mast_safety_requirements.htm  

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14 July 2004

Mr C. Finch,
Chief Executive,
MAST,
GPO Box 607,
Hobart, Tas. 7001

Dear Colin,


Safety Equipment - NSCV Part C7A

Thank you for the opportunity to discuss the proposed new vessel safety standards with yourself and Gwyn Alway at our TFIC Board meeting in Hobart on 12 July 2004.

As discussed TFIC Directors have serious concerns about several aspects of the proposed new requirements and we agreed to provide our written feedback or alternative options for your consideration.

Listed below are our major areas of concern or issues on which we wish to make comment –

• EPIRBs must be carried in a liferaft as well as on board a vessel.
  • Agree and as discussed this requirement does not apply to dinghies.
• Dinghies – marked with the parent vessel identification.
  • Agree, but need to be flexible as to how this is done.
  .
• Dinghies – to be stowed ready for immediate deployment.
  • Agree.
  .
• Dinghies – must be means to launch the dinghy.
  • Delete the requirement "with its full complement of equipment plus two persons" and replace "with its full complement of equipment (life jackets, flares etc.)".
• Dinghies – must be painted a highly visible colour.
  Strongly disagree as inappropriate, unnecessary and costly to implement and maintain. We suggest that a compromise is to allow for the painting in a highly visible colour of the dinghy foredeck or seats only plus the provision of reflective tape in appropriate locations. If a vessel is also equipped with a liferaft then dinghy painting requirements etc. should not apply.
• Dinghies - should be fitted with grab lines.
  • Disagree strongly. There are enough areas on a dinghy to hold on to. Grab lines create significant safety issues with the probability of dangerous entanglement both when is use and when not in use.
  .
• Dinghies - must have sufficient buoyancy for level flotation when swamped.
  • Agree.
• How to phase in these requirements for existing vessels?
  MAST to provide appropriate in advance advice to vessel operators of the new requirements and to then give notice at the next annual vessel survey for the requirements to be met by the following survey – provided MAST agrees and accepts our alternative options.
• Coastal Liferafts – standard to be replaced by the International Sailing Federation Special Regulations for Yachtsmen’s Inflatable Liferafts.
  • Agree – provided existing liferafts are acceptable and can be retained until next replacement.
  .
• Liferafts to have hydrostatic releases.
  • We would prefer that vessel operators be given the option of a hydrostatic release or a float free cradle with a rope of appropriate breaking strain between the painter and vessel.
  .
• Liferaft service intervals should increase.
  • Agree that service intervals should be extended in line with manufacturers recommendations.
  .
• EPIRBs required on vessels operating in Class B and C waters.
  • Agree.
  .
• Flares – new and upgraded required.
  • We support the status quo as being the minimum requirement. There is a difficulty in creating a fixed standard to meet all vessels and areas of operation as well as an increase in cost for operators. The proposal needs to be flexible and the current requirement should apply as the basic obligation to meet this standard. All flares should be given an extended life based on manufacturers recommendation.
• Torch – to be carried by every crew member.
  • We agree with this concept but that one torch should be available for use by every crew member on a vessel – i.e. not carried.
• Lifejackets – EN396 or Marine Orders Part 25 standard with some additions.
  • Agree but only when replaced. Existing lifejackets should be acceptable until then regardless of the period involved. Additions of lighting and marking etc.should only apply when lifejackets are replaced.
  .
• Medical kits – new scales.
  • We do not have sufficient information to comment other than to confirm that this requirement should be both practical and appropriate for each vessel, the number of crew onboard and the areas of operation.
We would be pleased to receive your confirmation and acceptance of all the above recommendations as soon as possible.

Yours sincerely,


R.K. LISTER
Chief Executive