Rules of the Road: by Capt. Jake DesVergers
As we welcome in the new year, we will see several new maritime regulations enter into force. The various regulatory bodies worked overtime to bring us their best. Below is a summary of the changes that will affect new and existing yachts.
SOLAS – Helicopter Firefighting Appliances (Jan. 1, 2020):
It was proposed that the relevant International Maritime Organization (IMO) instruments for helicopters be brought into line with the provisions of other United Nation’s agencies. As a result of this proposal, new requirements for the provision of foam application systems for helicopter landing areas were agreed. It was also agreed that the guidelines in the annex to MSC.1/Circ.1431 should be redrafted as a new chapter to the International Code for Fire Safety Systems (FSS Code).
Amendments to SOLAS II-2/18 require a foam application system that complies with the new Chapter 17 of the FSS Code, which details the specifications for foam firefighting appliances for the protection of helidecks and helicopter landing areas.
The requirements are applicable to new yachts having a helicopter landing area, i.e. an area on a yacht designated for occasional or emergency landing and not designed for routine helicopter operations.
SOLAS – Radiocommunications and GMDSS (Jan. 1, 2020):
These amendments to SOLAS Chapter IV and other related documents accommodate new mobile satellite systems recognized for use in the Global Maritime Distress and Safety System (GMDSS). The amendments are necessary because SOLAS Chapter IV currently recognizes only Inmarsat as a GMDSS satellite service provider. As the IMO considers the recognition of additional GMDSS satellite service providers, it is necessary to replace these references with a generic term.
The changes enter into force on Jan. 1, 2020, and are applicable to all ships and yachts which are subject to the requirements of the GMDSS.
SOLAS – Testing of Winches and Winch Brakes for Lifesaving Appliances (Jan. 1, 2020):
A discrepancy has been identified between Chapter 6 of the Life-Saving Appliances (LSA) Code and the pre-installation testing requirements for winches and winch brakes in resolution MSC.81(70). It was agreed to modify the texts in these documents to delete the word “brakes” and to add “including winch structural components.” Since only winch brakes are designed to have sufficient strength and be prototype tested to withstand a static proof load of not less than 1.5 times the maximum working load, the text “except the winch” should be read as “For lifeboats other than free-fall lifeboats, davits and launching appliances, except winches, should be subjected to a static proof load of 2.2 times their maximum working load.”
While manufacturers and surveyors need to be aware of the correction, this should have a limited impact on the prototype testing of LSA equipment. Special attention should be made on yachts equipped with rescue boat davits. This affects the pre-installation testing of equipment fitted on new yachts and new equipment installed on existing yachts after Jan. 1, 2020.
MARPOL: Noncompliant Fuel (March 1, 2020):
The use of 0.50% (or below) sulphur fuel oil outside of emission control areas (ECAs) from Jan. 1, 2020, was introduced in the 2008 amendments to the MARPOL Convention. This further amendment supplements the 2008 amendments by also prohibiting the carriage of fuel oil with a sulphur content higher than 0.50% unless the ship has a scrubber. MEPC 72 approved amendments to MARPOL Annex VI Regulation 14 to prohibit ships from carrying fuel oil with a sulphur content above 0.50% if its purpose is for combustion for propulsion or operations on board. The only allowance is if the ship has an approved equivalent arrangement in place, such as an exhaust gas treatment system. Corresponding amendments were also made to the supplement to the International Air Pollution Prevention (IAPP) Certificate.
Yacht owners may need to consider de-bunkering of any high sulphur fuel that is not used up before Jan. 1, 2020. This carriage prohibition goes into force on March 1, 2020, and affects all ships and yachts.
Capt. Jake DesVergers is chief surveyor for International Yacht Bureau (yachtbureau.org). Comments are welcome below.