Application of MSC 1/ Circ. 1352
DNV GL has recently issued regulatory update on the application of MSC.1/CIRC.1352 (CSS Code Annex 14) for container vessels and other vessels equipped for carriage of containers.
The amendment to the Code of Safe Practice for Cargo Stowage and Securing (CSS Code) Annex 14, Guidance on Providing Safe Working Conditions for Securing of Containers on Deck, as set out in the annex of MSC.1/Circ.1352, was approved by the IMO in 2010 and revised in 2014 (MSC.1/ Circ.1352/Rev.1).
Ships keel-laid on or after 1 January 2015: The IMO has not made the application of MSC.1/Circ.1352 mandatory, but it encourages ship owners, ship operators, shipmasters and crew to apply the annex in its entirety to container vessels and vessels equipped for carriage of containers. DNV GL intends to applyall the amendments in the annex to these vessels, which will then be given the class notation SafeLash in accordance with the upcoming DNV GL joint rule set.
Ships keel-laid before 1 January 2015 are, through MSC.1/ Circ.1352, encouraged to apply sections 4.4, 7.1, 7.3 and 8, and to apply the principles in sections 6 and 7.2 so far as practical, on the understanding that existing ships will not be required to be enlarged or undergo other major structural modifications. For ships keel-laid before 1 January 2015, DNV GL will implement the applicable sections as instructed by the flag administration.
RELEVANT DNV GL VESSELS
- 100 A5 vessels of the ship type container ship and other ship types with the additional class notation Equipped for Carriage of Containers
- 1A1 vessel of the ship type container ship and other ship types with the additional class notation Container.
FLAG STATE REQUIREMENTS
As of January 2015, the flag state administrations of Cyprus, Germany, Malta and the United Kingdom have issued circulars/ notes making MSC.1/Circ.1352 mandatory for container vessels and vessels equipped for the carriage of containers that sail under their flags. Please note that flag state administrations may interpret the requirements differently and this will be reflected in the implementation for the relevant ships.
ACTIONS
Container vessels in DNV GL class that were keel-laid before 1 January 2015 and sail under a flag that has made MSC.1/ Circ.1352, or parts of it, mandatory, will be addressed as follows: for 1A1 vessel, a Retroactive Requirement, RR Ref 1048, will be issued (see information below). For 100 A5 vessels currently in DNV GLs Fleet Online, a Special Requirement with a similar function and the same content as RR Ref 1048 will be issued. The Special Requirement will be replaced by RR Ref 1048 when the vessel is transferred to the new My DNV GL portal.
Sections 4.4, 7.1 and 7.3 of Annex 14, as described in the RR/ Special Requirement information stated below, are the responsibility of the ship owner/manager, while the DNV GL surveyor will perform an assessment of sections 8, 6 and 7.2 in so far as practical during the first safety construction survey. A Statement of Compliance will be issued in connection with the assessment.
ADDITIONAL INFORMATION
From 1 January 2015, owners shall be aware of the following risks relating to ships not in compliance with CSS Code Annex 14:
- Ships may be refused to call at ports where port state authorities require compliance with CSS Code Annex 14
- Ships may be subject to structural alterations in order to be in compliance with CSS Code Annex 14 when changing flag.
In order to avoid the above risks, owners of vessels sailing under flags that have not made CSS Code Annex 14 mandatory are strongly advised to contact DNV GL for an assessment and, if necessary, alterations and documentation of compliance.
You can read the Statutory Update issued by DNV GL by clicking here.
Source and Image Credit: DNV GL
