Bulk Carrier Safety

Interpretations of SOLAS Chapter XII

Pursuant to several tasks contained in the 1997 SOLAS Conference resolutions, the
MSC issued resolution MSC.79(70) which urges Member States to apply the following
clarifications concerning the application of SOLAS Chapter XII to bulk carriers. 4.18

Length limit - the lower length limit of 150m, to which SOLAS Chapter XII applies,
should not be lowered unless indicated otherwise by a formal safety assessment
scheduled to be carried out in the next 18 months. The MSC noted IACS position that
bulk carriers less than 150m would meet the strength requirements, but that
considerable difficulty can be expected in complying with flooding stability
requirements.

Bulk carrier definition - The resolution reiterates the definition of bulk carrier as per
SOLAS Conference Resolution 6 and thus removes ambiguities in the SOLAS
Chapter XII definition of bulk carrier, which is the same as the ISM Code definition as
per SOLAS regulation IX/1.6. To determine if a ship is a bulk carrier under the ISM
Code and the safety requirements for bulk carriers under SOLAS Chapter XII, a "bulk
carrier" means a ship constructed with a single deck, top side tanks and hopper side
tanks in cargo spaces and intended to primarily carry dry cargo in bulk; an ore carrier;
or a combination carrier. Also, recognizing that the accepted legal format of most
SOLAS certificates do not indicate the specific type of ship, the resolution indicates
that the certificated identification of ship type is as it appears on the ISM Code Safety
Management Certificate.

Double sides - Recognizing the reduced probability of water ingress due to shell
cracks, corrosion and low energy impact damage when cargo holds are protected
from the sea by double sides, the MSC is endeavoring to set a minimum distance in
order for a double sided bulk carrier to be exempt from the single side skin
requirements of SOLAS Chapter XII. However, this session of MSC could not agree
on the minimum distance separating the cargo hold from the side shell. One proposal
that was discussed proposed a distance of 760mm for existing bulk carriers built
before 1 July 1999 and 1.0m for bulk carriers built after that date. This matter is
scheduled to be finalized at MSC 71 in May 1999. In order to preserve the reduced
risk of flooding afforded by double sides, the minimum distance should allow for
effective access and inspection of the side structure.

Exemptions - Bulk carriers, arranged with an insufficient number of` bulkheads

necessary to meet the stability and structural survivability requirements under the
provisions of regulations XII/4 and 6, may be exempted from those requirements.
However, the resolution clarifies that eligibility for this exemption becomes void if the
ship has been modified thereby reducing the number of transverse watertight
bulkheads.

Cargo density - It was agreed that on/after 1 July 1999, the declaration of solid bulk
cargo density, when between 1250 to 1780 kg/m3, must be verified by an accredited
testing organization. This would apply to such cargoes being carried by existing bulk
carriers built before 1 July 1999, unless the ship fully complies with SOLAS Chapter
XII for bulk carriers carrying cargoes with densities of 1780 kg/m3 and above. Also, it
was agreed in principle - subject to discussion at MSC 71 in May 1999 - that bulk
carriers, carrying break bulk cargoes with stowage factors of 0.56 m3/ton or less,
should be subject to the provisions of SOLAS Chapter XII.

Seakeeping Assessment

The United Kingdom and Greece presented the results of their qualitative and
quantitative analyses and computer simulations carried out to determine the
sensitivity of the seakeeping performance of bulk carriers in extreme seastates. The
U.K. research presents relationships between the susceptibility of deck wetness and
deck loads for varying physical aspects, focsle configuration and magnitude of bow
height, shape and flare for the 160,000 dwt OBO "Derbyshire".

Although having a different objective than the U.K. research, the Greek research
focused on the effects of operational measures such as speed, heading and weather
routeing. The research aimed to establish optimal weather routeing (speed and
heading) by identifying minimum possible wave induced motions, loads and deck
wetness.

By carrying out a parametric analysis for varying headings, speed and wave period
and spectral distributions, predictions and trends similar to the U.K.'s work were
concluded for 4 different sizes of typical bulk carriers, albeit for a different purpose.

Recognizing the areas where there were corroborating results and considering the
impact of operational parameters on seakeeping performance, the MSC agreed that
further work in evaluating risks associated with bulk carriers should be performed and
that the physical aspects (bow height) and operational aspects (speed and heading)
should be jointly considered.

IACS presented the results of its analysis which was used to develop an IACS Unified
Requirement on the design loads for the fore end hatch covers. The IACS design
loads, applicable to ships built after 1 July 1998, are significantly larger than the loads
required by the 1966 Load Line Convention as illustrated below.

After reviewing and discussing the above analyses, the MSC instructed its SLF Sub-
Committee to further consider the adequacy of the current regulations relative to:
      - hatch cover/coaming strength;
      - bow height; - reserve buoyancy;
      - mitigation of forward structural loads; and
      - protection of crew access to the bow.

Future sessions of the MSC will consider for new and existing bulk carriers, after
completion of the Formal Safety Assessment (FSA) and the IACS hazard
identification study (see below), the following issues:
      - loss of steering and the degree of redundancy considering casualty statistics;
      - tank sounding/bilge alarms and emergency pumping;
      - additional training measures, particularly for operation in extreme weather
conditions; and
      - free-fall life boat capabilities;

FSA and HAZID Studies

The MSC endorsed the U.K.'s proposal for a collaborative formal safety assessment
study of bulk carriers by Administrations and industry organizations outside the
confines of IMO. In light of concerns expressed relative to the broad scope, manner of
conduct and prioritization of safety issues of the proposed study, the MSC
recommended that the FSA study consider human element aspects as per IMO's
draft guidelines and be conducted in accordance with IMO's FSA Interim Guidelines.

IACS is undertaking a hazard identification study on the watertight integrity of the fore
end structure of bulk carriers. Scheduled to be completed by May 1999 for MSC 71,
the study will evaluate the potential hazards, their causes and consequences.
Aspects to be addressed will be the design and operation of closures and systems
serving cargo holds and tanks in the fore end of bulk carriers including hatchcovers,
airpipes, ventilation trunks, bilge alarms and sounding and emergency pumping
systems. Influence of the human element on the effectiveness of the above systems
and closures will also be considered.

( + Note: All "ships" are all self propelled vessels)

For further information concerning the above information, please

contact ABS Regulatory Affairs Department at telephone (212) 839
5059, by fax (212) 839 5214, or by email Regulatoryaffairs@eagle.org.

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