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Overall, NUMAST considers the draft MS to be sensible, as NUMAST is supportive of measures to enhance safety, however, there are a couple of comments to make with respect to the draft.

Despite the fact that SOLAS sets out the requirement, NUMAST is of the opinion that the reference to providing one radar transponder for every four liferafts is flawed and as such, has serious reservations about this option.  NUMAST prefers option No. 3, as outlined in the Partial Regulatory Impact Assessment, as this will substantially increase the likelihood of survivors being rescued.  Although there is a need to carefully balance cost implications, it is important to take into consideration the dependability of all liferafts that have a radar transponder being successfully deployed in an emergency.

We have consulted our Members who have commented that they believed that the requirement to fit SARTs within the liferaft canister was unnecessary since they are already carried onboard vessels and the existing procedure where a crew member is nominated on the Muster List to take them to the liferafts (1 in 4) is considered effective but flexible.  The problem with internal stowage is that with the servicing/cycling of the number of life rafts on a large passenger roll on – roll of vessel there will be occasions when it will be difficult to maintain the correct ratios.  Furthermore the deployment of MES systems (each must be tested every 6 years together with 2/4 rafts) for training may occasionally require the use of MES rafts fitted with SARTs.  In fact I believe that a Safety Case for such situations has been submitted.  Is there any scope for the granting of exemptions in such cases?

Concern noted but MCA regard the management of service schedules as a matter for the ship operator.

Concern was also expressed as to the accuracy and detection range of the available equipment and it was felt that the SAR services should have been included in the consultation.  Finally regarding the annual maintenance cost, it was considered that this was unlikely to be zero.  A figure of £80 per unit was felt to be more likely.

We trust that these comments are useful and look forward to your comments in respect of possible exemptions.

The performance specification is under constant review.

The Regulatory Impact Assessment has been revised to take in to account the £80 annual maintenance cost.

We consider that the wording of SOLAS 111/26.2.5 is misleading and contradictory and that the same applies to the wording in the proposed Statutory Instrument. where it states;

(i) subject to sub-paragraph (bc) [a radar transponder] shall be mounted inside the liferaft so that the antenna of the radar transponder is more than one metre above sea level and

(ii) shall be capable of being manually erected, when the liferaft is deployed. "

The above wording indicates that the SART shall be pre-mounted in its operational position in the packed condition of the liferaft and at the same time it shall be arranged to be manually erected when the liferaft is deployed.

We would strongly recommend that the interpretation of the sub-paragraph will clearly specify that the SART should be manually erected after the liferaft is deployed.

The reason for this standpoint is caused by the following concerns:

A SART is by nature a sensitive piece of electronic equipment. Therefore it is of vital importance that it is effectively and uniformly protected against damage when dropped in a liferaft from the, often, great heights which are common for ro-ro passenger ship rafts.

In our experience it is not feasible to fully protect the equipment if the SART is preinstalled in its operational position, as the final position of the SART in a packed liferaft as well as the sufficiency of the protective measures will be very difficult to control.

Agreed.  Wording has been amended accordingly.

Number of SART's and distribution on the ship

We understand that the wording of SOLAS 111/26.2.5 and your sub-paragraph (ba): "one transponder for every four liferafts", is widely interpreted to mean that if the number of liferatts on board is not an exact multiple of four the required number of SART's should be rounded down to the nearest whole number.

The MCA understands that `rounding down` is the universal interpretation and therefore the UK needs to be consistent with the international position.  

However, we feel that some clarification and guidance as far as distribution of liferafts with SART's on the ship would be appropriate. We believe it is important to emphasize that liferatts fitted with SART's should be evenly distributed on both sides of the ship for the event that only one side of the ship is used for an evacuation.

Agreed.  MCA guidance will stress this point.

Likewise it would be desirable to emphasize that when stowing liferafts fitted with SART's on the ship, they should be the first in line for launching at the individual stations. This would ensure the presence of SART's in an evacuation scenario even with a small number of passengers on board.

MCA would favour an even distribution but there may be individual circumstances where it is not advantageous.  Therefore the MCA would not wish to be prescriptive on this matter and leave it to the best judgment of the ship operator.

Although this Association would rather support Option 3, ILAMA supports Option 2 as referred to in the paper Partial Regulatory Impact Assessment, however, we are disappointed that the MCA did not opt for Option 3, especially with regard to the objective statement `Carriage of SARTs is expected to improve the likelihood of rapid location and rescue of persons in liferafts launched from roll on – roll of passenger ships..etc.`

We would welcome clarification and guidance, however, on the issue of distribution and stowage of SARTs.

Concerns noted regarding Option 2 however this option accords with the SOLAS requirement.  This option is still an important step forward. Adoption by the MCA of Option 3 would place the UK at variance with the international shipping community by being in excess of SOLAS.

ILAMA believes that liferafts carrying SARTs:

1. should be evenly distributed on either side of the ship
2. should be first in line for launching at the individual stations

We also believe that the numbers of SARTs carried on liferafts on board ship should be rounded up, not down, i.e. if there are 20 rafts, five SARTs should be fitted, if 21-24, six SARTs and 25-28, seven SARTs.  Members of ILAMA took part in the drafting group and believe that this was the intention of the group.

MCA would favour an even distribution but there may be individual circumstances where it is not advantageous.  Therefore the MCA would not wish to be prescriptive on this matter and leave it to the best judgment of the ship operator.

The MCA understands that `rounding down` is the universal interpretation and therefore the UK needs to be consistent with the international position.