Convention requirement interpreted by HKMD
1. Maintenance of portable fire extinguishers
IMO Res.A.951(23), paragraph 9.1.1
（1）Portable fire extinguishers are to be examined annually by a competent person; (A competent person may be taken as Chief Officer, Second Engineer or above);
（2）Each portable fire extinguisher is to be with a tag indicating that it has been examined;
（3）CO2/Halon Portable fire extinguishers should not to be located in accommodation spaces;
（4）At least one portable fire extinguisher of each type manufactured in the same year and kept on board a ship is to should be test discharged at five yearly intervals (as part of a fire drill).
2. Spare charges for portable fire extinguishers
IMO MSC/Circ.847, paragraph 6.2
For portable fire extinguishers of the same type, capable of being recharged on board, the spare charges are to should be provided as follows:
(1) For portable fire extinguishers capable of being recharged on board, the requirements are as follows: 100% for the first ten portable fire extinguishers of the same type and 50% for the remaining portable fire extinguishers but not more than 60; and
(2) For portable fire extinguishers that cannot be recharged by the crew, additional portable fire extinguishers of the same quantity, type, capacity and number as determined in (1) above are toshould should be provided in lieu of spare charges.
3. Testing for portable fire extinguishers
IMO MSC/Circ.847, paragraph 6.5
Containers of permanently pressurized portable fire extinguishers and propellant bottles of non-pressurized portable fire extinguishers are to be hydraulic pressure tested as follows by a competent service station recognized by CCS:
(1) Powder type of portable fire extinguishers every 10 years;
(2) CO2 type of portable fire extinguishers every 10 years;
(3) Other type of portable fire extinguishers every 10 years; and
(4) Containers of non-permanently pressurized portable fire extinguishers are to be hydraulic pressure tested every 10 years.
4. Maintenance and inspection of fixed carbon dioxide fire extinguishing system
IMO MSC/Circ.1318 MSC.1/Circ.1318/Rev.1, paragraph 6.1.2
http:www.mardep.gov.hk/en/pub_services/pdf/clsolas 100318.pdf
All Hong Kong registered ships shall carry out maintenance and inspection of fixed carbon dioxide fire extinguishing systems in accordance with IMO MSC/Circ.1318 MSC.1/Circ.1318/Rev.1. High pressure cylinders should be subject to hydrostatic tests at intervals not exceeding 10 years. At the 10-year inspection, at least 10% of the total number provided should be subject to an internal inspection and hydrostatic test by a competent service station recognized by CCS.
5. Controls for fixed carbon dioxide fire extinguishing system
FSS Code, Chapter 5, paragraph 2.2.2
Carbon dioxide systems are to shall comply with the following requirements:
(1) Two separate controls are to shall be provided for releasing carbon dioxide into a protected space and to ensure the activation of the alarm. One control is to be used for opening the valve of the piping which conveys the gas into the protected space and a second control are to shall be used to discharge the gas from its storage containers. Feasible measures are to be taken to ensure the sequence of operation; and
(2) The two controls are to shall be located inside a release box clearly identified for the particular space. If the box containing the controls is to be locked, a key to the box are to shall be in a break-glass-type enclosure conspicuously located adjacent to the box.
6. Foam fire-extinguishing systems
IACS Recommendation No.53-2
IMO MSC/Circ.1312, MSC/Circ.670 and MSC/Circ.798
Fixed foam extinguishing systems are to should be inspected every two years by a competent service station recognized by CCS. Foam Sample test is to analysis shall be carried out to foam concentrate stored onboard in after a period of 3 years of date supplied onboard after being supplied to the ship and thereafter every year. Sample test is to be carried out to foam concentrate by a at authorized service agent or manufacturer’s laboratory authorized by CCS. A record of the age of the foam concentrates and of subsequent controls is to should be kept onboard.
7. Air cylinders for self contained breathing apparatus (SCBA)
IMO MSC/Circ.850, 1432
IACS Recommendation No.88
SCBA air cylinders are to be examined at least annually by a competent service station recognized by CCS. SCBA cylinders are to be hydraulic pressure tested at intervals not exceeding 5 years and the hydrostatic test is to be carried out by a competent service station recognized by CCS, and the hydrostatic test date must be permanently marked on the bottles. Two spare charges suitable for use with the breathing apparatus are to be provided for each SCBA. If cargo ships are equipped with suitably located means for fully recharging the air cylinders free from contamination, only one spare charge is required for each required SCBA.
8．Air bottles for air supply in totally enclosed lifeboats
IACS Recommendation No.88
Air bottles are to be hydraulic pressure tested by a competent service station recognized by CCS at intervals not exceeding 5 years and the hydrostatic test date must be permanently marked on the bottles.
10. IMSBC
IMSBC certificate is to be issued according to ship owners and relevant agreement of CCS. The certificate is not to be issued on behalf of HKSAR, and without label of “ISSUED ON BEHALF OF HKSAR”.
11．Remotely located survival crafts
IACS unified interpretation SC 213
IMO MSC/Circ.1243 1490
Liferafts, if located at the aft/forward end of the ship and at a distance of more than 100m from the closest survival craft, as required by SOLAS regulation III/31.1.4, are to be regarded as “remotely located survival craft” with regards to SOLAS regulation III/7.2.1.2. Following requirements are to be applied to all HK cargo ships regardless of date of construction.
(1) A minimum number of 2 lifejackets and 2 immersion suits;
(2) Adequate means of illumination, complying with SOLAS regulation III/16.7, either fixed or portable, which are to be capable of illuminating the liferaft stowage position as well as the area of water into which the liferaft are to be launched. Portable lights, when used, are to have brackets to permit their positioning on both sides of the ship; and
(3) An embarkation ladder or other means of embarkation enabling descent to the water in a controlled manner * in accordance with SOLAS regulation III/11.7.
* Controlled manner: A knotted rope is not acceptable for this purpose.
12．Periodic servicing and maintenance of lifeboats launching appliances & on-loadrelease gear
http://www.mardep.gov.hk/en/pub_services/pdf/clsolas060904.pdf
In accordance with the IMO MSC.1/Circ.1206/Rev.1, ship management company is to employ the manufacturer or a person appropriately trained and certified by the manufacturer to carry out the annual servicing and maintenance of lifeboats, launching appliance and on-load release gear. Under special circumstances, if ship management company may not be able to source the manufacturer certified facilities or personnel to carry out the servicing and maintenance work, HKMD would accept a service provider to carry out these functions, provided that the following conditions are complied with.
(1) The service provider is to be a firm engaging in ship repair/maintenance business, and is to have adequate track record to prove that it has sufficient expertise and experience in inspection, repair, testing and maintenance of lifeboats, launching appliances and on-load release gear and such record is to be done to the satisfaction of site surveyor and the service provider is to the satisfaction of site surveyor under the provision of IMO MSC.1/Circ.1277;
(2) When carrying out servicing and maintenance, the service provider is to follow the Guidelines as stated in the Annex 1 and the Specific procedures as stated in the Appendix of IMO MSC.1/Circ.1206/Rev.1;
(3) The five-yearly dynamic operational test of the winch brake is to be witnessed and monitored by CCS’s surveyor and meet surveyor’s requirements; and
(4) Upon completion of the services, reports and records as stated in paragraph 13 to 15 of Annex 1 of IMO MSC.1/Circ.1206/Rev.1 are to be properly maintained onboard.
13．Lifeboat turnout
SOLAS regulation III/20.7
SOLAS regulation III/20.7 requires that all lifeboats, except free-fall lifeboats, are to be turned out from their stowed position, without any person onboard if weather and sea conditions so allow.
14．Lifeboat drill
IMO MSC/Circ.1206/Rev.1, annex 2, paragraph 2.3.2
When performing drills with persons on board a lifeboat, the lifeboat is to first be lowered and recovered without persons on board to ascertain that the arrangement functions correctly. The lifeboat is to then be lowered into the water with only the number of persons on board necessary to operate the boat.
15．Freefall lifeboat drill
IMO MSC/Circ.1206/Rev.1, annex 2, paragraph 2.4.2
When the lifeboat is free-fall launched as part of a drill, this is to be carried out with the minimum personnel required to manoeuvre the boat in the water and to recover it. The recovery operation is to be carried out with special attention, bearing in mind the high risk level of this operation. Where permitted by SOLAS, simulated launching of lifeboats is to be carried out in accordance with the manufacturer’s instructions, and in compliance with requirements of the IMO MSC.1/Circ.1206/Rev.1.
16．Lifeboat fall preventer device
IMO MSC/Circ.1327
A “Fall Preventer Device” (FPD) can be used to minimize the risk of injury or death by providing a secondary alternate load path in the event of failure of the on-load hook or its release mechanism or of accidental release of the on-load hook. However, FPDs are not to be regarded as a substitute for a safe on-load release mechanism.
If FPDs are provided, they must be designed, installed, inspected and utilized in accordance with the manufacturer instruction and complied with IMO MSC.1/Circ.1327. The ship’s operating crew should be familiar with the operation of the FPD fitted to the lifeboat on their ship. The procedure to be followed is to be contained in the ISM Code documentation and the ship’s training manual.
17．Falls used in launching life saving appliances
Code of safe working practices for merchant seaman, annex 20.1
Wire rope grips “bulldog grips” are not accepted. Where wire rope grips “bulldog grips” are found to have been used on primary load-bearing terminations, arrangements are to be made by the operators to have them replaced wedged socket etc.
18．Drug
http://www.legislation.gov.hk（Cap478X）
http://www.mardep.gov.hk(Public Service/other related Services-4.Mercantile Marine Office)
Hong Kong registered cargo ships are to be equipped with drug according to http://www.legislation.gov.hk/bis_ind.nsf/elbf50c09a33dc482564840019d2f4/1d3061bc86bebc35482564ac0008b64d?OpenDocument or HKMSIN NO.57/2006.
A cargo ship registered in Hong Kong is required to have onboard medicines in accordance with the scales set out in the following;
1. The Schedule(s) of Cap478X “MERCHANT SHIPPING(SEAFARERS)(MEDICAL STORES)
REGULATION”;or
2. Annexes of MD notice “alternative Medicines and Medical Equipment to be kept on board
Hong Kong Seagoing Ships, and Hong Kong Seagoing Ship Carrying Dangerous Goods” is
Also acceptable to Marine Department
19．Requirement on ship material and equipment
HKMSIN No.32/2009 49/2014, paragraph 8
HKMD accepts materials and equipment complying with relevant IMO test procedure/standard and operation specification. In general, ship material and equipment accepted by any classification society approved by national administration or HKMD are allowed for Hong Kong registered cargo ships.
20. GMDSS radio installations operation and maintenance（MSIN 54/2013）
http://www.mardep.gov.hk/en/pub_services/pdf/clpsc071127.pdf
Test on DSC radio installations must be completed with reception acknowledgement so that the effectiveness of the equipment could be ensured. If no acknowledgement is received despite of numerous tests, it is to be recorded in the radio logbook and the shore engineer is to be called upon to check the effectiveness of the DSC radio.
The Administration required to not the MSC.1/Circ.1460 and act accordingly.
21．Dispensation for shipboard crew
Article VIII of STCW Convention
Dispensation for a Master or a Chief Engineer will never be granted except in circumstances of force majeure in accordance with STCW Article VIII.
22．Application evidence for certificate of endorsement
The “Consolidated Application for the Issue of Hong Kong Licence(s)” is the official acknowledgement and is issued in accordance with paragraph 5 of STCW regulation I/10. The officers is allowed to serve on Hong Kong registered ship(s) in the indicated or lower for three months pending the issue of the Hong Kong Licences under STCW I/2 paragraph 5. The fax copy of the “Consolidated Application for the Issue of Hong Kong Licence(s)” serves the purpose of documentary proof and there is no mandatory requirement to have original copy onboard for this official acknowledgement.
23．Annual Performance Test of AIS
IMO MSC/Circ.1252
To carry out annual performance test of AIS in accordance with the IMO MSC.Circ.1252 by a qualified radio inspector of an approved radio firm, and to retain the "AIS Performance Test Report" issued by the radio firm on board the ship.
24. Annual Performance Test of EPIRB
IMO MSC/Circ.1040 1123
To carry out annual performance test of EPIRB in accordance with the IMO MSC.Circ.1040 1252 by a qualified radio inspector of an approved radio firm, and to retain the "EPIRB Performance Test Report" issued by the radio firm on board the ship.
25. Annual Performance Test of VDR/S-VDR
IMO MSC/Circ.1222
To carry out annual performance test of VDR/S-VDR in accordance with the IMO MSC/Circ.1222 by a qualified radio inspector of an approved radio firm, and to retain the "VDR/S-VDR Performance Test Report" issued by the radio firm on board the ship.
26．Crew’s work and break time inspection by PSC
http://www.mardep.gov.hk/en/pub_services/pdf/psc_insp.pdf
This circular letter is to remind owner of Hong Kong registered ship and master from managing company to comply with requirement on crew’s work and break time by International Convention on Standards of Training, Certification and Watch-keeping for Seafarers, 1978, and suggest to use standard IMO/ILO format to record crew’s work and break time, as well as the interval.
27．Port State Control
HKMSIN No.31/2009 48/2014, paragraph 12
In the event of a Hong Kong registered ship being detained as a result of PSC intervention, the shipmaster or owner should immediately:
(1) Forward a copy of the PSC inspection report (i.e. FORM A and FORM B), stating when, where and by whom the ship has been detained, to this Department; and
(2) Contact the local office(s) of the ship’s Classification Society and/or the ship’s SMC classification Society and/or the ship’s ISSC Recognized Security Organization to arrange an inspection and/or audit for confirmation of the deficiencies and/or nonconformities, and other necessary remedial action as directed by the port State.
28．Emergency escape breathing device (EEBD)
IACS Recommendation No.88
IMO MSC/Circ.1081, 1432
At least two (2) EEBDs and one spare EEBD are to be provided in accommodation spaces.
EEBDs are to be provided in machinery spaces as stated below:-
(1) Machinery spaces of category A containing machinery used for main propulsion:
(a) One (1) EEBD in the engine control room, if located within the space.
(b) One (1) EEBD in workshop areas, if there is, however, a direct access to an escape way from the workshop, an EEBD is not requirement.
(c) One (1) EEBD on each deck or platform level near the escape ladder constituting the second means of escape from the machinery space (the other means being an enclosed escape trunk or watertight door at the lower level of the space).
(2) In machinery spaces of category A other than those of above (1):
(a) One (1) EEBD, as a minimum, on each deck or platform level near the escape ladder other than a fire shelter, an escape trunk or a watertight access door to safe spaces.
Emergency Escape Breathing Devices are to be examined at least annually by suitably qualified ship’ staff, or by a competent service station recognized by CCS.
Hydrostatic testing of EEBD is to be carried out in accordance with the repair and maintenance manual from manufacturer.
29．Immersion suit
IMO MSC/Circ.1114, Annex, paragraph 3
(1) An immersion suit of an appropriate size is to be provided for every person on board;
(2) At least two (2) immersion suits of an appropriate size at the bridge;
(3) At least two (2) immersion suits of an appropriate size at the engine control room; and
(4) At least two (2) immersion suits of appropriate size for additional forward liferaft fitted.
To ensure the maintenance of adequate strength and water tightness of immersion suits and anti-exposure suit, each suit is subject to an air pressure test at intervals not exceeding three years, or more frequent test for suits over ten years.
30. Electronic Nautical Publications and Digital Notice to Mariner
HKMSIN No. 49/2011 34/2013, Annex 2
IMO MSC-MEPC.2/Circ 2
Referring to enquiry of using Electronic Nautical Publications (ENPs) and Digital Notice to Mariner (Ntm) with applicable correction/amendment for nautical publications (either paper or electronic publication) on board HK registered ship,
please note the following:-
(1) In any case, the media should be treated in accordance with the document control procedures in the ship.s SMS including procedures for timely update.
(2) Bearing in mind that such publications or Digital Ntm need to be readily available for use in case of emergency without being restricted to a specific place and by the availability of a computer.
(3) In addition, hard copies of the publications and their correction/amendment for emergency use, including the International Code of Signals and IAMSAR Manual,shall be provided on board.
(4) When ENPs are used on board Hong Kong registered ships, the following requirements are applicable:-
(a) ENPs shall either be published by IMO, an Administration, a hydrographic organization, or other organizations which are authorized by an Administration;
(b) ENPs shall be kept up-to-date;
(c) ENPs shall be accessible to the Officer of Watch (OOW) without the need to leave his duty station;
(d) a computer shall be dedicated for ENPs and connected always to the main and emergency power supplies;
(e) for backup purpose, ENPs shall also be available in another computer on board which shall be accessible to the OOW in a short period of time; and
(f) operational guidelines for using the system and viewing of the publications shall be available on board and make known to the officers concerned.
(5) When using Digital Ntm with applicable correction/amendment for either ENPs or paper publication on board HK registered ship, the above guideline should also be taken into consideration.
(6) In additional to the above guidelines, it is advised to refer to the detail of MSC-MEPC.2/Circ.2 IMO requirements on carriage of publications on board ships.
31. Official Logbook and other logbooks/records
Official logbook for Hong Kong registered ships: The specific form HKLOG3 should be used as a ship’s Official Log Book.
The Official Log Book is available at MMO (Mercantile Marine Office).
Tel: 2852 4387 email: mmo_mdd@mardep.gov.hk
The following logbooks and record books could be purchased from other suppliers or Information Services Department or the
Shroff / Central Marine Office of Marine Department.
Global Maritime Distress & Safety System (GMDDSS) Radio Log
Oil Record Book Part 1 - Machinery Space Operations (All Ships)(MO632)
Oil Record Book Part II - Cargo/Ballast Operations (Oil Tankers)(MO633)
Garbage Record Book
32. Multiple Load Lines
http://www.mardep.gov.hk/en/pub_services/pdf/clloadline061220.pdf(dated27/12/2012)
Applicant should contact the Recognized Organization (RO) directly and provided with the details such as the figure of original load line with the dead weight and the new load line with the new dead weight etc. to seek Marine Department’s
authorization for assigning additional load lines.
Each set of the load line marks shall be verified by a surveyor of the RO when they are marked on the ships sides for the first time and subsequent periodical inspections.
Marine Department accepts that the verification can be conducted by the ship’s master instead of the RO surveyor. For change of the assigned freeboard, the master should follow the guidelines.
33. Exemption from Fixed Fire-extinguishing System Cargo Spaces
Cap. 369Y, regulation 31(2)(b)
Every cargo space on cargo ship of 2,000 tons and upwards shall be provided a fixed gas fire extinguishing system complying with the provisions of the Fire Safety Systems Code (FFS).
The Director may exempt any Hong Kong registered ship from the above requirements if the ship is constructed and solely intended for the carriage of ore, coal, grain, unseasoned timber or non-combustible cargoes or cargoes which, in the opinion
of the Director, constitute a low fire risk; and the ship is fitted with steel hatch covers and effective means of closing all ventilators and other openings leading to the cargo spaces.
Applicant (either owners/management company/Recognized Organization) should send the application for the exemption to Cargo Ships Safety Section (e-mail: ss_css@mardep.gov.hk) with: (A) a statement issued by the Recognized Organization
(RO) to confirm that the vessel complies with SOLAS Reg. II-2 10.7.1.4 as follows:
(1) the vessel is constructed, and solely intended, for the carriage of ore, coal grain, unseasoned timber, non-combustible cargoes or cargoes which constitute a low fire risk; and
(2) the ship is fitted with steel hatch covers and effective means of closing all ventilators and other openings leading to the cargo spaces; and
(B) a copy of the “Certificate of Survey” (COS) of the ship issued by the RO.
The initial Exemption Certificate will be issued by the Director of Marine. However, for operational conveniences to all parties, all subsequent renewal of these exemption certificates may tie in with the renewal of the trading certificates and be issued by
ROs or RSOs. The Director needs not be consulted by ROs or RSOs on the renewal of such exemption certificates unless the conditions stated by the Director in the original exemption certificates cannot be fulfilled.
34. Bridge Navigational Watch Alarm System (BNWAS)
The position of Hong Kong Marine Department is as follows:
(a) BNWAS which is going to be installed prior to 1 July 2011 should preferably be of an approved type conforming to IMO resolution MSC.128(75) - Performance Standards for a Bridge Navigational Watch Alarm System (BNWAS), unless the
owner applies for exemption from us with reasonable grounds;
(b) BNWAS which is already installed may be exempted from full compliance with MSC.128(75) provided that it has similar functions to a BNWAS conforming to MSC.128(75); and
(c) BNWAS which is not in full compliance with MSC.128(75) should be tested by its manufacturers or our recognized ROs to confirm that it is suitable for installation on board ships and has similar functions to a BNWAS conforming to MSC.128(75).
If the BNWAS was installed prior to 1 July 2011, you are required to approach the vessel’s classification society for their verification of complying with the above.
Otherwise, BNWAS installed after 1 July 2011, it needs full compliance with IMO standards requirement.