If the transverse watertight bulkheads in a region of the
ship are carried to a higher deck than in the remainder of the ship,
openings located in the bulkhead at the step may be considered as
being located above the freeboard deck.
All openings in the shell plating below the upper deck throughout
that region of the ship should be treated as being below the freeboard
deck, similar to the bulkhead deck for passenger ships (see figure
above), and the provisions of regulation 15 should be applied.