Applicability: Shipowners, ship operators, ship managers, ship masters, designers, shipbuilders, bulk carriers and container ships.

An IMO amendment to SOLAS regulation II-2/20 (‘Protection of vehicle, special category and ro-ro spaces’*) comes into force on 1 January 2020. The amendment clarifies the regulation’s application to non-ro-ro cargo holds used for carriage of ‘vehicles with fuel in their tanks for their own propulsion’.  

The new paragraph in SOLAS regulation II-2/20, which applies to both new and existing ships, states:

“2.1.2 On all ships, vehicles with fuel in their tanks for their own propulsion may be carried in cargo spaces other than vehicle, special category or ro-ro spaces, provided that all the following conditions are met:

1. The vehicles do not use their own propulsion within the cargo spaces

2. The cargo spaces are in compliance with the appropriate requirements of regulation II-2/19

3. The vehicles are carried in accordance with the IMDG Code, as defined in regulation VII/1.1.”

The new paragraph effectively waives the requirements of SOLAS, Ch II-2, Regulation 20 for vehicles when transported in a non-ro-ro cargo space, despite such spaces coming under the SOLAS definition of a ‘vehicle space’.  Consequently, a vehicle can be loaded into the cargo space, and the cargo space may need only comply with SOLAS Regulation II-2/19 instead of Regulation II-2/20; depending on the requirements of the IMDG code**.

*The amendments are contained in IMO Resolution MSC.421(98).

**Reference should be made to the IMDG Code requirements for carriage of vehicles, i.e. cargo schedules UN No. 3166 and 3171, and Special Provisions 961 and 962.