Proactive approach for safety

(Posted on 29/04/19)

Safety is what the regulatory work of IMO and classification societies is all about. A set of draft guidelines up for final voting at MSC 101 in June 2019 addresses a number of important concerns and reflects a new regulation philosophy that promises more flexibility.

While in the past, IMO and other regulatory bodies typically issued regulations in response to incidents, the trend today is to be proactive while pursuing a goal-based regulatory approach that defines what should be achieved, rather than how to achieve it. This provides flexibility for designers to reap the full benefits of advanced technology. A number of IMO draft Guidelines, which are subject to approval by MSC 101 in June 2019 and will likely enter into force on 1 January 2024, take this approach:

To reduce damage, injuries and fatalities resulting from mechanical failure of lifting appliances on board ships, IMO is developing appropriate mandatory requirements for inclusion in SOLAS. The draft requirements are prescriptive and refer to class standards for the design, construction and testing and to industry standards for operational testing, inspection, operation and maintenance of lifting appliances with capacity above a safe working load of 1,000 kg. The testing and inspection requirements will probably be retroactive.  
Mooring operations involve equally hazardous activities. IMO has therefore reviewed and amended the relevant SOLAS requirements and drafted new and revised guidelines for new ships; the inspection and maintenance requirements for mooring equipment, including lines, are expected to be applied retroactively.

The Polar Code, in force since 2017, was just the beginning: IMO has developed recommendations for navigation and communication equipment as well as for life-saving appliances for ships operating in polar waters. The new Guidance document for navigation and communication equipment addresses environmental factors such as polar temperatures, mechanical shock testing to withstand ice breaking situations, ice accretion and battery performances in cold temperatures. The Guidelines for life-saving appliances and arrangements (LSA) outline recommendations for mitigating hazards based on assessment criteria such as maximum expected time of rescue, operation at polar service temperatures, operation in ice, ice accretion of life-saving appliances and arrangements, the effect of operation in high latitudes, operation in extended periods of darkness and the possibility of abandonment into ice or land. It should be noted that the recommendations to carry additional clothing, survival equipment and water may affect the capacity of the survival craft. However, the actual capacity adjustment, if any, would be dependent on factors such as insulation and heating of the LSA.

The IMO draft amendments to the guidelines on alternative design and arrangements for SOLAS Chapter II-1 and III (MSC.1/Circ.1212) will allow life-saving appliances and arrangements to deviate from prescriptive requirements, provided an equivalent level of safety is achieved and the intent of the SOLAS requirements are met. IMO defines goals, functional requirements and expected performance criteria providing flexibility in the design of alternative and innovative life-saving appliances.

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