Have Your Say: Standards for Arrangement, Accommodation and Personal Safety

Dear participants

An issues paper on "Arrangement, Accommodation and Personal Safety" has been released for public comment as a precursor to drafting the new National Standard for Commercial Vessels Part C Section 1 that will be applicable to Australian Domestic Commercial Vessels. The standard is also used in New Zealand, a number of Pacific Island Nations and has been recognised for individual vessels by some countries in Asia and the Middle East.

Topics within the scope of this section of the standard that are discussed in the issues paper include:

- Application of the International Labour Conference Conventions
- Issues pertaining to Guard Rails and Bulwarks
- Sanitary arrangements
- Escapes and evacuation routes
- Minimum deck heights
- Minimum deck area requirements
- Protection of persons
- Berthing of persons
- Seating for passengers
- Gangways for safe movement on and off the vessel
- Dangerous Machinery
- Ventilation, lighting and habitability
- Noise levels on board vessels
- Field of Vision from the Operating Compartment
- Access for disabled passengers

The issues paper looks at the 1970s standards contained in the USL Code (the current standard) and compares them with modern practices, both within Australia and internationally. The issues paper proposes a series of underlying performance statements that describe the purpose behind the old prescriptive standards to help clarify the intent and benefits of the various safety provisions.

Have Your Say!

I would be grateful to receive any comments on the issues paper from members of this forum. In particular, I would appreciate the benefit of your experience on the suggested required outcomes for the various topics covered.

You need not comment on the whole issues paper if you don't have time. Just have a look at the issues paper when you get a curly question regarding a particular matter on a boat you are working on and see whether it is relevant, provides any insights into interpreting requirements, and/or can be improved. Your feedback even on a single aspect considered in the context of a real problem in the field would be most useful.

You can download a copy of the NSCV C1 Issues Paper via the link on the webpage: http://www.nmsc.gov.au/yoursay_2.html. A standard form for public commment can also be downloaded from this webpage.

The public comment period closes on 15 May 2009.

Regards
Mori

 

Hi Again Mori

Interesting. However, i still refer many points i made previously to this new paper too. I had a quick scan through.

Take 9. Evacuation and escape routes, for example.
You state exemptions are sought for reduction in "standard size" hatches on yachts etc. If you feel that the size of factory fitted are too small, why grant an exemption? This is all cart before the horse! Only the approval officer is to blame for allowing the reduction. Can't blame the yacht builder or designer, they want what they can get in terms of weight/cost or keeping the client happy.
It is, as i said before, YOUR job to prevent the vessel from falling below minimum standards. If the minimum size of hatch has not been met, why grant an exemption then blame the designer/builder for accidents?

Then in 9.4.2 for example, you discuss evacuation/escape routes, quoting SOLAS. The assembly station is just the old fashion muster point. Also the issue about 'smaller groups' is very obvious! Large ships with many decks, it is far better to muster passengers to smaller locations easy to control, then Shepard them to the main embarkation locations in safety. Rather than having passengers roaming about the decks in panic and mixing up different groups for checking off..chaos!!

You then say "..The extent to which the provisions for escapes apply to evacuation paths is unclear..." No it is clear. The provisions are to protect from fire damage. Therefore any path/route must be fire protected so it does not affect or prevent the evacuation during a fire.

and then in 10.2 you say:

"The spacing between deck and deck head on a vessel must be sufficient to facilitate the rapid movement of persons along escape and evacuation routes in the event of an emergency." followed by:

"53. Do you agree with the above draft required outcomes for minimum height between decks?"

How can you make comments like this? One does not need to be Einstein to realise that if a deck to deck height of 1.0m is used evacuation will be impeded! Passenger vessels do not have decks at 1.0m deck to deck..why, because everyone would be bent over double. So a height is used that allows easy movement on said deck. If naval architects can use their brain to decide what is or is not an acceptable ergonomically deck height for moving around with a glass of wine in your hand, why can Flag not decide what is acceptable as a safe or minimum height?

As i said before, i applaud what you're trying to do..but almost all of the issues are covered elsewhere with rules, or are self answering yet no one appears to wish to take the responsibility for making the decision and sticking to it!

Good luck

 

Ad Hoc,

Something for me to agree with.....so much of this bull **** from NSCV is "copy and paste" from others old rules, very little in the Australian public service can actually think for themselves, they were brought up being spoon fed, live in fear of litigation, and the phrase"common sence" is far from common.

My slipway in Sydney, 20 years ago, I sold out...some dumb wit from EPA came and told me that I had to move the roof support posts or cut the slipway cradle as the slip came too close to the post....the fact that it was operated by a dead man switch in full visibility and run for 50 years without incident was irrelevant...the same fuckwit then went to Gladesville Bridge Marina, and caused them years of grief after I sent him packing......

My Island Trader in the Pacific, we ran it with a crew of 5, to come to Australia, i had to have 14....14 to do what, sit and smoke all day, that was Australian manning regulations, what crap.

I am sick to death of Australian compliance and the corruption associated with it. The USLC was supposed to be UNIFORM, yet every state had its own version of it....none could agree so the boats were expensively modified to meet local conditions as they travelled.

I did a restoration on one of the old Maritime Services Boards boats, wanted to put it into survey for half the passengers that it used to carry, they ran it for years , when sold it had to have all the lines drawing approved again ( unfortunately they did not exist) before they would "accept" it ....,to carry half of what they carried....bunch of *******.

 

Mori,

Sorry mate, this is not personal to you, it is the SYSTEM....i am sure that you are trying to do your best mate.

 

Dear Landlubber and Ad Hoc

I suppose that I did ask for comments, although I rather expected them to be a little more constructive (i.e. relevant to improving the standard).

While you can be cynical in your views regarding the value of public consultation, the reality is that this is much better than the alternative where government makes no attempt to confer with stakeholders and just dishes up what it thinks people should do. At least with a transparent process of public consultation, stakeholders on all sides have to face each other when expressing their opinions, which somewhat tempers the more extreme views. In a way, that is just what we are doing discussing issues over this forum.

Just so you are aware, the issues papers, draft standards and final standards are put together in consultation with a reference group that represents a wide range of stakeholders including designers, builders, governments and operators. We are fortunate in having the participation of some very competent and successful persons from industry that help us keep in mind the needs of the private sector. So I would hope that the contents of the issues paper should not be too far "off the mark".

Should you feel more disposed to participate in the public comment process in the future, you need not comment on the whole issues paper if you don't have time. Just have a look at the issues paper when you get a curly question regarding a particular matter on a boat you are working on and see whether it is relevant, provides any insights into interpreting requirements, and/or can be improved. Your feedback even on a single aspect considered in the context of a real problem in the field would be most useful.

Best regards
Mori