MSC402(96) is the latest update to Lifeboat, Rescue Boat, Release Gear and Launching Appliances services which will supersede MSC.1/Circ.1206/Rev.1 and MSC.1/Circ.1277 after 1st Jan 2020.
This regulation may seem confusing to many but in recent months, the ROs (Classification Societies) has published an update to UR Z17, the Approval of Service Suppliers, the latest version is 14 and available for download. Now, let's dive into the details. I will discuss a few points which I feel is more important in the latest UR Z17 Rev. 14, Section 13. for "Firms engaged in maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear".
#1. Employment and documentation of personnel certified in accordance with a recognised national, international or industry-standard as applicable, or an equipment manufacturer's established certification program. What is important here is that this certification program cannot be a generic training but one that is specific to each make and the model number or series of the equipment. Class LRS' "Procedures for Approval of Service Suppliers", section 2.12, # Interpretation confirms this:
As the certification program has to take into account each make and type of equipment which is to be served, it cannot be a generic programme; but has to be a specific programme taking into account the requirements as established by the manufacturer of each equipment
Make in this case meant the manufacturer of the lifeboat, rescue boat, on-load release mechanism and/or launching appliances
The type does not equate to kind of equipment such as lifeboat, davit, etc... It is more specific and refers to the model or a series of equipment.
The above information has to be shown in your classification approval certificate. So during the audit with any of the classification society, you need to show the list of equipment (make and type) to the auditor and have that information entered into the certificate. I would assume post 1st Jan 2020, site surveyors will refer to the class approval certificate AND the technicians' license for allowing to proceed with the inspection.
#2. UR Z17 Rev. 14, Section 13.2.3, if an equipment manufacturer is no longer in business or does not provide technical support, then the Service Supplier might be approved to carry out the inspection service. If they were authorized by the said manufacturer before or if they can prove to be competent based on their long term experience and demonstrated they possess the expertise to carry out the service for the equipment.
Not much change here except that if you had been trained by the manufacturer and suddenly they went bust, you still have the technician working for you, all technical documents are still in your possession, you can actually add that manufacturer's name in your classification approval certificate. Otherwise, you need to prove why you are competent enough to provide service for the said make. The tricky part is auditor might request for proof that the manufacturer is already out of business.
#3. UR Z17 Rev. 14, Section 13.3, this part is relevant for certification of the personnel, the technician or engineer whom inspects or services the equipment. They may receive a license by taking part in a manufacturer's established certification programme or if they work for an Authorized Service Provider who is allowed to certify their own service personnel. The training for the personnel shall include practical technical training using the equipment for which the personnel is to be certified.
After the service personnel has successfully be trained for disassembly, reassembly, correct operation and adjustment of the equipment, then a competency assessment shall be satisfactorily completed, with a competency assessment conduct in order to renew the certification upon expiry. The certificate shall define the level of qualification, which make and type is certified to service and lastly, the scope of work allowed to perform (annual thorough examination and operational tests; 5 year thorough examination, overhaul; overload operational tests; repairs)
The keyword here is "Practical technical training using the equipment for which the personnel is to be certified". For example, if you are going to be certified by ABC maker for a lifeboat and its onload release system with a model number of TELB-ABC, then you will need at least the onload release system for TELB-ABC to conduct practical training. In terms of manufacturer certified training programme, this is very simple because it's normally available in their factory. In the case of an Authorized Service Supplier (and not ABC maker authorized service station) training their own technicians, they need to get their hands on one of those to include in their training programme.
#4. To fulfil the requirements of UR Z17 Rev. 14, besides having the relevant IMO resolutions stocked in the library, one of the reference documents that an Authorized Service Supplier must possess is the "Manufacturer's Instructions" including its updates, amendments and safety notices involving disassembly or adjustment of on-load release mechanisms and davit winches. The Service Supplier must prove to the auditor that they have the manufacturer's technical documents and also access to future updates to these documents.
Personally, I feel this is very important because the manufacturers of lifeboats and davits change suppliers or make minor upgrades to their designs every once in a while. They do this not only for obvious reasons such as lower costs but also after gathering feedback from their end users, it might be vital to replace say, the brake disc material and then the allowance for wear might not be the same! If the information is not disseminated to all service suppliers, then a safety risk is present.
#5. Another important requirement to be Authorized Service Supplier as per UR Z17 Rev. 14, is to possess appropriate parts and accessories specified by the manufacturers. As for the onload release mechanism, genuine replacement parts from manufacturers should be available. For makers authorized service suppliers, this is not a problem because they have the support of the manufacturers of lifeboats, release gear and davits. However, for companies that aim to develop their own training programme to comply to UR Z17's requirement, that might be tricky and how does the auditor confirm this, will be trickier.
Does manufacturer authorized lifeboat service suppliers require classification approvals after 1st Jan 2020?
This is not clearly mentioned but since Flag Administrations actually passed the responsibility to ROs with regards to MSC402(96), and only manufacturers servicing their own equipment is exempted from registering as a Service Supplier, then I would say yes, a manufacturer authorized service supplier needs classification approvals. Classification auditor will check and update the makes and models of the equipment into their system. If you look at the last few pages of the KRS reference link at the bottom of this article, you will notice a big number of Flag administration passes the responsibility to their ROs for approving service suppliers on their behalf
Which is the easier approach to be an Approved Lifeboat Service Supplier?
To me, I would say getting classification approval as the manufacturer's authorized service station would be a simpler and easier approach. There are hardly any changes from the current system of getting classification approval. All training programme, manufacturer documentation plus updates, spares requirements, etc... can be easily obtained from the manufacturer if the cooperation is continued. Although it will more expensive, it is straightforward and needs less effort to start and maintain.
As for a service supplier planning to gather manufacturer's documentation, organise practical training, etc... it will be a lot of work and initial investment of time and money to get it started but after it has been approved by classification society auditor, they are free to train then certify any amount of service personnel according to their in-house training programmes. They are also expected to maintain the records for future audits by flag or classification.
From a recent interview with Mr Sunny Yim from Marland Boat Service Ltd (a Global Service Company headquartered in Hong Kong with service branches all over China, Hong Kong, Singapore, Korea and Taiwan) has been following up with the lifeboat and davit manufacturers on MSC402(96) developments has this to share -
We believe that MSC402(96) is moving in the right direction; clear rules are imposed on the service suppliers whereby, if they are not trained by the manufacturers, they need to prove to the Administration and their ROs that their own training programme are comprehensive enough to take on such jobs. Depending on the establishment of the service provider, it will probably be more cost effective for a small to medium company, those with a handful of technicians to continue with manufacturer training.
Above are based on my understanding on MSC402(96) and UR Z17 Rev. 14, if you have comments or questions, please leave your message in Linkedin so we can discuss it.
Until then, stay safe!
Reference used for this article: