The 10th session of the International Maritime Organization’s (IMO) Sub-Committee on Ship Systems and Equipment (SSE 10) was held from 4 March to 8 March 2024 at the IMO.
SSE works under the Maritime Safety Committee (MSC) and considers technical and operational matters about:
- Systems and equipment including machinery and electrical installations
- Fire protection and life-saving appliances.
The following are some of the important updates which are of relevance to BIMCO members.
New requirements for ventilation of survival crafts (partially enclosed lifeboats and life rafts)
At the SSE 8, ventilation requirements for fully enclosed lifeboats were finalised. However, there was a new proposal to include additional ventilation requirements for a new set of survival crafts: partially enclosed lifeboats and life rafts.
While BIMCO supports proposals that enhance safety for seafarers, there is no compelling need to introduce extra ventilation systems here. BIMCO presented a well-prepared intervention at SSE 9 last year and this year at SSE 10, which talked about how we will need install new battery power systems, valves, ducts etc in order to achieve the required additional ventilation and thereby end up complicating these survival crafts, which should be kept simple in order to be operationally ready in distress situations. These points were well received amongst the participants. The majority supported not having extra ventilation systems on board these craft. However it remained on the agenda for one more session, as there was some support for having the extra ventilation, albeit without demonstrating the compelling need. Some member states took the floor to express displeasure that this item had not been removed from the agenda, requested that this be removed, if proposals supporting the compelling need were not submitted to the next session at SSE 11.
Fire safety of container ships
All papers submitted to this agenda, including BIMCO’s co-sponsored proposal, were sent to the working group on fire protection.
The group examined the risk control options (RCOs) listed in table 91 (Summary of cost-effectiveness of all RCOs for the three generic ships) of the CARGOSAFE study along with related documents and proposals therein and various relevant casualty reports, and concentrated on the following feasible RCOs for finding and managing fires in cargo holds and on the cargo deck of containerships, as follows:
1. Fixed fire detection within the cargo hold
2. Fixed fire detection for containers carried on deck
3. Portable IR cameras (thermal imagers)
4. Measures for fire-fighting including:
i. Water mist lances and option of using devices with extended reach
ii. Review of present regulations applicable to mobile water monitors and option of introducing mobile water monitors with remote control
iii. Systems using fixed water monitors with remote control
5. Fixed CO2 fire extinguishing systems
6. Protection of hatch covers.
The following opinions were shared about the cargo hold:
1. Fire detection was important because a fast response is needed to get the fire under control
2. There were limitations of the shape and layout as cargo hold hatch covers were usually removed in port
3. Loading and unloading operations could damage some of the fire safety systems.
The Group observed that the CARGOSAFE study proposed a heat detection system, which monitors the temperature increase of individual containers, as a feasible solution for ultra-large (twin island) and very large (single island) containerships, and that this could be achieved by installing a linear heat detection system (LHD). A LHD system is a special fire alarm system that uses a long, continuous cable to sense heat along its entire length. Unlike conventional point smoke detectors, which only cover a specific area, LHD can detect overheating or fire anywhere along the cable run, offering more complete protection.
Fixed fire detection for containers carried on deck
It was observed that, for video fire detection
1. Weather conditions could affect the performance of a video fire detection system
2. The proposed system's effectiveness during ship sailing and low light operation was not fully proven
3. Some delegations, including BIMCO, agreed that a novel video fire detection system could be efficient. One delegation showed a presentation where tests were conducted using a novel video fire detection system which used cameras and artificial intelligence (AI) tools to detect smoke and fire in a variety of conditions. More information on this will be presented in future sessions.
Positive support
There was positive support from a number of delegations for the following fire protections systems:
1. Portable fire detection equipment including portable infrared thermal imagers and thermometers
2. Manual fire-fighting tools - water mist lances including devices with extended reach
3. Manual fire-fighting tools - mobile water monitors
4. Fixed water monitors, were seen as a positive step but some challenges were noted, which will be dealt with further
5. There were a number of concerns raised with the existing Co2 systems, and that there is a need to look into improving them.
These measures will be taken to the correspondence group (CG) for further steps.
Since there is limited time available for the CG, the protection of hatch covers, both above and below deck, will be discussed at the next SSE in 2025. It was also agreed that there is the issue of one system affecting another, such as water pump capacity, bilge capacity, compressor arrangements etc and that these interdependencies issues should be discussed at the next meeting.
There are a number of items which should be looked at by other sub-committees such as the Cargo, Carriage and Containers (CCC), and Human element, training and watchkeeping (HTW), and the following items will be sent to them:
1. Improved training of shore-side personnel throughout the supply chain, (e.g. consideration of identification/certification regimes for shippers/handlers)
2. Measures to encourage, ensure and improve the quality and reliability of shipper's declaration
3. Container scanning process in port;
4. Stowage provisions for cargoes
5. Risk control measures (RCMs) in paragraph 4.3.1 in the CARGOSAFE study
6. Training of seafarers (HTW sub-committee).
Fire protection, detection and extinction arrangements to reduce the fire risk of ships carrying new energy vehicles, including battery electric vehicles (BEVs)
For these ships, as these are being discussed for the first time in the working group, the following road map was proposed:
1. Review of scientific reports and studies, new technologies, casualty reports and other available credible resources
2. Identification of hazards related to new energy vehicles, including BEVs, compared to conventional internal combustion engine vehicles (ICEVs)
3. Consideration of a goal-based approach
4. Identification of gaps in existing regulations and consideration of the way forward to mitigate the gaps
5. Identification of placeholders for possible future amendments (i.e. SOLAS regulation II-2/20 for all ro-ro ships or regulation II-2/20-2 for a given segment).
Also, a goal-based approach for the amendment of fire safety regulations in SOLAS was proposed.
Some of the items that should be looked into for reviewing the existing regulations are
1. Fixed fire detection systems in ro-ro spaces
2. Video monitoring in ro-ro spaces
3. Structural fire protection
4. Fixed fire extinguishing system – deluge – there was a clear preference for water based sytems, over CO2 however, there are also some issues with that which will have to be looked at and addressed (stability issues in cargo spaces, cargo damage due to seawater etc)
5. Fixed CO2 systems – there are useful, if carefully installed and properly managed, but will need to be carefully looked into, as CO2 does not provide any cooling measures.
6. Fixed firefighting – high expansion foams systems.
The group agreed to continue the discussion at the next SSE.
Self-righting or canopied reversible liferafts
The documents by China and Japan proposing self-righting liferafts were considered in the plenary and then in the LSA working group too, however, no consensus could be reached there, so interested member states and international organisations were asked to submit further proposals at future sessions. So, this matter will be further discussed in future.
Comprehensive review of the Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear (resolution MSC.402(96)) to address challenges with their implementation
SSE examined the challenges of applying the requirements in resolution MSC.402(96) in a consistent manner, taking into account relevant documents, for validation and prioritisation.
SSE grouped the identified issues as follows, to be considered when amending resolution MSC.402(96):
- Authorisation of service providers, including equipment manufacturers
- Manufacturer’s certification programme
- Certification of personnel
- Definitions of various terms
- Timing of annual servicing
- Other issues.
Concerning the previous issues raised about the maintenance and inspection of suspension parts for survival craft, there was agreement to add "suspension parts" to the list of identified issues. When discussing the issues identified, SSE decided that the most urgent item was the meaning of "make" and "type" in relation to resolution MSC.402(96). Furthermore, SSE decided that issues about ASP authorisation between different competent authorities/ROs were matters under the authority of individual Administrations, and items about manufacturers that no longer exist and lack of definitions of equipment were already covered elsewhere in the resolution.
Due to time constraints, SSE 10 did not finalise the draft amendments to resolution MSC.402(96), as such, this was sent to the LSA Correspondence Group reporting to SSE 11.