Regulation |
Regulation No. |
Clause |
Requirement |
Application |
Reason to Delete |
Alternative Approach |
Hull
Construction
Regulations |
Part VIII |
110 |
Remote operated WT doors |
Tugs > 24 m |
Very expensive |
Permit use of typical dogged doors |
|
|
104 |
Down-flood any compartment aft of engine
room without deck edge submersion |
Tugs > 5 GRT |
Illogical, and uniquely Canadian
requirement |
Evaluate practicability of having one-compartment standard of subdivision in all tugs, especially those above 24 m |
Towboat Crew
Accommodation
Regulations |
|
|
Full range |
Tugs > 5 GRT, plus other hurdles at 22.9 m loadline |
Contradicts majority of other standards |
Harmonize with BCTOA towboat Crew Accommodation Standards, OSHA requirements, and other international IMO standards for crew accommodation |
Marine
Machinery
Regulations |
MMR
Sch IV
Pt II |
Section 6-15 |
Plan approval of internal combustion oil
engines |
Engines > 375 kW |
Engines are a universal product, approved by Class or similar |
|
|
|
Section 6 Div I |
Plan approval of reversing and reduction
gearing |
> 375 kW |
Gears are a universal product, approved by Class or similar |
|
|
|
Section 6 Div II |
Shafting systems for propulsion, electrical generators, and motors |
> 375 kW |
These are a universal product, approved by Class or similar |
|
|
|
Section 6 Div III |
Propellers |
> 225 kW |
These are a universal product, approved by Class or similar |
|
|
MMR
Sch VIII
Pt I |
Section 4 Div I (1) |
Automation standards |
Periodically unattended machinery spaces |
Duplication and overlapping of requirements |
These requirements are well-defined by IACS member companies, and could be referenced directly |
Robert G. Allan, P. Eng.
President