Introduction to this issue
The ship's emergency escape channel is the lifeline of the ship's personnel in an emergency, and its guarantee significance is very important. However, due to the different positions of the parties to the understanding of the convention's laws and regulations, there are different degrees of controversy in practical work.
This issue of the column intends to promote the convergence of views of all parties through the interpretation of typical cases.
Contributed by: Liaoning Maritime Safety Bureau Ship Safety Inspection Expert Group
The main author of this issue: Gao Kaiyu Core draft: Liu Huiliang
Typical cases
Case 1:
A certain vessel, built in 2007, was inspected by the PSC for the following defects:
01
07120 stairways accessing to escape trunks in E/R had a width of only 600mm;
Action code: 30/70;
02
07120 escape route from accommodation to lifeboat deck (outside of accommodation ) width is measured 620mm；
Case 2:
A certain wheel, built on July 10, 2006, GT: 35824, Container Ship, PSC inspected the following defects:
07120 INTERNAL DIMENSION OF HATCH COAMING ON MAINDECK FOR EMERGENCY ESCAPE FROM E/R NOT PROVIDED AS REQUIRED (ONLY 620MM*630MM)30/70；
Case 3:
A certain round, built on January 20, 2008, gross tonnage: 7878, General cargo/multi purpose ship, PSC inspection issued the following defects:
07120 corridors and stairways as means of escape in accommodation spaces not as requirements; (handrails not provided)
07120 clear widths of stairways as means of escape in accommodation space not as requirements;(only 650mm)
Action code: 99 (consult with RO)
03
07120 clear widths of stairways as means of escape in E/R not as requirements;(only 580mm)
Action code: 17
The above defects are almost the same in nature, mainly manifested in the size of the escape channel does not meet the requirements; and these defects are considered to be stranded defects, and additional RO liability, and some have also caused controversy between the ship and the RO, why is the PSCO inspection of the escape channel very concerned and the treatment of defects is more severe? What requirements should be met for the layout of the ship's escape route?
(Knock on the blackboard, the following key points are recommended to collect)
Expert opinion
[Emergency escape channel in emergency situations.]
Importance】
The main role of the emergency escape route is to provide safe access to personnel located in dangerous places in emergency situations, especially in the event of a fire, so that the crew on board can safely and quickly withdraw to the lifeboat and life raft boarding deck. Its importance in ensuring the safety of human life is self-evident. To this end, SOLAS requires that, in general, all premises should be provided with two escape routes that are far from each other and ready to be used. The two most common and important places for ships are living quarters and machine quarters. Especially for the latter, there are many flammable materials in the premises, the equipment is concentrated and the layout is complicated, and the smoke is not easy to spread when the fire occurs, and the visibility is extremely poor, which greatly increases the difficulty of the safe evacuation of personnel. Therefore, it is particularly important to have a safe and quick passage that allows people to be evacuated. This is also the original intention of the Convention, which specifically requires that the premises of class A machines on cargo ships should be arranged within the protective ring that provides continuous protective shielding. In fact, in the construction of ships, due to the limitations of the space of the machine premises and the negligence of supervision, the technical conditions of this passage are more prominent, thus laying hidden dangers for whether personnel can be evacuated from the cabin in an emergency. Given the importance of escape routes in keeping lives safe in emergency situations, it is not surprising that PSCO has made them a priority when conducting inspections.
【Interpretation of Statutory Requirements】
The problem of insufficient size of the stairway to the escape passage is often controversial. The escape route of the cargo ship's living place is mainly manifested as the understanding of "net width". The 2000 Amendment requires that the "net width" refers to the distance between or between the handrail and the other side of the bulkhead, and that the doorway into the stairway should be the same size as the stairway. Since the escape route of the machine premises is otherwise stipulated in the body of the Convention, the minimum width of 700 mm referred to herein shall refer only to the stairway or corridor of the living place, and shall not extend to the inclined ladder or stairway of the machine exit that constitutes the escape channel.
In the original text of the Convention, no specific requirements were made for the width and width of the stairways and corridors used as escape routes where the machine premises were not located within protected enclosures, and in the course of actual inspections, the inspectors did encounter cases where the dimensions of the tunnels were narrow and less than 600 mm wide. Notwithstanding the additional explanation given by MSC.1/Circ.1511 above, the Circular was adopted on June 5, 2015, taking into account that such problems are structural defects, ships built before June 5, 2015 should not be considered defects, and ships built thereafter should be recorded as defects and required to take appropriate corrective measures, as appropriate. At the same time, special attention should be paid to the suitability of stairways or corridors that are not used as escape routes.
So back to the opening few cases, article 1 of case 1 is not reasonable. Article 2 defect, neither the original text of the Convention nor the FSSC makes specific requirements for the width of the stairway or corridor leading to the life-saving deck outside the living quarters, and the IACS has also submitted a proposal to the IMO that the requirements for escape routes in SOLAS and FSSC should not apply to open decks, and therefore the opening of this defect is unreasonable. For the defect in case two, since the opening mentioned forms part of the closed escape passage of the machine premises, its size obviously does not meet the requirements of the Convention 800mm*800mm, and there is no problem in the defect determination. The first defect of case 3 is that there is no handrail installed in a section of the corridor of the living area, which obviously does not meet the requirements of FSSC 13.3; the second defect constitutes the width of the escape passage in the living area of less than 700 mm, which does not meet the requirements of the FSSC; however, for the defect of article 3, considering that the width of the stairway that constitutes the escape passage that is not set up in the enclosed loop is not clearly stipulated before the circular of MSC.1/ Circ.1511, it is not appropriate to issue a defect.
【Industry Suggestions】
Considering that in recent years, the ship escape channel has always been the focus of the port state inspection, and there are more cases of detention caused by such defects, so for the shipping company and the ship, the self-inspection and maintenance of the escape channel should be strengthened, especially the thermal protection of the closed escape passage in the machine, the functional requirements of the self-closing fire door and the emergency lighting in the passage to strengthen the inspection. In addition, analyzing the cases of detention in recent years, many of the detention defects involving escape channels are that the structural dimensions of the channels do not meet the requirements, which involve the failure to meet the requirements of the Convention and the Rules when the ship is built, and it is very inconvenient to correct the defects, often need to be docked for repair, and will also have an adverse impact on the operation of the ship. Therefore, in order to avoid such structural defects, shipowners should strengthen supervision when building ships, and surveyors should also improve the quality of ship construction inspections to avoid similar negligence.
The arrangement of the escape passage of the cargo ship involves the personal safety of the crew in an emergency, so the rationality of its arrangement is very important. However, since such defects involve the structure of the ship, and the requirements for ships in different construction periods are not the same, PSC inspectors should also accurately understand and grasp the requirements of the Convention in the actual inspection, and make judgments based on the actual condition of the ship, so as not to bring inconvenience to the ship.
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【Analysis of Conventions and Regulations】
Chapter II-2 of SOLAS sets out the requirements for escape routes, but in the 74 Convention, it is simply mentioned that ships should arrange corresponding escape routes in the living area and engine room, and do not clearly stipulate the relevant structural details of escape routes. Since the 1981 Amendment, the Convention has continuously revised the layout and details of escape routes. Judging from the requirements of the amendments at different times, the requirements for the escape routes of cargo ships at different construction periods are not the same. It can be summarized as follows:
For escape passages in the living quarters, the main requirement for ships to which amendment 81 applies is the number and arrangement of escape passages, and there are no other specific provisions on their size except for the requirement that no corridor with a length of more than 7 m cannot be set up at one end. For the escape passage of the cabin, there are also no specific size requirements in addition to the number and arrangement. In particular, for the escape channel using continuous shielding protection, not only the continuity and size requirements of the shielding are relatively broad, but even the thermal insulation of the shielding protection is only vague and the requirements are satisfactory to the competent authorities.
The 2000 Amendment began to concretize the requirements for escape routes for cargo ships. For the escape passage of the living place, it is required to meet the technical provisions of the FSSC on the escape channel, specifically: the net width of the stairway and corridor used as the escape passage should not be less than 700mm, and the handrail should be installed on one side. Stairways and corridors with a net width of 1800mm and above should be equipped with handrails on both sides. "Net width" refers to the distance between or between the armrest and the other bulkhead. The incline angle of the stairway should generally be 45° but not greater than 50°.
For machine premises, ships built after the 2000 amendment, the requirements for escape routes are very specific, and in the actual PSC inspection, the problems encountered are basically from these ships, and there are more dispute cases, for which the IMO has issued a number of circular explanations on emergency channels, including:
1) MSC/Circ.847 Main Content: Article R45 of amendment 81 is explained, which mainly refers to the requirements for the second escape passage in the cabin located within the protected ring, which is basically the same as the technical requirements of the 2000 amendment on the escape passage of the cabin, and the Circular requires that the interpretation of the Circular should be taken into account for ships built on or after May 14, 1998.
2) MSC.1/Circ.1511 Main contents include:
.1 Explanation of ramps and stairways: For inclined ladders or stairways in the cabin that form part of the escape passage but are not located within a protected enclosure, the tilt angle shall not be greater than 60° and the width shall not be less than 600mm. This requirement does not apply to inclined or stairways that do not constitute a escape route and are only used to provide access from the main platform or deck floor located within the machine premises to a machine or equipment or similar area. (regulation II2/13.4.2)；
The internal dimensions of the enclosure channel should be understood as net width in order to meet the 800mm diameter requirement between the entire vertical ring and the ship structure. If there is an insulation or other equipment inside, the net width should be the distance to the insulation layer or between the devices. When the distance between the ladder in the ring and the ship structure or insulation or equipment is not less than 600mm, the ladder can be located within the internal dimension requirements. When horizontal openings are included in the enclosing channel, the net width of these openings should not be less than 600mm. (Regulation II2/13.4.2.1.1). As shown in the following figure:
【Brief Analysis of Statistical Statistics of Such Defects in the Tokyo Memorandum】
project
year
Number of vessels involved in defective escape routes
Number of vessels stranded due to defects in the escape route
Number of RO liabilities involved
2016
452
37
20
2017
643
22
5
2018
651
27
The above table is a summary of the defects related to the escape channel in the PSC inspection carried out by the Tokyo Memorandum of Understanding in 2016-2018, and it can be seen from the table that the number of ships involving defects in the escape channel has been relatively large in recent years, of which the number of ships stranded for this defect reached 37 in 2016, of which 20 were added RO liability. Although the number of stranded vehicles decreased slightly in 2017 and 2018, the number of defective vessels increased significantly, indicating that escape routes remain the focus of PSC inspectors.