The IACS proposal about an interpretation of SOLAS Regulation V/23.3.3, as amended by resolution MSC.308(88) dimmed yesterday after a lengthly debate between member states and members with consultative
status.
In her proposal, IACS proposed an interpretation to the regulation, which states that '...for an adverse list of 15°; the securing strong point, shackles and securing ropes shall be at least as strong as the side ropes..'
IACS interpretation included a suggestion that, as it is a rare occassion that a ship have a list of 15 degrees, pilot could climb a ladder of longer than 9 metres in this exceptional case...
In the debate, a number of countries spoke in favor of IACS proposal, while a number of countries spoke against. The international body of pilots, IMPA, pointed out the ultimate concern which should be on the personal safety of pilots. IMPA did not support the proposal.
In summary, 11 member countries were in favor of the proposal and 8 were against, but however, in his summing up, committee chairman Mike Sollosi emphasized that SOLAS; is a convention taking the safety into account and in this case its pilot's safety; therefore this suggestion of IACS would need further reviewing.
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Background
1 SOLAS regulation V/23.3.3, as amended by resolution MSC.308(88) states: 3.3 Safe and convenient access to, and egress from, the ship shall be provided by either:.1 a pilot ladder requiring a climb of not less than 1.5 m and not more than 9 m above the surface of the water so positioned and secured that:.4 the single length of pilot ladder is capable of reaching the water from the point of access to, or egress from, the ship and due allowance is made for all conditions of loading and trim of the ship, and for an adverse list of 15°; the securing strong point, shackles and securing ropes shall be at least as strong as the side ropes; or.2 an accommodation ladder in conjunction with the pilot ladder (i.e. a combination arrangement), or other equally safe and convenient means, whenever the distance from the surface of the water to the point of access to the ship is more than 9 m ...2 IACS notes that the above text was developed as a consequence of a proposal made to MSC 82 as a result of which the NAV and DE Sub-Committees were to consider the matter further, with the NAV Sub-Committee being assigned as the coordinator. IACS therefore submits this paper to the NAV Sub-Committee for its consideration.Discussion3 SOLAS regulation V/23.3.3.1, as amended by resolution MSC.308(88), requires that where a single length of pilot ladder is used then it should require the pilot to climb not less than 1.5 m and not more than 9m with due allowance being made for all conditions of loading and trim of the ship, and for an adverse list of 15°. It was brought to the attention of IACS Members that there was a need to clarify the circumstances under which the "adverse list of 15°" should be applied to both single lengths of pilot ladder, and an accommodation ladder used in conjunction with the pilot ladder.4 In this regard it is noted that SOLAS regulation V/23.3.3.1 states that where a single length of pilot ladder is used, not involving a climb of greater than 9 m, "due allowance" is to be made for all conditions of loading and trim of the ship, and for an adverse list of 15°. Following discussion among its Members, IACS concluded that this adverse list of 15° was not one which would be experienced in normal service. It is an emergency condition and could therefore result in a climb of greater than 9 m being necessary. This "due allowance" therefore permits a pilot climb more than 9 m by an additional length of pilot ladder.5 Where an accommodation ladder is used in conjunction with the pilot ladder, whenever the distance from the surface of the water to the point of access to the ship is more than 9 m, in accordance with SOLAS regulation V/23.3.3.2, no reference is made to allowance for an adverse list of 15°. This SOLAS regulation and section 3 of resolution A.1045(27) refer to the arrangement where an accommodation ladder is used in conjunction with the pilot ladder. These references do not contain a 15° list requirement, and it was therefore concluded that this requirement is not applicable for "an accommodation ladder in conjunction with the pilot ladder".6 To address the above issues IACS has developed UI SC 257, a copy of which is provided at the annex to this document. Paragraph 1 of the UI covers a pilot ladder alone, and paragraph 2 covers a pilot ladder used in conjunction with an accommodation ladder.7 The Sub-Committee is invited to note that IACS Members will uniformly implement UI SC 257 on ships contracted for construction on or after 1 July 2013, unless otherwise instructed by the Administration on whose behalf they are authorized to act as a Recognized Organization. The Sub-Committee is invited to agree that if it develops a draft IMO circular based on the attached IACS UI, and if this draft IMO circular includes a recommended implementation date that is based on the construction date of ships, then that construction date should be at least [16] months after the contracted for construction date referred to in the IACS UI. This would correspond to approximately six months after MSC 93 meets in May/June 2014.Action requested of the Sub-Committee8 The Sub-Committee is invited to consider the foregoing; the copy of IACS UI SC 257 as provided at annex and the application provisions as discussed in paragraph 6 above, and decide as appropriate.
In her proposal, IACS proposed an interpretation to the regulation, which states that '...for an adverse list of 15°; the securing strong point, shackles and securing ropes shall be at least as strong as the side ropes..'
IACS interpretation included a suggestion that, as it is a rare occassion that a ship have a list of 15 degrees, pilot could climb a ladder of longer than 9 metres in this exceptional case...
In the debate, a number of countries spoke in favor of IACS proposal, while a number of countries spoke against. The international body of pilots, IMPA, pointed out the ultimate concern which should be on the personal safety of pilots. IMPA did not support the proposal.
In summary, 11 member countries were in favor of the proposal and 8 were against, but however, in his summing up, committee chairman Mike Sollosi emphasized that SOLAS; is a convention taking the safety into account and in this case its pilot's safety; therefore this suggestion of IACS would need further reviewing.
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Background
1 SOLAS regulation V/23.3.3, as amended by resolution MSC.308(88) states: 3.3 Safe and convenient access to, and egress from, the ship shall be provided by either:.1 a pilot ladder requiring a climb of not less than 1.5 m and not more than 9 m above the surface of the water so positioned and secured that:.4 the single length of pilot ladder is capable of reaching the water from the point of access to, or egress from, the ship and due allowance is made for all conditions of loading and trim of the ship, and for an adverse list of 15°; the securing strong point, shackles and securing ropes shall be at least as strong as the side ropes; or.2 an accommodation ladder in conjunction with the pilot ladder (i.e. a combination arrangement), or other equally safe and convenient means, whenever the distance from the surface of the water to the point of access to the ship is more than 9 m ...2 IACS notes that the above text was developed as a consequence of a proposal made to MSC 82 as a result of which the NAV and DE Sub-Committees were to consider the matter further, with the NAV Sub-Committee being assigned as the coordinator. IACS therefore submits this paper to the NAV Sub-Committee for its consideration.Discussion3 SOLAS regulation V/23.3.3.1, as amended by resolution MSC.308(88), requires that where a single length of pilot ladder is used then it should require the pilot to climb not less than 1.5 m and not more than 9m with due allowance being made for all conditions of loading and trim of the ship, and for an adverse list of 15°. It was brought to the attention of IACS Members that there was a need to clarify the circumstances under which the "adverse list of 15°" should be applied to both single lengths of pilot ladder, and an accommodation ladder used in conjunction with the pilot ladder.4 In this regard it is noted that SOLAS regulation V/23.3.3.1 states that where a single length of pilot ladder is used, not involving a climb of greater than 9 m, "due allowance" is to be made for all conditions of loading and trim of the ship, and for an adverse list of 15°. Following discussion among its Members, IACS concluded that this adverse list of 15° was not one which would be experienced in normal service. It is an emergency condition and could therefore result in a climb of greater than 9 m being necessary. This "due allowance" therefore permits a pilot climb more than 9 m by an additional length of pilot ladder.5 Where an accommodation ladder is used in conjunction with the pilot ladder, whenever the distance from the surface of the water to the point of access to the ship is more than 9 m, in accordance with SOLAS regulation V/23.3.3.2, no reference is made to allowance for an adverse list of 15°. This SOLAS regulation and section 3 of resolution A.1045(27) refer to the arrangement where an accommodation ladder is used in conjunction with the pilot ladder. These references do not contain a 15° list requirement, and it was therefore concluded that this requirement is not applicable for "an accommodation ladder in conjunction with the pilot ladder".6 To address the above issues IACS has developed UI SC 257, a copy of which is provided at the annex to this document. Paragraph 1 of the UI covers a pilot ladder alone, and paragraph 2 covers a pilot ladder used in conjunction with an accommodation ladder.7 The Sub-Committee is invited to note that IACS Members will uniformly implement UI SC 257 on ships contracted for construction on or after 1 July 2013, unless otherwise instructed by the Administration on whose behalf they are authorized to act as a Recognized Organization. The Sub-Committee is invited to agree that if it develops a draft IMO circular based on the attached IACS UI, and if this draft IMO circular includes a recommended implementation date that is based on the construction date of ships, then that construction date should be at least [16] months after the contracted for construction date referred to in the IACS UI. This would correspond to approximately six months after MSC 93 meets in May/June 2014.Action requested of the Sub-Committee8 The Sub-Committee is invited to consider the foregoing; the copy of IACS UI SC 257 as provided at annex and the application provisions as discussed in paragraph 6 above, and decide as appropriate.