What happened at the recently concluded SSE 9 sub-committee at IMO?

Published: 08 March 2023

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Compelling need for additional ventilation requirements for partially enclosed lifeboats and liferafts.

MSC 106 approved additional ventilation requirements for totally enclosed lifeboats. These additional requirements are expected to come into force on 1 January 2026. In this connection, the Lifesaving appliances (LSA) Code and the resolution MSC.81(70) – Revised recommendations on testing of life saving appliances have been amended accordingly.

During MSC 106, countries also decided to consider whether these additional ventilation requirements should apply to only totally enclosed lifeboats or should those also be expanded to partially enclosed lifeboats and liferafts. Interested parties were asked to come up with a compelling need to include additional ventilation requirements to these crafts.

Member governments’ position is that although these crafts have a design advantage, there are times, such as bad weather, cold icy conditions, when these openings will need to be kept closed and additional ventilation will be required.

BIMCO’s position on this is that there has been no history of occupants being injured during survival due to lack of ventilation in these survival crafts. Partially enclosed lifeboats and liferafts, by design, have openings which can be used for ventilation. Moreover, additional ventilation systems mean additional equipment, such as high-pressure air bottles, batteries, pumps, pipings ducts etc. This brings additional maintenance requirements. Generally, these crafts are stored on the weather decks, which brings additional risks to batteries (if included) due to changes in temperature. Furthermore, these additional equipment bring more risks to occupants such as a battery fire, or a leaking high pressure cylinder etc. This puts occupants, who are already fighting for their lives during an abandon ship incident, at greater safety risks, which is not the intention of this extra requirement. Considering all the above, BIMCO concludes that there is no compelling need to add more ventilation requirements to these crafts.

Considering all the arguments presented, it was decided to not proceed with adding the ventilation requirements, but this topic will be further deliberated during the next meeting of the sub-committee.

Lowering speed for survival crafts and rescue boats

As per the LSA code, the maximum lowering speed of survival crafts and RBs shall be established by the Administration having regard to the design of the craft or rescue boat, the protection of its occupants from excessive forces etc.

The minimum lowering speed of survival crafts and rescue boats is calculated using the following formula and

S = 0.4 + 0.02H

Where S = the minimum lowering speed of the craft in metres/second and H is the height of the stowage of the craft above waterline in its lightest seagoing condition (in metres).

Therefore, when the craft is stowed at 20 metres, its minimum lowering speed is 0.8 m/s, when it is stowed at 30 metres, it is 1.0 m/s and when it is 40 metres, it is 1.2 m/s. For the maximum lowering speed, which is normally set by the administrations, it is generally taken at 1.3 m/s as there is an International Standards Organisation (ISO) standard – ISO 15516:2006, which prescribes maximum speed.

Generally, crafts are designed to have speed up to between a minimum of 0.8 m/s and a maximum of 1.3 m/s, however, when, the ships gets bigger and bigger this becomes an issue.

For example, the minimum lowering speed for a craft stowed at 40 metres should be 1.2 m/s and the maximum speed should be either set by the administration or 1.3 m/s as per the ISO standard. There are two issues here. If the maximum speed is set to much higher, then the boat has to be built with extra strength and better brake pads to take all the forces that it will be subject to, and if the maximum speed remains 1.3 m/s, then the installation should be carefully designed and operated between a fine range of 1.2 to 1.3 m/s and when ships get bigger, this problem aggravates.

This was discussed in depth at SSE 9, and a new minimum and maximum lowering speed for survival crafts and rescue boats were finalised.

The new minimum speed will be 1.0 m/s or as calculated by the formula S = 0.4 + 0.02H (mentioned above), whichever is lower.

The new maximum speed will be 1.3 m/s but administrations can set a different value taking into accounts all the strength factors of the craft and its installations. These will be approved at the MSC meeting and will apply to new systems installed on or after 1 Jan 2026.

Annual thorough examination and operational test – MSC 402(96)

A number of issues have been identified regarding Resolution MSC.402(96): Annual thorough examination and operational test, especially with the terms “make” and “type”, which were interpreted differently under different port states and flag states. The latest issue is the maintenance of fall wires of the launching appliances. It has been pointed that while the fall wires are inspected and if required replaced regularly, this is not the case with the associated suspension parts. The reason is that the suspension parts are not under the scope of the existing inspection and overhaul regime nor subject to mandatory periodic replacement.

This led to the sub-committee agreeing for a new output of comprehensive review of resolution MSC.402(96). This request will go to MSC 107, meeting in June, this year. MSC 107 could forward this output to be worked in the correspondence group so that group can work and submit the results to SSE 10, next year.

BIMCO’s position is that the original resolution is badly worded, which is leading to all these inconveniences. Shipowners and ships have to take the brunt most of the time. Our request is to expedite this work, but at the same time, come up with a document with no ambiguity.

Firefighting systems of Ro-Ro passenger ships

At SSE 9, further amendments were made to the SOLAS fire safety regulations in relation to both new and existing Ro-ro passenger ships. The amendments include adding fire protection to weather decks of these ships, permanent openings for cargo ships, fire detection and fire alarm systems, fire patrol system, video monitoring system.

Furthermore, arrangements of openings of side plating have been revised so they do not endanger the stowage areas of survival crafts, embarkation or assembly stations etc. Arrangements of the weather decks have also been revised keeping the above mentioned safety concerns in mind.

A new requirement of fixed water-based fire monitors and a drainage system will also be required for weather decks of these ships.

Generally, these amendments apply to new ships built on or after 1 January 2026 and to the existing ships from 1 January 2028, provided these amendments are adopted by 1 July 2024.

Firefighting system of container ships

A few countries submitted solutions for improvement of fire controls systems on container ships however the report from the formal safety assessment (FSA) is still not out. It is expected that the report will be submitted to IMO in the near future. All the solutions submitted until then will be kept in abeyance until the FSA report is submitted to IMO for consideration.

It is expected that this item will be deliberated in depth once the FSA report on this is out.

BIMCO is part of the fire correspondence group, the expert group connected with the FSA and is monitoring the developments closely.

BIMCO’s position is that safe and sustainable improvements to the safety systems on board ship should be made, however, design changes should apply to only new ships and not to existing ships retrospectively.

Revision of the Code of safety for diving systems (A.831(19)

This is a new non-mandatory code to be used for safe operation of diving systems. This will apply to all ships 500 GT and more, that have a new diving system installed. Ships with existing diving systems should be certified to this code by the next ship safety construction renewal survey or at an equivalent survey.

BIMCO will keep members updated of the progress from time to time. Please inform BIMCO if you are experiencing any issues in relation to lifesaving appliances and/or fire fighting systems. If you are a member and have any other queries, please do not hesitate to reach out to us.