29.11.
2008
RIVER SEA VESSELS - A NEW CONCEPT
We are all aware that in India we have Ocean going & coastal V/Ls which are conforming to
the guide lines given in the Indian Merchant Shipping Act and the Inland vessels which are
self propelled barges, tugs, launches, passenger ferries which ply in harbours, in side port
limit, in Hoogly, Brahmaputra rivers and back waters of Kerala etc which follow the Inland
Steam V/L Act 1917.
Up till now there was no integration between Inland V/Ls & coastal V/Ls. That means
self propelled Inland barges under I.V. act could not take iron ore from Mumbai Harbour to
Revdanda only 40N.M.away or coal from Mumbai to Dahanu for the Reliance power station,
Bentonite from okha to Mumbai or iron ore from Paradeep to Haldia & coal from Haldia to
Paradeep even in flat calm sea condition. For this low value cargo, an expensive coastal V/L,
registered under Indian Merchant Shipping Act, manned by officers & engineers, with
inflated salaries, & whose competence on paper is considered higher by the Industry, than
reqd about 3 days of short sea passage. Small coastal V/Ls registered under M.S.Act have 13
certificates 10 given by D.G. /MMD & 3 given by IRS. Where as self propelled barges under
I.V.act have only 4 certs. Two given by state administration such as Gujarath Maritime
Board, Maharashtra Maritime board (Registry & Survey) & 2 given by IRS (class &
loadline). The difference in finance required was huge, in crores of rupees for construction,
survey, certification and operation of an Inland twin screw cargo V/L under I.V. Act and a
same size coastal V/L registered under M.S.Act. In other words there was a need to upgrade
inland V/L under I.V.Act & down grade coastal V/L registered under M.S.Act, so that we can
have an RSV. A River Sea V/L which will economically and safely, within the frame work of
M.S.Act perform the functions of both the types of V/Ls mentioned above.
An expert committee under the chairmanship of Chief Surveyor to GOI, the Chief Co-
ordinator appointed by Government of India, key members of the Indian Coastal Conference
and Goa Barge Owner’s Association deliberated, and came out with Notification for
Construction, Survey, Certification and Operation of Indian River Sea vessel. It was not an
easy task.
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This presentation is not only about the gist of ninety odd pages of this Notification, which
is available on D.G. Shipping website but also about feed back from the industry, their
difficulties, suggestions recd from RSV shipowners and change in M.S.Act 1958.
But first briefly what is an RSV? Section 456 of M.S.Act 1958 empowers D.G.Shipping
to exempt Indian Shipping, operating along the Indian Coast within the territorial limits of
India, from following provisions of M.S. Act 1958 and dispenses with the requirements to
observe M.S. Act provisions, provided strict compliance is shown to the requirements and
stipulations detailed in Annexes I to XI of this Notification.
Brief Summary follows. For implemention of rules, the Notification is to be referred.
ANNEX - 1 Preamble & General Provisions: Here RSVs are divided in to 4 types of V/Ls
according to their voyage endurance. Type 1, Type II, Type III & Type IV.
Type 1: RSVs which ply 12 NM beyond IV limits in fair weather only. e.g. coal lighterage
which takes place out side Mumbai Harbour.
Type II: RSVs which ply between nearby ports in fair weather. During Day Light Hrs Only.
Type III: RSVs which ply between Indian ports where voyage duration does not exceed 24
hours. V/L to keep maximum parallel distance of 12 NM from nearest land, save Gulf of
Cambay & Kutch where max dist of 30 NM from shore is allowed.
Type IV: RSVs which ply between Indian Ports in all weather conditions, 12 NM parallel
dist Gulf Kutch / Cambay accepted.
Type I & II V/L may be registered under I.V. Act at owner’s option.
Type III & IV V/L to be registered under M.S.Act.
Maximum size limit for RSV 3000 Gross & 3000 KW.
And in between there is a thresh hold V/L of 1600GT and 1500KW.
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B. General Provisions:
RSV rules apply to V/Ls
1) Engaged exclusively on Indian coastal voyages.
2) Do not apply to passenger V/Ls, tankers, bulk chemicals in any form, fishing V/Ls,
OSVs, military & govt V/Ls not used for commercial purpose.
ANNEX II: Minimum Safe Manning Requirements. Here I.V. Master CL 1, Class 2 are &
Inland drivers CL.1 are utilized as watchkeepers. Officers & crew will receive full seatime in
respect of eligibility and service requirements towards NCV certificates.
ANNEX III: Accommodation Standards
a) Master & C/E - 1 person per room
b) Other Officers - 2 persons per room
c) Aprentices / Ratings - Not more than 4 persons per room.
ANNEX IV: Construction Rules
In this notification there are construction rules for Type III & Type IV RSV.
DGs has already framed rules for Type I & Type II under recommendations of
MSDC (Maritime States Development Council).
Engine room of all RSV >90M in length to have double bottom in E
Room. (All I.V. self propelled barges built in last 10yrs do not have
D.B. in Engine room space.)
A collision Bulk, Afterpeak bulkhead, A bulkhead at each of the
machinery space.
Fuel oil capacity of Type III Type IV Vessels shall not exceed 600m3.
Type III V/Ls having cargo hold(s) without hatch covers, the bilge
pumping capacity shall be increased by 1.5 times.
Chapter V regulation 22 of SOLAS 1994 as amended shall be
applicable to RSV > 45M length.
Hatch Covers: Type III V/Ls < 90M in length not reqd.
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ANNEX V: Prevention of Collisions
To comply with COLREG 1972 as amended.
ANNEX VI: Life Saving Appliances
Inflatable Life raft servicing can be stretched up to 17 months and not every 12
months as for M.S.Act V/Ls.
Mob Marker not reqd.
Only 6 parachute Roket flares. No smoke floats and Hand flares.
ANNEX VII: Fire Fighting Appliances
Only 2 fire hoses, 45MM internal dia, 32MM in accommodation.
Above 1500KW fixed five fighting system in E.Room
i) Gas
ii) High expansion foam
iii) Pressure water spraying system
Below 1500KW: Portable extinguishers between 2 to7, for each 75KW 1 Portable 1.45Ltrs.
ANNEX VIII: RADIO COMMUNICATIONS
<500 GT AIS class B transponder
500 to 1600GT AIS class A transponder
Above 1600GT AIS class A transponder
Annex IX: SAFETY OF NAVIGATION
1Gyro above 1600GT.
No sextant, No Nories tables, No Nautical Almanac.
1 Radar for all RSVs.
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ANNEX X: Survey & Certificates
An RSV V/L will not be stopped by an inspecting surveyor if some minor
deffeciencies are found. RSV will be allowed to sail and astipulated time will be
given to complete deffeciencies
Surveys will be:
1) An initial survey before the river-sea V/L is put in service
2) Renewal survey not exceeding 5 yrs.
3) Intermediate survey within 3 months before or offer 2nd or 3rd Anniversary date
4) Annual survey 3 months + -.
5) 2 dry docking with in 5 years. 1 can be CC TV
ANNEX XI: Prevention of Pollution
1) Dedicated holding tank or oil filtering equipment.
Briefly this is an RSV. But how many RSVs we have so for? According to IRS, as
of today, 10 nos. are in the process of RSV registration completion. Why only ten when about
130 to 150 probable units are on the coast. There are hurdles, which plagued our coastal
shipping in the past & they continue to plague today.
When I talked to small ship owners, barge owners, tug owners they put the blame
squarely on DG shipping. Yes more lenient regulations towards RSVs would definitely help.
So who is an RSV owner? He is not an established shipping company. He is not
elite enough to become INSA member. He does not have any voice or lobby, except Indian
Coastal Conference or various Barge owners Association which are not yet a force to reckon
with. But there are now 60 to 70 potential RSV owners barely surviving on lighterage
operations, waiting for opportunity to be given to them. They are burdened with below
mentioned well known, often talked about problems:-
Oil Prices: Airline Industry gets ATF at reduced price. Sales tax is only 7% on ATF. It is
34% for Diesel used on coastal V/Ls. Airline Industry gets 60 days credit to pay fuel bills
which they want to increase to 90 days. RSV shipowner has to pay DD in advance to IOC.
ATF got price cut 5 times in last few months. Right now Aviation Ministry is doing its
utmost by reducing ATF prices, reducing of air port charges so that air line industry survives.
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Customs: Menace of Customs, Immigration, Police, dock entry permits, shipping bills for
stores and spares, double handling of cargo and what have you? The road transport, Air cargo
transport & Rail transport industry do not have to waste time, energy & resources to over
come these hurdles.
Articles of Agreement: Opening Articles of Agreement with the shipping master, inspite of
simplifications of procedures, is still a hurdle. No RSV owner can afford to give Kumud
Bansal Award wages to crew. It is not yet insisted upon, as it applies to INSA members only,
however unions hovering around shipping office do creep in. Exemtion from opening articles
of agreement was given to OSVs from 1980/81 onwards for about 15 years, as search for
hydrocarbons was the national priority. The ministry concerned gave ONGC vessels total
immunity from interfearance by unions.
Manning: At the wages affordable by RSVowners NCV Masters and Mates, NCV class III
enginees are not available. These officers and engineers get lucrative wages on offshore
supply vessels of INSA members. So how to tackle this Manning problem? If we observe
East & West Coast of India, we will see that there is a Minor or a Major port at every 15 to
20hrs of sea passage of an RSV. On west coast we have besides 8 Major ports about 30
Minor ports already functioning. On east coast we have 7 Major ports and about 25 Minor
ports functioning. More Minor port & private port are being added every year. We are talking
about passage of 12 nautical miles from nearest land. So allow Inland Masters and Drivers to
man these vessels more prominently than what is allowed under Annex II of this Notification.
After all actual handling of twin screw V/Ls is presently done by Inland Masters and not by
NCV Masters. If at all any onboard maintenance is done during passage, it is done by Inland
Drivers and not by cl. III NCV engineers. Manning cost of a 1500GT twin screw vessel
plying under I.V.act is Rs. 60,000/- per month & and if the same vessel is converted to RSV,
the manning cost goes up to Rs. 7 lakhs / month. The current wages of NCV Master & cl. III
C/E are Rs. 2 lakhs each at least.
Another area where cost cutting can be done for survival is the reduction or of Port dues for
RSVs. There are no dry docks available to RSVs. The existing dry docks in MBPT are going
to be filled up. Perhaps IRS can give 50% reduction in the survey fees.
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For getting rid of oily water from engine room there are no facilities in ports to discharge oily
waste. RSV owner will have to pay local barge owners to get rid of waste oily water.
All problems facing Indian shipping in general & coastal shipping in particular are attributed
mainly to the out dated Indian Merchant Shipping Act.1958. United Kingdom, where this Act
originated has long since adopted a new concept, where regulating every corridor of shipping
operation and bringing every minor certification under Administration scrutiny is totally
dispensed with. Who will do this in India? Who will educate MPs of the coastal States, so
that they will speak in the Parliament and pass bills to drastically change Merchant Shipping
Act. We do not see major shipowners and doyens of Indian Shipping, rubbing shoulders with,
and interacting with Minister of Surface Transport as we see the owner of King Fisher Airline
constantly interacting with Aviation Minister.
The exhaustive study reports, to kick start coastal shipping were under taken by Pradhan
Committee, Afzalpurkar Committee and Tata Consulting Services. These reports are
gathering dust for years and not translated or converted in to legal infrastructure.
But atleast at our level we can strengthen the arms of Indian Coastal Conference and
persuade D.G. Shipping, IRS, Port Administration, State Maritime boards, oil companies,
Maritime Unions, Custom & Immigration and financial institutions to nurture RSV concept
and give it a chance to survive first and then thrive later.
Thank You,
Capt. M.B.Ajgaonkar
Director
ORION OFFSHORE SERVICES PVT. LTD.
Dhanashree “A” wing, Lt. Dilip Gupte Road,
Near Hinduja Hospital, Mahim (west), Mumbai - 400016.
Tel: +91- 022 - 24458665, 91+022-65072396.
Email: [email protected]
