Author &
Organisation

Reference

Comments

Response

Bill Farquhar

Macduff Shipyards Ltd

General:  Consultation Circulation

Robb Bailey

MCA

Last sentence: “If the motor and fuel tank are stowed in the boat they should stowed in such a manner that damage to the motor, fuel tank and the boat will not occur when the boat is stowed on board the vessel.”

Is this correct?

Roger Jansen

Survey and Inspection Branch MCA

Will be"live" and will be updated whenever relevant changes occur.

Bill Farquhar

Macduff Shipyards Ltd

5.2

Survey of Boilers:  Thought that this had been dropped by 15-24m Code, and also >24m Code

Boilers & other pressure vessels do exist on FVs, even if not for propulsion purposes. This section is retained because unclassed vessels need MCA survey.

Dead ship condition

If you have to use a deadship start because the electrical supply had failed, how does the electrical supply charge the battery?

Cross connections to an existing pump on board can be used to circulate the FW cooling system, but if the main pump has failed you still have to push the water through that pump. Better to carry a spare FW pump.

Not if connected in parallel.

Spares are addressed in 5.16

It was agreed that pumps could be fitted with automatic NRV to prevent leakage.

Agreed with whom ? How does a NRV prevent leakage from a tank ? The alternative to QC valves was agreed as pump stop.

We have never seen an internal examination of a fuel tank by an MCA Surveyor at a periodic survey

Really ? If vessel not classed then MCA surveyor must undertake CSM/CSH schedule surveys.

We have never seen a thermometer fitted to an oil fuel tank.

Will amend to “ on vessels operating on heavy fuel oil”. If oil is required to be heated then thermometers are required.

We have never fitted anything other than trip wire pulls

There are many vessels with hydraulic actuation.

In a vessel with a double bottom in the fishroom wing sumps would be fitted which drain down at more than 5º to ensure that bilge water remains in the central well.

This is not a contradiction, but a means to comply.

In a vessel with open floors it is customary to fit concrete ballast with a surface finish of more than 5º to ensure that bilge water remains in the central well.

This is not a contradiction, but a means to comply

Not if the valves are correctly operated.

“Slush wells should be easily accessed with suitable covers in place; access with fish cargo in hold should also be considered”.  This is impractical, fishrooms should have duplicate systems with further back up by hand pump.

MCA is obliged by MAIB recommendation

O.K. will amend

“Vessels over 24m require the main circulating pumps to be fitted with emergency bilge suction connections, however, these pump need to be self priming”.

Will amend to “ONE of the main S.W. circulating pumps” – class rule

We cannot find reference to this in the draft code, and we are not too sure what is meant.  How can you use a circulating pump for bilge pumping duties.

Any sea water pump can be utilised for bilge pumping.

“For vessels length 15-24m the diameter is increased by 5mm”.  This need not necessarily be the case – the figure 25 in the formula is changed to the figure 30.

30 – 25 = 5

A direct suction, as the name implies does not go through the valve chest.  If you split it again to wing suction we are back to the problem of pulling air into the system.  More emphasis should be make on containing bilge water in the central well.

Not a distribution chest but a chest on the pump may have two direct suctions. More applicable to larger vessels. Will enter comment re central well for smaller vessels

Bilge pumps could be used as standby circulating pump for main engine, but would require cross – connections not direct suction connections.  This should not be in this chapter.

Will delete this para.

There should not be a requirement for “equivalent capacity”.  It is perfectly acceptable to have a standby system where engine can be operated on reduced capacity to get to port.  Again this should not be in this chapter.

Will delete this para.

We have considered float switches before on deck sumps but have been advised against this by an electrical sub-contractor who has experienced major maintenance problems with this.

It is customary to have starters for deck sump pumps and electric motor driven pump at main deck level, usually just inside deckhouse door. Starters on 415/3/50 motors should be transformed down to 110v for safety.

Not understood. There is no mention here of float switches.

Aluminium bronze type material is used on piping for engine systems, there is nothing wrong with galvanized steel piping for bilge systems.

Aluminium bronze type material is used for bilge piping on some wooden boats.

Do not agree with minimum size of galvanized steel piping – 50mm pipe is commonly used.

The figure 30 is used in the formula for branch pipes in the 15-24m Code. No mention of branch pipe formula seems to be made in the draft 24m Code.

See 75 Rules and class rules

It is more common to fit the isolating valve on the aft side of the collision bulkhead, but because of access problems an extended spindle is fitted to control the valve from above the freeboard deck.

Engine suctions are a different matter, but not for this chapter.

“Flexible piping should not be used on the discharge side of pumps”.  If a bilge pump is belt driven from a flexibly mounted engine (noting that we are now to consider noise and vibration) then both suction and discharge pipes would require flexibles.

Will include comment “normally” … “ smaller vessels having engine mounted pumps may…”

General Comment – it is quite clear in the Code and in the 1975 Rules that systems are to be installed in a manner which prevents back flooding.  The Banff & Buchan Study shows an example of a bilge system with sea water and bilge suctions going through the same valve chest without even making reference to the fact that this does not meet rule requirements.  More emphasis should be make on what is acceptable and what is not.

Ships hull not to be used as an earth conductor  In new installations the hull not to be used for termination

It is our electrical sub-contractor’s opinion that all new work should be double pole.

That’s what 7.2.6 says.

However, it is alright to use single pole as long as the negative is insulated from the hull.

On existing old boats the hull may have been used as negative – in this situation it will probably have to be left.

We have to make some distinction between an 18m prawn trawler and a pelagic super-trawler; paralleling of generators is not an absolute necessity.  You don’t have blackingout because you always have your 24v emergency lights.  When changing over the lights will only cut out for an instant, and motors with automatic start will be ok.

Will preface with “where applicable”

Again automatic starting of an emergency generator is ok for a super-trawler with a chief and second engineer and a control room with computerized systems.  Automatic starting is not a necessity.

Then it is not an emergency generator.

There are 2 general points we would like to raise:-

1.There never seems to be any mention of paralleling of batteries – starter batteries, lighting batteries, aux batteries. i.e. if the starter batteries are flat due to an alternator not working, and the engine is stopped – how can the engine be started quickly?

Every main engine should have:-

• battery paralleling switching, or
• change over system for starters, or
• system for other alternators to charge starter batteries