Goal-based standards face tough scrutiny

Paul Gunton
Paul Gunton

20 December 2018

Goal-based standards (GBS) for ship construction have a difficult history but have now become established as the way that IMO and international classifications societies draft their rules. During this month’s 100th meeting of IMO’s Maritime Safety Committee (MSC 100) they came under particular scrutiny, as I detail below, but when they were first mooted and subsequently developed, there was a certain amount of distrust between IMO and the classification community.

There is an excellent ‘focus paper’ on IMO’s website that was written in 2015 and sets out their history, so I will not repeat that here, except to draw attention to the opening paragraph of those notes. It recalls that, back in November 2002, Bahamas and Greece suggested at that year’s meeting of the IMO Council that “IMO should play a larger role in determining the standards to which new ships are built.”

Imo Document

I remember the proposal coming as a shock to many classification society executives who, until then, had seen their organisations as IMO’s go-to experts on ship construction. They certainly did play that role but, by an unhappy coincidence, on 13 November 2002 – just days before the council met – the Greek-flagged and ABS-classed tanker Prestige had sunk off Spain and memories were still vivid of the RINA-classed, Maltese-flagged, tanker Erika, which had sunk in December 1999. In hindsight, it was inevitable that IMO would take a fresh look at classification with an emphasis on safety, with class societies becoming answerable to auditors appointed by IMO.

Out of that came a raft of goal-based standards and unified rules. It also put an end to suggestions that had surfaced from time to time since the 1980s of a split within IACS that would see the then three largest societies break away. My view at the time was that this would never happen, simply because IACS had a seat at IMO: would any individual society risk becoming an IMO outsider by leaving its own industry body?

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Since then, the bond between the two organisations has become even firmer: in December 2016, the two organisations signed a memorandum of agreement “to facilitate even closer working on the organisations’ shared goals and objectives.” In a statement, IACS’ then chairman Dr Sun of China Classification Society, described the agreement as “a historic moment for IACS [that] reflects our ongoing commitment to the work of the IMO.”

That same statement also said that, in May that year, all IACS members’ class rules had been confirmed to be in compliance with GBS. “IACS continues to work intensively on this issue … to use the experience gained from the initial verifications to expedite future maintenance audits,” the statement said.

I was reminded of these things by IMO’s summary of MSC 100 during which the first of those maintenance audits was on the agenda. It was clear that those audits had not been simply rubber-stamp exercises.

In all, 12 class societies had gone through a ‘maintenance verification’ process and all but one had “demonstrated continued conformance with the standards”, IMO’s notes said. The exception was DNV GL, “a classification society formed as the result of a merger between DNV and GL, which would be subject to a re-verification audit of its rules,” the notes went on.

A spokesman for DNV GL described the situation as “rather technical” and assured me that it does not mean that any DNV GL-classed ships are non-compliant in any way. He drew my attention to a section in a submission to MSC 100 (MSC 100/6/3; see below) in which the audit team “expressed the view that ships contracted by DNV GL after the successful initial verification, subject to the agreement of the committee, should be deemed to meet the goal-based standards pending consideration of the report of the audit on the re-verification of the combined DNV GL ship construction rules by the Committee. Another paragraph in that submission “makes fairly clear that this is an administrative, rather than a substantive, matter,” he said.

I also contacted other IACS members and the IACS secretariat and any feedback will be incorporated in due course.

The DNV GL merger had been announced in December 2012 and became effective in September 2013 – long before the 2016 initial GBS compliance confirmations – but IMO’s audit team decided that, because “a large number of rule changes had been carried out following the merger of DNV and GL … the information provided on the rule changes since DNV GL’s initial verification was insufficient to conduct the maintenance audit.” As a result, DNV GL will seek re-verification later.

That information from the audit team is contained in one of the key submissions on this topic, MSC 100/6/5, which is the final report of the GBS maintenance of verification audits. It is dated 24 August but, along with most other submissions to MSC 100, it has only been made publically available since the meeting’s conclusion.

Its full text can be read via the IMO DOCS area of IMO’s website. It includes more detail about DNV GL’s situation, which is dealt with fully in submission, MSC 100/6/3, mentioned above. You will need to register to use the public area of that resource if you have not previously visited.

The thoroughness with which the audit team scrutinised the documents that the various class societies and IACS submitted is impressive. It found one non-conformity in China Class Society’s rules and two non-conformities, along with four ‘common observations’, in IACS’ common structural rules.

In its response, submitted in October, IACS presented corrective action plans for the non-conformities and improvement plans for the ‘common observations’ which related to confusing details in IACS’ common structural rules. IACS committed to completing its corrective actions by the end of 2019. More details are available in IACS’ submission MSC 100/6/10, pictured above.

IACS’ accredited representative to IMO, Paul Sadler, told me in late December that the organisation was “getting on with work to address both non-conformities” but the auditor’s comments did not mean that “the actual technical rules have been found to be deficient,” he said. So he does not expect that any rule changes will be needed.

Instead, one of the non-conformities will be addressed by “writing a procedure about how we go about recording in-service feedback and the other [requires] more information in a technical background document [about] how rules are developed.” In summary, he said, the auditors “just wanted a bit more explanation as to the background to the rules.”

He was impressed at the thorough approach the auditors had taken and pointed out the difficulty of finding experts able to tackle the task that were outside of the ship classification community. “There aren’t many people in the world who can do this sort of work,” he said, but IMO has managed to assemble a pool of talent that includes experts in structural analysis and structural regulatory requirements and that “have certainly done a very thorough job,” he said.

Based on the experience gained from conducting this first review, MSC 100 decided that the procedural requirements guiding the audits should be updated and it adopted revised guidelines (MSC 100/6) for verifying conformity with GBS ship construction standards. They will come into effect on 1 January 2020, one year after their adoption.

These new guidelines “are an improvement, not a radical change, Mr Sadler said. “As you go through the process you realise that the guidelines you wrote before the process started could be improved. And that’s what we’ve done.”

The committee also approved interim guidelines for development and application of the IMO goal-based standards safety level approach (MSC 100/6/2).

If I seem to be making a great deal out of a minor technicality, that is because I do not think goal-based standards and getting them right are minor technicalities. As shipping becomes more autonomous and as new ship types emerge, standards based around outcomes, expectations and safety will inevitably be vital, so making sure those standards are consistent and satisfactory is also vital.

Like Paul Sadler, I applaud IMO’s audit team, which was led by Prof Cesare Rizzo, associate professor at the University of Genoa, Italy, supported by Robin Gehling, principal marine surveyor at the Australian Maritime Safety Authority, and Hossein Abbas Nejad, deputy director general of maritime affairs at the Port & Maritime Organization of Iran. They did an astonishing job.