Specialist safety codes
Updated 11 Oct 2019
Even the best trained crew can only work with what is provided on board and SOLAS has plenty to say in this regard. Not all of the regulation is in the SOLAS text and all operators should be aware of the IMO publications Life-Saving Appliances including LSA Code and the International Fire Safety Systems (FSS) Code. It is in these that the detail of the various regulations can be found but as with all IMO Codes and Conventions they are subject to continual revision.
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.
Life-Saving Appliances including LSA Code
The latest version of the Life-Saving Appliances including LSA Code referred to above is the 2017 edition. The book – which is almost as large as the main SOLAS text (which itself has now been consolidated into the latest 2014 version) 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.
Fire Safety Systems 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 the new 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 helicopter 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 guide 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.
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:
1. 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.
2. SOLAS Part F Regulation 55 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 measures
In addition to the fire safety rules outlined above, 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.
ILO Maritime Labour Convention 2006
The subject of medical facilities on board ships is not actually contained within SOLAS but has been a matter for the flag states to regulate. With the coming into force of the ILO Maritime Labour Convention (MLC) 2006 in 2013 many of the aspects relating to medical facilities are now contained within that convention. Where the flag state’s regulations go beyond those contained in the convention they will continue to apply and will be enforced by the flag state. In cases where the regulations applied by the flag state do not meet the convention requirements, it is likely that port state control enforcement will ensure that the convention requirements will apply when the ship is operating internationally.
There are two sections of MLC 2006 where medical matters are covered these are sections 3 and 4 of the main text. Section 3 covers accommodation and facilities and in this section the requirements for the ship’s hospital are laid down. As things stand, much of the text of the convention contains guidelines rather than prescriptive requirements. Each Member shall adopt laws and regulations establishing requirements for on-board hospital and medical care facilities and equipment and training on ships that fly its flag. National laws and regulations shall as a minimum provide for all ships to carry a medicine chest, medical equipment and a medical guide, the specifics of which shall be prescribed and subject to regular inspection by the competent authority. The national requirements must take into account the type of ship, the number of persons on board and the nature, destination and duration of voyages and relevant national and international recommended medical standards;
Ships carrying 100 or more persons and ordinarily engaged on international voyages of more than three days’ duration must carry a qualified medical doctor who is responsible for providing medical care and national laws or regulations shall also specify which other ships shall be required to carry a medical doctor, taking into account, inter alia, such factors as the duration, nature and conditions of the voyage and the number of seafarers on board;
Ships which do not carry a medical doctor are required to have either at least one seafarer on board who is in charge of medical care and administering medicine as part of their regular duties or at least one seafarer on board competent to provide medical first aid; persons in charge of medical care on board who are not medical doctors shall have satisfactorily completed training in medical care that meets the requirements of STCW. National laws or regulations shall specify the level of approved training required taking into account such factors as the duration, nature and conditions of the voyage and the number of seafarers on board. Flag states also have an obligation to ensure by a prearranged system that medical advice by radio or satellite communication to ships at sea, including specialist advice, is available 24 hours a day. The advice and the cost of transmitting it must be available free of charge to all ships irrespective of the flag that they fly.
Noise and vibration
Another impact of the MLC 2006 is that there is now international regulation covering noise and vibration on board ships. Noise has an obvious health impact being a cause of premature deafness but reducing noise levels also improves safety onboard. A non-mandatory noise code has been in existence since 1981 but some aspects have become obligatory.
SOLAS regulation II-1/3-12 adopted in 2012 at MSC91 came into force in June 2014 and requires new ships contracted after that date to be constructed in a way that reduces onboard noise. The limits are in accordance with the revised Code on noise levels on board ships (now widely known as the Noise Code), also adopted at MSC91, which sets out mandatory maximum noise level limits for machinery spaces, control rooms, workshops, accommodation and other spaces.
Unless a flag state approves any exemptions for individual ships, the Noise Code applies to ships of 1,600gt and above for which the building contract was placed on or after 1 July 2014; or, in the absence of a building contract, the keels of which are laid or are at a similar stage of construction on or after 1 January 2015; or the delivery of which is on or after 1 July 2018.
The rules go on to address vessels for which keels have been laid (or at similar stage of construction) on or after 1 July 2009 but before 1 January 2015, and are delivered before 1 July 2018, by stating measures in accordance with the Noise Code shall be taken to reduce noise in machinery spaces to an acceptable level as determined by their flag state. Where
noise levels cannot be reduced, then the rules say that the source of noise shall be suitably insulated or isolated, or a refuge from the noise provided. The regulation further states that ear protectors shall be provided for personnel entering such spaces. The level of noise allowed under the Noise Code for different areas is;
- Engine workshop 85 dB(A)
- Engine control room 75 dB(A)
- Main engine room 110 dB(A)
- Wheel and chart room 65 dB(A)
- Communication room 60 dB(A)
- Inside cabins and sickroom 55dB(A)
- Mess room 60dB(A)
- Gymnasium 60dB(A)
- Office 60dB(A)
- Kitchen 75 dB(A)
The levels apply during operations and measured under normal sailing condition with the main engines operating at service speed (not less than 80%MCR). Controllable pitch and Voith-Schneider propellers, if any, shall be in the normal seagoing position.
The IMO has asked flag states to consider extending the rules to ships built before the deadlines or taking other remedial action such as:
- Providing instruction in the hazard of noise exposure and the risk of hearing loss at initial employment and periodically thereafter.
- Providing warning signs at all entrances to spaces exceeding a noise level of 85dB(A) and making entry to such areas controlled.
- Providing warning information where hand tools, galley equipment or other portable equipment exceeds 85dB(A) in normal working conditions.
- Providing effective hearing protection on an individual basis.
- Providing a Hearing Conservation Plan for seafarers exposed to high levels of noise and that no expense is incurred by the seafarer.