Alert on Detainable Deficiencies
06 June 2018 | C18024
Following a recent Port State Control (PSC) inspection, one deficiency has been imposed that resulted in the detention of the vessel. Dromon wishes to draw attention to this detainable deficiency to avoid re-occurrence.
Ship Owners/ Managers/ Operators | Surveyors/Auditors
Launching arrangements for survival craft: “The ship is requested to comply with the SOLAS 74 Convention (am. 81), because of her keel laying the ship was not requested to carry totally enclosed lifeboats. Since at the time of boarding it was found that the ship has been later on equipped with totally enclosed lifeboats (S74 am.83) it was noted that both the lifeboats were missing the launching mechanisms inside the lifeboats by which it’s possible to actuate the break to permit to reach the water level.”
What the regulation requires
Following Dromon Circulars C16008 and C18005, we wish to remind stakeholders that SOLAS regulation III/1.5, requires all ships, lifeboat release and retrieval system to comply with paragraphs 184.108.40.206.4 to 220.127.116.11.6 of the LSA Code, as amended by resolution MSC.320(89). Ship Owners are reminded that those systems that do not comply with the Code should be replaced or modified not later than the next scheduled dry-docking after 1 July 2014, but not later than 1 July 2019.
Fall preventer devices in accordance with the guidelines for the fitting and use of fall preventer devices (FPDs), as per IMO MSC.1/Circ.1327, should be employed for each existing lifeboat release and retrieval system until the system is:
- found compliant with the LSA Code; or
- modified and found compliant with the LSA Code; or
- found compliant with paragraphs 18.104.22.168.4 to 22.214.171.124.6 of the LSA Code and paragraphs 16 and 17 (overhaul examination) of the IMO MSC.1/Circ.1392; or
- modified and found compliant with paragraphs 126.96.36.199.4 to 188.8.131.52.6 of the LSA Code and paragraphs 16 and 17 (overhaul examination) of the IMO MSC.1/Circ.1392; or
- replaced by a new lifeboat release and retrieval system.
After a successful completion of the design review, a performance test should be conducted by the manufacturer for each type of lifeboat release and retrieval systems for compliance with paragraphs 184.108.40.206.4 to 220.127.116.11.6 of the LSA Code, using the test specified below. The performance test should be witnessed by our Surveyor.
Release and retrieval system condition and test
- The lifeboat release and retrieval system and the longest used connection cable/linkage associated with the system should be mounted and adjusted according to instructions from the original equipment manufacturer and then loaded to 100% of its safe working load and released. Load and release should be repeated 50 times. During the 50 releases, the lifeboat release and retrieval system should be released simultaneously from each fall to which it is connected without any binding or damage to any part of the lifeboat release and retrieval system. The system should be considered as “failed” if any failure during the conditioning or unintended release occurs when load is applied but the system has not yet been operated.
- The lifeboat release and retrieval system should then be disassembled, the parts examined and wear recorded. The release and retrieval system should then be reassembled.
- The hook assembly, whilst disconnected from the operating mechanism, should then be tested 10 times with cyclic loading from zero load to 1.1 times the safe working load, at a nominal 10 seconds per cycle; unless the release and retrieval system has been specifically designed to operate as an off-load hook with on-load capability using the weight of the boat to close the hook, in this case the cyclic load should be from no more than 1% to 1.1 times the SWL; and
- The cable and operating mechanism should then be reconnected to the hook assembly; and the lifeboat release and retrieval system should then be demonstrated to operate satisfactorily under its safe working load. The actuation force should be no less than 100 N and no more than 300 N, if a cable is used it should be the maximum length specified by the manufacturer, and secures in the same manner it would be secured in the lifeboat. The demonstration should verify that any interlocks, including hydrostatic interlocks, where fitted, indicators and handles are still functioning and are correctly positioned in accordance with the operation and safety instruction from the original equipment manufacturer. The release and retrieval system is deemed to have passed the testing under this appendix when the tests have been conducted successfully. The system should be considered as “failed” if any failure during this test or any unintended release or opening occurs.
The scope of the overhaul examination includes also a detailed assessment of the condition of the components of the lifeboat release and retrieval system to observe the extent of wear, corrosion, erosion and other types of material degradation that may have occurred. Upon satisfactory completion of the overhaul examination, the manufacturer or one of their representatives should issue a factual statement to confirm this, for retention on board.
Should any part of the lifeboat release and retrieval system fail at any stage during the test, this type of lifeboat release and retrieval system should be deemed to be non-compliant and reported as such.
The procedure should be followed in all cases where a lifeboat is to be fitted with replacement lifeboat release and retrieval systems with on-load release capability.
Replacement of lifeboat
Companies should, where possible, select replacement equipment acceptable to the lifeboat manufacturer. However, in cases where the lifeboat manufacturer is unable to offer a suitable replacement lifeboat release and retrieval system, the Company may select an alternative lifeboat release and retrieval system, with the agreement, if possible, of the lifeboat manufacturer. The replacement equipment should be approved by the Administration or Dromon, under the provisions of the LSA Code.
Replacement of hook fixed structural connections of the release mechanism and supporting structure
As per IMO Circular MSC.1/Circ.1584, Dromon may allow hook fixed structural connections of the release mechanism and supporting structure which are not made of material resistant to corrosion in the marine environment, as required by paragraph 18.104.22.168.9 of the LSA Code, not be replaced if they are in a good condition and installed in a sheltered position inside the lifeboat. The assessment for verifying that fixed structural connections and supporting structures are in ‘good condition’ should be carried out by the manufacturer or by one of its representatives. The assessment for verification is not required if the materials of the foundation, bolts and supporting structure, both internally and externally, are made of materials resistant to corrosion in the marine environment.
You are reminded that in case the ship is fit with a totally enclosed lifeboat, irrespective of the ship’s date of keel laid, the release and retrieval system must comply with the above requirements.
Surveyors must take note on the above detainable deficiency and give special attention during forthcoming SOLAS/SAFEQ statutory surveys, irrespective of scope. When applying SOLAS regulation III/1.5, you must ensure that an evaluation of the type of existing lifeboat release and retrieval system is undertaken, for compliance with paragraphs 22.214.171.124.4 to 126.96.36.199.6 of the LSA Code, in accordance with the IMO MSC.1/Circ.1392, as amended by MSC.1/Circ.1584.
Ship Owners/ Managers/ Operators are encouraged to inform Masters and take corrective actions if necessary. For further assistance please contact DBS Head Office at firstname.lastname@example.org