Will the Amendments to Tanker Damage Stability Regulations affect a ship owner’s fleet?

January heralds the start of another year, and usually another round of new requirements and amendments to existing rules for the Ship Operator to meet. In most cases, amendments to major Regulations only apply to new ships, and with good lead time. If they are retrospective

– i.e. applicable to existing ships – a procedural change is often adequate rather than the need for immediate capital expense on new equipment. Alternatively there are phase-in periods based on age of ship, to give the industry time to comply.

Retrospective issues such as ballast water management and MARPOL Annex VI emissions control are understandably foremost in Operators minds, as they may soon involve considerable capital outlay to ensure existing ships comply.

However there is another retrospectively applicable Regulatory Amendment which, while the cost to resolve may be relatively low (typically $25,000 for anapproved system, installed aboard), could have a significant influence on vessel operability if not addressed promptly. This is the amendment to MARPOL Annex 1, requiring a means to demonstrate compliance with damage stability regulations. Similar amendments have also been made to the BCH Code, IBC Code and IGC Code.

Loading Computers – The Solution? The provision of an onboard ‘Loadicator’ (more recently termed ‘Loading Instrument’ or ‘Loading Computer System (LCS)’) is not new. For many years, Class Rules have required an approved system onboard for the verification of longitudinal strength compliance. Not surprisingly some systems also included stability compliance modules, and in some cases these could cover damage stability as well as intact.

However, the formal approval of any LCS stability functions was not mandatory until IACS UR L5 came into force (later echoed by IMO in the 2008 IS Code) and then only for ships contracted for construction after July 2005. But even then, if an LCS was only set up to cover strength aspects this was still acceptable under UR L5.

The new amendments require tankers to have a means to assess intact and damage stability compliance by means of an approved ‘Type 3’ LCS

– which means a system which can examine all the damage scenarios required by the applicable Regulations, and confirm compliance.There are many existing ships with an LCS aboard, but this does not mean the system is approved (or even capable) to carry out the necessary damage stability calculations.

Some older systems cannot calculate damage stability to the rigour needed for a Type 3 assessment due to use of simple methodologies. In fact, over the last 20 years the number of LCS systems on the market has exceeded 50 but only a handful (such as QinetiQ’s SeaWeigh system) are capable of following an approved Type 3 approach.

The Areas of Concern

– One cannot guarantee a ship will comply simply because it already has an LCS aboard, even those installed since IACS UR L5 came into force. The LCS may not be formally approved for the required scope (if it is included at all), and it may not be upgradable to the current standard.

– The number of suppliers of Type 3 LCS systems is limited, and lead time for setting up and gaining approval for a new system can be 2-3 months. So adequate advanced warning and prompt procurement is a necessity.

– Waivers may be granted by Flag for alternative approaches, but these are highly likely to restrict operability of the vessel. For example, the use of a Type2 (damage limit curve) LCS is a feasible alternative but Lloyd’s Register (Class News No.17/2015) advised that ‘To avoid complications associated with developing suitable KG/GM limit curves and their potential restriction on operational capacity, we strongly recommend that Type 3 stability software is fitted onboard’.

– Implementation is phased, based upon the next renewal survey date (rather than date ofconstruction). This means, for example, that your 10 year old ship may require attention before your 16 year old vessel.

Ensuring that Your Ships Comply

– If not already advised by Class or Flag, for each ship in your fleet the status of approval of any existing onboard LCS should be confirmed as soon as possible. Where the current system is acceptable this should be clearly documented, for example on an updated ship’s Form B or Certificate of Fitness.

– Where an existing LCS system is deficient, the supplier should be approached to explore how this can be corrected. However, in many cases it may not be possible to upgrade older systems and therefore it is advisable to also promptly approach other suppliers offering a Type 3 LCS solution, and then compare scope and costs.

– When procurement of a new Type 3 LCS system is an option, consider any added benefits. A Type 3 approach requires a 3D model of the vessel, and so can offer operationally useful tools such as accurate draught/deadweight surveys and ullage reporting, trim optimisation and voyage planning. While some suppliers may supply such functions as add-on modules

– and so attract additional cost

– other providers may include useful ‘extras’ within their standard price. The potential benefits of any added value elements should be taken into consideration in the selection process.

QinetiQ are a supplier of a suitable Type 3 LCS solution SeaWeigh, and are able to guide Operators through the process of assessing solutions for their ships. To this aim, QinetiQ have published a White Paper on this issue which includes a handy ‘Do I comply’ chart, and this can be downloaded from :

Source: Philip Royal, Onboard Systems Product Manager, QinetiQ, as arranged on behalf of Hellenic Shipping News Worldwide