Finnish Maritime Administration

Pertti Haatainen, Head of technical division

Helsinki 12.4.2002

　

Reference: Proposal from Mr. Delise Giovanni in email 1 March 2002

　

　

First I like to thank Mr. Giovanni for his excellent working paper on the item which really has been discussed from ship to ship and from time to time. It is important to get an internationally acceptable solution for this subject, and it is a clear continuation to the in ISO finalized standard ISO 17361:2002.

　

Now it is easy to give comments when there is a proposal, which can be improved (or at least commented). The following comments are offered to the proposal:

　

1) The proposal in its heading covers only the escape arrangements and only on board passenger ships. I would propose that it should cover all (or almost all) safety signage arrangements.

2) The lack of safety sign guidelines for ships has been faced by the maritime industry, maritime administrations and classification societies.

3) Some references to the existing IMO instruments could be listed (e.g. SOLAS II-2, SOLAS III, MSC/Circ.699, IMO Resolution A.654, IMO Resolution A.760 as amended, etc.).

4) The escape plan and the escape signs should present the escape routes to be used in case of emergency (e.g. abandon ship, fire), and not for 'normal' situation.

5) Bullet 5 of the second paragraph in 1.0 presents the order of the embarkation area and the assembly station not in a correct order. See also 2.2.

6) The last paragraph of 1.0 should be deleted. This conclusion should not be made on basis that several ships have certain arrangements. The lighting of the signs is a clear requirement which shall be achieved by emergency lighting with light inside the 'sing lamp unit' or a placard illuminated by from an emergency lighting. This applies to the basic sign system, i.e. those which are normally at a high level. For the LLL there are already specific requirements for lighting. The signs at high level should not be required to be of a photoluminescent material - of course such a material should be permitted.

7) The terms 'primary escape route' - 'secondary escape route', 'exit' - 'emergency exit' and their meanings should be carefully considered in different cases!

8) The signs to be used should be clearly specified in the standard, e.g. by referring to the applicable symbol numbers in standard ISO 17361:2002. Symbols should be used, but a text may be added - but not only a text (ULOS - UT means the same as exit, but are there many who know such a meaning; a running person is a well and easily understood symbol). The symbol or sign names should be clear (e.g. in 2.2 the 'escape' is not a familiar term).

9) For lifeboat station and for a liferaft station there should not be a separate symbol for the both types along the escape route: Only lifeboat should be used for both stations and at the station there shall be these separate sings/symbols with a station number.

10) Emergency escape/emergency exit should generally apply only in case there is a 'difficult' route (e.g. ladders and a ladder trunk). Of course e.g. the supplementary marking 'ladder is understood to be more difficult - but available!

11) The text seems to contain same things in several places and evidently they do not state the same in all cases. The text should be simplified.

12) The text should clearly state the difference between the markings/signs at high level and at low level (LLL). In addition it would be good to refer also to the supplementary emergency lighting required for the ro-ro passenger ships, because that systems is also a part of the guidance system.

13) The sizes of the signs should be 150 x 150 mm (or 150 x 60 mm, b x h) for a viewing distance up to 15 m and 200 x 200 mm for 20 m and so on. The size of the signs for the LLL system has been elsewhere specified (see standard ISO ...).

14) The signs should be installed so that the lower part of the symbol/sign is at a height of at least 1.7 m. The location of the signs for the LLL system has been elsewhere specified.

15) The signs should be, in general, the same in passenger areas and in crew areas. However, passengers do not have to know all the sign used on board ships.

16) The signs should not be installed on the door plate because the position of the door (e.g. open, closed) may give different meaning to the sign. Also if a sign for a hydrant is on a door of a locker containing the hydrant, the sign is not visible when the door is open (see it in a long corridor). An open door with an exit sign may lead persons to a wrong direction.

17) For escape signs there should be used the following basic principle:

18) Supplementary information may be necessary in some cases. It may be presented also as a text understood by those who should understand it.

　

Best regards

　

Pertti Haatainen

FMA