Recommendation Date
Recipient Name
MSA
Text
draft an amendment to Rule Part 40C.60(b) [Design, Construction and Equipment - Non-Passenger Solas] for the consideration of the Minister to clarify the intent of the rule with regard to the requirements for positive means of quick release mechanisms for ships towing from bollards
Reply Text
We noted that paragraphs 2.23 and 2.24 of the Commission’s report discusses the requirement of Clause 40C.60(b) of Maritime Rule Part 40C that “towing hooks and bollards must have positive means of quick release . . .”, and proposes the Rule clause infers that the bollard itself must be capable of performing this duty.
MSA does not support this view. The intent of the Rule was that a quick release mechanism should be installed within the towline. We are, however, considering additional wording in Clause 40.60 to clarify this matter.
Paragraph 2.26 discusses the use of an axe as a means of quick release. It should be noted that Maritime Rule Part 40C is intended for all non-passenger ships that are not SOLAS ships. This includes small work boats which may be utilised in towing operations and an axe is an appropriate means of quick release.
In the case in question, the use of an axe to the release the line would be ineffective and an alternative means of release should have been provided.
Considering the report, its recommendations and our comments, we would note that there would be merit in clarification of the Rule requirements and propose either a text change for the Minister’s consideration to clarify the requirements for towing bollards, or expansion notes within the advisory circular for this Rule.
MSA does not support this view. The intent of the Rule was that a quick release mechanism should be installed within the towline. We are, however, considering additional wording in Clause 40.60 to clarify this matter.
Paragraph 2.26 discusses the use of an axe as a means of quick release. It should be noted that Maritime Rule Part 40C is intended for all non-passenger ships that are not SOLAS ships. This includes small work boats which may be utilised in towing operations and an axe is an appropriate means of quick release.
In the case in question, the use of an axe to the release the line would be ineffective and an alternative means of release should have been provided.
Considering the report, its recommendations and our comments, we would note that there would be merit in clarification of the Rule requirements and propose either a text change for the Minister’s consideration to clarify the requirements for towing bollards, or expansion notes within the advisory circular for this Rule.
Related Investigation(s)