Member Questions MNZ Rules

In answer to the article in the Wellington DomPost, MNZ issued a statement recently which in part said that the ship was now “stronger” than it was originally and that length means 96% of the total length on a waterline at 85% of the least moulded depth measured from the top of the keel, or the length from the of the stern to the axis of the rudder stock on the waterline, if that is the greater length.

A member has forwarded the following comments

In supporting its actions MNZ is making much of the fact that the bow is now stronger. This is a red herring. Strength is not the issue. The real issue is the matter of her length since it appears that, based on MNZ statements, the regulations are based on length. I do not understand how the drilling of holes in the bow section has reduced her length.  

The ‘total length’ — the words, used in the first part of the MNZ definition and given their usual meaning — has not altered by either hole drilling or the fitting of the bulkhead. Neither the ‘fore side of the stem’ (the words in the second part of the MNZ definition) nor the rudder stock appear to have been moved to alter the length. 

He asks three questions: 

(i) Is there a definition of ‘stem’ in the regulations which may impart a different meaning from that normally associated with the use of the word? 

(ii) What, if any, is the effect on the position of the stem (as used by MNZ) by adding a watertight bulkhead?  

(iii) Does ‘the stem’, by definition other than that in normal use, but in compliance with any different one (if any) in the regulations, shift aft as a consequence? 

If this is the case, can it be argued that her ‘length’ is reduced below the 45m requirement for registration under the New Zealand Safe Ship Management.  If this so the following questions are asked:  

(i))How far can a vessel’s structure, with holes drilled in it, be permitted to extend beyond this watertight  bulkhead? 

(ii)Provided adequate structural strength, especially longitudinal strength, is designed into the ship in the first place, can this hull extension be of any length?  

While a vessel with an extension of say 20m, would involve extra building cost and at first appear completely pointless, attracting additional port dues and other costs, her speed could benefit by increased waterline length. Also, the larger vessel could be expected to have proportionally increased beam thereby increasing her cargo/earning capacity. 

Such a situation is, of course, hardly conceivable and even posing such a question may be considered farcical — but what does it say about the regulations? 

The MNZ counters the Dominion Post comments by stating rightly that the modifications are not a loophole. However, the modifications have been possible because of what can certainly be suggested as being a loophole in the regulations.  

While perhaps quite correctly MNZ was obliged on technical grounds to concede the vessel’s modifications and allow her to fall within the ambit of the SSM regime, clearly the regulations themselves are in need of modifications if their spirit is also to be observed. 

While fully recognising that ships are built or modified to bring them within the scope of certain rules and regulations, and that while under the SSM rules she is not subject to any International regulations, I do not believe that the current operation of ANATOKI fulfils the spirit of any regulations, national or international, intended to make shipping safer.