GUIDANCE NOTES FOR CARRYING OUT AN INCLINING TEST
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1. INTRODUCTION
1.1 These notes are intended to provide practical guidance in order to minimise inaccuracies and ensure that the information derived from the inclining test provides a satisfactory basis, acceptable to the MCA or delegated Authority, for the determination of the ship’s stability.
1.2 It is appreciated that the following recommended procedures for inclining tests cannot always be achieved and equally efficient alternative procedures may have to be adopted to suit particular circumstances.
1.3 For small ships where it is considered impracticable to adopt procedures as given in these notes the MCA may be prepared to accept alternative procedures.
1.4 Advice on the procedure when an inclining test may be dispensed with in certain circumstances is contained in paragraph 4 below.
2. PREPARATIONS FOR TEST
2.1 Notification to the MCA or delegated Authority
2.1.1 It is most important that the surveyor should inspect the ship shortly before the test in order to be satisfied that the ship will be in an acceptable condition. If this is not so the surveyor may require that the test be deferred.
2.1.2 An opportunity should be taken to discuss and confirm arrangements for the test with the builder/owner with particular regard to the following:-
(i) inclining weight data;
(ii) type, amount and position on board;
(iii) method of handling weights;
(iv) anticipated maximum angle of heel to each side from upright;
(v) pendulums; approximate location and length;
(vi) stabilograph or similar instrument; calibration and position; and
(vi) condition of tanks and approximate trim; consideration being given to practical measures to minimise the free surface effects of liquids, excessive trim or initial heel.
2.1.3 Draught marks;
(i) draught marks should have been checked on the building berth or in dry dock by a surveyor from the MCA or delegated Authority as appropriate;
(ii) keel sight readings indicating the baseline from which the draught marks have been measured should be available for reference;
(iii) a plastic damping tube with engraved scale may be of assistance in reading the marks if the water surface is likely to be disturbed;
(iv) draught datum marks may require to be established should the draught marks be inaccessible e.g. when there is a flat overhang at the stern;
(v) a recently calibrated hydrometer with suitable density bucket is available; and
(vi) a suitable small boat is to be available.
2.1.4 Degree of completion;
(i) items to be added;
(ii) items to be deducted;
(iii) items to be relocated; and
(iv) removal of debris and overall cleanliness.
2.1.5 Location and timing;
(i) the test should be carried out where possible in a wet dock basin to provide stable conditions and minimise disturbance from passing craft;
(ii) where the test may be affected by a tidal stream or current it may require to be timed to coincide with a slack water period; and
(iii) there should be no risk of grounding during the test.
2.1.6 Specialised ship types;
Ro-Ro ferries with hoistable or hinged decks; the centre of gravity of the ship will require to be determined for two lightship conditions, such decks will require to be adequately secured to prevent movement during the test.
2.2 Data required
2.2.1 Trimmed hydrostatic data should be available over an adequate range of draughts.
2.2.2 Tank layout plan. The drawing should show the locations of the sounding pipes, air pipes and access manholes.
2.2.3 Tank calibrations and capacities.
2.2.4 Length of sounding pipes from striker to deck plate. This can provide a useful indication in the event of a sounding pipe being blocked.
2.3 General condition of the ship
2.3.1 The ship should be complete or virtually so. An accurate list of items to be added, deducted, or relocated after the test should be prepared by the builder/owner and their weights and positions as recorded agreed by the surveyor. Such items, however, should be reduced in number to the absolute minimum.
2.3.2 In conjunction with the person conducting the test, the surveyor should thoroughly inspect the ship to ensure that all items on the list above are accurately assessed and check that any omissions are taken into account.
2.3.3 The ship should be generally clean. Shipyard equipment, staging and debris should be removed as far as practicable.
2.3.4 Suspended weights including boats, anchors, derricks, vehicle ramps and decks etc. should be secured in their seagoing positions.
2.3.5 Tank top, open floored spaces and bilges in the machinery space and elsewhere should be clean and dry. Loose water and oil should be removed.
2.3.6 In general, machinery, piping systems, boilers and associated equipment should be at operating levels.
2.3.7 Keys to all locked compartments should be available.
2.3.8 In the inclined condition, it should be ensured that the ship has adequate positive stability.
2.4 Tanks
2.4.1 General
(i) The number of tanks containing liquids during the test should be kept to a minimum. As a guide the total weight of liquids should not exceed 25% of the lightweight. This may be exceeded where it is desirable to reduce the trim of the vessel.
(ii) The disposition of all liquids required to be on board should be agreed by the surveyor, prior to the test.
(iii) Where it is agreed that particular tanks may contain liquid, these must either be pressed full or the level must be such that the free surface effect can be accurately determined. Slack tanks where permitted should comply with the slack tank instructions given in paragraph 2.4.2 below. The number of slack tanks is to be restricted to one pair for either oil or fresh water.
(iv) All tanks not permitted to contain liquids during the test should be dry. (See also paragraph 2.4.2 (ii) below).
(v) Cross connections between port and starboard tanks containing liquids should be checked to ensure that the control valves are closed.
2.4.2 Slack tanks
(i) The free surface allowance for slack tanks should be subject to agreement of the surveyor. When these are not agreed and they are slack a free surface correction should not be allowed for in determining the lightship KG.
(ii) Slack tanks should be limited to tanks with essentially rectangular form. Double bottom tanks should generally not be slack during the experiment.
(iii) As a guide where tanks are permitted to contain liquids in accordance with paragraph 2.4.1 (iii), above, deep tanks should be 20% to 80% full and double bottom tanks 40% to 60% full to ensure that a significant change in the dimensions of the free surface does not occur during inclining. The effect of trim should be taken into account when considering the configuration of the liquid surface.
(iv) Tanks containing liquids of high viscosity should not be permitted to be slack since the free surface effect is impossible to determine. However if such liquids can be heated to reduce viscosity then a free surface correction can be accepted at the surveyor's discretion.
2.4.3 Pressed-up tanks
Such tanks are assumed to be completely full with no air pockets or voids. In practice it is difficult to obtain a completely filled tank even assuming normal venting and air hole provision and a free surface of unknown extent may occur in an apparently filled tank. For this reason tanks required to be pressed should be filled in advance of the test until the tank is completely full. Each tank should subsequently be topped up, the final topping up being carried out slowly and the tank ullage checked at intervals.
2.4.4 Empty tanks
(i) Where tanks are required to be empty, it is not sufficient to pump tanks until stripping should be performed with portable pumps where this is necessary. Narrow tanks such as peaks having sharp deadrise and negligible free surface may be exceptions to this.
(ii) Proper safety precautions should be adopted before entering the tanks - See Marine Information Note MIN 29(M) regarding the Merchant Shipping (Entry into Dangerous Spaces) Regulations 1988 and Codes of Practice.
2.4.5 Identification of liquids
Liquids retained in tanks should be identified and their specific gravity’s determined.
2.5 Trim
2.5.1 Trim by the head or excessive trim by the stern should be avoided.
2.5.2 If tanks are to be pressed up, some trim by the stern will aid in venting and elimination of air pockets. A small trim will also facilitate emptying tanks required to be empty. Where a number of tanks are permitted to be full, aftermost tanks should be pressed up first.
2.5.3 Any marked change in the shape of the waterplane when the ship is heeled during inclining such as may occur with a chine form or where the ship has ‘flat’ sections aft, should be avoided e.g. by modifying the trim so that the chine is immersed both when upright and heeled.
2.5.4 Hydrostatic particulars for the ship as inclined should be calculated for the actual trimmed waterline. A correction should be made for hog or sag as applicable.
2.6 List
2.6.1 As far as practicable the ship should be upright with the inclining weights in the initial position.
2.6.2 A small initial list is acceptable but ideally this should not exceed onehalf degree. Weights to correct any list should be used where necessary.
2.7 Mooring arrangements
The ship should be moored so that it is floating freely during heeling in an adequate depth of water. The mooring ropes should be arranged so as not to restrict heeling. Ideally the ship should be moored bow and stern only by as few lines as possible led parallel to the fore and aft axis.
2.8 Weather
2.8.1 It is desirable that the weather should be fine with little or no wind and with calm water conditions.
2.8.2 The effect of wind, current, wavelets, or difficult mooring conditions may adversely affect results due to:
(i) inability to measure draught and freeboards accurately;
(ii) excessive or irregular oscillations of the pendulums; and
(iii) variations in superimposed heeling moments.
2.8.3 In poor or deteriorating weather conditions, the surveyor will require to assess the situation and indicate whether he considers it necessary to discontinue the test.
3. CONDUCT OF THE TEST
3.1 Supervision
3.1.1 Routine preparation, organisation and direction of the test is the builder's/owner's responsibility.
3.1.2 The builder's/owner's representative in charge should:
(i) make sure that the ship is completely prepared for the test in compliance with 2 above;
(ii) have authority over all personnel participating in the test; and
(iii) maintain close liaison with the surveyor;
3.1.3 The surveyor will personally verify:
(i) the adequacy of the ship's preparation and condition;
(ii) that the mooring arrangements are satisfactory having regard to the weather conditions; and
(iii) the accuracy of the test data accumulated and confirm its proper recording in the test report.
3.2 General
3.2.1 The minimum number of personnel should be on board during the test and their same position maintained during the recording of the pendulum readings.
3.2.2 Shore gangways should be lifted during the test to minimise restriction of ship's movement and maintain control on the number of personnel on board during the test. Power lines, hoses etc. connected to the shore should be kept to a minimum and those that are essential kept slack at all times.
3.2.3 Any appreciable quantities of snow or ice must be removed from the ship before test.
3.2.4 If the inclining test is carried out at low water, checks should be made to ensure that the ship is not aground.
3.3 Test weights
3.3.1 The total weight used should be sufficient to produce an inclination of about 2o to each side. Larger inclinations of up to 3o may be necessary to provide measurable deflections of the pendulum on smaller ships. This will depend upon the hull form and whether the waterplane shape changes during heeling. See also paragraph 2.5.3. The inclination should not exceed 4o from the upright zero position.
3.3.2 Generally, it will be most convenient to use 4 weights or sets of weights. These should be as near equal as practicable and be positioned symmetrically 2 each port and starboard.
3.3.3 The weights should be compact and of such configuration that the vertical centre of gravity may be accurately determined. Personnel are not an acceptable alternative to weights.
3.3.4 Each weight should be marked with an identification number and its weight. The surveyor should confirm that the test weights have been verified by means of weighbridge or equivalent immediately prior to the test. Weight test certificates should be inspected and the surveyor should be satisfied that the certificate remains applicable.
3.3.5 The weights should be positioned as far outboard as possible on the upper deck. The positions of the weights should be marked and arrangements made to ensure that they can be placed back in their exact original positions as the test progresses.
3.3.6 The transverse movement of the weights should be arranged so that there is no longitudinal change in the positions of each weight which would affect the ship's trim.
3.3.7 The lifting arrangements should be such that the weights can be transferred rapidly once the test is started to minimise delay and reduce the likelihood of encountering changing tide, current or weather conditions.
3.3.8 The use of water transfer between wing tanks in lieu of solid weights is not acceptable.
3.4 Pendulums
3.4.1 At least two pendulums should be used except as noted in paragraph 3.4.5 below. These should be located in separate positions in areas protected from the wind.
3.4.2 The pendulums should be as long as practicable. They should comprise good quality wire such as piano wire.
3.4.3 The deflections of the pendulum giving the reading for each individual shift of inclining weight should be sufficient to provide accurate results. A deflection for each shift of not less than 35mm would be expected.
3.4.4 The pendulum weights should be immersed in a trough of liquid to dampen the pendulum oscillations. Care should be taken that the trough is of adequate size to give ample margin beyond the maximum anticipated deflection and that the pendulum weight does not touch the bottom of the trough. The trough should be secured against accidental movement. Improved damping can be achieved by filling with oil rather than water.
3.4.5 In lieu of one of the pendulums referred top in paragraph 3.4.1 above:-
(i) a Stabilograph may be used. The surveyor should ensure that the Stabilograph has been regularly tested and require reports of such tests to be provided; or
(ii) a U tube water level may be used. The ends of the level should be positioned as far outboard as possible. Arrangements should be made for a record of all readings (from both ends of the tube) to be obtained. Clear plastic tube should be used and care should be taken to exclude all air bubbles and avoid topping up after commencement of test.
3.5 Draught and freeboards
3.5.1 Using the boat provided, draughts should be measured with the gangway raised, and with the ship in the same condition as during the test.
3.5.2 Draughts should be measured port and starboard at the forward and aft draught marks and freeboard or datum mark measurements obtained port and starboard amidships to determine hog and sag. In cases where the ship's form makes the draught marks inaccessible or difficult to read, adjacent check measurements of freeboard to a suitable datum should be taken.
3.5.3 The longitudinal positions at which the draught measurements are taken should be recorded so that the necessary corrections can be applied in the inclining report.
3.5.4 For small vessels:
(i) Freeboard may be utilised in lieu of draught measurements after establishing the sheer profile relative to the keel. In addition to measurements at bow and stern, measurements should be obtained at convenient locations near the fore and aft quarter lengths and amidships. The relative measurements fore and aft and port and starboard should be taken simultaneously.
(ii) When recording measurements, particular care should be taken that all persons who will be on board during the test, are disposed in the positions allocated.
3.5.5 The specific gravity of the water in which the ship is floating should be checked using a hydrometer at the same time as the draughts are measured. Where necessary, readings at various depths should be obtained to ensure accurate assessment of the mean specific gravity. The hydrometer should be checked in fresh water before use.
3.6 Communications and control
3.6.1 One person at a central control station should have complete control over all personnel involved in the test.
3.6.2 There should be efficient two-way communications between
(i) the person in control and the weight handlers;
(ii) each pendulum or deflection recording station; and
(iii) the mooring attendants.
3.7 Weight movements
3.7.1 Following the initial zero reading, the standard test should preferably involve at least 8 weight movements, and in no case less than 6 weight movements. Thus, where W is the total weight on each side of the ship:
| SHIFT | MOVEMENT |
| 1 | W/2 tonnes P to S |
| 2 | W/2 tonnes P to S |
| 3 | W/2 tonnes S to P |
| 4 | W/2 tonnes S to P (zero checked) |
| 5 | W/2 tonnes S to P |
| 6 | W/2 tonnes S to P |
| 7 | W/2 tonnes P to S |
| 8 | W/2 tonnes P to S (zero checked) |
3.7.2 At each weight shift, the pendulum readings should be marked on a wood batten, the deflection being measured from the previous shift mark.
3.7.3 As the test proceeds the standard of the results may conveniently be verified by plotting the moment of transverse weight movements against the tangent of deflection or equivalents. The weight movements proposed should give a good spread of points but additional shifts should be carried out if necessary to minimise any error resulting from an appreciable "stagger". All readings without omission should be shown in the test report. This recorded plot is to be included in the final inclining experiment report.
3.7.4 Weight movements should be made directly athwartships so as to avoid a change in the ship's trim, and should be maintained in the same horizontal plane above the keel.
3.7.5 Checks should be made during the test to see that all personnel are in their agreed locations and that all mooring lines which should be slack, are in fact slack.
3.8 Test results
3.8.1 The builder/owner should provide the surveyor with a detailed inclining test report which should include:
(i) a complete record of all test information, including the trace from the Stabilograph if used and including moment shift plotted against inclinations recorded;
(ii) a statement providing a clear account of the condition of the ship as inclined. This should include all weights, with their centres of gravity, required to be added, deducted or relocated for derivation of the lightship condition; and
(iii) calculations using the test data to determine the characteristics of the ship in the inclined and lightship condition.
3.8.2 The surveyor should examine the test report for accuracy and completeness and immediately advise the builder/owner concerning any comments or disagreement with the report.
3.8.3 When the surveyor has confirmed satisfaction with the results of the inclining test and the accuracy of the report, the report should be used as a basis for the production of the stability information booklet (marked 'provisional') to be placed on board prior to the ship's departure on the maiden voyage.
3.8.4 A copy of the inclining test report should be included in the approved stability information booklet.
4. DISPENSATION FROM THE INCLINING TEST REQUIREMENT
4.1 On receipt of a written request from the builders/owners, the MCA or delegated Authority may agree to dispense with the inclining test subject to:-
(i) the ship being a sister ship under construction in the same shipyard;
(ii) the surveyor being satisfied that the ships are similar in all respects (except as referred to in sub-paragraph (v) below);
(iii) the surveyor being satisfied with the accuracy of the inclining test carried out on the first ship;
(iv) a lightweight check being carried out on each subsequent ship after the first ship;
(v) small modifications capable of accurate assessment being taken into account by calculation; and
(vi) in the case of a series of sister ships (i.e. 3 or more), the surveyor may subsequently require further inclining tests additional to that carried out on the first ship as checks on the effect of cumulative unspecified changes.
5. SHIPS TRANSFERRING FROM FOREIGN TO UNITED KINGDOM REGISTRY
5.1 An inclining test should be carried out before the ship re-enters service, unless:
(i) the report of the previous inclining test carried out before transfer is available and has been witnessed by a recognised classification society, flag administration or a senior naval architect employed by a builder or owner;
(ii) after examination the surveyor consider the inclining test report is sufficiently detailed and acceptable in other respects and the surveyor is satisfied that the report is applicable to the ship at the time of survey bearing in mind the type and age of the vessel; and
(iii) a responsible representative of the owner provides written confirmation that the results of the last test are still valid for the ship in its present condition.
6. LIGHTWEIGHT CHECK
6.1 The lightweight check should be carried out by the builder's/owner's representatives with a MCA surveyor in attendance.
6.2 Where applicable, the surveyor should confirm with the builders that the ship is similar in all respects to the first sister ship for which a satisfactory inclining test or lightweight check report is available.
6.3 The same care should be exercised in carrying out the lightweight check, as applies to the inclining test. The relevant parts of these Guidance Notes apply.
6.4 After the lightweight check has been completed the builders should furnish the surveyor with a report which includes details of the condition of the ship, calculation of lightship displacement and longitudinal centre of gravity.
6.5 If the lightship particulars obtained from the lightweight check do not agree closely with the test results for the first ship, the subject should be inclined e.g.:-
(i) weight within ± 2%
(ii) LCG position within ± 1%
6.6 Where the lightship comparison is satisfactory, the lightship particulars from the inclining test or lightweight check report for the first ship may be applied to the sister ship and a copy of the report should be included in the stability information suitably endorsed to indicate an identical sister. Small modifications capable of accurate assessment may be taken account of by calculation. A copy of the lightweight check report should be kept in the file record.
HEELING TESTS FOR PASSENGER SHIPS OF CLASSES V, VI AND VI(A)
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1. In accordance with paragraph 5.4.3 of these Instructions, the heeling test for non subdivided or partially decked ships of Classes V, VI and VI(A), for which accurate hydrostatic information is not available, shall be carried out in the following manner:
2. Before the vessel is tested in the fully loaded service condition specified in paragraph 3. The vessel is to be presented in a “lightweight” condition in order that the lightweight freeboards may be measured amidships, fore and aft. These freeboards are to be used as a reference for future lightweight checks which are required at five yearly intervals. (A copy of the lightweight condition is to be kept in the vessel’s stability file.)
3. The ship shall be tested with weights to represent the maximum number of passengers (and cargo if carried) in the fully loaded service condition, the weights being disposed, as far as practicable, to represent the assumed distribution of passengers (and cargo, if carried). The fuel and fresh water tanks should be 95% full or, if not so filled, weights should be added equal to the weight of fuel and water necessary to bring the tanks to this level.
4. Each passenger shall be represented by a weight of 75kg. In decked or partially decked ships, the passengers shall be assumed to congregate at 0.30 m2 per person on the highest deck or decks to which they have access, and the centre of gravity shall be assumed to be at 760mm above the deck. In open.ships, or in the open portion of partially decked ships, the centre of gravity shall be assumed to be 300mm above the seating.
5. In this condition the freeboard of the ship, measured in accordance with paragraph 2 of Section 3 of Schedule 2 of Merchant Shipping Notice MSN 1699 (M), shall not be less than 380mm for ships of 6.0m in length or less and 760mm for ships of 18.3m in length or over. For lengths between 6.0m and 18.3m the freeboard shall be calculated by interpolation.
6. Battens shall be fitted close to the outboard sides of the ship, at amidships or at the portion of least freeboard where this is not at amidships for recording the freeboards. The distance between the battens shall be measured and recorded.
7. When the ship has been loaded with weights as described in paragraph 3., the freeboards (port and starboard) are to be recorded by marking the battens. Each batten shall also be marked with lines representing angles of heel of plus or minus 7o, which correspond to freeboards of:-
plus or minus 12.3 x Distance between battens
200
8. Calculate a heeling moment equal to 1/12 the weight of the passengers (W) multiplied by the extreme breadth (B) of the vessel
= (WB/12).
9. Transfer weights from one side of the vessel to the other side in 3 equal increments, such that the final heeling moment is equal to WB/12, the vertical centre of gravity of the whole being maintained. The weights, and the distance they are moved, together with the freeboards (P and S) shall be recorded for each of the three moves. (See however paragraph 13 (ii)).
10. Restore all the weights to their original positions, and record freeboards when they are restored.
11. Repeat 9 moving weights from opposite side.
12. Repeat 10.
13.
(i) The total heeling moment of WB/12 should be applied, provided an angle of heel of 7o is not exceeded. In cases where this angle would be exceeded by the application of WB/12, the owner might be given the opportunity of adding ballast sufficient to keep the angle within 7o, and the procedures at 9, 10, 11 and 12 carried out with the ballast fitted. The weight and position of such ballast shall be recorded.
(ii) If, where WB/12 would result in an angle exceeding 7o, the owner contends that WB/12 could not arise in service and disputes the necessity of fitting ballast, special consideration may be given to such a case. In this event, the surveyor shall assess the heeling moment which is likely to arise due to the movement of passengers from one side to the other, especially on disembarkation. The boat should then be tested as at 9, 10, 11 and 12 using the heeling moment so derived instead of WB/12.
14.
(i) If the angle of the heel does not exceed 7o when a heeling moment of WB/12 is applied, the owner may be informed by the surveyor that the stability is satisfactory, and the details and results of the test attached to the ship's file for record.
(ii) If, however, the angle of heel exceeds 7o, whether ballast is fitted or not, the owner should not be given to understand, at this stage, that the stability is satisfactory. The surveyor shall submit the details and results of the test on the ship's file to the Chief Surveyor, and should state in the report whether or not heeling moment equal to WB/12 could be expected to arise in service. The acceptance of the ship, from stability considerations, will then be dealt with as follows:
(a) As a general rule, no vessel will be accepted when the angle of heel exceeds 7o as a result of a heeling moment of WB/12, or any greater heeling moment which could be expected to arise in service.
(b) Where an angle of heel exceeding 7o has arisen as a result of a heeling moment of WB/12, the seating and other arrangements of the vessel will be examined in conjunction with the surveyor's report. If it is found that a heeling moment less than WB/12 could be expected to arise in service, the information in the stability test report can then be used - by extrapolation - to see if an angle greater than 7o would arise as a result of this heeling moment.
15. In the case of existing Class V ships operating in Categories A and B waters alternative criteria may be accepted by the Regional Chief Surveyor in the form of a reduction in the allowable freeboard specified in Merchant Shipping Notice MSN 1699(M), Schedule 2, Section 3, paragraph 2 due to an angle of heel of less than 7o being attained from the heeling test which would result in an increase in the minimum residual freeboard.
BUOYANCY TESTS FOR PASSENGER SHIPS OF CLASSES V, VI AND VI(A)
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1. A vessel shall be deemed to have met the buoyancy test survivability standard, when it can be shown, by the following calculations or otherwise, that, after all compartments not totally enclosed within watertight boundaries are filled with water up to the lowest point of progressive flooding, it remains afloat with a reserve of intact buoyancy of 1/10th of the vessel’s original loaded volume of displacement. For purposes of the calculation the flooded waterline is assumed to remain parallel with the intact loaded waterline.
2. An approved type of weathertight closing appliance in a compartment boundary may be considered as watertight for the purpose of the assessment of the extent of flooding.
3. Calculations must also show that the vessel would not capsize when swamped.
4. In accordance with paragraph 5.3.3 of these Instructions the buoyancy test calculations for non subdivided ships of Classes V, VI and VI(A) shall be carried out in the following manner:
5. The ship shall comply with the requirements of Appendix B (heeling test).
6. Ships for which hull form lines are not available.
(i) Vol. of displacement = L x B x d x Cb at the LWL
(a) an average block coefficient of 0.63 may be assumed, or each space may be measured up on board the ship to give a more reliable volume of buoyancy, unless the vessel is of an unusual shape or fine hull form where it will suffice to produce an estimate of the vessels volume of displacement,
(b) the above measurements are to be taken at the waterline corresponding to the full load condition.
(c) Vol. of displacement at the LWL= L x B x d x 0.63 at the LWL.
(ii) The volume of buoyancy required = volume of displacement at the LWL x 1.1.
= L x B x d x 0.63 x 1.1
= Length x Breadth x draught x 0.7
7. Ships for which hull form lines are available.
(i) a detailed calculation should be submitted to show that;
(ii) The volume of buoyancy items = volume of displacement at the LWL x 1.1.
8. Items accepted as providing buoyancy on the vessel in the event of swamping shall include;
(i) volume of spaces enclosed within watertight boundaries and therefore assumed not flooded,
(ii) volume of the ships structure (frames, floors, seats etc.) below the flooded waterline,
(iii) volume of engine(s), tanks and other buoyant fittings which shall,
(a) be protected against deterioration or damage; and
(b) effectively secured against movement; and
(c) be installed in such a way as to offer maximum stability as far as practicable whilst the ship is in an intact or damaged state.
9. The Volume of Buoyancy to be provided = Volume of Buoyancy required at 6(ii) or 7(ii) minus items 8(i), 8(ii) and 8(iii).
10. Figures C.1 to C.5 show some typical examples for open, partially decked and fully decked ships.
Figure C.1 Open Ship
To illustrate paragraph 1(1)(a)(i) of Section 4 of Schedule 2 of
Merchant Shipping Notice M 1699 (M)
Note: The inherent (built-in) buoyancy of the vessel comprising the buoyancy (below the
assumed flooded waterline) of the shell, structure, engine, tanks, seats and their supporting
structure, fittings etc., may be taken into account when assessing the required buoyancy.
Figure C.2 Open Ship
Alternative arrangement
To illustrate paragraph 1(1)(a)(i) of section 4 of Schedule 2 of Merchant Shipping Notice M 1699
(M)
Note: In this case, provided the spaces at the forward and after end of the vessel are watertight,
the part of their volume below the assumed flooded waterline, can be added to the buoyancy as
calculated in case 1.
Figure C.3 Partially Decked Ship
To illustrate paragraph 1(1)(a)(ii) of Section 4 of Schedule 2 of Merchant Shipping
Notice 1699 (M)
Figure C.4 Decked Ship
To illustrate paragraph 1(1)(b) pf Section 4 of Schedule 2 of Merchant Shipping
Notice 1699 (M)
Note: In this case provided the hull is watertight and the deck is weathertight the ship would
meet the buoyancy requirement (irrespective whether the bulkheads are watertight or not).
Figure C.5 Decked Ship
Alternative arrangement
To illustrate paragraph 1(1)(b) of Section 4 of Schedule 2 of Merchant Shipping
Notice 1699 (M)
Note: In this case, if the vessel does not meet “one” or “two” compartment standard, provided
the hull is watertight and deck is weathertight (the deck being weathertight inside and outside the
canopy), it meets the buoyancy test requirement.
However in such case the amount of water that can be trapped inside the canopy (and that cannot
discharge itself rapidly) is to be taken into account when considering the intact stability of thevessel.
STABILITY INFORMATION BOOK
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1. SUBDIVIDED (NON RO-RO) PASSENGER SHIPS CLASSES III TO VI(A)
1.1 General
1.1.1 The information relating to the stability of the ship required by Regulation 31 and paragraph 5.3.1 of these Instructions is to include particulars appropriate to the ship of the matters specified below.
1.1.2 Such particulars are to be in the form of a Stability Information Book.
1.1.3 The book is to be divided into two parts namely Operational Information and Reference Information.
1.1.4 Metric units are to be used throughout.
1.2 Operational Information
The information provided in this part of the book is for the use of the Master in order to ensure compliance with the stability criteria and safe operation of the ship and is as follows;
1.2.1 A "General Particulars" page including;
(i) The ship's name, official number, port of registry, year of build and owners name and address,
(ii) Principal dimensions, freeboard amidships, draught to the summer load line or subdivision load line as appropriate, full load displacement and allowable operational range of trim,
(iii) Class of passenger certificate, number of passengers for which the ship is certified and the standard of survivability.
(iv) Operational restrictions, eg area of operation, weather, loading of cargo etc.
(v) Standard of survivability should include a statement of the damage stability criteria applicable to the ship and the extent of damage assumed (one or two compartment).
1.2.1.1 The area of operation and any operational restrictions are considered to be of prime importance when considering the possible relaxation of any aspect of the ship’s survivability. As such a relaxation may only have been given in consideration of the area of operation, such cases require to be recorded as the ship may subsequently relocate to operate in a different area, where such a relaxation would not be permitted.
1.2.2 A small scale “General Arrangement” plan
Showing with their names, all compartments, tanks, storerooms, crew and passenger accommodation spaces, the mid length position, fore and after perpendiculars and rake of keel (when appropriate) and the type and position of permanent ballast (when fitted). If the required permeability of any compartment has been achieved by the addition of buoyant material, the extent and type of material is to be shown on the general arrangement plan.
1.2.3 “Notes on Intact Stability Criteria”
Derived from the appropriate parts of the Regulations and Merchant Shipping Notices. Where alternative intact stability criteria have been accepted in accordance with paragraph 5.2.1.3 of these Instructions, a statement to that effect is to be included.
1.2.4 “Tank capacities and Notes on Free Surface Effects”
Including the volumes, specific gravity of the contents, centres of gravity and free surface moments. Notes on the use of free surface moments including a worked example showing how the vertical centre of gravity of the ship is affected by free surface of liquids on board.
1.2.5 “Loading conditions”
Showing the ship in the departure and arrival conditions as appropriate, and a representative selection of loaded conditions (when necessary). A reference is to be made on each condition sheet that compares the actual KG with that from the maximum permissible KG for the required draught and trim to show that the condition meets the required stability criteria.
1.2.6 “Details of the assigned subdivision load line”
Indicating the deck line, thickness of deck, keel line, thickness of keel and freeboard together with a statement of the maximum draught and displacement. In the case of ships carrying cargo a "deadweight scale" showing the displacement, tonnes per centimetre and deadweight covering the operational range of draughts for salt and fresh water operations is to be provided. Information relating to the position of draught marks is to be shown when necessary, on this arrangement, together with a sample calculation when the draught readings require correction
1.2.7 “Maximum Permissible KG Values”
This should be in the form of an envelope curve supplemented by notes on its use. It is preferable to give one envelope curve which covers all permutations of trim for both intact and damage stability considerations, unless this would lead to problems achieving the desired loading conditions.
1.2.8 “Notes for the Master Regarding Stability”
Explaining the use of the Limiting KG Curve provided for the ship and those included in Annex I of the Instructions to Surveyors.
1.3 Reference Information:-
The information provided in this part is for the use of the surveyor/consultant when assessing the stability and operational criteria provided in the Operational Information and is as follows;
1.3.1 “Hydrostatic Data”
Over the “operational” draughts of the vessel, stating whether they are for salt or fresh water. The page is to include the relationship between weight and volume.
1.3.2 “Notes on Damaged Stability Criteria"
Derived from the appropriate parts of the Regulations and Merchant Shipping Notices.
1.3.3 “The Damaged Condition” for the worst possible case
Showing compliance with the damage stability criteria and non-submergence of the margin line after damage.
1.3.4 “Maximum permissible KG Values”
Derived for both the intact and damaged stability criteria of the vessel.
1.3.5 The “Inclining Test Report and Lightship Calculation”
1.3.6 A "Lightweight History" page
This will be suitably endorsed by the attending surveyor, when the ship is checked at the required statutory periods.
1.3.7 Where it can be readily demonstrated that the margin of stability is so high that the ship cannot be overloaded in any practicable loading condition, the contents of the stability information may be reduced further. Under such circumstances, the booklet will not require items 1.2.4 and 1.2.5. Item 1.2.8 should include specific instructions for the Master to be satisfied and give ensurance that the ship is safely loaded and that, as a minimum, that no more than the certificated number of passengers are being carried and that the subdivision mark is not submerged. Where small amounts of cargo may be carried, such instruction may specify a maximum weight and location with the vertical centre of gravity not exceeding a stated value.
2. SUBDIVIDED RO-RO PASSENGER SHIPS OF CLASSES III TO VIA
2.1 General
In addition to the general requirements listed in section I the following are required to be included for Ro-Ro Passenger Ships:- 2.1.1 Special notes regarding stability for Ro-Ro passenger ships (see Annex II).
2.1.2 A "Step by Step" guide for calculating actual loading conditions, including an example on it’s use. This should state the appropriate "option" from Merchant Shipping Notice No. M.1413 upon which the cargo KG's are based.
2.1.3 A worst "in port" condition drawing attention to the need to maintain adequate freeboard at openings during loading. This condition is to show positive stability when using KN curves derived to the deck below the opening concerned.
2.1.4 If any intact superstructures have been included as contributing to the derivation of the KN curves, the extent of the superstructures is to be marked on the general arrangement plan and a note is to be included in the instructions to the person in charge emphasising the need to close all access openings in the superstructures whilst the ship is under way.
3. SAMPLE LOADING CONDITIONS
3.1 General
Where sample loading conditions are submitted for approval for inclusion in the stability information booklet, in accordance with the Regulations, consideration should be given to the following points:-
3.1.1 All approved loading conditions should show a reasonable margin of stability over the limiting curve to account for minor variations in loading from the assumed values. In this respect the size of the margin which may be accepted should be considered in conjunction with the slope of the limiting curve, and the "option" from Merchant Shipping Notice No. M.1413 which has been chosen to determine the KG of the cargo.
3.1.2 Where the slope of the limiting curve is very steep, small variations in loading may give a large variation in the limiting KG.
3.1.3 The available options for the calculation range from:-
(i) Option 1 - exact calculation with no margin, to
(ii) Option 4 - pessimistic assumptions with high margin.
3.1.3 An extract from the appropriate option (from Merchant Shipping Notice No. M.1413) used in assessing the centre of gravity of the cargo is to be included in the stability information booklet.
3.1.4 Sample loading conditions should be produced for a range of draughts and trim which cover the operational envelope of the ship. Weights and longitudinal centres of gravity may be selected to cover this operating range.
3.1.5 When preparing approved loading conditions it is recommended that cargo, including passengers, is loaded "top down" eg Those items with the highest VCG should be assumed loaded first and, where a mix of vehicular cargo is possible, that with the highest VCG should be loaded in the first instance until the required deadweight is achieved. (This would normally be HGV's, with cars and lower saloon passengers being loaded thereafter).
3.1.6 Approved loading conditions should be made up in the above manner as the Regulations require the Master to ensure that for any given draught and trim, the ship is loaded closely with, but not inferior to, one of the approved loading conditions. To do this, the Master is only required to record the draught and trim, look up the approved loading condition which most closely reflects this position, and be satisfied that the actual cargo distribution is close to but not inferior to that shown in the condition.
SPECIAL NOTES REGARDING STABILITY FOR PASSENGER SHIPS CLASSES III TO VI(A), EXCLUDING RO-RO SHIPS
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The following notes are to be included in the Stability Information Book:
1. Compliance with Stability Criteria
#1.1 Compliance with intact and damage stability criteria has been investigated and calculations have been carried out for different draughts and trims. The summary of the results are shown as maximum KG (fluid)* curves on page [ ].
#1.2 WARNING. The KG (fluid)* for any load and trim condition MUST always be below the value shown on the corresponding trim curve at the relevant draught in order that intact and damaged stability criteria are satisfied. Otherwise excessive heeling may result after damage.
#1.3 In accordance with Regulation 30 of the 1998 Merchant Shipping (Passenger Ship Construction: Ships of Classes III to VI(A) Regulations equivalent intact stability criteria have been adopted for this ship.
2. General Precautions against Capsizing
2.1 Compliance with the requirements as regards maximum KG (fluid)* information shown on page[ ] does not ensure immunity against capsizing regardless of the circumstances or absolve the master from his responsibilities. Masters should therefore exercise prudence and good seamanship having regard to the season of the year, weather forecasts and the navigational zone and should take the appropriate action as to speed and course warranted by the prevailing circumstances.
#2.2 Care should be taken to ensure that the cargo allocated to the ship is capable of being stowed so that compliance with the KG (fluid)* requirements can be achieved. If necessary, the amount of cargo should be limited to the extent that ballast weight may be required.
#2.3 Before a voyage commences care should be taken to ensure that the cargo and sizable pieces of equipment have been properly stowed or lashed so as to minimise the possibility of both longitudinal and lateral shifting while at sea, under the effect of acceleration caused by rolling and pitching.
#2.4 If cargo is to be carried, a condition must be investigated to ensure that the resulting KG is below ** the envelope curve shown on page [ ]. The method of calculating a condition is shown on page [ ]
3. CLOSING OF OPENINGS IN HULLS AND IN WATERTIGHT BULKHEADS
3.1 Watertight Doors
All watertight doors are to be kept closed at sea except those which on instructions from the Captain are allowed to be opened (see Operational Instructions for the control of watertight doors in Part 3 of the Instructions to Surveyors for passenger ships of Classes I to II(A)). In case of damage, all the watertight doors MUST be closed immediately.
3.2 Portable Plates, Manholes and Hatches
All portable plates, manholes and hatches serving spaces below the main deck are to be effectively closed and secured watertight, or weathertight where applicable, before the ship leaves port and are to be kept closed during navigation, unless specifically authorised to be opened by the Captain. The times of opening and closing of any closing devices are to be entered in the official log as required by the Regulations.
# delete if not appropriate
* when GM envelope curves are adopted, replace with GM (fluid)
** when GM envelope curves are adopted, replace with "above"
SPECIAL NOTES REGARDING STABILITY OF RO-RO PASSENGER SHIPS OF CLASSES III TO VI(A)
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The following notes are to be included in the Stability Information Book,
1. Compliance with Stability Criteria
1.1 Compliance with intact and damage stability criteria has been investigated and calculations have been carried out for different draughts and trims. The summary of the results are shown as maximum KG (fluid) * curves on pages [ ].
1.2 WARNING. The KG (fluid) * for any load and trim condition MUST always be below the value shown on the corresponding trim curve at the relevant draught in order that intact and damaged stability criteria are satisfied. Otherwise excessive heeling may result after damage.
1.3 It is important to note that the effect of the position of the Vertical Centre of Gravity of the cargo on the loading condition KG may be considerable.
#1.4 For this ship, the accepted method of determining the position of the Vertical Centre of Gravity and the Vertical Moments of Weights of Vehicles /Cargo is as shown on pages [ ].
#1.5 This method is to be used at all times when loading condition calculations are carried out.
#1.6 Before sailing the actual loading condition must be calculated. A Step by Step Guide for this calculation is given on pages [ ].
1.7 The master's attention is drawn to the contents of Merchant Shipping Notice No 1361 - "Dangers of Flooding". The master must also be aware of the adverse effect that water trapped on the Vehicle Decks has on stability, for example when the drencher system is operated. Therefore it must be ensured that the drainage scuppers on the Vehicle Decks are always clear of obstructions, rubbish etc and free at all times for operation.
Stability and Freeboard during Loading and Unloading
1.8 The Master's attention is drawn to the stability and freeboards required to be complied with during the process of loading and unloading in order that this may be carried out safely; pages [ ] refers.
2. General Precautions against Capsizing
| 2.1 | As per 2.1 in Annex I. |
| 2.2 | As per 2.2 in Annex I. |
| 2.3 | As per 2.3 in Annex I. |
| 2.4 | As per 2.4 in Annex I. |
3. Closing of Openings in Hulls and in Watertight Bulkheads
3.1 Watertight Doors
As per 3.1 in Annex I.
3.2 Portable Plates, Manholes and Hatches
As per 3.2 in Annex I.
4. Geared Valves
A list of valves essential to maintain the integrity of watertight subdivision or to effect cross-flooding, are detailed on the damage control plan.
5. Bow, Side and Stern Doors on Decks
The Bow, Side and Stern doors MUST be closed and secured weathertight before the ship leaves the berth or, if impractical, within one ship length and MUST be kept closed during navigation. The KG (fluid) * curves on pages [ ] assume that these doors are closed weathertight. The Curves are invalid if these doors are open (see Operating Instructions for the Closure of openings in Enclosed Superstructures on pages [ ]).
6. Additional Notes Applicable to the Loading of the Ship
6.1 Stability Computer
# This vessel has on board a Stability Computer which carries out calculations of loading conditions by using the method and particular option chosen, pages [ ] refers.
6.2 Calculation of Loading Conditions
This ship has approved loading conditions in accordance with the Regulations. Actual loading condition are not required to be calculated prior to departure provided that:-
6.2.1 The Master ensures that the actual loading condition corresponds closely with, or is not inferior to, one of the conditions in this booklet.
6.2.2 A record of the condition number, with which the actual loading condition corresponds, is made in a book specially retained on board for that purpose, eg by completing columns 1 to 5 and 21 to 25 of Form AFS/72, or recording the condition in the deck log book.
6.2.3 If a sailing condition does not correspond closely with any of the approved conditions in this booklet, a calculation of the actual loading condition is to be carried out in accordance with the guidance given on pages [ ]
# Delete if not applicable
* when GM envelope curves are adopted, replace with GM (fluid)
** when GM envelope curves are adopted, replace with "above"
METHOD OF DETERMINING THE SELF-EXTINGUISHING PROPERTIES OF GRP LAMINATES
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1. The test sample
A flat panel measuring not less than 1 metre square should be laid up exactly as proposed for the hull, deck, etc. moulding of the ship and allowed to cure for not less than 21 days. It should then be stored at ambient temperature for a further 30 days. A test sample measuring 450mm x 450mm should then be cut from the centre of this panel and be mounted in a suitable steel frame to prevent the edges from being ignited during the self-extinguishing test.
2. The heat source
The heat source used to conduct the self-extinguishing test should be provided by a propane gas torch fitted with a Sievert burner type No 2944 giving a maximum flame temperature of 1600 degrees celsius and burning propane at a rate of 4110 grams per hour at a pressure of 2.0kg f/cm2. The rate of burning should be very carefully controlled and the length of the blue flame should be approximately 200mm to the point of the greatest heat.
3. The self-extinguishing test
The centre of the test sample should be exposed in the vertical plane on the non gel coat surface to the tip of the blue flame of the propane gas torch for an initial period of 1 minute. During this time observations of the heat effect on the sample should be recorded.
At the end of 1 minute the propane gas torch should be removed and the sample allowed to burn. The flame on the sample should self-extinguish in less than 30 seconds.
The sample should be closely examined and its conditions noted. It should then be re-exposed to the heat source to establish total burn through time which should be noted for record purposes.
A CODE OF PRACTICE FOR NOISE LEVELS IN SHIPS
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1. The revised Code of Practice for Noise Levels in ships was published in March 1990. Merchant Shipping Notice No. M.1415 advises shipowners, shipbuilders, ship managers and masters about the application of this Code.
2. Surveyors should make themselves familiar with the Code and Merchant Shipping Notice No. M.1415. Some additional points are mentioned below in order to assist surveyors to deal with any enquiries.
3. The Code takes the form of recommendations only and compliance with the Code will automatically ensure compliance with the requirements of various Merchant Shipping legislation’s extracted at the end of the Code and other relevant legislation’s (i.e. Ship's whistle as under the Merchant Shipping (Distress Signals and Prevention Collisions) Regulations 1989). Although the Code is in the nature of recommendations, non-compliance with the Code might breach existing Regulation, e.g. the sound of a ship's whistle should not exceed 110 dB(A) at listening posts, or noise levels in machinery spaces shall not exceed 110 dB(A) etc.
4. Various other requirements of Regulations need to be compiled with (i.e. designated refuge from noise, warning notice for high noise levels, availability of ear protectors etc.), notwithstanding the recommendatory nature of the Code, wherever the noise level requires such measures by Regulation.
5. Measurement of noise levels is the responsibility of the shipbuilder or shipowner, however under certain circumstance the MCA may consider it necessary for a surveyor to attend and witness noise measurements. The Engineering Section of MCA Headquarters should be contacted for further advice.
6. Regardless as to whether a surveyor from a District Marine Office has been involved in witnessing noise measurements or not, the noise survey report should be received and examined in the marine office dealing with the building of the vessel, on the appropriate file for each ship, and forwarded to the Engineering Section of MCA Headquarters with brief comments identifying areas of the ship where the Code is not complied with.
7. Surveyors should not get involved with the acoustic design of the ship prior to noise survey, neither should they indicate agreement that acoustic design features are acceptable. Surveyors may, should the builder and owner (and possibly unions) request their attendance in the case of non-compliance with the Code, discuss the problems with them and note their intended action. In all but very obvious cases it is unlikely that the surveyor, or the MCA, would have the expertise to offer solutions or to agree to remedial action. Surveyors are not to act as arbiters in disputes. A brief report of any such meetings should be included with the noise survey report forwarded to the Engineering Section under 2.4 above.
USE OF EAR PROTECTORS
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1. The revised "Code of Practice for noise levels in ships" was published in March 1990 and Merchant Shipping Notice No. M.1415 has been issued to shipowners, shipbuilders, ship managers and masters. Compliance with the Code should also satisfy the Merchant Shipping (General duties) Regulations 1998, AS AMENDED, under which shipowners and employers have a duty to ensure the health and safety of other persons aboard ship who are not engaged in the normal business of the ship. Surveyors of the MCA, while on board ships engaged in official business, would come under this category. However, in addition, the MCA has a duty to protect its employees from the risk of noise induced hearing loss under the Health and Safety Executive Noise at Work Regulations 1989 and NOISE GUIDES by HSE which implements in the UK, EC Directive 86/188/EEC
"The Protection of workers from noise".
2. It is considered that the time spent by most surveyors under potentially hazardous noise level conditions is likely to amount to a small proportion of their working time and that they are at little or no risk. However, the following information is to be noted and appropriate action taken.
3. During surveys or inspections on board ship where surveyors move from one place to another, or during inspections in works ashore, e.g. engine testing, the length of time spent in each place may vary and it is not generally practicable to measure and control exposure to potentially harmful noise. Ear muffs are therefore provided on an individual basis to surveyors who are likely to be exposed to high noise levels. These ear muffs are of a type which, when worn correctly, will effectively reduce all noise likely to be encountered by surveyors to, or below, the limit for unprotected ears.
4. Examples of noise levels in different locations are given below in order to enable personnel to appreciate when and where a potentially harmful noise exposure may exist:
| 120 dB(A) | 60 metre from a jet aircraft taking off. Between 2 running 1800 rpm diesel generators. | |
| 110 dB(A) | 1 metre from a riveting machine. In a small ship engine room with 900 rpm diesel main engines and 900 rpm diesel generator. |
|
| 105 dB(A) | 1 metre from cylinder tops, slow speed (120 rpm) main diesel engine. | |
| 100 dB(A) | Between 2 running diesel generators (600 rpm). | |
| 95 dB(A) | In a slow speed (120 rpm) diesel main engine room at the after end of the floor plate level or in an open side flat. |
|
| 90 dB(A) | Noisy factory, machine shop, quieter parts of ship's engine rooms. | |
| 80 dB(A) | 15 metre from a pneumatic drill. | |
| 70 dB(A) | Noisy domestic machinery (vacuum cleaner at 3 metre). | |
| 60 dB(A) | Inside large public building (i.e. supermarket). | |
| 50 dB(A) | Inside a house in a suburban area during daytime. | |
| 40 dB(A) | Quiet city area outdoors at night. Library whisper at one metre. | |
| 25-30 dB(A) | Countryside at night. Quiet church. | |
| 0 | Threshold of hearing of young persons of normal hearing. |
These levels are only approximate and engine noise can vary considerably with the type of installation.
5. The following figures illustrate the acceptable maximum daily noise doses for unprotected ears, based on dB(A) sound energy received.
Less than:
| 80 dB(A) for no limit (24 hours) |
| 82 dB(A) for 16 hours |
| 85 dB(A) for 8 hours |
| 90 dB(A) for 2 hours |
| 95 dB(A) for 50 minutes |
| 100 dB(A) for 15 minutes |
| 105 dB(A) for 5 minutes |
| 110 dB(A) for 1 minute |
As an alternative illustration and equivalent to the above figures, the maximum daily noise dose for unprotected ears is halved for each increase of 3 dB(A).
i.e.
| 85 dB(A) for 8 hours |
| 88 dB(A) for 4 hours |
| 91 dB(A) for 2 hours, etc. |
6. Surveyors should not, in general, allow themselves to be exposed to sound levels exceeding 80 dB(A) unless they are wearing the ear muffs provided. However, in order to avoid unnecessary encumbrance ear muffs need not be used where exposure to noise is for short periods where in the surveyor's professional opinion the noise level and time of exposure is within the limits described above. It is suggested however that in all circumstances where other shipboard personnel are seen to be wearing ear protection the surveyor should do likewise from the point of following or setting a good example, especially as entrances to such spaces should be provided with notices warning of excessive noise levels and requiring ear protectors to be used.
7. Surveyors may wish to note that as employees they have a duty under Section 7 of the Health and Safety at Work, Act 1974 to take reasonable care to avoid injury to themselves or to others by their work activities, and to co-operate with employers and others in meeting statutory requirements. Section 8 of the Act also requires employees not to interfere with or misuse anything provided to protect their health, welfare or safety in compliance with the Act.
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