Background
The IMO’s Maritime Safety Committee (MSC) has adopted amendments to the Safety at Sea Convention (SOLAS) Chapter II-2 effective from 1 January 2020, by resolutions MSC.404(96), MSC.409(97) and MSC.421(98). In addition, amendments are made to the International Code for Fire Safety Systems (FSS Code) by resolutions MSC.403(96) and MSC.410(97).
SOLAS Chapter II-2 has been implemented into Norwegian legislation by section 2 (a) of the Regulations on fire protection on ships, cf. section 3. The FSS Code has been implemented into Norwegian legislation by section 2 (b), cf. section 3. The implementing provisions must be amended to make them comply with the revised international legislation. The amendments apply to ships engaged on both domestic and foreign voyages, cf. sections 2 and 3 of the Regulations on fire protection on ships.
Details on the amendments
The amendments specified in the resolutions mentioned above were negotiated in the relevant IMO committees. In cooperation with the industry, Norway presented its positions and participated in the negotiations. The industry should be well aware of these amendments through information from special interest organisations and the Norwegian Maritime Authority. In short, the amendments made by the resolutions include:
MSC.403(96) and MSC.404(96)
Definition of helicopter landing area and winching area
SOLAS Regulation II-2/3 is amended by including a definition of helicopter landing area and winching area. Helicopter landing area means an area on a ship designated for occasional or emergency landing of helicopters but not designed for routine helicopter operations. Winching area is a pick-up area provided for the transfer by helicopter of personnel or stores to or from the ship while the helicopter hovers above the deck. These definitions are related to a new requirement for firefighting appliances for helicopter landing areas in SOLAS Regulation II-2/18.2.3.
Ships constructed on or after 1 January 2020, having a helicopter landing area, shall be provided with foam firefighting appliances.
SOLAS Regulation II-2/18.2.3 is amended to include a requirement for ships, constructed on or after 1 January 2020, having a helicopter landing area, to comply with the new chapter 17 of the FSS Code on foam firefighting appliances to protect helicopter decks and helicopter landing areas. Furthermore, the amendments to the FSS Code will have consequences for manufacturers of firefighting appliances used on ships. For Norwegian ships, this is maintained by the requirements for wheel-marked equipment.
New requirement for evacuation analysis for passenger ships carrying more than 36 passengers
SOLAS Regulation II-2/13.3.2.7.1 is amended to require an evacuation analysis in the design phase for passenger ships constructed on or after 1 January 2020 carrying more than 36 passengers. This type of requirement has formerly only applied to ro-ro passenger ships constructed on or after 1 July 1999, cf. SOLAS Regulation II-2/7.5, but is now extended to apply to several passenger ships. The purpose of an evacuation analysis is specified in SOLAS Regulation II-2/13.3.2.7.2. The analysis shall be used to identify and eliminate, as far as practicable, congestion which may develop during an abandonment. In addition, the analysis shall be used to demonstrate that escape arrangements are sufficiently flexible to provide for the possibility that certain escape routes, assembly stations, embarkation stations or survival craft may not be available as result of a casualty.
The amendment applies to passenger ships engaged on both domestic and foreign voyages carrying more than 36 passengers, cf. the scope of application for the Regulations on fire protection on ships cf. sections 2 and 3. The evacuation analysis requirement could entail an increased cost when constructing ships. However, due to digital aids, the MSC has reason to believe that the work will be easier to manage and require less resources. The evacuation analysis requirement is expected to have a lasting and positive effect.
MSC.409(97)
Exemptions from requirements for foam extinguishers for boilers protected by fixed water-based fire-extinguishing systems
The last sentence of SOLAS Regulation II-2/10.5.1.2.2 implements a new exemption from the requirement of at least one approved foam-type extinguisher of at least 135 l capacity or equivalent in each boiler room. In the case of a boiler of less than 175 kW, or boilers protected by fixed water-based fire-extinguishing systems, an approved foam-type extinguisher of at least 135 l capacity is no longer required. The exemption will be relevant to ships complying with requirements for fixed water-based local application fire-extinguishing systems cf. SOLAS Regulation II-2/10.5.6. See section 3 of the Regulations on fire protection on ships.
MSC.421(98)
The definition of vehicle carrier has been amended
SOLAS Regulation II-2/3.56 is amended by including a definition of vehicle carrier. The reason for this amendment is that the definition implemented by resolution MSC.365(93) was considered unclear. The purpose of the amendment is to clarify that certain fire protection requirements apply to vehicle carriers carrying motor vehicles with compressed hydrogen or natural gas (in limited quantities) for their own propulsion as cargo, cf. SOLAS Regulation II-2/20.1.
Fire protection of vehicle, special category and ro-ro spaces
Amendments to SOLAS regulations II-2/20 and 20-1 are made to specify which fire protection requirements that shall apply when vehicles are carried as cargo, cf. the amendment of the definition of vehicle carrier as stated in the previous paragraph. When vehicles sometimes are carried as cargo in other spaces than special category spaces and ro-ro spaces, the requirements stated in the International Maritime Dangerous Goods Code (IMGD Code) must be complied with along with the requirements stated in SOLAS Regulation II-2/19, provided that the vehicle does not use own propulsion in the cargo room.
Specification of requirements for fire integrity of windows on passenger ships
An amendment is made to SOLAS Regulation II-2/9.4.1.3.6 specifying that for ships constructed on or after 1 January 2020 carrying not more than 36 passengers, “windows facing survival craft, embarkation and assembly stations shall have fire integrity of at least equal to A-O class”.
The consultation
The proposed regulation concerning amendments to the Regulations on life-saving appliances on ships was circulated for review from 10 October to 1 December 2019. A total of 13 consultative statements came in, whereof 12 did not include comments to the proposal.
The Norwegian Better Regulation Council has submitted consultative comments to the proposal. In particular, the comments relate to consequences for trade and industry. The NMA will consider the comments and the assessment from the Norwegian Better Regulation Council. The NMA will compare its normative documents for regulatory work to comments from the Norwegian Better Regulation Council. Amendments to normative documents will be considered and may be implemented to improve the regulatory work process.
The NMA has found no grounds to circulate the amended Regulations for a new review, and they are therefore laid down as they are.
Administrative and financial implications
The amendments will, first and foremost, affect companies, yards and manufacturers, who will carry the largest responsibility related to costs. However, passengers and cargo owners will benefit from an increased security.
The NMA will adapt the enforcement of the legislation to the amendments of the international legislation. Beyond this, the proposal is not considered to have any significant administrative consequences.