1st January of 2020 marks the beginning for many regulatory updates for shipping. One of them is the new IMO requirements for the maintenance, examination, operational testing, overhaul and repair of lifeboats and rescue boats; the following article outlines key changes to assist operators in effective compliance with new requirements.
Maintenance of life-saving appliances: Key Amendments
Amendments on life saving appliances were adopted during the 96th session of IMO’s Maritime Safety Committee (MSC 96) in May 2016, introducing that maintenance, thorough examination, operational testing overhaul and repair of the following must be performed by authorized service providers:
- Lifeboats, rescue boats and fast rescue boats;
- Launching appliances and on-load and off-load release gear for lifeboats, rescue boats, fast rescue boats and davit-launched life rafts.
Inspection requirements
In order to ensure the proper operation of the equipment, the recent amendments set out that the following inspection intervals should be carried out:
- Weekly and monthly inspections must be conducted by authorized service providers, or by shipboard personnel under the direction of a senior ship’s officer in accordance with the maintenance manual(s);
- Annual thorough examinations and operational tests must be conducted by certified personnel from either the manufacturer or an authorized service provider. The service provider may be the ship operator, provided they are authorized;
- A five-yearly thorough examination, any overhaul, overload operational tests and repairs must be conducted by certified personnel from either the manufacturer or an authorized service provider.
Authorized service providers
An authorized service provider is authorized by the flag administration, with the authorization being limited to each make and type of equipment to be serviced. Flag administrations will grant the authorization document and make sure that information regarding authorized service providers is available.
Authorization shall include, as a minimum, demonstration of:
- Employment and documentation of personnel certified in accordance with a recognized national, international or industry standard as applicable, or a manufacturer’s established certification programme. In either case, the certification programme shall comply with section 8 for each make and type of equipment for which service is to be provided;
- Availability of sufficient tools, and in particular any specialized tools specified in the manufacturer’s instructions, including portable tools as needed for work to be carried out on board ship;
- Access to appropriate parts and accessories as specified for maintenance and repair;
- Availability of the manufacturer’s instructions for repair work involving disassembly or adjustment of on-load release mechanisms and davit winches;
- A documented and certified quality system.
In cases where a manufacturer is no longer in business or no longer provides technical support, the Administration may authorize service providers for the equipment on the basis of prior authorization for the equipment and/or long-term experience and demonstrated expertise as an authorized service provider.
In addition, regarding the issuance and maintenance of authorization document, after successful initial audit of a service provider, an authorization document shall be issued by the Administration describing the scope of services provided, while the expiry date shall be clearly written on the document.
Moreover, the Administration must make sure that work continues, via a periodic audit, to be carried out in accordance with these requirements, and shall withdraw the authorization of service providers who are not complying.
Finally, the Administration may accept or recognize service providers authorized by other Administrations or by their Recognized Organizations.
Education and training
Of course, it is very important that service personnel must be certified by the manufacturer or by an authorized service provider for each type of the equipment to be worked on.
Namely, initial certification must be issued only to personnel having completed education, training and competence assessment. Education shall address, as a minimum:
- Relevant rules and regulations, including international conventions;
- Design and construction of lifeboats (including free-fall lifeboats), rescue boats and fast rescue boats, including on-load release gear and launching appliances; .
- Causes of lifeboat and rescue boat accidents;
- Education and practical training in the procedures specified in section 6 for which certification is sought;
- Detailed procedures for thorough examination, operational testing, repair and overhaul of lifeboat (including free-fall lifeboats), rescue boats and fast rescue boats, launching appliances and on-load release gear, as applicable;
- Procedures for issuing a report of service and statement of fitness for purpose based on paragraph 5.3;
- Work, health and safety issues while conducting activities on board.
In addition, IMO mandates that training shall include practical technical training on thorough examination, operational testing, maintenance, repair and overhaul techniques using the equipment for which the personnel are to be certified.
The technical training shall include disassembly, reassembly, correct operation and adjustment of the equipment. Classroom training shall be supplemented by field experience in the operations for which certification is sought, under the supervision of a certified person
Before the issuance of certification, a competency assessment must be successfully completed, using the equipment for which the personnel are to be certified.
When training and competency assessment are completed, a certificate shall be issued defining the level of qualification and the scope of the. The expiry date must clearly be written on the certificate and shall be three years from the date of issue.
The validity of any certificate shall be suspended in case of any shortfall in performance and only revalidated after a further competency assessment.
Finally, a competency assessment shall be conducted to renew the certification. In cases where refresher training is found necessary, a further assessment must be conducted after completion.
