Detail of feedback received
A table of consultation comments and the MCA’s responses.
This notice clarifies areas of responsibility and UK procedures when applying the 2014 amendments to MARPOL Annex 1 chapter 1 regulation 3(6) and chapter 4 regulation 28(6) concerning the fitting of stability instruments on board oil tankers and the consequent amendments to the IOPP Certificate in APPENDIX II (Form B). Similar amendments on fitting stability instruments were made at the same time to the IBC Code, BCH or EGC Code, the IGC Code and the GC Code with equivalent modifications to their respective Certificates of Fitness.
Experience gained in applying the associated IMO Guidelines, MSC.1/Circ.1461, since they came into force on 8th July 2013 indicates that there are still some matters requiring clarification and/or interpretation, for example the issuance of waivers from using a stability instrument and the appropriate methods of demonstrating compliance with the required damage stability regulations when such an instrument is not employed either on board or via links to a shore support station.
The aim of this notice is to improve understanding and consistency of application of the Regulations and Guidelines and to re-emphasize that the MCA’s expectation is that all UK tankers should be fitting IACS URL5 – Type 3 stability instruments capable of verifying damage stability by direct calculation on the hull form and compartments rather than through use of tables or limiting KG/GM curves.
Only in limited case-by-case circumstances, when evidence is provided to the MCA/RO that the ship will still comply with the IMO requirements by using the alternative verification method, will a waiver be agreed to permit the non-fitment of a stability instrument.