**Executive Summary**
This Nautical Circular NT/LSA/02/2017 from the Directorate General of Shipping addresses lifeboat release and retrieval systems, specifically regarding SOLAS Regulation III/1.5 and the replacement of non-compliant on-load release mechanisms. It outlines requirements for the 5 knots installation test and equivalent testing methods. The circular also addresses the risk assessment and safety provisions for lifeboat testing and applies to ships subject to SOLAS regulations.
**Key Points / Main Content**
* **Background:**
* On-load release mechanisms in lifeboats became mandatory in 1986.
* Failures of these mechanisms have led to numerous accidents, prompting regulatory changes.
* IMO approved new requirements for conventional Lifeboat Release and Retrieval Systems (LRRS) under SOLAS Regulation III/1.5.
* **SOLAS Regulation III/1.5 Compliance:**
* Requires all SOLAS ships to identify and replace non-compliant on-load release mechanisms.
* Replacement must occur no later than the next scheduled dry-docking after July 1, 2014, but before July 1, 2019.
* This regulation does not apply to release mechanisms on free-fall lifeboats.
* **Hook System Evaluation and Testing:**
* Lifeboat manufacturers have re-evaluated existing hook systems, and compliant systems are listed in the IMO Global Integrated Shipping Information System (GISIS).
* Hooks not tested or found in GISIS are considered non-compliant and must be replaced.
* Post-installation tests, as outlined in IMO guidelines (MSC.1/Circ.1392), must be carried out by the manufacturer or their representative and witnessed by the Flag or Recognized Organization.
* **5 Knots Installation Test and Equivalents:**
* For rescue boats and/or boats on cargo ships of 20,000 gross tonnage or above, a 5 knots installation test is required.
* Equivalent testing methods are permitted under controlled conditions:
* The test must be conducted in a controlled environment with the ship stationary alongside or at anchor.
* The 5 knots current may be created using the wash from another vessel or a river/tidal flow, ensuring sufficient water depth.
* **Safety and Risk Assessment:**
* Companies must ensure suitable safety provisions and conduct a thorough risk assessment before any 5 knots installation test or equivalent.
* For equivalent testing, a prior application with a risk assessment must be submitted to the Recognized Organization.
* For passenger ships, the application and risk assessment must be submitted to the Principal Officer.
* No "sister ship" approach is allowed for the 5 knots installation test after hook replacement.
**Impact Analysis**
**Ship Owners/Operators**
* **Impact:**
* Need to identify and replace non-compliant on-load release mechanisms on existing lifeboats to comply with SOLAS Regulation III/1.5.
* Must conduct 5 knots installation tests or equivalent tests after the replacement of hooks.
* Need to ensure adequate safety provisions are in place and conduct a thorough risk assessment prior to testing.
* **Action Required:**
* Identify non-compliant release mechanisms and schedule their replacement.
* Plan and execute post-installation testing, including the 5 knots installation test or equivalent, under controlled conditions.
* Prepare and submit risk assessments to the Recognized Organization (or Principal Officer for passenger ships) for review and approval.
**Lifeboat Manufacturers**
* **Impact:**
* Responsible for re-evaluating and testing existing hook systems.
* Must provide compliant hook systems and documentation for inclusion in the IMO GISIS database.
* May be required to conduct post-installation tests and provide representatives to witness the tests.
* **Action Required:**
* Continue to develop and provide compliant lifeboat release and retrieval systems.
* Support ship owners/operators in complying with the SOLAS Regulation III/1.5 requirements.
**Recognized Organizations/Flag Surveyors**
* **Impact:**
* Responsible for reviewing and approving risk assessments for equivalent testing methods.
* Must witness post-installation tests to ensure compliance with SOLAS and IMO guidelines.
* **Action Required:**
* Evaluate and approve risk assessments submitted by ship owners/operators for equivalent testing methods.
* Oversee and verify the proper execution of post-installation tests.
Key Entities Referenced
SOLAS Regulation III/1.5: Regulation within the International Convention for the Safety of Life at Sea (SOLAS) concerning lifeboat release mechanisms.
International Life-Saving Appliance (LSA) Code: International code specifying requirements for life-saving appliances, as amended by IMO Resolution MSC.320(89).
Directorate General of Shipping: Issuing authority for the circular, responsible for shipping regulations in India.
IMO Resolution MSC.81(70): IMO resolution on testing of life-saving appliances, referenced for load testing requirements.
Mumbai: Location of the Directorate General of Shipping
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NT Circular No. NT/LSA/O212017
Diredorate General of shipping, Minisby of shipping, Govt. of lndia, Mumbai
Subject-Lifeboat Release and Retrieval System- reg.
the Govt. of Dated 08.08.2017
A) Back Ground
1) The fitment of on-load release mechanism to hooks fitted in conventional lifeboats
became mandatory in 1986. On-load release mechanisms are designed to permit the
release of the davit-launched lifeboat from fall wires when ship is still making way
through the water or in rough sea.
2) The failures of on-load release hooks led to many serious lifeboat accidents in the past.
Accordingly, various regulatory changes (such as mandatory annual maintenance and
servicing by authorized service supplier, and doing away with the requirement for
seafarers to be onboard the lifeboat being lowered during abandon ship drills) to reduce
the frequency and consequences of such accidents.
3) To further improve the safety of lifeboat release and retrieval systems (LRRS), the
Maritime Safety Committee (MSC) of IMO in its 89th session held in May 2011 approved
the new requirements for conventional LRSS for all existing and new build vessels under
SOLAS Regulation lll h.5.
4) SOLAS Regulation lll/1.5 requires all ships subject to SOLAS, regardless of build date, to
identify existing on-load release mechanisms that do not comply with paragraphs
4.4.7.6.4 to 4.4.7 .6.6 of the lnternational Life-saving Appliance (LSA) Code, as amended by
IMO Resolution MSC.320(89); and replace them with compliant release mechanisms no
later than the next scheduled dry-docking after July L,2074 (but in any case, before July 1,
Z}1gl, SOLAS Regulation lll/1.5 does not apply to the release mechanisms on free-fall
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risk assessment is conducted prior to the conduct of the 5 knots installation test' or
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4. ln case where the company applies equivalent means of conducting the 5 knots
installation test, prior application to be made to the concerned Recognized organization
along with the risk assessment. Only after a satisfactory review of the risk assessment by
concerned Recognized Organization, the test to be conducted by the manufacturer or its
representative and witnessed by Recognized Organization on cargo ships'
5. For passenger ships, application along with risk assessment to be submitted to the
concerned Principal officer for his review of risk assessment and witness of this test by
Flag SurveYor.
6. No "sister ship" approach will be considered when dealing with the 5 knots installation
testoragreedequivalenttestrequiredafterthereplacementofhooks'
This is issued with the approval of the Nautical Advisor to the Govt' of
lndia.
(cap{ R.K. Muduli)
Dy. Nautical Adviser to the Gol
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