Risk-Based Approval
4.7 Operating a Risk-Based Approved Ship
Even if tentative risk acceptance criteria can be developed, presently available data are limited and only in special cases risk acceptance criteria can be deduced for ship systems from historical data.
A dedicated certificate to document risk-based elements on board would certainly help to convince less knowledgeable administrations and port state controls that the vessel in question is properly built and maintained.
A good example is the documentation requirement in SOLAS II-2, reg.17.4.2 stating “A copy of the documentation, as approved by the Administration, indicating that the alternative design and arrangements comply with this regulation shall be carried on board the ship.”
The current discussion at IMO related to on board documentation is referred to the goal-based standards working group, where the so called “Ship Construction File” (SCF) is discussed. Such SCF will initially be carried on board the vessel throughout the lifetime of the vessel.
4.7.2 The International Safety Management Code
The ISM documentation is another instrument. The ISM-code (IMO 2002a/2005) requires to document a safety management system and to carry onboard all docu- mentation relevant to the particular ship.
The ISM code requires the establishment of a safety management system with safety management objectives which lead to “safe practices in ship operation and a safe working environment,” and establishing “safeguards against all identified risks”
(IMO 2002a/2005).
Although there is no further explicit reference to this general requirement in the remainder of the ISM Code, risk assessment is essential for demonstrating com- pliance with most of its clauses. The ISM Code does not specify any particular approach to the management of risk, and it is for the company to choose appropriate methods.
Risk-based ships have been analyzed during the design stage and hazards as well as risk control options have been identified. This constitutes a good part of the risk identification required by the ISM code. It is likely that, for a novel ship, all aspects of the operation will be addressed during the early design stage with risk-based approaches. Thus, including risk-based elements into the ISM-code provisions is simple: the risk assessment of the design stage is the ideal input for establishing the safety management system required by the ISM code.
It also follows that a more formal guidance for identifying risks and establishing safeguards and safe practices would create a harmonized approach to set up the safety management system under the ISM code.
Following from the above, it appears that a complete documentation of all risk- based elements of a ship together with the process and criteria of acceptance should be carried onboard. In addition, a proper summary addressing the concerns of sur- veyors and port state control officers has been drafted.
4.7.3 Inspection of the Risk-Based Ship
The inspection of a risk-based ship may require special competences for class surveyors and flag state inspectors. Supported by appropriate documentation, see above, the risk-based elements of the ship will have to be understood prior to check- ing. Likely, special training related to risk assessment is also needed for the inspec- tors and surveyors.
In the event that the initial assumptions that were made during design and ap- proval are changed (the operational area, the cargo etc), then it will be necessary to revaluate the risk levels and make necessary adjustments, however it is worth being aware of the potential pitfalls in the need for periodic reassessment.
Today, SOLAS II.2, reg. 17.6, requires a reassessment and states that “re- evaluation due to change of conditions if the assumptions, and operational restric- tions that were stipulated in the alternative design and arrangements are changed, the engineering analysis shall be carried out under the changed condition and shall be approved by the Administration.”
It is expected that a reassessment will also be required if the vessel changes flag and/or class.
Inspection of a risk-based designed ship is required, as well as for traditional ships. Class survey, flag state inspection and port state control have to understand the risk-based nature of the ship. This understanding could be promoted by means of additions to existing certificates affected (quoting on the risk based feature affect- ing them).
Consideration could alternatively be given to the issuance of a dedicated certifi- cate. Proper authoritative documentation has the advantage of providing an inspec- tor with evidence of the vessel being built and maintained in a satisfactory manner.
Except from the certificate, most of the documentation requirements are already in place.
When performing PSC, time is limited. Should the PSC inspector come across a feature (such as an asymmetrical distribution of lifeboats) which he is not familiar with, an easy means to access the information on such a feature should be available.
A “PSC-file”, or excerpts from the vessel documentation to ascertain that any such feature is approved by the administration, including further relevant informa- tion could be a practical tool.
With regards to PSC-inspections, the risk model and the detailed investigations will not need to be demonstrated to the officials of the port state. Even if “all rele- vant documentation” related to the operation of the vessel will have to be on board, this is interpreted as all documentation of immediate relevance for the operation of the vessel, and technical source documents are usually not being perused by PSC- inspectors.
4.7.4 Owner’s Inspection
Like in many other industries the responsibility lies at the owner to ensure that the information kept on board is correct.
The primary goal of the Owner’s inspection is to verify and ensure the safe oper- ations of a risk-based ship relating to current shipboard conditions, and that the ship will pass Flag, Class, Port-state and other inspections.
Owner’s inspections may consist of Management/Superintendent visit to the ship, or take place during annual internal company shipboard audits.
Management should verify that the initial assumptions made during design and approval process have not changed (i.e. the route, the ship arrangement, capacity, non-statutory required outfitting, etc) as it will be necessary to re-evaluate the risk levels and make any adjustments required to reflect this change. Levels of spares, consumables and outfitting should also be checked. Any changes compromising risk related design features and operational procedures should be identified, and necessary corrective actions addressed.
The inspection should include a review of onboard documentation, including the Ship Construction File (SCF) to ensure that it is current and being kept up-to-date.
Additionally, management should verify that a complete set of risk documentation is carried onboard detailing all risk-based elements of the ship, the process and criteria of acceptance, and that this information is included in a summary to address any concerns of attending surveyors and port state control officers.
Management must also confirm that the Officers and Crew onboard are aware of the risk based design and operational features the ship which should be detailed in the Safety Management System, and verify that they have undergone appropriate training to ensure that these features are not compromised.