Topic starter
17/06/2007 8:00 am
If I understand the issue correctly, the main concern for the Delta Queen's continued operation is her wooden superstructure. Am I correct in assuming that the issue of compliance is in SOLAS Chapter II-2 "CONSTRUCTION - FIRE PROTECTION, FIRE DETECTION AND FIRE EXTINCTION?"
If so, the statement that "This law forbids any vessel, foreign or domestic, from operating from a United States port carrying over 50 overnight passengers if it is constructed primarily of wood" is based in Regulation 11 "Structural Integrity."
1 Purpose
The purpose of this regulation is to maintain structural integrity of the ship, preventing partial or whole collapse of the ship structures due to strength deterioration by heat. For this purpose, materials used in the ships' structure shall ensure that the structural integrity is not degraded due to fire.
2 Material of hull, superstructures, structural bulkheads, decks and deckhouses
The hull, superstructures, structural bulkheads, decks and deckhouses shall be constructed of steel or other equivalent material. For the purpose of applying the definition of steel or other equivalent material as given in regulation 3.43, the "applicable fire exposure" shall be according to the integrity and insulation standards given in tables 9.1 to 9.4. For example, where divisions such as decks or sides and ends of deckhouses are permitted to have "B-0" fire integrity, the "applicable fire exposure" shall be half an hour.
Furthermore, I believe that the Delta Queen's exemption is covered in Regulation 1 as well:
4 Exemptions
4.1 The Administration may, if it considers that the sheltered nature and conditions of the voyage are such as to render the application of any specific requirements of this chapter unreasonable or unnecessary, exempt from those requirements individual ships or classes of ships entitled to fly the flag of its State, provided that such ships, in the course of their voyage, do not sail at distances of more than 20 miles from the nearest land.
I take it that this is the temporary exemption that we are all referring to, and that we envision a different exemption specifically for our vessel. Are these assumptions correct, or am I way off?
17/06/2007 12:00 pm
Jonathan: Good work finding that regulation on line! I had never read it, and it is interesting, to say the least. I thought I knew what SOLAS said, and was basically right, but did not know about the exemption provisions. This should make things easier, I would think.
Topic starter
17/06/2007 1:09 pm
I think that perhaps this is not the exact regulation and allowance for exemption that concerns the Delta Queen. The reason for my hesitance is the nature of the wording about the type of vessel she is. When the SS Yarmouth Castle burned in 1965, the new draft of SOLAS apparently addressed specifically that "any vessel carrying more than 50 overnight passengers is required to be built entirely of steel."
Title 46 of the Code of Federal Regulations (which also addresses SOLAS) refers to merchant marine vessels carrying more than 12 passengers and making at least one international voyage. The Yarmouth Castle, and subsequently the Delta Queen, would be classified rather as a "commercial passenger vessel," which is defined by the 50-pax minimum. This leads me to believe that what I posted earlier may not necessarily be the correct regulation at issue.