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DNV CLARIFIES LATEST IMO LSA EQUIPMENT RESOLUTION

DNV CLARIFIES LATEST IMO LSA EQUIPMENT RESOLUTION

Thursday, June 24, 2021 

Classification society DNV has issued a statement concerning IMO Resolution MSC.402(96), which covers the maintenance, thorough examination, operational testing, overhaul and repair of LSA equipment, which has been in force since 1 January 2020.

DNV says that there are, however, still challenges and unclarities in the adoption of its requirements. The main purpose of Resolution MSC.402(96) is to establish a uniform, safe and documented standard for the maintenance, thorough examination, operational testing, overhaul, and repair of lifeboats and rescue boats, launching appliances, and release gear. Some aspects of the regulations have been clarified within IACS with Revision 14 of UR Z17, and others are still under discussion.

Annual and five-yearly thorough examination, operational testing, overhaul, and repair of LSA equipment shall be undertaken either by the OEM or an authorised service provider / approved service supplier, who should be authorized/approved by a flag administration or Recognized Organization (RO) and hold an Approval of Service Supplier (AoSS) certificate for the make and type of the equipment installed on board. The AoSS certificate must be issued under the service provider’s name or, if another company carries out the servicing, this has to be listed as the subsidiary (company partly or wholly owned by the service supplier) on the AoSS certificate for the parent company.

Servicing companies should employ technicians certified by either the OEM or the company itself for the make and type of equipment installed on board. According to Revision 14 of the IACS UR Z17, an approved service supplier can certify their own personnel only (i.e. employed by the same service supplier) unless the flag administration accepts otherwise. DNV accepts personnel employed by a subsidiary of the company, but not by agents (person or company authorised to act for or to represent the approved/ recognised service supplier).

DNV has experienced cases where the servicing has been undertaken by a service provider (Company A) not authorised or approved for a given make and type of equipment, but the reports and statements left on board were issued by another service provider (Company B) holding the authorisation/approval for the make and type in question. This is not acceptable, as Company A should be authorised/approved for the equipment make and type being serviced, or alternatively be listed as a subsidiary in the AoSS of Company B.

In other cases, it has been found that Company B provides training and also certifies personnel employed by Company A for the make and type of equipment, whereby Company A is not authorised/approved for and Company B is not the OEM. Although it is in general acceptable that Company A makes use of an external training provider for education and training, it is not acceptable for Company B to certify personnel employed by Company A. It is also not acceptable if Company B employs personnel from Company A on a temporary basis, since they would be considered agents.

DNV recommends its clients consider the above interpretations for the use of service providers and be aware of DNV’s acceptance criteria. Nevertheless, DNV emphasises that any flag-specific requirement and interpretation differing from those of DNV shall prevail.

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