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Client Orientation Regulatory Updates

Leonidas Noulas
Divisional Lead Surveyor Athens, Greece 16 April 2013

Regulatory Developments Update


SOLAS: Revisions LSA Code: Revisions MARPOL Annexes I, IV, V and VI: Revisions BWM Convention: not in force

SOLAS: Asbestos Ban

Scope of ban (SOLAS II-1/3-5)

Existing components can remain as installed:


Vanes used in rotary vane compressors Rotary vane vacuum pumps Watertight joints and linings Thermal insulation assemblies

New installations to be asbestos-free New installations on all ships Effective 1 Jan 2011

Application: MSC.282(86)

SOLAS: Asbestos Ban

MSC.1/Circ.1379 prohibits asbestos in spare parts used 1 Jan 2011 Certification IACS UI 249 (MSC.1/Circ.1426)

New construction, conversions Replacement/additions Yards/manufacturers provide declaration with supporting documentation Owner provides documentation for M&R at surveys MSC.1/Circ.1426 specifies the 7 types of asbestos

ABS implementation

All type approvals require declaration by 1 Jan 2011 Audits of manufacturers 1 Jan 2011 will review supporting documentation Yards and repair facilities to comply with UI 249 by 1 July 2012 Form letter sent to yards/manufacturers
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SOLAS: Means of Embarkation/Disembarkation

Application (SOLAS II-1/3-9 as per MSC.256(84))


All ships > 500 gt New: keel laid > 1 Jan 10 Existing: keel laid < 1 Jan 10 Gangways identified ships equipment Accommodation ladders (installed on board and operated by winch) Installations on new ships Contained in MSC.1/Circ.1331 Gangways/accommodation ladders
Refers to ISO Standards (7061:1993, 5488:1979, National Standards) Max load/inclination to be marked
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Design standard

SOLAS: Means of Embarkation/Disembarkation


MSC.1/Circ.1331 Surveys Testing
Static Load Test (no permanent deformation permitted) Operational Test Static Load Test (no permanent deformation permitted) Operational Test

Winch/Accommodation Ladder[1] Arrangement


Apply load per 5.3.2 uniformly with winch suspending the ladder in horizontal position Apply 3.6.2 with weight of ladder only (raise/lower ladder at least twice) Apply load per 5.3.2 [2] uniformly with winch holding the ladder in horizontal position Raise and lower ladder once (weight of ladder only)

Gangway [2]

n/a

Initial Installation [4]

n/a

Five-year [3] [5]

Apply 5.1.2.2 with load per 5.3.2 [3] applied uniformly to gangway in horizontal position n/a

Annual [5]

No load testing to be carried out; only examination of components

1 - Includes landing platforms if fitted 2 - Only when carried onboard the ship 3 - If MWL unknown for existing gangways/ladders, owner nominates load as per 5.3.2 4 - Ships Constructed, and Equipment Replacements on Existing Ships, on/after 1 Jan 2010 5 - All installations, regardless of installation or ship construction date

SOLAS: Pilot Transfer Arrangements (PTA)

Application of SOLAS V/23 (MSC.308(88)) & MSC.1/Circ.1375)


New ships: CFC > 1 July 2012, or if no CFC, KLD > 1 July 2012 Existing ships:
PTA with contract delivery, or if no contract, actual delivery, > 1 July 2012 1st exception: does not apply to PTA delivered to a ship with KLD before and delivered after, 1 July 2012 2nd exception: components replaced > 1 July 2012 should comply to extent reasonable

PTA Requirements

Ladder certified to SOLAS or other standard (e.g. ISO 799) No more mechanical pilot hoists A.1045(27) supersedes A.889(21) Length of ladder based on angle 45, instead of 55 (MSC.1/Circ.1428)
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SOLAS: Pilot Transfer Arrangements (PTA)

Existing Pilot Transfer Arrangements


PTA on ships constructed < 1 Jan 1994 No later than the first survey 1 July 2012 Comply with regulation V/23.5: Shipside doors used for pilot transfer shall not open outwards

(Reg V/23.5 N/A)


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SOLAS: COT Corrosion Prevention Requirements

Application of SOLAS II-1/3-11 (MSC.291(87))


New crude oil tankers and crude oil/product carriers 5,000 dwt Top and bottom of cargo oil tanks to be protected CFC 1 Jan 2013; or If no CFC, keel laid > 1 July 2013, or Delivered > 1 Jan 2016 (regardless of CFC or keel lay date)

New defined as

3 Options (must meet IMO Performance Standard)


Approved protective coatings; Alternative means of protection (MSC.289(87)) Corrosion resistance material to maintain required structural integrity for 25 years (MSC.289(87))
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SOLAS: New Fire-Extinguishing Controls

Application (SOLAS II-2/10.4.1.5) (MSC256(84))


Ships constructed before 1 July 2002 Fixed CO2 fire-extinguishing systems (low and high pressure) for machinery spaces and cargo pump-rooms First scheduled DD on/after 1 Jan 2010 One control to open valve piping which conveys gas into protected space Second control used to discharge gas from cylinders Controls to be inside release box (low pressure, if permitted by design) If box is locked, provide breakable glass enclosure next to box for key

Compliance

Requirement (FSS Code, 5.2.2.2)

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SOLAS: Retroactive Measures for Lifeboats

SOLAS Chapter III Amendments applies retroactively to ships constructed 1 July 2014 Lifeboat on-load release mechanisms not complying with new LSA Code (*) (4.4.7.6.4 to 4.4.7.6.6) requirements are to be replaced or modified Compliance by the first scheduled drydocking 1 July 2014, but not later than 1 July 2019

Lifeboat release and retrieval system is the means by which the lifeboat is connected to, and released from, the lifeboat falls for lowering, launch and retrieval. It comprises the hook assembly and operating mechanism

(*) Ref. (MSC.1/Circ.1392)


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SOLAS: Retroactive Measures for Lifeboats

New Retroactive LSA Code Amendments


Existing release mechanism to be fail-safe Weight of lifeboat is not to transmit opening force to operating mechanism when reset in closed position Locking devices to be designed so they cannot open due to forces from hook load Hydrostatic interlock - if provided is to automatically reset upon lifting boat from water

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SOLAS: Retroactive Measures for Lifeboats

Evaluation process for existing release mechanisms:

Design assessment manufacturer determines compliance or extent of modification needed by 1 July 2013 for each type Performance test (by manufacturer or manufacturers rep) RO witnesses test after satisfactory review of design assessment Evaluation results details of components and evaluation results reported to IMO for each system type:
Compliant or compliant after modification: remain in service Non-compliant: to be replaced or modified to be made compliant

For compliant systems carry out overhaul exam by first drydocking 1 July 2014, if completed satisfactory, manufacturer issues factual statement to confirm

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SOLAS: Retroactive Measures for Lifeboats

Replacement of non-compliant release mechanisms:


Engineering review of replacement installation Installation and installation tests carried out by manufacturer, witness by flag State/RO Tests are:
1.1 times operational load release test (or hydraulic mechanisms) 2 times static load test of release gear connection to lifeboat 5 knot launching test (for LBs on cargo ships > 20k gt)

Statement of Acceptance issued by Flag State/RO after satisfactory completion of installation tests Replacement by first drydocking 1 July 2014, but not later than 1 July 2019
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SOLAS Revisions: Retroactive Application

Retroactive Equipment Requirements

Two (2) two-way portable radiotelephones for each fire party (Tankers Hazardous Areas all ships)
New ships 1 July 2014 Existing ships 1st survey 1 July 2014

Revised SCBA standards for onboard SCBA


By 1 July 2014 provide means of charging onboard or suitable number of spare cylinders By 1 July 2019 provide increased SCBA capacity with audible and visual low level alarms

Plans/procedures for recovery of persons:


Identify equipment to be used and measures to be taken New ships 1 July 2014 Existing ships 1st INT/REN survey 1 July 2014

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SOLAS: ECDIS Requirements

Electronic chart display and information system


SOLAS amendment MSC.282(86) Performance standards A.817(19) Back-up arrangements: Paper charts or 2nd ECDIS

Flag may exempt if ship is to be scrapped within two years of compliance date Implementation schedule
Ship Type Passenger Tanker Cargo Ship excluding tankers Passenger Tanker Cargo Ship Excluding Tankers Constructed 1 July 12 1 July 12 1 July 13 1 July 14 < 1 July 12 < 1 July 12 < 1 July 13 < 1 July 13 < 1 July 13 GT GT 500 GT 3k GT 10k 3k GT < 10k GT 500 GT 3k GT 50k 20k GT < 50k 10k GT < 20k Compliance Date

MSC.1/Circ.1290 If keel laid before, but delivered after, compliance date, 1st survey is the initial survey

At delivery 1st SLP 1 July 14 1st SLE 1 July 15 1st SLE 1 July 16 1st SLE 1 July 17 1st SLE 1 July 18

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SOLAS: ECDIS Requirements

Electronic Chart Display and Information System

Be Type Approved to Resolution MSC.232(82) by the administration or an organization acceptable to and on behalf of the administration Installation and arrangement details are to be reviewed by an engineering office Crew should be appropriately trained (Ref. SN.1/Circ.207/Rev.1, dated 22 October 2007 ECDIS software should be updated/maintained (Ref. SN.1/Circ.266, dated 22 October 2007

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SOLAS: BNWAS Requirements

Bridge Navigational Watch Alarm System


SOLAS amendment MSC.282(86) Performance standards MSC.128(75) Interface with heading and track controls Connected to VDR (not S-VDR)

BNWAS installed < 1 July 2011 may be exempted from compliance with MSC.128(75) Implementation Schedule
Ship Type Cargo Passenger Passenger Cargo Constructed 1 July 11 1 July 11 < 1 July 11 < 1 July 11 Gross Tonnage GT 150 GT 3k 500 GT < 3k 150 GT < 500 Compliance Date At delivery At delivery st 1 SLP 1 July 12 1st SLE 1 July 12 1st SLE 1 July 13 1st SLE 1 July 14

MSC.1/Circ.1290 If keel laid before, but delivered after, compliance date, 1st survey is the initial survey

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MARPOL Annex I: Oil Residue/Sludge Tank


MEPC.187(59) MARPOL I/12.2 Revised Application (as per MEPC 62)

Sludge

Contract placed on/after 1 January 2011 or Keel laid (or similar stage of construction) on/after 1 Jan. 2012 or Delivered on/after 1 January 2014 Require a designated pump for disposal Shall have no discharge connections to the bilge system or oily bilge water holding tanks Drains with manually operated self-closing valves to monitor settled water permitted
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Oil residue (sludge) tanks


MARPOL Annex I: Oil Residue/Sludge Tank

Connections permitted between sludge/bilge systems:


Non-return valves equivalent to no connections Common piping leading to the standard discharge connection Piping to other means of disposal (e.g., incinerator, boiler) Manually operated valves to drain settled water to bilge from sludge tanks

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MARPOL Annex IV: MEPC.200(62)

MARPOL Annex IV Revised


New Special Area Same Baltic Sea Area from Annex I Additional requirements for passenger ships:
New passenger* ships 1 Jan 2016 and existing passenger ships 1 Jan 2018 Discharge of sewage prohibited within a special area, except from an approved STP

A new passenger ship: (i) CFC or KLD 1 January 2016, or (ii) Delivery 1 January 2018

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MARPOL Annex V: Completely Revised

New definitions, additional; but still no Garbage certificate/ supplement Applies to all ships (new and existing) Allows discharge of grounded food waste ( 25mm) 3 nm or more from land Now regulates discharge of cargo holds solid residues Discharge of any type of plastics is prohibited Every ship 100 gt or with 15 POB to have Garbage Management Plan Every ship 400 gt and with 15 POB to have Garbage Record Book
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MARPOL Annex V: Revisions MEPC.201(62)

Provide shipowners/operators with information on the requirements for complying with revised Reg. 10 of Annex V Compliance with the regulation requires careful planning by the operator and proper execution by crew Publication helps when developing most appropriate procedures for handling and storing garbage Factors to take into account: type and size of the ship, the area of operation, garbage processing equipment on board, storage space, crew size, duration of voyage, regulations and reception facility at ports of call

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MARPOL Annex VI: NOx Limits


Ship Constructed ( 1 January) 1990 to 2000 Retroactive to existing engines 2000 x <2011 2011 x <2016 2016 2016* Application of Requirements Emission Limits Compliance at engines delivery except as below 1st IAPP Renewal Survey 12 months after IMO advised by Party of availability (physical and cost) of upgrade kit Operation outside and within ECA Engine > 130 kW Tier II Tier III Operation outside of ECA Operation within ECA Relative Reduction from Tier I 0% 15.5% - 21.8% 80%

Engine size > 5,000 kW and 90 liters / cylinder

Tier I

NOx calculated as total weighted emission of NO2 (g/kWh)

RPM Tier I Tier II Tier III

< 130 17.0 14.4 3.4

130 n < 2000 45*n(-0.2) 44*n(-0.23) 9*n(-0.2)

2000 9.8 7.7 2.0

* L<24m if used for recreational purposes or total propulsion < 750 kW if unable to achieve due to design limitations

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MARPOL VI: Engine Upgrades to Tier I

Retroactive Application of Approved Methods

Engines on ships constructed from 1990 through 2000 Engine size > 5,000 kW and 90 liters/cylinder Compliance required unless excessive cost Currently, three Approved Methods for MAN B&W
Type S50MC S70MC S70MC MCR (kW/cyl) 1160-1430 2530-2810 2530-2810 RPM 114-127 81-91 81-91
+

Approved Methods

Compliance * 12 Aug 2012 6 Oct 2011 + 12 Aug 2012 +

* First IAPP renewal survey on/after date

Depending on type of nozzle


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MARPOL Annex VI: Energy Efficiency

New Chapter 4 added to MARPOL Annex VI

Attained Energy Efficiency Design Index (EEDI)


Only for Reg 20 types of ships > 400gt
New ship:

EEDI =

Engine Power Speed x Cpty

CFC 1 Jan 2013, KLD 1 July 2013 (only if no CFC), or Del 1 July 2015 (regardless of CFC or KLD)

Existing ship types which undergo extensive major conversion


Attained EEDI for Reg 20 ship types and sizes < Required EEDI Ship Energy Efficiency Management Plan (SEEMP):
All new ships > 400gt on delivery Platforms and Drilling rigs excluded All existing ships > 400gt to comply by first IAPP INT or Renewal Survey on/after 1 Jan 2013

Apr 12

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Ballast Water Management Convention

Enters Into Force (EIF)


12 months after ratification by 30 States with 35% worlds GT As of March 2013, 35 States (27.95% GT) have ratified the Convention A.1005(25) delays D2 compliance for ships built in 2009 w/ballast capacity < 5,000 m3 Ships of signatory flag States, all ships in jurisdictional waters of signatory States
Construction or major modification Date < 2009

Implementation (D1 = Exchange Standard, D2 = Biological Standard)

Ballast Cpty (m3)

First Intermediate or Renewal Survey, whichever occurs first, after the anniversary date of delivery in 2014/2016 as shown below 2010 2011 2012 D1 or D2 2013 2014 2015 2016 201 7

2009

D2

<1500

in 2009 >2009

D1; D2 by 2nd Annual but not beyond 31 Dec 11 or EIF, whichever is later

D2 (at delivery or EIF, whichever is later) D1 or D2 D2


D1; D2 by 2nd Annual but not beyond 31 Dec 11 or EIF, whichever is later (Note)

1500 or 5000 >5000

< 2009 in 2009 >2009 < 2012 > 2012 N/A

D2 (at delivery or EIF, whichever is later) D1 or D2 D2 D2 (at delivery or EIF, whichever is later) 27

BWM Convention: Methods of Treatment


Exchange (D1) Flow Through Treatment Systems (D2) Retention/Reception

Sequential

Dilution

Mechanical Filtration Cyclonic Separation

Physical Cavitation Deoxygenation Ultraviolet Lights

Chemical Biocides Electrolytic Chlorination

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Keep Pace with Regulatory Developments

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