Two more documents have been published by IMO on agenda item 11 dealing with safe mooring.
SDC 4/11/1 – Issues for further consideration regarding safe mooring operations – Japan
Proposed draft revised SOLAS regulation II-1/3-8 will apply to ships with gross tonnage of 3000 and above. In the correspondence group Japan commented that the threshold of 3000 gt is too low and should be reconsidered. Since the 3000 gt threshold was endorsed and instructed by MSC 95, the group did not consider Japan’s comments. In this document Japan raises its concern that for ship around 3000 gt installation of mooring winches as proposed in the draft guidelines would be extremely difficult due to smaller work areas for the ship’s crew and compliance with the draft guidelines will be difficult for smaller ships due to small deck areas. So Japan thinks some requirements of the draft guidelines should be carefully reconsidered. Japan also has concern on ship specific risk assessment in the design phase as this will increase administrative burden for the Administration or the RO to verify validity of expert judgements in the assessment before issuing certificates. Japan is against introducing the ALARP (As Low As Reasonably Practicable) concept in the guidelines as it will make the administrative burden even worse. Other issues in the guidelines Japan raised include consideration of berth configuration of the ports the ship is expected to call (tramp ships can go to any port, also change of ownership can be an issue) and harbour tug operations related to mooring not adequately addressed. Finally it proposes some generic guidelines for inspection and replacement of mooring lines.
SDC 4/11/2 – Comments on document 4/11 – ICS
Commenting on the report of the correspondence group (SDC 4/11), ICS has questioned the approach of the new draft guidelines which it thinks is confusing making it difficult for the Administrations, owners, operators, designers and ROs to comply. The concerns are discussed in details in paragraphs 4 – 11. ICS argues that the draft guidelines as annexed in SDC 4/11 needs further work and it will be premature to finalise it at SDC 4. Finally ICS proposes to finalise the draft revised SOLAS regulation II-1/3-8 referring to the guidelines as “to be developed by the Organization”.
Australia participated in the correspondence group and made substantial comments on the final draft of the guidelines most of which were not considered due to time constraints. We have no issue in asking the Sub-Committee to consider further work on the guidelines.
I am also resending the document SDC 4/11 containing the draft guidelines along with the these two documents for your quick reference.
Your comments by 25 January 2017 will be highly appreciated.
PRINCIPAL ADVISOR VESSEL SAFETY
82 Northbourne Avenue, Braddon ACT 2612
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