永久检验通道PMA_MSC.133(76).doc

JWG/PMA
Unified Interpretations
Final Draft, v2.2
21 Nov 2003

(Final DRAFT, version 2.21)
Interpretations of SOLAS Reg.II-1/3-6 and Resolution MSC.133(76)

Outcome of Consideration by JWG/PMA
On 18 and 19 November 2003

Hisayasu Jin
Chairman of JWG/PMA

1. IACS established a Joint Working Group on Permanent Means of Access (JWG/PMA) with participation of IACS Member Societies, IACS Permanent Secretariat, Shipowners’ Associations and Shipbuilders’ Associations of Japan, Korea and China.
2. The task of the group was to establish draft Interpretations of SOLAS Regulation II-1/3-6 and Resolution MSC.133(76) with regard to means of access to and within spaces in the cargo area of oil tankers and bulk carriers for consideration by IACS with a view to an adoption as IACS Unified Interpretations and for possible submission to IMO MSC 78 in May 2004..
3. The work was carried out by three meetings in March, May and November 2003 and by correspondence between the meetings.
4. The interpretations contained herein have been reviewed and agreed by the members of JWG/PMA for finalization by IACS before submission to IMO.
5. The final draft UI’s version 2.2 circulated by the Chairman on 21 November 2003 is attached herewith. Changes introduced to the final draft UI’s are marked up with underlines or cross out in the attached final draft UI’s, against the former version 2.1. There remains no items that are left unresolved after review by the JWG/PMA.
6. Further the JWG noted the increasing concerns being raised by the industry organisations to the present PMA Resolutions and moves to IMO Assembly 23 urging to start consideration of their amendments at MSC 78. The JWG also considered that amendments of the PMA Resolutions is appropriate for improvement. They are incorporated in the draft UIs as alternatives subject to amendment of the Technical Provisions.

* * *

71

SOLAS Reg.II-1/3-6 Technical Provision
1 Application
1.1 Except as provided for in paragraph 1.2, this regulation applies to oil tankers of 500 gross tonnage and over and bulk carriers, as defined in regulation IX/1, of 20,000 gross tonnage and over, constructed on or after 1 January 2005.
1.2 Oil tankers of 500 gross tonnage and over constructed on or after 1 October 1994 but before 1 January 2005 shall comply with the provisions of regulation II-1/12-2 adopted by resolution MSC.27(61).

Interpretation
Oil tankers:
Notwithstanding the definition of “oil tanker” in Reg.II-1/2.12, this regulation is only applicable to oil tankers having integral tanks for carriage of oil, which is contained in the definition of oil in Annex 1 of MARPOL 73/78. Independent oil tanks can be excluded.
Reg. II-1/3-6 is not normally applied to FPSO or FSO unless the Administration decides otherwise..

Technical Background
Permanent Means of Access (PMA) specified in the Technical Provision contained in Resolution MSC.133(76) is not specific whether it assumes application to integral cargo oil tanks or also to independent cargo oil tanks. ESP requirements of oil tankers have been established assuming the target cargo oil tanks are integral tanks. The PMA regulated under SOLAS Reg.II-1/3-6 is for overall and close-up inspections as defined in regulation IX/1. Therefore it is assumed that the target cargo oil tanks are those of ESP, i.e. integral cargo tanks.
Reg. II-1/3-6 is applicable to FPSO or FSO if they are subject to the scope of ESP regulated by A744(18) as amended.
Ref.
SOLAS Reg. IX/1 and A.744 (18) as amended.

SOLAS Reg.II-1/3-6
2 Means of access to cargo and other spaces
2.1 Each space within the cargo area shall be provided with a permanent means of access to enable, throughout the life of a ship, overall and close-up inspections and thickness measurements of the ship’s structures to be carried out by the Administration, the company, as defined in regulation IX/1, and the ship’s personnel and others as necessary. Such means of access shall comply with the requirements of paragraph 5 and with the Technical provisions for means of access for inspections, adopted by the Maritime Safety Committee by resolution MSC.133(76), as may be amended by the Organization, provided that such amendments are adopted, brought into force and take effect in accordance with the provisions of article VIII of the present Convention concerning the amendment procedures applicable to the Annex other than chapter I.
Interpretation
Forepeak tanks on oil tankers and bulk carriers are excluded pending IMO decisionare to be addresssed in the Technical Provisions as follows:.
For fore peak tank with a depth of 6 m or more at the center line of the collision bulkhead a suitable means of access is to be provided for access to critical areas such as the underdeck structure, stringers, collision bulkhead and side shell structure.
Stringers of less than 6 m in vertical distance from the deck head or a stringer immediately above are considered to provide suitable access in combination with portable means of access.
In case the vertical distance between the deck head and stringers, stringers or the lowest stringer and the tank bottom is 6 m or more alternative means of access as defined in paragraph 9 of the Technical Provisions is to be provided.
Technical Background (Observation):
1) The third paragraph of Preamble of the Technical Provision contained in Annex of Resolution MSC.133(76) defines the ship structure referred to in SOLAS regulation II-1/3-6 on access to and within spaces in the cargo area of oil tankers and bulk carriers. Further it is defined that terms used in the Technical provisions have the same meaning as those defined in the 1974 SOLAS Conventions as amended, and in resolution A.744(18) as amended.
2) Definition of cargo area in SOLAS Reg. II-2/3.32 is cross-referenced in A.744(18) for oil tankers. However “cargo length area” is used for bulk carriers in A.744(18) for the relevant definition. This difference of terminology caused confusion for defining tanks or spaces, which are to be subject to the Technical provision.
3) Fore peak tanks have unique structural configurations and their means of access is addressed separately form other ballast tanks. to be considered in greater depth. At present there are no detailed requirements for access to these spaces. IACS is preparing a proposal for submission to MSC 78 (DE 47 ????)
Ref.
SOLAS Reg. II-2/3.32 and A.744(18)

SOLAS Reg.II-1/3-6
2.2 Where a permanent means of access may be susceptible to damage during normal cargo loading and unloading operations or where it is impracticable to fit permanent means of access, the Administration may allow, in lieu thereof, the provision of movable or portable means of access, as specified in the Technical provisions, provided that the means of attaching, rigging, suspending or supporting the portable means of access forms a permanent part of the ship’s structure. All portable equipment shall be capable of being readily erected or deployed by ship’s personnel.
Interpretation:
Movable means of access was envisioned in place of the elevated passageways for the permanent means of access to deck transverse. No specific design has been proposed that is considered appropriate. However a door should be kept open for an innovative approach in the future for developing alternative means of access suitable for the purposes:
Alternate means of access should include but not be limited to such devices as:
.1 hydraulic arm fitted with a stable base
.2 wire lift platform.
.3 staging
.4 Rafting
.5 Robot arm or ROV
..6 Rope access
.7 Portable ladders more than 5 m long shall only be utilized if fitted with a mechanical device to secure the upper end of the ladder
.8 other means of access, approved by and acceptable to the administration.
Means for safe operation and rigging such equipment to and from, and within these spaces, must be clearly demonstrated in the PMA Manual.
.
1) Subject to acceptance as equivalent by the Administration, an unmanned robot arm, ROV’s and dirigibles with necessary equipment of the permanent means of access for overall and close-up inspections and thickness measurements of the deck head structure such as deck transverses and deck longitudinals of cargo oil tanks and ballast tanks. Such robot arm and equipment are to be capable of:
· safe operation in ullage space in gas-free environment;
· introduction into the place from an access hole of the deck plating;
· remote control to reach the underdeck structure of a bay where the access hole is located;
· taking still and video pictures of intended areas by remote control and transmitting the data to a control station of the robot.
· Taking thickness measurement of intended spots by remote control and transmitting the data to a control station of the robot.
Technical Background
Elevated passageways in particular for access to deck transverses and upper part of transverse bulkheads and longitudinal bulkheads are subject to structural damages due to sloshing of liquid in the tank, corrosion and fatigue. Such damages would render the effective use of the permanent means of access when needed for survey and inspection of under deck structure.
Innovative approaches in particular a development of robot in place of elevated passageways are encouraged and it is considered worthwhile to provide the functional requirement for the innovative approach.
Ref.

SOLAS Reg.II-1/3-6
2.3 The construction and materials of all means of access and their attachment to the ship’s structure shall be to the satisfaction of the Administration. The means of access shall be subject to survey prior to, or in conjunction with, its use in carrying out surveys in accordance with regulation I/10.
Interpretation:
Inspection
The PMA arrangements, including portable equipment and attachments, are to be periodically inspected by the crew or competent inspectors as and when it is going to be used to 4confirm that the PMAs remain in serviceable condition.
Procedures
1. Any authorised person using the PMA shall assume the role of inspector and check for obvious damage prior to using the access arrangements. Whilst using the PMA the inspector is to verify the condition of the sections used by close up examination of those sections and note any deterioration in the provisions. Should any damage or deterioration be found, the effect of such deterioration is to be assessed as to whether the damage or deterioration affects the safety for continued use of the access. Deterioration found that is considered to affect safe use is to be determined as “substantial damage” and measures are to be put in place to ensure that the affected section(s) are not to be further used prior effective repair.
2. Statutory survey of any space that contains PMA shall include verification of the continued effectiveness of the PMA in that space. Survey requirements of the PMA shall not be expected to exceed the scope and extent of the survey being undertaken. [If the PMA is found deficient the scope of survey should be extended as found appropriate.. to cover all PMA in the tank.]
3. Records of all inspections are to be established with specific requirements detailed in the ships Safety Management System. The record is to be readily available to persons using the PMAs and it is recommended that a copy be attached to the PMA Manual. The original records should include as a minimum the date of the inspection, the name and title of the inspector, a confirmation signature, the sections of PMA inspected, verification of continued serviceable condition or details of any deterioration or substantial damage found. A file of permits issued should be maintained for verification.
Technical Background
It is recognised that PMA is subject to deterioration in a long term due to corrosive environment and external forces from ship motions and sloshing of liquid contained in the tank. PMA therefore should be inspected at every opportunity of tank/space entry. The above interpretation is to be contained in a section of the PMA Manual.
Ref.

SOLAS Reg.II-1/3-6
3 Safe access to cargo holds, cargo tanks, ballast tanks and other spaces
3.1 Safe access* to cargo holds, cofferdams, ballast tanks, cargo tanks and other spaces in the cargo area shall be direct from the open deck and such as to ensure their complete inspection. Safe access to double bottom spaces may be from a pump-room, deep cofferdam, pipe tunnel, cargo hold, double hull space or similar compartment not intended for the carriage of oil or hazardous cargoes.
* Refer to the Recommendations for entering enclosed spaces aboard ships, adopted by the Organization by resolution A.864(20).
Interpretation
Access to a double side skin space of bulk carriers may be either from a topside tank or double bottom tank or from both.
Technical Background
Unless used other purposes, the double side skin space is to be designed as a part of a large U-shaped ballast tank and such space is to be accessed through the adjacent part of the tank, i.e. topside tank or double bottom/bilge hopper tank. Access to the double side skin space from the adjacent part rather than direct from the open deck is justified.
Ref.

SOLAS Reg.II-1/3-6
3.2 Tanks, and subdivisions of tanks, having a length of 35 m or more shall be fitted with at least two access hatchways and ladders, as far apart as practicable. Tanks less than 35 m in length shall be served by at least one access hatchway and ladder. When a tank is subdivided by one or more swash bulkheads or similar obstructions which do not allow ready means of access to the other parts of the tank, at least two hatchways and ladders shall be fitted.

Interpretation
N/A A cargo oil tank of less than 35 m length without a swash bulkhead requires only one access hatch.

Technical Background

Ref.

SOLAS Reg.II-1/3-6 Technical Provision
3.3 Each cargo hold shall be provided with at least two means of access as far apart as practicable. In general, these accesses should be arranged diagonally, for example one access near the forward bulkhead on the port side, the other one near the aft bulkhead on the starboard side.

Interpretation
N/A

Technical Background

Ref.
Paragraph 19 of Annex to MSC/Circ.686.

SOLAS Reg.II-1/3-6 Technical Provision
4 Ship structure access manual
4.1 A ship’s means of access to carry out overall and close-up inspections and thickness measurements shall be described in a Ship structure access manual approved by the Administration, an updated copy of which shall be kept on board. The Ship structure access manual shall include the following for each space in the cargo area:
.1 plans showing the means of access to the space, with appropriate technical specifications and dimensions;
.2 plans showing the means of access within each space to enable an overall