MSC/Circ.1176 Unified Interpretations to SOLAS Chapters II-1 and XII and to the Technical Provisions for Means of Access for Inspections

Superseded by MSC.1/Circ.1464

Circular Letter
MSC/Circ.1176

UNIFIED INTERPRETATIONS TO SOLAS CHAPTERS II-1 AND XII AND TO THE TECHNICAL PROVISIONS FOR MEANS OF ACCESS FOR INSPECTIONS

(25 May 2005)

 

 

1. The Maritime Safety Committee, at its eightieth session (11 to 20 May 2005), approved unified interpretations of the provisions of SOLAS chapters II-1 and XII and the Technical provisions for means of access for inspections, as set out in the annex, following the recommendations made by the Sub-Committee on Ship Design and Equipment at its forty-eighth session, with a view to ensuring a uniform approach towards the application of the provisions of SOLAS chapters II-1 and XII.

 

2. Member Governments are invited to use the annexed interpretations when applying relevant provisions of SOLAS chapters II-1 and XII, and to bring them to the attention of all parties concerned.

 

Annex.

INTERPRETATIONS TO CHAPTER II-1, INCLUDING THE TECHNICAL PROVISIONS FOR MEANS OF ACCESS FOR INSPECTIONS, AND CHAPTER XII, INCLUDING THE PERFORMANCE STANDARDS FOR WATER LEVEL DETECTORS ON BULK CARRIERS, OF THE 1974 SOLAS CONVENTION

 

Table of contents

 

1. SOLAS regulation II-1/3-6 - Access to and within spaces in the cargo area of oil tankers and bulk carriers

 

2. Technical provisions for means of access for inspections (resolution MSC.158(78))

 

3. SOLAS regulation II-1/26 - General

 

4. SOLAS regulations II-1/40 - General - and II-1/41 - Main source of electrical power and lighting systems

 

5. SOLAS regulation II-1/41 - Main source of electrical power and lighting systems

 

6. SOLAS regulation II-1/42 and 43 - Emergency source of electrical power in passenger and cargo ships

 

7. SOLAS regulation II-1/44 - Starting arrangements for emergency generating sets

 

8. SOLAS chapter II-1, parts B Subdivision and stability - and B1 - Subdivision and damage stability of cargo ships

 

9. SOLAS regulation XII/9 - Requirements for bulk carriers not being capable of complying with regulation 4.3 due to the design configuration of their cargo holds

 

10. SOLAS regulation XII/12 - Hold, ballast and dry space water ingress alarms, including the Performance standards for water level detectors on bulk carriers (resolution MSC.145(77))

 

11. SOLAS regulation XII/13 - Availability of pumping systems

 

1. SOLAS REGULATION II-1/3-6 ACCESS TO AND WITHIN SPACES IN THE CARGO AREA OF OIL TANKERS AND BULK CARRIERS

 

1.1 SOLAS REGULATION II-1/3-6, SECTION 1

 

Interpretation

 

Oil tankers

 

This regulation is only applicable to oil tankers having integral tanks for carriage of oil in bulk, which is contained in the definition of oil in Annex I of MARPOL 73/78. Independent oil tanks can be excluded. Regulation II-1/3-6 should not normally be applied to FPSO or FSO unless the Administration decides otherwise.

 

Technical background

 

Means of Access (MA) specified in the Technical provisions contained in resolution MSC.158(78) are not specific with respect to the application to integral cargo oil tanks or also to independent cargo oil tanks. ESP requirements of oil tankers have been established assuming the target cargo oil tanks are integral tanks. The MA regulated under SOLAS regulation II-1/3-6 is for overall and close-up inspections as defined in regulation IX/1. Therefore it is assumed that the target cargo oil tanks are those of ESP, i.e. integral cargo tanks. Regulation II-1/3-6 is applicable to FPSO or FSO if they are subject to the scope of ESP as contained in resolution A.744(18) as amended.

 

Reference

 

SOLAS regulation IX/1 and resolution A.744(18) as amended.

 

1.2 SOLAS REGULATION II-1/3-6, PARAGRAPH 2.2

 

Interpretation

 

Some possible alternative means of access are listed under paragraph 3.9 of the Technical provisions for means of access for inspections (TP). Always subject to acceptance as equivalent by the Administration, alternative means such as an unmanned robot arm, ROVs and dirigibles with necessary equipment of the permanent means of access for overall and close-up inspections and thickness measurements of the deck head structure such as deck transverses and deck longitudinals of cargo oil tanks and ballast tanks, should be capable of:

 

.1 safe operation in ullage space in gas-free environment; and

 

.2 introduction into the place directly from a deck access.

 

Technical background

 

Innovative approaches, in particular a development of robots in place of elevated passageways, are encouraged and it is considered worthwhile to provide the functional requirement for the innovative approach.

 

1.3 SOLAS REGULATION II-1/3-6, PARAGRAPH 2.3

 

Interpretation

 

Inspection

 

The MA arrangements, including portable equipment and attachments, should be periodically inspected by the crew or competent inspectors as and when it is going to be used to confirm that the MAs remain in serviceable condition.

 

Procedures

 

1. Any Company authorized person using the MA should assume the role of inspector and check for obvious damage prior to using the access arrangements. Whilst using the MA the inspector should verify the condition of the sections used by close up examination of those sections and note any deterioration in the provisions. Should any damage or deterioration be found, the effect of such deterioration should be assessed as to whether the damage or deterioration affects the safety for continued use of the access. Deterioration found that is considered to affect safe use should be determined as "substantial damage" and measures should be put in place to ensure that the affected section(s) are not to be further used prior to effective repair.

 

2. Statutory survey of any space that contains MA should include verification of the continued effectiveness of the MA in that space. Survey of the MA should not be expected to exceed the scope and extent of the survey being undertaken. If the MA is found deficient the scope of survey should be extended if this is considered appropriate.

 

3. Records of all inspections should be established based on the requirements detailed in the ships Safety Management System. The records should be readily available to persons using the MAs and a copy attached to the MA Manual. The latest record for the portion of the MA inspected should include as a minimum the date of the inspection, the name and title of the inspector, a confirmation signature, the sections of MA inspected, verification of continued serviceable condition or details of any deterioration or substantial damage found. A file of permits issued should be maintained for verification.

 

Technical background

 

It is recognized that MA may be subject to deterioration in the long term due to corrosive environment and external forces from ship motions and sloshing of liquid contained in the tank. MA therefore should be inspected at every opportunity of tank/space entry. The above interpretation should be contained in a section of the MA Manual.

 

1.4 SOLAS REGULATION II-1/3-6, PARAGRAPH 3.1

 

Interpretation

 

Access to a double side skin space of bulk carriers may be either from a topside tank or double bottom tank or from both.

 

Technical background

 

Unless used for other purposes, the double side skin space should be designed as a part of a large U-shaped ballast tank and such space should be accessed through the adjacent part of the tank, i.e. topside tank or double bottom/bilge hopper tank. Access to the double side skin space from the adjacent part rather than direct from the open deck is justified. Any such arrangement should provide a directly routed, logical and safe access that facilitates easy evacuation of the space.

 

1.5 SOLAS REGULATION II-1/3-6, PARAGRAPH 3.2

 

Interpretation

 

A cargo oil tank of less than 35 m length without a swash bulkhead requires only one access hatch.

 

1.6 SOLAS REGULATION II-1/3-6, PARAGRAPH 4.1

 

Interpretation

 

The access manual should address spaces listed in paragraph 3 of regulation II-1/3-6. As a minimum the English version should be provided. The ship structure access manual should contain at least the following two parts:

 

Part 1: Plans, instructions and inventory required by paragraphs 4.1.1 to 4.1.7 of regulation II-1/3-6. This part should be approved by the Administration or the organization recognized by the Administration.

 

Part 2: Form of record of inspections and maintenance, and change of inventory of portable equipment due to additions or replacement after construction. This part should be approved for its form only at new building.

 

The following matters should be addressed in the ship structure access manual:

 

.1 the access manual should clearly cover scope as specified in the regulations for use by crews, surveyors and port State control officers;

 

.2 approval/re-approval procedure for the manual, i.e. any changes of the permanent, portable, movable or alternative means of access within the scope of the regulation and the Technical provisions are subject to review and approval by the Administration or by the organization recognized by the Administration;