付録2(5) BC Code見直しC.G.における日本コメント
Comments on the kick off letter
(10) Action Requested
(a) examine recent developments in IMO instruments and to suggest those which are considered relevant to the purpose of the Code and should be included in it;
I am of the opinion that reference to chapter XII of SOLAS should be considered in the C.G. for the inclusion of the MSC/Circ.908. One of the possible positions of the reference is the footnote in sub-section 2.1.
(b) check their contact details in Appendix A;
I checked that my contact details are correct.
(c) comment on the proposals in Appendix B;
A.866 (20)
I consider that the proposed position, i.e., the footnote in sub-section 2.2, is suitable.
BLU Code
I consider that the proposed position, i.e., the footnote in the introduction, is suitable.
MSC/Circ.908
I consider that new separated appendix is suitable for the inclusion of the method.
MSC/Circ.671
I consider that the circular can be referred to in the relevant entries in the revised BC Code. However, due regard should be paid about the reference to Table 1, i,e., the list of solid bulk cargoes which are non-combustible or constitute a low fire risk, in the entry for "Sulphur", i.e., the material classified into 4.1, Furthermore, it should be noted that the equivalent fire-extinguishing system for cargoes listed in Table 2, i,e., the list of solid bulk cargoes for which a fixed gas fire-extinguishing system is ineffective, is not specified and the clarification of the requirements on fire-extinguishing for such cargoes is discussed in FP Sub-committee.
The comprehensive review of chapter II-2 of SOLAS Convention were carried out by FP Sub-committee. In the C.G. for comprehensive review of chapter II-2, it was pointed out that the requirements on fire-extinguishing for materials listed in Table 2 of MSC/Circ.671 should be clarified for the interpretation of regulation 53 in the existing chapter II-2. Then. Japan prepared a document for the discussion on this issue in the C.G., as per attached sheets, and the document was included in the final circular letter of the C.G. for the discussion at the working group on the comprehensive review of chapter II-2 held just before FP 44 and the working group in FP 44. However, due to constraint in time, this issue could not be discussed at FP 44 nor the working groups before FP 44.
Therefore, in addition to the inclusion of Table 2 of the circular, the requirement for the materials listed in the table should be clarified to avoid confusion.
(d) comment on the timetable at Appendix C;
I will do my best to follow the timetable proposed by the coordinator.
(e) confirm that the report at Appendix D is an accurate record of the discussions of the DSC 5 Working Group on 10 and 11 February, and
My understanding is that the group was not the working group of the Sub-committee. There was no description on the establishment of the working group under the chairmanship of Ms J Smith in the working papers of the Sub-committee. Therefore, it is not appropriate to submit the paper to DSC 6 as the report of the Working Group. The results of the discussion in the group can be reflected in the report of the C.G.
Regarding the results of discussion in the group, the following two sentences are not needed to be introduced, because the intentions were reflected in the draft terms of reference and the relevant paragraph, i.e., item 3, was deleted at the plenary on Friday:
・ Canada proposed that information (safety measures and design etc.) regarding self unloading carriers should also be included; and
・ Finland proposed that consideration should be given to barges, water tight hatches, and relevant information be included in the revised code.
(f) confirm that my understanding of the responsibilities of individual members of the correspondence group set out in (9) is correct.
I confirmed my tasks.
- Relevant part of the C.G report -
Requirements of fire-extinguishing systems for the carriage of bulk cargoes for which a fixed gas fire-extinguishing system is ineffective by Japan
1 Basic comments
We consider that it is not appropriate to amend the requirements for fire extinguishing systems for the carriage of bulk cargoes for which a fixed gas fire-extinguishing system is ineffective at the next session of the sub-committee, by the following reasons:
(1) The addition of the requirements are considered as substantial change of SOLAS
Convention and it should be addressed to the MSC prior to the discussion in the sub-committee;
