Safety of life at sea is achieved in many ways and covers the ship and its equipment and the skills and competencies of seafarers. By way of national and international regulation, the operation of ships by their owners is also regulated to a greater or lesser degree.
The design and construction of the ship is a vital element and takes up a large part of the SOLAS Convention. Although the source for most international regulations on crew competency, safety and survival matters is the SOLAS convention, finding much of the detail within the SOLAS text itself is not possible because the individual subjects have codes of their own.
Skilled seafarers almost always mean safer ships and it is appropriate that within the IMO, both training and the various elements around safety come under the auspices of the Maritime Safety Committee (MSC) one of the two main committees and a number of its subcommittees.
While a skilled crew will make the best of the equipment and tools they are given, the condition of the ship and its equipment are also major factors in overall maritime safety,
Unfortunately, despite the priority given to training by high level operators, the human factor is often cited as a cause in marine accident investigations. Sometimes a cavalier attitude to training is evident even though an emphasis is placed on particular aspects by port state control and flag state audits.
As with all matters relating to ships, the first and foremost authority that can regulate and legislate on the competency of seafarers is the flag state. But just as in most maritime affairs, the basic standards have been agreed by most nations to be the remit of the IMO although the organisation does not issue any certificates or overly concern itself with the way in which training and education is delivered beyond formulation of a number of model courses.
Since the restructuring of the IMO sub-committee framework in 2013 most of the regulation of training falls to the Sub-Committee on Human Element, Training and Watchkeeping (HTW). The IMO’s regulatory role is relatively recent and is predominantly contained within The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW).
In 1977, the IMO (then the Inter-Governmental Maritime Consultative Organization or IMCO) arranged a conference that was the precursor to the Convention. The intention of the conference was ‘to specify minimum qualifications for training and certification for all grades of officers and crew on board merchant ships with priority for those immediately responsible for the safe navigation and handling of the ship’.
The first text for the convention was adopted in 1978 but did not become effective until 1984. The STCW was therefore a response to moves to establish universal minimum training, certification and watchkeeping standards for masters and officers which up to that point were the sole province of flag states. The lack of common standards prior to the STCW meant that there were wide variations in the training of seafarers and to a point that is still true today.
Compared to the latest version of STCW, the 1978 text was much slimmer and was contained in six chapters covering General provisions, Master and deck department, Engine department, Radio department, Special requirements for tankers and Survival craft proficiency. The six main chapters established basic principles covering keeping watches in the various departments alongside mandatory minimum requirements for certificating officers and crew.
With regard to the requirements for the radio department, as well as the certification requirements, ITU Radio Regulations and safety radio watchkeeping and maintenance provisions were included as these were also contained in SOLAS.
The singling out of tankers in particular was a response to several incidents involving such vessels and to introduce an aspect of pollution prevention. The regulation on tankers was designed to ensure that officers and ratings who had specific duties related to the cargo and cargo equipment of tankers should have completed an appropriate shore-based fire-fighting course; and have completed either an appropriate period of shipboard service or an approved familiarisation course. Requirements were more stringent for masters and senior officers. The chapter contains three regulations dealing with oil tankers, chemical tankers and liquefied gas tankers, respectively.
The inclusion of requirements for proficiency in survival craft in a separate chapter was in recognition of the importance of such equipment – the lack of lifeboats on the Titanic was a major factor behind the development of SOLAS. The requirements and regulation have been added to over the years and ironically are still the matter of much debate at the IMO and in the industry generally due to the number of accidents involving training with survival craft onboard.
In addition to the regulatory text, more than 20 recommendatory resolutions were also adopted at the 1978 Conference. As usual with IMO conventions and codes, more detail can be found in the resolutions than in the regulations themselves.
- Resolution 1 – Basic principles to be observed in keeping a navigational watch. An annex contains a recommendation on operational guidance for officers in charge of a navigational watch.
- Resolution 2 – Operational guidance for engineer officers in charge of an engineering watch. An annex to the resolution deals with engineering watch
- underway and at an unsheltered anchorage.
- Resolution 3 –Principles and operational guidance for deck officers in charge of a watch in port. Detailed recommendations are contained in an annex.
- Resolution 4 – Principles and operational guidance for engineer officers in charge of an engineering watch in port. Recommendations are in an annex.
- Resolution 5 – Basic guidelines and operational guidance relating to safety radio watchkeeping and maintenance for radio officers. A comprehensive annex is divided into basic guidelines and safety radio watchkeeping and maintenance.
- Resolution 6 – Basic guidelines and operational guidance relating to safety radio watchkeeping for radio telephone operators.
- Resolution 7 – Radio operators. Four recommendations are annexed to this resolution dealing with:
- – minimum requirements for certification of radio officers;
- – minimum requirements to ensure the continued proficiency and updating of knowledge for radio operators;
- – basic guidelines and operational guidance relating to safety radio watchkeeping and maintenance for radio operators; and training for radio operators.
- Resolution 8 – Additional training for ratings forming part of a navigational watch and a recommendation that such ratings be trained in use and
- operation of appropriate bridge equipment and basic requirements for the prevention of pollution.
- Resolution 9 – Minimum requirements for a rating nominated as the assistant to the engineer officer in charge of the watch. This recognises that suitable training arrangements are not widely available. Detailed requirements are contained in an annex.
- Resolution 10 – Training and qualifications of officers and ratings of oil tankers. Refers to resolution 8 adopted by the International Conference on Tanker Safety and Pollution Prevention, 1978 (TSPP), which deals with the improvement of standards of crews on tankers. Recommendation in annex.
- Resolution 11 – Training and qualifications of officers and ratings of chemical tankers.
- Resolution 12 – Training and qualifications of masters, officers and ratings of liquefied gas tankers.
- Resolution 13 – Training and qualifications of officers and ratings of ships
- carrying dangerous and hazardous cargo other than in bulk.
- Resolution 14 – Training for radio officers. Detailed recommendations in annex.
- Resolution 15 – Training for radiotelephone operators
- Resolution 16 – Technical assistance for the training and qualifications of masters and other responsible personnel of oil, chemical and liquefied gas tankers. Refers to requirements in several Convention regulations and recognises that training facilities may be limited in some countries. Urges governments which can provide assistance to do so.
- Resolution 17 – Additional training for masters and chief mates of large ships and of ships with unusual manoeuvring characteristics. Is designed to assist those moving to ships of this type from smaller vessels, where characteristics may be quite different.
- Resolution 18 – Radar simulator training. Recommended that such training be given to all masters and deck officers.
- Resolution 19 – Training of seafarers in personal survival techniques. Details contained in an annex.
- Resolution 20 – Training in the use of collision avoidance aids.
- Resolution 21 – International Certificate of Competency. IMO was invited to develop a standard form and title for this certificate.
- Resolution 22 – Human relationships. Emphasises the importance to safety of good human relationships between seafarers on board.
- Resolution 23 – Promotion of technical co-operation. Records appreciation of IMO’s work in assisting developing countries to establish maritime training facilities in conformity with global standards of training and invites the organization to intensify its efforts with a view to promoting universal acceptance and implementation of the STCW Convention.
1990s changes to STCW
Training and certification matters were constantly on the agenda just as they are today. In 1991 the Convention was amended by resolution MSC.21(59) to take into account the impending GMDSS regulations entering into force in December 1992 and under which radical changes to ship communications would be introduced and the role of radio officer would disappear on most merchant vessels.
In 1994 amendments contained in resolution MSC.33(63) replaced the chapter on special training for crews on tankers and extended it to cover roro passenger vessels. This was in response to incidents involving passenger ferries such as the Herald of Free Enterprise and Estonia tragedies.
The regulation referred to masters, officers, ratings and other personnel on ro-ro passenger vessels thus bringing cafeteria, entertainment staff and similar personnel under the STCW. Mostly these personnel are called on in emergencies and are tasked with issuing lifejackets, directing passengers and crowd control.
By 1995 several criticisms and suggested changes were adopted in a major revision to the convention adopted at a purposely convened conference. One of the criticisms levelled at the 1978 Convention was that it was not being interpreted consistently and much of the wording was vague. This was a period before the goal-based philosophy was in vogue and when much IMO regulation was prescriptive.
The 1995 amendments entered into force on 1 February 1997. One of the major features of the revision was the division of the technical annex into regulations, divided into Chapters as before, and a new STCW Code, to which many technical regulations were transferred. Part A of the Code is mandatory while Part B is recommended. The introduction of the Code meant that future major changes could be put in place easier by MSC resolutions rather than a special Conference.
The competencies required break down into three categories; management, operational and support.
Management level is defined as the level of responsibility associated with serving as master, chief mate, chief engineer officer or second engineer on board a seagoing ship and ensuring that all functions within the designated area of responsibility are properly performed. Operational level is the level of responsibility associated with serving as officer in charge of a navigational or engineering watch or as designated duty engineer for periodically unmanned
machinery spaces or as radio operator on board a seagoing ship, and maintaining direct control over the performance of all functions within the designated area of responsibility in accordance with proper procedures and under the direction of an individual serving in the management level for that area of responsibility;
The lower support level is defined as the level of responsibility associated with performing assigned tasks, duties or responsibilities on board a seagoing ship under the direction of an individual serving in the operational or management level.
The minimum standards of competence required for seagoing personnel are given in detail in a series of tables following each individual regulation. The tables are arranged over four columns.
The first list the various competencies, the second details the knowledge, understanding and proficiencies needed associated with it, the third is the method for demonstrating competence and the final column the criteria for evaluating competence.
The Convention and Code of 1995 extended Chapter VI which was original concerned with survival craft proficiency to cover ‘Emergency, occupational safety, medical care and survival functions’. Two new chapters were added covering alternative certification and watchkeeping.
Alternative certification enables crews to gain training and certification in various departments of seafaring rather than being confined to one branch for their entire career. The new rules on watchkeeping were aimed at preventing fatigue and required flag states to establish and enforce rest periods for watchkeepers and to regulate watch systems so as to ensure the efficiency of personnel is not impaired.
The 1995 Convention Chapter I, regulation I/4 established new procedures allowing port state authorities to intervene in the case of deficiencies deemed to pose a danger to persons, property or the environment. This right is restricted to ensuring crew certificates are in order or if there is an incident such as collision, grounding or pollution.
Flag states were required to ensure that training, certification and other procedures are continuously monitored by means of a quality standards system (regulation I/8) and were required to establish procedures for investigating acts by persons to whom they have issued certificates that endanger safety or the environment. Penalties and other disciplinary measures must be prescribed and enforced where the Convention is not complied with.
The 1995 convention recognised the use of simulators for training and assessment purposes and in particular made their use mandatory for training in the use of radar and automatic radar plotting aids (regulation I/12 and section A-I/12 of the STCW Code).
The white list
Another major change in 1995 was the requirement under Chapter I, regulation I/7 for flag states to provide detailed information to IMO concerning administrative measures taken to ensure compliance. This was a major departure from the earlier text and is one of the few instances where the IMO has a policing role.
The information that flag states must supply covers education and training courses, certification procedures and other factors relevant to implementation. The information is reviewed by panels of competent persons, nominated by parties to the Convention, who report on their findings via the Secretary-General to the MSC. Those states that are confirmed as meeting the requirements are included on a list of ‘confirmed parties’ more commonly known as the White List. A full list can be found at the IMO website.
For a flag state to remain on the White List its performance must be re-evaluated by the panel of experts every five years. Should it be found that, at the time of the re-evaluation that the country is not giving full and effective compliance to the convention, its name will be removed.
Countries that do not make the white list can still issue certificates to seafarers and these may be recognised by other states, but the omission from the white list can have a very detrimental effect on ships under the flag because the likelihood that they will be targeted by port state control is very high. For individual seafarers from nations not on the white list the opportunity to find work on other flag vessels may be reduced. The seafarer can apply to the flag state to have his or her certificates endorsed as being recognised and thus permitting employment but if the request is refused then they will have to consider completing the certification requirements of the flag state or else seek other employment.
Even countries on the White List cannot demand automatic acceptance of their seafarers’ certificates by other flag states. Although the right to accept other nation’s certification lies technically with the flag state, in the EU the European Commission, under an EU Directive, is responsible for approving non-EU training systems recognised by EU flag states – this duty has been delegated to the European Maritime Safety Agency (EMSA).
Changes to 1995 Code
The first changes to the 1995 Convention and Code were adopted in 1997 simultaneous with the 1995 amendments coming into effect. The changes were connected with the additional requirements for ro-ro passenger ships extending them to other passenger vessels. The amendments included an additional Regulation V/3 in Chapter V on Mandatory minimum requirements for the training and qualifications of masters, officers, ratings and other personnel. Related additions to the STCW Code, covered Crowd management training; Familiarisation training;
Safety training for personnel providing direct service to passengers in passenger spaces; Passenger safety; and Crisis management and human behaviour training.
In December 1998 amendments that would come into effect in 2003 were adopted. These were aimed at improving minimum standards of competence of crews, in particular relating to cargo securing, loading and unloading on bulk carriers. The amendments concern sections A-II/1 and A-II/2 under “Cargo handling and stowage at the operational and management levels”.
Amendments adopted in 2006 came into effect on 1 January 2008 and concerned two topics. The first was related to the ISPS Code and introduced minimum mandatory training and certification requirements for persons to be designated as ship security officers (SSOs). The amendments to the Convention and to both parts of the STCW Code included requirements for the issue of certificates of proficiency for Ship Security Officers; specifications of minimum standards of proficiency for ship security officers; and guidance regarding training for Ship Security Officers.
The second amendment was to part A of the Code and added additional training requirements for the launching and recovery of fast rescue boats as a consequence of numerous incidents involving injuries incurred during the launching and recovery of fast rescue boats in adverse weather conditions.
2010 – The Manila Amendments
A second comprehensive review of the Convention and Code was initiated by the IMO in 2007 and at a special conference held in Manila, Philippines in June 2010 a number of major amendments and new additions from the review were adopted – because of where the conference was held these changes are commonly referred to as the Manila Amendments. A new edition of the Convention and the Code dated 2010 was drawn up and became effective on 1 January 2012.
Among the changes now included are:
- Improved measures to prevent fraudulent practices associated with certificates of competency and strengthened evaluation process (monitoring of Parties’ compliance with the Convention)
- Refresher training made mandatory. All seafarers are now required to provide evidence of appropriate levels of competence in basic safety training (including survival, fire-fighting, first aid, and personal safety) at five year intervals
- Revised requirements on hours of work and rest bringing STCW into line with MLC 2006, and new requirements for the prevention of drug and alcohol abuse, as well as updated standards relating to medical fitness for seafarers
- New certification requirements for able seafarers including introduction of new grades of ‘Able Seafarer Deck’ and ‘Able Seafarer Engine’. These were in addition to the then current navigational and engine watch rating requirements which are otherwise unchanged
- New requirements relating to training in modern technology such as ECDIS
- New requirements for marine environment awareness training and training in leadership and teamwork
- New training and certification requirements for Electro-Technical Officers and Electro-Technical Rating
- Updating of competence requirements for personnel serving on board all types of tankers, including new requirements for personnel serving on liquefied gas tankers
- New requirements for security training, as well as provisions to ensure that seafarers are properly trained to cope if their ship comes under attack by pirates
- Introduction of modern training methodology including distance learning and web-based learning
- New requirement for all deck and engine rating trainees to demonstrate competence through the use of on board training record books, with completion supervised by officers responsible for on board training (in addition to the existing requirements applicable to officer trainees)
- New training guidance for personnel serving on board ships operating in polar waters
- New training guidance for personnel operating Dynamic Positioning Systems
Under STCW 2010, flag states had some leeway as to when the requirements become effective beyond the 2012 coming into force date of the Convention. This permitted seafarers holding STCW certificates issued prior to 1 January 2012 only needing to meet the new requirements, including new refresher training, in order for their certificates to be revalidated from 1 January 2017. The requirement for security training applied to all seafarers from I January 2014 and should now have been allowed for in ship operators’ ISPS procedures.
Medical Certificates could continue to be issued in accordance with the older requirements until 2017 after which all medical certificates must be in accord with the 2010 standards.
Although not a training issue, the seafarer working time changes included in STCW 2010 that entered into force in January 2012 increase the minimum amount of rest from 70 hours to 77 hours in any seven day period. Seafarers must always have 10 hours rest in any 24 hour period with no exceptions, except during an emergency and it became mandatory for seafarers’ hours to be recorded on board and confirmed by the individual seafarer on a monthly basis.
New training requirements
In recent years a number of new roles have been regulated for on board ship that go beyond the ranks and skills that STCW was initially devised to include. This began with GMDSS which added a requirement for additional training for all GMDSS operators needed to replace the defunct radio operator training of pre-GMDSS days. The next requirements came under the ISM and ISPS Codes which brought with them the new positions of Safety Officer and Security Officer respectively. The latter position looks to be further evolving and may soon include an element of cyber security training. More recently the Polar Code and the Gas Fuel Code have been adopted and these make specific mention of training.
In the Polar Code, a whole Chapter (Chapter 12) is devoted to manning and training. Although not a particularly long chapter, there are requirements contained in it that have major implications for training budgets for ships operating in Polar waters. For example, it demands that ‘while operating in polar waters the ship has sufficient number of persons meeting the appropriate training requirements for polar waters to cover all watches’ (Regulation 220.127.116.11). This would normally mean at least three persons having to undergo advanced training in ice navigation in each crew.
In 2015 the IMO adopted IGF Code adopted the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code), along with amendments to make the Code mandatory under the International Convention for the Safety of Life at Sea (SOLAS).
The use of gas as fuel, particularly liquefied natural gas (LNG), has increased in recent years but until the adoption of the IGF Code, each ship was treated as a special case by its flag state. Hence there were no universal regulations governing the use of LNG and other gaseous fuels.
Simultaneous with the adoption of the IGF Code, the MSC also adopted related amendments to the STCW Code, to include new mandatory minimum requirements for the training and qualifications of masters, officers, ratings and other personnel on ships subject to the IGF Code. The amendments became effective on 1 January 2017, in line with the SOLAS amendments related to the IGF Code.LSA Code
Given that safety at sea is the foundation upon which was built all international regulation of shipping for both safety and environmental purposes, this is perhaps the mots fundamental of all the conventions and codes that now come under the auspices of the IMO.
The latest version of the Life-Saving Appliances including LSA Code is the 2017 edition. The book – which is almost as large as the main SOLAS text and runs to almost 300 pages – is in fact a compilation of three separate texts.
First and foremost there is the LSA Code itself which was adopted in 1996 and came into force in 1998. The Code is essentially the detailed mandatory requirements of the equipment needed and referred to in the main SOLAS text. Also included are recommendations for testing of equipment and the Code of Practice for evaluating and approving life-saving appliances.
The vast extent of safety regulations contained in the main SOLAS text and in the LSA and other codes precludes a highly detailed account of them here, but the codes should be consulted when drawing up safety systems and during system audits.
The provisions of the LSA Code are not restricted to SOLAS ships since they have also been incorporated into the IMO’s Code for the Construction and Equipment of Mobile Offshore Drilling Units – better known as the MODU Code. The MODU Code was first published in 1989 but was agreed some ten years earlier. It was deemed necessary because of the growing number of drilling units then being built. At that time, drilling units were mostly of the rig or jack-up variety and not the drill ships that are becoming common today. Modern drill ships need to comply with both SOLAS and the MODU Codes.
From the point of view of seafarers and ship operators, some of the content in the book related to prototype testing might seem to be superfluous since they should be able to expect that a type approved piece of equipment should be fit for purpose. However, there is an important point that relates to this and that is the identification of any International Standards Organisation or – in the case of electrical equipment International Electroctechnical Council standards – that need to be complied with.
Usually any appropriate ISO standards numbers are to be found printed or attached somehow to pieces of equipment. Comparing the numbers with those in the book will help crews ensure that equipment on board is the most up to date and not an obsolete item supplied in error. Wrong ISO or IEC numbers can also be an indication that the equipment is not genuine and had been pirated in which case no confidence should be put in its effectiveness.
SOLAS regulations are kept under constant review but even so there are regular calls from organisations, individuals and equipment makers both from inside and outside the industry to introduce changes to the rules and performance standards.
The life-saving appliances makers themselves are constantly improving products and trying to learn from accidents and incidents. New materials make this process easier in some cases and academic research is also a valuable influence.
As with all IMO publications, the latest edition of the LSA Code at any given time may not represent all applicable regulations so those relying on it will also need to refer to recent IMO resolutions and circulars. For ship operators the need to stay up to date is not just a matter of safety as failure to comply can result in PSC detentions that will have economic and reputational implications.
The exact number of life-saving appliances from lifebuoys and lifejackets to lifeboats and liferafts to be carried on board any particular vessel will depend upon its type and purpose and the number of crew and passengers carried. The numbers will be recorded on the ship’s appropriate Safety Equipment Certificate issued by the flag state (or a recognised organisation acting on its behalf) which is one of the documents that needs to be produced in most ports in order to be given customs clearance for departure.
Customs clearance also requires the number of persons on board to be declared and although checks are sometimes cursory and some requirements overlooked, there are many instances of ships being prevented from sailing due to insufficient equipment being on board. This is mostly when contractors’ riding crews are being carried. In such cases it may be necessary to purchase or hire additional equipment.
SOLAS requires regular drills and instruction in the use of life-saving equipment and recording of these in the ship’s log. Most company ISM procedures also require evidence of basic training and instruction in the use of equipment to be documented. Port State Control inspections will frequently focus on these records especially as unfamiliarity with equipment and procedures is one of the most common causes of PSC detentions. PSC will also be looking for confirmation that the scheduled inspection and maintenance of lifeboats and liferafts has been carried out by approved service stations and appropriate certification provided.Fires Safety Systems (FSS) Code
Fires Safety Systems (FSS) Code
The very first version of SOLAS was far more concerned with life-saving than with fire and quite lacking in dealing with the subject fire on board vessels other than to say that there should be a system of fire patrols and that the ship should be equipped with pumps sufficient to direct ‘two powerful jets of water’ at any fire.
There was also a requirement to carry a smoke hood and safety lights. Over the years and due to some high-profile disasters at sea involving fire, the issue of fire gradually grew to become probably the second most important aspect of ship safety covered by the IMO.
While the SOLAS conventions of 1914, 1929, 1948 and 1960 did contain fire safety requirements, they proved inadequate for passenger ships. In the 1960s, a series of fires aboard international passenger ships highlighted many problems and, as a result, many changes were incorporated into the 1974 SOLAS Convention.
Amendments to SOLAS through the 1970s and 1980s gave fire a Chapter of its own (Chapter II-2). In 1992, the Sub-Committee on Fire Protection began a comprehensive revision of the chapter as it was felt that the adoption of various sets of amendments at different times had made it difficult to use and implement. Technological advancements and lessons learned from accidents, since the chapter’s last revision in 1981, required new provisions to be added and for existing requirements to be modified. However, the outcome of this eight-year effort resulted in more than just a “user friendly” amalgamation of the latest amendments, but an entirely new structure for SOLAS chapter II-2.
Fire is covered in several ways within SOLAS with these falling into three very separate areas. The first is the construction of the vessel and the materials used, the second is fire risks and hazards relating to cargoes carried and the third is related to fire detection and fire-fighting systems and equipment.
The new structure focused on the “fire scenario process” rather than on ship type, as the previous SOLAS chapter II-2 was structured. Thus, the regulations start with prevention, detection, and suppression following all the way through to escape. The revised SOLAS chapter II-2 had a new part E; that deals exclusively with human element matters such as training, drills and maintenance issues and a new part F; that sets out a methodology for approving alternative (or novel) designs and arrangements.
The new Chapter II-2 only applied fully to ships built after it came into force in 2002 however some aspects were also agreed to be applied to existing ships. Of the measures that affected existing vessels, most had a date by which the ship would have to comply or the measures did not apply unless repairs, alterations, modifications and outfitting to existing systems took place. All of the dates laid out in those requirements have since passed so all ships should now meet the latest rules.
In addition, to make the revised SOLAS chapter II-2 more user friendly, specific system- related technical requirements have been moved to the new International Fire Safety Systems Code and each regulation has a purpose statement and functional requirements to assist port and flag States. Some of the original technical provisions were transferred from the Convention to the International Fire Safety Systems (FSS) Code, and many others are spelled out in greater detail in the Code. Following the addition of a new final chapter on fixed hydrocarbon gas detection systems in 2007, the 2015 edition of the FSS Code consists of 16 chapters but a new chapter was agreed at MSC 95 and adopted at MSC 97 which brings the total to 17.
Each addresses specific systems and arrangements, except for chapter 1 which contains a several definitions and also general requirements for approval of alternative designs and toxic extinguishing media.
- Chapter 1 General
- Chapter 2 International shore connections
- Chapter 3 Personnel protection
- Chapter 4 Fire extinguishers
- Chapter 5 Fixed gas fire-extinguishing systems
- Chapter 6 Fixed foam fire-extinguishing systems
- Chapter 7 Fixed pressure water-spraying and water-mist fire-extinguishing systems
- Chapter 8 Automatic sprinkler, fire detection and fire alarm systems
- Chapter 9 Mixed fire detection and fire alarm systems
- Chapter 10 Sample extraction smoke detection systems
- Chapter 11 Low-location lighting systems
- Chapter 12 Fixed emergency fire pumps
- Chapter 13 Arrangement of means of escape
- Chapter 14 Fixed deck foam systems
- Chapter 15 Inert gas systems
- Chapter 16 Fixed hydrocarbon gas detection systems
- Chapter 17 Foam fire-fighting appliances for the protection of helicoptern facilities
In order to complement the FSS Code, and to assist in type approval of materials used in ship construction, the IMO has also published a document known as Fire Test Procedures (FTP Code). The FTP Code was first published at the same time as the FSS Code. Both have since been amended to take into account technology changes and desirable changes.
SOLAS chapter II-2 deals exclusively with human element matters such as training, drills and maintenance issues. This section does not concern itself with the actual training that seafarers have to do undergo as part of their certification process but with the organisational and practical aspects as regards individual ships. As part of the STCW Code, the IMO has prepared a series of three model courses for seafarers undergoing training at sure training establishments. These are:
- Model Course 1.20 – Fire Prevention & Fire Fighting
- Model Course 2.03 – Advanced Fire Fighting
- Model Course 3.05 – Survey of Fire Appliances
With so many different documents covering fire safety regulations, it is far beyond the scope of this site to fully detail all the requirements.
However, reference to the main SOLAS text and to the other documents mentioned here should give any operator or crew member sufficient information to understand the requirements under most situations.
In addition to these documents, fire safety should be one of the main subjects covered in the ship owner or operator’s safety management system. Because of that they should have been subject to both internal and external audit and deemed fit for purpose. As with all matters relating to the ISM Code they should be subject to regular review involving both ship and shore personnel.
January 2016 saw some new rules coming into effect in a number of areas concerned with safety. These include;
- amendments to SOLAS regulations II-2/4, II-2/3, II-2/9.7 and II-2/16.3.3, to introduce mandatory requirements for inert gas systems on board new oil
- and chemical tankers of 8,000dwt and above, and for ventilation systems on board new ships; related amendments to the International Code for Fire
- Safety Systems (FSS Code) on inert gas systems.
- amendments to SOLAS regulation II-2/10. This is in the form of new carriage requirements for water mist lance and mobile water monitors for new ships designed to carry containers on or above the weather deck and for the ships designed to carry five or more tiers of containers on or above the weather deck, respectively.
- amendments to SOLAS regulation II-2/13.4, mandating additional means of escape from machinery spaces.
- new SOLAS regulation II-2/20-1 Requirement for vehicle carriers carrying motor vehicles with compressed hydrogen or natural gas for their own propulsion, which sets additional requirements for ships with vehicle and ro-ro spaces intended for the carriage of motor vehicles with compressed hydrogen or compressed natural gas in their tanks as fuel.
Fire and LNG as fuel
A decade ago, only LNG carriers and a few small ferries were fuelled by LNG but it is now being heavily promoted as a cleaner alternative to fuel oil for all ship types. One impediment to its greater adoption has been the lack of an internationally agreed standard for fuel systems on ships powered by gas.
This has now been rectified following the adoption of the IGF Code at MSC 95 in 2015. The amendments caused by the adoption which previously existed as drafts include a new Part G in SOLAS chapter II-1 (Construction – Subdivision and stability, machinery and electrical installations) related to ships using low- flashpoint fuels, requiring such ships to comply with the IGF Code; and related amendments to SOLAS chapter II-2 (Fire protection, fire detection and fire extinction), covering to the use of fuel with a low flashpoint. Further amendments update the form of safety certificates, to include reference to the new Part G. Two additional amendments to SOLAS were also adopted at MSC 95:
Firstly SOLAS regulation II-2/4 was amended to allow existing ships that were approved to use oil fuels with flashpoint less than 60°C, for example fuel oils less than 60°C but not less than 43°C in emergency generators, to continue using such oil fuels after the IGF Code came into effect on 1 January 2017.
This allowance is accepted provided that the ship is not converted to use low-flashpoint fuels, or does not commence the use of low-flashpoint fuels that are different from that which it was previously approved to use, after entry into force of the IGF Code on 1 January 2017. At present, the requirements for low-flashpoint fuel oils (residual or distillate fuel oils) with a flashpoint less than 60°C are under development for future inclusion in the IGF Code.
The second amendment was to SOLAS Part F Regulation 55 which was revised to account for the IGF Code requirement that ships using other low-flashpoint fuels (methanol, propane,
butane, ethanol, hydrogen, dimethyl ether, etc.) need to comply with the functional requirements of the Code through the alternative design regulation based on an engineering analysis. Operationally-dependent alternatives are not permitted. The adopted Code includes several significant provisions which were previously agreed at MSC 94 with the exception of the provision for risk assessment application criteria which was refined at MSC 95.
The Committee clarified that, for ships using natural gas as fuel (part A-1 of the IGF Code) and complying with the detailed prescriptive requirements contained within the Code, a risk assessment need only be conducted where specifically required by the applicable prescriptive parts of the IGF Code.
New regulation V/3 (MSC.396(95)) and corresponding sections to Parts A (MSC.396(96)) and B of the 1978 STCW Convention containing training and qualifications of personnel that work on ships subject to the IGF Code were adopted. Criteria was included to ensure that certain personnel, with training and experience acquired for liquefied gas tankers, receive recognition towards the new mandatory training and qualification requirements specified in the Convention for ships subject to the new IGF Code.Other safety related codes
Other safety related codes
Depending on ship type there are a number of other codes that cover safety aspects of the cargo being carried. Among these are the International Maritime Dangerous Goods Code (IMDG Code), International Maritime Solid Bulk Cargoes Code (IMSBC Code) which replaced the Code of Safe Practice for Solid Bulk Cargoes (BC Code), The International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk (IBC Code) covering chemical tankers, and in addition special codes for grain and timber cargoes.
Other safety measures
In addition to the fire safety rules there are many other references to safety within SOLAS. For example, two chapters– VI Carriage of cargoes and VII Carriage of dangerous goods –both include references to safety relevant to the subjects contained in the titles of the chapters. Another chapter, Chapter XI-1 Special measures to enhance maritime safety, is also concerned with the matter of safety.
At MSC 92 in July 2013, some amendments to SOLAS regulation III/19 on emergency training and drills were agreed to mandate enclosed-space entry and rescue drills, which require crew members with enclosed-space entry or rescue responsibilities to participate in an enclosed-space entry and rescue drill at least once every two months. The amendments entered into force on 1 January 2015 and are applicable to SOLAS ships, and 1994and 2000 High Speed Crafts.
In order to accommodate the new enclosed space entry requirements, ships are required to carry some form of gas detection equipment. Tankers and gas carriers were already required to carry this equipment and the new rules may allow for some equipment to serve dual purposes providing sufficient redundancy in equipment is maintained.