Risk-Based Approval
4.1 Introduction
4.1.3 Risk-Based Approval Process – The Future Procedure
The risk-based approval process is different from the conventional, as risk-based ship design adds another set of criteria to the final selection of the design, also aim- ing to achieve required safety standards cost-effectively (safety of life and protection of property and environment). An optimum design solution that includes safety is possible only through risk-based design, because safety is treated as a design objec- tive concurrently with the commercial objectives (Fig. 4.5).
Fig. 4.5 Approval flow diagram for the risk-based design
As mentioned previously, one of the chapters within SOLAS that has driven the development of the risk-based approval concept to a usable extent is the chapter on fire protection, SOLAS Chapter II-2, regulation 17.
Currently, SOLAS has two accepted methods for approving designs and arrange- ments for fire safety.
1. The common prescriptive regulation set out in the parts B, C, D, E or G referring to specific topics such as prevention of fire and explosion, suppression of fire, escape, operational requirements and special requirements.
2. The new part F regulation 17, referring to alternative design and arrangements, applying to a specific fire safety system, design or arrangement for which the approval of an alternative design deviating from the prescriptive requirements of SOLAS Chapter II-2 is sought.
Today both methods are equally acceptable by the administrations. But due to the novelty of regulation 17, this procedure has only been used in few cases. Hence only few Administrations have developed standard rules and procedures for this risk- based approach. As the use of alternative designs has been dominated until now by cruise ship cases, and due to the fact that the dominating Flag states delegate this work to recognised organisations, there may be more experience in some major Classification societies (e.g. DNV, GL etc.)
As with the present approval process, compliance with class rules, international and flag state regulation is part of the foundation or basis for a design.
By evaluating compliance step by step, any rules challenged can be identified, thence following a path similar to what is described in the paragraphs on equivalence in the present approval process.
However more risk-based requirements are being adopted within SOLAS, even though still not in force:
The new Regulations II-1/55 and III/38 that will enter into force on 1 July 2010. This requirement will give future steps for approval of alternative design.
MSC/Circ.1212 (IMO 2006) that outlines a methodology for the development of the required engineering analysis will support these two regulations.
Resolutions 239(83) and 240(83) which will enter into force on 1 July 2009 de- fine the new format of Ship Safety Certificate with the purpose of stating the risk- based nature of a ship.
Finally the Goal Based Standards being discussed at the IMO introduce the Ship Construction File (SCF) concept that may become independent mandatory require- ments under SOLAS Chapter II-1.
The SCF, which contains drawings and information on materials/construction of hull, machinery and equipment, remains with the ship through changes of owner- ship, classification and flag.
Within SAFEDOR thoughts and considerations on how to develop a new ap- proval procedure have been developed. The purpose is to define and describe a high-level process for novel and risk-based ship types providing a sound and har- monized approval process to be used by the Approval Authority in order to ensure that novel and risk-based designs are handled safely and efficiently. Furthermore the work serves to make the approval process more transparent and logic to understand which should ease the process for clients seeking approval.
The following figure illustrates the novel approval process (Fig. 4.6).
The task pending with the Administration throughout the transitional period, largely consist of verifying the quality of the documentation submitted.
Fig. 4.6 Novel approval process developed in SAFEDOR (Wentworth et al. 2005)
As such, the Administration has a supervisory function, in terms of ensuring the soundness of the sources of information applied, whether approvable methodology is utilised, monitoring for proper generation of acceptance criteria and ensuring that the group of experts is indeed covering all relevant fields of knowledge, at least to the satisfaction of any minimum criteria set out in advance of the actual approval process.
Rendering explicit the safety levels of the existing prescriptive regulation is a task which is presently being addressed. This may eventually pave the way for com- parison with new and untested principles, along with predictions by means of proba- bilistic tools e.g. as described in various deliverables within SAFEDOR concerning the risk-based design.
When new design projects bearing alternative features are submitted for ap- proval, the Administration may utilise a number of tools already provided for to ensure a sound approval basis. One of these is the Formal Safety Assessment (FSA) procedure.
In the IMO guidelines for FSA, a number of “tools” to eventually achieve a concise evaluation of inherent risk and safety levels in any given project, design, operation or regulation are described, the result eventually being a “Safety study” (in principle equivalent to the Offshore sector “safety case” documenting all reviews, analyses and evaluations that may have taken place for the particular project). In most cases the FSA is a safety case for the Rules and Regulations.
The methodology, as per below (concisely described in the circular) may to some extent be applied at any given approval process level, as it contains core elements of the considerations which would in any case have to be investigated by the Authority to render any alternative approval process safety-wise acceptable (Fig. 4.7).
In this manner, evidently – provided of course, the safety study is devised with care and all due regard to sound scientific principle – the regulating body has a sound
Fig. 4.7 FSA process excerpt from MSC/Circ.1023 Annex (IMO 2002b)
tool to evaluate compliance by comparing risk and safety, querying for mitigating measures (Risk Control Options) where any risk may not have been reduced to what is reasonably possible at the design stage.
From the approval in principle, through the safety assessment in its integrity to the notification of compliance in principle, it should at all times be verifiable whether the sources of data used are sound, reliable and unbiased. To facilitate the process of approval, it may be relevant for the Administration to develop guidelines of its own on acceptable data sources, approval and audit methodology, accepted industry standards (- or minimum standards) as well as paving the way for database material on alternative approval cases, which might, if relevant, be shared selectively within the Community to build common ground.