tanker shall comply with the requirements of regulation 13F of MARPOL 73/78 Annex I
not later than the anniversary of the date of delivery of the ship in the year specified as follows:
2003 for ships delivered in 1973 or earlier
2004 for ships delivered in 1974 and 1975
2005 for ships delivered in 1976 and 1977
2006 for ships delivered in 1978 and 1979
2007 for ships delivered in 1980 and 1981
2008 for ships delivered in 1982
2009 for ships delivered in 1983
2010 for ships delivered in 1984
2011 for ships delivered in 1985

OPTION 1
OPTION 2
In the case of a Category 3 oil tanker fitted with only
double bottoms or double sides not used for the In the case of a Category 3 oil tanker the Administration
carriage of oil and extending to the entire cargo tank may allow continued operation of such a ship beyond
length or double hull spaces which are not used for the dates specified above, provided that such continued
the carriage of oil and extend to the entire cargo tank operation shall not go beyond the anniversary of the
length, the Administration may allow continued date of delivery of the ship in 2017 or the date on which
operation of such a ship beyond the dates specified the ship reaches 25 years after the date of its delivery,
above, provided that: whichever is the earlier, and also provided that either:

(i) the ship was in service on July 1 2001; (i) wing tanks or double bottom spaces, not used for the
carriage of oil and meeting the width and height
(ii) the Administration is satisfied by verification of the requirements of regulation 13E(4), cover at least 30% of
official records of the ship that it complied with the Lt, for the full depth of the ship on each side or at least
conditions specified above; 30% of the projected bottom shell area within the length
Lt, where Lt is as defined in regulation 13E(2); or
(iii) the conditions of the ship specified above remain
unchanged; and (ii) the tanker operates with hydrostatically balanced
loading, taking into account the guidelines developed by
(iv) such continued operation does not go beyond the the Organization.
date on which the ship reaches 25 years after the date
of its delivery.

NOTE
(a) The Administration of a State which allows the application of either of the options above, to a ship entitled to fly its flag shall
communicate to the IMO details of the ship for circulation to other Administrations for their information and appropriate action, if any.
(b) A Party to the present Convention shall be entitled to deny entry of an oil tanker operating in accordance with Options 1 and 2
above into the ports or offshore terminals under its jurisdiction. In such cases, that Party shall communicate to the Organization for
CATEGORY
circulation 1 OIL
to the Parties to theTANKERS - LIFE
present Convention EXTENSION
particulars thereof forBEYOND 25 YEARS
their information. The European Community Member
States, together with Cyprus and Malta, have already indicated that they will not accept such ships.

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Option (a) Designation of non-cargo carrying spaces


Selected cargo tanks can be designated as non-cargo carrying spaces, i.e. they are no
longer used for cargo nor for ballast. This is probably the simplest option in some respects.
The optimum arrangement of wing or centre tanks needs to be computed to meet the 30%
side or bottom protective location requirements. In selecting the tanks which are to be non-
cargo carrying spaces, it has to be ensured that the remaining tanks can be loaded, for both
ballast and cargo conditions, within the prescribed limits for longitudinal bending moment and
sheer forces. It will also be necessary to provide an addendum to the loading manual which
demonstrates compliance with the strength and stability requirements for the new operating
conditions.
The non-cargo carrying spaces must cover at least 30% of the side of the ship for the total
cargo tank length and be at least 2m in width or cover at least 30% of the projected bottom
area of the total cargo tank length and have a depth of at least B/15 or 2m, which ever is the
lesser.

Whilst it is not explicit in the regulation, it would be prudent to isolate the designated tanks
from the cargo pumping and piping system by blank flanges. Also, these tanks should be
isolated from the cargo venting system.
A suitable means of draining these non-cargo carrying tanks must be provided, together with
suitable sounding and venting arrangements. Other than the fitting of blanks and providing
suitable venting arrangements no other work should be required. However, the cargo
handling system may require some modifications to the in-tank pumping and piping
arrangements in order to retain operational efficiency and flexibility.
It is emphasised that designated non-cargo carrying tanks may not be used for cargo or
ballast under any circumstances in order for this to be an acceptable option.
If the designated non-cargo carrying spaces are used for water ballast then the ballast
arrangements should at least be in compliance with the requirements for Dedicated Clean
Ballast Tanks as given in IMO Resolution A.495 (XII). In this case the vessel would then
have to comply with all the provisions of Option (b).

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Option (b) Segregated Ballast Tanks (SBT) or Dedicated Clean Ballast Tanks (DCBT):
These options are similar and can be dealt with together.
The number and arrangements of tanks to be designated for SBT or DCBT are required to
be computed in the same was as for the previous option (a). However, in addition to meeting
the 30% side or bottom protective location requirements there are additional factors that
must be considered. If the non-cargo spaces are to be used for ballast then the ballast
arrangements must at least meet the requirements of IMO Resolution A.495 (XII) Revised
Specifications for Oil Tankers with Dedicated Clean Ballast Tanks in respect of pumping and
piping arrangements. It is suggested that the remaining requirements of A.495 (XII), including
the requirement to meet the draft and trim requirements of Regulation 13(2) are complied
with, although this is not mandatory.

Having decided on the optimum arrangement of tanks to meet the above requirements, the
pumping and piping arrangements need to be considered. In most cases a cargo pump or
pumps will be required to be dedicated to ballast handling purposes, thus removing them
from cargo handling duties. If the DCBT option is chosen then, in some cases, the pump(s)
can perform a dual role dependent upon whether a common or independent system is to be
used. Resolution A.495 (XII) addresses pumping and piping aspects and requires that:

(i) There must be at least two valves that isolate each DCB tank from the piping system(s)
serving that tank.

(ii) Arrangements must be such that discharges to sea from the DCBT can be monitored by
the Oil Discharge Monitoring and Control (ODM) System and that all the pumping and
piping can be flushed to the slop tank.

The system must also be such that discharges from the slop tank and any ballast water from
the cargo tanks can be monitored by the ODM system. Where cargo and ballast handling
are to take place simultaneously, there must be two valve separation between the cargo and
ballast systems. This can be achieved by the use of valves, blanks or a combination of both.
For a system to be considered SBT, there must be no physical connection between the
ballast system and the cargo system.
In many cases it is possible to achieve an SBT or DCBT system with minimal changes to the
existing pumping and piping systems. However additional cargo/ballast piping and
associated valves may be required to be installed to achieve a suitable SBT or DCBT system
which retains the required flexibility and efficiency for the intended trading pattern of the
vessel. Similar to Option (a), a new addendum to the loading manual will be required.

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Option (c) Installation of Bulkheads


Void spaces, i.e. non-cargo and non-ballast carrying spaces can be created by the
installation of additional bulkheads in sufficient wing tanks to achieve the 30% protective
location coverage criteria of regulation 13G (7). The bulkheads needed for the creation of
such void spaces would be required to be installed at least 2m inboard of the ships side
(measured inboard from the ships side at right angles to the centre line and clear of any
rounded gunwale area and bilge area). Alternatively a double bottom of at least B/15 or 2m,
whichever is lesser, can be installed in sufficient tanks to meet the 30% criteria.

For either the installation of bulkheads or fitting of double bottoms there are a number of
considerations to be taken into account including the possible necessity to relocate cargo
and ballast piping, venting systems, tank cleaning systems including crude oil washing
machines, tank access hatches and tank gauging systems.
From structural considerations, it is preferable to fit longitudinal bulkheads rather than double
bottoms. The necessary structure to support the cargo tank contents above a void double
bottom will be complex and of substantial scantlings. Additionally, such structure will
probably necessitate the complete relocation of the piping systems located in the bottom of
the tanks. Access to the double bottom spaces will also be required, but not easy to provide.
Although installing longitudinal bulkheads would be the preferable option, it remains a major
task that will require much planning. To physically install a bulkhead would require the
removal of sections of deck or the removal of sections of side plating in order for the work to
be carried out.
Void spaces, whether created by the installation of bulkheads or double bottoms, must be
provided with suitable venting, sounding, draining and access arrangements.

Option (d) Hydrostatic Balanced Loading


IMO has published guidelines for the approval of alternative structural or operational
arrangements as an alternative to the requirements of the 30% protective location
requirements of Regulation 13G (7). The guidelines are contained in Resolution MEPC.64
(36). Hydrostatic balanced loading is considered to be such an alternative arrangement.
Simply this means that cargo is loaded in all cargo tanks to an ullage that is greater than the
freeboard. The principle of hydrostatic balanced loading is that, at the cargo tank bottom, the
hydrostatic pressure of the cargo oil column plus the inert gas pressure in the ullage space
remains equal to or less than the hydrostatic pressure of the outside water column, thereby
mitigating the outflow of oil in the case of bottom damage. The actual level to which cargo
can be loaded in any one tank is governed by a formula containing a number of factors which
include the depth of the tank, cargo density and the normal inert gas over-pressure in the
tank.

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Since another factor is the corresponding draught of the vessel, it is permitted to carry ballast
in segregated ballast tanks to increase the draught to a larger value.
The guidelines require that hydrostatic balanced loading provides an equivalent level of
protection against oil pollution in the event of collision or stranding as would the same ship
having wing or double bottom spaces meeting the 30% coverage requirement. Calculations
are required to be carried out to establish the equivalence of the actual conditions for
hydrostatic balanced loading.
The calculations require an Equivalent Oil Spill (EOS) number to be calculated for three
conditions. An EOS number is the hypothetical outflow for defined damage cases as a
percentage of the cargo being carried in its original configuration for each condition under
consideration.
Three EOS numbers are required to be calculated for the fully loaded ship in the following
configurations:

(a) The existing ship arrangement,

(b) The ship with non-cargo carrying side tanks meeting 30% coverage criteria,

(c) The ship operating with hydrostatic balanced loading.

The EOS number for hydrostatic balanced loading should not exceed the EOS number for
the ship with non-cargo side tanks and, additionally, should not exceed 85% of the EOS
number for the existing ship arrangements.

CARGO CARGO CARGO

HYDROSTATIC BALANCED LOADING

The total number of cargo tanks required to be loaded in the hydrostatic balanced mode
need only be of sufficient number to ensure that the same level of protection is provided to
that required by Regulation 13G(7). Therefore it may be that not all cargo tanks will be
required to be hydrostatic loaded.

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MEPC.64 (36) requires that the Master must be provided with an approved operations
manual for the ship operating with hydrostatic balanced loading.
Hydrostatic balanced loading requires no alteration to the ship's structure or pumping and
piping system. However, there may be potential problems from the effects of sloshing.
Where oil cargo is carried in partially filled tanks, the possibility of the natural period of the
partial cargo resonating with the natural period of ship motions in a seaway and creating
sloshing forces should be investigated. Pre-MARPOL tanker designs were generally fitted
with maximum tank breadths of about 0.4B which would preclude significant sloshing forces
in the transverse mode. Although tank lengths could be up to 0.2L, the ships were usually
fitted with a wash bulkhead at mid-tank length to dampen cargo motion. However, as
designs of pre-MARPOL tankers began taking cognisance of the MARPOL legislation being
formulated at IMO, tanks became proportionally longer and narrower. This type of tank
geometry, especially when free of internal structure, is susceptible to sloshing motions.

Regulation 15 - Retention of Oil on Board


The main requirements of Regulation 15, applicable to oil tankers of 150 gross tons and
above, are:

15(2) (c) Slop Tanks.

15(3) (a) Oil Discharge Monitoring and Control System. (ODM System)

15(3) (b) Oil/Water Interface Detector

15(3) (c) Approved ODM Manual

Waivers are available from the requirements of Regulation 15 for vessels engaged solely in
short coastal voyages. In such cases all dirty ballast and slops must be discharged to
reception facilities.

Slop Tanks
• An effective tank cleaning system is to be provided, and arrangements made to
enable dirty tank washings to be transferred to a slop tank or tanks.

• The slop tank(s) should have a minimum capacity of 3% of the total cargo carrying
capacity. A reduction in this percentage is allowed if certain conditions are me

• 2% if a re-circulation system can be effectively used for tank washing

• 2% if SBT, DCBT or COW is provided, 1½% if a re-circulation system for tank


washing is also provided.

• 1% in combination carriers with smooth walled tanks, 0.8% if a re-circulation system


for washing is provided.

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• New oil tankers of 70,000 DWT and above are to be provided with at least two slop
tanks.

Oil Discharge Monitoring and Control Systems


An Oil Discharge Monitoring and Control System is a device which monitors the discharge
outflow of ballast being discharged from cargo tanks and from slop tanks. The system
monitors the outflow for oil content in litres per mile and the total quantity of oil discharged.
The system must be of an approved type, the standard for approval being IMO Resolution
A.586 (14) which also covers installation requirements for vessels built on or after 2nd
October 1986. For vessels built prior to that date the standard for approval is IMO
Resolution A.393(X) and the installation is covered by A.496 (XII) and MEPC.13 (19).
For vessels to which A.586 (14) applies there are two Categories of tanker, A or B. Category
A tankers are those of 4000 DWT and above, which must be fitted with a fully automatic
system. Category B tankers are those under 4000 DWT which may be fitted with a manual
system.
Vessels to which A.393(X) and A.496 (XII) apply are categorised as I, II III, IV (a), IV (b), V
(a) or V (b). The category is dependent upon the deadweight of the vessel, building date and
when the equipment is fitted. Each category details the complexity of the system, a category
I vessel is required to have a fully automatic system which includes automatic stopping, input
of speed and flow rate.
The system measures the oil content in the outflow in parts per million, and using inputs of
ships speed and output flow rate, calculates the litres per mile value, continuously updating
the total quantity of oil discharged.
Should the litre per mile value reach or exceed 30l/nm or the total amount of oil discharged
exceed the 1/15000 or 1/30000 limit stipulated in regulation 9, the system will alarm and the
discharge must be stopped.
The usual method of stopping the discharge is for the overboard valves to automatically
close and for the valve to the slop tank to automatically open, thus the discharge is diverted
from overboard to the slop tank.
The lower the category the less complex the system is required to be, and the fewer
automatic features are required to be employed.
An automatic system should comprise a control unit, which receives automatic inputs of
speed and flow rate, starting interlock and overboard discharge control. A starting interlock
is a device which prevents the overboard discharge valve being opened before the ODM
system is fully operational.
All systems must be capable of recording the litres per mile, ppm, total quantity of oil
discharged, time and date (GMT), ships speed, flow rate, alarms, discharge valve position
(i.e. open or closed), oil type, system failure and if the system is over riding.

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Interface Detector
Prior to discharge overboard of slops or ballast from a cargo tank the oil/water interface must
be determined, to ensure that the discharge is stopped prior to reaching the oil layer.
In its simplest from an interface detector consists of a steel tape with a brass, zinc tipped,
weight on the end, with a bonding wire between tape and weight to ensure electrical
continuity. A milliameter is fixed to the body of the tape and the tape reel is equipped with an
“earthing wire” which is attached to the ships steelwork.
When the zinc tip of the weight makes contact with the salt water beneath the oil an
electrolytic couple is produced between the zinc and steel of the cargo tank. The current
passes through the earthing wire and causes the needle of the ammeter to deflect. By
carefully adjusting the height of the weight in the tank the position of the oil/water interface
can be established. An accuracy of + 5 millimetres can be obtained. Modern interface
detectors are more complex and are often able to carry out other functions such as
temperature measurement; however the principle for interface detection is basically the
same.
By measuring the level of the top of the oil layer, the total contents of the tank can be
obtained from the vessels”ullage” tables. The amount of oil and water can then be obtained.

Regulation 18 - Pumping, Piping and Discharge Arrangements of Oil Tankers


Every oil tanker is to be provided with a discharge manifold for discharging dirty ballast
ashore (the cargo manifold satisfies this requirement in most cases).
In every oil tanker pipelines for the discharge of ballast to sea, led above the deepest ballast
waterline are required to be provided. For existing oil tankers the requirements for ballast
discharges state that these ships may discharge below water line, provided that a Part Flow
System is fitted (this is in addition to the requirement to monitor discharges with the ODM
system). A part flow system is a system which pumps a sample of the outflow to the deck
and through a sight glass in order that a visual observation of the ballast may be made.
Every new oil tanker is to be provided with a means of stopping the discharge above the
open deck. The means of stopping the discharge is to be located such that the
manifold/discharge point can be visually observed (not required if portable radio or telephone
communication is available between the two points).
Every new oil tanker provided with SBT or COW is to have a piping system such that oil
retention in the lines is minimised.
Every tanker equipped with COW and/or SBT/DCBT should have a means provided to drain
all pumps and lines on completion of discharge, by connection to a stripping device if
necessary and capable of being discharged both ashore and to a cargo or slop tank. For
discharge ashore a special small diameter line shall be provided and shall be connected
outboard of the ships manifold valves.

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Regulation 21 - Special Requirements for Drilling Rigs and other Platforms


This Regulation applies to all vessels engaged in the exploration or exploitation of seabed
mineral resources, i.e. oil/gas exploration and production.
Any vessel in this category shall comply with the requirements of Annex I applicable to non-
tankers of 400 GRT and above with the exceptions that Regulations 16 and 17 should be
complied with as far as practicable. A record of all operations should be kept in a form
approved by the Administration, discharges of oil or oily mixtures into the sea being
prohibited unless the oil content of the effluent is less than 15ppm.
There are four categories of discharges associated with offshore platforms which are:-

1. Machinery space drainage;


2. Offshore processing drainage;
3. Production water discharge; and
4. Displacement water discharge.

Only the discharge of machinery space drainage should be subject to MARPOL 73/78. The
remaining discharges from processing etc. are not covered by these regulations but may be
covered by National regulations.
It should be noted that Floating Storage Units and Floating Production Units are considered
as “other platforms”.
Compliance with regulations 13 to 13F (SBT, COW, double hull, etc.) is not required, but it is
always necessary to determine from both the Flag Administration and the government of the
sea area in which the vessel will be moored the exact application of MARPOL, as local
regulations may apply.

Requirements of Minimising Oil Pollution from Oil Tankers due to Side and Bottom
Damage
This group of Regulations, dealing with the requirements for minimising oil pollution from oil
tankers due to side and bottom damage, includes regulations 22, 23, 24, 25 and 25A.
Compliance with these regulations is verified in conjunction with structural and stability
aspects at the plan approval stage. A brief description of the regulations is as follows:

Regulation 22 - Damage Assumptions


This Regulation details the assumptions which may be made with respect to the extent of
side and bottom damage used in calculating the hypothetical outflow of oil.

Regulation 23 - Hypothetical Outflow of Oil


This Regulation states the formulae used for calculating the hypothetical outflow of oil with
respect to compartments breached by side and bottom damage to all conceivable locations
along the length of the ship, using the damage assumptions of Regulation 22.

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Regulation 24 - Limitations of Size and Arrangement of Cargo Tanks


This Regulation gives details of the size and arrangements of cargo tanks to ensure that the
hypothetical outflow of oil calculated by Regulation 23 does not exceed certain limits.

Regulation 25 - Subdivision and Stability


This Regulation gives the requirements for the stability of the vessel in the event of side or
bottom damage, such that it is capable of surviving under certain damage conditions. For
tankers over 20000 dwt required to comply with regulation 13F there are additional
requirements regarding raking damage.
Regulation 25A - Intact Stability
This regulation applies to all oil tankers of 5000 DWT and above for which the building
contract is placed on or after 1 February 1999 or, in the absence of a building contract,
whose keels are laid on or after 1 August 1999 or which are delivered on or after 1 February
2002, or which have undergone a major conversion after these dates.
More onerous intact stability criteria are required to be complied with and simple
supplementary written operational procedures for liquid transfer operations should be
provided which:

• Are approved by the Administration;


• Indicate tanks which may be slack yet still allow the stability criteria to be met;
• Are readily understandable by the crew;
• Provide for planned sequences of cargo/ballast transfer operations;
• Allow comparisons of attained and required stability;
• Require no extensive additional mathematical calculations by the crew;
• Provide for corrective actions to be taken by the crew in case of departure from
recommended values and in case of emergency situations.
• Are prominently displayed in the approved trim and stability booklet and at the
cargo/ballast transfer control station.

Ships Other Than Oil Tankers Carrying Oil In Bulk


Regulation 2(2) is worthy of note because it is quite frequently applied, particularly to
offshore supply vessels. It is acknowledged that such vessels, due to their size and design
characteristics, are not able to comply fully with the requirements of Annex I for oil tankers.
Certain of the provisions of Annex I are still applied such as the requirements to be provided
with slop tanks, an ODM System, tanker piping systems, and the maximum length of cargo
tanks detailed in regulation 24(4). If the aggregate capacity of the oil cargo is less than 1000
m3 then a waiver is available from the slop tank and ODM System requirements.

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9.2.5 Annex II - The Control Of Pollution By Noxious Liquid Substances In Bulk


MARPOL 73/78 Annex II is applicable to all vessels, irrespective of date of build or size,
carrying cargoes listed in IBC Code Chapters 17 or 18 which have been given the pollution
category of A, B, C or D. New vessels according to the Annex are those whose keels are laid
on or after 7 April 1987.

MARPOL 73/78 Annex II

• Applicable to all vessels carrying Noxious Liquid Substances in Bulk

• Covers the Pollution and operational waste disposal aspects

• Pollution Category A, B, C, D and III

MARPOL 73/78 Annex II is arranged in a similar manner to the Chemical Codes, with the
exception that there are no special requirements. Vessels must comply fully with parts of the
Annex applicable to the category of pollutant carried. When the IMO originally developed the
MARPOL Convention, one of its main aims was to deal with the pollution created as a result
of ship’s operational practices.

MARPOL 73/78 Annex II – The Main Requirements

• Underwater Discharge Outlet (A,B,C)

• Stripping Tests (B,C)

• Approved Procedures and Arrangements Manual (A,B,C,D)

• Cargo Record Book (A,B,C,D)

The fundamental principles upon which the requirements of MARPOL 73/78 Annex I were
based was that given time, oil and water would naturally separate, and that the clean water
produced could subsequently be discharged to the sea, whilst the oil or oily residues could
be retained on board for disposal to shore reception facilities.
It was noted that many chemical cargoes were miscible and hence the principle of natural
separation could not be applied. The cargo residue disposal requirements of MARPOL 73/78
Annex II were therefore based on a different philosophy.
Due to the relatively high value of chemical cargoes, sophisticated chemical tankers have
traditionally been designed to ensure that virtually no cargo residue remains on board
following discharge. The IMO decided that the Regulations should be developed to take
advantage of this design feature, and the requirements were therefore based on the virtual
complete discharge of the cargo.

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MARPOL 73/78 Annex II – Basic Requirements

NEW SHIPS EXISTING SHIPS


Pollution category A B C D D1 A B C D D1
P&A Manual X X X X X X X X X X
Cargo Record Book X X X X X X X X X X
NLS Certificate - - - - X - - - - X
Certificate of Fitness X X X X - X X X X -
Underwater X X X - - X X X - -
Discharge
Damage Stability X X X X - X X X X -
compliance
Stripping residue - 100 300 - - - 300 900 - -
quantity (litres)

Note: Pollution Category D = safety and pollution hazard (IBC Code Chapter 17)
Pollution Category D1 = pollution hazard only (IBC Code Chapter 18)

Pollution Categories
Chemical cargoes considered to pose an environmental threat have been divided into four
MARPOL 73/78 Annex II pollution categories based on their potential impact. Category A
cargoes are considered to be the most severe, with Categories B, C and D posing
progressively lesser threats. It is the aim of Annex II to discharge all cargo, such that the
residue left onboard presents a negligible risk to the marine environment. This requirement is
coupled to the pollution category of the cargo with the net result that the higher the pollution
category, the lower the permitted cargo residue.

Category A Substances
When a vessel has finished the discharge of its cargo and has lost suction on the cargo
pump, there will be a residue of cargo left in the cargo tank and associated pumping and
piping system. This small residue is considered to present a severe hazard to the marine
environment. The vessel is therefore required to add water to the cargo tank by means of a
tank washing machine. The water is used to wash the tank boundaries and to provide
sufficient liquid to enable the cargo pump to gain suction. The water is continuously added
and discharged to shore until such time as the concentration of cargo in the discharged water
meets a prescribed level. This is known as a “prewash”. The concentration is measured by
use of probes in the discharge line ashore, or by chemical analysis.
For many cargoes, probes are not available. As an alternative to the measurement of
concentration it has been agreed that the same acceptable concentrations can be achieved
by washing the tank with a calculated minimum quantity of wash water whilst continuously
pumping the residues to shore.
Once it is agreed that the tank is clean, the vessel may proceed to sea. If the Master wishes
to add further water to the tank for ballasting, washing to commercial requirements, etc., this

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will require that the water/cargo residue mixture generated must be discharged under the
following conditions:
• The ship is in water of 25m depth or more;
• The ship is en route at 7 knots or more;
• The ship is at least 12 miles from land;
• The mixture is discharged below the waterline using the “Underwater Discharge
Outlet”.

Any further water added to the tank can be discharged to sea without restriction.

Discharge at sea criteria

• The ship is in water of 25m depth or more

• The ship is en route at 7 knots or more

• The ship is at least 12 miles from land

• The mixture is discharged below the water line using the ‘underwater discharge
outlet’, or diluted

• Any further water introduced into the tank can be discharged to the sea without
restriction

Category B and C Substances


These cargo categories are both dealt with in the same manner and have therefore been
grouped together. When in the unloading port the vessel is required to follow an approved
discharge procedure which ensures that the residue remaining onboard satisfies the
requirements outlined below.
The requirements for ships built before Annex II came into force on 7 April 1987 are less
severe than those for new vessels. For new vessels the maximum stripping quantity for each
tank is 100 litres for pollution category B cargoes, and 300 litres for pollution category C. For
existing vessels the maximum stripping quantity for each tank is 300 litres for pollution
category B cargoes, and 900 litres for pollution category C. A 50 litre tolerance is permitted
on all of the values.
Once the discharge is complete the vessel can proceed to sea. Once again if further water is
added to the tank for washing, ballasting, etc., it must be discharged under the four
conditions outlined above for category A substances.

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Category D Substances
Category D substances are the least noxious of the chemical marine pollutants and therefore
have the least severe discharge requirements.
The cargo is discharged to the maximum possible extent prior to departure from the
unloading port. If the Master wishes to add water to the tank for any reason, this is in order
provided the following conditions are met before the cargo/water mixture is discharged:

• The cargo residue has been diluted in the ratio of 10 parts water to one part cargo;
• The ship is en route at 7 knots or more;
• The ship is at least 12 miles from land.

STRIPPING QUANTITIES
To ensure that the ship’s Certificate of Fitness contains the maximum possible number of
cargoes, it is usual to design the ship to satisfy the most onerous stripping criterion, that is
the 100 litres per tank associated with carriage of Category B substances.
To achieve this negligible residue quantity, modern chemical tankers are constructed with
smooth walled tanks which cannot entrap the cargo, and with a discharge and stripping
system which is designed such that virtually no cargo is retained within the pump and
associated piping system. The deepwell or submerged cargo pump is located in a recess or
sump within the tank. The discharge piping leads to the deck and finally to the tank’s
dedicated cargo manifold. The cargo discharge system on modern chemical tankers is very
simple whilst being highly efficient.
Sophisticated chemical tankers such as those currently building, easily achieve the maximum
permitted residue quantities, with some ships achieving residues as low as 20 litres per tank.
In order to verify that the vessel can achieve the maximum allowable quantities specified for
category B and C substances it is necessary to carry out a functional test of the cargo tank
stripping system. This test is called the “Stripping Test” and is carried out on all new vessels
(1/3 of tanks to be tested), and on existing vessels whenever they modify their pumping and
piping system (any tank modified to be tested) or carry out a MARPOL 73/78 Annex II
renewal survey (two selected cargo tanks to be tested). Stripping tests are only required on
vessels carrying category B and C substances, and full details of the requirements are
contained in the Survey Procedures Manual.

Stripping Tests

• Demonstrates that the vessel can discharge to the requirements of


Annex II

• Category A - No requirements

• Category B - 100 litres

• Category C - 300 litres

• Category D - No requirements

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• Category III - No requirements

Sufficient water is introduced to the tank to be tested to enable the cargo pump to gain
suction. The ships trim and list are kept to the absolute minimum. A device, usually a
constant pressure valve, is provided to maintain a constant 1 bar back pressure throughout
the operation. The cargo tank is discharged and stripped, and lines blown as they would be
during a normal tank discharge operation. The manifold valve is then closed; all valves
opened and drain plugs removed. The stripping residue is the total volume taken from the
cargo tank suction well, the cargo pump and all pipelines including the manifold.

Stripping Test Manifold Arrangement A

Stripping Test Manifold Arrangement A

Test hose or pipe

>=10m

Manifold valve Flange

Cargo piping

Ship’s deck

Ships side

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Stripping Test Manifold Arrangement B

Stripping Test Manifold Arrangement B

Constant pressure valve set


at 1 bar minimum

Manifold valve Flange

Cargo piping

Pressure gauge
Ship’s deck

Ships side

Underwater Discharge Outlet


An underwater discharge outlet is required for the carriage of pollution category A, B and C
cargoes. This outlet is sized such that when the water residue mixture is discharged its
velocity will not be sufficient to take it through the hull boundary layer. The mixture will then
be drawn into the propeller and thoroughly mixed with the sea.

Underwater discharge outlet


From cargo system

Boundary layer

Underwater
discharge
outlet

The opening size is based on the discharge pump capacity and the distance of the outlet
from the bow.

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Underwater Discharge Outlet

• Governs the rate of discharge of residues discharged into the sea

• Diameter of outlet is determined by :


D= Qd
5L

• D=diameter, Qd= max. discharge rate


L= length from FP

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Procedures and Arrangements Manual


In order to ensure that those involved with the vessel know how it is intended to comply with
the requirements of MARPOL 73/78 Annex II, each vessel is provided with a Procedures and
Arrangements Manual.
The Manual is divided into four main chapters. The first provides an introduction to Annex II.
The second gives a description of the layout of the vessel, details of its pumping and piping
system etc.. The third indicates how the hardware listed in the previous chapter should be
used to achieve the required stripping quantities. The fourth advises how to discharge the
acceptable residues when they have been achieved.

Procedures and Arrangements Manual

• Approved by certifying Authority

• Contains full details for ship’s staff on how to comply with the operational
requirements of Annex II

• Manual can be produced by MARSPEC then approved by certifying Authority

The remainder of the Manual is made up of the vessels cargo list, flow charts, ventilation
procedures, details of the tank washing machines, compatibility charts, results of the
stripping test and plans of the vessel.

Table 1 – Lists cargoes permitted to be carried, identifies:

• Pollution category

• Tanks suitable for carriage

• Melting point

• Viscosity

• Suitability for ventilation

• Miscibility in water

The Manual contains a Table of the permitted cargoes, which reflects the cargo list attached
to the Certificate of Fitness. The information in this Table includes anything necessary to
discharge the residues properly and includes details on melting point, viscosity, suitability for
ventilation and miscibility in water.
This Manual must be approved by the Flag State and placed onboard the vessel.
When LR approves the Manual on behalf of the Administration, approval is subject to
verification of the arrangements onboard against those stated in the Manual, and satisfactory
completion of cargo tank stripping tests. When these items are completed by the attending
surveyors the Manual is endorsed accordingly on the approval page.

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Approval of Manual written for the carriage of Pollution Category ‘D’ cargoes only would not
be subject to completion of stripping tests.
The Manual is also used by Port State officials to verify that the cargo tanks are being
discharged in the correct manner to achieve the required stripping quantities. This is why the
stripping test should be carried out under the most difficult conditions likely to be experienced
in practice. A failure to comply with the procedure laid down in the Manual would lead to the
vessel being required to carry out a pre-wash in port, and for all residues to be discharged
ashore, which is a very expensive operation.

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ABCD
LR No.

APPROVED
for and on behalf of the Government of the vessel’s Registration as complying with the
Regulations stated below.

PROCEDURES AND ARRANGEMENTS MANUAL


The information contained in this Procedures and Arrangements Manual has been examined
only for compliance with the standards for procedures and arrangements, MARPOL 73/78
Annex II, for the carriage of pollution category A, B, C and D substances.

Signed Date:

for Lloyd’s Register of Shipping

Approval is subject to satisfactory completion of stripping tests being carried out


in the presence of a surveyor to Lloyd’s Register. The stripping test results must
be attached to this Manual.

Signed Date:

for Lloyd’s Register of Shipping

Approval is subject to verification that the arrangements onboard are identical to


those described in this Manual.

Signed Date:

for Lloyd’s Register of Shipping

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LR No.
APPROVAL HISTORY
Original approval:

NAME PORT OF REGISTRY OFFICIAL NO. SURVEYOR/DATE


AND FLAG OR CALL SIGN

Changes:

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Special Areas
For certain sea areas, identified as "Special Areas", more stringent discharge criteria are
given. Under Annex II the Special Areas are the Baltic Sea Area, the Black Sea Area and
the Antarctic Area.
MARPOL 73/78 Annex II defines these areas as follows;

• The Baltic Sea Area means the Baltic Sea proper with the Gulf of Bothnia, the Gulf of
Finland and the entrance to the Baltic Sea bounded by the parallel of the Skaw in the
Skagerrak at 57° 44.8’N.
• The Black Sea Area means the Black Sea proper with the boundary between the
Mediterranean and the Black Sea constituted by the parallel 41° N.
• The Antarctic Area means the sea area south of latitude 60° S.

Cargo Record Book


The Cargo Record Book is a record of any operations onboard the vessel which involve
Noxious Liquid Substances, and it follows a similar format to the Oil Record Book. It must be
made available for inspection by port officials, and is admissible as evidence in court.
The ship’s staff are required to record all loading, unloading, stripping and prewash
operations, any discharges into the sea of Noxious Liquid Substances and disposal of tank
washings.

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9.2.6 Annex V – The Prevention of Pollution by Garbage from Ships

This Annex addresses regulations relating to the control of garbage pollution.


The most important issue in this Annex is that disposal at sea of all PLASTICS is prohibited.
Disposal of other materials at sea is controlled under the requirements of Annex V. These
controls are summarised below.

Garbage type Outside Special Areas Within Special Areas


Plastics, synthetic ropes, Disposal not permitted under Disposal not permitted under
fishing nets, and plastic any circumstances any circumstances
bags
Floating dunnage, lining Disposal permitted more than 25 Disposal not permitted under
and packing materials miles offshore any circumstances
Paper, rags, glass metal, Disposal permitted more than 12 Disposal not permitted under
bottles, crockery and miles offshore any circumstances
similar refuse
All other garbage, paper, Disposal permitted more than 3 Disposal not permitted under
rags, glass comminuted* miles offshore any circumstances
or ground
Food waste not Disposal permitted more than 12 Disposal not permitted under
comminuted or ground miles offshore any circumstances
Food waste comminuted Disposal permitted more than 3 Disposal permitted more than 12
or ground miles offshore miles offshore**
Mixed refuse Disposal is controlled in Disposal is controlled in
accordance with the most accordance with the most
stringent requirements of the stringent requirements of the
components of the garbage. i.e. components of the garbage. i.e.
If plastic waste is mixed with If plastic waste is mixed with
other garbage, the entire other garbage, the entire
container must be treated as container must be treated as
plastic and disposed to shore plastic and disposed to shore
reception. reception.
*Garbage that is ground or comminuted must be able to pass through a screen having a
mesh size no greater than 25mm.
** Disposal of ground food waste is permitted more than 3 miles offshore in the West
Caribbean Special Area.

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9.2.7 Annex VI - The Prevention Of Air Pollution From Ships


After many years of debate and development, the IMO adopted Annex VI to the MARPOL
Convention in September 1997, which will come into force when the required number of
countries ratify the Annex (thought to be mid-2004). This new Annex is entitled “Regulations
for the Prevention of Air Pollution from Ships." At the same time the IMO adopted the
“Technical Code on Control of Emissions of Nitrogen Oxides from Marine Diesel Engines”
usually referred to as the NOx Technical Code or simply the Code, which requires all diesel
engines installed on or after 1 January 2000 to comply with the NOx limits of Annex VI,
regardless of whether the Annex is in force or not.
The regulations cover the following areas of emissions from ships:-

a) Machinery Exhaust Emissions (NOx);

b) Prohibition of emissions of Halons, CFC’s and other ozone depleting substances;

c) Fuel Oil Quality - Sulphur content (SOx) and quality in general;

d) Incinerators;

e) Cargo Vapour Emissions from oil tankers.


Ships will be required to undergo surveys and be issued with a certificate. The survey and
certification procedures will be similar to the requirements in MARPOL 73/78 Annex I and II.
The NOx emission requirements will apply to all engines, main and auxiliary (except those for
emergency use) with a power output of 130 kW or more. Engines will be required to be
tested in accordance with the NOx Technical Code and be issued with a certificate.
Incinerators will be required to be type tested in accordance with the revised IMO
Specification for Shipboard Incinerators.
The sulphur content in fuel is limited to 4.5% maximum except in the Baltic Sea were a 1.5%
limit will apply. Ships will be required to obtain a bunker delivery note from the suppliers
giving details of the fuel quality including sulphur content.
Cargo Vapour Emissions from tankers when loading will be controlled. Tankers will be
required to be fitted with a cargo vapour return system.
Emissions of Halons etc. are prohibited, this part of the regulations re-enforces existing
provisions in SOLAS and other conventions and protocols.
MARPOL Annex VI and the Code will apply to ships constructed1 on or after the date the
acceptance criteria are met. For ships constructed before entry into force, Annex VI and the
Code will apply at the first scheduled dry docking but no later than three years after Annex VI
and the Code come into force. Annex VI will apply to all ships2, to fixed and floating drilling
rigs and other platforms. The Code will apply to all diesel engines with a power output of
more than 130 kW, except those intended solely for emergency use.

1 “Ship Constructed “means ships the keels of which are laid or which are at a similar stage of construction. See also IACS
interpretation MEPC 8.
2 A ‘ship’ is defined in Article 2 of the International Convention for the Prevention of Pollution from Ships, 1973 as “as vessel of
any type whatsoever operating in the marine environment and includes hydrofoil boats, air cushion vehicles, submersibles,
floating craft and fixed or floating platforms.”

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The IMO has adopted a circular (MEPC/Circ.344), which states:


”1 Each engine which will become, retrospectively3, subject to the provisions of regulation 13
of Annex VI of MARPOL 73/78 upon its entry into force, should be certified in accordance
with the requirements of the NOx Technical Code.
2 Pending entry into force of Annex VI and upon satisfactory compliance with the Code
requirements, a "Statement of Compliance" with the NOx Technical Code should be issued
by the flag State Administration, or an organisation acting on behalf of that Administration.
Such a Statement of Compliance should contain as a minimum the information as required
by appendix 1 of the NOx Technical Code.”
Such a Statement of Compliance should contain as a minimum the information as required
by appendix 1 of the NOx Technical Code.”

3 Applies to diesel engines installed on ships constructed, or engines which undergo a major conversion, on or after 1 January
2000.

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MARPOL Annex VI - General Surveys And Certification Requirements


Surveys and certification will be required in a similar manner to the requirements for the
familiar MARPOL Annex I and the IOPP certificate.
Annex VI regulations require that every ship of 400 gross tonnes or above and every fixed
and floating drilling rig and other platforms are surveyed and issued with an International Air
Pollution Prevention (IAPP) certificate. The survey and certification procedures will generally
follow the same format as those for MARPOL Annex I, IOPP certificates.
Ships of 400 gross tonnes and above and every fixed and floating drilling rig and other
platforms must be in possession of an IAPP certificate. For ships under 400 gross tonnes,
the flag administration may establish alternative requirements, for complying with the
provisions of Annex VI.
An IAPP certificate will be valid for five years from the date of the initial survey while its
continued validity will be maintained by annual, intermediate and renewal surveys. The
surveys follow the IMO Harmonised System of Surveys and Certification (HSSC)4.
In the period leading up to the Annex entering into force LR can on request issue certification
to demonstrate that a ship complies with the applicable regulations of the Annex. LR can
also test and certify that diesel engines comply with Regulation 13 of MARPOL Annex VI and
the NOx Technical Code.
Surveyors should consult the Country File prior to commencement of a survey to identify
any additional or specific requirements of the flag Administration.

4 Conference resolution.6 of MP/conf.3/35 invites the MEPC to develop the harmonised system of survey and certification to

replace the existing regulations 5 & 6 of Annex VI if MARPOL 73/78 and initiate action to amend it immediately upon entry
into force.

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Marpol Annex VI Surveys - General Requirements


A survey is conducted to confirm that the arrangements and equipment will, with proper
maintenance be expected to remain in good condition and working order until the next
survey.
MARPOL Annex VI surveys will normally be dealt with in their entirety and not as part
surveys.
Only on those occasions where the required service facilities or necessary replacement
equipment is not available locally would items be considered for deferment.
Surveys should only be held within the permitted range dates, with a certificate ceasing to be
valid if the periodical, intermediate or annual survey, as appropriate, is not completed within
the periods specified in the relevant regulations.
Carrying out the appropriate survey will restore the validity of the certificate. The
thoroughness and stringency of this survey will depend on the time the survey was allowed
to lapse.
When a survey is requested to be held after the expiry of the range dates, the owners should
be informed in writing that the certificate must be considered as having been invalid from the
expiry of the range dates until the date the survey was held.
Renewal surveys should be completed before or by the expiry date of the certificate.
Should a Surveyor become aware that the condition of the ship or its equipment, does not
correspond with the particulars of any of the statutory certificates or the condition of the ship
is such that it is not fit to proceed to sea, without danger to the ship or persons on board or
presents an unreasonable threat to the marine environment the Surveyor will recommend
repairs to rectify the deficiencies.
If the Surveyor’s recommendations are not carried out, the certificate will be withdrawn in
accordance with the regulations of the appropriate Convention. The Master will be advised
in writing that the certificate is to be surrendered and that the certificate is invalid from the
date of the letter. A copy of the letter will be forwarded immediately to the Flag
Administration and, when appropriate, the Port State Authority.
During the survey, operational tests will be required on some items of equipment. Trained
personnel who are familiar with the operation of the equipment to be tested should be
available to assist during the required tests.
The IAPP Initial Survey is to ensure that the working drawings used by the Builders do not
differ from the approved plans. The survey shall be such as to ensure that the equipment,
system, fittings, arrangements and materials fully comply with the applicable requirements of
MARPOL Annex VI.
Periodical or Renewal Surveys will, in addition to the requirements of an annual and
intermediate survey, be such as to ensure that the equipment, system, fittings, arrangements
and materials fully comply with the applicable requirements of MARPOL Annex VI.

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An annual surveys will consist of:

• verification that the certificate on board is in order,


• an examination of the various items of equipment together with tests as considered
necessary, all to an extent which, in the Surveyor’s judgement, indicates adequate
condition and standard of maintenance sufficient until the next due Survey.
• An Intermediate Survey will consist of:
• an Annual Survey, plus
• a thorough examination to ensure that the equipment complies with the requirements
of the Regulations and is in good working order sufficient until the next Survey.

To assist in completing the survey a draft provisional survey checklist has been developed.

Reporting and Certification


The surveyor will complete the checklist during the survey on board the ship to ensure all
relevant aspects are verified. Where necessary, supplementary sheets listing specific
information on the systems accepted are to be appended to the check list report.
On completion of the Initial Survey, the Surveyor completes the report and issues the
appropriate certificate or Statement of Compliance.
A copy of the survey report and certificate is to be exported to the central database. This
ensures the information is available to surveyors undertaking subsequent surveys.
A copy of the report and any certificate issued will be made available to the Flag
Administration as and when required.
On satisfactory completion of the Intermediate/annual survey the IAPP certificate on board
will be endorsed to show that the annual or intermediate survey has been completed. A copy
of the survey report is to be exported to the central database
On satisfactory completion of a Renewal Survey a new certificate valid for a maximum of
five years (taking into account the requirements of the HSSC where appropriate) will be
issued with a copy of the survey report and certificate exported to the central database

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Requirements for Control of Emissions From Ships

Regulation 12 - Ozone Depleting Substances


General requirements
The regulations prohibit the installation of systems containing, or the deliberate release of,
CFCs, halons and other ozone-depleting substances. When removing ozone-depleting
substances from a ship they are to be disposed of at appropriate reception facilities (ref. Reg.
17). This reflects existing requirements in SOLAS, the Montreal Protocol and other
international agreements. In addition some flag administrations have additional
requirements, refer to the Country Files for details5.
No fire-fighting system or other equipment such as refrigeration units is to contain Halons or
other ozone-depleting substances.
For new buildings, SOLAS II-2 Regulation 5-3 prohibits the installation of systems using
Halons. On existing ships, systems containing Halons can remain in service until replaced or
required to be removed by international, national or other requirements. Where there is any
concern regarding the acceptability of the media used, advice should be obtained from a
local Plan Appraisal Centre or London.

Plan Appraisal

Fire fighting systems - Fire plans are to be examined for compliance with the requirements
of MARPOL Annex VI when they are examined for SOLAS and class requirements.

Refrigeration systems - Plans are only required to be submitted where an RMC


(Refrigeration cargo installation) or EP (environmental protection) notation is requested.
Where plans are appraised for compliance with class requirements, compliance with the
requirements of MARPOL Annex VI are also to be addressed.
For all other systems using refrigerants, e.g. domestic refrigeration systems, air conditioning
systems, control air dryers, ice water machines, etc., the attending surveyor will be required
to verify that the media used is acceptable and in compliance with the requirements. These
systems should be documented and attached to the initial survey report.
The Design Appraisal Document (DAD) is to clearly indicate which regulations the plans
have being examined for compliance with.

5 On the intranet, external affairs site.

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Initial Survey requirements


The surveyor attending the initial SOLAS survey is to confirm that the equipment and media
placed on board are in accordance with the approved fire control plans and suitable for use.
It should be verified that no system contains CFC’s, by reviewing the relevant
documentation, certificates, etc.
The refrigeration media requirements will be verified during the initial survey on the ship, the
information being obtained from the manufacturer's and installer's6 information on the
systems. Systems verified on board should be documented, with a copy being attached to
the initial survey report.
The information for the surveys carried out under 6.1.3.1/2/3 above may be used for
completing the MARPOL Annex VI survey without further examination.
Where there is any concern regarding the acceptability of the media used in any of the
systems, then advice should be obtained from the appropriate Plan Appraisal Centre or
London.

In Service Survey requirements


Once the systems have been established at the initial survey, at all subsequent surveys it
should be sufficient to verify that no changes or additions to the systems have been made, to
ensure continued compliance with this regulation.
Where changes have been made or the transitional expiry date for the media reached and
there is concern over the action to take, advice should be obtained from the appropriate Plan
Appraisal Centre or London.

REGULATION 13 - NITROGEN OXIDES (NOX)


General requirements
MARPOL Annex VI requires all diesel engines with a power output of more than 130 kW to
be tested and issued with an Engine International Air Pollution Prevention (EIAPP) certificate
and an approved NOx Technical File. This EIAPP certificate and approved Technical File
stays with the engine and remains valid for its marine life. Periodic verification surveys are
carried out to confirm the engine continues to operate within the on-board NOx emission
limits.
Emergency diesel engines, lifeboat engines or any other engines installed in equipment
intended solely for emergency use do not have to comply with Regulation 13 of MARPOL
Annex VI.
Engines installed prior to the NOx Technical Code entering into force (i.e. ships constructed
on or after 1 January, 2000) will not be subject to the testing and certification procedures
unless they undergo a major conversion.

6 Some countries are known to have banned their manufacturers from supplying systems with certain refrigerants though they
may be acceptable to the Flag Administration. In such instances, installers may supply on site different gases to those
recommended by the manufacturer.

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The approved Technical File provides details of the allowable engine; components, settings,
operating values and allowable adjustments which ensures the engine will continue to
operate within the acceptable NOx emission limits.
Each EIAPP certified engine is subject to an on-board verification survey after installation on-
board as part of the initial IAPP survey. This verification procedure, contained in the
Technical File, is approved from the following available methods:

• Engine parameter method.

• Simplified measurement method.

• The direct measurement and monitoring method.

Where an engine has no EIAPP certificate, (i.e. not pre-certified) certification will be required
prior to issue of the ship's IAPP certificate7. Normally this will entail emission testing of the
engine on-board in accordance with the full test bed requirements or, in extreme
circumstances removing to a test bed.
Note, it is the shipowner who nominates the method to be used to demonstrate compliance
not the flag state authority. The flag state is responsible for the acceptance and approval of
the method. The engine builder will need to supply the necessary supporting equipment,
facilities and information from the outset.

7 Note: prior to entry into force certification is not required, it is an owners option. After entry into force of MARPOL Annex
VI, EIAPP certification for engines installed on ships constructed on or after January 1, 2000, is mandatory.

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Initial on-board verification Survey


The survey will consist of:

Identifying which engines are required to be certified and have an approved NOx Technical
File, and that they all have NOx Emission pre-certification (EIAPP).

A review of the engine certificates and NOx Technical Files including ensuring that the NOx
Technical files have been approved.

Verifying:

• The engine, its components, settings, and operating values remain within the limits
specified in the approved NOx Technical File by performing the on-board verification
procedure.
• The duty stated on the EIAPP certificate equates to the installed duty, e.g. D2 =
constant-speed auxiliary application, etc.
• That the cooling system is in line with that approved for the installation.
• Verifying that an Engine Parameter Book is provided for each engine. This is used
to record all modifications and adjustments to an engine that effect its emission
characteristics including details of the replacement of parts.
• Verification that the engine data logging systems are in place and operational. The
data logging system will vary from ship to ship and engine to engine but may consist
of the engine room logbook, telegraph records both from the engine room and
bridge, and any automatic recording devices fitted to a particular engine.
• The on-board engine verification should take advantage of the engine installation
and commissioning periods to check the component marking and settings to
minimise the degree of inspection required later.
• That the exhaust cleaning or other NOx reduction system, where fitted, is
operational.

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In service surveys
In service surveys will form part of the MARPOL Annex VI annual, intermediate and renewal
surveys. On satisfactory completion of the survey, the IAPP certificate will be endorsed to
show that the annual or intermediate survey has been completed. In the case of a renewal
survey, a new certificate valid for a maximum of five years will be issued.
The surveys will consist of:
• Identifying which engines are required to be certified and have an approved NOx
Technical File.
• A review of the engine certificates (EIAPP) and NOx Technical Files including
ensuring that the NOx Technical Files have been approved.
• Verifying that the Engine Parameter Book for each engine exists and is up to date
and relevant entries correctly completed. It should contain records of: work carried
out on the engine such as modifications, setting adjustments, component
replacements, and details of engine manufacturers technical notices appertaining to
the engine, details of approved modifications, etc., properly entered, signed by either
the Chief or Second Engineer or Manufacturer's Representative as appropriate and
dated.
• Verifying that any modification, adjustments, or replaced parts conform to the engine
specification and parameters in the NOx Technical file.
• Verification that the engine data logging systems are operational and that the data
records are current. Review engine data for trends, which may indicate possible
engine problems relating to NOx emission non-compliance.
• Verifying that the engine, components and settings are as detailed in the NOx
Technical File, i.e. that no modifications or adjustments have been made, by a
survey in accordance with the on-board engine verification method specified in the
approved NOx Technical File for the engine.

At this time the engine parameter method is the preferred route for verification surveys as
selected by the engine manufacturer and is the one currently provided for in the Technical
File.
The simplified method of on-board verification could be problematic since it is difficult to
obtain steady state conditions for each mode of the appropriate test cycle. The test
equipment must be calibrated in strict accordance with the NOx Technical Code.
The on-board direct measurement and monitoring method of on-board verification is not
yet available since the criteria for the recording equipment and its sensitivity have still to be
documented by IMO.
Where fitted, verify that the direct NOx measurement system is calibrated and operated in
accordance with the manufacturer's operational recommendations and that the records are
available.
Where fitted verify that the exhaust cleaning or other NOx reduction system is operational
and being operated in accordance with manufacturer's recommendations.

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Regulation 14 - Sulphur Oxides (SOX)


General
The sulphur oxide (SOx) emissions from ships will be controlled by a limit on the sulphur
content of marine fuel oils, this limit is currently set at 4.5%. In addition a further limit for the
sulphur content of fuel oil, of 1.5%, will exist in SOx Emission Control Areas. The Baltic Sea
will be the first of these areas. Ships operating both inside and outside the SOx Emission
Control Areas will be required to have separate storage arrangements for two grades of fuel
oil and be provided with a means to change from one grade to the other.
When approaching a SOx Emission Control Area the fuel must be changed over to the 1.5%
sulphur content fuel. The change over must completed before entering the control area..
The times and the ships' positions at the start and finish of each change over to and from
1.5% fuel oil must be recorded in a logbook, together with details of the bunker tanks and
fuel used.
As an alternative to using fuel oil with a 1.5% sulphur content an exhaust gas cleaning
system or other equivalent system may be used. The cleaning system must be capable of
reducing the total emissions to within permitted limits8.

Surveys
Though this regulation is operational, the following initial and periodical verifications surveys
should be made.

Initial Survey
Confirm the approved arrangement used on board for compliance with this requirement and
verify it has been installed and commissioned.
This could be:
• Separate fuel tanks for the two sulphur grades of fuel (4.5% and 1.5%).
• An approved exhaust gas cleaning system.
• An alternative equivalent approved system.

Verify official log book for record purposes is on board.

In Service Survey
Confirm the approved arrangements used on board for compliance with this requirement
remain as installed and operational.
Verify records of fuel change over (times, position and fuel tank capacity) are recorded in the
official log book as relevant.
Review the bunker notes to verify the quality of fuel carried onboard is in compliance with the
requirements for sulphur content (see Reg. 18).

8 SOx to 6.0g SOx/kWh or less

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Regulation 15 - Volatile Organic Compounds


General
A Vapour Emission Control (VEC) System is an arrangement of piping and hoses used to
collect the vapours emitted from a tanker's cargo tanks during cargo loading or ballasting
operations for transmission ashore to a vapour processing unit.
The regulations themselves do not require VEC systems to be installed or utilised. The
regulations control the standard the VEC system must comply with and the actions required
by countries which require VEC systems to be used.
A vapour emission control system is only required to be used where local regulations require
the discharge of volatile organic compounds to be controlled.
This regulation only applies to tankers.

Plan Approval
If a Vapour Emission Control system is fitted, plan approval and a survey of the system is to
be carried out to verify its compliance with IMO MSC/Circ.585 in accordance with the
requirements of the Administration. This would be done in conjunction with verification of the
VEC system for the US Coastguards requirements. A VEC system consists of the following
main components:

• A vapour recovery line


• Vapour manifolds
• A closed gauging system
• High level and over fill alarms

Initial and Periodical (In Service) Survey


Verifying that the ship has a Vapour Emission Control system manual or an approved tanker
transfer procedure containing information on the tanker's vapour collection system and
pressure drop calculations approved for compliance with MSC/ Circ 585.
An inspection of the system to ensure that it remains as detailed in the approved plans of the
system as shown in the operations manual or transfer system and that the alarms and safety
features are operational.
Verify the vapour collection system piping is electrically continuous and bonded to the hull.
Verify that the vapour collection system pipe discharge end is readily identifiable to prevent
misconnection, and fitted with an isolating valve capable of manual operation.

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Regulation 16 - Shipboard Incineration


General
The regulations do not require that an incinerator is fitted or that wastes must be incinerated.
The regulations only control incinerator emission standards when an incinerator is installed
on board a ship.
Incinerators installed on or after the 1 January 2000 are to be approved in accordance with
IMO standards9.
The incineration of certain materials that could result in toxic emissions will be prohibited, this
includes cargo residues from MARPOL Annex I, II and III and any related contaminated
packaging, polychlorinated biphenyl’s (PCB’s), garbage containing traces of heavy metals
and refined petroleum products. Other aspects of incineration controls already exist in
MARPOL 73/78 Annex V and the associated guidelines for the implementation of that Annex.
Initial Survey
The survey of the installed incinerator(s) will consist of:
• An review of the type approval certificate and verification that a copy of the
manufacturer's operating manual is on board.

• An inspection of the general condition of the incinerator and tests of the safety
systems. Refer to "Incinerator Test Report Rev 06" available from the LR web-site10
for the tests involved at the different stages.

In Service (Periodical) survey


This will consist of a visual inspection and operational test with verification of the safety
functions.
Verify that records are maintained of sludge, waste etc., incinerated, ship's location and date.
Also verify that the incinerator outlet temperature is monitored.
Check personnel training documentation/records to confirm operating staff have training on
the operation of the incinerator.
Regulation 17 - Reception Facilities
Survey
There are no survey requirements for surveyors. It is the sole jurisdiction of the
Administration to provide suitable facilities at various port locations.
Where an Owner reports to a surveyor, who is acting on behalf of a Flag Administration,
details of inadequate facilities at a location, the owner's representative should be requested
to provide a report detailing their concern for either submission to London through the
surveyor or direct to London. London would then submit the report to the flag states
concerned. Alternatively, the surveyor should advise the owner to send his complaint direct
to the responsible Flag Administration.

9 IMO ‘Standard Specification for Shipboard Incinerators’ in MEPC 76 (40)


10 Path: LR Intranet Home page / cdlive / log in / Information / Approvals / Type Approval System.

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Regulation 18 - Fuel Oil Quality


General
In addition to limiting the sulphur content of oil fuel there are controls to prevent the
incorporation of potentially harmful substances, particularly waste chemicals, into marine fuel
oil. Fuel oil supplied to ships is required to be free from inorganic acids, or chemical wastes
that could jeopardise the safety of the ship, be harmful to ships' personnel, or which would
contribute overall to additional air pollution. The addition of small amounts of additives
intended to improve performance is permitted.
Bunker suppliers are required to provide ships with a bunker delivery note, giving details of
the fuel supplied including the product name, density, quantity, its sulphur content, and a
declaration that the fuel meets the requirements of Annex VI. The bunker supplier must also
provide a truly representative sample of fuel delivered in serviceable containers. The sample
must be taken in a proper manner, sealed and signed by the supplier and the ships’ officer in
charge of bunkering operations
Bunker delivery notes are required to be retained on board for at least three years and the
fuel sample retained until the fuel is completely used but in any case for not less than 12
months.
The onus is on the bunker supplier to provide fuel of the correct quality and supply proper
samples and documentation. Owners who require their own checks on the fuel supplied can
use services such as Lloyds Registers ‘Fuel Oil Bunker Analysis and Advisory Service'
(FOBAS).

Survey
The survey will consist of:
• Verifying that the bunker delivery notes are on board and retained for at least the
previous three years ( refer also to Reg. 14).

• That bunker samples are being retained onboard for a period of at least 12 months.

Regulation 19 - Requirements For Platforms And Drilling Rigs


General
Annex VI applies to platforms and drilling rigs unless subject to the above exemptions.
Surveys would follow the format and philosophy of those for ships, taking into account the
different systems and media employed.
Where further guidance or information is required, this should be addressed to Offshore
Services in the first instance.

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Guidance On Marine Engine On-Board Verification Survey

Introduction

This survey is carried out after installation on board the ship to verify the engine's
components, settings and adjustments remain within the limits established at the NOx
emission test bed trial (Pre-certification) as recorded in the approved Technical File.
Provided these conditions are maintained, the engine is considered to remain operating
within the NOx Emission limit for its category. It being accepted that if the NOx sensitive
components and settings remain the same, then the engine will remain compliant with the
NOx emission limits. Thus, it is not necessary to carry out another NOx emission test.

A verification survey of the engine is required where modifications or adjustments to the


designated components and adjustable features have been carried out since the last survey.
This information should be available from the engine's record book of engine parameters11
where all modifications, repairs, adjustments, component replacements, etc., are recorded.

At each survey the engine would be inspected in accordance with the approved procedure in
the Technical File. The degree of stripping down would be sufficient to allow the NOx
sensitive components, settings and adjustments to be verified. In the real word this may not
always be possible, though still desirable, thus we need to consider the tools currently
employed for engine surveys and use them to our advantage without losing sight of our
responsibilities under our authorisation to carry out this statutory survey. Whichever
combination of methods are used, they must provide verification and confidence that the
engine remains in compliance.

The surveyor shall have the option of checking one or all of the identified components,
settings or operating values to ensure that the engine with no, or minor, adjustments or
modifications complies with the applicable emission limits and that only components of the
current specification are being used, Where adjustments and/or modifications in a
specification are referenced in the technical file, they must fall within the range
recommended by the manufacturer and approved by the Administration..

Where a combination of methods are used to verify compliance, such methods should be
applied with due care and diligence and only by surveyors who through experience
understand the techniques along with their limitations.

While looking at possible survey methods available, it is equally important to understand the
variations in components and settings which affect the engine emissions to appreciate their
limitations while maintaining full confidence in the surveys undertaken.

Survey Methods

Warning, this is not a list of acceptable alternatives to direct survey, but methods which may
be utilised periodically in conjunction with the direct surveys while still maintaining confidence
in the engine's compliance.

11 This is supplied by the Owner in which the Owner's representative records details of engine maintenance, modifications,
updates to the engines received from makers, etc.

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The Technical Code Procedure (This will always be the preferred method)

The Technical Code specifies requirements for the on-board verification survey.

• Documentation Review. A review of the documentation for each engine which includes
the engine parameter book to ensure the components, settings and adjustments
recorded remain within the designated limits. This may be supported by the engine log
book.

• Carry out the on-board verification survey in accordance with the procedure provided in
the engine's NOx Technical File.

• Where an engine is provided with an after treatment device such as an SCR (Selective
Catalytic Reduction) system, a check of its operation forms part of the survey. This
holds true for other NOx abatement systems such as for injection of water, steam, etc.,
into the cylinder or fuel to aid combustion.

Additional Survey Tools

These may be used in conjunction with the direct survey procedure to limit the degree of
opening up at intermediate surveys. For renewal surveys, it is recommended the full survey
is conducted.

• Classification surveys Allows verification inspection of NOx sensitive components


while the engine is open (dismantled) for survey. This can be a very useful tool provided
the verification is thorough and the information properly recorded in the survey report
such that it is available for use at future surveys.

• Operational test under load Allows comparison and assessment of the engine
operating parameters against those in the approved NOx Technical File. This could be
used to limit the degree of opening up required after confirming the easily accessible
components and settings are acceptable. Useful for the smaller engines driving pumps,
etc. Also for generators which are in operation, where it is not feasible to carry out the
full direct inspection.

• Engine Log Book Reviewing the engine log book data for the past few months, can
provide an insight into the engine condition through trends or variations in temperature
and pressure records of coolants, exhaust gas, fuel and lubricating oils and scavenge air.
Similarly, with reviewing records of indicator cards or peak pressures, etc., taken from the
engine. From these sources, gradual or rapid changes in the operating conditions can
be identified to provide an indication of deteriorating conditions or changes in settings or
adjustments which could result in the engine operating outwith the emission limits.

On-Board Verification Survey

The system considered here is the Engine Parameter Check Method (verification of the
NOx sensitive components), which at present the Technical Files are documenting as the
most likely system to be operated by the Owner.

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The following provides a general guide for some of the main components, settings and
adjustments, which may be encountered during a survey12. When carrying out the survey,
the surveyor is to use the On-board NOx verification survey procedure provided in the
approved NOx Technical File, which lists the specific information and data for the engine
under survey.

Combustion Chamber and Compression Ratio

The approved on-board survey method will define how to carry out the inspection/verification
of the various parameters or parts and can vary between manufacturers. The following are
provided as guidelines where this is not clear or alternatives may be considered.

Verifying the cylinder head, piston, piston rod (connecting rod) and shims where relevant,
would be the normal method used. However, the compression ration may be checked by
taking compression readings for each or selected cylinders. Other means are to check the
travel of the piston and to verify that the correct shims have been used where applicable.
Care must be taken, since the wrong type of cylinder head or piston could alter the
combustion space characteristic geometry, i.e. flow / swrill. This may not be easily observed
from travel measurements only. Variations in the combustion space / geometry can have an
effect on the NOx emissions produced due to changes in the combustion process.

Cylinder Head
Normally identified by its identification number (ID), which is usually in an accessible position
without opening up.
The NOx emissions may be altered if the combustion chamber geometry of the cylinder head
is modified, affecting NOx formation mechanism and therefore emission characteristics.

Piston and Piston Rods


Normally verified from the identification number on the piston head and connecting rod. It is
possible on some engines to verify the piston through the scavenge ports as described in the
approved procedure or by using a boroscope where provided, otherwise the cylinder head
must be removed to view the ID marking. In some cases, the ID is on the side of the piston
or at the lower end of the piston skirt. The connecting rod can usually be viewed from the
crankcase by turning the engine.

Turbo-chargers
Turbo-chargers are sized to suit the engine power and operating characteristics. Therefore
changes to their component parts (impellers, diffuser, etc.) will affect the combustion and
hence the NOx emissions. Each major component is marked and at classification surveys
their NOx identification number should be verified. Then at periodical Annex VI surveys it
would be sufficient to verify the correct type of turbo-charger is fitted provided no modification
had been carried out. Modification details can be confirmed from the records in the engine
book of engine parameters.

12 This information is for guidance only and therefore does not provide details for all types of engines which may be

encountered.

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Charge Air Cooler and Cooling System


The temperature of the cooling water controls the temperature of the combustion air, which
has a controlling effect on the engine combustion and thus the products of combustion. The
cooler is therefore sized to ensure optimum engine operating parameters with a sea water
temperature of 250 C. Hence the importance of verifying the cooler is the correct one for the
engine. This can be checked by the ID on the cooler nameplate. The cooler should be
maintained in good condition with effective sealing between the two media.

Note: The Technical File is approved for a particular cooling system and associated
temperature set points. Always consult the approved survey procedures for that engine.

Fuel Injection, Timing and Timing Control System


The injection timing, the injector nozzle, injection pump or the fuel cam, all affect the NOx
emission characteristics or an engine.
The injector nozzle will be marked with the ID on the nozzle. This is easy to remove and
check. It is important since a different number and/or size of holes in the nozzle can affect
the combustion and hence the NOx emissions. Also an incorrectly set injector opening
pressure can affect the combustion. This may be identified from the exhaust temperatures
and indicator cards. With regular maintenance this should not present a problem.
The fuel pumps may be in a block or individual depending on the engine type and
configuration. The fuel may be delivered via a common rail or by individual pumps to each
injector with the injector opening and closing by either electronic or mechanical control. The
fuel pumps are marked with an identifier and type designation, which may be checked
without dismantling completely depending on the type fitted. For some pumps, the plunger
travel is measured by a special tool after removal of the discharge pipe while for others it is
possible to verify by removal of the side plugs and turning the engine over to note the
discharge and cut-off points in relation to the camshaft markings. Electronic control units
have an ID number and are normally sealed. Where adjustments are required, these may
only be made by an authorised manufacturer's representative.

Note: Fuel Pumps in the common rail system are not defined as NOx sensitive components.

Injection timing depends on the system employed. Many of the smaller engines (Member's
of family) use pre-set electronic timing, which cannot be adjusted by the ship's staff.
In other engines, (e.g. members of an engine group) the timing can be altered by re-
positioning the camshaft, the timing chain, drive wheels or fuel cam or its profile or software
parameters in common rail applications. These items are all marked with an identifier plus
the original settings to facilitate verification checks. They can normally be reviewed by the
removal of a cover and turning the engine to the correct position in accordance with the
approved procedure.

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Frequently Asked Questions - MARPOL Annex VI And The NOx Technical Code
NOTE: Frequently asked questions relating to Regulation 13, Certification of Marine Diesel
Engines for compliance with the NOx Emission limits, are contained in a separate document,
"Emissions of Nitrogen Oxides from Marine Diesel Engines Questions and Answers, Sept
2001," available on LR Intranet or Internet : Path - www.lr.org / cdlive / Approval Lists / NOx
Emissions

Q Which regulations are required to be complied with?


A If a statement of fact is request then it is the owner’s option which regulations are
complied with.
If an IAPP certificate or statement of compliance is requested then all the
regulations as applicable for the ship type and equipment fitted are required to be
complied with: -
• Regulation 12
• Regulation 13 (if diesel engine > 130kW are fitted)
• Regulation 14
• Regulation 15 (tankers only and if VEC system fitted)
• Regulation 16 (if incinerator fitted)
• Regulation 18

Q How will Air Pollution from ships be controlled?


A Annex VI controls six areas of air pollution from ships: --
• A prohibition on the discharge of ozone depleting substances
• Emissions of nitrogen oxides -NOx
• Emissions of sulphur oxides - SOx.
• Volatile organic compound emissions from tankers
• Incinerators emission controls
• Fuel quality

Q What certification can LR offer?
A If requested by a shipbuilder or an owner, LR can offer the following certification and
surveys.
• A statement indicating the degree to which a ship complies with the
MARPOL Annex VI Regulations which were verified at the owners' request.
This would be a statement of fact stating the ship had been surveyed, with
details of the regulations it complies with at the time of survey. The
statement would have no period of validity and no further surveys would be
required.
• A certificate or statement of compliance with MARPOL Annex VI. This
will be a certificate or statement issued in the same format as an IAPP

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certificate and valid for five years. To maintain its validity annual and
intermediate surveys will be required. At the end of the five-year period of
validity a renewal survey will be required in order for a new certificate or
statement to be issued. The surveys required can be shown on the ships
survey status on ClassDirectLive.

Q Can LR issue certification on behalf of National Administrations?


A Most administrations have indicated that LR can issue Annex VI certification on their
behalf. Other administrations have indicated that an LR certificate or statement of
compliance would be sufficient evidence of compliance to issue an IAPP certificate
once Annex VI comes into force. This would be issued either by the Administration
or on their behalf by an authorised representative. Surveyors should consult the
Country File requirements of the Flag Administration.

Q Can an IAPP certificate be issued?


A NO. IAPP certificates cannot be issued until MARPOL Annex VI comes into force.
In the interim period Interim EIAPP and IAPP or Statements can be issued.

Q Can LR certify diesel engines for compliance with the NOx Technical Code?
A Yes. However, procedures for NOx code certification are not dealt with in these
guidelines13.
If a request is received for NOx Code certification, contact Engineering Systems,
London for instructions.

13Procedural documents are available on the LR web site at Path: www.lr.org / cdlive / Approvals List or www.lr.org / cdlive
/ login / information / Approvals. Note: By logging in to cdlive LR staff have access to all documents, whereas on front end of
cdlive only those accessible to clients are available..

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ANNEX VI SURVEY REQUIREMENT MAP

Reg 13 Reg16 Reg 12 Reg 15 Reg 14 Reg 18


NOx Incinerator Ozone- VOC SOx Fuel
TA Cert depletion Quality

Plan Appraisal & Plan Appraisal


Manufacturing Inspection, Test
& Certification

Bunker Note
+ Sample

EIAPP Certificate or Interim Design Appraisal Document


EIAPP

Initial on-board survey &


Issue IAPP Certificate

Annual / Intermediate Survey


Endorse IAPP Certificate

Five year Renewal Survey


& Issue of IAPP Certificate

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9.2.8 Recycling Of Ships


The Marine Environment Protection Committee (MEPC) - 47th session 2002 - reviewed the
issue of ship recycling and generally agreed that IMO has an important role to play in ship
recycling, including developing measures covering the preparation of a ship before recycling
commences, and a co-ordinating role in relation to the International Labour Organization
(ILO) and the Basel Convention (on the Control of Transboundary Movements of Hazardous
Waste and Their Disposal) in recycling matters.
The MEPC agreed that IMO, for the time being, should develop recommendatory guidelines
to be adopted by an Assembly resolution. The MEPC agreed to use as a basis for the
guidelines the “Industry Code of Practice”, which was developed by an Industry Working
Party on Ship Recycling.
The industry group included participants from the non-governmental organisations, including
the International Association of Classification Societies (IACS).

A Working Group met during the session and developed the following:

• the draft outline of IMO guidelines on ship recycling;


• views on the role of IMO in ship recycling;
• a work plan, including the use of correspondence and working groups;
• a preliminary draft Assembly resolution on ship recycling which would adopt the
proposed guidelines on recycling of ships and invite the MEPC to work further on
the issue.

The Committee agreed to the re-establishment of a Correspondence Group on ship recycling


to further develop the guidelines and agreed to continue the co-operation with ILO and the
Basel Convention. The MEPC also agreed to request input to the draft guidelines from the
Bulk Liquids and Gases (BLG), Ship Design and Equipment (DE) and Flag State
Implementation (FSI) Sub-Committees.
The Committee also agreed, in principle, that the Working Group on Ship Recycling would be
re-established at the next two MEPC sessions to further the work.
IMO’s role in the recycling of ships, the terminology used to refer to ship scrapping, was first
raised at the 44th MEPC session in March 2000 following which a correspondence group
was established to research this issue and provide a range of information about current ship
recycling practices and suggestions on the role of IMO.
Ships sold for scrapping may contain environmentally hazardous substances such as
asbestos, heavy metals, hydrocarbons, and ozone depleting substances and others.
Concerns have been raised about the working and environmental conditions at many of the
world's ship scrapping locations.

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9.2.9 Vapour Emission Control Systems (VECS)


Vapour emission control systems, are at this time, only required under United States Coast
Guard (USCG) regulations. Nevertheless, VECS will be a requirement under the new
MARPOL Annex VI when this enters into force. The IMO have published requirements for
VEC systems in IMO circular MSC/circ.585, which closely follows existing USCG
requirements.
Under US Federal Law each state is required to implement “Clean Air” legislation, which may
include requirements to control emissions of cargo vapours.
The USCG has developed Vapour Emission Control Systems regulations that are used as a
standard by individual states to ensure all ship and shore VEC facilities are compatible. The
USCG VECS Regulations for tankers are contained in the Code of Federal Regulations Part
46, Section 39 (46 CFR 39).
The Regulations apply to all tanker operations where cargo vapours can be released to the
atmosphere. The Regulations are applicable to Crude Oils, Gasoline Blends and Benzenes.
The USCG has published a list of cargoes that have been evaluated for use with VEC
systems. When “chemical” cargoes are involved there are a number of additional
requirements.
LR can under take plan approval surveys and issue certificates of compliance with the USCG
regulations. Statements are not issued on behalf of the USCG or the flag authority, the
USCG may require further surveys.

Detail of Vessel Vapour Connection

STUD

VAPOUR

Flange to ANSI 16.5B

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MAST RISER

P/V VALVE VAPOUR MANIFOLD


HIGH & LOW PRESSURE
ALARMS

TANK LEVEL ALARMS

L H

h hh

LEVEL GAUGE
VAPOUR CARGO MANIFOLD

OIL

SCHEMATIC OF A VECS SYSTEM

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9.2.10 Ballast Water Exchange


Aquatic organisms, viruses and bacteria can be carried in ship's ballast and in the
sediment in ballast tanks. The organisms, etc. can survive for long periods. When
these organisms, etc. are subsequently discharged with ballast into port waters they
can establish themselves and non indigenous species can then upset the local
ecological balance. The viruses and bacteria can affect human health.
As a means to control this problem one solution is for ships to exchange ballast mid
voyage in deep water. There are a number of considerations associated with ballast
exchange including stress, stability and sloshing considerations.
A number of countries around the world require ships to exchange their ballast water
at sea including Australia, New Zealand, the USA, Canada and Israel. This is to
reduce the introduction of non-indigenous aquatic organisms and pathogens into their
waters.
The International Maritime Organisation (IMO) was alerted to the problems of the
transfer of aquatic organisms the 1980’s and produced the first voluntary guidelines in
1991, since then the guidelines have been revised. The IMO realised that countries
where introducing, on a local basis, requirements for ships to exchange their ballast
prior to arrival in their ports. A need was identified by the IMO for some form of
international regulations for ballast water exchange and they began the development
of regulations.
The IMO realised that ballast water exchange would involve ships in operations which
could be hazardous and developed "Guidelines for the Control and Management of
Ships Ballast Water to Minimise the Transfer of Harmful Aquatic Organisms and
Pathogens", the most recent being Resolution A.868(20). These guidelines are
intended to assist governments and ships in minimising the introduction of harmful
aquatic species whilst protecting ship safety.
When undertaking ballast water exchange a ship has two recognised options,
complete exchange i.e. emptying a tank and refilling it, or a flow through method i.e.
pumping water into a tank and over-flowing it until at least three times the tank volume
has been exchanged. Whichever method is used an existing ship may need some
modification to the ballast pumping and piping system, particularly if the flow through
method is used. For new ships the designer will need to consider the requirements of
ballast water exchange at the design stage of the ballast system.
Alternatives to ballast water exchange are under consideration which involve the
treatment of water on passage or whilst discharging it. The alternatives include
heating, filtration, hydrocyclones, ultraviolet irradiation, chemical treatment and
combinations of these methods. Standards are being discussed at the IMO for the
approval of such systems.
Carrying out ballast water exchange at sea involves carefully planning as there are a
number of hazards involved which have the potential to seriously effect the safety of
the ship.

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In deciding which method to adopt, careful consideration must be given to the


potential hazards and limitations of the operation, which include the following:
• Where the topside and hopper side tanks are interconnected, emptying of fore or
aft water ballast spaces could present operational difficulties in maintaining the
forward draught within allowable limits.

• Emptying and filling of the ballast holds of bulk carriers and ballast tanks in other
ships may require consideration of sloshing loads on the ballast hold/tank
boundaries. On existing bulk carriers in particular substantial structural
reinforcement may be required

• The structure of topside and hopper tanks adjacent to the ballast hold may require
enhancement and reinforcement if it was proposed to empty and fill these spaces
whilst maintaining a full ballast hold.

• The bending moments and sheer forces must be kept within the approved limits
and on some ship designs torsional stresses may also need to be considered.

• A ship must be operated within its allowable stability margins, to meet both intact
and damage stability criteria. The main effects on stability will be free surface
effects from slack tanks and with the "Flow Through" method, from free water on
deck. The effects of free surface must be carefully considered as it can easily be
underestimated.

• When using the "Flow Through" method water on deck poses additional hazards
particularly for ships with deck cargoes. Additional top weight can be added from
water on deck, water can be absorbed by deck cargo, and in cold weather by ice
formation. Adequate arrangements must be made to ensure crew safety when
working on deck where free water exists.

• The dangers of having to stop the complete exchange of ballast water before
completion, due to unfavourable weather conditions or other factors, must also be
taken into account.

• An adequate draft and propeller immersion must be maintained for the intended
voyage and the prevailing and expected weather conditions. The trim must also
be maintained to ensure bridge visibility is not affected and such that slamming is
avoided.

• An existing ship may need some modification to the ballast pumping and piping
system, particularly if the "Flow Through" method is used. For new ships the
requirements of ballast water exchange must be considered at the design stage of
the ballast system.

• The ship must at all times be operated within its allowable stability margins, both
intact and damage stability criteria.

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• On some ship designs tensional stresses may need to be considered.

• Other factors include the prevailing and predicted weather and crew safety when
working on wet decks.

In order to ensure ballast exchange can be carried out safely each ship is required to
have a “Ballast Water Management Plan” which details the procedures for the ship,
the hazards, limitation and contingency measures.
It can be seen that ballast water exchange needs to be very carefully considered by
owners and the ships staff to ensure the safety of the ship. This includes the need for
proper training. Carrying out ballast water management practice at sea should not
result in placing the ship and its crew in hazardous situations. Operationally ballast
water management practice will require ships staff to undertake procedures which
they may well not be familiar with. It is therefore very important that the ships staff
involved in ballast water management receive proper training and that sufficient
guidance is provided onboard concerning the possible hazards involved and the safe
practices to be followed to ensure the safety of the Ship and its crew.
The International Association of Classification Societies (IACS) are concerned about
the safety aspect of ballast water exchange and have undertaken a study to
investigate the possible problems that can be associated with ballast water exchange.
The first stage of this was presented to the IMO in 1998. IACS will continue to
monitor the progress of the regulations and advise the IMO on safety issues. Lloyds
Register has also been investigating the safety aspects of ballast water exchange and
has been working closely with IACS.

9.2.11 Anti-Fouling Systems On Ships


The International Convention on the Control of Harmful Anti-fouling Systems on Ships
(AFS Convention), 2001, prescribes that ships shall be surveyed and certified in
accordance with the regulations of that Convention. The AFS Convention has not yet
entered into force.
The requirements apply to ships of 400 gross tonnage and above engaged in
international voyages, excluding fixed or floating platforms, floating storage units
(FSUs), and floating production storage and off-loading units (FPSOs).
An anti-fouling system means a coating, paint, surface treatment, surface, or device
that is used on a ship to control or prevent attachment of unwanted organisms.
The IMO have developed Guidelines for Surveys and Certification of Anti-fouling
Systems on Ships, that will assist the Administrations and recognised organisations
(of which Lloyd's register is one), in the uniform application of the provisions of the
Convention and assist companies, shipbuilders, manufacturers of anti-fouling
systems, as well as other interested parties to understand the process of the surveys
and issuance and endorsement of the certificates.

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These Guidelines cover the following broad areas:


When are surveys required
An initial survey should be carried out for a new building or for an existing ship, before
the International Anti-fouling System Certificate required under the Anti-Fouling
Convention is issued for the first time.
The initial survey of the anti-fouling system on existing ships may best be carried out
in connection with a dry-dock survey.
A survey should be carried out whenever an anti-fouling system is changed or
replaced.
A major conversion affecting the anti-fouling system of a ship may be considered as a
new building.
Repairs generally do not require a survey. However, repairs affecting approximately
25% or more of the anti-fouling system, should be considered as a change or
replacement of the anti-fouling system.
A non-compliant anti-fouling system controlled under the Anti-Fouling Convention, that
undergoes repair must be repaired, or replaced with a compliant anti-fouling system.

Request for survey


The Owner/Manager should formally request a survey, detailing the ships basic
details. It should be supplemented by a declaration and supporting information from
the anti-fouling system manufacturer, confirming that the anti-fouling system applied,
or intended to be applied to the ship is in compliance with the requirements of the
Convention (with an identification of the version of the Convention referred to). Such
declaration should provide the following information contained in the Record of Anti-
Fouling System, as can be found in the Convention:

1. Type of anti-fouling system;

2. Name of anti-fouling system manufacturer;

3. Name and colour of anti-fouling system;

4. Active ingredient(s) and their Chemical Abstract Service Registry Number (CAS
number(s)).

Information required by the surveyor regarding compliance of product with the


Convention should be found in a declaration from the anti-fouling system
manufacturer which may be provided on the anti-fouling system container and/or on
supportive documentation (such as Material Safety Data Sheets (MSDSs), or similar).
A link between the supportive documentation and the relevant container should exist.

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Conduct of surveys for new buildings


As part of the survey, it should be verified that the anti-fouling system specified by the
documentation submitted with the request for survey complies with the Convention.
The survey should include verification that the anti-fouling system applied is identical
to the system specified in the request for survey.
The verification should include one or more of the following tasks, as deemed
necessary to verify compliance:
1. Checking that the product identification on anti-fouling system containers used
during the application process is identical to the system specified in the request
for survey.
2. Sampling of the anti-fouling system.
3. Testing of the anti-fouling system.
4. Other checks conducted on site.
The verification tasks should be conducted at any time, either before, during, or after
the anti-fouling system has been applied to the ship, as deemed necessary to verify
compliance. No checks or tests must affect the integrity, structure or operation of the
anti-fouling system.
Surveys of existing ships intending to apply a new anti-fouling system
If the existing anti-fouling system is confirmed by an International Anti-fouling System
Certificate not to be controlled under the Convention, the provisions for the survey of
new buildings above apply.
If the existing anti-fouling system is declared not to be controlled under the
Convention, without being documented by an International Anti-Fouling System
Certificate, a verification should be carried out to confirm that the anti-fouling system
complies with the requirements of the Convention. This verification may be based on
sampling and/or testing and/or reliable documentation, as deemed necessary based
on experience gained and the existing circumstances. Documentation for verification
could e.g. be MSDSs, or similar, a declaration of compliance from the anti-fouling
system manufacturer, invoices from the shipyard and/or the anti-fouling system
manufacturer. To verify the new anti-fouling system, the provisions for the survey of
new buildings above should be applied.
If the existing anti-fouling system has been removed, the removal should be verified in
addition to the provisions for the survey of new buildings.
If a sealer coat has been applied, a verification should be carried out to confirm that
the name, type and colour of the sealer coat applied to the ship match those specified
in the request for survey, and that the existing anti-fouling system has been covered
with that sealer coat. Additionally the provisions described for the survey of new
buildings apply.
If the existing anti-fouling system is controlled under the Convention, it should be
removed or covered by a sealer coat not later than 1 January 2008. Prior to this date,
the existing anti-fouling system may be over-coated with an anti-fouling system not
controlled without removing or sealing the existing anti-fouling system. This option
should be stated on the International Anti-Fouling System Certificate by ticking off the
appropriate box. To verify the new anti-fouling system, the provisions described for
the survey of new buildings above apply.

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Surveys of existing ships requesting only an International Anti-fouling System


Certificate
If the existing anti-fouling system is declared to be controlled under the Convention
(i.e. containing prohibited/regulated compounds), an International Anti-fouling System
Certificate may be issued on request stating that the anti-fouling system will be
removed, or covered with a sealer coat when directed by the Convention.
If the existing anti-fouling system is declared not to be controlled under the
Convention, a verification should be carried out to confirm that the anti-fouling system
complies with the requirements of the Convention. This verification may be based on
sampling and/or testing and/or reliable documentation, as deemed necessary based
on experience gained and the existing circumstances. Such documentation could be
MSDSs or similar, a declaration of compliance from the anti-fouling system
manufacturer, invoices from the shipyard and/or the anti-fouling system manufacturer.
If this information raises no reasonable doubt that the system applied is compliant with
the Convention, the International Anti-fouling System Certificate may be issued on this
basis.

Surveys of ships prior to entry into force of the Convention


Prior to the Convention having entered into force, if so authorised by the
Administration, LR may conduct surveys of ships and may then issue a Statement of
Compliance.
Ships capable of documenting full compliance with the Convention through such a
statement of compliance may be issued, upon entry into force of the Convention, an
International Anti-fouling System Certificate on that basis, subject to any additional
requirements from the Administration.

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9.3 The International Convention on Standards of Training, Certification


and Watch-keeping for seafarers (STCW)
The International Convention on Standards of Training, Certification and Watch-
keeping for seafarers (STCW) 1978 was adopted by the International Conference on
the Training and Certification of Seafarers on 7th July 1978. Major amendments were
made to the ’78 Convention in 1995. STCW 78/95 comprises two parts. Part A
comprises the Convention itself and Part B comprises the STCW Code.

Part A
Contains mandatory provisions to which specific reference is made in the annex to the
STCW Convention and which give, in detail, the minimum standards required to be
maintained by Parties in order to give full and complete effect to the provisions of the
STCW Convention.

Part B
Contains recommended guidance to assist Parties to the STCW Convention and
those involved in implementing, applying or enforcing its measures to give the STCW
Convention full and complete effect in a uniform manner.

9.3.1 Changes to STCW


The 1978 STCW Convention entered into force on 28th April 1984. Three
amendments have since been adopted, in 1991, 1994 and 1995.

The 1991 amendment related to GMDSS


The 1994 amendment related to special training for Tanker personnel
The 1995 amendments were the final act of the STCW

Three significant dates relate to STCW 78/95. These are:


i. 1 February 1997 - came into force
ii. 1 August 1998 - all new entrants must meet new Standards
iii. 1 February 2002- All existing seafarers must meet new Standards

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9.3.2 Companies’ responsibilities


SCTW places responsibilities upon ship owners/operators who are responsible for the
assignment of seafarers for services in their ships.
The Owner/Operator has to ensure:
i. each seafarer assigned to any of its ships holds an appropriate certificate;
ii. its ships are manned in compliance with the applicable safe manning
requirements of the Administration;
iii. documentation and data relevant to all seafarers employed on its ships are
maintained and readily accessible
iv. seafarers, on being assigned to any of its ships, are familiarised with their
specific duties and with all ship arrangements, installations, :equipment,
procedures and ship characteristics that are relevant to their routine or
emergency duties;
v. ship's complement can effectively co-ordinate their activities in an emergency
situation and in performing functions vital to safety or to the prevention or
mitigation of pollution; and,
vi. establish and enforce rest periods for watch keeping personnel to prevent
fatigue.
For more details on the training requirements for different levels of responsibility, click
here.
Mandatory minimum requirements for familiarisation and basic safety training are as
follows. All seafarers must undergo:
i. Familiarisation training; and
ii. Basic safety training.

The basic safety training courses are:


i. Personal survival techniques:
ii. Fire prevention and fire fighting;
iii. Elementary first aid; and
iv. Personal safety and social responsibilities.

Additional mandatory safety courses required for all officers are:


i. Advanced fire fighting
ii. Proficiency in survival craft and rescue boats
iii. Medical care

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Specialised Training is required for tankers. Additional training for officers and ratings
is:
i. Fire fighting, and,
ii. At least 3 months of approved seagoing service on tankers; or
iii. Attendance at an approved tanker familiarisation course.

Additional training for Master, C/0, C/E & 2/E is:


i. Advanced fire fighting;
ii Experience on tankers (a period as specified by Administration); and
iii. An approved specialised or advanced tanker course.

9.4 Load Line

Above An International Load Line Certificate with the grid to be marked on the ship's side shown shaded
on the front page and the corresponding freeboard dimensions detailed above it.

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9.4.1 General
What is a Load Line and what is freeboard? Basically a Load Line is the horizontal
marking on the side of a ship indicating the maximum draught down to which it is
permitted to load. There may be a number of Load Lines marked on the side of a ship
at one time and these form what is commonly known as a Load Line grid as shown in
the illustration above. Each Load Line on a grid is annotated with grid letters relating
to the conditions under which it is permitted to be used. The use of the individual lines
is governed by the following (corresponding grid letters are shown in brackets):
1. The seasonal time of year in the location where the ship is operating in salt water
e.g. Summer (S), Winter (W)
2. The geographical zone in which the ship is operating in salt water e.g. Tropical
Zone (T)
3. A combination of seasonal time of year and geographical location when operating
in salt water e.g. Winter North Atlantic (WNA)
4. When the ship is not operating in salt water e.g. Fresh Water (F)
5. A combination of the geographical zone and when the ship is not operating in salt
water e.g. Tropical Fresh (TF)
6. In addition when a ship is carrying a timber cargo on deck which has been loaded
in accordance with the 1966 International Load Line Convention (1966 ILLC) it
can also be permitted to load down to one of a set of timber Load Lines. These
timber Load Lines allow the ship to load to a deeper draught than normal due to
the additional buoyancy afforded to the ship by the cargo and the protection it
offers to the upper deck from seas. If timber freeboards are assigned the
corresponding Load Lines are marked on an additional grid aft of the Load Line
disc. Timber Load Line grid designations are, in most cases, formed by the
standard grid letter prefixed with the letter 'L' e.g. Where 'S' is used to indicate the
summer Load Line 'LS' would be used to indicate the timber summer Load Line (L
meaning lumber).

Above an example of Load Line markings including timber Load Lines (grid shown left of disc)

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The type of grid letters are used is ultimately dependent on the country of registration
of the ship and before any Load Lines are marked the flag requirements should be
established. In some instances the more commonly used grid letters are replaced by
letters corresponding to the national language e.g. for Danish flag ships 'W' for Winter
is replaced by 'V' for 'Vinter'.
In addition to the grid letters, designatory letters are marked above the horizontal line
through the Load Line disc, these indicate who was the assigning authority e.g. The
use of the letters 'LR' indicates that Lloyd's Register was the assigning authority. It
should be noted that, in some instances regardless of whether the Class Society
assigned the Load Lines on behalf of a flag administration, the assigning authority's
mark will remain that of the flag administration. LR assigns the freeboards for Danish
flag ships but instead of 'LR' being marked beside the Load Line ring the letters 'DL'
are marked instead thus indicating that the assigning authority was the Danish
Administration. As for grid letters the existence of flag requirements for assigning
authority markings should be established before marking Load Lines.
It is important to note that although Load Lines govern the maximum permissible
draughts in varyious operating conditions their primary purpose is in fact to ensure a
minimum freeboard is maintained. Generally speaking freeboard is the distance from
the sea level to the exposed weather deck of a ship and it is clear therefore, that a
minimum freeboard is required to ensure the integrity of the hull is maintained, thus
preventing ingress of sea water. In addition adequate freeboard will ensure that the
crew can go about their duties on deck safely and without fear of being washed
overboard. Adequate freeboards will also reduce the likelihood of cargo being
damaged.
In reality the actual freeboards of a ship are the distances from the deck line marked
on the side of a ship down to each of the horizontal Load Lines of the Load Line grid
as described previously. The deck line is a 300mm horizontal line 25mm deep
marked on the side of the ship at amidships. The top of the deck line is normally in
line with the top of the deck designated as the freeboard deck. Sometimes the deck
line is marked a known distance below the top of the freeboard deck for practical
marking reasons such as the ship having a rounded gunwhale.

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The freeboard deck of a ship is normally the uppermost complete deck exposed to
weather and sea, which has permanent means of closing openings in the weather part
thereof, below which all openings in the sides of the ship are fitted with permanent
means of weathertight closing. The word 'normally' should be noted in the definition
of the freeboard deck as it is frequently the case in ships which are non deadweight
carriers such as Container Ships that a deck below the uppermost complete weather
deck is designated the freeboard deck. In the case of Container Ships the freeboard
deck quite often corresponds to the passageway deck.

Above arrangement of Load Line markings including grid, disc and deck line plus standard dimensions.

9.4.2 History
The subject of freeboards is as old as mans' attempts to conquer the seas and the
allowance for and provision of freeboard was initially based on a combination of the
best practice of the period based on the basic human instinct for self preservation
when confronting adversity. It is, however, of interest to note that ancient Venetians
took the subject of provision of freeboards more seriously than most and actually had
regulations covering the subject incorporated in their laws.
For a substantial period of history, as ships grew larger and longer journeys were
being made at sea, the loading of ships and provision of freeboard was usually still
governed by common sense and safety considerations. It is however fact, that
although the maximum load draught of ships was being recorded in Lloyd's Register
Book from 1774, there was no prescribed method of how the figure was determined.
Up until 1835 the maximum loading draught of a ship was decided by the ship's owner
who, in more and more cases, did not form part of the ships complement. The owner
did however, have a financial incentive to carry more cargo on each of his ships and
not surprisingly, the recorded load draughts and actual loading of ships was
excessive, leading to the losses of hundred of ships a year around the British Isles
alone.
In 1835 following conflicts between interested parties such as owners, shippers and
underwriters the Committee of Lloyd's introduced "Lloyd's Rule" which proposed a
freeboard of 3" (approx 75mm) per foot (approx 300mm) depth of hold and this rule
was used extensively up until 1880. The first compulsory regulations for the loading
of ships was introduced in the 1890 Merchant Shipping Act. Lloyd's Register had
made freeboard a condition of classification in 1873 and was, therefore, the first public

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body to require a Load Line. The requirements for the compulsory marking of deck
lines and Load Line discs on the side of ships was introduced in the 1876 Merchant
Shipping Act but the formal tabulated minimum required freeboards setting the
location of the Load Lines was not introduced until 1890.
The tables of minimum freeboards were known as the "Board of Trade Tables" and
were formed as a result of a report issued by Lloyd's Register's Chief Surveyor Mr
Benjamin Martell in 1882 and the work done by Sir Digby Murray. The compulsory
marking of deck lines, a Load Line disc and draught marks on the side of ships can be
attributed to the, work of the famous Samuell Plimsoll from whom the name Plimsoll
Line is derived, and the equally important work of the almost unknown James Hall.
James Hall campaigned tirelessly on the subject and supplied Plimsoll with many
illustrations of cases of overloading and ideas for his reform programme.
The first international conference on Load Lines was held in 1930 and the findings
became known as the 1930 International Load Line Convention. It was with the
introduction of the 1930 Convention that, for the first time, there was an international
agreement between maritime nations on the method of calculating required
freeboards and the conditions for their assignment.
As a result of changes in ship design, defects seen in the 1930 Load Line Convention
and changes in philosophy the 1930 Load Line Convention was replaced by the 1966
International Load Line Convention which came into force on the 21st of July 1968.
The 1966 Convention which remains in force has been ratified by 142 countries which
represent 98.34% of the worlds merchant shipping fleet. The following criteria were
used as the basis for assessing the required freeboards:
• Prevention of entry of water through exposed parts of the ship
• Probability of deck wetness in relation to bow height
• Maintenance of sufficient reserve buoyancy in normal conditions of service
• Protection of crew when moving about the ship
• Adequate structural strength of the ship
• Stability and compartmentation

As a result of the 1966 Load Line Convention some of the changes included:
• Freeboard length of a ship fixed according to its depth
• Categories of ship types totally revised
• Ship's required to have a specified minimum bow height
• Ship's required to have both approved loading and approved stability
information
• Requirements for number, height and support of guard rails and bulwarks

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9.4.3 Freeboard / Load Line Calculations


It is not the intention of these notes to detail how to carry out a complete freeboard
calculation but to give a brief understanding of the process and how the results are
achieved. When calculating freeboards the first step is to calculate the freeboard
which corresponds to the summer freeboard. The process involved for ships over
100m in length comprises of the following six steps:

Step 1 Determine the tabular freeboard


Step 2 Correct the tabular freeboard according to a correction based on the ships
block coefficient to obtain the ship's basic freeboard
Step 3 Apply a depth correction based on the ship L/D ratio
Step 4 Apply a deck sheer correction
Step 5 Apply a superstructure correction
Step 6 Apply a bow height correction

Step 1 Tabular Freeboard


The tabular freeboard of a ship is obtained directly from tables contained in the Load
Line convention. Separate tables exist based on the vessels Ship Type as defined in
Regulation 27 of the 1966 International Load Line Convention and shown below:
Ship Type 'A':
A ship designed to carry only liquid cargoes in bulk and in which the cargo tanks have
only small access openings closed by weathertight gasketted covers of steel or
equivalent materials.
Ship Type 'B':
Any ship which does not comply with the provisions applicable to type 'A' ships.
Ship Type 'B-60':
A type 'B' ship with freeboards reduced by 60% of the difference between the required
tabular freeboard for the ship as a type B ship and that of the ship as a type A ship.
Ship Type 'B-100':
A type 'B' ship with freeboards reduced by 100% of the difference between the
required tabular freeboard for the ship as a type B ship and that of the ship as a type
A ship.
Ship Type 'B+':
A type 'B' ship required to have increased freeboards.

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The reduction in freeboards for type 'B-60' ships is based on the ship complying with
additional conditions laid down in the convention covering the following:
• The protection of crew
• freeing arrangements
• hatch coamings, covers and their height, strength, sealing and securing
• Damage stability requirements (single compartment standard)

For type 'B-100' ships they must comply with all the conditions for assignment of 'B-
60' freeboards plus additionally requirements covering the following as if the ship were
a type 'A' ship:
• Arrangements for machinery casings
• Arrangements for gangways and access
• Arrangements of open guard rails height of sheerstrake
• Damage stability requirements (two compartment standard)

Type 'B+' ships have had their freeboards increased because their hatch covers do
not comply with either regulation 15(7) (re. Pontoon hatch covers) or regulation 16 (re.
hatchway coamings, weathertight covers and means of securing covers and
maintaining weathertightness).
When the Load Line ship type has been established the tabular freeboard is simply
obtained by referencing the correct table, for type 'A' ships or for type 'B' ships and
reading of the freeboard that corresponds to that required for the ship according to its
freeboard length.
Freeboard length is defined is the greater of the following two measurements taken on
a waterline at 85% of the least moulded depth measured from the top of the keel:
• 96% of the total length from the fore side of the stem to the after side of the
stern, or
• The length from fore side of the stem to the centre line axis of the rudder
stock.

Step 2 Correction for Block Coefficient


Where the block coefficient (Cb) of the ship is greater than 0.68 then the tabular
freeboard is multiplied by a factor equal to the following:

(Cb + 0.68)
1.36

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Step 3 Correction for Depth


Where the depth from the bottom of the keel to the underside of the freeboard deck
(D) is more than one fifteenth of the freeboard length (L) then the freeboard is
increased in accordance with the following formula:

L
D− .R
15

When L>120m then R=250


When L<120m then R=L /48

NB: D and L are in metres and the result is in mm's

Where the depth is less than one fifteenth of the freeboard length then the freeboard
can be decreased provided the ship's arrangement provides superstructures and
trunks on the freeboard deck to the extent required by the Load Line Convention.

Step 4 Sheer Correction


If the design sheer of the ship differs from the standard sheer allowed for in the Load
Line Convention then the freeboards can be reduced if excess sheer is provided or
the freeboards are increased if the sheer is defficient. In the calculations a standard
sheer is calculated and this is compared with the actual sheer using Simpson's Rule
and ordinates based on the actual sheer as measured at the side of the ship.

The sheer correction to the freeboard is then obtained by multiplying the deficiency or
excess of sheer by the result of the following formula:

S
0.75 −
2.L
Where S = The total length of enclosed superstructures as defined in Reg.34 of the
Load Line Convention.

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It should be noted that where a forecastle or poop superstructure is in excess of the


standard height then a sheer credit is incorporated into the calculation.The standard
height of superstructure as defined in Reg.33 of the Load Line Convention and
repeated in the table below:

Freeboard Length (m) Standard Height


Raised quarter deck (m) All other superstructures (m)

30 or less 0.9 1.8


75 1.2 1.8
125 or more 1.8 2.3

Table 9.4.3.1 Standard Superstructure Heights

Step 5 Superstructure Correction


The presence of enclosed superstructures on the freeboard deck will have the effect
of increasing the reserve buoyancy of the ship. As a result a reduction in the
freeboard may be granted dependent on the effective length of the superstructure
which is based on the superstructure length and its breadth in relation to the breadth
of the ship. If the effective length is equal to the freeboard length of the ship then a
set deduction from the freeboard is laid down in Regulation 37 of the Load Line
Convention based solely on the length of the ship.

Should the effective length of the superstructure be less than the freeboard length of
the ship then the deduction in freeboard is dependent on the proportion of the
freeboard deck covered by superstructures, the type of superstructure and the Load
Line type of ship i.e. type'A' or type'B'.

Step 6 Bow Height Correction


Where the bow height is less than the minimum laid down in Reg.39 of the Load Line
Convention then the freeboard is required to be increased by the value equal to the
deficiency in bow height.
When all the corrections have been made to the basic freeboard as outlined
previously in steps one to six then the figure calculated corresponds to the minimum
summer freeboard. Once the summer freeboard has be obtained the other
freeboards to be marked on the Load Line grid are obtained by adding or deducting
the corresponding seasonal allowances from the summer freeboard. Detail of when
the seasonal allowances should be used is contained in Regulations 46 to 52 of the
Load Line Convention.

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The seasonal allowances are obtained as follows:


Tropical freeboard This freeboard which is to be used when the ship is operating in
the tropical zone is obtained by deducting from the summer freeboard a value equal to
one forty-eighth of the summer draught.
Winter freeboard This freeboard which is to be used when the ship is operating in an
area during the winter season is obtained by adding to the summer freeboard a value
equal to one forty-eighth of the summer draught.
Winter North Atlantic freeboard This freeboard is only required to be marked on
ships which have a freeboard length less than 100m, ships with a freeboard length
equal to or greater than 100m are required to used their winter freeboard instead
when operating in the North Atlantic in Winter. The freeboard is derived by adding an
additional 50mm to the winter freeboard.
Fresh Water freeboard A freeboard to be used when the ship is operating in fresh
water. The freeboard is derived by deducting from the summer freeboard an
allowance equal to the summer displacement divided by four times the tonnes per
centimetre immersion (TPC) for the ship at the summer load water line.
Tropical Fresh Water freeboard When operating in fresh water within a tropical
zone this freeboard may be used and as a result the required minimum freeboard may
be reduced by a value of one forty-eighth of the summer load draught. This deduction
is applied to the fresh water freeboard value.

9.4.4 Load Line Surveys


Lloyd's Register (LR) carries out Load Line surveys to verify compliance with the 1966
International Load Line Convention, like any other statutory survey, on behalf of a flag
administration. LR is at present fully authorised to carry out such surveys and issue
certificates under the terms of the convention on behalf of 112 countries and is
partially authorised by a further 12 countries.
It should be noted that regardless of whether or not LR is authorised to carry out the
statutory Load Line survey on behalf of the flag administration the satisfactory
condition of all Load Line items is also a classification requirement which is verified as
part of the class Annual Survey (see annex 3).

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9.4.4.1 Initial Load Line Survey


This survey is held before the ship enters service and its purpose is to confirm that all
the requirements of the Load Line Convention have been met before issuing the
ship's International Load Line Certificate on delivery. The certificate issued on
delivery is normally valid for a period of five years subject to the satisfactory
completion of Annual Load Line survey and the ship not changing flag.
As part of the initial survey the ship's freeboards as marked on the ship's side are
checked to see that they correspond to the values assigned by the assigning authority
following the relevant calculation of freeboards. The assigned freeboards are usually
detailed in a memorandum of freeboards and these values are recorded by the new
construction surveyor when preparing the ship's Load Line Certificate ready for
delivery. It should be noted that due to the capacity of the modern ship yards to
fabricate and handle large side shell blocks of up to 700 tonnes in weight the
freeboard markings are quite often marked and verified at block stage. Marking and
verification at block stage makes the process both easier and safer but the final
acceptance is subject to confirmation of the actual depth moulded of the ship being
the same as the design figure used in the Load Line computation.
In addition to verifying the accurate marking of the freeboards, the surveyor will verify,
that the ship has adequate approved loading and stability information onboard (Reg.
10) and that all other Load Line related arrangements fitted on the ship which are
required to meet the regulations contained in the Load Line Convention are complied
with. The requirement for compliance of these 'as-fitted arrangements' with the
regulations contained in the Load Line Convention is known as the conditions of
assignment. The newbuilding surveyors will, in addition to verifying that all
conditions of assignment are met, make a record of conditions of assignment
which is commonly known as the C11(IMO). The C11(IMO) acts as a reference
document for future surveys and a copy is placed onboard the ship when it is
delivered along with the Load Line Certificate. The contents of the C11(IMO)
includes, amongst many items, the following (applicable convention regulation is
shown in brackets):
• Sketch of the ship with locations of closing appliances on the freeboard deck,
in positions 1 & 2 plus and those serving openings to enclosed machinery
space
• Details of weathertight and watertight doors (Reg.12)
• Details of hatchways, miscellaneous openings and closing devices (Regs. 14,
15,16, 17 & 18)
• Details of ventilators (Reg. 19)
• Details of air pipes (Reg. 20)
• Details of scuppers and discharges (Reg. 22)
• Details of side scuttles and windows (Reg. 23)
• Details of sea inlets and outlets (Reg. 22)
• Details of bulwarks, guard rails and life lines (Regs. 24 & 25)
• Details of machinery casings (Reg. 26)
• Details of special arrangements (e.g. bow doors, side doors etc.)

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When considering what is acceptable, during new construction, in terms of the


minimum heights of openings above the freeboard deck and requirements for closing
appliances for Load Line items such as ventilators, doors, etc. it is most important that
the items location is recognised in terms of Load Line position. The Load Line
positions are defined as follows:

ft of
fitted a cated on
o sitio n 2 If a nd lo
P L
rd 0.25 k
forwa tructure dec
rs
a supe
0.25 L
rward rstructure
n 1Fo e
Positio d on a sup e
locate recastl
even if such as a fo

D ec k
eb o ar d
1 fre
tion
Posi
Freeboard Deck

Position 1 Upon exposed freeboard and raised quarter decks for their entire length,
and upon exposed superstructure decks situated forward of a point located a quarter
of the ship's length from the forward perpendicular.

Position 2 Upon exposed superstructure decks situated abaft a quarter of the ship's
length from the forward perpendicular.

It should be noted that for a opening to be classed as being in position 2 the then it
must be upon a deck the height of which is at least one standard superstructure
height (see table 9.4.3.1) above the freeboard deck.

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Additional Load Line definitions:


Superstructure. This is a decked structure on the freeboard deck, extending from
side to side of the ship or with side plating not being more than 4% of the breadth of
the ship inboard of the shell plating.
Enclosed Superstructure. This is a superstructure which is of substantial
construction and with its openings protected by efficient regulation means of closing
appliances.
Deck House. A decked structure on the freeboard deck which is not a
superstructure.
Some ships are permitted to be issued with multiple Load Line certificates and
therefore a number of sets of marks may be permanently marked on the side of a ship
by punch marking or welded steel grids. Such a ship is commonly known to have
been assigned multiple Load Lines.
Although a ship may have onboard a certificate for each set of Load Lines marked on
the side of the ship it is still only permitted to use one certificate and one grid at any
given one time. As a result all other existing certificates are required to be locked
away and the corresponding markings painted over so that they are not clearly visible.
At any one time only the markings related to the Load Line certificate which is
in use should be visible, i.e. painted in a different colour to that of the background
hull. It should be noted that not all national administrations permit ships flying
their flag to be issued with multiple Load Lines.
One example of a ship requiring multiple Load Lines is an Oil Tanker requiring
summer freeboards corresponding to a defined maximum deadweight as requested
by the owner. Such a freeboard often allows the owner to operate his ship out of a
port which has a deadweight restriction on ships using it. In such cases the freeboards
assigned are often much greater than the minimum permitted by the Load Line
convention based on the actual geometry and arrangements of the ship however the
financial benefits to the shipping company more than compensate for this.

9.4.4.2 Periodical Load Line Inspection (PLI)


The Periodical Load Line Inspection, sometimes referred to as the Annual Load Line
Survey, is due to be held annually on the anniversary date of the delivery of the ship.
As for the class Annual Survey a range date of +/- 3 months is applicable to the
survey.
During the PLI the surveyor will ensure that:
• The Load Line certificate is valid and if the ship has multiple Load Lines the
certificates are being used correctly and that the currently displayed Load Line
markings correspond to the certificate in use
• The required loading and stability information remains onboard
• Confirm that no alterations to the ship which may effect the assignment of
Load Lines have taken place in the past year
• The freeboards are correctly marked
• Items such as appliances for the protection of openings, guard rails and
means of access are being maintained i.e. the conditions of assignment as
detailed on the C11(IMO) in effective condition.

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A requirement for the satisfactory completion of the PLI is that the class annual survey
has been satisfactorily completed.

9.4.4.3 Periodical Load Line Renewal Survey (PLR)


Before issuing a new International Load Line Certificate to a ship a PLR is required to
be completed before the expiry date of the existing certificate. No provision can be
made to extend the existing Load Line certificate and it is usually carried out at the
same time as the class Special Survey. As stated previously in the chapter covering
class surveys it is a pre-requisite for consideration of the postponement of a ship's
Special Survey that the PLR has been completed satisfactorily. The scope of the
renewal survey does not differ to that of the annual inspection.

9.4.4.4 Survey of Fixtures and Appliances for the Protection of Openings


As stated previously a requirement of all the Load Line surveys is that the conditions
of assignment remain valid at all times. Some of the most commonly surveyed items
are illustrated in the following pages along with common defects.

Ventilators
The ventilators surveyed are those required to comply with Regulation 19 of the 1966
Load Line Convention. In general ventilators lead to dry spaces such as holds, stores,
accommodation and machinery spaces.
Ventilators are frequently located in exposed positions and are subjected to sea water
spray possibly resulting in wastage both internally and externally on covers and flaps.
The surveyor will look inside the cover to check the condition of the gaskets and
retaining channels. Where vent ducts and casings are welded to the deck rather than
actually penetrating the deck grooving of the casing directly above the deck may
occur due to an accumulation of moisture.
When considering the dimensions of ventilators the minimum height from the deck on
which they are fitted to its effective downflooding point must equal a minimum of
900mm in position 1 and 760mm in position 2. Ventilators are to be substantially
constructed and have coamings made of steel. It should be noted that ventilators in
excess of 900mm in height are to be specially supported, typically brackets are fitted
and welded at the base of the ventilator and to the deck. It is most important that
when fitting the brackets to the deck they are correctly aligned with underdeck
structure such as longitudinals, it may be necessary to fit additional structure such as
carlings to prevent the brackets puncturing the deck.

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Types of ventilator and typical defects

Gooseneck type ventilator

Gooseneck type ventilator

Bulkhead type ventilator

Mushroom type ventilator

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Ventilators and defects


Broken centre bolt Holed

Corroded pipe through deck

Air Pipes
The air pipes surveyed are those required to comply with Regulation 20 of the 1966
Load Line Convention. Air pipes lead to tanks, cofferdams, void spaces and other
spaces which can be pumped out. As a result of air pipes being required to be fitted
with automatic closing devices and the fact that they serve spaces which are often
filled or emptied of liquids it is imperitive that the closing device is operative at all
times. Obviously the primary purpose of the automatic closing device is to prevent the
entry to the tank of sea water, however it must perform the function of allowing air out
during filling of the tank and air in when emptying the tank. Failure of the closing
device can lead to catastrophic failure of the tank due to excess pressure or vacuum.
Due to the importance of the closing device they are to be of an approved type with
removable access panels so that the float and seating can be easily examined. In
addition the devices are to be self draining with casings manufactured of an approved
metallic material adequately protected against corrosion. In addition air pipes leading
to cargo, fuel oil, diesel oil and lub oil tanks are required to be fitted with spark
arresting gauze to prevent explosions.
From the base of the air pipe at the deck level on which it is fitted up to the point
where water may flow into the tank which the air pipe is serving the minimum height of
the coaming must equal 760mm if the deck is the freeboard deck. If the deck on

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which the air pipe is fitted is a superstructure deck then the minimum coaming height
is 450mm.
Air Pipe Types

Above left, fitted air pipe with access


cover
Above, cylinder type air pipe
Left, disc type air pipe

Air Pipe Defects

Air Pipe Defects

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As discussed earlier, if the closing devices are not working efficiently, tank over
pressurisation can occur with catastrophic results as illustrated below.

Similarly vacuums in ballast holds can result in severe damage (shown below).

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Sounding Pipes
Clearly marked as to which space they serve these are fitted to all tanks plus dry
spaces such as cofferdams and cargo holds. Below the upper deck, inside the tanks,
holds or spaces the sounding pipes that run through them are normally examined
during the internal examination of the space concerned. The remaining section of the
sounding pipe above the upper deck is examined during the Load Line survey along
with the closing arrangement such as threaded steel cap.

Sounding Pipe with Screw Cap Flush Type with Threaded Plug

Below, no thread remains on either the plug Cap or in the deck

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Machinery Casings, Superstructures, Doors and Small Hatches


These are examined for the effectiveness of the closing appliances and their integrity
with regard to preventing the ingress of sea or rain water. Doors, ventilators, windows
and plating are all examined for their efficiency. Plating of a casing and/or
superstructure which makes up part of the boundary of a saveall is given special
attention due to the increased retention of gathered water against the plating leading
to the increased possibility of accelerated corrosion.
The area of plating forming casings and superstructure at and just above deck level is
also given additional attention due to problems experienced with internal
condensation building up between internal insulation and the outside plating (see
below).

All access openings in enclosed superstructure, accommodation deckhouses and


machinery casings are required to be fitted with doors of steel or equivalent materials
permanently and strongly attached to the bulkhead. The doors concerned are
required to be gasketted and secured weathertight by means of clamping devices
(clips/dogs) attached to the bulkhead or door. The doors clips/dogs are to be capable
of being operated from both sides.
When weathertight doors are fitted in Position 1 they should have a minimum of 6
clips and a sill height of 600mm when fitted in Position 2 a minimum of 4 is required
and a sill height of 380mm.
Small access hatches when leading to spaces either within the ships hull, enclosed
superstructure or machinery casing are required to have a coaming height of 600mm
if fitted in Position 1 or 450mm if fitted in Position 2. The hatches are to be gasketted
and weathertight.
Weathertight doors and hatches are examined in way of seals, retaining channels,
dogs and hinges. Worn or wasted items are renewed, seized dogs are freed and
adjusted as necessary.

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Below, Regulation 12 doors, gasketted and with clips. These can be fitted in Position 1.

Below, A selection of access hatches some of which are obviously in need of repair.

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Cargo Hatch Covers

The primary function of hatch covers is to maintain the weathertight integrity of the
ship by effectively closing the hatchway used for loading and unloading cargo. The
basic types of hatch covers are:
• Mechanically operated weathertight steel covers including side rolling, single
pull, hinge and ram, folding and end rolling hatch covers
• Steel pontoon weathertight hatch covers
• Steel pontoon covers with tarpaulins
• Portable covers with tarpaulins
• Flush deck hatch covers

Hatchways closed by weathertight covers made of steel or an equivalent material


fitted with gaskets and clamping devices are required to comply with Regulation 16 of
the 1966 Load Line Convention. The minimum height required for the hatchway
coaming is dependent on the Load Line position i.e position 1 or 2. In position 1 the
minimum required coaming height is 600mm and in position 2 it is 450mm. In addition
the assumed loads for steel hatch covers, used in design, is also dependent on their
position requiring loads of 1.75 t/m² and 1.30 t/m² to be taken into account in positions
1 and 2 respectively. Regulation 16 also gives details of the maximum deflections of
the steel cover top plating plus minimum scantling requirements.
When weather tight hatch covers are fitted the tightness of the covers is tested both at
the initial Load Line survey before the ship is delivered and then annually along with
confirmation of the covers satisfactory operation. Non-weathertight hatch covers as
sometimes allowed, by the flag administration, if fitted on a container ships second or
virtual second tier superstructure deck are, however, not required to be tested for
tightness.

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Testing for weathertightness of hatch covers during the Load Line survey is usually
confirmed by hose testing. During hose testing a jet of water from a 12mm
diameter nozzle with a pressure of 2Kg/cm² is directed at the joints and gasketted
areas of the hatch covers from a distance of not more than 1.5metres. Host tests
can be difficult to conduct satisfactorily. With only one surveyor available it is hard to
check for leaks whilst at the same time ensuring that the crew are directing the hose
jet correctly and from the correct distance. If a trickle of water is detected leaking
through the sealing arrangements the actual defect area can sometimes only be found
by chalk testing.

Above, hose testing of hatch covers


Chalk testing consists of rubbing chalk along the entire length of the compression bar
which seals against the hatch cover gasket. After the chalk has been applied the
cover is closed with the normal operational amount of torque applied to each clamp
etc. When the cover has been fully closed and secured it is then opened and the
sealing gasket examined. Where the compression bar has been in contact with the
gasket, thus effecting a seal, chalk should have been transferred to the gasket and
therefore a continuous chalk line should exist along the entire length of the gasket if
the seal is effective. Gaps in the chalk line indicate a lack of seal which requires
corrective action.
The weathertightness of hatch covers can also checked using ultrasonic testing
(UT).

Above left, if the hatch cover is not tight then sound waves escaping the hold can be
detected with sensing equipment (above right)

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Reasons why hatch covers may not be weathertight include:


• Corrosion of cover plating particularly in areas which are difficult to access
and therefore hard to clean/paint.
• Cracks in cover plating due impact damage, overloading etc.
• Gasket retaining bars being wasted/corroded allowing gasket to move and not
seal. Corrosion may be due to blocked drainage channels or non-return drain
valves being inoperative.
• Seals missing or partially destroyed.
• Seal rubber deterioration/permanent set (properly compressed seals normally
last 4 to 5 years). Permanent set may be caused by over compression
possibly due to worn compression pads. It should be noted that painting of
gaskets effects the elastic properties of the rubber by causing hardening.
• Misalignment of compression bars and gaskets especially at cross joints.
• Incorrectly fitted gaskets including use of packing pieces, rubber hose, pre-
formed corner piece gaskets replaced by straight gasket pieces bent to
shape.
• Poor condition of closing arrangements such as damaged / inoperative /
missing cleats, missing wedges.

General hatch cover defects include:


• Structural defects including wasting, deformation and damage of cover and
coaming plating and stiffeners.
• Inoperative non-return drain valves.
• Defects in operating mechanisms such as seized running wheels, stretched
chains, mis-aligned running gear, seized link mechanisms, hydraulic oil leaks
from pistons/motors, wastage/damage to rack and pinion systems.

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Hatch cover types and illustrations of typical defects

Side Rolling Hatch Cover Single Pull Hatch Cover Side Coaming

Above, Folding Hatch Cover Above, Hinge & Ram Arrangement

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Hatch cover types and illustrations of typical defects

Above, End Rolling Cover Above, Pontoon Hatch Cover

Above, End Rolling Hatch Cover Open and Above, Portable Covers with Tarpaulins
Closed with Tarpaulins (top)

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Above, Folding Flush Type Covers Open Above, Folding Flush Type Closed

Above, Doublers Welded to Cover Above, Crack in Cover Girder


(undesirable)

Above, Damaged Cover Gasket Above, Incorrect Corner Fitting Fitted

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Above, Hatch Cover Securing Above, Wasted Securing Arrangements

Above, Quick Adjusting (QA) Cleats (NB Above, Hatch Cover with cardboard
painted compression rubber (left) and discovered covering a hole.
wasted shank (right)).

Miscellaneous Openings and Arrangements


Other miscellaneous openings and arrangements which are required to comply with
the Load Line Convention and be examined during the Load Line examination are:
• Chain locker closing arrangements
• Flush deck hatches
• Windows, side scuttles and deadlights
• Scuppers, inlets and discharges plus closing arrangements
• Freeing ports
• Guard rails and bulwarks
• Gangways, walkways and lifelines

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9.4.5 Hatch Cover Best Practice


Detailed below are straightforward procedures which if followed will help to ensure
that ship's hatch covers remain in good condition.
Always
• Carry out regular examination of the hatch covers, hatch beams and coamings to
identify:

General levels of corrosion


Localised corrosion at welded connections (grooving)
Cracks in joints and weld metals
Permanent distortion of plating and stiffeners

• Call an LR surveyor and carry out repairs as soon as possible when there are:

Indications of excessive corrosion e.g. holes or local buckling of the top plate
Cracks in main structural joints
Areas of significant indentation, other localised mechanical damage

• Be particularly vigilant after heavy weather

• Rectify any steel-to-steel fault before renewal of rubber packing. Renewal will not
be effective if steel-to-steel contact points are defective and expensive rubber
packing will be ruined after only a few months of use

• Replace missing or damaged hatch gaskets immediately. The minimum length of


replaced gasket should be 1 metre.

• Keep hatch coaming tops clean and the double drainage channels free of
obstructions. (Open hatch covers to clean coaming tops and the double drainage
channels after loading bulk cargo through grain or cement ports)

• Keep cleats and wedges in serviceable condition and correctly adjusted

• Keep hauling wires and chains adjusted correctly

• Attach locking pins and chains to open doors and hatches

• Keep wheels, cleats, hinge pins, haul wires and chain tension equipment well
greased

• Test hydraulic oil regularly for contamination and deterioration


• Keep hydraulic systems oiltight

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• Ensure the oil tank of the hydraulic system is kept filled to the operating level and
with the correct oil

• Clean up oil spills. If the leak cannot be stopped immediately, construct a save-all
to contain the oil and empty it regularly

• Engage tween deck hatch cover cleats when the panels are closed

• Give notice when maintenance is being performed so that no one tries to


open/close the hatch being maintained

• Remember that continuing and regular maintenance of hatches is more effective


and less expensive than sporadic inspection and major repair

Never
• Treat temporary repairs as if these were permanent. The strength of the cover
and ultimately the ship will depend on the quality of repairs carried out

• Ignore serious corrosion, cracking or distortion in the covers and supports. These
are signs of weakness and are potentially hazardous

• Allow grooves to form in the coaming top, especially where the hatch side or end
panel rests when the hatch is closed

• Apply petroleum based grease or paint to rubber packing

• Remove the rubber ball from a non-return drain valve

• Use anything other than the recommended hydraulic oil

• Leave cleats unfastened when proceeding to sea

• Attempt to open or close any hatch that has a load or cargo on it

• Open hatch covers at sea unless absolutely essential

• Leave unattended open covers when at sea

• Tighten down the cleats so that the hatch cover is unable to move on the coming
top

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9.4.6 Common false beliefs about hatch covers


Hatch covers are non-load bearing - they are only there to keep the water out.
Hatch covers can be subjected to very high pressure loadings during heavy weather.
This in turn induces significant in-plane stresses in the component plating, girders and
stiffeners.
Leakage is an inconvenience resulting in cargo wetting.
Leakage can, where unchecked, cause serious flooding and ultimately endanger the
ship and its personnel.
Internal cracking at joints, corrosion/cracking in way of welds and distortion of
plating do not affect the hatch cover function.
Such problems change the way a structure works and can significantly reduce the
load carrying capacity.
Hatch covers constructed of high tensile steel are more robust than those made
from mild steel.
This is not the case. A cover constructed from high tensile steel will normally
comprise of thinner plating than one constructed from mild steel.
It is the rubber seal that keeps the water out of the cargo.
The double drainage system is as important in keeping water away from the cargo
and out of the hold.
Renewing a worn rubber seal is all that is needed to keep a hatch weathertight.
Worn rubber is usually the result of worn steel-to-steel contact surfaces or a deformed
structure. Rubber renewal alone is futile unless the steel-to-steel contact surface is
repaired.
The hatch cover side plate when closed should rest on the coaming top.
If the weight of a hatch panel is sufficient to cause distortion of its side plate (hatch
skirt), then landing pads are fitted to the panel to transfer the weight evenly across the
coaming top.
Hatch covers will always leak in heavy weather.
Hatch covers are designed to withstand the rigours of the sea. Provided the cleats
are correctly adjusted, hatch gaskets are in good condition and the construction
material sound, then hatch covers should not leak, regardles of the weather.
Screwing down cleats down hard will ensure weathertightness.
No amount of tightening of cleats beyond their correct position will improve hatch
cover weathertightness. Hatch cover manufacturers usually test for weathertightness
without engaging cleats. The weight of a hatch is sufficient to create the required
gasket compression.
The use of hatch cover tape will ensure watertightness.
The use of sealant tape gives a false sense of security. Hatch cover tape is a short
term temporary measure that can be used to stop water from entering cross or side
joints. However, the prolonged use of tape increases corrosion in the cross joint and
side plate. In bad weather, sealing tape can and does wash off. Even when sealing
tape is used with success a hatch cover will only be weathertight.

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Drain valves are not important, it does not matter if they are blocked.
Drain valves are an essential feature of the double drainage system as they allow
water that has penetrated the hatch gasket (rubber packing) to drain away. If the
valve is blocked or closed, water will spill from the drainage channel into the cargo
hold.
When carrying a cargo on top of a hatch cover it is not necessary to fasten
cleats.
Cleats prevent excessive movement of the hatch covers as the ship bends and flexes
in a seaway. They allow a limited movement to ensure correct contact between the
cover and the coaming, preventing hatch cover damage. Cargo loaded on the hatch
does not secure the hatch cover to its coaming.
Tween deck cleats are not essential because the tween deck covers are not
weathertight.
Cleats on tween deck covers should always be engaged when the covers are closed.
This is because they stop tween deck panels from jumping when a ship pitches,
ensuring maintenance of tween deck strength. When cargo is stowed on a tween
deck panel, the panel must be secured to the ship's structure.
Any rubber gasket can be used provided the gasket fits the channel.
No, use only the gasket type recommended by the hatch cover manufacturer.

9.4.7 Items affecting the validity of the Load Line Certificate


The validity of a given Load Line Certificate is subject to:
• Its five year period of validity not being exceeded
• The certificate being endorsed correctly for annual Load Line surveys having
been satisfactorily carried out
• The ship's current country of registration being the same as that under which
the certificate was issued

The Load Line certificate will become invalid if:


• Any alterations affecting the assignment of freeboards having been made
• The conditions of assignment not being maintained
• The certificate not being endorsed for the Periodical Load Line Inspection
• The structural strength of the ship is deemed to have been lowered to such an
extent that the ship is unsafe to operate at the assigned freeboard

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10 Implementing the IMO Conventions


Member States of IMO are required to adopt new Conventions, or Amendments to
existing Conventions, into the laws of their respective countries.
These Member States are responsible for implementing and enforcing the
requirements of IMO’s Conventions, Resolutions etc. In many cases they control
marine departments who are entrusted with responsibility for conducting surveys of
vessels, investigating casualties, issuing safe manning documents, seafarers’
certificates of competency etc. Some Member States (such as the small island
States) do not have this infrastructure and may entrust these responsibilities to
Classification societies. The Member States or their agents will issue to each vessel
under their control, numerous Certificates that will signify that the vessel is in
compliance with the statutory requirements. These Certificates must be kept valid.
They provide evidence that the vessel is in compliance with the requirements of the
prevailing Conventions.
Classification Societies are responsible for setting standards to which vessels are
constructed, and equipment is fitted, and thereafter maintained throughout their lives.
Ship Operators are responsible for ensuring that their vessels are at all times
operated in accordance with the requirements of IMO and as specified in their trading
certificates.
The Master is responsible for ensuring that operational requirements of the vessel are
discharged safely and with regard to avoidance of pollution.

In certain waters enforcement of the laws will be the concern of the relevant
Coastal State. For example, vessels passing through the English Channel will
come under the jurisdiction of either France or the United Kingdom, even if they
are registered elsewhere and are not calling at ports in either country.

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11 SOLAS Based Surveys


It is a SOLAS 1974 requirement that the hull, machinery and equipment of a cargo
ship be surveyed on completion and thereafter in such a manner that the Flag State is
satisfied that the condition of the ship is satisfactory. Flag States achieve this
through conducting the Cargo Ship Safety Construction (SAFCON), Safety Equipment
and Safety Radio Surveys. This surveys are held in conjunction with the periodical
classification surveys.
Lloyd’s Register is authorised by various Flag States to perform statutory surveys
(including the Cargo Ship Safety Construction, Safety Equipment and Safety Radio
Surveys) on their behalf. On satisfactory completion of the Special (or Renewal)
Survey, the SOLAS associated certificates are issued accordingly. This certificates
are valid for a five year period and are endorsed on completion of the Annual and
Intermediate Surveys. No extension to the five year validity of these certificates is
permitted.

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11.1 Safety Equipment Surveys

Above left an Emergency Escape Breathing Device (EEBD) and above right pyrotechnics, line
throwing appliance and distress signalling device

The requirements for safety equipment surveys, safety equipment to be


installed/provided and the safety equipment arrangements to be fitted onboard ships
is contained in Part 1 Chapters I, II-2 and III of the Convention for Safety of Life at
Sea, SOLAS plus the International Codes for Life Saving Appliances (LSA Code), Fire
Safety Systems (FSS Code) and Fire Test Procedures (FTP Code).

The applicability of the SOLAS requirements has been previously described in section
9.1.3 of these notes and the scope of the safety equipment surveys can be seen from
the Safety Equipment Survey Checklist (see Annex 7).

It is not intended in this section to run through all the requirements of SOLAS, the
LSA, FSS and FTP codes but only to highlight how safety equipment surveys can be
helped to progress more smoothly and to detail the more common deficiencies
resulting in safety equipment related detentions or problems with the validity of a
ship’s Safety Equipment Certificate.

It is worth emphasising at this point, however, that from a review of the Safety
Equipment Survey Checklist it can be seen that although the checklist is relatively
long the items to be examined are in general both simple to examine and
straightforward to test and maintain. It is therefore worth asking the question as to
why in excess of 50% of Port State Control detentions are year on year related to
safety equipment deficiencies?

With effective use of the Safety Equipment Survey Checklist and the Record of Safety
Equipment Fitted Onboard (SE1) as a basis for a continuous maintenance and test

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regime of safety equipment onboard a ship it is fair to conclude that many deficiencies
could be avoided and the number one priority of ensuring the safety of the ship and its
crew would be better ensured. It is a fact that a methodical approach to both
inspection and maintenance of safety equipment is key to ensuring that all the
necessary equipment is present onboard and in good working order. In addition to a
methodical approach it should be ensured that checks by ship’s staff are carried out
as frequently as practical and not just prior to formal surveys.

11.1.1 Preparing for Safety Equipment Survey

Detailed below are examples of ways of preparing for a Safety Equipment Survey,
these will help to smooth the survey process and make it more efficient.

• Take out the life boat equipment for each boat and range it out on deck neatly.
This will make the checking of the inventory against the SE1 more efficient and
also give the surveyor clear access to the necessary spaces within the lifeboat
so that its structural condition can be checked.

• Be prepared to lower all life boats to at least the embarkation deck and
demonstrate use of bowsing tackle and hanging off arrangements. Boats may
be requested to be launched and shown to be fully operational. It should be
noted that sufficient crew members should be adequately trained to launch the
lifeboats so that in the event of injury to any member of the crew the boats can
still be launched. This scenario is quite often simulated during survey by the
surveyor requesting the person initially controlling launching operations to step
back and hand over operations to the remaining crew.

• Place all life jackets together in one cabin.

• Prepare the following information for presentation to the surveyor:


Safety Equipment Certificate
Record of Equipment for the Cargo Ship Safety Equipment Certificate (Form
E)
Record of Safety Equipment Installed (SE1)
Dates of lifeboat drills
Dates when lifeboats were turned out and lowered
Date when rescue boat was turned out and lowered
Dates of renewal or reversing the lifeboat falls
Charts including those for arrival and departure voyages, chart correction
record, pilots sailing directions (inc. area covered followed by name of pilot)
Publications including Admiralty Notices to Mariners (last 12 weeks), Lists of
Lights and Fog Signals, Admiralty Tide Tables, Nautical Almanac for the
current year, International Code of Signals, Navigational Tables, Mariners
Handbook, List of Radio Signals
Compass deviation record book
Liferaft servicing certificates
Liferaft hydrostatic release device servicing certificates

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Fire extinguisher servicing certificates


CO2 extinguishing system and bottles servicing certificates
Exemption certificates issued by the Flag Administration
The Chief Engineer should be prepared and ready to demonstrate to the Surveyor the
efficient working order of any safety related equipment including:

• All fire pumps (especially the emergency fire pump)

• Fire main isolation valves

• Remotely operated tank isolation valves and operating system

• Remote stops of ventilators and pumps

• Ventilation dampers including funnel dampers and any engine room skylight.
The status of funnel dampers (i.e. open/closed) should be indicated at the
operating location and engine room skylights should be gas tight and operable
from both inside and outside the engine room.

• Life boat engines.

• Emergency generator operation and secondary starting arrangements

• Emergency power supply (including condition of batteries and cabling)

• CO2 system alarm

• Smoke, flame and heat detectors (10% of each type fitted)

The list of items detailed above is by no means definitive and details only the most
basic items. The full list of items which will need to be surveyed will depend on the
actual as fitted shipboard arrangements and the type of survey being carried out i.e.
Annual (A), Intermediate (I), Periodical (P) or Renewal (R) survey the Chief Engineer
and Master should prepare accordingly referring to the Safety Equipment Survey
Checklist (see annex 7).

11.1.2 Most Common Safety Equipment Deficiencies

Comprehensive details of all detentions and their causes are recorded by both the
Classification Societies and Port State Control Organisations e.g. Paris MOU (see
Chapter 8). As a result of these records it can be seen that the most common safety
equipment related deficiencies are as a result of basic defects including:

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• Life saving appliances – life boat and life boat inventory defects

• Fire safety measures – fire pump, ventilator, isolating valve, fire hydrant and
engine room remotely operated valve defects

Safety in general – electrical equipment defects

Safety of navigation – charts and nautical publications missing, out of date

Propulsion and auxiliary machinery – cleanliness of main and auxiliary machinery


spaces

11.1.3 Items Seriously Affecting Safety Equipment Certificate Validity

Listed below are serious safety equipment defects which frequently compromise the
validity of a ship’s Safety Equipment Certificate:

• Excessive amount of oil found in bilges and defects with the bilge pumping
arrangements

• Failure of correct operation of the emergency generator, lighting circuits,


batteries and breakers

• Absence, insufficient capacity or serious deterioration of life saving appliances,


survival craft and or launching arrangements

• Absence, non-compliance or serious deterioration of the fire detection system,


fire alarms, fire fighting equipment, fixed fire extinguishing installations,
ventilators, fire dampers or remotely operated tank closing valves

• Absence, non-compliance or serious deterioration of navigation lights, shapes


or sound signals

• Absence or faults affecting the proper operation of the radio equipment for
distress and safety communication

• Absence of corrected navigational charts and other nautical publications

• Inert gas system failure

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11.2 The International Code for the Safe Operation of Ships and for
Pollution Prevention (The International Safety Management (ISM) Code)

11.2.1 History

During the 1980’s members of the International Maritime Organisation (IMO) voiced
concerns over a perceived deterioration in the professionalism of some shipboard
personnel and a reduction in care plus investment on the part of some ship owners
and operators. As a result, in 1989, IMO adopted the first “Guidelines on
Management for the Safe Operation of Ships and Pollution Prevention” (Res.
A647(16)). Following a number of revisions detailed in the following table IMO
adopted the “ISM Code” (Res. A741(18)) in 1993 and incorporated the code into the
SOLAS convention in 1994 through Chapter IX.

The application of the ISM Code was made mandatory to the ships covered by the
SOLAS convention in two phases. In phase 1 (1998) the requirements were made
applicable to Oil Tankers, Chemical Tankers, Liquefied Gas Carriers, Bulk Carriers,
Passenger Ships and High Speed Craft. In phase 2 the requirements of the code
were made mandatory to all the remaining ships required to comply with the SOLAS
Convention. Phase 2 came into force on the 1st of July 2002.

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IMO adopts A647(16) “Guidelines on Management for the Safe Operation of Ships and Pollution
Prevention
1989

1991 A647(16) revised and adopted as resolution A680 (17)

1993 Further revision led to resolution A741(18) – ISM Code

1994 ISM Code incorporated into SOLAS through Chapter IX

1995 IMO adopts resolution A788(19) “Guidelines on implementation of the ISM Code by Administrations”

1998 Phase 1

2002 Phase 2 Code revised A913(22) replaces A788(19)

11.2.2 Background

After more than two centuries of detailed and prescriptive regulation aimed almost
entirely at the integrity and reliability of the ship and its equipment i.e. the technology,
the marine industry realised that 80% of all accidents at sea were caused by human
error. In fact 80% of all accidents at sea could therefore be attributed to the absence
or failure of a management system. The ISM Code, at last, focused the industries
minds on the people and systems used in the operation of ships and established
some minimum standards and goals.

The marine industry had realised that the condition and functioning of a ship and its
equipment was very much dependent on the way in which it was managed and
operated and that to separate condition from management was artificial and
misleading.

The introduction of the ISM code has succeeded in returning responsibility for the
maintenance of the ship and its equipment to where it belongs i.e. to the company –
the decision makers and resource allocators.

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11.2.3 What is the ISM Code

Simply put the ISM code is a model, which enables the development of documented
safety management systems that ensure there is a uniform minimum standard of care
with respect to safety and pollution prevention within all shipping companies both on
land and at sea. For a ship to trade it must be in possession of a valid Safety
Management Certificate (SMC) issued to the ship as a result of the ship’s safety
management system being shown to be effectively implemented onboard. Unlike
most other statutory certificates which stand alone the SMC is only valid if it
corresponds to a relevant, valid, Document of Compliance (DOC) issued to the ship’s
operator as a result of the safety management system being shown to be effectively
implemented ashore in the company’s offices. A copy of the appropriate up to date
DOC must therefore be kept onboard a ship together with the original SMC.

The code is not prescriptive and is therefore not a specification. The code does not
detail how the objectives are to be achieved only what objectives are to be met.
During the early implementation of the code it is fair to say that it was misunderstood.
Many of the safety management systems developed by shipping companies were
excessively documented, overly prescriptive and voluminous in size. These early
systems achieved the goals of the code but in a manner which was both unpopular
with sea staff and unnecessary to fulfil the requirements of the ISM code most
effectively.

As experience in the development and implementation of effective safety


management systems has increased simpler more efficient and more popular
procedures have been produced to meet the objectives of the ISM Code.

11.2.4 Objectives of the ISM Code

To provide an international standard for the safe management and operation of


ships and the prevention of pollution in order to:

• Ensure safety at sea

• Prevent personal injury and


loss of life

• Prevent damage to property


and the environment

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11.2.5 What is a Safety Management System

A safety management system that satisfies the requirements of the ISM Code is a
system of prevention, a system designed to prevent pollution and improve safety. The
safety management system provides confidence that the company is complying with
safety and pollution prevention requirements and is systematically planning and
implementing its activities and operations. In addition the system provides evidence
of the application of controls with respect to safety and pollution prevention, plus
procedures for corrective action in order to prevent the repetition of problems. A
safety management system must include the following functional requirements:

• A safety and environmental policy


• Instructions and procedures to ensure safe operation of ships and protection of
the environment in compliance with relevant international and flag state
legislation
• Defined levels of authority and lines of communication between, and amongst,
shore and shipboard personnel
• Procedures for reporting accidents and non-conformities with the provisions of
the ISM Code
• Procedures to prepare for and respond to emergency situations
• Procedures for internal audits and management reviews

A safety management system does not provide a guarantee that there will never
be another accident or technical defect.

The statement above may appear obvious, but there is an implication in the attitude of
many in the marine industry that certification is some kind of guarantee that this will be
the case. There appears to be a belief that an accident or technical defect or failure
is, per se, irrefutable evidence of the failure of the safety management system. This
attitude reflects a fundamental lack of understanding of the purpose, scope and
limitation of management systems – and the audit process. A management system
audit is not a technical inspection! It probably also reflects a difference in the level of
maturity of the shipping industry in matters of safety and pollution prevention when
compared to the airline and off-shore industries.

The ISM Code recognizes that, where there is risk, eventually something will go
wrong. When it does, it is the job of the management system to respond in a way that
minimises the consequences and identifies improvements that can be made. The
ISM Code also requires risk management comprising of four main activities as follows:

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1. Hazard identification

2. Risk assessment

3. Risk control

4. Performance monitoring

11.2.6 What is Safety?

Safety can be defined as “A perceived quality that determines the extent to which
the management, engineering and operation of a system are free from danger to
life, property and the environment.”

An important word here is perceived. Perceptions of risk and safety are inevitably
subjective and this has some very important implications for design and
implementation of safety management systems.

e.g. Some people feel much happier than others when swinging from a Bosun’s chair
despite the fact that the equipment used and the controls in place may be exactly the
same.

11.2.7 What is risk?

Risk is the function of likelihood (probability or frequency) and consequence


(nature and severity). Simply put, the greater likelihood of an event combined with
greater severity of the consequences of an event then the greater is the risk from the
event.

The development and implementation of a documented management system is,


essentially, an exercise in risk management. The written procedures and work
instructions are the means by which the controls are applied to the previously
identified and assessed risks associated with the company’s processes and
operations. The controls applied are intended to eliminate risk entirely or reduce the
level of risk.

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11.2.8 Risk Management

Risk management can be defined as “The process whereby decisions are made
to accept a known or assessed risk and/or the implementation of actions to
reduce the consequences or probability of occurrence” (ISO 8402:1995/BS 4778)

The ISM Code implies that risk assessment should be undertaken in the development
of plans for shipboard operations (Cl.7), in the preparation for emergencies (Cl.8) and
when reviewing shipboard technical systems plus equipment in order to identify critical
equipment the failure of which may result in hazardous situations (Cl.10.3).

In addition to identifying and controlling risk, the ISM Code requires the safety
management system of a company to be such that it provides for continuous
improvement. System elements that contribute to continual improvement are:

• Safety management skills of company personnel


• Identification of the need for, and the provision of training
• Motivation of the crew
• Reporting and investigation of accidents, hazardous occurrences and non-
conformities
• Internal audits
• Management and shipboard review of the system
• Corrective and preventative action

The above elements if effectively implemented help considerably in achieving the goal
of continual improvement in the safety management system by allowing it to be
adapted and improved in all parts including equipment, documentation and personnel.

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11.2.9 Management System Failures

80% of all accidents in the maritime industry are caused by human error!

Human error is a factor in all accidents!

THE CAUSES OF LOSS

LOSS

Incident

Direct Cause
Unacceptable acts and
Basic Cause conditions

Personal factors
Lack of Job factors
Control
Lack of, or inadequate planning and measurement

Instead of “human error” we should be talking about management system failures.


People do not normally set out to do things badly, dangerously or to damage the ship
and its equipment deliberately. If things do go wrong, the direct cause may be the
action of an individual, but the root cause will always be the failure of one or more
management controls.

The commonly used term “no-blame culture” is often interpreted as meaning that
individuals should no longer be held accountable for their actions. This is dismissed
as a platitude because everyone knows that such a policy will never be applied in the
real world. An organization’s first reaction following a non-conformity or an accident
must not be to seek out and sever the nearest head. The temptation to demonstrate
quickly and dramatically that the incident has been taken seriously and that something
is being done can be very strong. Disciplinary action makes a clear distinction
between those who are said to be guilty and those who are pointing the finger,
sackings put a very comforting distance between the two.

It may be that, following an investigation, the conclusion is reached that someone was
lazy, negligent or incompetent but there are many management system questions to
be answered before such a conclusion is reached. Even if such an outcome is
reached following an investigation we need to ask how that person came to be
employed, whether there was a failure in supervision and why the problem was not
identified during appraisals, training reviews or internal audits. As for the 20% of
accidents caused by technical defects or breakdowns, here too, we should be asking
what were the management system failures that gave rise to them?

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11.2.10 Documentation Design and Control

A safety management system in compliance with the ISM Code is required to be a


formal, documented system for the following reasons:

• It is a means of communication and clarification


• It increases consistency in the conduct of operations and other activities
• It is independent of the people engaged in the activities and permits continuity
• It facilitates the audit of the system
• It assists in the training of the personnel
• It is a record of good practice
• It assists in the management of change
• It is a requirement of the code

However, many people are fearful of paperwork probably because so much of it is


badly designed (cumbersome, time-consuming, difficult to use) and therefore leads to
its completion becoming an end in itself, rather than a tool to facilitate the
achievement of an objective.

It is important to remember that the issue of a certificate means that the system meets
the requirements of the ISM Code. It is not a guarantee that it does so in the most
efficient and least irksome way possible. As stated previously some very over-blown
and inefficient systems have received ISM Certificates!

The design and drafting of instructions, forms and checklists is not as easy as it may
first appear and requires much thought and care. If done well, it will make life simpler,
easier and safer. The more concise a document, the more likely people are to read it,
and the easier it will be to understand. Flow charts and well-designed forms and
checklists can do much to reduce the number and size of the procedures.

The administration of the system will inevitably mean some additional tasks including,
for example, the conduct of internal audits and system reviews. If the system results
in a significant increase in the amount of work then it is likely that the company is now
doing things that it should have been doing before, but wasn’t, provided of course that
the increase is not the result of duplication or excessive requirements.

A straightforward review and approval process is essential for the efficiency of the
safety management system. To concentrate document authorization in one very
senior position, for example, is to invite delay. It may be better to approve documents
at lower levels more directly associated with the activities concerned plus the flexibility
of one or two alternative signatories. This also has the added advantage of increasing
the sense of ownership of those responsible for implementing the procedures.

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In some systems, “work instructions” may be issued by lower management and


supervisory levels, for immediate implementation. These are then collected and
presented at the next management review meeting for approval and inclusion in the
main system documentation. This permits a very flexible and rapid response to
changing circumstances without the need to amend and distribute whole manuals or
sections on every occasion. It also avoids the inflexibility that arises from allowing
proposed amendments to accumulate before it becomes administratively worthwhile
to issue revisions. Whether or not such an arrangement is suitable is ultimately
dependent on the nature of the activities and the structure of the organization.

The flow of information in a good safety management system should be continual


between the company’s seaman and the company’s senior managers via the ship’s
master and company’s Designated Person Ashore (DPA). Information should flow
from formal and informal sources at all levels, both ashore and onboard, up through
departmental managers and the master, through the DPA and on up to the senior
management. All employees should be encouraged to contribute in ways appropriate
to their position and activities. They should be encouraged to think critically about
what they are doing and how they do it.

Equally important is the flow of information from senior management down. Having
encouraged people to contribute, the company should ensure they receive a
response, even if only to explain why a suggestion or a recommendation has not been
implemented. If their contributions are ignored they will soon lose interest.

It should be noted that because there is a requirement that the DPA has “access to
the highest level of management”, the company’s senior managers may be assumed
to know what the DPA knows.

11.2.11 Verification and Certification

Compliance with the ISM Code is a statutory requirement and therefore like all other
statutory codes and conventions compliance is verified by representatives of either
the flag administration or a Recognized Organization (RO) acting on behalf of the flag
administration. Whether the verification of compliance with the requirements of the
ISM Code is actually carried out by the flag administration or by the RO is dependent
on the individual administration concerned and whether or not they have delegated
their ISM verification activities to a specific RO. Classification Societies such as LR
are often authorised to act as an RO but their representatives must always confirm
that they are actually authorised to carry out the ISM verification onboard the ship
concerned paying regard to the flag it is flying.

As stated previously, unlike other statutory certification, ISM requires the issuance of
two certificates i.e. The Document of Compliance (DOC) to the shipping company
and the Safety Management Certificate (SMC) to the ship. Verification of the correct
implementation of the safety management system for issuance/endorsement of the
ISM related certificates is carried out via an audit regime.

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Documents of Compliance (DOC’s) are issued to companies following initial


verification of compliance with the requirements of the ISM Code. A DOC is valid for
5 years, subject to an annual (+/- 3 months) Periodic Verification Audit (PVA).
The issue of the DOC to a company must at least have been recommended before a
company ship may be audited for the issue of a Safety Management Certificate
(SMC). It should be noted that only the issuing administration may withdraw a DOC
or SMC.

Safety Management Certificates (SMC’s) are issued to ships following initial


verification of compliance with the requirements of the ISM Code. An SMC is valid for
5 years, subject to at least one Intermediate Verification Audit (IVA). An SMC is
automatically withdrawn when the corresponding DOC is withdrawn.

Although we talk about an SMC being issued to a ship, and the certificate has the
ship’s name on it, strictly speaking, it is not a ship’s certificate in the same way that
other statutory certificates are. The SMC refers to the effective operation of a
company’s management system onboard a referenced ship. Hence, if the ship
concerned leaves a company to be operated by another, the original SMC becomes
invalid the day the company changes. The new operating company’s management
system must then be audited on the ship concerned to see that it is running effectively
onboard for the issue of a new SMC certificate.

Interim ISM certificates may be and are issued to new companies and their ships,
ships brought under new management of an existing company (requiring an Interim
SMC), or an existing company that enters into the management of a ship type not
included in its existing certified safety management documentation (requiring an
interim DOC and an interim SMC).

Interim ISM certification is issued following interim verification. This level of


verification has the purpose of solely establishing the existence of a documented
safety management system which is in the process of being fully implemented. An
Interim DOC may be valid for up to 12 months and an Interim SMC normally valid for
up to 6 months. In special circumstances the validity of an Interim SMC may be
extended for a further 6 months. The periods of validity of the Interim certificates
allows the safety management system to run so that when the Initial Audit for either
the issue of the full term DOC or SMC is carried out there is sufficient evidence to
show it has been operating effectively.

The purpose of the initial audit is to establish the existence of a system that complies
with the requirements of the ISM Code, that the system is understood by those who
operate it and that it is being fully implemented. In most cases by the time of the initial
audit the existing records are only sufficient to demonstrate that the system is in
operation. Furthermore, experience has shown that the first verification audit does
little more than reassure the auditor there has been no relaxation in the
implementation of the system after the considerable effort involved in putting the

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system into place. It is in the audit of the more mature systems that the effective audit
will show the requirement for continual improvement being achieved by highlighting
areas that have been identified for more attention and how changes have been made
to the system itself.

Initial Annual PVA DOC Renewal


(+/- 3 mths) (up to -3

YEARS

0 1 2 3 4 5

Initial SMC Renewal


Single IVA (up to -3

YEARS

0 1 2 3 4 5
ISM Audit Regime

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11.2.12 Maintenance of the Safety Management System

Having obtained certification following DOC and SMC audits followed by one or two
Periodical Verification Audits (PVA’s) many companies feel they know exactly what to
expect from a safety management system assessment. However, if audits are done
well, the emphasis during the audit of a more mature system will be quite different
from that of an initial or early verification audit.

It should be noted that certification is by no means the end of the process. A safety
management system must be “alive” and must adapt to changing requirements of the
company, developments in technology and operational practice, and changes in the
regulatory environment in which it operates. The system must be maintained by a
process of continual improvement.

11.2.13 ISM Terminology

Administration. The government of the state whose flag the ship is entitled to fly.

Company. The owner of the ship or any other organization or person such as a
manager, or the bareboat charterer, who has assumed responsibility for the operation
of the ship from the shipowner and who, on assuming such responsibility, has agreed
to take over all the duties and responsibility imposed by the code.

Non-conformity. An observed situation where objective evidence indicates the non-


fulfilment of a specified requirement.

Major Non-conformity. An identifiable deviation that poses a serious threat to the


safety of personnel or ship or a serious risk to the environment that requires
immediate corrective action and includes the lack of effective and systematic
implementation of a requirement of the ISM Code.

During the audits a number of non-conformities may be issued by the auditor. Many
people live in fear of non-conformities. In fact they are nothing more than
discrepancies between what is required and what is done and requires attention. In
themselves they have no impact on the certification although a situation can arise in
which a number of non-conformities are brought together to create a major non
conformity. A single major non-conformity prevents the issue of a new certificate or
the endorsement of an existing certificate.

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