IMO New Regulations for Life Saving Appliances 2022

The IMO Sub-Committee on Ship Systems and Equipment (SSE) held its 8th session virtually from February 28 to March 4, 2022. This Brief provides an overview of the more significant issues that progressed at this session.
While new regulations developed by the SSE Sub-Committee are not finalized until approved by the Maritime Safety Committee (MSC), a review of the Sub-Committee’s activity can provide a forecast of future regulatory developments.

The Sub-Committee finalized amendments to the LSA Code and Recommendation on testing of life-saving appliances MSC.81(70) to provide performance requirements for the ventilation of totally enclosed lifeboats, partially enclosed lifeboats, and life rafts. Building on work which began at the 4th session of the Sub-Committee in 2017, the draft amendments approved by the Sub-Committee will require totally enclosed lifeboats to provide a means of ventilation operable from inside the lifeboat at a rate of not less than 5 m3/hour per person, for the number of persons which the lifeboat is permitted to accommodate and for a period of at least 24 hours. Where the means of ventilation is powered, the source of power shall not be the radio batteries, and if dependent upon the lifeboat engine, then sufficient fuel shall be provided. The openings for the ventilation are to be provided with a means of closing that is operable from inside the lifeboat and positioned so as to minimize the ingress of water.

For the ventilation of partially enclosed lifeboats and life rafts, these survival crafts will be required to admit sufficient air at all times that prevents the long-term CO2 concentration from exceeding 5,000 ppm for the number of persons the craft is intended to accommodate. The means of ventilation is to be operable from inside the craft, and if powered, sufficient energy shall be provided for at least 24 hours.
Corresponding amendments to the Recommendations on testing of life-saving appliances (MSC.81(70)) require that the capacity of the lifeboat’s fuel tank, needed to maneuver the lifeboat at a minimum speed of 6 knots for 4 hours, include the fuel consumed by the powered ventilation system.

• For totally enclosed lifeboats, a ventilation performance test is required with all entrances and hatches closed to confirm the ventilation rate noted above. Additionally, the lifeboat is to be incrementally rotated to an angle of heel of 180° and, upon release, the lifeboat is to return to the upright position without the assistance of its occupants.
• For partially enclosed lifeboats, the testing will require a demonstration that the ventilation system is capable to provide (1) a rate of not less than 5 m3/hour per person for 24 hours or (2) a CO2 concentration not exceeding an 8-hour timeweighted average concentration of 5000 ppm or a 15-minute time-weighted average of 15000 ppm.

Next Steps: The draft amendments will be presented to MSC 106 (Nov-2022) for further consideration and, if approved, they would be considered for adoption at MSC 107 (Jun-2023) which would have an anticipated entry into force on 1 January 2026.
Upon their acceptance, the draft new ventilation requirements in the LSA Code will be applied to life rafts, totally enclosed lifeboats, and partially enclosed lifeboats installed on or after 1 January 2029, so as to allow ample time for Administrations and manufacturers to implement the new ventilation requirements.

The Sub-Committee agreed to draft amendments to the Interim Guidelines on Life-Saving Appliances and Arrangements for Ships Operating in Polar Waters (MSC.1/Circ.1614), providing a methodology for estimating the maximum expected time of rescue in determining resources needed to support survival following abandoning ship under section 8.3 of part I-A of the Polar Code. This time duration will affect the type and amount of survival equipment and supplies to be provided.

Next Steps: The draft Interim Guidelines will be presented to MSC 106 (Nov-2022) for further consideration and approval, and subsequent release as MSC.1/Circ.1614/Rev.1.

Continuing work from the previous session and an intersessional correspondence group, the Sub-Committee progressed an action plan for the revision of SOLAS Chapter III and the LSA Code, using a safety level approach (SLA) in order to identify a broader spectrum of risks and hazards and remove gaps, inconsistencies, and ambiguities in SOLAS Ch III and the LSA Code.
Discussions have produced the following goals for a revised SOLAS Chapter III:

1. a safe, effective process and means to maintain human life during and after abandoning ship;
2. the detection and recovery of people after abandonment;
3. the ability to safely recover people from the water who are in need of assistance; and
4. the means to safely transfer sick or injured people from the vessel without further injury.

In support of these goals, the following areas of concern (i.e. major events) have been identified:

1. abandoning ship;
2. survival at sea;
3. detection and recovery;
4. person overboard; and
5. transferring an injured person.

A working group was established to further work on identifying hazards that are currently addressed, hazards that should be additionally addressed, and to consider a possible restructuring of SOLAS Chapter III based on functional requirements and expected performance.

Next Steps: Discussions on this subject will continue in an intersessional experts’ group and at SSE 9 (Mar2023).

The Sub-Committee had for its consideration a proposed amendment to LSA Code paragraph 4.6.3.1 which would clarify the coloring requirements of safety harnesses for free-fall lifeboats. The amendment serves to clarify that the safety harness fitted at each seating position onboard such craft is to be a contrasting color to the harness fitted on seats immediately adjacent. Additionally, the amendment clarifies that the above provision applies to lifeboats installed on new and existing ships on or after the date of entry into force of the amendments which is yet to be determined.

The Sub-Committee also had for consideration a proposed amendment to SOLAS Chapter III / Regulation 19 “Emergency Training and Drills”. This amendment would incorporate the donning of immersion suits (if applicable to the vessel) as part of abandon ship drills.

Next Steps: The Sub-Committee’s current output on SOLAS Chapter III and the LSA Code is primarily focused on the development of a goal-based framework of functional requirements and expected performance criteria through hazard identification related to life-saving appliances. Because these proposed amendments are secondary to this work, their consideration has been postponed to a future session.

The Sub-Committee received for consideration several items related to the LSA Code and the Revised Recommendation on Testing of Life-Saving Appliances (MSC.81(70)) for the in-water performance of life jackets. After considering the results of investigations on the capability of a SOLAS lifejacket to retain a person’s airways clear of the water and the level of safety carried out by a group of experts chaired by the UK Maritime and Coastguard Agency, the SubCommittee assigned a working group to consider a draft MSC circular on “Guidance on the In-Water Performance of Lifejackets and Consideration for Selection of a Lifejacket”, which should be applied in determining whether a lifejacket will perform satisfactorily for its intended use. The Sub-Committee also received for consideration draft amendments to the Revised Recommendation on Testing of Life-Saving Appliances (MSC.81(70)) providing detailed requirements for lifejacket marking, righting, and buoyancy requirements for testing, and new criteria for the clothing worn by test subjects during the lifejacket testing.

Next Steps: Due to time constraints, this subject was not able to be addressed at this session. Discussions on this subject will continue in an intersessional correspondence group and at SSE 9 (Mar-2023).

Subsequent to amendments to the Revised Recommendation on Testing of Life-Saving Appliances MSC.81(70) that were adopted by resolution MSC.488(103), the Sub-Committee agreed to associated amendments to the Revised Standardized Life-Saving Appliance Evaluation and Test Report Forms (Survival Craft) (MSC.1/Circ.1630). These amendments are intended to update references to testing standards for oil resistance testing of inflatable life rafts.

Next Steps: The draft amendments will be presented to MSC 106 (Nov-2022) for further consideration and approval, and subsequent release as MSC.1 Circ.1630/Rev.1.