Bahamas issues notices on passenger ship windows, and emergency escape breathing devices

The Bahamas Maritime Authority (BMA) has issued notices on passenger ship windows, and emergency escape breathing devices.

These notices were published on January 31st, 2023.

Passenger Ship Windows

This Information Notice provides guidance on the protection of windows and side scuttles in passenger ships and the safety of passengers when situated in areas close to windows and side scuttles during bad weather.

It supersedes BMA Information Bulletin No. 154, and applies to all Bahamian passenger ships of 500 gross tonnage and above, other than passenger High Speed Craft.

As defined in the International Convention on Load Lines, 1996, and Protocol of 1988, as amended (Load Lines Convention):

• windows are “...rectangular openings generally, having a radius at each corner relative to the window size and round or oval openings with an area exceeding 0.16m2”.
• side scuttles are “...round or oval openings with an area not exceeding 0.16m2. Round or oval openings having area exceeding 0.16m2 shall be treated as windows”.

The Company* should perform a risk assessment, taking into account the ship’s operating areas and voyage durations, to determine if any windows and side scuttles are at risk of failure in heavy seas and determine the appropriate number of portable headlights to be carried for each size of the window, in addition to those required under the Load Lines Convention, if any.

*The “Company” is the entity responsible for the management of the ship in accordance with the ISM Code. For ships to which the ISM Code is not applicable, the Company is the Managing Owner in accordance with Section 52 of the Bahamas Merchant Shipping Act.

Additional portable deadlights which are required as a result of the risk assessment should be carried on board and be readily accessible.

Spare glasses for external windows and side scuttles described above should be carried on board.

The Bahamas Maritime Authority recommends that, as a guide, spare glasses should be provided for each size of window or side scuttle identified in 4.1 and 4.2 to cover 4% of the total number of windows or side scuttles, but never less than 2 spare glasses.

Notwithstanding the above, single windows identified by the risk assessment as being at risk need only one spare glass specifically for the window concerned.

Sister ships on regular services of less than 24 hours duration may hold common spare glasses at a mutually shared port.

Noting that it may be difficult to replace a broken window or side scuttle whilst the ship is at sea, sufficient material should be available on board to ensure that effective temporary repairs can be made until the window or side scuttle is replaced.

The broken window or side scuttle should be replaced before the ship departs on its next voyage by a spare glass, or material with equal or better strength which ensures watertightness (below freeboard deck) or weathertightness (above freeboard deck).

In recent years, there have been several incidents that have resulted in serious injuries to passengers owing to failure of windows in bad weather.

The Company is required to undertake a risk assessment and introduce appropriate safeguards in relation to seating and communal areas in way of windows and side scuttles.

Emergency Escape Breathing Devices

This Notice outlines the carriage and maintenance requirements for Emergency Escape Breathing Devices (EEBDs). It supersedes BMA Information Bulletin No. 29.

This Notice should be read in conjunction with the following International Maritime Organisation Maritime Safety Committee Circulars:

• MSC/Circ.849, Guidelines for the performance, location, use, and care of emergency escape breathing devices (EEBDs);
• MSC/Circ.1081, Unified interpretation of the revised SOLAS Chapter II-2; and
• MSC.1/Circ.1432, Revised guidelines for the maintenance and inspection of fire protection systems and appliances.

This Notice applies to all Bahamian ships and offshore units to which the International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS) applies.

Offshore units certified under the 1979, 1989 or 2009 Code for the Construction and Equipment of Mobile Offshore Drilling Units (MODU Code) shall be provided with EEBDs as if they were SOLAS certified.

All EEBDs shall comply with the requirements specified in Chapter 3.2.2 of the Fire Safety Systems Code.

The number and location of all EEBDs shall be indicated on the fire control plan.

Carriage Requirements

Regulation 13.3.4 of Chapter II-2 of SOLAS specifies the following minimum carriage requirement for EEBDs in accommodation spaces:

• Cargo ships: 2 EEBDs;
• Passenger ships carrying not more than 36 passengers : 2 EEBDs in each main vertical zone;
• Passenger ships carrying more than 36 passengers: 4 EEBDs in each main vertical zone.

The number of EEBDs to be provided in the machinery spaces is not specified in SOLAS, however guidance is provided in MSC/Circ.1081.

The Bahamas Maritime Authority (BMA) requires the Company to carry out a risk assessment whenever the location and/or number of EEBDs in the machinery spaces is changed.

A risk assessment is not required when a ship is delivered with EEBDs already in place, unless the new Company wishes to change the locations and/or number of EEBDs.

The risk assessment, if required, should take into account the guidance provided in MSC/Circ.1081 and must consider the size and layout of the machinery spaces, number of persons normally present, the length of the escape routes and any other relevant factors.

Unless personnel are individually carrying EEBDs, consideration should be given to placing EEBDs along the escape routes within the machinery spaces or at the foot of each escape ladder within the space.

In addition, control spaces and workshops located within the machinery spaces should also be considered for the possible location of EEBDs.

The number and location of EEBDs required in the machinery spaces identified b the risk assessment is to be agreed with the Recognised Organisation responsible for the issue of statutory certificates on behalf of the BMA.

Documentation related to the risk assessment results/conclusions is to be maintained onboard.

In the event that the Company and Recognised Organisation cannot reach an agreement on the location and numbers of EEBDs to be provided in the machinery spaces, the BMA will act as the final arbiter.

All ships shall carry spare EEBDs that shall be located in a control station. Cargo ships and offshore units shall carry a minimum of 1 spare EEBD and passenger ships shall carry a minimum of 2 spare EEBDs.

In order to satisfy the SOLAS requirements for on-board training in the use of EEBDs, the vessel shall have either:

• at least one separate EEBD clearly marked as designated for training; or
• facilities to re-instate the EEBD that was used during the training exercise to a fully operational condition (such as means of recharging the cylinder to full operating pressure).

With respect to Bahamian ships carrying dangerous chemicals in bulk, the BMA will permit the carriage of the emergency equipment specified in either paragraph 14.3.1 of the International Code for the Construction and Equipment of Ships Carrying dangerous Chemicals in Bulk (IBC Code) or paragraph 3.16.10 of the Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (BCH Code), in lieu of EEBDs.

With respect to Bahamian ships carrying liquefied gases in bulk, the BMA will permit the carriage of the emergency equipment specified in paragraph 14.4.2 of the International Code for The Construction and Equipment of Ships Carrying Liquefied Gases in Bulk 1983, as amended (IGC Code), in lieu of EEBDs.

Inspection and Testing

All EEBDs shall be inspected by a competent person at least annually.

Maintenance and servicing of EEBDs shall be carried out in accordance with the manufacturer’s instructions.

Hydrostatic pressure testing of EEBD cylinders shall be undertaken at least once every five years, or in accordance with the manufacturer’s instructions if such testing is required on a more frequent basis.

The test pressure and test date shall be clearly and permanently marked on the cylinder.

Where EEBDs are fitted with a small capacity oxygen cartridge and manufacturers specify a fixed service life without scheduled hydrostatic pressure testing (e.g. “Ocenco” M-20.2), hydrostatic testing is not required.

Records

Records of inspection, maintenance and testing shall be retained on board for examination. The records must include the test certificates and the inspection status of each cylinder.

Survey Requirements

During Safety Equipment surveys the Recognised Organisation shall verify that:

• the manufacturer’s instructions for the EEBDs are provided and are readily available on board;
• the EEBDs have been inspected and maintained in accordance with the manufacturer’s instructions and this Bulletin;
• the records of inspection, maintenance and testing are available and up to date;
• spare EEBDs are provided in accordance with the above.

Recognised Organisations shall notify the BMA, with relevant recommendations, when a Bahamian ship does not satisfy the requirements for periodical inspections and testing or carriage of spares, prior to the issue or endorsement of a Cargo Ship Safety Equipment Certificate, Passenger Ship Safety Certificate or any other statutory certificate that relates to safety equipment (e.g. MODU/MOU Safety certificates).

RELEVANT DOCUMENTS (AVAILABLE ONLY TO SUBSCRIBERS):

Passenger Ship Windows

Emergency Escape Breathing Devices (EEBDs)

MSC/Circ.849: GUIDELINES FOR THE PERFORMANCE, LOCATION, USE AND CARE OF EMERGENCY ESCAPE BREATHING DEVICES (EEBDs)

MSC/Circ.1081: UNIFIED INTERPRETATION OF THE REVISED SOLAS CHAPTER II-2

MSC.1/Circ.1432: REVISED GUIDELINES FOR THE MAINTENANCE AND INSPECTION OF FIREPROTECTION SYSTEMS AND APPLIANCES