RINA enters SOLAS 2009 debate


Experts at Te Royal Institution of Naval Architects (RINA) have identified anomalies in the SOLAS 2009 regulation regarding the safety of ro-ro passenger ships and have approached the International Maritime Organization (IMO) with proposals that would literally plug any regulatory gaps.


C


oncerns over the safety of ro-ro passenger ships that are designed with long [or large]


low holds (LLH) has been discussed at the IMO’s Subcommittee on Stability and Load Lines and on Fishing Vessel Safety, thankfully abbreviated to the SLF Committee. The concerns raised as far as the


regulation goes are primarily two fold. In the first instance RINA has pointed out that SOLAS 2009 has failed to accurately define a rapid capsize. “There are no definitions within


SOLAS which explain capsize or rapid capsize or the criteria,


in numerical


terms, which the designers can use to determine when a rapid capsize situation exists. This is fundamental to the damage stability assessment and the survivability of passenger and cargo ships other than tankers,” the RINA paper states. RINA says that numerical criteria for


the definition of capsize or rapid capsize must be defined so that regulations that can protect vessels with LLH’s can be drawn up. In addition RINA points out that


“Regulation 8.3 of SOLAS 2009 contains requirements for the extent of side damage to passenger ships, but makes no reference to how Large Lower Holds are to be protected.” Regulation 9.9 does contain


requirements for double bottoms in passenger, and cargo ships other than tankers, which include requirements for


increased protection for


with LLH’s. This


is further clarified in the


Explanatory Notes, regulation 9.9. It is noted that at SLF 52 the issue of smaller ships with fewer passengers as well as ships fitted with LLH and B/10 longitudinal bulkheads should be the main focus of the work and that


The Naval Architect April 2011


4 the proposed amendments to regulation 8 contained in the annex, relating to the prevention of water on ro-ro decks which are above the damaged waterline (paragraph 4); and


5 the proposed amendments to regulation 8 contained in the annex, relating to the investigation of non-contributing damages to ro-ro decks and long lower holds and develop Explanatory Notes on the investigation process and the actions that are required (paragraph 5.1).


Action requested of the Sub-Committee


1 the inclusion in the regulations and the Explanatory Notes definitions for capsize and rapid capsize (if there are no definitions for such criteria then research will need to be considered) (paragraph 2);


2 the proposed amendments to regulation 9.9 contained in the annex which extend the level of double bottom protection provided in regulation 9.9 for passenger ships with LLH, to cargo ships other than tankers, with LLH (paragraph 3.1);


3 the proposed amendments to regulation 8 contained in the annex, relating to the inconsistencies between regulations 8 and 9 for the increased protection of long lower holds, from side damages (paragraphs 3.2 and 3.3);


the Sub-Committee should await the outcome of further research.” However, as the IMO waits for the


ships


outcome of research already begun by industry specialists “ships with LLH could be constructed in accordance with the current regulations, which could leave them at risk in the event that the longitudinal bulkhead to the LLH is penetrated, with subsequent flooding of the LLH,” RINA concludes. RINA’s submission to the subcommittee


following its appraisal of SOLAS 2009 included the view that ro-ro passenger and cargo ships with LLH’s should be included, however, the SLF Subcommittee has a very narrow brief and is looking solely at damage stability for passenger vessels. As such the


discussion on ro-ro cargo ships could not take place, even though the same inconsistencies exist in both vessel types, posing the same threat to both vessel types. Effectively one of the reasons for


disallowing the RINA paper to be debated was the mention of cargo ships in the paper which allowed some, unspecified, administrations to claim that the paper was beyond the remit of the SLF. The reasoning behind the opposition


of these administrations and who they are is unclear, though one SLF Committee insider did suggest that the SLF had a very narrow remit for good reason and that time was so limited that to broaden that remit would stall the whole process. NA


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Feature 3


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