I have a issue with the mexico flag administration about the requirements for Passenger Vessels, which according to SOLAS Ch. III, Reg. 7.2, must carry infant lifejackets. Since the vessel is dedicated to offshore activities (transfer of personnel from platform and ships to shore and viceversa), it is clearly never will taking infants on board.
But looking into SOLAS, there is not any clarification about this requirement, which I believe for sure apply to Passenger Vessels relating to Tourism, Cruise, Ferry activities.
Anyone has an idea how to deal with this issue?
Having worked in Mexico and had port state interactions with the navy, it’s best to go throught the harbor master via the agent for clarification. Almost everything is a hand delivered letter over there; it will be hard to give guidance outside of the harbor master’s determination.
SOLAS III Reg 2.2 In the case of passenger ships which are employed in special trades for the carriage of large numbers of special trade passengers, such as the pilgrim trade, the Administration, if satisfied that it is impracticable to enforce compliance with the requirements of this chapter, may exempt such ships from those requirements.
A letter from the Mexican Flag Administration exempting the subject vessels from 7.2 based on 2.2 would suffice nicely or the flag can also accept adult life jackets as an equivalent arrangement under SOLAS I/5 with the condition that no infants embark the vessel.
Either way a letter from the Flag Administration is in order.