IACS

SHIP SAFETY AND

POLLUTION PREVENTION:
THE REGULATORY REGIME

BY

J R G SMITH
Permanent Representative to IMO
May 1999
SHIP SAFETY AND POLLUTION PREVENTION:
THE REGULATORY REGIME

TABLE OF CONTENTS

1. INTRODUCTION 2

2. THE SHIP: ITS PURPOSE AND THE PERCEIVED HAZARDS IT 3

WILL ENCOUNTER AT SEA ; ALSO THE PERCEIVED HAZARDS
PRESENTED BY THE SHIP TO THE SEA

3. A REGULATORY STRATEGY - TAKING INTO ACCOUNT THE 5

PERCEIVED HAZARDS

4. THE REGULATORY REGIME ESTABLISHED ON THE BASIS OF 7

THE REGULATORY STRATEGY

5. CONCLUSION 27

REFERENCES 28

ORIGINS & DEVELOPMENT OF CLASSIFICATION I.B.C.

1
1. INTRODUCTION

This paper is intended to be a general, and hopefully useful guide to the current safety and pollution prevention
requirements for ships. These have evolved over many years and have been criticised for being too prescriptive, and
amended only on the basis of reaction to problems. Some critics claim that the present requirements are not
efficiently focussed on the perceived hazards, and that future requirements should be formulated on the basis of
formal safety assessments. Others go further, urging that future requirements be target setting or functional instead
of prescriptive, leaving the ship or equipment designer to achieve the targets in each case, taking into account the
human element.
Whilst it is entirely right and proper that progress be made, using the latest formal safety assessment techniques and
taking into account the human element, the Author feels that some of those critical of the present regulatory regime
and eager for radical and far reaching change, may not fully understand the nature of the system they are seeking
to change.
Change should be effected on the basis of precise knowledge of what is being changed and why it is being changed.
If it is proceeded to change something which is not thoroughly understood, it is unlikely that significant progress will
be made. Indeed, it is more likely that progress may actually be retarded.
The present regulatory regime is complex having evolved over a period of over 100 years, and yet is not without
logic. The regime sets out requirements which, although prescriptive, do address perceived hazards. There is nothing
technically wrong with a prescription provided it addresses properly an accurate diagnosis. This paper sets out to
explain the present regulatory regime, how the prescriptive requirements do address perceived hazards, and why
for the great majority of routine shipbuilding, prescriptive requirements represent the only practical form of
regulatory regime. Also, how the present regulatory regime seeks to strike a balance to allow the use of either
prescription or equivalent to prescription on the basis of a technical/scientific first principals approach.
In order to show more clearly how the present regulatory regime, unwieldy as it may seem, does in fact address the
perceived hazards, an intermediate step has been introduced between Section 2, which deals with the perceived
hazards, and Section 4, which describes the regulatory regime. The intermediate step (Section 3) is a regulatory
strategy, formulated by the Author on the basis of the perceived hazards.
The regulatory regime described at Section 4 is then shown to meet the demands of the regulatory strategy (Section
3), and thus can be seen to address fully the perceived hazards (Section 2).

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2. THE SHIP: ITS PURPOSE AND THE PERCEIVED HAZARDS IT WILL
ENCOUNTER AT SEA; ALSO THE PERCEIVED HAZARDS PRESENTED BY
THE SHIP TO THE SEA

The purpose of a merchant ship is to carry cargo and/or passengers at sea, at a profit. If it cannot make a profit, it
will cease to operate. It could be said, absurdly, that such a situation would represent the ultimate in safety, since a
ship not at sea cannot be subjected to the hazards of the sea, and would therefore be safe. However, this clearly
absurd statement does help to focus on the fact that the vast majority of goods transported around the world, and
which we all make use of in some form, are carried by ships. Ships must therefore trade, and owners of ships are
not in business for entirely altruistic reasons. Income must therefore exceed expenditure. Compliance with a
regulatory regime is part of the shipowners expenditure, and when considering any additional regulatory burden, it
would be foolish to ignore this.
EXTERNAL AND INTERNAL HAZARDS IMPOSED UPON THE SHIP
(i) The sea constitutes a very hostile environment and ships at sea face significant hazards. In addition to having
sufficient strength and stability to withstand the awesome force of the sea itself, the ship must find means of
avoiding collisions with other ships and of going aground. These are externally imposed hazards.
(ii) Additionally, the ship is exposed to hazards imposed upon it internally, by far the most serious being that of
fire and/or explosion. The source of the fire hazard can be the cargo, the oil fuel burning main engine and
associated machinery, and the officers and crew. As regards officers and crew it must be accepted that they are
human and therefore liable to make human errors. This could result in a fire in their own accommodation, in the
cargo area or in the engine room. To concentrate the mind on the fire/explosion hazard on very large crude oil
carrier, for example, it should be understood that in land based terms, the accommodation spaces are situated
on the roof of a power plant (engine room) and adjacent to a reservoir of some 200,000 tonnes of highly
flammable crude oil (cargo tanks). Additionally, in the event of fire, the assistance of outside professional
firefighters cannot be called upon. A fire onboard a ship must be fought by professional seamen who, however
well trained, are not professional fire fighters.
Most ship fires occur in the engine room, typically caused by oil fuel leakage onto hot surfaces, whilst fire in
accommodation spaces can be the result of faulty electrics or careless use of lighted cigarettes, just as in land
based human habitats.
To summarize the fire hazard, all ships have a similar or common hazard insofar as they all have engine rooms
and crews. The cargo related fire hazard will, however, vary dependent on the flammability of the cargo.
A further safety hazard internally imposed upon the ship by the cargo, is that of cargo shift. Cargo shift can
significantly reduce stability and also impose excessive loading on the ship structure.
High toxicity of some cargoes also constitutes an internally imposed hazard.
The major safety hazard imposed internally on the ship by the main engine and its auxiliary machinery systems
(hereafter referred to as essential engineering systems) is that caused by engine or steering gear breakdown
resulting in the ship drifting out of control in a seaway thereby increasing the likelihood of grounding or collision.

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HAZARDS IMPOSED BY THE SHIP ON THE MARINE ENVIRONMENT
In navigating the sea, just as other ships constitute a collision threat to it, so the ship itself constitutes a collision
threat to others. The main hazards imposed by the ship to the sea and the marine environment, are potential pollution
problems. At the present time recognised potential pollutants are:

• oil

• noxious liquid substances

• harmful goods in packaged form

• sewage

• garbage

• discharge into the atmosphere of excessive sulphur oxide from the combustion of fuel oils and
nitrogen oxide from diesel engines.

• discharge into the atmosphere of volatile organic compounds from tanker cargoes

• discharge into the atmosphere of ozone depleting substances, such as halons and chloro-
fluorocarbons (CFCs)
It should be noted that whenever a ship fails under the safety hazards imposed and sinks, or its shell is breached, it
could in turn become a hazard to the marine environment by releasing some of the previously described pollutants.

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3. A REGULATORY STRATEGY -
TAKING INTO ACCOUNT THE PERCEIVED HAZARDS

(1) The ship must have sufficient strength such that it can withstand the forces imposed upon it externally by the
sea and internally by the cargo.
(2) The ship must be provided with a main engine and associated machinery (essential shipboard engineering
systems) of a dependability such that it does not break down, leaving the ship drifting out of control.
(3) The essential engineering systems to be designed such that hazards imposed by it on the ship and ships
personnel are kept to a minimum.
(4) Due regard should be paid to providing an adequate height of uppermost continuous deck above the water line
(freeboard), commensurate with ship strength adequate for the corresponding draught, with a view to limiting
sea water on deck and providing ships personnel with a safe working platform.
(5) Adequate protection and means of closure should be provided for all openings in the ship’s hull, deck and
superstructures with a view to preventing sea water entering the ship and thereby reducing reserve buoyancy.
(6) The ship must have sufficient stability such that it will not capsize.
(7) Due regard should be paid to specific hazards imposed internally on the ship by specific cargoes. (e.g. liquid
cargoes - sloshing loads imposed on the ship structure and free surface effects on the ship’s stability,
flammability, toxic and pollutive properties.)
(8) The ship must be provided with sufficient navigational aids to enable it to be navigated safely, avoiding
grounding and collision.
(9) The ship must be designed such that specific areas of high fire and/or explosion risk are adequately separated,
and each protected from a fire in an adjacent area.
(10) The fire safety system should be capable of being used by professional seamen, bearing in mind that when at
sea, the services of professional fire fighters cannot be called upon.
(11) Due regard should therefore be paid to prevention of fire by providing sufficient fire protection.
(12) Fire protection to be such that if a fire does occur it is contained in a sufficiently small space such that it may
be extinguished swiftly.
(13) To further facilitate swift extinction, adequate detection systems should be provided.
(14) Adequate fire extinguishing systems and equipment to be provided.
(15) The ship be provided with radio equipment such that it may always be safely in contact with other ships and
shore stations. This is especially important in emergency situations.
(16) If other safety precautions fail and the ship must be abandoned, means to be provided such that this may be
swiftly and safely accomplished i.e. lifeboats and other life saving appliances to be provided together with
means of swift, safe embarkation and disengagement from the ship. Due regard should be paid to the
prevention of hyperthermia as a result of abandoning ship.

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(17) Adequate means to be provided to prevent pollution of the marine environment.
(18) Ship personnel to be competent to operate efficiently and maintain in satisfactory condition, the ship, its safety
systems and environment protection systems.
(19) Shore-based management to provide clear direction to and liaise closely with ship personnel regarding efficient
operation and satisfactory maintenance of the ship, its safety systems and environment protection systems.
(20) On going compliance with a regulatory regime formulated on the basis of this regulatory strategy, should be
verified by surveys at regular intervals.
GENERAL
In establishing safety and pollution prevention standards (hereafter referred to as the regulatory regime) it should
be recognised that neither safety nor pollution prevention is absolute. It is not possible to provide either perfect
safety, or perfect pollution prevention.
Safety can be defined as that level of safety deemed by the community at any given time, to be both necessary and
affordable.
Pollution of the marine environment is that level of pollution introduced into it which is deemed by the community to
be unacceptable i.e. that which cannot be adequately absorbed by it. By definition, anything less is acceptable.
Ship safety and pollution prevention as so defined is achieved by complying with a regulatory regime established on
the basis of a regulatory strategy, which has taken into account the perceived hazards.

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4. THE REGULATORY REGIME ESTABLISHED ON THE BASIS OF THE
REGULATORY STRATEGY

The regulatory regime concerning ship safety and marine pollution prevention is comprised of Classification rules
made by Classification Societies AND the regulations contained in the International Conventions made collectively by
Member States at IMO.
Classification Societies make comprehensive Classification rules for hull structural design and essential shipboard
engineering systems and apply them by means of appraisal of the design and survey of the ship and its systems.
Each Member of the International Association of Classification Societies (IACS) (Ref. 1) can be defined as a
Classification Society having comprehensive Classification rules compiled on the basis of sound research and
development; a worldwide network of well qualified surveyors; efficient and effective feedback of significant technical
data via surveyor’s reports and an internationally recognised quality management system. Throughout the remainder
of this Paper, the phrase “Classification Society” only will be used, but this should be taken to mean a Member Society
of IACS. References to Classification rules should be taken to mean those of IACS Member Societies.
Classification rules have been in a constant state of evolution and development, in some cases for over 200 years,
and have traditionally addressed hull structures and essential shipboard engineering systems. Thus, even before the
turn of the century, when various National Administrations first contemplated statutory legislation concerning the
safety of life at sea, classification rules for these fundamental items of ship safety were already well established.
There was, therefore, no need for the Administrations to duplicate this when considering their own statutory
requirements. They were thus able to concentrate on other safety factors, such as the computation of load lines and
conditions of assignment, stability, fire safety, life saving appliances, navigation lights and equipment, and radio
communication.
In 1948, at a conference held by the United Nations, a convention was adopted, establishing the Inter-Governmental
Maritime Consultative Organisation (IMCO). This title was changed some years later to the International Maritime
Organisation (IMO). The Organisation is the United Nations Agency for maritime matters concerning ship safety and
marine pollution prevention. Recognising that shipping is of an international nature, it enables Member States to meet
collectively for the purpose of formulating International Conventions, instead of producing their own safety and
pollution prevention requirements individually and in isolation.
These International Conventions reflect the practice of the majority of individual Administrations prior to 1948, in so
far as they address safety aspects other than hull structures and essential shipboard engineering systems, thus
implicitly recognising the experience and expertise of the Classification Societies in these fields.
It is emphasised that the regulatory regime concerning ship safety and marine pollution
prevention comprises the rule making function of the Classification Societies together with the
Convention making function of IMO.

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CLASSIFICATION RULES
Classification rules are produced on the basis of considerable research and development to keep abreast of
advancing technology as well as reflecting the results of service feedback received continuously through hull and
machinery survey reports. They contain detailed requirements for:

• Materials

• Ship structures

• Main and auxiliary machinery

• Control engineering systems

• Electrical Installations
SHIP STRUCTURES
The rules for ship structures are based on sound technical principles and they have been thoroughly tested against
service performance. Complying with the rules will ensure the provision of adequate overall or global strength,
together with adequate local strength of individual components. For overall strength, a ship’s hull structure must be
capable of withstanding design values of still water and wave induced loads and internal cargo loads within specified
stress criteria. Local strength, to resist modes of buckling, fatigue, yielding or brittle fracture, is obtained by
compliance with the rules’ material requirements and scantling formulations. Alternatively, the rules provide for the
determination of scantlings by application of direct calculation procedures and defined permissible stress criteria.
Some Societies have developed sophisticated computer programs capable of assessing structural response to
complex dynamic loads and the fatigue performance of structural connections.
ESSENTIAL ENGINEERING SYSTEMS
The rules for main and auxiliary machinery, control engineering systems, electrical installations and refrigerated
cargo installations cover a broad range of detail. Where appropriate, the rules prescribe methods of deriving primary
scantlings of shafting, pressure vessels, propellers and other components of the shipboard engineering system, whilst
allowing designers certain freedom to utilize more complex methods of analysis. Details which are not specifically
prescribed in the rules are assessed for suitability by means of appropriate calculation methods. The rules also
prescribe requirements for the provision of safety devices, control alarms and shut down arrangements to protect
life and equipment. For pumping and piping and electrical installations, the rules stipulate the key requirements for
layout, arrangement, duplication and duty.
GENERAL
The rules also define requirements for survey during construction and periodic surveys on an annual basis in service to
ensure that the prescribed standards are satisfied, thus taking cognizance of the regulatory strategy at Section 3(20).
Compliance with Classification rules provides adequate ship strength together with safe and reliable essential
shipboard engineering systems, as per the regulatory strategy at Section 3(1), (2) and (3), also (7) as regards loads
imposed on the ship structure by liquid cargoes. Classification rules are applicable to all types of steel ships (except
ships of war), of all sizes and on international or domestic voyages.

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SHIP STRUCTURES - CLARIFICATION OF PRESCRIPTIVE RULES AND DIRECT CALCULATION
It has been previously mentioned that the regulatory regime has been criticised for being too prescriptive. As regards
classification rules, it is those for ship structures which are particularly criticised in this way. It is therefore
considered necessary to provide more explanation in this regard, as follows:
The initial phase of ship design is to develop an outline comprising principal dimensions, hull form and arrangement
of compartments. An estimate of lightweight and the selection of the system of primary structural support is also
made at this stage.
The classification rules for ship structures set out requirements which enable the design to progress from such an
outline to a complete structural design. The items covered include:

• chemical composition and mechanical properties of materials;

• longitudinal strength and permissible still water bending moments and shear forces;

• plating thicknesses of decks, shell, inner bottom, bulkheads;

• stiffener sizes, spacings and end connections;

• arrangement and dimensions of primary supporting structure such as girders, floors, cross ties
and stringers;

• structural details including arrangements at the intersections of secondary stiffeners with

primary structure to provide satisfactory fatigue performance;

• rudder scantlings, support arrangements and stock diameter;

• weld types and sizes;

• anchor weights and the length and diameter of chain cables.

The prime objective of the rules for ship structures is to define a standard of strength which allows ships to fulfil their
commercial requirements with what is recognised by a consensus of informed opinion as a proper level of safety.
Over the years the rules for ship structures have been progressively developed by means of theoretical investigations
of the behaviour of materials and structures, by direct observations and measurements and by the analysis of service
experience.
Theoretical investigations identify the parameters relevant to structural strength and determine their functional
relationship to one another and to the responses of the ship and individual components. They are normally concerned
with idealised situations and so, wherever practical, it is important to calibrate the results by comparison with direct
measurements. A good example is the extensive programme of strain measurements used in the establishment of
design values for wave bending moments on a probabilistic basis. Photoelastic techniques have been used at both
full and model scale to verify the results of theoretical predictions of the distribution of stress in structures. This has
become less common in recent years on account of the growing availability and confidence in finite element methods
for numerical analysis.
The accumulation of consistent and reliable information concerning the service performance of ships’ structures is
an area in which Classification Societies are in a unique position. Each survey of a classed ship is the subject of a

9
report which includes a detailed description of any damage or defects found. On older ships the wastage of plating
is measured by means of thickness determinations and the results reported. All survey reports are collated and
constitute the raw material for a comprehensive data base of service experience for the structural components of
merchant ships of all types and sizes. By examining and comparing rates of defect or damage, areas where a
modification to the rules should be considered are identified.
Other triggers for the investigation of changes or additions to the rules are:

• developments in ship design or functions which result in arrangements and loadings not
envisaged by the existing rules, an example being the advent of the double hull Very Large Crude
Carrier (VLCC);

• recognition of anomalies or inconsistencies in the Rules;

• requests by designers to accommodate the use of new materials;

• advances in understanding of loads, structural responses and modes of failure

For most structural components the scantling requirements are given prescriptively by means of formulae. In deriving
the formulae, anticipated loadings on the various components are assumed, the intent being to limit stress to
permissable limits.
It is important however that the rules should achieve their objective of providing for structural
safety whilst at the same time allowing designers the freedom to innovate. To this end the rules
recognize the concept of ‘equivalence’ to the prescriptive requirements. If it can be
demonstrated that an alternative to the combinations of arrangements and scantlings envisaged
by the published requirements would give an equivalent standard of strength, then it will be
approved and the ship will be deemed to fully comply with the rules.
The establishment of equivalence normally involves some form of direct calculation of structural responses.
The term ‘direct calculation’ is used to refer to the assessment from first principles of loads and structural responses,
using basic physical laws as opposed to the use of specific rule formulae. At its simplest it is the calculation of the
cross sectional areas and inertia of fabricated stiffening members. At its most complex it could be nonlinear finite
element analysis or the evaluation of transient pressure peaks due to sloshing of liquid cargoes in partially-filled
tanks.
There are three sets of circumstances in which direct calculations are carried out or considered in association with
the approval of plans for classification purposes:

• some direct calculations are called for as an integral part of the application of the rules;

• other direct calculations are carried out when the proposed arrangement is outside the validity
of the rule formulae. For example, when primary structure is arranged in both the longitudinal
and transverse directions the loads in a given component become dependent on the interaction
of stiffnesses. Only the simplest cases of such interaction can be practically expressed as
formulae or tables. For more complex situations appropriate techniques of structural analysis
must be used to determine stresses and deflections;

10
 • direct calculations may also be used to approve, on the grounds of equivalence, scantlings
below the values determined from rule formulae. The apparent paradox that this implies can be
explained by pointing out that the Rule formulae incorporate assumptions as to how a particular
component will interact with adjacent structure. To provide for structural safety over the full
range of applications, these assumptions must be chosen conservatively. For a specific
arrangement, it may be possible to carry out structural analysis to determine the interactions
more accurately and so justify scantling reductions.
When structural responses are determined by direct calculation the results must be assessed
using acceptance criteria appropriate to the type and refinement of the analysis carried out. It
would, for example, be misleading to talk of a single set of permissible stresses applicable to all
finite element analysis results. The appropriate values must be assessed taking into account the
extent of the model, the fineness of the mesh, the nature and probability of the applied loads and
the likely modes of failure.
INTERNATIONAL CONVENTION REGULATIONS
Detailed regulations pertaining to design, construction arrangements and equipment other than for hull structural
design and essential shipboard engineering systems, together with requirements concerning standards of training,
certification and watchkeeping, also safety management, are contained in the various International Conventions and
related Codes and Resolutions, which are formulated at IMO, after detailed debate by delegations representing some
155 member States.
The Conventions and related Codes and Resolutions contain detailed regulations for:

• Computation of Load Line (or freeboard) marks and conditions of assignment

• Intact and damage stability

• Carriage of dangerous goods (i.e. bulk chemical cargoes, liquefied gas cargoes and dangerous
goods in packaged forms)

• Navigational aids, light and sound signals

• Fire protection, detection and extinction.

• Radio equipment

• Lifeboats, liferafts, lifejackets and other lifesaving appliances

• Pollution prevention arrangements and equipment

• Standards of training, certification and watchkeeping

• Safety management

• Port State Control

• Tonnage computation

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The Conventions also include regulations for survey during construction and periodic surveys on an annual basis in
service to ensure that the prescribed standards are satisfied, thus taking cognizance of the regulatory strategy at
Section 3(20).
Although a tonnage computation is neither a safety nor a pollution prevention item in itself, many safety and pollution
prevention requirements are related to gross tonnage, since this is a measure of ship size. (In general, the safety and
pollution prevention requirements for large ships are more onerous than those for small ones.)
There are four key International Conventions which form the main framework of International Safety and Pollution
Prevention legislation:

• 1966 Load Line Convention

• 1969 Tonnage Convention

• 1973 Marine Pollution Convention as amended by the 1978 Protocol thereto, and Amendments
(known as MARPOL 73/78 and Amendments thereto) but referred to in this paper simply as
MARPOL 73/78.

• 1974 Safety of Life at Sea Convention (SOLAS) and Amendments thereto. (Referred to in this
paper simply as SOLAS 74)
Other relevant Conventions are:

• 1972 Convention - Regulations for preventing Collision at Sea (COLREGS 72)

• International Convention on Standards of Training, Certification and Watchkeeping for

Seafarers, 1978.

• International Convention on Standards of Training, Certification and Watchkeeping for

Seafarers, 1978, as amended in 1995 (Referred to in this paper as STCW 95).
APPLICABILITY OF CONVENTIONS
It should be noted that, the SOLAS 74 Convention unless expressly provided otherwise applies only to ships engaged
on international voyages. Also, unless expressly provided otherwise, it does not apply to:
(i) Ships of war and troopships.
(ii) Cargo ships of less than 500 gross tonnage.
(iii) Ships not propelled by mechanical means.
(iv) Wooden ships of primitive build.
(v) Pleasure yachts not engaged in trade.
(vi) Fishing vessels.
Regarding “expressly provided otherwise”, it should be noted that:
(1) Chapter IV of SOLAS 74 “Radiocommunications” applies to all ships to which the Convention generally applies
(as above) and to cargo ships of 300 gross tonnage and upward.

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(2) Chapter V of SOLAS 74, “Safety of navigation” (unless otherwise expressly provided in the Chapter) applies to
all ships on all voyages, except ships of war and ships solely navigating the Great Lakes of North America.
(3) Chapter VII of SOLAS 74 “Carriage of Dangerous Goods” applies to chemical tankers (on international voyages)
including those of less than 500 gross tonnage unless expressly provided otherwise in the Chapter or related
Code. It also applies to liquefied gas carriers (on international voyages) including those of less than 500 gross
tonnage, unless expressly provided otherwise in the Chapter or related Code.
The 1966 Load Line Convention applies to all ships on international voyages, except:
(a) ships of war;
(b) new ships of less than 24 metres (79 feet) in length;
(c) existing ships of less than 150 gross tonnage
(d) pleasure yachts not engaged in trade
(e) fishing vessels
The various Annexes of MARPOL 73/78 differ with regard to their applicability, but none are entirely applicable to
every type of ship of any size and on any voyage.
PRESCRIPTION AND EQUIVALENCE
The Conventions and ongoing Amendments thereto are formulated by delegations of IMO member States working
through a system of committees, subcommittees and working groups coordinated by the IMO Secretariat. Like
Classification rules the requirements so produced have been criticized as being too prescriptive, and therefore
discouraging innovation.
However, they are formulated on the basis of considerable research and development carried out by individual IMO
member States and non-governmental organizations, and an awareness through experience of ship safety and
marine pollution matters. The requirements so formed are logical and successfully address real problems.
The concept of equivalency is also well established and is enshrined for example, in SOLAS ‘74, whereby ‘the
Administration may allow any other fitting, material, appliance or apparatus, or type thereof, to be fitted or carried,
or any other provision to be made in that ship, if it is satisfied by trial thereof, or otherwise, that such fitting, material,
appliance or apparatus, or type thereof, or provision, is at least as effective as that required by the present
regulations’. Any Administration which allows such an equivalence must communicate to IMO particulars thereof
together with a report on any trials made and IMO will circulate such particulars to other Contracting Governments
for the information of their officers.
RELATIONSHIP OF CLASSIFICATION RULES AND INTERNATIONAL CONVENTION REGULATIONS
It is important to emphasize that the IMO Conventions do not address hull structural and essential shipboard
machinery systems in any detail. Nevertheless the 1966 Load Line Convention requires, inter alia, that before a Load
Line Certificate can be issued to a ship, the ship must be of adequate strength. The Convention states that ships built
and maintained in conformity with the requirements of a Classification Society recognised by the Flag Administration
may be considered to possess such strength. SOLAS 74 requires that every cargo ship of 500 gross tonnage and over

13
engaged in international trade must have a Cargo Ship Safety Construction Certificate, and all passenger ships
intended for international voyages must have a Passenger Ship Safety Certificate.
The Convention requires that these Certificates (together with additional safety requirements for passenger ships) be
issued on the basis of the arrangements, material and scantlings of the structure, boilers and other pressure vessels
and their appurtenances, main and auxiliary machinery including steering gear and associated control systems,
electrical installation and other equipment being in all respects satisfactory for the service for which the ship is
intended. The only detailed authoritative rules for these vitally important items are those of the Classification
Societies.
Thus, for total compliance with the ship safety and marine pollution prevention standards as envisaged by IMO
member states, it is necessary for ships to comply with the rules of a Classification Society or equivalent, as well as
with the requirements of the IMO Conventions.
Dependence on compliance with Classification rules as a prerequisite for the issue of these Convention certificates,
has always given the Classification rules an implicit statutory status.
It should be noted, however, that Regulation 3-1 of Part A-1 of Chapter II-1 of SOLAS 74, which entered into force
on 1 July 1998, states as follows:- “In addition to the requirements contained elsewhere in the (SOLAS) regulations,
ships shall be designed, constructed and maintained in compliance with the structural, mechanical and electrical
requirements of a classification society which is recognised by the Administration in accordance with the provisions
of chapter XI/1, or with applicable national standards of the Administration which provide an equivalent level of
safety.”
Thus the longstanding but previously implicit IMO Convention relationship with classification
rules for ship structures and essential engineering systems is now explicit.
It will be noted that the regulation quoted above begins with the phrase “In addition to the requirements contained
elsewhere in the regulations -----”. These general and largely non-detailed requirements for ship structure and
essential engineering system are contained in Chapters II-1 and XII of SOLAS 74. They have also been incorporated
in the Classification rules, together with appropriate details.
The following is a synopsis of other Convention regulations for the ships to which they are applicable:
COMPUTATION OF LOAD LINE (OR FREEBOARD) MARKS AND CONDITIONS OF ASSIGNMENT
Regulations for these matters are contained in the 1966 Load Line Convention, and take due cognizance of the
regulatory strategy at Section 3(4) and (5).
They prescribe the computational method by which the load line or freeboard marks are fixed, and the conditions of
their assignment. Freeboards are computed assuming the ship to be a completely enclosed and
watertight/weathertight envelope. The Convention then goes on to recognize the practical need for openings in a ship
and prescribes means of protection and closure of such openings. These are called conditions of assignment, since
the assignment of the computed freeboards is conditional upon the prescribed means of protection and closure of
openings such as hatchways, doorways, ventilation, air pipes, scuppers and discharges being complied with.
Regulations are also included for freeing ports in bulwarks to prevent water accumulating on the deck, also guard
rails and walkways to provide safe passage on deck for the ship’s personnel.

14
The philosophy is to provide sufficient height of the uppermost continuous deck above the waterline such that the
breaking of seawater over it (commensurate with the size of hatchways and means of closure) will not constitute
an unforeseen hazard and, provide the ship’s personnel with a working platform at a sufficiently safe height above
the waterline.
The Regulations prescribe the computational method by which the freeboard marks are fixed. The prescribed method
is related to the geometry of the ship. Hence, the minimum computed summer freeboard (corresponding to the
maximum summer draught) is known as the minimum summer geometric freeboard. Before this can be assigned and,
prior to establishing conditions of assignment regarding protection and closure of openings and protection of crew,
as described above, it must be confirmed that the ship’s strength is adequate for the corresponding maximum
summer draught.
This is not always the case, since a ship carrying a light density (or capacity) cargo may not attain the maximum
obtainable draught when fully laden. In such a case, an owner may choose not to incur the expense involved in the
provision of adequate strength for the deepest draught, and have a greater than minimum geometric freeboard
assigned, corresponding to a maximum permissible draught for strength purposes, (i.e. not the maximum geometric)
known as the scantling draught.
In most cases however, the maximum scantling draught is the same as that corresponding to the minimum geometric
summer freeboard.
The minimum geometric summer freeboard is computed by first taking a freeboard for a standard ship of the same
length (provided in tabular form in the regulations) and correcting it for those geometric properties of the ship
which differ from those of the standard ship. The geometric corrections prescribed in the Regulations are those
for block coefficient, depth, superstructure, trunks and sheer. There is also a regulation which stipulates a
minimum bow height.
Once the summer freeboard mark has been established, it is a simple matter to further compute the additional marks
for fresh water, tropical, tropical freshwater, winter and winter North Atlantic, as required.
Note: It is appreciated that the method of computing freeboards in accordance with the 1966 Load Line
Convention is outdated, and that it would be more technically pure to replace it with a method based on
stability and deck wetness.
However, thousands of ships in service have been assigned freeboard in accordance with the present
statutory method. Any new method regardless of its technical purity, should provide for similar freeboards
to those already assigned so that new ships neither benefit in terms of draught nor are penalised by
comparison with ships already in service; unless there is compelling safety evidence indicating a need for
change. In such a case, retroactive adjustments might also be indicated.

15
INTACT AND DAMAGE STABILITY
Initial stability is maintained when a vessel’s centre of gravity is located below the geometric metacentre.
So long as the sea is calm, a small initial positive GM (metacentric height) would satisfy the basic intact stability
requirements for any vessel and normally prevents capsizing. However, the world’s oceans can be very hostile and
minimum freeboards have had to be established to restrict the ingress of water together with minimum GM values
to ensure that positive stability is maintained throughout the range of rolling in a seaway.
This had been considered to be an acceptable state of affairs until the largest passenger ship afloat at the time,
Titanic, was damaged and sank with many fatalities. This event prompted the first legislation for the stability of
passenger ships in a damaged condition. In more recent years damage stability requirements have been progressively
introduced for oil tankers, chemical tankers, liquefied gas carriers and dry cargo ships.
As a result of regulation development occurring in different periods of technological advance and to satisfy the needs
of particular ship types at the time, two quite different concepts and methods of carrying out damage stability
analyses have evolved. These are known as the deterministic and probabilistic methods.
The so-called deterministic method is where the regulations require survival with certain prescribed residual
stability characteristics being maintained after sustaining damages up to a maximum prescribed size. These damage
assumptions need not necessarily be applied to all locations in the ship. However, survival of the ship must be
achieved in each case of flooding after the prescribed damage.
The more recently evolved probabilistic method is where the regulations address the probability of damage
occurring at any particular location throughout the ship and adopts a more rational approach to longitudinal
subdivision by considering the likelihood of a damage resulting in the flooding of only one compartment, or any
number of other adjacent compartments either longitudinal, transversely or vertically. The probability of a ship having
sufficient residual buoyancy and stability to survive in each such case of damage is assessed and the summation of
all positive probabilities of survival provides an “Attained Subdivision Index” for comparison against a required norm,
the “Required Subdivision Index”, for that size of ship.
In the probabilistic method a ship need not necessarily survive in every possible case of assumed damage provided
that there are sufficient survival cases in aggregate which contribute to the minimum “Required Subdivision Index”
as determined by the regulations.
The regulations presently prescribe the deterministic method for oil tankers, dry cargo ships with reduced freeboards,
chemical carriers, liquefied gas carriers and passenger ships. The deterministic method is also prescribed for bulk
carriers of 150m in length and upwards of single side skin construction, carrying solid bulk cargoes of a specified
density, regardless of any reduction in freeboard.
However, damage stability regulations, which entered into force in 1992, prescribe the probabilistic method for dry
cargo ships.
The present Damage stability legislation is contained in the following Conventions or related mandatory Codes,
although it is expected that efforts to achieve harmonisation will cause some changes in the future.

16
 DETERMINISTIC OR
CONVENTION OR CODE TYPE OF SHIP
PROBABILISTIC

Oil Tankers Deterministic

1966 Load Line Convention Dry Cargo Ships with Deterministic
reduced freeboard

1974 SOLAS and Passenger Ships Deterministic

Amendments thereto
Chapter II-I Dry Cargo Ships Probabilistic

1974 SOLAS and

Amendments thereto Bulk Carriers Deterministic
Chapter XII

Bulk Chemical Code Chemical Tankers Deterministic

International Bulk
Chemical Tankers Deterministic
Chemical Code

Liquefied Gas Carrier Code Liquefied Gas Carriers Deterministic

International Liquified
Liquefied Gas Carriers Deterministic
Gas Carrier Code

MARPOL 73 / 78
Oil Tankers Deterministic
Annex 1

17
It is clear that further work on damage stability legislation is required in order to achieve harmonisation. This is
presently lacking because as previously mentioned, regulation development has occurred during different periods of
technological advance. The primary concerns of some of the current legislation is to protect the ship against the
hazards of the sea, whilst some of it is primarily concerned with the protection of the marine environment against
quantities of pollutant cargo being released into it, after damage.

It is of interest to note that although there is much damage stability legislation enshrined in various Conventions and
mandatory Codes, with one exception, there is no similar technically detailed legislation for intact stability. (However
recommendations have been published by IMO in the form of a booklet entitled “Code on Intact Stability For All Types
of Ships Covered by IMO Instruments”.) The exception is reg 25A of Annex I of MARPOL 73/78, which specifies intact
stability criteria for any operating draught under the worst possible conditions of cargo and ballast loading,
consistent with good operational practice, including intermediate stages of liquid transfer operations. This regulation
is not yet in force, but will apply to new ships constructed on or after 1 August 1999.

The “Code on Intact Stability for All Types of Ships covered by IMO Instruments” comprises the annex to resolution
A.749(18), adopted by the IMO Assembly as a recommendatory Code, on 4 November 1993. In the Preamble, it is
stated that criteria included in the Code are based on the best “state of the art” concepts taking into account sound
design and engineering principles and experience gained from operating such ships. Furthermore, design technology
for modern ships is rapidly evolving and the Code should not remain static but be re-evaluated and revised, as
necessary. To this end, the Organization (i.e. IMO) will periodically review the Code, taking into consideration both
experience and further development.

The contents of the Code take into account the external hazards imposed upon the ship by the sea and weather, in
conjunction with internal stability reduction hazards, notably the effect of free surfaces of liquids in tanks.

Compliance with all applicable regulations as mentioned in the foregoing will satisfy the regulatory strategy at Section
3 (6), also (7) insofar as liquid free surface is concerned.

It should also be noted that SOLAS Chapter VI “Carriage of Cargoes” addresses the carriage of grain and other
cargoes with a view to minimizing cargo shift, which is another internal stability reduction hazard. (See also
regulatory strategy 3 (7)).

CARRIAGE OF DANGEROUS GOODS

The basic regulations are contained in Parts A, B and C of SOLAS Chapter VIII, which in turn refer to Codes for
detailed requirements and take into account the regulatory strategy of Section 3(7).

Part A addresses the carriage of dangerous goods in packaged form or in solid form in bulk, and
cross reference is made to the International Maritime Dangerous Goods Code. Although the regulations do not specify
any particular ship arrangements or equipment, they do address stowage requirements with a view to avoiding fire.
In this respect, it should be noted that reg. 54 of SOLAS Chapter II-2, addresses special requirements for ships
carrying dangerous goods. This regulation specifies where, on a ship, particular classes of dangerous goods (as
defined in Chapter VII) may be stowed and, what special fire safety arrangements should be provided.

Part B addresses the construction and equipment of ships carrying dangerous liquid chemicals
in bulk, and refers for technical detail to the mandatory International Bulk Chemical (IBC) Code.

18
Chemical tankers are required to comply with the various safety aspects detailed in SOLAS ‘74, but are additionally
required to comply with the IBC Code. Chemical cargoes can be very dangerous, most of them being flammable
and/or toxic, some of them extremely so. For this reason, the Code requirements are now analyzed in some depth.
The IBC Code lists, in its fourteen chapters, the requirements which must be satisfied by a ship prior to it being
certified as a chemical tanker regardless of the specific cargoes it is intended to carry. Within each chapter the
designer is given an option on the level of compliance required. If compliance with the more onerous requirements
is chosen, the ship will be more sophisticated and will therefore be able to carry the more hazardous cargoes.
Chapter 15 of the Code contains ‘Special Requirements’ which are cargo specific and which must be complied with
only if that specific cargo is to be carried. Chapter 16 addresses aspects which are the responsibility of the operator,
whilst Chapter 17 lists all chemicals considered to be suitable for transportation by sea. Chapter 17 also summarizes
the minimum requirements pertaining to ship arrangements and equipment which are required to be complied with
for the carriage of each chemical so listed. The list is regularly reviewed and updated by the IMO to ensure that it
contains all products regularly transported by sea and that the carriage requirements remain pertinent.
The basic requirements which must be satisfied prior to the carriage of any cargo listed in the IBC Code relate to the
general arrangement of the ship. As with oil tankers, the accommodation and engine room are required to be situated
aft of the cargo tanks. A cofferdam is required at the forward and aft ends of the cargo spaces to further segregate
the engine room. Cargoes which, if released into the sea following an accident, would pose a significant hazard to
the environment are required to be carried in tanks with no boundary adjacent to the sea - that is, tanks protected
by a double skin of hull plating (a longitudinal bulkhead and inner bottom, in addition to the shell plating). Cargoes
posing a minimal threat can be carried adjacent to the ship’s shell plating - that is, either in centre or wing tanks.
The ship must be able to withstand predefined deterministic damages to the hull structure without catastrophic loss
of stability, buoyancy or cargo. This ‘damage stability’ requirement is once again more onerous for those cargoes
posing greater hazards.
The major hazards associated with the safe transportation of liquid chemical cargoes in bulk relate to cargo
compatibility, toxicity and flammability.
The problem of compatibility of each cargo with the materials used in the construction of the ship and its equipment
is significant and the list of cargoes in the IBC Code highlights those cargoes which will react with specific materials.
Cargoes which react in a hazardous manner with one another are not permitted to be carried in adjacent cargo tanks
or to use common ventilation or pumping and piping systems. Cargoes which are water-reactive are not permitted
to be stowed adjacent to the ship’s hull or to ballast tanks containing sea water. Heat-sensitive cargoes which may
polymerize, decompose, become unstable or evolve gas must not be loaded in tanks adjacent to cargoes which
require to be heated to maintain pumpability. Tanks containing heat-sensitive cargoes are required to be fitted with
an alarm system which continuously monitors the cargo temperature.
The risk of cargo spillage during loading, transfer or discharge operations is high. The crew are required by the Code
to be provided with chemical resistant overalls, boots and gloves. Showers and eye washes are required to be
available on deck so that in the event of an accident involving the crew, water is immediately available.
Antidotes for all cargoes carried must be available on board in accordance with the Medical First Aid Guide produced
by the IMO. Many cargoes listed in the Code are toxic and the crew and shore-based personnel involved on cargo
operations must be protected from toxic vapours. When carrying toxic cargoes, chemical tankers are required to

19
have additional chemical-resistant suits and self-contained breathing apparatus suitable for use in a toxic
environment. All toxic vapours displaced from a cargo tank during loading must be vented directly to shore reception
facilities through a vapour return line.
Many cargoes are required by the Code to be carried in a controlled inert atmosphere, either because of their
flammability, toxicity or to prevent oxygen from adversely affecting the quality of the cargo. Bottled nitrogen is
normally supplied to the ship for this purpose; however, many of the more sophisticated ships have a nitrogen
generating plant installed on board. Unlike on oil tankers, exhaust gas from the main engines is insufficiently clean
for use on chemical tankers, and could impair the cargo quality demanded by the shipper. When carrying cargoes
which evolve highly flammable gases, the Code requires that all electrical equipment installed within their vicinity be
specifically designed for use in hazardous atmospheres. To assist the designer in the selection of safe electrical
equipment, the Code lists the temperature class and apparatus groups, as defined in the International
Electrotechnical Commission’s Publication ‘79, for each of the flammable cargoes in the code.
Cargo tank deck foam and firemain systems are required for fighting fires in the cargo tanks or as a result of cargo
spillage. The foam compound used must be compatible with the majority of cargoes carried on the ship and an
alcohol-resistant foam compound is normally supplied. When cargoes are carried for which foam or water is
unsuitable, an alternative fire extinguishing system using a medium such as dry powder must be supplied.
Most modern chemical tankers do not have a dedicated cargo pump room, and normally fit a cargo pump directly
into each cargo tank. Each pump has its own dedicated piping system and cargo discharge manifold. The main
advantage of this system is that it enables a large number of different cargoes to be discharged or loaded without the
need for time-consuming pipe flushing between each cargo. The cargo piping is required to be constructed of a
material compatible with the cargoes carried. To minimize the risk of cargo leakage, all joints - except those to valves
or expansion pieces must be welded.
Part C addressed the construction and equipment of ships carrying liquefied gases in bulk, and
refers for technical detail to the mandatory International Gas Carrier (IGC) Code.
The philosophy of the IGC Code is similar to that of the IBC Code insofar as it is one of ship types related to the
hazards of the products covered by the Code. Each of the products may have one or more hazard properties which
include flammability, toxicity, corrosivity and reactivity. A further possible hazard may arise due to the products being
transported under cryogenic or pressure conditions.
The IGC Code is therefore not now analyzed in depth as was the IBC Code in the foregoing.
NAVIGATIONAL AIDS, LIGHT AND SOUND SIGNALS
The navigational hardware together with operational requirements, all with the objective of providing for safe
navigation of ships and the avoidance of collisions and grounding (as per the regulatory strategy at Section 3(8)), are
regulated in Chapter V of SOLAS 74 and Amendments thereto, “Safety of navigation”. As previously mentioned,
unless otherwise expressly provided, this chapter applies to all ships on all voyages, except ships of war. A further
exception is for ships solely navigating the Great Lakes of North America and their connecting and tributary waters
as far east as the lower exit of the St Lambeth Lock at Montreal in the Province of Quebec, Canada.
Hardware requirements include regulations for compass, radar, automatic radar plotting aids, rudder angle
indicators, rate-of-turn indicators and radio direction-finding apparatus. The regulations also provide for pilot
transfer arrangements.

20
Further regulations with a view to collision avoidance are contained in the Convention on the International
Regulations for Preventing Collisions at Sea, 1972 (COLREGS 72). This contains hardware regulations for lights and
shapes, also sound and light signals.
FIRE PROTECTION, FIRE DETECTION AND FIRE EXTINCTION
The regulations are provided in Chapter II-2 of SOLAS 74 and compliance will satisfy the regulatory strategy as per
section 3(9), (10), (11), (12), (13) and (14). The regulations recognize that absolute fire prevention is not possible.
However they seek to protect lesser fire hazardous spaces from higher fire hazardous spaces by the provision of fire
protection divisions. In this way, for example, accommodation is protected from the high fire hazardous engine room
and in the event of flammable cargoes being carried, the cargo area. In addition to the provision of fire protection
divisions in this respect the regulations also require that the flammable atmosphere in the cargo tanks of oil tankers
over a certain size, be inerted. Exhaust gas from the ships essential engineering system is utilised for this purpose.
Fire protection divisions are also required such as to contain any outbreak of fire within a
sufficiently small space, such that given early detection, it can be successfully extinguished.
To further facilitate this basic philosophy, the regulations also require the provision of fire detection systems and
means of fire extinction.
The primary fire extinction system is the fire main, which is required to extend throughout the
ship, thus making use of a ship’s only fire fighting advantage, that of an inexhaustible supply of water. Hydrants are
required together with hoses, such that two jets of water may be directed into any normally accessible part of the
ship. Pumps to drive the fire main will usually be provided in the engine room. Thus, to provide for a situation in
which a fire may occur in the engine room, rendering these pumps inoperable, an emergency fire pump is required,
situated in a separate location.
A valve is to be provided in the fire main, outside the engine room, so that the fire main system inside the engine
room, which may also be rendered ineffective in the event of an engine room fire, may be isolated from the remainder
of the system. Thus, the emergency fire pump must be able to supply the fire main system independently of the main
fire pumps and fire main piping situated in the engine room.
Additional to the requirement for a fire main, the regulations also provide for portable fire extinguishers and fixed
extinguishing systems in engine rooms, cargo pump rooms, accommodation and in cargo spaces or cargo areas.
The extinguishing medium in fixed systems in engine and cargo pump rooms may be gas, high
expansion foam or water (pressure water spray). Low expansion foam systems may be provided in addition
to any of these. In dry cargo spaces, intended for flammable cargoes, fixed gas systems are specified. It should be
noted that in respect of gas systems, with a view to reducing air pollution, new installations of halogenated gas
systems are prohibited.
In cargo areas of oil tankers (carrying oil with a low flash point), fixed low expansion foam
systems are required. This is also a requirement of the Bulk Chemical and International Bulk Chemical Codes for
chemical tankers, but if chemical cargoes are carried which are miscible with water, such as alcohols, then the foam
media provided should be alcohol resistant. Also, in such cases, dry chemical powder systems may be provided as
an alternative. Water spray is also permitted as an alternative for certain cargoes.
For liquefied gas carriers, the Gas Carrier and International Gas Carrier Codes require that a
water spray system be provided in the cargo area, for cooling, fire prevention and crew protection. Dry
chemical powder systems are required for fire extinguishing purposes.

21
Fixed fire extinguishing systems in crew and passenger accommodation are of the automatic water sprinkler type,
installed in association with fire detection and fire alarm systems.
Finally, with respect to the fire protection detection and extinction requirements of SOLAS Chapter II-2, it is of
interest to note the following basic principles stated therein as underlying the regulations in that chapter, having
regard to the type of ships and the potential fire hazard involved:
1. division of ship into main vertical zones by thermal and structural boundaries;
2. separation of accommodation spaces from the remainder of the ship by thermal and structural boundaries;
3. restricted use of combustible materials;
4. detection of any fire in the zone of origin;
5. containment and extinction of any fire in the space of origin;
6. protection of means of escape or access for fire fighting
7. ready availability of fire-extinguishing appliances;
8. minimization of possibility of ignition of flammable cargo vapour.
It should also be noted that the problem of engine room fires caused by oil fuel leakage onto hot surfaces is addressed
as SOLAS amendment, reg. 15- 2.9 to 2.12, Chapter II-1. The amendment will be applicable to ships the keels of
which are laid or at a similar stage of construction on or after 1 July 1998, and all ship types to which the Convention
applies, and requires that fuel delivery lines and adjacent hot surfaces are to be jacketed and protected to contain
leakages and prevent oil spraying onto hot surfaces or other sources of ignition. Existing ships built before 1 July
1998 are to comply with the regulations not later than 1 July 2003, with some alternative arrangements for engines
of 375kW and below.
RADIO EQUIPMENT
The regulations are contained in Chapter IV of SOLAS 74 as amended “Radiocommunications” and, as previously
mentioned, are applicable to all ships to which SOLAS 74 applies and to cargo ships of 300 gross tonnage and
upwards. However, it does not apply to ships to which the present regulations would otherwise apply while such
ships are being navigated within the Great Lakes of North America and their connecting and tributary waters as far
east as the lower exit of the St Lambert Lock at Montreal in the Province of Quebec, Canada. This is because such
ships are subject to special requirements relative to radio for safety purposes, as contained in the relevant agreement
between Canada and the United States of America.
The principal requirement is for the provision of shipboard equipment to enable ship-to-ship and ship-to-shore
communications under a system known as the “Global Maritime Distress and Safety System” (GMDSS). This system
reflects the latest technological developments in satellite communication, making it possible for a ship to make
distress calls direct to nearby shipping and to shore-based rescue coordination centres, using both manual and
automated systems. The Shore base, on receipt of a distress call, is able to send advice to the ship and others as
necessary in its vicinity. GMDSS also provides for the dissemination of marine safety information including
navigational and meteorological warnings.
In general, GMDSS enables any ship irrespective of the area in which it operates, to perform those communication
functions considered essential to the safety of the ship itself and other ships operating in the same area.

22
The regulations take full cognizance of the regulatory strategy at Section 3(15).
LIFEBOATS, LIFERAFTS, LIFEJACKETS AND OTHER LIFESAVING APPLIANCES
The regulations are contained in Chapter III of SOLAS 74 and provide for abandonment of a stricken ship whilst
avoiding the danger of hypothermia in so doing (the so called “dry-shod” principle), thus taking into account the
regulatory strategy at Section 3(16). The “dry-shod” requirements were introduced in the 1983 amendments to
SOLAS 74.
Lifeboats on cargo ships are required to be totally enclosed, self-righting and either fire
retardant or non-combustible. However when the ship is operating in favourable climatic conditions and in
suitable areas, partially enclosed, self-righting lifeboats are permissible. On chemical tankers and liquefied gas
carriers carrying cargoes emitting toxic vapours, the lifeboats must be totally enclosed, self-righting, fire retardant
or non-combustible, and fitted with a self contained air support system. On oil tankers, chemical tankers and liquefied
gas carriers carrying low flash point cargoes, the lifeboats must be totally enclosed, self-righting, fire retardant or
non-combustible, fitted with a self contained air support system and a fire protection system (external water spray).
All cargo ships are required to carry a rescue boat, the primary purpose of which is for “man-
overboard” rescues. Means are therefore to be provided for recovering rapidly a rescue boat from the sea. Such
rapid recovery is not required for lifeboats, the purpose of which is to take people off the ship and not onto it. A
rescue boat is also used to marshall survival craft (i.e. lifeboats and liferafts).
Liferafts are required as a back-up to lifeboats on smaller ships and, in some smaller ships are allowed in lieu of
lifeboats.
Lifeboat davits are to be capable of turning out against an adverse heel of 20° and a trim of 10°, with the boat
having been fully boarded in the stowed position; or, in the case of oil tankers, chemical tankers and liquefied gas
carriers, an adverse list greater than 20°, if found necessary on completion of deterministic damage stability
calculations carried out in accordance with MARPOL 73/78 Annex 1, the International Bulk Chemical Code or the
International Gas Code. The launching mechanism is to be such that it may be controlled by one person from a
position on the ship’s deck, and from a position within the boat.
Davits of this type are not required for a totally enclosed free-fall lifeboat, which is simply restrained in the stowed
position at the top of a ramp situated at the aft end. When released, the boat slides down the ramp, the angle of
which is normally 30°, and continues in free fall over the aft end, into the sea. The free-fall launch rapidly clears the
ship and is almost unaffected by heel and trim whereas a conventional launch, using conventional davits and falls,
poses problems when the ship is listing, heaving and rolling. Free-fall may be uncomfortable, but it is the surest and
quickest way to leave a stricken ship.
The regulations do not demand the provision of free-fall lifeboats, but allow for choice between free-fall and
conventionally launched boats.
Lifebuoys are required, primarily to assist in “man-overboard” situations.
Lifejackets are to be provided for every person on board, and retro-reflective tape is required on all lifeboats,
liferafts, lifebuoys and lifejackets.
Immersion suits and thermal protective aids are required, the actual number to be provided being dependent on
several variables. An immersion suit is intended to enable the wearer to survive when immersed in a cold sea, e.g.

23
when rescuing some one from the sea. A thermal protective aid is a lightweight waterproof garment intended to
conserve body heat and be worn by persons suffering from exposure to cold temperatures, e.g. a person recovered
from the sea.
Training and maintenance is of vital importance. The regulations require abandon ship training and drills, including
practice musters and fire drills. Operational readiness, maintenance and inspections, including weekly and monthly
inspections of life-saving appliances, servicing of inflatable liferafts, lifejackets, rescue boats and hydrostatic release
units, are also stipulated.
Although the foregoing summarises the regulations for cargo ships only, those for passenger ships follow the same
philosophy, but take into account that passengers are not trained seamen, and will include elderly people and
children. Also because of the generally larger capacity and size of lifeboats on passenger ships as compared to those
on cargo ships, partially enclosed lifeboats are permitted. Another reason for this is that for many passengers,
embarkation into a partially enclosed lifeboat is also faster and easier than into a totally enclosed lifeboat. Free-fall
lifeboats are not permitted on passenger ships.
POLLUTION PREVENTION ARRANGEMENTS AND EQUIPMENT
The regulations are contained in MARPOL 73/78 and provide means of preventing pollution of the marine
environment as per the regulatory strategy at Section 3(17).
Annex I of MARPOL 73/78 is mandatory and is entitled “Regulations for the Prevention of
Pollution by Oil”. Annex 1 is based on the principle that oil and water do not mix and are therefore easily
separated. It contains requirements regarding the operation, construction and equipment of ships. The operational
requirements stipulate the conditions under which ships may discharge water/oil mixtures into the sea. Overboard
discharges are to be above the water line so that discharges are visible. The construction and equipment
requirements are such as to enable the ship’s personnel to comply with the discharge conditions. Other construction
requirements are such as to minimise the chances of oil cargo tank penetration in the event of damage, i.e. double
hull construction and protective location of segregated ballast tanks. Requirements for minimising oil pollution from
oil tankers in the event of side and/or bottom damages penetrating the cargo oil tanks are also included.
Annex II of MARPOL 73/78 is also mandatory and is entitled “Regulations for the Control of
Pollution by Noxious Liquid Substances in Bulk”. Unlike oil, most chemicals or noxious liquids will mix with
water and are not easily separated from it. The main principle of Annex II is to dilute cargo residues in sea water to
prescribed limits depending on their pollution hazard and facilitate the distribution of discharges by utilising the wake
of the ship. The discharges are required to be made below the water line and in such a way that the water/residue
mixture is retained in the ship’s boundary layer and carried aft when en route to be distributed by the wake astern.
Annex III of MARPOL 73/78 is entitled “Regulation for the Prevention of Pollution by Harmful
Substances Carried by Sea in Packaged Forms, or in Freight Containers, Portable Tanks or Road
and Rail Wagons”. The regulations are to be implemented through the International Maritime Dangerous Goods
Code. The Regulations are operational only and there are no requirements for surveys and certification.
Annex IV of MARPOL 73/78 is entitled “Regulations for the Prevention of Pollution by Sewage
from Ships.” This Annex is not yet in force, the entry into force conditions not yet having been satisfied. The
regulations contain requirements for surveys and certification of sewage systems and impose operational restrictions
regarding sewage discharge.

24
Annex V of MARPOL 73/78 is entitled “Regulations for the Prevention of Pollution by Garbage
from Ships”. They are operational only and there are no requirements for surveys and certification.
Annex VI of MARPOL 73/78 is entitled “Regulations for the Prevention of Air Pollution from
Ships”, but is not yet in force. The target date for entry into force is 31 December 2003. If the conditions for
entry into force have not been met by 31 December 2002, the situation will be reviewed urgently by the Marine
Environment Protection Committee (MEPC) at IMO. The regulations limit discharges into the atmosphere of volatile
organic compounds from tanker cargoes, sulphur oxide from the combustion of fuel oils and nitrogen oxide from diesel
engines. With regard to ozone depleting substances, deliberate discharge is prohibited. New installations which
contain ozone depleting substances are prohibited on all ships, except that new installations containing
hydrochlorofluorocarbons are permitted until 1 January, 2020.
STANDARDS OF TRAINING, WATCHKEEPING AND CERTIFICATION
The latest requirements are laid down in STCW 95, and give IMO a participation in the implementation of the required
standards. This will entail the identification of Administrations that have demonstrated their full compliance with the
provisions of STCW 95. The intention is that IMO will establish a list of such Administrations, to be known as the
“White List”. Any Administration not on the “White List” will thus be easily identified as not having complied with
STCW 95 in providing a satisfactory training for seafarers, and any Certificates of Competency issued by it will
therefore not be valid. STCW 95 entered into force on 1st February 1997. Administrations must submit evidence to
IMO that they are implementing the new rules for new trainees by 1 August 1998. It will come into full effect on 1
February 2002, by which time Administrations must have phased in all the new certificates of competency
requirements.
STCW 95 certification will evidence competency of ship personnel to operate efficiently and maintain satisfactorily
the ship, its safety systems and environment protection systems, as per the regulatory strategy at Section 3(18).
SAFETY MANAGEMENT
The International Safety Management (ISM) Code is given Convention status by inclusion in Chapter IX -
“Management for the safe operation of ships” of SOLAS 74, and entered into force on 1 July 1998.
It is applicable to ships, regardless of the date of construction, as follows:
1. passenger ships including passenger high-speed craft, not later than 1 July 1998;
2. oil tankers, chemical tankers, gas carriers, bulk carriers and cargo high-speed craft of 500 gross tonnage and
upwards, not later than 1 July 1998; and
3. other cargo ships and mobile offshore drilling units of 500 gross tonnage and upwards, not later than 1 July 2002.
It does not apply to government-operated ships used for non-commercial purposes.
The Code requires that each Company be issued with a Document of Compliance (DOC) and each
ship with a Safety Management Certificate (SMC) (“Company” means the Owner of the Ship or any other
organization or person such as the Manager, or the Bareboat Charterer, who has assumed the responsibility for
operation of the ship from the Shipowner and who on assuming such responsibility has agreed to take over all the duties
and responsibility imposed by the Code.) It requires each Company to apply a Safety Management System
(SMS) to the ships it operates, the contents of which will be affected by company Commitment, values and beliefs.

25
The impact of the ISM Code, when fully implemented, will be that Owners/Operators will focus more effectively on
safety matters. It may be anticipated that this will result in more efficient operation and satisfactory maintenance of
ships, their safety systems and environment protection systems as per the regulatory strategy at Section 3(19).
PORT STATE CONTROL
Recognising that Classification surveys and Statutory surveys for which the Flag Administration is responsible are
carried out on an annual basis and that without satisfactory maintenance of the ship, its systems and equipment in
the intervals between such surveys, severe deterioration can take place, regulation 19 of Chapter I, SOLAS 74,
requires that every ship when in a foreign port be subject to control by officers of that port. Such control is usually
exerted on a percentage of ships in the port by means of Port State Control (PSC) inspections. PSC inspections
provide a further authoritative check on the condition of the ship, its systems and equipment during the intervals
between Classification Surveys and Statutory surveys for which the Flag Administration is responsible. Thus further
cognizance is taken of the regulatory strategy at section 3(20).
TONNAGE COMPUTATION
Before a ship can be registered with a signatory to the 1969 Tonnage Convention, it must be measured in accordance
with the regulations of that Convention. The Convention consists of only seven regulations for establishing the gross
and net tonnages of a ship. In addition to the resultant tonnages being necessary for identification of ships when
registered, they are also used for the charging of port dues, but more importantly from the regulatory regime point
of view, gross tonnage is used in imposing size limitations in SOLAS 74 and MARPOL 73/78. For example a dry cargo
ship of 499 gross tonnage on international voyages would have to comply with Chapter IV (Radio Communications)
and Chapter V (Safety of Navigation) only of SOLAS 74. It would also have to comply with requirements of the 1966
Load Line Convention (being in excess of 24 metres in length) and MARPOL 73/78 Annexes I, III, V and when entered
into force, IV.

26
5. CONCLUSION

The paper has attempted to explain and summarize the regulatory regime. It has attempted to show how the
regulatory regime has been established on the basis of a regulatory strategy formulated by the Author to take account
of the perceived hazards encountered by a ship at sea, and the hazards imposed by the ship on the marine
environment. Thus the regulatory regime has been shown to address fully the perceived hazards.
The paper explains how the regulatory regime is comprised of Classification rules for ship structures and essential
engineering systems and the applicable regulations of the various International Conventions made collectively by the
Governments of the world, under the auspices of IMO. It further explains that compliance with the classification rules
is necessary to facilitate the issuance of some certificates required by the International Conventions, thus
establishing an essential relationship between the Classification Societies and IMO.
The paper acknowledges that the regulatory regime is prescriptive, but explains how it gives ample scope to a ship
designer to demonstrate equivalence.
In contemplating change from the prescriptive nature of the regulatory regime, it should be understood that for the
great majority of routine shipbuilding they represent the only practicable form of rules and regulations for the world’s
shipbuilders. This is a fundamental issue when considering the replacement of the present regulatory regime with
one based on formal safety assessment. It is important to understand the basic nature of the marine industry when
considering the practicality of formal safety assessment of ship design to demonstrate compliance with target setting
or functional requirements in a regulatory regime.
Ships are built to carry a wide diversity of cargoes on a wide diversity of trading routes using a wide diversity of
trading ports and rivers with varying facilities and draughts. The result is many different ship types (designed for
particular cargoes) and sizes (designed for a particular route and the physical constraints of the envisaged trading
ports). The building of ships in large series is rare. Ship operators order a ship or ships when they feel best able to
exploit an identified market, and require delivery as quickly as possible, typically less than eighteen months from
inception. Thus marine transport differs from air, automotive and rail transport in respect of this wide diversity and
the consequences of it. The practical difficulties in achieving compliance with a target setting or functional regulatory
regime by the application of formal safety assessment techniques taking into account the human element, whilst at
the same time achieving a consistent and uniform level of safety internationally, are enormous.
Although the subject of Formal Safety Assessment and the Human Element is under close scrutiny by the Maritime
Safety Committee at IMO (with the enthusiastic support of IACS Members who are also studying the subject closely),
the first objective is to promulgate its future use in the regulatory process. That is, to assist in deciding whether a
particular contemplated regulation should be formulated and, if so, to what extent. Thus a prescriptive regulation
would be produced on the basis of a formal safety assessment, taking into account the Human Element. Although
this is a very neat merger of the two systems, it is at this time only in a very early stage of development.
Also, it should be recognized that , world wide application of formal safety assessment techniques by numerous
national administrations, to designs of a large number of ships varying in type and size and with dissimilar hazards,
is a much more complex problem.

27
It is not the intention of this paper to advocate permanent retention of the present regulatory regime, but rather to
explain it and highlight the essential problems in changing it. With a clear understanding of these issues steady and
worthwhile progress may be made. Without it, it will not.
REFERENCES
1. Member societies of the International Association of Classification Societies (IACS) are:
American Bureau of Shipping
Bureau Veritas
China Classification Society
Det Norske Veritas
Germanischer Lloyd
Korean Register of Shipping
Lloyd’s Register of Shipping
Nippon Kaiji Kyokai
Registro Italiano Navale
Russian Maritime Register of Shipping
Associates: Hrvatski Registar Brodova (Croatian Register of Shipping)
Indian Register of Shipping
Polski Rejester Statkow

28
ORIGINS AND DEVELOPMENT OF CLASSIFICATION:
THE BEGINNING
Started to verify and “class” the condition and seaworthiness of merchantmen for insurers and charterers, the origins of
classification can be traced to London in 1760.
That year saw the foundation of “the Register’s Society” - predecessor of Lloyd’s Register - although the gathering and exchange
of shipping information for merchants began about 70 years earlier in Lloyd's coffee house, located in modern Great Tower Street.
Similarly, the focus on printed shipping news began with the founding of Lloyd’s List, in 1734.
The first shipping “Register” was published in 1764, detailing vessel ownership, characteristics and condition - but based on
unstated (and differing) standards of the earliest surveyors. At this time, “class” was judged purely on vessel age - “first class”
being a notation only valid for the first eight years in the life of many ships.
Underwriters secured their information through subscription to the early registers, though after the creation of LR in 1834 it
became custom and practice for shipowners to pay for class surveys.
SOCIETY ORIGINS
Of the modern societies, BV was the first, founded in Antwerp in 1829, but based in Paris from 1832. The intention was: “to be
of use of all maritime professions including shipowners, charterers and mariners - but above all to the insurers…particularly by
preserving them from the underwriting risks of bad ships”.
Two British registers joined forces to create Lloyd’s Register in 1834; Italy’s RINA dates from 1861 and ABS traces its
origins back to 1862. Adoption of common rules for ship construction by Norwegian insurance societies in the late 1850s led to
establishment of DNV in 1864. GL was formed in 1867 and Class NK in 1899.
RULES AND STANDARDS
The safety relationship between freeboard and draught was first written in a Lloyd's Rule of 1835. However, it was 1883 before
Samuel Plimsoll was instrumental in passing the UK Merchant Shipping Act, in which class rules became the basis of compliance
with a Flag State’s power (through the then Board of Trade) to detain overloaded ships as unseaworthy.
Arguably the origin of today’s Port State Control, this marked a turning point in maritime safety, based in essence on rules developed
by a classification society.
The intervening 50 years had seen dramatic transition from wood and sail to iron, steam and steel. With the first rules for iron hulls,
in 1853, vessel age first gave way to structural integrity as the basis of classification. The first in-works examination of production
steel took place in 1855, while classification of propulsion machinery began in 1880. Class rules for steel ships were first drafted
in 1888, and rules for oil-fired ships followed in 1898 - just a year after the first steam turbines went to sea.
Classification has traditionally been based on what is now known as the feedback loop. From the earliest days of the modern
societies, the process developed whereby plans were examined and approved; ships were surveyed through construction, class was
granted and certificates issued. Ships were surveyed for as long as their life within the Register. Data on ship operation and in-
service experience flowed back to each Society’s Head Office. The vast amount of experience gained enabled the lessons learned
to be built into new designs and new ships - with continual improvement in strength and safety.
ORIGINS OF IACS
IACS can trace its history back to the LoadLine Convention of 1930 and its British-based recommendations. The Convention
recommended collaboration between classification societies to secure: “as much uniformity as possible in the application of the
standards of strength upon which freeboard is based…”
Following the Convention, RINA hosted the first conference of major societies in 1939 - also attended by ABS, BV, DNV, GL, LR and
Class NK - which agreed on further co-operation between the societies.
Although the first international maritime conference was held in 1889, technical regulation within international shipping safety did
not come to the fore until the establishment in 1948 of IMO's predecessor, the International Maritime Consultative Organisation
(IMCO). Since then, class rules have become increasingly prominent as the recognised technical basis of structural ship safety.
The second major class society conference, held in 1955, led to creation of Working Parties on specific topics, with the first - on
hull structural steel, in 1957 - laying the foundations for more than 200 Unified Requirements, numerous Unified Interpretations
and Guidelines that IACS has today.
UNIQUE KNOWLEDGE
IACS was formed by the seven leading class societies in 1968. The value of their combined and unique level of classification
knowledge and experience in contributing to maritime safety and its regulatory regime was quickly recognised. In 1969, IACS was
accordingly given consultative status with the IMO. It remains the only non-governmental organisation with Observer status which
is able to develop and apply structural rules.
 Dedicated to safe ships and clean seas,
IACS makes a unique contribution to maritime safety
and regulation through technical support, compliance
verification and research and development.

More than 90% of the worldÕs cargo carrying tonnage

is covered by the classification design, construction
and through-life compliance rules and standards set
by the 10 Member Societies and three Associates of IACS.

IACS
INTERNATIONAL ASSOCIATION OF CLASSIFICATION SOCIETIES LTD.

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