E

MARITIME SAFETY COMMITTEE

89th session
Agenda item 7

MSC 89/7/8
22 March 2011
Original: ENGLISH

DANGEROUS GOODS, SOLID CARGOES AND CONTAINERS

Comments on the draft Code of Safe Practice for
Ships Carrying Timber Deck Cargoes, 2011
Submitted by the International Association of Classification Societies (IACS)
SUMMARY
Executive summary:

This document comments on paragraph 2.4 of document

MSC 89/7, which refers to the draft Code of Practice for Ships
Carrying Timber Deck Cargoes, 2011, as set out in annex 4 to
document DSC 15/18

Strategic direction:

5.2

High-level action:

5.2.3

Planned output:

5.2.3.8

Action to be taken:

Paragraph 3

Related documents:

MSC 89/7 and DSC 15/18 (annex 4)

Introduction
1
This document is submitted in accordance with the provisions of paragraph 4.10.5 of
the Guidelines on the organization and method of work of the Committees and their subsidiary
bodies (MSC-MEPC.1/Circ.2) and comments on document MSC 89/7. In particular, this
document discusses the action requested in paragraph 2.4 of document MSC 89/7 regarding
the approval of the draft Code of Safe Practice for Ships Carrying Timber Deck Cargoes
(TDC Code), 2011, as set out in annex 4 to document DSC 15/18.
2
Having carefully reviewed the draft TDC Code in detail, IACS considers the issues
discussed in annex 1 are matters requiring further consideration before the draft Code is
approved by the Committee. IACS would also wish to draw the attention of the Committee to
the technical considerations discussed contained in annex 2 to this document.
Action requested of the Committee
3
The Committee is invited to consider the comments and proposals contained in the
attached annexes when considering the draft Code of Safe Practice for Ships Carrying
Timber Deck Cargoes, 2011, and decide whether the issues raised are of a nature that will
require further consideration by the DSC Sub-Committee.
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MSC 89/7/8
Annex 1, page 1
ANNEX 1
MATTERS REQUIRING FURTHER CONSIDERATION

1
Paragraph 2.4.2 of the draft Code states "A ship carrying timber deck cargo must
comply with applicable parts of the damage stability requirements as well as the 2008 Intact
Stability Code (IS Code)[11], particularly the timber deck cargo requirements. Since excessive
GM values induce large accelerations, GM should preferably not exceed 3% of the breadth
of the vessel, as indicated in 3.7.5 of the IS Code."
Comment: Which damage stability requirements are being referred to, as IACS is not aware
of any specific additional requirements for ships carrying timber deck cargoes? IACS
understands that there are no damage stability requirements specifically for ships when
carrying timber deck cargoes and ships carrying timber deck cargoes need only comply with
SOLAS requirements for a general cargo ship. This is unless this text is intended to refer to
damage stability requirements for ships with reduced freeboard, in which case IACS
proposes that this needs to be clarified.
2
The draft Code makes several references to voids in the cargo such as due to
stow (paragraph 2.9.4), leaving such voids for access, egress and emergency escape
(paragraph 2.8.5).
Comment: IACS proposes that the draft Code should confirm that such voids are to be in
accordance with the International Load Line Convention (ICLL) regulation 44(2) which
requires gaps are not to exceed a mean of 4% of the breadth of the ship.
3
Paragraph 2.10.1 of the draft Code states "One or more of the following principal
methods may be used to secure timber deck cargoes, by themselves or in combination with
each other .4 frictional securing, taking into account scientific research and appropriate
weather and voyage criteria;".
Comment: IACS believes the Code should state that securing solely based on friction should
only be used in relation to smaller vessels engaged in short sea shipping in calm seas.
It should not be provided as the only securing method in any other cases.
4
Paragraph A.2.12 of Annex A of the draft Code states "An approximation of the
metacentric height should be obtained (when safe to do so) from the rolling period or static
list at a late stage of loading. Rolling or static list may be initiated by quick or slow
(as appropriate) shifting of cargo with the deck cranes or lowering cargo bundles onto other
deck cargo at one side of the vessel."
Comment: IACS is very concerned about the apparent encouragement of an ad hoc dynamic
inclining experiment, and would question such a recommendation. IACS asks for clarification
of the purpose of this potentially dangerous experiment. The vessel should be loaded in
accordance with the approved Trim and Stability booklet which will include instructions on
calculating the GM on the basis of the actual loading of the ship.
5
Paragraph B.4 of Annex B of the draft Code gives racking strength = 3.5 kN.
In accordance with paragraph 4.7.1 IACS suggests the units should be kN/m.

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MSC 89/7/8
Annex 1, page 2
6
In example B.5.1 of Annex B of the draft Code it is stated that "static = 0.5 =
Coefficient of static friction between the timber deck cargo and the ship's deck/hatch cover."
Comment: This static value is not in line with the value given in Table 4.2. IACS suggests
that 0.35 is the correct value.
IACS also believes the result provided in example B.5.1 of the draft Code is NOT in line with
the data given in Table 7.1 of the draft Code. In example B.5.1, the height of cargo is 7 m
and the transverse acceleration is 4.6 m/s2. Consequently, according to Table 7.1, the
required section modulus is 9413 cm3. However, in the example, the result of the required
section modulus is only 3749 cm3.
7
It is noted that pilot boarding arrangements are addressed in SOLAS, but are not
addressed in the new draft Code. IACS considers that the Code should include a reference
to these SOLAS provisions.
8
In the draft Code, diagrams such as 6.3, 6.4, 6.5, 6.6, 6.7, 6.8, B.4 show timber
loaded on deck to the edge of the hatch coamings, and indeed, supporting uprights being
welded to the coamings. It is very unlikely that the breadth of the coamings is such as to
achieve a minimum 96% of beam (regulation 44.2 of ICLL) in order to give the effective
superstructure required by the ILLC in order to assign a Timber Load Line. IACS is
concerned that users of the Code will assume that if timber is stowed in accordance with the
diagrams then it will meet all the relevant requirements for lashing of timber, i.e. including
those in the ILLC for timber freeboard assignment. These diagrams do not reflect the
requirements of load line and IACS believes that users of the Code should be made aware of
this limitation.

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MSC 89/7/8
Annex 2, page 1
ANNEX 2
TECHNICAL CONSIDERATIONS

1
Paragraph 4.6 of the draft Code includes a statement about the increase of weight
due to ice and that it should be considered in accordance with the 2008 IS Code. However,
the provisions relating to icing in Part B chapter 6 of the 2008 IS Code give only specific
guidance to fishing vessels and offshore supply vessels. Details of increases in weight due
to icing on other ship types are not specified. It is suggested that this matter needs to be
further considered and proposals developed for inclusion in the 2008 IS Code.
2
Section 4.7 of the draft Code relates to racking strength. It is given in units of force
per metre package length. However, the suggested test setup would not give a value for
racking strength in the units specified in paragraph 4.7.1. Further guidance on the conduct of
the tests and resultant calculations to obtain the racking strength in the units required would
help ensure consistency in measurement and recording of the information.
3
The introduction to chapter 5 makes reference to using alternative technologies in
cargo securing design which provide at least the same level of safety as specified in the
chapter. IACS believes it would be beneficial to identify acceptable means/methods for
proving that alternative technologies in cargo securing design achieve this same level of
safety.
4
Paragraph 5.3.6 of the draft Code states "Timber packages may alternatively be
secured by a chain or wire loop lashing system, based on the design principles contained in
chapter 6."
Comment: IACS has compared the draft Code and resolution A.715(17) and questions if the
loop lashing system based on chapter 6 has the same safety level as that specified in
chapter 5, to the extent that a chapter 6 loop system can be considered as an alternative to a
loop system complying with chapter 5.
5
The introduction to chapter 6 of the draft Code permits the development (and use) of
new designs and securing arrangements, by providing functional based requirements on the
securing of timber deck cargoes, which may be used as an alternative to the requirements in
chapter 5 for ships of less than 24 metres in beam and for designers considering alternative
technologies in cargo securing. When chapter 6 is applied, operational procedures based on
design risk assessment should be included within the vessel's safety management system.
However, in the opinion of IACS the design principles of chapter 6 are questionable because
most of these securing plans are based on friction securing. IACS believes it is difficult to
include all those severe conditions which could possibly be met during navigation in the
design risk assessment.
6
Paragraph 6.5.31 of the draft Code states: "In restricted sea areas round wood may
be transversely stowed and secured by bottom blocking and/or friction between tiers only.
This may be done only if the friction between layers is sufficient and the expected transverse
accelerations are limited ".
Comment: IACS would seek clarification as to how the accelerations are to be limited.

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MSC 89/7/8
Annex 2, page 2
7
Paragraph 6.5.22 of the draft Code requires two blocking devices per side the height
of which should extend to at least 200 mm. It is noted that this height requirement has been
considerably reduced from that in the previous version of the Code (where blocking devices
were required to be at least as high as one package). IACS would appreciate an explanation
being provided for this reduction.
8
IACS notes that only the bending moment of uprights is taken into account in
chapter 7 of the draft Code, while ignoring any strength requirements for the connection of
uprights to the deck, including the components of connection (e.g., sheer strength of welds),
which are also deemed important.
IACS suggests the addition of some strength
requirements for the connection of uprights to the deck, also for the components of the
connection or, alternatively, that the connection of uprights to the deck is to be to the
satisfaction of the Administration or recognized organization. The method of putting round
wood into a slot as an upright is still in use and therefore IACS proposes strength calculation
procedures for this kind of upright are developed.
9
Paragraph 7.1 of the draft Code requires uprights at least as high as the stow. It is
noted that the previous version of the Code required a height of at least 1 metre higher than
the stow. Again, IACS would appreciate an explanation being provided for this reduction.
10

Paragraph 7.3 of the draft Code includes the equation:

Comment: In this formula, dynamic friction factor is taken as 60% of the static friction factor.
However, IACS notes that paragraph 4.2.6 of the draft Code states that the dynamic friction
factor should be taken as 70% of the static values. IACS would appreciate clarification
regarding these different values.
11
Paragraph A.2.11 of Annex A of the draft Code states "Any obstruction such as
lashings or securing points in the access way of escape routes or operational spaces and to
safety equipment, fire fighting equipment or sounding pipes should be kept to a minimum and
in any case they should be clearly marked."
Comment: It does not seem desirable to permit minimum obstructions to safety equipment,
fire-fighting equipment or sounding pipes. Rather, the Code should state that such
obstructions should not be permitted at all. However, if the text is to remain as is, then IACS
believes examples or guidance should be provided to explain how to achieve "kept to a
minimum".
12
Further to paragraph 6 of annex 1 to this document, based on an actual ship
(32,500 DWT bulk carrier) data, the height of cargo is typically 8.5 m, and the transverse
acceleration is 4.6 m/s2.
According to Table 7.1, the required section modulus is
therefore 14030 cm3.
But the accurate section modulus of this ship's uprights is
only 2623 cm3. Increasing the dimension of the uprights according to Table 7.1 will
significantly affect the arrangement of timber cargo and upper deck structure. It is therefore
suggested to check the data provided in Table 7.1 and the formulae used for uprights.

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