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Article 19.03(9)(c) in conjunction with Article 1.01(4.6) and Article 19.02(16) - Flooding criteria when calculating stability

Article 1.01(4.6) sets the margin line 10 cm below the bulkhead deck.

Article 9.02(16) deals with windows relative to the margin line.

Article 19.03(9)(c) defines the flooding criteria. “The bulkhead deck shall not be immersed in the final stage of flooding.”

These articles of the ES-TRIN precisely define the margin line but the flooding criterion refers not to this line but to the bulkhead deck. The margin line can thus be located below the waterline as long as the bulkhead deck is not immersed.

Is this interpretation correct? If so, the calculation of the length that can be flooded is based on flooding up to the bulkhead deck.

If the draught is permitted to be up to the bulkhead deck, what is the point of defining the margin line in the requirements?


The 2nd sentence of article 19.03(9)(c) (“The bulkhead deck shall not be immersed in the final stage of flooding”) is different to the first criterion of the definition in 4.6 (“an imaginary line drawn on the site plating not less than 10 cm below the bulkhead deck”).

There are grounds for wondering whether this difference of 10 cm is voluntary and whether there are grounds for retaining it or else amending the regulations. In the latter case, article 19.03(9)(c) could be worded as follows:

“The margin line shall not be immersed.” or “In the final stage of flooding, the bulkhead deck must be located a minimum of 0.10 m above the waterline.”

RV/G (07) 84 rev. 1

The information on this topic is accurate. But there is no point amending the requirements.

The definition of the margin line is required because of other requirements (article 19.02(5) and (16), article 19.06(8), article 19.10(6), article 19.15(1) and article 28.04(3)(c)).

RV/G (07) 90

CCNR Inspection Regulations Working Group RV/G, stability, flooding, margin line