INTERNATIONAL MARITIME ORGANIZATION E - … lifebuoy shall be suspended from its upper edge via a release device so that the lower edge of the lifebuoy will be at the required height

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For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.

INTERNATIONAL MARITIME ORGANIZATION

IMO

E

SUB-COMMITTEE ON SHIP DESIGN AND EQUIPMENT 47th session Agenda item 9

DE 47/9/1 28 November 2003 Original: ENGLISH

PERFORMANCE TESTING AND APPROVAL STANDARDS FOR SOLAS PERSONAL

LIFE-SAVING APPLIANCES

International approval procedures for life-saving appliances evaluation and test report forms and resolution MSC.81(70)

Submitted by the International Life-saving Appliance Manufacturers' Association

(ILAMA)

SUMMARY

Executive summary:

The Sub-Committee is asked to consider amendment of resolution MSC.81(70), MSC/Circ.980, MSC/Circ.980/Add.1 and Add.2, SOLAS and the LSA Code as applicable.

Action to be taken:

Paragraph 6

Related documents:

LSA Code; SOLAS; resolution MSC.81(70); MSC/Circ.980; MSC/Circ.980/Add.1 and Add.2; DE 43/WP.6; DE 45/19/1 and DE 45/19/2

1 During the formulation of the evaluation and test reports, the working groups concerned produced a list of issues that needed further consideration or clarification. This list appeared at annex 3 of DE 43/WP.6. 2 ILAMA submitted papers DE 45/19/1 and DE 45/19/2 for the Sub-Committee to consider as appropriate. Both papers received support at DE 45 and DE 46, whereby it was decided to review the papers in full at DE 47 (DE 46/32, report to the Maritime Safety Committee, paragraphs 14.6 and 14.7). 3 Referring to ILAMA paper DE 45/19/2 and taking into the consideration the significant workload at DE 47, the ILAMA Technical Committee has produced the following submission to assist the DE 47 Sub-Committee. 4 Each of the 78 items contained in annex 3 of DE 43/WP.6 have been considered by ILAMA and proposals have been listed against these. These proposals are contained in the annex to this paper.

DE 47/9/1 - 2 -

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5 ILAMA paper DE 45/19/1 concerning the flash duration survival locator lights is self-explanatory and requires no additional comment. Action requested of the Sub-Committee 6 The Sub-Committee is requested to consider the above and decide as appropriate.

***

DE 47/9/1

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ANNEX

ISSUES WHICH NEED FURTHER CONSIDERATION OR CLARIFICATION

Issue Reference to paragraph of the LSA Code

Reference to paragraph of MSC.81(70)

Remarks

1 General whole Heading of paragraph to be checked

No Comment by ILAMA at this stage

2 Method to drop lifebuoys 2.1.1.6 1/1/3 Drop test does not provide

method to drop

Proposed Text / Amendment The lifebuoy shall be suspended from its upper edge via a release device so that the lower edge of the lifebuoy will be at the required height for approval.

3 Requirement to seal battery compartment to prevent tempering

1.2.2.10

Amendment to MSC.81(70) Paragraph 10.4.7 Rain Test and Watertightness Test insert: [It shall be established that the battery housing is completely sealed to prevent unauthorised tampering or battery removal, without the use of tools.] Amendment to MSC/Circ. 980 Paragraph 2.1.2.1.4 Visual Inspection-Electrical Short Circuit Protection. Paragraph 2.2.3.1.4 Visual Inspection-Electrical Short Circuit Protection. Paragraph 4.3.6.1.4 Visual Inspection-Electrical Short Circuit Protection. Add the following text to each of the above paragraphs: [If the unit contains a lithium battery dry-cell, the housing containing the cell must be completely sealed to prevent unauthorised tampering or battery removal without the use of tools.]

4 Measurement method of smoke colour and obscuration to be separated

1.2.2 and 2.1.3 1/4.8.3

Amendment to MSC.81(70) 4.8.3 Laboratory testing of the smoke signal should establish that at least 70% obscuration throughout the minimum emission time is attained when the smoke is drawn through a 19 cm diameter duct by a fan capable of producing an entrance air flow of 18.4 m3/min. The colour of the smoke should be orange as defined by sections 34,48,49 or 50 of the publication color: Universal Language and Dictionary of names. * * Special Publication 440, National Institute of Science and Technology, Gaithersburg, Md., 20899-0001, USA.

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Insert new paragraph 4.8.3 [4.8.3 Laboratory testing of smoke density and colour. To be conducted at an ambient temperature of +20oC to +25oC as follows: 4.8.3.1 The smoke shall be blown through an apparatus consisting of a 190 mm diameter duct with a fan capable of producing an entrance air flow of 18.4 m3/min. By means of a light source with at least 10cd on one side of the tunnel and a photoelectric cell on the other side the density of the passing smoke is to be recorded.

If the photocell picks up the total emitted light from the light source then the smoke density is zero percent which means that no smoke is passing through the tunnel. The smoke density is then considered to be 100 % when the photocell is not able to pick up any light of the light source through the passing smoke in the tunnel. From the amount of light which the photocell is able to pick up the smoke density is calculated.

Before each measurement the light intensity of the 100% value shall be checked. Each measurement shall be recorded.

4.8.3.2 The colour of the orange smoke shall be evaluated by means of visual comparison, in daylight, to a colour comparison chart containing the range of acceptable orange colours.

The colour comparison chart shall have a gloss or matte finish, and shall consist of a series of at least five orange colour chips, covering the range from reddish orange (Munsell notation 8.75 YR 6/14) to yellowish orange (Munsell notation 5 YR MAX) in gradual steps of hue, chroma, and lightness.

NOTE A typical acceptable progression would be 8.75 YR 6/14 ; 10 R 6/14 ; 1.25 YR 6/14 ; 3.75 YR MAX ; 5 YR MAX.

NOTE ASTM D1535-97 specifies a method to convert between Munsell notation and CIE co-ordinates.

The colour chips shall be secured adjacent to one another, in order of progression from reddish orange to yellowish orange, and shall extend on at least one side to the edge of the chart. Each colour chip shall be at least 50 mm x 100 mm in size.]

Delete Footnote * Special Publication 440,National Institute of Science and Technology, Gaithersburg, Md., 20899-0001, USA. Amendment to MSC/Circ.980 Amend paragraphs 2.1.3.9 and 3.3.10 to confirm test temperature of +20oC to +25oC in column 3.

5 Temperature at which the smoke obscuration test is carried out

1.2.2 and 2.1.3 1/4.8.3 To be specified in test procedures

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Amendment to MSC.81(70) Laboratory testing of smoke density and colour to be conducted at an ambient temperature of +20oC to +25oC as shown in new paragraph 4.8.3 above. Amendment to MSC/Circ.980 Amend paragraphs 2.1.3.9 and 3.3.10 to confirm test temperature of +20oC to +25oC in column 3.

6 Strength test of attaching devices to the lifebuoy

1.2.2, 2.1.3 and 2.1.1.6

Amendment to MSC.81(70) 1.9.6 A force of 225 N should be applied to the fitting that attaches the self-activating smoke signal to the lifebuoy. Neither the fitting nor the signal should be damaged as a result of the test. Amendment to MSC/Circ.980 Add new strength test 3.3.14 to page 264. Add new test page as above. [Test Procedure: A force of 225 N should be applied to the fitting that attaches the self-activating smoke signal to the lifebuoy. Acceptance Criteria: Neither the fitting nor the signal should be damaged as a result of the test; the unit should also function after the test. Significant Data: Pass. Fail.] 7 Material requirements for inherent buoyant lifejackets

2.2 To be developed

Proposed Text / Amendment Materials shall comply with the requirement of C.EN396. 8 Jump test for children�s lifejackets

2.2.1.2.5 2.2.1.5

1/2.9.6. 2.10

Such test can be done by using manikin

Proposed Text / Amendment Five test subjects within the weight range of 41 to 57 kg shall perform the drop test as described in 2.2.1.18 For weight ranges 9 � 25kg and 25 � 41kg a suitable manikin should be used in lieu of test subjects.


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9 Appropriate corresponding measures (immersion suits)

2.3.2.1. 1/3.2.4 Relationship between human and manikin to be clarified

Proposed Text / Amendment A thermal manikin shall produce readings of heat loss from the same body areas as those required when using human test subjects. 10 Tests for inflatable lifejackets 2.2.1 & 2.2.2 1/2/11/1, 2.11.2

& 2.11.3 Discrepancy between A689(17) and MSC.81(70) to be resolved

Proposed Text / Amendment MSC.81(70) does not contain the reference numbers referred to tests as defined in MSC.81(70) and DE 43/3 evaluation and test forms are the same as A.698(17) plus some additional testing. 11 Righting test for immersion suits 2.3.3 1/3.1.8 Test is carried out with or

without a lifejacket

Proposed Text / Amendment If an immersion suit is designed to be worn with a lifejacket, all in water tests shall be performed by test subjects wearing approved lifejackets.

The above mentioned item is still open for discussion / amendments. Reference to agenda item 7 proposed provisional agenda for DE 47. It is strongly recommended to include fast rescue boat requirements into the LSA Code. Heavy weather test and other items of fast rescue boat operation require further consideration by the DE Sub-Committee

13 Rescue boat visibility from helmsman position

4.4.7.12 Requirements should be identical as those to lifeboats

Lifeboats: LSA Code (MSC.48(66)) 4.4.7.12; Every lifeboat shall be so arranged that an adequate view forward, aft and to both side is provided from the control and steering position for safe launching and manoeuvring.

12 Requirements for rescue boats and fast rescue boats

chapter V 1/section 7 To be thoroughly reviewed in order to clarify the application of the requirements in section 7 Discrepancy between A.689(17) and MSC.81(70) to be resolved

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Rescue boats: In the LSA Code no reference is made to regulation 4.4.7.12 to be applicable for rescue boats. This requirement to be added to the LSA Code and subsequently added to the test programmes. Proposed amendments LSA Code (MSC.48(66)) 5.1.1.1 Except as provided �� 4.4.7.9, 4.4.7.10,[4.4.7.12] and 4.4.9.

14 Engine Throughout the LSA Code and the resolution, the word "engine" should be replaced by propulsion system

Propulsion system means complete unit including shafting, propeller, water jet or whatever. But engine suppliers only shall and can only test the engine and not complete unit. Here no changing in the regulations is applicable. It is therefore recommended NOT to change the LSA Code and resolution MSC.81(70) in this respect.

15 Material of inflatable rescue boats 1/5.17.8 Rubber is not the only material used for inflatable rescue boats

Proposed amendments MSC.81(70) Part 1 paragraph 5.17.8 Following change is recommended in the text; �.compartment rubber material (delete word rubber).

16 Inflatable liferaft, righting test 1/5.17.2 Alternative test to be further clarified

No comment by ILAMA at this stage.

17 Number of persons to lie down 5.1.1.3 1/7.1.3 For rescue boat carrying more than 6 persons

LSA Code (MSC.48(66)) 5.1.1.3.2 ...be capable of carrying at least five seated persons and a person lying on a stretcher. .... MSC.81(70) Part 1, paragraph 7.1.3 : The rigid rescue boat should be fitted with its engine and all its equipment. The number of persons for which the rescue boat is to be approved, having an average mass of at least 75 kg, and all wearing lifejackets and immersion suits and any other essential equipment required, should then board; one person should lie down and the others should be properly seated in the


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rescue boat. The rigid rescue boat should then be manoeuvred and all equipment on board tested to demonstrate that it can be operated without difficulty or interference with the occupants. Both LSA Code (MSC.48(66)) and MSC.81(70) are quite clear: there should be one lying person- it doesn�t matter if the capacity of the boat is min. 6 or 20 persons. Therefore no change is required in this respect. There is however another discrepancy: The LSA Code MSC.48(66) asks for a person lying on a stretcher while resolution MSC.81(70) asks for one lying person only. This makes large difference in size and necessary support. One version should be chosen and a size for this should be defined to avoid further discussion. Furthermore the requirement to wear lifejackets and immersion suits during seating is mentioned in resolution MSC.81(70) but not in LSA Code MSC.48(66). Proposed amendments LSA Code (MSC.48(66)) 5.1.1.3.2 ..be capable of carrying at least five seated persons and a person lying on a stretcher, [all wearing lifejackets and immersion suits] MSC.81(70) Part 1, paragraph 7.1.3 The rigid rescue boat should be fitted with its engine and all its equipment. The number of persons for which the rescue boat is to be approved, having an average mass of at least 75 kg, and all wearing lifejackets and immersion suits and any other essential equipment required, should then board; one person should lie down [on a stretcher (2000 x 400 mm)] and the others should be properly seated in the rescue boat. The rigid rescue boat should then be manoeuvred and all equipment on board tested to demonstrate that it can be operated without difficulty or interference with the occupants.

18 Inspection of no damage after the test of release mechanism of rigid rescue boats/rigid fast rescue boats

4.4.1.3.2 1/6.9.4 To be clarified

LSA Code (MSC.48(66)) 4.4.1.3.2 be capable of being launched and towed when ship is making headway at a speed of 5 knots in calm water. MSC.81(70) Part 1 paragraph 6.9.4 It should be demonstrated that the ��.. There is a wrong reference in �Annex 3�: instead of Part 1 paragraph 6.9.4 it should be referenced to Part 1 paragraph 6.11.1 where it is clearly stated that �there should be no damage to the lifeboat or its equipment as a result of this test�. However Part 1 paragraph 6.9.4 contains some confusing items that should be resolved during this opportunity:

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6.9.4.1 �a force equal to the force necessary to tow the lifeboat at a speed of 5 knots�.� : nobody knows this force; neither surveyor nor hook manufacturer. Example from actual test: a 10 t lifeboat with 2 x 5 t SWL hooks which can drive 6 knots executes a bollard pull of approximately 400 kg- the towing force at 5 knots should therefore be a little bit less, maybe 350 kg. Under 45° towing this increases to approximately 500 kg which is 10% of the SWL. To include some safety margin, we would propose this force to be 25% of the hook SWL. 6.9.4.3 �a force equal to the SWL of the hook should be applied to the hook in a direction halfway between the position of tests 1 and 2 within the ellipse segment formed by 1 and 2�: During tests no surveyor could explain what is meant. Therefore often the SWL of the hook is used for towing with an angle of 33° as average between 20° and 45°. Proposed amendments 6.9.4 It should be demonstrated that the release mechanism can release the fully equipped lifeboat when loaded with weights equal to the mass of the number of persons for which the lifeboat is to be approved, when the lifeboat is being towed at speeds up to 5 knots. In lieu of a waterborne test, this test may be conducted as follows:

.1 A force equal to the force necessary to tow the lifeboat at a speed of 5 knots [20 % of the safe working load of the hook] should be applied to the hook in the lengthwise direction of the boat at an angle of 45° to the vertical. This test should be conducted in the aftward as well as the forward direction, depending upon the design of the release hook;

.2 A force equal to the safe working load of the hood should be applied to the hook

in an athwartships direction at an angle of 20° to the vertical. This test should be conducted on both sides.

.3 A force equal to the safe working load of the hook should be applied to the hook

in a direction half-way between the positions of tests 1 and 2 [(i.e. 45° to the longitudinal axis of the boat in plan view)] and within the ellipse segment formed by 1 and 2 [at an angle of [33°] to the vertical]. This test should be conducted in four positions.

19 Minimum number of persons being carried by liferaft which the rescue boat can tow

4.4.6.8, 5.1.1.7 and 5.1.1.9

1/7.1.2 Requirements to be made consistent

LSA Code (MSC.48(66)) 4.4.6.8 (Lifeboats) The speed of the lifeboat when proceeding ahead in calm water, when loaded with its full complement of persons and equipment and with all engine-powered auxiliary equipment in operation, shall be at least 6 knots and at least 2 knots when towing a 25-persons ��..


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5.1.1.7 (Rescue boats) �.tow the largest life raft carried on the ship when loaded with it�s full complement of persons and equipment or its equivalent at a speed of at least 2 knots. 5.1.1.9 (Rescue boats) Arrangements for towing shall be permanently fitted in rescue boats and shall be sufficiently strong�� MSC.81(70) Part 1 paragraph 7.1.2 (rescue boats and fast rescue boats) The largest size of fully loaded liferaft which the rigid rescue boat can tow at a speed of at least 2 knots should be determined. Alternatively the maximum towing force of the rescue boat should be determined. The maximum towing force of the rescue boat should be recorded on the type approval certificate. This information should be used to determine the largest fully loaded liferaft the rescue boat can tow at two knots. The fitting designated for towing other craft should be secured to a stationary object by a tow rope. The engine shall be operated ahead at full speed for a period of at least 2 minutes. There shall be not damage to the towing fitting or its supporting structure. Proposed amendments To make regulations consistent and use only one method for testing we suggest to delete the first sentence of MSC.81(70) Part 1 paragraph 7.1.2; The largest size of fully loaded liferaft which the rigid rescue boat can tow at a speed of at least 2 knots should be determined. Alternatively the maximum towing force of the rescue boat should be determined. The maximum towing force of the rescue boat should be recorded on the type approval certificate. This information should be used to determine the largest fully loaded liferaft the rescue boat can tow at two knots. The fitting designated for towing other craft should be secured to a stationary object by a tow rope. The engine shall be operated ahead at full speed for a period of at least 2 minutes. There shall be no damage to the towing fitting or its supporting structure.

20 Re-start requirements of the engine after the righting test

1/7.1.7 To be clarified

MSC.81(70) Part 1 paragraph 7.1.7 (rescue boats and fast rescue boats) It should be demonstrated that both with and without engine and fuel or an equivalent mass in place of the engine and fuel tank, the rescue boat is capable of being righted by not more than two persons if it is inverted on the water. Part 1, 6.14.2 (fast rescue boats which are self- righting) At the beginning of these tests, the engine should be running in neutral position and:

.1 �.. .2 if the engine is arranged to stop automatically when inverted, it should be easily

restarted and run for 30 min after the lifeboat has returned to the upright position.

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MSC/Circ.809/ 4.1.8 ��.. when the rescue boat has righted, each engine or motor should be capable of being restarted�.� Proposed amendments For fast rescue boats which are self-righting engine re-start is defined in MSC.81(70) Part 1 paragraph 6.14.2.2. For fast rescue boats which are NOT self- righting a definition for engine restart should therefore be added to MSC.81(70), Part 1, paragraph 7.1.7: 7.1.7 It should be demonstrated that both with and without engine and fuel or an equivalent mass in place of the engine and fuel tank, the rescue boat is capable of being righted by not more than two persons if it is inverted on the water.

[.1 In case of fast rescue boats which are NOT self- righting the engine is arranged to stop automatically when inverted. It should be easily restarted and run for 30 min after the lifeboat has returned to the upright position.]

21 Serious deformation of the life-raft 1/5.11 Criteria to be developed 22 Significant accumulation of water in the life-raft

1/5.12 Criteria to be developed

No comment on these items by ILAMA at this stage.

Issue

Reference to paragraph of the

LSA Code

Reference to Paragraph of MSC.81 (70)

Remarks

23 Words �sea-activated� and �dry activated�

1/10.1.2 and 1/10.1.3

To avoid confusion, these to be replaced by �sea-cell� and �dry cell�

Amendment to MSC.81(70) 10.1.2 In the case of sea-activated [seawater-cell] power sources, four survival craft lights of each type should, etc.etc. 10.1.3 In the case of dry-activated [dry-cell] power sources, provided they will not come into contact with seawater, etc.etc.

Amendment to MSC/Circ.980 4.3.6.3 Light Tests Column 1 Test Procedure Line 1 Paragraph 1 �In the case of sea-activated [seawater-cell] power sources, four etc. etc. Line 1 Paragraph 2 �In the case of dry-activated [dry-cell] power sources, etc. etc.


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24 Highly visible colour 1.2.2.6 Not consistent see: LSA Code

4.5.2.4 and 4.5.3

Proposed amendments LSA Code (MSC.48(66)) 1.2.2.6 be of a highly visible colour on all parts where this will assist detection. 4.5.2.4 its exterior is of a highly visible colour [on all parts where this will assist detection] and its interior is of a colour which does not cause discomfort to the occupants. 4.5.3 The interior of the lifeboat shall be of a highly visible colour [which does not cause discomfort to the occupants.] 4.6.2.8 Its exterior is of a highly visible colour [on all parts where this will assist detection] and its interior is of a colour which does not cause discomfort to the occupants.

25 Fire retardant material 4.4.6.9 Material or equivalency to be specified

It is recommended to provide a reference in LSA Code MSC.48(66) paragraph 4.4.6.9, maybe as a footnote to MSC/Circ.1006 which defines fire-retardant facilities for laminates. Administrations are invited to add further fire retardant materials (like steel, �)

26 Embarkation time 4.4.3.1, 4.4.3.2 6.7.1 Embarkation time in lifeboats destined for passenger ships not specified

LSA Code (MSC.48(66)) 4.4.3.1 Every passenger ship lifeboat shall be so arranged that it can be rapidly boarded by its full complement of persons. Rapid disembarkation shall also be possible. 4.4.3.2 Every cargo ship life boat shall be so arranged that it can be boarded by it�s full complement of persons in no more than 3 min from the time the instruction to board is given. Rapid embarkation shall also be possible. MSC.81(70) Part 1, paragraph 6.7.1 The lifeboat should be fitted with its engine and all its equipment. The number of persons for which the lifeboat is to be approved, having an average mass of at least 75 kg, and wearing a lifejackets and any other essential equipment, should be able to board the lifeboat and be properly seated within a period of 3 min in case of a lifeboat intended for a cargo ship and as rapidly as possible in the case of a lifeboat intended for a passenger ship. The lifeboat should then be manoeuvred and all equipment on board tested by an individual to demonstrate that the equipment can be operated without difficulty or interference with the occupants.


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SOLAS chapter III, paragraph 21.1.4 already provides a definition for the max. time of launching: All survival craft�.capable of being launched�. within �.30 min from the time the abandon ship signal is given.

27 Escape in case of capsizing 4.5.2.8 No test requirements to verify means of escape

LSA Code (MSC.48(66)) 4.5.2 �..The canopy shall be so arranged that:

.8 The occupants can escape in the event of the lifeboat capsizing.

Escape in case of capsizing will usually happen through the �entrances at both ends and on each side� (4.5.2). As these entrances �can be easily and quickly opened and closed from inside and outside�� (4.5.2.5), this will also be possible in same way with a capsized boat, when water level inside the boat is above the entrance. A practical test would require to capsize the boat and to trap somebody inside and to wait until he dives up under the boat, without any chance to see what he is doing or if he is already in danger of life. Due to the danger of life to the people involved a practical test should NOT be required. A visual inspection as foreseen in MSC/Circ.980 should remain sufficient.

28 Hanging-off pendants Ch.III.16.2 and 20.11 require means for maintaining release gear. In LSA code and MSC 81(70) no requirements yet

SOLAS chapter III/16.2 (and 20.11) Each lifeboat shall be provided with an appliance which is capable of launching and recovering the lifeboat. In addition there shall be provision for hanging-off the lifeboat to free the release gear for maintenance. LSA Code MSC.48(66) and subsequently MSC.81(70) have no requirements for so-called maintenance or hanging off gear. This gear is intended to be fitted when maintenance on release gear is performed as a safety precaution. As it is no part of the LSA Code and the testing requirements there are different interpretations on the application of such gear. This is unwanted and may jeopardise safe handling. It is recommended to copy the requirements of chapter III/16.2 (and 20.11) into the Code. Furthermore it is strongly recommended to add requirements for the testing of hanging off arrangements to MSC.81(70) to make it mandatory. Test overload advised to be 2.2 times as for launching appliances.


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Proposed amendments LSA Code (MSC.48(66)) New paragraph 4.4.7.13 [Each lifeboat shall be provided with provision for hanging-off the lifeboat to free the release gear for maintenance. The appliance shall be designed with a factor of safety of 6 on the basis of the weight of lifeboat loaded with its normal equipment (exclusive weight of occupants) and in addition 1000 kg covering maintenance personnel and equipment.] MSC.81(70), part 2: New paragraph 5.3.4 [Provision for hanging-off the lifeboat (hanging-off pennant) shall be tested with a static load of 2.2 times the design load for the provision.]

29 Drop test 4.4.1.5 6.4.3, 6.6.1 Drop test to be brought in line

LSA Code (MSC.48(66)) 4.4.1.5 Seating shall be provided on thwarts, benches or fixed chairs which are constructed so as to be capable of supporting:

.1 a static load equivalent to the number of persons each weighing 100 kg for which spaces are provided in compliance with the requirements of paragraph 4.4.2.2.2;

.2 a load of 100 kg in any single seat location when a lifeboat to be launched by falls

is dropped into the water from a height of at least 3 m; and .3 a load of 100 kg in any single seat location when a free-fall lifeboat is launched

from a height of at least 1.3 times its free-fall certification height. MSC.81(70) Drop test 6.4.3 The fully equipped lifeboat, with its engine, should be loaded with weights equal to the mass of the maximum number of persons for which the lifeboat is to be approved. The weights should be distributed to represent the normal loading condition but need not be placed 300 mm above the seatpan. The lifeboat should then be suspended above the water so that the distance from the lowest point of the lifeboat to the water is 3 m. The lifeboat should then be released so that it falls freely into the water. 6.6.1 The seating should be loaded with a mass of 100 kg in each position allocated for a person to sit in the lifeboat. The seating should be able to support this loading without any permanent deformation or damage.


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Proposed amendments 6.6.1 The seating should be loaded with a mass of 100 kg in each position allocated for a person to sit in the lifeboat. The seating should be able to support this loading without any permanent deformation or damage. New proposal added to 6.6.1: [During the drop test acc. to 6.4.3, a weight of 100kg should be loaded in each typical seat location when the lifeboat is dropped into water. The overload weight for the test seat shall be taken from other compensation weights so that the total weight of the lifeboat is as specified in 6.4.3. The seating should be able to support this loading without any permanent deformation or damage that would influence the function of seat.]

30 Air supply test 4.8 6.15 It is not clear whether the engine has to be stopped and restarted after 10 mins.

LSA Code (MSC.48(66)) 4.8 Lifeboats with a self-contained air support system In addition to complying with the requirements of section 4.6 or 4.7 , as applicable, a lifeboat with a self-contained air support system shall be so arranged that, when proceeding with all entrances and openings closed, the air in the lifeboat remains safe and breathable and the engine runs normally for a period of not less than 10 min. During this period the atmospheric pressure inside the lifeboat shall never fall below the outside atmospheric pressure nor shall it exceed it by more than 20 hPa. The system shall have visual indicators to indicate the pressure of the air supply at all times. MSC.81(70) 6.15 Air supply test for lifeboats with a self-contained air support system All entrances and openings of the lifeboat should be closed, the air supply to the inside of the lifeboat turned on and the engine run at full speed for a period of 10 min. During this time the atmospheric pressure within the enclosure should be continuously monitored to ascertain that a small positive air pressure is maintained within the lifeboat and to confirm that noxious gases cannot enter. Even if the engine should stop, the internal air pressure should never fall below the outside atmospheric pressure nor should it exceed outside atmospheric pressure by more than 20 mbar during the test. It should be ascertained that when the air supply is depleted automatic means are activated to prevent dangerously low pressure being developed within the lifeboat. Proposed amendments To include test requirements for means to prevent dangerously high or low internal pressure in the boat, the resolution MSC.81(70) should be amended as following:


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6.15 Air supply test for lifeboats with a self-contained air support system All entrances and openings of the lifeboat should be closed, the air supply to the inside of the lifeboat turned on and the engine run at full speed for a period of 10 min. During this time the atmospheric pressure within the enclosure should be continuously monitored to ascertain that a small positive air pressure is maintained within the lifeboat and to confirm that noxious gases cannot enter. Even if the engine should stop, [After 10 min the engine should be stopped:] the internal air pressure should never fall below the outside atmospheric pressure nor should it exceed outside atmospheric pressure by more than 20 mbar during the test. It should be ascertained that when the air supply is depleted automatic means are activated to prevent dangerously low pressure being developed within the lifeboat [by starting the engine with air supply turned off.] 31 Foul weather strops for rescue boats

Ch.III, 17.5 requires foul weather strops if heavy blocks constitute a danger. No requirements in LSA Code and MSC.81(70) yet

Revised SOLAS chapter III, part B 17.5 Rescue boat embarkation and recovery arrangements shall allow for safe and efficient

handling of a stretcher case. Foul weather recovery strops shall be provided for safety if heavy fall blocks constitute a danger.

Proposed amendments LSA Code (MSC.48(66)) It is advised to add a new paragraph to: [6.1.1.11 if heavy fall blocks constitute a danger for safe recovery foul weather recovery strops shall be provided for rescue boat launching appliances].

Further discussions on this topic may be required as the use of foul weather recovery strops constitute a safety hazard.

32 Fuel tank for outboard engine 5.1.1.8 Present requirement is insufficient. More specifications required

LSA Code (MSC.48(66)) 5.1.1.8 A rescue boat shall be fitted with an inboard engine or outboard motor. If it is fitted with an outboard motor, the rudder and tiller may form part of the engine. Notwithstanding the requirements of paragraph 4.4.6.1 , petrol driven outboard engines with an approved fuel system may be fitted in rescue boats provided the fuel tanks are specially protected against fire and explosion. No experience at ILAMA. Administrations should advise to which standard they have approved current petrol fuel systems.


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33 Outboard engine, fitted in self-righting rescue boat

Test in MSC.81(70) is not clear. Also prototype tests for outboard engines have to be amended.

MSC.81(70) 7.7 Outboard motors for rescue boats 7.7.1 When the rescue boats are fitted with outboard motors, the following tests should be applied to the motor in place of those tests specified in 6.11. Power test 7.7.2 The motor, fitted with a suitable propeller, should be placed in a test rig such that the propeller is completely submerged in a water tank, simulating service conditions. 7.7.3 The motor should be run at the maximum continuous rated speed using the maximum power obtainable for 20 min, and should not overheat or be damaged. Water drench test 7.7.4 The motor protective cover should be removed and the motor thoroughly drenched with water, by hose, except for the intake to the carburetor. The motor should be started and run at speed for at least 5 min while it is still being drenched. The motor should not falter or be damaged by this test. Hot start test 7.7.5 While still in the test rig referred to in 7.3.2, the motor should be run at idling speed in order to heat up the cylinder block. At the maximum temperature achievable, the motor should be stopped and immediately restarted. This test should be carried out at least twice. The motor should not fail to restart. Manual start test 7.7.6 The motor should be started at ambient temperature by manual means. The means should be either a manual automatic-rewind system or a pull cord round the top flywheel of the motor. The motor should be started twice within 2 min of commencement of the start procedure. 7.7.7 The motor should be run until normal operating temperatures are reached, then it should be stopped and started manually twice within 2 min, in accordance with 7.3.6. Cold start test 7.7.8 The motor, together with the fuel, fuel lines and battery, should be placed in a chamber at a temperature of -15ºC and allowed to remain until the temperature of all parts has reached the temperature of the chamber. The temperature of the fuel, battery and motor should be measured for this test.


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The motor should be started twice, within 2 min of commencement of the start procedure, and allowed to run long enough to demonstrate that it runs at operating speed. It is recommended that this period should not exceed 15 s. 7.7.9 Where, in the opinion of the Administration, having regard to the particular voyages in which the ship carrying the boat is constantly engaged, a lower temperature is appropriate, that lower temperature should be substituted for -15ºC in 7.3.8 for the cold start test. 7.7.10 The engine should be operated for at least 5 min at idling speed under conditions simulating normal storage. The engine should not be damaged as a result of this test. Proposed amendments It is recommended to add following new paragraphs similar to MSC.81(70) 6.14.6, 7 and 8: [Engine inversion test (for engines destined for fast rescue boats only) 7.7.11 The engine and its fuel tank should be mounted on a frame that is arranged to rotate about an axis equivalent to the longitudinal axis of the boat in the height of the boat transom . Propeller should be in a water basin until height of cavitation plate 7.7.12 The following procedure should be followed during this test:

.1 start the engine and run it at full speed for 5 min; .2 stop the engine and rotate it in a clockwise direction through 360o; .3 restart the engine and run it at full speed for 10 min; .4 stop the engine and rotate it in a counter-clockwise direction through 360o; .5 restart the engine, run it at full speed for 10 min, and then stop the engine; .6 allow the engine to cool; .7 restart the engine and run it at full speed for 5 min; .8 rotate the running engine in a clockwise direction through 180o, hold at the 180o

position for 10 s. and then rotate it 180o further in a clockwise direction to complete one revolution;

.9 if the engine is arranged to stop automatically or by kill- cord when inverted,

restart it; .10 allows the engine to continue to run at full speed for 10 min; .11 shut the engine down and allow it to cool;


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.12 repeat the procedure in 7.7.11.7 through 7.7.11.11, except that the engine should be turned in a counter-clockwise direction;

.13 restart the engine and run it at full speed for 5 min; .14 dismantle the engine for examination.

7.7.12 During these tests, the engine should not overheat or fail to operate during any one inversion. When examined after being dismantled the engine should show no evidence of overheating or excessive wear.]

34 Righting test, rigid rescue boat 7.1.7 Test should not be required for boat with inboard engine

MSC.81(70) Righting test 7.1.7 It should be demonstrated that both with and without engine and fuel or an equivalent mass in place of the engine and fuel tank, the rigid rescue boat is capable of being righted by not more than two persons if it is inverted on the water. Proposed amendments For clarification resolution MSC.81(70) should be modified as following: Righting test 7.1.7 It should be demonstrated that both with and without engine and fuel or an equivalent mass in place of the engine and fuel tank, the rigid rescue boat is capable of being righted by not more than two persons if it is inverted on the water. [For rescue boats with inboard engine the test without engine and fuel is not applicable.] 35 Engine out of water test 4.4.6.3 6.10.5 Water supply for outboard engine is

permitted. Requirements to be amended accordingly

LSA Code (MSC.48(66)) 4.4.6.3 The engine shall be capable of operating for not less than 5 min after starting from cold with the lifeboat out of the water. MSC.81(70) 6.10.5 The engine should be operated for at least 5 min at idling speed under conditions simulating normal storage. The engine should not be damaged as a result of this test.


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Revised SOLAS chapter III, part B Regulation 20.6 Weekly inspection The following tests and inspections shall be carried out weekly:

.1 all survival craft, rescue boats and launching appliances shall be visually inspected to ensure that they are ready for use;

.2 all engines in lifeboats and rescue boats shall be run for a total period of not less

than 3 min provided the ambient temperature is above the minimum temperature required for starting and running the engine. During this period of time, it should be demonstrated that the gear box and gearbox train are engaging satisfactorily. If the special characteristics of an outboard motor fitted to a rescue boat would not allow it to be run other than with its propeller submerged for a period of 3 min, it should be run for such period as prescribed in the manufacturer's handbook. In special cases the Administration may waive this requirement for ships constructed before 1 July 1986;

Add to 4.4.6.3 and 6.10.5: [If the special characteristics of an outboard motor fitted to a rescue boat would not allow it to be run other than with its propeller submerged for a period of 5 min, it should be run for such period as prescribed in the manufacturer's handbook.]

36 Length, definition 5.1.1.3 For inflatable and rigid-inflatable rescue boats a clear definition for �length� is required. MSC Circ.809, 4.1.3 might be copied

Already settled with MSC/Circ.809/Add.1, no further action required.

37 Material test for inflatable rescue boats

1.2.2 7.2.14 To be developed

ILAMA suggest making reference to ISO standards that will most likely be available.

38 Self-righting test for fast rescue boats

6.14 Self-righting test is only applicable for totally enclosed fast rescue boat

Self-righting test is also required for fast rescue boats. Reference to 6.14 is also applicable for the possible case of an enclosed fast rescue boat. For the usual open fast rescue boats following amendment is proposed to be added to MSC.81(70) 7.4.1, 7.5 and 7.6: [For the case of open fast rescue boats, the self righting test is only to be done in the light condition acc. 6.14.1.2 with the fully equipped boat but without persons (these would fall out of the boat during capsize and are therefore not of influence). 6.14.1.1, 6.14.3, 6.14.4 and 6.14.5 are not applicable]


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39 Strength of launching appliances 6.1.1.5, 6.1.1.6 8.1.1 There is no uniform way to determine the strength of launching appliances. It can be done by calculation or by testing to destruction. Standard to be developed.

LSA Code (MSC.48(66)) 6.1.1.5 The launching appliance and its attachments other than winch brakes shall be of sufficient strength to withstand a static proof load on test of not less than 2.2 times the maximum working load. 6.1.1.6 Structural members and all blocks, falls, padeyes, links, fastenings and all other fittings used in connection with launching equipment shall be designed with a factor of safety on the basis of the maximum working load assigned and the ultimate strengths of the materials used for construction. A minimum factor of safety of 4.5 shall be applied to all structural members, and a minimum factor of safety of 6 shall be applied to falls, suspension chains, links and blocks. MSC.81(70) 8.1.1 For lifeboats other than free-fall lifeboats, davits and launching appliances, except the winch brakes, should be subjected to a static proof load of 2.2 times their maximum working load. With the load at the full outboard position, the load should be swung through an arc of approximately 10E to each side of vertical in the intended fore and aft plane. The test should be done first in the upright position, followed by tests simulating a shipboard condition of list of 20E both inboard and outboard. There should be no evidence of significant deformation or other damage as a result of this test. For free-fall lifeboats, the launching appliances for lowering a free-fall lifeboat by falls, except the winch brakes, should be subjected to a static proof load of 2.2 times the maximum working load at the full outboard position. There should be no evidence of significant deformation or other damage as a result of this test. The problem is the way to verify the factor of safety. A safety factor can be proven by calculation, comparison with breaking load declaration of supplier or by testing to destruction. This is however not clear in the regulations. Clear regulations should be developed.

40 Remote control for winch brake 6.1.2.2, 6.1.2.12 Uniform interpretation to be developed. Which type of remote control is required?

LSA Code (MSC.48(66)) 6.1.2.2 The launching mechanism shall be so arranged that it may be actuated by one person from a position on the ship's deck, and except for secondary launching appliances for free-fall launching arrangements, from a position within the survival craft or rescue boat. When launched by a person on the deck, the survival craft or rescue boat shall be visible to that person. 6.1.2.12 Manual brakes shall be so arranged that the brake is always applied unless the operator, or a mechanism activated by the operator, holds the brake control in the "off" position.


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THIS REQUIREMENT IS OFTEN A TOPIC OF DISCUSSION. THIS ITEM TO BE DISCUSSED IN DEPTH FOR FURTHER DEVELOPMENT This is a question of accepting �pull and go system�. Experienced from IMO meetings there are different strong opinions among authorities regarding this item. From our point of view there is a too high risk of malfunction when operating remote control from the inside lifeboat/rescue boat caused by the distance from winch and amount of sheaves. We should therefore change 6.1.2.12 to accept �pull and go�. 6.1.2.2 only describes the position from where the operation should take place this could also be a �pull and go system.� Proposed new text: [6.1.2.13 When using remote control system the manual brakes shall be so arranged that the brake is always applied unless the operator, or a mechanism activated by the operator holds the brake control in the "off" position.]

41 Remote control for winch brake 6.1.2.2 Part 2, 6.1.3 and 6.1.6

The text of these paragraphs is ambiguous. The LSA Code requires remote control from the survival craft

LSA Code (MSC.48(66)) 6.1.2.2 The launching mechanism shall be so arranged that it may be actuated by one person from a position on the ship's deck, and except for secondary launching appliances for free-fall launching arrangements, from a position within the survival craft or rescue boat. When launched by a person on the deck, the survival craft or rescue boat shall be visible to that person. MSC.81(70) 6.1.3 The survival craft or rescue boat loaded with its normal equipment or an equivalent mass should be released by operation of the launching control on deck to demonstrate that the lifeboat's mass is sufficient to overcome the frictional resistance of the winch, falls, blocks and associated gear. The lowering speed should be as established by the Administration. If the launching gear is controlled from within the survival craft or rescue boat a person should then board the survival craft or rescue boat and perform a test of the launching operation. 6.1.6 If lowering of the lifeboat is controlled from within the lifeboat by means of a control wire paid off from an auxiliary drum on the winch, the following additional points should receive particular consideration after installation of the davits and winches:

.1 the mass on the control wire should be sufficient to overcome the friction of the various pulleys on the control wire, when turning out the lifeboat from the stowed to the embarkation position;

.2 it should be possible to operate the winch brake from within the lifeboat;


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.3 the winch brake should not be affected by the mass of the fully extended control

wire; .4 there should be sufficient length of control wire available at the lifeboat, during all

stages of lowering; and .5 means should be provided to retain the free end of the control wire in the lifeboat

until the lifeboat is detached from the launching appliance by the operator. Proposed amendments MSC.81(70) 6.1.3 The survival craft or rescue boat loaded with its normal equipment or an equivalent mass should be released by operation of the launching control on deck to demonstrate that the lifeboat's mass is sufficient to overcome the frictional resistance of the winch, falls, blocks and associated gear. The lowering speed should be as established by the Administration. If the launching gear is controlled from within the survival craft or rescue boat a [A] person should then board the survival craft or rescue boat and perform a test of the launching operation [by using the remote actuating system].

Issue


LSA Code


Remarks

42 Hydrostatic release unit 1.2.2.5 11 UV test to be developed

Amendment to MSC.81(70) Insert new paragraph 11.2.6 .6 Solar radiation test

One unit shall be subjected to a solar radiation test to IEC 945: 3rd edition (Nov.1996), paragraph 8.10. (Note: The solar radiation test may be waived where the manufacturer is able to produce evidence that the materials employed will satisfy the test, i.e. UV stabilized).

NOTE. The Evaluation and Test Report Forms for HRU�s (MSC/Circ.980) will need to be similarly amended to conform.


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43 Liferafts 4.2 Self bailing should be required for all liferafts, not only for self-righting type

44 Deformation of liferafts 5.11 Criteria to be developed, which may have consequences for construction

45 Undue distortion 5.16.4, 5.17.12 Criteria or clarification to be developed

46 Self-righting liferafts 5.18.1 This paragraph is not only applicable to rigid liferafts

47 Self draining test 5.2.1 Criteria to be developed for �appreciable accumulation of water� and for the capacity of self draining

48 Signalling system in MES 6.2 To monitor passage of persons development of a signalling system is recommended

49 Material test MES 1.2 5.17.13 Material test is only applicable for inflatable slides. Specifications to be developed for rigid materials

50 Test procedure MES 6.2 12 Test procedure of MES to be reviewed

51 Load test MES 6.2 12.3.1.4 This test should also be a production test; to be incorporated in part 2 of MSC 81(70)

52 Inflation system for inflatable liferafts and MES

Specifications to be developed (or reference to ISO standards) for inflation systems for liferafts and MES

Items 43 to 52 above, ILAMA do not have any comments on these items at this stage.

53 Pyrotechnics drop test 1.2, 4.1.1.2 4.4.1 Pyrotechnics stowed in liferafts must withstand a drop of at least 18 m. The prototype tests of pyrotechnics do not require this test. To be brought in line

Amendment to MSC.81(70) Insert new paragraph 4.4.3 [.3 be packaged into a life raft in the normal manner and dropped from a minimum height of 18m as described in paragraph 5.1. The pyrotechnics should remain in a safe condition after this test and should subsequently be operated and function effectively.] Amendment to MSC/Circ.980 No amendment needed.

54 Expiry date of pyrotechnics 1.2.3 4.5.6 A minimum required lifespan of pyrotechnics to be established. Now it is up to the Administration and the same brand of pyrotechnics may get a different lifespan of various Administrations


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Amendment MSC.81(70) 4.5.6 can be indelibly marked with means of determining its age 4.5.6 [The date of expiry for pyrotechnic lifesaving appliances shall be indelibly marked on the

product, and it shall be 36 months from the date of manufacture, except in cases where a maritime Administration has approved a longer service life based upon documented operational experience.]

Amendment to MSC/Circ.980 Change paragraphs 3.1.1.2/ 3.2.1.2 and 3.3.1.2 to be amended to read as paragraph 2.1.3.1.2 [Acceptable Life] in column 1 in all cases. Change all above paragraph columns 2 to read: [The date of expiry for pyrotechnic lifesaving appliances shall be indelibly marked on the product, and it shall be 36 months from the date of manufacture, except in cases where a maritime Administration has approved a longer service life based upon documented operational experience.]

55 Colour of pyrotechnics 3.1, 3.2, 3.3 4.6, 4.7, 4.8 Definition of colour to be

specified in accordance with latest international standard (CIE 15.2?). USA publication 440 is obsolete, no longer obtainable

Amendment to MSC.81(70) 4.6.2 Laboratory testing of the flare material should establish that it will burn uniformly with an average luminous intensity of not less than 30,000 cd over the complete flare burn time and that the colour of the flame is a vivid red as defined by section 11 of the publication Color: Universal Language and Dictionary of Names. * [flare shall be vivid red, with CIE coordinates x = 0.61 to 0.69 and y = 0.3 to 0.39, or computed from these coordinates: a wavelength of 608nm +/- 11nm.] Delete Footnote * Special Publication 440,National Institute of Science and Technology, Gaithersburg, Md., 20899-0001, USA. 4.7.2 Laboratory testing of the flare material should establish that it will burn with an average luminous intensity of at least 15,000 cd over the complete flare burn time and that the colour of the flame is a vivid red as defined by section 11 of the publication Color: Universal Language and Dictionary of Names. * [flare shall be vivid red, with CIE coordinates x = 0.61 to 0.69 and y = 0.3 to 0.39, or computed from these coordinates: a wavelength of 608nm +/- 11nm.] 4.8.3 As amended by previous action, and insertion of a new paragraph.


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Amendment to MSC/Circ.980 Amend paragraph 3.1.8 Acceptance criteria to delete all existing text: The testing laboratory report should confirm that the average luminous intensity of the flare is at least 30,000 Cd for a period of not less than 40 seconds. etc. etc. Insert new text : [Laboratory testing of the flare material should establish that it will burn uniformly with an average luminous intensity of not less than 30,000 cd over the complete flare burn time and that the colour of the flare shall be vivid red, with CIE coordinates x = 0.61 to 0.69 and y = 0.3 to 0.39, or computed from these coordinates: a wavelength of 608nm +/- 11nm.] Amend paragraph 3.2.9 Acceptance criteria to delete all existing text:

The testing laboratory report should confirm that the average luminous intensity of the flare is at least 15,000 Cd for a period of not less than 1 minute, etc. etc. Insert new text : [Laboratory testing of the flare material should establish that it will burn with an average luminous intensity of at least 15,000 cd over the complete flare burn time and that the colour of the flare shall be vivid red, with CIE coordinates x = 0.61 to 0.69 and y = 0.3 to 0.39, or computed from these coordinates: a wavelength of 608nm +/- 11nm.]

56 Means of rescue (MOR) MSC/Circ.810 MSC/Circ.810 Requirement and tests to be thoroughly reviewed. First of all performance standards to be developed

Standards to be developed by Administrations or IMO DE Sub-Committee under DE item 47/7 �Review of fast rescue boat and means of rescue requirements�. In these standards also the following items should be considered:

- MSC/Circ. 810/ 2.2: �The means of rescue should provide an area of at least 9 m² at water level to receive rescued persons� =>Definition of �area� required: is this the complete projected area in plan view of the device or the actual usable floor area inside - If fast rescue boats should be used as MOR as recommended by UK and Netherlands, this alternative should be added to 2.4 and maybe additional requirements for such MOR should be added. However the double role as FRB and MOR should also be considered in detail: in a disaster like ESTONIA the FRB should pick up survivors and bring them to the MOR for transfer to ship. If the FRB is used as MOR also, it will at least spend 50% of the available time to rescue survivors as an elevator. THIS ITEM SHOULD BE TREATED AS A SEPARATE ITEM; FIRST OF ALL IT IS REQUIRED TO DEVELOP FUNCTIONAL REQUIREMENTS AND SUBSEQUENTLY DEVELOP DESIGN AND TEST REQUIREMENTS.


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57 Means of rescue ! ladder for able-bodied persons in

vertical MES ! hoisting device and ladder in

combination with MES ! recovery of helpless person ! capacity of MOR

- not acceptable - specifications to be developed - test to be incorporated - Minimum required capacity of

MOR (platform, hoisting or climbing up speed) to be developed. There should be a relation between MES used as MOR and a platform with a hoisting device

ILAMA have no comments on this item at this stage.

Issue


LSA Code


Remarks

58 Lifejacket light 10.4.10 Test should read �at least 11 out of 12��

Note The above proposal makes reference to life jacket lights only. However, survival craft lights and lifebuoy lights also require to be tested for chromaticity. It is proposed that paragraph 10.4.10 of MSC.81(70) be amended as follows: Amendment to MSC.81(70) 10.4.10 Chromaticity Test procedure One unit [On completion of the light output tests, all lights] shall be tested for chromaticity to determine that it lies [they lie] within the boundaries of the area �white� etc.etc.

Amendment to MSC/Circ.980 No Amendment needed.

Issue


LSA Code


Remarks

59 Lifejacket light 10.4.9 It is not possible to perform the light output test

Note: This refers to the difficulty experienced whilst approval testing lifejacket lights during the �Drop test� described in paragraph 10.3.3 of MSC.81(70). It is impossible to determine the actual light output and chromaticity of a light after completing the 4.5 metre drop test into water. The personnel doing the test will be at a test site well away from the laboratory, and this is where light output tests and chromaticity tests must be done. In the case of seawater-cell type products,


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the procedure is further complicated, as the cell may not in fact function correctly again after being removed from the water for a period of time. As the 4.5 metre drop test is only to confirm the method of attaching the light to a lifejacket, it is proposed that only a �functional test� be conducted, this will confirm that the light has not been torn from the lifejacket and will actually operate and illuminate. Amendment to MSC.81(70) 10.3.3 One light attached to a lifejacket should be subjected to a drop test as prescribed in 2.9.6. The light should not suffer damage, should not be dislodged from the lifejacket and should [be switched on and seen to be illuminated and conspicuous whilst the test subject is still in the water.] function as prescribed in 10.3.2.

Amendment to MSC/Circ.980 2.2.3.5 Drop Test Column 1 Test Procedure Delete the entire last paragraph commencing: �After this drop test the light should be taken from ordinary room conditions etc. etc.� Column 2 Acceptance Criteria Delete all the remaining text from the middle of line four: �The lifejacket light should not suffer damage, should not be dislodged from the lifejacket and should not injure the wearer and should [be switched on and seen to be illuminated and conspicuous whilst the test subject is still in the water.] function after the test. Water-activated [Seawater-cell] lights should commence functioning within 2 min and have reached a luminous intensity of not less than 0.75 cd within 5 min in seawater. etc. etc. etc� 60 Inflatable Lifejackets Service card

2.2 2 Certification should be similar as with liferafts

Proposed Text / Amendment (No requirement currently exists for this under chapter III of SOLAS 74 or subsequent amendments) Proposed Text The approved service station shall issue a Certificate of Test and Inspection.


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61 lights

tests with lifejackets should be performed with a light fitted

Amendments to MSC.81(70) Paragraph 2.9.6. Lifejacket drop test insert: [Each lifejacket must be fitted with an approved survivor locator light. The light must not become detached, cause injury and must illuminate after the test. It must be confirmed that the light is conspicuous, and not masked by any part of the jacket i.e. hood when fitted] Paragraph 3.1.10 Immersion suit jump test insert: [If the immersion suit is to be fitted with its own survivor locator light, an approved light must be fitted for the test. The light must not become detached, cause injury and must illuminate after the test. It must be confirmed that the light is conspicuous, and not masked by any part of the suit i.e. hood when fitted] Amendment to MSC/Circ.980 All sections of the above document relating to jump or drop tests of lifejackets or immersion suits needs to be amended to state that an approved survivor locator light must be fitted to the appliance prior to carrying out the test. Add the following text to paragraphs 2.2.1.17 & 21 also 2.2.2.2.16 & 20: [Each lifejacket must be fitted with an approved survivor locator light. The light must not become detached, cause injury and must illuminate after the test. It must be confirmed that the light is conspicuous, and not masked by any part of the jacket i.e. hood when fitted] Add the following text to paragraphs 2.3.1.14 and 2.3.2.14: [If the immersion suit is to be fitted with its own survivor locator light, an approved light must be fitted for the test. The light must not become detached, cause injury and must illuminate after the test. It must be confirmed that the light is conspicuous, and not masked by any part of the suit i.e. hood when fitted] 62 Lifejackets not causing discomfort

2.2.1.2.4 Guidelines for assessing these subjective requirement

Proposed Text / Amendment The lifejacket shall not cause discomfort to the wearer such as undue pressure on the airways. (Comment: This is very subjective, a lifejacket may feel uncomfortable to the wearer because it is gripping the neck area, however this is necessary to enable the lifejacket to support the neck and head if the wearer is unconscious). 63 Missing tests compared with non-inflatable lifejackets

2.11 should be brought in line with 2.1 up to and inclusive 2.6 This has high priority. See �old� res. A.689(17)


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Proposed Text / Amendment MSC.81(70), 2.11 follows the basis of A.689(17) all test requirements are stated but not necessarily in the order as defined under A.689(17). 64 Compass test 2.11.4.6.2 Test not reasonable. A small

boat compass can not be read with a 1û accuracy

Proposed Text / Amendment Metal components used in the manufacture of inflatable lifejackets shall not affect a magnetic compass of a type used in small boats by more than 5û when placed at a distance of 500 mm from it. 65 Donning 2.10.2.3 2.10.2.3 Investigation into the practicality

of donning inflated lifejackets

Proposed Text / Amendment This paragraph refers to in water trunk angle for children�s lifejackets, donning is covered under 2.8 and is identical to A.689(17). 66 Mobility children�s lifejackets 2.10.2.5 Investigation into assessing the

mobility of children for lifejackets (inflatable and inherently buoyant)

Proposed Text / Amendment The surveyor shall observe the wearer�s ability to manoeuvre both in and out of the water, taking into account the age of the test subject. 67 Oil and water absorption 2.7.7 Buoyancy material shall be

subjected to oil and water absorption test. Sentence �alternatively, the entire lifejacket may be subjected to the test� should be removed.

Proposed Text / Amendment The sentence �Alternatively, the entire lifejacket may be subjected to the test� is correct as per A.689(17).


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68 Immersion suits in combination with lifejackets

3.1.2 When testing immersion suits in combination with lifejackets the compatibility should be established

Proposed Text / Amendment Tests 3.1.3 to 3.1.12 inclusive will demonstrate the compatibility of the immersion suit and lifejacket. 69 Immersion suit (donning after -30ûC test)

3.1.4 To be defined: reasonable time

Proposed Text / Amendment A.689(17) and MSC.81(70) state in a �reasonable time�, propose delete �reasonable time� and insert �5 minutes�.

70 Release mechanism of fast rescue boats

4.4.7.6 6.9.1/6.9.4 8.1.8

Compatibility of release mechanism and launching appliances

LSA Code (MSC.48(66)) 4.4.7.6 Every lifeboat to be launched by a fall or falls except a free-fall lifeboat shall be fitted with a release mechanism complying with the following requirements subject to paragraph .5 below:

.1 The mechanism shall be so arranged that all hooks are released simultaneously. .2 The mechanism shall have two release capabilities as follows: .2.1 normal release capability which will release the lifeboat when it is waterborne or

when there is no load on the hooks; .2.2 an on-load release capability which will release the lifeboat with a load on the

hooks. This release shall be so arranged as to release the lifeboat under any conditions of loading from no load with the lifeboat waterborne to a load of 1.1 times the total mass of the lifeboat when loaded with its full complement of persons and equipment. This release capability shall be adequately protected against accidental or premature use. Adequate protection shall include special mechanical protection not normally required for offload release, in addition to a danger sign. To prevent an accidental release during recovery of the boat, the mechanical protection (interlock) should only engage when the release mechanism is properly and completely reset. To prevent a premature on-load release, on-load operation of the release mechanism should require a deliberate and sustained action by the operator. The release mechanism shall be so designed that crew members in the lifeboat can clearly observe when the release mechanism is


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properly and completely reset and ready for lifting. Clear operating instructions should be provided with a suitably worded warning notice.

.3 The release control shall be clearly marked in a colour that contrasts with its

surroundings. .4 The fixed structural connections of the release mechanism in the lifeboat shall be

designed with a calculated factor of safety of 6 based on the ultimate strength of the materials used, assuming the mass of the lifeboat is equally distributed between the falls.

.5 Where a single fall and hook system is used for launching a lifeboat or rescue boat

in combination with a suitable painter, the requirements of paragraph 4.4.7.6.2 need not be applicable; in such an arrangement a single capability to release the lifeboat or rescue boat, only when it is fully waterborne, will be adequate.

MSC.81(70) 6.9.1 The lifeboat with its engine fitted should be suspended from the release mechanism just clear of the ground or the water. The lifeboat should be loaded so that the total mass equals 1.1 times the mass of the lifeboat, all its equipment and the number of persons for which the lifeboat is to be approved. The lifeboat should be released simultaneously from each fall to which it is connected without binding or damage to any part of the lifeboat or the release mechanism. 6.9.4 It should be demonstrated that the release mechanism can release the fully equipped lifeboat when loaded with weights equal to the mass of the number of persons for which the lifeboat is to be approved, when the lifeboat is being towed at speeds up to 5 knots. In lieu of a waterborne test, this test may be conducted as follows:

.1 A force equal to the force necessary to tow the lifeboat at a speed of 5 knots should be applied to the hook in the lengthwise direction of the boat at an angle of 45E to the vertical. This test should be conducted in the aftward as well as the forward direction, depending upon the design of the release hook.

.2 A force equal to the safe working load of the hood should be applied to the hood

in an athwartships direction at an angle of 20E to the vertical. This test should be conducted on both sides.

.3 A force equal to the safe working load of the hook should be applied to the hook

in a direction half-way between the positions of tests 1 and 2 and within the ellipse segment formed by 1 and 2. This test should be conducted in four positions.

8.1.8 The fast rescue boat launching appliance should be demonstrated in a sea state associated with a wind of force of 6 on the Beaufort scale, in association with a significant wave height of at least 3 m. The test should include launching and recovery of a fast rescue boat and demonstrate:


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.1 satisfactory operation of the device to dampen forces and oscillations due to

interaction with the waves;

.2 satisfactory operation of the winch brake; and

.3 satisfactory operation of the tensioning device.

Remarks by ILAMA Release system mainly covered under item 76. Further items to be considered under DE- item 47/7 �Review of fast rescue boat and means of rescue requirements�. 71 Reference to international standards

Reference to international standards should be consistent in all documents

ILAMA have no comments on this item at this stage. 72 Clothing specification 2.8.3 Definition to be given for

�normal clothing � and �heavy weather� clothing

Proposed Text / Amendment Propose normal clothing: Cotton underwear, cotton shirt, woollen sweater, cotton or woollen trousers, woollen socks and shoes. Heavy weather clothing: Normal clothing plus foul weather jacket and trousers (oil skins). 73 TPA 2.5.2 To clarify whether arms are

required or not

Proposed Text / Amendment This is currently optional, ISO are currently developing a new standard. 74 TPA 2.4.2.1 & 2.5.1 3.2.13 & 3.3.2 Thermal protective test to be

clarified

Proposed Text / Amendment 2.4.2.1 refers to anti exposure suits and is therefore erroneous. 2.5.1. is the same as A.689(17). 3.2.13 refers to anti exposure suits and is therefore erroneous. 3.3.2 is correct.


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75 Immersion suits 2.3.3 3.1.17 To bring in line with

requirements for righting

Proposed Text / Amendment LSA Code 2.3.3 is the same as SOLAS chapter III (1983), regulation 34, paragraph 3. MSC.81(70), paragraph 3.1.17, refers to anti exposure suits designed to be worn without a lifejacket and requires the same maximum buoyancy loss requirements as per lifejackets. LSA Code 2.2.1.7 and MSC.81(70), paragraph 2.2.

76 Release mechanism for fast rescue boats and launching appliances

Described in document DE 43/3/3 (ILAMA)

Paper again should be brought to the attention of the Commission. Reference is made to DE 45/17/3.

77 Standard - radar reflective - inflatable life-raft - material for rigid - rescue boats - material for inflatable - rescue boats - on/off load release - hook system

To be identified

No comment on this item by ILAMA at this stage.

78 Standard - first aid kits - food rations - drinking water - desalting apparatus - magnetic compass

To be identified

SOLAS LSA Code chapter IV - Survival craft 4.1.5.1.18 Emergency Food Rations a food ration totalling not less than 10,000 kJ for each person the liferaft is permitted to accommodate. These rations should be palatable, edible throughout the recommended shelf life, and packed in a manner which can be readily divided and easily opened. The rations shall be kept in airtight packaging and be stowed in a watertight container; One food ration is required for each person the liferaft is equipped to accommodate, and consists of minimum 10 000 kJ (2 400 kcal) of approved emergency provisions.


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Food rations shall be palatable, readily divided and edible throughout the recommended shelf life and packed in waterproof, airtight packaging in a manner, which can be easily opened using immersion suit gloved hands.

A single food ration unit would consist of the following components:

Ration unit: 500-550 g Energy: minimum 10,000 kJ Packing: Hermetically sealed tin (can) or vacuum-packed, flexible package,

protected by a cardboard box. Composition: Moisture: Maximum 5 % Salt (NaCl): Maximum 0.2% Carbohydrates: 60-70% weight = 50-60% energy Fat: 18-23% weight = 33-43% energy Protein: 6-10% weight = 5-8% energy Food rations shall be packed in tins (cans), or vacuum packed in a flexible packaging material with a negligible vapour transmission rate (<0.1g/m2 per 24 hours at 23 degrees C / 85% R.H.) (DIN 53122). Flexible packaging materials shall be a laminate construction including at least one ply of aluminium foil and should be covered by a outer cardboard box in order to prevent holes and damage to the food ration and other items as result of sharp edges.

The packaging material must be clearly marked with date of packing and date of expiry, a lot number, the content in the package and an instruction for use. In addition the Emergency Ration should comply with ISO DIS 18813 Standard Survival Craft Equipment. SOLAS LSA Code chapter IV - Survival craft 4.1.5.1.19 Emergency drinking water watertight receptacles containing a total of 1.5 l of fresh water for each person the liferaft is permitted to accommodate, of which either 0.5 l per person may be replaced by a desalting apparatus capable of producing an equal amount of fresh water in two days or 1 l per person may be replaced by a manually powered reverse-osmosis desalinator, as described in paragraph 4.4.7.5, capable of producing an equal amount of fresh water in two days; Emergency drinking water shall be of an approved type and satisfy national and international drinking water standards (WHO / EU / US). It should be stored in watertight receptacles containing 1.5 l. of fresh water for each person the liferaft is permitted to accommodate. Up to one third of the required water may be replaced by chemical or solar desalting apparatus capable of producing an equal amount of fresh water in 2 days, or up to two thirds may be replaced by a manually operated reverse osmosis desalinator complying with IMO MSC/Circ.1048. Emergency drinking water must be packed in hermetically sealed containers that are of corrosion resistant material or are treated to be corrosion resistant. If a flexible material is being used, it


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must be a laminate of which at least one ply is aluminium and with the same demand to water vapour transmission as for the food rations. Each water container must have a method of spill proof reclosure, or else individual portions containing no more than 100 ml, or should have a system for spill of re-closure. The actual quantity of water in the container must not, at any time of its life span, be less than the stated quantity. The container must be clearly marked with date of packing and date of expiry, a lot number, the quantity of water in the container and an instruction for consumption. The containers must be easy to open, even when using immersion suit gloved hands. In addition the emergency drinking water should comply with ISO DIS 18813 Standard Survival Craft Equipment. SOLAS LSA Code chapter IV - Survival craft 4.4.8.9 Emergency drinking water Watertight receptacles containing a total of 3 l of fresh water as described in paragraph 4.1.5.19 for each person the lifeboat is permitted to accommodate, of which either 1 l per person may be replaced by a desalting apparatus capable of producing an equal amount of fresh water in two days or 2 l per person may be replaced by a manually powered reverse-osmosis desalinators, as described in paragraph 4.4.7.5, capable of producing an equal amount of fresh water in two days. SOLAS LSA Code chapter IV - Survival craft 4.4.8.12 Emergency food rations A food ration as described in paragraph 4.1.5.18 totalling not less than 10,000 kJ for each person the lifeboat is permitted to accommodate; these rations shall be kept in airtight packaging and be stowed in a watertight container.

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Documents

INTERNATIONAL MARITIME ORGANIZATION E - … lifebuoy shall be suspended from its upper edge via a release device so that the lower edge of the lifebuoy will be at the required height