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Article 19.06(3)(a) - Application of article 19.06(3)(a) to a group of toilets

The wording of article 19.06(3)(a) of the ES-TRIN is as follows:

“a) Rooms or groups of rooms designed or arranged for 30 or more passengers or including berths for 12 or more passengers shall have at least two exits. On day trip vessels one of these two exits can be replaced by two emergency exits. Rooms, with the exception of cabins, and groups of rooms which have only one exit, shall have at least one emergency exit. ”

Q1) The last sentence of article 19.06(3)(a) of the ES-TRIN stipulates that “Rooms, with the exception of cabins, and groups of rooms which have only one exit, shall have at least one emergency exit.”

The exemption envisaged for cabins seems to us to be appropriate because we believe such a requirement would be severe and difficult to apply for rooms which are only intended to accommodate very few people at a time. But other rooms are in the same situation, in particular toilets. Should the latter also possess an emergency exit or can they be equated with “cabins” as construed by this article?

Q2) Reading article 19.06(3)(a) leads to the following conclusion: a group of rooms, designed or arranged for fewer than 30 passengers, must possess a minimum of one exit and one emergency exit. This requirement is valid for a group of cabins containing berths for fewer than 12 passengers.
By extension, a group of toilet cubicles, designed or built for fewer than 30 passengers, must possess a minimum of one exit and an emergency exit. Can the working group confirm this interpretation, in particular for day-trip vessels?

RV/G (15) 30

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CCNR Inspection Regulations Working Group RV/G, group of rooms, passenger vessels, group of toilets, exit, emergency exit