Interpretations launched for keel laid date or similar stage of construction

The US Office of Commercial Vessel Compliance published ‘Determinations for a Vessel’s Keel Laid Date or Similar Stage of Construction.’ The work instruction was updated on September 20, 2019.

This work instruction aims to establish the interpretations of when a vessel’s keel is considered to be laid or the vessel is at a similar stage of construction.

It also provides guidelines for Officers in Charge, Marine Inspection (OCMIs) to determine what may be accepted for the purpose of establishing a vessel’s keel laid date.

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Regulatory applicability may depend on a ship’s keel laid date or a similar stage of construction to establish when a vessel should be considered new or existing, built, or constructed.

The intent of establishing an accurate date to mark the start of a construction project ensures that new requirements are applied to vessels while phasing out vessels built to older standards. Simply placing an undefined structural member in a shipyard without construction plans or the intent to build a specific vessel is not in keeping with the spirit of advancing safer vessel standards.

In addition, once a keel laid date or a similar stage of construction has been established, there should be progress towards completion.

The following criteria may be used to determine the date when a keel is considered to be laid or is at a similar stage of construction:

1. Keel laid to meet the requirements for a new or existing vessel, or the terms built or constructed, as outlined in each respective inspection subchapter. The keel should be a structure adequate for serving as a primary centerline strength member running longitudinally stem to stern along the bottom of a ship around which the hull of the vessel will be built. The keel should be accompanied by verifiably dated structural drawings/plans for a specific vessel identifiable with the keel in question and should not specify a keel length other than the length of the keel that has been laid. Attestation from the shipyard or surveyor noting the keel laying date should be made available to the Marine Inspector;
2. A prefabricated section or first module of a specific vessel’s hull built that is comprised of 50 metric tons or at least one percent of the estimated mass of all structural material, whichever is less, to meet the similar stage of construction requirement under built or constructed. The section or modules should be accompanied by verifiably dated structural drawings/plans for a specific vessel. Attestation from the shipyard or surveyor noting the date the vessel meets the similar stage of construction should be made available to the Marine Inspector;
3. The OCMI may provide the shipyard with the keel laid date determination via correspondence;
4. If the vessel’s structural drawings/plans change at a later date for the purposes of building a different vessel than originally intended, the OCMI may determine that variance is significant enough to reset the keel laid date;
5. Once the keel laid date or a similar stage of construction is established, progressive construction on the identifiable vessel should continue until completion. The time taken to complete construction should be commensurate with typical construction timelines for vessels of similar size, type, and complexity. The OCMI should take into account construction delays that may be associated with factors outside the control of the builder;
6. For vessels that are unable to provide objective evidence of a keel laid date or a similar stage of construction, the OCMI should apply current regulations and requirements to the vessel in so far as reasonable and practical.

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