Japanese comments on ISO/CD 16848
(1)Sub-clause 4.1
The sentence of sub-clause 4.1 should be changed as follows in accordance with SOLAS Regulations.
"The ladder shall be designed so that the lower platform is not more than 9m above the waterline-----."
(2)Sub-clause 4.2.1
According to the figure 2, pilot ladder is hung under the lower platform and the two vertical rails shall extend from the floor of the platform to a point 2 m above the platform.
On the other hand, IMO Resolution A. 667(16), 3.8 requires to extent the pilot ladder above the lower platform to the height of the handrail.
We think that it is necessary to meet the IMO Resolution.
So the following should be amended.
(a) First para. of sub-clause 4.2.1
"below" should be read as "through".
(b) 4th para. and 5th para. of sub-clause 4.2.1.
Following sentence should be deleted.
"Two vertical rails shall extend from the floor of the platform to a point 2 m above the platform. The rails shall be in line with the side ropes of the pilot ladder."
(c) Following sentence should be added at the end of sub-clause 4.2.1.
"The pilot ladder shall extend above the lower platform to the height of the handrails through an opening."
(d) Figure 2
Figure 2 should be replaced with attached Annex 1 (New figure 2), and specify the way to release a pilot ladder from the platform and to fix one to the platform.
(3)Sub-clause 4.2.2
If the pilot ladder is lashed with the lower platform to ensure, it should be result in twisting of the pilot ladder being pulled by the lower platform when the ship lists or when the height of the accommodation ladder is adjusted.
So the following should be amended.
(a)Following sentence in sub-clause 4.2.2 should be deleted.
"The platform shall be provided with a means to lash a pilot ladder alongside to allow the pilot to step safety from the pilot ladder and onto the platform."
(b)Following sentence should be added at the end of sub-clause 4.2.2.
