Key requirements for underwater examination and survey

Underwater Examination (UWE) is the inspection of the outside of the ship’s bottom while afloat as part of the Passenger Ship Safety Renewal survey while Underwater Survey (UWS) is the inspection of the outside of the ship’s bottom while afloat in lieu of a dry-docking, including measurements of shaft and rudder bearing clearances, as applicable. The Marshall Islands Ship Registry has issued a revised marine notice to outline the procedures and circumstances by which the underwater examination/survey of a passenger ship’s hull by divers in lieu of drydocking may be permitted.

Why Underwater Examination and Survey are important

Regulation 7(b)(ii) in Chapter I of SOLAS requires the annual inspection of passenger ship structures, including the outside of the ship’s bottom, as part of the annual renewal survey for issuance of a Passenger Ship Safety Certificate (PSSC). The external bottom examination is normally performed with the ship in dry dock. However, it is also recognized that under certain conditions for specific surveys, the external examination of the ship’s bottom may be carried out with the ship afloat.

The Harmonized System of Survey and Certification (HSSC) Guidelines Resolution A.1140(31) specifies that a passenger ship’s bottom inspection as required by SOLAS regulation I/7 should be carried out annually, with two inspections in dry-dock in any five-year period. However, this minimum number of inspections in dry-dock on the outside of the bottom of a passenger ship may be reduced from two to one by allowing an in-water survey in lieu of bottom inspection in dry-dock. International Maritime Organization (IMO) Circular MSC.1/Circ.1348 has guidelines for performing an in-water survey in lieu of a dry-dock examination.

General Procedures

The operator of the ship must make the request to perform an underwater examination in  lieu of drydocking directly to the Recognized Organization (RO) issuing the Passenger Ship Safety certificate on behalf of the Administrator.

The request must contain, as a minimum:

• the proposed schedule and location when the ship will be available for inspection;
• a statement in writing from the Master confirming that the ship has not sustained any grounding or contact damage since the previous bottom inspection; and
• proof of implementation of a comprehensive maintenance regime based upon a five year cycle in accordance with MSC.1/Circ.1348, Guidelines for the Assessment of Technical Provisions for the Performance of an In-Water Survey in Lieu of Bottom Inspection in Dry Dock.

Submission of the application to the RO must be provided at least four weeks in advance of the intended date of inspection.

What applies to all passenger ships

The Administrator recognizes the examination of passenger ships in dry-dock at least twice during any five (5) year period, to coincide with the survey guidelines provided in IMO Resolution A.1140(31). Underwater examinations are to be requested for the three remaining passenger ship safety renewal surveys in accordance with the procedures outlined above.

The interval between the dry-dock surveys must not exceed three years. Therefore, the first bottom survey in dry-dock during any five year period must be scheduled during the second or third year of the five year cycle.

For passenger ships of 15 years of age or less, other than Ro-Ro passenger ships, the Administrator may consider applications to permit one UWS during any five year period. In such cases, the DS must be scheduled so that the interval between dry-dockings does not exceed five years.

Passenger ships of 15 years of age and over must carry out the external bottom survey in dry-dock as required. Such ships may
be evaluated on a case-by-case basis for special consideration.

Key Conditions

• The ship must be constructed to facilitate the UWE and UWS, and be assigned the requisite Class Notation for the same.
• The IMO Guidelines of MSC.1/Circ.1348 are to be applied on a mandatory basis for all passenger ships regardless of age
• All UWEs, UWSs and DSs, must be carried out within the normal renewal survey window of three months before the survey due date, up to the due date.
• If a survey in dry-dock is not completed within this window, the Passenger Ship Safety Certificate will cease to be valid until the survey in dry-dock is completed.