Permanent means of access contained in table 1 of the Technical
provisions for means of access for inspections (resolution
MSC.158(78)) should not apply to tankers converting from single-hull
to double-hull. However, if, in the course of conversion, substantial
new structures are added, these new structures should comply with
the regulation. The term “substantial new structures”
means hull structures that are entirely renewed or augmented by new
double bottom and/or double side construction (e.g., replacing the
entire structure within cargo area or adding a new double bottom and/or
double side section to the existing cargo area).