Marine Operations Note: 08/2006 - IMMERSION SUITS
27 October 2006
Marine Operation Note 08/2006
This document is archived. It is kept for reference and may have been superseded.
October 27, 2006
MARINE OPERATIONS NOTE: New 8/2006
SUBJ: IMMERSION SUITS
Reference: a. Marine Notice SAF-001
- SOLAS III/32
- MSC.152(78)
Dear Owner/Operator, Designated Person Ashore, Nautical Inspector/Auditor and Classification Society Surveyor:
The following is provided as additional guidance and supplements and revises the information contained in Marine Notice SAF-001 until that document is updated.
Amendments to SOLAS Regulation III/32.3 require immersion suits for every person on board a cargo ship by the first Safety Equipment Survey after 1 July 2006. There is a provision which exempts cargo ships that are not bulk carriers and are engaged in voyages in warm climates where in the opinion of the Administration Immersion suits are unnecessary. The amendment removed the previous provision that immersion suits and thermal protective aids need not be required if a ship has totally enclosed lifeboats.
Warm Climates: After review of the available information, the Administration has revised its definition of warm climate for purposes of SOLAS Regulations III/7.3, 22.4.1.2, III/32.3.2.3 and III/32.3.3.3, as being that between 30o North and 30 o South latitudes.
Form E of the Cargo Ship Safety Equipment Certificate: The total number of immersion suits on board is required to be listed in section 2.8.8.1 of Form E to the Cargo Ship Safety Equipment Certificate (SE). This number should include the immersion suits required for every person on board and the additional required for any watch or work stations which are considered "remote locations". Thus, in most cases, the number of immersion suits in section 2.8.8.1 should be more than the number listed in section 2.1. of Form E.
If the total number of immersion suits required for every person on board is less than the total listed in 2.1 of Form E of the current SE, the Owner/Operator has the option to request the class society to reduce the number in 2.1, or to provide additional immersion suits to match the number in section 2.1. In making this decision, Owners/Operators should consider the possible future need to carry additional persons on board and the requirement to provide additional immersion suits and other life-saving appliances.
Definition of remote locations: The revised paragraph 3.3 of SOLAS III/32 reads: "If a ship has any watch or work stations which are located remotely from the place or places where immersion suits are normally stowed, additional immersion suits shall be provided at these locations for the number of persons normally on watch or working at those locations at any one time."
Due to different ship designs and configurations, Liberia allows some flexibility in determining the number of immersion suits required for "remote locations". As stated in reference a., the location and number of additional immersion suits to be supplied is subject to review by the classification society to determine whether or not the wheel house, engine control room and/or lookout stations are considered as “remote locations.”
One of the Class Societies, which is recognized by this Administration, has developed additional guidance to assist in determining locations that are “remote locations”. To illustrate this, the society developed examples of “remote locations” on for different ship types contained in the attached sketch, and included an interpretation of the term “remotely located”, as follows:
- Remotely located is an area not integrated into the superstructure/living quarters, and therefore not in the direct vicinity of the survival craft and/or the normal stowage position of the immersion suits.
- To determine if additional immersion suits are required when there is an additional liferaft forward or aft; “remotely located” would only apply if distance between bow or stern from the primary survival craft is more than 100m to the where the additional liferaft is fitted (see SOLAS Reg.III/31.1.4)
Liberia accepts this interpretation for Liberian flag vessels.
Rescue boat crew: The immersion suits required for every person assigned to crew the rescue boat, may be the same as those immersion suits required by SOLAS III/32.3.2.
For more information please contact Timothy M. Keegan at +1 703 251 2409 or email:
safety@liscr.com
Regards,
Capt. David Pascoe
Head Maritime Operations & Standards
On behalf of
DEPUTY COMMISSIONER OF MARITIME AFFAIRS
REPUBLIC OF LIBERIA
