Regulatory Framework
3.4 Development of Risk Assessment and FSA
3.4.4 FSA for Bulk Carriers
3.4.4.4 The Risk Control Options and the Decisions
The first and most important risk control option related to the side shell failures.
These failures had been demonstrated by all studies to be a major contributor to bulk carrier casualties. The most comprehensive risk control option considered was to require a double side skin. The quantification of costs and benefits were carried out by IACS (2001). The key data, from IACS, are given in Table 3.1. The decision parameters are now defined in the FSA guidelines as Gross and Net Cost of Averting a Fatality, Eqs. (3.1) and (3.2):
GCAF=ΔCost/ΔPLL (3.1)
NCAF= (ΔCost−ΔBenefit)/ΔPLL (3.2)
Table 3.1 Double side skin for new bulk carriers (IACS 2001)
Cost $ Risk
reduction
GCAF $ million
NCAF $ million Double Side Skin,
new bulk carriers
131,000–182,000 41% 0.8–1.1 0.1–0.4
PLL is the Potential Loss of Life, ΔCost is the additional cost of the RCO, andΔBenefit is the economic benefits resulting from implementing the risk control option.
The clear recommendation for double side skin, given an acceptance criterion of
$3 million for CAF was later confirmed by UK (2002a). This study claimed many commercial benefits of double side skin in addition to the safety benefits which resulted in negative NCAF values. Although the IACS study was conclusive, IACS did wait for MSC76 to take the decision, and promised to develop the necessary IACS Unified Requirements (UR) for double side skin bulk carriers (IMO 2002a).
IACS could have decided to mandate double side skin for bulk carriers classified by the IACS member societies, but finally decided that such decisions should be made at IMO level.
IACS (2002) and UK (2002a) both had included coating in their assessment, and both studies produced negative NCAFs. IACS summarized the situation in the work- ing group by stating that the analysis confirmed that it is always in the owner’s best interest to properly coat his ships and to maintain coating. However, as explained by INTERCARGO, coating of cargo holds can not be easily be regulated, as appro- priate coating depends on the cargo. However, MSC noted that SOLAS regulation II-1/3-2 made the coating of dedicated ballast tanks mandatory for oil tankers and bulk carriers but extending that requirement to cargo holds could introduce seri- ous problems, bearing in mind that cargos can react distinctly to different coatings.
Therefore, MSC agreed that new ships should be required to have their dedicated seawater ballast tanks and void spaces within double hull spaces coated according to current SOLAS requirements for ballast spaces. The MSC instructed the Design and Equipment (DE) Sub-Committee to develop international performance stan- dards for coatings. With respect to existing ships, the Committee acknowledged that at present there was sufficient control over the condition of coatings through the enhanced survey programme and agreed that this risk control option should also be addressed by class and the ship owner.
Control standards of steel repair carried out at terminals, was proposed by UK (2002a), and presented with negative NCAFs, but very small risk reducing effects, actually an indication that this was mainly of commercial interest. The discussion disclosed that the problem could be associated with repair carried out without noti- fying the class society. The discussion was inspired by a detailed casualty investiga- tion presented by Marshall Island (2002), where this problem was clearly identified.
MSC agreed to request the DE Sub-Committee to prepare a draft MSC circular to remind ship owners and operators of their obligations and responsibilities under SO- LAS regulation II-1/3-1, concerning the provision that ships shall be maintained in accordance with the structural requirements of recognized classification societies, and other related management obligations under the ISM Code. It is clear from the discussion that the FSA was not used as a significant contributor to this decision.
IACS did propose the fitting of a forecastle and presented this as marginally cost effective for new building; see Table 11 of IACS (2001) and Table 3.2.
MSC noted the information provided by IACS on the on-going development of Unified Requirement S28, requiring the fitting of a forecastle on bulk carriers
Table 3.2 Forecastle for new bulk carriers
Cost $ Risk reduction NCAF $ million GCAF $ million
Capesize 54,000–102,000 0.0211 2.2–4.5 2.6–4.8
Panamax 29,100–54,000 0.0493 0.2–0.7 0.6–1.1
Handymax 15,600–51,000 0.0933 −4.9 to−2.0 0.2–0.3
contracted for construction on or after 1 January 2004 with the purpose of protecting foredeck fittings against green sea loads and minimizing the impact of such loads on fore hatch covers. The Committee also noted that, while the fitting of a forecastle as such was not an IMO requirement, draft Load Lines Protocol regulation 39 – ‘Mini- mum bow height and reserve buoyancy’ would require additional reserve buoyancy forward consistent with the provision of some sheer and/or a forecastle. This demon- strated the advantage of use of common and agreed risk acceptance criteria by IMO and IACS.
The MSC recognized that replacing hatch covers in existing ships would not be cost-effective, but agreed that more attention should be paid to hatch cover securing mechanisms and the issue of horizontal loads, especially with regard to maintenance and frequency of inspection. The Committee agreed that ship owners and operators should be made aware of the need to implement regular maintenance and inspec- tion procedures for closing mechanisms in existing bulk carriers in order to ensure proper operation and efficiency at all times, and instructed the DE Sub-Committee to develop standards for hatch cover securing arrangements for existing ships. The decision of not strengthening hatch covers on existing ships is not well documented.
It may be noted that IACS (2001), in Table 12, lists this risk control option as cost effective. UK (2002b) also lists this as cost-effective. The reason for not implement- ing this risk control option may be found in Japan (2002c), Table 3.1. This table shows that UK classified too many accidents as hatch cover related. A scrutiny of the data, which was made possible by the exchange of information between UK and Japan, resulted in an agreement to reduce the frequency of hatch cover failures in the models. This resulted in the conclusion that this risk control option was no longer cost effective. This demonstrates the lack of consistency in the approach followed at IMO. When such changes in assumptions are made, this should be recorded.
Retrospectively, it is practically impossible to identify from the documents what considerations were finally made.5
Hold, ballast and dry space water level detectors were already scheduled for im- plementation in the new SOLAS regulation XII/12, both for new and existing bulk carriers. Both Norway and ICFTU (2001) and IACS (2001) demonstrated this risk control option to be cost effective, using very different risk models. After the de- cision was made, also UK (2002a) confirmed this. Close comparisons of the FSA studies show that all risk models are different – still giving the same result. Earlier, at IMO, many delegates had expressed scepticism on FSA by referring to undoc-
5 The author’s knowledge is as a member of the International Steering Board of the UK/International study.
umented experience that an FSA can produce ‘any answer’. The case of the water level detectors is clear evidence of the opposite.
3.4.4.5 Note on the Decision-Making Related to Double Side Skin