Authorized service providers for life-saving appliances

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Policy objective

1.1 This policy implements requirements from the International Maritime Organization’s (IMO) Resolution A.761(18) (Recommendation on conditions for the approval of servicing stations for inflatable life rafts), as amended, and Resolution MSC.404(96) (Amendments to the International Convention for the Safety of Life at Sea, 1974, as amended).

1.2 These resolutions relate to the maintenance, testing and servicing of life-saving appliances. This policy also sets parameters for authorizing service providers.

Policy statement

2.1 Annex 1 of this policy outlines the provisions and interpretations for the implementation of IMO Resolution A.761(18), amended by MSC.55(66)Footnote 1 and MSC.388(94)Footnote 2, addressing testing and procedures related to servicing of inflatable survival equipment.

2.2 Annexes 2 and 3 of this policy outline the provisions and additional interpretations and guidance for the implementation of IMO Resolution MSC.404(96) with respect to SOLAS III/20 and MSC.402(96)Footnote 3, addressing the operational testing of lifeboats and rescue boats, launching appliances and release gear.

2.3 Any Canadian authorized service provider (ASP) must be approved by Canadian Recognized Organizations (RO) on behalf of Transport Canada (TC). The approval of an ASP situated outside Canada and issued by a Recognized Organization on behalf of another administration will be recognized by TC provided the approval is issued by one of the Canadian RO and the ASPs accepts in writing to make available all approval-related documentation upon request by TC.

Scope

3.1 This policy applies to convention vessels or any vessel subject to the Alternative Regulatory Regime for Inspection, Construction and Safety Equipment policy through a Marine Technical Review Board (MTRB) decision.

3.2 Once the proposed Vessel Construction and Equipment Regulations come into force, this policy will also apply to all Canadian vessels 24 metres or more in length. In the interim, maintenance, testing and servicing of life-saving appliances made in accordance with this policy will be deemed equivalent to the maintenance requirements required by the Life Saving Equipment Regulations.

3.3 This policy applies to the weekly and monthly inspections performed by the crew, and servicing, maintenance or repairs of survival craft, rescue boats, launching appliances and release gear, performed by the ASP and their technicians.

3.4 In this policy, the term “service provider” in the context of ASPs refers to:

  • service stations that service inflatable survival equipment, which are referred to in the Life Saving Equipment Regulations or the Vessel Construction and Equipment Regulations, when they come into force, or
  • businesses that provide services for lifeboats (including freefall lifeboats), rescue boats (including fast rescue boats), launching appliances and release gear (including those for davit-launched liferafts).

Authority

4.1 This policy was approved by the Marine Safety and Security Executive Committee and supports the objectives of the Canada Shipping Act, 2001, and ensures that Canada meets its international obligations with respect to navigation and shipping.

Responsibility/further information

The Executive Director, Domestic Vessel Regulatory Oversight is responsible for the development, implementation, maintenance, and continuous improvement of this policy.

Comments or questions should be sent to:

Executive Director, Domestic Vessel Regulatory Oversight
330 Sparks Street (AMSD)
Ottawa ON K1A 0N8
Fax: 613-991-4818
insp.stand-norm.insp@tc.gc.ca

6.1 IMO Resolution A.761(18): Recommendation on conditions for the approval of servicing stations for inflatable liferafts;

6.2 IMO Resolution MSC.55(66): Adoption of amendments to the recommendation on conditions for the approval of service stations for inflatable liferafts (Resolution A.761(18));

6.3 IMO Resolution MSC.388(94): Amendment to the recommendation on conditions for the approval of service stations for inflatable liferafts (Resolution A.761(18));

6.4 IMO Resolution MSC.404(96): Amendments to the International Convention for the Safety of Life at Sea, 1974, as amended;

6.5 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;

6.6 Schedule IV of the Life Saving Equipment Regulations; and,

6.7 ISO/PAS 23678: Ship and marine technologyService personnel for the maintenance, thorough examination, operational testing, overhaul and repair of lifeboats (including free-fall lifeboats) and rescue boats (including fast rescue boats), launching appliances and release gear – Training, competency assessment and certification of personnel – Parts 1 to 4.

Background

7.1 Life-saving appliances are constantly improving their capabilities to address a multitude of shipboard casualties. Their increased functionality is accompanied with greater complexity, thus making the maintenance of these systems critical and more complex. Ship operators depend on third-party, specially trained personnel to maintain their life-saving appliances. Improper use and maintenance of life-saving appliances have led to incidents involving these appliances, with some resulting in severe injuries or fatalities.

7.2 In order to address incidents involving life-saving equipment, the IMO developed guidelines for the periodic servicing and maintenance of survival craft and their launching appliances, as well as recommendations to Administrations for the authorization of service providers. IMO Resolution MSC.402(96) incorporated both past and new IMO recommendations, including those previously covered under MSC.1/Circ.1206 and 1277. These requirements were adopted by the IMO’s Maritime Safety Committee (MSC) through amendments to SOLAS Chapter III -Resolution MSC.404(96).

7.3 IMO Resolution MSC.404(96), and by extension Resolution MSC.402(96), became applicable on 1 January 2020 for convention vessels. They are also applicable to vessels subject to the Tier I – Policy – Acceptance of an Alternative Regulatory Regime for Inspection, Construction and Safety Equipment, in which SOLAS Chapter III is made applicable following an MTRB request and favorable decision.

Date of application

8.1 This policy comes into force on August 17, 2020 and will be reviewed when the Vessel Construction and Equipment Regulations enter into force.

RDIMS reference

9.1 The English version of this document is saved in RDIMS under reference number 16787335. The applied naming convention is Publication – TP 13585 – Policy – Authorized Service Providers for life-saving appliances.

9.2 La version française du présent document est dans le SGDDI et porte le numéro de référence 16787381. La règle d'affectation des noms est Publication – TP 13585 – Politique - Fournisseurs de services autorisés pour les engins de sauvetage.

9.3 This is the first approved and finalized revision of the English version of this document.

Keywords

  • Servicing
  • Inflatable
  • Inspection
  • Maintenance, Examination & Testing
  • Launching Appliance, Release Gear
  • Survival Craft
  • Lifeboat
  • Rescue Boat
  • Liferaft

Annex 1

Implementing IMO Resolution A.761(18)

1.1 This section explains how IMO Resolution A.761(18) should be interpreted by ASPs. It deals with the tests and methods for servicing inflatable survival equipment.

1.2 The requirements with which the ASP needs to comply, as set out in section 118, 119 and Schedule IV of the Life Saving Equipment Regulations, have been replaced by the requirements of IMO resolution A.761(18), as amended from time to time, with the exception of 2(1) of Schedule IV of the Life Saving Equipment Regulations, which remain.

1.3 When reading the resolutions, “should” means “must”.

1.4 Paragraph 2.15 of A.761(18) requires that after any inflatable liferaft is serviced, a service record must be given to the ship owner. This record must be signed and dated by an accredited service technician, and must include:

  • the name of the ship
  • the ship owner’s name
  • the model and serial number of the equipment
  • the name of the manufacturer of the equipment
  • the number of the gas cylinders and the type of gas
  • the emergency pack class
  • the expiry dates of all equipment in the liferaft pack, (e.g. flares, medicine, rations, etc.)
  • the following statement:
    “This certifies that this inflatable survival equipment has been inflated, tested, inspected, serviced, repaired and properly repacked according to the manufacturer’s recommendations and in accordance with IMO Resolution A.761(18), as amended.”

1.5 Paragraph 3.1 of A.761(18) relating to the servicing of inflatable liferafts requires that manufacturers show how ASPs comply with this guidance.

1.6 ASPs that service equipment on board convention vessels or any vessel subject to the alternative regulatory regime policy must be approved by a Recognized Organization (RO), on behalf of TC. The RO must inspect any ASP that it approves, as per paragraph 3.2 of A.761(18), relating to the servicing of inflatable liferafts.

Annex 2

Implementing IMO Resolutions MSC.404(96) and MSC.402(96)

1.1 These resolutions explain how lifeboats and rescue boats, launching appliances and release gear should be inspected, maintained, tested, overhauled and repaired. Any Canadian service providers must be authorized by a Canadian Recognized Organization, on behalf of TC.

1.2 The requirements set out in section 113 and subsection 114(3) of the Life Saving Equipment Regulations are replaced by the requirements of SOLAS regulation III/20 and must be met by vessel owners.Footnote 4

1.3 For the purpose of SOLAS regulation III/20.11, the Requirements for maintenance, thorough examination, operational testing, overhaul and repair can be found in MSC.402(96), as amended.

Annex 3

1 Other requirements from IMO Resolution MSC.402(96)

1.1 This section outlines requirements, interpretations and guidance for implementing IMO Resolution MSC.402(96).

1.2 For the purpose of paragraph 2.2.1 of MSC.402(96), an Authorized Service Provider (ASP) can be either the Original Equipment Manufacturer (OEM) or a third-party service provider.

1.3 The thorough examination, operational testing, repair and overhaul of equipment referred to in this policy are to be carried out in accordance with the IACS UR Z17: Procedural Requirements for Service Suppliers, but modified by this annex.

1.4 Recognized Organizations (RO) must send TC a copy of the approval certificate from all of their ASPs and technicians to DSIP-PDIO@tc.gc.ca.

1.5 If a major non-conformity is found during the audit of an ASP, the RO must report it to TC: DSIP-PDIO@tc.gc.ca.

1.6 A TC Marine Safety and Security Inspector can join any inspection done by a Canadian RO. Authorizations made according to this policy can be withdrawn if an inspection shows that an ASP does not comply with MSC.402(96).

1.7 ASPs are required to be authorized by only one Canadian RO to service, examine and test equipment that they are authorized to service on board any Canadian vessel.

2 Authorized service providers (ASP) and their technicians

2.1 For the purpose of MSC.402(96), TC defines “make” and “type” as follows:

2.1.1 “Make” refers to the equipment manufacturer.

2.1.2 “Type” refers to the category of equipment:

  • Lifeboats (including free-fall lifeboats)
  • Rescue boats and fast rescue boats
  • Launching appliances (including winches and davits)
  • On-load and off-load release gears for lifeboats (including primary and secondary means of launching appliances for free-fall lifeboats), and
  • Davit-launched liferafts

2.2 For the purpose of sections 7.1 and 8.1 of MSC.402(96):

2.2.1 Only a technician who has successfully completed an approved training program provided by an ASP, in accordance with part 1 to 4 as applicable of ISO/PAS 23678 (Ship and marine technology – Service personnel for the maintenance, thorough examination, operational testing, overhaul and repair of lifeboats (including free-fall lifeboats) and rescue boats (including fast rescue boats), launching appliances and release gear – Training, competency assessment and certification of personnel), is authorized to maintain, thoroughly examine, test, overhaul and repair at the level stated on their training certificate, for any makes specified on their approval certificate.

2.2.2 Technicians that, contrary to section 2.2.1 above, did not successfully complete an approved training program provided by an ASP must be approved for each make and type.

2.3 The ASP and each approved technician must keep a record of the scope of their certification and training. These records must be made available to a person authorized to do an inspection under the Canada Shipping Act, 2001.

3 Original Equipment Manufacturer (OEM)

3.1 TC recognizes that some equipment may require special skills, equipment or parts for servicing. In these cases, the OEM must provide a justification to TC. If TC agrees that special skills, equipment or parts are required for servicing and are not available to certain ASPs, TC may include special conditions on the Type Approval certificate.

3.2 These requests must be emailed to TC: TC.MarineTA-ATMaritime.TC@tc.gc.ca.

4 Vessel Owners and Operators

4.1 TC requires that owners and operators of convention vessels and vessels subject to the Acceptance of an Alternative Regulatory Regime for Inspection, Construction and Safety Equipment policy use, as required by SOLAS III/20, an ASP to maintain, examine, test, overhaul and repair all:

  • lifeboats (including freefall lifeboats);
  • rescue boats (including fast rescue boats);
  • launching appliances (including for the davit-launched liferafts); and
  • release gear.

4.2 ASPs and their technicians, must only service equipment that they are authorized to deal with, as specified on their approval certificate.

4.3 If the manufacturer is no longer in business or no ASP for the make can provide technical support, TC may authorize another company’s ASP to provide service on a case-by-case basis. This is also possible for cases where an ASP for the make or the original equipment manufacturer can’t be provided within a reasonable amount of time. The ASP technician may also be approved using the option as stipulated in section 2.2.1 of annex 3, above.

  • These requests must be emailed to TC: TC.MarineTA-ATMaritime.TC@tc.gc.ca. The authorization of another ASP is based on prior authorization for the type of equipment, and five years of experience.

4.4 In order to make sure that the following lifesaving appliances can be safely examined, tested, overhauled and repaired, vessel owners and/or operators must keep a maintenance manual and their specific tools onboard each vessel:

  • lifeboats (including freefall lifeboats);
  • rescue boats (including fast rescue boats);
  • launching appliances (including davit-launched liferafts); and
  • release gear.

4.5 You can find a list of Canadian ASPs in TC’s Approved Products Catalogues for the marine industry.