Good Day,

Australia will attend MSC 98 7-16 June 2017 and AMSA is preparing the
Australian Brief for the meeting.  Attached is the provisional agenda
for the meeting. Under Agenda item 20 there is a submission from Sweden
proposing a new output (agenda item) relating to the securing of cargo
on ships. Cargo securing is covered by Marine Order 42 in Australia.
Recipients of this message have registered an interest in being
consulted on either all Marine Orders or MO42 specifically. The proposal
MSC 98/20/10 is attached.

As noted in paragraph 2 of the submission:

"At its third session (5 to 9 September 2016), the Sub-Committee on
Carriage of Cargoes and Containers (CCC) considered document CCC 3/10/4
(IACS), proposing a unified interpretation on cargo securing based on
environmental conditions set out in annex 13 to the Code of Safe
Practice for Cargo Stowage and Securing (CSS Code). The Sub-Committee
could not reach agreement on the proposal and urged interested Member
States and international organizations to submit a proposal for a new
output under which the issue could be dealt with. In this document,
Sweden proposes that a new output to amend chapter 7 of annex 13 to the
CSS Code with a view to harmonization with other IMO instruments be
included in the biennial agenda of the CCC Sub-Committee. Proposed
amendments to chapter 7 of annex 13 to the CSS Code are provided in
annex 2."

The proposed output is described in paragraphs 16-18 inclusive and is as
set out in annex 3 of the submission. The proposed amendments are
introduced in paragraph 2 and are laid out in annex 2 of the submission.

We are seeking comments and views on the Swedish submission, if any, and
would appreciate if any such comments are provided to the
email address by 30 April 2017.

(Notes that may assist - the proposal relates to the Cargo Stowage and
Securing (CSS) Code - specifically chapter 7 of annex 13 of that Code.
The CSS Code is not specifically mandatory under SOLAS, however it is
described in SOLAS as being the source of information and calculations
for the mandatory under SOLAS Cargo Securing Manual (CSM) to be
developed for each ship. The Flag of the vessel (Adminstration) must
approve the CSM.

The CSS Code currently provides acceleration forces for every voyage
except 'restricted voyages'. The proposal is to add reduction factors
for restricted voyages in the CSS Code to assist the development of CSMs
on vessel on restricted voyages.

Australia notes that SOLAS Chapter VI applies to 'all ships' - it
actually applies to the carriage of cargoes not to ships on particular
voyages. In annex 3 of the proposal, the suggestion is that SOLAS in
this regard applies to international voyages on ships over 500 GT. This
seems incorrect noting SOLAS VI/1.1 states (bold added)

1 Unless expressly provided otherwise, this chapter applies to the
carriage of cargoes (except liquids in bulk, gases in bulk and those
aspects of carriage covered by other chapters) which, owing to their
particular hazards to ships or persons on board, may require special
precautions in all ships to which the present regulations apply AND IN
CARGO SHIPS OF LESS THAN 500 TONS GROSS TONNAGE. HOWEVER, FOR CARGO
SHIPS OF LESS THAN 500 TONS GROSS TONNAGE, THE ADMINISTRATION, IF IT
CONSIDERS THAT THE SHELTERED NATURE AND CONDITIONS OF VOYAGE ARE SUCH AS
TO RENDER THE APPLICATION OF ANY SPECIFIC REQUIREMENTS OF PART A OR B OF
THIS CHAPTER UNREASONABLE OR UNNECESSARY, MAY TAKE OTHER EFFECTIVE
MEASURES TO ENSURE THE REQUIRED SAFETY FOR THESE SHIPS.

Regulation 5.6 is the mandatory application of the CSM and refers to the
guidelines to Administrations (for format) and to the CSS Code for
developing that. It seems a good place to reference the guidelines on
cargo securing data reductions Administrations may consider, since the
CSM is certainly based on the data in the CSS Code. A proposal to amend
SOLAS (to add a new reference for example) isn't being made here though.

It appears that restricted voyages mentioned in the CSS code may best be
considered to be applicable to vessels of less than 500 GT, if the
Administration "considers that the sheltered nature and conditions of
voyage are such as to render the application of any specific
requirements of part A or B of this chapter unreasonable or unnecessary,
may take other effective measures to ensure the required safety for
these ship". If that is the case we believe it would be reasonable to
amend the CSS Code to more specifically reference these conditions as to
when the reduced accelerations (and hence reduce securing) can be
considered by the Administration. As proposed the references between the
mandatory parts of SOLAS and the non-mandatory CSS Code may cause
confusion and lead to parties other than the Administration of the
vessel, determining when reduced accelerations may be used).

DAVID ANDERSON

HEAD OF CARGOES AND TECHNICAL

SHIP INSPECTION AND REGISTRATION

OPERATIONS

82 Northbourne Avenue, Braddon ACT 2612

GPO BOX 2181, Canberra ACT 2601

P +61 2 6279 5070

F +61 2 6279 5058

M +61 408 222 195

E

W www.amsa.gov.au