Lifeboat and liferaft provision has been at the heart of the Safety of Life at Sea (SOLAS) convention ever since the first treaty was signed in 1914, in the aftermath of Titanic. With regard to where these craft should be situated, the current rules state:
- “[They] shall be stowed as close to accommodation and service spaces as possible”
- “Muster and embarkation stations shall be readily accessible from the accommodation and work areas..”
- “Each survival craft shall be stowed, as far as practicable, in a secure and sheltered position and protected from damage by fire and explosion.”
Such wording intentionally allows for some latitude in interpretation, but is there a danger that modern ship designs could be taking that license too far?
That’s the opinion of Jan Babicz, a naval architect, surveyor, former chief designer of Gdansk Shipyard and author of Ship Design in Practice (see TNA March 2020), who has recently been highlighting some of the more egregious and potentially unsafe examples of lifeboat positioning. Among these are two new multipurpose (MPP) DP2 B-type vessels currently being built for Spliethoff at Mawei Shipyard, China, the design for which has the free-fall lifeboat located extreme aft aboard ship with the superstructure located fore.
Lifeboat arrangements of this nature are not uncommon particularly where free-fall lifeboats are involved. In a similar case, Wagenborg’s EasyMax MPP tweendecker series (starting with the 2017-delivered Egbert Wagenborg) requires crew located in the superstructure to travel the length of the vessel via a corridor under the deck to reach the lifeboat.
Why is this allowed? Although lifeboats should be stored ‘as close as possible’ to the ship’s accommodation, there is also a mandate under SOLAS III/31.1.2.1 that lifeboats can only be launched from the vessel’s stern. Moreover, at the flag state’s discretion, ships equipped with free-fall lifeboats may also be excluded from the SOLAS requirement for merchant vessels to have 200% lifeboat capacity. In other words, there is no need to supplement lifeboat provision with additional conventional davit lifeboats on the port and starboard.
Neither Conoship, naval architects for the under-construction Spliethoff vessels, nor Lloyd’s Register, the appointed classification society, were available for comment when approached by TNA. However, one source explained that a determining factor in such decisions is SOLAS III/31.1.5, which states:
“All survival craft required to provide for abandonment by the total number of persons on board shall be capable of being launched with their full complement of persons and equipment within a period of 10 minutes from the time the abandon ship signal is given.”
Therefore, one has to assume that, in the aforementioned examples, the classification societies are satisfied that the vessels could be completely evacuated in 10 minutes. In mitigation, it should also be noted that since the engines are located aft, officers and crew working in the engine room would obviously reach the lifeboats in a much quicker time (although the bridge is clearly quite another matter).
Babicz tells TNA that he has inquired with a number of classification societies and regulators with little success. He explains: “I received three answers: from DNV GL, Russian Register and IMO. All of them defended the solution of free-release aft with accommodation foreship. DNV GL sees this as modern design.”
He believes accommodation fore is nothing more than an example of poor design that ignores crew safety. Furthermore, he doesn’t think there is any technical reason why a free-release lifeboat couldn’t be situated behind the superstructure or even at the front wall.
“In my opinion ‘as far as possible’ means that designers shall check all reasonable solutions to place lifeboats near crew accommodation. Their explanations I treat as [an] inadmissible compromise,” he concludes.