NVIC 03-19: Servicing lifeboats, rescue boats and launching appliances

Commandant U.S. Coast Guard Stop 7501 United States Coast Guard 2703 Martin Luther King Jr. Ave SE Washington, DC 20593-7501 Staff Symbol: CG-5P Email: TypeApproval@uscg.mil COMDTPUB 16700.4 NVIC 03-19 November 20, 2019 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 03-19 Subj: MAINTENANCE, THOROUGH EXAMINATION, OPERATIONAL TESTING, OVERHAUL AND REPAIR OF LIFEBOATS AND RESCUE BOATS, LAUNCHING APPLIANCES AND RELEASE GEAR Ref: (a) Servicing and Maintenance of Lifeboats, Launching Appliances and On-load Release Gear, NVIC 04-07, COMDTPUB P16700.4 (b) Title 46 Code of Federal Regulations (CFR) Part 199

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — PURPOSE. This Navigation and Vessel Inspection Circular (NVIC) provides guidance to

assist owners and operators of vessels that are subject to the requirements in the International Convention for the Safety of Life at Sea (SOLAS) on complying with the amendments to SOLAS Chapter III Regulations 3 and 20, through the International Maritime Organization (IMO) Maritime Safety Committee (MSC) Resolution MSC.404(96). These amendments will enter into force on January 1, 2020. Additionally, this NVIC provides guidance with respect to IMO Resolution MSC.402(96) Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear.

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — ACTION.

a. The Coast Guard will use this guidance to provide information on how vessel owners and operators may comply with the amendments to SOLAS Chapter III Regulation 3 and 20 and the IMO Resolution MSC.402(96). b. Vessel owners and operators, lifesaving equipment manufacturers, servicing and repair facilities and personnel may use this guidance to ensure that the servicing and maintenance of lifeboats, rescue boats, release gear, and launching systems for their vessels are carried out in accordance with SOLAS Chapter III Regulations 3 and 20, and the IMO Resolution MSC.402(96). DISTRIBUTION SDL No. 169 a b c d e f g h i j k l m n o p q r s t u v w x y z A B X X X X C X X X X D E X X X X F G H X NON-STANDARD DISTRIBUTION: NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 03-19 c. Internet release is authorized.

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — DIRECTIVES AFFECTED. Reference (a) is cancelled.

DIRECTIVES AFFECTED. Reference (a) is cancelled.

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — BACKGROUND.

a. Over the years, life-saving appliances have become more sophisticated, providing increased capabilities better able to deal with different possible types of shipboard casualties. This is readily apparent in such equipment as modern totally enclosed tanker lifeboats, fast rescue boats, and on-load/offload release mechanisms. While this equipment provides greater functionality, they also come with greater complexity, and consequently are more difficult and critical to maintain properly. Ship operators now rely more heavily on specially trained personnel, outside of the ship’s crew, to maintain their life-saving appliances. Unfortunately, accidents involving life-saving appliances, some resulting in fatalities, have been reported worldwide, often due to operator error or improper maintenance. b. In 2006, the IMO developed guidelines for periodic servicing and maintenance of lifeboats, launching appliances and on-load release gear (MSC.1/Circ.1206) to address accidents with life-saving equipment. In 2007, the Coast Guard promulgated NVIC 04- 07 as guidance on how to apply the non-mandatory provisions of MSC.1/Circ.1206. In 2008, the IMO also developed guidelines with interim recommendations on conditions for authorization of service providers (MSC.1/Circ.1277) to be used in conjunction with MSC.1/Circ.1206. In 2009, MSC.1/Circ.1206 was revised to consolidate the circulars on preventing accidents with lifeboats and included amendments to the guidelines for periodic servicing and maintenance of lifeboats, launching appliances and release gears

(MSC.1/Circ.1206/Rev.1). c. In 2016, the IMO Maritime Safety Committee (MSC) incorporated MSC.1/Circ.1206/Rev.1 and MSC.1/Circ.1277 into IMO Resolution MSC.402(96) Requirements For Maintenance, Thorough Examination, Operational Testing, Overhaul And Repair Of Lifeboats And Rescue Boats, Launching Appliances And Release Gear. The MSC implemented those requirements through amendments to SOLAS Chapter III by IMO Resolution MSC.404(96). IMO Resolutions MSC.402(96) and MSC.404(96) will enter into force on January 1, 2020.

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — DISCUSSION.

a. In accordance with 46 CFR § 2.01-25, the Officer in Charge, Marine Inspection (OCMI), or an Authorized Classification Society, will issue a SOLAS Cargo Ship Safety Certificate or Passenger Ship Safety Certificate, following verification that the vessel complies with the relevant requirements of the International Convention for the Safety of Life at Sea (SOLAS). b. The amendments to SOLAS Regulations III/20 and III/3 are given in IMO Resolution MSC.404(96), Enclosure (1). SOLAS Regulation III/20 adds specific examinations and NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 03-19 tests required for each type of equipment. SOLAS Regulation III/3 adds the definition for requirements for maintenance, thorough examination, operational testing, overhaul, and repair as meeting the requirements in IMO Resolution MSC.402(96). IMO Resolution MSC.402(96), provided in Enclosure (2), outlines the requirements for maintenance, through examination, operation testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear. c. These SOLAS requirements apply to the servicing of lifeboats, rescue boats, launching appliances and release mechanisms on vessels that are subject to the requirements in SOLAS. This includes those vessels enrolled in the Alternate Compliance Program or the Maritime Security Program. d. For those vessels that are not subject to the requirements of SOLAS, the Coast Guard recommends they also follow the guidance in this NVIC when servicing their lifesaving equipment. e. The U.S. requirements for maintenance and inspection of lifesaving equipment on board inspected U.S. vessels can be found in Reference (b). This policy does not supersede the requirements found in Reference (b).

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — IMPLEMENTATION.

a. Coast Guard Headquarters.

(1) IMO Resolution MSC.402(96) Section 3, Authorization, in Enclosure (2), states that the Administration shall ensure that the examination, operational testing, repair and overhaul of equipment is carried out by service providers authorized by the Administration.

(2) The Coast Guard considers a service provider to be authorized by the Administration if a classification society that is an Authorized Classification Society (ACS) under 46 CFR § 8.420 has verified the service provider is capable of servicing life-saving equipment in accordance with Reference (b) and Enclosure (2). The procedures for verifying a service provider’s capability should include the International Association of Classification Societies Unified Requirement Z17 Procedural Requirements for Service Suppliers.

(3) The Coast Guard may conduct oversight on the ACS to verify the ACS is complying with U.S. and IMO requirements. The Coast Guard may review records pertaining to the authorization of service providers when an issue is discovered with a service provider authorized by the ACS.

(4) The Coast Guard maintains a list of ACSs on the Flag State Control Division website at https://www.dco.uscg.mil/Our-Organization/Assistant-Commandant-for- Prevention-Policy-CG-5P/Inspections-Compliance-CG-5PC-/Commercial-Vessel- Compliance/Flag-State-Control-Division/AltComp/. NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 03-19 b. Coast Guard Officer in Charge, Marine Inspection.

(1) In accordance with 33 CFR § 1.01-20 and 46 CFR § 199.45, the local Coast Guard Officer In-charge, Marine Inspection (OCMI) is responsible for conducting tests and inspections to verify the proper condition and operation of lifesaving equipment onboard U.S. vessels.

(a) The OCMI may inspect the lifesaving equipment and review the servicing records during annual vessel inspections.

(b) The OCMI may witness the annual and 5-year testing of lifesaving equipment, and the testing for repairs, as appropriate.

(c) If the OCMI is the issuing authority for the SOLAS Safety Certificates required in SOLAS Regulation I/12, the OCMI should be present to witness important maintenance and repairs of the lifesaving equipment.

(2) In accordance with 46 CFR § 199.190(a) and SOLAS Regulation III/20, all life- saving appliances must be in working order and ready for immediate use. If the lifesaving equipment is not being maintained, inspected or tested as required, the OCMI may withhold or withdraw the COI. The OCMI should work with the vessel owner and operator, and the service provider to correct any issues with lifesaving equipment. The OCMI should contact the ACS and Coast Guard Headquarters if the issue involves an authorized service provider. c. Authorized Classification Society.

(1) An Authorized Classification Society (ACS) under 46 CFR § 8.420, may authorize service providers to conduct the maintenance, servicing, inspection and testing of lifesaving equipment required in Enclosure (2). The Coast Guard considers those services providers to be authorized by the Administration.

(2) The ACS should issue authorization documentation after verifying that the service provider is capable of servicing the equipment in accordance with Reference (b) and Enclosure (2). Once the authorization documentation is issued, the service provider may be considered an Authorized Service Provider (ASP).

(a) The ACS should use the procedures in the International Association of Classification Societies Unified Requirement Z17 Procedural Requirements for Service Suppliers to verify the service provider’s capability of servicing life- saving equipment in accordance with Reference (b) and Enclosure (2).

(b) The ACS should conduct an initial audit of the service provider during their review. NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 03-19

(3) The ACS should periodically verify that the ASP is continuing to carry out the requirements in Enclosure (2), including conducting periodic audits of the ASP. Any significant non-conformity may result in an ACS surveyor attending a servicing by an ASP and the ACS notifying the Coast Guard.

(a) The ACS audits should occur at least every 5 years or during the ASP reauthorization. Audits may occur more frequently as determined by the ACS.

(b) The ACS audits should also occur whenever an issue with an ASP is identified. These audits may be conducted in conjunction with the Coast Guard.

(4) The ACSs should maintain a record of the ASP authorization documentation and verification results for the time that the ASP is authorized to be a service provider. These records should be made available to the Coast Guard, as requested.

(5) The ACS should maintain a list of authorized service providers that is available to vessel owners and operators. The ACS should provide the location of that list to the Coast Guard.

(6) If the ACS is the issuing authority for the SOLAS Safety Certificates, required in SOLAS Regulation I/12, the ACS should be present to witness important testing, maintenance and repairs of the lifesaving equipment. d. Authorized Service Providers.

(1) A service provider may be either an original equipment manufacturer or a third party service provider. Some components of lifeboat and launching systems are generally of common and conventional designs for which service and repair do not necessarily require manufacturer-specific expertise.

(2) A service provider should apply to be an authorized service provider through an ACS. The service provider should provide evidence they are capable of meeting the requirements in Section 7 in Enclosure (2). Upon a successful initial audit of the service provider, the ACS should issue authorization documentation outlining the scope of services provided by the service provider. Once the authorization documentation is issued, the service provider may be considered an Authorized Service Provider (ASP). The ASP should maintain their authorization documentation for the period of validity.

(3) Paragraph 7.1.1 of Enclosure (2) requires the ASP employ personnel certified to conduct inspection, maintenance, servicing and testing for each make and type of equipment for which the ASP provides service. The Coast Guard’s definitions for make and type are provided in Enclosure (3).

(4) Where a lifesaving appliance manufacturer believes that a particular model requires certified servicing personnel to have additional competencies, those competencies NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 03-19 should be identified during the equipment approval process and will be listed on the USCG Certificate of Approval for that model.

(5) The ASP and each certified technician should maintain a record of the scope of their certifications and training as required.

(6) The ASP should maintain their servicing program records for the duration of the time they are authorized as an ASP. These records should be made available to the Coast Guard or ACS during an audit, as requested. e. Vessel Owners and Operators.

(1) The SOLAS amendments in Enclosures (1) and (2) enter into force on January 1, 2020. The requirements in those amendments will be applicable to vessels that are subject to the requirements in SOLAS.

(2) Enclosures (1) and (2) require the owners and operators of vessels subject to the requirements in SOLAS to use certified personnel of an equipment manufacturer or ASP to carry out the annual thorough examination and operational tests, and the five- year thorough examination, overhaul, and overload operational tests. Shipboard personnel or certified personnel of an ASP may conduct the weekly and monthly inspections, and routine maintenance.

(3) Vessel owners and operators may use an ASP authorized by an ACS, as described in the sections above.

(a) The Coast Guard maintains a list of ACSs on the Flag State Control Division website at https://www.dco.uscg.mil/Our-Organization/Assistant-Commandant- for-Prevention-Policy-CG-5P/Inspections-Compliance-CG-5PC-/Commercial- Vessel-Compliance/Flag-State-Control-Division/AltComp/.

(b) ACSs should maintain a list of service providers they authorize.

(c) Issues involving the unavailability of an equipment manufacturer or ASP will be handled on a case-by-case basis. If the original equipment manufacturer is unavailable and there is no ASP available to conduct the required servicing or testing, the vessel owner or operator should contact Commandant (CG-ENG-4), Lifesaving and Fire Safety Division at TypeApproval@uscg.mil.

(4) Vessel owners and operators should maintain the maintenance manuals and technical documentation for all lifesaving equipment onboard the vessel subject to the requirements in IMO Resolution MSC.402(96).

(5) Vessel owners and operators should maintain a record of the lifesaving equipment servicing on board the vessel for the service life of the equipment. These records NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 03-19 should be made available to Coast Guard inspectors during annual inspections, as requested. f. Feedback. In order to provide supporting documentation for future discussions at IMO concerning the application of IMO Resolution MSC.402(96), vessel owners and operators, lifesaving equipment manufacturers, service providers and personnel, and OCMIs are encouraged to inform the Commandant (CG-ENG-4) of any practical problems encountered in the implementation of its provisions, particularly with regard to availability of Authorized Service Providers.

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — DISCLAIMER. This guidance is not a substitute for applicable legal requirements, nor is it

itself a regulation. It is not intended to, nor does it impose legally-binding requirements on any party. It represents the Coast Guard’s current thinking on this topic and is issued for guidance purposes to outline methods of best practice for compliance with the applicable law. You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations.

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — ENVIRONMENTAL ASPECT AND IMPACT CONSIDERATIONS.

a. The development of this publication and the general policies contained within it have been thoroughly reviewed by the originating office in conjunction with the Office of Environmental Management, Commandant (CG-47). This publication is categorically excluded under current Department of Homeland Security (DHS) categorical exclusion DHS (CATEX) A3 from further environmental analysis in accordance with the U.S. Coast Guard Environmental Planning Policy, COMDTINST 5090.1 and the Environmental Planning (EP) Implementing Procedures (IP). b. This publication will not have any of the following: significant cumulative impacts on the human environment; substantial controversy or substantial change to existing environmental conditions; or inconsistencies with any Federal, State, or local laws or administrative determinations relating to the environment. All future specific actions resulting from the general policy in this publication must be individually evaluated for compliance with the National Environmental Policy Act (NEPA) and Environmental Effects Abroad of Major Federal Actions, Executive Order 12114, Department of Homeland Security (DHS) NEPA policy, Coast Guard Environmental Planning policy, and compliance with all other applicable environmental mandates.

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — DISTRIBUTION. No paper distribution will be made of this NVIC. An electronic version

will be located at https://www.dco.uscg.mil/Our-Organization/NVIC/.

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — RECORDS MANAGEMENT CONSIDERATIONS. This NVIC has been thoroughly

reviewed during the directives clearance process, and it has been determined there are no further records scheduling requirements, in accordance with the Federal Records Act (44 U.S.C. 3101 et seq.), NARA requirements, and the Information and Life Cycle Management Manual, COMDTINST M5212.12 (series). This policy does not create significant or substantial change to existing records management requirements. NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 03-19

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — FORMS/REPORTS. None.

FORMS/REPORTS. None.

Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair Of Lifeboats and Rescue Boats, Launching Appliances and Release Gear — REQUEST FOR CHANGES. All requests for changes and regarding implementation of this

NVIC should be directed to Commandant (CG-ENG-4), Lifesaving and Fire Safety Division at TypeApproval@uscg.mil. R. V. TIMME Rear Admiral, U.S. Coast Guard Assistant Commandant for Prevention Policy Encl: (1) IMO Resolution MSC.404(96) - Amendments to the International Convention for the Safety of Life at Sea, as amended (2) IMO Resolution MSC.402(96) - Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear (3) Coast Guard Definitions for Make and Type