France comments

ANNEX……

Safety requirements for passenger ships with a length
equal to or less than 24 m

Table of contents

Chapter I – General Provisions2

Chapter II-1 –Construction, subdivision and stability,
machinery and electrical installations2

Part A - General2

Part A-1 – Structure of ships2

Part A-2 - Load Line requirements2

Part B – Intact stability, subdivision and damage stability4

Part B-1 – Intact stability4

Part B-2 – Subdivision and damage stability4

Part C – Machinery5

Part D – Electrical installations7

Chapter II-2 Fire protection, fire detection and fire extinction

Part A – General8

Part B – Prevention of fire and explosion8

PART C – Suppression of fire10

PART D – Escape 13

Part E – Operational requirements 14

Chapter III – Life saving appliances14

Chapter IV – Radio communication equipment15

Chapter I – General Provisions

This annex shall apply to Class B, C and D ships with a length equal to or less than 24 m constructed from 01/01/20xx.

Giventhe practical inapplicabilityof the rulesoftechnicalannexesof Directive2009/45/EC for small ships, France considers that this annexshould apply also tovessels with a lengthnot exceeding45 m with some adjustments.

Chapter II-1 – Construction, subdivision and stability, machinery and electrical installations

Part A - definitions

  1. The definitions as given in Annex I, Chapter II-1, part A, shall be applied.
  1. Freeboard: The freeboard assigned is the distance measured vertically downwards amidshipsfrom the upper edge of the deck line to the upper edge of the related load line.
  1. The 'structural fire protection time' is the time in which the temperature of the unexposed side to the fire will not rise more than 139oC above the original temperature,nor will the temperature at any one point, including any joint, rise more than 225oC above the original temperature, to the end of the indicated time of the standard fire test.
  1. "F" class divisions are those divisions formed by bulkheads, decks, ceilings and linings which comply with the following:
  2. They shall be so constructed as to be capable of preventing the passage of flame to the end of the first half-hour of the standard fire test;
  3. They shall have an insulation value such that the average temperature of the unexposed side to the fire will not rise more than 139oC above the original temperature, nor will the temperature at any one point, including any joint, rise more than 225oC above the original temperature, to the end of the first half-hour of the standard fire test.
  1. "LSA Code" means the International Life-Saving appliance (LSA) Code contained in IMO Resolution MSC 48(66), as amended.

Part A-1 – Structure of ships

  1. Ships shall comply with the requirements of Annex I, chapter II-1, part A-1.

Part A-2 - Load Line requirements

Strength and materials

  1. The structure of the ship shall provide adequate strength, taking into account the intended service.
  1. The materials used shall:
  2. be appropriate for the purpose of use;
  3. comply with the standards of a recognised organisation; and
  4. used according to the appropriate methods of application and assembly.

Freeboard

  1. The maximum permitted draught shall be compatible with the assigned freeboard.
  1. The assigned freeboard shall be:
  2. The freeboard of the deepest approved loading condition recorded in the stability information booklet.
  3. At least 380 mm for ships with a length equal to or less than 12 m.
  4. At least 760 mm for ships with a length of 24 m.
  5. At least the value obtained by interpolation between b and c for ships with a length more than 12 m and less than 24 m.
  6. Clearly and permanently marked on each side of the ship at amidships.
  1. If the Administration considers the trim of the ship to be such that the freeboard aft of the ship will become marginal, the Administration may decide to have the freeboard measured at 0,25 L from the after perpendicular.
  1. Ships shall be provided with a scale of draughts clearly and permanently marked at the bow and stern, to the satisfaction of the administration.

Doors, hatch covers, coamings, ventilators, air pipes, skylights and freeing ports

  1. Doors giving access to enclosed superstructures or to spaces below the freeboard deck shall:
  2. Be weathertight;
  3. Be permanently fixed to the bulkhead;
  4. Be constructed with sufficient strength of materials having properties at least equal to the bulkhead;
  5. Be opening outwards and operable from both sides of the bulkhead.
  6. Have doorsills with a height of at least 380 mm.

For reasonsof accessibility todisabled people, France proposes the following amendment:

External Doors giving access to enclosed superstructures:

  1. Be weathertight;
  2. Be permanently fixed to the bulkhead;
  3. Be constructed with sufficient strength of materials having properties at least equal to the bulkhead;
  4. Be opening outwards and operable from both sides of the bulkhead.

Doors giving access to spaces below the freeboard deck shall, in addition, have doorsills with a height of at least 380 mm

And thedeletion of Article14which has norelevancein viewof Article 13.

  1. The height of doorsills shall be
  2. 380 mm for doors leading directly to the machinery space
  3. 230 mm for doors leading to spaces below the freeboard deck
  4. 100 mm for other doors
  1. Hatch covers shall be of adequate strength and weather tight.
  1. Coamings of hatchways on exposed decks shall have a height of at least 380 mm. Coamings of other hatchways shall have a height of at least 230 mm. Coamings may be omitted when hatchways are secured and not being used during the voyage.
  1. Ventilators serving spaces within the ship shall be provided with coamings of adequate strength with weather tight closing devices and shall have a height of at least 760 mm above the freeboard deck and 450 mm above enclosed superstructure decks. For Class C and D vessels this height may be reduced to the satisfaction of the administration, but shall not be less than respectively 380 mm and 230 mm
  1. Air pipes,which shall be fitted to prevent air locks or high pressure in tanks, extending above the deck shall be of adequate strength and be provided with weather tight closing devices and shall have a height of at least 760 mm above the freeboard deck and 450 mm above enclosed superstructure decks. For Class C and D vessels this height may be reduced to the satisfaction of the administration, but shall not be less than respectively 380 mm and 230 mm
  1. Skylights shall be of adequate strength and if they comprise openings they shall be located at least 450mm above the deck. Such openings shall be capable of being closed by permanently attached weather tight covers. Skylights may be in the form of opening side scuttles with deadlights.
  1. The ship shall have sufficient and effective freeing ports of appropriate dimensions, with the lower edge as near as the deck as possible, to the satisfaction of the administration. Openings of large freeing port areas shall be adequately protected with bars, to the satisfaction of the administration. The minimum freeing port area (A) on each side of the ship shall be given by the formula:

A = 0,5 (0,7 + 0,035l) m2

Where l is the length of the bulwark in the well or the length of the superstructure.

At the last meeting (21-22 june 2011), the expert group has accepted the formula proposed by France as follow:

— For wells located in position I :

A = 0,4 (0,7 + 0,035 l)

— For wells located in position II :

A = 0,3 (0,7 + 0,035 l)

— For superstructures which are not enclosed superstructures :

A = 0,2 (0,7 + 0,035 l)

With A minimum area(A)in square metersof freeing portson each side and l is the length ofthe bulwark inthe well orthe length of thesuperstructure.

(Definitions are those of LL66)

Openings in the shell plating

  1. The number of openings, such as scuppers and sanitary discharges, in the shell plating shall be kept to a minimum.
  1. Doors in the shell plating with the lowest point below the load waterline are prohibited.
  1. Side scuttles
  2. To spaces below the freeboard deck or to spaces within enclosed superstructures shall be fitted with efficient hinged internal deadlights, which are permanently attached, arranged so that they can be effectively closed and secures watertight.
  3. Which are not accessible while underway shall be closed and sealed before sailing.
  4. Fitted below the freeboard deck shall be fixed and be fitted at least 500 mm above the load line corresponding to the maximum draught..

The last requirement is not coherent with the minimum freeboard of 380 mm for ships with a length equal or less than12 m as stated in chapter I Part A-2 §10

  1. Sea inlets and outlets shall be
  2. Fitted with valves.
  3. Be installed such that they cannot cause accidental admission of water into the ship.
  4. Readily accessible and be provided with an indicator showing whether the valve is open or closed.
  5. Controlled from a point above the freeboard deck when they are fitted in machinery spaces below the freeboard deck. Locally operated valves may be permitted in manned machinery spaces for outlets located above the load line corresponding to the deepest draught.

Valves controlledabove thefreeboarddeckare not easily feasibleon small vessels. France proposesto delete "in mannedmachineryspaces" given that there isno risk ofaccidentaladmissionof water whenthe dischargesare abovethe waterline

  1. Machinery inlets shall be fitted with closing devices and a detachable filter such that foreign bodies cannot interfere with the functioning of the closing device.
  1. Sea outlets shall be fitted with a non-return valve fitted directly to the side or to the water outlets. In case of wet exhaust systems the valve may be of a flap type.

Watertightness and sounding arrangements

  1. Decks, bulkheads, watertight doors and fore and after peaks and double bottom compartments shall be tested on water or weather tightness, as appropriate, to the satisfaction of the administration.

France understandsthat the decks must beweathertightand other elements(watertight doors, and bulkheads) must be watertight. This should beclarified.

  1. Spaces intended to hold liquids and spaces that are not easily accessible shall be provided with arrangements for allowing soundings, in general, from above the freeboard deck. If this is impracticable, the sounding arrangement shall be to the satisfaction of the administration.

Part B – Intact stability, subdivision and damage stability

Part B-1 – Intact stability

  1. Ships shall comply with the relevant provisions for passenger ships of the International Code on Intact Stability, 2008 (2008 IS Code; IMO Resolution MSC.267(85)), part A, as well as part B, chapter 3 and 8. If the vessel is sailing in conditions where ice accretion may occur, part B of the IS Code 2008, chapter 6 shall apply.
  1. Notwithstanding paragraph 29, if the inclining test is considered to be impractical, such a test may be replaced by a lightweight survey to the satisfaction of the Administration.
  1. In cases where a ship's characteristics render compliance with certain provisions of the 2008 IS Code impracticable, alternative requirements shall be in place to the satisfaction of the flag Administration.
  1. Notwithstanding the provisions of paragraph 29,

a.the maximum righting lever (GZ) shall occur at an angle of not less than 15o

b.For the calculation of the weather criterion for Class C and D ships, the wind pressure may be taken as 372 N/m2

For wind pressure, The 2008 IS code indicates that the value of the wind pressure used for ships in restricted service may be reduced subject to the approval of the Administration. According to this, French rules are:

For the parameter on the weather criterion, especially the pressure P due to the wind, it is retained value determined by h in respect with Table below :

P = pressure due to the wind to be determined by linear interpolation between the values ​​given in Table above (Pa)
h = vertical distance from the center of the projected lateral area of the vessel located above the waterline to the waterline (m)

This proposal has received the support of the expert group during the last meeting.

Part B-2 – Subdivision and damage stability

Subdivision

  1. Ships shall be fitted with a collision bulkhead complying with the following:
  1. The distance from the forward perpendicular shall be equal to or more than 5% and equal to or less than 8% of the length (L) of the ship;
  2. The collision bulkhead shall be watertight up to the bulkhead deck and on ships having a long forward superstructure it shall be extended at least weather tight up to the next deck above the bulkhead deck;
  3. Steps or recesses are only permitted within the length limits prescribed in 33.a2.a.;
  4. The number of penetrations by pipes through the collision bulkhead shall be kept to a minimum. Such pipes shall be fitted with valves installed on the front side of the bulkhead that shall be operable from above the bulkhead deck;
  5. Other penetrations in the part below the bulkhead deck are not allowed.

The requirement relating the long forward superstructure is considered useful only for RoRo ships. France doesn't know RoRo ships of less than 24 m. If the requirement must be kept, a definition of "long forward superstructure" must be given.

  1. Ships shall be further fitted with watertight bulkheads such that when any compartment – that is limited by such bulkheads - is flooded, the margin line of the ship will not be immersed.

Stability

  1. The stability of the ship:
  1. in the final conditionwhen any single compartment is flooded - and after equalisation where provided - shall comply with article II-1/B-3/10.2.3–II-1/B-3/10.2.5; and
  2. If the administration considers that the stability in intermediate stages may be insufficient, further investigation shall be required. In that case the intermediate stages of flooding of any single compartment shall comply with article II-1/B-3/10.2.6.
    Cette règle de stabilité impose un vent latéral en plus de l’avarie, elle est donc plus contraignante que la division 223b qui ne requiert que l’envahissement.
  1. Ships where asymmetrical flooding will occur shall comply with article II-1/B-3/10.5.
  1. The final condition of the ship after damage and, in the case of unsymmetrical flooding, after equalisation measures have been taken, shall comply with article II-1/B-3/10.6.
  1. For the purpose of making damage stability calculations:
  1. The ship shall be assumed to be in the worst service condition as regards stability which is likely to be experienced having regard to the intended service of the ship.
  2. The volume and surface permeability's shall comply with article II-1/B-3/10.3.
  3. The assumed extent of damage shall comply with article II-1/B-3/10.4.

Article II-1/B-3/10.4 gives longitudinal extent: 3,0 metres plus 3% of the length of the ship, or 11,0metres, or 10% of the length of the ship, whichever is less. For ships of less than 24 m, 10% of the length of the ships is always the less. Therefore a simplification is needed.

Article II-1/B-3/10.4 gives transverse extent: a distance of one fifth of the breadth of the ship. For multihull ships, the requirement has to be clarified.

Ce texte ne mentionne rien sur les expériences de stabilité requises

Part C – Machinery

General

  1. Ships shall comply with the standards of a recognized organisation and with the general provision from article II-1/C/1and II-1/E/1, except for II-1/E/1.3,

Due tothe regulationsof classification societies, evidence that a vesselmeets thestandardsis theclassification certificate. Article 39would thus requirevesselsless than 24mto be classified for machinerywhen nothingis required for the hull in this annex.
France considers that, for vessels under 24m,a check ofcalculationsof the hullstructural strengthis sufficient.The classification"machinery"of these vessels isanadditional economic costnotjustifiable.

With regard topropulsion,France considers thatpassenger shipsof classes B, C and Dshould beequipped with 2two totally independentmeans of propulsion. Indeed, theseshipsare always near the coastand thereforehave not thetime tomake repairsif the only propulsion engine is off. France istherefore requested thatthis requirement bestudied.

  1. Notwithstanding paragraph 39, class C and D ships need not be fitted with two fuel oil service tanks.

Internal combustion engines

  1. Internal combustion engines shall comply with article II-1/C/2.

Bilge pumping arrangements

  1. aBilge pumping arrangements shall comply with the general requirements in article II-1/C/3.1.1 – II-1/C/3.1.5.

b.Ships shall be provided with at least two fixed and independently powered pumps, one of the pumps shall be capable of being supplied by the emergency source of electrical power. The pumps shall not be located in the same space and one of the pumps may be driven by the main engine.

c.Suction pipes shall be arranged such that any compartment can be separately and effectively drained. The drainage of very small compartments may be dealt with by movableor fixed hand pumps.

d.Each bilge pump shall be capable of pumping water through the required main bilge pipe at a speed of not less than 1.2 m/sec.

e.The diameter of the main bilge and branch bilge suction pipes shall be that of the normally used pipes closest to the diameter determined by the following formula:
d = 1,68 x √(L x (B + D)) + 25
where d is the internal diameter in millimetres and L, B and D (in meters) respectively mean the Length, the Breath and the moulded Depth of the ship..

f.An audible and visual bilge alarm for the machinery space shall be provided on the navigating bridge.

g.Provisions shall be made to prevent the compartment served by any bilge suction pipe being flooded in the event of the pipe being severed or otherwise damaged by collision or grounding in any other compartment.

h.Distribution boxes, cocks and valves in connection with the bilge pumping system shall be so arranged that, in the event of flooding, one of the bilge pumps may be operative on any compartment. If there is only one system of pipes common to all the pumps, the necessary valves for controlling the bilge suctions must be capable of being operated from above the bulkhead deck. Such controls shall be clearly marked and provided with means to indicate whether they are closed or open.

iAn emergency bilge pumping system, if any, shall be independent of the main bilge pumping system.

Article II-1/C/3.1.1 § 1.3 says that all bilge pipes shall be of steel of other suitable material. This requirement is not suitable for ships made of alternative material. For example, on an aluminium hull vessel and for corrosion matter, the suitable material for bilge piping must be aluminium.

The formula for the branch bilge suction pipes is over the requirement for ships with a length more than 24 m and must be corrected.

Means of going astern

  1. The means of going astern shall comply with II-1/C/5.

Steering system

  1. a.Ships shall be provided with an efficient main and auxiliary steering system complying with II-1/C/6.1 – II-1/C/6.5, except for II-1/C/6.4.1.

b.The main steering system and if power operated, the auxiliary steering system, shall be operable from the navigating bridge.