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ES-TRIN, Article 19.06(3) - Number of exits necessary for the evacuation of the upper deck (often referred to as the “sun deck”)

Question:
Article 19.06(3) lays down the requirements for the number and width of the exits of passenger rooms. From a technical point of view it would appear to us to be reasonable to require such an upper deck to have several access points, in particular for evacuating it when one of the access points is obstructed by an accident. However the requirements for exits (Article 19.06(3) of ES-TRIN) only appear to apply to passenger rooms and not to an open deck. This seems to indicate that there is no particular obligation regarding the number of exits on the upper deck.

What requirements apply to exits necessary for the evacuation of the upper deck?

Answer:
For the purposes of Article 19.06(3), an exit is a passage from one passenger room to another, or from one passenger room to an outside area (open deck). With the exception of partially enclosed deck areas referred to in Article 19.06(1) paragraph 2, ES-TRIN does not set requirements on the number and width of the exits from the upper deck (or sun deck) of passenger vessels. Open decks are deemed to be outside areas, which therefore in point of fact, by definition, do not have any “exits”. If the upper deck (or sun deck) is used for the evacuation of passengers, the requirements of Article 19.06(8) in ES-TRIN remain valid.

CESNI/PT/Pax (19) 5, Q20, CESNI/PT/Pax (21) 4, CESNI/PT/Pax (21)m 5, item 5

Working group for passenger vessels (CESNI/PT/Pax), sun deck, upper deck