IFSMA Monthly Logs

IFSMA records with deep sadness the loss  of  more  than  900  lives  in  the accident involving the ferry al-Salam Boccaccio 98 in the Red Sea in February.

During January and February 2006 IFSMA attended the following IMO meetings:-

The Sub-Committee on Fire Protection (FP), 50th session: 9-13 January 2006, the Sub-Committee on Standards of Training and Watchkeeping (STW): 23^rd to 27^th January 2006 and the Sub-Committee on Ship Design and Equipment (DE) held 20^th -24^th  February 2006.

IFSMA members also attended the meeting at ILO 94^th (Maritime) Session in Geneva.

The Secretary General attended the Nautical Institute Education and Training committee on the

Overseas:  In January, the Secretary General visited Buenos Aires in Argentina and met with Captain Marcos Castro and other senior members of the Argentina Association, Ctro de Caps de Ultramar Oficiales de la Marine Mercante. 

In February the Secretary General represented IFSMA at the Maritime Safety Umbrella Operation Seminar discussing the identification and planning of places of refuge within the EU.

We were represented by Captain Christof Luedeke at the recent Comite Maritime International (CMI), Cape Town Colloquium from 12 to 15 February, where our main interest was to promote the IFSMA paper on the Fair Treatment of Seafarers.

The IFSMA Executive Council meeting was held in Stockholm on 27^th and 28^th February.

The Sub-Committee on Fire Protection (FP), 50th session: 9-13 January 2006.

Celebrating its golden jubilee session, the IMO Secretary-General paid tribute to the Sub-Committee's work and invited everyone to reflect on the advances that had been achieved and had made significant contributions to the achievement of the objectives of the Organization. He pointed out that since the first meeting in 1964 there have been many advances in the field of fire protection engineering and in the regulations which incorporate fire safety technologies, drills and fire-fighting operations and practices on board ships. He highlighted, in particular, automatic sprinklers, inert gas systems, fire detection systems, machinery space fire extinguishing systems, automated safety control systems, new non-combustible materials and enhanced personal protection for fire-fighters, as a few examples and noted that ships and the seafarers that sail them now have a host of new technologies, which their predecessors could only have dreamed of, to both prevent and quickly mitigate fires when they occur.

Other key points discussed at the meeting were as follows:

Life-saving appliances and arrangements.

The Sub-Committee agreed there was a need for further work by the Ship Design and Equipment Sub-Committee, in particular with regard to improvements to requirements for on-load release mechanisms; improvements to free-fall lifeboat launching and seating arrangements; and compatibility of life-saving appliances, specifically compatibility of immersion suits and lifejackets; compatibility of immersion suits and lifeboat access and capacity; and compatibility of lifejackets and marine evacuation systems. The DE Sub-Committee recognised at its last session that the real problem was not the relationship between lifeboat capacity and immersion suits, but rather the increased weight and size of seafarers and passengers. Further statistical data was needed to allow a thorough analysis of the issue.

Prevention of accidents involving lifeboats.

The Sub-Committee agreed a draft amendment to SOLAS regulation III/19.3.3.4 concerning provisions for the launch of free-fall lifeboats during abandon ship drills, for submission to MSC 81 for approval and subsequent adoption. The amendment will allow, during the abandon-ship drill, for the lifeboat to either be free-fall launched with only the required operating crew on board, or lowered into the water by means of the secondary means of launching without the operating crew on board, and then manoeuvred in the water by the operating crew. The aim is to prevent accidents with lifeboats occurring during abandon-ship drills.

The Sub-Committee also agreed a draft MSC circular on early implementation of draft SOLAS regulation III/19.3.3.4 to encourage early implementation of the regulation prior to its entry into force.

It also agreed a draft MSC circular on Guidelines for the development of operation and maintenance manuals for lifeboats and a draft MSC circular on Measures to prevent accidents with lifeboats consolidating previous circulars MSC/Circ.1049, MSC/Circ.1093, MSC/Circ.1136 and MSC/Circ.1137. The draft consolidated circular includes the Guidelines for periodic servicing and maintenance of lifeboats, launching appliances and on-load release gear; Guidance on safety during abandon ship drills using lifeboats; and Guidelines for simulated launching of free-fall lifeboats.

Fire safety amendments for passenger ship safety.

Amendments to SOLAS chapter II-2 and the International Fire Safety Systems (FSS) Code were agreed as part of the comprehensive review on passenger ship safety, which began in 2000. The guiding philosophy for this work is based on the premise that the regulatory framework should place more emphasis on the prevention of a casualty from occurring in the first place and that future passenger ships should be designed for improved survivability so that, in the event of a casualty, persons can stay safely on board as the ship proceeds to port.

The Sub-Committee agreed draft amendments to SOLAS chapter II-2 and the FSS Code related to:

• safe areas and the essential systems to be maintained while a ship proceeds to port after a casualty;
• on-board safety centres, from where safety systems can be controlled, operated and monitored;
• fixed fire detection and alarm systems, including requirements for fire detectors and manually operated call points to be capable of being remotely and individually identified;
• prevention, including amendments aimed at enhancing the fire safety for atriums, the means of escape and ventilation systems.

The Sub-Committee also agreed proposed amendments related to time for orderly evacuation and abandonment, which includes requirements for the essential systems that must remain operational in case any one main vertical zone is unserviceable due to a fire casualty. The draft amendments will be considered by the Maritime Safety Committee (MSC) at its eighty-first session together with contributions from other sub-committees assigned work on this issue.

Other amendments to the FSS Code were also agreed by the Sub-Committee as part of a programme of work on harmonization, or new development of performance testing and approval standards for fire safety systems.

The amendments to the FSS Code will be forwarded to MSC 81 and concern portable foam applicators; fixed foam fire-extinguishing systems; and fixed pressure water-spraying and water-mist fire-extinguishing systems.

The Sub-Committee also agreed draft amendments to the revised Guidelines for the approval of equivalent fixed gas fire extinguishing systems for machinery spaces and cargo pump rooms (MSC/Circ.848); draft amendments to the Guidelines for the approval of fixed water-based local application fire-fighting systems for use in category A machinery spaces (MSC/Circ.913); and draft Guidelines for maintenance and inspections of fixed CO₂ systems. However, the amendments will not be forwarded to the Committee for approval until the harmonization exercise has been completed.

A correspondence group was established to continue the work on harmonizing and developing performance testing and approval standards for fire safety systems.

Life Saving Appliances amendments.

The Sub-Committee also agreed other draft amendments to SOLAS chapter III, the Life Saving Appliances (LSA) Code and the Recommendation for testing of life-saving appliances (LSA). They include:

SOLAS chapter III - draft amendments relating to:

• onboard communications and alarm systems
• survival craft muster and embarkation arrangements
• stowage of survival craft, rescue boats and marine evacuation systems
• survival craft launching and recovery arrangements
• operational readiness, maintenance and inspections
• servicing of inflatable liferafts, inflatable lifejackets, and marine evacuation systems, and maintenance and repair of inflated rescue boats
• periodic servicing of launching appliances and release gear
• survival craft and rescue boats
• immersion suits
• training manuals - which should be written in the working language or languages of the ship

LSA Code - draft amendments relating to:

• definitions
• life-jackets
• immersion suits
• requirements for liferafts
• requirements for lifeboats
• requirements for rescue boats
• additional requirements for fast rescue boats
• launching and embarkation appliances
• general alarm and public address systems

Recommendations on testing of LSA - draft amendments relating to:

• drop tests for lifebuoys
• tests for inflatable lifejackets
• testing of metallic components
• donning tests for non-insulated and insulated immersion suits and anti-exposure suits
• fabric tests for thermal protective aids for survival craft
• tests for pyrotechnics - rocket parachute flares, hand flares and buoyant smoke signals
• canopy closure tests on liferafts
• davit-launched lifeboat impact and drop tests
• lifeboat freeboard and stability tests
• release mechanism tests
• lifeboat operational tests
• air supply tests for lifeboats with a self-contained air support system
• rigid rescue boat and rigid fast rescue boats tests
• testing of davits and launching appliances
• tests on position-indicating lights for life-saving appliances
• tests for hydrostatic release units
• tests for launching appliances using falls and winches

The Sub-Committee on Standards of Training and Watchkeeping (STW) 37^th Session: 23^rd to 27^th January 2006.

The IMO Secretary-General drew attention to the widely reported shortage of seafarers, noted that the BIMCO/ISF manpower 2005 update provided a more encouraging picture than that projected in the 2000 study with the calculated shortage of officers being estimated at around 2%,  reportedly due to increased levels of training in the Asian region.

Measures to Prevent Accidents with Lifeboats

The Sub-Committee recalled that MSC 74 had included a new agenda item Measures to prevent  accidents  with  lifeboats.  to  be  co-ordinated  by  the  DE  Sub-Committee  in  the  work programme of the Sub-Committee (MSC 74/24, paragraph 21.34) and STW 35 had subsequently developed amendments to table A-VI/2-1 of the STCW Code, which were adopted at MSC 79 and would enter into force on 1 July 2006.

The Sub-Committee further recalled that STW 36 agreed that Administrations should also be permitted to accept, during drills, all free-fall lifeboats, irrespective of their launching heights, be launched by falls in lieu of free-fall launching, provided that a simulated free-fall launch was conducted at least every six months in accordance with the Organization.s guidelines and referred this view to DE 48 for consideration.  STW 36, also noting that the Committee was aware that this advice was in conflict with the existing provisions of SOLAS regulation III/19.3.3.4, had invited  MSC 80  to  instruct  the  DE Sub-Committee  to  consider  the  need  to  amend  the SOLAS Convention when addressing this issue.

The Sub-Committee noted (STW 37/6) that MSC 80 had endorsed the views expressed by STW  36,  and  in  view  of  the  need  to  reduce  some workload of DE 49, MSC 80 had agreed to move, on an  ad  hoc  basis  for  the  year  2006 only,  this  agenda  item  to  the  Sub-Committee  on Fire Protection (FP 50).

The Sub-Committee was informed that FP 50 had  prepared  the  draft  amendment  to  SOLAS  regulation  III/19.3.3.4  concerning  the launching of free-fall lifeboats during abandon ship drills as follows:

19.3.3.4  In the case of a lifeboat arranged for free-fall launching, at least once every three months during an abandon ship drill the crew shall board the lifeboat,  properly secure themselves in their seats and commence the launch procedure up  to but not including the actual release of the lifeboat (i.e., the release hook shall  not be released).  The lifeboat shall then either be free-fall launched with only the required  operating  crew  on  board,  or  lowered  into  the  water  by  means  of  the secondary  means  of  launching  without  the operating crew on board, and then manoeuvred  in  the  water  by  the  operating  crew.    At  intervals  of  not  more  than six  months,  the  lifeboat  shall  either  be launched by free-fall with only the operating crew on board, or simulated launching shall be carried out in accordance with the guidelines developed by the Organization and noted  that  the  provisions  of  MSC/Circ.1115  on  Prevention  of  accidents  in  high free-fall launching of lifeboats had been  superseded  by  the  new  draft  SOLAS  regulation III/19.3.3.4 and agreed that Administrations should be urged to effect early  implementation  of  the  draft  SOLAS regulation  III/19.3.3.4,  i.e. prior to its entry into force (FP 50/WP.3/Add.1, paragraphs 2 and 7).

The Sub-Committee agreed  that  it  was  necessary  for  seafarers  on  board  ships with  free-fall  lifeboats  to  have knowledge of actions  to  be  taken  when boarding free-fall lifeboats.  The Sub-Committee also agreed that while only seafarers assigned as operating crew of free-fall lifeboats should undergo training and actually participate on at least one occasion in a free-fall launch prior to boarding a vessel fitted with free-fall lifeboats, all seafarers serving on board such vessels should receive familiarization training in boarding and launching procedures for such lifeboats.

Accordingly  the  Sub-Committee,  taking  into  account  the  draft  amendment  to  SOLAS regulation III/19.3.3.4  agreed  by  FP  50,  prepared  draft  amendments  to  part  B  of  the  Seafarers Training,  Certification  and  Watchkeeping  Code  related  to  section  B-I/14  of  the  STCW  Code (Guidance regarding responsibilities of companies and recommended responsibilities of masters and crew members) providing guidance on familiarization and training for seafarers serving on board ships fitted with free-fall lifeboats and the associated STCW.6 circular set out in annex 1, and invited the Committee to adopt the amendments in accordance with its Rules of Procedure.

Proposed new model courses

IFSMA had brought to the attention of the sub committee at the 36^th meeting that there was a need for am AIS model training course.. The  Sub-Committee  gave  preliminary  consideration  to  the  draft  model  course  on  the Operational use of AIS (contained in document STW 37/3/1) and referred it to the drafting group to be established to consider and comment on the text.

There a also proposals to develop the following model courses:

• Chemical cargo and ballast-handling simulator;
• LPG cargo and ballast-handling simulator;
• LNG cargo and ballast-handling simulator;
• Familiarization training for LNG tankers; and
• Specialized training for LNG tankers,

and make them available to the Organization free of charge for the benefit of the international shipping  industry  and  for  circulation  to  the  validation  panel  for  its  comments  with  a  view  to validate them at the next session of the Sub-Committee.

Unlawful practices associated with Certificates of Competency.

In considering issues relating to  unlawful  practices  associated  with  certificates  of competency  and  the  means  to  prevent  them,  the secretary general  noted  that  the  Sub-Committee  would  be considering  advice  on  the  implications  for  the  Organization  if  the  nationality of individuals holding a fraudulent certificate was to be included in any report published by the Secretariat and hoped that further progress to prevent these dangerous and unlawful practices could be made.

Measure to enhance Maritime Security   

The Sub-Committee recalled that MSC 75 (MSC 75/24, paragraph 22.9) had decided to include in the work programme  of  the  Sub-Committee and provisional agenda for STW 34, a high-priority item on Measures to enhance maritime security. The Sub-Committee also recalled that STW 36 had prepared training and certification requirements for ship security officer as well as training requirements for company security officers.

With regard to training and certification of ship security officers MSC 80 had:

Approved  draft  amendments  to  the  STCW  Convention  along  with  the associated  draft  MSC resolution,  regarding  requirements  for  the  issue  of certificates of proficiency for ship security officers;

Approved  draft  amendments  to  part A of the STCW Code on Training requirements  for  issue  of  certificates  of  proficiency  for  ship  security officers; and  

approved  related  draft  amendments  to  part  B  of  the  STCW  Code  on Guidance  regarding  training  for  ship  security  officers  and  the  associated STCW.6 circular, to become operative on the same date as the entry into force  of  the  aforementioned  amendments  to  the  STCW  Convention  and part A of the STCW Code, with a view to adoption at MSC 81 (MSC 80/24, paragraphs 5.7 to 5.9);  Instruments  to  be  reviewed  and  amended so as to include appropriate security-related provisions

The Sub-Committee recalled that training and knowledge requirements for .the Company Security  Officer.  and  .appropriate  shore-based  personnel.;  .the  Ship  Security  Officer, shipboard personnel having specific  security-related  duties  and  all other shipboard personnel were set out in the ISPS Code (paragraphs B/13.1 to B/13.4) and agreed to refer both documents  to  the  working  group  to  be  established  to  consider  measures  to  enhance  maritime security, for detailed consideration.

The Sub-Committee agreed that the working group, to be established to consider measures to enhance maritime security, should identify the various aspects of the STCW Convention which may need to be reviewed and amended with  a  view  to  including therein appropriate security-related provisions.   Furthermore, the group should note that the Committee expected a holistic proposal on the matters which  needed  to  be  addressed and that the drafting of specific amendments would be initiated after the Committee had reviewed and endorsed the proposals of the Sub-Committee.

Education and Training Requirements for Fatigue Prevention, Mitigation and Management.

IFSMA arranged for the Nautical Institute to report on their research into fatigue at an informal session at STW subcommittee meetings and this was well received.

At has opening address the IMO Secretary General  drew  attention  to  the  outcome  of  recent  analyses  of  accidents which  indicated  that,  due  to  inappropriate  levels of manning and watchkeeping  arrangements, particularly in short sea voyages, fatigue had emerged as a significant contributory factor in accidents.    In  this  context,  the  IMO  principles  of  safe  manning  and  the  provisions related to watchkeeping  arrangements  and  hours  of  rest  within  the  STCW  Convention  were  arguably sufficiently  comprehensive.   

However,  against  the  background  of  continuing  accidents attributable to fatigue, he expressed the view that perhaps the time had come for these principles to  be  re-assessed,  possibly  by  the  identification  of  factors  against  which  maritime Administrations could evaluate proposed or actual manning levels on ships of similar types, size and trade.

The  Sub-Committee  recalled  that,  in  considering  the  report  of  the  Joint  MSC/MEPC Working Group on the Human Element (MSC 75/WP.10), MSC 75 had considered the issue of education and training for fatigue prevention, mitigation and management to be very important and of some urgency and had agreed to include, in the Sub-Committee’s work programme and provisional  agenda  for  STW  34,  a  high  priority  item  on  .Mandatory  education  and  training requirements for fatigue prevention, mitigation and management..

STW  34  had  decided  that  training  in  fatigue  management  should  be  addressed  through  voluntary  guidance  rather  than  mandatory  requirements  and  had  invited  Member  Governments  to  submit  information  on  their  experience  with  the application  of  the  Guidelines  on  fatigue, as set out in MSC/Circ.1014, and the hours of work and rest provisions in STCW chapter VIII and ILO Convention 180;

STW 35 had decided that, in light of no submissions from Member Governments related  to  their  experiences  with  the  application  of  the  above  provisions,  it  was premature to develop a model course, as proposed by the United States; and

STW 36 had agreed that, since only one submission related  to experiences with the application of the above provisions had been received, it was still premature to decide on this issue.

The  Sub-Committee,  noting  the  information  provided  by  some administrations requested the delegation to provide STW 38 with the results of the research and noted the information provided by a study commissioned by the Dutch Government concerning fatigue and fatigue prevention and that detailed findings could be submitted to MSC 81. In light of this the sub- committee requested MSC 81 to extend the target completion date to 2007.

Development of Competency for Ratings

The  Sub-Committee  recalled  that  MSC 79  had  considered  the  outcome  of  the ILO Preparatory Technical Conference and had instructed STW 36 to consider the issue and the possible implications arising from standards for training related to ratings being regulated by the Organization, and to suggest the best way forward to MSC 80 and that:

·     there was a need for ILO to consider the legal status of those countries that had ratified ILO Convention No.74;

·     there  was  a  need  to  provide  for  transitional  arrangements  for  seafarers  holding certificates issued under the provision of ILO Convention No.74;

·     the term  .able  seamen.  needed  to  be  retained  as  it  had  implications  within  the ILO regulatory framework, in particular to basic wage recommendations;

·     the proposed standards to be developed should include both deck and engine-room ratings, with a possibility of also addressing general purpose ratings; the  proposed  standards  should  follow  the  structure  of  the  present STCW Convention namely:

o    competence;

o    knowledge, understanding and proficiency;

o    methods of demonstrating competence; and

o    criteria for evaluating competence,

To  facilitate  the  development  of  competence  for  ratings,  STW 36  had  also established a correspondence group, under the co-ordination of the United Kingdom, to continue the work intersessionally.

The  Sub-Committee  agreed  with  the  proposal  of  the  correspondence  group  to  adopt  a two-stage  grading  structure  while  developing  competences  for  ratings without using the terms Grades 1 and 2, as follows

• entry  point  as  trainee  as  defined  by  paragraph 1 of existing regulations II/4 and III/4;
• deck and engine-room watchkeeping rating, as defined by existing regulations II/4 and III/4 respectively; and
• able  seafarer  and  motorman  as  defined  by  the  proposed  new  regulations  II/5 and III/5 respectively.

The Sub-Committee agreed that the proposed new grades of able seafarer and motorman should be trained and certificated in accordance with the requirements of existing regulations II/4 and III/4 respectively, prior to being certificated in the proposed new grades.  In this context, the Sub-Committee agreed that it was necessary to strengthen the requirements of chapters II and III by the inclusion of new draft regulations II/5 and III/5 for able seafarer and motorman respectively to reflect the proposed new grading structure.

The Sub-Committee also agreed that the existing requirements in regulations II/4 and III/4 were appropriate for deck and engine-room watchkeeping rating, and that in doing so, there was also no need to address the issue of new entrants/trainees since paragraph 1 of existing regulations II/4 and III/4 already provided for trainee ratings on board ship.

Some delegations were of the view that in order to provide flexibility, it was appropriate to  explore  the  possibility  of  developing  competences  for  General  Purpose  (GP)  ratings.    The Sub-Committee  therefore  agreed  that the proposed correspondence  group  should  be  tasked  to consider  the  need  for  the  development  of  training  and  certification  requirements  for  General Purpose (GP) ratings and prepare such requirements, if deemed necessary.

The Sub-Committee considered in detail the qualification requirements for the proposed new grading structure and agreed that the able seafarer should have proficiency in survival craft and rescue boats only but not in advanced fire-fighting  while  the  motorman  would  not  require training in either.

The  Sub-Committee  agreed  that  it  was  necessary  to  develop  definitions  for  the  terms .able  seafarer and motorman.  for  inclusion  in  the  STCW  Convention  to  reflect  the  proposed new ratings grading structure taking into consideration the definition in the ILO Certification of Able Seamen Convention, 1946 (C74).  Accordingly, the Sub-Committee prepared the following definitions for .able seafarer. and .motorman.:

• Able  seafarer  means  a  rating  qualified  in  accordance  with  the  provisions  of regulation II/5 of the Convention.
• .2  Motorman  means  a  rating  qualified  in  accordance with the provisions of regulation III/5 of the Convention.

In this context, the Sub-Committee also agreed that the proposed correspondence group should also explore the possibility of resolving the gender issue relating to the term .motorman.

The  Sub-Committee  discussed  in  detail  the  actual  seagoing  service  required  for certification as an able seafarer and agreed that it should be not less than 18 months or, not less that 12 months with completion of approved training.

The  Sub-Committee  agreed  the  actual  seagoing  service required  for  certification  as  a  motorman  should  be  not  less  than  12  months  or  not  less  than 6 months with completion of approved training.

The  Sub-Committee  considered  in  detail  the  mandatory  minimum  requirements  for certification of ratings as able seafarer, and as motorman in a manned engine-room or designated to perform duties in a periodically unmanned engine-room, to reflect the proposed new grading structure for ratings and also agreed that appropriate transitional arrangements should be put in place  so  that  existing  seafarers  certified  in  accordance  with  the  provisions  of  the ILO Certification of Able Seamen Convention 1946 (C74) are not at a disadvantage.

Revalidation of GMDSS Operators Certificate

The Sub-Committee noted that COMSAR 9, had invited  the  Committee  to  change  the  title  to  .Revalidation  of  GMDSS  operator’s  certificate. MSC 80 had concurred with the recommendations of both STW 36 and COMSAR 9 and had added  a  corresponding  new  work  programme  item  with  a  target  completion  date  of  2007  and included it in the agenda for STW 37.

 The Sub-Committee agreed that there was a real skills problems associated with GMDSS operators  and  that  the  long-term  solution  could  be  addressed  through  standardization  of equipment  and  operating  procedures.    In  this  context,  the  Sub-Committee  agreed  to  invite COMSAR 10  to  include  this  in  the  IMO  liaison  statement  to  WRC  2007.    As an immediate solution,  the  Sub-Committee  prepared  an  MSC  circular  on  promoting  and  verifying  continued familiarization  of  GMDSS  operators  on  board  ships,  as  set  out  in  annex  4  and  invited  the Committee to approve it.

Consolidated amendments to STCW Convention

The Secretary-General in his opening address, noted that the 1995 version of the STCW Convention had been amended four times since its adoption and was likely to be amended further over the medium-term, expressed the view that since more than ten years had elapsed since its last major revision, perhaps the time had come for the Sub-Committee to give some preliminary consideration to the need for, and the timing of, another comprehensive review of  the  Convention  to  ensure  that it met the new challenges facing the shipping  industry  in  the years to come and if appropriate to advise the MSC accordingly with full justification.

In considering the remarks made by the Secretary-General on the need for a preliminary consideration of another comprehensive review of the STCW Convention, the Sub-Committee, after an in-depth discussion, agreed that it was indeed necessary and timely to  undertake  such  a  review  of  the  STCW  Convention  and  the  STCW Code with a view to consolidating  the  various  changes,  additions  and  modifications  including  the  removal  of  any anomalies  that  could  arise.    This would ensure that the Convention meets the new challenges facing the shipping industry including, but not limited to, rapid technological advances today and in the years to come.

The Sub-Committee noted the following illustrative list of issues to be reviewed in the Convention and Code included:

• security provisions;
• development of competence for ratings;
• the review of .near coastal voyage.;
• competence standards for tankers, including LNG carriers;
• demonstration of competence;
• the review of alternative certification in chapter VII; and
• the criteria for safe manning and inclusion of rest provisions.

This being the case, the Sub-Committee also agreed that it would be appropriate at this stage to also harmonize the various inconsistencies that may arise during the review, and taking into account new  and innovative training methodologies including, but not limited to, the use of  simulator in training and e-learning.

The Sub-Committee further agreed that, taking into account the experience gained after the 1995 revision and a number of subsequent amendments, it would be more pragmatic  to  ensure  that  the  resulting  amendments  were  developed  concurrently  and therefore a comprehensive review of the STCW Convention and Code should be undertaken.

This will benefit Administrations, training institutions, ship-owners and seafarers  will  benefit  from  the proposed comprehensive review as follows:

• Administrations would need  to  amend  laws,  decrees  and  regulations  relating  to training and certification requirements only once, instead of several times, thereby saving legislative time and reducing administrative burden; 

• training institutions would need to revise their curriculum only once to meet these requirements resulting in more time being available for training; 
• shipowners would have the benefit of planning the training of its crew in a holistic manner, rather than in a piece meal process leading to saving of time and money; and
• seafarers normally have to undertake the new training requirements  during  their leave period after a long spell on board.  It would be beneficial for them to undertake these requirements in a single phase rather than every time they are on leave.

This matter should have high priority since there is benefit for all sectors of the industry. It is expected that the review could be completed by the end of 2008 with a proposed entry into force date of 1 January 2010.

The International Labour Conference 94^th (Maritime) Session in Geneva.

During this three week conference members of the ILO agreed to adopt an instrument consolidate maritime labour standards. Although the Provisional Record is with the Secretariat, time does not permit a meaningful explanation of this complex document at this time. However once ratified by sufficient members it will have a positive effect on our industry. 

The Sub-Committee on Ship Design and Equipment (DE) (49^th session)held 20^th -24^th  February 2006.

Much of DE’s woek is technical and routinely checks on equipment etc. Some interesting developments are listed below.

Mandatory Emergency Towing systems in ships other than Tankersof not less than  20,000 DWT

The  Sub-Committee  recalled  that  DE  48  had  established  a  correspondence  group  under the co-ordination of Germany and instructed it  to  prepare  a  proposal  for  draft  amendments  to SOLAS  regulation  II-1/3-4  on  Emergency  towing  arrangements  on  tankers,  and  related guidelines  for  the  assessment  of  deck  equipment  to be used in emergency  towing,  taking  into account comments and proposals made in plenary.

The  Sub-Committee  had  for  its  consideration  the  report  of  the  correspondence  group (DE 49/7) and also document DE 49/INF.3 (both by Germany).  The Sub-Committee noted that, due to a lack of commonly agreed scope and content of the procedures, the correspondence group had  not  been  able  to  develop  specific  wording  for  the  SOLAS  amendments  and  the  related guidelines as requested in its terms of reference.  The report contains, in annex 1, an outline for the draft amendments and related comments and, in annex 2, a rough outline for guidelines and related comments.  Document DE 49/INF.3 contains the report of a shipmaster on the connection of two tugs using both anchor chains under SW monsoon conditions and the subsequent towing of the vessel, intended to illustrate the issue under discussion.

The  Sub-Committee  agreed,  in  principle,  to  the  draft  amendments  to  SOLAS  regulation II-1/3-4 for further consideration at DE 50.

In the context of the possible application of the proposed draft SOLAS amendments and in  view  of  the  decision  made  earlier  to  apply  the  proposed  amendments  to cargo ships above 500 gross  tonnage  and  all  passenger  ships,  the  Sub-Committee  noted  possible  difficulties regarding the application to existing ships, in particular that in existing ships certain information may not always be available, e.g. capacity of bollards.  However, the Sub-Committee agreed that the proposed draft SOLAS amendments should apply to existing ships and the above-mentioned difficulties could be taken into account when developing the guidelines for procedures.  Bearing in mind that one date of coming into force for all ships, both new and existing, could lead to a bottleneck in developing the required procedures, the Sub-Committee agreed to split the date of entry  into  force  into  two  phases:  one  date  for  new  ships,  existing  cargo  ships  of  not  less than 20,000 dwt, and existing passenger ships; and another date for existing cargo ships of less than 20,000 dwt two years later.

Noting  that  SOLAS  regulation  II-1/3-4  requires  emergency  towing  arrangements  on tankers of not less than 20,000 dwt the Sub-Committee discussed the application of emergency towing  procedures  also  to  such  tankers.    Noting  further  that  the  existing  SOLAS  requirements  as  well  as  the  Guidelines  on  emergency  towing  arrangements  for  tankers,  adopted  by  resolution MSC.35(63), do not explicitly contain requirements for procedures, but on the other hand most  of  those  ships  are  provided  with  respective  procedures anyway, the Sub-Committee agreed to apply the new procedures also to tankers of not less than 20,000 dwt.

The  Sub-Committee  noted  the  comments  made  during  previous  meetings  and  in  the correspondence  group  and  discussed  the  exemption  of  ships  fitted  with  redundant  propulsion systems.    Some  delegations  were  of  the  opinion  that  having  a  redundant  propulsion  would significantly reduce the likelihood of a ship facing such emergency situations and consequently such additional investments in the ship’s safety should be encouraged by exemptions, while other delegations  felt   that  emergency  towing  procedures  would  be  beneficial  also  for  ships  having redundant propulsion. However, after further discussion, the Sub-Committee agreed not  to provide for exemption of ships having redundant propulsion systems.  In case of, for example, offshore supply vessels, it was mentioned that, in particular, such ships could be used for towing and, subsequently, it could be of additional value to reflect this different view in their onboard procedures.

Regarding the question as to whether to limit the procedures to towing over the bow only or not, aside from possible misinterpretations in case of, for example, double ended ferries, the Sub-Committee was of the opinion that there would be no benefits in such a limitation, in particular as the additional burden to extend the considerations for establishment of emergency towing procedures to towing over the aft would be minor.  Subsequently no such limitation to one end of a ship was included in the draft SOLAS amendments.

With regard to the draft SOLAS amendments, a certain affinity to the ISM requirements was  noted  and  it  was  discussed  whether  the  proposed  text  would  be  more  suitable  as  part  of SOLAS  chapter  IX.    However,  having  in  mind  the  different  concept  in  ship  management requirements,  it  was  agreed  that  detailed  requirements  closely  related  to technical equipment should  better  remain  in  SOLAS  chapter  II-1  and  to  refer  to  implications regarding ISM Code matters with a clear reference in the guidelines to be developed.

The Sub-Committee, noting the special characteristics and operational environment  of high-speed craft agreed to instruct the correspondence group (see below to consider the need of such procedures for high-speed craft, including the implications this might have for other instruments like the HSC Code.

Furthermore, the Sub-Committee noted possible implications on navigational issues and instructed  the  Secretariat  to  inform  the  NAV  Sub-Committee  about  the  ongoing  work  on emergency towing procedures in the Sub-Committee.

In order to progress the work on the item intersessionally, the Sub-Committee agreed to establish a correspondence group taking into account comments and proposals made in plenary, to finalize  the  related  guidelines  for  owners/operators  on  the  development  of emergency  towing  procedures. 

The  Sub-Committee  agreed  to  recommend  to  the Committee  an  extension  of  the  target completion date for the item to 2007 in order to complete the work at the next session.

Revision of the Guidelines for Handling Oily Wastes in  Machinery Spaces of Ships.

The Sub-Committee had for its consideration document DE 49/9, containing the draft revision of the Guidelines for systems for handling oily wastes in machinery spaces of ships (MEPC/Circ.235), incorporating the design concept of integrated bilge water treatment systems (IBTS).

During the discussion, while the draft revised circular was supported in principle, views were expressed that large quantities of waste water generated by automatic back-flushing oil had not  been  addressed  and  that  difficulties  could  be  expected  concerning  the  storage,  incineration and discharge ashore of slops with a very high water content. With  regard  to  the  flow  diagram  of  IBTS  (annex  1  of  document  DE  49/9),  The Sub-Committee agreed to include clean water tanks in the diagram.

The Sub-Committee considered that work on the item had been completed, and agreed to recommend to the MEPC the deletion of the item from the Sub-Committee’s work programme.

Rodger MacDonald

Secretary General