Question on Cruise Ships and Door Coamings

According to ICLL its required to have a coaming around any doors leading from a superstructure to the outside deck.

My question (as I am unfamiliar with maritime regulations and such) Is how are vessels that follow ICLL or Llyod’s able to get around these regulations?

From what I can understand is it is possible to be exempted from an ICLL code if your country has some form of Marine Techinicle Review Board that allows you to be exempted.

Another question is if a cruise ship does get an exemption, what is their argument that justifies being exempted from having (for an example) door coamings?

Any information or places I can go to read up more about this would be greatly appricated.

Dear Alex - Though I do not have, off the top of my head, the answers to your Qs, may I ask why you are asking? SG

Regulation 6 of the Load Line Convention 2005 Edition state:
" Ships when engaged on international voyages between the near neighbouring ports of two or more States may be exempted by the Administration (ie; the Flag State) from the provisions of the present Convention, so long as they shall remain engaged on such voyages if the Government of the States in which such ports are situated shall be satisfied that the sheltered nature or conditions of such voyages between such ports make it unreasonable or impracticable to apply the provisions of the present Convention to ships engaged on such voyages."
In layman terms, a Flag Administration such as the USCG, Panama, Marshall Islands, etc may make exemptions for such doors if they feel like such a requirement is not necessary. The burde of proof for the voyage being sheltered is usually on the vessel owner.

Any information or places I can go to read up more about this would be greatly appricated.[/QUOTE]

What specific info do you want, pertaining to what? Answers depend upon WHAT, WHERE and WHEN the particular opening you are looking for is on a vessel.

From your description, of a door leading from the superstructure OUT to a deck is ABOVE the watertight subdivision, then it does NOT have to be watertight (just weathertight) But, again, without specific details, it is hard to pinpoint.

Also remember that the LL Convention of “superstructure” does not necessarily include deckhouses. Coaming requirements are regulated by location onboard the vessel and the spaces that the hatches/doors/etc. open into. They are defined in Form LL-11-D, the Survey for Load Line Assignment and are issued for every vessel that carries one.

Bit more information,

Why I’m looking for this: Has to do with a potential research paper I will be doing for school. (Im studying to be a Naval Architect)

On the vessel itself, the problem is coming up with a theoretical ice breaker that will have large hallways in order to allow access of pallet jacks to move various materials from inside and outside of the ship.
The owner of the icebreaker wants to be able to use the pallet jack route while techincally at sea but stopped in ice to collect scientific data.

The doors are in the aft .75L of the vessel on the main deck.

To do this idealy for the pallet jack routes there would be no coamings on the door.

What the challenge really is to get a rule exemption from transport Canada (I go to a Canadian school so my proffessor has asked us to use transport canada as the agency to apply for accemption).

Now I have a better idea of what I am looking for at it would help if I could find any information on any vessels that were able to a door coaming exemption for any reason at all (doesn’t have to be canadian). I have found one example but I am having trouble finding out why they were permitted and what details or any risk calculations that were included in their exemption application.

Again any information or suggestions on where to look would be greatly apprecitaed.