Notes on reading SOLAS
by Russell Lunt
Copyright Russell Lunt 2001

The International Convention for the Safety of Life at Sea (SOLAS) is one of the oldest conventions of its kind. The first version was adopted in 1914 following the sinking of the R.M.S. "TITANIC" with the loss of more than 1500 lives.

Since then, there have been four more versions of SOLAS – 1929, 1948, 1960, and the present SOLAS 1974 version which entered into force in 1980. Parts of the Convention apply to every ship, including small pleasure craft.

A Protocol of 1978 (SOLAS Protocol 1978) dealing with safety matters relating to tankers was adopted by the International Conference on Tanker Safety and Pollution Prevention, and came into force in 1981. Over the last 20 years there have been several amendments to both treaty documents. These amendments are not just to correct the spelling! Since 1974 the amendments have added extra chapters to SOLAS, for GMDSS, ISM, etc., and in 1988 a new SOLAS Protocol replaced the Protocol of 1978.

As SOLAS is an agreement between Governments who 'undertake to give effect to the provisions of the present Convention and the annex thereto', it is ultimately the flag State under which a yacht is registered who is responsible for interpretations and implementation of the Regulations. Yacht owners should always contact their national maritime administrations for guidance and relevant national rules and regulations.

SOLAS is published as a hard back book by the International Maritime Organisation, and contains the consolidated text of both treaty documents, articles, annexes and certificates. It is obviously easier to work with the most recent edition which incorporates amendments in force at date of publication. The latest edition – SOLAS Consolidated Edition, 2001 - is just published – January 2001 – and incorporates all amendments in effect from 1^st January, 2001.

Don’t discard your old copy yet. To identify some requirements applicable to ships constructed before 2001, previous texts of the 1974 SOLAS Convention, the 1988 SOLAS Protocol and the amendments to the Convention should be consulted. For instance, special requirements for existing passenger ships are contained only in part F of chapter II-2 of the original 1974 SOLAS Convention but neither in chapter II-2 of the 1981 amendments nor in the latest consolidated edition.

The consolidated edition of SOLAS runs to over 500 pages.

Part 1 - the bulk of the book, up to page 493 - contains the actual Articles of the International Convention for the Safety of Life at Sea, 1974, and those of the Protocol of 1988 (this only to page 15) and the rest is the consolidated text of the annexes to the Convention and Protocol. Appendices give examples of certificates.

Part 2 – the last 20 pages – contains 3 items:

• Resolution A.883(21): Global and uniform implementation of the harmonized system of survey and certification (HSSC).
• A very useful list of Certificates and documents required to be carried on board ships.
• List of resolutions adopted by the SOLAS Conferences.

We shall concern ourselves with a look at the consolidated text of the annex to the 1974 SOLAS Convention and the 1988 Protocol, which is divided into 12 chapters. Each chapter contains Regulations, and the numbering of these Regulations starts again with each chapter. Some chapters have more than one part, and in this case the Regulation numbers run on through the different parts.

Unless expressly provided otherwise, SOLAS applies only to ships engaged on an ‘international voyage’ – which is defined as ‘a voyage from a country to which the present Convention applies to a port outside such country, or conversely’. (Note that it is ‘expressly provided otherwise’ in chapter V. The first part of each chapter gives the details of which types of ship the chapter will apply).

A ‘passenger’ is defined as ‘every person other than:

(i) the master and the members of the crew or other persons employed or engaged in any capacity on board a ship on the business of that ship; and

(ii) a child under one year of age.’

A ‘passenger ship’ is a ship which carries more than twelve passengers.

A ‘cargo ship’ is any ship which is not a passenger ship.

The regulations, unless expressly provided otherwise, do not apply to:

1. Ships of war and troopships.
2. Cargo ships of less than 500 gross tons.
3. Ships not propelled by mechanical means.
4. Wooden ships of primitive build.
5. Pleasure yachts not engaged in trade.
6. Fishing vessels.

Although ‘pleasure yacht’ is not defined, it follows that if a pleasure yacht is ‘engaged in trade’ it is – for the purposes of SOLAS – a ‘cargo ship, and if more than 500 gross tons then the regulations apply.

Regulation 5 provides for Administrations (the Government of the State whose flag the ship is entitled to fly) to allow any alternative fitting, material, appliance or apparatus to be fitted or carried, or any other provision to be made in a particular ship, if it is satisfied by trial thereof or otherwise that the alternative is at least as effective as that required by the regulations. This gives Administrations fairly wide powers to accept equivalents, although they are required to pass particulars of the substitution, together with a report on any trials, to the IMO for them to circulate to other Contracting Governments.

This section (Regulations 6 – 20) deals with Safety Certificates - who inspects, the types of Certificates issued, the duration, and measures to be taken in the case that deficiencies are found.

The inspections and surveys are to be carried out by officers of the Administration, or surveyors nominated by them. In either case, the Administration assumes full responsibility for the certificates.

Until recently, cargo ships were always issued with 3 separate safety certificates, unlike passenger ships which were issued with a single Passenger Ship Safety Certificate which was valid for 12 months. This was because the different Cargo Ship Safety Certificates had different duration’s – one year for the Radio Certificate, two for the Equipment Certificate and five years for the Construction Certificate. Administrations may now issue a single Cargo Ship Safety Certificate, valid for up to 5 years, but like the separate certificates (which still may be issued) subject to various intermediate survey requirements. The surveys are the same whether 3 separate certificates or the single certificate is issued.

Cargo Ship Safety Radio Certificate – issued after survey of the radio equipment and installation (including any used in life saving appliances). Valid up to 5 years, but subject to annual surveys. Supplemented by a Record of Equipment.

Cargo Ship Safety Equipment Certificate – issued after survey of the life saving appliances and arrangements, navigation equipment, fire safety systems and appliances, fire control plans, embarkation of pilots, and nautical publications. Lights, shapes and sound signals are also included in this survey for the purpose of ensuring that they comply fully with the requirements of SOLAS and the International Regulations for Preventing Collisions at Sea (COLREGS). Valid up to 5 years, but subject to annual survey, and a periodical survey (more thorough than an annual survey) in place of the second or third annual survey. Supplemented by a Record of Equipment.

Cargo Ship Safety Construction Certificate – issues after survey of hull, machinery and equipment, including the arrangements, materials and scantlings of the structure, machinery, steering gear, control systems, electrical installation and other equipment. Valid up to 5 years, but subject to annual surveys, and an intermediate survey in place of the second or third annual survey.

When an exemption is granted to a ship, an Exemption Certificate is issued in addition to the Safety Certificate(s).

All Safety Certificates cease to be valid on change of flag.

Regulation 19 authorises officers duly appointed by Governments to control visiting ships (Port State Control), the circumstances under which ships may be detained, and points out that all possible efforts shall be made to avoid a ship being unduly detained or delayed. Ships which are unduly detained or delayed shall be entitled to compensation for any loss or damage suffered.

This part contains only Regulation 21, which obliges Administrations to conduct investigations of any casualty when it judges that it may assist in determining any changes in the regulations.

Like all the chapters, this starts with more detail of ships to which the chapter applies. Chapter II-1, unless expressly provided otherwise, applies to ships built on or after 1 July 1986. Ships built before need to comply with the earlier version of SOLAS 1974. In this chapter the expression ‘all ships’ means ships constructed before, on, or after 1 July 1986. The expression is re-defined in each chapter.

Administrations may exempt individual or classes of ships from any requirements which may be unreasonable or unnecessary, given the sheltered nature of voyages by ships which do not proceed more than 20 miles from land.

There are good definitions in this part, including ‘permeability of a space’ which is the percentage of that space which can be occupied by water, measured only to the height of the ‘margin line’, which is a line drawn at least 76mm below the upper surface of the bulkhead deck at side. The ‘bulkhead deck’ is the uppermost deck up to which the transverse watertight bulkheads are carried.

Regulation 3-1 of this part requires ships shall be designed, constructed and maintained in compliance to the rules of a classification society (or equivalent national standards).

The rest deals with corrosion prevention of seawater ballast tanks, safe access to tanker bows, and emergency towing arrangements on tankers.

This part deals with floodable lengths in passenger ships, permeability in passenger ships, lengths of compartments, stability of passenger ships in damaged condition and similar subjects – all with formulae for the computation of criterion of service numeral which determines the factor of subdivision.

Watertight bulkheads, double bottoms, watertight doors, openings in shell plating, bilge pumping arrangements, stability information, damage control plans, and related subjects are covered. Cargo ships require a watertight collision bulkhead located at a distance from the forward perpendicular of not less than 5% of the length of the ship. This would normally be 5% of the ships length back from the bow at the waterline, and no doors or openings (apart from a single pipe protected with valve) are allowed to penetrate this bulkhead. Cargo ships built on or after 1 February 1992 are required to have a double bottom extending from the collision bulkhead to the afterpeak bulkhead, as far as this is practicable and compatible with the design and proper working of the ship.

This part applies to cargo ships over 100m built on or after 1 February 1992, and between 80m and 100m if built on or after 1 July 1998. The regulations are intended to provide ships with a minimum standard of subdivision, and deals with the calculation of the required subdivision index R, the attained subdivision index A (this not to be less than R), calculation of the factors p_i (the probability that only the compartment or group of compartments under consideration may be flooded, disregarding any horizontal subdivision) and s_i, (the probability of survival after flooding those compartments, including the effects of any horizontal subdivision).

Related regulations deal with permeability, stability information, openings in watertight bulkheads and external openings in cargo ships.

This part applies to passenger ships and cargo ships. It deals fully with the safety and reliability of machinery. Some points from this part:

• It requires Administrations to ‘give special consideration to the reliability of single essential propulsion components’.
• Main Propulsion is to be retained (or restored) in the event of a breakdown of one of the essential auxiliaries.
• Means to be provided to ensure that the machinery can be brought into operation from the dead ship condition without external aid.
• Engines with cylinder diameter of 200mm or a crankcase volume of 0.6m³ to have crankcase explosion relief valves.
• Stopping times, ship headings and distances on trials, performance with only one engine etc. to be recorded and available on board.
• Main steering gear to put the rudder from 35deg on side to 30deg on other side in 28 seconds whilst running ahead at maximum service speed.
• Auxiliary steering gear to put the rudder from 15deg on side to 15deg on the other in 1 minute whilst running ahead at half speed.
• Indicators for propeller speed and direction to be fitted on the bridge (and engine control room if the ship is built on or after 1 July 1998).
• At least 2 means of communication (one being an engine-room telegraph) to be provided between navigation bridge and engine control room.

This part gives quite general descriptions of much of the installation, and great detail about emergency lighting, emergency power sources, times emergency equipment is required to operate, transitional source of emergency power (to operate between shut down of main power and start of emergency genset), precautions against shock and other electrical hazards, and type and use of cables. As examples:

• Administrations are required to ensure the uniformity of electrical installations, and referred to the publications of the International Electotechnical Commission, especially Publication 92 – Electrical Installations in Ships.
• The main source of electrical power is to be at least two gensets, and any one should be able to run the ship.
• Emergency source of power and emergency switchboard to be provided, and to be located above the uppermost continuous deck, remote from the main power and switchboard and from the engine room boundaries, and with ready access to the open deck.
• Emergency source of power, which can be either a genset or batteries, to supply power for given minimum times to emergency services including emergency lighting, navigation lights, radio equipment, navigation equipment, fire detection and alarm, fire pump, emergency bilge pump.

The arrangements provided shall be such as to ensure that the safety of the ship in all sailing conditions, including manoeuvring, is equivalent to that of a ship with manned machinery spaces.

Engines of 2,250 kW and above or having cylinders of more than 300mm bore shall be provided with crankcase oil mist detectors or engine bearing temperature monitors or equivalent devices.

Increased requirements apply to bilge pumping, engine controls, communications, alarm systems, automatic machinery shut-down, generator operation including load shedding to ensure the integrity of power for essential services.

Unless expressly provided otherwise, this chapter applies to ships built on or after 1 July 1998. Ships built before need to comply with earlier versions of SOLAS. ‘All ships’ means ships built before or after that date.

The basic principals which are applied – depending on the type of ship – are:

• Division of the ship into main vertical zones, and separation of accommodation spaces, by thermal and structural boundaries.
• Restricted use of combustible materials.
• Detection, containment and extinction of any fire in the zone of origin.
• Protection of means of escape or access for fire fighting.
• Ready availability of fire fighting appliances.
• Minimization of possibility of ignition of flammable cargo vapour.

Requirements are detailed and provide exact details of equipment and specifications.

Full details of bulkheads and fire test requirements, escape routes, ventilation systems, fixed fire fighting systems – for passenger ships.

As above, but for cargo ships. With restricted use of combustible materials.

As may be imagined, a very detailed chapter.

This chapter applies to ships built on or after 1 July 1998. ‘All ships’ means ships built before, on or after that date. Ships built prior to that date need to conform to earlier versions of SOLAS, and phase into the latest requirements as and when equipment is replaced. There are good definitions in this section, including ‘Length’, ‘Moulded depth’, and ‘Novel life-saving appliance or arrangement’.

The paragraph dealing with Radio life-saving appliances (the requirement to carry VHF radio and Radar transponders) applies to passenger ships, cargo ships over 500GT, and to a slightly lesser extent all cargo ships between 300GT and 500GT.

As well as detailing the various appliances to be carried, sections dealing with Muster lists, Abandon ship drill procedures, Emergency training and drills, Fire drills, On-board training and instructions, Operational readiness, Servicing and maintenance of life-saving appliances and related issues give a very good (and easy to understand) overview of the types of systems which should be in place on board.

Taking section I as basic requirements for all ships, sections II, III and IV give the additional requirements for passenger ships (II), cargo ships (III), and section IV requires life-saving appliances to comply with the requirements of ‘the Code’ – which is the International Life-Saving Appliance (LSA) Code adopted by the Maritime Safety Committee of the IMO by resolution MSC.48(66). It is the responsibility of the ship to fit equipment approved by the flag State Administration, and the responsibility of the Administration to ensure that they only approve equipment which meets the standards set out in ‘the Code’.

This is a very useful part which gives the format for the compilation of the Training manual and on-board training aids, Instructions for on-board maintenance, and the Muster List and emergency instructions.

This chapter deals with the Global Maritime Distress and Safety System (GMDSS) and is in three parts:

The requirements of this chapter apply to passenger ships and cargo ships of 300 GT and upwards. There was a phase-in period for ships built before February 1995, but this has now passed, and since February 1999 all of these ships have needed to comply fully with this chapter. Whilst other chapters give various degrees of latitude to Administrations to accept equivalents or allow exemptions, it is noted here that ‘Contracting Governments consider it highly desirable not to deviate from the requirements of this chapter’. Any partial or conditional exemptions which may be granted to individual ships needs to be reported to IMO together with the reasons for granting the exemption.

The four Sea Areas are defined, A1 (VHF coverage), A2 (MF coverage), A3 (INMARSAT coverage) and A4 (an area outside the other 3).

The actual Functional Requirements are summarised in simple and positive language – ‘Every ship, while at sea, shall be capable.....of transmitting ship-to-shore distress alerts by at least two separate and independent means, each using a different Radiocommunication service.....of receiving shore-to ship distress alerts.....and so on.

This deals with the undertaking from Contracting Governments to make available shore-based facilities for space and terrestrial Radiocommunication services, providing service by Satellite, VHF, MF and HF as may be appropriate.

These 14 pages give the detail of the equipment to be carried and service provided on board so the ship can comply with the Functional Requirements as set out in Part A. The concise and (in general) non-technical descriptions of Equipment, Power sources, Watches to be maintained, Maintenance requirements and Certification of personnel, are – apart from being the prime regulations - a valuable introduction to the whole system of GMDSS to yachtsmen who may be considering fitting GMDSS as a ‘voluntary fit’.

This chapter, unless otherwise expressly provided for in this chapter, applies to all ships on all voyages, except ships of war and ships solely navigating the Great Lakes of North America and their connecting and tributary waters.

SOME PARTS OF THIS CHAPTER THEREFORE APPLY TO ‘PLEASURE YACHTS’ OF ANY SIZE.

The various express provisions within this chapter which effectively exempt certain types or sizes of ships (including yachts) from compliance to some of the Regulations in this chapter take a number of different forms and need to be read with great care. Some of the Regulations apply to ‘every ship to which Chapter I of SOLAS applies’ – that meaning they apply to passenger ships, and cargo ships over 500GT, engaged on international voyages (so other ships do not need to comply). Other descriptions used to either include or exclude ships from particular Regulations include:

• Ships of less than 150 gross tonnage.
• Ships of 150 gross tonnage and upwards.
• All ships of over 150 gross tonnage, when engaged on international voyages.
• On every passenger ship to which chapter I applies.
• Ships engaged on voyages in the course of which pilots are likely to be employed,
• All ships which, in accordance with the present Convention, are required to carry radio installations.
• Ships of not less than 45m in length.
• ....and lots more.

Apart from the need to comply with fairly obvious requirements, there are some perhaps less well known requirements which apply to ALL yachts. Some requirements (well known and not so well known) which apply to ALL YACHTS are:

• The Master of every ship is bound to report Danger Messages (e.g. meeting dangerous ice, derelict, or other direct danger to navigation, or tropical storm, etc.).
   
• The Master of a ship at sea which is in a position to be able to provide assistance, on receiving a signal from any source that persons are in distress at sea, is bound to proceed with all speed to their assistance.... (Note – this Regulation 10 goes on to provide that in special circumstances, if the master considers it unreasonable or unnecessary to proceed to their assistance he must log the reasons and inform search and rescue services accordingly.)
   
• The Master shall not be constrained by the shipowner, charterer or any other person from taking any decision which, in the professional judgement of the Master, is necessary for safe navigation, in particular in severe weather and in heavy seas.
   
• The Contracting Governments undertake, each for its national ships, to maintain, or, if it is necessary, to adopt, measures for the purpose of ensuring that, from the point of view of safety of life at sea, all ships shall be sufficiently and efficiently manned. (Note – in a footnote attention is drawn to the Principals of safe manning adopted by IMO by resolution A.890(21) and to IMO Maritime Safety Committee Circular 242 on single-handed voyages.) Ships to which chapter I of SOLAS applies are required to carry a Safe Manning Document.)
   

• Ships engaged on voyages in the course of which pilots are likely to be employed shall be provided with pilot transfer arrangements. (Note – there follows 4 pages with the detail of the required arrangements.)
   
• Within 12 hours before departure, the ship’s steering gear is to be checked and tested by the ship’s crew. Administrations may waive this requirement for ships which regularly engage on short voyages, in which case they should be done at least once a week. Dates of checks and tests to be logged.
   
• All ships shall carry adequate and up-to-date charts, sailing directions, lists of lights, notices to mariners, tide tables, and all other nautical publications necessary for the intended voyage.

CHAPTER VI (Carriage of cargoes) and Chapter VII (Carriage of dangerous goods) deal with their titled subjects, and have almost no relation to yachts – although they do both apply to cargo ships of less than 500GT. CHAPTER VIII deals with Nuclear ships. The relevant Nuclear Passenger Ship Safety Certificate and Nuclear Cargo Ship Safety Certificate are valid for one year.

This chapter brings into effect the requirement for the owner or manager of the ship (the ‘Company) and the ship, to comply with the IMO International Safety Management (ISM) Code and to be issued with a Document of Compliance (DOC) by the Administration after satisfactory audit. The ship, which must carry a copy of the DOC, is issued with a Safety Management Certificate after the Administration verify that the Company and its shipboard management operate in accordance with the approved safety-management plan.

These regulations already apply to passenger ships and tankers, and come into force for cargo ships of 500GT and upwards on 1^st July 2002. Note also that Resolution 3 of the 1994 Conference of Contracting Governments to the International Convention for the Safety Of Life At Sea strongly urges Governments to implement as far as practicable the ISM Code for cargo ships of 150GT and over, and requests Governments to inform IMO of the action they have taken to implement the ISM Code for those smaller ships.

High Speed Craft – as defined in this chapter and operating no more than 4 or 8 hours (depending if passenger or cargo craft) from a place of refuge – conforming to the IMO High-Speed Craft (HSC) Code ‘in its entirety’ shall be deemed to have complied with the requirements of chapters I to IV and regulation V/12 of SOLAS. The HSC Code is an alternative to SOLAS in those areas, and drafted to be more suitable for High Speed Craft which operate in coastal waters and rely on shore based maintenance. The one and a half pages of this chapter in SOLAS only gives effect to the use of the HSC Code. The actual Code is a booklet – separately available from IMO – which gives all the detail.

This is a general ‘tidying up’ exercise dealing with Authorisation of recognised organizations, Enhanced surveys (bulk carriers and oil tankers), and Port State Control. There is one Regulation which may apply to yachts, and that is the requirement for all cargo ships (that includes pleasure yachts engaged in trade) of 300 GT and upwards to be provided with an IMO identification number.

Additional requirements relating to damage stability and structural strength of bulk carriers.

This gives forms of the Safety Certificates for Passenger and Cargo ships.

SOLAS, Consolidated Edition, 2001
English Language Version IMO-110E
Available from:
International Maritime Organization, 4, Albert Embankment, London, SE1 7SR.
Tel: +44 (0) 20 77 35 76 11 Fax: +44 (0) 20 75 87 32 41
Website: http://www.imo.org    e-mail: info@imo.org