Summary For Sector Comment Summar No.1 Life-Saving Appliances Y For .

40-Series Reform - Exploring Change: Design, Construction and EquipmentNot Government Policy - Report to sector for comment – Life-Saving Appliances - September 2021Question:Consider the proposals in Appendix Three – can they be applied to auxiliary vessels acting as rescuecraft?More flexibility to recognise a parent vessel’s capability to rescue from the waterWe are proposing recognising when the parent vessel’s manoeuvrability and design enables it toapproach and retrieve a casualty from the water as effectively, or more effectively, than using arescue boat.Maritime NZ has granted a lot of exemptions for rescue boats, many based on evidence that theparent vessel is able to efficiently retrieve a casualty from the water.It is proposed that for vessels with inshore and enclosed limits, the use of the parent vessel can berecognised as an alternative to carrying a rescue boat. A condition would need to includedemonstrating that recovery of a person from the water using the parent vessel is as, or more,effective.Question:What tests are appropriate to prove that a vessel has the design and navigation arrangements toretrieve a person from the water without using a rescue craft?Should it be a surveyor or Maritime NZ decision to accept parent vessel use instead of requiring arescue boat?Some current rules appear too toughSome requirements appear excessive for vessel safety. These include: any passenger vessel of 24m or more in length requires a rescue boat regardless of thenumber of persons on board (enclosed, inshore and restricted coastal area limits), anda passenger vessel of 45m or more must have two rescue boats (not just one) - there is norelationship to the number of persons on board.Also, some 15m vessels with coastal and offshore operating limits are required to have a rescue boat,but there is not much room to store and launch a rescue boat on such small vessels. As the currentrequirement is hard to meet, there is an incentive to have the vessel assigned restricted limits (outsideAppendix 1 of Part 20) to avoid the rescue boat requirement.Separately, there is currently a requirement to have more than one rescue boat because of the task ofmustering liferafts – i.e. no more than nine liferafts per rescue boat doing the marshalling. Havingmore than nine liferafts would be very unusual, and the current requirements appears excessive. Onerescue boat can get people out of the water and to safety.Questions:If the 24m length trigger for a passenger vessel to have a rescue boat was to be removed, whatnumber of persons on board should be the trigger to require a rescue boat (or equivalent)?Do you have any views on the current rescue boat standards (described above) for passengervessels 24m or more, passenger vessels 45m or more, and 15m length vessels?4

40-Series Reform - Exploring Change: Design, Construction and EquipmentNot Government Policy - Report to sector for comment – Life-Saving Appliances - September 2021Some current rule requirements for fishing vessels appear too lowSituations are: a fishing vessel in the unlimited area only requires a rescue boat if it is 24m or more in lengthoverall, while any length non-passenger vessel or sailing vessel requires a rescue boat (andpassenger vessels carrying more than 12 passengers require one under the internationalagreement - SOLAS), anda non-passenger vessel of 15m in length assigned coastal limits (i.e. beyond restricted limits)or offshore limits requires a rescue boat. But, a fishing vessel with the same operating limitsdoes not, unless it is 45m or more in length.The ability of fishing vessels to operate at a lower standard in regard to rescue boats, compared tonon-fishing vessels with the same operating limits, is being reviewed. It is proposed that requirementsbe raised to make them more consistent across vessel categories.Questions:Do you agree that fishing vessels should be required to meet similar standards to other commercialvessels, of comparable size, that have the same operating limits?(This question is particularly applicable to under 24m fishing ships operating beyond the offshore limitand under 45m ships within the coastal limit – and the requirement to have a rescue boat, orequivalent.)What length fishing vessel, or what number of persons on board, should trigger the rescue boat (orequivalent) requirement?Clarify the legal status of a rescue boat as “ship’s equipment”It needs to be clear when a rescue boat, or an auxiliary vessel carried on the parent vessel and actingas the rescue boat, has to have its own Maritime NZ number. Currently the term “ship’s equipment” isonly mentioned in the rules for auxiliary boats in regard to fishing ships.2It is proposed that where a rescue boat is carried on board, it be classified as ship’s equipmentassociated with the vessel for all ship categories.The exception would be situations where the auxiliary vessel (acting as a rescue boat) routinely wentout of sight of the parent vessel, i.e. it did excursions. In these cases, the craft would require its ownMaritime NZ number.Question:Should all rescue boats, or boats acting as one, be “ships equipment”?Review references providing for lifeboats as rescue boatsWe are proposing removing the current non-conditional ability to have lifeboats as an alternative to arescue boat. Instead, we would establish appropriate design standards for rescue boats and if analternative vessel (including a lifeboat) can also meet those standards, then it can technically beconsidered equivalent.Question:Do you have any views on removing current ability for lifeboats to automatically be rescue boats?240D.83(4)5

40-Series Reform - Exploring Change: Design, Construction and EquipmentNot Government Policy - Report to sector for comment – Life-Saving Appliances - September 2021Remove references to “passengers” where the term “persons” can be usedOne of the general principles behind the reform is to rely less on ship categories. This includes,looking at where the number of passengers on a vessel triggers a rescue boat.We are proposing changing the current “passenger” references to “persons” in some places – so thatvessels are treated more consistently. If this change is confirmed, the number of persons used as thetrigger will be chosen carefully so that fishing vessels and workboats have the appropriate safetyrequirements.Examples: amending the trigger for a vessel with coastal and offshore operating limits so that a rescueboat is required on a vessel able to carry 12 or more persons (i.e. persons not “passengers”).A variation on this is to review the number of persons on board to acknowledge the addition ofcrew. What number persons would be an appropriate trigger? reviewing the trigger for a rescue boat in “restricted coastal”, which is currently required forthe carriage of more than 36 passengers. However, this matter is linked to the biggerquestion, considered below, about whether the “restricted coastal” standard can be removedcompletely.See Appendix Two for current requirements, where the number of “passenger” is referred to.Question:Do you have any views on referring to person rather than passengers in future rules?Removing separate “restricted coastal limit” standard in regard to rescue boat requirementsWe are proposing to remove the separate requirements for “restricted coastal”, which is currentlyused in standards for passenger [40A] and non-passenger [40C] ships. The alternative rulearrangement is to have a rescue boat standard for vessels operating within 12NM of the shore(territorial sea) and a separate standard for vessels operating in the coastal limit (out to 50 NM).Currently a rescue boat is required for vessels with restricted coastal limits if they are: carrying more than 36 passengers and 15m or more in length, orpassenger vessel [40A] 24m or more in length (and carrying any passengers), ornon-passenger vessel 35m or more in length.The proposal is for a simplified requirement for a rescue boat for:a) any vessel operating outside the territorial sea (12NM) and within 50NM –o above a certain length – somewhere between 15m and 35m and /oro carrying more than a specified number of persons on board – somewherebetween 12 and 36.b) any vessel out to the territorial sea (12NM) limit (and outside restricted limits as listed inAppendix 1 of Part 20)o that is above a certain length – somewhere between 15m and 35m and /oro carrying more than a specified number of persons on board – somewherebetween 12 and 36.Questions:Do you have any views on simplifying requirements and having a requirement for a rescue boatbased on vessel length and/ or just the number of persons on board?What length trigger and / or number of persons on board should trigger the rescue boat requirement(or equivalent) in the two areas: out to 12 NN and 12 to 50NM?6

40-Series Reform - Exploring Change: Design, Construction and EquipmentNot Government Policy - Report to sector for comment – Life-Saving Appliances - September 2021Allow for use of other power sources to launch rescue boatsIn the current rules it is not clear whether the parent vessel is assumed to be incapacitated. Currentrules require that launching a rescue boat must not depend on any means other than gravity or storedmechanical power that is independent of the ship’s power supplies3, although a general exemption in2017 provides for alternative arrangements.4We are assuming that in the vast majority of scenarios the parent boat’s power supply is unaffected.However, it is also known that if there is a fire, then the engine room is a likely source.We are proposing retaining the current requirement for launching rescue boats (i.e. launched safetywithin 5 minutes, and during abandon ship and normal operations). But, the proposal is to provideflexibility to use other power sources (e.g. independent power or stored mechanical power).Launching procedures in the event of vessel power loss may need to be included in the vessel’soperating procedures in some situations.Hook requirements also need to be appropriate – allowing on-load release.Question:Do you have any views on allowing the use of alternative stored mechanical power when launchingrescue boats?2. LifebuoysThe function of lifebuoys is to assist when someone goes overboard, by: giving the person in the water something to hold on to, to reduce panic and aid retrieval whenalongside parent or other vesselacting as a marker – to reduce the risk of losing sight of the person in the water as anybuoyant object can signal where the person might be and keep track of drift.There is a lack of consistency between the numbers and types of lifebuoys required by a vesseloperating in the same area where the risks may be the same. However, Maritime New Zealand is notaware of any specific safety risks that would require the standards to be raised.The current rules means the requirements are overly complex, particularly for a multi-certificationvessel – e.g. fishing /passenger/non-passenger. Current requirement are set out in Appendix Five.To be effective, lifebuoys need to be accessible. There needs to be sufficient numbers of lifebuoysthat can be easily reached and rapidly deployed. They also need to be produced to a recognisedstandard covering buoyancy, visibility and strength.It is proposed that current rules be replaced with risk-based rules that consider: 34the size of the vessel, sea conditions likely to be experienced, and distance from land, andthe following principles developed with input from the TAG:o passenger, non-passenger and fishing vessels, where reasonable to do so, have similarrequirements for the number of lifebuoys if operating in the same areao vessels with large numbers of passengers and/or multiple decks need more lifebuoyso rational distribution (of lifebuoys) around the vessel not “evenly distributed”o vessel length of 9m in length, rather than 6m, is the preferred trigger for allowing greaterflexibility for alternative lifebuoy types and attachments. Throw lines and rescue slingsmay also be appropriate alternatives42A. 28(2)GE-02-177

40-Series Reform - Exploring Change: Design, Construction and EquipmentNot Government Policy - Report to sector for comment – Life-Saving Appliances - September 2021ooohorseshoe lifebuoys are appropriate in some circumstances – noting they need to bebacked by a standardchecks on lifebuoy accessibility should continue to be a requirement of a survey to issueor reissue a Certificate of Survey, andit is appropriate to have some flexibility as to attachments required on lifebuoys.Questions:Are you aware of any safety issues with the current rules? [See Appendix Five for details]Do you agree with the principles above that will inform the development of the new rules? Are wemissing any?Setting a minimum requirement for the number of lifebuoys, with surveyor discretion toincrease the number if appropriateThe proposed minimum number of lifebuoys and throwing apparatus that must be carried on board aship is set out in Table 2 below.In addition, it is proposed that: a surveyor would be required to increase the minimum number of lifebuoys if:o the number of decks, or the length of the vessel, means that there are no lifebuoys within[15m] of any point on an exposed decko if a lifebuoy is not easily accessible and deployable from the navigating position, oro the manoeuvrability of the vessel is such that it would generally take it (or any rescueboat on board) longer than [2 minutes] to return to the man overboard location. a surveyor may increase the minimum number of lifebuoys if:o those on board are unlikely to be able to effectively access or deploy a lifebuoy if thenumber and distribution of lifebuoys is in accordance with Table 2.Table 2: Minimum number of lifebuoys or throw bag required to be carried, based on operatingenvironment and vessel lengthOperational Limits (of vessel)Unlimited and OffshoreWithin the Coastal limit(12-50 NM)To simplify requirements thereisn’t a separate proposed standardfor assigned restricted coastal limitvesselsWithin 12 NM of shore 5Within Inshore limits (and inshorefishing limits)Restricted limits (and includesoperations solely in enclosed waters)Vessel lengthMinimum number oflifebuoys required 9m LOA (length overall)4 lifebuoys 9m LOA2 lifebuoys 15m LOA4 lifebuoys 9 but less than 15m LOA2 lifebuoys 9m LOA1 lifebuoy or throw bag5Note line throwing appliances required on large vessels ( 30m) is covered on page 18.8

40-Series Reform - Exploring Change: Design, Construction and EquipmentNot Government Policy - Report to sector for comment – Life-Saving Appliances - September 2021Questions:Do you agree that the rule should set a minimum number of lifebuoys and provide advice as to whenan increase (above the minimum) is appropriate?Do the simplified rules work for most situations?-Are 9m and 15m meaningful length thresholds for different lifebuoy requirements?Do you agree that the threshold to allow throw bags, as an alternative to a lifebuoy, should be setat less than 9m LOA (length overall)?Are the thresholds of 15m and 2 minutes (for requiring an increase in lifebuoys - see references insquare brackets [ ]) the correct parameters? If not why not?Allowing greater flexibility around the use of horseshoe lifebuoys in certain situationsThe current rules allow for the use of horseshoe lifebuoys on charter yachts and sail training ships15m or less and operating within offshore limit.6 This reflects the fact that horseshoe lifebuoys areeasier to throw and can be stored in more accessible places.Ships, other that charter yachts and sailing training ships, may have similar constraints in terms ofbeing able to store and deploy standard lifebuoys.As a result, it is proposed that the new rules allow for greater flexibility about the types of ships thatare able to use horseshoe lifebuoys, but with the same caveats that apply when used by charteryachts and sail training ships. That is, that horseshoe lifebuoys: should only be used within the offshore limitmust have a minimum buoyancy of 100 Newtonsmust have a strap or line attached to control the gap and people from slipping out of thelifebuoy, andmust have a drogue attached to prevent them from blowing away after they are deployedbecause they are lighter than standard lifebuoys.Unlike round lifebuoys, there is no specified international standard for horseshoe lifebuoys. Thecurrent rules require a minimum buoyancy of 100 Newtons, but there are no other requirements as tomaterials or construction.Questions:Do you agree that ships, other than charter yachts and sail training ships less than 15 m, should beable to use horseshoe lifebuoys? If so, should limits be placed on the type, size, and operating limit ofthe ships that can use them?Other than buoyancy, what standards should be applied to the manufacture of horseshoe buoys?Providing greater discretion as to the type and number of lifebuoy attachmentsThe current rules are very prescriptive about the type and number of attachments.New Zealand has a similar system to the lifebuoy attachment requirements in Australia, whichrequires plain, lights, lights and smoke or buoyant line. With a limited number of exceptions, both NewZealand and Australia follow the international Life Saving Appliances Code in respect of lifebuoyspecification.It is important that any lifebuoy attachments required are appropriate for the operation and design ofthe ship and are effective at assisting visibility and rescue. For example, in some situations floating6See MR 42A.17 (3) and 40E Appendix 4 references to 42A.17.9

40-Series Reform - Exploring Change: Design, Construction and EquipmentNot Government Policy - Report to sector for comment – Life-Saving Appliances - September 2021lines may cause more of a hazard with the risk of entanglement, and attached smoke signals may getactivated if the distance from release to the waterline is too short. Similarly, light attachments may beless useful on ships that only operate in daylight and close to shore, although a combination of eventsmay mean that a daytime activity turns into a night time emergency.It is proposed that the new rules provide the surveyor with greater flexibility about the type of lifebuoyattachments that are appropriate, taking into consideration: how the ship operates and design affecting access and deployment of lifebuoyswhere the ship operateswhen the ship operates (day or night), andfuture changes in technology - different types of attachments might be appropriate in thefuture, for example, locator beacons.Questions:Do you agree that there should be more flexibility around the types and numbers of lifebuoyattachments? If so:-Is there a minimum number / type that should be required?What are the critical elements that influence the type of attachment that is most appropriate? Forexample, consider when and where the ship is operating and ship designReview reliance on lifebuoys in abandon ship scenarioLifebuoys are sometimes an alternative to buoyant apparatus or liferafts under the current rules. Thisis a different application to retrieval of a person who has gone overboard, discussed above.The reference to lifebuoys (alongside liferafts) emphasises the current low standard in the rules,whereby floating appliances that require people to hold on while still in the water, are accepted.The discussion on use of lifebuoys in abandon ship situations is covered under survival craft andlifejackets below.3. Survival Craft (particularly liferafts)The current requirements, for whether liferafts are required or not, are too low in some areas and toohigh in others. Also, rules on the capacity for survival craft, particularly liferafts, the location of liferaftsand the ability to utilise auxiliary vessels needs review.Current requirements are set out in Appendix Six.The proposals we would like comment on are set out below.Increasing liferaft requirements for vessels in enclosed and inshore watersCurrently all vessels (other than fishing vessels 12m or more in length), are able to replace a liferaftrequirement with carriage of buoyant apparatus. As a result, in most situations a liferaft does not needto be carried on a vessel operating on lakes and within 12 NM of the coast. This includes ferries andpassenger charters. These requirements do not reflect New Zealand’s commonly cold water andlikelihood that immediate assistance is not available. Liferafts enable people to be out of the waterwhile they await rescue. Buoyant apparatus does not.We believe it is appropriate to consider increasing New Zealand’s fleet requirements to carry liferafts.Some operators already choos

Not Government Policy - Report to sector for comment - Life-Saving Appliances - September 2021 2 Exploring changes to existing requirements We propose aligning requirements for life-saving appliances across the rules for passenger, non- passenger, fishing vessels and sailing vessels, where it is practical and sensible to implement.