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The scope of the Marine Information Notice publication is to provide the Shipping Sector with information relevant to RINA, its organization, initiatives and services as well as to disseminate information of a general nature which in RINA view may be of interest. The information provided does not intend to be exhaustive and is given for reference only.

DIRECTIVE 2009/45/EC APPLICABLE TO PASSENGER SHIPS AND CRAFT

Directive 2009/45/EC, applicable to passenger ships and craft, regardless of their flag when engaged on domestic voyages in the water of a EU Member, has been amended by directive 2010/36/EC. According to article 2 of this Directive Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with this Directive within 12 months of its entry into force at the latest. It is to be noted that the date of entry into force of the Directive was the 29 June 2010 but still, to date, there are Members that did not implement it in their national legislation.

IN THIS ISSUE:
Directive 2009/45/EC applicable to Passenger Ships and Craft

The present Circular provides a brief explanation of the major modifications introduced by the new text; amendments that shall be retrospectively applied are highlighted by the wording Retroactive amendments. As may be easily deducted by the text provided, for some new items (or modification of existing requirements) it has been found necessary to seek clarification or guidance by the Flag Administrations for their harmonized application; A subsequent Marine Information Note will provide further clarifications on these items.

For further information please contact: Ignazio Mul Marpol- IBC- IGC and Environmental Issues RINA Services SpA - Marine Division - Technical Services Via Corsica, 12 - 16128 Genova - ITALY Phone: +39 010 5385240 Fax: +39 010 5351450 e-mail: ignazio.mul@rina.org

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ANNEX COMPARISON BETWEEN DIRECTIVES 2010/36/EC AND 2009/45/EC

GENERAL Reference to SOLAS and other international instruments vs new passenger ships The definition of SOLAS given in article 2(a) has been slightly amended by inserting the wording as amended (similar amendments have been introduced for other international instruments such as the FSS Code , FTP Code, etc). The definition of new ship given in regulation 2(h) refer to ships built on or after 1 July 1998. Compliance with SOLAS 1974 as amended is requested in different parts of the Directive (e.g. in article 6.2(a) for Class A ships). Article 10.1 specifies which references to international instruments may be adapted in order to take into account of developments at international level. Considering the above, RINA understanding is that the reference to SOLAS 1974 as amended , as well to its ancillary Codes, should not be intended as to constitute a continuous updating of ships (i.e. those built on or after 1 July 1998) to catch up with the amendments to the Convention, unless these amendments are explicitly requested to be applied retrospectively to existing ships (where existing would have the meaning in line with the SOLAS amendments concerned); in this case, the applicability of these retroactive amendments to ships other than Class A ships should be specifically discussed with the Flag Administration. This approach seems consistent with the content of Annex I, General Provisions, paragraph 8 and will be applied unless otherwise instructed by the concerned Administration. Reference to IMO resolutions Similarly to what described in A), above, the reference to various IMO resolutions has been updated by adding the wording as amended (e.g. regulation II-1/B-2/1, regulation II-2/B/6-1.1.4). Also in this case RINAs opinion is that the sentence as amended means that the amendments to a specific resolution are applicable to ships built on or after the date such amendments entered into force and should not be intended, unless specified, as applicable retrospectively. Also in this case, the above approach is consistent with the content of Annex I, General Provisions, paragraph 8. ARTICLES OF THE DIRECTIVE Article 6(1)(c) (RETROACTIVE REQUIREMENTS) The text of this article (applicable to new and existing ships) has been revised as follows: i) the wording as amended in respect to SOLAS 74 has been replaced by in its up-to-date version. It appears the new wording has not a different meaning than the previous one; ii) the compulsory application of reg. V/12 given in directive 2009/45 has been replaced by a reference to regulations V/17, 18, 19, 20 and 21. The application of these new requirements deserves some discussion; in fact, the amendment appears to introduce retroactive requirements whose application is not clearly regulated. The attached file Excel provides a comparison between SOLAS regulations V/17, 18, 19, 20 and 21 and former regulations V/11, 12, 20 and 21. As it can be seen from such a file, for some items guidance from the Flag Administration is needed. Article 2 (c) The definition High Speed Craft Code has been implemented with the addition of the mention to the HSC 2000. Similarly, the reference to the HSC

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Code, 2000 (entered into force on 1 July 2002) has been added to any other article where the HSC Code, 1994 was originally referred to. Article 12 (4) As far as procedures and guidelines for surveys for the Passenger Ship Safety Certificate are concerned, the reference to resolution A.746(18) has been modified to resolution A.997(25). The main difference between the two pieces of legislation is the schedules for dry-docking, as the latter resolutions requires for passenger ships a A minimum of two of the inspections of the outside of the ships bottom during any five-year period should be conducted in dry-dock. In all cases, the maximum interval between any two dry-dock bottom inspections should not exceed 36 months.

ANNEX I
General Provisions (applicable to new and existing ships as indicated in the various requirements) Sentences have been numbered and new requirements/clarifications have been added as indicated below. It is assumed that the references to regulations of Chapter II-1 Part B mentioned in paragraphs 2. and 5. should be read as related to Part B-2 (as it is understood that the reference to Part B has been left from the previous text of the Directive). Paragraph 5: in addition to the possible relaxation to certain requirements of Annex I stated in paragraph 2., this paragraph indicates that new Class B, C and D of less than 24 m may also not be required to conform to a number of requirements provided that the Flag Administration of the concerned ships ensures that they comply with the flag States national rules and that such rules guarantee an equivalent level of safety class. The requirements mentioned in both paragraphs 2. and 5 are listed hereinafter for ease of reference: - II-1/B-2/2 Watertight subdivision; - II-1/B-2/3 Floodable length; - II-1/B-2/4 Permissible length of compartments; - II-1/B-2/5. Permeability; - II-1/B-2/6 Subdivision factor; - II-1/B-2/7 Special requirements concerning ship subdivision; - II-1/B-2/8 Stability in damaged conditions; - II-1/B-2/10 Double bottoms; - II-1/C/4 Number and type of bilge pumps; - II-1/C/9 Communication between the navigating bridge and machinery space; - II-1/C/10 Engineers alarm; and - II-1/E all the regulations (pertinent to periodically unattended machinery spaces) Paragraph 6: Class D ships not extending their voyage outside of Sea Area A 1 (see SOLAS Regulation IV/2.12) need not to comply with the carriage requirements in Chapter IV Radiocommunications of the 1974 SOLAS Convention, but shall at least comply with the provisions in Chapter IV of Annex I. Paragraph 7 (RETROACTIVE REQUIREMENTS): The application of the requirements relevant to navigation bridge visibility set out in SOLAS Regulation V/22 has been extended to ships of less than 55 meters in length, as reasonable and practicable. Paragraph 10: the original explanation for the reference to SOLAS regulations (R) showed in several titles of regulations in the Annex has been expanded

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to provide a further clarification on which SOLAS amendments the referred (SOLAS) regulations belong to. Paragraphs 11 and 12: it is worth to recall that article 6.2(a) of the Directive specifies that new passenger ships of Class A shall comply entirely with the requirements of the 1974 SOLAS Convention, as amended, and with the specific relevant requirements specified in this Directive;. These paragraphs list those regulations in Annex I in which requirements applicable to said ships may be found, specifically: - Chapter II-1/A-1, Regulation 1, 17-2 and 20 (the last two for ro-ro ships); - Chapter II-1/B, Regulations 1, 23 and 24; - Chapter II-1/C, Regulations 1, 3, and 16; - Chapter II-2/A, Regulations 4, 9 and 12, and - Chapter II-2/B, Regulation 6.

CHAPTER II-1 PART A-1 STRUCTURE OF SHIPS

A new Part A-1 has been added to include the requirements explained hereinafter. Regulation II-1/A-1/1 New installation of materials containing asbestos applicable to all ships: newly installed materials for the structure, machinery, electrical installations and equipment covered by Annex I shall not contain asbestos. The text of this requirement is the same as the one used in SOLAS regulation II-1/3-5. In this context, reference can be made to IMO MS/Circ. 1379, providing an interpretation on the term "new installation of materials containing asbestos". Clarifications are also provided by IACS Unified Interpretation SC 249 that can be downloaded at www.iacs.org.uk; according to this UI SC 249, in this respect In this respect it is particular important to note that; i) asbestos-free declarations and supporting documentation are to be provided for any new structure, machinery, electrical installations and equipment covered by the SOLAS Convention for: - new construction (keel laid, or at a similar stage of construction, on or after 1 July 2012); - conversions (contract date for the conversion or, in the absence of a contract, the date on which the work identifiable with the specific conversion begins) on or after 1 July 2012; ii) the phrase new installation of materials containing asbestos in MSC.1/Circ.1379: - means that material used (i.e., repaired, replaced, maintained or added) as a working part of the ship as per Annex 1 which is installed on or after 1 July 2012 is required to be documented with an asbestosfree declaration; and - does not preclude the stowage of material which contains asbestos onboard (e.g., spare parts existing on board as of 1 July 2012). iii) the phrase should not be permitted to be installed after 1 January 2011 as a working part in MSC.1/Circ.1379 means that replacement, maintenance or addition of materials used for the structure, machinery, electrical installations and equipment covered by the SOLAS Convention is prohibited Regulation II-1/A-1/2 Construction drawings maintained on board and ashore Applicable to class B, C and D ships constructed on or after 1 January 2012. A set of as-built construction drawings and other plans showing any subsequent structural alterations shall be kept on board ships as well as ashore by the Company, as defined in Regulation IX/1.2 of the 1974 SOLAS Convention. The list of such drawings is given in IMO MSC/Circ.1135 on As-

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built construction drawings to be maintained on board the ship and ashore. It should be noted that this requirements applies regardless the length of the ship being considered. Regulation II-1/A-1/3 Towing and mooring equipment Applicable to class B, C and D ships of 24 m in length and above constructed on or after 1 January 2012. Ships shall be provided with arrangements, equipment and fittings to enable the safe conduct of all towing and mooring operations associated with the normal operation of the ship. Each fitting or item of equipment provided shall be clearly marked with any restrictions associated with its safe operation, taking into account the strength of its attachment to the ships structure.

PART B-1 INTACT STABILITY, SUBDIVISION AND DAMAGE STABILITY

A new Part B-1 has been added to indicate that as an alternative to the requirements set out in Part B-2 (referring to intact and damage stability and related constructional requirements) the content of Annex 2 to resolution MSC.216(82) [containing the amended full text of Part B of Chapter II-1 of SOLAS 74] may be applied to Class B, C and D ships the keel of which was laid on or after 1 January 2009, or which were at a similar stage of construction on that date (the date indicated is the date of the entry into force of the mentioned amendment to SOLS 74). The adoption of one requirement (Part B-2 of the Directive OR Annex 2 of resolution MSC.216(82)) is to be left to the Parties concerned (designer, yard, owner) unless requested otherwise by the Flag Administration. It is noted that both the references to resolution MSC.216(82) and Part B-2 do not render the application of the new Intact Stability Code (resolution MSC.267(85) mandatory.

PART B-2 INTACT STABILITY, SUBDIVISION AND DAMAGE STABILITY

Regulation II-1/B-2/1 Intact stability Resolution A.749(18) as amended by Resolution MSC.75(69) A new sentence had been added in respect to ships of class A, B, C and D ships of 24 m in length and above constructed before 1 January 2009: intact stability shall comply with the Intact Stability code contained in resolution A.749(18) as amended by resolution MSC.75(69). Although there is a difference in the reference to resolution A.749(18) between the title (amended by resolution MSC.79(69)) and the text (as amended) it is taken for granted that the new Intact Stability Code (MSC.267(85) entered into force on 1 January 2010) is not applicable. Regulation II-1/B-2/18 Stability information Two amendments have been introduced to this regulation: i) paragraph .4: as far as the exemption for carrying out the inclining test for sister ships is concerned, it has been added a reference to MSC/Circ. 1158 (whose application is then meant to be mandatory). It should be noted that the content of MSC/circ 1158 had been accommodated in the IS Code (resolution MSC.267(85)) except for a simple sentence providing details on ship's data to be included in the stability booklet of a ships for which the results of the inclining test of a sister ship had been taken. This sentence (in MSC/Circ 1158) reads "Where the deviation is within these limits the actual lightship weight and longitudinal centre of gravity derived from the lightship check should be used in conjunction with the higher of either the lead ships vertical centre of gravity or the calculated value.". This means that, according to the circular, all ship's data from the sister ship shall be taken except for those details indicated (lightship and LCG that are the ones of the ship being considered). Instead, by applying the IS Coode as written, in case of a sister ship ALL the data

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to be reported in the stability booklet may come from the inclining experiment carried out on the prototype. It is deemed that the IS Code provides the most correct approach to the matter but confirmation by Flag Administrations will be sought. ii) Regulation II-1/B-2/18 paragraph .5: this new paragraph has been added to allow (in special cases) the determination of displacement and centre of gravity shall be determined by a lightweight survey and accurate calculation rather than an inclining test. Although the paragraph makes reference to the information contained in Regulation 2.7 in the High Speed Craft Code 2000, as written, it may be applicable to other ship types.

PART C MACHINERY
Regulation II-1/C/12 Machinery controls The numbering of the various paragraphs has been revised and a new paragraph 9 has been added. This paragraph applies to class B, C and D ships constructed on or after 1 January 2012 of 24 metres in length and over and requires that the automation systems are to be designed in a manner which ensures that threshold warning of impending or imminent slowdown or shutdown of the propulsion system is given to the officer in charge of the navigational watch in time to assess navigational circumstances in an emergency. Other details are provided in the text.

PART D ELECTRICAL INSTALLATIONS

Regulation II-1/D/2 Main source of electrical power and lighting A new paragraph 4 has been added. This paragraph applies to class B, C and D ships constructed on or after 1 January 2012 and requires the fitting of supplementary lighting in all cabins to clearly indicate the exit. Such lighting, which may be connected to an emergency source of power or have a selfcontained source of electrical power in each cabin, shall automatically illuminate when power to the normal cabin lighting is lost and remain on for a minimum of 30 min. Regulation II-1/D/3 Emergency source of electrical power Two amendments have been introduced to this regulation: i) paragraph 1: a new subparagraph has been added to this paragraph (that is applicable to new class B, C and D and existing class B ships) indicating that if a ship is designed with two fully redundant machinery spaces, separated by at least one watertight and fire-safe compartment and two bulkheads or an alternative construction giving the same level of safety, and that there is at least one generator with an associated switchboard etc in each machinery space, the installation of a self-contained emergency source of electrical power with emergency switchboard is not required. Being this a relaxation to the compulsory installation of an emergency source of electrical power, the retroactivity of this new requirement is not expected to create problems; ii) paragraph 5.2(b)1: (applicable to new class B, C and D and existing class B ships) it has been specified that the location of emergency lighting at assembly or embarkation stations and over the sides is to fulfill Regulation III/5.3. Regulation II-1/D/5 Precautions against shock, fire and other hazards of electrical origin A new paragraph 10 has been added. This paragraph applies to class B, C and D ships constructed on or after 1 January 2012 and specifies that no electrical equipment can be installed in any space where flammable mixtures are liable to collect, such as batteries rooms, paint lockers, acetylene stores

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or similar spaces, unless the justifications and precautions listed in the paragraph itself are met.

CHAPTER II-2 PART A FIRE PROTECTION, FIRE DETECTION AND FIRE EXTINCTION
Regulation II-2/A/2 Definitions The definition of the FTP Code provided under paragraph 24 makes reference to resolution MSC.61(67) as amended. This explicitly renders the application of the new FTP Code (resolution MSC.307(88)) mandatory (where it is clearly referred to in the various regulations) . It is worth to recall that article of the new FTP Code provides a framework for issuing new certificates on the basis of fire tests conducted in accordance with the previous version of the Code. Regulation II-2/A/6 Fire-extinguishing arrangements in machinery spaces (RETROACTIVE REQUIREMENTS): Two amendments have been introduced to this regulation: i) paragraph .4 (applicable to new class B, C and D of less than 24 m and existing class B ships) has been slightly amended by addinding the possibility of substituting the 45 l fire extinguishers by fire extinguishing using other media. It should be noted that the rephrased sentence also allows the fitting of portable foam extinguisher of total aggregate of 45 l. ii) existing paragraph .9 has been deleted as the requirement for the fitting of the fixed local application fire-fighting system on new class B, C and D ships constructed before 1 January 2003 and in existing class B ships has been merged into the title of paragraph 8. However, this change seems to have excluded existing class C and D ships certified to carry more than 400 passengers to be fitted with such a system; confirmation on this latter understanding need to be sought to Flag Administrations. Regulation II-2/A/10 Arrangements for oil fuel, lubricating oil and other flammable oils (RETROACTIVE REQUIREMENTS): In paragraph 5 two subparagraphs have been introduced for requiring: i. ships constructed on or after 1 January 2012 having a gross tonnage of less than 500, fuel tanks above the double bottom shall be fitted with a cock or valve; and ii. for ships constructed before 1 January 2012 having a gross tonnage of less than 500 the cock or the valve mentioned in the first paragraph shall also be fitted in fuel tanks having a capacity of less than 500 litres and situated above the double bottom, not later than the first periodical survey on or after 1 January 2012. The correct application of this retroactive requirement deserves some discussion. As the title of the section of regulation containing the subparagraph under discussion refers to NEW CLASS B, C AND D AND EXISTING CLASS B SHIPS it is understood that this particular retroactive requirement applies to - class C and D ships (GT not less than 500) constructed between 1 July 1998 and 1 January 2012 (new class C and D ships); and - class B ships (GT not less than 500) constructed before 1 January 2012. This understanding will be applied, unless otherwise instructed by the Administration. Regulation II-2/A/12.10.1 Miscellaneous items In subparagraph the reference here to ISO 15371:2000 used here is not in line with the MED (where the most updated standard referred is ISO 15371:2009). However, MED certification is not compulsory for ships subject

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to the Directive under discussion, unless otherwise determined by the Flag Administration. Regulation II-2/A/13 Fire control plans as far as the preparation of Fire Control Plan is concerned, the reference to resolution A.654(16) has been replaced by resolution A.952(23), containing the IMO symbols to be used in preparing such plans. Regulation II-2/A/14 Operational readiness and maintenance Existing paragraph 1.2 generically specified that maintenance, testing and inspections of fire-fighting equipment were to be carried out based on the guidelines developed by IMO; this generic sentence has bee replaced by a direct reference to based on the guidelines in IMO MSC/Circ.850. Therefore, unless otherwise stated by the Flag Administration, the content of such circular is meant to be regarded as mandatory.

PART B FIRE SAFETY MEASURES

Regulation II-2/B/6 Means of escapes For existing class B ships, while the previous text of paragraph 4 indicated that a corridor, or part of a corridor from which there is only one route of escape shall not exceed 5 metres in length the amended text contains some relaxation on this very same requirement in that now specifies a corridor, or part of a corridor from which there is only one route of escape , shall not exceed: - 5 metres in length for ships constructed on or after 1 October 1994, - 13 metres in length for ships constructed before 1 October 1994, carrying more than 36 passengers, and - 7 metres in length for ships constructed before 1 October 1994, carrying not more than 36 passengers. Therefore, for existing class B ships already certified according to the Directive, the entry into force of this retroactive requirement should not create any problem. Regulation II-2/B/16 Upgrading of existing class B ships carrying more than 36 passengers Being all of them already passed, the implementation dates previously present in the text have been deleted. Therefore, an existing ship to be registered under class B shall immediately satisfy the requirements set out in this regulation. Regulation II-2/B/16 Special requirements for helicopter facilities The normative reference has been changed to Regulation 18 of Part G of the SOLAS Chapter II-2, as revised per 1 January 2003 (instead of SOLAS Convention Chapter II-2, as amended).

CHAPTER III LIFE SAVING APPLIANCES

Regulation III/1 Definitions The definition of the LSA Code has been introduced, i.e. Resolution MSC.48(66), as amended. Regulation III/2 Communication, survival craft and rescue boats, personal life-saving appliances As for the previous version, this regulation is applicable to new and existing class B, C and D ships.

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Different changes/modifications have been introduced in the text as explained in the followings: i) all paragraphs have been numbered (the existing ones correspond to new paragraphs 1, 2, 3, 4 and 6); ii) in the existing paragraph 2 it has been introduced the necessity for life saving appliances to comply with (along with SOLAS Chapter III) the LSA Code, unless provided otherwise in the Chapter; moreover, it has been clarified that existing equipment shall at least comply with the provisions that were in force at the time of installation of the equipment. There no need for replacing existing equipment due to the entering into force of this amendment; iii) paragraph 3 (addressing the installation of immersion suits and thermal protective aids) have been totally redrafted by clearly specifying the criteria governing the number of such equipment to be installed on board; however, ships constantly engaged on voyages in warm climates may be exempted by this requirement, having regard to the recommendations in IMO MSC/Circ.1046. The regulation does not specify any timetable for satisfying the above therefore its compliance shall be verified at the first survey. Where the equipment are not found on board, the shipowner shall get the exemption from the Flag Administration; iv) paragraph 4 has been redrafted to indicate that immersion suits and the requirements for thermal protective aids to be accommodated in totally enclosed life boats also apply to partially or totally enclosed lifeboats not complying with the requirements in section 4.5 or 4.6 of the LSA Code, provided they are carried on ships constructed before 1 July 1986; v) a new paragraph 5 has been added. This paragraph requires an immersion suit or an anti-exposure suit to be provided for every person assigned to crew rescue boats or assigned to the marine evacuation party; however, ships constantly engaged on voyages in warm climates may be exempted by this requirement, having regard to the recommendations in IMO MSC/Circ.1046. Also the table annexed to this regulation has been updated has briefly explained in the followings: the wording Number of passengers (P) has been added beside the existing Number of persons (N); the requirement Infant life jackets has been added; footnote (1): the main change is in the first sentence where, in respect to the type of LSA being used, the reference to the LSA Code has been replaced by a reference to the provisions of regulation III/2.2.; footnote(3): the text has been slightly rephrased but is content is basically the same except for the addition of the requirements imposing that if the stowage requirement for life rafts, in Regulation III/7.5 is not complied with, additional life rafts can be required. The very same requirement is better explained under said regulation III/7.5; footnote (5): the first sentence has been changed; the new one indicates that launching appliances for rescue boats shall comply with the requirements of Regulation III/10. footnote (6): the text has been totally revised to indicate that an inflatable lifejacket (that may be included in the total number of lifejackets on board) shall be provided for each person that has to carry out work on board in exposed areas (former footnote (9); footnote (9): is now relevant to the minimum number of lifejackets for children to be fitted on board; NEW footnote (10) (RETROACTIVE REQUIREMENTS): specifies the minimum number of lifejackets for infant to be carried on board;

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NEW footnote (11) (RETROACTIVE REQUIREMENTS): is relevant to the number and location of lifejackets for persons on watch and for use at remotely located survival craft stations. This requirement shall be complied with not later than the first periodical survey after 1 January 2012; NEW footnote ( 13 ) (RETROACTIVE REQUIREMENTS) requires that each life jacket shall be fitted with light complying with the requirements of paragraph 2.2.3 of the LSA Code. All ro-ro passenger ships shall comply with the provisions in Regulation III/5.5.2. These requirement shall be complied with not later than the first periodical survey after 1 January 2012.

Regulation III/3 Emergency alarm system, public address system, assembly list and emergency instructions, radio communication personnel, operating instructions, training manual and instructions for maintenance (RETROACTIVE REQUIREMENTS) Some amendments have been introduced as follows: i) the last sentence of paragraph 1, applicable to new class B, C and D ships constructed on or after 1 January 2003, that originally required the general emergency alarm systems to be audible on all open decks with the minimum sound pressure levels in accordance with paragraphs 7.2.1.2 and 7.2.1.3 of the LSA Code, had been amended to extend to all the accommodation and normal crew working spaces. It is noted that this regulation does not provide any timeframe for the fulfillment of the new requirement. Instructions by Flag Administrations will be sought; ii) in subparagraph .2 of paragraph 2,4 (dealing with the PA system and applicable to new class B, C and D ships, the generic reference to recommendations adopted to IMO in respect to the performances of the PA systems has been changed to IMO MSC/Circ 808. Based on the text of paragraph 2.6 (indicating that Existing ships which are already fitted with the public address system approved by the Administration of the flag State which comply substantially with those required by paragraph .2.2,.2.3 and .2.5 are not required to change their system) no changes should be needed for those systems fitted on ships built between 1 July 1998 and the date of entry into force of Directive 2010/36/EC, unless otherwise provided by the Flag Administration. iii) in paragraph 3 (applicable to new class B, C and D ships) the reference to resolution A.691(17) in respect to the instructions to be provided for every persons on board in case of an emergency has been replaced by a direct reference to SOLAS regulation III/8 stating the following: Regulation 8 Muster list and emergency instructions 1 This regulation applies to all ships. 2 Clear instructions to be followed in the event of an emergency shall be provided for every person on board. In the case of passenger ships these instructions shall be drawn up in the language or languages required by the ship's flag State and in the English language. 3 Muster lists and emergency instructions complying with the requirements of regulation 37 shall be exhibited in conspicuous places throughout the ship including the navigation bridge, engine-room and crew accommodation spaces. 4 Illustrations and instructions in appropriate languages shall be posted in passenger cabins and be conspicuously displayed at muster stations and other passenger spaces to inform passengers of : .1 their muster station ; .2 the essential actions they must take in an emergency ; and

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.3

the method of donning lifejackets.

iv) a new paragraph 3a Radio communication personnel has been added (by including the last paragraph of the existing paragraph 3). This new paragraph requires: for new and existing class B, C and D ships, every ship to carry personnel qualified for distress and safety radiocommunication purposes (the personnel shall be holders of certificates specified in the Radio Regulations as appropriate, any one of whom shall be designated to have primary responsibility for radiocommunications during distress incidents, which shall be reflected in the emergency instructions) and for new and existing class B and C ships, at least one person qualified as per above shall be assigned to perform only radiocommunication duties during distress incidents, which shall be reflected in the emergency instructions;

v) in paragraph 4, subparagraph (iii), the wording as amended by resolution MSC.82(70) has been added after the reference to Resolution A.760(18).. Regulation III/5 Survival craft assembly and embarkation arrangements (RETROACTIVE REQUIREMENTS) The field of application of paragraph 8 has been changed from new class B, C and D ships to new and existing class B, C and D ships making then the requirements contained therein retroactive; therefore, all ships shall be provided with at least one embarkation ladder, complying with the requirements of paragraph 6.1.6 of the LSA Code on each side of the ship unless otherwise determined by the Administration taking into account the criteria set out in the paragraph. As per other cases already described, the text of this requirement does not provide any timeframe for the fulfillment of the new requirement. Instructions by Flag Administrations will be sought. Regulation III/5-1 REQUIREMENTS) Requirements for ro-ro passenger ships (RETROACTIVE

The entire text of this regulation has been editorially revised. In addition, a new paragraph 2 Transponders has been added to require liferafts carried on all class B ro-ro ships not later than the date of the first periodical survey after 1 January 2012 to be fitted with a radar transponder in the ratio of one transponder for every four liferafts. Details of such arrangement are also provided. Regulation III/5-2 Helicopter landing and pick-up areas The entire text of this regulation has been revised and the following considerations are provided: i) as far as the approval of the arrangement of the helicopter pick-up area on new and existing class B, C and D ro-ro ships is concerned, the former text made reference to resolution A.229(VII) while the new text makes reference to Resolution A.894(21), as amended. In RINAs opinion, unless otherwise instructed by the Flag Administration, pickup areas already approved in accordance with Directive 2009/45/EC need not to be re-approved; ii) the same understanding is applicable to helicopter landing areas already fitted on new ro-ro passenger ships of class B, C and D of 130 metres and upwards. Regulation III/13 Abandon ship training and drills Two amendments have been introduced: i) under paragraph 3, a reference to MSC.1/Circ.1206 Measures to prevent accidents with lifeboats has been added to SOLAS Regulation III/19.3.3.1 in respect to abandon ship drills; and

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ii) under paragraph 4, precautions to be taken when lifeboat and rescue boat launching drills are carried out with the ship making headway have been added.

CHAPTER V RADIO COMMUNICTIONS

(RETROACTIVE REQUIREMENTS) This Chapter, consisting in a single regulation, is applicable to class D ships. As written, it is understood that it addresses all (new and existing) class D ships. It requires the fitting of means of communications, such as .1.1 A VHF radio installation, DSC and radiotelephony. Further details are also provided. No timeframe for the installation of such means (if not already present on board) and therefore, guidance need to be sought to Flag Administrations. Attachment: Navigational Equipment Comparison between Dir. 2009/45 and 2010/36

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