Load Lines for ships below 24m

Agreed. But this is commercial boat practice....these rules only become nonsense, like all parametric based rules, when at the extreme ends, such as a 10m boat! Unless you have a very friendly and understanding surveyor/plan approval...you're stumped!

 

Yes, usually we can convince them to be reasonable, but in this case it was done by the builder. This is why we are trying to propose an amendment to the Rules, and for this I am interested what is the source of RS LL section for boat <24m.

 

As JEH notes the requirement is not onerous. Here is MCA's small passenger code for inland water ways:



Not much different.

 

I sympathize with you Alik. Arguing with the "Administrator" of the Statutory rules is futile. In our case, we never did win a single case of argument with the administrator/authority when the rule states "to the satisfaction of the Administrator".

In our case, ventilators/air pipes heigth are 600 mm. in the freebord deck and 300 mm. in the superstructure deck and does not make a distinction whether it is <24 meter in length.

In cases where the length is specified as between 15 and less than 24 meters, the minimum freeboard is less than 200 mm (for a 23.9m length).

There are other rules we argued but as the authority gets their way by invoking "to the satisfaction of the Administrator".

 

AH- Would the MCA have any leverage on the way our local Administrator think? Just in case the situation arises again and we have to plead.

Our statutory regulation is almost a selective "cut and paste" of the ABS rules. You can take an ABS rulebook and most of it would be a word for word copy. Ironically, ABS does not care for ships less than 24 meters and that is where most of the bulk of the work is here.

 

The problem for small craft is that there no common international rules (ISO Small Craft not often counted by maritime authorities), and surveyors with 'big ship mentality' often treat small craft in their weird way.

Once we had to address IACS to get clarifications on their Recommendations #99 for cargo ships below 500RT. The issue was in structural fire protection of 12m composite workboat and we knew that this document is not applicable, but RS insisted we should apply class A0-A60, etc. partitions. The reply from IACS was clear: 'this document #99 does not apply for craft below 24m and is not intended for composite craft'. On this, the head office of RS replied that 'Fibreglass is not composite material'...

I think the professional community should work out a Commercial Small Craft Code and push the authorities to accept it. This can be based on ISO standards with some additions, say on watertight partitions, some requirements for small passenger craft, etc. There are some codes such as MCA SCV Code but this does not cover passenger craft and it is not 'international'. There is also IMO SCV Code for Caribbean... If someone is willing to participate - I am ready to talk.

 

About one year ago published a paper in Russian, on freeboard assessment for small craft. Now translating into English slowly... Here is one of the graphs - comparison of freeboard requirements from different sources. As one can see, there exists high discrepancy on the subject, even the trends are different. Here SCV Code refers to MCA SCV Code (MGN280); RRR refers to Russian River Register, GOST refers to Russian small craft standard, RS-LL is RS load lines Rules for L<24,; ICLL is international Convention on load lines, ISO12217 is understood...

 

You can try. Its really whether the local administrator feels intimated by another Flag State's rule where other flag state has more experience and in general setting higher standards too.

Most local flag rules now quote HSC, despite being on domestic routes, as a default. The HSC while not perfect for all, is far far better than local 'big ship' rules. The rest is down to experience by the Flag state. Those with little or no experience tend to err on the side of caution..and too much too. Been there done that sadly...

The main issue is what is the purpose of the boat...and in general..there are sufficient rules that exist to apply. Whether 'we' like them or not, is immaterial. And like all rules, those that are on the fringes tend to loose out.

On one of the several committees I am on, there was an attempt to investigate every single rule in the HSC/EU Directive to ascertain the origins of each and to establish whether said rule is applicable today and to certain range of vessels/speed/construction etc...in order to promote a "philosophy" based equivalence. It didn't last long...very very time consuming and many rules, next to impossible to find the exact source. But, most Flag states now do accept an "equivalence" if it can be demonstrated.

 

Well, HSC Code (and associated Rues) for craft below 24m are not really suitable. Structural section - yes, and we use it, thought for GL it will 'by default' result very low H1/3, but this can be corrected. Intact stability - yes. Damaged stability - damage cases are excessive, small craft will hardly comply. Structural fire protection - not practical, no composite craft will comply. Electrical - excessive, having two generator sets sounds like a joke; RS required this from us many times, also on the same 10m boat they asked for 2 generators...

So I would not say HSC Rules are the best, but yes at least something. Still a lot of problems built into those Rules.

 

I think that would be a problem here in our country. They tend to lean towards ABS rule and not on the "European rule" ISO that is.

So far, they have adopted the NKK standards for what they call "Small Ships" in their heading and it is mostly applicable to "fiberglass" vessels.

Even the local CS (there are about seven in our country) is geared towards big ship rules and there is always a never ending argument between the local builders and the local CS.

 

The arguments you're citing are all the same ones raised by many builders prior to the HSC 2000 code being introduced. We were even we tasked with looking at several issues you raised because it become such a hot topic. Post Introduction...almost none of their fears have been realised.

You must not throw the baby out with the bath water (English expression). The rules are for passenger safety... safety is paramount, period! It would be a very brave person to ignore such levels of safety for the sake of an easy build. Such idiosyncrasies of being at the extreme ends of such rules should be accounted for from the outset of the design phase. Doesn't mean we like them...we just have to live with them.

 

Absolute safety is not achievable, and You know it. Any safety issue written in big ship Rules should be taken through the filter of common sense, when it is applied to small craft. Say, why do we need 60 minutes of structural fire protection, if evacuation of 30-50 passengers takes only 3-5 minutes? 15 minutes would be more that sufficient, and this can be done just by engine room composite structure, without formal compliance to 'non combustible materials' and other clauses developed for steel ships.

So, I say it again, common sense has the priority over the formal rules. The rules are just reflection of good practice, not a dogma. And we need to change them (or at least ask for deviation) in case if they do not work properly.

 

Alik

It seems you are raising the very same arguments that were made back in pre 94 HSC code and pre HSC 200 code. Having been brought up with the DSC code and then the HSC Code's...this is nothing new.

I suggest you should read:

"High Speed Marine Transport" IMAS '91, Uni NWS, Australia, 1991, "High Speed Vessels for Transport and Defence" RINA Conf 1995 and "The Safety of High Speed Craft" RINA Conf 1997 et al. Pretty much all your issues are raised and addressed accordingly, not all satisfactory..but that is the state of play.

 

Alik- This might help you- "Further information
International Regulations for High-Speed craft an overview – St Petersburg, Russia, June 2005. Article by Mrs Heike Hoppe.
The paper presents an overview of the international regulations in force concerning high-speed craft, i.e. the Code of Safety for Dynamically Supported Craft (DSC Code) and the International Codes of Safety for High-Speed Craft 1994 and 2000. The historical background of the development of regulations for high-speed craft is briefly highlighted and the technical contents of the Codes are described. The status of the Codes, i.e. mandatory or recommendatory, is explained, together with their association with the International Convention for the Safety of Life at Sea (SOLAS) 1974. Finally, on-going work in IMO regarding the review of the Codes and the preparation of appropriate amendments is outlined." http://www.imo.org/OurWork/Safety/Regulations/Pages/HSC.aspx

And the mother of all rules, the book published by IMO regarding 2000 HSC code http://mdnautical.com/marine-safety/587-imo-ia185e-high-speed-craft-2000-hsc-code-2008-edition.html Cost less than 40 USD.

 

Thanks, I have the HSC Code.

The problem is that this Code is often applied by Classification societies to small craft, though it is not intended to apply in full, say fire protection section. The Code is applicable to passenger craft and cargo craft >500RT making international voyages only. Not for local craft, not for small passenger boats.