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IMO DE 53 Agenda Preview

The 53rd session of IMO Sub-Committee on Ship Design and Equipment will be held on 22 – 26 February 2010 10th February, 2010

(Updated version)

This publication, produced by Lloyd’s Register, provides an overview of the agenda for DE 53, and summarises all the documents submitted for discussion at this meeting.

It contains details of all papers submitted and published by the IMO up to 10th February, 2010, updating the previous document issued on 27th January, 2010.

Synopses have only been included for each agenda item.

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Contents

1. Agenda for DE 53 5

2. Decisions of other IMO bodies (Agenda Item 2) (Target completion date – Continuous) 7

3. Measures to prevent accidents with lifeboats (Agenda Item 3) (Target completion date – 2010) 7

4. Compatibility of life-saving appliances (Agenda Item 4) (Target completion date – 2010) 10

5. Revision of resolution A.760 (18) (Agenda Item 5) (Target completion date – 2010) 11

6. Performance standards for recovery systems (Agenda Item 6) (Target completion date – 2010) 12

7. Cargo oil tank coating and corrosion protection (Agenda Item 7) (Target completion date – 2010) 12

8. Development of a new framework of requirements for life-saving appliances (Agenda Item 8) (Target completion date – 2012) 14

9. Guidance to ensure consistent policy for determining the need for watertight doors to remain open during navigation (Agenda Item 9) (Target completion date – 2010) 15

10. Protection against noise on board ships (Agenda Item 10) (Target completion date – 2010) 15

11. Thermal performance of immersion suits (Agenda Item 11) (Target completion date – 2010) 16

12. Alternative arrangements for the bottom inspection requirements for passenger ships other than ro-ro passenger ships (Agenda Item 12) (Target completion date – 2010) 16

13. Amendments to the Revised recommendation on testing of life-saving appliances (Agenda Item 13) (Target completion date – 2010) 17

14. Safety provisions applicable to tenders operating from passenger ships (Agenda Item 14) (Target completion date – 2011) 18



15. Classification of offshore industry vessels and consideration of the need for a code for offshore construction support vessels (Agenda Item 15) (Target completion date – 2010) 18

16. Interpretation on application of SOLAS, MARPOL and Load Line requirements for major conversions of oil tankers (Agenda Item 16) (Target completion date – 2010) 19

17. Consideration of IACS unified interpretations (Agenda Item 17) (Target completion date – continuous) 20

18. Development of a mandatory Code for ships operating in polar waters (Agenda Item 18) (Target completion date – 2012) 21

19. Application of amendments to SOLAS chapter III and the LSA Code (Agenda Item 19) (Target completion date – 2010) 22

20. Guidelines for a visible element to general alarm systems on passenger ships (Agenda Item 20) (Target completion date – 2012) 23

21. Improvement of existing pollution prevention equipment (Agenda Item 21) (Target completion date – 2011) 24

.1 Development of test standards for type approval of add-on equipment 24

.2 Promotion of integrated bilge water treatment systems 24

22. Development of guidelines for a shipboard oil waster pollution prevention plan (Agenda Item 22) (Target completion date – 2011) 24

23. Manually operated alternatives in the event of pollution prevention equipment malfunctions (Agenda Item 23) (Target completion date – 2011) 25

24. Any other business (Agenda Item 25) 26



1. Agenda for DE 53

Opening of the session

1. Adoption of the agenda

2. Decisions of other IMO bodies

3. Measures to prevent accidents with lifeboats

4. Compatibility of life-saving appliances

5. Revision of resolution A.760(18)

6. Performance standards for recovery systems

7. Cargo oil tank coating and corrosion protection

8. Development of a new framework of requirements for life-saving appliances

9. Guidance to ensure consistent policy for determining the need for watertight

doors to remain open during navigation

10. Protection against noise on board ships

11. Thermal performance of immersion suits

12. Alternative arrangements for the bottom inspection requirements for

passenger ships other than ro-ro passenger ships

13. Amendments to the Revised recommendation on testing of life-saving

appliances

14. Safety provisions applicable to tenders operating from passenger ships

15. Classification of offshore industry vessels and consideration of the need for a

code for offshore construction support vessels

16. Interpretation on application of SOLAS, MARPOL and Load Line requirements

for major conversion of oil tankers

17. Consideration of IACS Unified interpretations

18. Development of a mandatory Code for ships operating in polar waters

19. Application of amendments to SOLAS chapter III and the LSA Code



20. Guidelines for a visible element to general alarm systems on passenger ships

21. Improvement of existing pollution prevention equipment

1. Development of test standards for type approval of add-on equipment

2. Promotion of integrated bilge water treatment system

22. Development of guidelines for a shipboard oil waste pollution prevention plan

23. Manually operated alternatives in the event of prevention pollution

equipment malfunctions

24. Work Programme for DE 54

25. Any other business

26. Report to the Maritime Safety Committee

Working and Drafting Groups:

WG or DG Life-saving appliances, including measures to prevent accidents with lifeboats and performance standards for recovery systems

WG or DG Cargo oil tank coating and corrosion protection WG or DG Alternative arrangements for the bottom inspection requirements for

passenger ships other than ro-ro passenger ships WG or DG Safety provisions applicable to tenders operating from passenger ships WG or DG Interpretation on application of SOLAS, MARPOL and Load Line

requirements for major conversions of oil tankers



2. Decisions of other IMO bodies (Agenda Item 2) (Target completion

date – Continuous)

Background: The Sub-Committee will be informed of relevant decisions made and action taken by MSC 86 (DE 53/2); MEPC 59 (DE 53/2/1); and FSI 17, NAV 55, DSC 14, STW 41 and SLF 52 (DE 53/2/2) and will take action, as appropriate, under the relevant agenda items. LR position: To monitor discussion Implications: None, as substantial discussion will take place under respective agenda item. Application: N/A (Document submitted) DE 53/2 (Secretariat) – Outcome of MSC 86 This document reports on decisions taken at MSC 86 relevant to the work of the Sub-Committee. DE 53/2/1 (Secretariat) - Outcome of MEPC 59 This document reports on decisions taken at MEPC 59 relevant to the work of the Sub-Committee. It introduces new work programmes added to this Sub-Committee. DE 53/2/2 (Secretariat) - Outcome of FSI 17 and NAV 55 This document contains references to decisions taken at FSI 17 and NAV 55 relevant to the work of the Sub-Committee. The document contains proposed changed to MSC.1/Circ. 1331 made by the NAV Sub-Committee to the Maritime Safety Committee. DE 53/2/3 (United Kingdom) - Comments on the outcome of NAV 55 This document highlights concerns relating to the proposed amended text from NAV 55 for MSC.1/Circ.1331, paragraph 3.1, aimed at resolving the possible conflict between SOLAS regulation V/23 and the new SOLAS regulation II-1/3-9.

3. Measures to prevent accidents with lifeboats (Agenda Item 3) (Target completion date – 2010)

Background: In 1986 on-load release hooks for lifeboats and rescue boats were made mandatory by SOLAS in response to the Norway’s worst offshore accident in March 1980. Since 1986 when the IMO requirements for all new ships to be fitted with on-load release systems came into place, there have been a number of serious accidents during drills and servicing. At DE 52, the Sub-Committee developed the following amendments which have been subsequently approved by the Committee: - Draft amendments to the LSA Code – paragraph 4.4.7.6 (approved at MSC 86 for

adoption at MSC 87) The Sub-Committee considered new criteria for safer lifeboat on-load release hooks, and agreed that existing hooks with “poor and unstable design” are to be



replaced, but existing hooks which “are of a safe design/have a good safety record” may continue in service.

- Draft amendments to the SOLAS Regulation III/1 (approved at MSC 86 for adoption at MSC 87)

Draft amendments to SOLAS III/1 will require the lifeboat on-load release mechanisms of all ships to be replaced if they are assessed and identified as being of a “poor and unstable design” (as described above). These draft amendments will be submitted to MSC 86 for approval and subsequent adoption.

- Draft MSC Circular on Guidelines for the fitting and use of fall prevention devices (subsequently approved by MSC 86 as MSC.1/Circ 1327)

As this is an interim measure, until the launching mechanism (hook) is re-assessed and replaced, if necessary, the type approval of FPD is not required. Although the type approval of FPD is not mandatory, it is expected that FPD will satisfy the design criteria as specified in the circular and may be issued by a company acceptable to an Administration. The circular also specified the requirement for inspection and testing.

- Authorization of independent service providers to lifeboats - amendments to MSC.1/circ.1206 (Subsequently approved as MSC.1/Circ. 1206 Rev.1 by MSC.86)

A draft MSC Circular was prepared to update MSC Circ. 1206 taking into account various developments since the approval of the circular.

The following will be further discussed at this session - Definition of “unfavourable conditions of trim and list” - Safety of lifeboat release mechanism on various points - Draft guidelines for lifeboat control arrangements (DE 53/3 – Annex) - Draft amendments to the revised recommendation on testing of life-saving

appliances (Resolution MSC.81 (70)) (DE 53/3 – Annex) - Draft Measures to make all or parts of MSC.1/Circ. 1206/Rev.1 mandatory (DE 53/3/1) - Counterfeit products (DE 53/3/2) The following documents may be considered under this agenda item - Loading test of hooks for primary release of free-fall lifeboats (DE 53/17/4) It is envisaged that the following issues would require further attention: - At least one recommendation (para 4-20 of DE 53/3) will place a large work load on

owners, manufacturers and ROs - The test given in DE 53/3 para 21 is difficult to carry out in practice. There are

concerns about possibly damaging the lifeboat whilst completing the test. - The term “long term and stable relationship” (DE 53/3/1) needs to be clearly defined

to ensure consistency of application. - The FMEA (DE 53/3/3) can be very subjective and consistent application may be

difficult. The large additional costs associated with FMEA should also be considered in discussions.

LR position: To actively participate in this important discussion by sending an expert to the Working / Drafting group as a part of IACS delegation in order to improve safety of lifeboat. LR considers that consistencies of the approval of safe/unsafe hook among authorities would be a great challenge, therefore, would have particular attention to these elements. LR, in conjunction with the proposal given in DE 53/3/4, would like bring attentions of concerned parties that test requirement for lifting lug does not exist in the current LSA code. Implications:



- Shipbuilders & boat manufacturers: The result of this discussion will affect design launching appliances of lifeboat.

- Shipowners and managers: The result of this discussion will affect maintenance and inspection of launching arrangements of lifeboat. The result may trigger replacement of existing launching appliances, e.g., hooks.

- Flag Administration and its RO: New survey and type approval instructions would be required. Training of surveyors will become very important to ensure consistent application. If FMEA is used further training in risk assessment will be necessary. Overall, implementation of these initiatives will require significant resources.

Application: All new and existing life boat launching arrangements used for ships subject to SOLAS Chapter III (ships engaged on international voyages - no-tonnage limitation for passenger ships and 500 tons or over for ships other than passenger ships). (Document submitted) DE 53/3 and DE 53/3/Add.1 (United States) - Report of the correspondence group on Life-saving Appliances (LSA) This document reports the outcome thus far of the LSA correspondence group with regard to measures to prevent accidents with lifeboats, and invites further comments and proposals. The group addressed the following issues: - Evaluation of lifeboat on-load release mechanisms for “poor and unstable”

characteristics - Modification of non-compliant hooks to address shortcomings - A proposed alternate or supplementary approach for consideration - Evaluation of new hook installations in existing lifeboats - Standardization and the human element - Test procedures for evaluation of release hooks against the new LSA Code

requirements - Failure Mode and Effects Analysis (FMEA) - Unfavourable conditions of trim and list This report contains the following draft: - Draft guidelines for lifeboat control arrangement - Draft amendments to the revised recommendation on testing of life-saving

appliances (Resolution MSC.81 (70)) DE 53/3/1 (China) - Proposal for amendment to MSC.1/Circ.1206/Rev.1 This submission makes a proposal for amendment to annex 1 of MSC.1/Circ.1206/Rev.1 with a view to paving the way for mandatory implementation of the circular by encouraging shipowners to give preference to the maintenance network provided by manufacturers of life-saving appliances. DE 53/3/2 (ILAMA) - Counterfeit LSA products − A growing problem and a threat to the safety of lives at sea The document provides the information on the necessity for IMO to raise awareness on the growing problem of counterfeit LSA products. DE 53/3/3 (ILAMA) - FMEA (Failure Mode and Effect Analysis) on on-load release hooks The document provides the information on the necessity for an FMEA (Failure Mode and Effect Analysis) procedure to be included in the present requirements for lifeboat on-load release hooks.



DE 53/3/4 (ICS) - Information regarding experience gained in the use of Fall Preventer Devices (FPD) ICS provides information regarding experience gained to date with the use of fall preventer devices (FPD). DE 53/3/5 and DE 53/3/5/Rev.1 (China) - Proposals on introduction of redundancy of protection measures to improve the safety level of lifeboat on-load release mechanisms This document provides comments to the report of the LSA Correspondence Group submitted in document DE 53/3, and proposes the introduction of redundancy of protection measures to improve the safety level of lifeboat on-load release mechanisms. DE 53/INF.5 (ILAMA) - FMEA (Failure Mode and Effect Analysis) on on-load release hooks The document provides information on the principles and procedures of an FMEA (Failure Mode and Effect Analysis) for lifeboat on-load release hooks.

4. Compatibility of life-saving appliances (Agenda Item 4) (Target completion date – 2010)

Background: The Sub-Committee will consider, based on the report of the LSA Correspondence Group (DE 53/4), guidance on the application of the new liferaft weight criteria agreed at DE 52 to passenger ship liferaft launching appliances. The LSA Working Group, if established under agenda item 3, may be instructed to consider the guidance with a view to finalizing it at this session. Other issues for discussions are: - Clarification on radar transponder (DE 53/4/1) - Exterior colour of lifeboat (DE 53/4/3) (see also documents submitted under agenda

item 17) - the time for wearing lifejacket and immersion suite – review of MSC.1/Circ. 1278 (DE

53/4/4) - carrying capacity of liferaft (DE 53/4/2, DE 53/4/5) - Practical matter regarding change of the weight of personnel in the design of

liferaft. (DE 53/4/6) LR position: To monitor the development. LR appreciates all the efforts made by IMO to bring harmonization/clarity of the existing requirements, however, the some of the solution proposed may require revision/amendments of the regulation concerned (e.g., DE 53/4/3) Implications: This will affect design and type approval of the life-saving appliances

Manufacturers may need to develop new design for the future life-saving appliances Owner & builder may need to acquire system meeting new standards Flag Administrations and their ROs (Classification Societies) need to be ready for the implementation.

Application: To life saving appliances required by SOLAS Chapter III & LSA Code (used onboard all passenger ships engaged on international voyages and cargo ships of 500 gt or more engaged on international voyages). (Document submitted) DE 53/4 (USA) - Report of the Correspondence Group on Life-saving Appliances (LSA) This document reports the outcome of the LSA correspondence group with regard to compatibility of life-saving appliances. The report attaches draft MSC Circular on



determination of the required safe working load of liferaft launching appliances on passenger ships. DE 53/4/1 (IACS) - Clarification to the requirements of the LSA Code regarding radar transponders This document provides comments on the requirements of the International Life-Saving Appliances (LSA) Code in respect of survival craft radar transponders. DE 53/4/2 (IACS) - Approved carrying capacity of liferafts This document provides comments on the approved carrying capacity of liferafts. Currently there is a capacity limit for lifeboats, but not for liferaft. DE 53/4/3 - LSA Code – lifeboat exterior colour (Islamic Republic of Iran) This document provides a proposal of the Islamic Republic of Iran on lifeboat exterior colour regarding the implementation of paragraph 1.2.2.6 of the LSA Code concerning the exterior colour of lifeboats.

DE 53/4/4 (China) - Proposals on the donning and carriage requirements of lifejackets and immersion suits by crew during actual cargo ship abandonment or abandon ship drills This document provides proposals on the donning and carriage requirements of lifejackets and immersion suits by crew during actual cargo ship abandonment or abandon ship drills. DE 53/4/5 (ILAMA) - Approved carrying capacity of liferafts and lifeboats The document provides comments on document DE 53/4/2 and proposals for changing the maximum allowed carrying capacities for lifeboats as presently reflected in the requirements DE 53/4/6 (ILAMA) - Request for clarity regarding related practical matters This document requests clarification on certain practical matters in respect of the adoption of 82.5 kg as the standardized mass of occupants accommodated within inflatable liferafts.

5. Revision of resolution A.760 (18) (Agenda Item 5) (Target completion date – 2010)

Background: The Sub-Committee will continue its consideration of the revision of symbols related to life-saving appliances and arrangements (resolution A.760(18)), taking into account the outcome of ISO’s work on the new standard on shipboard signs (ISO 24409) which would form the basis for the revision. The LSA Working Group, if established under agenda item 3, may be instructed to deal with the matter, with a view to finalizing the work at this session. LR position: To monitor the development. Implications: Once the A. 760 (18) - Symbols Related to Life-Saving Appliances and Arrangements have been revised, it will affect signs posted onboard. Application: To all SOLAS Ships as a non-mandatory standard (but in general, a ship is expected to indicate these signs)



No document has been submitted under this agenda item

6. Performance standards for recovery systems (Agenda Item 6) (Target completion date – 2010)

Background: The Sub-Committee will finalize draft amendments to SOLAS and the LSA Code concerning recovery systems, based on the report of the LSA Correspondence Group (DE 53/6). The LSA Working Group, if established under agenda item 3, may be instructed to prepare the final text of the draft amendments. LR position: To monitor the development with a view to implementing it once the matter is finalized by IMO. Implications:

Manufacturers will need to develop such a system meeting the requirement Builders will need to install and to adjust onboard arrangements for the new standard Shipowners & Managers will need to install new equipment and to train seafarers as appropriate Flag Administrations and their ROs (Classification Societies) will need to provide necessary instructions to surveyors for type approval and survey of the system.

Application: To life saving appliances (recovery system) required by SOLAS Chapter III (Passenger ship regardless of tonnage engaged on international voyages and cargo ships of 500 gt or above engaged on international voyages) (Document submitted) DE 53/6 (United States) - Report of the correspondence group on Life-saving Appliances (LSA) This document reports the outcome thus far of the correspondence group with regard to performance standards for recovery systems, and invites further comments and proposals. DE 53/6/1 (Iceland) - Performance standard for manually operated recovery system This document provides information on experiences with manually operated “recovery equipment” presently a mandatory requirement on board all Icelandic fishing vessels of 15 m in overall length and over. This equipment has proven to provide for successful recovery of persons from the water under the harsh environmental conditions to be expected in the North Atlantic Ocean.

7. Cargo oil tank coating and corrosion protection (Agenda Item 7) (Target completion date – 2010)

Background: The Sub-Committee will finalize performance standards for cargo oil tank coatings for crude oil tankers, based on the report of the Correspondence Group (DE 53/7) and establish a working/drafting group to finalize the draft amendments and performance standards at this session. The standard as it is now does not provide any guidance for areas of the tank outside those specified. These are usually left in a shop primed condition with welds left untreated.



LR position: To closely monitor the development and to contribute via IACS from technical view point with a view to implement it once the discussion is concluded. Implications:

Paint manufacturers will need to submit paint testing result, and may need to develop a new product to meet the requirement. Shipbuilders For shipyards which have already built to the WBT PSPC the increased levels of inspection and record keeping will be the only real effect of the COT PSPC. This will be reflected in an increase in the coating costs. In any case, there will be a need to review fabrication process and make some modification of the design for cargo tank areas in order to allow coatings in a most efficient manner. Shipowners and Managers the introduction of the COT PSPC will give them additional confidence in the coating system and it's application, but will inevitably result in an increase in coating costs. They will be required to look at maintenance aspect of the coating throughout ship’s life. Flag Administration and its ROs will need to develop guidelines and instructions for surveyors. The introduction of the COT PSPC will increase the amount of information in the vessel Coating Technical File and require a slight in crease in surveyor attendance. In the main the major change to all parties was caused by the implementation of the Ballast water tank PSPC, and the proportionate increase for the Cargo oil tank PSPC will be much less, nevertheless, substantial increase on the work will be envisaged.

Application: To new crude oil tankers of 5,000 DWT (date for the new building – to be finalized at MSC 87) (Document submitted) DE 53/7 (Japan) - Report of the correspondence group This document provides the report of the Correspondence Group on Cargo Oil Tank Coating and Corrosion Protection. The Sub-Committee is invited to:

1. note the progress made by the Correspondence Group; 2. agree in general to the developed draft performance standards for cargo oil

tanks of crude oil tankers (annexes 1 and 2); 3. establish a working group and forward the remaining matters for the

finalization of the draft performance standards for cargo oil tanks of crude oil tankers, taking into account only the outstanding issues identified (paragraphs 8, 12, 13, 14 and 17); and

4. if time permits, develop the draft guidelines on procedures for in-service maintenance and repair of coating systems for cargo oil tanks of crude oil tankers, taking into account the preliminary views of the group (paragraph 19).

DE 53/7/1 (NACE International) - Comments on the report of the correspondence group This document supports the report of the correspondence group and proposes an alternative to the methodology specified in ISO 8502-9 for testing the salt limit on the substrate with a NACE International developed standard SP0508-2008 that allows an equivalency. The use of the NACE International standard allows alternative and new technologies that are more flexible and of greater accuracy. The text for a modified footnote is proposed.



DE 53/7/2 (China) - Comments on Test procedures for coating qualification for cargo oil tanks of crude oil tankers This document provides comments on the test procedures for coating qualification for cargo oil tanks of crude oil tankers contained in the report of the Correspondence Group on Cargo Oil Tank Coating and Corrosion Protection. DE 53/7/3 (China) - Proposal on establishment and maintenance of a list of training and examination schemes of Marine Coating Inspectors This document proposes to establish and maintain a list of training and examination schemes of Marine Coating Inspectors approved by Administrations. (Note by LR – this documents refers to PSPC for Ballast Water Tanks, not coating standards for cargo oil tanks) DE 53/7/4 (IACS) - Comments on the report of the Correspondence Group This document provides comments on the report of the Correspondence Group (DE 53/7) with regard to the draft test procedures for coating qualification for cargo oil tanks of crude oil tankers, and tables 1.1 (Selection of the coating system) and 1.3 (Secondary surface preparation) of the draft performance standard provided in annex 1. DE 53/7/5 (China) - Comments on the draft performance standard for alternative means of corrosion protection for cargo oil tanks of crude oil tankers This document provides comments on the report of the Correspondence Group on Cargo Oil Tank Coating and Corrosion Protection (appendix to annex 2). DE 53/INF.4 (China) - Report of China on the performance test comparison and evaluation on the protective coatings for cargo oil tanks of crude oil tankers This document gives a report on the testing work conducted by China for comparison and evaluation on the protective coatings for cargo oil tanks of crude oil tankers. DE 53/INF.6 (NACE International) - Standard for alternatives to testing the salt limit on the substrate NACE International submits a standard that allows alternative and new technologies that are more flexible and of greater accuracy to be used for testing the salt limit on the substrate.

8. Development of a new framework of requirements for life-saving appliances (Agenda Item 8) (Target completion date – 2012)

Background: The Sub-Committee will continue work on the review of the requirements for life-saving appliances in SOLAS chapter III and the LSA Code through a systematic approach, developing a comprehensive framework for requirements for LSA and a procedure for the review and subsequent relocation of present requirements in SOLAS. LR position: To monitor the development. Implications: At this stage, the outcome of the discussion is not visible yet. However, there may be impact on the design of life saving appliances and launching appliances. Application: To be developed. No document has been submitted under this agenda item



9. Guidance to ensure consistent policy for determining the need for watertight doors to remain open during navigation (Agenda Item 9) (Target completion date – 2010)

Background: The Sub-Committee will continue its work on the development of guidance for Administrations to ensure a consistent policy for determining the need for watertight doors to remain open during navigation, based on the report of the Correspondence Group (DE 53/9) and taking into account the SLF Sub-Committee’s work on guidance on the impact of open watertight doors on existing and new ship survivability (DE 53/9/1). LR position: To closely monitor development in IMO. Implications: The guidelines will affect the consideration of leaving watertight doors open and may affect passenger ship design if the current approach is deemed to be unsatisfactory. Application: Currently watertight doors are only permitted to be left open on passenger ships. These guidelines will only be applicable to passenger ships. (Document submitted) DE 53/9 and DE 53/9/Corr.1 (Sweden) - Report of the correspondence group This document contains the report of the Correspondence Group on Guidance to ensure consistent policy for determining the need for watertight doors to remain open during navigation. DE 53/9/1 (Sweden) - Comments on the report of the correspondence group This document comments on the report of the correspondence group, document DE 53/9, and proposes one common MSC circular for both the guidance on open watertight doors developed by the SLF and DE Sub-Committees respectively.

10. Protection against noise on board ships (Agenda Item 10) (Target completion date – 2010)

Background: The Sub-Committee will commence work on the agenda item, taking into account the proposals made in document MSC 83/25/13. Currently, the discussion is limited to noise only, not vibration. LR position: To closely monitory the development. Implications: At present, the implication is not certain, but there may be impact on ship design and equipment. Possible application to existing ship, if any, would require careful consideration on the actual implementation. Application: To be developed but limited to SOLAS ship only at this stage, i.e., MODU, High Speed Craft etc are not included. (Document submitted) DE 53/10 (Austria, Belgium, Bulgaria, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania,



Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, the United Kingdom and the European Commission) - This document offers proposals for the development of amendments of SOLAS regulation II-1/36 and for a revision of the Code on noise levels on board ships. The following is the draft SOLAS text proposed:

Regulation 36: Protection against noise “Measures shall be taken to reduce the noise on board as far as possible and in any event it should shall not exceed the mandatory maximum noise limits and the maximum noise exposure limits stipulated in IMO resolution A.468(XII), chapter 4.2 and chapter 5. The actual noise levels shall be assessed on the basis of measurement conditions stipulated in chapters 2 and 3 or equivalent internationally recognised standards.”

The proposal also contains draft amendments to A.468 (XII).

11. Thermal performance of immersion suits (Agenda Item 11) (Target completion date – 2010)

Background: The Sub-Committee will commence consideration of amendments to the LSA Code and the revised recommendation on testing of life-saving appliances relevant to the evaluation of the thermal performance of immersion suits. LR position: To monitor the development. Implications: Specification and type approval standards of immersion suits. Application: Immersion suits required by SOLAS Chapter III. (Document submitted) DE 53/11 (Japan) - Introduction of “Reference test device (RTD) concept” for thermal performance requirements This document proposes to introduce the “Reference test device (RTD) concept” for thermal performance requirements of immersion Suits. DE 53/INF.3 (Japan) - Results of thermal protective tests of immersion suits This document provides results of thermal protective tests of immersion suits. The results clearly indicate the effectiveness of introducing new test procedures based on “reference test device (RTD) concept”.

12. Alternative arrangements for the bottom inspection requirements for passenger ships other than ro-ro passenger ships (Agenda Item 12) (Target completion date – 2010)

Background: The Sub-Committee will continue its work on the item, taking into account the outcome of the related work of the FSI Sub-Committee on amendments to the Survey Guidelines under the HSSC (resolution A.997(25)) (DE 53/12), and establish a working/drafting group to progress the matter. LR position: To closely monitor the discussion with a view to provide clearer instructions to surveyors.



Implications: Survey scheme as well as ship arrangements for ships choosing in water bottom survey in lieu of dry docking may need to meet the technical requirements under development. Application: Passenger ships that to which in water survey will be applied, in lieu of dry docking. (Document submitted) DE 53/12 (Secretariat) - Outcome of FSI 17, MSC 86 and MEPC 59 The document reports on the outcome of FSI 17, MSC 86 and MEPC 59 in the matter. DE 53/12/1 (Bahamas, Malta, the Marshall Islands, CLIA and ICS) - Guidance for Administrations when considering bottom inspection during in-water survey in lieu of dry dock, for passenger ships other than ro-ro passenger ships, of less than 15 years of age This document provides draft guidance for Administrations when considering bottom inspection during in-water survey in lieu of dry dock for passenger ships other than ro-ro passenger ships of less than 15 years of age, under the work programme item H.14. DE 53/12/2 (United States) - Guidance for Administrations when considering bottom inspection during in-water survey in lieu of dry-dock for passenger ships other than ro-ro passenger ships of less than 15 years of age The United States offers comments on document DE 53/12/1 submitted by the Bahamas, Malta, the Marshall Islands, CLIA and ICS regarding in-water survey (IWS) of passenger ships. This procedural paper is intended to supplement the guidance in resolution A.997(25) regarding the periodic use of IWS as an alternative to dry-docking for fulfilment of the mandatory SOLAS requirement for annual survey of the outside of a passenger ships bottom.

13. Amendments to the Revised recommendation on testing of life-saving appliances (Agenda Item 13) (Target completion date – 2010)

Background: The Sub-Committee will commence the consideration of amendments to the Revised recommendation on testing of life-saving appliances, as amended by resolutions MSC.200(80) and MSC.226(82), in order to rectify inconsistencies. LR position: To closely monitor the discussion. Implications: Manufacturers will be required to meet the new test procedures, however, such new procedure will be simple reflection of the amendments made to SOLAS and LSA Code. The majority of changes proposed are editorial and will not have significant impact on current practice. Application: To life Saving Appliances required by SOLAS and LSA Code. (Document submitted) DE 53/13 (Japan) - Discussion points and preliminary draft amendments to the revised recommendation on testing of life-saving appliances This document provides discussion points and preliminary draft amendments to the Revised recommendation on testing of life-saving appliances for further consideration by the Sub-Committee.



14. Safety provisions applicable to tenders operating from passenger

ships (Agenda Item 14) (Target completion date – 2011)

Background: The Sub-Committee will commence work on the development of provisions for the design, equipment and operation of tenders carrying passengers and crew from passenger ships to shore and establish a working/drafting group to progress the matter. For number of years it has become a common practice for passenger ships to use their tenders to transfer passengers and crew from the ship to shore where there are no berthing facilities for the ship; however there are no internationally agreed and available standards that address operational procedures, performance standards, safety provisions and manning requirements ( including training ) for those boats when used as tenders. There is a need to consider development and implementation of an international standard LR position: To monitor the discussion. Implications: Potentially it would require new type approval and survey and certification for tender as a part of SOLAS requirements. Therefore, it would affect manufacturers, builders, owners & managers as well as flag Administration. The degree of impact is yet to be decided. Application: Generally speaking, it applies to tenders onboard passenger ships, but it would require clearer definition of a “tender”. (Document submitted) DE 53/14 (CLIA) - Passenger Vessel Tender Guidelines This document provides at annex a preliminary draft of Passenger Vessel Tender Guidelines for the further consideration of the Sub-Committee. DE 53/14/1 (United Kingdom) - Proposed draft Passenger Vessel Tender Guidelines The annex provides proposed Passenger Vessel Tender Guidelines for the further consideration of the Sub-Committee.

15. Classification of offshore industry vessels and consideration of the need for a code for offshore construction support vessels (Agenda Item 15) (Target completion date – 2010)

Background: The Sub-Committee will investigate the need for clarification of the classification of vessels in the offshore industry with regard to guidance provided in relevant IMO codes and guidelines, with a view to, inter alia, exploring the possibility of developing a safety code for offshore construction support vessels. Preliminary investigations have been done to identify problems with using the SPS Code and to identify differences in the stability (intact and damage), LSA, and Personnel requirements in the various applicable codes (2008 SPS, OSV, SOLAS, 2008 IS Code, MODU Code). LR position: To monitor developments.



Implications: This will affect the regulations which offshore construction vessels are required to meet. The details of such impact is yet to be developed. Application: So far work has concentrated on “offshore construction support vessels” which are defined as “those designed for operations that include finding and developing offshore oilfields and their installation, construction, maintenance and decommissioning.” It is expected that the definition will cover those ships which will assist in the construction of offshore wind farms. (Document submitted) DE 53/15 (IMCA) - Issues related to the classification of offshore construction support vessels IMCA provides the outcomes of an IMCA work group which has been considering the various issues related to the classification of offshore construction support vessels, with particular reference to the 2008 SPS Code. These outcomes include the identification of apparent practical obstacles to trying to design and build to the 2008 SPS Code, a possible inconsistency in the application of SOLAS regulations II-2/21-23 to special purpose ships, and other areas of potential confusion. The work group also considered the challenges of selecting appropriate sets of rules for such a diverse fleet, and the different approaches taken by administrations. IMCA therefore provides the outcome of an initial study of the various relevant IMO instruments (provided at annex) and suggests that the outline methodology on the use of alternative design and arrangements might prove an appropriate starting point for clarifying the classification of offshore construction support vessels.

16. Interpretation on application of SOLAS, MARPOL and Load Line requirements for major conversions of oil tankers (Agenda Item 16) (Target completion date – 2010)

Background: The Sub-Committee will commence work on the development of an interpretation of the extent of the application of the SOLAS, MARPOL and Load Line Conventions to major conversions of oil tankers and establish a working/drafting group to progress the matter. With regard to the proposal on the clarification of the coating requirements (DE 53/16/2), the Unified Interpretation currently in existence does not clearly identify which standard should be adopted for the ballast tanks when MSC.216(82) is not applicable. LR position: To closely monitor the discussion. Implications: The uniform interpretations, if that is agreed by IMO, will assist uniform application of the requirements at conversions of ships. Currently, such decisions are left to the flag Administrations. Application: Ships undergoing conversions. (Document submitted) DE 53/16 (IACS) - Relevant IACS Unified Interpretations of the SOLAS Convention Further to document DE 52/17/1, this document advises the Sub-Committee about IACS Unified Interpretations for the application of SOLAS regulations to major conversions of single-hull tankers to double-hull tankers or bulk carrier/ore carriers.



DE 53/16/1 (IACS) - The application of ICLL regulations to conversions of single-hull tanker to double-hull tanker or bulk carrier/ore carrier This document advises the Sub-Committee about the IACS draft UI for the application of ICLL regulations to conversions of single-hull tanker to double-hull tanker or bulk carrier/ore carrier and looks for clarification on this matter from the Sub-Committee. DE 53/16/2 (Republic of Korea) - Comments on the relevant IACS Unified Interpretations of the SOLAS Convention annexed to document DE 53/16 The Republic of Korea proposed in DE 53/16/2 that additional wording are to be inserted into UI SC 226 referenced in DE 53/16. This proposal is made in order to positively provide interpretation on requiring protective coatings of dedicated seawater ballast tanks and DSS spaces of bulk carriers after being converted, rather than simply say MSC.216(82) and MSC.215(82) being not applicable. The proposed amended interpretation is that at least the coating standards as per SOLAS II-1/3-2 adopted by MSC.47(66) and meeting standards given in A.798(19) are to be achieved for these tanks and spaces.

17. Consideration of IACS unified interpretations (Agenda Item 17) (Target completion date – continuous)

Background: The Sub-Committee will consider IACS unified interpretations submitted to the session with a view to developing relevant IMO interpretations, as appropriate. A substantial discussion is expected regarding the exterior colour of lifeboat (DE 53/17, DE 53/17/3)), which may be considered under agenda item 4, as there is another submission paper on this item (DE 53/4/3). LR position: To closely monitor the discussion with a view to implementing these interpretations. LR implements these interpretations unless flag Administration instruct otherwise. Implications: To be provided under each interpretation submitted. Application: To be provided under each interpretation submitted. (Document submitted) DE 53/17 (IACS) - LSA Code − lifeboat exterior colour (IACS UI SC 233) This document provides at annex a copy of IACS Unified Interpretation SC 233 regarding the implementation of paragraph 1.2.2.6 of the LSA Code concerning the exterior colour of lifeboats. Implications: The use of white or grey will not be permitted or accepted as suitable colours for the canopies or hull of enclosed or partially enclosed lifer boats. Only colours that are colours of strong chromatic content such as orange or yellows will be acceptable. This may affect design (outlook) of lifeboat used onboard passenger ships. Applications: Lifeboats required by SOLAS Chapter III. DE 53/17/1 (IACS) - IACS Unified Interpretation on steam boilers and boiler feed systems (SOLAS regulation II-1/32.4) This document advises the Sub-Committee about IACS Unified Interpretation SC 232 on the application of SOLAS regulation II-1/32.4 regarding steam boilers and boiler feed systems.



DE 53/17/2 (IACS) - Application of the Performance Standard for Protective Coatings (PSPC) for dedicated seawater ballast tanks in all types of ships and double-side skin spaces of bulk carriers – resolution MSC.215(82) – “Assistant inspector” This document proposes a revision of IACS Unified Interpretation (UI) SC 223, which takes into account the comments made regarding this UI during DE 52. DE 53/17/3 (ILAMA) - LSA Code − Lifeboat Exterior Colour (IACS UI SC 233) The document provides comments to document DE 53/17 − lifeboat exterior colour and proposals for clarification. DE 53/17/4 (IACS) - Load testing of hooks for primary release of free-fall lifeboats This document provides at annex a draft IACS Unified Interpretation on the load testing of hooks for primary release of free-fall lifeboats for the consideration of the Sub-Committee.

18. Development of a mandatory Code for ships operating in polar waters (Agenda Item 18) (Target completion date – 2012)

Background: The Sub-Committee will commence work on the development of a mandatory Code for ships operating in polar waters. LR position: To monitor the development Implications: Although current voluntary code (MSC/Circ.1056-MEPC/Circ.399. further updated by A.1025 (26) has been widely implemented, this mandatory code will have further implication to concerned parties.

Owners and builders will need to meet the new mandatory requirements, the degree of the change is yet to be decided. Flag Administration: will need to consider new approval, survey and certification scheme.

Application: To be decided in the course of the discussion. (Document submitted) DE 53/18 (Secretariat) - Outcome of the 32nd Antarctic Treaty Consultative Meeting (ATCM XXXII) The document informs about the outcome of the 32nd Antarctic Treaty Consultative Meeting (ATCM XXXII) with regard to the agenda item. DE 53/18/1 (Germany) - Proposal for the concept of development This document proposes to develop the Code for ships operating in polar waters on the basis of a goal-based standard concept. DE 53/18/2 (Canada) - Proposed framework for the Code for ships operating in polar waters This document is a proposal for structure and contents of a draft mandatory Code for ships operating in polar waters. DE 53/18/3 (FOEI, IUCN, Greenpeace, IFAW and WWF) - Shipping management issues to be addressed



In this document, FOEI, IUCN, Greenpeace, IFAW and WWF1 identify a range of shipping management issues which they submit should be considered and addressed through the development of a mandatory code for ships operating in polar waters. DE 53/18/4 (New Zealand) - Antarctic Treaty Meeting of Experts on the management of ship-borne tourism in the Antarctic Treaty area This document provides information with regard to the agenda item about the Antarctic Treaty Meeting of Experts on the management of ship-borne tourism in the Antarctic Treaty area which was held in Wellington from 9 to 11 December 2009. DE 53/18/5 (Denmark) - HAZID analysis of ships navigating in Arctic waters This document provides information on a HAZID analysis of ships navigating in Arctic waters performed by the Danish Maritime Authority (DMA) under the guidance of DNV. The goal of the analysis was to identify potential hazards encountered by ships navigating in polar waters – and to provide the Sub-Committee with the findings in order to focus and facilitate its development of mandatory regulations for ships navigating in polar waters. DE 53/18/6 (United Kingdom) - Draft framework to be used in the development of a mandatory Code for vessels operating in polar waters This document proposes a draft framework to be used in the development of a mandatory Code for vessels operating in polar waters. DE 53/18/7 (New Zealand) - Proposed framework for the Code for ships operating in polar waters This document comments on the approach to the development of the Code proposed by the United Kingdom and the framework of the draft Code submitted by Canada. It stresses the importance of the code ensuring the ability to quickly identify vessels potentially able to assist in search and rescue in the region. DE 53/18/8 (Finland) - Comments on the principles in developing the Polar Code This document contains comments and observations to be taken into account when developing the Polar Code. DE 53/18/9 (Canada, Denmark, Germany, Norway, Sweden, the United States, BIMCO, the Community of European Shipyards’ Associations (CESA), and the Royal Institution of Naval Architects (RINA) - Principles for proposed mandatory Code for ships operating in polar waters This document proposes principles to be followed in developing a proposed mandatory Code for ships operating in polar waters, the Polar Code.

19. Application of amendments to SOLAS chapter III and the LSA Code (Agenda Item 19) (Target completion date – 2010)

Background: The Sub-Committee will consider the scope of application of amendments to SOLAS chapter III and the LSA Code, taking into account comments and proposals made in any documents submitted. LR position: To monitor the discussion. LR welcomes discussion as it clarifies the application of the statutory requirements.



Implications: To be decided. However, there is a possibility that DE come up with clarifications/interpretations that will result wider scope of the application (e.g., application to existing ships), which was not envisaged at the time of the adoption of the resolutions in question. Application: To ships to which SOLAS chapter III and LSA code applies. (Passenger ships regardless of tonnage and non-passenger ships of 500 gt or over both engaged in international voyages) (Document submitted) DE 53/19 (Secretariat) - Scope of application of amendments to SOLAS chapter III and the LSA Code The document provides background information on the agenda item. DE 53/19/1 (IACS) - Proposed clarification to the LSA and FSS Codes This document proposes a more permanent solution to ensure that the scope of application of future amendments to SOLAS chapter III and the LSA Code are clear. Also, a consequential revision to the FSS Code is proposed. DE 53/19/2 (IACS) - Proposed clarification of SOLAS chapter III As a follow-up to the discussion at MSC 86, this document proposes a clarification on the scope of application of amendments to SOLAS chapter III and the LSA Code. DE 53/19/3 (United States) - Scope of application of amendments to IMO instruments relating to life-saving appliances This document comments on DE 53/19 (Secretariat), and proposes a way forward with regard to clarification of the scope of application of amendments to the LSA Code. United States suggest installation dates, rather than the keel laying date.

20. Guidelines for a visible element to general alarm systems on passenger ships (Agenda Item 20) (Target completion date – 2012)

Background: The Sub-Committee will commence work on the development of non-mandatory guidelines regarding a visible element to the general emergency alarm on passenger ships to accommodate passengers who have hearing difficulties. LR position: To monitor the discussion Implications: As a non-mandatory guideline, the implication is not predictable at this stage. However, it could be industry/international standard. If that is the case, this will significantly affect design/installation of passenger ships. Application: To passenger ships on voluntary basis. (Document submitted) DE 53/20 (United States) - Proposed draft Guidelines This document provides proposed draft Guidelines for the design and installation of a visible element to the general emergency alarm on passenger ships to accommodate passengers who are deaf or hard of hearing. DE 53/20/1 (CLIA) - Guidelines for visible element to general alarm systems on passenger ships



This agenda item was added at MSC 86th session to provide guidelines for the installation of a visible element to the general alarm on passenger ships. At annex to this document are draft guidelines for this purpose.

21. Improvement of existing pollution prevention equipment (Agenda Item 21) (Target completion date – 2011)

.1 Development of test standards for type approval of add-on equipment

.2 Promotion of integrated bilge water treatment systems

Background: The Sub-Committee will continue, as instructed by MEPC 59, considering simplified test procedures for add-on equipment capable of breaking up emulsions that could supplement existing resolution MEPC.60(33)-compliant equipment; and the promotion of Integrated Bilge Water Treatment System (IBTS) as a holistic approach to address the perceived illegal oil discharges related to engine-room management, taking into account the relevant discussions at DE 52. LR position: To monitor the discussion. Implications:

Equipment manufacturers may be required to producing a new add-on equipment meeting IMO guidelines, once such guideline is developed. Shipowner will need to consider the use of such add-on equipment and IBTS, which may affect training/management of the crew onboard. Flag Administration and its RO will need to consider survey and type approval instruction once the discussion is concluded.

Application: To be considered (Document submitted) DE 53/21 (United States) - Development of tests standards for type approval of add-on equipment MEPC 59 has tasked the DE Sub-Committee to develop test standards for type approval of add-on equipment for improving existing pollution prevention equipment. This document proposes that the testing of certain equipment attributes be included in the development of any such test standards. DE 53/21/1 (Japan) - Proposal for tests standards for type approval of add-on equipment combined with resolution MEPC.60(33) − compliant equipment This document proposes a simplified test standard for type approval of add-on equipment capable of separating emulsions and suggests points to be considered for proper use of add-on equipment as well as for the promotion of IBTS.

22. Development of guidelines for a shipboard oil waster pollution prevention plan (Agenda Item 22) (Target completion date – 2011)

Background: The following was discussed at MEPC 59:



As instructed by MEPC 59 the Sub-Committee will consider the development of guidelines for a shipboard oil waste pollution prevention plan. LR position: To closely monitor the discussion with a view to approving revisions to the ODMC manual once decision is made by IMO. Implications: - Shipowners will need to revise and obtain approval of the ODMC manual. - Flag Administrations and ROs will need to secure resources for timely

implementation of the requirements. Application: To ODMC Manual onboard (required to oil tankers of 150 gt and above). No document has been submitted under this agenda item

23. Manually operated alternatives in the event of pollution prevention equipment malfunctions (Agenda Item 23) (Target completion date – 2011)

Background: According to regulation 31 of Annex I there is a possibility of manual operation in case of equipment failure. The Committee considered the concern expressed by a member regarding manuals for this operation. MEPC 59 agreed to instruct DE Sub-Committee to consider this matter further, taking into account practical implementation related issues, such as: - an appropriate time frame for implementation, e.g., the first IOPP survey carried

out on or after 6 months after the adoption date of any resolution/circular; - how such a revision should affect many ODME Manuals, e.g., to delete that

provision if it is contained in the approved ODME Manual As instructed by MEPC 59, the Sub-Committee will consider the development of appropriate amendments to the Revised Guidelines and specifications for oil discharge monitoring and control systems for oil tankers (resolution MEPC.108(49)). Implications: It is not clear at this stage however, the following implications are envisaged:

Owners will need to revise the instructions as to the operation the Oil discharge monitoring and control system (ODME manual) as per required by MARPOL Annex I regulation 31 and have them approved by the flag Administration or by its RO. Flag Administration and its RO: will need to provide instructions to surveyors and secure resources for the approval job, as the conclusion may result in re-approval of all existing manuals onboard the ship.

Application: To ships which are required to have an approved ODEM manual onboard (Oil tankers of 150 gt and above) as per MARPOL Annex I regulation 31. (Document submitted) DE 53/23 (Denmark) - Inadequate manuals for equipment malfunction for oil discharge monitoring and control systems for oil tankers This document addresses the need to review manuals regarding discharge of oil or oily mixtures from cargo tanks on oil tankers in the event of equipment malfunctions, in



order to reduce the likelihood of uncontrolled discharges at sea, leading to cleaner oceans. DE 53/23/1 (OCIMF) - Comments on manually operated alternatives in the event of pollution prevention equipment malfunctions This document draws the Sub-Committee’s attention to the impact upon the port environment and safety of document DE 53/23. DE 53/23/2 (Iran) - Inadequate manuals for equipment malfunction for oil discharge monitoring and control system for oil tankers This document provides a proposal of the Islamic Republic of Iran on the review of manuals regarding discharge of oil or oily mixtures from cargo tanks on oil tankers in the event of equipment malfunctions, in order to reduce the likelihood of uncontrolled discharges at sea.

24. Any other business (Agenda Item 25)

Background: As instructed by MSC 86, the Sub-Committee will consider: 1. the development of a definition of “new installation of materials” (DE 53/25); 2. the investigation report on the fire on the fishing factory vessel Hercules (DE

53/25/1); and 3. amendments to the 2008 SPS Code (MSC 86/26, paragraph 25.10, and MSC

86/25/2). The Sub-Committee will also consider any other matters submitted by Member Governments or international organizations or referred to it by the committees or other sub-committees. Proposal made to the amendments to the 2008 SPS code includes substantial changes in its requirements. LR position: To monitor the discussion with special attention to item 1 above. Implications:

1. definition of “new installation of materials” This is an interpretation of the revised SOLAS regulation II-1/3-5 (MSC. 282 (86)) entering into force on 1 January 2011. Depending upon the interpretation might be agreed at DE53, builders and owners will not be allowed to use spare parts kept in their store any longer.

2. and 3. (the investigation report on the fire on the fishing factory vessel Hercules) and amendments to the 2008 SPS Code.

At this moment, implications are not clear. Further development in the DE Sub-Committee is awaited.

Application: To be developed depending on the decisions taken at the DE Sub-Committee. (Document submitted) DE 53/25 (Secretariat) - Definition of “new installation of materials” The document provides background information on the instruction by MSC 86 for the Sub-Committee to consider the need for the development of a definition for “new installation of materials”.



DE 53/25/1 (Secretariat) - Investigation report on the fire on the fishing factory vessel Hercules The document provides information on the very serious fire that occurred in April 2007 on the Faroese fishing factory vessel Hercules which FSI 17 requested the Sub-Committee to consider. DE 53/25/2 (Germany and Norway) - Incorrect wording in the 2008 SPS Code This document describes findings of incorrect text having practised the new Code towards the industry; and offers revised texts to correct the shortcomings. This document is submitted under the provision that the findings will be taken into account and corrected in a manner found practical. DE 53/INF.2 (Denmark) - Safety study on shipwrecked fishermen’s experience with finding the knives in liferafts This document contains extracts from reports of the Danish Division for Investigation of Maritime Accidents regarding seafarers’ experience when entering the liferafts in connection with abandon ship. In several cases, shipwrecked persons in liferafts have had problems releasing the painter line of the liferaft from the sinking ship, because they could not find the knife that is a part of the liferaft equipment. The information provided in the annex draws attention to the very critical situations that have emerged because shipwrecked persons in liferafts could not find the knife needed to cut the painter line.



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