Maritime Questions › Wah Mgn Whatif Maib

A vessel's existing overside painting rig was built in-house by the crew using a custom rail and trolley arrangement, without any external testing or certification, and has been used for several years without incident. Does this arrangement comply with MGN 578/WAH Regulations expectations?

A. Yes — years of incident-free use demonstrates the system is safe
B. No — an engineered overside rail/trolley system should have installation drawings submitted for approval and witnessed installation/load testing (e.g. to 12kN) per MGN 578, regardless of how long an uncertified system has been used without incident
C. No, but only because the system was built by crew rather than purchased commercially
D. Yes, provided the crew re-inspect it informally before each use
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A company's internal safety manual, based on an older edition of COSWP, states a particular height-work practice is acceptable, but the current WAH Regulations 2010 / MGN 410 guidance is more stringent on that same point. Which requirement should the Chief Officer follow?
A. Follow the company manual, since it is the vessel's day-to-day reference document
B. Follow whichever is easier to implement operationally
C. Follow the more stringent WAH Regulations 2010 / MGN 410 requirement, since it is statutory law and takes precedence over COSWP guidance where the two conflict — the company manual itself should also be flagged for update
D. Average the two requirements to find a middle ground
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A vessel occasionally undertakes search and rescue support tasks under contract, and the Master wants to apply the Regulation 4(2) derogation broadly to reduce paperwork for all height-work tasks onboard, not just the SAR-specific ones. Is this a valid application?
A. Yes, since the vessel does sometimes carry out SAR work
B. Yes, provided the Master documents the decision in the deck log
C. Yes, but only if the vessel is flagged in a Red Ensign Group register
D. No — the derogation only applies to the specific provision that cannot be complied with due to characteristics peculiar to the SAR/civil protection activity itself; it cannot be stretched to cover routine height-work tasks unrelated to that activity
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