Rules of the Road: by Capt. Jake Desvergers
As we say goodbye to 2018 and welcome in the new year, we look ahead to what awaits us in the world of maritime regulations.
The various regulatory bodies were again very busy this past year. We will see several new rules enter into force. Below is a summary of those changes that will affect new and existing yachts.
SOLAS: Escape Route Signs, Jan. 1
As part of the recommendations following the Costa Concordia incident, the International Maritime Organization (IMO) has reviewed the adequacy of shipboard safety signs and markings. As a result of that review, the IMO adopted Resolution A.1116 (30), “Escape Route Signs and Equipment Location Markings.”
This resolution harmonizes the requirements outlined in existing SOLAS regulations and the associated requirements listed in ISO standard 24409 for the “design, location, and use of shipboard safety signs, safety-related signs, safety notices and safety markings.” The new resolution incorporates the ISO graphical symbols without any changes.
Yacht designers, builders, owners, captains and consultants should note that when developing and/or revising fire-control plans, the new resolution should be used in conjunction with the existing Resolution A.952(23), “Graphical Symbols for Shipboard Fire Control Plans.”
This new requirement will affect all yachts constructed on or after Jan. 1, 2019. It will also affect existing yachts which undergo repairs, alterations, modifications, and outfitting within the scope of SOLAS chapters II-2 and/or III.
MARPOL: Bunker Delivery Note, Jan. 1
The regulations outlined in Annex VI of MARPOL require all vessels to ensure that the fuel used on board is compliant to the geographic area in which they operate. This is most commonly documented through the use of a Bunker Delivery Note (BDN).
After the initial implementation of this annex of MARPOL, it was noted that the existing guidance did not provide for the provision of fuel oils that do not meet certain sulfur limits. Different limits are mandated depending upon a vessel’s operation within a designated Emission Control Area (ECA). Current ECAs in effect are the Baltic Sea, North Sea and North America, including Hawaii and U.S. territories in the Caribbean.
In short, the revised BDN includes a new entry for the “purchaser’s specified limit value” of the sulfur content. This means that even fuels with higher sulfur content than required by MARPOL can be delivered to a yacht where the yacht uses equivalent measures, such as an Exhaust Gas Cleaning System (EGCS).
This change to the Bunker Delivery Note is intended to avoid any ambiguities and problems during inspections by Port State Control and the statutory survey for the International Air Pollution Prevention (IAPP) Certificate.
MARPOL: Amended ECA for Baltic Area and North Sea, Jan. 1
States in this existing ECA proposed further regulations for emission control. Ships, including yachts, constructed on or after Jan. 1, 2021, will be required to have Tier III engines if they visit these geographic regions.
There are exemption provisions to allow ships fitted with dual fuel engines to navigate without compliant fuel (e.g. LNG) and temporary operation for emergency repairs.
In summary, new ships and yachts that visit this area will be required to have Tier III engines. This will require the future operating areas of a ship or yacht to be assessed at the building contract stage.
SOLAS: Required Publication, July 1
New amendments to the International Aeronautical and Maritime Search and Rescue (IAMSAR) Manual will take effect. The amendments are detailed in the IMO MSC Circular MSC.1/Circ.1594.
The most significant revision includes a new section (1.8) on search and rescue operations (SAR) by maritime rescue services in times of armed conflict.
As a reminder, SOLAS regulation V/21 requires all commercial yachts to carry an up-to-date copy of IAMSAR Manual Volume III. Yachts should be prepared to purchase a new copy, paper or electronic, when it becomes available.
Capt. Jake DesVergers is chief surveyor for International Yacht Bureau (yachtbureau.org). Comments are welcome below.