What are IACS’ submissions at SDC 9

Noting the work IACS Members undertake as Recognized Organizations of IMO Member States, verifying compliance of ships with the IMO agreed requirements, and with a view to achieve clarity for all parties, IACS has submitted or co-sponsored the following papers:

• SDC 9/7/1 comments on the report of the Correspondence Group on “Safety Objective and Functional Requirements for the SOLAS chapter II-1”, as provided in document SDC 9/7, and recommends performing identification of the failure mode(s)/hazards(s) being addressed by the existing prescriptive regulations, to ensure the alternative design and arrangements requirements adequately consider the intent of the existing regulations.
• SDC 9/10 clarifies the necessary documentation in order to support the Administration or RO in verifying compliance with SOLAS regulation II-1/3-8 and proposes an interpretation, as set out in the annex.
• SDC 9/10/1 follows on IACS document SDC 8/10/7 and responds to the Sub-Committee’s invitation to further consider the applicability of prototype testing of bulkhead/deck penetrations to ship types (cargo ships and/or passenger ships). IACS review concluded that there is no similar requirement or related explanatory note for testing bulkhead penetrations on cargo ships, hence the new interpretation proposed by IACS is only applicable to passenger ships. The interpretation clarifies that SOLAS regulation II-1/13 should be applicable to heat sensitive piping systems and should not be applied to cable penetrations in watertight bulkheads and decks.
• SDC 9/10/2 proposes a draft interpretation of amendments of SOLAS chapter II-1 adopted by resolutions MSC.474(102) and MSC.482(103), concerning the expressions “ships constructed before 1 January 2024” and “Multiple hold cargo ships other than bulk carriers and tankers constructed on or after 1 January 2024.
• SDC 9/10/3 proposes a revision of the annex to the Unified Interpretations of the 2008 Intact Stability Code (MSC.1/Circ.1537/Rev.1) so that the scope of application of the specific down-flooding points (ventilators, fitted with weathertight closing appliances, serving machinery spaces that are required to remain open) mentioned in paragraph 2 applies to the entirety of the 2008 Intact Stability Code (parts A and B).
• SDC 9/12 proposes a correction to paragraph 2.2.2 of the Revised performance standards for water level detectors on bulk carriers and single hold cargo ships other than bulk carriers (resolution MSC.188(79)/Rev.1) to clearly distinguish installation heights of detectors between requirements of applicable SOLAS regulations.
• SDC 9/15 discusses the impact of the proposals against existing regulations, the lack of technical justification to apply new draft requirements to the family of bulk carriers and recommends that without clear justification for specific ship type(s) the Sub-Committee invites MSC to only note the proposals in document MSC 102/21/9/Rev.1.

IACS will also provide advice and comments to the Sub-Committee on a number of other issues, both in plenary and in the Working Groups that are expected to be established.

IACS will contribute to the discussions also on agenda item 5 (Review of the guidelines for the reduction of underwater noise) and item 11 (Revision of the Interim explanatory notes for the assessment of passenger ship systems’ capabilities after a fire or flooding casualty (MSC.1/Circ.1369) and related circulars).