Paragraph 2 – Definitions
GOOD: Condition with spot rusting on less than 3% of the
area under consideration without visible failure of the coating, or
no-perforated blistering. Breakdown at edges or welds should be less
than 20% of edges or weld lines in the area under consideration.
Coating Technical File (CTF): A term used for the collection
of documents describing issues related to the coating system and its
application from the point in time when the first document is provided
and for the entire life of the ship including the inspection agreement
and all elements of PSPC-COT 3.4.
Paragraph 3.2 – General principles
1 Inspection of surface preparation and coating
processes agreement should be signed by shipyard, shipowner and coating
manufacturer and should be presented by the shipyard to the Administration
for review prior to commencement of any coating work on any stage
of a new building and as a minimum should comply with the PSPC-COT.
2 To facilitate the review, the following from
the CTF, should be available:
-
a) Coating specification including selection of
areas (spaces) to be coated, selection of coating system, surface
preparation and coating process.
-
b) Statement of Compliance or Type Approval of
the coating system.
3 The agreement should be included in the CTF
and should at least cover:
-
a) Inspection process, including scope of inspection,
who carries out the inspection, the qualifications of the coating
inspector(s) and appointment of one qualified coating inspector (responsible
for verifying that the coating is applied in accordance with the PSPC-COT).
Where more than one coating inspector will be used then their areas
of responsibility should be identified. (For example, multiple construction
sites).
-
b) Language to be used for documentation.
4 Any deviations in the procedure relative to
the PSPC-COT noted during the review should be raised with the shipyard,
which is responsible for identifying and implementing the corrective
actions.
5 Cargo Ship Safety Certificate or Cargo Ship
Safety Construction Certificate, as appropriate, should not be issued
until all required corrective actions have been closed to the satisfaction
of the Administration.
Paragraph 3.4 – Coating Technical File (CTF)
Procedure for Coating Technical File Review
1 The shipyard is responsible for compiling the
Coating Technical File (CTF) either in paper or electronic format,
or a combination of the two.
2 The CTF is to contain all the information required
by paragraph 3.4 of the PSPC and the inspection of surface preparation
and the coating processes agreement (see PSPC-COT, paragraph 3.2).
3 The CTF should be reviewed for content in accordance
with the PSPC-COT, paragraph 3.4.2.
4 Any deviations found under paragraph 3 should
be raised with the shipyard, which is responsible for identifying
and implementing the corrective actions.
5 Cargo Ship Safety Certificate or Cargo Ship
Safety Construction Certificate, as appropriate, should not be issued
until all required corrective actions have been closed to the satisfaction
of the Administration.
Paragraph 3.5 – Health and safety
In order to document compliance with paragraph 3.5 of the
PSPC-COT relevant documentation from the coating manufacturer concerning
health and safety aspects such as Material Safety Data Sheet is recommended
to be included in the CTF for information.
Paragraph 4.5 – Special application
Reference is made to the Guidelines for corrosion
protection of permanent means of access arrangements (MSC.1/Circ.1279), approved by MSC 84 in
May 2008.
Paragraph 4, table 1 – Footnotes of standards
Only the footnoted standards referred to in PSPC-COT table
1 are to be applied, i.e. they are mandatory.
Paragraph 4, table 1, section 1.3 – Design of
coating system
Procedure for coating system approval
Type Approval Certificate showing compliance with the PSPC-COT
5 should be issued if the results of either method A+C, or B+C are
found satisfactory by the Administration.
The Type Approval Certificate should indicate the Product
and the Shop Primer tested. The certificate should also indicate other
type approved shop primers with which the product may be used which
have under gone the cross over test in a laboratory meeting the requirements
in Method A, paragraph 1.1 of this Unified Interpretation.
The documents required to be submitted are identified in
the following sections, in addition for all type approvals the following
documentation is required:
Technical Data Sheet showing all the information required
by PSPC-COT, paragraph 3.4.2.2.
Winter type epoxy is required separate prequalification
test including shop primer compatibility test according to PSPC-COT,
annex 1. Winter and summer type coating are considered different unless
Infrared (IR) identification and Specific Gravity (SG) demonstrates
that they are the same.
Method A: Laboratory test
1.1 Coating pre-qualification test should be carried
out by the test laboratory which is recognized by the Administration.
1.2 Results from satisfactory pre-qualification
tests (PSPC-COT, table 1: 1.3) of the coating system should be documented
and submitted to the Administration.
1.3.1 Type Approval tests should be carried out
for the epoxy based system with the stated shop primer in accordance
with the PSPC-COT, annex 1. If the tests are satisfactory, a Type
Approval Certificate will be issued to include both the epoxy and
the shop primer. The Type Approval Certificate will allow the use
of the epoxy either with the named shop primer or on bare prepared
steel.
1.3.2 An epoxy based system may be used with shop
primers other than the one with which it was originally tested provided
that, the other shop primers are approved as part of a system, PSPC-COT,
table 1: 2.3 and table 1: 3.2, and have been tested according to the
immersion test of PSPC-COT, annex 1, or in accordance with resolution MSC.215(82), which is known as the "Crossover
Test". If the test or tests are satisfactory, a Type Approval Certificate
will be issued. In this instance the Type Approval Certificate will
include the details of the epoxy and a list of all shop primers with
which it has been tested that have passed these requirements. The
Type Approval Certificate will allow the use of the epoxy with all
the named shop primers or on bare prepared steel.
1.3.3 Alternatively the epoxy can be tested without
shop primer on bare prepared steel to the requirements of the PSPC-COT,
annex 1. If the test or tests are satisfactory, a Type Approval Certificate
will be issued. The Type Approval Certificate will just record the
epoxy. The certificate will allow the use of the epoxy on bare prepared
steel only. If in addition, crossover tests are satisfactorily carried
out with shop primers, which are approved as part of a system, the
Type Approval Certificate will include the details of shop primers
which have satisfactorily passed the crossover test. In this instance
the Type Approval Certificate will allow the use of the epoxy based
system with all the named shop primers or on bare prepared steel.
1.3.4 The Type Approval Certificate is invalid
if the formulation of either the epoxy or the shop primer is changed.
It is the responsibility of the coating manufacturer to inform the
Administration immediately of any changes to the formulation.
1.3.5 For the coating pre-qualification test,
the measured average dry film thickness (DFT) on each prepared test
panels should not exceed a nominal DFT (NDFT) of 320 microns plus
20% unless a paint manufacturer specifies a NDFT greater than 320
microns. In the latter case, the average DFT should not exceed the
specified NDFT plus 20% and the coating system should be certified
to the specified NDFT if the system passes the tests according to
annex 1 of PSPC-COT. The measured DFT should meet the "90/10" rule
and the maximum DFT should be always below the maximum DFT value specified
by the manufacturer.
Method B: 5 years field exposure
1.4 Coating manufacturer's records, which should
at least include the information indicated in paragraph 1.4.1, should
be examined to confirm coating system has 5 years field exposure,
and the current product is the same as that being assessed.
1.4.1 Manufacturer's records
- – Original application records
- – Original coating specification
- – Original Technical Data Sheet
- – Current formulation's unique identification (Code or number)
- – If the mixing ratio of base and curing agent has changed,
a statement from the coating manufacturer confirming that the composition
mixed product is the same as the original composition. This should
be accompanied by an explanation of the modifications made.
- – Current Technical Data Sheet for the current production
site
- – SG and IR identification of original product
- – SG and IR identification of the current product
- – If original SG and IR cannot be provided then a statement
from the coating manufacturer confirming the readings for the current
product are the same as those of the original.
1.5 Either class survey records from an Administration
or a joint (coating manufacturer and Administration) survey of cargo
tanks of a selected ship is to be carried out for the purpose of verification
of compliance with the requirements of paragraphs 1.4 and 1.9. The
reporting of the coating condition in both cases should be in accordance
with the principles given in section 4 of MSC.1/Circ.1399.
1.6 The selected ship is to have cargo tanks in
regular use, of which:
- – At least one tank is exposed to minimum temperature of
60°C plus or minus 3°C.
- – For field exposure the ship should be trading in varied
trade routes and carrying substantial varieties of crude oils including
highest temperature and lowest pH limits to ensure a realistic sample:
for example, three ships on three different trade areas with different
varieties of crude cargoes.
1.7 In the case that the selected ship does not
meet the requirements in paragraph 1.6 then the limitations on lowest
pH and Highest temperature of crude oils carried should be clearly
stated on the Type Approval Certificate.
1.8 In all cases of approval by Method B, the
shop primer should be removed prior to application of the approved
epoxy based system coating, unless it can be confirmed that the shop
primer applied during construction, is identical in formulation to
that applied in the selected ship used as a basis of the approval.
1.9 All cargo tanks should be in "GOOD" condition
excluding mechanical damages, without touch up or repair in the prior
5 years.
1.9.1 "Good" is defined as: Condition with
spot rusting on less than 3% of the area under consideration without
visible failure of the coating, or no perforated blistering. Breakdown
at edges or welds should be less than 20% of edges or welds in the
area under consideration.
1.9.2 Examples of how to report coating conditions
with respect to areas under consideration should be as those given
in the principles contained in section 4 of MSC.1/Circ.1399.
1.10 If the applied NDFT is greater than required
by the PSPC, the applied NDFT will be the minimum to be applied during
construction. This will be reported prominently on the Type Approval
Certificate.
1.11 If the results of the inspection are satisfactory,
a Type Approval Certificate should be issued to include both the epoxy
based system and the shop primer. The Type Approval Certificate should
allow the use of the epoxy based system either with the named shop
primer or on bare prepared steel. The Type Approval Certificate should
reference the inspection report which will also form part of the Coating
Technical File.
1.12 The Type Approval Certificate is invalid
if the formulation of either the epoxy based system or the shop primer
is changed. It is the responsibility of the coating manufacturer to
inform the Administration immediately of any changes to the formulation.
Method C: Coating manufacturer
1.18 The coating/shop primer manufacturer should
meet the requirements set out in IACS UR Z17 paragraphs 4 to 7, (except
for 4.6) and paragraphs 1.18.1 to 1.18.6 below, which should be verified
by the Administration.
1.18.1 Coating manufacturers
-
(a) Extent of engagement – Production of
coating systems in accordance with PSPC-COT and this Unified Interpretation.
-
(b) These requirements apply to both the main
coating manufacturer and the shop primer manufacturer where both coatings
form part of the total system.
-
(c) The coating manufacturer should provide to
the Administration the following information;
- - A detailed list of the production facilities.
- - Names and location of raw material suppliers, which should be
clearly stated.
- - A detailed list of the test standards and equipment to be used,
(scope of approval).
- - Details of quality control procedures employed.
- - Details of any sub-contracting agreements.
- - List of quality manuals, test procedures and instructions, records,
etc.
- - Copy of any relevant certificates with their issue number and/or
date e.g. Quality Management System certification
-
(d) Inspection and audit of the manufacturer's
facilities will be based on the requirements of the PSPC-COT.
-
(e) With the exception of early "scale up" from
laboratory to full production, adjustment outside the limitations
listed in the QC instruction referred to below is not acceptable,
unless justified by trials during the coating system's development
programme, or subsequent testing. Any such adjustments must be agreed
by the formulating technical centre. If formulation adjustment is
envisaged during the production process the maximum allowable limits
will be approved by the formulating technical centre and clearly stated
in the QC working procedures.
-
(f) The manufacturer's quality control system
will ensure that all current production is the same formulation as
that supplied for the Type Approval Certificate. Formulation change
is not permissible without testing in accordance with the test procedures
in the PSPC-COT and the issue of a Type Approval Certificate by the
Administration.
-
(g) Batch records including all QC test results
such as viscosity, specific gravity and airless spray characteristics
will be accurately recorded. Details of any additions will also be
included.
-
(h) Whenever possible, raw material supply and
lot details for each coating batch will be traceable. Exceptions may
be where bulk supply such as solvents and pre-dissolved solid epoxies
are stored in tanks, in which case it may only be possible to record
the supplier's blend.
-
(i) Dates, batch numbers and quantities supplied
to each coating contract will be clearly recorded.
1.18.2 All raw material supply should be accompanied
the supplier's "Certificate of Conformance". The certificate will
include all requirements listed in the coating manufacturer's QC system.
1.18.3 In the absence of a raw material supplier's
certificate of conformance, the coating manufacturer should verify
conformance to all requirements listed in the coating manufacturer's
QC system.
1.18.4 Drums should be clearly marked with the
details as described on the "Type Approval Certificate".
1.18.5 Product Technical Data Sheets must comply
with all the PSPC-COT requirements. The QC system will ensure that
all Product Technical Data Sheets are current.
1.18.6 QC procedures of the originating technical
centre will verify that all production units comply with the above
stipulations and that all raw material supply is approved by the technical
centre
1.19 In the case that a coating manufacturer wishes
to have products which are manufactured in different locations under
the same name, then IR identification and SG should be used to demonstrate
that they are the same coating, or individual approval tests will
be required for the paint manufactured in each location.
1.20 The Type Approval Certificate is invalid
if the formulation of either the epoxy based system or the shop primer
is changed. It is the responsibility of the coating manufacturer to
inform class immediately of any changes to the formulation. Failure
to inform class of an alteration to the formulation will lead to cancellation
of the certificates for that manufacturer's products.
Paragraph 4, table 1, section 1.4 – Job specification
Wet film thickness should be regularly checked during application
for quality control by the Builder. PSPC-COT does not state who should
check WFT, it is accepted for this to be the Builder. Measurement
of DFT should be done as part of the inspection required in PSPC-COT,
paragraph 6.
Stripe coats should be applied as a coherent film showing
good film formation and no visible defects. The application method
employed should insure that all areas that require stripe coating
are properly coated by brush or roller. A roller may be used for scallops,
ratholes etc. but not for edges and welds.
Paragraph 4, table 1, section 2 – PSP (Primary
surface preparation)
The conductivity of soluble salts is measured in accordance
with standards ISO 8502-6 and ISO 8502-9 or equivalent method as validated
according to NACE SP0508-2010, and compared with the conductivity
of 50 mg/m2 NaCl. If the measured conductivity is less
than or equal to, then it is acceptable. Minimum readings to be taken
are one (1) per plate in the case of manually applied shop primer.
In cases where an automatic process for application of shop primer
is used, there should be means to demonstrate compliance with PSPC-COT
through a Quality Control System, which should include a monthly test.
Shop primers not containing zinc or not silicate based are
considered to be "alternative systems" and therefore equivalency is
to be established in accordance with section 8 of the PSPC-COT with
test acceptance criteria for "alternative systems" given in section
3.1 (right columns) of appendixes 1 and 2 to annex 1 of PSPC-COT.
Procedure for review of Quality Control of Automated
Shop Primer plants
1 It is recognized that the inspection requirements
of PSPC-COT, paragraph 6.2, may be difficult to apply to an automated
shop primer plant and a Quality Control approach would be a more practical
way of enabling compliance with the requirements of PSPC-COT.
2 As required in PSPC it is the responsibility
of the coating inspector to confirm that the quality control procedures
are ensuring compliance with PSPC-CO
3 When reviewing the Quality Control for automated
shop primer plants the following procedures should be included.
3.1 Procedures for management of the blasting
grit including measurement of salt and contamination.
3.2 Procedures recording the following: steel
surface temperature, relative humidity, dewpoint.
3.3 Procedures for controlling or monitoring surface
cleanliness, surface profile, oil, grease, dust and other contamination.
3.4 Procedures for recording/measuring soluble
salts.
3.5 Procedures for verifying thickness and curing
of the shop primer conforms to the values specified in the Technical
Specification.
Paragraph 4, table 1, section 3 – SSP (Secondary
surface reparation)
Usually, the fillet welding on tank boundary watertight
bulkhead is left without coating on block stage (because not yet be
leakage tested), in which case it can be categorized as erection joint
("butt") to be power tooled to St 3.
The conductivity of soluble salts is measured in accordance
with standards ISO 8502-6 and ISO 8502-9, or equivalent method as
validated according to NACE SP0508-2010, and compared with the conductivity
of 50 mg/m2 NaCl. If the measured conductivity is less
than or equal to, then it is acceptable.
All soluble salts have a detrimental effect on coatings
to a greater or lesser degree. The standard ISO 8502-9:1998 does not
provide the actual concentration of NaCl. The percentage of NaCl in
the total soluble salts will vary from site to site. Minimum readings
to be taken are one (1) reading per block/section/unit prior to applying.
Paragraph 4, table 1, section 4 – Miscellaneous
All DFT measurements should be measured. Only the final
DFT measurements need to be measured and reported for compliance with
the PSPC-COT by the qualified coating inspector. The Coating Technical
File may contain a summary of the DFT measurements which typically
will consist of minimum and maximum DFT measurements, number of measurements
taken and percentage above and below required DFT. The final DFT compliance
with the 90/10 practice should be calculated and confirmed, see PSPC-COT,
paragraph 2.8.
Paragraph 4, table 1, section 5 – Coating system
approval
See Interpretation of PSPC-COT table 1: 1 Design of coating
system, 1.3 Coating prequalification test.
Paragraph 4, table 1, section 6 – Coating inspection
requirements
Procedure for assessment of Coating Inspectors'
qualifications
1 Coating inspectors required to carry out inspections
in accordance with the PSPC-COT, paragraph 6, should be qualified
to NACE Coating Inspector Level 2, FROSIO Inspector Level III, or
an equivalent qualification. Equivalent qualifications are described
in paragraph 3 below.
2 However, only coating inspectors with at least
2 years relevant coating inspector experience and qualified to NACE
Coating Inspector Level 2 or FROSIO Inspector Level III, or with an
equivalent qualification, can write and/or authorise procedures, or
decide upon corrective actions to overcome non-compliances.
3 Equivalent Qualification
3.1 Equivalent qualification is the successful
completion, as determined by course tutor, of an approved course.
3.1.1 The course tutors should be qualified with
at least 2 years relevant experience and qualified to NACE Coating
Inspector Level 2 or FROSIO Inspector Level III, or with an equivalent
qualification.
3.1.2 Approved Course: A course that has a syllabus
based on the issues associated with the PSPC including the following:
- – Health environment and safety
- – Corrosion
- – Materials and design
- – International standards referenced in PSPC
- – Curing mechanisms
- – Role of inspector
- – Test instruments
- – Inspection procedures
- – Coating specification
- – Application procedures
- – Coating failures
- – Pre-job conference
- – MSDS and product data sheet review
- – Coating Technical File
- – Surface preparation
- – Dehumidification
- – Waterjetting
- – Coating types and inspection criteria
- – Specialized application equipment
- – Use of inspection procedures for destructive testing and
non-destructive testing instruments
- – Inspection instruments and test methods
- – Coating inspection techniques
- – Cathodic protection
- – Practical exercises, case studies.
Examples of approved courses may be internal courses run
by the coating manufacturers or shipyards etc.
3.1.3 Such a course should have an acceptable
measurement of performance, such as an examination with both theoretical
and practical elements. The course and examination should be approved
by the Administration
3.2 Equivalent qualification arising from practical
experience: An individual may be qualified without attending a course
where it can be shown that the individual:
- – has a minimum of 5 years practical work experience as
a coating inspector of ballast tanks and/or cargo tanks during new
construction within the last 10 years; and
- – has successfully completed the examination given in paragraph
3.1.3.
4 Assistants to coating Inspectors
4.1 If the coating inspectors requires assistance
from other persons to perform part of the inspections, those persons
should perform the inspections under the coating inspector's supervision
and should be trained to the coating inspector's satisfaction.
4.2 Such training should be recorded and endorsed
either by the inspector, the yard's training organization or inspection
equipment manufacturer to confirm competence in using the measuring
equipment and confirm knowledge of the measurements required by the
PSPC-COT.
4.3 Training records should be available for verification.
Paragraph 4, table 1, section 7 – Coating verification
requirements
Procedure for Verification of Application of
the PSPC-COT
1 The verification requirements of PSPC-COT, paragraph
7, should be carried out by the Administration.
1.1 Monitoring implementation of the coating inspection
requirements, as called for in PSPC-COT, paragraph 7.5 means checking,
on a sampling basis, that the inspectors are using the correct equipment,
techniques and reporting methods as described in the inspection procedures
reviewed by the Administration.
2 Any deviations found under paragraph 1.1 should
be raised initially with the coating inspector, who is responsible
for identifying and implementing the corrective actions.
3 In the event that corrective actions are not
acceptable to the Administration or in the event that corrective actions
are not closed out then the shipyard should be informed.
4 Cargo Ship Safety Certificate or Cargo Ship
Safety Construction Certificate, as appropriate, should not be issued
until all required corrective actions have been closed out to the
satisfaction of the Administration.
Annex 1 – Footnotes of standards
Only the footnoted standards referred to in annex 1 are
to be applied, i.e. they are mandatory.