INTERNATIONAL MARITIME ORGANIZATION
E
IMO
SUB-COMMITTEE ON SAFETY OF
NAVIGATION
53rd session
Agenda item 21
NAV 53/INF.7
20 April 2007
ENGLISH ONLY
ANY OTHER BUSINESS
Review of vague expressions in SOLAS regulation V/22
Clarification on the Application of SOLAS regulation V/22
Submitted by the International Association of Classification Societies (IACS)
SUMMARY
Executive summary:
This document seeks clarification for the uniform application of
SOLAS regulation V/22
Action to be taken:
Paragraphs 6 and 7
Related documents:
SOLAS 74, as amended; MSC 82/24 (paragraphs 21.39 and 21.40)
Background
1
The Maritime Safety Committee at its eighty-second session agreed to include, in the
Sub-Committee’s work programme, a high priority item on “Review of vague expressions in
SOLAS regulation V/22”.
2
IACS deems that the vagueness of requirements in SOLAS regulation V/22 may lead to a
lack of harmonized application. The subsequent paragraphs highlight the parts of the
above-mentioned regulation that, in IACS opinion, need to be considered by the Sub-Committee
with the view of clarifying their intent.
Clarifications needed
3
For the uniform implementation of the above requirements, it is IACS’ opinion that the
following require clarification:
a)
the meaning of the term “conning position” used throughout SOLAS
regulation V/22, and also in regulation V/19.2.5.4;
For reasons of economy, this document is printed in a limited number. Delegates are
kindly asked to bring their copies to meetings and not to request additional copies.
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b)
whether blind sectors mentioned under SOLAS regulation V/22.1.2 that are
created due to cargo loading arrangement should be permitted on a routine basis
or only on exceptional basis;
c)
whether the requirement for horizontal field of vision at the conning position, bridge wings
and steering position in SOLAS regulations V/22.1.3, 22.1.4 and 22.1.5 respectively are
meant to be “unobstructed” field of vision, with the exemption for blind sectors
indicated in regulation V/22.1.2;
d)
the meaning of the term “as low as possible” used in regulation V/22.1.7, taking
into account the various standards wheelhouse windows have today (based on
which it may be found that the lower edge of windows is varying
from 200 to 1400 mm above deck);
e)
the meaning of the sentence “When the ship is pitching in heavy seas” used in
regulation V/22.1.8;
f)
whether the horizontal field of vision shall be considered at a specific height from
the navigating bridge deck (i.e. by a person with eye height as referred to in
regulation V/22.1.8); and
g)
which amount of blind sectors is acceptable for the field of vision
from 90 to 112.5 degrees on each side, as seen from the conning position.
4
It is also IACS’ opinion that SOLAS regulation V/22.2 is incomplete with respect to the
visibility requirements for the field of vision from 10 to 90 degrees on either side of the bow, as
seen from the conning position, since it does not precisely define when an object outside of the
wheelhouse within these sectors is to be defined as an object causing a blind sector.
5
In developing these requested clarifications, IACS notes that regulation V/15 indicates
that the aims contained therein are to be taken into account when applying regulation V/22 and
considers that due regard should be given to regulations V/15.1 and V/15.6 with respect to
“facilitating the tasks to be performed ... in making full appraisal of the situation” and
“preventing or minimizing excessive or unnecessary work ... or distractions”.
Action requested of the Sub-Committee
6
The Sub-Committee is invited to note the foregoing and take action as appropriate.
7
In this context, reference is made to document NAV 53/INF.5 containing IACS
Recommendation No.95. It should be noted that that document addresses the problems related to
vague expressions in SOLAS regulation V/22 and contains material that may be of value to
the Sub-Committee.
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