USCG: How to comply with SOLAS amendments on life-saving appliances

The US Coast Guard issued a new circular providing guidance to the maritime industry and Coast Guard personnel on how vessel owners and operators may comply with amendments to SOLAS Chapter III, Regulation 3 and 20 regarding life-saving appliances, that will enter into force from 1st January 2020.

The Navigation and Vessel Inspection Circular (NVIC) 03-19, “Maintenance, Thorough Examination, Operational Testing, Overhaul And Repair Of Lifeboats And Rescue Boats, Launching Appliances And Release Gear” dated Nov. 20, 2019, supersedes and cancels NVIC 04-07.

Amendments on life saving appliances were adopted during the 96th session of IMO’s Maritime Safety Committee (MSC 96) in May 2016, adding specific examinations and tests required for each type of equipment.

SOLAS Regulation III/3 adds the definition for requirements for maintenance, thorough examination, operational testing, overhaul, and repair as meeting the requirements in IMO Resolution MSC.402(96).

Vessel owners and operators, lifesaving equipment manufacturers, servicing and repair facilities, and associated personnel may use NVIC 03-19 to ensure that the servicing and maintenance of lifeboats, rescue boats, release gear, and launching systems for their vessels subject to the requirements of SOLAS are carried out in accordance with SOLAS Chapter III Regulations 3 and 20, and IMO Resolution MSC.402(96).

Authorized Service Providers

• A service provider may be either an original equipment manufacturer or a third party service provider. Some components of lifeboat and launching systems are generally of common and conventional designs for which service and repair do not necessarily require manufacturer-specific expertise.
• A service provider should apply to be an authorized service provider through an ACS. The service provider should provide evidence they are capable of meeting the requirements in Section 7 in Enclosure (2). Upon a successful initial audit of the service provider, the ACS should issue authorization documentation outlining the scope of services provided by the service provider. Once the authorization documentation is issued, the service provider may be considered an Authorized Service Provider (ASP). The ASP should maintain their authorization documentation for the period of validity.
• Paragraph 7.1.1 of Enclosure (2) requires the ASP employ personnel certified to conduct inspection, maintenance, servicing and testing for each make and type of equipment for which the ASP provides service. The Coast Guard’s definitions for make and type are provided in Enclosure (3).
• Where a lifesaving appliance manufacturer believes that a particular model requires certified servicing personnel to have additional competencies, those competencies  should be identified during the equipment approval process and will be listed on the USCG Certificate of Approval for that model.
• The ASP and each certified technician should maintain a record of the scope of their certifications and training as required.
• The ASP should maintain their servicing program records for the duration of the time they are authorized as an ASP. These records should be made available to the Coast Guard or ACS during an audit, as requested.

Vessel Owners and Operators

• The SOLAS amendments in Enclosures (1) and (2) enter into force on January 1, 2020. The requirements in those amendments will be applicable to vessels that are subject to the requirements in SOLAS.
• Enclosures (1) and (2) require the owners and operators of vessels subject to the requirements in SOLAS to use certified personnel of an equipment manufacturer or ASP to carry out the annual thorough examination and operational tests, and the fiveyear thorough examination, overhaul, and overload operational tests. Shipboard personnel or certified personnel of an ASP may conduct the weekly and monthly inspections, and routine maintenance.
• Vessel owners and operators may use an ASP authorized by an ACS, as described in the sections above.
  (a) The Coast Guard maintains a list of ACSs on the Flag State Control Division
  website at https://www.dco.uscg.mil/Our-Organization/Assistant-Commandantfor-Prevention-Policy-CG-5P/Inspections-Compliance-CG-5PC-/CommercialVessel-Compliance/Flag-State-Control-Division/AltComp/.
  (b) ACSs should maintain a list of service providers they authorize.
  (c) Issues involving the unavailability of an equipment manufacturer or ASP will be handled on a case-by-case basis. If the original equipment manufacturer is unavailable and there is no ASP available to conduct the required servicing or testing, the vessel owner or operator should contact Commandant (CG-ENG-4), Lifesaving and Fire Safety Division at [email protected].
• Vessel owners and operators should maintain the maintenance manuals and technical documentation for all lifesaving equipment onboard the vessel subject to the requirements in IMO Resolution MSC.402(96).
• Vessel owners and operators should maintain a record of the lifesaving equipment servicing on board the vessel for the service life of the equipment. These records  should be made available to Coast Guard inspectors during annual inspections, as requested.

Further, NVIC 03-19 outlines how the USCG will authorize service providers through a verification process by Authorized Classification Societies, and the expected roles and responsibilities of the respective stakeholders as it relates to these new amendments to SOLAS Chapter III and Resolution MSC.402(96).

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See also: 

MPA Singapore: Implementing new requirements for life-saving appliances