IACS Common Structural Rules (CSR) released

As previously reported, the IACS Council has approved the adoption of new Common Structural Rules (CSRs) that will apply to tankers of 150m in length and greater and to bulk carriers of 90m in length and greater, effective 1 April 2006. The new Rules were released this week and can be accessed here for tankers and at http://www.iacs.org.uk/csr/bulk_carriers/index.html for bulk carriers. 

IACS has also provided a summary of these rules, the harmonisation process and their future maintenance programme, which can be seen at http://www.iacs.org.uk/csr/CSR%20IACS%20Council%20External%20Presentationrev1.ppt 

While welcoming the introduction of these rules, INTERTANKO has expressed its disappointment that IACS did not respond to INTERTANKO’s proposal to include in these rules the industry agreed performance standards for coating application in ballast tanks. We reproduce the relevant paragraph in Part 2 of Section 6 of the new CSR for tankers, which shows that IACS has decided NOT to require the industry standard but to defer it to a future IMO decision, with no certainty as to when this may be, nor when it would become enforceable, and with a still unknown level of quality. For those familiar with the issue, we reproduce herewith the relevant text from the CSR rules on tankers: 

SECTION 6 MATERIALS AND WELDING

2 CORROSION PROTECTION INCLUDING COATINGS

2.1 Hull Protection. . .

2.1.1.2 For ships contracted for construction on or after the date of IMO adoption of the amended SOLAS Regulation II-1/3-2, by which an IMO “Performance standard for protective coatings for ballast tanks and void spaces” will be made mandatory, the coatings of internal spaces subject to the amended SOLAS Regulation are to satisfy the requirements of the IMO performance standard. 

2.1.1.3 Consistent with IMO Resolution A.798(19) and IACS UI SC 122, the selection of the coating system, including coating selection, specification, and inspection plan, are to be agreed between the shipbuilder, coating system supplier and the owner, in consultation with the Classification Society, prior to commencement of construction. The specification for the coating system for these spaces is to be documented and this documentation is to be verified by the Classification Society and is to be in full compliance with the coating performance standard. 

The new IACS regulations therefore acknowledge that there would be no concrete requirement for performance standards of coatings in tankers built after 1 April 2006 until some future unknown date when the IMO "Performance Standards for Protective Coatings" might take effect. It is of a less relevant significance that the second paragraph makes reference to existing IMO and IACS guides because, so far, these have not been used as matters of routine practice. 

INTERTANKO believes that IACS has missed this perfect opportunity to introduce sound performance standards for coatings into these new rules, irrespective of the IMO future decision on this matter. This even more critical  because the new rules base their model for fatigue assessment on the assumption that the coating in tankers' ballast tanks remains in good condition for a long period of time. IACS has thus  made an assumption on premises that they subsequently have not included into the rules. 

Members are advised to pay serious attention to these aspects when using these new rules. 

Despite these observations, there are many positive features in the new rules, which are well explained in a booklet which can be accessed at the ABS web site (click here to view).   

Contact: Dragos Rauta