IACS Common Structural Rules Knowledge Centre

Updated: 05/02/2007

IMO PSPC - IACS Interpretations

IMO
PSPC

Topic

Approved

General

fee

2006-12-21

Clarification Items

Interpretations

Classification fee including detail scope of verification and inspection.

Verification and inspection in accordance with the IACS PR34

2.5

edges

2007-01-31

PSPC 2.5 reads: Edge grinding is the treatment of edge before

secondary surface preparation.

Edges mean all sharp edges (non-radiused or with a radius less than 2 mm).
Which includes both thermally and mechanically edges. All sharp edges (non
- radiused or radius less than 2mm) are subject to edge grinding. All edges
with the exception of the natural rounded edges of sections (or profiled steel
bars) are subject to two stripe coats.

2.11

sharp edges

2006-12-21

Do edges mean sharp edges or flame cut edges?

Are automated welds included or not for stripe coats?

Edges means all edges except the natural rounded edges of sections (or
profiled steel bars). Automated welds need stripe coat.

3.2

inspection
requirements

2007-01-31

PSPC 3.2 reads: Inspection of surface preparation and coating

processes shall be agreed upon between the ship owner, the shipyard
and the coating manufacturer and presented to the Administration for
review.

PSPC inspection requirements are the minimum to be applied, there is no

provision for that to be reduced. There is no provision for a reduction within
CSR.

EG to
confirm

3.4.1

Record

2007-02-10

What is Record of the shipyards and shipowners coating work? For

shipbuilding, is it the same as 3.4.2-3/6?

Yes

4.4.2

coating
specifications

2006-12-21

What should be included in the specification? f the specification

means the coating specification which is defined in ANNEX1, is it
possible to use PSPC as a coating specification because PSPC is
covered the required inclusions.

Manufacturers need to provide a specification detailing all the requirements of

table 1 of the PSPC.

4.4.2

coating
specifications

2007-01-31

The specification may be the technical data sheet if all the information required
PSPC 4.4.2 reads: Coating manufacturers shall provide a specification is provided on it. This question should be addressed to paint manufacturers.
of the protective coating system to satisfy the requirements of table 1. The specification should contain application procedure, acceptance criteria and
inspection etc. as specified in paragraph 2 of annex 1 of the PSPC.

2006-12-21

Type approved paint and manufacturer list including verified technical

data sheet.

4.4.3/
paint and
table 1-1.3 manufacturer list

Printed: 2007-02-08

Coating manufacturers should provide details of the type approved coatings in

accordance with PSPC. This is no different from other manufacturers providing
details of their products and relevant certification.

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IMO
PSPC

Topic

Approved

table 1-1.

type approval
certificate

2006-12-21

Is further consideration necessary to the coating systems which have a Yes as required by sect 3.2 agreement between all parties. Coating systems
type approval certificate?
must meet all relevant requirements of the PSPC

table 1-1.2

light color

2006-12-21

Definition of light color?

light colour as agreed by all parties in PSPC sect 3.2

10

table 1-1.2

light color

2007-01-31

Table 1-1.1.2,4th bullet reads: The top coat shall be of a light colour in
order to facilitate in-service inspection.

A light colour means a colour that reflects light to an extent that a simple flash
light (hand torch) will make inspection easy fast. Normally light grey, off-white,
swimming pool blue/green etc. easily distinguishable from rust.
1) Yes winter and summer type coating are considered different unless IR
identification and specific gravity demonstrates that they are the same.
2) shop primer should be removed if it cannot be demonstrated to be compatible
with the coating to be used.
3) No because it should be included as coating system which is confirmed by
the coating manufacturer.

Clarification Items

Interpretations

11

table 1-1.3

type epoxy

2006-12-21

1) Is winter type epoxy required separate prequalification test including

shop primer compatibility test according to Annex 1?
2) Intact shop primer should be removed or not, in case 5 years field
exposure are validate as a type approval test?
3) Is separate compatibility test for shop primer required? If yes, please
provide detail test procedure.

12

table 1-1.4

NDFT

2006-12-21

Who and how to prove that the NDFT can be met in way of welded
seam in order to skip second stripe coat.

measure flat plate adjacent to the weld, approved by the inspector ref table

2006-12-21

Does Stripe coats shall be applied by brush or roller. Roller to be used

for scallops, ratholes, etc. only. interpret that Stripe coats shall be
applied by brush or roller. However, stripe coat for scallops, ratholes,
etc. to be applied by roller?

As discussed at MSC 82 by the IMO informal Group of Experts the

understanding is that stripe coat to be applied by brush. However in way of rat
holes, scallops etc a roller may be used.

2007-01-31

Table 1-1.4, 1st bullet reads: There shall be a minimum of two stripe
coats and two spray coats, except that the second stripe coat, by way of
welded seams only, may be reduced in scope where it is proven that the
NDFT can be met by the coats applied in order to avoid unnecessary
over thickness. Any reduction in scope of the second stripe coat shall
be fully detailed in the CTF.

It was confirmed at MSC 82 that stripe coats are to be applied by brush, this
includes all welds. However where edges are rounded to a radius greater or
equal to 2 mm, stripe coats may be applied by brush or roller. Two stripe coats
are to be applied to all edges and all irregular welding beads. One stripe coat
may be applied in way of smooth automatic weld beads subject to confirmation
that the NDFT has been achieved by thickness measurement of the coating
after the second spray coat. Measurement of this NDFT is to be immediately
adjacent to the weld bead.

13

14

table 1-1.4

table 1-1.4

Printed: 2007-02-08

stripe coats

stripe coats

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16

EG to
confirm

IMO
PSPC

Topic

Approved

table 1-1.4

stripe coats

2007-01-31

Table 1-1.4, 2nd bullet reads: Stripe coats shall be applied by brush or
roller. Roller to be used for scallops, ratholes, etc., only.

Etc. means or similar.

2007-01-31

Table 1-1.5, 3rd bullet reads: Wet film thickness shall be regularly
checked during application.

Wet film thickness shall be regularly checked during application for quality
control by the Builder. PSPC does not state who should check WFT, it is
accepted for this to be the builder. DFT is to be done as part of the inspection
section 6.

2007-02-10

The last para. reads: Checking of the steel surface cleanliness and
roughness profile shall be carried out at the end of the surface
preparation and before the application of the primer, in accordance with
the manufacturers recommendations. Section 6.2 Inspection itemPrimary surface preparation, the statements is very clear about the time
for checking steel temperature, relative humidity and dew point: before
the blasting process starts and at time of sudden changes in weather.
How about the testing of salt content and checking of oil, greese and
other contamination? Shall we check all of the plate or random check
can be accepted?

As agreed in Sect 3.2 of PSPC and noted in the shipyard procedure. If it is an

automated system it may be monitored instead of measuring every plate as long
as it is noted in the shipyard procedure and meets the requirements of Table12.

1) As agreed in Sect 3.2 PSPC

2) measure salt and remove before going into shot blasting or have shipyard
procedures to check occasional readings after shot blasting
3) The whole conductivity value is calculated to NaCl in accordance with the
manufacturers test instrument manual.

table 1-1.5 wet film thickness

table 1-2.1

steel surface
cleanliness

Clarification Items

Interpretations

17

table 1-2.2

measurement of
salt

2006-12-21

1) How many measurements of salt shall be required during primary

surface stage?
2) How to measure the salt during automated process?
3) How to convert only sodium chloride from the conductivity measure in
accordance with ISO 8502-9?

EG to
confirm

table 1-3

blcok and after

erection

2007-02-10

it is separate into two group: Block & after Erection. How to define the
painting work for joints and damages of Grand Assembly or PreErection? (The blocks had been coated before combine)

Can be categorized as after erection.

18

table 1-3.1

one pass

2006-12-21

One pass edge cut machining or one pass grinding followed by disc
papering on remaining edges are considered equivalent to three pass
grinding or not.

Only if a radius of 2mm is achieved.

2007-01-31

The PSPC requires all edges to be rounded to a radius of 2 mm minimum or

Edges to be treated to a rounded radius of minimum 2mm, or subjected that havent been subject to three pass grinding. An example of an equivalent
process is a dedicated edge grinding machine which will provide the profile
to three pass grinding or at least equivalent process before painting.
equal to radius 2 mm or three pass grinding by a single pass.

19

table 1-3.1

Printed: 2007-02-08

rounded radius

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IMO
PSPC

20

21

22

table 1-3.2

table 1-3.2

table 1-3.2

Topic

shop primer

Sa2.5

shop primer

Approved

Clarification Items

Interpretations

2006-12-21

1) Does The retained shop primer shall be cleaned by sweep blasting,

high pressure water washing or equivalent method. interpret that The
contamination on retained shop primer shall be cleaned by sweep
1) Yes
blasting, high pressure water washing or equivalent method.?
2) No
2) Is power tool cleaning applicable as an equivalent method?
3) Yes
3) Is power tool cleaning acceptable to the small areas of insufficiently
treated by blasting?

2007-01-31

Table 1-3.2, 1st and 2dnd bullets read: Sa 2.5 on damaged shop primer
Sa 2.5 shall be applied to any damaged area of shop primed steel. This
and welds.
Sa 2 removing at least 70% of intact shop primer,
includes damage arising from welding, thermal and mechanical cutting and any
which has not passed a pre-qualification certified by test procedures in
other form of mechanical abrasion damage during fabrication.
1.3.

2007-01-31

Table 1-3.2, 3rd bullet reads: If the complete coating system comprising
epoxy based main coating and shop primer has passed a prequalification certified be test procedures in 1.3, intact shop primer may
be retained provided the same epoxy coating system is used. The
retained shop primer shall be cleaned by sweep blasting, high pressure
water washing or equivalent method.

Provided the Marintek test report includes the same shop primer, if epoxy
coating system have an existing satisfactory Marintek test reports minimum
level B1 issued before December 8th 2006 or a documented experience of field
exposure for 5 years with a final coating condition of not less that GOOD, the
contamination on retained shop primer shall be cleaned by sweep blasting,
fresh water washing or equivalent method such as power tool cleaning.

23

table 1-3.2

zinc silicate

2007-01-31

If coating manufacture confirms (in accordance with paragraph 1.7 of appendix

1 to annex 1 without wave movement.) the compatibility of combination between
their qualified epoxy coating system and other coating manufacturers zinc
Table 1-3.2, 4th bullet reads: If a zinc silicate shop primer has passed a silicate shop primer, the contamination on retained shop primer shall be cleaned
by sweep blasting, fresh water washing or equivalent method such as power
pre-qualification test of 1.3 as part of an epoxy coating system, it may
tool cleaning.
be used in combination with other epoxy coating certified under 1.3,
provided that the compatibility has been confirmed by the manufacturer If both the shop primer and epoxy coating to be applied has been pre-qualified
by the test in accordance with paragraph 1.7 of appendix 1 to annex 1 however with different epoxy coating and shop primer to the one to be applied,
the only test needed for compatibility is the one described in paragraph 1.7,
without wave movement.
when combining the actual shop primer and epoxy coating.
All new paints will be type approved but that does not prevent use of the above
prequalification methods.

24

table 1-3.3

St3

2006-12-21

1) St3 shall be used if Sa 2.5 is impracticable in case contiguous

damages over 25 m2 or over 2% of the total area of the tank?
2) How to identify and calculate damaged area?

Printed: 2007-02-08

1) In accordance with the standard, over 25m2 or 2% is Sa 2.5

2) Consider damage to be a % of total area of the tank.
Using the method of scribing matrix on the photos and calculating area.

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IMO
PSPC

Topic

Approved

Clarification Items

Interpretations

25

table 1-3.3

damage

2007-01-31

Table 1-3.3, 1st bullet reads: Butts St 3 or better or SA 2.5 where

practicable. Small damages up to 2% of total area: St 3. Contiguous
damages over 25m2 or over 2% of the total area of the tank, Sa 2.5
should be applied.

Definition of damage is anything that in the opinion of the qualified coating

inspector will prevent the coating from functioning, such as damage reaching
the shop primer or bare steel..
The damage is considered to be in % of total
area of tank.
The method of scribing
matrix on the photos and calculating area maybe used.
The PSPC states that SA 2.5 is to be used if contiguous damages is over 25m2
or over 2% of the total area of the tank.

EG to
confirm

table 1-3.3

small damages

2007-02-10

After erection, small damages up to 2% of the tank area, St3 can be

accepted. What will be the standard if small damages area over 2%?
Will it be Sa2-1/2?

Yes

EG to
confirm

table 1-3.3 small damages

2007-02-10

In case small damage areas over 2%, can we do it this way: treat the
concentrated area with blasting to Sa2-1/2, the remaining 2% area
be power tooling to St3?

No. All small damages are to be blasted to Sa2-1/2.

EG to
confirm

table 1-3.3

2007-02-10

How to define contiguous damage?

Closely located or adjacent damages.

EG to
confirm

contiguous vs
table 1-3.3
butt

2007-02-10

Usually, the fillet welding on tank boundary watertight bulkhead is left

without coating on block stage(because not yet be leakage tested), how
Can be categorized as erection joint (butt) to be power tooling to St3.
will this area be considered ? butt or contiguous damage or small
damage?

table 1-3.5

2006-12-21

1) How to distinguish the size of dust with naked eye?

2) How many measurements for dust per block shall be required?

26

Printed: 2007-02-08

contguous
damage

dust

1) if you can see it is dust

2) to the satisfaction of the inspector

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IMO
PSPC

Topic

Approved

table 1-3.5

dust

2007-01-31

Table 1-3.5 reads: Dust quantity rating 1 for dust size class 3, 4 or If dust is visible anywhere on the block then it should be removed to the
5. Lower dust size classes to be removed if visible on the surface to
satisfaction of the inspector. The whole block shall be to the satisfaction of the
be coated without magnification.
inspector, see PSPC 3.2.
One measurement is minimum per Block.

Clarification Items

Interpretations

28

table 1-3.6

ISO

2006-12-21

1) How to extract sodium chloride only from the conductivity measure in

accordance with ISO 8502-9? Or
1) The whole conductivity value is calculated to NaCl in accordance with the
2) How to convert sodium chloride from total soluble salt content
manufacturers test instrument manual.
extracted from the surface?
3) to the satisfaction of the inspector
3) Salt measurements for block joint area and damaged area shall be
required? If yes, how many?

29

table 1-3.6

ISO

2007-01-31

Table 1-3.6 reads: Water soluble salts limit equivalent to NaCI after
blasting/ grinding 50 mg/m2 of sodium chloride

ISO standard mandated by CSR no provision in PSPC for equivalence.

whole block shall be to the satisfaction of the inspector, PSPC 3.2.

2006-12-21

1) Measurement result of dry film thickness for 1st coat to be also

included in the CTF?
2) 25 m offset to be considered or not for calibration of DFT Gauge
according to ISO 19840, even the wording calibrated using 30 m
offset had been deleted at DE 49?

1) No, the total DFT required only

2) MSC 82 has finally decided to replace the reference to ISO 19840 with that
to SSPC-PA2 which does not contain the provisions on correction values.

30

table 1-4.3

CTF , DFT

The

31

table 1-4.3

DFT

2007-01-31

All DFT measurements are to be measured and recorded. Only the final DFT
measurements need to be measured and reported for compliance with the
Table 1-4.3 reads: Dry film thickness shall be measured after each coat
PSPC by the qualified coating inspector. The Coating Technical File may
for quality control purpose and the total dry film thickness shall be
contain a summary of the DFT measurements which typically will consist of min
confirmed after completion of final coat, using appropriate thickness
/ max DFT measurements, number of measurements taken and percentage
gauges.
above and below required DFT. The final DFT compliance with the 90/10
practice is to be calculated and confirmed, see PSPC 2.8.

EG to
confirm

4.4.4

shipyard

2007-02-10

What is shipyards verified application procedure for applying the

protective coating?

Printed: 2007-02-08

Shipyard application procedure verified by coating inspectors and coating

manufacture and the Administration.

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PSPC

Topic

Approved

Clarification Items

Interpretations

32

type approval
certificate

2006-12-21

1) Who is the third party issued Type Approval Certificate or SOC?

2) Is there the terms of validity for Type approval?
3) If yes, How to do it?
4) Who and how will check the quality of paint during production of
paint?

33

inspection

2006-12-21

1) Who/how will do inspection?

2) Who will organize inspector?
3) Who will pay the inspection fee?

1) the coating inspector as agreed in 3.2

2) as agreed PSPC Section 3.2
3) as agreed PSPC Section 3.2

34

6.1.1

quality control

2006-12-21

Are the inspectors of Builder and Manufacturer for self quality control
also qualified by NACE, FROSIO, or equivalent?

only the coating inspector required to provide the reports must be qualified

1) Certificate by the Society

2) As per Society standard practice
3) As per Society standard practice
4) Paint manufacturers quality system approved by the Society.

35

6.1.1

coating inspector

2007-01-31

Coating inspector can be anyone qualified in accordance with the PSPC, prior
to 1 July 2008 the administration are not involved with the PSPC, however the
6.1.1 reads: To ensure compliance with this Standard, the following
IACS CSR invoke the PSPC so prior to 1 July 2008 verification is by IACS
shall be carried out by qualified coating inspectors certified to NACE
PR34.
Who supplies the coating inspectors is a matter for shipyard, paint
Coating Inspector Level 2, FROSIO Inspector Level III or equivalent as
manufacturer and owner to decide in accordance with paragraph 3.2 of the
verified by the Administration.
PSPC.
However, the responsibility for the inspection and quality of the
product belong to the yard.

36

6.2 PSPC

primary surface
preparation

2007-01-31

Who shall do this ?

37

6.2
PSPC
1,2

automatic

2006-12-21

1) Are periodical tests or checks necessary if shop primer and surface

yes, measure salt and remove before going into shot blasting or have shipyard
preparation is carried out by automatic plant?
procedures to check occasional readings after shot blasting.
2) How to test or check the contamination in automated process?

EG to
confirm

6.2-Block
Assembly -1

water washing

2007-02-10

38

6.2
Block
assembly
5

DFT

2006-12-21

Printed: 2007-02-08

This is inspection and shall be done by a qualified inspector for each job.

before secondary surface preparation starts, a visual inspection----------. Any oil, grease or other visible contamination to be removed. Does
that mean water washing should be done? (According to the normal
As agreed in Sect 3.2 of PSPC.
practice, only serious oil/grease contamination should be removed prior
blasting, otherwise, oil/grease contaimination will be removed by thinner
cleaning prior coating.)
Any qualified inspector can carry out DFT readings as agreed in 3.2. However
According to our investigation, more than 3 inspectors are required to
the readings will be required to be reviewed and the report signed by the
minimize the extension of building schedule for DFT measurement only.
qualified inspector as referred to in PSPC section 6.1.3

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