not the case and it is now applying to the IMO to develop common guidelines to ensure operators can show that their vessel meets damage stability rules before it is allowed to set sail. In January the MCA intends to take its


evidence on the compliance of tankers with damage stability regulations to the IMO in an effort to make certain that rules are applied consistently and that owners can show port state control that their vessel meets damage stability regulations.


Expectations within the MCA are


that its view will be challenged by owners because some operators are concerned that any new requirements placed upon them to make certain that their ships meet damage stability rules could be commercially damaging. However, the MCA’s assistant


Four options for operators


There are four possible options for the operator to demonstrate compliance with damage stability:


1. to load the vessel only in accordance with fixed loading conditions from the approved Stability Information Booklet, as these have also been approved for damage;


2. where there is a significant variation from the fixed loading conditions in the approved Stability Information Booklet, the operator must obtain approval from the Administration, or a Recognized Organization acting on its behalf, for the proposed loading condition;


3. to load the vessel in accordance with an envelope limiting KG (or GM) curve, possibly supported by tank filling requirements, which had been developed in accordance with the relevant damage stability provisions. This curve is checked by an intact stability instrument; or


4. to use an approved Stability Program to check that all loading conditions comply with damage as well as intact stability.


The Naval Architect November 2009


director: seafarers and ships Paul Coley said: “It is not acceptable for tank vessels to employ alternate loading conditions without any means to verify that these comply with damage stability requirements. To satisfy flag and port state inspection, operators of tank vessels must ensure crews can produce auditable records to demonstrate that damage stability has been verified.” Part icularly vociferous in the


putting the owner’s view has been the International Parcel Tanker Association (IPTA) which could yet see the MCA’s proposals thrown out. The debate in January will be the


culmination of a number of past discussions at the IMO’s Maritime Safety Committee (MSC) 82 and the Stability Loadline and Fishing (SLF) vessels sub-committee. Mr Coley of the MCA representing


the UK at IMO said: “The UK strongly recommends the provision of damage stability programmes for this purpose [to ensure compliance with damage stability rules] on any vessel where adherence to the approved conditions is not practicable.” IPTA group manager Janet Strode,


however, argues: “We are concerned that to insist on PSC requiring vessels to demonstrate compliance with damage stability requirements before leaving port will inevitably lead to vessel delays. Why? Because, as the MCA has conceded all along, the only way practical way to do this is by use of a damage stability computer. “If the vessel does not have such


a computer (which is the case with a large number of vessels) then the administration would have to be called in. This would naturally take time and lead to delays for vessels, and not necessarily because the vessel is not in compliance with damage stability requirements, but simply because it


Ship heels toward damage.


Cross section of tanker loaded with low specific gravity cargo.


does not have on board a piece of equipment which is not mandatory.” The MCA believes this argument to


be spurious with the cost of buying a computer and damage stability programme along with the requisite training coming at under £10,000 a ship the MCA considers this a very small price to pay for ensuring that a ship remains stable following an accident. IPTA further argued that: “due


to their high degree of subdivision, chemical tankers normally have high margins of damage stability”. According to the MCA this view is


dangerously complacent and factually erroneous. “We’ve already had a near miss with a vessel called the Ece which sank with a hole that was only around 5m wide,” following a collision close to the Channel Islands, said Mr Coley. That ship was not at the time carrying


a hazardous pollutant and there was no danger to marine wildlife. However, he added: “We’re not saying that the Ece was not compliant, but how many ships are out there carrying noxious


47


Feature 2


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