SDC 4 16 Report To The Maritime Safety Committee Secretariat

E
SUB-COMMITTEE ON SHIP DESIGN AND SDC 4/16

CONSTRUCTION 8 March 2017
4th session Original: ENGLISH
Agenda item 16
REPORT TO THE MARITIME SAFETY COMMITTEE
TABLE OF CONTENTS
Section Page
1 GENERAL 4
2 DECISIONS OF OTHER IMO BODIES 4
3 AMENDMENTS TO SOLAS REGULATIONS II-1/6 AND II-1/8-1 5
4 COMPUTERIZED STABILITY SUPPORT FOR THE MASTER IN CASE 10

OF FLOODING FOR EXISTING PASSENGER SHIPS
5 FINALIZATION OF SECOND GENERATION INTACT STABILITY 13

CRITERIA
6 AMENDMENTS TO SOLAS AND THE FSS CODE TO MAKE 24

EVACUATION ANALYSIS MANDATORY FOR NEW PASSENGER
SHIPS AND REVIEW OF THE RECOMMENDATION ON EVACUATION
ANALYSIS FOR NEW AND EXISTING PASSENGER SHIPS
7 REVISION OF SECTION 3 OF THE GUIDELINES FOR DAMAGE 25

CONTROL PLANS AND INFORMATION TO THE MASTER
(MSC.1/CIRC.1245) FOR PASSENGER SHIPS
8 MANDATORY INSTRUMENT AND/OR PROVISIONS ADDRESSING 26

SAFETY STANDARDS FOR THE CARRIAGE OF MORE THAN 12
INDUSTRIAL PERSONNEL ON BOARD VESSELS ENGAGED ON
INTERNATIONAL VOYAGES
9 AMENDMENTS TO THE 2011 ESP CODE 28
10 UNIFIED INTERPRETATION TO PROVISIONS OF IMO SAFETY, 30

SECURITY, AND ENVIRONMENT-RELATED CONVENTIONS
11 REVISED SOLAS REGULATION II-1/3-8 AND ASSOCIATED 33

GUIDELINES (MSC.1/CIRC.1175) AND NEW GUIDELINES FOR SAFE
MOORING OPERATIONS FOR ALL SHIPS
I:\SDC\04\SDC 4-16 (E).docx

SDC 4/16
Page 2
Section Page
12 GUIDELINES FOR USE OF FIBRE REINFORCED PLASTIC (FRP) 37

WITHIN SHIP STRUCTURES
13 BIENNIAL STATUS REPORT AND PROVISIONAL AGENDA FOR SDC 5 41
14 ELECTION OF CHAIR AND VICE-CHAIR FOR 2018 44
15 ANY OTHER BUSINESS 44
16 REPORT TO THE MARITIME SAFETY COMMITTEE 45
LIST OF ANNEXES
ANNEX 1 DRAFT MSC RESOLUTION ON REVISED EXPLANATORY NOTES TO

THE SOLAS CHAPTER II-1 SUBDIVISION AND DAMAGE STABILITY
REGULATIONS
ANNEX 2 DRAFT AMENDMENTS TO SOLAS REGULATIONS II-1/1 AND II-1/8-1
ANNEX 3 DRAFT MSC CIRCULAR ON AMENDMENTS TO SECTION 3 OF

THE GUIDELINES FOR DAMAGE CONTROL PLANS AND INFORMATION
TO THE MASTER (MSC.1/CIRC.1245)
ANNEX 4 DRAFT MSC CIRCULAR ON UNIFIED INTERPRETATIONS OF SOLAS

CHAPTER II-1
ANNEX 5 DRAFT MSC CIRCULAR ON GUIDELINES ON THE MEANS OF ACCESS

TO STRUCTURES FOR INSPECTION AND MAINTENANCE OF OIL
TANKERS AND BULK CARRIERS
ANNEX 6 DRAFT MSC CIRCULAR ON UNIFIED INTERPRETATIONS OF SOLAS

CHAPTERS II-1 AND XII, OF THE TECHNICAL PROVISIONS FOR MEANS
OF ACCESS FOR INSPECTIONS (RESOLUTION MSC.158(78)) AND OF
THE PERFORMANCE STANDARDS FOR WATER LEVEL DETECTORS ON
BULK CARRIERS AND SINGLE HOLD CARGO SHIPS OTHER THAN BULK
CARRIERS (RESOLUTION MSC.188(79))
ANNEX 7 DRAFT CORRIGENDUM TO MSC.1/CIRC.1464/REV.1
ANNEX 8 DRAFT MSC CIRCULAR ON UNIFIED INTERPRETATION OF SOLAS

REGULATIONS II-1/2.20 AND II-2/3.21
ANNEX 9 DRAFT MEPC CIRCULAR ON UNIFIED INTERPRETATION OF

REGULATION 1.23 OF MARPOL ANNEX I
ANNEX 10 DRAFT MSC CIRCULAR ON INTERIM GUIDELINES FOR USE OF FIBRE

REINFORCED PLASTIC (FRP) ELEMENTS WITHIN SHIP STRUCTURES:
FIRE SAFETY ISSUES
ANNEX 11 BIENNIAL STATUS REPORT AND OUTPUTS ON THE COMMITTEE'S

POST-BIENNIAL AGENDA THAT FALL UNDER THE PURVIEW OF
THE SUB-COMMITTEE

SDC 4/16
Page 3
ANNEX 12 PROPOSED BIENNIAL AGENDA FOR THE 2018-2019 BIENNIUM
ANNEX 13 PROPOSED PROVISIONAL AGENDA FOR SDC 5
ANNEX 14 STATEMENTS BY DELEGATIONS

SDC 4/16
Page 4
1 GENERAL
1.1 The Sub-Committee on Ship Design and Construction (SDC), chaired by

Mr. Kevin Hunter (United Kingdom), held its fourth session from 13 to 17 February 2017.
The Vice-Chair, Mrs. Turid Stemre (Norway), was also present.
1.2 The session was attended by delegations from Member Governments, an Associate
Member of IMO and by observers from intergovernmental organizations and non-governmental
organizations in consultative status, as listed in document SDC 4/INF.1.
Opening address
1.3 The Secretary-General welcomed participants and delivered the opening address.
The full text of the opening address can be downloaded from the IMO website at the following link:
http://www.imo.org/en/MediaCentre/SecretaryGeneral/SpeechesByTheSecretaryGeneral/Pages/Default.aspx
Chair's remarks
1.4 In responding, the Chair thanked the Secretary-General for his words of guidance and
encouragement and assured him that his advice and requests would be given every
consideration in the deliberations of the Sub-Committee.
Adoption of the agenda and related matters
1.5 The Sub-Committee adopted the agenda (SDC 4/1) and agreed to be guided in its work,
in general, by the annotations contained in document SDC 4/1/1 (Secretariat) and the arrangements
in document SDC 4/1/2 (Chair). The agenda, as adopted, together with the list of documents
considered under each agenda item, is set out in document SDC 4/INF.11.
2 DECISIONS OF OTHER IMO BODIES
2.1 The Sub-Committee noted the decisions and comments pertaining to its work
made by the Maritime Safety Committee (MSC), at its ninety-sixth session, the Council, at its
116th session, the Marine Environment Protection Committee (MEPC), at its seventieth
session and the Maritime Safety Committee (MSC), at its ninety-seventh session, as reported
in documents SDC 4/2 and SDC 4/2/1 (Secretariat), and took them into account in its
deliberations when dealing with the relevant agenda items.
2.2 The Sub-Committee also noted that MSC 96, taking into account the availability of
a new GISIS module on "Development of amendments to the 1974 SOLAS Convention and
related mandatory instruments", had instructed its subsidiary bodies and the Secretariat
to keep the records updated in GISIS during the preparation of draft amendments to
the 1974 SOLAS Convention and related mandatory instruments.
2.3 It was further noted by the Sub-Committee that MSC 97, having agreed to the draft
amendments to the Committees' Guidelines in relation to the use of gender-neutral terms, as
approved by MEPC 70, concurrently approved the document on Organization and method of
work of the Maritime Safety Committee and the Marine Environment Protection Committee and
their subsidiary bodies (MSC-MEPC.1/Circ.5) with immediate effect.

SDC 4/16
Page 5
3 AMENDMENTS TO SOLAS REGULATIONS II-1/6 AND II-1/8-1
General
3.1 The Sub-Committee recalled that SDC 3 had re-established the Correspondence
Group on Subdivision and Damage Stability (SDS) for finalization of the draft revised Explanatory
Notes to SOLAS chapter II-1 subdivision and damage stability regulations.
3.2 The Sub-Committee also recalled that SDC 3, having agreed to continue the work on
availability of a passenger ship's electrical power supply in cases of flooding from side raking
damage, not only for "double-hull in way of main engine-room" but also for other alternatives
under this output, had advised MSC 96 that a double hull may not be the only solution and
that, therefore, other solutions needed to be further considered and had requested the Committee
to endorse the view that the change of the existing scope of the output was acceptable and
did not require any specific justification.
3.3 The Sub-Committee noted that the Secretariat, following the request by SDC 3, had
issued a corrigendum to resolution MSC.216(82) containing consequential editorial
amendments to SOLAS regulations II-1/42.2.6.1 and II-1/42.4.2, i.e. replacing references
to SOLAS regulation II-1/15 with references to SOLAS regulation II-1/13 and adding
footnotes indicating that, prior to 1 January 2009, regulation 13 was regulation 15
(MSC 82/24/Add.1/Corr.7).
Outcome of MSC 96
3.4 The Sub-Committee noted that MSC 96 had endorsed the views that the double hull
may not be the only solution and, therefore, other alternative solutions needed to be further
considered, and that the recommended change of the existing scope of the output was
acceptable and did not require any specific justification (see also paragraph 3.2).
3.5 The Sub-Committee also noted that MSC 96, having approved the draft amendments
to SOLAS chapter II-1 on subdivision and damage stability regulations, had requested
the Secretary-General to circulate them in accordance with SOLAS article VIII, with a view to
subsequent adoption at MSC 97.
Outcome of MSC 97
3.6 The Sub-Committee further noted that MSC 97 had agreed to hold the adoption of
the draft amendments to SOLAS chapter II-1 on subdivision and damage stability regulations in
abeyance until MSC 98, pending the finalization of the draft amendment to SOLAS
regulation II-1/6 (Required subdivision index R), taking into account that this would still allow for
the amendments to SOLAS chapter II-1, if adopted at MSC 98, to enter into force as planned,
i.e. on 1 January 2020, and that any further modifications to SOLAS regulation II-1/6 should not
lower the current safety level of SOLAS provisions.
3.7 It was also noted by the Sub-Committee that MSC 97, having recalled that the adoption
of the draft amendments to SOLAS chapter II-1 had been deferred to the next session, had
agreed to hold the adoption of the draft amendments to SOLAS chapter III and the approval of
the draft MSC circular on Revised guidance for watertight doors on passenger ships which
may be opened during navigation in abeyance until MSC 98.

SDC 4/16
Page 6
3.8 The Sub-Committee further noted that MSC 97, having agreed that the draft MSC circular
on Early implementation of the amendments to SOLAS regulation II-1/12.6.1 on the acceptance
of the use of butterfly valves on cargo ships was related to corrections to existing provisions,
had noted the explanation by the Director of the Legal Affairs and External Relations Division
that there may be a possibility whereby the error could be corrected in accordance with
article 79 (Correction of errors in texts or in certified copies of treaties) of the Vienna
Convention on the Law of Treaties, 1969, and had agreed to consider the matter at MSC 98,
after taking into account the document to be submitted by the Secretariat on how to correct
the errors.
Revised Explanatory Notes to SOLAS chapter II-1 subdivision and damage stability
regulations
Part 2 of the report of the SDS Working Group established at SDC 3
3.9 Having considered part 2 of the report of the SDS Working Group established
at SDC 3 (SDC 4/3), the Sub-Committee, bearing in mind that the SDS Correspondence Group
had already considered the draft amendments proposed in the report during its deliberations,
approved part 2 of the report in general.
Report of the SDS Correspondence Group and related documents
3.10 The Sub-Committee, having considered the report of the SDS Correspondence Group
(SDC 4/3/1), providing information regarding the development of the revised Explanatory Notes
to SOLAS chapter II-1 subdivision and damage stability regulations, noted that the revised
Explanatory Notes should be issued as a new MSC resolution with the same applicability as
the amendments to SOLAS chapter II-1 subdivision and damage stability regulations
(i.e. applicable to ships built on or after 1 January 2020).
3.11 The Sub-Committee also had for its consideration the following two documents
commenting on the report of the SDS Correspondence Group:
.1 SDC 4/3/2 (Norway), advising of an inconsistency between the previous SOLAS

regulation II-1/20-2 (Watertight integrity from the ro-ro deck (bulkhead deck)
to spaces below) and the current SOLAS regulation II-1/17-1 (Integrity of
the hull and superstructure, damage prevention and control on ro-ro
passenger ships), and proposing that the above inconsistency should be
treated as an unintended result of the harmonization of SOLAS chapter II-1
and, as an interim measure, a new explanatory note to SOLAS
regulation 17-1.1 be introduced in the draft revised Explanatory Notes
developed by the SDS Correspondence Group; and
.2 SDC 4/3/3 (China), proposing to develop an internationally uniform

time-domain simulation standard method and to add a footnote referring to
it, where appropriate, and providing a new text to replace footnote 1 to
paragraph 4 in the explanatory notes to SOLAS regulation II-1/13.2.3.
3.12 In considering the above documents and noting that all of those who spoke supported
the proposal in document SDC 4/3/2, the Sub-Committee noted the following general
comments expressed:
.1 watertight bulkheads and decks shall be made of steel and have A-class fire
integrity, and, in this context, A-class fire integrity shall also apply to pipes
penetrating them;

SDC 4/16
Page 7
.2 the use of time-domain simulations as an alternative to damage stability

calculations for sequential flooding and cross-flooding has been accepted for
a number of years and are referred to in a number of MSC resolutions;
.3 an internationally uniform time-domain flooding simulation standard method

would be helpful, but its development is outside of the scope of the current
output and, therefore, a new output would be required for the development
of such a uniform method; and
.4 the proposal in document SDC 4/3/2 needs to be carefully considered as it

may have possible consequences related to evacuation aspects,
and agreed that the proposal in document SDC 4/3/2 should be further considered, when
finalizing the draft revised Explanatory Notes to SOLAS chapter II-1 subdivision and damage
stability regulations, and decided that no further action should be taken regarding the proposals
in document SDC 4/3/3.
3.13 Following consideration of the action requested in paragraph 24 of the report of

the SDS Correspondence Group (SDC 4/3/1), the Sub-Committee approved the report in
general and took the following actions:
.1 noted the specific issues that require further consideration at this session, as
outlined in paragraphs 6 to 22 of the report;
.2 agreed that the elements of the draft revised Explanatory Notes presented in
square brackets could be kept for discussion in a working group; and
.3 agreed to establish an SDS Working Group to further consider the outstanding

issues, including the proposal in document SDC 4/3/2, with a view to finalizing
the draft revised Explanatory Notes at this session.
Availability of a passenger ship's electrical power supply in cases of flooding from side
raking damage
3.14 Having noted that no documents had been submitted on this issue, the Sub-Committee
agreed to instruct an SDS Working Group to further consider the matter and advise on how
best to proceed.
Establishment of the SDS Working Group
3.15 Following discussion and recalling the relevant decision at SDC 3, the Sub-Committee
established the SDS Working Group and instructed it, taking into account the comments made
and decisions taken in plenary, to:
.1 consider the outstanding issues, as specified in documents SDC 4/3/1

(paragraphs 6 to 22) and SDC 4/3/2;
.2 finalize the draft revised Explanatory Notes as a new MSC resolution with
the same applicability as the new SOLAS chapter II-1 subdivision and damage
stability amendments (i.e. applicable to ships built on or after 1 January 2020);
and

SDC 4/16
Page 8
.3 examine the draft amendments to SOLAS regulation II-1/8-1.2 to improve

the availability of a passenger ship's electrical power supply in cases of
flooding from side raking damage, not only for "double-hull in way of main
engine-room" but also for other alternatives, taking into account
document SDC 3/3/6 (United States), and advise the Sub-Committee on how
best to proceed.
Report of the SDS Working Group
3.16 Having considered the part of the report of the SDS Working Group (SDC 4/WP.3),
dealing with the agenda item, the Sub-Committee took action as outlined in paragraphs 3.17
to 3.33 below.
Revised Explanatory Notes to SOLAS chapter II-1 subdivision and damage stability
regulations
3.17 In considering the draft new Explanatory Note 2 for the draft regulation II-1/5.2,
the Sub-Committee noted that the Group had agreed to include the deviation limits regarding
what could be accepted as "known differences from the lead sister ship" to qualify a ship as
a sister ship.
3.18 Regarding the draft new Explanatory Note 3 for the draft regulation II-1/5.2,
the Sub-Committee noted that the Group, having recognized that the provision, taken from
paragraph 3 of the existing Unified interpretation of SOLAS chapter II-1 (MSC/Circ.1158) to
use the highest of either the lead sister ship's vertical centre of gravity or the calculated
adjusted value, might be overly conservative in some cases, had agreed that this provision
should be retained and, in any cases where it may be overly conservative, there would always
be the option to incline the ship in order to obtain the actual vertical centre of gravity.
3.19 The Sub-Committee noted that, with regard to the draft new Explanatory Note 2 for
regulation II-1/5.4, the Group, having considered whether all alterations should require an
amended stability information to be supplied to the master, based on the calculated new
lightship properties, had agreed to include a threshold for when the amended stability
information should be supplied to the master.
3.20 In considering the draft revised Explanatory Note 1 for regulation II-1/7.7,
the Sub-Committee noted that the Group, taking into account the concerns expressed with
regard to the sketch providing a "typical example of valve that can be considered part of
the bulkhead where the separation distance is of the same order as the bulkhead stiffening
structure (d≤t)", had agreed not to include this sketch in the Explanatory Note.
3.21 With regard to the draft new Explanatory Note 6 for the draft regulation II-1/7-2.2,
the Sub-Committee noted that this Explanatory Note had been substantially modified and
finalized to ensure that the ship does not immediately capsize after damage.
3.22 The Sub-Committee noted that, in relation to the draft revised Explanatory Note 2 for
regulation II-1/7-2.5.2.2, the Group had decided to use the term "space" within the context of
the "horizontal evacuation routes" description and agreed to delete any reference to
the acceptable number of escape routes that should be available when an "undamaged zone"
contained more than one horizontal escape route.

SDC 4/16
Page 9
3.23 In considering the draft new Explanatory Note for the draft regulation II-1/12.2, which
would exclude the application of this requirement to cargo ships complying with subdivision
and damage stability requirements in other IMO instruments, the Sub-Committee noted that
the Group had agreed to delete this Explanatory Note because it was considered to contradict
the application requirement in the draft regulation II-1/4.2.2.
3.24 Regarding the draft new Explanatory Note 1 for regulation II-1/13.2.3, the Sub-Committee
noted that this Explanatory Note had been developed to prevent progressive flooding when
heat-sensitive materials are used in systems which penetrate watertight bulkheads.
3.25 In considering the draft new Explanatory Note 2 for regulation II-1/13.2.3,
the Sub-Committee noted that the definitions for closed and open piping systems were
sufficiently detailed and, therefore, no examples of such systems should be included.
3.26 With regard to the draft new Explanatory Note 3 for regulation II-1/13.2.3, which was
intended to address the strength of heat-sensitive and thin-walled materials after exposure to
heat, the Sub-Committee noted that the Group had agreed on how these materials should be
treated when used in systems which penetrate watertight bulkheads.
3.27 The Sub-Committee noted that the Group, when finalizing the draft new Explanatory
Note 2 for regulation II-1/17.1, had agreed on the need to distinguish watertight doors which
become intermittently immersed at angles of heel in the required range of stability beyond
the equilibrium position from other watertight doors due to the difference in their operational
requirements and had recognized that this issue will be further addressed under the output on
"Review SOLAS chapter II-1, parts B-2 to B-4, to ensure consistency with parts B and B-1 with
regard to watertight integrity", included in the post-biennial agenda of the Committee (see also
paragraphs 13.8, 13.10 and 13.13, and annexes 11 to 13).
3.28 It was also noted by the Sub-Committee that the Group, having lengthily discussed
the proposal contained in document SDC 4/3/2 (Norway) to introduce a draft new Explanatory
Note for regulation II-1/17-1, had agreed to include the proposed draft new Explanatory Note.
In this context, it was recognized that accesses leading to spaces below ro-ro decks will be
addressed within the work on the new output referred to in paragraph 3.27 above.
3.29 Following the discussion, the Sub-Committee endorsed the draft Revised Explanatory
Notes to SOLAS chapter II-1 subdivision and damage stability regulations and the associated
draft MSC resolution, as set out in annex 1, for submission to MSC 98 for adoption, in
conjunction with the adoption of the draft amendments to SOLAS chapter II-1 subdivision and
damage stability regulations.
Availability of passenger ships' electrical power supply in cases of flooding from side
raking damage
3.30 In regard to the Group's discussion on how best to address the availability of
a passenger ship's electrical power supply in SOLAS (SDC 4/WP.3, paragraphs 17 to 21),
the Sub-Committee noted that the Group had agreed that the SDS Correspondence Group
should be re-established and instructed to work on developing functional and performance
requirements, and, as appropriate, amendments to SOLAS regulations.
3.31 Following the discussion, the Sub-Committee endorsed the Group's recommendation
that the title of the existing output, i.e. "Amendments to SOLAS regulations II-1/6 and II-1/8-1",
should be replaced with "Amendments to SOLAS regulation II-1/8-1 on the availability of
passenger ships' electrical power supply in cases of flooding from side raking damage" (see
also paragraphs 13.10 and 13.13, and annexes 12 and 13).

SDC 4/16
Page 10
Re-establishment of the SDS Correspondence Group
3.32 Having considered the above matters and in order to progress the work
intersessionally, the Sub-Committee re-established the SDS Correspondence Group, under
the coordination of the United States, and instructed it to (see also paragraph 4.16):
.1 develop draft amendments to SOLAS regulation II-1/8-1 including functional

and performance requirements in order to improve the availability of
passenger ships' electrical power supply in cases of flooding from side raking
damage, taking into account document SDC 4/WP.3; and
.2 submit a report to SDC 5.
Extension of the target completion year
3.33 In light of the above decisions, the Committee was invited to extend the target
completion year for this output to 2019.
4 COMPUTERIZED STABILITY SUPPORT FOR THE MASTER IN CASE OF

FLOODING FOR EXISTING PASSENGER SHIPS
General
4.1 The Sub-Committee recalled that SDC 3 had invited Member States and international
organizations to submit comments and proposals on draft amendments to SOLAS
regulation II-1/8-1.3, as set out in annex 2 to document MSC 94/6/1 (Bahamas et al.), and on
implementation of the draft revised Guidelines on operational information for masters of
passenger ships for safe return to port by own power or under tow (MSC.1/Circ.1400) on
existing passenger ships, for consideration at this session.
4.2 The Sub-Committee had for its consideration the following two documents:
.1 SDC 4/4 (IACS), further discussing the need for existing passenger ships to
be provided with computerized stability support and proposing a draft
amendment to SOLAS regulation II-1/8-1.3; and
.2 SDC 4/4/1 (United States), commenting on the draft amendment to SOLAS

regulation II-1/8-1.3, proposed in document SDC 4/4, and providing an
alternative proposal that is intended to improve clarity and also align with
the similar text used to apply the draft new SOLAS regulation II-1/19-1 to existing
passenger ships.
4.3 Having considered the above documents, the Sub-Committee noted the following
views expressed on this matter:
.1 document SDC 4/4/1 should be used as a basis for further consideration;

Coordinator:
Mr. James Person
Naval Architecture Division
Office of Design and Engineering Standards
U.S. Coast Guard Headquarters
Washington, DC 20593
United States
Tel: +1 (202) 372 1369
Email: james.l.person@uscg.mil

SDC 4/16
Page 11
.2 the need for the proposed duplication of the application provisions in SOLAS
regulations II-1/1.1.1.1 and II-1/8-1.3.1 should be carefully considered, taking
into account the possibility of future amendments to these regulations;
.3 it would be desirable to clarify that the first scheduled dry-docking is the first
out-of-water dry-docking;
.4 a number of issues need to be further considered, e.g. definition of "all ships",

availability of data, practicability and flexibility in application to all ships;
.5 flexibility in application to existing ships may be achieved by introducing

the words "as far as reasonable and practicable";
.6 a discussion regarding the flexibility in application is necessary to clarify what

it means to be flexible instead of using words such as "as far as reasonable
and practicable"; and
.7 two possible options can be used, i.e. onboard software and shore-based
support, and, therefore, both of these should be taken into consideration,
and agreed to instruct the SDS Working Group, established under item 3 (Amendments
to SOLAS regulations II-1/6 and II-1/8-1), to further consider the matter and advise
the Sub-Committee on how best to proceed, taking into account that the finalization of the draft
revised Explanatory Notes to SOLAS chapter II-1 subdivision and damage stability regulations
should have a higher priority.
Instructions to the SDS Working Group
4.4 The Sub-Committee instructed the SDS Working Group, established under agenda
item 3 (see paragraph 3.15), to consider the draft amendments to SOLAS regulation II-1/8-1.3
proposed in the annex to document SDC 4/4, and the alternative proposal on amending
SOLAS regulations II-1/1 and II-1/8-1.3, as set out in the annex to document SDC 4/4/1, taking
into account possible difficulties in applying all the items in MSC.1/Circ.1400, MSC.1/Circ.1532
and MSC.1/Circ.1229 to some existing passenger ships, and the comments and decisions
made in plenary; and to advise the Sub-Committee on how best to proceed.
4.5 Having considered the part of the report of the SDS Working Group (SDC 4/WP.3),
to 4.17 below.
Draft regulations SOLAS II-1/1 and II-1/8-1.3
4.6 With regard to the proposed draft amendments to SOLAS regulations II-1/1
and II-1/8-1.3, the Sub-Committee noted that the Group, having discussed on how
the applicability of SOLAS regulation II-1/8-1.3 should be implemented for existing passenger
ships, had agreed that any limitations of applicability of the current guidelines,
i.e. MSC.1/Circ.1400, MSC.1/Circ.1532 and MSC.1/Circ.1229, should be addressed by means
of an appropriate set of new guidelines.

SDC 4/16
Page 12
4.7 In this context, the Sub-Committee also noted that the Group had agreed that
the characteristics of the passenger ships to which SOLAS regulation II-1/8-1 applies, as
specified in its application paragraph, should be indicated in the amendments to SOLAS
regulation II-1/8-1.3, with a view to ensuring that the scope was not extended to other
passenger ships due to the direct application of SOLAS regulation II-1/8-1.3 to draft
amended SOLAS regulations II-1/1.1.2 and II-1/1.2 (MSC 97/WP.6/Add.1, annex 13).
4.8 Regarding the application date of the new draft amendments to SOLAS
regulation II-1/8-1.3 for existing passenger ships, the Sub-Committee noted that the Group had
emphasized that this date would depend on:
.1 the date of adoption of the draft amended regulation;
.2 the complexity of the criteria for stability computers or shore-based support

to be included in the new set of guidelines; and
.3 the date of approval of the set of guidelines to be developed.
4.9 Notwithstanding the above, and noting the views expressed that a five year window
after the amendments enter into force may be adequate, the Sub-Committee also noted that
the Group was not able to include a specific application date in the draft amended SOLAS
regulation II-1/8-1.3. However, it was decided by the Group that the date of application should
be linked with the renewal survey of the ship in order to avoid the uncertainties associated with
the initially proposed reference to "scheduled dry-docking".
4.10 In this context, the Sub-Committee further noted that the Group, having considered
possible options for the entry into force process of the draft amendments to SOLAS
regulations II-1/1 and II-1/8-1 prepared at this session (SDC 4/WP.3, paragraph 27), and taking
into account that the complexity of the criteria for stability computers in the new set of
guidelines would impact the application date of the new draft regulations for existing passenger
ships, was not able to advise on how best to proceed in this regard.
4.11 Following the discussion, the Sub-Committee agreed to the draft amendments
to SOLAS regulations II-1/1 and II-1/8-1 on computerized stability support for the master in
case of flooding for existing passenger ships, as set out in annex 2, for submission to MSC 98
for approval, with a view to their subsequent adoption at MSC 99.
Draft guidelines on stability computers and shore-based support for existing passenger
ships
4.12 In considering the difficulties that existing passenger ships may face in applying all
items of MSC.1/Circ.1400 and MSC.1/Circ.1532, the Sub-Committee noted that the Group had
agreed that the most appropriate approach would be to develop a new set of guidelines on stability
computers and shore-based support for passenger ships constructed before 1 January 2014.
4.13 With regard to the new set of guidelines, the Sub-Committee noted that the Group
had agreed that they should contain the minimum standards to set the acceptance criteria,
based on the following principles:
.1 the base document used to develop the new draft guidelines should be
the Revised guidelines on operational information for masters of passenger
ships for safe return to port (MSC.1/Circ.1532);
.2 the necessary inputs to the stability computer should be clearly provided;

SDC 4/16
Page 13
.3 careful consideration should be given to the provisions related to manual and

sensor data entries to the stability computer; and
.4 ships constructed before 1 January 2014 that voluntarily carry on-board

stability computers may not fully comply with the new draft guidelines
and should be subject to the equivalence provision in paragraph 31
of MSC.1/Circ.1532.
4.14 In this context, the Sub-Committee noted that, owing to time constraints, the Group
was not able to prepare the new draft guidelines and had agreed that they may be developed
by a correspondence group, if established. The Sub-Committee also noted that the Group had
started the development of the new draft guidelines with a view to reporting to SDC 5, as part 2
of the report of the SDS Working Group.
4.15 Following the discussion, the Sub-Committee endorsed the above Group's views on
the development of draft guidelines on stability computers and shore-based support for existing
passenger ships.
Instruction to the SDS Correspondence Group
intersessionally, the Sub-Committee instructed the SDS Correspondence Group established
under agenda item 3 (see paragraph 3.32) to finalize the draft guidelines on stability computers
and shore-based support for passenger ships constructed before 1 January 2014, using
the Revised guidelines on operational information for masters of passenger ships for safe
return to port (MSC.1/Circ.1532) as a base document and taking into account
document SDC 4/WP.3 and the report of the SDS Working Group (part 2).
4.17 In this regard, the Sub-Committee noted the view that the decision in paragraph 4.9
above (see also paragraph 26 of document SDC 4/WP.3) should be taken into account by
the SDS Correspondence Group.
5 FINALIZATION OF SECOND GENERATION INTACT STABILITY CRITERIA
General
5.1 The Sub-Committee recalled that SDC 3 had endorsed the revised plan of action for
intact stability work, identifying priorities, time frames and objectives for the work to be
accomplished (SDC 3/WP.5, annex 8), and had re-established the Correspondence Group on
Intact Stability (IS), with the terms of reference set out in paragraph 6.18 of document SDC 3/21,
to continue the work on development of second generation intact stability criteria, taking into
account the revised plan of action.
5.2 The Sub-Committee noted that MSC 97 had not agreed to the modifications to
the draft amendments to part B of the International Code on Intact Stability, 2008
(2008 IS Code) for ships engaged in lifting operations regarding equal safety level independent
of a calculation method, as proposed by Germany in documents MSC 97/3/6
and MSC 97/INF.10, and had instructed the Sub-Committee to consider them and develop
guidance with regard to the different calculation methods for stability evaluation, if considered
necessary.

SDC 4/16
Page 14
Part 2 of the report of the IS Working Group established at SDC 3
5.3 Having considered part 2 of the report of the IS Working Group established at SDC 3
(SDC 4/5), the Sub-Committee, bearing in mind that the IS Correspondence Group had already
considered the matters outlined in the report during its deliberations, approved part 2 of
the report in general.
Report of the IS Correspondence Group and related documents
5.4 The Sub-Committee considered the report of the IS Correspondence Group

(SDC 4/5/1 and addenda 1 to 6), providing information regarding the Group's work related to
the finalization of the draft explanatory notes for the second generation intact stability criteria,
collection of sample ship calculation results of the five modes of stability failure of the second
generation intact stability criteria, standards to be used with each level of vulnerability criteria
for the five modes of stability failure, refinement of vulnerability criteria, and development of
guidelines and specifications for direct stability assessment, guidelines for the preparation of
ship specific operational limitations, and relevant operational guidance.
5.5 The Sub-Committee noted with appreciation the information collected by

the IS Correspondence Group regarding the finalization of second generation intact stability
criteria (SDC 4/INF.4 and addenda 1 and 2).
5.6 The Sub-Committee also had for its consideration the following documents related to
the report of the IS Correspondence Group:
.1 SDC 4/5/2 (China), providing proposals on selection of motion prediction

method for parametric rolling level 2 criteria and on setting of calculation
parameters;
.2 SDC 4/5/3 (China), providing comments on parameter setting of level 2

criteria of excessive acceleration and on standard deviation integral method;
.3 SDC 4/5/4 (China), providing the results of the sample calculation conducted
by China for vulnerability of ships to surf-riding/broaching, and comments on
level 2 vulnerability criteria for surf-riding/broaching, based on the analysis of
the calculation results;
.4 SDC 4/5/5 (China), providing comments on the draft Guidelines on direct

stability assessment procedures, i.e. that the draft Guidelines need to be
amended and detailed calculation requirements need to be provided;
.5 SDC 4/5/6 (United States), providing draft consolidated explanatory notes that
restructure, generally consolidate and suggest some edits to the draft
working versions of the explanatory notes (SDC 3/WP.5), into a single
document, advising that the explanatory notes cannot be realistically
completed until all other elements of the output on second generation intact
stability criteria are completed and suggesting the revision of the plan of
action for the intact stability work to show finalization of the explanatory notes
at the same session as the target completion year (i.e. 2019);
.6 SDC 4/5/7 (United States), commenting on the status of the finalization of

second generation intact stability criteria, the challenges yet to be resolved
and consistency issues, and recommending elements to be included in
the draft terms of reference for an IS Working Group, if established;

SDC 4/16
Page 15
.7 SDC 4/5/8 (Germany), providing recommendations for further discussion on,

and finalization of, the draft Guidelines for the direct stability assessment in
the framework of the second generation intact stability criteria;
.8 SDC 4/5/9 (Japan), proposing the updated draft Guidelines for operational
limitations, focusing on the inclusion of operational limitations in the second
generation intact stability criteria, for further discussion at this session;
.9 SDC 4/5/10 (Japan), referring to the report of the IS Correspondence Group,

reporting on the outcome of model experiments of an offshore supply vessel
in astern waves and providing comments on the definition of a vessel with
extended low weather deck, in particular that it is not appropriate to apply
the criteria for pure loss of stability to this offshore supply vessel and that, in
order to establish the definition of "a vessel with extended low weather deck",
further study and consideration regarding the behaviour of water on deck are
needed, taking into account that the accumulated water on deck is the key
issue;
.10 SDC 4/5/11 (Japan), referring to the report of the IS Correspondence Group
and proposing a way for refining the second check of level 2 vulnerability
criterion for parametric roll, by focusing on the critical ship speed for
parametric roll;
.11 SDC 4/5/12 (Germany), commenting on the report of the IS Correspondence

Group and providing a proposal concerning dead ship stability criteria,
i.e. advising that it is important to provide sufficient testing of the three
assessment levels of dead ship stability criteria in comparison with the weather
criterion and with the assessment according to MSC/Circ.1200, and careful
study of the reasons for differences in all cases, to gather sufficient
confidence in the new criteria; and
.12 SDC 4/5/13 (Germany), commenting on the report of the IS Corresponding

Group and providing supplementary information for the discussions on
second generation intact stability criteria.
5.7 In considering the above documents, the Sub-Committee noted the following views
expressed:
.1 the availability of operational guidance should not be seen as an alternative

to taking action during design and construction to avoid, as far as possible,
the provision of a ship that is known to be potentially susceptible to one or
more specific failure modes;
.2 consideration should be given to the inclusion of advice on the need for

loading scenarios to be investigated for relevant failure modes prior to
commencement of loading;
.3 the explanatory notes cannot be finalized until the set of regulations/guidelines

on second generation intact stability criteria have themselves been finalized;
.4 the results of sample calculations so far carried out demonstrate a number

of inconsistences;

SDC 4/16
Page 16
.5 priority should be given to the development of the method for direct stability
assessment and the draft guidelines for preparation and approval of
operational limitations and operational guidance;
.6 the draft explanatory notes prepared by the IS Correspondence Group

should be used a as basis for future development, rather than the consolidated
draft set out in the annex to document SDC 4/5/6, as the Group identified
a number of issues (i.e. texts in square brackets) requiring further
consideration;
.7 there were concerns as to how the work under this output is organized and, in
particular, regarding the very academic approach taken on the development
of the draft explanatory notes, i.e. it is expected that a final product should
be a simple text understandable to all stakeholders. The outcome currently
available does not seem to be a practical tool for the industry, and
confirmation of its reliability is required; and
.8 the work on this output should be finalized within the currently approved time
frame without the addition of any new tasks, especially those that might
require further significant research to address them.
5.8 The Sub-Committee also noted with appreciation the information provided in
the following documents:
.1 SDC 4/INF.5 and SDC 4/INF.6 (China), providing supplementary sample

ship matrix calculation results for parametric rolling, pure loss of stability and
excessive acceleration criteria, and results of sample ship calculations for
dead ship stability criteria;
.2 SDC 4/INF.7 (United States), providing sample ship calculation outcomes for
vulnerability criteria (levels 1 and 2) for the dead ship condition and excessive
acceleration stability failure modes;
.3 SDC 4/INF.8 (Germany), providing an input for discussion on, and finalization
of, the draft Guidelines for the direct stability assessment in the framework
of the second generation intact stability criteria;
.4 SDC 4/INF.9 (Denmark), providing the results of sample ship calculation of

the vulnerability criteria for five different stability failure modes under
the scope of the second generation intact stability criteria; and
.5 SDC 4/INF.10 (Japan), providing the additional sample calculation results

obtained by using the modified effective wave slope coefficient estimation
procedure for the vulnerability of ships to the dead ship stability and excessive
acceleration failure modes.
5.9 Following a lengthy discussion, the Sub-Committee, having approved the report of
the IS Correspondence Group in general, agreed to establish an IS Working Group to continue
the work, based on the draft terms of reference proposed in annex 2 to document SDC 4/5/7
and taking into account that the priority should be given to the development of the method for
direct stability assessment.

SDC 4/16
Page 17
Draft amendments to part B of the 2008 IS Code regarding equal safety level independent
of a calculation method
5.10 The Sub-Committee recalled that MSC 97 had not agreed to the modifications to
the draft amendments to part B of the International Code on Intact Stability, 2008
(2008 IS Code) for ships engaged in lifting operations regarding equal safety level
independent of a calculation method, as proposed in documents MSC 97/3/6
and MSC 97/INF.10 (Germany), and noted that, consequentially, no further action on this
matter is necessary.
Establishment of the IS Working Group
established the IS Working Group and instructed it, taking into account the comments made
and decisions taken in plenary, to:
.1 review the plan of action for matters related to intact stability contained in
annex 8 to document SDC 3/WP.5, taking into account the progress made
during the session, and prepare a detailed and comprehensive revised plan,
identifying tasks, sub-tasks, priorities, time frames and objectives for
the work to be accomplished;
.2 further develop the draft Guidelines for the specification of direct stability
assessment, with a view to preparing draft Interim guidelines at this
session, taking into account document SDC 3/INF.12 and the report of
the IS Correspondence Group (SDC 4/5/1/Add.6);
.3 further consider the draft amendments to the 2008 IS Code regarding

the draft vulnerability criteria (levels 1 and 2) for each of the five stability
failure modes, taking into account part 2 of the report of the IS Working Group
at SDC 3 (SDC 4/5), part 7 of the report of the IS Correspondence Group
(SDC 4/5/1/Add.6 and SDC 4/INF.4) and, in particular:
.1 with regard to the pure loss of stability failure mode, discuss and
decide on the method to establish equivalence between regular and
irregular waves, and consider consistency issues in detail and
decide how and when these should be resolved;
.2 with regard to the parametric roll stability failure mode, consider

consistency issues in detail and decide how and when these should
be resolved, and decide on the method of presentation of stability
variation in waves;
.3 with regard to the dead ship condition stability failure mode,

consider in detail consistency and integrity issues deriving from
the use of different mathematical models in levels 1 and 2
vulnerability criteria, and decide if more studies are needed, how to
perform such studies, and when the issues should be resolved;
.4 with regard to both the dead ship condition and excessive

acceleration stability failure modes, decide on roll damping
linearization method; and

SDC 4/16
Page 18
.5 with regard to general calculation methods, consider whether

alternative formulae are needed for inertial properties of ships with
specific hull form parameters, consider issues associated with
evaluation of roll wave moment and coefficients of the effective
wave slope function, and consider issues associated with the choice
of the critical roll frequency for use with the roll damping estimation;
and
.4 further develop the draft explanatory notes for all five stability failure modes
with a view to completing the draft interim explanatory notes, taking into
account part 2 of the report of the IS Working Group at SDC 3 (SDC 4/5),
parts 1 to 6 of the IS Correspondence Group's report (SDC 4/5/1,
SDC 4/5/1/Add.1, SDC 4/5/1/Add.2, SDC 4/5/1/Add.3, SDC 4/5/1/Add.4,
SDC 4/5/1/Add.5 and SDC 4/INF.4) and, in particular:
.1 develop draft text for:
.1 the introduction and framework of the second generation

intact stability criteria;
.2 the algorithm of assessment of ship vulnerability to

parametric roll;
.3 the description of the assessment of ship vulnerability to

stability failure in the dead ship condition;
.4 the input data for thrust and resistance for the surf-riding/
broaching condition;
.5 the description of the background of the vulnerability

assessment for the excessive acceleration stability failure
mode; and
.6 the description of the evaluation of metacentric height and

righting lever curve in longitudinal waves;
.2 perform and compare calculations on the example input data set

and develop example assessments for each of the five stability
failure modes;
.3 prepare an example data set for the pure loss of stability failure
mode;
.4 decide on the need for additional information to be included as

appendices;
.5 further develop the draft Guidelines for the preparation and approval
of operational limitations and operational guidance with a view to
preparing draft Interim guidelines at this session, taking into account
part 2 of the report of the IS Working Group at SDC 3 (SDC 4/5),
part 7 of the report of the IS Correspondence Group
(SDC 4/5/1/Add.6 and SDC 4/INF.4) and documents SDC 3/6/7,
SDC 3/INF.10, SDC 3/INF.12 and SDC 3/INF.15;

SDC 4/16
Page 19
.6 consider whether it is necessary to re-establish a correspondence

group and, if so, prepare terms of reference for consideration by
the Sub-Committee; and
.7 submit a written report (part 1), continue working through the week
and submit part 2 of the report to SDC 5, as soon as possible after
the current session, so that it can be taken into account by
the IS Correspondence Group, if re-established.
Report of the IS Working Group
5.12 Having considered the report of the IS Working Group (SDC 4/WP.4), the Sub-Committee
took action as outlined in paragraphs 5.13 to 5.34 below.
Draft Guidelines for the direct stability assessment procedures
5.13 The Sub-Committee noted that, after a general discussion, the Group, having noted
that there was a lack of data in several areas of the draft Guidelines for direct stability
assessment (SDC 4/INF.4/Add.2, annex 16), had agreed that, at this session, priority should
be given to the identification and the scope of the remaining tasks, with a view to finalizing
the draft Guidelines at the next session.
5.14 The Sub-Committee also noted that the Group had decided to use the probabilistic
assessment procedures for direct stability assessment.
5.15 The Sub-Committee further noted that the Group, having lengthily discussed
paragraph 2.2 of the draft Guidelines with regard to the general requirements, taking into
account the framework for the application of the second generation intact stability criteria
(i.e. ships not satisfying the second level vulnerability criteria are allowed to navigate, if they
satisfy the direct stability assessment, and those not satisfying the direct assessment are
allowed to navigate with proper operational guidance/limitations):
.1 had agreed that the issue was out of the scope of the terms of reference
(see paragraph 5.11.2); and
.2 had recommended to the Sub-Committee to invite Member States and

international organizations to submit proposals on this issue for
consideration at SDC 5.
5.15 The Sub-Committee also noted the Group's view that a ship in a given condition of
loading is considered compliant with the requirements if the criterion does not exceed
a standard.
5.16 The Sub-Committee further noted the discussion on the issues connected with
the approval/accreditation of the methodologies to be produced following the guidelines for
the direct stability assessment, taking into account that accreditation is one of the three
keystones of the Verification, Validation and Accreditation (VV&A) process, by which software
is approved for use in critical applications.

SDC 4/16
Page 20
Draft amendments to the 2008 IS Code regarding the draft vulnerability criteria (levels 1
and 2)
5.17 The Sub-Committee noted the concerns expressed by the delegation of Norway
regarding the results of the matrix sample calculations submitted for consideration at this
session. These results demonstrated that when applying the five vulnerability criteria,
about 40 out of 57 ships do not meet the levels 1 or 2 criteria and, therefore, need to apply
either operational restrictions or undertake the expensive and time consuming process of
the direct stability assessment. Bearing in mind that these results were not backed by
experience on operating existing ships or by any accident statistics, the proposed draft
amendments to the 2008 IS Code need to be carefully evaluated.
5.18 In this context, the Sub-Committee also noted that not all combinations of the loading
conditions in the matrix calculations were feasible in actual operations.
The pure loss of stability failure mode
5.19 The Sub-Committee noted that the Group, in considering the draft amendments to
part B of the 2008 IS Code with regard to vulnerability criteria of levels 1 and 2 for the pure
loss of stability failure mode, had agreed to use annex 1 to document SDC 2/WP.4 as a basis.
5.20 With regard to the accumulation of a large volume of water on deck, which alters
the physics of the pure loss of stability failure mode, the Sub-Committee noted that the Group
agreed:
.1 that there was a need to further clarify the application regarding the loading
conditions of a ship that might be susceptible to the shipping of water on deck;
.2 to add the terms "Except for the loading conditions of the ship that may be
susceptible to the shipping of water on deck" in paragraph 2.10.1.1 of
the draft amendments to part B of the 2008 IS Code (SDC 2/WP.4, annex 1);
and
.3 that a corresponding explanatory note should be developed.
5.21 In the context of the discussion on the treatment of non-buoyant elements, such as
superstructures and deck cargo, within the second generation intact stability criteria,
the Sub-Committee noted that it was suggested that weathertight bodies could be taken into
account as a possible option, although further discussion on this issue was needed.
5.22 With regard to the matters related to inconsistencies between levels 1 and 2 of
vulnerability criteria for the pure loss of stability failure mode, the Sub-Committee noted
the Group's view that the problem of inconsistency between the levels may exist because
the GM-value, on which the level 1 vulnerability criterion for pure loss of stability is solely
based, only describes the initial stability, whereas the GZ curve, which is used for the level 2
criterion, does so throughout the range of stability.
5.23 In considering whether a method of calculation of minimum GM on a wave in

the level 1 vulnerability criterion could be a possible source of inconsistency,
the Sub-Committee noted that inconsistencies were found when the direct calculation of
minimum GM was used and that the Group, having discussed the removal of the direct
calculation of minimum GM, had decided to retain the direct calculation of minimum GM as
a more accurate option for its calculation.

SDC 4/16
Page 21
5.24 The Sub-Committee noted that the Group considered the increasing wave steepness
(Sw) in the level 1 criteria from the current value of 0.0334 (SDC 2/WP.4, annex 1) as possible
way to mitigate the inconsistency. The reason for such an increase was that the level 2
vulnerability criteria contain a stability assessment in the weather conditions where the wave
steepness can be as much as 0.1 and, therefore, increasing the wave steepness in level 1 up
to 0.05 may resolve the problem for the current level 2 standard.
5.25 With regard to the increase of the standard RPLA for level 1 from the current 0.05 m
(SDC 2/WP.4, annex 1), the Sub-Committee noted that the Group, having discussed
the matter, had noted that several delegations expressed concern that it might make the criteria
too conservative by causing too many ships' loading conditions to be identified as possibly
vulnerable to this stability failure mode.
5.26 It was also noted by the Sub-Committee that the Group considered the heeling
lever RPL3 in the CR2 criterion of the level 2 vulnerability criterion (SDC 2/WP.4, annex 1) as
another possible source of inconsistency. Most of the sample ship calculations in which an
inconsistency between levels 1 and 2 was identified, cited the CR2 criterion as the limiting
factor. For this reason, the CR2 criterion may be considered as a possible overestimation of
the heeling lever to be applied. In this regard, the Group recalled that the basis for the formulation
of the heeling lever RPL3 can be found in documents SLF 55/3/14 and SLF 55/INF.15
(annex 12).
5.27 In view of the above, the Sub-Committee noted the Group's opinion that further
studies were needed, with a view to validating a suitable solution to resolve the inconsistency.
The dead ship condition stability failure mode
5.28 The Sub-Committee noted that annex 1 to document SDC 3/WP.5 was used as
a basis for consideration of the draft amendments to the 2008 IS Code with regard to
vulnerability criteria of levels 1 and 2 for the dead ship condition stability failure mode.
5.29 The Sub-Committee also noted that the Group considered in detail the issues
regarding inconsistencies deriving from the use of different mathematical models in levels 1
and 2 vulnerability criteria, and discussed the inconsistency issues regarding the use of
the second generation intact stability criteria versus the use of the mandatory weather criterion
(regulation 2.3 of part A of the 2008 IS Code).
5.30 With regard to the Group's discussion on the consistency between the mandatory
weather criterion and vulnerability criteria to stability failure in dead ship condition, as contained
in annex 15 to document SDC 4/INF.4/Add.2, the Sub-Committee noted the following issues
that might be associated with possible inconsistencies:
.1 method for calculation of the effective wave slope coefficient;
.2 use of a relative versus absolute response amplitude operator in the calculation

of the spectrum of the roll angle;
.3 use of a different mathematical model of stability failure in the level 2

vulnerability criterion from that used in both the level 1 and the weather
criterion; and
.4 use of a deterministic criterion in the level 1 and in the weather criterion,

whereas the level 2 vulnerability criteria use a probabilistic criterion.

SDC 4/16
Page 22
5.31 It was also noted by the Sub-Committee that:
.1 to facilitate assessment of the dead ship condition vulnerability criteria of

level 2 and the standard to be used therein, a procedure for performing such
assessments should be provided;
.2 the dead ship problem should be further investigated by using a direct

stability assessment allowing sway-roll coupling and more accurate roll
damping prediction methods; and
.3 the priority for the dead ship condition failure mode should be the direct
stability assessment, and the levels 1 and 2 vulnerability criteria should be
developed after that, in a way that would be consistent with the direct stability
assessment.
Revised plan of action for matters related to intact stability
5.32 The Sub-Committee noted that the Group, taking into account the progress made
during this session, had revised the plan of action for intact stability work (SDC 3/WP.5,
annex 8), identifying the priorities, time frames and objectives for the work to be accomplished.
The revised plan of action for the matters related to intact stability is set out in annex 2 to
document SDC 4/WP.4.
5.33 Following the above discussions, the Sub-Committee:
.1 noted the significant progress made by the Group on the development of the
draft Guidelines for direct stability assessment procedures (SDC 4/WP.4,
annex 1);
.2 noted the Group's deliberations on general requirements of the draft

Guidelines;
.3 invited Member States and international organizations to submit proposals

regarding the application of operational limitations and/or operational
guidance within the framework for the second generation intact stability
criteria for consideration at SDC 5;
.4 noted the Group's discussion on the draft amendments to part B of

the 2008 IS Code regarding the draft vulnerability criteria (levels 1 and 2) for
the pure loss of stability failure mode and dead ship condition failure mode;
and
.5 approved the revised plan of action for matters related to intact stability
(SDC 4/WP.4, annex 2).

SDC 4/16
Page 23
Re-establishment of the IS Correspondence Group
intersessionally, the Sub-Committee re-established the IS Correspondence Group, under
the coordination of Japan,* and instructed it, based on the comments made and decisions taken
at this session, taking into account relevant documents from this and previous sessions, to:
.1 further develop the draft Guidelines for the specification of direct stability
assessment, based on annex 1 to document SDC 4/WP.4, and, in particular,
to:
.1 further develop procedures and methodologies to determine

the stability limit curves, with special emphasis on the dead ship
condition failure mode;
.2 collect information regarding the standard for direct stability

assessment (SDSA), possibly based on direct calculation, existing
FSA studies and other data;
.3 further consider exceedance criteria, including heel angle and

lateral acceleration;
.4 further develop the provisions for approval procedures;
.5 further develop the quantitative standards for validation, by

collecting comparisons of model tests and simulations;
.6 further consider selection and treatment of the loading conditions for

the direct stability assessment;
.7 further develop the design scenarios, including sea states and wave
directions for all failure modes;
.8 collect application examples of direct assessment and extrapolation

methods, including the comparison of results with levels 1 and 2;
.9 develop a list of sample situations for qualitative validations;
.10 develop a list of benchmarks available for quantitative validations;

and
.11 prepare detailed descriptions of direct counting procedures and

extrapolation procedures;
*
Coordinator:
Dr. Eng. Naoya Umeda
Professor
Department of Naval Architecture
and Ocean Engineering
Osaka University
2-1 Yamadaoka, Suita
Osaka 565-0871, JAPAN
Tel: + 81 6 6879 7587
Fax: + 81 6 6879 7594
Email: umeda@naoe.eng.osaka-u.ac.jp

SDC 4/16
Page 24
.2 further develop the draft amendments to the 2008 IS Code regarding the draft
vulnerability criteria (levels 1 and 2) for each of the five stability failure modes,
based on documents SDC 2/WP.4 (annexes 1 to 3), SDC 3/WP.5 (annexes 1
and 2) and SDC 4/5/1/Add.6, with a view to resolving the inconsistencies
between levels 1 and 2, in particular, with regard to the dead ship condition
stability failure mode, taking into account documents SDC 4/5/7
and SDC 4/INF.4, consider in detail the consistency and integrity issues
deriving from the use of different mathematical models in vulnerability
levels 1 and 2 and direct assessment criteria, and decide if more studies are
needed, how to perform such studies, and when the issues should be
resolved;
.3 further develop the draft explanatory notes for all five stability failure modes,
based on the annexes to addenda 1 to 5 of document SDC 4/5/1 and
the annex to document SDC 4/5/6, taking into account the need to have
a direct link between the draft amendments and the explanatory notes;
.4 further develop the draft Guidelines for the preparation and approval
of operational limitations and operational guidance, based on
documents SDC 3/6/7, SDC 3/INF.10 (annex 21), SDC 3/INF.15, SDC 4/5
and SDC 4/5/9; and
6 AMENDMENTS TO SOLAS AND THE FSS CODE TO MAKE EVACUATION

ANALYSIS MANDATORY FOR NEW PASSENGER SHIPS AND REVIEW OF
THE RECOMMENDATION ON EVACUATION ANALYSIS FOR NEW AND
EXISTING PASSENGER SHIPS
General
6.1 The Sub-Committee recalled that SDC 3, having endorsed the recommendation to
maintain this output on the provisional agenda for SDC 4 for consideration of draft amendments
to SOLAS regulation II-2/13 and chapter 13 of the FSS Code with regard to open decks, had
requested the Committee for an extension of the target completion year for this output to 2017
and invited Member States and international organizations to submit specific proposals on
matters related to open decks for consideration at this session.
6.2 In connection with the above, the Sub-Committee noted that MSC 96 had agreed to
extend the target completion year for this output to 2017.
6.3 Having noted that no documents related to this output had been submitted for
consideration at this session, the Sub-Committee considered whether any further actions were
needed to be taken to complete the output.
6.4 Following discussion, the Sub-Committee agreed that no further action needed to be
taken on this matter and invited the Committee to endorse this decision.
Completion of the work on the output
6.5 The Committee was invited to note that the work on this output had been completed.

SDC 4/16
Page 25
7 REVISION OF SECTION 3 OF THE GUIDELINES FOR DAMAGE CONTROL

PLANS AND INFORMATION TO THE MASTER (MSC.1/CIRC.1245) FOR
PASSENGER SHIPS
General
7.1 The Sub-Committee recalled that SDC 3, having received no document for
consideration under this output, had recalled that document MSC 93/6/12 (CLIA), presenting
a tangible output from the Cruise Ship Safety Forum relating to proposed enhancements to
the damage control plan based on experience of the global cruise industry and use on board
during damage response drills, provided a strong basis for further consideration of this output,
and had invited Member States and international organizations to submit specific proposals on
the matter for consideration at this session.
7.2 Having considered document SDC 4/7 (China), comparing symbols that are used in
damage and fire control plans for passenger ships, and proposing that the graphical symbols
for shipboard fire control plans, which were adopted by resolution A.952(23) on Graphical
symbols for shipboard fire control plans, should be used for the same fittings and equipment
in damage control plans, for ease of identification and consistent operation on board,
the Sub-Committee agreed to instruct the SDS Working Group, established under item 3
(Amendments to SOLAS regulations II-1/6 and II-1/8-1), to further consider the matter and
advise the Sub-Committee on how best to proceed.
Instructions to the SDS Working Group
7.3 The Sub-Committee instructed the SDS Working Group, established under agenda
item 3 (see paragraph 3.15), taking into account the comments made and decisions taken in
plenary, to consider the proposals in documents MSC 93/6/12 and SDC 4/7, and advise
the Sub-Committee on how best to proceed.
7.4 Having considered the part of the report of the SDS Working Group (SDC 4/WP.3)
to 7.9 below.
7.5 The Sub-Committee recalled that MSC 93, having considered the enhancements to
the damage control plans for passenger ships in relation to section 3 of the Guidelines for
damage control plans and information to the master (MSC.1/Circ.1245), as proposed in
document MSC 93/6/12, had agreed to the following:
.1 the scope of this work should not be extended to ships other than passenger
ships; and
.2 the scope was for new passenger ships and for those existing passenger
ships that would need to update the damage control plan following significant
alterations to the ship.

SDC 4/16
Page 26
7.6 In this context, the Sub-Committee noted that the Group, having discussed whether
the new provisions of MSC.1/Circ.1245 should be dealt with by a complete revision of
the Guidelines or by means of amendments to the Guidelines, was of the view that the approval
of a complete revision of the existing Guidelines might have a number of implications, taking
into account that the referred Guidelines are applicable to both cargo and passenger ships,
and that this work would be out of the scope of this output. Consequently, the Sub-Committee
noted that the Group had agreed to develop draft amendments to MSC.1/Circ.1245, based on
the proposals contained in documents MSC 93/6/12 and SDC 4/7.
7.7 Having recalled that MSC 97 had approved the Shipboard escape route signs and
emergency equipment location markings (MSC.1/Circ.1553), the Sub-Committee noted that
the Group had decided that, for the time being, a reference to Graphical symbols for shipboard
fire control plans (resolution A.952(23)) for fittings and/or equipment which are common in both
fire and damage control plans, in order to facilitate the shipboard operation, was acceptable.
7.8 Following the discussion, the Sub-Committee agreed to the draft amendments to
section 3 of the Guidelines for damage control plans and information to the master
(MSC.1/Circ.1245) for passenger ships and the associated draft MSC circular, as set out in
annex 3, with a view to their approval at MSC 98.
Completion of the work on the output
7.9 The Committee was invited to note that the work on this output had been completed.
8 MANDATORY INSTRUMENT AND/OR PROVISIONS ADDRESSING SAFETY

STANDARDS FOR THE CARRIAGE OF MORE THAN 12 INDUSTRIAL
PERSONNEL ON BOARD VESSELS ENGAGED ON INTERNATIONAL VOYAGES
General
8.1 The Sub-Committee recalled that SDC 3 had agreed that the development of safety
standards for the carriage of more than 12 industrial personnel on board vessels engaged on
international voyages would not affect MODUs.
8.2 The Sub-Committee noted that MSC 96, having endorsed the outlines of the draft
new chapter [XV] of SOLAS and the draft new code, addressing the carriage of more
than 12 industrial personnel on board vessels engaged on international voyages
(MSC 96/WP.7, annexes 2 and 3), had instructed the Sub-Committee to use these outlines as
a basis for the further development of the draft new chapter [XV] of SOLAS and the draft new
code, taking into consideration the impact on other IMO instruments.
8.3 It was also noted by the Sub-Committee that MSC 96, having agreed to delete
output 5.2.1.19 on "Classification of offshore industry vessels and a review of the need for
a non-mandatory code for offshore construction support vessels" from the biennial agenda of
the SDC Sub-Committee and provisional agenda for this session, had noted that the ongoing
work under the aforementioned output would be considered under this output.
8.4 The Sub-Committee further noted that MSC 97, having adopted resolution MSC.418(97)
on Interim recommendations on the safe carriage of more than 12 industrial personnel
on board vessels engaged on international voyages, had endorsed the view that the proposed
definitions of industrial personnel and offshore industrial activities should be a basis for
the development of the mandatory instrument and had approved the updated roadmap
(MSC 97/WP.7, annex 2) to be followed by the Sub-Committee, when developing the draft new
chapter [XV] of SOLAS and the draft new code.

SDC 4/16
Page 27
8.5 The Sub-Committee also noted that MSC 97 had agreed that this output should be
considered by the Sub-Committee on a regular basis, taking into account that no slots were
available for establishing a Working Group on Carriage of Industrial Personnel at SDC 4 and
that there was no justification for treating this output as a special case, with a view to
establishing an experts' group.
.1 SDC 4/8 (Germany), providing the draft text of a new mandatory code
addressing the carriage of more than 12 industrial personnel on board
vessels engaged on international voyages and proposing to use the provided
text as a basis for the technical discussion; and
.2 SDC 4/8/1 (United States), supporting the development of a new mandatory

code, based on the draft text proposed in document SDC 4/8 and
recommending elements for inclusion into the draft terms of reference for
a Correspondence Group on Carriage of more than 12 Industrial Personnel
on board Vessels engaged on International Voyages, if established.
views expressed:
.1 a matrix clarifying the regulatory framework of new SOLAS chapter [XV] and
the new code should be developed, taking into account the existing
requirements of SOLAS and the 2000 HSC, 2008 SPS and OSV Codes;
.2 it may not be possible to selectively use the requirements of

the 2000 HSC Code, as this Code has a context relevant to high-speed craft
and is appropriate for those vessels only. In this context, paragraph 1.2.1.1
of the 2000 HSC Code, stating that "the Code will be applied in its entirety",
should be noted;
.3 a relaxation in safety standards should not be permitted if industrial

personnel are to be accommodated on these vessels as crew;
.4 application of the requirements of part C of the 2000 HSC Code to vessels

carrying up to 60 industrial personnel sets an inappropriate threshold and
the existing threshold of 36 passengers in SOLAS chapter II-2 should be
applied instead;
.5 the application of the new code should be limited to cargo ships

of 500 gross tonnage and above;
.6 offshore activities should not be overregulated by the new code, i.e. vessels
not engaged on international voyages should be regulated by national law;
.7 the development of the OSV Chemical Code (by the PPR Sub-Committee)
should be taken into account, when considering the carriage of various
amounts and types of dangerous goods; and
.8 aspects related to training should be carefully considered and medical

standards applicable to industrial personnel should be defined.

SDC 4/16
Page 28
Establishment of a correspondence group
8.8 In order to progress the work on this output intersessionally, the Sub-Committee
established the Correspondence Group on Carriage of more than 12 Industrial Personnel
on board Vessels engaged on International Voyages, under the coordination of Norway, and
instructed it, taking into account documents MSC 96/WP.7, MSC 97/WP.7, MSC 97/22,
SDC 4/8 and SDC 4/8/1, and the comments made at this session, to:
.1 develop a matrix that identifies the relevant aspects of the existing IMO
regulatory framework, with regard to definitions and application, in order to
ensure that the new SOLAS chapter [XV] and the new code are consistent
with, and avoid unnecessary duplication of, the existing IMO instruments;
.2 develop the draft new SOLAS chapter [XV];
.3 consider the format and organization of the draft new code, providing
explanation on the Group's decision;
.4 develop the introduction and preamble for the draft new code, including also
a possible promotion of a consistent level of safety in non-mandatory
applications;
.5 consider the impact that the service of the vessel may have on the total
number of industrial personnel carried;
.6 develop the draft new code, taking into account the matrix developed under
subparagraph .1; and
9 AMENDMENTS TO THE 2011 ESP CODE
General
9.1 The Sub-Committee noted that MSC 96, having recalled that the 2011 ESP Code is
updated regularly in order for the Code to be aligned with IACS Unified Requirement (UR) Z10,
had decided that the four-year cycle for the entry into force of amendments to the 1974 SOLAS
Convention and related mandatory instruments should not be adhered to in the case of
the 2011 ESP Code, and specifically that the entry-into-force date of draft amendments to
the 2011 ESP Code should be set to the earliest allowable date (i.e. 18 months following
adoption by a two-thirds majority of the SOLAS Contracting Governments present and voting in
the expanded Maritime Safety Committee), and, consequently, had agreed that
the amendments to the 2011 ESP Code, adopted at MSC 96 by resolution MSC.405(96), should
be deemed to have been accepted on 1 July 2017 and enter into force on 1 January 2018.

Coordinator:
Mrs. Turid Stemre
Senior Adviser
International environment, safety and security
P.O. Box 2222
N-5509 Haugesund, Norway
Tel: +47 52 74 51 51
Email: mailto:Turid.Stemre@sjofartsdir.no

SDC 4/16
Page 29
9.2 It was also noted by the Sub-Committee that MSC 97 had adopted further
amendments to the 2011 ESP Code, that were developed by SDC 3 and subsequently
approved by MSC 96, unanimously by resolution MSC.412(97) and had determined that
the adopted amendments should be deemed to have been accepted on 1 January 2018 and
enter into force on 1 July 2018.
.1 SDC 4/9 (IACS and Secretariat), highlighting the need to prepare

a consolidated text of the ESP Code, with a view to taking on board all
amendments adopted by the Maritime Safety Committee, aligning the Code
with the most updated version of IACS Unified Requirement (UR) Z10 and
clearly identifying all mandatory requirements, and proposing a plan of
further actions; and
.2 SDC 4/9/1 (India), commenting on the proposal to prepare a consolidated text

of the ESP Code, provided in document SDC 4/9, identifying the areas that
need to be further clarified, such as an ambiguous definition of "complete
ballast tank" and the scope of survey required in the 2011 ESP Code, and
suggesting to include them in the scope of the further work.
general comments:
.1 the use of words "shall" and "should" within Codes, in general, needs to
be considered at the Committee level as this issue is not limited to
the 2011 ESP Code; and
.2 the proposal in document SDC 4/9/1 should be considered when reviewing

the 2011 ESP Code,
and agreed that the following interpretation of the term "complete ballast tank" should be
accepted for the purpose of developing a consolidated text of the ESP Code:
"Apart from the fore and aft peak tanks, the term "complete ballast tank" has
the following meaning:
.1 all ballast compartments (hopper tank, side tank and double-deck tank, if
separate from double-bottom tank) located on one side, i.e. portside or
starboard side, and additionally double-bottom tank on portside plus
starboard side, when the longitudinal central girder is not watertight and,
therefore, the double-bottom tank is a unique compartment from portside to
starboard side; or
.2 all ballast compartments (double-bottom tank, hopper tank, side tank and
double-deck tank) located on one side, i.e. portside or starboard side, when
the longitudinal central girder is watertight and, therefore, the portside
double-bottom tank separate from the starboard-side double-bottom tank."
Plan of further actions
9.5 Following the consideration of the plan of further actions set out in paragraph 9 of
document SDC 4/9, the Sub-Committee endorsed the actions in paragraphs 9.1 to 9.5, and
authorized IACS and the Secretariat to analyse the 2011 ESP Code and provide the report on
the progress made for consideration at the next session.

SDC 4/16
Page 30
9.6 With regard to the proposal that Member States and international organizations may
be invited to apply IACS UR Z10 until the consolidated ESP Code enters into force, as set out
in paragraph 9.6 of document SDC 4/9, the Sub-Committee agreed that Member States and
international organizations should note the relevance of IACS UR Z10, when carrying out
hull surveys of bulk carriers and oil tankers. In this context, the Sub-Committee noted
that IACS members will uniformly implement IACS UR Z10, unless they are provided with
written instructions to apply a different standard by an Administration on whose behalf they are
authorized to act as a recognized organization.
10 UNIFIED INTERPRETATION TO PROVISIONS OF IMO SAFETY, SECURITY, AND

ENVIRONMENT-RELATED CONVENTIONS
General
10.1 The Sub-Committee recalled that this was a continuous item on the biennial agenda
and that the Assembly, at its twenty-eighth session, had expanded the output to include all
proposed unified interpretations to provisions of IMO safety, security, and environment-related
Conventions, so that any newly developed or updated draft unified interpretation could be
submitted for the consideration of the Sub-Committee, with a view to developing an appropriate
IMO interpretation.
10.2 The Sub-Committee agreed firstly to consider document SDC 4/10/1 (IACS), with
a view to finalizing the draft revised Explanatory Notes to SOLAS chapter II-1 subdivision and
damage stability regulations (see also section 3), and then to deal with the remaining
documents.
Drainage of enclosed spaces situated on the bulkhead deck and special requirements
for vehicle ferries, ro-ro ships and other ships of similar type
10.3 Having considered document SDC 4/10/1, referring to the outcome of the consideration
that was given to IACS Unified Interpretations (UIs) SC81 and SC220 by the experts on
subdivision and damage stability at SLF 54 and SDC 2, and proposing to endorse these UIs
and prepare an associated draft MSC circular, the Sub-Committee endorsed the text of
the draft unified interpretations of SOLAS regulations II-1/17-1, II-1/20-2 and II-1/35-1, and
agreed to the draft MSC circular on Unified interpretations of SOLAS chapter II-1, as set out in
annex 4, for submission to MSC 98 with a view to approval, in conjunction with the approval of
the draft revised Explanatory Notes to SOLAS chapter II-1 subdivision and damage stability
regulations.
Draft amendments to MSC/Circ.686
10.4 The Sub-Committee recalled that SDC 3, having considered document SDC 3/WP.3
providing consideration of the Guidelines on the means of access to structures for inspection
and maintenance of oil tankers and bulk carriers (MSC/Circ.686), in the context of
the 2011 ESP Code, had noted that there were aspects of the Guidelines that had not been
incorporated into the 2011 ESP Code, and, throughout the text, there were some references
that needed to be updated, the relevance of SOLAS regulation II-1/3-6 and of the Technical
provisions for means of access for inspections (resolution MSC.133(76)) may also need to be
considered, and the Guidelines could still be considered as an independent instrument which
may or may not need a complete revision, and had invited interested Member States and
international organizations to further consider document SDC 3/WP.3, with a view to providing
an effective solution to this matter, which may not necessarily be a new output, and to submit
proposals to this session.

SDC 4/16
Page 31
10.5 In considering document SDC 4/10 (IACS), referring to the invitation of SDC 3 to
further consider document SDC 3/WP.3 and proposing updating the obsolete references
contained in MSC/Circ.686, the Sub-Committee noted the following comments:
.1 the words "existing ships" should be replaced with the words "ships
constructed before 1 October 1994" in paragraph 4 of the draft revised
circular and in paragraph 3 of the draft revised Guidelines; and
.2 the words "parts of the" should be added after the word "relevant" in
paragraph 1 of the draft revised Guidelines.
10.6 Following discussion, the Sub-Committee endorsed the proposal to update

the references to the superseded instruments contained in the Guidelines, in order to provide
alignment with the relevant regulatory references, and agreed to the draft revised Guidelines on
the means of access to structures for inspection and maintenance of oil tankers and bulk
carriers, and the associated draft MSC circular (i.e. MSC/Circ.686/Rev.1), as set out in annex 5,
for submission to MSC 98 with a view to approval.
Unified interpretations of SOLAS chapters II-1 and XII, of the Technical provisions for
means of access for inspections (resolution MSC.158(78)) and of the Performance
standards for water level detectors on bulk carriers and single hold cargo ships other
than bulk carriers (resolution MSC.188(79))
10.7 The Sub-Committee noted that MSC 97 had requested the Sub-Committee to
consider the consolidated draft MSC circular containing provisions of MSC.1/Circ.1464/Rev.1
and its Corr.1, as amended by MSC.1/Circ.1507 and MSC.1.Circ.1545, as set out in the annex
to document MSC 97/21/2 (Secretariat), and advise the Committee accordingly.
10.8 Having noted that document SDC 4/10/2 (IACS) was also related to this issue,
the Sub-Committee agreed, firstly, to decide on how the consolidated draft MSC circular should
be finalized, i.e. how the general points identified by the Secretariat in document MSC 97/21/2
should be addressed, and, secondly, to consider the concrete IACS proposals in
document SDC 4/10/2, which might lead to some further refinement of the consolidated
draft MSC circular.
Consolidated draft MSC circular containing provisions of MSC.1/Circ.1464/Rev.1 and

its Corr.1, as amended by MSC.1/Circ.1507 and MSC.1.Circ.1545
10.9 The Sub-Committee, having considered document MSC 97/21/2, noted the following
views expressed on this matter:
.1 the proposed draft consolidated MSC circular (MSC 97/21/2, annex) should
be used as the base document;
.2 the proposals in document SDC 4/10/2 (IACS) should be incorporated in

the draft consolidated MSC circular;
.3 the draft consolidated MSC circular should apply to new ships only and,
therefore, in paragraph 5 of the draft consolidated MSC circular, the date
"1 January 2009" should be replaced with "date of approval";
.4 paragraph 6 of the draft consolidated MSC circular should be deleted; and

SDC 4/16
Page 32
.5 for existing ships, the Secretariat should be requested to issue a corrigendum

to MSC.1/Circ.1464/Rev.1, with a view to correcting references to SOLAS
regulations and any out-of-date elements,
and endorsed the draft MSC circular on Unified interpretations of SOLAS chapters II-1 and XII,
of the Technical provisions for means of access for inspections (resolution MSC.158(78))
and of the Performance standards for water level detectors on bulk carriers and single
hold cargo ships other than bulk carriers (resolution MSC.188(79)), as set out in annex 6
(see also paragraph 10.12), and the draft corrigendum to MSC.1/Circ.1464/Rev.1
(i.e. MSC/Circ.1464/Rev.1/Corr.2), as set out in annex 7, for submission to MSC 98 with a view
to approval.
Application of SOLAS regulation II-1/3-6, as amended, and the revised Technical

provisions for means of access for inspections
10.10 The Sub-Committee, having considered document SDC 4/10/2, providing information
on the latest amendments to IACS Unified Interpretations SC191 relating to the application
of SOLAS regulation II-1/3-6, as amended, and the revised Technical provisions for means of
access for inspections (resolution MSC.158(78)), and proposing that the above amendments
should be taken into account by the Sub-Committee when preparing a consolidated
draft MSC circular containing the provisions of MSC.1/Circ.1464/Rev.1 and Corr.1, as amended
by MSC.1/Circ.1507 and MSC.1/Circ.1545, noted:
.1 that IACS members will uniformly implement the amended version of IACS
UI SC191 (Rev.7, Corr.1), including the clarification to the interpretations
relating to section 3.5 of the annex to resolution MSC.158(78), on ships
contracted for construction on or after 1 July 2016, unless they are provided
with written instructions to apply a different interpretation by an
Administration on whose behalf they are authorized to act as a recognized
organization; and
.2 a proposal that each section of the vertical ladders should be fitted with
a ladder cage of minimum 600 mm x 600 mm clearance from 2.5 m above
its landing platform,
and agreed to take into account the proposed amendments to IACS UI SC191, when finalizing
the consolidated draft MSC circular containing provisions of MSC.1/Circ.1464/Rev.1 and
its Corr.1, as amended by MSC.1/Circ.1507 and MSC.1/Circ.1545.
10.11 With regard to the proposal in paragraph 10.10.2 above, the Sub-Committee agreed
that the proposal went beyond a unified interpretation and, therefore, decided not to take any
further action on the issue.
10.12 Following discussion, the Sub-Committee endorsed the draft MSC circular on Unified
interpretations of SOLAS chapters II-1 and XII, of the Technical provisions for means of access
for inspections (resolution MSC.158(78)) and of the Performance standards for water level
detectors on bulk carriers and single hold cargo ships other than bulk carriers
(resolution MSC.188(79)), as set out in annex 6 (see also paragraph 10.9), for submission
to MSC 98 with a view to approval.

SDC 4/16
Page 33
Determination of the deadweight to be stated on certificates
10.13 In considering document SDC 4/10/3 (IACS), referring to the outcome of SDC 3
regarding the application of deadweight-dependent regulations if a deadweight at a trimmed
waterline exceeds the even-keel deadweight, and providing draft IACS unified interpretations
on the determination of deadweight of a ship for inclusion on ships' certificates, for both
the SOLAS and MARPOL Conventions, the Sub-Committee noted the following views
expressed:
.1 a clarification is needed on how to deal with the other MARPOL and SOLAS
regulations (e.g. parameters and reduction factors for the EEDI), if
a deadweight at a trimmed waterline exceeds the even-keel deadweight;
.2 it is not acceptable for a loading manual and stability information to include

a loading condition at a trimmed waterline with a deadweight that exceeds
the even-keel deadweight corresponding to the load line mark in use; and
.3 the load line marks shall not be submerged and the even-keel hydrostatics
shall be used.
10.14 Following a lengthy discussion, the Sub-Committee endorsed the draft unified
interpretations of SOLAS regulations II-1/2.20 and II-2/3.21, and regulation 1.23
of MARPOL Annex I, regarding the use of even-keel hydrostatics for determination of
the regulatory deadweight to be entered on relevant statutory certificates, and agreed to
the draft MSC circular on Unified interpretation of SOLAS regulations II-1/2.20 and II-2/3.21,
as set out in annex 8, and the draft MEPC circular on Unified interpretation of regulation 1.23
of MARPOL Annex I, as set out in annex 9, for submission to MSC 98 and MEPC 71,
respectively, with a view to approval.
10.15 With regard to the acceptance for a loading manual and stability information to include
a loading condition at a trimmed waterline with a corresponding deadweight that exceeds
the even-keel deadweight corresponding to the load line mark in use, the Sub-Committee could
not reach a conclusion on this issue and invited interested Member States to bring this issue
to the attention of the Maritime Safety Committee in accordance with the provisions of
the document on Organization and method of work of the Maritime Safety Committee and
the Marine Environment Committee and their subsidiary bodies (MSC-MEPC.1/Circ.5).
11 REVISED SOLAS REGULATION II-1/3-8 AND ASSOCIATED GUIDELINES

(MSC.1/CIRC.1175) AND NEW GUIDELINES FOR SAFE MOORING OPERATIONS
FOR ALL SHIPS
General
11.1 The Sub-Committee recalled that SDC 3 had agreed that, when considering the draft
Guidelines on the design of safe mooring arrangements (SDC 3/15, annex 2), references made
to "towing" should be taken to mean "harbour tug operations related to mooring", and that this
was within the scope of this output, and had established a Correspondence Group on Safe
Mooring Operations, with terms of reference set out in paragraph 15.8 of document SDC 3/21.
11.2 The Sub-Committee noted that MSC 97, having considered document MSC 97/19/2
(IACS), had instructed the Sub-Committee to consider the recent updates to IACS Unified
Requirement (UR) A2 and the non-fishing vessel mooring-related elements of IACS
Recommendation 10, when reviewing MSC/Circ.1175.

SDC 4/16
Page 34
Report of the Correspondence Group and related documents
11.3 The Sub-Committee had for its consideration the following documents:
.1 SDC 4/11 (Denmark and Japan), providing the report of the Correspondence
Group on Safe Mooring Operations regarding the development of draft
revised SOLAS regulation II-1/3-8 and the associated draft Guidelines on
the design of safe mooring arrangements, and consideration of the need
for IMO guidance on selection, identification, use, inspection and/or
maintenance of mooring lines;
.2 SDC 4/11/1 (Japan), referring to the report of the Correspondence Group on

Safe Mooring Operations and identifying the issues that need to be further
considered under this output;
.3 SDC 4/11/2 (ICS), commenting on the development of the draft new

Guidelines on design of safe mooring arrangements associated with the draft
revised SOLAS regulation II-1/3-8 and proposing a modification to the draft
SOLAS regulation II-1/3-8.2 prepared by the Correspondence Group; and
.4 SDC 4/11/3 (OCIMF), providing comments on the draft Guidelines on

the design of safe mooring arrangements prepared by the Correspondence
Group on Safe Mooring Operations.
and comments expressed:
.1 the use of such terms as "berth configurations", "dock workers", "efficiency",

"healthy", "independent competent person" and "sufficient" should be further
considered, e.g. the term "healthy" has a wide meaning and should be
replaced with the term "occupational health" and the term "dock workers"
should be replaced with the term "mooring personnel" specified in
the Guidelines on minimum training and education for mooring personnel
(FAL.6/Circ.11/Rev.1);
.2 definitions of terms not used in the draft Guidelines should be deleted;
.3 the MSC GBS Working Group should be requested to provide its advice
regarding the goals and functional objectives set out in sections 3 and 4 of
the draft Guidelines, respectively, to the Correspondence Group, if
re-established;
.4 type and size of mooring lines should be taken into account as well as
the limited space on mooring decks of small ships;
.5 the requirement for ship specific risk assessment should be deleted and
section 6 (Risk assessment) of the draft Guidelines should focus on
identifying preferred techniques for different system components;
.6 section 7 (Acceptable mooring arrangements) of, and the appendix

(An example of a risk assessment on roller guides) to, the draft Guidelines
should be deleted;

SDC 4/16
Page 35
.7 any guidelines related to operational aspects should be separated from the draft
Guidelines on the design of safe mooring arrangements; and
.8 any improvement of mooring equipment on board ships cannot be

considered without taking into account port facilities, i.e. compliance with
relevant FAL instruments should be ensured.
11.5 In this context, the observer from IFSMA made a statement regarding a possible
conflict between paragraphs 4.2.3 and 5.1.6 of the draft Guidelines. The full text of this
statement is reproduced in annex 14.
11.6 The Sub-Committee noted with appreciation the information provided by ICHCA in
document SDC 4/INF.3 on mooring rope incidents to support the amendments to SOLAS,
proposed by the Correspondence Group on Safe Mooring Operations.
11.7 In considering the actions requested in paragraph 40 of the report of the Correspondence
Group (SDC 4/11), the Sub-Committee approved the report, in general, and took the following
actions:
.1 noted the progress made on the development of the draft revised SOLAS
regulation II-1/3-8;
.2 endorsed the Group's view that further discussion is necessary in order to

finalize the draft Guidelines on the design of safe mooring arrangements;
.3 agreed that the draft Guidelines on the design of safe mooring arrangements
should only give guidance on how to design the mooring arrangement;
.4 agreed that the definitions reproduced in square brackets should be further

considered, when finalizing the draft Guidelines on the design of safe
mooring arrangements;
.5 agreed that the term "healthy" should be replaced with the term "occupational
health" and the definitions specified in the Guidelines on minimum training
and education for mooring personnel (FAL.6/Circ.11/Rev.1) should be used,
e.g. the term "dock workers" should be replaced with the term "mooring
personnel";
.6 agreed that efficiency should not be a part of the scope of the Guidelines;
.7 agreed that the requirement for ship specific risk assessment should be
deleted and section 6 (Risk assessment) of the draft Guidelines should focus
on identifying preferred techniques for different system components;
.8 agreed that a correspondence group should be instructed to further consider

whether section 7 on acceptable mooring arrangements and the appendix
should be maintained within the Guidelines or not, when finalizing the draft
Guidelines on the design of safe mooring arrangements;
.9 agreed that relevant descriptions, such as selection, identification and use of

mooring lines, should be included in the guidelines on the selection,
identification and use of mooring lines;

SDC 4/16
Page 36
.10 with regard to the Group's view:
.1 agreed that generic guidelines on the inspection and/or maintenance

of mooring lines should be developed as part of the guidelines
related to operations, taking into account the possibility of
consequential amendments to other IMO instruments;
.2 having agreed that information on break accidents and best

practices of maintenance of mooring lines would be beneficial,
encouraged Member States to provide more detailed information
while reporting such incidents via GISIS; and
.3 agreed that an awareness campaign would be beneficial, however,

no special statements regarding such an awareness campaign
would be necessary; and
.11 decided to re-establish the Correspondence Group on Safe

Mooring Operations, with a view to finalizing the draft revised SOLAS
regulation II-1/3-8 and the draft Guidelines on the design of safe mooring
arrangements, and to developing guidelines on the selection, identification and
use of mooring lines as well as generic guidelines on inspection and/or
maintenance of mooring lines.
Consideration of the recent updates to IACS UR A2 and Recommendation 10
11.8 With regard to the instruction of MSC 97 to consider the recent updates to IACS UR A2
and the non-fishing vessel mooring-related elements of IACS Recommendation 10,
the Sub-Committee, having noted that the updated versions of IACS UR A2 and IACS
Recommendation 10 had not been enclosed to document MSC 97/19/2, agreed to instruct
the Correspondence Group on Safe Mooring Operations to take into account the updates
to IACS UR A2 and the non-fishing vessel mooring-related elements of IACS
Recommendation 10, when finalizing the draft Guidelines on the design of safe mooring
arrangements, and requested IACS to provide the Correspondence Group with the updated
versions of IACS UR A2 and IACS Recommendation 10.
Re-establishment of the Correspondence Group
intersessionally, the Sub-Committee re-established the Correspondence Group on Safe Mooring
Operations, under the coordination of Denmark and Japan,* and instructed it, taking into
account documents MSC 97/19/2, MSC 97/22 (paragraph 19.15), SDC 4/11, SDC 4/11/1,
SDC 4/11/2, SDC 4/11/3 and SDC 4/INF.3, and the comments made and decisions taken at
this session, to:
.1 further consider the draft revised SOLAS regulation II-1/3-8, based on

annex 1 to document SDC 4/11, regarding the design of arrangements and
selection of equipment for safe mooring;
*
Coordinators:
Mr. Steen Moller Nielsen Dr. Susumu Ota
Danish Maritime Authority Director, Center for International Cooperation
Denmark National Maritime Research Institute, Japan
Email: sn@dma.dk Email: ohta@nmri.go.jp

SDC 4/16
Page 37
.2 further consider the draft new Guidelines for safe mooring operations on all
ships, supporting the draft revised SOLAS regulation II-1/3-8, based on
annex 2 to document SDC 4/11, regarding the design of arrangements and
selection of equipment for safe mooring;
.3 review MSC.1/Circ.1175 and the draft new Guidelines in light of:
.1 recent updates to IACS Unified Requirement (UR) A2, and IACS

Recommendation 10; and
.2 ensuring that no duplications or unintended consequences of

application are included in the draft new Guidelines referred to in
subparagraph .2 above;
.4 consider the references in the draft revised SOLAS regulation II-1/3-8 to

the Guidelines as referred to in subparagraphs .2 and .3 above;
.5 develop separate guidelines on safe mooring operations, taking into account

the need for any additional guidance on selection, identification, inspection,
maintenance and use of mooring lines;
.6 in line with paragraph 3.2.1.3.10 of the Guidance on drafting of amendments

to the 1974 SOLAS Convention and related mandatory instruments
(MSC.1/Circ.1500), consider any consequential amendments to relevant
IMO instruments; and
12 GUIDELINES FOR USE OF FIBRE REINFORCED PLASTIC (FRP) WITHIN SHIP

STRUCTURES
General
12.1 The Sub-Committee recalled that SDC 3 had noted that the Interim guidelines for use
of Fibre Reinforced Plastic (FRP) elements within ship structures should be finalized as soon
as possible; however, it had also been noted that there were still issues to be further
considered, as outlined in paragraph 31 of document SDC 3/WP.6.
12.2 The Sub-Committee also recalled that SDC 3 had established the Correspondence
Group on Development of Interim guidelines for use of Fibre Reinforced Plastic (FRP) elements
within ship structures, with terms of reference set out in paragraph 17.9 of document SDC 3/21.
Report of the Correspondence Group and related documents
12.3 The Sub-Committee had for its consideration the following documents:
.1 SDC 4/12 (Sweden), providing the report of the Correspondence Group on

Development of Interim guidelines for use of Fibre Reinforced Plastic (FRP)
elements within ship structures, including the updated draft Interim
guidelines and the associated draft MSC circular; and

SDC 4/16
Page 38
.2 SDC 4/12/1 (Germany), providing additional comments and proposal to

the report of the Correspondence Group on Development of Interim
guidelines for use of Fibre Reinforced Plastic (FRP) elements within ship
structures and, in particular, to the term "element", the application to load
bearing structures, and specific requirements for element categories.
and general comments expressed on this matter:
.1 taking into account that these guidelines are titled Interim guidelines, it was
proposed to agree on a time frame for the validity of these Interim guidelines,
i.e. at some point they should be revisited based on experience gained, and
at that point it should be decided if they are still needed and, if so, whether
they might need to be amended based on experience gained. Until such time,
it is proposed to keep this output on the post-biennial agenda of
the Committee, so that the Interim guidelines can be revisited, in due course,
without the need for a justification for a new output;
.2 the meaning of the term "main deck" should be clarified and that in doing so
it may be possible to use defined terms such as "freeboard deck" or
"bulkhead deck";
.3 the draft FRP Guidelines have now reached a level of maturity that allows
for finalization at this session;
.4 the proposal to develop different hazard levels and related procedures may
be based on some European railway standards (SDC 4/12/1) and should
be considered as a starting point for future work, i.e. this idea could be
revisited when the Interim guidelines will be reviewed and eventually
amended in order to convert them to final Guidelines after sufficient
experience has been achieved through the use of the interim version;
.5 the definition and compliance to functional requirements should be kept

separate, i.e. FRP elements are parts of the ship structure that have to
prove their equivalence with traditional building materials by means of
alternative design, making use of the draft Interim guidelines, therefore
a method of compliance with the functional requirements should be
explained in the Guidelines, but this goal should not be introduced into
the definition;
.6 more work is required regarding the term "element", with a view to limiting
the application to non-load bearing structures; and
.7 the issues related to panels fitted in escape routes especially corridors and
stairs, may require a special consideration.
12.5 The Sub-Committee also noted with appreciation the information provided by Sweden
in document SDC 4/INF.2, with a view to facilitating the discussion on the amended draft
Interim guidelines and the draft associated MSC circular, to show the changes proposed
by the Correspondence Group to the draft Interim guidelines and the draft associated
MSC circular set out in annex 6 to document SDC 2/25.

SDC 4/16
Page 39
12.6 In considering the actions requested in paragraph 32 of the report of the Correspondence
Group (SDC 4/12), the Sub-Committee approved the report in general, agreed with
the proposal to keep the output on the post-biennial agenda (see also paragraph 13.10 and
annex 12) of the Committee and took the following actions:
.1 endorsed the statement regarding the need to consider the fire safety
objectives and functional requirements, as set out in paragraph 1.3 of
the draft Interim guidelines;
.2 noted the discussion on developing more specific procedures and detailed

examples in regard to the evaluation of fire safety risks for FRP elements;
.3 endorsed the new text with regard to the scope of the draft Interim guidelines,
as set out in paragraph 1.6 of the draft Interim guidelines;
.4 agreed that a Working Group on Fire Protection (FP) should be established and
instructed to finalize the draft Interim guidelines, including the text of
paragraph 1.2, based on the text set out in the annex to document SDC 4/12,
taking into account document SDC 4/12/1, and the comments in
paragraph 12.4 above;
.5 endorsed the Group's decision that non-combustible FRP composite structures

which comply with all prescriptive requirements are outside the scope of the draft
Interim guidelines, as set out in paragraph 1.1 of the draft Interim guidelines;
and
.6 noted the discussion regarding testing of fire integrity.
Establishment of the FP Working Group
established the FP Working Group and instructed it, taking into account the comments made
in paragraph 12.4 and decisions taken in paragraph 12.6, to finalize the draft Interim guidelines
for use of Fibre Reinforced Plastic (FRP) elements within ship structures and the associated
draft MSC circular, based on the annex to document SDC 4/12, taking into account
document SDC 4/12/1.
Report of the FP Working Group
12.8 Having considered the report of the FP Working Group (SDC 4/WP.5),
the Sub-Committee took action as outlined in paragraphs 12.9 to 12.16 below.
Definition of the term "element"
12.9 The Sub-Committee noted that the Group amended the definition of the term
"element" to read as follows:
"An element, for the purpose of these guidelines, is a structure which may be removed
without compromising the safety of the ship."
12.10 The Sub-Committee also noted that the Group inserted a new paragraph immediately
under the definition of the term "element", highlighting that safety-critical spaces (e.g. control
stations, evacuation stations and escape routes) should be given special consideration
(within the assessment) if the use of FRP elements was being considered.

SDC 4/16
Page 40
Categories of FRP elements
12.11 The Sub-Committee noted that the Group, having extensively discussed the proposal
regarding structures below and above the main deck, in conjunction with the categorization
of FRP elements, had agreed that the list of FRP element categories was intended to provide
examples of some of the possible FRP element categories that could be considered when
applying the Interim guidelines, rather than a complete and fixed enumeration of categories.
In this context, taking into account the difficulties in reaching a consensus with regard to
the first category (i.e. "structures"), the Group had further agreed to list two categories
(i.e. "integrated structures" and "components") rather than three in the penultimate paragraph
of chapter 1 of the draft Interim guidelines, separate from the definition of the term "element",
with the understanding that during a future review the list of categories could be refined and/or
expanded, based on experience gained from the use of the Interim guidelines.
Additional tests
12.12 With regard to the small-scale "Purser Furnace" method for FRP, the Sub-Committee
noted that Group had concluded that the test was not suitable for FRP.
Time frame for the review of the Interim guidelines
12.13 The Sub-Committee endorsed the Group's recommendation that four years were
a suitable period for Administrations to gather experience in the application of the Interim
guidelines for use of Fibre Reinforced Plastic (FRP) elements within ship structures: Fire safety
issues, with a view to reviewing them.
12.14 In this context, the Sub-Committee noted that the Group modified the draft MSC circular
to include a paragraph inviting Member States and international organizations to submit
information, observations, comments and recommendations based on the practical experience
gained through the application of the Interim guidelines to the Sub-Committee under
the agenda item "Any other business".
Finalization of the draft Interim guidelines
12.15 Following the discussion, the Sub-Committee endorsed the draft Interim guidelines for
use of Fibre Reinforced Plastic (FRP) elements within ship structures: Fire safety issues and
the associated draft MSC circular, as set out in annex 10, for submission to MSC 98 for
approval.
Transfer of the output to the post-biennial agenda of the Committee
12.16 In light of the decision that four years would be a suitable period for Administrations
to gather experience in the application of the Interim guidelines, with a view to reviewing
them, the Sub-Committee invited the Committee to maintain this output on its post-biennial
agenda.

SDC 4/16
Page 41
13 BIENNIAL STATUS REPORT AND PROVISIONAL AGENDA FOR SDC 5
Application of the Polar Code to non-SOLAS vessels
General
13.1 The Sub-Committee recalled that MSC 96, having noted the information provided in
support of the next phase of the work on the International Code for Ships Operating in Polar
Waters (Polar Code), had invited Member States and international organizations to submit
more information to MSC 97 to facilitate the consideration on the matter, taking into account
that a relevant output is already included in the 2018-2019 biennial agenda of the Committee.
13.2 It was also noted by the Sub-Committee that MSC 97, having considered
the information provided on this matter, had noted the Chair's view that the work related to
the second phase for non-SOLAS ships should not begin until experience in the application of
the Polar Code to SOLAS ships was gained.
Proposals for future work
13.3 The Sub-Committee had for its consideration the following documents related to this
issue:
.1 SDC 4/13 (FOEI, WWF and Pacific Environment), providing summary

information on 21 incidents involving non-SOLAS vessels from 10 flag States
and a preliminary assessment of relevance of the Polar Code chapters to
fishing vessels, pleasure yachts not engaged in trade (motorized and
non-motorized) and cargo ships under 500 gross tonnage, expressing
concern that the threat to human life and to the polar environment has not
yet been fully addressed, and proposing an agenda item be included in
the Sub-Committee's biennial agenda for the forthcoming biennium; and
.2 SDC 4/13/1 (New Zealand), containing the information regarding

the progression of the second phase of the Polar Code work, expressing
the opinion that prevention through strengthened training, construction,
design and equipment requirements is the best method to address
the well-known safety and environmental concerns regarding
non-SOLAS vessels operating in polar waters, and encouraging Member
States to place this issue on the provisional agenda of SDC 5.
13.4 In considering the above documents, the Sub-Committee noted the following:
.1 according to the agenda for the 2016-2017 biennium and the post-biennium
agenda of the Committee, the issues related to application of the Polar Code
to non-SOLAS vessels cannot be considered under the existing
output 5.2.1.15 on "Consequential work related to the new Code for ships
operating in polar waters" as this output is intended for finalization of the first
phase of the Polar Code work, which is currently on the provisional agendas
of the SSE and NCSR Sub-Committees;

SDC 4/16
Page 42
.2 while some delegations supported the proposal to commence the second

phase of the Polar Code work, a number of other delegations expressed
the view that it is premature to start the work at this stage, taking into account
the uncertainty on how to apply the provisions of the Polar Code, which had
been developed as an add-on to SOLAS and its related instruments and
other conventions, to non-SOLAS vessels and, in particular, to fishing vessels;
.3 with regard to fishing vessels, the ratification of the Cape Town Agreement
of 2012 on the Implementation of the Provisions of the Torremolinos Protocol
of 1993 relating to the Torremolinos International Convention for the Safety
of Fishing Vessels, 1977 (the Agreement), is necessary in order to provide
international standards for the safety of fishing vessels. In this connection,
pending pertinent decision of the Committee on the mandatory nature of
the second phase of the Polar Code, the Sub-Committee noted that
the Agreement would be the most appropriate instrument to be amended to
include safety measures for fishing vessels operating in polar waters; and
.4 any further discussion requires a policy decision on how this work should
be structured and, therefore, clear instructions should be provided by
the Committee regarding:
.1 when the development of the second phase of the Polar Code

should begin;
.2 the scope of application of the second phase of the Polar Code; and
.3 the recommendatory or mandatory status of the second phase of

the Polar Code.
13.5 Following an in-depth discussion, the Sub-Committee decided that no further action
could be taken on this matter, without receiving clear policy instructions from the Committee.
In this context, MSC 98 was invited to consider the discussion in paragraph 13.4 above, in
particular the need for clear direction, and take action as necessary.
13.6 In this context, the delegation of New Zealand made a statement regarding
the above Sub-Committee's decision. The full text of this statement is reproduced in annex 14.
Biennial status report, proposal for the 2018-2019 biennial agenda and provisional
agenda for SDC 5
General
13.7 The Sub-Committee noted that MSC 96 had agreed to delete the output on
"Passenger ship safety" from the High-level Action Plan, with the understanding that new
outputs could be proposed by Member States in the future, in accordance with the document
on Organization and method of work of the Maritime Safety Committee and the Marine
Environment Protection Committee and their subsidiary bodies (MSC-MEPC.1/Circ.5).
13.8 It was also noted by the Sub-Committee that MSC 96 had agreed to include in
the 2018-2019 biennial agenda of the Committee an output on "Review SOLAS chapter II-1,
parts B-2 to B-4, to ensure consistency with parts B and B-1 with regard to watertight integrity",
with three sessions needed to complete the item, assigning the Sub-Committee as
the coordinating organ.

SDC 4/16
Page 43
13.9 The Sub-Committee further noted that MSC 96 had agreed to maintain the output on
"Guidelines for wing-in-ground craft" in its post-biennial agenda, for inclusion in the provisional
agenda of SDC 5, with a view to finalization during the 2018-2019 biennium.
Biennial status report and proposed biennial agenda for the 2018-2019 biennium
13.10 Taking into account the progress made at the session, the Sub-Committee prepared
the biennial status report (SDC 4/WP.2, annex 1) and the proposed biennial agenda for
the 2018-2019 biennium (SDC 4/WP.2, annex 2), as set out in annexes 11 and 12,
respectively, for consideration by MSC 98.
13.11 The Sub-Committee, having reviewed the outputs on the Committee's post-biennial
agenda, that fall under the purview of the Sub-Committee (SDC 4/WP.2, annex 1),
invited MSC 98 to endorse:
.1 the replacement of the references to "SDC" as the associated organ for

output 9 and the coordinating organ for output 42 with "SSE"; and
.2 the addition of "MEPC" as a parent organ for output 32.
13.12 In connection to the above, the Sub-Committee noted that, to ensure an alignment of
the existing outputs with the new strategic directions agreed by C 117, the outputs currently
presented in the usual format in annex 12 will be further renumbered and reorganized for
the 2018-2019 biennium in due course (SDC 4/WP.2, paragraphs 4 to 10).
Proposed provisional agenda for SDC 5
13.13 Taking into account the progress made at the session, the Sub-Committee prepared
the proposed provisional agenda for SDC 5 (SDC 4/WP.2, annex 3), as set out in annex 13,
for consideration by MSC 98.
Correspondence groups established at the session
13.14 The Sub-Committee established correspondence groups on the following subjects,

due to report to SDC 5:
.1 subdivision and damage stability (see paragraphs 3.32 and 4.16);
.2 intact stability (see paragraph 5.34);
.3 carriage of more than 12 industrial personnel on board vessels engaged on

international voyages (see paragraph 8.8); and
.4 safe mooring operations (see paragraph 11.9).
Arrangements for the next session
13.15 The Sub-Committee agreed to establish at its next session working and drafting
groups on the following subjects:
.1 subdivision and damage stability (agenda items 3 and 4);

Refer to annex 13.

SDC 4/16
Page 44
.2 intact stability (agenda item 6);
.3 carriage of more than 12 industrial personnel on board vessels engaged on

international voyages (agenda item 7);
.4 safe mooring operations (agenda item 10); and
.5 guidelines for wing-in-ground craft (agenda item 11),
whereby the Chair, taking into account the submissions received on the respective subjects,
would advise the Sub-Committee before SDC 5 on the final selection of such groups.
Date of the next session
13.16 The Sub-Committee noted that the fifth session of the Sub-Committee has been
tentatively scheduled to take place from 22 to 26 January 2018.
14 ELECTION OF CHAIR AND VICE-CHAIR FOR 2018
In accordance with the Rules of Procedure of the Maritime Safety Committee, the Sub-Committee
unanimously re-elected Mr. Kevin Hunter (United Kingdom) as Chair and Mrs. Turid Stemre
(Norway) as Vice-Chair, both for 2018.
15 ANY OTHER BUSINESS
General
15.1 The Sub-Committee noted that one document reporting on the progress made on
the draft Guidelines for wing-in-ground (WIG) craft had been submitted under this output.
Revision of the Interim guidelines for wing-in-ground craft (MSC.1/Circ.1054 and Corr.1)
15.2 Having considered document SDC 4/15 (Antigua and Barbuda et al.), summarizing
the work carried out intersessionally by interested parties and providing recommendations
regarding the revision of the Interim guidelines for wing-in-ground craft (MSC.1/Circ.1054
and Corr.1), based on document SDC 3/12, the Sub-Committee noted, among other things,
the following information provided by the co-sponsors:
.1 the intention of the draft Guidelines was to achieve comparable safety

standards to those of the 1974 SOLAS Convention, and that it was of great
importance to incorporate the lessons learned from the development of
the 2000 HSC Code; and
.2 new issues which are not established in the Interim guidelines, but related
to WIG craft safety and pollution prevention, had been identified, in particular,
the need for further development of the relevant amendments to
the requirements for training and certification of officers on WIG craft, taking
into consideration the special operation mode of WIG craft and the human
element, and to the requirements and measures for avoiding collision with
other ships, which may result from operations in ground effect mode or at
low altitude.

SDC 4/16
Page 45
15.3 In considering how best to proceed on this matter, the Sub-Committee noted
the following views expressed:
.1 taking into account that this output is not on the provisional agenda of SDC 4,
the Sub-Committee should only note the progress made by the interested
parties intersessionally, without taking any action or decisions; and
.2 before inviting the Committee(s) to take any further actions, a consolidated

text of the draft Guidelines and consequential amendments to other
instruments, if any, should be considered by the Sub-Committee.
15.4 Following discussion, the Sub-Committee, having noted with appreciation the progress
made on the draft Guidelines for wing-in-ground (WIG) craft, agreed to continue promoting
the work regarding the development of the draft Guidelines, as appropriate.
15.5 The Sub-Committee recalled that MSC 96 had agreed to maintain the output on
"Guidelines for wing-in-ground craft" in its post-biennial agenda, for inclusion in the provisional
agenda for SDC 5, with a view to finalization during the 2018-2019 biennium.
15.6 With a view to finalizing the work on this output, the Sub-Committee invited all
interested Member States and international organizations to:
.1 proceed with further development of the draft Guidelines, with a view to

submitting the consolidated text for consideration at SDC 5; and
.2 consider whether the new issues identified in document SDC 4/15 remain
within the scope of this output, and, if not, prepare a draft justification for
either an expansion of the existing output, or for new output(s), in accordance
with the provisions of the document on Organization and method of work of
the Maritime Safety Committee and the Marine Environment Protection
Committee and their subsidiary bodies (MSC-MEPC.1/Circ.5).
Expressions of appreciation
15.7 The Sub-Committee expressed appreciation to the delegates and members of

the Secretariat, who had recently relinquished their duties, retired or been transferred to other
duties, or were about to do so, for their invaluable contribution to its work and wished them
a long and happy retirement or, as the case may be, every success in their new duties.
16 ACTION REQUESTED OF THE COMMITTEES
16.1 The Maritime Safety Committee, at its ninety-eighth session, is invited to:
.1 adopt the draft Revised Explanatory Notes to SOLAS chapter II-1 subdivision
and damage stability regulations and the associated draft MSC resolution, in
conjunction with the adoption of the draft amendments to SOLAS chapter II-1
subdivision and damage stability regulations (paragraph 3.29 and annex 1);
.2 approve the change of the existing title of output 5.2.1.13 (i.e. "Amendments
to SOLAS regulations II-1/6 and II-1/8-1") with "Amendments to SOLAS
regulation II-1/8-1 on the availability of passenger ships' electrical power
supply in cases of flooding from side raking damage" and extend the target
completion year for this output to 2019 (paragraphs 3.31 and 3.33);

SDC 4/16
Page 46
.3 approve the draft amendments to SOLAS regulations II-1/1 and II-1/8-1 on

computerized stability support for the master in case of flooding for existing
passenger ships, with a view to adoption at MSC 99, taking into account
the check/monitoring sheet and records for regulatory development prepared
by the Sub-Committee (paragraph 4.11 and annex 2);
.4 noting the progress made by the Sub-Committee on the development of draft

guidelines on stability computers and shore-based support for existing
passenger ships, extend the target completion year for this output to 2018
(paragraphs 4.13 to 4.18);
.5 endorse the Sub-Committee's view that no further amendments should be

developed to SOLAS regulation II-2/13 or chapter 13 of the FSS Code with
regard to open decks (paragraph 6.4);
.6 approve the draft amendments to section 3 of the Guidelines for damage

control plans and information to the master (MSC.1/Circ.1245) for passenger
ships and the associated draft MSC circular (paragraph 7.8 and annex 3);
.7 note the comments made and decisions taken regarding the development of
a consolidated text of the ESP Code (paragraphs 9.4 to 9.6);
.8 approve the draft Unified interpretations of SOLAS chapter II-1 and

the associated draft MSC circular, in conjunction with the approval of the draft
Revised Explanatory Notes to SOLAS chapter II-1 subdivision and damage
stability regulations (paragraph 10.3 and annex 4);
.9 approve the draft revised Guidelines on the means of access to structures

for inspection and maintenance of oil tankers and bulk carriers (MSC/Circ.686)
and the associated draft MSC circular (i.e. MSC/Circ.686/Rev.1)
(paragraph 10.6 and annex 5);
.10 approve the draft MSC circular on Unified interpretations of SOLAS

chapters II-1 and XII, of the Technical provisions for means of access
for inspections (resolution MSC.158(78)) and of the Performance standards
for water level detectors on bulk carriers and single hold cargo ships other
than bulk carriers (resolution MSC.188(79)), and the draft corrigendum
to MSC.1/Circ.1464/Rev.1 (i.e. MSC/Circ.1464/Rev.1/Corr.2) (paragraphs 10.9
and 10.12, and annexes 6 and 7);
.11 approve the draft Unified interpretation of SOLAS regulations II-1/2.20

and II-2/3.21 and the associated draft MSC circular (paragraph 10.14 and
annex 8);
.12 note that the Sub-Committee could not reach a conclusion regarding
the acceptance for a loading manual and stability information to include
a loading condition at a trimmed waterline with a corresponding deadweight
that exceeds the even-keel deadweight corresponding to the load line mark
in use, and invited interested Member States to bring this issue to
the attention of the Committee (paragraph 10.15);
.13 noting the progress made with regard to the matters related to the design of
arrangements and selection of equipment for safe mooring, extend the target
completion year for this output to 2019 (paragraphs 11.4 to 11.10);

SDC 4/16
Page 47
.14 approve the draft Interim guidelines for use of Fibre Reinforced Plastic (FRP)
elements within ship structures: Fire safety issues and the associated
draft MSC circular (paragraph 12.15 and annex 10);
.15 endorse the Sub-Committee's decision that four years would be a suitable
period for Administrations to gather experience in the application of
the Interim guidelines for use of Fibre Reinforced Plastic (FRP) elements
within ship structures: Fire safety issues, with a view to reviewing them, and
maintain the output on "Guidelines for use of Fibre Reinforced Plastic
(FRP) within ship structures" on the Committee's post-biennial agenda
(paragraph 12.16);
.16 consider the discussion regarding the second phase of the Polar Code work,
with a view to deciding on when the development of the second phase of
the Polar Code should begin, its scope of application and its recommendatory
or mandatory status, and take action as appropriate (paragraphs 13.4
and 13.5);
.17 approve the biennial status report of the Sub-Committee (paragraph 13.10
and annex 11);
.18 with regard to the outputs on the Committee's post-biennial agenda, that fall
under the purview of the Sub-Committee, endorse the replacement of
the references to "SDC" as the associated organ for output 9 and
the coordinating organ for output 42 with "SSE", and addition of "MEPC" as
a parent organ for output 32 (paragraph 13.11);
.19 approve the proposed biennial agenda for the 2018-2019 biennium
(paragraph 13.10 and annex 12);
.20 approve the proposed provisional agenda for SDC 5 (paragraph 13.13 and
annex 13); and
.21 approve the report in general.
16.2 The Marine Environment Protection Committee, at its seventy-first session, is invited to:
.1 approve the draft Unified interpretation of regulation 1.23 of MARPOL

Annex I and the associated draft MEPC circular (paragraph 10.14 and
annex 9); and
.2 with regard to the outputs on the Maritime Safety Committee's post-biennial

agenda, that fall under the purview of the Sub-Committee, endorse
the addition of "MEPC" as a parent organ for output 32 (paragraph 13.11).
***

SDC 4/16
Annex 1, page 1
ANNEX 1
DRAFT RESOLUTION MSC.[…](98)

(adopted on […] June 2017)
REVISED EXPLANATORY NOTES TO THE SOLAS CHAPTER II-1 SUBDIVISION AND

DAMAGE STABILITY REGULATIONS
THE MARITIME SAFETY COMMITTEE,
RECALLING Article 28(b) of the Convention on the International Maritime Organization

concerning the function of the Committee,
RECALLING ALSO that, by resolution MSC.216(82), it adopted the regulations on subdivision

and damage stability as contained in SOLAS chapter II-1 which are based on the probabilistic
concept, using the probability of survival after collision as a measure of ships' safety in
a damaged condition,
NOTING that, at the eighty-second session, it approved Interim Explanatory Notes to

the SOLAS chapter II-1 subdivision and damage stability regulations (MSC.1/Circ.1226), to
assist Administrations in the uniform interpretation and application of the aforementioned
subdivision and damage stability regulations,
NOTING ALSO that, at the eighty-fifth session, it adopted the Explanatory Notes to the SOLAS
chapter II-1 subdivision and damage stability regulations (resolution MSC.281(85)),
NOTING FURTHER that, by resolution MSC.[…](98), it adopted amendments to regulations

on subdivision and damage stability, as contained in SOLAS chapter II-1,
RECOGNIZING that the Revised Explanatory Notes should be adopted in conjunction with
the adoption of the aforementioned amendments to subdivision and damage stability
regulations (resolution MSC.[…](98)),
RECOGNIZING ALSO that the appropriate application of the Revised Explanatory Notes is
essential for ensuring the uniform application of the SOLAS chapter II-1 subdivision and
damage stability regulations,
HAVING CONSIDERED, at its [ninety-eighth] session, the recommendations made by

the Sub-Committee on Ship Design and Construction, at its fourth session,
1 ADOPTS the Revised Explanatory Notes to the SOLAS chapter II-1 subdivision and
damage stability regulations set out in the annex to the present resolution;
2 URGES Contracting Governments and all parties concerned to utilize the Revised
Explanatory Notes when applying the SOLAS chapter II-1 subdivision and damage stability
regulations adopted by resolution MSC.216(82), as amended;
3 INVITES Contracting Governments to note that these Revised Explanatory Notes

should take effect on ships contracted on or after [1 January 2020], as defined in SOLAS
regulation II-1/1.1.1, as adopted by resolution MSC.[…](98).

SDC 4/16
Annex 1, page 2
ANNEX
REVISED EXPLANATORY NOTES TO THE SOLAS CHAPTER II-1 SUBDIVISION AND

Contents
Part A – INTRODUCTION
Part B – GUIDANCE ON INDIVIDUAL SOLAS CHAPTER II-1 SUBDIVISION AND

Regulation 1 Application
Regulation 2 Definitions
Regulation 4 General
Regulation 5 Intact stability
Regulation 5-1 Stability information to be supplied to the master
Regulation 6 Required subdivision index R
Regulation 7 Attained subdivision index A
Regulation 7-1 Calculation of the factor pi
Regulation 7-2 Calculation of the factor si
Regulation 7-3 Permeability
Regulation 8 Special requirements concerning passenger ship stability
Regulation 8-1 System capabilities and operational information after a flooding
casualty on passenger ships
Regulation 9 Double bottoms in passenger ships and cargo ships other than
tankers
Regulation 10 Construction of watertight bulkheads
Regulation 12 Peak and machinery space bulkheads, shaft tunnels, etc.
Regulation 13 Openings in watertight bulkheads below the bulkhead deck in
passenger ships
Regulation 13-1 Openings in watertight bulkheads and internal decks in cargo ships
Regulation 15 Openings in the shell plating below the bulkhead deck of passenger
ships and the freeboard deck of cargo ships
Regulation 15-1 External openings in cargo ships
Regulation 16 Construction and initial tests of watertight closures
Regulation 17 Internal watertight integrity of passenger ships above the bulkhead
deck
Regulation 22 Prevention and control of water ingress, etc.
Appendix Guidelines for the preparation of subdivision and damage stability

calculations

SDC 4/16
Annex 1, page 3
PART A
INTRODUCTION
1 The harmonized SOLAS regulations on subdivision and damage stability, as

contained in SOLAS chapter II-1, are based on a probabilistic concept which uses
the probability of survival after collision as a measure of ships' safety in a damaged condition.
This probability is referred to as the "attained subdivision index A" in the regulations. It can be
considered an objective measure of ships' safety and, ideally, there would be no need to
supplement this index by any deterministic requirements.
2 The philosophy behind the probabilistic concept is that two different ships with
the same attained index are of equal safety and, therefore, there is no need for special
treatment of specific parts of the ship, even if they are able to survive different damages.
The only areas which are given special attention in the regulations are the forward and bottom
regions, which are dealt with by special subdivision rules provided for cases of ramming and
grounding.
3 Only a few deterministic elements, which were necessary to make the concept
practicable, have been included. It was also necessary to include a deterministic "minor
damage" on top of the probabilistic regulations for passenger ships to avoid ships being
designed with what might be perceived as unacceptably vulnerable spots in some part of their
length.
4 It is easily recognized that there are many factors that will affect the final
consequences of hull damage to a ship. These factors are random and their influence is
different for ships with different characteristics. For example, it would seem obvious that in
ships of similar size carrying different amounts of cargo, damages of similar extents may lead
to different results because of differences in the range of permeability and draught during
service. The mass and velocity of the ramming ship is obviously another random variable.
5 Owing to this, the effect of a three-dimensional damage to a ship with given watertight
subdivision depends on the following circumstances:
.1 which particular space or group of adjacent spaces is flooded;
.2 the draught, trim and intact metacentric height at the time of damage;
.3 the permeability of affected spaces at the time of damage;
.4 the sea state at the time of damage; and
.5 other factors such as possible heeling moments owing to unsymmetrical

weights.
6 Some of these circumstances are interdependent and the relationship between them
and their effects may vary in different cases. Additionally, the effect of hull strength on
penetration will obviously have some effect on the results for a given ship. Since the location
and size of the damage is random, it is not possible to state which part of the ship becomes
flooded. However, the probability of flooding a given space can be determined if the probability
of occurrence of certain damages is known from experience, that is, damage statistics.
The probability of flooding a space is then equal to the probability of occurrence of all such
damages which just open the considered space to the sea.

SDC 4/16
Annex 1, page 4
7 For these reasons and because of mathematical complexity as well as insufficient

data, it would not be practicable to make an exact or direct assessment of their effect on
the probability that a particular ship will survive a random damage if it occurs. However,
accepting some approximations or qualitative judgments, a logical treatment may be achieved
by using the probability approach as the basis for a comparative method for the assessment
and regulation of ship safety.
8 It may be demonstrated by means of probability theory that the probability of ship

survival should be calculated as the sum of probabilities of its survival after flooding each single
compartment, each group of two, three, etc., adjacent compartments multiplied, respectively,
by the probabilities of occurrence of such damages leading to the flooding of the corresponding
compartment or group of compartments.
9 If the probability of occurrence for each of the damage scenarios the ship could be
subjected to is calculated and then combined with the probability of surviving each of these
damages with the ship loaded in the most probable loading conditions, we can determine
the attained index A as a measure for the ship's ability to sustain a collision damage.
10 It follows that the probability that a ship will remain afloat without sinking or capsizing
as a result of an arbitrary collision in a given longitudinal position can be broken down to:
.1 the probability that the longitudinal centre of damage occurs in just the region
of the ship under consideration;
.2 the probability that this damage has a longitudinal extent that only includes
spaces between the transverse watertight bulkheads found in this region;
.3 the probability that the damage has a vertical extent that will flood only
the spaces below a given horizontal boundary, such as a watertight deck;
.4 the probability that the damage has a transverse penetration not greater than
the distance to a given longitudinal boundary; and
.5 the probability that the watertight integrity and the stability throughout
the flooding sequence is sufficient to avoid capsizing or sinking.
11 The first three of these factors are solely dependent on the watertight arrangement of
the ship, while the last two depend on the ship's shape. The last factor also depends on
the actual loading condition. By grouping these probabilities, calculations of the probability of
survival, or attained index A, have been formulated to include the following probabilities:
.1 the probability of flooding each single compartment and each possible group
of two or more adjacent compartments; and
.2 the probability that the stability after flooding a compartment or a group of

two or more adjacent compartments will be sufficient to prevent capsizing or
dangerous heeling due to loss of stability or to heeling moments in
intermediate or final stages of flooding.
12 This concept allows a rule requirement to be applied by requiring a minimum value

of A for a particular ship. This minimum value is referred to as the "required subdivision
index R" in the present regulations and can be made dependent on ship size, number of
passengers or other factors legislators might consider important.

SDC 4/16
Annex 1, page 5
13 Evidence of compliance with the rules then simply becomes:
A R
13.1 As explained above, the attained subdivision index A is determined by a formula for
the entire probability as the sum of the products for each compartment or group of
compartments of the probability that a space is flooded, multiplied by the probability that
the ship will not capsize or sink due to flooding of the considered space. In other words,
the general formula for the attained index can be given in the form:
A  pi si
13.2 Subscript "i" represents the damage zone (group of compartments) under
consideration within the watertight subdivision of the ship. The subdivision is viewed in
the longitudinal direction, starting with the aftmost zone/compartment.
13.3 The value of "pi" represents the probability that only the zone "i" under consideration
will be flooded, disregarding any horizontal subdivision, but taking transverse subdivision into
account. Longitudinal subdivision within the zone will result in additional flooding scenarios,
each with its own probability of occurrence.
13.4 The value of "si" represents the probability of survival after flooding the zone "i" under
consideration.
14 Although the ideas outlined above are very simple, their practical application in an
exact manner would give rise to several difficulties if a mathematically perfect method was to
be developed. As pointed out above, an extensive but still incomplete description of
the damage will include its longitudinal and vertical location as well as its longitudinal, vertical
and transverse extent. Apart from the difficulties in handling such a five-dimensional random
variable, it is impossible to determine its probability distribution very accurately with
the presently available damage statistics. Similar limitations are true for the variables and
physical relationships involved in the calculation of the probability that a ship will not capsize
or sink during intermediate stages or in the final stage of flooding.
15 A close approximation of the available statistics would result in extremely numerous

and complicated computations. In order to make the concept practicable, extensive
simplifications are necessary. Although it is not possible to calculate the exact probability of
survival on such a simplified basis, it has still been possible to develop a useful comparative
measure of the merits of the longitudinal, transverse and horizontal subdivision of a ship.

SDC 4/16
Annex 1, page 6
PART B
GUIDANCE ON INDIVIDUAL SOLAS CHAPTER II-1

SUBDIVISION AND DAMAGE STABILITY REGULATIONS
REGULATION 1 – APPLICATION
Regulation 1.3
1 If a passenger ship built before 1 January 2009 undergoes alterations or modifications

of major character, it may still remain under the damage stability regulations applicable to ships
built before 1 January 2009.
2 If a passenger ship constructed on or after 1 January 2009 but before the applicable
dates in regulation 1.1.1.1* undergoes alterations or modifications of major character that don't
impact the watertight subdivision of the ship, or only have a minor impact, it may still remain
under the damage stability regulations that were applicable when it was constructed. However,
if alterations or modifications of major character significantly impact the watertight subdivision
of the ship, it should comply with the damage stability regulations in part B-1 applicable when
the alterations or modifications of major character are carried out unless the Administration
determines that this is not reasonable and practicable, in which case the attained subdivision
index A should be raised above the original construction required subdivision index R as much
as practical.
3 Application of MSC.1/Circ.1246 is limited to cargo ships constructed

before 1 January 2009.
4 A cargo ship constructed on or after 1 January 2009 of less than 80 m in length that
is later lengthened beyond that limit should fully comply with the damage stability regulations
according to its type and length.
5 If a passenger ship that has been in domestic service only and never issued a SOLAS
Passenger Ship Safety Certificate is converted to international service, for purposes of
the stability requirements in parts B, B-1, B-2, B-3 and B-4 it should be treated as a passenger
ship constructed on the date on which such a conversion commences.
REGULATION 2 – DEFINITIONS
Regulation 2.1
Subdivision length (Ls) – Different examples of Ls showing the buoyant hull and the reserve
buoyancy are provided in the figures below. The limiting deck for the reserve buoyancy may
be partially watertight.
The maximum possible vertical extent of damage above the baseline is ds + 12.5 metres.
*
References to regulations in this Guidance are to regulations of SOLAS chapter II-1, unless expressly
provided otherwise.

SDC 4/16
Annex 1, page 7
Regulation 2.6
Freeboard deck – See explanatory notes for regulation 13-1 for the treatment of a stepped
freeboard deck with regard to watertightness and construction requirements.

SDC 4/16
Annex 1, page 8
Regulation 2.11
Light service draught (dl) – The light service draught (dl) corresponds, in general, to the ballast
arrival condition with 10% consumables for cargo ships. For passenger ships it corresponds,
in general, to the arrival condition with 10% consumables, a full complement of passengers
and crew and their effects, and ballast as necessary for stability and trim. Any temporary ballast
water exchange conditions for compliance with the International Convention for the Control
and Management of Ships' Ballast Water and Sediments, 2004 or any non-service conditions,
such as dry-docking, should not be taken as dl.
Regulation 2.19
Bulkhead deck – See explanatory notes for regulation 13 for the treatment of a stepped
bulkhead deck with regard to watertightness and construction requirements.
REGULATION 4 – GENERAL
Regulation 4.5
See explanatory notes for regulation 7-2.2, for information and guidance related to these
provisions.
REGULATION 5 – INTACT STABILITY
Regulation 5.2
1 For the purpose of this regulation, a sister ship means a cargo ship built by the same
shipyard from the same plans.
2 For any new sister ship with known differences from the lead sister ship that do not
exceed the lightship displacement and longitudinal centre of gravity deviation limits specified
in regulation 5.2, a detailed weights and centres of gravity calculation to adjust the lead sister
ship's lightship properties should be carried out. These adjusted lead sister ship lightship
properties are then used for comparison to the new sister ship's lightweight survey results.
However, in cases when the known differences from the lead sister ship exceed lightship
displacement or longitudinal centre of gravity deviation limits specified in regulation 5.2,
the ship should be inclined.
3 When the lightweight survey results do not exceed the specified deviation limits,
the lightship displacement and the longitudinal and transverse centres of gravity obtained from
the lightweight survey should be used in conjunction with the higher of either the lead sister
ship's vertical centre of gravity or the calculated, adjusted value.
4 Regulation 5.2 may be applied to the SPS Code ships certified to carry less
than 240 persons.

SDC 4/16
Annex 1, page 9
Regulation 5.4
1 When alterations are made to a ship in service that result in calculable differences in
the lightship properties, a detailed weights and centres of gravity calculation to adjust
the lightship properties should be carried out. If the adjusted lightship displacement or
longitudinal centre of gravity, when compared to the approved values, exceeds one of
the deviation limits specified in regulation 5.5, the ship should be re-inclined. In addition, if
the adjusted lightship vertical centre of gravity, when compared to the approved value,
exceeds 1%, the ship should be re-inclined. The lightship transverse centre of gravity is not
subject to a deviation limit.
2 When a ship does not exceed the deviation limits specified in explanatory note 1 above,
amended stability information should be provided to the master using the new calculated
lightship properties if any of the following deviations from the approved values are exceeded:
.1 1% of the lightship displacement; or
.2 0.5% of L for the longitudinal centre of gravity; or
.3 0.5% of the vertical centre of gravity.
However, in cases when these deviation limits are not exceeded, it is not necessary to amend
the stability information supplied to the master.
3 When multiple alterations are made to a ship in service over a period of time and each
alternation is within the deviation limits specified above, the cumulative total changes to
the lightship properties from the most recent inclining also should not exceed the deviation
limits specified above or the ship should be re-inclined.
Regulation 5.5
When the lightweight survey results do not exceed the specified deviation limits, the lightship
displacement and the longitudinal and transverse centres of gravity obtained from
the lightweight survey should be used in conjunction with the vertical centre of gravity derived
from the most recent inclining in all subsequent stability information supplied to the master.
REGULATION 5-1 – STABILITY INFORMATION TO BE SUPPLIED TO THE MASTER
Regulation 5-1.3
The requirement that applied trim values shall coincide in all stability information intended for
use on board, is intended to address initial stability calculations as well as those that may be
necessary during the service life of the ship.
Regulation 5-1.4 (see also regulation 7.2)
1 Linear interpolation of the limiting values between the draughts ds, dp and dl is only
applicable to minimum GM values. If it is intended to develop curves of maximum
permissible KG, a sufficient number of KMT values for intermediate draughts should be
calculated to ensure that the resulting maximum KG curves correspond with a linear variation
of GM. When light service draught is not with the same trim as other draughts, KMT for draughts
between partial and light service draught should be calculated for trims interpolated between
trim at partial draught and trim at light service draught.

SDC 4/16
Annex 1, page 10
2 In cases where the operational trim range is intended to exceed ±0.5% of L,

the original GM limit line should be designed in the usual manner with the deepest subdivision
draught and partial subdivision draught calculated at level trim and estimated service trim used
for the light service draught. Then additional sets of GM limit lines should be constructed on
the basis of the operational range of trims which is covered by loading conditions for each of
the three draughts ds, dp and dl ensuring that intervals of 1% L are not exceeded. The sets
of GM limit lines are combined to give a single envelope limiting GM curve. The effective trim
range of the curve should be clearly stated.
3 If multiple GM limiting curves are obtained from damage stability calculations of

differing trims in accordance with regulation 7, an envelope curve covering all calculated trim
values should be developed. Calculations covering different trim values should be carried out
in steps not exceeding 1% of L. The whole range including intermediate trims should be
covered by the damage stability calculations. Refer to the example showing an envelope curve
obtained from calculations of 0 trim and 1% of L.
4 Temporary loading conditions may occur with a draught less than the light service
draught dl due to ballast water exchange requirements, etc. In these cases, for draughts
below dl, the GM limit value at dl is to be used.
5 Ships may be permitted to sail at draughts above the deepest subdivision draught ds
according to the International Convention on Load Lines, e.g. using the tropical freeboard. In
these cases, for draughts above ds the GM limit value at ds is to be used.
Regulation 5-1.5
There could be cases where it is desirable to expand the trim range, for instance around dp.
This approach is based on the principle that it is not necessary that the same number of trims
be used when the GM is the same throughout a draught and when the steps between trims do
not exceed 1% of L. In these cases there will be three A values based on draughts s1, p1, l1
and s2, p2, l2 and s2, p3, l2. The lowest value of each partial index As, Ap and Al across these
trims should be used in the summation of the attained subdivision index A.

SDC 4/16
Annex 1, page 11
s2 s1
ds
p3 p2 p1
dp
Permitted Permitted
Draught
Draught
l2 l1
dl GM
Trim
0.5%L  0.5%L  0.5%L 0.5%L
Trim limit diagram GM limit curve
Regulation 5-1.6
This provision is intended to address cases where an Administration approves an alternative

means of verification.
REGULATION 6 – REQUIRED SUBDIVISION INDEX R
Regulation 6.1
To demonstrate compliance with these provisions, see the Guidelines for the preparation of
subdivision and damage stability calculations, set out in the appendix, regarding the presentation
of damage stability calculation results.
REGULATION 7 – ATTAINED SUBDIVISION INDEX A
Regulation 7.1
1 The probability of surviving after collision damage to the ship's hull is expressed by
the index A. Producing an index A requires calculation of various damage scenarios defined
by the extent of damage and the initial loading conditions of the ship before damage. Three
loading conditions should be considered and the result weighted as follows:
A  0.4 As  0.4 Ap  0.2 Al
where the indices s, p and l represent the three loading conditions and the factor to be
multiplied to the index indicates how the index A from each loading condition is weighted.
2 The method of calculating A for a loading condition is expressed by the formula:

i t
Ac   pi vi si 
i 1
2.1 The index c represents one of the three loading conditions, the index i represents
each investigated damage or group of damages and t is the number of damages to be
investigated to calculate Ac for the particular loading condition.

SDC 4/16
Annex 1, page 12
2.2 To obtain a maximum index A for a given subdivision, t has to be equal to T, the total
number of damages.
3 In practice, the damage combinations to be considered are limited either by

significantly reduced contributions to A (i.e. flooding of substantially larger volumes) or by
exceeding the maximum possible damage length.
4 The index A is divided into partial factors as follows:
pi The p factor is solely dependent on the geometry of the watertight

arrangement of the ship.
vi The v factor is dependent on the geometry of the watertight arrangement

(decks) of the ship and the draught of the initial loading condition.
It represents the probability that the spaces above the horizontal subdivision
will not be flooded.
si The s factor is dependent on the calculated survivability of the ship after

the considered damage for a specific initial condition.
5 Three initial loading conditions should be used for calculating each index A.
The loading conditions are defined by their mean draught d, trim and GM (or KG). The mean
draught and trim are illustrated in the figure below.
Level trim dds s

Level trim ddpp
100%
60% Service trim
Mean draught ddl
Mean draught
ddl l
6 The GM (or KG) values for the three loading conditions could, as a first attempt, be
taken from the intact stability GM (or KG) limit curve. If the required index R is not obtained,
the GM (or KG) values may be increased (or reduced), implying that the intact loading
conditions from the intact stability book must now meet the GM (or KG) limit curve from
the damage stability calculations derived by linear interpolation between the three GMs.
7 For a series of new passenger or cargo ships built from the same plans each of which
have the same draughts ds, dp and dl as well as the same GM and trim limits, the attained
subdivision index A calculated for the lead ship may be used for the other ships. In addition,
small differences in the draught dl (and the subsequent change in the draught dp) are
acceptable if they are due to small differences in the lightship characteristics that do not exceed
the deviation limits specified in regulation 5.2. For cases where these conditions are not met,
a new attained subdivision index A should be calculated.
"Built from the same plans" means that the watertight and weathertight aspects of the hull,
bulkheads, openings and other parts of a ship that impact the attained subdivision index A
calculation remain exactly the same.
8 For a passenger or cargo ship in service which undergoes alterations that materially
affect the stability information supplied to the master and require it to be re-inclined in
accordance with regulation 5.4, a new attained subdivision index A should be calculated.
However, for alteration cases where a re-inclining is not required and the alterations do not

SDC 4/16
Annex 1, page 13
change the watertight and weathertight arrangements of the ship that impact the attained
subdivision index A, if ds and the GM and trim limits remain the same then a new attained
subdivision index A is not required.
9 For passenger ships subject to lightweight surveys every 5 years, if the lightweight
survey results are within the limits specified in regulation 5.5, and ds and the GM and trim limits
remain the same, a new attained subdivision index A is not required. However, if the lightweight
survey results exceed either limit specified in regulation 5.5, a new attained subdivision index A
should be calculated.
10 For any new passenger or cargo ship for which the deviation in lightship
characteristics between the preliminary and the as built values are within the limits specified in
regulation 5.2 and ds is unchanged, then the preliminary attained subdivision index A calculation
may be approved as the final attained subdivision index A calculation. However, for cases where
these conditions are not met, then a new attained subdivision index A should be calculated.
Regulation 7.2
When additional calculations of A are performed for different trims, for a given set of
calculations the difference between trim values for ds, dp and dl may not exceed 1% L.
Regulation 7.5
1 With the same intent as wing tanks, the summation of the attained index A should
reflect effects caused by all watertight bulkheads and flooding boundaries within the damaged
zone. It is not correct to assume damage only to one half of the ship's breadth B and ignore
changes in subdivision that would reflect lesser contributions.
2 In the forward and aft ends of the ship where the sectional breadth is less than
the ship's breadth B, transverse damage penetration can extend beyond the centreline
bulkhead. This application of the transverse extent of damage is consistent with
the methodology to account for the localized statistics which are normalized on the greatest
moulded breadth B rather than the local breadth.
3 Where, at the extreme ends of the ship, the subdivision exceeds the waterline at
the deepest subdivision draught, the damage penetration b or B/2 is to be taken from centre
line. The figure below illustrates the shape of the B/2 line.

SDC 4/16
Annex 1, page 14
4 Where longitudinal corrugated bulkheads are fitted in wing compartments or on

the centreline, they may be treated as equivalent plane bulkheads provided the corrugation
depth is of the same order as the stiffening structure. The same principle may also be applied
to transverse corrugated bulkheads.
Regulation 7.6
Refer to the explanatory notes for Regulation 7-2.2 for the treatment of free surfaces during all
stages of flooding.
Regulation 7.7
1 Pipes and valves directly adjacent or situated as close as practicable to a bulkhead

or to a deck can be considered to be part of the bulkhead or deck, provided the separation
distance on either side of the bulkhead or deck is of the same order as the bulkhead or deck
stiffening structure. The same applies for small recesses, drain wells, etc.
2 For ships up to L = 150 m the provision for allowing "minor progressive flooding"
should be limited to pipes penetrating a watertight subdivision with a total cross-sectional area
of not more than 710 mm2 between any two watertight compartments. For ships of L = 150 m
and upwards the total cross-sectional area of pipes should not exceed the cross-sectional area
of one pipe with a diameter of L/5000 m.
REGULATION 7-1 – CALCULATION OF THE FACTOR pi
General
1 The definitions below are intended to be used for the application of part B-1 only.
2 In regulation 7-1, the words "compartment" and "group of compartments" should be

understood to mean "zone" and "adjacent zones".
3 Zone – a longitudinal interval of the ship within the subdivision length.

SDC 4/16
Annex 1, page 15
4 Room – a part of the ship, limited by bulkheads and decks, having a specific permeability.
5 Space – a combination of rooms.
6 Compartment – a space within watertight boundaries.
7 Damage – the three dimensional extent of the breach in the ship.
8 For the calculation of p, v, r and b only the damage should be considered, for
the calculation of the s-value the flooded space should be considered. The figures below
illustrate the difference.
Damage shown as the bold square: Flooded space shown below:
Regulation 7-1.1.1
1 The coefficients b11, b12, b21 and b22 are coefficients in the bi-linear probability density
function on normalized damage length (J). The coefficient b12 is dependent on whether Ls is
greater or less than L* (i.e. 260 m); the other coefficients are valid irrespective of Ls.
Longitudinal subdivision
2 In order to prepare for the calculation of index A, the ship's subdivision length Ls is
divided into a fixed discrete number of damage zones. These damage zones will determine
the damage stability investigation in the way of specific damages to be calculated.
3 There are no specific rules for longitudinally subdividing the ship, except that
the length Ls defines the extremities of the zones. Zone boundaries need not coincide with
physical watertight boundaries. However, it is important to consider a strategy carefully to
obtain a good result (that is a large attained index A). All zones and combination of adjacent
zones may contribute to the index A. In general it is expected that the more zone boundaries
the ship is divided into the higher will be the attained index, but this benefit should be balanced
against extra computing time. The figure below shows different longitudinal zone divisions of
the length Ls.

SDC 4/16
Annex 1, page 16
4 The first example is a very rough division into three zones of approximately the same
size with limits where longitudinal subdivision is established. The probability that the ship will
survive a damage in one of the three zones is expected to be low (i.e. the s-factor is low or
zero) and, therefore, the total attained index A will be correspondingly low.
5 In the second example the zones have been placed in accordance with the watertight
arrangement, including minor subdivision (as in double bottom, etc.). In this case there is
a much better chance of obtaining higher s-factors.
6 Where transverse corrugated bulkheads are fitted, they may be treated as equivalent
plane bulkheads, provided the corrugation depth is of the same order as the stiffening structure.
7 Pipes and valves directly adjacent or situated as close as practicable to a transverse

bulkhead can be considered to be part of the bulkhead, provided the separation distance on
either side of the bulkhead is of the same order as the bulkhead stiffening structure. The same
applies for small recesses, drain wells, etc.
8 For cases where the pipes and valves cannot be considered as being part of the
transverse bulkhead, when they present a risk of progressive flooding to other watertight
compartments that will have influence on the overall attained index A, they should be handled
either by introducing a new damage zone and accounting for the progressive flooding to
associated compartments or by introducing a gap.
9 The triangle in the figure below illustrates the possible single and multiple zone
damages in a ship with a watertight arrangement suitable for a seven-zone division.
The triangles at the bottom line indicate single zone damages and the parallelograms indicate
adjacent zones damages.

SDC 4/16
Annex 1, page 17
10 As an example, the triangle illustrates a damage opening the rooms in zone 2 to

the sea and the parallelogram illustrates a damage where rooms in the zones 4, 5 and 6 are
flooded simultaneously.
11 The shaded area illustrates the effect of the maximum absolute damage length.
The p-factor for a combination of three or more adjacent zones equals zero if the length of
the combined adjacent damage zones minus the length of the foremost and the aft most
damage zones in the combined damage zone is greater than the maximum damage length.
Having this in mind when subdividing Ls could limit the number of zones defined to maximize
the attained index A.

SDC 4/16
Annex 1, page 18
12 As the p-factor is related to the watertight arrangement by the longitudinal limits of

damage zones and the transverse distance from the ship side to any longitudinal barrier in
the zone, the following indices are introduced:
j: the damage zone number starting with

No.1 at the stern;
n: the number of adjacent damage zones in

question where j is the aft zone;
k: the number of a particular longitudinal

bulkhead as a barrier for transverse
penetration in a damage zone counted
from shell towards the centreline.
The shell has No. 0;
K: total number of transverse

penetration boundaries;
pj,n,k: the p-factor for a damage in

zone j and next (n-1) zones
forward of j damaged to
the longitudinal bulkhead k.

SDC 4/16
Annex 1, page 19
Pure longitudinal subdivision
Single damage zone, pure longitudinal subdivision:

pj,1 = p(x1j,x2j)
Two adjacent zones, pure longitudinal subdivision:

pj,2 = p(x1j,x2j+1) - p(x1j,x2j) - p(x1j+1,x2j+1)
Three or more adjacent zones, pure longitudinal

subdivision:
pj,n = p(x1j,x2j+n-1) - p(x1j,x2j+n-2) -
p(x1j+1,x2j+n-1) + p(x1j+1,x2j+n-2)

SDC 4/16
Annex 1, page 20
Regulation 7-1.1.2
Transverse subdivision in a damage zone
1 Damage to the hull in a specific damage zone may just penetrate the ship's watertight
hull or penetrate further towards the centreline. To describe the probability of penetrating only
a wing compartment, a probability factor r is used, based mainly on the penetration depth b.
The value of r is equal to 1, if the penetration depth is B/2 where B is the maximum breadth of
the ship at the deepest subdivision draught ds, and r = 0 if b = 0.
2 The penetration depth b is measured at level deepest subdivision draught ds as

a transverse distance from the ship side right-angled to the centreline to a longitudinal barrier.
3 Where the actual watertight bulkhead is not a plane parallel to the shell, b should be
determined by means of an assumed line, dividing the zone to the shell in a relationship b1/b2
with 1 2  b1 b2  2 .
4 Examples of such assumed division lines are illustrated in the figure below. Each
sketch represents a single damage zone at a water line plane level ds and the longitudinal
bulkhead represents the outermost bulkhead position below ds + 12.5 m.

SDC 4/16
Annex 1, page 21
4.1 If a transverse subdivision intercepts the deepest subdivision draught waterline within
the extent of the zone, b is equal to zero in that zone for that transverse subdivision, see
figure 1. A non-zero b can be obtained by including an additional zone, see figure 2.
4.2 If the deepest subdivision draught waterline on the side of a single hull ship includes
a part where multiple transverse (y) coordinates occur for a longitudinal (x) location,
a straightened reference waterline can be used for the calculation of b. If this approach is
chosen, the original waterline is replaced by an envelope curve including straight parts
perpendicular to the centreline where multiple transverse coordinates occur, see figures 1 to 4.
The maximum transverse damage extent B/2 should then be calculated from waterline or
the reference waterline, if applicable, at the deepest subdivision draught.

SDC 4/16
Annex 1, page 22
5 In calculating r-values for a group of two or more adjacent compartments, the b-value
is common for all compartments in that group, and equal to the smallest b-value in that group:
b  minb1 , b2 ,, bn 
where: n number of wing compartments in that group;

b1 , b2 ,, bn  mean values of b for individual wing compartments
contained in the group.
Accumulating p
6 The accumulated value of p for one zone or a group of adjacent zones is determined by:
k K j ,n
p j ,n  p
k 1
j ,n ,k
j  n 1
where K j ,n  K j
j the total number of bk's for the adjacent zones in question.
7 The figure above illustrates b's for adjacent zones. The zone j has two penetration
limits and one to the centre, the zone j+1 has one b and the zone j+n-1 has one value for b.
The multiple zones will have (2+1+1) four values of b, and sorted in increasing order they are:
(bj,1 ; bj+1,1 ; bj+n-1,1 ; bj,2 ; bK)
8 Because of the expression for r(x1, x2, b) only one bK should be considered.
To minimize the number of calculations, b's of the same value may be deleted.
As bj,1 = bj+1,1 the final b's will be (bj,1 ; bj+n-1,1 ; bj,2 ; bK)

SDC 4/16
Annex 1, page 23
Examples of multiple zones having a different b
9 Examples of combined damage zones and damage definitions are given in the figures
below. Compartments are identified by R10, R12, etc.
Figure: Combined damage of zones 1 + 2 + 3 includes a limited penetration to b3,

taken into account generating two damages:
1) to b3 with R10, R20 and R31 damaged;

2) to B/2 with R10, R20, R31 and R32 damaged.
Figure: Combined damage of zones 1 + 2 + 3 includes 3 different limited damage

penetrations generating four damages:

2) to b2 with R11, R21, R31 and R32 damaged;
3) to b1 with R11, R21, R31, R32, and R22 damaged;
4) to B/2 with R11, R21, R31, R32, R22 and R12 damaged.
Figure: Combined damage of zone 1 + 2 + 3 including 2 different limited damage

penetrations (b1 < b2 = b3) generating three damages:

2) to b2 with R11, R21, R31 and R12 damaged;
3) to B/2 with R11, R21, R31, R12, R22 and R32 damaged.

SDC 4/16
Annex 1, page 24
10 A damage having a transverse extent b and a vertical extent H2 leads to the flooding
of both wing compartment and hold; for b and H1 only the wing compartment is flooded. The figure
below illustrates a partial subdivision draught dp damage.
11 The same is valid if b-values are calculated for arrangements with sloped walls.
12 Pipes and valves directly adjacent or situated as close as practicable to a longitudinal

bulkhead can be considered to be part of the bulkhead, provided the separation distance on
either side of the bulkhead is of the same order as the bulkhead stiffening structure. The same
applies for small recesses, drain wells, etc.
REGULATION 7-2 – CALCULATION OF THE FACTOR si
General
1 Initial condition – an intact loading condition to be considered in the damage analysis

described by the mean draught, vertical centre of gravity and the trim; or alternative parameters
from where the same may be determined (e.g. displacement, GM and trim). There are three
initial conditions corresponding to the three draughts ds, dp and dl.
2 Immersion limits – immersion limits are an array of points that are not to be immersed
at various stages of flooding as indicated in regulations 7-2.5.2 and 7-2.5.3.
3 Openings – all openings need to be defined: both weathertight and unprotected.

Openings are the most critical factor to preventing an inaccurate index A. If the final waterline
immerses the lower edge of any opening through which progressive flooding takes place,
the factor "s" may be recalculated taking such flooding into account. However, in this case
the s value should also be calculated without taking into account progressive flooding and
corresponding opening. The smallest s value should be retained for the contribution to
the attained index.
Regulation 7-2.1
1 In cases where the GZ curve may include more than one "range" of positive righting
levers for a specific stage of flooding, only one continuous positive "range" of the GZ curve
may be used within the allowable range/heel limits for calculation purposes. Different stages
of flooding may not be combined in a single GZ curve.

SDC 4/16
Annex 1, page 25
2 In figure 1, the s-factor may be calculated from the heel angle, range and
corresponding GZmax of the first or second "range" of positive righting levers. In figure 2, only
one s-factor can be calculated.
Regulation 7-2.2
Intermediate stages of flooding
1 The case of instantaneous flooding in unrestricted spaces in way of the damage zone
does not require intermediate stage flooding calculations. Where intermediate stages of
flooding calculations are necessary in connection with progressive flooding, flooding through
non-watertight boundaries or cross-flooding, they should reflect the sequence of filling as well
as filling level phases. Calculations for intermediate stages of flooding should be performed
whenever equalization is not instantaneous, i.e. equalization is of a duration greater than 60 s.
Such calculations consider the progress through one or more floodable (non-watertight)
spaces, or cross-flooded spaces. Bulkheads surrounding refrigerated spaces, incinerator
rooms and longitudinal bulkheads fitted with non-watertight doors are typical examples of
structures that may significantly slow down the equalization of main compartments.
Flooding boundaries
2 If a compartment contains decks, inner bulkheads, structural elements and doors of

sufficient tightness and strength to seriously restrict the flow of water, for intermediate stage
flooding calculation purposes it should be divided into corresponding non-watertight spaces.
It is assumed that the non-watertight divisions considered in the calculations are limited to "A"
class fire-rated bulkheads and decks, and do not apply to "B" class fire-rated bulkheads
normally used in accommodation areas (e.g. cabins and corridors). This guidance also relates
to regulation 4.5. For spaces in the double bottom, in general, only main longitudinal structures
with a limited number of openings have to be considered as flooding boundaries.

SDC 4/16
Annex 1, page 26
Sequential flooding computation
3 For each damage scenario, the damage extent and location determine the initial stage
of flooding. Calculations should be performed in stages, each stage comprising of at least two
intermediate filling phases in addition to the full phase per flooded space. Unrestricted spaces
in way of damage should be considered as flooded immediately. Every subsequent stage
involves all connected spaces being flooded simultaneously until an impermeable boundary or
final equilibrium is reached. Unless the flooding process is simulated using time-domain
methods, when a flooding stage leads to both a self-acting cross-flooding device and
a non-watertight boundary, the self-acting cross-flooding device is assumed to act immediately
and occur before the non-watertight boundary is breached. If due to the configuration of
the subdivision in the ship it is expected that other intermediate stages of flooding are more
onerous, then those should be investigated.
3.1 For each phase of a flooding stage (except the final full phase), the instantaneous
transverse moment of this floodwater is calculated by assuming a constant volume of water at
each heeling angle. The GZ curve is calculated with a constant intact displacement at all stages
of flooding. Only one free surface needs to be assumed for water in spaces flooded during
the current stage.
In the final full phase of each stage, the water level in rooms flooded during this stage reaches
the outside sea level, so the lost buoyancy method can be used. The same method applies for
every successive stage (added volume of water with a constant intact displacement for all
phases before the final full phase of the stage in consideration), while each of the previous
stages at the final full phase can be calculated with the lost buoyancy method.
The examples below present a simplified, sequential approach to intermediate stage

down-flooding and cross-flooding. Because simultaneous down-flooding and cross-flooding is not
accounted for, any time-to-flood calculated with this sequential approach should be conservative.
Alternative approaches, such as time-domain* flooding simulation, are also acceptable.
Example 1: Major damage with cross-flooding device
Stage 0: Unrestricted spaces in way of damage should be considered as flooded immediately

(intermediate phases are not considered). The lost buoyancy method is applied as this is
a full (final) phase. Provided the ship does not capsize and remains at a floating position
from which cross-flooding can proceed, stage 0 need not be taken into account for
the sfactor calculation as the first intermediate stage to be calculated is after 60 seconds. See
cross-flooding/equalization explanatory note 5 below.
Rooms within breach extent

instantaneously flooded
Breach extent

SDC 4/16
Annex 1, page 27
Stage 1: Cross-flooding of opposite room
Rooms flooded in previous stage

treated in lost buoyancy method
Flood water is added, with

one free surface
Cross-flooded rooms
Cross-flooding device
An intermediate phase

treated in lost buoyancy method
Cross-flooded rooms in lost

buoyancy method
Full (final) phase of flooding stage 1
Example 2: Minor damage with down-flooding and cross-flooding
Stage 0: Unrestricted spaces in way of damage should be considered as flooded immediately

(intermediate phases are not considered). The lost buoyancy method is applied as this is
a full (final) phase. Provided the ship does not capsize and remains at a floating position
from which cross-flooding can proceed, stage 0 need not be taken into account for
the sfactor calculation as the first intermediate stage to be calculated is after 60 seconds. See
cross-flooding/equalization explanatory note 5 below.

SDC 4/16
Annex 1, page 28
Breach extent Rooms within breach extent

instantaneously flooded
Stage 1: Down-flooding through non-watertight deck
Rooms flooded in previous stage treated

by lost buoyancy method
Down-flooded room
Floodwater is added with one common

free surface

treated by lost buoyancy method
Down-flooded rooms treated

by lost buoyancy method
Final (full) phase of stage 1

SDC 4/16
Annex 1, page 29
Stage 2: Cross-flooding
Rooms flooded in previous stages,

Floodwater is added with

one free surface
Cross-flooded room
Cross-flooding device
Rooms flooded in previous stages,

Cross- flooded room treated by

lost buoyancy method
Full (final) phase of stage 2
Cross-flooding/equalization
4 In general, cross-flooding is flooding of an undamaged space of the ship to reduce

the heel in the final equilibrium condition.
5 The cross-flooding time should be calculated in accordance with the Revised

recommendation on a standard method for evaluating cross-flooding arrangements
(resolution MSC.362(92)). If complete fluid equalization occurs in 60 s or less, it should be
treated as instantaneous and no further calculations need to be carried out. Additionally, in
cases where sfinal = 1 is achieved in 60 s or less, but equalization is not complete, instantaneous
flooding may also be assumed if sfinal will not become reduced. In any cases where complete
fluid equalization exceeds 60 s, the value of sintermediate after 60 s is the first intermediate stage
to be considered. Only self-acting open cross-flooding arrangements without valves should be
considered effective for instantaneous flooding cases.

SDC 4/16
Annex 1, page 30
6 Provided that the ship has a GZ greater than 0 and remains in a position from which
cross-flooding can proceed, stage 0 need not be taken into account for the sfactor calculation as
the first intermediate stage to be calculated is after 60 seconds.
7 Only cross-flooding devices which are sufficiently submerged below the external
waterline at stage 0 are to be used in the calculation for cross-flooding according to
resolution MSC.362(92).
8 If complete fluid equalization can be finalized in 10 min or less, the assessment of

survivability is carried out using the formula in regulation 7-2.1.1 (i.e. as the smallest value of
sintermediate or sfinal · smom)
9 In case the equalization time is longer than 10 min, sfinal is calculated for the floating
position achieved after 10 min of equalization. This floating position is computed by calculating
the amount of flood water according to resolution MSC.362(92) using interpolation, where
the equalization time is set to 10 min, i.e. the interpolation of the flood water volume is made
between the case before equalization (T=0) and the total calculated equalization time. For
damage cases involving different cross-flooding devices serving different spaces, when
the interpolation between the case before equalization (T=0) and the total calculated
equalization time is needed for flood water volume calculation after 60 s or 10 min, the total
equalization time is to be calculated separately for each cross-flooding device.
10 In any cases where complete fluid equalization exceeds 10 min, the value of sfinal used in
the formula in regulation 7-2.1.1 should be the minimum of sfinal at 10 min or at final equalization.
11 The factor sintermediate,i may be used for cross-flooding stages if they are intermediate
stages which are followed by other subsequent flooding stages (e.g. the flooding stages of
non-watertight compartments).
Alternatives
12 As an alternative to the procedure described above in the explanatory notes for

regulation 7-2.2, direct calculation using computational fluid dynamics (CFD), time-domain
flooding simulations or model testing may be used to analyse intermediate stages of flooding
and determine the time for equalization.
Regulation 7-2.3
1 The formulation of sfinal,i is based on target values for GZ and Range to achieve s = 1.
These values are defined as TGZmax and TRange.
2 If ro-ro spaces are damaged there might be the possibility of water accumulation on
these deck spaces. To account for this, in any damage case where the ro-ro space is damaged
the higher values for TGZmax and TRange are to be applied for the calculation of si.
Regulation 7-2.4.1.2
The parameter A (projected lateral area) used in this paragraph does not refer to the attained
subdivision index.

SDC 4/16
Annex 1, page 31
Unprotected openings
1 The flooding angle will be limited by immersion of such an opening. It is not necessary
to define a criterion for non-immersion of unprotected openings at equilibrium, because if it is
immersed, the range of positive GZ limited to flooding angle will be zero so "s" will be equal
to zero.
2 An unprotected opening connects two rooms or one room and the outside.
An unprotected opening will not be taken into account if the two connected rooms are flooded
or none of these rooms are flooded. If the opening is connected to the outside, it will not be
taken into account if the connected compartment is flooded. An unprotected opening does not
need to be taken into account if it connects a flooded room or the outside to an undamaged
room, if this room will be considered as flooded in a subsequent stage.
Openings fitted with a weathertight mean of closing ("weathertight openings")
3 The survival "s" factor will be "0" if any such point is submerged at a stage which is
considered as "final". Such points may be submerged during a stage or phase which is
considered as "intermediate", or within the range beyond equilibrium.
4 If an opening fitted with a weathertight means of closure is submerged at equilibrium

during a stage considered as intermediate, it should be demonstrated that this weathertight means
of closure can sustain the corresponding head of water and that the leakage rate is negligible.
5 These points are also defined as connecting two rooms or one room and the outside,
and the same principle as for unprotected openings is applied to take them into account or not.
If several stages have to be considered as "final", a "weathertight opening" does not need to
be taken into account if it connects a flooded room or the outside to an undamaged room if this
room will be considered as flooded in a successive "final" stage.
1 Partial immersion of the bulkhead deck may be accepted at final equilibrium. This
provision is intended to ensure that evacuation along the bulkhead deck to the vertical escapes
will not be impeded by water on that deck. A "horizontal evacuation route" in the context of this
regulation means a route on the bulkhead deck connecting spaces located on and under this
deck with the vertical escapes from the bulkhead deck required for compliance with SOLAS
chapter II-2.
2 Horizontal evacuation routes on the bulkhead deck include only escape routes
(designated as category 2 stairway spaces according to SOLAS regulation II-2/9.2.2.3 or as
category 4 stairway spaces according to SOLAS regulation II-2/9.2.2.4 for passenger ships
carrying not more than 36 passengers) used for the evacuation of undamaged spaces.
Horizontal evacuation routes do not include corridors (designated as category 3 corridor spaces
according to SOLAS regulation II-2/9.2.2.3 or as category 2 corridor spaces according to
SOLAS regulation II-2/9.2.2.4 for passenger ships carrying not more than 36 passengers)
or escape routes within a damaged zone. No part of a horizontal evacuation route serving
undamaged spaces should be immersed.
3 si = 0 where it is not possible to access a stair leading up to the embarkation deck

from an undamaged space as a result of flooding to the "stairway" or "horizontal stairway" on
the bulkhead deck.

SDC 4/16
Annex 1, page 32
1 The purpose of this paragraph is to provide an incentive to ensure that evacuation

through a vertical escape will not be obstructed by water from above. The paragraph is
intended for smaller emergency escapes, typically hatches, where fitting of a watertight or
weathertight means of closure would otherwise exclude them from being considered as
flooding points.
2 Since the probabilistic regulations do not require that the watertight bulkheads be
carried continuously up to the bulkhead deck, care should be taken to ensure that evacuation
from intact spaces through flooded spaces below the bulkhead deck will remain possible, for
instance by means of a watertight trunk.

SDC 4/16
Annex 1, page 33
Regulation 7-2.6
The sketches in the figure illustrate the connection between position of watertight decks in
the reserve buoyancy area and the use of factor v for damages below these decks.
Above the waterline In this example, there are 3 horizontal subdivisions

H3 to be taken into account as the vertical extent of
H2 damage.
H1 12.5 m
d The example shows the maximum possible vertical
extent of damage d + 12.5 m is positioned
between H2 and H3. H1 with factor v1, H2 with
factor v2 > v1 but v2 < 1 and H3 with factor v3 = 1.
H4
H3
The factors v1 and v2 are the same as above.
H2
The reserve buoyancy above H3 should be taken
12.5 m undamaged in all damage cases.
H1
d
Below the waterline The combination of damages into the rooms R1, R2
and R3 positioned below the initial water line should
be chosen so that the damage with the lowest s-factor
d
R1 is taken into account. That often results in the definition
R2 of alternative damages to be calculated and
R3 compared. If the deck taken as lower limit of damage
Dam. Zone is not watertight, down flooding should be considered.
Regulation 7-2.6.1
The parameters x1 and x2 are the same as parameters x1 and x2 used in regulation 7-1.
REGULATION 7-3 – PERMEABILITY
Regulation 7-3.2
1 The following additional cargo permeabilities may be used:
Permeability at Permeability at Permeability at

Spaces
draught ds draught dp draught dl
Timber cargo in holds 0.35 0.7 0.95
Wood chip cargo 0.6 0.7 0.95
2 Reference is made to MSC/Circ.998 (IACS Unified Interpretation regarding timber

deck cargo in the context of damage stability requirements) regarding timber deck cargo.

SDC 4/16
Annex 1, page 34
Regulation 7-3.3
1 Concerning the use of other figures for permeability "if substantiated by calculations",
such permeabilities should reflect the general conditions of the ship throughout its service life
rather than specific loading conditions.
2 This paragraph allows for the recalculation of permeabilities. This should only be
considered in cases where it is evident that there is a major discrepancy between the values
shown in the regulation and the real values. It is not designed for improving the attained value
of a deficient ship of regular type by the modification of chosen spaces in the ship that are known
to provide significantly onerous results. All proposals should be considered on a case-by-case
basis by the Administration and should be justified with adequate calculations and arguments.
REGULATION 8 – SPECIAL REQUIREMENTS CONCERNING PASSENGER SHIP

STABILITY
Regulation 8.1
This regulation is intended to ensure a sufficient safety level if a large compartment is located
aft of the collision bulkhead.
REGULATION 8-1 – SYSTEM CAPABILITIES AND OPERATIONAL INFORMATION

AFTER A FLOODING CASUALTY ON PASSENGER SHIPS
Regulation 8-1.2
1 In the context of this regulation, "compartment" has the same meaning as defined under
regulation 7-1 of these Explanatory Notes (i.e. an on-board space within watertight boundaries).
2 The purpose of the paragraph is to prevent any flooding of limited extent from
immobilizing the ship. This principle should be applied regardless of how the flooding might
occur. Only flooding below the bulkhead deck need be considered.
REGULATION 9 – DOUBLE BOTTOMS IN PASSENGER SHIPS AND CARGO

SHIPS OTHER THAN TANKERS
Regulation 9.1
1 This regulation is intended to minimize the impact of flooding from a minor grounding.
Special attention should be paid to the vulnerable area at the turn of the bilge. When justifying
a deviation from fitting an inner bottom an assessment of the consequences of allowing a more
extensive flooding than reflected in the regulation should be provided.
2 The determination regarding the requirement to fit a double bottom "as far as this is
practicable and compatible with the design and proper working of the ship" is made, or should
be accepted by, the Administration or a recognized organization acting on its behalf.
Compliance with the damage stability requirement in regulation 9.8 should not be considered
as an equivalent optional requirement to the fitting of a dimensionally compliant double bottom.
This is because a flooded watertight compartment, such as an engine room, that complies with
the damage stability requirement in regulation 9.8 is not equivalent to a flooded double bottom
below that compartment. Compliance with the damage stability requirement in regulation 9.8
is intended to provide a minimum level of safety in cases when the fitting of a double bottom
is not practicable or compatible with the design and proper working of the ship.

SDC 4/16
Annex 1, page 35
Regulation 9.2
1 Except as provided in regulations 9.3 and 9.4, parts of the double bottom not extended
for the full width of the ship as required by regulation 9.2 should be considered an unusual
arrangement for the purpose of this regulation and should be handled in accordance with
regulation 9.7. An example is provided below.
B/20
2 If an inner bottom is located higher than the partial subdivision draught dp, this should
be considered an unusual arrangement and is to be handled in accordance with regulation 9.7.
Regulations 9.3.2.2, 9.6 and 9.7
For cargo ships of less than 80 m in length (L), the alternative arrangements to provide a level
of safety satisfactory to the Administration should be limited to compartments not having
a double bottom, having an unusual bottom arrangement, or having an "other well" extending
below the required double bottom height that is greater than the h/2 or 500 mm limit indicated
in regulation 9.3.2.1. In these cases compliance with the bottom damage standard in
regulation 9.8 should be demonstrated assuming that the damage will only occur between
the transverse watertight bulkheads in compartments not having a double bottom, having an
unusual bottom arrangement, or having an "other well" extending below the required double
bottom height that is greater than the h/2 or 500 mm limit indicated in regulation 9.3.2.1.
Regulation 9.6
1 Any part of a passenger ship or a cargo ship of 80 m in length (L) and upwards where
a double bottom is omitted in accordance with regulation 9.1, 9.4 or 9.5 shall be capable of
withstanding bottom damages, as specified in regulation 9.8. The intent of this provision is to
specify the circumstances under which the Administration should require calculations, which
damage extents to assume and what survival criteria to apply when double bottoms are not fitted.
2 The definition of "watertight" in regulation 2.17 implies that the strength of inner
bottoms and other boundaries assumed to be watertight should be verified if they are to be
considered effective in this context.
Regulation 9.7
The reference to a "plane" in regulation 9.2 does not imply that the surface of the inner bottom
may not be stepped in the vertical direction. Minor steps and recesses need not be considered
unusual arrangements for the purpose of this paragraph as long as no part of the inner bottom
is located below the reference plane. Discontinuities in way of wing tanks are covered by
regulation 9.4.

SDC 4/16
Annex 1, page 36
Regulation 9.8
1 For ships to which the probabilistic damage stability requirements of part B-1 apply,
the term "all service conditions" used in this paragraph means the three loading conditions with
all trims used to calculate the attained subdivision index A. For ships not subject to the
probabilistic damage stability requirements in part B-1, such as cargo ships that comply with
the subdivision and damage stability requirements of other instruments as allowed by
regulation II-1/4.2.1.2 and cargo ships of less than 80 m in length (L), "all service conditions"
means that the limit curves or tables required by regulation 5-1.2.1 should include values
calculated for the same draught and trim range(s) as for the other applicable stability
requirements.
2 The damage extents specified in this paragraph should be applied to all parts of
the ship where no double bottom is fitted, as permitted by regulations 9.1, 9.4 or 9.5, and
include any adjacent spaces located within the extent of damage. Small wells in accordance
with regulation 9.3.1 do not need to be considered damaged even if within the extent of
the damage. Possible positions of the damages are shown in an example below (parts of
the ship not fitted with a double bottom are shaded; the damages to be assumed are indicated
by boxes).

SDC 4/16
Annex 1, page 37
Regulation 9.9
1 For the purpose of identifying "large lower holds", horizontal surfaces having
a continuous deck area greater than approximately 30% in comparison with the waterplane
area at subdivision draught should be taken to be located anywhere in the affected area of
the ship. For the alternative bottom damage calculation, a vertical extent of B/10 or 3 m,
whichever is less, should be assumed.
2 The increased minimum double bottom height of not more than B/10 or 3 m,
whichever is less, for passenger ships with large lower holds, is applicable to holds in direct
contact with the double bottom. Typical arrangements of ro-ro passenger ships may include
a large lower hold with additional tanks between the double bottom and the lower hold, as
shown in the figure below. In such cases, the vertical position of the double bottom required to
be B/10 or 3 m, whichever is less, should be applied to the lower hold deck, maintaining
the required double bottom height of B/20 or 2 m, whichever is less (but not less than 760 mm).
The figure below shows a typical arrangement of a modern ro-ro passenger ferry.
>B/10
>B/20
REGULATION 10 – CONSTRUCTION OF WATERTIGHT BULKHEADS
Regulation 10.1
For the treatment of steps in the bulkhead deck of passenger ships see explanatory notes for
regulation 13. For the treatment of steps in the freeboard deck of cargo ships see explanatory
notes for regulation 13-1.

SDC 4/16
Annex 1, page 38
REGULATION 12 – PEAK AND MACHINERY SPACE BULKHEADS, SHAFT TUNNELS,

ETC.
Regulation 12.6.1
For cargo ships, the following figures show examples of suitable butterfly valve arrangements:
Figure 1
Figure 2

SDC 4/16
Annex 1, page 39
As butterfly valves must be capable of being remotely operated the following shall apply:
.1 the actuator shall be of a double acting type;
.2 when subject to loss of power, the actuator shall remain in its current position;
and
.3 when subject to loss of power, the valve shall be able to be manually

operated.
Regulation 12.10
1 In cargo ships the after engine room bulkhead can be regarded as the afterpeak
bulkhead provided that the after peak adjoins the engine room.
2 In cargo ships with a raised quarter deck, it may be impracticable to extend

the afterpeak bulkhead to the freeboard deck as the freeboard deck does not extend to the aft
perpendicular. Provided that the afterpeak bulkhead extends above the deepest load line, and
that all rudderstock bearings are housed in a watertight compartment without open connection
to spaces located in front of the afterpeak bulkhead, termination of the afterpeak bulkhead on
a watertight deck lower than the freeboard deck can be accepted by the Administration.
Regulation 12.11
In cargo ships a stern tube enclosed in a watertight space of moderate volume, such as an
afterpeak tank, where the inboard end of the stern tube extends through the afterpeak/engine
room watertight bulkhead into the engine room is considered to be an acceptable solution
satisfying the requirement of this regulation, provided the inboard end of the stern tube is
effectively sealed at the afterpeak/engine room bulkhead by means of an approved
watertight/oiltight gland system.

SDC 4/16
Annex 1, page 40
REGULATION 13 – OPENINGS IN WATERTIGHT BULKHEADS BELOW THE

BULKHEAD DECK IN PASSENGER SHIPS
General – Steps in the bulkhead deck
1 If the transverse watertight bulkheads in a region of the ship are carried to a higher
deck which forms a vertical step in the bulkhead deck, openings located in the bulkhead at
the step may be considered as being located above the bulkhead deck. Such openings should
then comply with regulation 17 and should be taken into account when applying regulation 7-2.
2 All openings in the shell plating below the upper deck throughout that region of the ship
should be treated as being below the bulkhead deck and the provisions of regulation 15 should
be applied. See figure below.
1 Bulkhead deck 2 Considered as located above the bulkhead deck

3 Ship's side 4 Considered as located below the bulkhead deck
Regulation 13.2.3
1 For closed piping systems compliance with this regulation is achieved if approved
pipe penetrations are fitted at the crossing of watertight bulkheads to ensure that heat-sensitive
pipes outside the space affected by the fire remain intact, so that any flooding of the fire
affected space does not cause progressive flooding through the piping or pipe penetration.
For open piping systems compliance with this regulation is achieved if approved pipe
penetrations are fitted at the crossing of watertight bulkheads as are required for closed piping
systems, and additionally each pipe connection to a watertight compartment is fitted with an
isolation or non-return valve, as appropriate, to prevent progressive flooding through the piping
system after a fire. As an alternative to fitting an isolation or non-return valve, pipes may be
routed above the damaged waterline in such a way that progressive flooding is prevented,
taking into account the dynamic movements of the ship in a damaged condition.
However, progressive flooding may be taken into account in accordance with regulation 7-2.5.4
instead.

SDC 4/16
Annex 1, page 41
2 For the purpose of this explanatory note the following definitions apply:
A closed piping system is a piping system without openings in multiple watertight

compartments.
An open piping system is a piping system with openings in multiple watertight

compartments.
3 Materials used in systems which penetrate watertight bulkheads should be of

sufficient strength after exposure to heat or be considered as part of an open piping system.
Closing devices using intumescent material (swelling when exposed to heat) for open piping
systems should not be considered equivalent to the fitting of a valve, since the fire might be
located too far from the device to create a watertight seal.
4 Approval of pipe penetrations fitted to ensure the watertight integrity of a bulkhead

or deck where heat-sensitive materials are used should include a prototype test of
watertightness after having undergone the standard fire test appropriate for the location in
which the penetrations are to be installed1.
The fire tested pipe penetration should then be tested to a test pressure of not less than 1.5 times
the design pressure as defined in regulation 2.18. The pressure should be applied to the same
side of the division as the fire test.
The fire tested pipe penetration should be tested for a period of at least 30 minutes under
hydraulic pressure equal to the test pressure, but minimum 1.0 bar. There should be no
leakage during this test.
The fire tested pipe penetration should continue to be tested for a further 30 minutes with
the test pressure. The quantity of water leakage is not to exceed a total of 1 litre.
The prototype test should be considered valid only for the pipe typology (e.g. thermoplastic
and multilayer), pressure classes, the maximum/minimum dimensions tested, and the type and
fire rating of the division tested.
5 The pressure test need not be carried out on the hot penetration arrangement. Ample
time may be given to prepare for the pressure test, i.e. dismantling the fire testing equipment
and rigging the pressure test equipment.
The pressure test should be carried out with the pipe section used in the fire test still in place.
Any pipe insulation fitted for the purpose of the fire test may be removed before the pressure test.
Prototype testing need not be carried out if the pipe penetration is made of steel or equivalent
material having a thickness of 3 mm or greater and a length of not less than 900 mm
(preferably 450 mm on each side of the division), and there are no openings. Such penetrations
shall be suitably insulated by extension of the insulation at the same level of the division. See
also regulation II-2/9.3.1 with respect to piping. However, the penetration must still comply with
the watertight integrity requirement in regulation 2.17.
1
Refer to the requirements for A-class division set out in part 3 of annex 1 to the 2010 FTP Code.

SDC 4/16
Annex 1, page 42
Regulation 13.4
In cases where main and auxiliary propulsion machinery spaces, including boilers serving
the needs for propulsion, are divided by watertight longitudinal bulkheads in order to comply
with redundancy requirements (e.g. according to regulation 8-1.2), one watertight door in each
watertight bulkhead may be permitted, as shown in the figure below.
W.T.
W.T.
W.T.
W.T.
W.T.
REGULATION 13-1 – OPENINGS IN WATERTIGHT BULKHEADS AND INTERNAL
DECKS IN CARGO SHIPS
Regulation 13-1.1
1 If the transverse watertight bulkheads in a region of the ship are carried to a higher
deck than in the remainder of the ship, openings located in the bulkhead at the step may be
considered as being located above the freeboard deck.
2 All openings in the shell plating below the upper deck throughout that region of
the ship should be treated as being below the freeboard deck, similar to the bulkhead deck for
passenger ships (see relevant figure under regulation 13 above), and the provisions of
regulation 15 should be applied.
REGULATION 15 – OPENINGS IN THE SHELL PLATING BELOW THE BULKHEAD

DECK OF PASSENGER SHIPS AND THE FREEBOARD DECK
OF CARGO SHIPS
General – Steps in the bulkhead deck and freeboard deck
regulation 13. For the treatment of steps in the freeboard deck of cargo ships see explanatory
notes for regulation 13-1.
REGULATION 15-1 – EXTERNAL OPENINGS IN CARGO SHIPS
Regulations 15-1.1 to 15-1.3 apply to cargo ships which are subject to the damage stability
analysis required in part B-1 or other IMO instruments.
Regulation 15-1.1
With regard to air-pipe closing devices, they should be considered weathertight closing devices
(not watertight). This is consistent with their treatment in regulation 7-2.5.2.1. However, in
the context of regulation 15-1, "external openings" are not intended to include air-pipe openings.

SDC 4/16
Annex 1, page 43
REGULATION 16 – CONSTRUCTION AND INITIAL TESTS OF WATERTIGHT

CLOSURES
General
These requirements are only to establish a general design standard for watertight closures.
They are not intended to require any non-watertight hatches to be watertight, nor do they
override the requirements of the International Convention on Load Lines.
Regulation 16.2
Large doors, hatches or ramps on passenger and cargo ships, of a design and size that would
make pressure testing impracticable, may be exempted from regulation 16.2, provided it is
demonstrated by calculations that the doors, hatches or ramps maintain watertightness at
design pressure with a proper margin of resistance. Where such doors utilize gasket seals,
a prototype pressure test to confirm that the compression of the gasket material is capable of
accommodating any deflection, revealed by the structural analysis, should be carried out. After
installation every such door, hatch or ramp should be tested by means of a hose test or
equivalent.
Note: See explanatory notes for regulation 13 for additional information regarding
the treatment of steps in the bulkhead deck of passenger ships. See explanatory notes
for regulation 13-1 for additional information regarding the treatment of steps in
the freeboard deck of cargo ships.
REGULATION 17 – INTERNAL WATERTIGHT INTEGRITY OF PASSENGER SHIPS

ABOVE THE BULKHEAD DECK
General – Steps in the bulkhead deck
regulation 13.
Regulation 17.1
1 Sliding watertight doors with a reduced pressure head that are located above
the bulkhead deck and which are immersed in the final or during any intermediate stage of
flooding should comply fully with the requirements of regulation 13. These types of sliding
watertight doors tested with reduced pressure head must not be immersed at any stage of
flooding by a head of water higher than the tested pressure head. See figure 1 below. These
sliding watertight doors shall be kept closed during navigation in compliance with
the requirements of regulation 22 and this should be clearly indicated in the damage control
information required by regulation 19.
2 If watertight doors are located above the worst final and above the worst intermediate
waterline in damage cases contributing to the attained subdivision index A, but within the area
where the door becomes intermittently immersed (fully or partly) at angles of heel in the required
range of positive stability beyond the equilibrium position, such doors are to be power operated
and remotely controlled sliding semi-watertight doors complying with the requirements of
regulation 13, except that the scantlings and sealing requirements could be reduced to
the maximum head of water caused by the waterline being intermittently immersed
(see figure 1 below). These doors should be closed in case of damage and this should be
clearly indicated in the damage control information required by regulation 19.

SDC 4/16
Annex 1, page 44
Figure 1
3 The use of watertight sliding doors above the bulkhead deck affects the escape
provisions of regulation II-2/13. When such doors are used above the bulkhead deck, there
should be at least two means of escape from each main vertical zone or similarly restricted
space or group of spaces, at least one of which should be independent of watertight doors and
at least one of which should give access to a stairway forming a vertical escape. Sliding
watertight doors that will be used frequently by passengers must not create a tripping hazard.
4 Doors fitted above the bulkhead deck, which are required to meet both fire protection
and watertight requirements should comply with the fire requirements in regulation II-2/9.4.1.1
and the watertight requirements in paragraphs 1 and 2 above. Notwithstanding the ultimate
sentence of regulation II-2/9.4.1.1.2, watertight doors fitted above the bulkhead deck should
be insulated to the standard required by table 9.1 and regulation II-2/9.2.2.1.1.1. The door must
be capable of operation using both the remote fire door control circuit and the remote watertight
door control circuit. If two doors are fitted, they must be capable of independent operation.
The operation of either door separately must not preclude closing of the other door. Both doors
must be capable of being operated from either side of the bulkhead.
Regulation 17.3
This paragraph is intended to ensure that progressive flooding through air pipes of volumes
located above a horizontal division in the superstructure, which is considered as a watertight
boundary when applying regulation 7-2.6.1.1, will be taken into consideration if a side or bottom
damage would cause flooding via tanks or spaces located below the waterline.

SDC 4/16
Annex 1, page 45
REGULATION 17-1 – INTEGRITY OF THE HULL AND SUPERSTRUCTURE, DAMAGE

PREVENTION AND CONTROL ON RO-RO PASSENGER SHIPS
Regulations 17-1.1.1 and 17-1.1.3 apply only to direct accesses from a ro-ro space to spaces
located below the bulkhead deck. The operation of doors in bulkheads separating a ro-ro space
and other spaces should be limited to compliance with regulation 23.3.
Ro-ro deck Accomodation
WTD
REGULATION 22 – PREVENTION AND CONTROL OF WATER INGRESS, ETC.
The word "port" used in this regulation includes all berths and sheltered locations where
loading and/or discharging may take place.

SDC 4/16
Annex 1, page 46
APPENDIX
GUIDELINES FOR THE PREPARATION OF SUBDIVISION AND

DAMAGE STABILITY CALCULATIONS
1 GENERAL
1.1 Purpose of the Guidelines
1.1.1 These Guidelines serve the purpose of simplifying the process of the damage stability
analysis, as experience has shown that a systematic and complete presentation of the particulars
results in considerable saving of time during the approval process.
1.1.2 A damage stability analysis serves the purpose to provide proof of the damage
stability standard required for the respective ship type. At present, two different calculation
methods, the deterministic concept and the probabilistic concept are applied.
1.2 Scope of analysis and documentation on board
1.2.1 The scope of subdivision and damage stability analysis is determined by the required
damage stability standard and aims at providing the ship's master with clear intact stability
requirements. In general, this is achieved by determining KG-respective GM-limit curves,
containing the admissible stability values for the draught range to be covered.
1.2.2 Within the scope of the analysis thus defined, all potential or necessary damage
conditions will be determined, taking into account the damage stability criteria, in order to
obtain the required damage stability standard. Depending on the type and size of ship, this
may involve a considerable amount of analyses.
1.2.3 Referring to SOLAS chapter II-1, regulation 19, the necessity to provide the crew with
the relevant information regarding the subdivision of the ship is expressed, therefore plans
should be provided and permanently exhibited for the guidance of the officer in charge. These
plans should clearly show for each deck and hold the boundaries of the watertight
compartments, the openings therein with means of closure and position of any controls thereof,
and the arrangements for the correction of any list due to flooding. In addition, Damage Control
Booklets containing the aforementioned information should be available.
2 DOCUMENTS FOR SUBMISSION
2.1 Presentation of documents
The documentation should begin with the following details: principal dimensions, ship type,
designation of intact conditions, designation of damage conditions and pertinent damaged
compartments, KG-respective GM-limit curve.
2.2 General documents
For the checking of the input data, the following should be submitted:
.1 main dimensions;
.2 lines plan, plotted or numerically;

SDC 4/16
Annex 1, page 47
.3 hydrostatic data and cross curves of stability (including drawing of the buoyant
hull);
.4 definition of sub-compartments with moulded volumes, centres of gravity and

permeability;
.5 layout plan (watertight integrity plan) for the sub-compartments with all internal
and external opening points including their connected sub-compartments, and
particulars used in measuring the spaces, such as general arrangement plan
and tank plan. The subdivision limits, longitudinal, transverse and vertical,
should be included;
.6 light service condition;
.7 load line draught;
.8 coordinates of opening points with their level of tightness (e.g. weathertight,

unprotected);
.9 watertight door location with pressure calculation;
.10 side contour and wind profile;
.11 cross and down flooding devices and the calculations thereof according to
resolution MSC.362(92) with information about diameter, valves, pipe
lengths and coordinates of inlet/outlet;
.12 pipes in damaged area when the destruction of these pipes results in
progressive flooding; and
.13 damage extensions and definition of damage cases.
2.3 Special documents
The following documentation of results should be submitted.
2.3.1 Documentation
2.3.1.1 Initial data:
.1 subdivision length Ls;
.2 initial draughts and the corresponding GM-values;
.3 required subdivision index R; and
.4 attained subdivision index A with a summary table for all contributions for all
damaged zones.
2.3.1.2 Results for each damage case which contributes to the index A:
.1 draught, trim, heel, GM in damaged condition;
.2 dimension of the damage with probabilistic values p, v and r;

SDC 4/16
Annex 1, page 48
.3 righting lever curve (including GZmax and range) with factor of survivability s;
.4 critical weathertight and unprotected openings with their angle of immersion;

and
.5 details of sub-compartments with amount of in-flooded water/lost buoyancy

with their centres of gravity.
2.3.1.3 In addition to the requirements in paragraph 2.3.1.2, particulars of non-contributing

damages (si = 0 and pi > 0.00) should also be submitted for passenger ships and ro-ro ships
fitted with long lower holds including full details of the calculated factors.
2.3.2 Special consideration
For intermediate conditions, as stages before cross-flooding or before progressive flooding, an

appropriate scope of the documentation covering the aforementioned items is needed in
addition.
***

SDC 4/16
Annex 2, page 1
ANNEX 2
DRAFT AMENDMENTS TO SOLAS REGULATIONS II-1/1 AND II-1/8-1*
Regulation 1 – Application
1 The following new paragraphs 1.1.1 and 1.1.2 are inserted after the existing paragraph 1.1:
"1.1.1 Unless expressly provided otherwise, parts B, B-1, B-2 and B-4 of this
chapter shall only apply to ships:
.1 for which the building contract is placed on or after 1 January 2020;

or
.2 in the absence of a building contract, the keel of which is laid or

which are at a similar stage of construction on or after 1 July 2020;
or
.3 the delivery of which is on or after 1 January 2024.
1.1.2 Unless expressly provided otherwise, for ships not subject to the provisions
of subparagraph 1.1.1 but constructed on or after 1 January 2009,
the Administration shall:
.1 ensure that the requirements for parts B, B-1, B-2 and B-4
which are applicable under chapter II-1 of the International
Convention for the Safety of Life at Sea, 1974, as amended by
resolutions MSC.216(82), MSC.269(85) and MSC.325(90) are
complied with; and
.2 ensure that the requirements of regulations 8-1.3 and 19-1 are

complied with."
2 The existing paragraph 1.3.4 is deleted.

3 The existing paragraph 2 is replaced with the following:
"2 Unless expressly provided otherwise, for ships constructed
before 1 January 2009, the Administration shall:
.1 ensure that the requirements which are applicable under
chapter II-1 of the International Convention for the Safety of Life at
Sea, 1974, as amended by resolutions MSC.1(XLV), MSC.6(48),
MSC.11(55), MSC.12(56), MSC.13(57), MSC.19(58), MSC.26(60),
MSC.27(61), Resolution 1 of the 1995 SOLAS Conference,
MSC.47(66), MSC.57(67), MSC.65(68), MSC.69(69), MSC.99(73),
MSC.134(76), MSC.151(78) and MSC.170(79) are complied with;
and
.2 ensure that the requirements of regulations 8-1.3 and 19-1 are
complied with."
*
Tracked changes are created using "strikeout" for deleted text and "grey shading" to highlight all
modifications and new insertions, including deleted text.

SDC 4/16
Annex 2, page 2
Regulation 8-1 – System capabilities and operational information after a flooding

casualty on passenger ships
4 The existing text of regulation 8-1 is amended to read as follows:
"1 Application
Passenger ships having length, as defined in regulation II-1/2.5, of 120 m or more or

having three or more main vertical zones shall comply with the provisions of this
regulation.
2 Availability of essential systems in case of flooding damage*
A passenger ship constructed on or after 1 July 2010 shall be designed so that

the systems specified in regulation II-2/21.4 remain operational when the ship is
subject to flooding of any single watertight compartment.
3 Operational information after a flooding casualty
3.1 For the purpose of providing operational information to the Master for safe
return to port after a flooding casualty, passenger ships constructed on or after 1
January 2014, as specified in paragraph 1, shall have:
.1 on-board stability computer; or
.2 shore-based support,
based on the guidelines developed by the Organization.**
3.2 Passenger ships constructed before 1 January 2014 shall comply with
the provisions in paragraph 3.1 not later than the first renewal survey after [X years
after the date of entry into force].
__________________
*
Refer to the Interim Explanatory Notes for the assessment of passenger ship systems' capabilities
after a fire or flooding casualty (MSC.1/Circ.1369).
**
Refer to the Guidelines on operational information for Masters of passenger ships for safe return
to port by own power or under tow (MSC.1/Circ.1400) for ships constructed on or after 1 January
2014 but before 13 May 2016, or the Revised Guidelines on operational information for masters
of passenger ships for safe return to port (MSC.1/Circ.1532) for ships constructed on or after
13 May 2016, or the guidelines to be developed by the Organization for passenger ships
constructed before 1 January 2014."

SDC 4/16
Annex 2, page 3
APPENDIX 1*
CHECK/MONITORING SHEET FOR THE PROCESSING OF AMENDMENTS TO

THE CONVENTION AND RELATED MANDATORY INSTRUMENTS
(PROPOSAL/DEVELOPMENT)
Part III – Process monitoring to be completed during the work process at the
sub-committee and checked as part of the final approval process by the Committee
(Refer to section 3.2.1.3)**
1 The sub-committee, at an initial engagement, has allocated sufficient time for

technical research and discussion before the target completion date, especially
on issues needing to be addressed by more than one sub-committee and yes
for which the timing of relevant sub-committees meetings and exchanges of the
result of consideration needed to be carefully examined.
2 The scope of application agreed at the proposal stage was not changed
yes
without the approval of the Committee.
3 The technical base document/draft amendment addresses the proposal's
issue(s) through the suggested instrument(s); where it does not, the
yes
sub-committee offers the Committee an alternative method of addressing the
problem raised by the proposal.
4 Due attention has been paid to the Interim guidelines for the systematic
yes
application of the grandfather clauses (MSC/Circ.765-MEPC/Circ.315).
5 All references have been examined against the text that will be valid if the
yes
proposed amendment enters into force.
6 The location of the insertion or modified text is correct for the text that will be
valid when the proposed text enters into force on a four-year cycle of entry
yes
into force, as other relevant amendments adopted might enter into force on
the same date.
7 There are no inconsistencies in respect of scope of application between the
technical regulation and the application statement contained in regulation 1
yes
or 2 of the relevant chapter, and application is specifically addressed for
existing and/or new ships, as necessary.
8 Where a new term has been introduced into a regulation and a clear definition
is necessary, the definition is given in the article of the Convention or at the n/a
beginning of the chapter.
9 Where any of the terms "fitted", "provided", "installed" or "installation" are
used, consideration has been given to clarifying the intended meaning of the n/a
term.
*
This appendix is reproduced in English only.

SDC 4/16
Annex 2, page 4
Part III – Process monitoring to be completed during the work process at the
sub-committee and checked as part of the final approval process by the Committee
(Refer to section 3.2.1.3)**
10 All necessary related and consequential amendments to other existing

instruments, including non-mandatory instruments, in particular to the forms
of certificates and records of equipment required in the instrument being yes1
amended, have been examined and included as part of the proposed
amendment(s).
11 The forms of certificates and records of equipment have been harmonized,
n/a
where appropriate, between the Convention and its Protocols.
12 It is confirmed that the amendment is being made to a currently valid text and
yes
that no other bodies are concurrently proposing changes to the same text.
13 All entry-into-force criteria (building contract, keel laying and delivery) have
yes
been considered and addressed.
14 Other impacts of the implementation of the proposed/approved amendment
have been fully analysed, including consequential amendments to the yes
"application" and "definition" regulations of the chapter.
15 The amendments presented for adoption clearly indicate changes made with
yes
respect to the original text, so as to facilitate their consideration.
16 For amendments to mandatory instruments, the relationship between the
Convention and the related instrument has been observed and addressed, as n/a
appropriate.
17 The related record format has been completed or updated, as appropriate. yes
**
Part III should be completed by the drafting/working group that prepared the draft text using "yes", "no" or
"not applicable".
1
Consequential development of a circular has been initiated.

SDC 4/16
Annex 2, page 5
APPENDIX 2*
RECORDS FOR REGULATORY DEVELOPMENT
The following records should be created and kept updated for each regulatory development.
The records can be completed by providing references to paragraphs of related documents

containing the relevant information, proposals, discussions and decisions.
1 Title (number and title of regulation(s))

SOLAS regulations chapter II-1/1 (Application) and II-1/8-1 (System capabilities and
operational information after a flooding casualty on passenger ships).
2 Origin of the requirement (original proposal document)
MSC 94/6/1
3 Main reason for the development (extract from the proposal document)
Document MSC 92/6/3 (Italy), which provided the preliminary recommendations arising from
the Costa Concordia marine casualty investigation (paragraph 8.3), recommended to
extend, to existing passenger ships, the SOLAS requirement relating to computerized stability
support for the master in case of flooding (MSC 94/6/1, paragraph 1).
It may be assumed that a compelling "safety" need was demonstrated as part of the work to
develop the amendments to SOLAS to require ships constructed on or after 1 January 2014
to have an on-board stability computer or shore based support (MSC 96/4/1, paragraph 7).
The co-sponsors considered extending the applicability of the current provisions to also
include existing passenger ships would enhance damage stability knowledge on board
existing passenger ships (MSC 96/4/1, paragraph 7).
4 Related output
Computerized stability support for the master in case of flooding for existing passenger ships
(5.2.1.7)
5 History of the discussion (approval of work programmes, sessions of
sub-committees, including CG/DG/WG arrangements)
MSC 94 agreed to include a new output in the post-biennial agenda of the Committee on
"Computerized stability support for the master in case of flooding for existing passenger
ships", assigning the SDC Sub-Committee as the coordinating organ, with a view to including
provisions in SOLAS chapter II-1 for ships constructed before 1 January 2014 (MSC 94/21,
paragraph 18.20).
SDC 3 had no documents submitted. The Sub-Committee noted the views expressed by
the delegations of Germany and Norway that it was premature to agree on the proposed
amendments to SOLAS regulation II-1/8-1.3, as set out in annex 2 to document MSC 94/6/1,
because the scope of application of the proposed amendments still needed to be clarified,
taking into account that the current SOLAS chapter II-1 applies to ships constructed on or
after 1 January 2009 and the revised chapter II-1 will apply to ships built on or
after 1 January 2020 (see also paragraph 4.3). In addition, it was noted that MSC.1/Circ.1400
may need to be revised and that, possibly, additional guidance may need to be developed,
and this will require new outputs (SDC 3/21, paragraph 4.4).
*
This appendix is reproduced in English only.

SDC 4/16
Annex 2, page 6
SDC 4 considered two documents submitted under this output (agenda item 4) and
developed draft amendments to SOLAS regulations II-1/1 and II-1/8-1.3. The Sub-Committee
also considered the preparation of a new set of guidelines to set the acceptance criteria for
stability computers for passenger ships constructed before 1 January 2014.
6 Impact on other instruments (e.g. codes, performance standards, guidance
circulars, certificates/records format, etc.)
N/A
7 Technical background
7.1 Scope and objective (to cross check with items 4 and 5 in part II of the
checklist)
Amendments to regulations chapter II-1/1 and II-1/8-1.3 to extend the requirement for having
an on-board stability computer or shore-based support for passenger ships having length, as
defined in regulation II-1/2.5, of 120 m or more or having three or more main vertical zones,
constructed before 1 January 2014.
7.2 Technical/operational background and rationale (summary of FSA study, etc.,
if available or, engineering challenge posed, etc.)
Recommendations from the Costa Concordia casualty investigation report.
7.3 Source/derivation of requirement (non-mandatory instrument, industry
standard, national/regional requirement)
SOLAS regulation II-1/8-1.3, as adopted by resolution MSC.325(90).
7.4 Short summary of requirement (what is the new requirement – in short and lay
terms)
See paragraph 7.1 above.
7.5 Points of discussions (controversial points and conclusion)
.1 Establishment of clear application provisions in terms of dates and ships.
.2 Addressing of the difficulties faced in applying all the items provided in the Guidelines
on operational information for masters of passenger ships for safe return to port by
own power or under tow (MSC.1/Circ.1400), the Revised guidelines on operational
information for masters of passenger ships for safe return to port (MSC.1/Circ.1532),
and the Guidelines for the approval of stability instruments (MSC.1/Circ.1229) to
some existing passenger ships, which will be done by means of a new set of
guidelines.
***

SDC 4/16
Annex 3, page 1
ANNEX 3
DRAFT MSC CIRCULAR
AMENDMENTS TO SECTION 3 OF THE GUIDELINES FOR DAMAGE CONTROL PLANS

AND INFORMATION TO THE MASTER (MSC.1/CIRC.1245)
1 The Maritime Safety Committee, at its [ninety-eighth session (7 to 16 July 2017)], with
a view to improving the damage control information on board passenger ships and to positively
impacting survivability of those ships in the event of flooding, approved amendments to
the Guidelines for damage control plans and information to the master (MSC.1/Circ.1245), as
prepared by the Sub-Committee on Ship Design and Construction at its fourth session
(13 to 17 February 2017), as set out in the annex.
2 Member States are invited to use MSC.1/Circ.1245 in conjunction with the annexed
amendments when applying the requirements of SOLAS regulation II-1/19 to passenger ships
built on or after [date of approval] and to passenger ships which undergo significant alterations
on or after [date of approval] that necessitate amending the damage control information, and
to bring these amendments to the attention of all parties concerned.

SDC 4/16
Annex 3, page 2
ANNEX
AMENDMENTS TO SECTION 3 OF THE GUIDELINES FOR DAMAGE CONTROL PLANS

AND INFORMATION TO THE MASTER (MSC.1/CIRC.1245)
1 After the existing paragraph 3.2.7, the following new paragraphs 3.3 and 3.4 are
inserted as follows:
"3.3 In addition to the provisions of paragraph 3.2 above, damage control plans
of passenger ships should be prepared as follows:
.1 provide the plan in colour and ensure that it is legible when printed;
.2 provide a legend describing each symbol used within the plan;
.3 clearly identify the location of damage control equipment and

damage equipment lockers on the plan;
.4 provide compartment identification consistent with the damage

control booklet and the stability computer information, as applicable;
.5 highlight access points (stairways and ladders) as follows:
.1 indicate the compartment and deck to be accessed;
.2 indicate whether an access point represents both up and

down or only one way transit (at the bottom of the stair or
ladder); and
.3 indicate all hatches;
.6 shading of key features may be used on the damage control plan to

clearly depict essential information regarding the ship's watertight
subdivision and related equipment;
.7 depict watertight doors and semi-watertight doors;
.8 indicate the locations of sounding pipes for all spaces with a sounding
pipe, including void spaces;
.9 in addition to the bilge and ballast pumps, indicate the location of

any other relevant pumps referred to in the damage control booklet;
and
.10 the inboard profile plan should indicate the compartment boundaries
with the list of watertight closing appliances necessary to ensure
the watertight integrity of the compartment and the list of tanks and
description of spaces within the compartment (see the example
below).

SDC 4/16
Annex 3, page 3
3.4 Where fittings or equipment are common in both fire and damage control
plans of passenger ships, the graphical symbols used in damage control plans should
be in accordance with the Graphical symbols for shipboard fire control plans
(resolution A.952(23))."
***

SDC 4/16
Annex 4, page 1
ANNEX 4
DRAFT MSC CIRCULAR
UNIFIED INTERPRETATIONS OF SOLAS CHAPTER II-1
1 The Maritime Safety Committee, at its [ninety-eighth session (7 to 16 June 2017)],

with a view to providing more specific guidance on special requirements for vehicle ferries,
ro-ro ships and other ships of similar type, and on the drainage of enclosed spaces
situated on the bulkhead deck, approved the unified interpretations of SOLAS chapter II-1,
prepared by the Sub-Committee on Ship Design and Construction, at its fourth
session (13 to 17 February 2017), as set out in the annex.
2 Member States are invited to use the annexed unified interpretations as guidance
when applying SOLAS regulations II-1/17-1, II-1/20-2 and II-1/35-1, and to bring the unified
interpretations to the attention of all parties concerned.

SDC 4/16
Annex 4, page 2
ANNEX
UNIFIED INTERPRETATIONS OF SOLAS CHAPTER II-1
Regulations II-1/17-1.1.1 and II-1/20-2
1 Stern, bow and side doors of large dimensions, when manual devices would not be
readily accessible, should be normally secured by means of power systems.
2 Alternative means of securing should also be provided for emergency use in case of
failure of the power systems.
3 In ro-ro passenger ships, constructed before 1 July 1997, all access doors or
hatchways to spaces below the ro-ro deck, which may be used at sea, should have sills or
coamings not less than 380 mm in height above the ro-ro deck, and should be provided with
doors or covers considered weathertight in relation to their position, refer to SOLAS
regulation II-1/20-2.
4 For ro-ro passenger ships constructed on or after 1 July 1997 but before 1 January 2009,
refer to SOLAS regulation II-1/20-2.
5 The ro-ro deck, referred to in paragraph 3 above, is the deck above which the stern,
bow or side doors are fitted, or the first deck above the load waterline.
Regulation II-1/35-1.2.6.1
The drainage of enclosed spaces situated on the bulkhead deck to suitable spaces below
the bulkhead deck is also permitted provided such drainage is arranged in accordance with
the provisions of regulation 22(2) of the Protocol of 1988 relating to the International
Convention on Load Lines, 1966.
***

SDC 4/16
Annex 5, page 1
ANNEX 5
DRAFT MSC CIRCULAR
[MSC/Circ.686/Rev.1]
[date]
GUIDELINES ON THE MEANS OF ACCESS TO STRUCTURES FOR INSPECTION AND

MAINTENANCE OF OIL TANKERS AND BULK CARRIERS
(SOLAS REGULATION XI-1/2)
1 In the context of the Guidelines on the enhanced programme of inspections during

surveys of bulk carriers and oil tankers, adopted by Assembly resolution A.744(18),1
the Maritime Safety Committee instructed the Sub-Committee on Ship Design and Equipment
to develop requirements for access to tanks and ballast space structures.
2 At its sixty-fifth session (9 to 17 May 1995), the Committee approved Guidelines on

the means of access to structures for inspection and maintenance of oil tankers and bulk
carriers which provide recommendations on the access to tanks, cargo holds and ballast
spaces to enable the hull structure to be examined in a safe and practical way, when the overall
and close-up surveys complying with the provisions of SOLAS regulation XI/2 and
resolution A.744(18)1 are being performed.
3 At its [ninety-eighth session (7 to 16 June 2017)], the Committee approved

the amendments to the Guidelines on the means of access to structures for inspection and
maintenance of oil tankers and bulk carriers, annexed hereto.
4 Member Governments are invited to apply these Guidelines to ships constructed on

or after 1 October 1994. In the case of ships constructed before 1 October 1994, the Guidelines
should be applied in so far as the Administration deems reasonable and practicable.
1
Superseded by the 2011 ESP Code (resolution A.1049(27)).

SDC 4/16
Annex 5, page 2
ANNEX
GUIDELINES ON THE MEANS OF ACCESS TO STRUCTURES FOR INSPECTION AND

MAINTENANCE OF OIL TANKERS AND BULK CARRIERS
(SOLAS REGULATION XI-1/2)
GENERAL
1 These Guidelines provide recommendations on the access to tanks, cargo holds and
ballast spaces of oil tankers and bulk carriers, to enable the hull structure to be examined in
a safe and practical way, when performing the overall and close-up surveys required in SOLAS
regulation XI-1/2 and in the relevant parts of the International Code on the Enhanced
Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers, 2011
(2011 ESP Code), adopted by Assembly resolution A.1049(27).
2 These Guidelines recall:
.1 SOLAS regulation II-1/12-2 (as amended by resolution MSC.27(61)) on

the "Access to spaces in the cargo area of oil tankers", which applies to oil
tankers constructed on or after 1 October 1994 but before 1 January 2005;
.2 SOLAS regulation II-1/3-6 (as amended by resolution MSC.134(76)) on

the "Access to and within spaces in, and forward of, the cargo area of oil
tankers and bulk carriers", which applies to oil tankers and bulk carriers
constructed on or after 1 January 2005 but before 1 January 2006;
.3 SOLAS regulation II-1/3-6 (as amended by resolutions MSC.151(78)

and MSC.194(80)) on the "Access to and within spaces in, and forward of,
the cargo area of oil tankers and bulk carriers", which applies to oil tankers
and bulk carriers constructed on or after 1 January 2006;
.4 the "Recommendation on safe access to and working in large tanks and

recommendation on safe access to and working in large cargo holds of bulk
carriers", adopted by resolution A.272(VIII); and
.5 the "Amendment to the Recommendation on safe access to and working in

large tanks (resolution A.272(VIII), annex 1) to include large water ballast
tanks", adopted by resolution A.330(IX).
They also take into account general Principles of the ILO publication on Safety and health in
dock work.
3 These Guidelines should apply to ships constructed on or after 1 October 1994.

In case of ships constructed before 1 October 1994, the Guidelines should be applied in so far
as the Administration deems reasonable and practicable.
4 These Guidelines recommend the owner to agree with the shipyard, in consultation
with the Administration or an organization recognized by the Administration, to develop and
incorporate, at the time of construction of new oil tankers or bulk carriers, secure and practical
means of access to tanks, ballast spaces and cargo holds for an efficient and effective
inspection and maintenance, taking into consideration the following aspects.

SDC 4/16
Annex 5, page 3
5 Safe access to enclosed spaces can only be provided if an adequate standard of

cleaning, ventilation and testing is achieved prior to entry.*
ACCESS TO AND WITHIN TANKS AND DOUBLE HULL SPACES OF OIL TANKERS
Access from weather deck
6 Tanks, and subdivision of tanks, having lengths of 35 m and above, should be fitted
with at least two access hatchways and ladders, as far apart as practicable longitudinally.
Where the tanks are of confined construction, two separate means of access from the weather
deck are recommended, one each at either end of the tank space.
7 Access to cofferdams, vertical wing and double bottom space of ballast tanks, cargo
tanks and other spaces in the cargo area should be direct from the open deck and such as to
ensure their complete inspection. Access to double bottom spaces, particularly with regard to
double hull tankers, may be interpreted to include a ladder/platform arrangement that leads
from the open deck to the double bottom space through the double hull space. Access to
double bottom spaces may be through a cargo pump-room, pump-room, deep cofferdam, pipe
tunnel or similar compartments, subject to consideration of ventilation aspects.
Accessibility for personnel safety and inspection
8 The dimensions of any access hatchway should be sufficient to allow a person

wearing a self-contained breathing apparatus to ascend or descend the ladder without
obstruction and also to provide a clear opening to facilitate the removal of an injured person
from the space. Alternatively, one of the deck access hatches can be enlarged and fitted with
a hinged top ladder and with clear vertical straight access down to the tank bottom.
9 For access through horizontal openings, hatches and manholes, the minimum clear
opening should be not less than 600 mm by 600 mm. Openings of 600 mm by 600 mm
minimum clearance, or larger, should be provided in each horizontal girder in vertical alignment
within the vertical wing space. The term minimum clear opening of not less than 600 mm
by 600 mm means that such openings may have corner radii up to 100 mm maximum, due
regard being given to stress concentration.
10 Any opening or open hatchway larger than 200 mm diameter on bulkhead stringers
and horizontal girders should be fitted with gratings or safety guide rails of adequate design
and construction. The free edge of walkways, bulkhead stringers and horizontal girders should
be fitted with two-tier guide rails and vertical plate at least 50 mm high around edge of platform
except in way of ladder. Guide rails or fencing should be free from sharp edges and should
consist of an upper rail at a height of 900 mm and an intermediate rail at a height of 500 mm.
The rails may, where necessary, consist of taut wire or taut chain. Step rungs and grip rails
should be provided on inclined or curved surfaces to assist footing.
11 For access through vertical openings, or manholes providing passage through

the length and breadth of the space, the minimum clear opening should be not less than 600 mm
by 800 mm, at a height of not more than 600 mm from the bottom shell plating or stringer
unless gratings or other footholds are provided. Such openings should be provided with grab
bars. The term minimum clear opening of not less than 600 mm by 800 mm also includes an
opening with corner radii of 300 mm. For inspection purposes, an adequate number of vertical
access openings should be provided.
*
Refer to the Revised recommendations for entering enclosed spaces aboard ships (resolution A.1050(27)).

SDC 4/16
Annex 5, page 4
12 Smaller dimensions may be approved by the Administration in accordance with SOLAS

regulation II-1/12-2.5 or regulation II-1/3-6.5.3, as applicable.
Access methods for inspection of tank structures
13 The access methods for the inspection of tank structures may include:
.1 permanent access arrangement such as:
.1 the fitting of permanent staging;
.2 the fitting of bulkhead stringers as walkways;
.3 the fitting of horizontal girders as walkways;
.4 the fitting of independent horizontal walkways;
.5 the use of enlarged longitudinal girders as walkways;
.6 the fitting of step rungs on face plates of longitudinal girders;
.7 the fitting of vertical climbing rails on face plates of longitudinal

girders;
.8 the fitting of vertical or inclined ladders on face plates of longitudinal

girders;
.9 the fitting of vertical and inclined ladders on transverse bulkheads;*
.10 the fitting of step rungs and grip rails on inclined or curved surfaces;
and
.11 the fitting of permanent lugs, clips and pad eyes for temporary
staging or portable staging support;
.2 temporary staging;
.3 portable staging/mobile platform/mechanical arms;
.4 temporary/portable ladder;
.5 rafting;
.6 remotely operated vehicles;
.7 use of divers; and
.8 remotely-operated video system.
*
Refer to recognized standards for inspection and maintenance of lifting equipment.

SDC 4/16
Annex 5, page 5
Inspection in cargo tanks
14 Rafting and climbing are possible in open type cargo tanks. However, it is
recommended that the following should also be provided:
.1 Permanent staging and/or walkway at strategic locations below the deckhead

to monitor possible structural fractures and corrosion.
.2 Permanent walkways along the longitudinal and transverse bulkheads.
.3 Large access openings in swash bulkheads and centreline and side girders
for raft passage, where feasible. Alternatively, large deck access hatches
should be provided on both sides of the swash bulkhead.
Inspection in vertical wing spaces
15 Rafting in the double hull vertical wing space is not considered practical and is
deemed unsafe. Permanent access arrangements, therefore, should be provided.
16 Permanent horizontal walkways with clear width of 600 mm or greater, positioned at

intervals harmonized with the design of ship's structures, should give an adequate coverage
for inspection purposes. These may be formed by horizontal girders or enlarged longitudinal
girders, as opposed to purpose-built walkways. Such permanent walkways could be
incorporated in the design of the ship's structures during the design stage.
17 Step rungs, grab bars and vertical ladders should be considered only as secondary
means to assist in reaching those vertical areas which cannot readily be visually inspected
from the walkways. These should also be limited to 3 m to 4 m extent.
ACCESS TO AND WITHIN CARGO HOLDS OF BULK CARRIERS
Access to cargo holds
18 If separate hatches are used to access the ladders required in each cargo hold, each
hatch should have a clear opening of at least 600 mm by 600 mm. The access hatch and
associated ladders should, unless used solely for inspection and maintenance and not for
operational access, be located such that a person using them will not enter the volume defined
by the vertical projection upwards and downwards of the uppermost cargo hatchway. Accesses
and ladders should be so arranged that personnel equipped with self-contained breathing
apparatus may readily enter and leave the cargo hold. Access hatch coamings having a height
greater than 450 mm should be fitted with steps or footholds inside the coaming and, if greater
than 900 mm, should also have steps on the outside in conjunction with cargo hold ladders.
Access within cargo holds and ballast tanks
19 Each cargo hold should be provided with at least two ladders as far apart as
practicable longitudinally. If possible, these ladders should be arranged diagonally, e.g. one
ladder near the forward bulkhead on the port side, the other one near the aft bulkhead on
the starboard side, from the ship's centreline. Ladders should be so designed and arranged
that the risk of damage from the cargo handling gear is minimized.

SDC 4/16
Annex 5, page 6
20 Vertical ladders should be at an angle of not less than 70 degrees to the horizontal
and should comprise one or more ladder linking platforms spaced not more than 6 m apart
vertically and displaced to one side of the ladder. Adjacent sections of ladder should be laterally
offset from each other by at least the width of the ladder.
21 Tunnels passing through cargo holds should be equipped with ladders or steps at
each end of the hold so that personnel may easily get across such tunnels.
22 Where it may be necessary for work to be carried out within a cargo hold or ballast
tanks, consideration should be given to suitable arrangements for the safe handling of staging
or movable platforms. Such staging and platforms should always be adequately supported and
fitted with handrails. Planks should be free from splits and lashed down. In topside and lower
hopper tanks, it may be necessary to arrange staging to provide close-up examination of
the upper parts of the tank, particularly the transverse web frames, especially where protective
coatings have broken down or have not been applied.
23 Hydraulic arm vehicles ("Cherry Pickers") may be used for close-up examination of
the cargo hold bulkheads and the upper parts of the cargo hold structure. The standing platform
should be fitted with a safety harness. For those vehicles equipped with a self-levelling
platform, care should be taken so that the locking device is engaged after completion of
manoeuvring to ensure that the platform is fixed.
24 Extending/articulated ladders (frame walk) may be used to enable close-up

examination of both the lower and upper portions of side shell frames and end brackets. These
ladders incorporate a hydraulic locking system and a built-in safety harness. Portable
equipment requires regular maintenance and inspection and this should be confirmed prior to
its use.
25 When a short portable ladder is used to gain access to the lower portion of the side
shell plating, frames and lower brackets, they should be fitted with adjustable feet, lashings or
other safe means, to prevent them from slipping and falling.
***

SDC 4/16
Annex 6, page 1
ANNEX 6
DRAFT MSC CIRCULAR
UNIFIED INTERPRETATIONS OF SOLAS CHAPTERS II-1 AND XII, OF THE TECHNICAL

PROVISIONS FOR MEANS OF ACCESS FOR INSPECTIONS (RESOLUTION MSC.158(78))
AND OF THE PERFORMANCE STANDARDS FOR WATER LEVEL DETECTORS ON BULK
CARRIERS AND SINGLE HOLD CARGO SHIPS OTHER THAN BULK CARRIERS
(RESOLUTION MSC.188(79))
1 The Maritime Safety Committee, at its ninety-second session (12 to 21 June 2013),
approved unified interpretations of the provisions of SOLAS chapters II-1 and XII, of
the Technical provisions for means of access for inspections (resolution MSC.158(78)) and
of the Performance standards for water level detectors on bulk carriers and single hold
cargo ships other than bulk carriers (resolution MSC.188(79)), as set out in the annex
to MSC.1/Circ.1464/Rev.1 and in Corr.1, following the recommendations made by
the Sub-Committee on Ship Design and Equipment at its fifty-seventh session, with a view to
ensuring a uniform approach towards the application of the provisions of SOLAS chapters II-1
and XII.
2 The Maritime Safety Committee, at its ninety-fifth session (3 to 12 June 2015), with a view
to providing more specific guidance on the application of SOLAS regulation II-1/3-6.3.1, as amended,
and the revised Technical provisions for means of access for inspections (resolution MSC.158(78)),
approved amendments to the Unified interpretations of the provisions of SOLAS chapters II-1
and XII, of the Technical provisions for means of access for inspections
(resolution MSC.158(78)) and of the Performance standards for water level detectors on bulk
carriers and single hold cargo ships other than bulk carriers (resolution MSC.188(79))
(MSC.1/Circ.1464/Rev.1), as prepared by the Sub-Committee on Ship Design and Construction, at
its second session (16 to 20 February 2015), as set out in the annex to MSC.1/Circ.1507.
3 The Maritime Safety Committee, at its ninety-sixth session (11 to 20 May 2016), approved
the Unified interpretations relating to the application of SOLAS regulation II-1/3-6, as amended,
and the Revised technical provisions for means of access for inspections (resolution MSC.158(78)),
prepared by the Sub-Committee on Ship Design and Construction, at its third session
(18 to 22 January 2016), as set out in the annex to MSC.1/Circ.1545, with a view to ensuring
a uniform approach towards the application of the provisions of SOLAS regulation II-1/3-6.
Having approved MSC.1/Circ.1545 and considered the need to consequentially
amend MSC.1/Circ.1464/Rev.1 and its Corr.1, as amended by MSC.1/Circ.1507,
the Committee requested the Secretariat to prepare a consolidated MSC circular containing
the provisions of MSC.1/Circ.1464/Rev.1 and Corr.1, as amended by MSC.1/Circ.1507,
and MSC.1/Circ.1545.
4 The Maritime Safety Committee, at its [ninety-eighth session (7 to 16 July 2017)],

approved the Unified interpretations of the provisions of SOLAS chapters II-1 and XII, of
the Revised technical provisions for means of access for inspections (resolution MSC.158(78))
and of the Performance standards for water level detectors on bulk carriers and single hold
cargo ships other than bulk carriers (resolution MSC.188(79)), containing the provisions
of MSC.1/Circ.1464/Rev.1 and Corr.1, as amended by MSC.1/Circ.1507, and MSC.1/Circ.1545,
as set out in the annex.
5 Member States are invited to use the annexed interpretations when applying relevant
provisions of SOLAS chapters II-1 and XII to ships constructed on or after [date of approval],
and to bring them to the attention of all parties concerned.

SDC 4/16
Annex 6, page 2
ANNEX

AND OF THE PERFORMANCE STANDARDS FOR WATER LEVEL DETECTORS ON
BULK CARRIERS AND SINGLE HOLD CARGO SHIPS OTHER THAN
BULK CARRIERS (RESOLUTION MSC.188(79))
Table of contents
1 SOLAS regulation II-1/3-6 – Access to and within spaces in, and forward of, the cargo
area of oil tankers and bulk carriers
2 Technical provisions for means of access for inspections (resolution MSC.158(78))
3 SOLAS chapter II-1, parts B-2 – Subdivision, watertight and weathertight integrity –
and B-4 – Stability management
4 SOLAS regulation II-1/26 – General
5 SOLAS regulations II-1/40 – General – and II-1/41 – Main source of electrical power
and lighting systems
6 SOLAS regulation II-1/41 – Main source of electrical power and lighting systems
7 SOLAS regulations II-1/42 and II-1/43 – Emergency source of electrical power in

passenger and cargo ships
8 SOLAS regulation II-1/44 – Starting arrangements for emergency generating sets
9 SOLAS regulation XII/12 – Hold, ballast and dry space water ingress alarms, including
the Performance standards for water level detectors on bulk carriers and single hold
cargo ships other than bulk carriers (resolution MSC.188(79))
10 SOLAS regulation XII/13 – Availability of pumping systems

SDC 4/16
Annex 6, page 3
1 SOLAS REGULATION II-1/3-6 – ACCESS TO AND WITHIN SPACES IN, AND

FORWARD OF, THE CARGO AREA OF OIL TANKERS AND BULK CARRIERS
1.1 SOLAS REGULATION II-1/3-6, SECTION 1
Interpretation
Oil tankers
This regulation is only applicable to oil tankers having integral tanks for carriage of oil in bulk,
which is contained in the definition of oil in Annex I of MARPOL. Independent oil tanks can be
excluded. Regulation II-1/3-6 should not normally be applied to FPSO or FSU unless
the Administration decides otherwise.
Technical background
Means of Access (MA) specified in the Technical provisions contained in resolution MSC.158(78)
are not specific with respect to the application to integral cargo oil tanks or also to independent
cargo oil tanks. Enhanced survey programme (ESP) requirements of oil tankers have been
established assuming the target cargo oil tanks are integral tanks. The MA regulated under
SOLAS regulation II-1/3-6 is for overall and close-up inspections as defined in regulation IX/1.
Therefore it is assumed that the target cargo oil tanks are those of ESP, i.e. integral cargo
tanks. Regulation II-1/3-6 is applicable to new, purpose-built FPSO or FSU if they are subject
to the scope of the 2011 ESP Code (resolution A.1049(27), as amended). Considering that
the principles of the Technical provisions for means of access for inspections
(resolution MSC.158(78)) recognize that permanent means of access should be considered
and provided for at the design stage so that, to the maximum extent possible, they can be
made an integral part of the designed structural arrangement, regulation II-1/3-6 is not
considered applicable to an FPSO/FSU that is converted from an existing tanker.
Reference
SOLAS regulation IX/1 and the 2011 ESP Code, as amended.
1.2 SOLAS REGULATION II-1/3-6, PARAGRAPH 2.1
Interpretation
Each space for which close-up inspection is not required such as fuel oil tanks and void spaces
forward of cargo area, may be provided with a means of access necessary for overall survey
intended to report on the overall conditions of the hull structure.
Interpretation
Some possible alternative means of access are listed under paragraph 3.9 of the Technical
provisions for means of access for inspections (TP). Always subject to acceptance as
equivalent by the Administration, alternative means such as an unmanned robot arm, ROVs
and dirigibles with necessary equipment of the permanent means of access for overall and
close-up inspections and thickness measurements of the deck head structure such as deck
transverses and deck longitudinals of cargo oil tanks and ballast tanks, should be capable of:
.1 safe operation in ullage space in gas-free environment; and
.2 introduction into the place directly from a deck access.

SDC 4/16
Annex 6, page 4
Innovative approaches, in particular a development of robots in place of elevated

passageways, are encouraged and it is considered worthwhile to provide the functional
requirement for the innovative approach.
Interpretation
Inspection
The MA arrangements, including portable equipment and attachments, should be periodically

inspected by the crew or competent inspectors as and when it is going to be used to confirm
that the MAs remain in serviceable condition.
Procedures
1 Any Company authorized person using the MA should assume the role of inspector
and check for obvious damage prior to using the access arrangements. Whilst using the MA,
the inspector should verify the condition of the sections used by close-up examination of those
sections and note any deterioration in the provisions. Should any damage or deterioration be
found, the effect of such deterioration should be assessed as to whether the damage or
deterioration affects the safety for continued use of the access. Deterioration found that is
considered to affect safe use should be determined as "substantial damage" and measures
should be put in place to ensure that the affected section(s) are not to be further used prior to
effective repair.
2 Statutory survey of any space that contains MA should include verification of

the continued effectiveness of the MA in that space. Survey of the MA should not be expected
to exceed the scope and extent of the survey being undertaken. If the MA is found deficient
the scope of survey should be extended if this is considered appropriate.
3 Records of all inspections should be established based on the requirements detailed

in the ship's Safety Management System. The records should be readily available to persons
using the MAs and a copy attached to the MA Manual. The latest record for the portion of
the MA inspected should include as a minimum the date of the inspection, the name and title
of the inspector, a confirmation signature, the sections of MA inspected, verification of
continued serviceable condition or details of any deterioration or substantial damage found.
A file of permits issued should be maintained for verification.
It is recognized that MA may be subject to deterioration in the long term due to corrosive
environment and external forces from ship motions and sloshing of liquid contained in the tank.
MA therefore should be inspected at every opportunity of tank/space entry. The above
interpretation should be contained in a section of the MA Manual.

SDC 4/16
Annex 6, page 5
Interpretation
1 Access to a double-side skin space of bulk carriers may be either from a topside tank
or double-bottom tank or from both.
2 The wording "not intended for the carriage of oil or hazardous cargoes" applies only
to "similar compartments", i.e. safe access can be through a pump-room, deep cofferdam, pipe
tunnel, cargo hold or double-hull space.
Unless used for other purposes, the double-side skin space should be designed as a part of
a large U-shaped ballast tank and such space should be accessed through the adjacent part
of the tank, i.e. topside tank or double-bottom/bilge hopper tank. Access to the double-side
skin space from the adjacent part rather than direct from the open deck is justified. Any such
arrangement should provide a directly routed, logical and safe access that facilitates easy
evacuation of the space.
Interpretation
1 A cargo oil tank of less than 35 m length without a swash bulkhead requires only one
access hatch.
2 Where rafting is indicated in the ship structures access manual as the means to gain
ready access to the under-deck structure, the term "similar obstructions" referred to in
the regulation includes internal structures (e.g. webs > 1.5 m deep) which restrict the ability to
raft (at the maximum water level needed for rafting of under-deck structure) directly to
the nearest access ladder and hatchway to deck. When rafts or boats alone, as an alternative
means of access, are allowed under the conditions specified in the 2011 ESP Code, permanent
means of access are to be provided to allow safe entry and exit. This means:
.1 access direct from the deck via a vertical ladder and small platform fitted
approximately 2 m below the deck in each bay; or
.2 access to the deck from a longitudinal permanent platform having ladders to

the deck in each end of the tank. The platform should, for the full length of
the tank, be arranged in level with, or above, the maximum water level needed
for rafting of the under-deck structure. For this purpose, the ullage
corresponding to the maximum water level is to be assumed not more
than 3 m from the deck plate measured at the midspan of deck transverses
and in the middle length of the tank (see figure below). A permanent means
of access from the longitudinal permanent platform to the water level
indicated above should be fitted in each bay (e.g. permanent rungs on one
of the deck webs inboard of the longitudinal permanent platform).

SDC 4/16
Annex 6, page 6
Interpretation
1 The access manual should address spaces listed in paragraph 3 of regulation II-1/3-6.
As a minimum the English version should be provided. The ship structure access manual
should contain at least the following two parts:
Part 1: Plans, instructions and inventory required by paragraphs 4.1.1 to 4.1.7 of

regulation II-1/3-6. This part should be approved by the Administration or
the organization recognized by the Administration.
Part 2: Form of record of inspections and maintenance, and change of inventory of

portable equipment due to additions or replacement after construction. This part
should be approved for its form only at new building.
2 The following matters should be addressed in the ship structure access manual:
.1 the access manual should clearly cover scope as specified in the regulations
for use by crews, surveyors and port State control officers;
.2 approval/re-approval procedure for the manual, i.e. any changes of

the permanent, portable, movable or alternative means of access within
the scope of the regulation and the Technical provisions are subject to review
and approval by the Administration or by the organization recognized by
the Administration;
.3 verification of MA should be part of the safety construction survey for

continued effectiveness of the MA in that space which is subject to
the statutory survey;
.4 inspection of MA by the crew and/or a competent inspector of the company

as a part of regular inspection and maintenance (see interpretation of
paragraph 2.3 of SOLAS regulation II-1/3-6);

SDC 4/16
Annex 6, page 7
.5 actions to be taken if MA is found unsafe to use; and
.6 in case of use of portable equipment plans showing the means of access

within each space indicating from where and how each area in the space can
be inspected.
Interpretation
1 Critical structural areas should be identified by advanced calculation techniques for

structural strength and fatigue performance, if available, and feedback from the service history
and design development of similar or sister ships.
2 Reference should be made to the following publications for critical structural areas,
where applicable:
.1 Oil tankers: Guidance Manual for Tanker Structures by TSCF;
.2 Bulk carriers: Bulk Carriers Guidelines for Surveys, Assessment and Repair
of Hull Structure by IACS; and
.3 Oil tankers and bulk carriers: the 2011 ESP Code (resolution A.1049(27), as
amended).
These documents contain the relevant information for the present ship types. However,
identification of critical areas for new double-hull tankers and double-side skin bulk carriers of
improved structural design should be made by structural analysis at the design stage, this
information should be taken into account to ensure appropriate access to all identified critical
areas.
Interpretation
The minimum clear opening of 600 mm x 600 mm may have corner radii up to 100 mm
maximum. The clear opening is specified in MSC/Circ.686 to keep the opening fit for passage
of personnel wearing a breathing apparatus. In such a case where as a consequence of
structural analysis of a given design the stress should be reduced around the opening, it is
considered appropriate to take measures to reduce the stress such as making the opening
larger with increased radii, e.g. 600 x 800 with 300 mm radii, in which a clear opening
of 600 x 600 mm with corner radii up to 100 mm maximum fits.
The interpretation is based upon the established Guidelines in MSC/Circ.686.
Reference
Paragraph 9 of the annex to MSC/Circ.686.

SDC 4/16
Annex 6, page 8
Interpretation
1 The minimum clear opening of not less than 600 mm x 800 mm may also include an
opening with corner radii of 300 mm. An opening of 600 mm in height x 800 mm in width may be
accepted as access openings in vertical structures where it is not desirable to make large
openings in the structural strength aspects, i.e. girders and floors in double-bottom tanks.
2 Subject to verification of easy evacuation of an injured person on a stretcher

the vertical opening 850 mm x 620 mm with wider upper half than 600 mm, while the lower half
may be less than 600 mm with the overall height not less than 850 mm is considered
an acceptable alternative to the traditional opening of 600 mm x 800 mm with corner radii
of 300 mm.
3 If a vertical opening is at a height of more than 600 mm steps then handgrips should
be provided. In such arrangements it should be demonstrated that an injured person can be
easily evacuated.
The interpretation is based upon the established Guidelines in MSC/Circ.686 and an innovative
design is considered for easy access by humans through the opening.
Reference
2 TECHNICAL PROVISIONS FOR MEANS OF ACCESS FOR INSPECTIONS

(RESOLUTION MSC.158(78))
2.1 PARAGRAPH 1.3
Interpretation
A "combined chemical/oil tanker complying with the provisions of the IBC Code" is a tanker
that holds both a valid IOPP certificate as a tanker and a valid certificate of fitness for
the carriage of dangerous chemicals in bulk, i.e. a tanker that is certified to carry both oil
cargoes under MARPOL Annex I and Chemical cargoes in chapter 17 of the IBC Code either
as full or part cargoes. The Technical provisions should be applied to ballast tanks of combined
chemical/oil tankers complying with the provisions of the IBC Code.

SDC 4/16
Annex 6, page 9
2.2 PARAGRAPH 1.4
Interpretation
1 In the context of the above requirement, the deviation should be applied only to
distances between integrated PMA that are the subject of paragraph 2.1.2 of table 1.
2 Deviations should not be applied to the distances governing the installation of

under-deck longitudinal walkways and dimensions that determine whether permanent access is
required or not, such as height of the spaces and height to elements of the structure
(e.g. cross-ties).
2.3 PARAGRAPH 3.1
Interpretation
The permanent means of access to a space can be credited for the permanent means of
access for inspection.
The Technical provisions specify means of access to a space and to hull structure for carrying
out overall and close-up surveys and inspections. Requirements of MA to hull structure may
not always be suitable for access to a space. However, if the MA for access to a space can
also be used for the intended surveys and inspections such MA can be credited for the MA for
use for surveys and inspections.
2.4 PARAGRAPH 3.3
Interpretation
1 Sloping structures are structures that are sloped by 5 or more degrees from horizontal
plane when a ship is in an upright position at even-keel.
2 Guard rails should be fitted on the open side and should be at least 1,000 mm in
height. For stand-alone passageways guard rails should be fitted on both sides of these
structures. Guardrail stanchions are to be attached to the PMA. The distance between
the passageway and the intermediate bar and the distance between the intermediate bar and
the top rail should not be more than 500 mm.
3 Discontinuous top handrails are allowed, provided the gap does not exceed 50 mm.
The same maximum gap is to be considered between the top handrail and other structural
members (i.e. bulkhead, web frame, etc.). The maximum distance between the adjacent
stanchions across the handrail gaps is to be 350 mm where the top and mid handrails are not
connected together and 550 mm when they are connected together. The maximum distance
between the stanchion and other structural members is not to exceed 200 mm where the top
and mid handrails are not connected together and 300 mm when they are connected together.
When the top and mid handrails are connected by a bent rail, the outside radius of the bent
part is not to exceed 100 mm (see figure below).

SDC 4/16
Annex 6, page 10
4 Non-skid construction is such that the surface on which personnel walks provides
sufficient friction to the sole of boots even if the surface is wet and covered with thin sediment.
5 "Substantial construction" is taken to refer to the as-designed strength as well as

the residual strength during the service life of the vessel. Durability of passageways together
with guard rails should be ensured by the initial corrosion protection and inspection and
maintenance during services.
6 For guard rails, use of alternative materials such as GRP should be subject to
compatibility with the liquid carried in the tank. Non-fire resistant materials should not be used
for means of access to a space with a view to securing an escape route at a high temperature.
7 Requirements for resting platforms placed between ladders should be equivalent to

those applicable to elevated passageways.
Reference
2.5 PARAGRAPH 3.4
Interpretation
Where the vertical manhole is at a height of more than 600 mm above the walking level, it
should be demonstrated that an injured person can be easily evacuated.
2.6 PARAGRAPH 3.5
Interpretation
MA for access to ballast tanks, cargo tanks and spaces other than fore peak tanks:
For oil tankers:
1 Tanks and subdivisions of tanks having a length of 35 m or more with two access
hatchways:
First access hatchway: Inclined ladder or ladders should be used.

SDC 4/16
Annex 6, page 11
Second access hatchway:
.1 A vertical ladder may be used. In such a case where the vertical distance is
more than 6 m, vertical ladders should comprise one or more ladder-linking
platforms spaced not more than 6 m apart vertically and displaced to one
side of the ladder.
The uppermost section of the vertical ladder, measured clear of the overhead
obstructions in the way of the tank entrance, should not be less than 2.5 m but
not exceed 3.0 m and should comprise a ladder-linking platform which should
be displaced to one side of a vertical ladder. However, the vertical distance of
the uppermost section of the vertical ladder may be reduced to 1.6 m,
measured clear of the overhead obstructions in the way of the tank entrance,
if the ladder lands on a longitudinal or athwartship permanent means of access
fitted within that range. Adjacent sections of the ladder should be laterally
offset from each other by at least the width of the ladder (see paragraph 20
of MSC/Circ.686/Rev.1 and refer to the interpretation of Technical Provision,
resolution MSC.158(78), paragraphs 3.13.2 and 3.13.6); or
.2 Where an inclined ladder or combination of ladders is used for access to

the space, the uppermost section of the ladder, measured clear of
the overhead obstructions in the way of the tank entrance, should be vertical
for not less than 2.5 m but not exceed 3.0 m and should comprise a landing
platform continuing with an inclined ladder. However, the vertical distance of
the uppermost section of the vertical ladder may be reduced to 1.6 m,
measured clear of the overhead obstructions in the way of the tank entrance,
if the ladder lands on a longitudinal or athwartship permanent means of
access fitted within that range. The flights of the inclined ladders are normally
to be not more than 6 m in vertical height. The lowermost section of
the ladders may be vertical for the vertical distance not exceeding 2.5 m.
2 Tanks less than 35 m in length and served by one access hatchway: an inclined ladder
or combination of ladders should be used to the space as specified in 1.2 above.
3 In spaces of less than 2.5 m in width the access to the space may be by means
of vertical ladders that comprise one or more ladder-linking platforms spaced not more
than 6 m apart vertically and displaced to one side of the ladder. The uppermost section of
the vertical ladder, measured clear of the overhead obstructions in the way of the tank
entrance, should not be less than 2.5 m but not exceed 3.0 m and should comprise
a ladder-linking platform which should be displaced to one side of a vertical ladder. However,
the vertical distance of the uppermost section of the vertical ladder may be reduced to 1.6 m,
measured clear of the overhead obstructions in the way of the tank entrance, if the ladder lands
on a longitudinal or athwartship permanent means of access fitted within that range. Adjacent
sections of the ladder should be laterally offset from each other by at least the width of
the ladder (see paragraph 20 of MSC/Circ.686/Rev.1 and refer to the interpretation of
Technical Provision, resolution MSC.158(78), paragraphs 3.13.2 and 3.13.6).
4 Access from the deck to a double-bottom space may be by means of vertical ladders
through a trunk. The vertical distance from deck to a resting platform, between resting
platforms, or a resting platform and the tank bottom should not be more than 6 m, unless
otherwise approved by the Administration.

SDC 4/16
Annex 6, page 12
MA for inspection of the vertical structure of oil tankers:
Vertical ladders provided for means of access to the space may be used for access for
inspection of the vertical structure.
Unless stated otherwise in table 1 of TP, vertical ladders that are fitted on vertical structures for
inspection should comprise one or more ladder-linking platforms spaced not more than 6 m apart
vertically and displaced to one side of the ladder. Adjacent sections of ladder should be laterally
offset from each other by at least the width of the ladder (see paragraph 20 of
MSC/Circ.686/Rev.1 and refer to the interpretation of Technical Provision, resolution
MSC.158(78), paragraphs 3.13.2 and 3.13.6).
Obstruction distances
The minimum distance between the inclined ladder face and obstructions, i.e. 750 mm and, in
the way of openings, 600 mm specified in TP 3.5 should be measured perpendicular to the face
of the ladder.
It is common practice to use a vertical ladder from the deck to the first landing to clear overhead
obstructions before continuing to an inclined ladder or a vertical ladder displaced to one side
of the first vertical ladder.
Reference
For vertical ladders: paragraph 20 of the annex to MSC/Circ.686/Rev.1.
2.7 PARAGRAPH 3.6
Interpretation
1 The vertical height of handrails should not be less than 890 mm from the centre of
the step and two course handrails need only be provided where the gap between the stringer
and the top handrail is greater than 500 mm.
2 The requirement of two square bars for treads specified in TP, paragraph 3.6, is based
upon the specification of the construction of ladders in paragraph 3(e) of annex 1 to
resolution A.272(VIII), which addresses inclined ladders. TP, paragraph 3.4, allows for single
rungs fitted to vertical surfaces, which is considered a safe grip. For vertical ladders, when
steel is used, the rungs should be formed of single square bars of not less than 22 mm by 22 mm
for the sake of safe grip.
3 The width of inclined ladders for access to a cargo hold should be at least 450 mm to
comply with the Australian AMSA Marine Orders part 32, appendix 17.
4 The width of inclined ladders other than an access to a cargo hold should be not less
than 400 mm.
5 The minimum width of vertical ladders should be 350 mm and the vertical distance
between the rungs should be equal and should be between 250 mm and 350 mm.
6 A minimum climbing clearance in width should be 600 mm other than the ladders
placed between the hold frames.

SDC 4/16
Annex 6, page 13
7 The vertical ladders should be secured at intervals not exceeding 2.5 m apart
to prevent vibration.
1 TP, paragraph 3.6, is a continuation of TP, paragraph 3.5, which addresses inclined
ladders. Interpretations for vertical ladders are needed based upon the current standards
of IMO, AMSA or the industry.
2 Interpretations 2 and 5 address vertical ladders based upon the current standards.
3 Double square bars for treads become too large for a grip for vertical ladders and
single rungs facilitate a safe grip.
4 Interpretation 7 is introduced consistently with the requirement and the interpretation

of TP, paragraph 3.4.
Reference
1 Annex 1 to resolution A.272(VIII).
2 Australian AMSA Marine Orders part 32, appendix 17.
3 ILO Code of Practice Safety and health in dock work – section 3.6, Access to ship's
hold.
2.8 PARAGRAPH 3.9.6
Interpretation
A mechanical device such as hooks for securing at the upper end of a ladder should be
considered as an appropriate securing device if a movement fore/aft and sideways can be
prevented at the upper end of the ladder.
Innovative design should be accepted if it fits the functional requirement with due consideration
for safe use.
2.9 PARAGRAPHS 3.10 AND 3.11
Interpretation
See interpretation for paragraphs 5.1 and 5.2 of SOLAS regulation II-1/3-6.
2.10 PARAGRAPH 3.13.1
Interpretation
1 Either a vertical or an inclined ladder or a combination of them may be used for access
to a cargo hold where the vertical distance is 6 m or less from the deck to the bottom of
the cargo hold.
2 Deck is defined as "weather deck".

SDC 4/16
Annex 6, page 14
2.11 PARAGRAPHS 3.13.2 AND 3.13.6
Adjacent sections of vertical ladder should to be installed so that the following provisions are
complied with:
- the minimum "lateral offset" between two adjacent sections of vertical ladder, is
the distance between the sections, upper and lower, so that the adjacent stringers
are spaced of at least 200 mm, measured from half thickness of each stringer.
- adjacent sections of vertical ladder should be installed so that the upper end of
the lower section is vertically overlapped, in respect to the lower end of the upper
section, to a height of 1500 mm in order to permit a safe transfer between ladders.
- no section of the access ladder should be terminated directly or partly above an

access opening.

SDC 4/16
Annex 6, page 15
Figure "A"
Vertical Ladder – Ladder through the linking platform
Upper Section of Vertical Ladder
≥A
≥A
≥ B (mm)
Linking platform Lower Section of Vertical Ladder
Dimension
Horizontal separation
A between two vertical ≥ 200 mm
ladders, stringer to stringer
Stringer height above
B landing or intermediate ≥ 1500* mm
platform
C between ladder and 100 mm ≤ C < 300 mm
platform
* The minimum height of the handrail of resting platform
is 1000 mm (Technical Provision, resolution
MSC.158(78), paragraph 3.3)

SDC 4/16
Annex 6, page 16
Figure "B"
Vertical Ladder – Side mount
Upper Section of Vertical Ladder

≥A
≥A
≥ B (mm)
Linking platform Lower Section of Vertical Ladder
Dimension
A between two vertical ≥ 200 mm
ladders, stringer to stringer
Stringer height above
B landing or intermediate ≥ 1500* mm
platform
C between ladder and platform 100 mm ≤ C < 300 mm
* The minimum height of the handrail of resting platform
is 1000 mm (Technical Provision, resolution
MSC.158(78), paragraph 3.3)

SDC 4/16
Annex 6, page 17
2.12 TABLE 1 – MEANS OF ACCESS FOR BALLAST AND CARGO TANKS OF OIL TANKERS,
PARAGRAPH 1.1
Interpretation
1 Subparagraphs .1, .2 and .3 define access to under-deck structure, access to

the uppermost sections of transverse webs and connection between these structures.
2 Subparagraphs .4, .5 and .6 define access to vertical structures only and are linked
to the presence of transverse webs on longitudinal bulkheads.
3 If there are no under-deck structures (deck longitudinals and deck transverses) but
there are vertical structures in the cargo tank supporting transverse and longitudinal
bulkheads, access in accordance with subparagraphs from .1 through to .6 should be provided
for inspection of the upper parts of vertical structure on transverse and longitudinal bulkheads.
4 If there is no structure in the cargo tank, section 1.1 of table 1 should not be applied.
5 Section 1 of table 1 should also be applied to void spaces in the cargo area,
comparable in volume to spaces covered by regulation II-1/3-6, except those spaces covered
by section 2.
6 The vertical distance below the overhead structure should be measured from
the underside of the main deck plating to the top of the platform of the means of access at
a given location.
7 The height of the tank should be measured at each tank. For a tank the height of
which varies at different bays, item 1.1 should be applied to such bays of a tank that have
a height of 6 m and over.
Interpretation 7, if the height of the tank is increasing along the length of a ship, the permanent
means of access should be provided locally where the height is above 6 m.
Reference
Paragraph 10 of the annex to MSC/Circ.686/Rev.1.
PARAGRAPH 1.1.2
Interpretation
There is a need to provide a continuous longitudinal permanent means of access when

the deck longitudinals and deck transverses are fitted on deck but supporting brackets are
fitted under the deck.

SDC 4/16
Annex 6, page 18
PARAGRAPH 1.1.3
Interpretation
Means of access to tanks may be used for access to the permanent means of access for
inspection.
As a matter of principle, in such a case where the means of access can be utilized for
the purpose of accessing structural members for inspection there is no need of duplicated
installation of the MA.
PARAGRAPH 1.1.4
Interpretation
The permanent fittings required to serve alternative means of access such as wire lift platform,
that should be used by crew and surveyors for inspection should provide at least an equal level
of safety as the permanent means of access stated by the same paragraph. These means of
access should be carried on board the ship and be readily available for use without filling of water
in the tank. Therefore, rafting should not be acceptable under this provision. Alternative means of
access should be part of the Access Manual which should be approved on behalf of the flag State.
For water ballast tanks of 5 m or more in width, such as on an ore carrier, side shell plating should
be considered in the same way as "longitudinal bulkhead".
PARAGRAPH 2.1
Interpretation
Section 2 of table 1 should also be applied to wing tanks designed as void spaces.
Paragraph 2.1.1 represents requirements for access to under-deck structures, while
paragraph 2.1.2 is a requirement for access for survey and inspection of vertical structures on
longitudinal bulkheads (transverse webs).
Regulation II-1/3-6.2.1 requires each space to be provided with means of access. Though void
spaces are not addressed in the technical provisions contained in resolution MSC.158(78), it is
arguable whether MA are not required in void spaces. MA or portable means of access are
necessary arrangements to facilitate inspection of the structural condition of the space and
the boundary structure. Therefore, the requirements of section 2 of table 1 should be applied to
double-hull spaces even when designed as void spaces.

SDC 4/16
Annex 6, page 19
PARAGRAPH 2.1.1
Interpretation
1 For a tank, the vertical distance between horizontal upper stringer and deck head of
which varies at different sections, item 2.1.1 should be applied to such sections that fall under
the criteria.
2 The continuous permanent means of access may be a wide longitudinal, which

provides access to critical details on the opposite side by means of platforms as necessary on
web frames. In case the vertical opening of the web frame is located in the way of the open
part between the wide longitudinal and the longitudinal on the opposite side, platforms should
be provided on both sides of the web frames to allow safe passage through the web frame.
3 Where two access hatches are required by SOLAS regulation II-1/3-6.3.2, access
ladders at each end of the tank should lead to the deck.
Interpretation 1: The interpretation of varied tank height in item 1 of table 1 is applied to

the vertical distance between horizontal upper stringer and deck head for consistency.
PARAGRAPH 2.1.2
Interpretation
The continuous permanent means of access may be a wide longitudinal, which provides
access to critical details on the opposite side by means of platforms as necessary on web
frames. In case the vertical opening of the web is located in the way of the open part between
the wide longitudinal and the longitudinal on the opposite side, platforms should be provided
on both sides of the web to allow safe passage through the web. A "reasonable deviation", as
noted in TP, paragraph 1.4, of not more than 10% may be applied where the permanent means
of access is integral with the structure itself.
PARAGRAPH 2.2
Interpretation
1 Permanent means of access between the longitudinal continuous permanent means

of access and the bottom of the space should be provided.
2 The height of a bilge hopper tank located outside of the parallel part of the ship should
be taken as the maximum of the clear vertical distance measured from the bottom plating to
the hopper plating of the tank.
3 The foremost and aftmost bilge hopper ballast tanks with raised bottom, of which
the height is 6 m and over, a combination of transverse and vertical MA for access to the upper
knuckle point for each transverse web, should be accepted in place of the longitudinal
permanent means of access.

SDC 4/16
Annex 6, page 20
Interpretation 2: The bilge hopper tanks at fore and aft of cargo area narrow due to raised
bottom plating and the actual vertical distance from the bottom of the tank to hopper plating of
the tank is more appropriate to judge if a portable means of access could be utilized for
the purpose.
Interpretation 3: In the foremost or aftmost bilge hopper tanks where the vertical distance is 6 m
or over but installation of longitudinal permanent means of access is not practicable,
permanent means of access of combination of transverse and vertical ladders provides an
alternative means of access to the upper knuckle point.
2.20 TABLE 2 – MEANS OF ACCESS FOR BULK CARRIERS, PARAGRAPH 1.1
Interpretation
1 Means of access should be provided to the cross-deck structures of the foremost and
aftermost part of each cargo hold.
2 Interconnected means of access under the cross deck for access to three locations
at both sides and in the vicinity of the centreline should be acceptable as the three means of
access.
3 Permanent means of access fitted at three separate locations accessible

independently, one at each side and one in the vicinity of the centreline, should be acceptable.
4 Special attention should be paid to the structural strength where any access opening
is provided in the main deck or cross deck.
5 The requirements for a bulk carrier cross-deck structure should also be considered
applicable to ore carriers.
Pragmatic arrangements of the MA are provided.
Interpretation
Particular attention should be paid to preserve the structural strength in way of access opening
provided in the main deck or cross deck.
Interpretation
"Full upper stools" are understood to be stools with a full extension between topside tanks and
between hatch end beams.

SDC 4/16
Annex 6, page 21
Interpretation
1 The movable means of access to the under-deck structure of cross deck need not
necessarily be carried on board the ship. It should be sufficient if it is made available when needed.
2 The requirements for a bulk carrier cross-deck structure should also be considered
applicable to ore carriers.
Interpretation
The maximum vertical distance of the rungs of vertical ladders for access to hold frames should
be 350 mm. If a safety harness is to be used, means should be provided for connecting
the safety harness in suitable places in a practical way.
The maximum vertical distance of the rungs of 350 mm is applied with a view to reducing
trapping cargoes.
Interpretation
Portable, movable or alternative means of access should also be applied to corrugated

bulkheads.
Interpretation
Readily available means able to be transported to location in cargo hold and safely erected by
ships' crew.
Interpretation
If the longitudinal structures on the sloping plate are fitted outside of the tank, a means of
access should be provided.
Interpretation
1 The height of a bilge hopper tank located outside of the parallel part of the vessel
should be taken as the maximum of the clear vertical height measured from the bottom plating
to the hopper plating of the tank.
2 It should be demonstrated that portable means for inspection can be deployed and
made readily available in the areas where needed.

SDC 4/16
Annex 6, page 22
2.29 TABLE 2 – MEANS OF ACCESS FOR BULK CARRIERS, PARAGRAPH 2.5.2
Interpretation
A wide longitudinal frame of at least 600 mm clear width may be used for the purpose of
the longitudinal continuous permanent means of access. The foremost and aftermost bilge
hopper ballast tanks with raised bottom, of which the height is 6 m and over, a combination of
transverse and vertical MA for access to the sloping plate of hopper tank connection with side
shell plating for each transverse web can be accepted in place of the longitudinal permanent
means of access.
Interpretation
The height of web frame rings should be measured in way of side shell and tank base.
In the bilge hopper tank the sloping plating is above the opening, while the movement of
the surveyor is along the bottom of the tank. Therefore the measurement of 1 m should be
taken from the bottom of the tank.
3 SOLAS CHAPTER II-1, PARTS B-2 AND B-4
DOORS IN WATERTIGHT BULKHEADS OF PASSENGER SHIPS AND CARGO SHIPS
Interpretation
This interpretation pertains to doors1 located in way of the internal watertight subdivision
boundaries and the external watertight boundaries necessary to ensure compliance with
the relevant subdivision and damage stability regulations.
This interpretation does not apply to doors located in external boundaries above equilibrium or
intermediate waterplanes.
The design and testing requirements for watertight doors vary according to their location relative
to the equilibrium waterplane or intermediate waterplane at any stage of assumed flooding.
1 DEFINITIONS
For the purpose of this interpretation the following definitions apply:
1.1 Watertight: Capable of preventing the passage of water in any direction under a design
head. The design head for any part of a structure should be determined by reference to its location
relative to the bulkhead deck or freeboard deck, as applicable, or to the most unfavourable
equilibrium/intermediate waterplane, in accordance with the applicable subdivision and damage
stability regulations, whichever is the greater. A watertight door is thus one that will maintain
the watertight integrity of the subdivision bulkhead in which it is located.
1
Doors in watertight bulkheads of small cargo ships, not subject to any statutory subdivision and damage
stability requirements, may be hinged quick-acting doors arranged to open out of the major space protected.
They should be constructed in accordance with the requirements of the Administration and have notices
affixed to each side stating: "To be kept closed at sea".

SDC 4/16
Annex 6, page 23
1.2 Equilibrium waterplane: The waterplane in still water when, taking account of
flooding due to an assumed damage, the weight and buoyancy forces acting on a ship are in
balance. This relates to the final condition when no further flooding takes place or after cross
flooding is completed.
1.3 Intermediate waterplane: The waterplane in still water, which represents

the instantaneous floating position of a ship at some intermediate stage between commencement
and completion of flooding when, taking account of the assumed instantaneous state of flooding,
the weight and buoyancy forces acting on a ship are in balance.
1.4 Sliding door or rolling door: A door having a horizontal or vertical motion generally
parallel to the plane of the door.
1.5 Hinged door: A door having a pivoting motion about one vertical or horizontal edge.
2 STRUCTURAL DESIGN
Doors and their frames should be of approved design and substantial construction in
accordance with the requirements of the Administration and should preserve the strength of
the subdivision bulkheads in which they are fitted.
3 OPERATION MODE, LOCATION AND OUTFITTING
Doors should be fitted in accordance with all requirements regarding their operation mode,
location and outfitting, i.e. provision of controls, means of indication, etc., as shown in table 1
below. This table should be read in conjunction with paragraphs 3.1 to 5.4 below.
3.1 Frequency of use whilst at sea
3.1.1 Normally closed: Kept closed at sea but may be used if authorized. To be closed again
after use.
3.1.2 Permanently closed: The time of opening such doors in port and of closing them before
the ship leaves port should be entered in the logbook. Should such doors be accessible during
the voyage, they should be fitted with a device to prevent unauthorized opening.
3.1.3 Normally open: May be left open provided it is always ready to be immediately closed.
3.1.4 Used: In regular use, may be left open provided it is ready to be immediately closed.
3.2 Type
Power operated, sliding or rolling2 POS

Power operated, hinged POH
Sliding or rolling S
Hinged H
2
Rolling doors are technically identical to sliding doors.

SDC 4/16
Annex 6, page 24
3.3 Control
3.3.1 Local
3.3.1.1 All doors, except those which should be permanently closed at sea, should be capable
of being opened and closed by hand locally,3 from both sides of the doors, with the ship listed
to either side.
3.3.1.2 For passenger ships, the angle of list at which operation by hand should be possible
is 15º or 20º if the ship is allowed to heel up to 20º during intermediate stages of flooding.
3.3.1.3 For cargo ships, the angle of list at which operation by hand should be possible is 30º.
3.3.2 Remote
Where indicated in table 1, doors should be capable of being remotely closed by power from
the bridge.4 Where it is necessary to start the power unit for operation of the watertight door,
means to start the power unit is also to be provided at remote control stations. The operation
of such remote control should be in accordance with SOLAS regulations II-1/13.8.1 to 13.8.3.
3.4 Indication
3.4.1 Where shown in table 1, position indicators should be provided at all remote operating
positions5 as well as locally, on both sides of the doors,6 to show whether the doors are open
or closed and, if applicable, with all dogs/cleats fully and properly engaged.
3.4.2 The door position indicating system should be of self-monitoring type and the means
for testing of the indicating system should be provided at the position where the indicators are
fitted.
3.4.3 An indication (i.e. red light) should be placed locally showing that the door is in remote
control mode ("doors closed mode"). Refer also to SOLAS regulation II-1/13.8.1. Special care
should be taken in order to avoid potential danger when passing through the door.
Signboard/instructions should be placed in way of the door advising how to act when the door
is in "doors closed" mode.
3.5 Alarms
3.5.1 Doors which should be capable of being remotely closed should be provided with an
audible alarm, distinct from any other alarm in the area, which will sound whenever such a door
is remotely closed. For passenger ships the alarm should sound for at least 5 s but not more
than 10 s before the door begins to move and should continue sounding until the door is
completely closed. In the case of remote closure by hand operation, an alarm is required to
sound only while the door is actually moving.
3.5.2 In passenger areas and areas of high ambient noise, the audible alarms should be
supplemented by visual signals at both sides of the doors.
3
Arrangements for passenger ships should be in accordance with SOLAS regulation II-1/13.7.1.4.
4
Arrangements for passenger ships should be in accordance with SOLAS regulation II-1/13.7.1.5.
5
Indication at all remote control positions (SOLAS regulation II-1/13.6).
6
Refer to SOLAS regulation II-1/13-1.3.

SDC 4/16
Annex 6, page 25
3.6 Notices
As shown in table 1, doors which are normally closed at sea, but are not provided with means
of remote closure, should have notices fixed to both sides of the doors stating: "To be kept
closed at sea". Doors which should be permanently closed at sea should have notices fixed to
both sides stating: "Not to be opened at sea".
3.7 Location
For passenger ships the watertight doors and their controls should be located in compliance
with SOLAS regulations II-1/13.5.3 and II-1/13.7.1.2.2.
4 FIRE DOORS
4.1 Watertight doors may also serve as fire doors but need not be fire tested when intended
for use below the bulkhead deck. Where such doors are used at locations above the bulkhead
deck they should, in addition to complying with the provisions applicable to fire doors at the same
locations, also comply with means of escape provisions of SOLAS regulation II-2/13.
4.2 Where a watertight door is located adjacent to a fire door, both doors should be
capable of independent operation, remotely if required by SOLAS regulations II-1/13.8.1
to 13.8.3 and from both sides of each door.
5 TESTING
5.1 Doors which become immersed by an equilibrium or intermediate waterplane or are

below the freeboard or bulkhead deck should be subjected to a hydrostatic pressure test.
5.2 For large doors intended for use in the watertight subdivision boundaries of cargo
spaces, structural analysis may be accepted in lieu of pressure testing. Where such doors
utilize gasket seals, a prototype pressure test to confirm that the compression of the gasket
material is capable of accommodating any deflection, revealed by the structural analysis,
should be carried out.
5.3 Doors above freeboard or bulkhead deck, which are not immersed by an equilibrium
or intermediate waterplane but become intermittently immersed at angles of heel in
the required range of positive stability beyond the equilibrium position should be hose tested.
5.4 Pressure testing
5.4.1 The head of water used for the pressure test should correspond at least to the head
measured from the lower edge of the door opening, at the location in which the door should be
fitted in the ship, to the bulkhead deck or freeboard deck, as applicable, or to the most
unfavourable damage waterplane, if that be greater. Testing may be carried out at the factory
or other shore-based testing facility prior to installation in the ship.
5.4.2 Leakage criteria
5.4.2.1 The following acceptable leakage criteria should apply:
Doors with gaskets No leakage

Doors with metallic sealing Maximum leakage 1 l/min

SDC 4/16
Annex 6, page 26
5.4.2.2 Limited leakage may be accepted for pressure tests on large doors located in cargo
spaces employing gasket seals or guillotine doors located in conveyor tunnels, in accordance
with the following:7
(P+4.572) h3
Leakage rate (l/min) =
6568
where P = perimeter of door opening (metres)

h = test head of water (metres)
5.4.2.3 However, in the case of doors where the water head taken for the determination of
the scantling does not exceed 6.1 m, the leakage rate may be taken equal to 0.375 l/min if this
value is greater than that calculated by the above-mentioned formula.
5.4.3 For doors of passenger ships which are normally open and used at sea and which
become submerged by the equilibrium or intermediate waterplane, a prototype test should be
conducted, on each side of the door, to check the satisfactory closing of the door against
a force equivalent to a water height of at least 1 m above the sill on the centre line of the door.8
5.5 Hose testing after installation
All watertight doors should be subject to a hose test9 after installation in a ship. Hose testing
should be carried out from each side of a door unless, for a specific application, exposure to
floodwater is anticipated only from one side. Where a hose test is not practicable because of
possible damage to machinery, electrical equipment insulation, or outfitting items, it may be
replaced by means such as an ultrasonic leak test or an equivalent test.
7
Published in the ATM F 1196, Standard Specification for Sliding Watertight Door Assemblies and referenced
in the Title 46 US Code of Federal Regulations 170.270 Door design, operation installation and testing.
8
Arrangements for passenger ships should be in accordance with SOLAS regulation II-1/13.5.2.
9
Refer to IACS URS 14.2.3 IACS Reg. 1996/Rev.2, 2001.

SDC 4/16
Annex 6, page 27
Table 1 – Internal doors in watertight bulkheads in cargo ships and passenger ships
Position relative 1 2 3 4 5 6 7 8
to equilibrium Frequency of use Type Remote Indication Audible Notice Comments Regulation
or intermediate whilst at sea control6 locally and alarm6
waterplane on bridge6
I. Passenger ships
Certain doors may be left SOLAS II-1/22.1,
Normally closed POS Yes Yes Yes No
open, see SOLAS II-1/22.4 to II-1/22.4
A. At or below
SOLAS II-1/13.9.1
Permanently closed S, H No No No Yes See Notes 1 + 4
and 13.9.2
POS, SOLAS II-1/22.4
Normally open Yes Yes Yes No
POH SOLAS II-1/17.1
B. Above S, H No Yes No Yes See Note 2 MSC/Circ.541
Normally closed Doors giving access to ro-ro
S, H No Yes No Yes SOLAS II-1/17-1
deck
II. Cargo ships
Used POS Yes Yes Yes No SOLAS II-1/13-1.2
Normally closed S, H No Yes No Yes see Notes 2 + 3 + 5 SOLAS II-1/13-1.3
A. At or below
SOLAS II-1/13-1.4
Permanently closed S, H No No No Yes see Notes 1 + 4
SOLAS II-1/15-1
B. Above SOLAS II-1/13-1.3
Normally closed S, H No Yes No Yes See Notes 2 + 5
SOLAS II-1/15-1
Notes:
1 Doors in watertight bulkheads subdividing cargo spaces.
2 If hinged, this door should be of quick-acting or single-action type.
3 SOLAS requires remotely operated watertight doors to be sliding doors.
4 The time of opening such doors in port and closing them before the ship leaves port should be entered in the logbook.
5 The use of such doors should be authorized by the officer of the watch.
6 Cables for control and power systems to power-operated watertight doors and their status indication should comply with the requirements
of IACS UR E15.

SDC 4/16
Annex 6, page 28
4 SOLAS REGULATION II-1/26 – GENERAL
4.1 PARAGRAPH 4
Interpretation
1 Dead ship condition for the purpose of regulation II-1/26.4 should be understood to
mean a condition under which the main propulsion plant, boilers and auxiliaries are not in
operation and in restoring the propulsion, no stored energy for starting and operating
the propulsion plant, the main source of electrical power and other essential auxiliaries is
assumed to be available.
2 Where the emergency source of power is an emergency generator which complies

with regulation II-1/44, IACS SC185 and IACS SC124, this generator may be used for restoring
operation of the main propulsion plant, boilers and auxiliaries where any power supplies
necessary for engine operation are also protected to a similar level as the starting
arrangements.
3 Where there is no emergency generator installed or an emergency generator does

not comply with regulation II-1/44, the arrangements for bringing main and auxiliary machinery
into operation should be such that the initial charge of starting air or initial electrical power and
any power supplies for engine operation can be developed on board ship without external aid.
If for this purpose an emergency air compressor or an electric generator is required, these
units should be powered by a hand-starting oil engine or a hand-operated compressor.
The arrangements for bringing main and auxiliary machinery into operation should have
capacity such that the starting energy and any power supplies for engine operation are
available within 30 min of a dead ship condition.
4.2 PARAGRAPH 11
Interpretation
1 Arrangements complying with this regulation and acceptable "equivalent

arrangements", for the most commonly utilized fuel systems, are shown below.
2 A service tank is a fuel oil tank which contains only fuel of a quality ready for use,
i.e. fuel of a grade and quality that meets the specification required by the equipment
manufacturer. A service tank should be declared as such and not be used for any other
purpose.
3 Use of a setting tank with or without purifiers, or purifiers alone, and one service tank
is not acceptable as an "equivalent arrangement" to two service tanks.

SDC 4/16
Annex 6, page 29
Examples of application for the most common systems
1 Example 1
1.1 Requirement according to SOLAS – Main and auxiliary engines and boiler(s)
operating with heavy fuel oil (HFO) (one fuel ship)
HFO Serv. TK HFO Serv. TK

Capacity for at least 8 h Capacity for at least 8 h MDO TK
Main Eng. + Main Eng. + For initial cold starting or
Aux. Eng. + Aux. Eng. + repair work
Aux. Boiler Aux. Boiler Engines/Boiler
1.2 Equivalent arrangement
HFO Serv. TK MDO Serv. TK

Capacity for at least 8 h Capacity for at least 8 h
Main Eng. + Main Eng. +
Aux. Eng. + Aux. Eng. +
Aux. Boiler Aux. Boiler
This interpretation only applies where main and auxiliary engines can operate with heavy fuel
oil under all load conditions and, in the case of main engines, during manoeuvring.
For pilot burners of auxiliary boilers if provided, an additional MDO tank for eight hours may be
necessary.
2 Example 2
2.1 Requirement according to SOLAS – Main engine(s) and auxiliary boiler(s)

operating with HFO and auxiliary engine operating with marine diesel oil (MDO)
2.2 Equivalent arrangement
The arrangements in paragraphs 1.2 and 2.2 apply, provided the propulsion and vital systems
which use two types of fuel support rapid fuel changeover and are capable of operating in all
normal operating conditions at sea with both types of fuel (MDO and HFO).

SDC 4/16
Annex 6, page 30
5 SOLAS REGULATIONS II-1/40 – GENERAL – AND II-1/41 – MAIN SOURCE OF

ELECTRICAL POWER AND LIGHTING SYSTEMS
Interpretation
Essential services and arrangements of sources of power, supply, control and

monitoring to the different categories of essential services
1 Classification of essential services
1.1 Essential services are those services essential for propulsion and steering, and safety
of the ship, which are made up of "Primary Essential Services" and "Secondary Essential
Services". Definitions and examples of such services are given in 2 and 3 below.
1.2 Services to ensure minimum comfortable conditions of habitability are those services
defined in 4 below.
2 Primary Essential Services
Primary Essential Services are those services which need to be in continuous operation to
maintain propulsion and steering. Examples of equipment for "Primary Essential Services" are
as follows:
- steering gears;
- pumps for controllable pitch propellers;
- scavenging air blower, fuel oil supply pumps, fuel valve cooling pumps, lubricating
oil pumps and cooling water pumps for main and auxiliary engines and turbines
necessary for propulsion;
- forced draught fans, feed water pumps, water circulating pumps, vacuum pumps
and condensate pumps for steam plants on steam turbine ships, and also for
auxiliary boilers on ships where steam is used for equipment supplying primary
essential services;
- oil burning installations for steam plants on steam turbine ships and for auxiliary
boilers where steam is used for equipment supplying primary essential services;
- azimuth thrusters, which are the sole means for propulsion/steering with
lubricating oil pumps, cooling water pumps;
- electrical equipment for electric propulsion plant with lubricating oil pumps and
cooling water pumps;
- electric generators and associated power sources supplying the above equipment;
- hydraulic pumps supplying the above equipment;
- viscosity control equipment for heavy fuel oil;
- control, monitoring, and safety devices/systems for equipment to primary
essential services;
- fire pumps and other fire extinguishing medium pumps;
- navigation lights, aids and signals;
- internal safety communication equipment; and
- lighting system.

SDC 4/16
Annex 6, page 31
3 Secondary Essential Services
Secondary Essential Services are those services which need not necessarily be in continuous
operation to maintain propulsion and steering but which are necessary for maintaining
the vessel's safety. Examples of equipment for secondary essential services are as follows:
- windlass;
- fuel oil transfer pumps and fuel oil treatment equipment;
- lubrication oil transfer pumps and lubrication oil treatment equipment;
- pre-heaters for heavy fuel oil;
- starting air and control air compressors;
- bilge, ballast and heeling pumps;
- ventilating fans for engine and boiler rooms;
- services considered necessary to maintain dangerous spaces in a safe condition;
- fire detection and alarm system;
- electrical equipment for watertight closing appliances;
- electric generators and associated power sources supplying the above equipment;
- hydraulic pumps supplying the above equipment;
- control, monitoring, and safety systems for cargo containment systems; and
- control, monitoring, and safety devices/systems for equipment to secondary
essential services.
4 Services for habitability
Services for habitability are those services which need to be in operation for maintaining
the ship's minimum comfort conditions for the crew and passengers. Examples of equipment
for maintaining conditions of habitability are as follows:
- cooking;
- heating;
- domestic refrigeration;
- mechanical ventilation;
- sanitary and fresh water; and
- electrical generators and associated power sources supplying the above equipment.
5 Regulation II-1/40.1.1 and regulation II-1/41.1.1 – For the purposes of these

regulations, the services as included in paragraphs 2 to 4 should be considered.
6 Regulation II-1/40.1.2 – For the purposes of this regulation, the services as included
in paragraphs 2 and 3 and the services in regulation II-1/42 or II-1/43, as applicable, should be
considered.
in paragraphs 2 to 4, except for those also listed in interpretation 3 (SOLAS chapter II-1,
regulation 41.1.2), should be considered.
in paragraphs 2, 3 and 4 should be considered.10
10
See also IACS UI SC83.

SDC 4/16
Annex 6, page 32
9 Regulation II-1/41.5.1.2 – For the purposes of this regulation, the following interpretations
are applicable:
.1 services in paragraph 2 should not be included in any automatic load

shedding or other equivalent arrangements;
.2 services in paragraph 3 may be included in the automatic load shedding or

other equivalent arrangement provided disconnection will not prevent
services required for safety being immediately available when the power
supply is restored to normal operating conditions; and
.3 services for habitability in paragraph 4 may be included in the load shedding

or other equivalent arrangement.
6 SOLAS REGULATION II-1/41 – MAIN SOURCE OF ELECTRICAL POWER AND

LIGHTING SYSTEMS
6.1 PARAGRAPH 1.2
Interpretation
Those services necessary to provide normal operational conditions of propulsion and safety
do not include services such as:
.1 thrusters not forming part of the main propulsion;
.2 moorings;
.3 cargo handling gear;
.4 cargo pumps; and
.5 refrigerators for air conditioning (those which are not necessary to establish
a minimum condition of habitability).
6.2 PARAGRAPH 1.3
Interpretation
Generators and generator systems, having the ship's main propulsion machinery as their prime
mover, may be accepted as part of the ship's main source of electrical power, provided:
1 They should be capable of operating under all weather conditions during sailing and
during manoeuvring, also when the ship is stopped, within the specified limits for the voltage
variation in IEC 60092-301 and the frequency variation in IACS UR E5.
2 Their rated capacity is safeguarded during all operations given under 1, and is such
that in the event of any other one of the generators failing, the services given under
regulation II-1/41.1.2 (interpretation 3) can be maintained.
3 The short circuit current of the generator/generator system is sufficient to trip

the generator/generator system circuit-breaker taking into account the selectivity of
the protective devices for the distribution system.

SDC 4/16
Annex 6, page 33
Protection should be arranged in order to safeguard the generator/generator system in case

of a short circuit in the main busbar. The generator/generator system should be suitable for
further use after fault clearance.
4 Standby sets are started in compliance with paragraph 2.2 of SOLAS chapter II-1,
regulation II-1/41.5 (interpretation 5).
6.3 PARAGRAPH 5
Interpretation of paragraph 5.1.1
1 Where the electrical power is normally supplied by more than one generator set
simultaneously in parallel operation, provision of protection, including automatic disconnection
of sufficient non-essential services and if necessary secondary essential services as defined
in the unified interpretation of SOLAS regulation II-1/40 and 41 above (Interpretation 2) and
those provided for habitability, should be made to ensure that, in case of loss of any of these
generating sets, the remaining ones are kept in operation to permit propulsion and steering
and to ensure safety.
2 Where Administrations permit electrical power to be normally supplied by one

generator, provision should be made, upon loss of power, for automatic starting and connecting
to the main switchboard of stand-by generator(s) of sufficient capacity with automatic restarting
of the essential auxiliaries, in sequential operation if required. Starting and connection to the main
switchboard of one generator should be as rapid as possible, preferably within 30 seconds after
loss of power. Where prime movers with longer starting time are used, this starting and
connection time may be exceeded upon approval from the Administration.
3 The load shedding should be automatic.
4 The non-essential services, service for habitable conditions, may be shed and, where
necessary, additionally the Secondary Essential Services, sufficient to ensure the connected
generator set(s) is/are not overloaded.
1 Other approved means can be achieved by:
.1 circuit breaker without tripping mechanism; or
.2 disconnecting link or switch by which busbars can be split easily and safely.
2 Bolted links, for example bolted busbar sections, should not be accepted.

SDC 4/16
Annex 6, page 34
7 SOLAS REGULATIONS II-1/42 AND II-1/43 – EMERGENCY SOURCE OF

ELECTRICAL POWER IN PASSENGER AND CARGO SHIPS
Interpretation
1 "Blackout" as used in regulations II-1/42.3.4 and II-1/43.3.4 should be understood to

mean a "dead ship" condition-initiating event.
2 "Dead ship" condition, for the purpose of regulations II-1/42.3.4 and II-1/43.3.4, should
be understood to mean a condition under which the main propulsion plant, boilers and auxiliaries
are not in operation and in restoring the propulsion, no stored energy for starting the propulsion
plant, the main source of electrical power and other essential auxiliaries should be assumed
available. It is assumed that means are available to start the emergency generator at all times.
3 Emergency generator stored starting energy is not to be directly used for starting
the propulsion plant, the main source of electrical power and/or other essential auxiliaries
(emergency generator excluded).
4 For steam ships, the 30-min time limit given in SOLAS can be interpreted as time from
blackout defined above to light-off of the first boiler.
5 Exceptionally is understood to mean conditions such as:
.1 blackout situation;
.2 dead ship situation;
.3 routine use for testing;
.4 short-term parallel operation with the main source of electrical power for
the purpose of load transfer; and
.5 use of the emergency generator during lay time in port for the supply of
the ship's main switchboard, provided the requirements of 6 (Suitable
measures for the exceptional use of the emergency generator for
power-supply of non-emergency circuits in port) are achieved and unless
instructed otherwise by the Administration.
6 Suitable measures for the exceptional use of the emergency generator for
power-supply of non-emergency circuits in port:
.1 To prevent the generator or its prime mover from becoming overloaded when
used in port, arrangements should be provided to shed sufficient
non-emergency loads to ensure its continued safe operation.
.2 The prime mover should be arranged with fuel oil filters and lubrication oil
filters, monitoring equipment and protection devices as required for the prime
mover for main power generation and for unattended operation.
.3 The fuel oil supply tank to the prime mover should be provided with
a low-level alarm, arranged at a level ensuring sufficient fuel oil capacity for
the emergency services for the period of time as required by SOLAS.

SDC 4/16
Annex 6, page 35
.4 The prime mover should be designed and built for continuous operation and
should be subjected to a planned maintenance scheme ensuring that it is
always available and capable of fulfilling its role in the event of an emergency
at sea.
.5 Fire detectors should be installed in the location where the emergency

generator set and emergency switchboard are installed.
.6 Means should be provided to readily change over to emergency operation.
.7 Control, monitoring and supply circuits, for the purpose of the use of
emergency generator in port should be so arranged and protected that any
electrical fault will not influence the operation of the main and emergency
services.
.8 When necessary for safe operation, the emergency switchboard should be

fitted with switches to isolate the circuits.
.9 Instructions should be provided on board to ensure that when the ship is

under way all control devices (e.g. valves, switches) are in a correct position
for the independent emergency operation of the emergency generator set
and emergency switchboard.
8 SOLAS REGULATION II-1/44 – STARTING ARRANGEMENTS FOR EMERGENCY

GENERATING SETS
8.1 PARAGRAPH 1
Interpretation (from MSC/Circ.736)
Emergency generating sets should be capable of being readily started in their cold condition
at a temperature of 0ºC. If this is impracticable, or if lower temperatures are likely to be
encountered, heating should be provided to ensure ready starting of the generating sets.
8.2 PARAGRAPH 2
Interpretation (from MSC/Circ.736)
Each emergency generating set arranged to be automatically started should be equipped with
starting devices with a stored energy capability of at least three consecutive starts. A second
source of energy should be provided for an additional three starts within 30 min unless manual
starting can be demonstrated to be effective.
9 SOLAS REGULATION XII/12 – HOLD, BALLAST AND DRY SPACE WATER

INGRESS ALARMS
When water level detectors are installed on bulk carriers in compliance with SOLAS
regulation XII/12, the Performance standards for water level detectors on bulk carriers and
single hold cargo ships other than bulk carriers, annexed to resolution MSC.188(79) adopted
on 3 December 2004 should be applied, taking into account the following interpretations to
the paragraphs of the Performance standards.

SDC 4/16
Annex 6, page 36
9.1 PERFORMANCE STANDARDS FOR WATER LEVEL DETECTORS ON BULK CARRIERS AND
SINGLE HOLD CARGO SHIPS OTHER THAN BULK CARRIERS, PARAGRAPH 3.2.3
Interpretation
Detection equipment includes the sensor and any filter and protection arrangements for
the detector installed in cargo holds and other spaces as required by SOLAS regulation XII/12.1.
Interpretation
1 In general, the construction and type testing should be in accordance with publication
IEC 60079: Electrical Equipment for Explosive Gas Atmospheres to a minimum requirement
of EX(ia). Where a ship is designed only for the carriage of cargoes that cannot create
a combustible or explosive atmosphere then the requirement for intrinsically safe circuitry
should not be insisted upon, provided the operational instructions included in the Manual
required by 4.1 of the appendix to the annex specifically exclude the carriage of cargoes that
could produce a potential explosive atmosphere. Any exclusion of cargoes identified in
the annex should be consistent with the ship's Cargo Book and any Certification relating to
the carriage of specifically identified cargoes.
2 The maximum surface temperature of equipment installed within cargo spaces should
be appropriate for the combustible dusts and/or explosive gases likely to be encountered.
Where the characteristics of the dust and gases are unknown, the maximum surface
temperature of equipment should not exceed 85ºC.
3 Where intrinsically safe equipment is installed, it should be of a certified safe type.
4 Where detector systems include intrinsically safe circuits, plans of the arrangements
should be appraised/approved by individual classification societies.
Interpretation
The pre-alarm, as a primary alarm, should indicate a condition that requires prompt attention
to prevent an emergency condition and the main alarm, as an emergency alarm should indicate
that immediate actions must be taken to prevent danger to human life or to the ship.
Interpretation
Fault monitoring should address faults associated with the system that include open circuit, short
circuit, as well as arrangement details that would include loss of power supplies and CPU failure
for computer based alarm/monitoring system, etc.

SDC 4/16
Annex 6, page 37
Interpretation
1 The electrical power supply should be from two separate sources, one should be
the main source of electrical power and the other should be the emergency source, unless
a continuously charged dedicated accumulator battery is fitted, having arrangement, location
and endurance equivalent to that of the emergency source (18 h). The battery supply may be
an internal battery in the water level detector system.
2 The changeover arrangement of supply from one electrical source to another need
not be integrated into the water level detector system.
3 Where batteries are used for the secondary power supply, failure alarms for both
power supplies should be provided.
9.6 PERFORMANCE STANDARDS FOR WATER LEVEL DETECTORS ON BULK CARRIERS

AND SINGLE HOLD CARGO SHIPS OTHER THAN BULK CARRIERS, FOOTNOTE TO
PARAGRAPH 3.4.1
Interpretation
1 IACS UR E10 may be used as an equivalent test standard to IEC 60092-504.
2 The range of tests should include the following:
For alarm/monitoring panel:
.1 functional tests in accordance with resolution MSC.188(79) – Performance

standards for water level detectors on bulk carriers and single hold cargo
ships other than bulk carriers;
.2 electrical power supply failure test;
.3 power supply variation test;
.4 dry heat tests;
.5 damp heat tests;
.6 vibration test;
.7 EMC tests;
.8 insulation resistance test;
.9 high-voltage test; and
.10 static and dynamic inclinations tests, if moving parts are contained.
For IS barrier unit, if located in the wheelhouse: in addition to the certificate issued by
a competent independent testing laboratory, EMC tests should also be carried out.

SDC 4/16
Annex 6, page 38
For water ingress detectors:
.1 functional tests in accordance with resolution MSC.188(79) – Performance

.2 electrical power supply failure test;
.3 power supply variation test;
.4 dry-heat test;
.5 damp-heat test;
.6 vibration test;
.7 enclosure class in accordance with resolution MSC.188(79) – Performance

.8 insulation resistance test;
.9 high-voltage test; and
.10 static and dynamic inclinations tests (if the detectors contain moving parts).
SINGLE HOLD CARGO SHIPS OTHER THAN BULK CARRIERS, APPENDIX, PARAGRAPH 2.1.1
Interpretation
The test procedure should satisfy the following criteria:
.1 the type tests should be witnessed by a classification society surveyor if

the tests are not carried out by a competent independent test facility;
.2 type tests should be carried out on a prototype or randomly selected item(s)

which are representative of the manufactured item that is being type tested;
and
.3 type tests should be documented (type test reports) by the manufacturer and
submitted for review by classification societies.
SINGLE HOLD CARGO SHIPS OTHER THAN BULK CARRIERS, APPENDIX, PARAGRAPH 2.1.1.1
Interpretation
1 The submerged test period for electrical components intended to be installed in ballast
tanks and cargo tanks used as ballast tanks should be not less than 20 days.
2 The submerged test period for electrical components intended to be installed in dry
spaces and cargo holds not intended to be used as ballast tanks should be not less than 24 h.

SDC 4/16
Annex 6, page 39
3 Where a detector and/or cable connecting device (e.g. junction box, etc.) is installed
in a space adjacent to a cargo hold (e.g. lower stool, etc.) and the space is considered to be
flooded under damage stability calculations, the detectors and equipment should satisfy
the requirements of IP68 for a water head equal to the hold depth for a period of 20 days
or 24 h on the basis of whether or not the cargo hold is intended to be used as a ballast tank
as described in the previous paragraphs.
SINGLE HOLD CARGO SHIPS OTHER THAN BULK CARRIERS, APPENDIX, PARAGRAPH 2.1.1.2
Interpretation
1 The type test required for the sensor should be in accordance with the following:
.1 The test container for the cargo/water mixture should be dimensioned so that
its height and volume are such that the sensor and any filtration fitted can be
totally submerged for the repeated functionality tests required by
paragraph 2.1.1.2 and the static and dynamic inclination tests identified in
the previous interpretation.
.2 The sensor and any filtration fitted that should be submerged and should be
arranged in the container as they would be installed in accordance with
the installation instructions required by paragraph 4.4.
.3 The pressure in the container for testing the complete detector should be not
more than 0.2 bar at the sensor and any filter arrangement. The pressure
may be realized by pressurization or by using a container of sufficient height.
.4 The cargo/water mixture should be pumped into the test container and
suitable agitation of the mixture provided to keep the solids in suspension.
The effect of pumping the cargo/water mixture into the container should not
affect the operation of the sensor and filter arrangements.
.5 The cargo/water mixture should be pumped into the test container to

a predetermined level that submerges the detector and the operation of
the alarm observed.
.6 The test container should then be drained and the deactivation of the alarm
condition observed.
.7 The test container and sensor with any filter arrangement should be allowed
to dry without physical intervention.
.8 The test procedure should be repeated consecutively ten times without

cleaning any filter arrangement that may be fitted in accordance with
the manufacturer's installation instructions (see also 2.1.1.2).
.9 Satisfactory alarm activation and deactivation at each of the 10 consecutive

tests will demonstrate satisfactory type testing.

SDC 4/16
Annex 6, page 40
2 The cargo/water mixture used for type testing should be representative of the range
of cargoes within the following groups and should include the cargo with the smallest particles
expected to be found from a typical representative sample:
.1 iron ore particles and seawater;
.2 coal particles and seawater;
.3 grain particles and seawater; and
.4 aggregate (sand) particles and seawater.
The smallest and largest particle size together with the density of the dry mixture
should be ascertained and recorded. The particles should be evenly distributed
throughout the mixture. Type testing with representative particles will in general
qualify all types of cargoes within the four groupings shown above.
The following provides guidance on the selection of particles for testing purposes:
.1 Iron ore particles should mainly consist of small loose screenings of iron ore
and not lumps of ore (dust with particle size < 0.1 mm).
.2 Coal particles should mainly consist of small loose screenings of coal and
not lumps of coal (dust with particle size < 0.1 mm).
.3 Grain particles should mainly consist of small loose grains of free-flowing

grain (grain having a size > 3 mm, such as wheat).
.4 Aggregate particles should mainly consist of small loose grains of

free-flowing sand and without lumps (dust with particle size < 0.1 mm).
SINGLE HOLD CARGO SHIPS OTHER THAN BULK CARRIERS, APPENDIX, PARAGRAPH 3.1.1
Interpretation
The test procedure should satisfy the following criteria:
.1 The type tests should be witnessed by a classification society surveyor if

the tests are not carried out by a competent independent test facility.
.2 Type tests should be carried out on a prototype or randomly selected item(s)

which are representative of the manufactured item that is being type tested.
.3 Type tests should be documented (type test reports) by the manufacturer

and submitted for review by classification societies.
9.11 PERFORMANCE STANDARDS FOR WATER LEVEL DETECTORS ON BULK CARRIERS AND SINGLE
HOLD CARGO SHIPS OTHER THAN BULK CARRIERS, APPENDIX, SECTION 4 – MANUALS
Interpretation
For each ship, a copy of the manual should be made available to the surveyor at least 24 hours
prior to survey of the water-level detection installation. Each classification society should ensure
that any plans required for classification purposes have been appraised/approved as
appropriate.

SDC 4/16
Annex 6, page 41
10 SOLAS REGULATION XII/13 – AVAILABILITY OF PUMPING SYSTEMS
SOLAS regulation XII/13.1 and MSC/Circ.1069
Dewatering of forward spaces of bulk carriers
Interpretation
1 Where the piping arrangements for dewatering closed dry spaces are connected to
the piping arrangements for the drainage of water ballast tanks, two non-return valves should
be provided to prevent the ingress of water into dry spaces from those intended for the carriage
of water ballast. One of these non-return valves should be fitted with a shut-off isolation
arrangement. The non-return valves should be located in readily accessible positions.
The shut-off isolation arrangement should be capable of being controlled from the navigation
bridge, the propulsion machinery control position or enclosed space which is readily accessible
from the navigation bridge or the propulsion machinery control position without travelling
exposed freeboard or superstructure decks. In this context, a position which is accessible via
an under-deck passage, a pipe trunk or other similar means of access should not be taken as
being in the "readily accessible enclosed space".
2 Under SOLAS regulation XII/13.1:
.1 the valve specified under SOLAS regulation II-1/12.5.1 should be capable of

being controlled from the navigation bridge, the propulsion machinery control
position or enclosed space which is readily accessible from the navigation
bridge or the propulsion machinery control position without travelling exposed
freeboard or superstructure decks. In this context, a position which is
accessible via an under-deck passage, a pipe trunk or other similar means of
access should not be taken as being in the "readily accessible enclosed
space";
.2 the valve should not move from the demanded position in the case of failure
of the control system power or actuator power;
.3 positive indication should be provided at the remote control station to show

that the valve is fully open or closed; and
.4 local hand-powered valve operation from above the freeboard deck, as

permitted under SOLAS regulation II-1/12.5.1, is required. An acceptable
alternative to such arrangement may be remotely operated actuators as
specified in SOLAS regulation XII/13.1, on the condition that all of the
provisions of regulation 13.1 are met.
3 The dewatering arrangements should be such that any accumulated water can be
drained directly by a pump or eductor.
4 The dewatering arrangements should be such that when they are in operation, other
systems essential for the safety of the ship including firefighting and bilge systems remain
available and ready for immediate use. The systems for normal operation of electric power
supplies, propulsion and steering should not be affected by the operation of the dewatering
systems. It should also be possible to immediately start fire pumps and have a readily available
supply of firefighting water and to be able to configure and use the bilge system for any
compartment when the dewatering system is in operation.

SDC 4/16
Annex 6, page 42
5 Bilge wells should be provided with gratings or strainers that will prevent blockage of
the dewatering system with debris.
6 The enclosures of electrical equipment for the dewatering system installed in any of
the forward dry spaces should provide protection to IPX8 standard as defined in
publication IEC 60529 for a water head equal to the height of the space in which the electrical
equipment is installed for a time duration of at least 24 h.
***

SDC 4/16
Annex 7, page 1
ANNEX 7
DRAFT CORRIGENDUM TO MSC.1/CIRC.1464/REV.1

AND OF THE PERFORMANCE STANDARDS FOR WATER LEVEL DETECTORS ON
BULK CARRIERS AND SINGLE HOLD CARGO SHIPS OTHER THAN
BULK CARRIERS (RESOLUTION MSC.188(79))
The existing annex is amended as follows:
.1 In the table of contents, the title of chapter 1 is amended to read "SOLAS

regulation II-1/3-6 – Access to and within spaces in, and forward of, the cargo
area of oil tankers and bulk carriers", the title of chapter 8 is replaced with
"SOLAS chapter II-1, parts B-2 – Subdivision, watertight and weathertight
integrity – and B-4 – Stability management", and the existing chapter 9 is
deleted and the remaining chapters are renumbered accordingly.
.2 In paragraph 3.3.2 of chapter 8, the reference to "SOLAS regulations II-1/15.8.1

to 15.8.3" is replaced with "SOLAS regulations II-1/13.8.1 to 13.8.3".
.3 In paragraph 3.7 of chapter 8, the reference to "SOLAS regulations II-1/15.6.3

and II-1/15.7.1.2.2" is replaced with "SOLAS regulations II-1/13.5.3
and II-1/13.7.1.2.2".
.4 In paragraph 4.1 of chapter 8, the text "(2000 SOLAS amendments,

resolution MSC.99(73))" is deleted.
.5 In chapter 8, the existing table 1 is replaced with the following table:

SDC 4/16
Annex 7, page 2
"Table 1 – Internal doors in watertight bulkheads in cargo ships and passenger ships
Position relative 1 2 3 4 5 6 7 8
to equilibrium Frequency of use Type Remote Indication Audible Notice Comments Regulation
or intermediate whilst at sea control6 locally and alarm6
waterplane on bridge6
I. Passenger ships
Certain doors may be left SOLAS II-1/22.1,
Normally closed POS Yes Yes Yes No
open, see SOLAS II-1/22.4 to II-1/22.4
A. At or below
SOLAS II-1/13.9.1
Permanently closed S, H No No No Yes See Notes 1 + 4
and 13.9.2
POS, SOLAS II-1/22.4
Normally open Yes Yes Yes No
POH SOLAS II-1/17.1
B. Above S, H No Yes No Yes See Note 2 MSC/Circ.541
Normally closed Doors giving access to ro-ro
S, H No Yes No Yes SOLAS II-1/17-1
deck
II. Cargo ships
Normally closed S, H No Yes No Yes see Notes 2 + 3 + 5 SOLAS II-1/13-1.3
A. At or below
SOLAS II-1/13-1.4
Permanently closed S, H No No No Yes see Notes 1 + 4
SOLAS II-1/15-1
B. Above SOLAS II-1/13-1.3
Normally closed S, H No Yes No Yes See Notes 2 + 5
SOLAS II-1/15-1
Notes:
1 Doors in watertight bulkheads subdividing cargo spaces.
2 If hinged, this door should be of quick-acting or single-action type.
3 SOLAS requires remotely operated watertight doors to be sliding doors.
4 The time of opening such doors in port and closing them before the ship leaves port should be entered in the logbook.
5 The use of such doors should be authorized by the officer of the watch.
6 Cables for control and power systems to power-operated watertight doors and their status indication should comply with the requirements of IACS UR E15."

SDC 4/16
Annex 7, page 3
.6 The existing chapter 9 is deleted and the remaining chapters are renumbered
accordingly.
.7 In the renumbered paragraph 9, the date "5 June 2003" is replaced

with "3 December 2004".
***

SDC 4/16
Annex 8, page 1
ANNEX 8
DRAFT MSC CIRCULAR
UNIFIED INTERPRETATION OF SOLAS REGULATIONS II-1/2.20 AND II-2/3.21

with a view to providing more specific guidance on the deadweight to be stated on
certificates, approved the unified interpretation of SOLAS regulations II-1/2.20 and II-2/3.21,
prepared by the Sub-Committee on Ship Design and Construction, at its fourth session
(13 to 17 February 2017), as set out in the annex.
2 Member States are invited to use the annexed unified interpretation as guidance when
applying SOLAS regulations II-1/2.20 and II-2/3.21 to determine the regulatory deadweight to
be entered on relevant statutory certificates, and to bring the unified interpretations to
the attention of all parties concerned.

SDC 4/16
Annex 8, page 2
ANNEX
UNIFIED INTERPRETATION OF SOLAS REGULATIONS II-1/2.20 AND II-2/3.21
Deadweight to be stated on certificates
Even-keel hydrostatics should be used to determine the regulatory deadweight to be entered

on relevant statutory certificates.
***

SDC 4/16
Annex 9, page 1
ANNEX 9
DRAFT MEPC CIRCULAR
UNIFIED INTERPRETATION OF REGULATION 1.23 OF MARPOL ANNEX I
1 The Marine Environment Protection Committee, at its [seventy-first

session (3 to 7 July 2017)], with a view to providing more specific guidance on the deadweight
to be stated on certificates, approved the unified interpretation of regulation 1.23 of MARPOL
Annex I, prepared by the Sub-Committee on Ship Design and Construction, at its fourth
session (13 to 17 February 2017), as set out in the annex.
2 Member States are invited to use the annexed unified interpretation as guidance when
applying regulation 1.23 of MARPOL Annex I to determine the regulatory deadweight to be
entered on relevant statutory certificates, and to bring the unified interpretations to the attention
of all parties concerned.

SDC 4/16
Annex 9, page 2
ANNEX
UNIFIED INTERPRETATION OF REGULATION 1.23 OF MARPOL ANNEX I
Deadweight to be stated on certificates
Even-keel hydrostatics should be used to determine the regulatory deadweight to be entered

on relevant statutory certificates.
***

SDC 4/16
Annex 10, page 1
ANNEX 10
DRAFT MSC CIRCULAR
INTERIM GUIDELINES FOR USE OF FIBRE REINFORCED PLASTIC (FRP) ELEMENTS

WITHIN SHIP STRUCTURES: FIRE SAFETY ISSUES

having considered a proposal by the Sub-Committee on Ship Design and Construction at its
fourth session, approved the Interim guidelines for use of Fibre Reinforced Plastic (FRP)
elements within ship structures: Fire safety issues, as set out in the annex.
2 The annexed Interim guidelines should be used as a supplement to the Guidelines for
the approval of alternatives and equivalents as provided for in various IMO instruments
(MSC.1/Circ.1455) and the Guidelines on alternative design and arrangements for fire safety
(MSC.1/Circ.1002, as amended by MSC.1/Circ.1552) when approving FRP elements within
ship structures.
3 Member States are invited to apply the annexed Interim guidelines when approving
alternative designs and arrangements for FRP elements in ship structures in accordance with
SOLAS regulation II-2/17 (Alternative design and arrangements). The Interim guidelines are
intended to ensure that a consistent approach is taken with regard to standards of fire safety of
ships making use of FRP elements in their structures and that the level of fire safety afforded
by the provisions of SOLAS chapter II-2 is maintained.
4 These guidelines have been issued as "interim guidelines" in order to gain experience
in their use. They should be reviewed four years after their approval in order to make any
necessary amendments based on experience gained.
5 In the meantime, Member States and international organizations are invited to submit
information, observations, comments and recommendations based on the practical experience
gained through the application of these Interim guidelines to the Sub-Committee on Ship Design
and Construction under the agenda item "Any other business".
6 Member States are invited to bring the annexed Interim guidelines to the attention
of all parties concerned.

SDC 4/16
Annex 10, page 2
ANNEX
INTERIM GUIDELINES FOR USE OF FIBRE REINFORCED PLASTIC (FRP) ELEMENTS
WITHIN SHIP STRUCTURES: FIRE SAFETY ISSUES
Chapter 1 General
1.1 Fibre Reinforced Plastic (FRP) composite is a lightweight material composition with
high strength to weight ratio and corrosion resistance compared to steel. A key issue when
considering combustible FRP elements within ship structures is fire safety. These guidelines
raise issues which are pertinent also to non-combustible FRP composite structures, but any
element that can comply with the prescriptive requirements is outside the scope of these
guidelines; in these guidelines combustible FRP elements are implied.
1.2 These guidelines currently do not fully address the risks of progressive structural
collapse or global loss of structural integrity due to fire associated with a fully FRP composite ship
or FRP composite structures contributing to global strength. Deviations from the guidelines should
be identified and additional assessments be performed, as appropriate.
1.3 An element, for the purpose of these guidelines, is a structure which may be removed
without compromising the safety of the ship.
1.4 Special emphasis should be given to safety-critical spaces such as, but not limited to,
control stations, evacuation stations and escape routes.
1.5 FRP elements can be approved as part of alternative design and arrangements of
fire safety, according to SOLAS regulation II-2/17. In accordance with SOLAS
regulation II-2/17.2.1, the alternative design and arrangements shall meet the fire safety
objectives and the functional requirements in SOLAS chapter II-2.
1.6 These guidelines have been developed to provide support for Administrations to
ensure that fire safety evaluation of FRP elements can be made in a consistent way by any
flag State. The guidelines contain important factors that should be addressed in
the engineering analysis required by SOLAS regulation II-2/17. It is recommended that
the individuals assigned to review such analysis have expertise in fire safety and also in fire
safety engineering or risk assessment.
1.7 These guidelines are intended to facilitate the safe use of FRP elements in
shipbuilding, which may be categorized, for example, as:
.1 integrated structures: elements integrated into the ship structure that do not
contribute to global strength (e.g. pool, sliding roof, stage, tender
platform, etc.); and
.2 components: non-structural parts that are connected to the ship structure via
mechanical or chemical joining methods (e.g. balcony, funnel, mast, gantry,
flooring, etc.).
1.8 There is a diversity of FRP composite compositions with different properties and
the scope of their intended use may vary widely. Therefore, these guidelines cannot provide
all the necessary information for approval. Nonetheless, it is important that all essential
questions are raised during the approval process, which may be remedied by these guidelines.
They contain known properties, problems and solutions with regard to fire safety but cannot
be considered to cover all possible hazards associated with use of FRP composite materials.
Furthermore, use of FRP elements may also affect other parts of a ship's safety than those
associated with fire, e.g. those specified in appendix A (Issues other than fire safety).

SDC 4/16
Annex 10, page 3
Chapter 2 Assessing fire safety of FRP composite structures
2.1 Laminates, sandwich panels and stiffeners formed by polymers, fibres and core
materials may be combined in different ways to make up FRP elements on ships. Within these
guidelines, FRP is defined as multi-material compositions of monolithic or sandwich
constructions. Monolithic constructions and skin layers of sandwich constructions are based
on long-fibre reinforced resins. Reinforcements can be for example fabrics of glass, carbon,
aramide or basalt fibres. Resins shall be based on duromer (thermoset) resin. Sandwich core
materials are typically based on structural foams or honeycombs. Coatings (gelcoats, topcoats
or paints), casting masses and adhesives are handled under these guidelines as well. Some
typical FRP composite materials and compositions used in shipbuilding are further described
in appendix B (FRP composite materials and compositions used in shipbuilding). It also
exemplifies fire behaviour of typical FRP composite constituents and compositions. Relevant
fire properties of the particular materials considered in an alternative design must be derived
by tests for each specific design case (see appendix D (Fire testing of FRP composite)).
2.2 Use of FRP composites on SOLAS vessels is generally not allowed due to prescriptive
requirements on use of non-combustible materials. However, when design or arrangements
deviate from the prescriptive requirements of SOLAS chapter II-2, review and approval can be
carried out in accordance with SOLAS regulation II-2/17. Combustible FRP elements and
related safety measures can thus be treated as alternative fire safety design and
arrangements. Engineering analysis, evaluation and approval shall then be carried out based
on a procedure summarized in the regulation, whilst more detailed descriptions are contained
in the Guidelines on alternative design and arrangements for fire safety (MSC/Circ.1002, as
amended by MSC.1/Circ.1552). Life safety performance criteria are contained in
MSC.1/Circ.1552. These guidelines support the use of performance-based methods of fire
safety engineering to verify that the fire safety of a ship with alternative design and
arrangements is equivalent to the fire safety stipulated by prescriptive requirements, a concept
often referred to as the "equivalence principle". Briefly, the procedure can be described as
a two-step deterministic risk assessment carried out by a design team. The two major parts to
be performed are:
.1 the preliminary analysis in qualitative terms; and
.2 the quantitative analysis.
In the first part, the design team is to define the scope of the analysis, identify hazards and,
from these, develop design fire scenarios as well as develop trial alternative designs.
The different components of the preliminary analysis in qualitative terms are documented in
a preliminary analysis report which needs consent by the design team before it is sent to
the Administration for review. With the Administration's approval, the preliminary analysis
report documents the inputs to the next step of the assessment, the quantitative analysis.
At this stage, the design fire scenarios are quantified and outcomes are compared with
performance criteria determined based on the fire safety objectives and the functional
requirements of the SOLAS regulations. The criteria are quantified with reference to relevant
prescriptive requirements or by comparison to the performance of an acceptable prescriptive
design. The documented level of fire safety of the alternative design and arrangements may
therefore not be absolute but relative to the fire safety of a traditional design, which is a product
of the fire safety implied by prescriptive regulations. Accounting for uncertainties when
comparing levels of fire safety, the final documentation of the engineering analysis based on
SOLAS regulation II-2/17 (hereafter referred to as "SOLAS regulation II-2/17 assessment")
should with reasonable confidence demonstrate that the fire safety of the alternative design
and arrangements is at least equivalent to that of a prescriptive design.

SDC 4/16
Annex 10, page 4
2.3 According to SOLAS regulation II-2/17, alternative design and arrangements for fire
safety should provide a degree of safety at least equivalent to that achieved by compliance
with the prescriptive requirements. It is therefore important that the approach used to assess
safety can properly describe the effects on fire safety posed by the alternative design and
arrangements, i.e. descriptions of uncertainties must be sufficient to establish appropriate
safety margins. This is a particularly relevant consideration when evaluating FRP composite
structures. Depending on the scope, an assessment in accordance with MSC/Circ.1002, as
amended by MSC.1/Circ.1552, could appear overly complex or insufficient. Recommendations
and requirements for the method used to assess the safety of an alternative design involving
FRP composite structures are discussed in appendix C (Recommendations regarding
the assessment). It may also be relevant to consider the Guidelines for the approval of
alternatives and equivalents as provided for in various IMO instruments (MSC.1/Circ.1455),
which describe an approach which is more adaptable to the scope of the alternative design
and arrangements. MSC.1/Circ.1455 was developed to provide a consistent process for
the coordination, review and approval of alternative design and arrangements in general,
i.e. not only concerning fire safety. It may therefore provide additional guidance when the use
of FRP composite structures affects other aspects of safety than those related to fire
(see appendix A (Issues other than fire safety)). In detail it also describes the risk-based
approval process surrounding the assessment. As referred to in SOLAS, the guidelines in this
document take basis in MSC/Circ.1002, as amended by MSC.1/Circ.1552.
2.4 One of the first and most foundational steps in the SOLAS regulation II-2/17 assessment
is to form an approval basis. This is done by identifying the prescriptive requirement(s) deviated
by the alternative design and arrangements (SOLAS regulation II-2/17.3.2). With an
understanding of their associated functional requirements, the deviated prescriptive
requirements are then used to define performance criteria, as described in MSC/Circ.1002, as
amended by MSC.1/Circ.1552, paragraphs 4.4, 5.1.2 and 6.3.2 and in SOLAS
regulation II-2/17.3.4. However, owing to limitations in the current regulations, identification of
deviated prescriptive requirements may not form a sufficient basis to ensure equivalent safety.
When considering FRP composite structures, deviations fundamentally concern the required
non-combustibility of structures. With the assumption that non-combustible structures are
used, the fire safety regulations include unwritten (implicit) safety requirements. In order to
establish an appropriate approval basis, it is therefore required in each design case to perform
the necessary investigations to identify all relevant effects on fire safety. This is further
described in appendix C (Recommendations regarding the assessment). In particular,
the achievement of each fire safety objective and functional requirement should be judged
independently, including the functional requirements in purpose statements at the beginning
of the regulations. Potential challenges to fire safety objectives, functional requirements,
purpose statements and prescriptive requirements in SOLAS chapter II-2 when considering
FRP elements are exemplified in chapter 3 (Important factors to consider when evaluating
FRP elements with starting point in the regulations of SOLAS chapter II-2). Further
recommendations regarding an assessment of fire safety involving FRP elements are
presented in appendix C (Recommendations regarding the assessment).
2.5 A number of fire hazards may be introduced by the use of FRP elements. A useful
starting point for the hazard identification is the investigation of challenges to regulations and
thus chapter 3 (Important factors to consider when evaluating FRP elements with starting point
in the regulations of SOLAS chapter II-2). Fire hazards relevant for further investigation,
categorized according to the regulations in SOLAS chapter II-2, are particularly:
.1 probability of ignition;
.2 fire growth potential;

SDC 4/16
Annex 10, page 5
.3 potential to generate smoke and toxic products;
.4 containment of fire;
.5 firefighting; and
.6 structural integrity.
2.6 The fire hazards and performance of safety measures may be quantified by tools for
fire safety engineering and risk assessment and with reference to fire tests (see appendix D
(Fire testing of FRP composite)). Sufficient safety may be assured within delimited areas
separately, e.g. covered by functional requirements or regulations, or included in a holistic
estimation of effects on safety. The former is illustrated along with further examples of an
assessment in appendix E (Assessment examples).
2.7 Key terms are defined in MSC/Circ.1002, as amended by MSC.1/Circ.1552,

and MSC.1/Circ.1455, as well as in fire safety engineering guidelines for buildings,
e.g. ISO 23932.
Chapter 3 Important factors to consider when evaluating FRP elements with starting
point in the regulations of SOLAS chapter II-2
The different fire safety regulations in SOLAS chapter II-2 have been analysed with the intention
to identify important factors that could be necessary to address when using FRP elements in
ship structures. These factors are described in the following paragraphs. Each of the regulations
with prescriptive requirements (regulations 4 to 23) starts with a purpose statement. Each
purpose statement consists of a regulation objective and one or several regulation functional
requirements. The purpose statements have been reproduced for each regulation followed by
comments on how a ship with FRP elements may challenge the regulation. The regulations
are not only investigated based on potential deviations and how these may have an effect on
safety but also in a broader sense, i.e. how a ship with FRP composite structures could affect
the regulations' purpose statements or envisioned purpose.
Note that this investigation of the regulations is not complete and may not cover all relevant
effects on fire safety for a certain design and arrangements with FRP composite structures.
The intention is for these guidelines to be developed, concretized and updated based on
the regulations. In particular, some of the regulations could be investigated in more detail and
from different perspectives.
3.1 Regulation 1 – Application
There are currently no comments to this regulation with regard to FRP composite.
3.2 Regulation 2 – Fire safety objectives and functional requirements
Paragraph 2 states a number of functional requirements which are embodied in the regulations
of the fire safety chapter in order to achieve the fire safety objectives set out in paragraph 1.
In particular, the third functional requirement (regulation 2.2.1.3) requires restricted use of
combustible material. The fire safety objectives and the functional requirements can be
achieved by ensuring compliance with all prescriptive requirements in parts B, C, D, E and G
or by alternative design and arrangements which comply with part F (regulation 17). Approval
in accordance with regulation 17 still requires that the alternative design and arrangements
meet the fire safety objectives and the functional requirements but allows doing so in a different
way than in accordance with the prescriptive requirements.

SDC 4/16
Annex 10, page 6
In evaluating the achievement of the fire safety objectives and the functional requirements from
a broad perspective, it may be stated that a ship with FRP elements may achieve some better
and some worse than a traditional design. The focus on safety of human life in the fire safety
objectives makes it topical to address not only the safety of passengers, but also the safety of
firefighters and crew. Consideration of the functional requirements especially indicates that
risks from adding combustible materials need to be accounted for.
3.3 Regulation 3 – Definitions
From the definitions in this regulation a few details may be useful to recapitulate with regard to
FRP composite:
3.2 From the definition of "A" class divisions it should be noted that such divisions
are described to be constructed of "steel or other equivalent material" and
that they should be so constructed as to be capable to preventing
the passage of smoke and flame to the end of the one-hour standard fire test.
3.4 From the definition of "B" class divisions it should be noted that such divisions
are described to be constructed of "approved non-combustible materials" and
that they should be so constructed as to be capable to preventing the passage
of smoke and flame to the end of the first half hour of the standard fire test.
3.10 From the definition of "C" class divisions it should be noted that such
divisions are described to be constructed of "approved non-combustible
materials" and that no other requirements apply.
3.33 From the definition of non-combustible material it should be noted that such
material is described to neither burn nor to give off flammable vapours in
sufficient quantity for self-ignition when heated to approximately 750°C.
3.43 From the definition of steel or other equivalent material it should be noted
that the phrase refers to any non-combustible material which, by itself or due
to insulation provided, has structural and integrity properties equivalent to
steel at the end of the applicable exposure to the standard fire test.
Therefore, there are requirements regarding non-combustibility as well as
structural and integrity properties. Note that the former is not limited in time
but the latter requirements need only be achieved until the end of
the applicable exposure of the standard fire test. An aluminium alloy with
appropriate insulation is used to exemplify an equivalent material to steel.
3.47 From the definition of a standard fire test it is described to be a test in which
specimens of the relevant bulkheads or decks are exposed in a test furnace
to temperatures corresponding approximately to the standard time-temperature
curve.
3.4 Regulation 4 – Probability of ignition
Purpose statement:
The purpose of this regulation is to prevent the ignition of combustible materials or

flammable liquids. For this purpose, the following functional requirements shall be met:
.1 means shall be provided to control leaks of flammable liquids;
.2 means shall be provided to limit accumulation of flammable vapours;
.3 the ignitability of combustible materials shall be restricted;

SDC 4/16
Annex 10, page 7
.4 ignition sources shall be restricted;
.5 ignition sources shall be separated from combustible materials and

flammable liquids; and
.6 the atmosphere in cargo tanks shall be maintained out of the explosive

range.
Comments:
1 Using combustible materials for structures is not in conflict with the objective of this
regulation. However, it states to aim at preventing the ignition of combustible materials.
Looking at the prescriptive requirements, they prevent the occurrence of fire by restricting
ignition sources and some combustibles. Mainly fuels and the handling of highly flammable
substances are concerned, but also a few miscellaneous items in enclosures. Most are ignition
sources and the only actual combustible material concerned is primary deck coverings.
If applied within accommodation, service or control spaces or on cabin balconies, they shall
not readily ignite (regulation 4.4.4). This requirement may seem a bit illogical since a primary
deck covering is the first layer fitted on a deck, used to smooth out unevenness, and covered
by a floor construction. It is rather the surface of the floor construction which may be exposed
to a potential ignition source. Furthermore, the requirement implies the primary deck coverings
should have low flame-spread characteristics, which is a requirement that fits better in
regulation 5. However, apart from this requirement, there are no other prescriptive
requirements to be found on how the ignitability of combustible materials shall be restricted,
as stated amongst the functional requirements in the purpose statement.
2 New hazards may be introduced where FRP composite is used close to significant
ignition sources, such as exhaust pipes or other high-temperature surfaces. It may be argued
that this challenges the functional requirement on separation of ignition sources from
combustible materials. Due to assumptions regarding the use of non-combustible structures,
this safety function is not clearly stated in prescriptive requirements of this regulation. It is
nevertheless important to identify ignition sources and ensure that FRP composite surfaces
are properly protected.
3 It may be argued that leaving combustible FRP composite surfaces unprotected is not
in line with the functional requirement concerning restricted combustibility. However, this rather
concerns ignition sources and easily ignitable (e.g. by a small flame) combustibles and
flammable substances whilst combustible materials which have restricted ignitability, such as
FRP composite, are managed in regulation 5. It is noted that an IMO test method for evaluation
of restricted ignitability of products does not exist.
3.5 Regulation 5 – Fire growth potential
Purpose statement:
The purpose of this regulation is to limit the fire growth potential in every space of
the ship. For this purpose, the following functional requirements shall be met:
.1 means of control for the air supply to the space shall be provided;
.2 means of control for flammable liquids in the space shall be provided; and
.3 the use of combustible materials shall be restricted.

SDC 4/16
Annex 10, page 8
Comments:
1 This regulation oversees materials and other items in spaces with the intention to limit
the fire growth potential. Looking at the functional requirements, neither of the first two is
affected by use of FRP elements in ship constructions. However, the third functional
requirement must be taken into account as it states that the use of combustible materials shall
be restricted. The definition of a non-combustible material is given in regulation 3.33 and
defines it as a material that neither burns nor gives off flammable vapours when heated
to 750°C. For example, vinyl ester, which is often used as resin in FRP composite, will give
rise to pyrolysis gases above 500°C.
2 In the prescriptive requirements, use of non-combustible and combustible materials

is primarily managed in paragraph 3. Except interiors and furnishings, the requirements
concern linings, grounds, draught stops, ceilings, faces, mouldings, decorations, veneers,
insulation materials, partial bulkheads etc. These are also the materials that will govern
the growth phase of a fire, together with, for example, luggage and other loose fittings. In
general, all surfaces and linings in accommodation and service spaces must fulfil requirements
of a maximum calorific value of 45 MJ/m2, a maximum volume of combustible material and
have low flame-spread characteristics according to the FTP Code. However, since
the regulations assume that the bulkhead plate behind any wall construction is steel, there are
no requirements regarding the materials behind the wall construction.
3 The requirements in this regulation could be claimed to apply to surfaces of any sort.
Therefore, if the same approved materials for linings, grounds, draught stops, ceilings, faces,
mouldings, decorations, veneers, etc. are used in a ship with FRP composite constructions as
in a traditional (prescriptive) design, it could be claimed that the design complies with
the prescriptive requirements in regulation 5. This would generally not increase the fire growth
potential in the spaces in the initial stages during evacuation. However, if the FRP composite
surfaces are left uncovered or if divisions are constructed with combustible FRP composite
just underneath surfaces of low flame-spread characteristics, it can be argued that the surface
laminate in fact represents the surface lining, to which requirements regarding low
flame-spread characteristics and maximum volume of combustible material apply;
the requirement on maximum calorific value would then apply to the core. With this reasoning
all of these requirements would generally be deviated.
4 As mentioned above, thermal insulation may be used to provide structural integrity,

which will also protect the combustible FRP composite surfaces from fire involvement,
e.g. for 60 minutes. In this case the FRP composite will not add to the fire growth potential in
the space within the first hour of a fire having the same intensity as a standard fire test curve.
5 As mentioned above, this regulation covers materials and other items in spaces with
the intention to limit the fire growth potential. All discussions above have considered internal
spaces. Since external surfaces on ships are typically made up of painted steel there has not
been any reason to regulate this matter. This is another example of where the FRP composite
goes beyond the steel-based regulations. Making exterior surfaces in combustible FRP composite
will affect the fire growth potential and could cause vertical fire spread between decks, which
is a hazard that must be addressed on these ships. Hazardous exterior surfaces could for
example be protected to achieve low flame-spread characteristics or be protected with
drencher system. An indirect way to manage the problem is to use fire rated windows, which
could avoid fire spread.

SDC 4/16
Annex 10, page 9
3.6 Regulation 6 – Smoke generation potential and toxicity
Purpose statement:
The purpose of this regulation is to reduce the hazard to life from smoke and toxic
products generated during a fire in spaces where persons normally work or live.
For this purpose, the quantity of smoke and toxic products released from combustible
materials, including surface finishes, during fire shall be limited.
Comments:
1 Similarly to regulation 5, the prescriptive requirements of regulation 6 mostly concern

enclosures. All materials involved in a fire will contribute to the production of toxic smoke but
during the first stages of a fire it is mainly the exposed surface that will contribute to
the generation and toxicity of smoke. This regulation generally controls exposed surface
finishes and primary deck coverings.
2 FRP composites could either be covered with approved surface materials or left
unprotected. In spaces where the FRP composite is left unprotected, it could be difficult to fulfil
regulation 6.2.1. Furthermore, if an approved surface material is used on the FRP composite,
it may be argued that the regulations are predicated on that a non-combustible material is used
for the ship structures that are underneath. The generation and toxicity of smoke may,
depending on the construction, therefore not be limited to the same extent as in a prescriptive
design during an enclosure fire.
3 When scrutinizing regulations 5 and 6, it is important to realize that both regulations

manage smoke production but where the latter mainly has to do with the individual material
characteristics, it could be said that regulation 5 manages so that an unlimited area of
combustible materials does not catch fire and produce smoke and that regulation 6 manages
the potential of each square meter that can be involved in a fire.
4 Thermal insulation may be used to protect the combustible FRP composite surfaces
from becoming involved in a fire. For the time that the construction is thermally protected,
the FRP composite will not add to the generation or toxicity of the produced smoke. In the event
of a fire lasting long enough to involve the FRP composite divisions, an increased generation
and toxicity of smoke could be argued to occur, in comparison with a steel ship. This will
depend on the selection of plastic materials. For instance, PVC is known to release highly toxic
hydrochloric acid (HCl) during combustion.
5 It is hard to predict whether the smoke generation and toxicity at a given time would
be worse in a ship with FRP elements compared to a steel ship depending on the insulating
capacity of the construction. If thermal insulation is used to protect the FRP composite, fire
spread will likely be delayed. It could be noted that when a fire starts to involve the protected
FRP composite divisions, conditions will already have been uninhabitable for a while.
An increased smoke generation or toxicity could be hazardous to persons on the embarkation
deck depending on wind direction.
6 Fires on open deck and involving exterior surfaces in FRP composite could also be
affected by the smoke generation and toxicity. However, this problem may not be as relevant
when considering exteriors, since smoke management is not critical.

SDC 4/16
Annex 10, page 10
3.7 Regulation 7 – Detection and alarm
Purpose statement:
The purpose of this regulation is to detect a fire in the space of origin and to provide
for alarm for safe escape and firefighting activity. For this purpose, the following
functional requirements shall be met:
.1 fixed fire detection and fire alarm system installations shall be suitable for
the nature of the space, fire growth potential and potential generation of
smoke and gases;
.2 manually operated call points shall be placed effectively to ensure a readily

accessible means of notification; and
.3 fire patrols shall provide an effective means of detecting and locating fires
and alerting the navigation bridge and fire teams.
Comments:
In general, use of FRP composite does not present any deviations from prescriptive
requirements. However, the functional requirements give reason to oversee the need for
detection. Considering the first regulation functional requirement, there is no reason to believe
that significantly less smoke is produced by FRP composites than organic materials in general.
However, since the fire growth potential in some areas may be affected, there may also be an
additional need for detection. For areas where non-insulated FRP elements are used, it is
particularly critical to provide early activation of an extinguishing system with quick detection.
It may therefore be relevant with faster or more reliable smoke detection or to provide it in
additional areas of the ship, possibly even in open spaces or void spaces. The potential
increased need for detection should be considered in the fire risk assessment and depends on
how FRP composite is used.
3.8 Regulation 8 – Control of smoke spread
Purpose statement:
The purpose of this regulation is to control the spread of smoke in order to minimize
the hazard from smoke. For this purpose, means for controlling smoke in atriums,
control stations, machinery spaces and concealed spaces shall be provided.
Comments:
As discussed in 3.6 (regulation 6 – Smoke generation potential and toxicity) the amount of
smoke generated in a fire test with FRP composite structures (glass fibre reinforced polyester
with PVC core) was only slightly larger than that from a fire in a steel ship. If this is the case
for the alternative design and arrangements being evaluated, this would indicate that
the current requirements for control of smoke spread could be met.
3.9 Regulation 9 – Containment of fire
Purpose statement:
The purpose of this regulation is to contain the fire in the space of origin. For this
purpose the following requirements shall be met:
.1 the ship shall be divided by thermal and structural boundaries;

SDC 4/16
Annex 10, page 11
.2 thermal insulation boundaries shall have due regard to the fire risk of the space
and adjacent spaces; and
.3 the fire integrity of the division shall be maintained at openings and

penetrations.
Comments:
1 This regulation prescribes main vertical and horizontal zones and, where necessary,
internal bulkheads to be made up by divisions of "A" class standard. "A" class means that steel
or other equivalent material shall be used. Regulation 3.43 defines steel or other equivalent
material as a non-combustible material which, by itself or by insulation provided, has structural
and integrity properties equivalent to those of steel at the end of the standard fire test.
Unprotected FRP composite generally ignites when exposed to significant fire but could for
example be combined with thermal insulation in order to gain fire integrity comparable with "A"
class standard. Tests have demonstrated that the temperature rise at the unexposed side of
a FRD60 (cf. HSC Code) division will be as low as 45°C after 60 minutes of fire exposure
(temperature rise and integrity test in accordance with the standard test for bulkheads and
decks, see the Test procedures for fire-resisting divisions of high-speed craft (MSC 45(65)).
This low conduction of heat will prevent heat from being transferred long distances through
the ship structure, which may be a fire risk in conventional ships.
2 The low conductivity of a FRD60 division can also give rise to a faster fire
development within the enclosed space, equivalent to an insulated aluminium structure or
a heavily insulated steel structure (e.g. "A-60" class). When insulation or any protective surface
layer is deteriorated and the surface temperature of the FRP composite reaches its ignition
temperature, the FRP composite will start contributing to the fire, which could also accelerate
the fire development if additional oxygen is available.
3 Specific fire integrity and insulation requirements for internal decks and bulkheads
depend on a classification made of the spaces and are given in tables in regulation 9. The way
spaces are assigned fire categories may need to be reconsidered, in particular for spaces with
added fire load by exposed untreated FRP composite. This includes open decks.
4 If FRP composite is used on open deck, all connections between interior and external
spaces must be reconsidered. Design of windows, doors and ventilation systems may, for
example, need to be reconsidered due to the potential external fire hazards, i.e. due to potential
spread of smoke and fire into the ship or out to external surfaces.
5 Regarding penetrations in fire-resisting divisions, doors, pipes, window frames, etc.

are generally also required to be non-combustible when penetrating "A" class divisions.
The integration of such penetrations into an FRP composite division must be documented by
fire tests or potentially by engineering judgement. The integration of doors, windows, cable
glands, ducts, fire dampers and pipes in FRP composite fire divisions has been successfully
demonstrated in tests.
6 A robust integration of the insulation systems onto an FRP composite fire division is
crucial. The effect of voids between insulation and the composite structure could be further
evaluated. Essential systems in a fire situation, such as sprinkler systems, piping and ducts,
must have a fastening/support system that is designed not to fail in case of a fire.

SDC 4/16
Annex 10, page 12
3.10 Regulation 10 – Firefighting
Purpose statement:
The purpose of this regulation is to suppress and swiftly extinguish fire in the space
of origin. For this purpose the following requirements shall be met:
.1 fixed fire-extinguishing systems shall be installed, having due regard to the fire
growth potential of the spaces; and
.2 fire-extinguishing appliances shall be readily available.
Comments:
1 The first functional requirement states that the fixed fire-extinguishing systems shall
have due regard to the fire growth potential of the space. It is only if the fire growth potential
differs significantly that it is necessary to take into account FRP composites when designing
the fire-extinguishing systems. In most cases, fire growth in the FRP composite will not be
dimensioning for the fire-extinguishing system since more rapid fire developments can
generally occur in other combustibles and since the size of a fire depends on the oxygen
supply. The fire pump capacity and pressure requirements should therefore generally not need
to be changed. However, since early extinguishment is important, it may still be suitable to
oversee the firefighting systems and that extinguishment is managed properly.
2 It may also be necessary to consider fire-extinguishing systems and equipment in

additional places of a ship with FRP composite constructions. If exterior surfaces are made of
FRP composite they may need to be protected in order to prevent an enclosure fire from
spreading to the exteriors if a door or window is left open or broken, e.g. by a sprinkler above
the openings. It may also be relevant to install drencher systems covering essential parts of
the hull or exteriors of superstructure, if there is a risk of fire spread or deterioration of structural
performance.
3 Even though the purpose statements and prescriptive requirements of this regulation
only cover fire-extinguishing systems and appliances, it is in the context of the regulation title
also relevant to consider effects on manual firefighting routines. There are a few significant
differences:
.1 First and foremost, the need to perform defensive boundary cooling from
the outside of a fire enclosure is removed. It is instead important to have an
offensive strategy to provide direct cooling of the fire. Boundary cooling is
a strategy that requires many resources without actually fighting the fire, but
mainly hindering fire spread. A much more efficient way to fight a fire is to
quickly reach inside the enclosure. With traditional equipment this may not
be possible due to the heat or risk of fire spread if a door is opened. However,
there is more suitable firefighting equipment already in use, such as
the Cutting Extinguisher or Fog Spear. Tests have demonstrated that
firefighting by such equipment through small holes in the FRP composite
boundaries is very effective. The holes may be pre-fabricated or made by
equipment on site. This will allow dampening the fire from outside of the fire
origin. Suitable equipment in combination with a rerouting of firefighting
resources relieved from boundary cooling to either assist in active combat of
the fire may increase both effectiveness and efficiency.

SDC 4/16
Annex 10, page 13
.2 Furthermore, a fire which has taken root in the FRP composite may be
difficult to fully extinguish. This implies more resources will be needed to
keep watch over fire-scorched areas to ensure that the FRP composite does
not reignite. This may not significantly interfere with the critical stages of
taking control of the fire.
.3 Another aspect of how firefighting routines could be affected is that the improved
thermal resistance of FRP composite structures could imply difficulties in
finding the seat of the fire from adjacent compartments with a commonly
used thermal imaging camera.
.4 Routines regarding potential collapse must also be developed in order to

insure the safety of passengers and firefighting crew.
4 All in all, the ability to focus more resources on actively fighting the fire, combined with
the introduction of tools to cool hot fire gases from an adjacent compartment could improve
the efficiency and effectiveness of firefighting in ships with FRP composite structures. In any
case, effects on firefighting routines must be taken into consideration when making ship
structures in FRP composite.
5 Additional equipment for manual firefighting could also be necessary, e.g. in open
deck spaces surrounded by FRP composite surfaces.
3.11 Regulation 11 – Structural integrity
Purpose statement:
The purpose of this regulation is to maintain structural integrity of the ship, preventing
partial or whole collapse of the ship structures due to strength deterioration by heat.
For this purpose, the materials used in the ships' structure shall ensure that
the structural integrity is not degraded due to fire.
Comments:
1 This regulation intends to ensure that structural integrity is maintained in case of a fire.
After the purpose statement of the regulation, paragraph 2 of regulation 11 states that:
"The hull, superstructures, structural bulkheads, decks and deckhouses shall be

constructed of steel or other equivalent material. For the purpose of applying
the definition of steel or other equivalent material as given in regulation 3.43,
the "applicable fire exposure" shall be according to the integrity and insulation
standards given in tables 9.1 to 9.4. For example, where divisions such as decks or
sides and ends of deckhouses are permitted to have "B-0" fire integrity, the "applicable
fire exposure" shall be half an hour."
2 Structures shall thus be constructed of steel or other equivalent material, i.e. any
non-combustible material which, by itself or due to insulation provided, has structural and
integrity properties equivalent to steel at the end of the standard fire test. This prescriptive
requirement cannot be complied with if combustible FRP composite structures are used.
The existing fire tests within the FTP Code for A and B class divisions are conducted over
a period of up to 60 minutes. Structural and integrity properties equivalent to steel may be
achieved for such a time of fire exposure in the standardized test, for example if the FRP
composite is sufficiently insulated. However, unlike the requirements on structural and integrity
properties, the requirement on non-combustibility is not time-limited. The fire tests do not
assess the performance of the material after the end of the test, nor when subject to load.

SDC 4/16
Annex 10, page 14
3 Insulated steel divisions may lose fire integrity after for example 60 min; not due to
strength deterioration by heat but due to possible fire spread to adjacent compartments by
heat transfer. A prolonged fire could involve and deteriorate an FRP composite structure when
thermal insulation or other means are no longer enough to provide structural and integrity
performance. A large enough fire could then bring about a local collapse.
4 Steel generally loses its structural strength at about 400°C to 600°C and an
unstiffened FRP composite sandwich panel may lose bonding between core and laminate, and
thereby structural performance, when heated to about 150°C (or a temperature where
the bonding between core and laminate starts to soften). Improved structural integrity
of FRP composite structures may be achieved by use of e.g. stiffeners, pillars or additional
layers but steel ships have proved to be able to survive fire for several days without progressive
structural collapse occurring. This is particularly important when considering that the ship shall
retain safe areas for the refuge of passengers (SOLAS regulation II-2/21.5), including control
stations to remain intact and habitable for command and control activities necessary during an
incident. This can for example affect the measures required to achieve successful evacuation
of the ship (cf. HSC Code). It is crucial that fire hazards introduced in case of a long-lasting fire
(lasting for more than 60 minutes) are addressed in the SOLAS regulation II-2/17 assessment.
5 Deviations from prescriptive requirements are found in regulation 11.4 if steel

(not "steel or other equivalent material") is not used for structures forming crowns, casings and
floor plating of machinery spaces of category A. Use of FRP composite for such structures
may need special consideration.
6 Further to the above, steel-FRP joints need to be assessed in detail to ensure that
structural fire integrity is achieved (see also section B.3.4 of appendix B).
3.12 Regulation 12 – Notification of crew and passengers
Purpose statement:
The purpose of this regulation is to notify crew and passengers of a fire for safe
evacuation. For this purpose, a general emergency alarm system and a public
address system shall be provided.
Comments:
There are no obvious challenges posed to this regulation by the use of FRP composite.
However, a public address system may be indirectly affected if special instructions must be
made to avoid passengers to reside in certain areas where there is a risk of collapse.
An exterior fire could also affect the possibility of using certain exterior areas or life-saving
appliances.
3.13 Regulation 13 – Means of escape
Purpose statement:
The purpose of this regulation is to provide means of escape so that persons on board
can safely and swiftly escape to the lifeboat and liferaft embarkation deck. For this
purpose, the following functional requirements shall be met:
.1 safe escape routes shall be provided;
.2 escape routes shall be maintained in a safe condition, clear of obstacles; and

SDC 4/16
Annex 10, page 15
.3 additional aids for escape shall be provided as necessary to ensure

accessibility, clear marking, and adequate design for emergency situations.
Comments:
1 This regulation aims to provide means for persons to safely and swiftly escape a fire,
assemble and proceed to their embarkation station. Considering the prescriptive requirements,
regulation 13.3.1.3 requires all stairways in accommodation spaces, service spaces and
control stations to be of steel frame construction or other equivalent material sanctioned by
the Administration. If they are made of FRP composites they need to be evaluated in the fire
safety analysis. The same applies to stairways and ladders in machinery spaces
(regulation 13.4.1). However, such constructions are generally not considered in other
materials than steel, even on ships in FRP composite. It may be noted that safe havens and
escape ways manufactured from composites are used in the offshore industry.
2 In order to achieve safe escape routes, regulation 13 requires fire integrity and
insulation in several places, referring to values in regulation 9 (tables 9.1 to 9.4). A sufficiently
insulated FRP composite division could be claimed to achieve these requirements (since
non-combustibility is not required).
3 In an FRP composite structure the temperature on the unexposed side could, due to
the high insulation capacity of the composite construction, be very low even after 60 minutes of
fire. The heat from a fire will therefore to a larger extent stay in the fire enclosure and not easily
be transmitted to adjacent spaces. This could be advantageous in an escape situation.
3.14 Regulation 14 – Operational readiness and maintenance
Purpose statement:
The purpose of this regulation is to maintain and monitor the effectiveness of the fire
safety measures the ship is provided with. For this purpose the following functional
requirements shall be met:
.1 fire protection systems and firefighting systems and appliances shall be

maintained ready for use; and
.2 fire protection systems and firefighting systems and appliances shall be

properly tested and inspected.
Comments:
The functional requirements are not affected by use of FRP composite. The fire protection
systems and firefighting systems and appliances must be maintained ready for use and should
be properly tested and inspected on a ship with FRP composite structures, as on any ship.
Even if the regulation may be directly applied and no deviations are posed, the content covered
by this regulation may be affected. Depending on the alternative design and arrangements,
there may be a need for faster extinguishment, increased capacity or improved reliability and
consequently more maintenance.

SDC 4/16
Annex 10, page 16
3.15 Regulation 15 – Instructions, onboard training and drills
Purpose statement:
The purpose of this regulation is to mitigate the consequences of fire by means of

proper instructions for training and drills of persons on board in correct procedures
under emergency conditions. For this purpose, the crew shall have the necessary
knowledge and skills to handle fire emergency cases, including passenger care.
Comments:
Except for the need for increased knowledge of firefighters considering strategies, techniques,
routines, etc. (see 4.10), there are no direct differences on a ship with FRP composite
structures in comparison with a traditionally built ship. In similarity with regulation 14,
the content covered by this regulation may be affected depending on the systems considered
in the alternative design and arrangements.
3.16 Regulation 16 – Operations
Purpose statement:
The purpose of this regulation is to provide information and instructions for proper ship
and cargo handling operations in relation to fire safety. For this purpose, the following
functional requirements shall be met:
.1 fire safety operational booklets shall be provided on board; and
.2 flammable vapour releases from cargo tank venting shall be controlled.
Comments:
There are no known challenges posed to this regulation for a ship with FRP composite
structures. In similarity with regulation 14, the content covered by this regulation may
nevertheless be affected depending on the solutions considered in the alternative design and
arrangements.
3.17 Regulation 17 – Alternative design and arrangements
Purpose statement:
The purpose of this regulation is to provide a methodology for alternative design and
arrangements for fire safety.
Comments:
The method described in regulation 17 (and MSC/Circ.1002, as amended

by MSC.1/Circ.1552) and its suitability when assessing fire safety in FRP composite
constructions is discussed in chapter 6 of these guidelines.

SDC 4/16
Annex 10, page 17
3.18 Regulation 18 – Helicopter facilities
Purpose statement:
The purpose of this regulation is to provide additional measures in order to address

the fire safety objectives of this chapter for ships fitted with special facilities for
helicopters. For this purpose, the following functional requirements shall be met:
.1 helideck structure shall be adequate to protect the ship from the fire hazards
associated with helicopter operations;
.2 firefighting appliances shall be provided to adequately protect the ship from

the fire hazards associated with helicopter operations;
.3 refuelling and hangar facilities and operations shall provide the necessary
measures to protect the ship from the fire hazards associated with helicopter
operations; and
.4 operation manuals and training shall be provided.
Comments:
Helicopter decks have previously been built with FRP composite materials on non-SOLAS ships
but will require special evaluations, including testing, and tailored detection and
extinguishment.
3.19 Regulation 19 – Carriage of dangerous goods
Purpose statement:
The purpose of this regulation is to provide additional safety measures in order to

address the fire safety objectives of this chapter for ships carrying dangerous goods.
For this purpose, the following functional requirements shall be met:
.1 fire protection systems shall be provided to protect the ship from the added
fire hazards associated with carriage of dangerous goods;
.2 dangerous goods shall be adequately separated from ignition sources; and
.3 appropriate personnel protective equipment shall be provided for the hazards

associated with the carriage of dangerous goods.
Comments:
None of the prescriptive requirements are likely to be affected by use of FRP composite
constructions. However, there may be reason to evaluate potential hazards from leakage of
dangerous goods onto an FRP composite deck, not only from a fire perspective. Certain
dangerous goods may for example cause the FRP composite to deteriorate if they come in
contact. These and other hazardous non-fire related scenarios must be considered. With
regard to fire, the time to collapse may change due to a potentially larger fire involving
combustible surrounding exterior FRP composite surfaces.

SDC 4/16
Annex 10, page 18
3.20 Regulation 20 – Protection of vehicle, special category and ro-ro spaces
Purpose statement:
The purpose of this regulation is to provide additional safety measures in order to

address the fire safety objectives of this chapter for ships fitted with vehicle, special
category and ro-ro spaces. For this purpose, the following functional requirements
shall be met:
.1 fire protection systems shall be provided to adequately protect the ship from
the fire hazards associated with vehicle, special category and ro-ro spaces;
.2 ignition sources shall be separated from vehicle, special category and ro-ro
spaces; and
.3 vehicle, special category and ro-ro spaces shall be adequately ventilated.
Comments:
This regulation describes requirements for ventilation, alarm and detection systems,
fire-extinguishing equipment and structural requirements for spaces with vehicles.
In passenger ships carrying more than 36 passengers, the boundary bulkheads or decks of
the ro-ro space are by regulation 20.5 required to achieve A-60 (with some exceptions where
the structural fire protection can be reduced to A-0). This cannot be achieved if such divisions
are made of FRP composite. Furthermore, even if not required by prescriptive requirements,
it may prove necessary to better address the first regulation functional requirement by passive
or active measures, e.g. by an additional active fire-extinguishing system on exterior surfaces.
For ro-ro spaces which are not of special category, the fire safety requirements are different
and in generally considered less stringent.
3.21 Regulation 21 – Casualty threshold, safe return to port and safe areas
Purpose statement:
The purpose of this regulation is to establish design criteria for a ship's safe return to
port under its own propulsion after casualty that does not exceed the casualty
threshold stipulated in paragraph 3 and also provides functional requirements and
performance standards for safe areas.
Comments:
Passenger ships constructed on or after 1 July 2010 having a length of 120 m or above or
having three or more main vertical zones, shall comply with this regulation. However, FRP
composite may be used in superstructures of the ship. In any case, it may be relevant to
evaluate e.g. whether the definition of the casualty threshold in regulation 21.3 is appropriate
for ships in FRP composite. Furthermore, structural integrity is important to consider (see
section 3.11) when considering safe areas for the refuge of passengers (regulation 21.5),
including control stations to remain intact and habitable for command and control activities
necessary during an incident.

SDC 4/16
Annex 10, page 19
3.22 Regulation 22 – Design criteria for systems to remain operational after a fire
casualty
Purpose statement:
The purpose of this regulation is to provide design criteria for systems required to
remain operational for supporting the orderly evacuation and abandonment of a ship,
if the casualty threshold, as defined in regulation 21.3, is exceeded.
Comments:
Passenger ships constructed on or after 1 July 2010 having a length of 120 m or above or
having three or more main vertical zones, shall comply with this regulation. However,
FRP composite may be used in superstructures of the ship. In any case, it may be relevant to
evaluate, e.g. whether there are additional hazards from the potential fire size and potential
smoke production from FRP structures with regard to evacuation and abandonment.
3.23 Regulation 23 – Safety centre on passenger ships
Purpose statement:
The purpose of this regulation is to provide a space to assist with the management of
emergency situations.
Comments:
Passenger ships constructed on or after 1 July 2010 shall have a safety centre on board
complying with the requirements of this regulation. From the safety centre all fire safety
systems should be available, such as ventilation systems, alarm systems, fire detection and
alarm systems, fire and emergency pumps etc. In general, this is not affected by the
FRP composite construction material, but it may be necessary to consider collapse when
determining the location of the safety centre.

SDC 4/16
Annex 10, page 20
APPENDIX A
ISSUES OTHER THAN FIRE SAFETY
1 Use of FRP composite may affect other parts of a ship's safety than those associated
with fire. Potential issues are listed below, categorized as issues which are indirectly related
to fire safety and issues which are unrelated to fire safety. It should be noted that the list of
issues in this appendix is not exhaustive and is meant to be used as an example.
2 An example of an issue indirectly related to fire safety is:
If, for example, additional drencher systems are installed in combination with
FRP composite, drainage and pumping arrangements may need to be installed in
the same manner as in SOLAS regulations II-2/19 and II-2/20.
3 Issues unrelated to fire safety are:
.1 Water intrusion over time in FRP elements:
Experience with FRP has demonstrated that resin-fibre construction may

absorb water over the years. This moisture is believed to be the source of
free water found in otherwise sound voids.
.2 Required use of steel or other equivalent material in the International

Convention on Load Lines 1966 (1966 LL Convention), which states:
i) Regulation 12: All access doors in bulkheads at ends of enclosed

superstructures shall be fitted with doors of steel or other equivalent
material.
ii) Regulation 15: Pontoon hatch covers: Gives criterion for deflection
(z-direction) due to uniformly distributed load on pontoon hatch
covers. The formula (criterion) is assuming steel as material in
the hatches.
iii) Regulation 16: Hatchways closed by weather tight covers of steel or

other equivalent materials: gives criterion for deflection (z-direction)
due to uniformly distributed load on pontoon hatch covers. The formula
(criterion) is assuming steel as material in the hatches. In addition,
hatch covers as per regulation 16 shall be made of steel or other
equivalent materials.
iv) Regulation 19: Ventilators "shall be made of steel or other

equivalent materials".
v) Regulation 20: Air pipes "exposed parts of air pipes shall be of

substantial construction".
These issues could be managed through the opening for performance-based

design provided in regulation 2.4 of the 1966 LL Convention, which states
"Ships of wood or of composite construction, or of other materials the use
of which the Administration has approved, or ships whose construction
features are such as to render the application of this annex unreasonable
or impracticable, shall be assigned freeboards as determined by
the Administration."

SDC 4/16
Annex 10, page 21
.3 Electromagnetic compatibility (EMC)
In a ship made of steel the hull acts as a counterpoise to external and internal
electrical and radio interferences, e.g. lightning or EMC. In an FRP structure
the same grounding mechanism is not present, which could interfere and
cause problems for the radio communication, radar, fire detection system,
automation, etc.
Special consideration is needed for addressing compliance with standards

such as IEC-60533, stating for example that "complex electric and/or
electronic systems require EMC planning in all phases of design and
installation, considering the electromagnetic environment, any special
requirements and the equipment performance."
.4 Radio communications.
.5 Radar issues might need reconsideration. For instance the radar might need
adjustments and should be set up for sector transmission, due to radio wave
transparency of the structure and radio frequency hazards.
.6 Electrical issues need to be reconsidered, for instance:
.1 grounding points (FRP structure being non-conductive), i.e. reconsider

grounding of the equipment installed on board;
.2 insulation measurements; and
.3 lightning arrestors.
.7 Damage stability with regard to grounding and collision, floatability, structural

integrity and impact strength:
.1 deformation due to unexpected high sea loads (same resistance to

lateral pressure as implied by minimum thickness requirements may
conservatively be provided); and
.2 deformations or other damage due to local contacts (same

resistance to lateral pressure as implied by minimum thickness
requirements may conservatively be provided).
Experience with the operation of HSLC of composite construction has

demonstrated that, when minimum scantling requirements are complied with,
no particular problems concerning robustness to local loads have been
experienced.
.8 CO2 emissions and fuel efficiency.
.9 Life-saving arrangements.

SDC 4/16
Annex 10, page 22
APPENDIX B
FRP COMPOSITE MATERIALS AND COMPOSITIONS USED IN SHIPBUILDING
Introduction
Steel is a robust shipbuilding material with a high limit for destruction, both when it comes to
temperature and loading. Uninsulated structural steel divisions generally start to deteriorate
at 400-500°C. However, permanent deformation and fire spread may occur to large areas
when structures are heated to temperatures below those levels, both due to deformations and
due to heat conduction. An exemplified alternative non-combustible material in SOLAS is
aluminium, despite relatively poor structural behaviour at elevated temperature. Similarly, FRP
composite could provide the same rigid and strong qualities as steel if excessive temperature
increase is avoided. Other benefits with FRP composite are the minimization of maintenance,
lack of corrosion, prolonged fatigue life, reduced efforts for repairs and, above all, reduction in
weight. However, the material is not non-combustible according to SOLAS definitions and this
has effects on fire safety. Below follow descriptions of how different materials can be combined
to make up FRP composite as well as more details on the different materials. Thereafter follow
descriptions of their behaviour when exposed to fire.
B.1 FRP composite compositions
1 A typical FRP composite structure in shipbuilding is the sandwich panel with

a lightweight core separating two stiff and strong FRP laminates, as illustrated in figure 1.
When the laminates are bonded on the core the composition altogether makes up a lightweight
construction material with very strong and rigid qualities. The key to these properties is
anchored in the separation of the laminates. It makes them effective in carrying all in-plane
loads and bending loads. The core, separating the face sheets, carries local transverse loads
as shear stresses, comparable with how webs of stiffeners contribute in stiffened steel panels.
The way the materials are combined makes the construction altogether function as a "stretched
out I-beam" which may not need additional stiffeners. The FRP composite sandwich panel has
a low in-plane modulus of elasticity compared to steel. However, due to the "I-beam" type of
construction, the panel becomes very stiff with regard to bending. The FRP composite
structure is able to deform elastically under high strains and this can reduce stress
concentrations in the interface between for example a steel hull and FRP composite
deckhouse or superstructure. This reduces fatigue problems and steel weight.
Figure 1: Illustrations of an FRP composite sandwich panel composition
2 Another FRP composite structure is the single skin panel, consisting of one single
fibre reinforced laminate. Other FRP designs are also viable, e.g. triple skin (two cores and
three laminates). The composite design could also include stiffeners.

SDC 4/16
Annex 10, page 23
B.2 FRP composite constituents and fire behaviour
The fire performance of FRP composite structures depends on the used materials and their
combined behaviour at elevated temperatures. Knowledge of the materials is therefore crucial.
Common core materials in FRP composite structures are for example polymer-based foams,
cellulosic or metallic honeycomb cores and balsa wood. The laminate face sheets are
generally made of carbon or glass fibre reinforced polymer. However, there is a constant
development of new FRP composite materials and the variety of materials is large. These
guidelines are not extensive when it comes to the description of various FRP composite
materials but some common materials for marine structures, i.e. where most experience has
been accumulated, are briefly described below.
B.2.1 Polymers
1 A common processing method is hand layup with resin infusion and curing at elevated
temperature (60-80°C) or post-curing. The resins normally used are polyester, vinylester and
epoxy. Marine grades of these materials do not differ very much with respect to behaviour in
fire or at elevated temperatures; unmodified they give comparable smoke production and heat
release. Heat weakens the polymer of an FRP, which means that structural strength is
challenged in a fire event. A key property is therefore the heat distortion temperature for
the cast resin (not the laminate), where half the stiffness is reached, comparable to glass
transition temperatures for polymers. For normal room temperature cured systems the heat
distortion temperature is usually about 70-100°C but systems may be produced with
significantly improved properties.
2 With regard to fire contribution, figure 2 shows the weight loss (left Y-axis) of
a moderately performing polyester polymer used in an FRP laminate as a function of
temperature increase and also its derivative (right Y-axis). It can be seen that the polymer will
not contribute significantly to a fire until heated to ~350°C, which is a common range for
the polymer pyrolysis temperature. It should be noted that this temperature of significant weight
loss is significantly higher than the point at which aluminium is structurally useful. Therefore,
FRP composites do not contribute to a fire until reaching a temperature beyond which
a currently acceptable non-combustible materialFile:has
Sample: BR intergard glasfiber
ceased to either provide structural
Intergard brandhämmare BR glasfiber.001
support or
Size:restrict
30.3480 mgthe spread of fire.
Method: High Resolution Dynamic
TGA Operator: AnnSofie
Run Date: 10-Apr-06 14:21
Instrument: 2950 TGA HR V6.1A
120 1.2
1.0
2.820%
100 (0.8560mg)
Deriv. Weight (%/°C)

14.28% 0.8
(4.334mg)
Weight (%)
80 14.48% 0.6
(4.393mg)
3.914%
(1.188mg) 0.4
6.803%
60 (2.065mg)
0.2
40 0.0
0 200 400 600 800 1000
Temperature (°C) Universal V3.9A TA Instruments
Figure 2: Thermo Gravimetric Analysis of a standard FRP polyester polymer

SDC 4/16
Annex 10, page 24
3 The resins referred to above are all combustible and with comparable smoke
production and heat release. There are also numerous modified resin systems that can provide
better fire performance in terms of fire, smoke and toxic gas formation properties, sometimes
at penalty of processing properties, mechanical properties or increased fire smoke production.
B.2.2 Fibres and reinforcements
1 When it comes to reinforcing fibres, E-glass and carbon fibres are currently most
common. Polymeric fibres such as aramids (e.g. Kevlar and Twaron) are also used and other
fibre types may be developed in the future.
2 E-glass fibres have been common mainly due to a good strength to cost ratio. E-glass
fibres remain unaffected in fire until heated to about 830°C when viscous flow starts.
Nonetheless, mechanical properties such as strength and stiffness decrease from around 500°C.
3 Carbon fibres are more heat resistant than glass fibres and are also common. They
are unaffected by temperatures up to about 350°C and oxidize at a temperature of 650°C
to 700°C (i.e. far above the temperature at which typical resins decompose). In addition,
carbon fibre mats exhibit better heat distribution properties than glass fibres, which can avoid
the occurrence of "hot spots".
4 While the polymer may contribute to the fire and increase its severity, the reinforcing
fibres do not normally add to the fire intensity. On the contrary, as they often are quite inert,
they serve as a temperature barrier and thermal insulator. However, a hazard is the possibility
of fibres being spread to the environment from a fire event. Such fibres are known to cause
skin/throat/eye irritation in the vicinity of a fire.
B.2.3 Core materials
1 Polymer-based foams and balsa cores are often used in shipbuilding. Figure 3 shows
a similar analysis as in figure 2 but for a PVC (polyvinyl chloride) foam core material. It shows
no weight loss, and thereby no fire contribution from the material, until reaching ~250°C.
The high smoke and
Sample: BR toxicity
intergard cellplast generation potential of PVC has
File: led tobrandhämmare
\\...\BR\Intergard an increased
BR.001 use of other
Size: 2.2650 mg TGA Operator: AnnSofie
polymer-based foams.
Method: High Resolution Dynamic Run Date: 10-Apr-06 10:12
Instrument: 2950 TGA HR V6.1A
120 5
7.426%
100 (0.1682mg)
80 34.59%
(0.7835mg)
Deriv. Weight (%/°C)
3
60
Weight (%)
40
52.01% 2
(1.178mg)
20
4.386%
(0.09934mg)
1
-20 0
0 200 400 600 800 1000
Temperature (°C) Universal V3.9A TA Instruments
Figure 3: Thermo Gravimetric Analysis of PVC core foam

SDC 4/16
Annex 10, page 25
2 Different core materials have varying responses to fire exposure. Typical behaviour
of polymer-based foams at high temperature is melting, softening and shrinking, whereas
end-grain balsa wood chars (generally at temperatures exceeding 200°C to 250°C). Balsa
wood does not have a softening temperature nor does it shrink in the same way as a polymer,
and the smoke generation potential is generally more limited. Note that in this context PVC
and balsa cores have been provided as examples but other cores exist and may be developed.
In each case a clear understanding of the fire performance of the core material is necessary.
B.3 Fire performance of FRP composite, key issues and means for improvement
1 The performance of an FRP composite structure when exposed to fire varies with
the composition of core and laminates but mainly depends on the following five conditions:
.1 type of polymer and thickness of laminate;
.2 type and density of core;
.3 type and amount of fire protection (e.g. insulation); and
.4 structural support, e.g. stiffeners.
2 Some typical critical temperatures for an FRP composite sandwich panel using
standard polyester-based FRP laminates and a PVC foam core are summarized in figure 4.
Spontaneous ignition of the laminate could typically occur at 350°C to 400°C and the core
material will lose structural integrity at certain temperatures due to phase transitions (melting,
vaporizing). However, the composite sandwich construction will generally lose its structural
strength at temperatures well below such temperatures (discussed above for the individual
materials). For a load-bearing structure it is thus more critical to manage structural integrity
than ignition and fire involvement. Loss of the mechanical properties of a sandwich panel may
be claimed to be associated with delamination, i.e. when a significant part of the laminate is
detached from the core. In fire testing sandwich panels under load, it has been found, e.g. for
the above-mentioned sandwich systems, that overall structural failure of the panel often occurs
when the bond of the laminate skin to the core reaches a critical temperature. It is important to
note that this will generally occur much sooner than ignition in a fire situation. Softening of the
skin to core bond then results in the structure ceasing to act as a sandwich panel and failing
by buckling of the resulting thin skin structure. However, it should be noted that the thermal
insulating quality of the composite allows for local hot spots without compromising an entire
structure. It is in other words required that a sufficient percentage of a load bearing element is
heated before a collapse occurs. There are also remedies to lower the risk of structural
collapse, e.g. supporting stiffeners or pillars.
Figure 4: Typical critical temperatures for an FRP composite sandwich

(PVC core, polyester FRP)

SDC 4/16
Annex 10, page 26
B.3.1 Structural fire performance of FRP composite structures
1 FRP composite can never fulfil "A" class requirements as defined by SOLAS, since "A"
implies "non-combustible" according to SOLAS regulation II-2/3.2. It further implies 60 minutes
fire resistance, represented by a temperature rise in a large furnace according to the standard
temperature-time curve, as defined by the ISO. FRP composite and metallic construction
materials differ conceptually from a fire safety point of view. Not only from a reaction to fire
perspective (ignitability, smoke and heat production) but also from a resistance to fire
perspective (structural integrity and heat transfer). In the SOLAS requirements for fire
resistance, metallic materials are expected to keep the temperature increase at the unexposed
side of the bulkhead or deck in the standardized fire test below ~200˚C for 0, 30 minutes
or 60 minutes, depending on the requirements for the particular space. The motive is to control
the risk for fire spread to compartments adjacent to the fire compartment. A steel construction
could still be load carrying for a long time after such temperatures are reached, whereas, e.g.
an aluminium construction would start to lose its structural strength at about 200˚C. A steel
construction is therefore allowed with insulation on one side of the division, whereas aluminium
constructions must be insulated on both sides. The same would be true also for
FRP composites.
2 An FRP composite is a good thermal barrier. The fundamental condition for

the FRP composite to achieve structural integrity "equivalent" to an A-class division is therefore
not the temperature requirement at the unexposed side but that structural resistance is
maintained for 60 min. As discussed above, an FRP composite structure will generally start to
lose structural strength below 200˚C, and an FRP composite deck or bulkhead would therefore
start to lose its structural integrity long before the temperature at the unexposed side
approaches 200˚C. Thus, an FRP composite construction generally achieves SOLAS
regulation II-2/9 "Containment of fire" much better than metallic materials due to its insulating
capacity but has problems to fulfil SOLAS regulation II-2/11 "Structural integrity". Therefore, if
structural collapse due to heat in an FRP composite construction can be avoided,
the FRP composite design has a major advantage to metallic materials since fire spread due
to heat transfer is a much lower risk in FRP composite than in metallic materials.
3 To achieve structural resistance in FRP, it is important to keep temperatures down,

which is achievable through insulation or cooling. Structural fire performance may also be
achieved by structurally redundant design, e.g. by using pillars, stiffeners or sandwich panels
with over-capacity (e.g. triple skin panels designed so that half of the structure is sufficient to
carry the design load). If redundancy of the constructions' load-bearing capacity is incorporated
in the design, a fire could be well contained within the fire enclosure for a long time before
spreading to other areas through the structure.
4 While structural performance is maintained, a fire will actually be better contained than
in a prescriptive steel design since the insulating capacity of the composite will add significantly
to the total insulating capacity of the construction. Since the heat is well kept within the fire
enclosure, the overall temperature may also be higher compared to in a steel enclosure. Thus,
a more intense fire with higher temperatures is possible using an FRP composite construction
but the fire is more localized and less likely to spread due to heat transfer than in a metallic
construction. The high temperatures motivate water based extinguishing systems since
inertion by evaporated water is well facilitated.
5 If active and passive risk control measures fail and the fire falls out of control, a heat
induced structural collapse could occur. The FRP composite could then also take part in
the developing fire.

SDC 4/16
Annex 10, page 27
B.3.2 Firefighting of FRP composite structures
1 The high insulation capacity also affects the way of fighting fires in the construction
material. In general when a fire appears on a vessel, water cooling of boundary surfaces of
the fire enclosure is a basic strategy in maritime firefighting. When using FRP composites
instead of metallic materials, such cooling is more or less meaningless since the outer surfaces
of the fire room will have very low temperatures for a long time and also, the insulating capacity
of the material will make such construction cooling ineffective. Instead, firefighting must take
place inside the fire enclosure. Suitable firefighting equipment is already in use, such as
the Cutting Extinguisher or small pre-fabricated inlets for nozzles which allow firefighting
without entering the room. This is further discussed in 3.10 (regulation 10 – Firefighting).
2 The combustion of FRP composites is dependent on a thermal breakdown of organic

molecules in the material. The insulating quality of the material will initially create a very steep
temperature gradient in the material when subjected to a fire. If the material is cooled down,
the production of combustible gases is hindered and the fire is stopped. This cooling should
be applied to the hot surface. Empirical testing has shown that early application of water
(which also requires fast detection) on a burning surface will quench the pyrolysis reactions in
the FRP composite quite quickly.
3 If the fire has given sufficient heat exposure for the FRP composite to reach pyrolysis
temperatures also deeply within the construction, fire tests have shown that continuous cooling
may be necessary to prevent re-ignition. In particular, the core works as a thermal barrier, both
in heat exposure and during cooling. Thus, for efficient firefighting it is beneficial if surfaces
within a fire enclosure are cooled down as soon as possible. Active systems with quick
response could therefore be useful.
4 A gaseous extinguishing system should be avoided since it will not provide

the necessary cooling of the material at the surface. See also the discussion in section B.3.1
concerning evaporation advantages in well-insulated enclosures.
B.3.3 Exterior surfaces in FRP composite
1 Exchanging traditional external steel surfaces for combustible FRP composite will
give a fire the ability to propagate vertically if a window breaks or if an external door is left
open. The fire can then potentially spread between decks and fire zones. This issue has been
given much attention and full scale tests have been carried out in order to find suitable
mitigating measures. Producing FRP face sheets with low flame-spread characteristics or
installing a drencher system for external surfaces are alternatives to avoid fire spread.
Fire rated windows and doors are other fire safety measures that could be relevant. It may also
prove necessary to provide some kind of structural redundancy, as described above,
addressing external fire exposure.
B.3.4 Steel-FRP joints
1 An important area for an assessment of fire safety of FRP elements is

the steel-FRP joints. A hazard associated with steel-FRP joints is the possibility of conduction
of fire induced heat in the steel structure to an adhesive joint. If the adhesive reaches a critical
temperature, the joint will fail. Furthermore, there are combined effects of differences in thermal
expansion and other properties (e.g. heat conductivity, elastic modulus, combustibility) which
could cause loss of structural and fire integrity.

SDC 4/16
Annex 10, page 28
2 Steel-FRP joints must be properly assessed to ensure that they are sufficiently
protected from fire and heat deterioration. The assessment of steel-FRP joints should be part
of the SOLAS regulation II-2/17 assessment and can include performance of fire tests.
3 Furthermore, it must be ensured that the structural fire integrity of the steel-FRP joint
is maintained throughout its service life.

SDC 4/16
Annex 10, page 29
APPENDIX C
RECOMMENDATIONS REGARDING THE ASSESSMENT
Introduction
When assessing against SOLAS chapter II-2, regulation 17, an analysis shall show that an
equivalent level of safety is achieved by the alternative design and arrangements with regard
to introduced fire hazards. Guidelines for such analysis are found in MSC/Circ.1002, as
amended by MSC.1/Circ.1552. However, when considering FRP composite structures, it may
also be relevant to consider MSC.1/Circ.1455 which contains guidelines that have been
developed to provide a consistent process for the coordination, review and approval of
alternative design and arrangements in general, i.e. not only fire safety. This may be
particularly appropriate when the use of FRP composite affects other aspects of safety than
those related to fire. Further assistance may be found in guidance notes for MSC/Circ.1002,
as amended by MSC.1/Circ.1552 and in guidelines on fire safety engineering applied to
buildings. Below follow discussions on the required method for analysis, evaluation and
approval of FRP composite structures, with regard to uncertainty treatment, sophistication and
the practical process. Reference is made to the guidelines referenced in SOLAS,
MSC/Circ.1002, as amended by MSC.1/Circ.1552, and also to MSC.1/Circ.1455. It is
particularly pointed out that the assessment must stand in relation to the current scope of
the proposed design and arrangements; a simple and well-protected structure in
FRP composite should not require a complicated or time-consuming assessment.
C.1 Uncertainty treatment
1 Even the most detailed risk assessment contains limitations; uncertainties are
involved throughout the whole process. The uncertainties that arise when determining
the frequencies and probabilities of events are often perceived as the dominating sources of
error. Data is insufficient or not fully relevant for the particular events. Common reasons are
that statistics have simply not been recorded or that the data is aged and does not comprise
updates in legislation and novel technology. However, even if statistical information is often
considered to be "the truth", it should be handled with care since the figures are always
changing and may have great errors. Furthermore, statistics can give an image of something
that has happened in the past but evaluations of novel ship designs need to be carried out
before the ship is put into practice, which implies that statistical data will not be available for
such parts of the ship. A general statistical representation may be available for the prescriptive
design but the fire risk of the alternative design and arrangement needs to be calculated from
knowledge.
2 Attempting to compare a calculated risk of alternative design and arrangements with

a statistical representation of a prescriptive design, or an absolute risk criterion, may become
extremely uncertain since the different approaches contribute with fundamentally different
uncertainties. It could therefore be recommendable to carry out a relative risk assessment, as
described in MSC/Circ.1002, as amended by MSC.1/Circ.1552, even when carrying out
a SOLAS regulation II-2/17 assessment at a more sophisticated level. Thereby, uncertainties
can be minimized by founding the risk estimations of the ship designs on similar assumptions
(e.g. in models, expert judgement, statistical data, etc.). In order to expose the differences in
fire safety it is also recommendable that the assessment concerns only the alternative design
and arrangements and thereby relevant parts of the ship (a risk measure for the ship as a whole
may give a wrong representation of the safety).

SDC 4/16
Annex 10, page 30
3 When determining consequences of events, uncertainties depend on how systematic

and detailed the approach is. Models used when estimating the consequences and
the experience in the expert group are also sources of uncertainties. In the hazard
identification, uncertainties are also often linked to the method used, how detailed it is and
the competence of the expert group examining the systems. Lack of routines, knowledge and
experience are drawbacks which need to be considered when designing a ship with novel
technology. The uncertainties can result in missing or wrong scenarios when identifying
hazardous events, which can have great effects on the proceeding analysis. A common feature
of all the steps of the risk assessment is that many simplifications are made in order to model
complicated systems. Much because of the complex matter of assessing the impact of human
behaviour when modelling, they tend to be focused on machines and technical components.
Leaving the effects of organizational aspects, safety management systems and operator
actions outside the scope of the risk assessment will, however, not reduce uncertainties.
C.2 Required method
1 Many different methods for risk assessment, of varying sophistication, can be used to
evaluate uncertainties in a ship design, which is the focus when adopting a risk-based
approach. All ship designs contain uncertainties and all risk assessments contain
uncertainties. As a result, all decisions will be made under some measure of uncertainty.
If a risk assessment would result in an absolute certain probability density function of
the possible consequences, a decision would be truly "risk-based". However, since
uncertainties cannot be eliminated, it is important to analyse them and to appraise the effects
of uncertainties on the result and the total effect when these uncertainties are considered.
Methods for risk assessment are often classified based on the inclusion of quantitative
measures (qualitative-quantitative) or on the consideration of the likelihood of outcomes
(deterministic-probabilistic). A more suitable classification includes the previous features but
depends on how uncertainties are treated with varying thoroughness.
2 The guidelines in MSC/Circ.1002, as amended by MSC.1/Circ.1552, outline

a plausible worst-case approach for analysis and evaluation which can be described as
a deterministic risk assessment. This kind of consequence analysis, commonly referred to as
"engineering analysis", is described in several engineering guides to performance-based
analysis of fire protection in buildings, which have formed the basis for the guidelines.
MSC/Circ.1002, as amended by MSC.1/Circ.1552, makes clear that the scope of the analysis
depends on the extent of deviations from prescriptive requirements and on the extent of
the alternative design and arrangements. However, increased uncertainties do not only
increase the scope of the analysis but also affect the required accuracy and sophistication of
the method for verification of safety. A more sophisticated approach will further increase
the engineering efforts but may be necessary if safety margins are to be kept reasonable and
risks are to be properly managed when for example deviations are numerous, significant or
concern many areas or when the design and arrangements are large, complex, novel or
outside the scope of prescriptive requirements. Therefore, the approach outlined
in MSC/Circ.1002, as amended by MSC.1/Circ.1552, may or may not be sufficient to
adequately assess fire safety. Furthermore, if the case is simple, a less complicated kind of
risk assessment should be sufficient. Therefore, MSC/Circ.1002, as amended
by MSC.1/Circ.1552, "only" presents guidelines; the required sophistication of the method
used to assess safety depends on whether it is sufficient to describe the current design and
arrangements in terms of fire safety. The adaptability of the method used to verify fire safety
and its dependence on the current scope is clearer in MSC.1/Circ.1455 (paragraph 4.13.2).
Since the term "engineering analysis" refers to a certain kind of risk assessment, the more
general term "SOLAS regulation II-2/17 assessment" is used in these guidelines.

SDC 4/16
Annex 10, page 31
3 Moving to SOLAS regulation II-2/17, the stated ultimate requirement for alternative
design and arrangements is sufficient safety; an alternative design and arrangements shall be
at least as safe as if prescriptive requirements were complied with (regulation II-2/17.3.4.2).
If the scope of the deviations posed by the alternative design and arrangements is great it may
be relevant to carry out an assessment at a higher level and determine an index of safety for
the whole (or a considered part of the) ship. However, if effects on safety can be managed
within the areas of one or a few regulations separately, this will allow for an assessment at
a lower level (e.g. limited to evaluations of fire growth potential or containment of fire). This is
also why it was decided to have regulation II-2/17.2.1 read: "provided that the design and
arrangements meet the fire safety objectives and the functional requirements", without
mentioning whether it is the functional requirements in SOLAS regulation II-2/2 or in any other
regulation. "Minor" alternative design and arrangements should be possible to analyse and
compare to single affected functional requirements of deviated regulations. As long as those
functional requirements are met it may not be necessary to evaluate safety at a higher level
through the overall fire safety objectives and functional requirements. However, this requires
that risk control measures are found which target potential deficiencies in the areas of
the individual deviated regulations.
4 It should be noted when considering FRP composite structures that a sole

ASET-RSET evaluation, common in fire safety engineering, may provide an insufficient
assessment. Effects on safety from use of FRP composite may go beyond what is captured by
such assessment, e.g. effects appearing after escape from the fire or disproportionate
damage. In any case, it should be proven that the ship can survive a set of relevant design
fires and be its own lifeboat. The design fire scenarios must be specified to represent all
the affected safety barriers, i.e. not only those presented as functional requirements in SOLAS,
as further elaborated below.
C.3 Establishment of approval basis
1 Modern ships (in particular passenger ships) are built with several fire safety functions
or barriers. This will provide an integrated and redundant system that takes into account that
some safety systems do not work as intended. A ship (partly) built of FRP composite structures
should provide similar robustness and the design process should document that safety system
can fail without loss of important safety functions or disproportionate consequences. However,
all safety barriers are not clearly stated in the regulations and may be hard to identify.
2 According to SOLAS regulation II-2/17, alternative design and arrangements for fire
safety should provide a degree of safety at least equivalent to that achieved by compliance
with the prescriptive requirements. To form an approval basis, it is stated that the SOLAS
regulation II-2/17 assessment should include an identification of the prescriptive
requirement(s) with which the alternative design and arrangements will not comply
(regulation II-2/17.3.2). This is also a foundational part in MSC/Circ.1002, as amended by
MSC.1/Circ.1552, where it is stated that the regulations affecting the proposed alternative
design and arrangements, along with their functional requirements, should be clearly
understood and documented (paragraph 5.1.2). This is further stressed in paragraph 4.3.4,
where it is stated that the preliminary analysis should include a clear definition of
the regulations which affect the design and a clear understanding of the objectives and
functional requirements of the regulations (i.e. the purpose statement in figure 5).
The objectives and functional requirements of the deviated prescriptive requirements can
thereafter be used (along with the fire safety objectives) to define performance criteria, as
described in paragraphs 4.4 and 6.3.2 of the Guidelines on alternative design and
arrangements for fire safety (MSC.1/Circ.1002, as amended by MSC.1/Circ.1552) and in
regulation II-2/17.3.4.

SDC 4/16
Annex 10, page 32
3 When FRP composite is used, the fundamental deviations concern requirements on

non-combustibility. However, due to limitations in current regulations, an identification of
deviated prescriptive requirements and their associated purpose statements may not form
a sufficient basis to evaluate the safety of FRP composite ship designs. The regulations are
based on assumptions regarding the design and arrangements and therefore not all safety
requirements are apparent. In particular, many requirements are made up around steel
designs, leaving many implicit requirements unwritten. Therefore, use of FRP composite will
affect fire safety in many ways, some of which are not covered by the fire safety regulations.
An approval basis for equivalent safety may therefore not be sufficiently defined based only on
deviations from prescriptive requirements, which is clearer in MSC.1/Circ.1455
(paragraph 4.7.1) than in MSC/Circ.1002, as amended by MSC.1/Circ.1552 (paragraph 5.1.2).
4 Depending on the scope of the proposed alternative design and arrangements,

additional investigations may be called for to consider how the implicit level of fire safety
represented in the Convention is affected. This may be relevant for an assessment of any
design and arrangements which are truly novel (not simple extensions of the corresponding
prescriptive requirements) since all hazards are not addressed by the Convention. A simple
comparison with existing prescriptive requirements may not be sufficient and the assessment
may therefore require special attention.
5 Investigations of effects on the implicit level of fire safety, or identification of missing

requirements, can also be claimed necessary regardless of the novelty of the proposed
alternative design and arrangements. To further complicate the comparison of safety levels,
many prescriptive requirements have unclear connections with the purpose statements of their
regulations and with the fire safety objectives of the fire safety chapter, which are supposed to
define "fire safety". Some functional requirements could, for example, be claimed missing
based on the prescriptive requirements and for some functional requirements listed at
the beginning of regulations there are no associated prescriptive requirements. Deviation from
one prescriptive requirement may affect the achievement of a functional requirement of
a different regulation, etc.
6 A SOLAS regulation II-2/17 assessment involving FRP composite structures, as any

SOLAS regulation II-2/17 assessment, must be sufficient to describe the introduced novelty in
terms of fire safety. Determining the approval basis only based on deviated prescriptive
requirements may not be sufficient and additional investigations of effects on the implicit level
of fire safety may be necessary. These guidelines attempt to clarify such potential explicit and
implicit effects on fire safety when using FRP composite compared to what is implied by
the prescriptive requirements from a broad perspective in section 3 (Important factors to
consider when evaluating FRP composite structures with starting point in the regulations of
SOLAS chapter II-2). However, it could also be the case that further investigations are needed
regarding how the proposed design and arrangements affect the fire safety implied by
prescriptive requirements. Investigations could, for example, be carried out to clarify effects on
the fire safety objectives and functional requirements of the fire safety chapter, effects on
the structure of the fire safety (effects on the source, exposure or effect on part of the fire
protection), effects on properties of the fire protection (e.g. effects on the flexibility, sensitivity,
complexity, vulnerability, reliability or human intervention) or effects on fire development
(effects on a fire in the incipient, growth, fully developed or decay phase). There are also many
established methods for hazard identification which may be used.

SDC 4/16
Annex 10, page 33
7 In order to manage all the identified pros and cons of the alternative design and
arrangements with regard to fire safety, it is also suggested that they are managed in a better
way than the way in which it is described in MSC/Circ.1002, as amended by MSC.1/Circ.1552
(paragraphs 5.2.1.2 and 5.2.1.3), e.g. by collection and rating in a risk-based presentation,
such as a ProCon List or Risk Matrix. This will be of significant value when forming fire
scenarios. In general, when novel design and arrangements are managed, it is
recommendable to have a larger focus on the initial stages of the SOLAS regulation II-2/17
assessment, particularly on the identification, collection, rating and selection of fire hazards.
C.4 Approval process
It should be stressed that the sophistication of the risk assessment may vary depending on
the scope of the proposed design and arrangements, so may the practical process of
the assessment. MSC/Circ.1002, as amended by MSC.1/Circ.1552, describes an approach
where the assessment is reviewed at two stages by formal approval of reports. The guidelines
in MSC.1/Circ.1455 include the Administration more in the process by putting a larger focus
on monitoring and having review and approval of the assessment in several more but smaller
stages. Regardless of which guidelines are referred to, it should be emphasized that the actual
process may include more steps than in the guidelines but it may also be significantly
simplified. For example, proposing the use of FRP composite for interior structures, a limited
part of the ship or structures which are ubiquitously thermally insulated, may not require
a lengthy, detailed or very time-consuming assessment.

SDC 4/16
Annex 10, page 34
APPENDIX D
FIRE TESTING OF FRP COMPOSITE
Introduction
Many of the fire safety regulations in SOLAS stand in correlation with performance in fire tests.
Some relevant characteristic parameters which are currently measured are:
.1 spread of flames;
.2 evolved effect and energy;
.3 combustibility;
.4 smoke generation;
.5 toxicity; and
.6 structural resistance to fire.
These parameters are measured in different ways depending on the represented fire risk
scenarios and with various criteria depending on the hazards involved. The different tests have
not developed with particular attention to FRP composite constructions but may still be
applicable, even if certain considerations may be necessary. However, there is already
a market for FRP composite constructions in naval and commercial maritime applications,
particularly for high-speed crafts (HSC). For this purpose, new regulations and standardized
tests applying to such materials have been implemented in the International Code of Safety
for High-Speed Craft (HSC Code). It includes several significant differences with regard to
the safety organization, available egress time and requirements for the materials, but it may
still be relevant to refer to the related fire tests when considering FRP composite structures in
SOLAS ships. Any standardized or experimentally set up test may be referred to as a SOLAS
regulation II-2/17 assessment but may require evaluations of the test results. Assessments by
experts may also allow the transfer of test results from one FRP composite composition to
another.
Below follows a discussion on the limitations of safety validation through tests in general and
on uncertainties that need to be considered when using current fire test procedures to validate
FRP composite in particular. Thereafter, the most relevant fire tests prescribed by SOLAS and
the HSC Code are briefly described, with focus on the particularities with testing
FRP composite. For some FRP composite constructions it may be necessary to look beyond
the approved fire test procedures and consider other standardized tests or tailored
experimental tests, which are discussed at the end of this chapter.
D.1 Uncertainties when using tests to validate FRP composite
1 Testing is a good tool to evaluate whether a construction performs satisfactorily in

a certain situation. Full-scale testing is the method that typically will give the most accurate
results on how a design will perform, even if natural variations are always present. Since it
would be very costly to evaluate all possible scenarios in full-sized tests, some characteristic
parameters are generally investigated in certain ways during exposure to plausibly worst-case
scenarios. The overall safety performance is therefore assumed to stand in correlation with
the performance in these characteristic tests, derived from knowledge of fire dynamics and
behaviour of materials when exposed to fire.

SDC 4/16
Annex 10, page 35
2 However, FRP composite and steel, which it generally replaces, are inherently very
different. Some general particularities with FRP composites are the anisotropy and
inhomogeneity, which may give variations in test results depending on the positioning. Another
potential difficulty is that the different plies of resin impregnated fibre cloths might delaminate
during testing. Produced gases will strengthen this tendency as they seek the outlet of "least
resistance". The latter effect will not be captured in a small-scale test since the maximum travel
distance for gases in the real fire will be much longer than in, e.g. a "Cone Calorimeter" test
where the maximum "travel" distance is 5 cm. The "edge" effect will therefore be much more
important in a small-scale test than in a full-sized test. Different remedies to problems related
to scale are given in the literature and they include edge protection, which in the Cone
Calorimeter could be the use of a sample holder that covers the edges completely or to vary
the sample size or orientation.
3 Evaluation of two such diverse construction materials through the same tests may be
claimed to be quite obtuse. Today's fire tests are generally constructed to measure some key
properties reflecting different disadvantages of traditional (steel) constructions and ideally
represent the performance of such constructions when exposed to a severe fire. However,
some characteristics are left out in the tests because of the implicit benefits of traditional
solutions. Therefore, implicit advantages may not be represented in the tests and may not be
possible to evaluate. What must be considered further is also the uncertainty associated with
performance criteria generally being binary, i.e. pass or fail. When evaluating designs through
tests there is always a lowest level for passing the test, an acceptance criterion. Assurance of
identical set-ups and measurements are obviously of greatest significance when tests are
carried out by different people and at different labs in countries throughout the whole world.
However, even without those uncertainties, a test says nothing about the performance not
represented in the test, i.e. the performance of the sample if the load, temperature or time in
the test increases by 10%, 20% or 50%. In general, the prescriptive fire tests of
the International Code for Application of Fire Test Procedures, 2010 (2010 FTP Code) only
give pass or fail. Therefore, no information is given on how the construction performed during
the test or how long it could have performed with satisfaction. An example of this is the ability
of steel bulkheads to withstand high temperatures before structural deterioration. It is because
of the implicit advantages of steel, not visible in standardized tests, that there is an additional
requirement for many structures to be made of steel or other equivalent material. However,
when aluminium was introduced to merchant shipbuilding, it was necessary to address this in
a better way. Aluminium was, according to regulations, considered as an alternative
non-combustible material to steel. However, the relatively poor structural behaviour at elevated
temperatures (aluminium does not burn but nevertheless melts in the non-combustibility test)
highlighted the simplistic nature of the non-combustibility requirement. Aluminium structures
were therefore generally required to be fitted with double sided insulation and were thereby
considered equivalent to steel in this regard. Furthermore, when non-metal load-bearing
structures are considered for HSC, they are subjected to an additional load during structural
fire resistance tests in order for the structure to be considered equivalent to a metal
construction. Therefore, there may be reason to assess whether the standardized tests fully
reflect the risks and benefits of FRP composite structures in case of fire. Implicit properties
beyond the tests need to be identified, which is one of the objectives behind these guidelines,
and may require verification through additional tests.

SDC 4/16
Annex 10, page 36
D.2 Low flame-spread characteristics
1 The potential for flame spread of a material is tested in equipment where an irradiating
panel provides heat input to a surface in order to initiate flaming combustion. The IMO typical
example of such equipment is shown in figure 5. Fire is initiated where the distance between
panel and sample is the shortest, i.e. where the irradiation intensity is the highest. The radiation
level decreases at the test specimen from left to right in figure 5, and the extreme burning point
to the right, i.e. the point with the lowest irradiation level for sustained combustion, is given as
a measure of flame spread for the material. The speed of the flame front movement is also
quantified in an appropriate way. There are also criteria regarding the peak heat release as
well as of the total evolved effect.
Figure 5: Test for flame spread according to part 5 of the 2010 FTP Code
2 When testing FRP composite according to this procedure, it is important to comply

with the requirement to test the specimen with end-use conditions. The material behind
the tested surface material will significantly affect the fire behaviour. A well-insulating material
behind a thin ply will keep much more of the heat at the surface and generally worsen
the conditions for the tested surface material. Therefore, if the end-use is a sandwich panel, it
is not appropriate to test only the surface laminate on a steel plate or directly in the sample
holder. The equipment normally fits a 50 mm thick sample and for FRP composite it is
recommendable to include as much of the composite material as possible in the sample holder.
D.3 Generated effect and smoke in small scale
1 The HSC Code includes regulations for furniture and other components which require
investigating fire behaviour on a small scale in the "Cone Calorimeter" test equipment defined
in the standard ISO 5660 (shown in the schematic picture in figure 6). The 0.1 x 0.1 m specimen
is horizontally positioned and subjected to irradiation from electrically heated surfaces above
the tested material. Irradiation levels are typically in the range of 25 to 50 kW/m2.

SDC 4/16
Annex 10, page 37
Figure 6: Schematic picture of a Cone Calorimeter
2 Except from time to ignition, the standard ISO 5660 Cone Calorimeter test includes
measurement of smoke (obscuration) and heat release under different radiant fluxes. There is
a criterion for the peak heat release rate. The time integrated HRR signal provides the total
heat release (THR), which must be limited and is a very important material fire characteristic.
The HRR curve for such an experiment on a carbon fibre based composite laminate is shown
in figure 7. HRR for Carbon fibre based FRP in Cone Calorimeter experiment
300
250
200
Effect (kW/m2
150
100
50
0
0 50 100 150 200 250 300 350 400 450
time (s)
Figure 7: Small-scale experimental results from carbon FRP composite material
D.4 Generated effect and smoke on a large scale
1 The criteria for the Cone Calorimeter are designed to correlate with a large scale
"Room Corner" test scenario according to the standard ISO 9705. It is an important
standardized piece of equipment for testing material potential for HRR and smoke,
schematically pictured in figure 8. In this test, the material to be tested is mounted on walls
and ceiling and a propane gas burner positioned in a corner of a full-scale room provides
a 100 kW power output for 10 min, followed by a 300 kW output for an additional 10 minute
period. The HRR and smoke production rate are continuously measured and the criteria that
apply are similar to those in the Cone Calorimeter.

SDC 4/16
Annex 10, page 38
Figure 8: Schematic view of ISO 9705 Room-Corner experimental set-up
2 The standard ISO 9705 test is important for marine applications as it is used in
the 2010 FTP Code for experimental verification of FRM, "Fire Restricting Materials", used on
HSC. On SOLAS ships requirements are more relaxed and surfaces are often coated with
combustible paints that would not pass FRM requirements, in particular if applied to an
FRP composite surface. The material behind the surface finish has a major impact on the test
results and, due to the high thermal conductivity of FRP composite, this test is therefore rather
challenging for FRP composite systems. Furthermore, droplets and debris must also be
considered according to the test requirements. It is thus crucial that FRP composite materials
are tested in end-use conditions. It should be noted that, in comparison with the test for surface
flammability, the room corner test is not only full scale but also includes further complexities,
in particular with regard to effects of enclosure fire dynamics. Flames and smoke are collected
in the room and heat up surfaces in a different way. These reradiate between each other.
The effects from enclosure fire dynamics also generally make the test harder to pass than
the test for spread of flame; that is, materials that pass the room corner test generally also
pass the test for spread of flame. For exterior combustible surfaces, the ability to manage
effects from enclosure fires could be claimed irrelevant, as these effects will not appear out in
the open on exterior surfaces. Therefore, for such areas a different test could be more suitable.
D.5 Non-combustibility
The previously described test methods have been presented in an approximate order of difficulty
with regard to fire behaviour of the materials. The ultimate fire-related material quality is
non-combustibility, determining whether the material is at all considered combustible. An accepted
method for measuring combustibility is the fire test given in part 1 of the 2010 FTP Code
(see figure 9). A specimen is exposed to 750°C in a cylindrical furnace where temperature
increase, flames and weight loss are measured to determine combustion.

SDC 4/16
Annex 10, page 39
Figure 9: Combustibility test equipment according to part 1 of the 2010 FTP Code
D.6 Smoke generation and toxicity
1 In evaluations of materials it is often relevant to combine properties of fire behaviour

(fire growth, fire spread, etc.) with materials' potential for smoke generation and toxicity.
For maritime applications, the "smoke box" is used for smoke and toxicology measurements,
based on part 2 of the 2010 FTP Code. For SOLAS applications this test is only required if
results in the test for spread of flame are insufficient. In this method, a 0.5 m3 closed cubic box
(figure 10) is used for exposing a small (75 mm x 75 mm) sample for irradiation and measuring
continuously gases and smoke opacity in the box. Criteria concern maximum amount of smoke
produced and maximum concentrations of the following gaseous species: CO, HCl, HF, NOx,
HBr, HCN and SO2, as given in the 2010 FTP Code. The test proceeds for 10 minutes if
a maximum has been observed in the smoke obscuration level; otherwise the test proceeds
for another 10 minutes. The toxicity levels when the smoke obscuration reached its peak value
are used as the result from the test.
Figure 10: Smoke box equipment
2 In this test, materials generally produce more smoke before ignition than after they
have ignited. The same applies to most gases, in particular CO levels which are significantly
higher before ignition (the opposite applies for HCN). Therefore, FRP composite materials that
have been treated to impede ignition and flame spread generally produce smoke and toxic gas
in levels which may make it challenging to pass the test.

SDC 4/16
Annex 10, page 40
3 There is no requirement to test insulations, bulkhead panels and similar items for
smoke and toxicity, since they are assumed to be non-combustible. However, regardless of
whether a fire restricting material is used on top of an FRP composite panel, if a surface with
low flame-spread characteristics is applied or if the FRP composite panel is left bare it could
be claimed that it is the surface of the compartment which should be tested. End-use conditions
apply also in this test method and as much of the FRP composite that fits in the 25 mm sample
holder should then be included in the test. The long and significant heat exposure will cause
materials underneath the potentially burning surface to thermally decompose. Even if the result
is not the same as if the underlying materials were directly exposed, they will contribute to
the generated smoke and toxic gases to an extent that is representable to the heat exposure
in the test and in a fully developed fire.
D.7 Structural resistance
1 For load-bearing structures on SOLAS ships, structural resistance to fire is tested by

exposing the sample to a well-defined temperature that increases over time. Typical
standardized time-temperature curves are used as reference for the temperature in the furnace
as depicted in figure 11.
Fire exposure
1400
1200
Temperature (C)
1000
800
600 X2000
400 HC-curve
200 Standard curve
0
0 30 60 90 120 150 180 210 240 270 300
Time (minutes)
Figure 11: Time-temperature curves used for testing of structural resistance
2 In the structural resistance test the sample insulation properties are tested, i.e. its
ability to withstand heat while keeping the temperature down at the unexposed side of
the sample. The required performance time in a test and the demand for the backside
temperature depends on type of test and type of classification. An example of a structural
resistance test, used e.g. for walls, doors, bulkheads, etc., is illustrated in figure 12, where
a load-bearing wall with a window is exposed to heat. Another test for a door construction is
shown in figure 13.
Figure 12: Large-scale structural fire resistance test of a window

SDC 4/16
Annex 10, page 41
Figure 13: Insulation test of a door where thermocouples measure the

temperature of the unexposed side during the heat exposure
3 As discussed above, for SOLAS applications there is no requirement in the test

procedures to evaluate the construction load-bearing capabilities. In the HSC Code
the divisions corresponding to A-class divisions in SOLAS are referred to as Fire Resisting
Divisions (FRD). The main difference is the requirement for an A-class division to be
constructed with non-combustible material, which does not apply to an FRD. The structural fire
resistance test is basically identical to the test required for A-class divisions, except for an
additional load-bearing requirement. This requirement implies that FRD decks and bulkheads
shall withstand the standard fire test while subjected to transverse and in-plane loading,
respectively. A FRD deck or bulkhead structure must sustain the specified static loading whilst
exposed to fire in a large-scale furnace for 30 minutes or 60 minutes in order to be certified as
an FRD30 or FRD60 division, respectively.
4 Loading during fire resistance tests may be highly relevant when evaluating
FRP composite constructions for SOLAS ships. However, research has shown that it is more
suitable to apply the design load than the relatively low static load (in accordance with part 11
of the FTP Code) when testing insulated FRP sandwich panel bulkheads. It is likely that
a similar fire test procedure is suitable also for other FRP composite design concepts
(e.g. non-insulated FRP bulkheads, different deck concepts) but this must yet be verified.
Penetrations in FRP composite structures could reduce the load-bearing capacity and may call
for testing of penetrations in load-bearing structures as well. Tests have been performed with
certain FRP composite panels with holes that did not show any such effects. However, effects
clearly depend on the made penetrations and on the safety margins included in the design.
Fire resistance tests for penetrations on HSC are not performed with applied load.
Figure 14: Small-scale furnace for structural resistance tests

SDC 4/16
Annex 10, page 42
4 Small-scale test methods for structural resistance exist but are used in R&D projects
or for product quality control. The maximum size of the tested sample in the small-scale furnace
is 0.5 m x 0.6 m (figure 14), which is to be compared to a typical full-sized test as shown in
figure 12, where a 3 m x 3 m sample is being tested. In a SOLAS regulation II-2/17 assessment
it may be relevant to refer to standards other than IMO test standards to evaluate
fire-resistance (e.g. ISO 834-12 Fire resistance tests – Elements of building construction,
Part 12: Specific requirements for separating elements evaluated on less than full scale
furnaces and ISO 30021 Plastics – Burning behaviour – intermediate-scale fire-resistance
testing of fibre reinforced polymer composites).
D.8 Additional testing
1 Throughout different research projects many experimental tests have been carried
out. Except for tests according to all of the standardized test procedures described above,
tests have, for example, been carried out for divisions' structural integrity in vertical and
horizontal furnaces with various time, integrity requirements and loads (nominal load according
to the HSC Code, design load and realistic load). Many solutions for doors, windows and
penetrations have also been certified in such tests and different outfitting solutions have been
tested in experimental tests with corresponding fire exposure. Fire growth has been evaluated
for external combustible FRP composite surfaces based on a standardized test method for
testing reaction to fire properties of building façade systems.1 In the tests, the performance of
FRP composite surfaces protected with different passive or active measures were compared
with a completely non-combustible surface (hence the multiple layers of paint on a steel ship
were ignored). Performance criteria have been developed for external drencher systems to
determine under which conditions a drencher may be effective when using FRP composite on
external surfaces. Tests have also been performed based on the Guidelines for the approval
of fixed pressure water-spraying and water based fire-extinguishing systems for cabin
balconies (MSC/Circ.1268) which showed that a balcony sprinkler prevented a fully developed
cabin fire from spreading to FRP composite surfaces on the balcony and on outboard sides of
the ship.
2 Depending on the intended use of FRP composite further tests may be relevant, e.g.:
.1 a joint between steel and FRP composite could be fire tested to ensure that
collapse will not occur due to heat conduction from fire in an underlying steel
compartment;
.2 if insulation is used, it may be relevant to test FRP composite which is

insufficiently insulated, e.g. a small or large-scale furnace test with
0.1 m x 0.1 m or 0.5 m x 0.5 m lack of insulation, or emergency
repaired/modified; and
.3 structural integrity test of a composite deck exposed to fire from above.
3 It may also be claimed necessary to prove that an FRP composite material is not
easily ignited. Even though restricted ignitability is required by functional requirements in
SOLAS regulations, there is no IMO certifying test to show this property. However,
EN ISO 11925-2, Reaction to fire tests – Ignitability of building products subjected to direct
impingement of flame – Part 2: Single-flame source test or the Guidelines on fire test
procedures for acceptance of fire-retardant materials for the construction of lifeboats
(MSC/Circ.1006) provide possible test methods. EN ISO 11925-2 specifies a test method
which measures the ignitability of building products when exposed to a small flame. Based on
1
SP FIRE 105-External Wall Assemblies and Façade Claddings – Reaction to Fire.

SDC 4/16
Annex 10, page 43
numerous fire tests with various FRP composite materials,2 it has, however, been judged very
likely that most exposed surfaces of untreated FRP composite (i.e. the laminate) would pass
such a test. This can also be distinguished from the Cone Calorimeter test data in figure 7.
The graph does not only show that the FRP composite may become involved in a significant
fire but also that it resists the rather significant irradiation of 50 kW/m2 for at least one minute
before becoming involved in a large fire. For reference, 15 to 20 kW/m 2 towards the floor is
often referred to as a criterion for when flashover is determined in an enclosure fire. A Molotov
cocktail has, for example, been concluded not to be able to ignite the particular FRP composite
surface tested in figure 7. In the aforementioned test method for ignitability of building products,
the material is exposed to a flame the size of a match for 15 or 30 seconds. It can thereby be
concluded that FRP composite surfaces generally have restricted ignitability and what could
rather be a problem is fire spread if the surface is exposed to an already established fire. If
considered relevant, the ignitability of various FRP composite surfaces may be evaluated
through a test, e.g. according to the standard EN ISO 11925-2 or MSC.1/Circ.1006.
2
Fire Tests of FRP Composite Ship Structures, SP Technical Research Institute of Sweden,
http://publikationer.extweb.sp.se/user/default.aspx?RapportId=30980

SDC 4/16
Annex 10, page 44
APPENDIX E
EXAMPLE OF ASSESSMENT PROCEDURE
1 In this appendix, examples of a SOLAS regulation II-2/17 assessment are presented

with the ambition to guide the Administration in what to require from an assessment involving
FRP composite structures. The following three general principles are used:
.1 protect internal structures against exposure to an indoor fire;
.2 protect against fires exposing external surfaces; and
.3 document performance of fire protection using primarily established test

procedures.
2 A design preview meeting is typically held between the client, coordinator of

the assessment and the Administration prior to the start of the assessment in order to clarify
the scope, objectives, process and roles of stakeholders. Then a design team is selected to
mirror the complexity of the task, in the sense that the members should together possess all
the necessary competencies to perform the assessment of fire safety. For example, experts in
FRP composite materials, fire safety, fire testing, fire safety engineering, risk assessment, fire
safety regulation, ship design and operation may all be relevant to include. Even if the design
team should be formed at the beginning of the project, it may be necessary to expand it further
along. The whole design team will not be part of all parts of the process but it is key that
the design team is well represented at the hazard identification. It is also recommendable that
the Administration is included in the hazard identification, as well as at key review meetings,
as a witness to gain insight or to provide direct feedback on preliminary results.
3 An effective hazard identification requires that an investigation of potential challenges

to regulations has been performed (see section 3 (Important factors to consider when
evaluating FRP composite structures with starting point in the regulations of chapter II-2)) on
the basis of a base alternative design, which must be well-defined at this stage. A base
alternative design is the fire safety design and arrangements which all trial alternative designs
have in common, including the introduced novelty and pre-determined safety measures.
Different combinations of safety measures (risk control options) added to the base alternative
design defines the trial alternative designs to be evaluated (see example below).
4 As an example, consider the deck house in figure 15 with FRP composite sandwich panel
structures (composition as in figure 1). In the base alternative design the inside of
the FRP composite surfaces are covered by thermal insulation to achieve 60 minutes of fire
integrity according to the 2010 FTP Code, part 11. The fire integrity is maintained at openings and
penetrations.
Figure 15: Example deck house structure of FRP composite

SDC 4/16
Annex 10, page 45
5 Since the structures are not made of non-combustible material, deviations to

prescriptive requirements are found in SOLAS regulations II-2/9 and II-2/11. Regulation II-2/9
requires A-class divisions with 0 to 60 minutes fire insulation capability and regulation II-2/11
requires deckhouses to be constructed of steel or other equivalent material. By evaluation of
the purpose statements, several more challenges are identified, particularly when considering
the unprotected external surfaces (see section 3 (Important factors to consider when
evaluating FRP composite structures with starting point in the regulations of chapter II-2)).
Affected functional requirements may be identified as:
.1 restrict ignitability of combustible materials;
.2 restrict the amount of combustible materials;
.3 restrict the fire growth potential of combustible materials;
.4 limit the quantity of smoke and toxic products released from combustible
materials during fire;
.5 boundaries shall provide thermal insulation and integrity with due regard to
the fire risk of adjacent spaces; and
.6 materials used in the ships' structure shall ensure that the structural integrity
is not degraded due to fire.
6 During the hazard identification a number of potential ignition sources and fuels may
be identified inside and outside the deck house. With a deterministic (worst-case) approach,
two design fire scenarios are defined to evaluate the fire safety of the deck house: a flashover
fire in the generator space and a significant exterior hydrocarbon fire. Trial alternative designs
are said to be formed by adding any combination of risk control measures (RCMs), identified
as:
.1 provision of stiffeners on the inside of the exterior bulkheads (to provide

structural integrity along with the unexposed laminate in case of an external
fire);
.2 use of double sandwich panels (triple skin sandwich panels), where only half
are necessary to carry the design load (to structural integrity along with
the unexposed laminate in case of an external fire);
.3 provision of a drencher system covering the external surfaces;
.4 redundant supply unit for the drencher system;
.5 provision of low flame-spread characteristics on external surfaces; and
.6 automatic surveillance of closure of doors.
7 In quantifying effects on safety there are different approaches (see appendix D

(Recommendations regarding the assessment)). Here, an approach where the ambition is to
perform at least as well as a prescriptive design in all areas where fire hazards are introduced
independently is exemplified; this implies that a sufficient safety margin is sought which by
conservative safety measures allows to keep the complexity of the assessment at a minimum.

SDC 4/16
Annex 10, page 46
8 Regarding ignitability, this is only considered affected at external surfaces. A fire test
is performed in accordance with the standard ISO 11925-2, a test method to evaluate
the ignitability of building products when exposed to a small flame, which shows that ignitability
is not a problem. A full-scale experimental fire test is performed for different RCMs applied to
an FRP composite panel constructed as one of the external sides of the deck house. They
show that RCM e above or pre-activation of RCM c prevents ignition during 20 minutes of
significant fire exposure during the fire tests. This is argued sufficient with regard to
the potential for external fire exposure and the organization of manual firefighting. Tests
according to part 11 of the 2010 FTP Code are used to demonstrate that fire integrity, fire
growth potential and smoke production are managed in case of a fully developed fire inside
the spaces. Event tree analysis shows that function of door closing devices is key to prevent
an interior fire to grow and spread. It is therefore included in all risk control options (RCOs),
which are now concretized as:
.1 RCO A: RCMs a + c + d + f;
.2 RCO B: RCMs b + c + d + f;
.3 RCO C: RCMs b + c + d + f + extended detection system;
.4 RCO D: RCMs c + d + f + extended detection system; and
.5 RCO E: RCMs e, f.
9 RCO A and RCO B require that the drencher system is activated if structural integrity
is not to deteriorate and therefore includes a redundant supply unit (RCM c). Smoke production
may not be a problem on deck but it can be argued that fire growth is not properly managed.
This may be handled by an extended detection system, providing quick and reliable activation
of the drencher system, which was therefore added in RCO C. The question is then if
the over-capacity in structural integrity provided by RCM b is necessary, hence RCO D.
Without further elaborating on these issues, it is decided to present RCO E as the suggested
final alternative design, since it cost-effectively is considered to cost-effectively provide
a reliable solution. The performance criteria to better achieve safety functions where fire
hazards have been introduced are thereby considered to be met.
***

SDC 4/16
Annex 11, page 1
ANNEX 11
BIENNIAL STATUS REPORT AND OUTPUTS ON THE COMMITTEE'S POST-BIENNIAL AGENDA

THAT FALL UNDER THE PURVIEW OF THE SUB-COMMITTEE
SUB-COMMITTEE ON SHIP DESIGN AND CONSTRUCTION (SDC)

Output Description Target Parent Associated Coordinating Status of Status of References
number completion organ(s) organ(s) organ(s) output for output for
year Year 1 Year 2
1.1.2.3 Unified interpretation of provisions Continuous MSC/MEPC III/PPR/CCC/ Ongoing Ongoing MSC 78/26,
of IMO safety, security, and SDC/SSE/ paragraph 22.12;
environment-related Conventions NCSR SDC 4/16,
section 10
Notes: The Assembly, at its twenty-eighth session, had expanded the output to include all proposed unified interpretations to provisions of
IMO safety, security, and environment-related Conventions.
2.0.1.1 Amendments to the ESP Code Continuous MSC SDC Ongoing Ongoing MSC 91/22,
paragraph 19.24;
SDC 4/16,
section 9
5.1.1.1 Guidelines on safe return to port 2016 MSC SDC Completed MSC 81/25,
for passenger ships paragraph 23.54;
MSC 96/25,
paragraph 11.10

SDC 4/16
Annex 11, page 2

year Year 1 Year 2
5.1.1.3 Amendments to SOLAS and 2016 MSC SDC Extended Completed MSC 83/28,
FSS Code to make evacuation paragraph 25.25;
analysis mandatory for new MSC 93/22,
passenger ships and review of paragraph 20.11;
the Recommendation on MSC 96/25,
evacuation analysis for new and paragraph 11.13;
existing passenger ships MSC 96/25,
paragraph 11.15;
SDC 4/16,
paragraph 6.5
Notes: Target completion year extended to 2017 (MSC 96/25, paragraph 23.25).
5.1.1.6 Amendments to SOLAS 2016 MSC HTW SDC Completed MSC 93/22,
chapter II-1 and associated paragraphs 6.28.4,
guidelines on damage control 20.5 and 20.14;
drills for passenger ships MSC 97/22,
paragraphs 3.11
and 3.23
5.2.1.1 Revised SOLAS regulation II-1/3-8 2017 MSC HTW/SSE SDC In progress Extended MSC 95/22,
and associated guidelines paragraph 19.22;
(MSC.1/Circ.1175) and new SDC 4/16,
guidelines for safe mooring section 11
operations for all ships
Notes: Target completion year extended to 2019 (SDC 4/16, paragraph 11.10).

SDC 4/16
Annex 11, page 3

year Year 1 Year 2
5.2.1.2 Amendments to the IGF Code 2016 MSC HTW/PPR/ CCC No work No work MSC 94/21,
and development of guidelines SDC/SSE requested requested paragraphs 18.5
for low-flashpoint fuels and 18.6;
MSC 96/25,
paragraphs 10.1
to 10.3
Notes: MSC 97 approved the request of CCC 3 to extend the target completion year to 2017 (MSC 97/22, paragraph 19.2).
5.2.1.4 Mandatory instrument and/or 2017 MSC SDC In progress In progress MSC 95/22,
provisions addressing safety paragraphs 10.13
standards for the carriage of and 19.25;
more than 12 industrial MSC 96/25,
personnel on board vessels paragraphs 7.10
engaged on international and 7.12;
voyages (2020) MSC 97/22,
paragraphs 6.22
to 6.25;
SDC 4/16,
section 8
5.2.1.5 Revised SOLAS regulations II-1/13 2017 MSC SDC SSE No work No work MSC 95/22,
and II-1/13-1 and other related requested requested paragraphs 19.20
regulations for new ships and 19.32
5.2.1.6 Revision of section 3 of the 2017 MSC SDC In progress Completed MSC 93/22,
Guidelines for damage control paragraphs 6.28
plans and information to the and 20.15;
master (MSC.1/Circ.1245) for SDC 4/16,
passenger ships paragraph 7.9

SDC 4/16
Annex 11, page 4

year Year 1 Year 2
5.2.1.7 Computerized stability support 2016 MSC SDC Extended Extended MSC 94/21,
for the master in case of flooding paragraph 18.20;
for existing passenger ships SDC 4/16,
section 4
5.2.1.12 Finalization of second 2017 MSC SDC In progress Postponed MSC 85/26,
generation intact stability criteria paragraphs 12.7
(2019) and 23.42;
SDC 4/16,
section 5
5.2.1.13 Amendments to SOLAS 2017 MSC SDC In progress Extended MSC 85/26,
regulations II-1/6 and II-1/8-1 paragraph 23.35;
MSC 97/22,
paragraph 3.11;
SDC 4/16,
section 3
5.2.1.15 Consequential work related to 2017 MSC/MEPC NCSR/PPR/ SDC No work No work MSC 93/22,
the new Code for ships SSE requested requested paragraphs 10.44,
operating in polar waters 10.50 and 20.12;
MSC 96/25,
paragraph 3.77
5.2.1.21 Guidelines for use of Fibre 2017 MSC SDC In progress Completed MSC 95/22,
Reinforced Plastics (FRP) within paragraph 10.16;
ship structures SDC 4/16,
paragraph 12.15
Notes: Moved to the post-biennial agenda (SDC 4/16, paragraph 12.16).

SDC 4/16
Annex 11, page 5

year Year 1 Year 2
5.2.1.24 Amendments to Part B of the 2016 MSC SDC Completed MSC 88/26,
2008 IS Code on towing, lifting paragraph 23.36;
and anchor handling operations MSC 97/22,
paragraphs 3.88
and 3.89
5.2.1.29 Review SOLAS chapter II-2 and 2017 MSC HTW/SDC SSE No work MSC 97/22,
(New) associated codes to minimize requested paragraph 19.19
the incidence and
consequences of fires on ro-ro
spaces and special category
spaces of new and existing ro-ro
passenger ships (2019)
Notes: Pending endorsement by C 118
7.1.2.3 Code for the transport and 2017 MSC/MEPC SDC/SSE PPR No work No work
handling of limited amounts of requested requested
hazardous and noxious liquid
substances in bulk on offshore
support vessels
14.0.1.1 Analysis and consideration of 2017 Council III/HTW/PPR/ MSC/MEPC/ No work No work MSC 96/25,
recommendations to reduce CCC/SDC/ FAL/LEG requested requested paragraphs 19.4.5,
administrative burdens in IMO SSE/NCSR 19.4.9 and
instruments including those 19.4.10
identified by the SG-RAR

SDC 4/16
Annex 11, page 6
OUTPUTS ON THE COMMITTEE'S POST-BIENNIAL AGENDA THAT FALL UNDER THE PURVIEW OF THE SUB-COMMITTEE
SHIP DESIGN AND CONSTRUCTION (SDC)

ACCEPTED POST-BIENNIAL OUTPUTS
Reference to Parent Associated Coordinating Timescale
References
*
Number Biennium High-level Description organ(s) organ(s) organs(s) (sessions)
Actions
7 2012-2013 2.0.1 Mandatory application of the MSC SDC 2 MSC 76/23,
Performance standard for paragraphs 20.41.2
protective coatings for void and 20.48;
spaces on bulk carriers and oil DE 50/27, section 4
tankers
8 2012-2013 2.0.1 Performance standard for MSC SDC 2 MSC 76/23,

protective coatings for void paragraphs 20.41.2
spaces on all types of ships and 20.48
9 2012-2013 2.0.1 Revision of the provisions for MSC SDC 2 MSC 86/26,
helicopter facilities in SOLAS paragraph 23.39
and the MODU Code
Notes: The associated organ should be SSE (SDC 4/16, paragraph 13.11.1).
129 2016-2017 5.2.1 Guidelines for wing-in-ground MSC SDC 2 MSC 88/26,
craft paragraph 23.30,
MSC 96/25,
paragraph 23.25
Notes: To be included in the 2018-2019 biennial agenda and the provisional agenda of SDC 5 (SDC 4/16, paragraphs 13.9, 13.10 and 13.13).
*
Biennium when the output was placed on the post-biennial agenda.

SDC 4/16
Annex 11, page 7
SHIP DESIGN AND CONSTRUCTION (SDC)

ACCEPTED POST-BIENNIAL OUTPUTS
Reference to Parent Associated Coordinating Timescale
References
*
Number Biennium High-level Description organ(s) organ(s) organs(s) (sessions)
Actions
130 2016-2017 5.2.1 Review SOLAS chapter II-1, MSC SDC 3 MSC 96/25,
parts B-2 to B-4, to ensure paragraph 23.23
consistency with parts B and B-
1 with regard to watertight
integrity
Notes: To be included in the 2018-2019 biennial agenda and the provisional agenda of SDC 5 (SDC 4/16, paragraphs 13.8, 13.10 and 13.13).
42 2012-2013 5.2.1 Review of the 2009 Code on MSC NCSR SDC 2 MSC 89/25,
Alerts and Indicators paragraph 22.25
Notes: The coordinating organ should be SSE (SDC 4/16, paragraph 13.11.1).
76 2014-2015 5.2.1 Application of the Mandatory MSC SDC 3 Output 5.2.1.15
Code to non-SOLAS ships
operating in polar waters
[…] 2016-2017 5.2.1 Guidelines for use of Fibre MSC SDC 2 SDC 4/16,
Reinforced Plastics (FRP) paragraph 12.16
within ship structures
Notes: During the interim period any information, observations, comments and/or recommendations should be submitted under "Any other
business".
32 2012-2013 5.2.4 Recommendations related to MSC/MEPC SDC 1 MSC 91/22,
navigational sonar on crude oil paragraph 19.23;
tankers SDC 4/16,
paragraph 13.11.2
Notes: Navigational sonar may be a source of underwater noise (MSC 91/22, paragraph 16.15.3)
***

SDC 4/16
Annex 12, page 1
ANNEX 12
PROPOSED BIENNIAL AGENDA FOR THE 2018-2019 BIENNIUM

year Year 1 Year 2
1.1.2.3 Unified interpretation of provisions Continuous MSC/MEPC III/PPR/CCC/ Ongoing MSC 78/26,
of IMO safety, security, and SDC/SSE/ paragraph 22.12;
environment-related Conventions NCSR SDC 34/2116,
section 1410
Notes: The Assembly, at its twenty-eighth session, had expanded the output to include all proposed unified interpretations to provisions of
IMO safety, security, and environment-related Conventions.
2.0.1.1 Amendments to the ESP Code Continuous MSC SDC Ongoing MSC 91/22,
paragraph 19.24;
SDC 34/2116,
section 139
5.1.1.1 Guidelines on safe return to port 2016 MSC SDC Completed MSC 81/25,
for passenger ships paragraph 23.54;
MSC 96/25,
paragraph 11.10

SDC 4/16
Annex 12, page 2

year Year 1 Year 2
5.1.1.3 Amendments to SOLAS and 2016 MSC SDC Extended MSC 83/28,
FSS Code to make evacuation paragraph 25.25;
analysis mandatory for new MSC 93/22,
passenger ships and review of paragraph 20.11;
the Recommendation on MSC 96/25,
evacuation analysis for new and paragraph 11.13;
existing passenger ships MSC 96/25,
paragraph 11.15
Notes: Target completion year extended to 2017 (MSC 96/25, paragraph 23.25).
5.1.1.6 Amendments to SOLAS 2016 MSC HTW SDC Completed MSC 93/22,
chapter II-1 and associated paragraphs 6.28.4,
guidelines on damage control 20.5 and 20.14;
drills for passenger ships MSC 97/22,
paragraphs 3.11
and 3.23
5.2.1.1 Revised SOLAS regulation II-1/3-8 2017 MSC HTW/SSE SDC In progress MSC 95/22,
and associated guidelines 2019 paragraph 19.22;
(MSC.1/Circ.1175) and new SDC 34/2116,
guidelines for safe mooring section 1511
operations for all ships
5.2.1.2 Amendments to the IGF Code 2016 MSC HTW/PPR/ CCC No work MSC 94/21,
and development of guidelines [2019] SDC/SSE requested paragraphs 18.5
for low-flashpoint fuels and 18.6;
MSC 96/25,
paragraphs 10.1
to 10.3
Notes: MSC 97 approved the request of CCC 3 to extend the target completion year to 2017 (MSC 97/22, paragraph 19.2)

SDC 4/16
Annex 12, page 3

year Year 1 Year 2
5.2.1.4 Mandatory instrument and/or 2017 MSC SDC In progress MSC 95/22,
provisions addressing safety 2019 paragraphs 10.13
standards for the carriage of and 19.25;
more than 12 industrial MSC 96/25,
personnel on board vessels paragraphs 7.10
engaged on international and 7.12;
voyages (2020) MSC 97/22,
paragraphs 6.22
to 6.25;
SDC 4/16,
section 8
5.2.1.5 Revised SOLAS regulations II-1/13 2017 MSC SDC SSE No work MSC 95/22,
and II-1/13-1 and other related [2019] requested paragraphs 19.20
regulations for new ships and 19.32
5.2.1.6 Revision of section 3 of the 2017 MSC SDC In progress MSC 93/22,
Guidelines for damage control paragraphs 6.28
plans and information to the and 20.15;
master (MSC.1/Circ.1245) for SDC 3/21,
passenger ships section 10
5.2.1.7 Computerized stability support 2016 MSC SDC Extended MSC 94/21,
for the master in case of flooding 2018 paragraph 18.20;
for existing passenger ships SDC 34/2116,
section 4
Notes: Target completion year extended to 20178 (MSC 96/25SDC 4/16, paragraph 23.254.18).

SDC 4/16
Annex 12, page 4

year Year 1 Year 2
5.2.1.12 Finalization of second 2017 MSC SDC In progress MSC 85/26,
generation intact stability criteria 2019 paragraphs 12.7
(2019) and 23.42;
SDC 34/2116,
section 65
5.2.1.13 Amendments to SOLAS 2017 MSC SDC In progress MSC 85/26,
regulations II-1/6 and II-1/8-1 2019 paragraph 23.35;
Amendments to SOLAS MSC 97/22,
regulation II-1/8-1 on the paragraph 3.11;
availability of passenger ships' SDC 4/16,
electrical power supply in cases section 3
of flooding from side raking
damage
5.2.1.15 Consequential work related to 2017 MSC/MEPC NCSR/PPR/ SDC No work MSC 93/22,
the new Code for ships 2019 SSE requested paragraphs 10.44,
operating in polar waters 10.50 and 20.12;
MSC 96/25,
paragraph 3.77
5.2.1.21 Guidelines for use of Fibre 2017 MSC SDC In progress MSC 95/22,
Reinforced Plastics (FRP) within paragraph 10.16;
ship structures SDC 3/21,
section 17

SDC 4/16
Annex 12, page 5

year Year 1 Year 2
5.2.1.24 Amendments to Part B of the 2016 MSC SDC Completed MSC 88/26,
2008 IS Code on towing, lifting paragraph 23.36;
and anchor handling operations MSC 97/22,
paragraphs 3.88
and 3.89
5.2.1.29 Review SOLAS chapter II-2 and 2017 MSC HTW/SDC SSE MSC 97/22,
(New) associated codes to minimize 2019 paragraph 19.19
the incidence and
consequences of fires on ro-ro
spaces and special category
spaces of new and existing ro-ro
passenger ships (2019)
Notes: Pending endorsement by C 118
5.2.1.[…] Guidelines for wing-in-ground 2019 MSC SDC MSC 88/26,
craft paragraph 23.30,
MSC 96/25,
paragraph 23.25;
SDC 4/16,
paragraphs 13.9,
13.10 and 13.13
Notes: Moved from the post-biennial agenda.
5.2.1.[…] Review SOLAS chapter II-1, 2019 MSC SDC MSC 96/25,
parts B-2 to B-4, to ensure paragraph 23.23;
consistency with parts B and B-1 SDC 4/16,
with regard to watertight integrity paragraphs 13.8,
(2020) 13.10 and 13.13
Notes: Moved from the post-biennial agenda.

SDC 4/16
Annex 12, page 6

year Year 1 Year 2
7.1.2.3 Code for the transport and 2017 MSC/MEPC SDC/SSE PPR No work
handling of limited amounts of requested
hazardous and noxious liquid
substances in bulk on offshore
support vessels
14.0.1.1 Analysis and consideration of 2017 Council III/HTW/PPR/ MSC/MEPC/ No work MSC 96/25,
recommendations to reduce CCC/SDC/ FAL/LEG requested paragraphs 19.4.5,
administrative burdens in IMO SSE/NCSR 19.4.9 and
instruments including those 19.4.10
identified by the SG-RAR
***

SDC 4/16
Annex 13, page 1
ANNEX 13
PROPOSED PROVISIONAL AGENDA FOR SDC 5
Opening of the session
1 Adoption of the agenda
2 Decisions of other IMO bodies
3 Amendments to SOLAS regulation II-1/8-1 on the availability of passenger ships'

electrical power supply in cases of flooding from side raking damage (5.2.1.13)
4 Computerized stability support for the master in case of flooding for existing
passenger ships (5.2.1.7)
5 Review SOLAS chapter II-1, parts B-2 to B-4, to ensure consistency with parts B
and B-1 with regard to watertight integrity*
6 Finalization of second generation intact stability criteria (5.2.1.12)
7 Mandatory instrument and/or provisions addressing safety standards for the carriage
of more than 12 industrial personnel on board vessels engaged on international
voyages (5.2.1.4)
8 Amendments to the 2011 ESP Code (2.0.1.1)
9 Unified interpretation to provisions of IMO safety, security, and environment-related

Conventions (1.1.2.3)
10 Revised SOLAS regulation II-1/3-8 and associated guidelines (MSC.1/Circ.1175) and

new guidelines for safe mooring operations for all ships (5.2.1.1)
11 Guidelines for wing-in-ground craft (5.2.1.23)*
12 Biennial status report and provisional agenda for SDC 5
13 Election of Chair and Vice-Chair for 2019
14 Any other business
15 Report to the Maritime Safety Committee
***
*
Output number to be decided by the Council in due course.

SDC 4/16
Annex 14, page 1
ANNEX 14
STATEMENTS BY DELEGATIONS
AGENDA ITEM 11
STATEMENT BY THE OBSERVER FROM IFSMA
IFSMA, representing the Shipmaster, would like to thank Denmark and Japan for the report of
the Correspondence Group and we agree with the comments of both ICS and OCIMF.
On a more specific point there appears to be a number of conflicting issues in the draft
Guidelines set out in annex 2 to document SDC 4/11. As an example, in sub-paragraph 4.2.3
(Objectives) it states that "In normal mooring operations only mooring lines that are
permanently fixed to a winch are used;" but in sub-paragraph 5.1.6 (Construction) it states
that "The mooring arrangement should be so designed that manual handling of towing and
mooring lines is minimized [(As Low As Reasonably Practicable)]. This could be accomplished
through use of fixed/dedicated mooring lines, use of spooling equipment and by placing
mooring winches close to the ship side served." This seems to be a conflict between the
Objective being a Wish List and the Construction being the Practical Application.
AGENDA ITEM 13
STATEMENT BY DELEGATION OF NEW ZEALAND
New Zealand is proud to be part of an organization that does not back away from taking timely
action to meet its mandate of safe, secure and environmentally sound shipping – however
complex it may be to solve or however many questions need to be answered.
Although disappointed with the decision not to place Mandatory Polar Code Phase II onto
the agenda of SDC 5, we accept that this Sub-Committee is seeking direction from the Maritime
Safety Committee on a way forward for this important issue.
New Zealand wishes to remind delegates that our parent Committee has already agreed that
there is a compelling need, and has created an output on its programme entitled "Application
of the Mandatory Code to non-SOLAS ships operating in polar waters". The latest record of
this Committee decision can be found on page 2 of annex 25 to document MSC 97/22/Add.1
– and is on GISIS.
This need has been further supported by the submission of accident data and data on the loss
of a significant number of lives on non-SOLAS ships operating in polar waters.
New Zealand is concerned about the notion that experience needs to be gained from Phase I
before progress on Phase II can begin, and we do not support that as an approach.
Over 90% of the accidents occurring in the Ross Sea region of Antarctica involve
non-SOLAS ships – this statistic will not improve with the implementation of Phase I.
New Zealand notes the Secretary-General's recent voyage to Antarctica. While experiencing
the beauty of Polar Regions, he would have heard about, and maybe even experienced
first-hand, how fast this beauty can become dangerous and violent – especially in the Drake
Passage.

SDC 4/16
Annex 14, page 2
When a non-SOLAS ship requires rescue, it not only places that ships' crew and the polar
environment at direct and immediate risk, it also places every other ship in the vicinity at greater
risk as they endeavour to effect a rescue.
New Zealand plans to submit a paper to MSC 98 with a view to building on the successful
momentum achieved at this meeting. We thank Member States for the substantial support
for our paper at this meeting, and extend an invitation to collaborate with us on a paper
for MSC 98.
We believe a collective approach is the best way – to design a path forward for this work.
Contact details:
Melissa Idiens
Senior International Policy Advisor
Maritime New Zealand
Wellington
Tel: +64 4 830 0537
Fax: +64 4 494 8901
W www.maritimenz.govt.nz/contact-us
___________

SDC 4 16 Report To The Maritime Safety Committee Secretariat

Загружено:

Сведения о документе

Оригинальное название

Авторское право

Доступные форматы

Поделиться этим документом

Поделиться или встроить документ

Параметры публикации

Этот документ был вам полезен?

Это неприемлемый материал?

Авторское право:

Доступные форматы

SDC 4 16 Report To The Maritime Safety Committee Secretariat

Загружено:

Авторское право:

Доступные форматы

E

SUB-COMMITTEE ON SHIP DESIGN AND SDC 4/16

REPORT TO THE MARITIME SAFETY COMMITTEE

2 DECISIONS OF OTHER IMO BODIES 4

3 AMENDMENTS TO SOLAS REGULATIONS II-1/6 AND II-1/8-1 5

4 COMPUTERIZED STABILITY SUPPORT FOR THE MASTER IN CASE 10

5 FINALIZATION OF SECOND GENERATION INTACT STABILITY 13

6 AMENDMENTS TO SOLAS AND THE FSS CODE TO MAKE 24

7 REVISION OF SECTION 3 OF THE GUIDELINES FOR DAMAGE 25

8 MANDATORY INSTRUMENT AND/OR PROVISIONS ADDRESSING 26

9 AMENDMENTS TO THE 2011 ESP CODE 28

10 UNIFIED INTERPRETATION TO PROVISIONS OF IMO SAFETY, 30

11 REVISED SOLAS REGULATION II-1/3-8 AND ASSOCIATED 33

I:\SDC\04\SDC 4-16 (E).docx

12 GUIDELINES FOR USE OF FIBRE REINFORCED PLASTIC (FRP) 37

13 BIENNIAL STATUS REPORT AND PROVISIONAL AGENDA FOR SDC 5 41

14 ELECTION OF CHAIR AND VICE-CHAIR FOR 2018 44

15 ANY OTHER BUSINESS 44

16 REPORT TO THE MARITIME SAFETY COMMITTEE 45

ANNEX 1 DRAFT MSC RESOLUTION ON REVISED EXPLANATORY NOTES TO

ANNEX 2 DRAFT AMENDMENTS TO SOLAS REGULATIONS II-1/1 AND II-1/8-1

ANNEX 3 DRAFT MSC CIRCULAR ON AMENDMENTS TO SECTION 3 OF

ANNEX 4 DRAFT MSC CIRCULAR ON UNIFIED INTERPRETATIONS OF SOLAS

ANNEX 5 DRAFT MSC CIRCULAR ON GUIDELINES ON THE MEANS OF ACCESS

ANNEX 6 DRAFT MSC CIRCULAR ON UNIFIED INTERPRETATIONS OF SOLAS

ANNEX 7 DRAFT CORRIGENDUM TO MSC.1/CIRC.1464/REV.1

ANNEX 8 DRAFT MSC CIRCULAR ON UNIFIED INTERPRETATION OF SOLAS

ANNEX 9 DRAFT MEPC CIRCULAR ON UNIFIED INTERPRETATION OF

ANNEX 10 DRAFT MSC CIRCULAR ON INTERIM GUIDELINES FOR USE OF FIBRE

ANNEX 11 BIENNIAL STATUS REPORT AND OUTPUTS ON THE COMMITTEE'S

I:\SDC\04\SDC 4-16 (E).docx

ANNEX 12 PROPOSED BIENNIAL AGENDA FOR THE 2018-2019 BIENNIUM

ANNEX 13 PROPOSED PROVISIONAL AGENDA FOR SDC 5

ANNEX 14 STATEMENTS BY DELEGATIONS

I:\SDC\04\SDC 4-16 (E).docx

1.1 The Sub-Committee on Ship Design and Construction (SDC), chaired by

Adoption of the agenda and related matters

2 DECISIONS OF OTHER IMO BODIES

I:\SDC\04\SDC 4-16 (E).docx

3 AMENDMENTS TO SOLAS REGULATIONS II-1/6 AND II-1/8-1

I:\SDC\04\SDC 4-16 (E).docx

Part 2 of the report of the SDS Working Group established at SDC 3

Report of the SDS Correspondence Group and related documents

.1 SDC 4/3/2 (Norway), advising of an inconsistency between the previous SOLAS

.2 SDC 4/3/3 (China), proposing to develop an internationally uniform

I:\SDC\04\SDC 4-16 (E).docx

.2 the use of time-domain simulations as an alternative to damage stability

.3 an internationally uniform time-domain flooding simulation standard method

.4 the proposal in document SDC 4/3/2 needs to be carefully considered as it

3.13 Following consideration of the action requested in paragraph 24 of the report of

.3 agreed to establish an SDS Working Group to further consider the outstanding

Establishment of the SDS Working Group

.1 consider the outstanding issues, as specified in documents SDC 4/3/1

I:\SDC\04\SDC 4-16 (E).docx

.3 examine the draft amendments to SOLAS regulation II-1/8-1.2 to improve

Report of the SDS Working Group

I:\SDC\04\SDC 4-16 (E).docx

I:\SDC\04\SDC 4-16 (E).docx

Re-establishment of the SDS Correspondence Group

.1 develop draft amendments to SOLAS regulation II-1/8-1 including functional

.2 submit a report to SDC 5.

Extension of the target completion year

4 COMPUTERIZED STABILITY SUPPORT FOR THE MASTER IN CASE OF