SOLAS – New Safe Mooring Requirements Came into Force
By ASLA – Associazione degli Studi Legali Associati
Studio Legale Mordiglia
Towing activities in Genoa's harbour
Genova – On 1 January 2024, the revised SOLAS Regulation II-1/3-8 and associated guidelines entered into force, introducing new towing and mooring requirements.
These amendments have been issued by the IMO Maritime Safety Committee (MSC) with a view of encouraging greater consideration of the occupational safety and safe mooring of the ship when designing new vessels, and are detailed in the following documents:
- IMO Resolution MSC.474(102);
- IMO MSC.1/Circ.1175/Rev.1, Revised guidance on shipboard towing and mooring equipment;
- IMO MSC.1/Circ.1619, Guidelines on the design of mooring arrangements and the selection of appropriate mooring equipment and fittings for safe mooring;
- IMO MSC.1/Circ.1620, Guidelines for inspection and maintenance of mooring equipment including lines.
The new regulations require appropriate and safe-to-use designs of mooring arrangements and introduce a maintenance and inspection regime of mooring and towing arrangements, together with proper documentation, in order to reduce serious and fatal accidents related to the handling of mooring lines or equipment used for mooring operation.
Hence from 1 January 2024 onwards, all shipowners are required to establish and maintain management plans and procedures for inspection and maintenance of mooring equipment on board in accordance with the guidelines set out in circular MSC.1/Circ.1620.
This includes the production of a consolidated document gathering the information related to the below procedures and describing how it was collected:
- Procedures for mooring operations, inspection and maintenance of mooring equipment, including mooring lines;
- Procedures allowing identification and control of mooring lines, tails, and associated attachments;
- Periodic inspection of mooring lines, mooring line tails and associated attachments as part of the onboard maintenance plan or equivalent maintenance management system;
- Manufacturer’s criteria for replacement of mooring lines;
- Records of original design concept, equipment, arrangements, and specifications (to be available on board).
Availability of the above documentation will be confirmed by the administration or recognized organization during the first annual survey for the issuance of the Cargo Ship Safety Construction Certificate, respectively the Passenger Ship Safety Certificate. The records of inspection and maintenance of mooring equipment and mooring lines since the last periodical survey should be kept updated and available on board.
Nevertheless, compliance with such requirements may be challenging for ships built before 1 January 2007, since they were not required to comply with SOLAS Regulation II-1/3-8 and may therefore not have the appropriate documentation. In such cases, shipowners may establish the original design concept, including the Ship Design Minimum Breaking Load (MBLSD), for mooring based on the safe working load of mooring equipment provided on board. If no safe working load is specified on the ship’s mooring documentation nor on the fittings, shipowners are advised to assess the strength of mooring equipment and their supporting hull structure in accordance with circular MSC.1/Circ.1175/Rev.1 and to determine the MBLSD based on the actual capacity of mooring equipment and their supporting hull structure. In this event, it is likely that some classification organizations will require the detailed calculations for their review and appraisal.
For ships built after 1 January 2024, the new regulations provide for additional requirements besides the establishment of the management plans and procedures described above. Shipowners must indeed ensure that the design of the mooring arrangement, including the selection of mooring lines, comply with circulars MSC.1/Circ.1175/Rev.1 and MSC.1/Circ.1619, which aim to cover all aspects of occupational safety and safe mooring of the ship.
The practical implications of SOLAS new requirements for newbuilds are twofold. On the one hand, designers and shipbuilders shall make sure to provide the shipowners with all the necessary technical data and maintenance instructions to enable them to establish their maintenance and inspection procedures. In the other hand, the new guidelines will demand shipowner’s scrutiny during the vessel’s ordering and design process in order for the ship to comply with all requirements.
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