Consultation Load Line Length (LLL) policy clarification: hullform, cut-outs, extension and steps
This consultation seeks the views of industry views on a Marine Guidance Notice (MGN) which clarifies the UK policy when determining LLL on vessel hullforms featuring cut-outs, removable end sections, and bathing platforms.
The MCA has become aware of vessels with cut-outs which are being used as a means of avoiding regulations in relation to the 24m rule. The cut-out arrangement can lead to undesirable hydrodynamic characteristics and safety issues which potentially make the vessel unsafe.
Other examples have been noted where one or both end sections of a vessel are bolted-on (or otherwise fixed) at a vertical flat-plane bulkhead to artificially increase the length of a vessel with an allegedly “removable” portion of hull which has been discounted from Load Line Length calculations. In this case, some information asymmetry exists between builders, repairers, owners and certifying authorities in respect of how to calculate Load Line Length and what constitutes a fixed/permanent addition or ‘add-on’ which contributes towards tonnage, buoyancy and therefore LLL. It is crucial that this be calculated correctly otherwise vessels will not be compliant with the correct regulations for vessels either above or below 24 metres in length.
This MGN does not modify existing legislation and has been designed to provide clarification on current policies in relation to Load Line Length of a vessel.
Important updateUK Ship and Technical Standards are currently reviewing responses to this consultation. The feedback provided has resulted in several key alterations to the proposed MGN. The MCA is therefore carefully considering how to proceed and will respond fully in due course.