Software to prove compliance

Malcolm Latarche
Malcolm Latarche

11 December 2017


As things stand, the only software specifically mentioned and required in SOLAS regulations are strength and stability software aimed at ensuring crews can accurately assess if ships are safe under all but the most extreme circumstances. Some ships are also required to carry loading instruments which in essence are computers programmed with specialist software.

In addition, there are now requirements for a range of instruments and systems such as ECDIS which will have embedded software that must be capable of performing the tasks demanded of the system.

Strength, stability, stowage and effect of changes

Strength and stability and loading software are probably produced by more software suppliers than any other form of application. And disproving the argument that shipping is slow to adopt new technology, some of the makers of loading and stowage software still strong in the market produced their first offerings in the early 1970s.

In addition there are several commercial software offerings that have an element of ensuring compliance with a wide range of regulations. In some cases, the particular software included may be part of a more extensive offering from the provider.

At MEPC 66 in April 2014, new rules requiring tankers and gas carriers to carry stability instruments were adopted. The rules required them to be mandatory on new vessels built after 1 January 2016 and fitted on board existing tankers built before that date at the first renewal survey or by 1 January 2021 whichever is earlier. Now that the January 2016 deadline has passed, the rollout programme is underway and should be completed by the later date.

By 2006, the IMO had developed guidelines for the performance standards for stability instruments which were release in January 2007 in MSC.1/Circ.1229. The following year, the IMO produced its International code on intact stability known more usually as The IS Code 2008 in which a whole chapter (Chapter 4) deals with stability instruments.

The 2008 Code was an update to the older 1993 Intact Stability Code taking into account new technology and experience. Through amendments to the SOLAS Convention and to the 1988 Load Lines Protocol, the 2008 IS Code was made mandatory and entered into force on 1 July 2010. The code provides, in a single document, both mandatory requirements and recommended provisions relating to intact stability. Under the rules governing them, stability instruments must always be programmed according to the ship’s Stability Booklet.

Intact stability and loading are clearly closely connected topics and the various software offerings will be used to carry out draught, trim, list, longitudinal strength, intact and damaged stability calculations. Most permit some form of virtual loading where constants and ballast, fresh water, fuel and lubricant are entered along with cargo details prior to loading so as to determine if the planned cargo intake and stow are safe. The software can generally be used to produce documents and information such as draft survey report, loading report, hogging/sagging calculations and loading/unloading optimisation.

Most software of this type will be developed initially from versions based on relatively simple ship types such as tankers and bulkers but more complex calculations and in greater variety are needed for vessels that are used or intended for carrying deck cargo, abnormal loads and where conditions can change regularly such as liner vessels where cargo is constantly changing at each port of call. Some will even calculate stability during cranage operations where outreach and hook load can significantly affect stability.

Stability and loading software need to be maintained to reflect changes in the ship itself. The official report into the loss of the El Faro in 2015 highlighted that alterations to the ship had not been taken into account and the ship was still using original software and stability booklet. This was considered a contributing factor in the loss of the ship.

Over the next five years or so, many ships will need to undergo modifications related to installing ballast water treatment systems or scrubbers as well as possible conversion to run on alternative fuels. Class societies should make the necessary changes but some care should also be taken by operators and crew to ensure that software remains valid.

ISM and ISPS compliance

Many software products are promoted as being of assistance in meeting the requirements of regulations imposed by international and national regimes. Compliance with ISM and ISPS codes is mentioned as being a feature of many products but often the compliance is a secondary function of a feature such as maintenance and repair or document control. Since much of the policing of the codes comes down to a matter of documentary evidence, software that incorporates document management can also be extremely useful.

Crewing software is another that can be used to demonstrate compliance as recording hours for payroll purposes can also have a function of proving the requirements of MLC have been met. Such software can also ensure valid certification for seafarers and contain a record of training, drills and experience. There are however, some products that have been developed with particular aspects of regulation as a driving factor. Class societies are particularly strong in this area which is perhaps not surprising considering their role in certifying and auditing safety and security systems.

Dedicated ISM software will be able to provide a ‘solution in a box’ but because the individual ship operating company’s system has to be audited by an appropriate body before certification, the success in gaining approval will depend much more on the company staff than the product itself. Some systems are more rigid than others and do not have the flexibility needed for a rapidly changing organisation. They do however provide a good basic idea of the requirements for certification that a new organisation may not fully understand.

As well as providing a structure for the establishment, auditing and compliancy of a safety management system, the best of the dedicated software products will also include procedure manuals, checklists and other documents although the purchasers will need to spend a large amount of time adapting them to the specific requirements of individual vessels in the fleet.

MRV and other compliance

With first the EU and soon the IMO bringing in requirements for monitoring, verification and reporting of fuel use and emissions data it must be expected that many products will soon be devised to cover this aspect of ship operation. The IMO requirements are not yet fully determined but the EU requirements came into effect in August 2017 and cover all vessels flagged in EU member states and all other ships calling to EU ports.

The EU rules are contained in Regulation (EU) N° 2015/757 and require ships to have monitoring and reporting methodology for gathering data that will later need to be verified by a third party. The emissions will be calculated on the basis of work done which means that cargo volumes need to be part of the calculations.

One of the many companies offering MRV software is ABB which is providing it as an add on to its Octopus software suite. The ABB MRV system collects data from onboard sensors on ships fuel consumption, the bunkering procedure and carbon dioxide emissions on a per-voyage basis. In addition, data such as the total amount or weight of the carried cargo, total transport work, aggregated CO₂ emissions, expected distance at sea and start and end of the voyage can be entered into the system. All this information is then further processed within the cloud to create an annual emission report as required by the MRV regulation.

ABB is by no means the only organisation offering MRV software and the list is growing.

Interschalt has added an MRV to its Bluetracker performance monitoring tool and Kongsberg, Danaos and many more are also adding products. In addition, there are organisations such as StormGeo that like ABB will manage the whole process although they will have to sub-contract the verification aspect in order to satisfy the regulations.

Most class societies also produce MRV software and many can also fulfil the verifier role as well. Because the EU rules require details of cargo quantities as part of the reporting, the potential to connect other software such as stability or even customs reporting should be investigated so as to reduce the need to duplicate inputs.

Most forms of environmental technology on board ships from oil water separators through to ballast water treatment and fuel switching systems are either obliged to have or are optionally fitted with some form of data logging that can be used to prove that environmental regulations have been complied with.

At least one software maker has a product that has been designed around this aspect of regulation. Teomaki Environment enables ship managers and owners to collect waste information, calculate emission levels and attain waste minimisation goals through innovative management reporting. It is based on waste management requirements defined in MARPOL Annexes I-VI, EU- and US requirements. This includes electronic prearrival notification to ports for all waste and ballast water, oil record books, garbage log book, bunker and fuel samples, NOx & SOx reporting. There are already a number of other products designed to be electronic log books now that this form of recording is permitted on board ships.

Keeping current

Staying up to date with regulations is a demanding task and for large ship operating organisations, software such as the IMO Vega database allows for reasonably easy access to all the rules and regulations applicable to a particular ship based upon size, year of build, ship type and other criteria. It is a very expensive piece of software and outside the reach of smaller operators.

Classification societies frequently produce their own versions of rules software in addition to the programs developed for advising of society rules for ship construction. These will highlight impending new regulation often covering rules from bodies other than the IMO. As an example, Lloyd’s Register’s Rulefinder is an interactive PC-based software system that gives searchable access to an extensive library of consolidated versions of the latest requirements from both Lloyd’s Register and the IMO.

Updated twice yearly, Rulefinder includes consolidated versions of the latest Lloyd’s Register classification requirements, IACS Common Structural Rules and Statutory requirements, including ten international conventions and protocols such as SOLAS and MARPOL and over 20 international codes, including the ISPS, ISM, IBC, IGC and LSA codes. It also covers IMO Assembly, MSC and MEPC resolutions and circulars and ILO conventions.

To complement this LR has in conjunction with the UK P&I Club released several pocket checklist mobile apps for iOS and Android to help owners and operators comply with international convention requirements and reduce the risk of port state controls detentions.
LR has also established a joint venture with ABS. These types of programs are not unique and many other versions from other organisations are available. Apps intended for use on mobile devices rather than installed on a network are becoming increasingly popular. However, where they are intended to aid or prove compliance with regulations some care should be exercised in ensuring they are accurate and current if they are being commercially produced.