資料3
INTERNATIONAL MARITIME ORGANIZATION |
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SUB-COMMITTEE ON SHIP DESIGN AND
EQUIPMENT
48th session
Agenda item 5
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DE 48/5/7
17 December 2004
Original: ENGLISH |
MEASURES TO PREVENT ACCIDENTS WITH LIFEBOATS
Rectification of MSC/Circ.1093
Submitted by Japan
SUMMARY
Executive summary: This document provides the rectification of MSC/Circ.1093, i.e., the Guidelines for periodic servicing and maintenance of lifeboats, launching appliances and on-load release gear.
Action to be taken: Paragraph 10
Related documents: MSC/Circ.1093, DE 46/32, MSC 77/26 and ISM Code
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Background
1 The Sub-Committee, at its forty-sixth session, agreed to the draft Guidelines for periodic servicing and maintenance of lifeboats, launching appliances and on-load release gear and the associated draft MSC circular for submission to MSC 77 for approval (see DE 46/32, paragraph 9.29 and annex 9). The draft Guidelines were approved at the Committee, at its seventy-seventh session, as MSC/Circ.1093 (see MSC 77/26 paragraph 13.6).
2 MSC/Circ.1093 is referred to at the footnote of revised regulation III/20.3.1, i.e., the requirement for maintenance, testing and inspections of life-saving appliances, which will enter into force on 2006 July 1.
Rectification of the guidelines on statement by manufacturer's representative
3 Paragraph 12 of the Guidelines is as follows:
"12 All other inspections, servicing and repair should be conducted by the manufacturer's representative or a person appropriately trained and certified by the manufacturer for the work to be done."
4 On the other hand, paragraph 15 of the Guidelines is as follows:
"15 When repairs, thorough servicing and annual servicing are completed, a statement confirming that the lifeboat arrangements remain fit for purpose should be issued by the manufacturer's representative."
This paragraph requires a statement by the manufacturer's representative.
5 Japan would like to interpret that the above mentioned requirement for the statement can be complied with by issuing a statement by the person certified by the manufacturer for the work, taking into account the provision in paragraph 12.
6 For clarity, it may be better to rectify MSC/Circ.1093 for example as follows:
"15 When repairs, thorough servicing and annual servicing are completed, a statement confirming that the lifeboat arrangements remain fit for purpose should be issued by the manufacturer's representative or by the person certified by the manufacturer for the work."
Rectification of the guidelines on signature by company's representative
7 Paragraph 13 of the Guidelines is as follows:
"13 All reports and checklists should be correctly filled out and signed by the person who carries out the inspection and maintenance work and should also be signed by the company's representative."
8 If the requirement in paragraph 13 of MSC/Circ.1093 is interpreted as that reports and checklists should be signed by the company's representative each time, it is impracticable to comply with.
9 It is required by paragraph 10.1 of the ISM Code that the Company should establish procedures to ensure that the ship is maintained in conformity with the provisions of the relevant rules and regulations. Therefore, the check of the report will be incorporated into the SMS manuals of the ships. It should further be noted that responsibility and authority of ship's master should clearly be defined by the Company with regard to verifying that specified requirements are observed, in accordance with 5.1.4 of the annex to the ISM Code. Based on this requirement, it is generally determined in SMS manuals that management of on-board maintenance is within a purview of master's responsibility and authority. Taking these issues into consideration, the other practical way of rectification of the above mentioned paragraph is as follows:
"13 All reports and checklists should be correctly filled out and signed by the person who carries out the inspection and maintenance work and should also be signed by the company's representative or the ship's master."
Action requested of the Sub-Committee
10 The Sub-Committee is invited to clarify the interpretation of paragraphs 13 and 15 of MSC/Circ.1093 and take action as appropriate.
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