IS THIS BRIDGE FIT FOR PURPOSE?
Following my article in the summer issue concerning the Crimson Mars grounding and the visibility from the “conning position”, the Southampton pilots notified me of a new class of ships that they have formally complained about.
The vessels in question are Wilhelmson’s latest car carriers the Tortugas and Toronto which form part of a fleet of 12 identical new ships and the problem is that forward of the bridge, large ventilators have been located in positions which severely restrict the visibility to port and starboard of the bow. These vessels are sailing under the British flag and registered in Southampton so would have been surveyed and passed by the MCA. Although the visibility ahead complied with regulations the visibility on either bow is so restricted that the pilots felt that there must be a breach of the bridge visibility requirements contained within regulation 22 of SOLAS Chapter 5 2002. It is not just the Southampton pilots, the Captains and watchkeeping officers are also deeply concerned and believe that these ships represent an accident waiting to happen!
So what are the operational restrictions experienced on board?
I encountered great difficulty in being able to see objects such as buoys when passing nearby, in particular when turning at the Calshot and West Bramble Turns.
The problem is caused by ventilators to port and starboard ahead of the bridge, whilst the horizon can be just seen from the conning position, great arcs of visibility are obstructed to port and starboard. This causes a problem with sighting objects (Buoys, small targets) at a close range, as they are obscured.
Whilst outward at Calshot, I could not see the buoys that I normally reference from the centre of the bridge where all the bridge instrumentation is sited, in the event I had to move to the extreme wing of the bridge to sight the Calshot Light Float, which then means that I cannot see/use the bridge instrumentation (apart from a rudder indicator) or see any potential small craft ahead of or to the other side of the vessel.
Other pilots have made similar adverse reports such as:
As I passed the North Sturbridge buoy inwards, I lost sight of the buoy from the conning position when the buoy was red 18 degrees at eight and a half cables. Whilst turning at the West Brambles and at Calshot I had to leave the conning position and go to the bridge wing in order to keep sight of the buoys that I was turning around. From this position my view of the other side of the vessel is totally obscured. With the concentrations of leisure traffic experienced at times in Southampton Water and the Solent, in my view, it is only a matter of time before an accident will occur.
This is not just an issue with the Southampton pilots but apparently all pilots who have to pilot these ships complain and one Captain informed the Southampton pilots that entering locks presents an acute problem because you have to stick your head out of the bridge wing windows, as far as possible, to see the approaching lock. I understand that this problem has only arisen on the newest class of car carriers because the earlier class such as the Tamesis had an extra deck which permitted clear visibility over the top of the vents which are located in a similar position on the foredeck. It would appear that the air draft of the earlier class restricted entry into some ports such as Yokohama so for the new class it was decided to remove a deck without any thought to the consequences for keeping a safe watch!
THE BOW OF A MEDIUM SIZED TANKER IS JUST VISIBLE UNDER THE BINOCULARS
Photo: Nigel Allen
So how on earth have such ships been granted safety certificates? Well the crucial legislation covering bridge visibility is contained within SOLAS Chapter 5 Regulation 22. Since this is such an important issue with respect to safe navigation it is worth reproducing Regulation 22:
22.1 Ships of not less than 45 m in length as defined in regulation III/3.12, constructed on
or after 1 July 1998, shall meet the following requirements:
22.1.1 The view of the sea surface from the conning position shall not be obscured by
more than two ship lengths, or 500 m, whichever is the less, forward of the bow
to 10° on either side under all conditions of draught, trim and deck cargo;
22..1.2 No blind sector caused by cargo, cargo gear or other obstructions outside of the
wheelhouse forward of the beam which obstructs the view of the sea surface as
seen from the conning position, shall exceed 10°. The total arc of blind sectors
shall not exceed 20°. The clear sectors between blind sectors shall be at least
5°. However, in the view described in .1, each individual blind sector shall not
exceed 5°;
22.1.3 The horizontal field of vision from the conning position shall extend over an arc
of not less than 225°, that is from right ahead to not less than 22.5°, abaft the
beam on either side of the ship;
22.1.4 From each bridge wing the horizontal field of vision shall extend over an arc at
least 225°, that is from at least 45° on the opposite bow through right ahead
and then from right ahead to right astern through 180° on the same side of the
ship;
22.1.5 From the main steering position the horizontal field of vision shall extend over an
arc from right ahead to at least 60° on each side of the ship;
22.1.6 The ship’s side shall be visible from the bridge wing;
22.1.7 The height of the lower edge of the navigation bridge front windows above the
bridge deck shall be kept as low as possible. In no case shall the lower edge
present an obstruction to the forward view as described in this regulation;
.8 The upper edge of the navigation bridge front windows shall allow a forward
view of the horizon, for a person with a height of eye of 1,800 mm above the
bridge deck at the conning position, when the ship is pitching in heavy seas. The
Administration, if satisfied that a 1,800 mm height of eye is unreasonable and
impractical, may allow reduction of the height of eye but not less than 1,600
mm;
22.1.9 Windows shall meet the following requirements:
22.1.9.1 To help avoid reflections, the bridge front windows shall be inclined from
the vertical plane top out, at an angle of not less than 10° and not more
than 25°.
22.1..9.2 Framing between navigation bridge windows shall be kept to a minimum
and not be installed immediately forward of any work station.
22.1..9.3 Polarised and tinted windows shall not be fitted.
22.1.9.4 A clear view through at least two of the navigation bridge front windows
and, depending on the bridge configuration, an additional number of
clear-view windows shall be provided at all times, regardless of weather
conditions.
22.2 Ships constructed before 1 July 1998 shall, where practicable, meet the requirements
of paragraphs 1.1 and 1.2. However, structural alterations or additional equipment need
not be required.
22.3 On ships of unconventional design which, in the opinion of the Administration, cannot
comply with this regulation, arrangements shall be provided to achieve a level of
visibility that is as near as practical to that prescribed in this regulation.
Being convinced that these ships didn’t comply with these regulations the Southampton pilots contacted the MCA and received the following response:
The requirement in reg. 22.1.1 is as follows:
“The view of the sea surface from the conning position shall not be
obscured by more than two ship lengths, or 500 m, whichever is
less, forward of the bow to 10° on either side under all conditions of
draught, trim and deck cargo.”
According to my calculations the sea surface from the conning
position is visible at a length of approximately 250 metres (I based my
calculations on measurements taken from the general arrangement
plan) and approx. 40 degrees to either side when the vessel is at its
summer draught on even keel. These results satisfy the SOLAS requirements
as the vessel’s length is 200 metres and the required angle is clearly
achieved. Even though vent heads port and stbd forward could well block the
view of the sea surface such blockage would not appear to be in contravention
of SOLAS requirements. The only recommendation I can make at this stage is to require the master to post a lookout on the foc’sle if it is felt that otherwise
small and close targets might be missed out.
So long as you can see the horizon the obstruction doesn’t represent a “blind sector”?
Photo N. Allen
To me it beggars belief that in 2008 you can still get a full safety certificate for a ship with a severely restricted view from the “conning position” and that the MCA suggest posting a lookout on the foc’sle if there is a problem. Welcome the 19th Century! In the opinion of the MCA such restrictions don’t represent “blind sectors” because a bit of sea below the horizon is visible from the conning position.They have come to this conclusion because the regulations only specify the 500m requirement for right ahead to 10º either side of the bow and therefore so long as the horizon isn’t totally obscured by a “blind sector” there is no minimum visibility requirement outside 10º either side of the bow!! This would appear to be bureaucratic whitewash because the SOLAS regulations also contain Regulation 15 and the pilots therefore challenged the MCA by quoting from the guidance notes for rule 15 which state the following:
All decisions which are made for the purpose of applying the requirements of regulations 19, 22, 24, 25, 27 and 28 and which affect bridge design, the design and arrangement of navigational systems and equipment on the bridge and bridge procedures shall be taken with the aim of:
.1 facilitating the tasks to be performed by the bridge team and the pilot in making
full appraisal of the situation and in navigating the ship safely under all
operational conditions;
.2 promoting effective and safe bridge resource management;
.3 enabling the bridge team and the pilot to have convenient and continuous access
to essential information which is presented in a clear and unambiguous manner,
using standardized symbols and coding systems for controls and displays;
.4 indicating the operational status of automated functions and integrated
components, systems and/or sub-systems;
.5 allowing for expeditious, continuous and effective information processing and
decision-making by the bridge team and the pilot;
.6 preventing or minimizing excessive or unnecessary work and any conditions or
distractions on the bridge which may cause fatigue or interfere with the vigilance
of the bridge team and the pilot; and
.7 minimizing the risk of human error and detecting such error if it occurs, through
monitoring and alarm systems, in time for the bridge team and the pilot to take
appropriate action.
The reply from the MCA went into great detail interpreting each clause but the MCA conclude that they are satisfied the vessel is fully compliant and that rule 15 is irrelevant with respect to the vents because
It would be illogical if SOLAS in one regulation (reg. 22) requires certain standards which it in another regulation (reg. 15) declares to be insufficient. It appears, therefore, that when SOLAS V, reg. 22 is complied with, reg. 15 is not asking for different arrangements.
So there you have it. You can ignore all the MCA notices and recommendations concerning keeping a visual lookout because they are perfectly satisfied if from the “conning position” a watchkeeper with a height of eye of 1.8m above the bridge deck can see 500m ahead and 10º either side of the bow and from there to 22½º abaft the beam on either side can just see the horizon then a vessel will be fully compliant. The Southampton pilots however continue to challenge such nonsense but meanwhile the shipyards are happily building the sister ships to the Tortugas which will continue to severely hamper both the Masters’ and pilots’ ability to navigate the ship safely. Such appalling disregard for safe operation would never be allowed in any other transport mode but this scenario sums up the commercial maritime world of the 21st century.
JCB Based on information supplied by the Southampton pilots.
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