This unified interpretation pertains to ships assigned reduced
freeboards in accordance with regulation
27 of the International Convention on Load Lines, 1966 (1966
LL Convention) and intended to carry deck cargo.
In subparagraph .6 of the footnote to SOLAS regulation II-1/25-1,
ships shown to comply with regulation 27 of
the 1966 LL Convention as applied in compliance with IMO resolutions A.320(IX) and A.514(13), may be excluded from the application
of SOLAS chapter II-1 part B-1.
The footnote accepts the deterministic damage stability
analysis according to the load line regulations in lieu of the probabilistic
method of SOLAS chapter II-1 part B-1. This was considered an acceptable
substitution because of the very conservative assumptions of the initial
load case made in the deterministic calculation under regulation 27(7) of the 1966 LL Convention.
This can only be presumed for bulk carriers where the cargo is carried
solely within the cargo holds, but may not always be true for bulk
carriers which may occasionally also carry deck cargo, or other cargo
ships intended for carriage of deck cargo which have been designed
to take advantage of a reduced freeboard assignment.
Therefore, for such ships damage stability calculations
should be carried out as follows:
.1 due to the assigned reduced freeboards, in
compliance with the damage stability requirements of regulation 27 of the 1966 LL Convention
and the 1988 LL Protocol; and
.2 due to the intended deck cargo capacity, the
limiting GM or KG curve required by SOLAS regulation II-1/25-8 should
be provided to the master for guidance, based on compliance with the
probabilistic damage stability analysis of SOLAS chapter II-1 part
The KG used for demonstrating compliance with the deterministic
damage stability requirements of regulation
27 of the 1966 LL Convention should be the same as that used
for the probabilistic damage stability calculations required by SOLAS
chapter II-1 part B-1, at the deepest subdivision load line.