Route change to an international crossing with a lifeboat out of service
A 1,450 GT, 96 m day-cruise vessel holds a domestic certificate for 350 persons (46 crew, 304 passengers) on a 3 nm sheltered-water route. Her life-saving appliances are two 120-person partially enclosed lifeboats, one each side, and four davit-launched 50-person liferafts, two each side. The galley has a deep-fat fryer protected only by a 9-litre foam extinguisher, the laundry has no detector, and smoke detectors cover the rest of the accommodation. The owner wins a contract for a 14 nm crossing to a neighbouring State. During the pre-contract survey a crack is found in the starboard lifeboat davit's slewing ring, and the maker quotes six weeks for a replacement. The owner proposes to start the new service with the starboard boat removed and "only" 200 persons on board, arguing that the four liferafts still provide 200 places, and asks the port authority to authorise the first sailing while the flag's route approval is pending.
1. Assess the owner's reduced-complement proposal against the life-saving appliance rules for a passenger ship.
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The proposal fails, and the arithmetic is the wrong calculation. SOLAS III/21.1.1 requires passenger ships to carry lifeboats of capacity for at least 50% of all persons on each side, plus davit-launched liferafts for at least 25% of all persons. For 350 persons that is 175 lifeboat places per side; the ship has 120 per side, so she does not comply even with both boats in service, and liferafts cannot substitute for the lifeboat requirement. With the starboard boat removed, starboard lifeboat capacity is zero, so no reduction in persons cures it. The largest complement for which 120 places per side satisfies the 50% rule is 240 persons, and that still assumes both boats are available. The correct answer to the port authority is that the service cannot begin: the options are to repair or replace the davit and restore the boat, to increase lifeboat capacity, or to reduce the certified complement to a figure the lifeboats can genuinely cover, which still requires the starboard boat back in service.
2. What does the 14 nm crossing change about the ship's certification regime?
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It is a change of regime, not a permission. A crossing to another State is an international voyage, so the ship becomes a SOLAS passenger ship (more than 12 passengers) and needs a Passenger Ship Safety Certificate supported by surveys of subdivision and damage stability, fire integrity, life-saving appliances, radio and navigation. The domestic certificate does not bridge that gap and the port authority cannot authorise the trade. Expect findings on the lifeboat capacity, on compliance with the subdivision index for damage stability, and on the fire integrity of accommodation boundaries. ISM applies to all passenger ships, so the company needs a Document of Compliance and the ship a Safety Management Certificate; ISPS applies to passenger ships on international voyages with no lower size limit. The flag issues the certificate and would have to accept any equivalent arrangement. The owner's assumption that only a route approval is missing is wrong and should be corrected before any contract is signed.
3. What fire-safety findings would you expect, and how should they be resolved?
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Two clear findings. First, the deep-fat fryer. SOLAS chapter II-2 requires deep-fat cooking equipment to be fitted with a fixed extinguishing arrangement tested to a recognised standard, a primary and a secondary thermostat, and a manual fuel shut-off; a 9-litre foam extinguisher is not an equivalent and would not control a fryer fire. Second, the laundry is a service space inside the accommodation and should be covered by the fixed fire detection and fire alarm system, unless a documented exemption is justified by the flag; a blind spot in a space with heat-producing appliances is exactly where detection matters. Both deficiencies would be raised at the Passenger Ship Safety Certificate survey, and both are cheap to fix relative to the cost of a delayed start. The resolution is to fit an approved fixed system to the fryer with the thermostats and shut-off, extend detection into the laundry, and have the additions surveyed and recorded before the first international voyage.