Commercial Vessel Compliance

Recap of the 7th Session of the IMO Sub-Committee on Ship Systems and Equipment

The IMO Sub-Committee on Ship Systems and Equipment (SSE), held its 7th session at IMO headquarters in London on March 2-6, 2020. Ms. Brandi Baldwin, Chief of the Coast Guard’s Lifesaving and Fire Safety Division, led the U.S. delegation, comprised of members from the Coast Guard and technical advisors from government and private sectors. 

Key topics discussed at SSE 7 were:

  • New requirements for the ventilation of survival craft
  • Revisions to SOLAS Chapter III and the LSA Code
  • Amendments to paragraph 4.4.7.6.17 of the LSA Code concerning single fall and hook systems with on-load release capability
  • Revision of the Standardized Life-Saving Appliance Evaluation and Test Report Forms (MSC/Circ.980 and addenda)
  • Requirements for onboard lifting appliances and anchor handling winches
  • Development of guidelines for cold ironing of ships and consideration of amendments to SOLAS chapters II-1 and II-2
  • Review of SOLAS chapter II-2 and associated codes to minimize the incidence and consequences of fires on ro-ro spaces and special category spaces of new and existing ro-ro passenger ships
  • Amendments to guidelines for the approval of fixed dry chemical powder fire-extinguishing systems for the protection of ship carrying liquefied gases in bulk (MSC.1/Circ.1315)
  • Amendments to chapter 9 of the FSS Code for fault isolation requirements for cargo ships and passenger ship cabin balconies fitted with individually identifiable fire detector systems
  • Revision of the Guidelines for the maintenance and inspections of fixed carbon dioxide fire-extinguishing systems (MSC.1/Circ.1318)

New requirements for ventilation of survival craft

The sub-committee agreed to draft amendments to the LSA Code for totally enclosed lifeboats, partially enclosed lifeboats, and liferafts. Consensus was reached on a requirement for a maximum long-term CO2 concentration of not more than 5,000 ppm for both partially enclosed lifeboats and liferafts. The working group finalized draft test procedures for fully enclosed lifeboats in support of envisioned amendments to Resolution MSC.81(70) and made progress on draft test procedures for partially enclosed lifeboats. Work will continue in an intersessional correspondence group this summer and fall.

Revisions to SOLAS chapter III and the LSA Code

The working group discussed a way forward on this agenda item and subsequently developed an action plan endorsed by the sub-committee to begin work during an intersessional correspondence group.  The initial work will include developing a methodology to identify and evaluate hazards to be addressed through revisions to SOLAS Chapter III and the LSA Code; reviewing the existing functional requirements in MSC.1/Circ.1212/Rev.1 supporting SOLAS Chapter III with a view to mapping them to the existing prescriptive requirements of SOLAS III; and if time permits, to begin carrying out a hazard identification process based on the agreed methodology.

Other Lifesaving matters completed at this session

The sub-committee agreed to the draft revision of the Standardized Life-Saving Appliance Evaluation and Test Report Forms (MSC/Circ.980 and addenda) submitted by the United States, including the proposal to separate the test forms into six independent circulars each corresponding to a chapter of the LSA Code. The sub-committee agreed that the forms should only include amendments adopted through January 1, 2020. The six new circulars will be submitted to MSC 103 for adoption.

The sub-committee agreed to amendments removing the requirement to launch free-fall lifeboats with the ship making headway at speeds up to 5 knots in calm water from SOLAS Chapter III, the LSA Code and Resolution MSC.81(70). These amendments will be submitted to MSC 103 for approval and adoption, as appropriate.

The sub-committee agreed to draft amendments to paragraph 4.4.7.6.17 of the LSA Code concerning single fall and hook systems with on-load release capability. These amendments clarify that a release system is only exempt from the on-load system requirements if the system does not have the capability to release the lifeboat or rescue boat with a load on the hook when it is not fully waterborne. The amendments will be submitted to MSC 103 for approval.

Onboard Lifting Appliances and Anchor Handling Winches

The sub-committee completed the draft of the lifting appliances guidelines and minor revisions to the associated draft SOLAS regulations. The revised SOLAS regulations and draft lifting appliances guidelines will be submitted to MSC 103 for approval and subsequent adoption by MSC 104. The working group made progress on the guidelines for anchor handling winches but did not complete the draft prior to the end of the session. Accordingly, the sub-committee established a correspondence group, to be led by Japan, to continue work on these guidelines.

Cold Ironing of Ships

In consideration of the five papers submitted under agenda item 11, including the correspondence group report, the experts group finalized the draft interim guidelines on safe operation of onshore power supply (ops) service in port for ships engaged on international voyages. The group agreed that there is no need to develop draft amendments to SOLAS chapters II-1 and II-2 at this time. They developed questions and text concerning personnel training in regard to cold ironing, for consideration by the HTW sub-committee. The guidelines will be sent to MSC 103 for adoption.

Safety Objectives and Functional Requirements for SOLAS Chapter II-1

The sub-committee developed an action plan for developing goals, functional requirements, and expected performance for SOLAS chapter II-1 (Parts C, D and E), and established a correspondence group to continue the work.  The sub-committee recommended that this work item be reassigned to SDC, subject to the authorization of the Committee and Council.

Review SOLAS chapter II-2 and associated codes to minimize the incidence and consequences of fires on ro-ro spaces and special category spaces of new and existing ro-ro passenger ships

The working group on fire protection continued work on the review of SOLAS chapter II-2 and associated codes to minimize the incidence and consequences of fires on ro-ro spaces and special category spaces of new and existing ro-ro passenger ships. SSE 7 established an intersessional correspondence group to draft amendments to mandatory instruments under this agenda item.

Guidelines for Dry Chemical Extinguishing Systems (MSC.1/Circ.1315)

The working group further developed amendments to MSC.1/Circ.1315, waiting to finalize the amendments until further research is available on dry chemical powders.

Additional Fire Safety Agenda Items

The sub-committee approved amendments to chapter 9 of the FSS Code for fault isolation requirements for cargo ships and passenger ship cabin balconies fitted with individually identifiable fire detector systems. The sub-committee approved revisions to the guidelines for the maintenance and inspection of fixed carbon dioxide fire-extinguishing system (MSC.1/circ.1318) (6.17) clarifying when carbon-dioxide cylinders should be hydrostatically tested. The sub-committee approved a unified interpretation to clarify classification of isolated pantries in accommodation spaces.

Correspondence Groups established

 The following correspondence groups were established at this session:

  • Life-Saving Appliances will finalize draft amendments to MSC.81(70) for the testing of the means of ventilation of partially enclosed lifeboats and develop a methodology to identify and evaluate hazards to be addressed by a revised SOLAS Chapter III and revised LSA Code.
  • Fire Protection will develop draft amendments to relevant IMO instruments regarding fire safety on ro-ro passenger ships.
  • Safety Objectives and Functional Requirements for SOLAS chapter II-1 to consider how best to develop the goals, functional requirements and expected performance for SOLAS chapter II-1(Parts C, D and E).
  • Requirements for onboard lifting appliances and anchor handling winches will draft and finalize SOLAS regulations and develop guidelines for anchor handling winches.
  • Revision of the Code of safety for diving systems to progress the work.

Contact us at imo@uscg.mil if you are interested in participating in discussions of any of the above topics.

Finally, the Sub-Committee re-elected Mr. Umut Şentürk (Turkey) as Chair and Mr. Sergey Tolmachev (Russian Federation) as Vice-Chair. The next session of the SSE Sub-committee (SSE 8) is tentatively scheduled for March 1-5, 2021.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.