02055.GEN - October 30, 2002

This year has been a remarkable one from the regulatory standpoint. There have been numerous changes to major maritime regulations, and we wanted to make note of a few.

Safety of Life at Sea Convention (SOLAS)
Numerous updates for SOLAS came into force on 1 July 2002, and more are on the way. Among those that we want to point out to the Fleet are:

Chapter II-1 prohibits the installation of all materials containing asbestos onboard all ships.

In Chapter II-2 the new International Code for Fire Safety Systems (FSS) is made mandatory. It contains specific and general requirements for vessels, as well as detailed specifications for fire safety systems.

Also in Chapter II-2, Emergency Escape Breathing Devices (EEBDs) required onboard vessels in various locations. EEBDs will give a person a minimum of 10 minutes to evacuate a space in case of fire or loss of oxygen. At least two EEBDs are required in the accommodation spaces. Vanuatu requires that SOLAS vessels have 200% coverage for engine room watch personnel, plus 1, with a minimum of 5 on off shore supply vessels, and 7 on all other SOLAS ships. All units must meet regulatory specifications. Please refer to Chapter II, Section 3 for further details.

Chapter V requires inter alia, voyage data recorders (VDRs) to assist in accident investigations by recording information on passenger vessels, ro-ros, and ships of 3,000 gts and above. There are various grandfathering clauses for older vessels excepting them from the requirements. Refer to Chapter V of the Convention for further information.

Chapter V also requires that vessels obtain an Automatic Information System (AIS) capable of automatically providing information vessel to vessel, and vessel to coastal authority. An AIS is to be placed on vessels built on or after1 July 02 as follows;
· Vessels of 300 gt and above engaged on international voyages;
· Cargo ships of 500 gt and above not engaged on international voyages; and
· Passenger ships irrespective of size.

Ships constructed before the deadline are required to install AIS in accordance with the following schedule;
· •Passenger ships by 1 July 2003;
· •Tankers by no later then the first survey for safety equipment on or after 1 July 2003;
· •Ships other then passenger ships and tankers:
      o Of 50,000 gt and above, no later then 1 July 2004;
      o Of 10,000 gt to 50,000 gt, no later then 1 July 2005;
      o Of 3,000 gt to 10,000 gt, no later then 1 July 2006;
      o Of 300 gt to 3,000gt, no later then 1 July 2007.

Note: Chapter V applies to all vessels including non-self propelled vessels and fishing vessels. Administrations are permitted to exempt certain types of vessels from various requirements in the regulation, where safety is not compromised. Vanuatu does not issue general exceptions, and owners are encouraged to apply for specific exemptions where required.

Chapter IX containing the International Safety Management Code has been updated. Changes include items in Chapter 13 on certification, verification, and control, and Chapters 14-16 (which have been added to the Code). Additionally, appendices have been amended to give formats for documents and certifications.

The International Code of the Application for Fire Testing Procedures (FTP Code) implements testing of fire restricting material and divisions for high speed craft (see Annex 1). Additional new parts of the Convention can be found in Parts 10 and 11.

The International Code for Construction and Equipment of Ships Carrying Dangerous Chemicals is Bulk (IBC Code), and the Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (BCH Code) have new amendments that came into force on 1 July 2002. These changes include protection for personnel, and the carriage of carbon disulfides, as well as new cargo hose requirements, vent systems, and operational & safety requirements.

The International Convention for the Prevention of Pollution from Ships (MARPOL)
Annex I sets a new time table for the phase out of single hull tankers worldwide. All tankers are classified under the Annex into three categories with various phase-out dates, ending in 2015. Vanuatu has the ability to allow some newer single hull ships to continue operating if they conform to other technical requirements. In these special cases the vessel may continue to sail until her 25th anniversary date.
Note also that under the amendments, a Condition Assessment Scheme (CAS) will be applied to several categories of tankers, as defined in the Annex by 2005 and 2010. For further details on the phase out and CAS requirements see Annex I, and Resolution A.744(18).

Annex III has been amended to delete tainting as criteria for marine pollutants from the Guidelines for the Identification of Harmful Substances in Package Form. This regulation came into force on 1 January 2002 (under tacit acceptance). Products now identified as marine pollutants because of their tainting properties are no longer classified as such. (Tainting affects seafood products when they are infected by organisms making the fish unpalatable to smell and/or consume).

One final note, remember that any updates made to safety equipment onboard a vessel must be reflected on the Safety Plan. Additionally, please prepare for changes to our annual inspection routine to include the verification of compliance with new requirements such as EEBDs. Please contact our office for further assistance if necessary.

Donald J. Sheetz
Executive Vice President