Las rutas del vino en La Rioja

Double bottoms in passenger ships and cargo ships other than tankers [Proposed new footnote. A decision is needed on 24 or 80 m in square brackets]:- ____________

[* The regulations in Part B-2 apply to passenger ships regardless of length and to cargo ships of [24][80] m in length (L) and upwards but shall not apply to those cargo ships which are shown to comply with subdivision and damage stability regulations in other instruments developed by the Organization (Ref. footnote to Regulation 4.1).]

Note: The aim of these proposals is to clarify the regulations to be applied to cargo ships thereby enabling the Table in Regulation 4.1 of the EN to be removed.

Q6B (for SLF53 S-C and WG). Can we agree to the changes to Reg. 4.1 and the heading of Part B-2 shown under “Proposal” in the Round 2 discussion, above? A decision will also be needed as to whether Part B-2 applies to cargo ships of 24 m L and upward or 80 m L and upward (see square brackets in proposed new footnote to Part B-2).

To be discussed by the new SDS CG for SLF 54 (Ref: SLF 53/WP.6 paragraphs 25 and 26 and TOR 32.5)

Q6C (for round 4 questionnaire). Having made the decisions highlighted above at SLF53 the issue of the size of cargo ship to which Part B-2 applies was referred back to our 2011 CG.

Therefore, could you please state whether you think that Part B-2, which includes the DB regulations, should apply to cargo ships of 24 m L and upward or only to 80 m L and upward?

Also, the proposal for a footnote to Part B-2 to clarify the applicability of these regulations was rejected by the WG at SLF 53. However, it would seem that in view of the newly agreed footnote to Reg 4.1 which now only mentions Part B-1, some form of clarification of the applicability of Part B-2 is still needed somewhere – perhaps in the regulation title or by retaining the Table in the EN? Your comments are invited (see also Q10C).

B-2 applies to cargo vessels with L>24?

Yes Norway, Japan, France, China, Germany (Generally yes, however the requirements for Reg. 9 may need to be adjusted to those small ships after further investigations), Finland, UK.

No Vanuatu

Neither US (see comments)

RINA (If this was applied to cargo vessels then it would be applicable to ships which are less than 500 gross tons and could raise a conflict between the application of this Part and other Parts of SOLAS, which have an applicability criteria of 500 gross tons, or greater, for cargo ships.

There is a requirement in Classification Rules which states that double bottoms need not be fitted in cargo ships less than 500 ton gross tonnage.

Noting that a review of cargo ships is currently on the work program in hand at MSC, is it an option at this to forward this issue to DE for inclusion in their work program?).

B-2 only applies to cargo vessels with L>80?

Yes Vanuatu, Italy

RINA (While it is the case that Part B-2 could be applied to cargo ships greater that 80 m. However there are requirements in Part B-2, such as Regulation 12 - Peak and machinery space bulkheads, shaft tunnels, which will surely be applicable to SOLAS cargo ships with a length less than 80 m. This may be the case for other paragraphs in Part B-2.

It is considered that Part B-2 needs to be reviewed to provide appropriate regulation for cargo ships between 500 GT, and over, and ships with a length greater that 80 m. See comments in paragraph above).

Spain (In relation with regulation 9.7 and 9.8 (damage stability requirements - bottom damage) we prefer 80 m. The other regulations should be studied in a case-by case basis. Anyway, it is important to point out that a cargo vessel of 24 m length could have less than 500 GT (SOLAS common limit)).

Continued….

Where

Vanuatu: With respect to the double bottom issue we think this is less a question of applicability for vessel type(s) but more as a question of the impact on vessels designed to operate from shallower ports. We feel this would tend bloat draught without providing any quantifiable ‘improvement’ characteristics from the application of current rule. Otherwise Administrations will need the flexibility as for Regulation 9.5 for passenger ships; this however seems backwards (and a bit archaic).

US: Suggested options:

A. Insert a regulation 4.1bis as follows:

4.1bis Except where expressedly provided otherwise,

.1 Part B-2 applies to passenger ships and cargo ships.

.2 Part B-3 applies to passenger ships.

.3 Part B-4 applies to passenger ships and cargo ships.

B. The approach used in Parts C and D; a caption under the Part B-2 title:

(Except where expressedly provided otherwise part B-2 applies to passenger ships and cargo ships); etc.

The applicability should be clear in the regulations; an EN should not be necessary. We prefer option A.

Note: this will all now need to be considered/combined in the context of MSC 89/22/8 and its proposed text.

Japan: Japan does not have a strong position, but we suggest inserting new paragraph before current reg 9.1, ex;

“1 This regulation applies to cargo ships of [24][80] m in length (L) and upwords other than tankers and to all passenger ships regardless of length.

2 A double bottom shall be fitted with ...”

RINA: This should be clarified in Regulation 4.

Denmark: (with comments).

Germany: It’s already laid down in Reg. 4 as updated during SLF 53. We think it’s clear enough. But if the group finds it’s not, we would suggest putting it clearly in SOLAS, not in the EN.

Italy: Regulation title.

UK: To have a direct reference in the main regulation text would be preferable at this stage.

Further Comments?:-

Vanuatu: With respect we submit this not an issue that lends itself to global ‘one size fits all’

style absolutism since under SOLAS the options are limited to the binary set of Passenger vs Cargo vessel. Seeking to apply 9.8 extents of damage based on beam for beamy, shallow draught vessels under 80 meters will likely be remarkably disruptive of the design process.

US: We do not believe there should be a cargo ship length threshold for Part B-2. Our understanding of the SLF 53 outcome was that Part B-2 was to be applied to all SOLAS cargo ships irrespective of length (see last sentence of SLF 53/WP.6 paragraph 25). The validity of applying regulation 9.8 to smaller ships was identified as a separate issue and highlighted for consideration as a SDS CG TOR. (see SLF 53/19, paragraphs 14.6 and 14.10.2)

Note: we believe only regulations 13-1 and 15-1 have their origins in SOLAS 90 Part B-1 and any legacy connection to L>80. Under SOLAS 90, regulations 9, 10, 11, 12, 15, 16 and 16-1 applied to all cargo ships.

Japan: The scope of reg.9.6 to 9.8 should be considered carefully because ships with L <80m need not to calculate si in Part B-1. (See also A.44C.)

Denmark: In the old SOLAS the double bottom requirements for cargo ships were included in Reg. 12-1. These requirements were valid to all cargo vessels under SOLAS. Our worries concern the application of Reg. 9.8 for the very small cargo ships only. The clarification should go into SOLAS for clarity and accessibility.

France: France considers that B-2 should apply to cargo vessels with L> 24 m whilst keeping in mind that the double bottom requirement with regard to the damage extent and “s” level needs to

be considered / further studied. We refer for example to tugs of 24 m and over and GT > 500.

Round 6 Discussion: Many thanks for all your Round 4 comments – this is getting very