January 2016 indicates another round of new requirements and amendments to existing rules for the Ship Operator to meet.
Amendments relating to MARPOL Annex 1, requiring means to demonstrate compliance with damage stability regulations should be complied with. Similar amendments have also been made to the BCH Code, IBC Code and IGC Code.
- It is a retrospectively applicable Regulatory Amendment which could have a significant influence on vessel operability if not addressed promptly.
- The cost to resolve may be relatively low (typically $25,000 for an approved system, installed aboard).
The formal approval of any ‘Loading Computer System (LCS)’ stability functions was not mandatory until IACS UR L5 came into force (later echoed by IMO in the 2008 IS Code) and then only for ships contracted for construction after July 2005. But even then, if an LCS was only set up to cover strength aspects this was still acceptable under UR L5.
The new amendments insist tankers to have a Type 3 LCS. This Type 3 LCS means a system which can examine all the damage scenarios required by the applicable Regulations, and confirm compliance. The existing ships also have a LCS which cannot calculate damage stability to the rigour needed for a Type 3 assessment since it follows simple methodologies.
Despite the vast availability of LCS in the market only a handful (such as QinetiQ’s SeaWeigh system) are capable of following an approved Type 3 approach.
To check:
- whether the LCS available onboard the ship is an upgraded one.
- proper advanced warning and proper procurement is made available as the number of suppliers for the type 3 LCS is limited.
- whether the type 3 LCS is recommended so as to avoid complications associated with developing suitable KG/GM limit curves and their potential restriction on operational capacity.
- whether the implementation is phased. It should be based on next renewal survey date rather than date of construction.
Ships should be complied with:
- Each ship in your fleet should get the confirmed status of approval of any existing onboard LCS .
- Efficient LCS onboard. Where an existing LCS system is deficient, the supplier should be approached to explore how this can be corrected.
- When procurement of a new Type 3 LCS system is an option, consider any added benefits. A Type 3 approach requires a 3D model of the vessel, and so can offer operationally useful tools such as accurate draught/deadweight surveys and ullage reporting, trim optimisation and voyage planning.
- The potential benefits of any added value elements should be taken into consideration in the selection process.
QinetiQ are a supplier of a suitable Type 3 LCS solution SeaWeigh, and are able to guide Operators through the process of assessing solutions for their ships. To this aim, QinetiQ have published a White Paper on this issue which includes a handy ‘Do I comply’ chart.
Source: QinetiQ Marine Design Software
