goal based standards: a new theoretical safety approach

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Goal based Standards: A new theoretical safety approach Bachelor’s Final Degree Project A breakthrough perspective on the ship construction standards and the new business opportunities that will be generated in the maritime industry Candidate: Ferran Ministral Rosa Supervised by: Dr. Jaime Rodrigo de Larrucea Bachelor’s Degree in Marine Technologies (Marine Engineering) Barcelona, May 2018 Department of Nautical Sciences and Engineering

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Goal based Standards: A new theoretical

safety approach

Bachelor’s Final Degree Project

A breakthrough perspective on the ship construction standardsand the new business opportunities that will be generated in

the maritime industry

Candidate:

Ferran Ministral Rosa

Supervised by:

Dr. Jaime Rodrigo de Larrucea

Bachelor’s Degree in Marine Technologies (Marine Engineering)

Barcelona, May 2018

Department of Nautical Sciences and Engineering

i

AcknowledgmentsI will start thanking all those people who surrounded me and have seen me grow, not

only throughout the attainment of this project but also during my life, regardless of

whether they supported me or not, as they have made me who I am.

Notably, I would like to express my most sincere and deeply gratitude to Dr. Jaime

Rodrigo de Larrucea for striving to accomplish this paper and for guiding and advising

me. Likewise, I consider myself fortunate for having been able to enjoy his wisdom

and his amusing talks.

I will never stop thanking my whole family for their endless love for me; To my

parents, who pushed me to keep going in good and bad times. They have always been

my support and they provided me with their advice when necessary. To my father

who, since I was a child, I have utterly admired him for who he is, for his incomparable

intelligence and sense of humor; To my mother for her determination, fortitude,

patience and endless efforts to bring me up against all odds. I still cannot believe how

powerful she is. Also, to my sister Meritxell, for her good mood and patience to cheer

me, follow and review my project. The kindest woman I’ve ever met. I could not ask

for a better family.

Furthermore, to my friends and specially Marina, who bring energy to my life and

bring out the best of me, and always encourage me to be even better, not just

professionally but personally.

I hope someday to be able to compensate them for all they have provided. Thank you

all for believing in me.

Goal based Standards – A new theoretical safety approach

ii

iii

AbstractThis paper conducts a complete study of the new theoretical safety approach for the

new ship construction standards that has recently appeared, the so-called Goal-based

Standards (GBS). The GBS are high-level standards and procedures that can be

attained putting forward certain rules and regulations for ships. Being a breakthrough

perspective on the ship construction standards and the new business opportunities, it

has changed the mode of standards development, thus, changing completely the

maritime industry.

The development and implementation of the GBS have been given high importance

by the International Maritime Organization and its Maritime Safety Committee. The

objectives of this paper are to gain knowledge in regards the GBS’s from its inception,

throughout their development and recent implementation, as well as, to identify the

adaptation of the maritime industry stakeholders to these regulatory changes.

Concept, inception, history and current development of GBSs in the maritime world is

firstly presented, followed by an outline of the possible relevant future work, which is

presented in the frame of the five-tier structure of constituting the backbone of the

GBS system. A final overview will set strong basis for its further analysis.

A comparison between the Formal Safety Assessment and the Goal Based Standard

system is discussed. Firstly, setting the basis of the FSA, and afterwards comparing

and relating both systems.

Current alternatives regarding ship construction standards based on risk-based

assessment are presented taking into account the limitation of the GBS framework

previously assessed. Recommendations are elaborated to facilitate their

development.

The present problems in the GBS implementation are analyzed considering a few

controversial aspects for instance, economic funds and workforce. Then,

recommendations are suggested based on the analysis carried out.

Finally, a holistic conclusion about the current GBS system is drawn.

Recommendations are summarized to form a systematic scheme of future work on

Goal based Standards – A new theoretical safety approach

iv

GBS to progress towards a GBS generalization considering the needs and viability of

the furtherance growth.

v

Goal based Standards – A new theoretical safety approach

vi

Table of contentsAcknowledgments......................................................................................................... i

Abstract....................................................................................................................... iii

Table of contents......................................................................................................... vi

Data tables ................................................................................................................... x

Illustrations.................................................................................................................. xi

Key words.................................................................................................................. xiii

Abbreviations ............................................................................................................ xiv

Introduction............................................................................................................... xvi

Chapter 1. Goals Based Standards (GBS).................................................................... 18

1.1. Concept........................................................................................................ 18

1.2. Inception and history.................................................................................... 20

1.2.1. SOLAS Chapter II-1 amends .................................................................. 22

1.2.2. Guidelines for the Verification of Conformity with GBS & Guidelines for

the Information to be included in a Ship Construction File (SCF)......................... 23

1.2.3. Generic guidelines for developing Goal-based standards...................... 24

1.3. GBS basic principles ..................................................................................... 35

1.4. GBS development methodology .................................................................. 35

1.5. The classification societies (CLASS) ..............................................................37

1.5.1. Classification ......................................................................................... 39

1.5.2. Inspections ............................................................................................ 39

1.5.3. Classification society responsibilities .................................................... 40

1.5.4. IACS ...................................................................................................... 40

1.5.5. Other associations.................................................................................49

1.6. Current situation ..........................................................................................49

vii

1.6.1. Current situation in Spain .......................................................................... 50

1.7. Verification conformity of the GBS............................................................... 51

1.7.1. GBS auditors ......................................................................................... 53

1.7.2. IACS plan for compliance with GBS....................................................... 53

1.7.3. Classification Societies to the verification regime ................................. 55

1.7.4. Controversial issues in the verification of conformity ............................ 56

1.8. Ship construction file (SCF) .......................................................................... 61

1.8.1. Scope of its information ........................................................................ 61

1.8.2. Availability and storage.........................................................................62

Chapter 2. Risk vs Goals (FSA/GBS) ............................................................................64

2.1. FSA...............................................................................................................64

2.1.1. Step 1: HAZID........................................................................................ 65

2.1.2. Step 2: Risk analysis .............................................................................. 67

2.1.3. Step 3: RCO’s (Risk Control Options)..................................................... 67

2.1.4. Step 4: Cost-benefit assessment ...........................................................68

2.1.5. Step 5: Recommendations .................................................................... 70

2.2. Comparison between GBS & FSA ..................................................................71

2.2.1. ALARP Principle .................................................................................... 75

2.3. Relation between GBS-SLA and FSA............................................................ 76

Chapter 3. Alternative procedures on the current Safety Regulations ........................ 79

3.1. SOLAS Chapter II-2 ...................................................................................... 81

3.2. Application of the alternative options .......................................................... 82

3.3. The SAFEDOR project .................................................................................. 84

Chapter 4. Implementation/application...................................................................... 88

Goal based Standards – A new theoretical safety approach

viii

4.1. Goals (Tier I) ................................................................................................. 91

4.2. Functional requirements (Tier II) ..................................................................92

4.2.1. Design ................................................................................................... 93

4.2.2. Construction..........................................................................................96

4.2.3. In-service considerations.......................................................................96

4.2.4. Recycling considerations.......................................................................96

4.3. Verification of compliance (Tier III)............................................................... 97

4.4. Technical procedures and guidelines, classification rules and industry

standards (Tier IV)...................................................................................................99

4.5. Codes of practice and safety and quality systems for shipbuilding, ship

operation, maintenance, training, manning, etc. (Tier V) ......................................99

4.6. Monitoring ...................................................................................................99

4.7. Specific application .................................................................................... 100

4.7.1. Safety of large passenger ships ........................................................... 101

Chapter 5. Other applications................................................................................... 105

5.1. Safety Level Approach (SLA)...................................................................... 105

Chapter 6. Future of GBS system...............................................................................107

6.1. Application of the safety level approach to the GBS system ...................... 108

6.1.1. The safety knob................................................................................... 108

6.1.2. Further work in SLA-GBS .................................................................... 109

6.2. Generalization of the GBS system. ..............................................................113

6.2.1. Analysis on the process of GBS generalization .................................... 114

6.2.2. Practical recommendations on the GBS generalization implementation

119

6.3. Further ways of GBS development............................................................. 120

ix

6.3.1. Vessels for the future .......................................................................... 120

Chapter 7. Conclusions ............................................................................................. 123

Chapter 8. Bibliography............................................................................................ 126

Goal based Standards – A new theoretical safety approach

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Data tablesTable 1. IACS Members .............................................................................................. 42

Table 2. H-CSR schedule.............................................................................................46

Table 3. Other Associations ........................................................................................49

Table 4. IACS vs world fleet 2014................................................................................ 55

Table 5. List of documents in the SCF.........................................................................62

Table 6. Example of HAZOP Analysis [ABS,2003] ...................................................... 67

Table 7. GBS – FSA Relations.......................................................................................71

All the tables have been retrieved from a source but modified by the author of this

paper.

xi

IllustrationsIllustration 1. Development of rules and regulation .................................................... 20

Illustration 2. GBS Current stablished future timeline ................................................ 33

Illustration 3. GBS Timeline ........................................................................................ 34

Illustration 4. IACS Organization. ............................................................................... 43

Illustration 5. IACS relation with Maritime Industry .................................................... 44

Illustration 6. IACS world fleet by ship type (m GT) in April 2015 ................................ 45

Illustration 7. CSR harmonization process by IACS ..................................................... 47

Illustration 8. H-CSR Timeline .................................................................................... 48

Illustration 9. GBS Compliance process ...................................................................... 54

Illustration 10. Timeline Compliance process.............................................................. 54

Illustration 11. World vs IACS fleet 2014 ..................................................................... 56

Illustration 12. SCF availability and storage ................................................................ 63

Illustration 13. Flow Chart of the FSA methodology ................................................... 65

Illustration 14. Information flow chart in a FSA study ................................................. 70

Illustration 15. ALARP Principle .................................................................................. 76

Illustration 16. Flow chart characterizing the relation between GBS-SLA and FSA .....77

Illustration 17. Flow chart of the SLA framework ........................................................ 78

Illustration 18. Risk-based standards application visual diagram. ............................... 83

Illustration 19. The SAFEDOR roadmap...................................................................... 85

Illustration 20. Five Tier system ..................................................................................89

Illustration 21. Goal-Based Standards Framework......................................................90

Illustration 22. The coverage of GBS in the maritime field.......................................... 91

Illustration 23. Mechanism of rules verification. .........................................................98

Illustration 24. Application of GBS in the maritime field........................................... 101

Illustration 25. The maritime regulator's safety knob ............................................... 109

Illustration 26. Use of FSA in SLA-GBS ......................................................................111

Illustration 27. Hierarchy of IMO GBS-SLA instruments ........................................... 112

Illustration 28. New container ship orders of the world's leading operators ............. 116

Illustration 29. 40 years of container ship growth ......................................................117

Goal based Standards – A new theoretical safety approach

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Illustration 30. Forecast for global TEU capacity of container ships until 2018...........117

Illustration 31. Step scheme for GBS expansion........................................................ 118

Illustration 32. Vessels for the Future logo................................................................ 121

Illustration 33. Vessels for the Future Board Members.............................................. 121

All the illustrations have been retrieved from a source but modified by the author of

this paper.

xiii

Key wordsGoal-based standards; Formal safety assessment; Functional requirements; GBS

generalization; GBS verification audit scheme; Implementation; Maritime safety;

Prescriptive standards; Regulatory framework; Risk-based approach; Risk-based

approval, Risk-based GBS; Safety level approach; Safety-level approach to GBS; Ship

classification; Ship construction; and Verification of compliance

Goal based Standards – A new theoretical safety approach

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AbbreviationsALARP As Low As Reasonably Practical

BOE “Boletín Oficial del Estado”

BC Bulk Carriers

BIMCO Baltic and International Maritime Council

CAF Cost of Averting a Fatality

CEC Commission of the European Community

CESA Community of European Shipyards Associations

CPs Common Packages

CSR Common Structural Rules

CSR-H Harmonized Common Structural Rules

EMSA European Maritime Safety Agency

EU European Union

FEM Finit Element Modelling

FSA Formal Safety Assessment

GBS Goal Based Standards

HARDER Harmonization of rules and design rationale

HAZID Hazard Identification

HAZOP Hazard and Operability Study

HSR Harmonized Common Structural Rules

IACS International Association of Classification Societies

IGF International Code of Safety for Ships using Gases or other Low-

flashpoint Fuels

IMO International Maritime Organization

INTERCARGO International Association of dry Cargo ship-owners

INTERTANKO International Association of Independent Tanker Owners

IP Intellectual Property

IS Industry Standard

LL Load Lines

LNG Liquefied Natural Gas

xv

LPG Liquefied Petrol Gas

LSA Safety Level Approach

MARPOL Maritime Pollution

MEPC Marine Environment Protection Committee

MSC Maritime Safety Committee

OT Oil Tankers

PSC Port State Control

R&D Research and Development

RBA Risk Based Approach

RBD Risk Based Design

RCOs Risk Control Options

RO Recognized Organizations

RO-PAX Roll on - Roll off + Passenger ship

RO-RO Roll on - Roll off

SCF Ship Construction File

SIGTTO Society of International Gas Tanker and Terminal Operators

SOLAS Safety Of Life At Sea

SRA Structural Reliability Assessment

SSE Ship Systems and Equipment

TEU Twenty-foot Equivalent Unit

UK United Kingdom

Goal based Standards – A new theoretical safety approach

xvi

IntroductionThe objective of this paper is to acquire strong knowledge about standards of

construction and GBSs, from inception through development and into

implementation, as well as about the adaptation of maritime industry stakeholders to

these regulatory changes.

This final project comes at the heels of a personal thirst for expanding my knowledge

on ship construction standards based on international law and politics environment.

According to the maritime industry and its professionals, a new concept of standards

has started to revolutionize the whole maritime industry, the goal-based standards

(GBS), which are high-level standards and procedures to be met through regulations,

rules and standards for ships. GBS’s are comprised of goal(s), functional

requirement(s) associated with these goals, and verification of conformity to

rules/regulations meeting the functional requirements including goals.

For these purposes, this final project is structured into six sections. Section one

provides an overview of the inception, history and current development of GBSs in the

maritime world and outlines possible relevant future work. In section two, a

comparison between the Formal Safety Assessment, after setting up its bases, and

the Goal Based Standard system is presented. Chapter three presents current

alternatives regarding ship construction standards based on risk-based assessment. In

chapter four, the guidelines for GBS implementation are discussed. Chapter five

identifies current specific applications of GBS standards. In the closing section, a

holistic conclusion about the current GBS system is drawn. In addition, in this section,

recommendations are summarized to form a systematic scheme of future work on

GBS.

The methodology will consist in collecting all possible information about GBSs from

every possible resource to be able to express a sound opinion, for instance, MSC

xvii

meeting summaries, slides from different stakeholders, reviews, student papers, etc.

The deadline for completion is mid-June 2018. Developments will be weekly shown to

the tutor for advice and guidance.

Chapter 1. Goals Based Standards (GBS)

18

Chapter 1. Goals Based Standards (GBS)

1.1. Concept

IMO defines the Goal Based Standards (GBS) in the following terms: “The Goal-based

standards (GBS) are high-level standards and procedures that are to be met through

regulations, rules and standards for ships. GBS are comprised of goal(s), functional

requirement(s) associated with that goal, and verification of conformity that

rules/regulations meet the functional requirements including goals. In order to meet the

goals and functional requirements, classification societies acting as recognized

organizations (ROs) and/or national Administrations will develop rules and regulations

accordingly. These detailed requirements become a part of a GBS framework when they

have been verified, by independent auditors and/or appropriate IMO organs, as

conforming to the GBS.1”

On the other hand, we have the prescriptive regulation, which is well known to have

several inconveniences. The prescriptive standards state what to do and/or what to

avoid doing, usually they clearly stipulate specific means of achieving compliance. Just

carrying out the mandated actions the parties applying these regulations are

1 IMO Goal Based Standards. Consultation available at:http://www.imo.org/en/OurWork/Safety/SafetyTopics/Pages/Goal-BasedStandards.aspx

Chapter 1. Goals Based Standards (GBS)

19

exonerated of their legal responsibilities. Subsequently, if these actions are proved to

be insufficient to prevent an accident, would the regulations and those that set them

be held responsible instead of the parties applying them? Furthermore, the

regulations’ prescriptive tends to be the product and synthesis of experience and, as

such, may become outdated over time and at worst, could create unnecessary

dangers in a vanguard industry. Hence, it is the innovator that is best placed to ensure

the safety of their design, not the regulator. Clearly, prescriptive regulations are

unable to cope with a diversity of brand new design solutions. Prescriptive regulations

encode the best engineering practice at the time they were written but rapidly

become deficient where best practice is changing in an industry with constantly

evolving technologies. This results into a possible affection to the technical quality

and cost of the available solutions provided by commercial suppliers.

Since there are various international agreements, EC Directives and Regulations

intending to promote open markets and equivalent safety across nations, another

draw forth for adopting goal-based regulation, from a legal point of view, is that

overly-restrictive regulation could be viewed as a barrier to open markets. Whilst it is

necessary to prescribe minimum levels of safety and interoperability requirements, in

other areas, this kind of prescriptions would be conflicting with the aim of facilitating

open markets and competition.

Therefore, the “Goal-based regulation” does not specify the means of achieving

compliance but sets the goals that allow alternative ways of achieving it.

Goal based Standards – A new theoretical safety approach

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Illustration 1. Development of rules and regulationSource: Skovbakke Juhl, J. (2016) Goal Based Standards – Ship Construction File: Industry Standards (IS)

[PowerPoint slides]. BIMCO.

1.2. Inception and history

During the 89th Session of the IMO Council that took place in November 2002, the

notion of "Goal based standards" was introduced through a proposal of two State

members: Bahamas and Greece. This represented a major step with which IMO

sought to play a more active role in determining new ships construction standards,

traditionally a responsibility attributed to classification societies and shipyards. The

Council referred the proposal to the 77th meeting of the MSC in May/June 2003 for

further consideration.

“The introduction of GBS to IMO had its reasonable technical background. Around

2000, three accidents which led to serious casualties occurred. They were

Chapter 1. Goals Based Standards (GBS)

21

NAHODKA in 1997, ERIKA in 1999 and PRESTIGE in 2002, and each of the involved

ships was more than 25 years old. So, considerations were raised by

administrations on whether there were some deficiencies in the present regime of

ship construction in which ships were designed, constructed and maintained

according to the rules of classification societies. At that time there was no

international legislation or guidance addressing these matters.”2

The conceptual approach is that IMO should develop standards for ship construction

to enable innovative designs and implementation of modern technologies, but

simultaneously it should ensure that when ships are built, if properly maintained, they

can remain active throughout their economic life (25 years of average). The standards

would also have to ensure that all parts of the vessel are easily accessible to allow

adequate inspections and maintenance tasks.

For two long years, the issue was discussed in the Maritime Safety Committee (MSC),

the Council, and finally, in the IMO Assembly, which at its 23th session in 2003,

included the topic "new shipbuilding rules based on objectives" in the strategic plan

(A.944 (23)) and the long-term working plan (A.943 (23)) of the Organization. Then,

the technical work commenced on the development of goal-based ship construction

standards at the MSC 78th session in May 20043. An intense debate regarding all issues

related to Goal Based Standards was generated during the session, concluding in the

agreement of using a five-tier system, as proposed by the Bahamas, Greece and the

IACS.

2 Nakajima, Y (2006, Sep 15) Japan. IMO Goal-based Standards: A shipbuilders’ point of view.3 For the sake of clarity, in order to enunciate the different MSC sessions, the preferred option has beento indicate after “MSC” the number of the session, without attaching the ordinal marker.

Goal based Standards – A new theoretical safety approach

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In the MSC 80th session (24th May 2005) it was agreed on having two parallel tracks

with both the deterministic approach and the safety level approach, and two

correspondence groups on SLA were established to address this issue between MSC

81 and MSC 83. They discussed the linkages between GBS and FSA, the evaluation of

current safety level, and the development of risk models and common terminology of

FSA.

1.2.1. SOLAS Chapter II-1 amends

Following, at MSC 84 the task of developing a generic GBS framework was proposed

in the report of the GBS correspondence group. So, a draft of the guidelines was made

but not approved until subsequent sessions.

After a long period of discussions, IMO's Maritime Safety Committee (MSC) met at

the Organization's London Headquarters for its 87th session from 12 to 21 May 2010,

which saw the adoption of mandatory International Goal-based ship construction

standards for Bulk Carriers and Oil Tankers from lengths of 150 meters and above. In

addition, the adoption of amendments to Chapter II-1 of the International Convention

for the Safety of Life at Sea (SOLAS), making their application mandatory, entered

into fore date of 1st January 2013.

As agreed on SOLAS, Chapter II-1 / 3-10 stated that GBS should be applied following

the schedule below:

Construction contract from July 1, 2016.

In the absence of a building contract, the keels of which are laid, or which are in

similar stage of construction on or after 1 July 2017.

Delivery date from July 1, 2020 hereinafter.

This regulation also sets up a group of general goals, which are also stipulated in Tier I

of the GBS system for the new construction of ships, as we will see in future section

Goals (Tier I). Therefore, this regulation instigated a historic change on how

international standards for ship construction will be determined and implemented. As

Chapter 1. Goals Based Standards (GBS)

23

a matter of fact, IMO started stablishing ship construction standards for the first time

in its history.

1.2.2. Guidelines for the Verification of Conformity with GBS & Guidelines for

the Information to be included in a Ship Construction File (SCF)

From the beginning of the 2000s, governments and international organizations had

expressed their point of view as regards the Organization’s larger role in determining

the structural standards with which new ships are built. Knowing that this significant

role could only be played by them, the Organization decided to increase their power in

the maritime industry. For that purpose, the 87th Committee also adopted the

Guidelines for verification of conformity with GBS, that, equally for the first time, gave

the Organization a role in verifying conformity with SOLAS requirements. The

guidelines established the procedures to be followed in order to verify that the design

and construction rules of an Administration or its recognized organization, for bulk

carriers and/or oil tankers, conform to the adopted GBS. Also, another set of

Guidelines was established, the Guidelines for the information to be included in a Ship

Construction File (SCF): MSC.1/Circ.1343.

All of the instruments adopted in the MSC 87 in May 2010, such as the guidelines, the

new regulations and the GBS, can be found in resolution MSC.290 (87). Between the

24th November and the 3rd December, the MSC 88 took place. Some Member States

and international organizations were invited to submit detailed proposals in order to

finalize generic guidelines for developing a Goal Based Standards draft by the MSC

89. Also, the Committee noted the information on the progress made about the

implementation of the verification scheme for the International GBS along the

associated amendments to SOLAS Chapter II-1 that were adopted at its last session.

Goal based Standards – A new theoretical safety approach

24

1.2.3. Generic guidelines for developing Goal-based standards

As agreed on the previous sessions and in order to kick off the process of

development, verification, implementation and monitoring of goal based standards

(GBS) for the purpose of supporting development policy, during the 89th MSC

meeting (11th-20th May 2011), finally the generic guidelines for developing GBS (MSC

1 / Circ. 1394) were approved.

Based on the experiences obtained from the establishment process of the

International Goal-Based Ship Construction Standards for BC and OT, the Generic

Guidelines for Developing Goal-based Standards were developed. These followed the

purpose of providing a standardized process to develop, verify, implement and

monitor GBS so that the future regulatory development of IMO GBS could be guided.

It is important to notice that the guidelines are applicable both within deterministic

and safety level approaches.

The guidelines require that goals (Tier I) which are high-level objectives to be met,

should reflect the required level of safety. Regarding the functional requirements (Tier

II), it is instructed that they should provide the criteria to be satisfied in order to meet

the goals. Also, they need to be developed according to experiences, assessment of

existing regulations or systematic analysis of relevant hazards, covering all functions

and areas necessary to meet the goals. Concerning Tier IV, it is specified that the rules

and regulations refer to detailed requirements which form a part of GBS framework

after verification as conforming to the GBS. Finally, in the Tier V it is clarified that the

suitability of industry practice and standards incorporated into or referenced in

Chapter 1. Goals Based Standards (GBS)

25

rules/regulations should be justified by the rules/regulations submitted and should be

provided during verification of conformity.4

The guidelines also stablish fundamental key points regarding the monitoring process,

including the basic process, main consideration and responsibility of each tier.

“It can be concluded that the guidelines provide requirements in principle regarding the

development of GBS. In order to make it broad, generic and applicable to all ship types

and aspects, the guidelines do not contain technical criteria within specific ship types.

Nevertheless, the guidelines are a preparation document for further development and the

holistic expansion of the GBS regime throughout the whole maritime regulatory

system.”5

The Committee also discussed and agreed upon how the work on GBS should be

progressed, including how the safety level approach (SLA) may be introduced in goal-

based standards.

In July 2011, Secretariat staff was recruited and commenced its work on the

establishment of the GBS verification scheme. Also, this organ issued a circular letter

inviting requests for initial verification audits.

The MSC 90 (16th to 25th May 2012) established a correspondence Group of work on

Goal-Based Standards in order to develop draft guidelines and approve equivalents

and alternatives as provided for in various IMO instruments. Finally, the Committee

endorsed a work plan for the development of interim guidelines for the SLA.

4 International Maritime Organization, 2011.5 Peng, Y. An analysis of the implementation and future development of IMO Goal-based standards.Master of Science in Maritime Affairs. Malmö, Sweden: World Maritime University, 2011. p. 20.

Goal based Standards – A new theoretical safety approach

26

On its 91th Session (26-30 November 2012), the MSC continued its work on goal-

based standards, as established on the MSC 90 for further updates and

improvements. The development of interim guidelines for the SLA was also discussed,

and a working group agreed on a draft set of elements to be considered. The "Safety

level” was defined as: “a measure of exposure to risk” and the "Safety-level approach”

was defined as: “the structured application of risk-based methodologies for the IMO

rule-making process”6.

Since this process was really complex and there were third parties involved rather than

just the MSC and the other shareholders, such as Member States and interested

organizations, they were invited to submit comments on the safety level approach

elements ahead of future sessions.

In connection with the GBS, the 92th Session of the MSC (12-21 June 2013) examined

the report of a correspondence group on goal-based standards and approved the

Guidelines for the approval of alternatives and equivalents as provided for in various

IMO instruments. The MSC encouraged Member States to provide feedback to the

Organization on experience gained with their application to enhance the Guidelines

and amend the deficiencies in them.

The work groups established by the MSC, International Organizations and Member

States kept working on the same trend until the MSC 94 session that took place on 17-

21 November 2014 where GBS issues were discussed. First, the International Code for

Ships Operating in Polar Waters (Polar Code) was adopted and related amendments

to the International Convention for the Safety of Life at Sea (SOLAS) were made to

6 ((MSC), 2012)

Chapter 1. Goals Based Standards (GBS)

27

make it mandatory. This was an important headway as it established goals and

functional requirements in relation to ship design, construction, equipment,

operations, training, and search and rescue, relevant to ships operating in Arctic and

Antarctic waters. Therefore, it constituted a big step towards the general

implementation of GBS.

Because it contains both safety and environmental related provisions, the Polar Code

was made mandatory under both SOLAS and the International Convention for the

Prevention of Pollution from Ships (MARPOL). In October 2014, IMO’s Marine

Environment Protection Committee (MEPC) approved the necessary draft

amendments to make the environmental provisions in the Polar Code mandatory

under MARPOL. The MEPC adopted the Code and associated MARPOL amendments

at its session that took place in May 2015, with an entry-into-force date that was

aligned with SOLAS amendments. This step on the GBS is important due to the

improvement it represents regarding the FSA, which now carries environment related

provisions.

The Polar Code entered into force with the SOLAS amendments the 1st of January

2017, under the tacit acceptance procedure. It is applicable to all new ships

constructed after the entry into force date. Ships constructed before 1 January 2017

will be required to meet the relevant requirements of the Polar Code by the first

intermediate or renewal survey, whichever occurs first, after 1 January 2018.

The IGF code is the International Code of Safety for Ships using Gases or other Low-

flashpoint Fuels, whose draft was, in principle, approved. At the same time,

amendments were approved to make the IGF code mandatory under SOLAS, with a

view to adopting both the IGF Code and SOLAS amendments at the MSC 95 session,

convened in June 2015.

Goal based Standards – A new theoretical safety approach

28

As in the Polar Code, the IGF code addresses all areas that need special consideration

for the usage of low-flashpoint fuels, based on a goal-based approach, with goals and

functional requirements specified for each section forming the basis for the design,

construction and operation of ships using this type of fuel.

Finally, it is relevant to mention that the GBS Working group at MSC 94 initiated the

work on the draft interim guidelines for the application of GBS SLA to the IMO rule-

making process. All party Member States and International Organizations were

invited to submit comments and proposals to the draft Interim guidelines for further

development and approaches.

The MSC 95 that took place on 3th -12th June 2015 approved a work plan for continued

work on goal-based standards safety level approach (GBS-SLA), over the next three

sessions. During that session some progress was made on developing the draft

interim guidelines for the application of the GBS-LSA, and Member Governments and

international organizations were invited, as in session 94th, by MSC to submit

comments and proposals about the guidelines with the aim of bringing more views,

knowledge and innovative ideas to the discussion.

But one of the most important events in that MSC was the MSC.1/Circ.1394/Rev.1 –

which can be found in its integrity in the Generic guidelines for developing IMO goal-

based standards. This represents an enormous step towards the GBS. The revised

generic guidelines specify the structure and contents of functional requirements to be

used in GBS and provide several examples to set a model to follow suit. In order to

support the regulatory development with IMO, the guidelines also describe the

process for the development, verification, and implementation and monitoring of the

GBS.

The MSC was notified that, by the end of March 2015, all five GBS verification audit

teams had delivered their interim reports, which included 13 interim reports on

relevant recognized organizations (ROs); and two interim reports on IACS Common

Chapter 1. Goals Based Standards (GBS)

29

Packages. According to the MSC schedule, the five audit teams should provide their

final reports to the Secretary-General and relevant ROs by the end of June 2015.

Afterwards the Secretariat submitted these reports to MSC 96 for their approval.

Under the GBS standards, construction rules for bulk carriers and oil tankers of

classification societies which act as ROs, or national Administrations, must be verified.

These standards and construction rules should be based on the Guidelines for

verification of conformity with goal-based ship construction standards for bulk

carriers and oil tankers (resolution MSC.296(87)) (GBS Guidelines). Please refer to:

¡Error! No se encuentra el origen de la referencia..

The new rules also require that a ship construction file must be provided on the

delivery of a new ship and must be taken on board and / or land.

During MSC 96 held from 11 to 20 May 2016, at the IMO headquarters in London, two

elements on the Goal based new-ship construction standards agenda stood out:

The audit of the RO rules packages to enable the implementation of the GBS

for hull structures of new OT and BC, SOLAS II-1/3-10.

General move within IMO towards developing regulations in support of a

specific goal which includes the SLA.

The current GBS regime was, finally established, but only to a restricted domain the

structure of bulk carriers and oil tankers. The purpose of restricting this new

framework to a single area responds to the need to test it. Further work, development

and expansion of the GBS in other fields was expected to ensue afterwards.

Regarding the GBS audits, the IACS common structural rules, which were audited by

the IMO, proved to conform with the goals and functional requirements set by the

Organization, set out in the International goal-based ship construction standards for

bulk carriers and oil tankers, adopted in 2010. This means that oil tankers and bulk

Goal based Standards – A new theoretical safety approach

30

carriers over 150 meters in length contracted for construction on or after 1 July 2016

would fully comply with the new SOLAS requirements. As confirmed by Circular

MSC.1/Circ.1518, all of the rules submitted from RO’s, conforming to IACS, were

accepted.

For the first time in history, IMO had a role in auditing and verifying the rules

developed by the classification societies for the building of new bulk carriers and oil

tankers, even in determining the minor details that until now had been an exclusive

competence of the building companies. Therefore, the whole standard process has

dramatically changed. Completing this process made a big difference regarding the

development for international standards in the ship construction industry, notably In

how these rules are determined and implemented.

As Kitack Lim, the IMO General Secretary, said: “the verification process which had

now been completed, was a significant step for IMO, since until now, there had been no

direct oversight by IMO of the classification societies’ structural rules. The completion of

this process of developing goal-based standards for oil tankers and bulk carriers, followed

by the detailed verification audit process, means that we now have a much closer

alignment between the classification societies’ rules and the IMO regulatory process. This

marks a very significant development in the IMO rule making process.”7

The MSC 96th session noted that there were some audits findings requiring resolution,

but these were not considered to affect the safety of ships. An additional audit to

specifically address these issues would be carried out in the first half of 2017. The

results were expected to be communicated to MSC 98, which was held in June 2017.

7 Kitack Lim, press conference held after MSC 96th session, 2016.

Chapter 1. Goals Based Standards (GBS)

31

Referring to the Safety Level Approach, the MSC 96, as expected, carried out further

work on the draft for “Interim guidelines for development and application of IMO

goal-based standards safety level approach”. Changes were relatively minor, such as

specifying the need to periodically monitor and maintain goals and functional

requirements once they have been agreed within the IMO rule-making process.

The MSC 96 requested the Ship Systems and Equipment (SSE) sub-committee to

develop a draft for functional requirements for SOLAS chapter III, lifesaving

appliances. That was a step forward in the quest for a general application of GBS.

Despite not having had support at MSC 96 for expanding the scope of the draft

guidelines, nor for applying the SLA guidelines to restructure SOLAS, it is well known

that the regulations on lifesaving appliances would end up conforming with the GBS in

the future. MSC 96 considered that a lot of experience was earned in using the

“Generic guidelines for developing IMO goal-based standards”, but that it is too early

to make changes as more experience would be gained as the work on SOLAS chapter

III continues.

Even though there was some prior discussion, concluding that the following matters

require further consideration in future sessions, new issues were welcome to be

submitted from delegations for discussion:

• Definitions or descriptions of key words

• Better explanations on the relationship between information and

documentation requirements and the evaluation criteria

• Maintenance of verification audits

• Other issues from individual auditors

• Amendments to ensure a continuous improvement process

Goal based Standards – A new theoretical safety approach

32

• Change to a more proactive approach8

At MSC 97 on the 21st to the 22nd November 2016the committee: “further developed

proposed amendments to revise and update the GBS Verification Guidelines, based

on the experience gained during the initial verification audits. The revisions, were

planned to be considered at future sessions, include additional and revised paragraphs

relating to issues such as the insertion of an application date for any revised version of

the Guidelines or submitting corrective action plans to address any findings reported

by the GBS Audit Teams. Guidelines on common submissions by groups of submitters

and the inclusion of an ongoing review of the rules are also proposed to be included. A

revised timetable and schedule of activities for the implementation of the GBS

verification scheme was also agreed, to include a 31 December 2017 deadline for the

receipt of rule change information and request for new initial verification audits, if

any. The MSC also confirmed that ship construction rules for oil tankers and bulk

carriers submitted by 12 classification societies conform to the goals and functional

requirements set by the Organization for new oil tankers and bulk carriers set out in

the International goal-based ship construction standards for bulk carriers and oil

tankers (resolution MSC.287(87)), which were adopted in 2010.”9

8 MSC 96th session, 2016.9 Maritime Safety Committee (MSC). 97th Session, 21-15 November 2016. Meeting Summary.http://www.imo.org/en/MediaCentre/MeetingSummaries/MSC/Pages/MSC-97th-session.aspx

Chapter 1. Goals Based Standards (GBS)

33

Illustration 2. GBS Current stablished future timeline

Goal based Standards – A new theoretical safety approach

34

Illustration 3. GBS Timeline

Chapter 1. Goals Based Standards (GBS)

35

1.3. GBS basic principles

For the future development of the GBS system, it was necessary to define the GBS

basic principles which would provide an objective, a purpose and a direction. These

basic principles were decided throughout plenary discussions and in the working

group during MSC 79 and MSC 80, resulting in an agreement on the basic principles of

IMO goal-based standards as per the following characteristics:

I. Broad, over-arching safety, environmental and/or security standards that ships

are required to meet during their lifecycle;

II. The required level to be achieved by the requirements applied by class

societies and other recognized organizations, Administrations and IMO;

III. Clear, demonstrable, verifiable, long standing, implementable and achievable,

irrespective of ship design and technology; and

IV. Specific enough in order not to be open to differing interpretations.” 10

It is understood that these basic principles were developed to be applicable to all goal-

based standards developed by IMO. Furthermore, not only goal-based new ship

construction standards, but recognizing that in the future, IMO may develop goal-

based standards for other areas, for instance: machinery; equipment; fire-protection;

etc. To sum up, all goal-based standards developed by the Organization should follow

the same basic principles.

1.4. GBS development methodology

From the very beginning there were different views in the Committee on how to

approach the development of GBS for ship construction.

10 International Maritime Organization, 2004.

Goal based Standards – A new theoretical safety approach

36

Some IMO Members advocated for the application of a holistic approach which would

define a procedure for the risk-based evaluation of the current safety level of existing

mandatory regulations related to ship safety and consider ways forward to establish

future risk acceptance criteria using FSA. This methodology is known as Safety Level

Approach (SLA).

The SLA is supposed to be an ideal basis for further GBS development since it is

recognized as a holistic approach. Employing the FSA process can provide a

quantitative analysis of safety level and address the problem with cost-effective

means. However, there is still a lot of research work to do in order to assess the risk of

a variety of elements for instance, the protection of human life, healthiness and the

maritime environment. Therefore, it will be a long-term work.

Contrarily, other Members supported a more deterministic approach, based on the

vast practical experience gained with oil tankers and bulk carriers over the years and

stressed the need for quantified functional requirements.

The Committee had extensive and wide-ranging discussions on this issue, with many

different Administrations active participation, during which, support for both

methodologies was expressed. It was particularly noted that the GBS for new ship

construction would not be limited to bulk carriers and tankers, but were meant to

address, at a future date, all ship types. Subsequently, the current results would have

to be expanded in order to make them applicable.

It was, therefore, agreed that the use of the risk-based methodology should be further

explored over the next few sessions of the Committee, while, at the same time,

proceeding with the development of GBS using the deterministic approach. But this

also meant that, if it was decided to adopt the risk-based approach at some point in

the future, a revision of the goal-based standards developed under the deterministic

Chapter 1. Goals Based Standards (GBS)

37

methodology would be required to verify consistency and make changes where

necessary.

1.5. The classification societies (CLASS)

Classification Societies are entities that provide inspection and technical services to

the maritime industry and States (flag). By the request of the ship-owner, Class

certificates can be issued. In addition, the classification societies are able to carry out

surveys on behalf of the States which have previously recognized them. As IACS

describes: “the objective of the Classification Society is to provide classification and

statutory services and assistance to the maritime industry and regulatory bodies as

regards maritime safety and pollution prevention, based on the accumulation of

maritime knowledge and technology. The objective of ships classification is to verify

the structural strength and integrity of essential parts of the ship’s hull and its

appendages, and the reliability and function of the propulsion and steering systems,

power generation and those other features and auxiliary systems which have been

built into the ship in order to maintain essential services onboard. CLASS aim to

achieve this objective through the development and application of their own Rules

and by verifying compliance with international and/or national statutory regulations

on behalf of flag Administrations. And the vast majority of commercial ships are built

to and surveyed form compliance with the standards laid down by Classification

society”11, thus they play a major role in the maritime industry.

Classification societies have their origin between the seventeenth and eighteenth

centuries, as the result of the insurance market needs, which lacked reliable

11 (IACS). Jan. 2015. Classification societies – what, why and how?http://www.iacs.org.uk/media/3785/iacs-class-what-why-how.pdf

Goal based Standards – A new theoretical safety approach

38

information to calculate premiums. At that time, all information obtained by insurers

came from personal interviews with the captains and their crews, conducted in

lodgings, bars or cafes in the port area.

Soon after these organizations sprang, Edward Lloyd Coffee stood out. Established in

1685, Lloyd was a meeting place for traders, marine insurers and others related to the

marine industry. A ship data list began circulating in a structured way. It was not until

1760 that Lloyd’s customers shaped the "Register Society". with Lloyd’s underwriters

and brokers in its drafting committee. Their main task was to examine merchant ships

and classify them according to their condition and to provide basic information such

as the technical characteristics of the insured ships. The first-ever printed ship register

book of which we have record dates back to 1764.

The “Green Book”, which was published in 1806, was elaborated only under the

direction of insurers, which sparked great controversies in the industry. This led to

ship-owners to issue their own version, the so-called “Red Book”. In 1834 the

differences between both books were settled, and a new company was established to

develop a ship registry, called Lloyds Register of Shipping, which included in its board

groups of merchants, ship-owners and insurers. Therefore, it represented the entire

shipping industry, although the influence and power over the management was kept

predominantly by insurers.

Lloyds Register of Shipping developed a regional network of inspectors, and a regular

ship inspection system, but its main purpose was still to draw a record of categorized

ships.

From its initial core activity, classification, companies such as Lloyds Register of

Shipping started issuing certificates gradually, as ship-owners needed to establish

long-term valid systems after the vessel had been inspected and classified. Thus, the

Chapter 1. Goals Based Standards (GBS)

39

system of issuing certificates and “rules” for class maintenance was developed, and it

became the core business of Classification Societies.

Classification Societies have a dual role:

• Establish and apply Classification rules.

• Act as Recognized organizations for Flag States.

1.5.1. Classification

The aim to classify ships is to assign a class to a ship in the ship register of each

company after carrying out the inspections and surveys that allow them to ensure that

the ship is designed, constructed, equipped and maintained in accordance with its

own rules. Classification Certificates accredit the condition of the ship and is the proof

of their status and maintenance. The Classification Certificate is a document usually

required in their trade relations by the maritime industry.

The certificates by means of images, trademarks and a proper coding of each society,

specifies the "Dimensions" and "Notations" that describes the ship class. It should be

noted that the IACS is continually working on the adoption of a common symbology

to avoid confusions.

1.5.2. Inspections

Once the ship is operating, in order to maintain and renew the class, the ship-owner is

obliged to submit the vessel to a clearly established regular inspection program,

carried out onboard by Classification Society inspectors whom are responsible for the

verification of ship compliance to the conditions stipulated in the Rules.

The inspections are scheduled over a five-year cycle, with Annual inspections,

Intermediate inspections and Special inspection or Class Renewal inspection, which

are performed in the end of this 5 years period. Each type of inspection has a certain

scope and coverage and generally are deeper and more rigorous as the vessel age.

Goal based Standards – A new theoretical safety approach

40

1.5.3. Classification society responsibilities

As recognized and authorized organizations to carry out mandatory inspections, the

liability regime for Classification Societies, is regulated in the EU by the Directive

2001/105, transposed into Spanish law by Royal Decree 90/2003, on January 24th,

concerning common rules and standards for inspection organizations, ship control and

other activities corresponding maritime administration.

Article 106 of the Maritime Navigation Law, effective on September 24th of 2014,

defines the contract classification, as follows: "the classification society certifies that a

ship or any of its parts or belongings meets the established of the corresponding class

rules".

Regarding the Classification societies responsibility, the same article states:

"Classification societies will be liable for liquidated damages caused to those who

contract them and that are a consequence of lack of diligence in the inspection of the

vessel and the issue of the certificate. The liability of classification societies against

third parties shall be determined under common law, without prejudice to

International and Community legislation that may apply."

1.5.4. IACS

The preponderance of the ship-owners interests in issuing the Certificates by

Classification Societies generated in the sixties a strong distrust and criticism on the

mutual insurance companies P&I (Protection & Insurance) who created their own

systems of verification and inspection, known as "full condition survey", which

considers not only the ship condition but also include human factors such as the crew

certification and the prevention systems installed onboard.

In the same vein the Marine Insurers Union criticized the excessive reliance on

classification societies to ship-owners, with the consequent conflict of interest that

could result in a lower level of demand in the maintenance of ships.

Chapter 1. Goals Based Standards (GBS)

41

All these events, forced Classification Societies to create in 1968 the International

Association of Classification Societies (IACS) in an attempt to recover a constructive

dialogue with insurers offering a rules’ progressive standardization and to represent

their interests in international organizations such as the IMO, where the IACS holds

advisory body status.

Therefore, as abovementioned, the IACS, as defined by themselves: “is a nonprofit

membership organization of classification societies contributing to maritime safety,

regulation and environmental protection throughout technical support, compliance

verification and research and development. As IACS is composed by twelve Members of

the most important Classification Societies and more than 90% of the world's cargo

carrying tonnage is covered by the classification design, construction and through-life

compliance rules and standards set by them”6.

12 Introduction about IACS. Retrieved from: http://www.iacs.org.uk/about/ (February 2018)

Goal based Standards – A new theoretical safety approach

42

Table 1. IACS Members

The challenges facing the IACS are addressed in the IMO strategic plan for the

maritime industry, which includes among other issues: globalization, maritime safety

Chapter 1. Goals Based Standards (GBS)

43

and security, environmental awareness, maritime security and efficiency of the ship,

innovation and new technologies, changing the emphasis on people and promoting

safety culture. These challenges are seen by IACS as opportunities to promote and

further enhance the role of class and its function in the maritime world. For doing so

the effective regulation should be developed with the maritime Industry.

Illustration 4. IACS Organization.Retrieved from: http://www.iacs.org.uk/media/2914/iacs-organisation-wbg.png

Goal based Standards – A new theoretical safety approach

44

Illustration 5. IACS relation with Maritime IndustrySource: PowerPoint: Risk, Safety and Vetting IACS role & contribution by Philippe Donche-Gay.

Chairman of the IACS Council. INTERNTANKO- Athens, 19-22 May 2015.

By the end of 2013, the twelve International Association of Classification Societies

(IACS) members (recognized organizations: ROs) and one non-IACS RO submitted

requests for GBS verification audits.

Chapter 1. Goals Based Standards (GBS)

45

Illustration 6. IACS world fleet by ship type (m GT) in April 2015Source: LMIU April 2015 retrieved from Powerpoint: Risk, Safety and Vetting IACS role & Contribution by

Philippe Donche-Gay. Chairman of the IACS Council. INTERNTANKO- Athens, 19-22 May 2015.

This graphic represents the IACS world fleet by ship type. Bearing in mind that the

90% of the world tonnage is classed by IACS societies. Allowing us to see the high

importance of the IACS in the maritime industry, representing most of the

stakeholders.

Goal based Standards – A new theoretical safety approach

46

1.5.4.1. IACS Harmonizing CSR

On the 14th of December 2005 the common Structural rules (CSR) for Oil-Tankers

(CSR-OT) and Bulk Carriers (CSR-BC) construction were adopted unanimously by the

Council of the IACS for implementation on 1st April 2006. The IACS Council

appreciated that these rules were technical- based. They made the design of the ships

become more robust and safer, thus reaching the stablished goals.

Table 2. H-CSR scheduleSource: Horn, G. (2010). IMO Goal-Based ship construction standards. INTERTANKO – North American

Panel. Houston, Texas. [PowerPoint slides].

The two sets of rules for each type of boat were developed independently, based on

different technical approaches. To prevent and eliminate variations and achieve

consistency between them, IACS decided to harmonize both, starting in 2012.

Currently, there is only one set of rules called "Structural Common Rules for Bulk

Carriers and Oil Tankers" (CSR BC & OT) which satisfies the commitments made to

industry stakeholders. It comprises two parts: Part One indicates common

Chapter 1. Goals Based Standards (GBS)

47

requirements for Bulk Carriers and double hull oil tankers, and the second part

provides special additional requirements specifically for Bulk Carriers or double-hulled

tankers. This single set of rules is based on transparent methods, and is supported by

published technical background, providing a rational link between the requirements

for newbuilding and ships in service. Moreover, the key point is that the concept of

IMO GBS is included within.

Illustration 7. CSR harmonization process by IACSSource: Arima, T. (2012). GBS for Oil Tankers and Bulk Carriers [PowerPoint slides].

There were several project teams working on different areas of development such as:

loads, bulking, FEM, Corrosion, welding, fatigue of hatch cover, ships in operation,

fatigue, prescriptive requirements and consequence assessment.

Goal based Standards – A new theoretical safety approach

48

Illustration 8. H-CSR TimelineHorn, G. (2010). IMO Goal-Based ship construction standards. INTERTANKO – North American Panel.

Houston, Texas. [PowerPoint slides].

Chapter 1. Goals Based Standards (GBS)

49

1.5.5. Other associations

Having the observer status from IMO, other sectorial associations of ship-owners

exist, whom through their services and studies contribute to supply important

technical inputs.

Among them we can highlight:

Table 3. Other AssociationsSource: Author of this work

The main objective of these associations is to develop reports and technical

specifications, for instance constructive designs or propose alternative materials.

Thus, allowing the industry to move towards a maritime activity development based

on technical standards and procedures that provide greater safety, respect the

environment and better protection of the crew members and the transported goods.

1.6. Current situation

In general, there is an increasing tendency to adopt a goal-based approach to create

new regulation and as afore mentioned there are good technical and commercial

reasons for believing this approach is preferable rather to more prescriptive

regulation. Consequently, goal-based standards for new ship construction should

form the foundation for the future on international regulatory shipping standards.

Nevertheless, it should be accepted that the current limits of these standards may

change because of continuous innovation and public/political change of perception.

Goal based Standards – A new theoretical safety approach

50

At the las MSC session 98th held on 7-16 of June 2017, as retrieved from its summary:

“the MSC confirmed that the initial verification audit of ship construction rules for oil

tankers and bulk carriers submitted by 12 classification societies had been successfully

completed, following rectification of the non-conformities reported, as instructed by

MSC 96. As previously mentioned, in 2016, MSC 96 confirmed that ship construction

rules for oil tankers and bulk carriers submitted by 12 classification societies conform to

the goals and functional requirements set by the Organization in the International goal-

based ship construction standards for bulk carriers and oil tankers (resolution

MSC.287(87)) which were adopted in 2010; and agreed that the non-conformities

identified were to be rectified. The MSC also made progress in developing amendments to

the GBS Verification Guidelines and agreed an updated timetable and schedule of

activities for the implementation of the GBS verification scheme, including the

maintenance of verification.”13

The forthcoming meeting of the MSC will be the 3-7th of December for its 100th

session.

1.6.1. Current situation in Spain

On 23 December 2011 the Ministry of Foreign Affairs and Cooperation published a

resolution on the International standards for the ship construction based on goals for

bulk carriers and oil tankers.14

13 Maritime Safety Committee (MSC). 98th meeting. Meeting summaries. Retrieved from:http://www.imo.org/en/MediaCentre/MeetingSummaries/MSC/Pages/MSC-98th-session.aspx14 “Boletín Oficial del Estado”, published on the 23rd of December of 2011 by the Ministry of Foreing

Affairs and cooperation. The International standards for the ship construction based on goals for bulk

carriers and oil tankers.

Retrieved from: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2011-20018

Chapter 1. Goals Based Standards (GBS)

51

Therefore, as specified in the afore mentioned BOE, those were officially adopted

from the 20th of May 2010. The presented rules entered into force generally and as for

Spain they did on the 1st of January 2012, when the standard II-1/3-10 from the

amended SOLAS from 1974 came into effect too.

1.7. Verification conformity of the GBS

The verification conformity process conforms a bridge between what is to be achieved

and what is to be done, linking the goals and functional requirements to regulations.

To build such a linkage, it must be found “how to decide on what constitutes sufficient

evidence”15. That is done because dissimilarly to the prescriptive regulations, usually

being clear and explicit, GBS are vague and implicit in terms of valid measures.

The conformity verification of the shipbuilding rules established by individually

recognized organizations and / or national maritime administrations regarding the

GBS was conducted by international GBS audit teams stipulated by the IMO General

Secretary General, in accordance with verification Guidelines. These Guidelines

provide that those recognized regulatory authorities who submit applications for the

verification of its shipbuilding rules to the General Secretary, will forward these

inquiries to the audit teams to verify the submitted information through an

independent review. The final reports of the teams with relevant recommendations

will be addressed to the Maritime Safety Committee (MSC) for its consideration and

approval.

For an examination of risk-based methodologies, the MSC 90 established a GBS

correspondence group and instructed it to develop draft guidelines for the approval of

15 Kelly, McDermid, & Weaver, 2005, p. 5. Goal‐based safety standards: opportunities and challenges.

Goal based Standards – A new theoretical safety approach

52

equivalents methods and alternatives provided in various IMO instruments. It should

be based on the Guidelines for approval of ship design risk by Annex to document

MSC 86/5/3.

According to the implementation plan (MSC 87/26 / Add.1 / Annex 13), the deadline for

applications receipt to start initial checks at the IMO was 31 December 2013. To

facilitate the preparation of the audit the IMO sent Circ. No.3097 letter in August

2010, inviting the previous notice of intent to submit an application for a GBS

verification audit, and in June 2012, eight notifications of classification societies were

received. But before the due date they received twelve submissions from the

classification societies members, the IACS and one from another international

organization.

From January 2012 to December 2015, the Secretariat prepared, organized and

finalized all audits requested, processed any appeal and finally any progress made was

reported to the Committee.

During the 2014 MSC, progress was made in reviewing GBS implementation, on

schedule. On January 2016 the Secretariat prepared the documentation on all audits

conducted for MSC 96 for final decision.

While writing this document the MSC 96 which took place from Wednesday, 11 May

2016 - Friday, 20 May 2016, they took a final decision on conformity with GBS for all

rules submitted. The Secretariat informed the Administration /Regulated organs of

MSC’s decisions, circulates results of successful verifications and maintains lists of all

rules verified to conform to Standards.

As said in the specific part, the IACS common structural rules, which have been

audited by the IMO, where confirmed to conform the goals and functional

requirements set by the Organization set out in the International goal-based ship

Chapter 1. Goals Based Standards (GBS)

53

construction standards for bulk carriers and oil tankers which were adopted in

2010. This meant that oil tankers and bulk carriers over 150 meters in length

contracted for construction on or after 1 July 2016 which are designed and built to

these rules will fully comply with this new SOLAS requirement. Such as stablished in

the Circular MSC.1/Circ.1518, all of the rules submitted from RO’s, conforming IACS,

have been agreed.

1.7.1. GBS auditors

In response to the Circ. Letter No.3076 of July 2010, which invited to the appointment

of GBS auditors 33 nominations were submitted by Member States and international

organizations up until July 12, 2012. The Audit Teams of Experts was composed, from

three to five members depending on the complexity of the submissions. All of the

nominees have an adequate knowledge of and experience in ship structural design

and construction, the Standards and classification society rules and rule development.

This entails that they should be able to correctly interpret the rules for correlation with

relevant regulatory requirements.

1.7.2. IACS plan for compliance with GBS

The classification Societies individually submitted a package of technical

documentations to IMO for verification of GBS compliance, which was composed of:

A. Individual Class rules

B. IACS Common Packages, divided into two parts:

a. IACS Common Package, 1st Part – Composed of pertinent IACS resolutions

and other IACS documents

b. IACS Common Package, 2nd Part – Composed of pertinent IACS

Harmonized Common Structural Rules (CSR-H).

The IACS Common Package should comply with 15 functional requirements of the

GBS stablished by IMO on the Tier II.

Goal based Standards – A new theoretical safety approach

54

Illustration 9. GBS Compliance processSource: Corsetti M.W. (2014) Rule-based and Goal-based Standards. Copenhagen, Denmark.

[PowerPoint slides].

Illustration 10. Timeline Compliance processSource: Arima, T. (2012). GBS for Oil Tankers and Bulk Carriers [PowerPoint slides].

Chapter 1. Goals Based Standards (GBS)

55

1.7.3. Classification Societies to the verification regime

The verification of conformity with GBS is a significant issue for the main classification

societies over the world and represents for them both opportunities and challenges.

As the GBS requirements become mandatory, the rules of some classification

societies need be verified as conforming with GBS. If that is not the case, they will lose

the right to employ their own rules for the construction of bulk carriers and oil tankers

of 150m or longer. On the other hand, if some classification societies’ rules get

through the audit while others do not, the former will gain a competitive advantage in

the ship-building market. Therefore, the verification audit can be seen as an

opportunity for some advanced classification societies to demonstrate their technical

competence and eliminate their opponents. Thus, the implementation of GBS can be

seen as the establishment of a new order in the classification market.

Table 4. IACS vs world fleet 2014Source: Equasis. The world merchant fleet in 2014. Statistics from Equasis, 2014.

Goal based Standards – A new theoretical safety approach

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Illustration 11. World vs IACS fleet 2014Source: Equasis. The world merchant fleet in 2014. Statistics from Equasis, 2014.

In the current ship building market, largest ships are under the class of IACS members,

and among these ships, slightly over a 20% of the bulk carriers and oil tankers of 150m

or larger are designed and constructed in conformity to the IACS HSR and are under a

IACS member.

1.7.4. Controversial issues in the verification of conformity

When talking about the GBS verification of conformity and its implementation, the

guidelines for verification of conformity with the GBS, including the correct procedure

and the criteria to follow, will play a key role during the conduct of rule verification.

Some controversial issues were found while developing the guidelines. These were

discussed and finally agreed in the current adopted guidelines.

1.7.4.1. Self-assessment process for verification

The first controversial issue was whether to adopt a self-assessment-based

verification process or a full assessment by the IMO Group of experts. Some

delegations had opposing views regarding this issue. It was believed by some that a

Chapter 1. Goals Based Standards (GBS)

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self-assessment model would ensure the transparent technological and state-of-art

development of classification rules and the efficient use of the resources. For others,

carrying out a full assessment by the IMO auditors would ensure a reliable and

effective verification16.

When talking about costs, the self-assessment approach is considered more

reasonable because of three key facts. Firstly, the cost of a full assessment by the IMO

is very high. The estimate indicates that the cost of one Group of Experts verifying just

one set of structural rules would be around of US $300000. If the scope of GBS

expands to all structural rules, the cost will be hundreds of times higher or more

Secondly, it is really difficult to “scrutinize the work of hundreds of experts done over

several years with a handful of other experts in just a few weeks”, and “the availability,

number and quality of such independent experts is most likely not sufficient to

manage the verification in a reasonable time frame”17. Thirdly, in the legal field, as

IMO settled out the goals and functional requirements, it is the rule developer’s duty

to ensure that construction standards comply with rules. If this is done by audit teams,

the classification societies would waive their responsibility.

Taking into account these three issues, the MSC finally adopted the self-assessment

approach. As the key point of taking such decision and implementation is

practicability, it is accepted to be a wise choice. In all processes being at the first stage

of implementation, it is meaningful to make it easy and practical in order to enhance

it.

16 International Maritime Organization. (2009d. June 12). Report of the Maritime Safety Committee (MSC86/26). London.17 International Maritime Organization. (2009b, p. 5. February 24). Goal-based new ship constructionstandards. Report of the correspondence group. Submitted by Germany (MSC 86/5/2). London.

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1.7.4.2. Funding mechanism

When it comes to funding, it is always problematic to decide who should bear the

expenses. Choices were among IMO itself, rule submitters or the nominating

governments. According to the costs estimated by IACS18, a team of five auditors

working 15 days, an initial verification of one rule set would approximately cost US

$50000.

The MSC 87 reached an agreement by which “the submitter of a request for

verification should pay an audit fee of US $50000 into a GBS Trust Fund to be

established at IMO”. The GBS Trust Fund was approved by the 104th session of IMO

Council. Besides the Expert Group, it was also agreed that “a professional officer and

an administrative assistant should be made available in the Secretariat for the

implementation of the verification scheme”.

This arrangement put a new financial question; who should cover the cost of the two

additional jobs? As always, there were two opposite solutions. One proposed that the

regular budget of the IMO Secretariat covered the expense, the other that the rule

submitters would pay an extra amount. Considering all the advantages and

disadvantages, the Council approved that the expenses of the two new jobs could be

undertaken by the existing staff so there was no need for new recruitment.19

Bearing in mind all the decisions taken, such as that the cost of the Expert Group

being paid by the rule submitters and the cost of IMO staff covered within the

Secretariat budget, a balance between the stakeholders was reached. Taking a

18 Maritime Organization. (2010a, January 18). Goal-based new ship construction standards. Resourcerequirements and timing of GBS verification audits. Note by the Secretariat (MSC 87/5/2). London.19 International Maritime Organization. (2010e, May 28). Consideration of the report of the maritimesafety committee. Note by the Secretary-General (C104/8). London.

Chapter 1. Goals Based Standards (GBS)

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proper funding regime is essential for the successful conduct of the verification

scheme, as it may affect the long-term economic aspect of the new system. For the

time being, it seems that the adopted funding regime is feasible, but it must remain

open to future adjustments due to the learning process.

1.7.4.3. Certification during the verification process

The third and last issue was whether the Cargo Ship Safety Construction Certificate

could be issued when a ship’s construction is under an amended rule during the

verification process. The United Kingdom pointed out in its proposal based on the

revised SOLAS II-1/3-10, that a ship designed and built to a rule amendment which is

at the time going through the verification process, should not be issued with a valid

Cargo Ship Safety Construction Certificate. Furthermore, if rule amendments were

reviewed based on a five-year collecting period, this would result in a serious negative

effect on the development of rules20. The MSC considered this concern and finally

agreed on an annual verification regime, in which an aim of 10% of the rule change

would be selected for verification by IMO audit team every year.

Using an annual verification scheme instead of the 5-year basis can avoid conflicts

between the SOLAS requirements on the certificate and the development of rules.

Based on the annual verification scheme, the period during which rules are revised by

classification societies but waiting for the outcome of verification by IMO has been

reduced to an acceptable span which is estimated around 1 or 2 months, so that the

rule development will not be obstructed by waiting for a time-consuming process.

20 International Maritime Organization. (2009c, September 9). Goal based New Ship ConstructionStandards. Guidelines for verification of conformity with goal-based ship construction standards for bulkcarriers and oil tankers. Note by the Secretariat (MSC 87/5/1). London.

Goal based Standards – A new theoretical safety approach

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However, the annual verification would only be applied on a 10% of total rule changes,

and that leads to another problem. Aiming only that percentage on the verification

regime for maintenance of conformity while being selective, means that only a small

portion of rules will be audited. Therefore, there may be liability issues involved in the

decision-making method to choose the rules to be audited. For that reason, another

mechanism was established by which the administrations were allowed to request

IMO to conduct a review when they realize there may be non-conformity in the new

rules. It was also agreed during these discussions that the Organization would retain

the flexibility to vary the actual percentage of the rule conformity verification over

time.

The foregoing solution was also based on a practical consideration, given the

workload and the resources with regards to GBS implementation. The development

of new rules involves a huge amount of expertise, which is usually the business of

classification societies through their long-term technical experience.

The verification process will be a long-term task for IMO to arrange and update,

including not only the initial verification but also maintenance verification, a steady

and routinely task that will most likely never cease. Furthermore, the regime will be

expanded to all aspects related to ship safety, security and environmental protection.

The future workload will increase to a vast level. Therefore, how to conduct the

verification in a cost-effective and resource-effective way is a key point to achieve

successful implementation. It is widely recognized that IMO will find difficulties to

find enough impartial and well qualified experts in GBS auditing, so the selective

regime would help a lot to reduce the total workload for maintenance verification in

the long run. As far as the liability issue is concerned, it is clear that it should be the

rule submitter’s responsibility to guarantee the conformity to GBS of their rules.

Considering the practical aspects, the selective regime, as employed in the Port State

Chapter 1. Goals Based Standards (GBS)

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Control regime, might be the only acceptable mode to carry out a long-term

operation.

1.8. Ship construction file (SCF)

In accordance with SOLAS II-1/3-10.4, a Ship Construction File (SCF) shall be provided

upon delivery of a new ship and kept on board and/or ashore while being updated as

appropriate throughout the ship’s service. It should contain specific information on

how the functional requirements of the Goal-Based Ship Construction Standards for

Bulk Carriers and Oil Tankers have been applied in the ship design and construction.

The contents of the Ship Construction File shall, at least, conform to the guidelines

developed by the Organization (MSC.1-Circ.1343). Please see: ¡Error! No se

encuentra el origen de la referencia..

Summary:

i. Introduction

ii. Definitions

iii. SCF Information (Scope, format, IP levels, Location)

iv. Management of SCF information (Preparation, Acces/Safekeeping, archive)

v. Revision of the Industry Standards

1.8.1. Scope of its information

The documents and information constituting SCF should be the ones required for a

ship's safe operation, maintenance, survey, repairs and in emergency situations.

Other details or specific information not considered to be critical to safety might be

included directly or by reference to other documents.

The SCF should model a balance objective of design transparency (information

presented and practical access to it) coupled with safeguarding intellectual property

protection. Reaching that way an equality among the stakeholders’ interests.

Goal based Standards – A new theoretical safety approach

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1.8.2. Availability and storage

The SCF should remain onboard and must be available to its classification society and

flag State throughout the ship's life. The information not considered necessary to be

onboard can be stored ashore, and procedures to access this information should be

specified in the SCF onboard. The SCF should duly comply with the Intellectual

property provisions. Depending on the documents’ IP Level, which can be Ordinary or

High, their access need be managed by the shipowner on a day-to-day basis or may be

kept on shore. All the files kept ashore, since they have a high IP level, require an

access request, and their copies must be either returned or destroyed.

Table 5. List of documents in the SCFSource: Skovbakke Juhl, J. (2016) Goal Based Standards – Ship Construction File: Industry Standards (IS)

[PowerPoint slides]. BIMCO.

Chapter 1. Goals Based Standards (GBS)

63

Finally, the SCF should be updated throughout the ship's life at any major event,

including, substantial repair and conversion, or any modification to the ship structure.

Illustration 12. SCF availability and storageSource: Sören Marquardt, Dr. R. (2015) Ship Construction File (SCF): Status Report on the Development of

SCF Industry Standard (co-ordinated by CESA) [PowerPoint slides].

Goal based Standards – A new theoretical safety approach

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Chapter 2. Risk vs Goals (FSA/GBS)As previously commented, the international shipping industry has been moving from

a reactive to a proactive approach to safety through what is known as ‘Formal Safety

Assessment’ (FSA). The most recent implementation of ‘Goal Based Standards’ (GBS)

approach has become another proactive instrument. Therefore, discussions have been

taken place at the IMO in regards with the possible links between the FSA and the

GBS.

Since SLA is a risk-based approach (RBA), this chapter will first introduce the FSA to

provide a better understanding of the SLA. The FSA is, currently, a tool used for

proposed new rules and nowadays is being used within the Safety Level Approach to

GBS.

2.1. FSA

As IMO defines it: “Formal Safety Assessment (FSA) is a structured and systematic

methodology, aimed at enhancing maritime safety, including protection of life,

health, the marine environment and property, by using risk analysis and cost-benefit

assessment.”

This methodology is a tool to help in the evaluation of new regulations for maritime

safety and protection of the marine environment or in making a comparison between

existing and possibly improved regulations. One of the main ideas is to achieve a

balance between the various technical and operational issues, including the human

element, and between maritime safety or protection of the marine environment and

costs.

Chapter 2. Risk vs Goals (FSA/GBS)

65

The FSA methodology can be applied by a Member Government or an organization in

consultative status with IMO, Committee, or an instructed subsidiary body for the

purposes previously described. It is not intended that FSA should be applied in all

circumstances. In order to apply this methodology, a five steps guideline should be

followed, as it is reproduced in ¡Error! No se encuentra el origen de la referencia.:

Illustration 13. Flow Chart of the FSA methodologySource: Revised Guidelines for Formal Safety Assessment (FSA) for use in the IMO rule-making process.

MSC-MEPC.2/Circ.12/Rev.1. 18 June 2015.

2.1.1. Step 1: HAZID

There are two main objectives of the Hazid Identification:

a) To identify all potential hazardous scenarios which could lead to significant

consequences.

Goal based Standards – A new theoretical safety approach

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b) To prioritize them by risk level.

Using a combination of creative and analytical methods, aiming to identify all relevant

hazards, the first objective can be satisfied. Using the creative part to ensure that the

HAZID process is more proactive rather than solely confined into hazards that have

occurred in the past.

To rank the hazards and to discard scenarios judged to have minor significance is the

second objective. Typically ranking is a task undertaken by expert judgment using

available data and modelling. Therefore, a group of experts develops a ranked list

starting with the most severe threat. For that purpose, they use a risk matrix which

divides the dimensions of frequency and consequence into categories, giving a form of

evaluation or ranking of the risk that is associated with that hazard.

The Hazard and Operability (HAZOP) study is a method of identifying hazards that

could possibly affect to the safety and operability of the ship, based on the use of

guidewords. It is usually carried out by a team built from professionals of different

fields of the system under the guidance of an independent leader. A standard list of

guidewords is used to prompt the experts to identify deviations from design intent.

For each plausible deviation, experts should consider possible causes and

consequences, and most important, if additional safeguards should be recommended.

From all that a report come out in a standard format. HAZOP is on the top of the most

commonly used HAZID techniques. A typical example of HAZOP is shown in Table 6.

Chapter 2. Risk vs Goals (FSA/GBS)

67

Table 6. Example of HAZOP Analysis [ABS,2003]Source: Kontovas, C.A. Formal safety assessment: Critical review and future role. Psaraftis, H.N. National

technical university of Athens, School of naval architecture & marine engineering. July 2005.

2.1.2. Step 2: Risk analysis

In step 2, a Risk analysis is carried out. It consists in a detailed investigation of the

causes, initiating events and consequences of the more important accident scenarios

identified previously. For that purpose, several techniques that model the risk are

used. Therefore, the attention can be easily focused upon high-risk areas and will

allow the identification and evaluation of the factors influencing the risk level. Be that

as it may, Risk analysis on ships is much more difficult to perform than for stationary

structures. Calculating probabilities and consequences is not an easy task. The most

difficult part of the Risk analysis is translating these into risk acceptance criteria for all

failure modes.

2.1.3. Step 3: RCO’s (Risk Control Options)

The main purposes of step 3 are:

a) Identify Risk Control Measures (RCMs)

Goal based Standards – A new theoretical safety approach

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b) Group them into a limited number of Risk Control Options (RCOs) for use as

practical regulatory options.

This step comprises four stages which are:

i. Focusing on risk areas needing control

ii. Identifying potential RCMs

iii. Evaluating the effectiveness of the RCMs in reducing risk by re-evaluating step

2

iv. Grouping RCMs into practical regulatory options.

Step 3 aims creating a series of risk control options that address both existing risks

and risks introduced by new technologies or new methods of operation and

management. Both historical risks and newly identified risks (from steps 1 and 2)

should be considered, producing a wide range of risk control measures. Techniques

designed to address both specific risks and underlying causes should be used.

2.1.4. Step 4: Cost-benefit assessment

The purpose of this assessment is to identify and compare benefits and costs

associated with the implementation of each RCO identified and defined in the

previous step. For instance, a cost-benefit assessment may consist of the following

stages:

a) Consider the risks assessed in step 2, both in terms of frequency and

consequence, in order to define the base case in terms of risk levels of the

situation under consideration.

b) Arrange the RCOs, defined in step 3, in a way to facilitate understanding of the

costs and benefits resulting from the adoption of an RCO.

c) Estimate the pertinent costs and benefits for all RCO’s.

d) Estimate and compare the cost-effectiveness of each option, in terms of the

cost per unit risk reduction by dividing the net cost by the risk reduction

achieved resulting of the RCO implementation.

Chapter 2. Risk vs Goals (FSA/GBS)

69

e) Rank the RCOs from a cost-benefit perspective in order to facilitate the

decision-making recommendations in step 5 (e.g. to screen those which are

not cost-effective or impractical).

Costs should be expressed in terms of life cycle costs and may include initial,

operating, training, inspection, certification, decommission, etc. On the other hand,

benefits may include reductions in fatalities, injuries, casualties, environmental

damage and clean-up, indemnity of third party liabilities, etc. and an increase in the

average life of ships. Therefore, we would have a great tool to compare the results.

In order to compare RCO’s in a cost-effectiveness way, several indices may be used.

For instance, the indices expressing cost-effectiveness in relation to safety of life such

as Gross Cost of Averting a Fatality (Gross CAF) and Net Cost of Averting a Fatality

(Net CAF) as described in ¡Error! No se encuentra el origen de la referencia.. It does

exist other indices based on damage and effect on property and environment, but

them may be used for a cost-benefit assessment relating to such matters.

∆C = cost per ship of the RCO under consideration.

∆B = economic benefit per ship resulting from the implementation of the RCO.

∆R =risk reduction per ship, in terms of fatalities averted, implied by the RCO.

GCAF = ∆C/∆R

NCAF = (∆C-∆Β)/∆R

2.1.4.1. The $3 Million criterion

The dominant yardstick in all the FSA studies that have been submitted to the IMO

thus far is the so-called “$3m criterion”, as described in document MSC78/19/2.

According to this, in order to recommend the RCO for implementation (covering risk

of fatality, injuries and ill health) this must give a CAF value – both NCAF and CGAF –

of less than $3 million. If this is not the case, the RCO is rejected.

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2.1.5. Step 5: Recommendations

The last step defines recommendations and they should be presented to the relevant

decision makers in an auditable and traceable manner. The recommendations would

be based upon the comparison and ranking of all hazards and their underlying causes;

the comparison and ranking of risk control options as a function of associated costs

and benefits; and the identification of those risk control options which keep risks as

low as reasonably practicable.

A key point on the recommended RCO(s) is that they should be submitted in SMART

(specific, measurable, achievable, realistic, and time-bound) terms and accompanied

with the application of the RCO(s).

Recommendations should be presented in a form that can be understood by all parties

irrespective of their experience in the application of risk and cost-benefit assessment

and related techniques. There are several standards for risk acceptance criteria, none

as yet universally accepted.

Illustration 14. Information flow chart in a FSA studySource: Kontovas, C.A., Psaraftis, H.N. and Zachariadis, P. Risk based rulemaking and design – Proceed

with caution. RINA conference on Developments in Classification and International Regulations.London, UK: Rina, January 2007

Chapter 2. Risk vs Goals (FSA/GBS)

71

2.2. Comparison between GBS & FSA

As far as observed, there shall not be a question that risk-based principles are the

central approach for modern maritime safety regulation. Although GBS and FSA have

been developed thus far in parallel, many linkages between them exist. That is the

main reason why naturally the FSA arsenal is being used in GBS. Despite that fact,

there are also few differences to bear in mind.

The following table analyses the complementarity between the two methodologies. .

Table 7. GBS – FSA RelationsSource: Rodrigo de Larrucea, J. Hacia una teoría general de la Seguridad Marítima. 1st Edition.

Barcelona, Spain: Ediciones Gráficas Rey, 2015. ISBN: 9788461736232.

Goal based Standards – A new theoretical safety approach

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At MSC 80 the linkage between the GBS and FSA was discussed. The working group

on FSA agreed that, generally, the FSA process could be used to:

Conduct holistic assessments with a view to establishing the level of risk and

set goals accordingly.

Identify and/or formulate high-level goals and functional requirements.

Support high-level goals to determine associated hazards and develop

appropriate risk control options.

Assess specific issues to determine associated hazards and associated risks and

develop appropriate risk control options.

Identify inherent safety levels in existing standards and, from that, make

explicit the inherent risk acceptance criteria.

Verify compliance of regulations with high-level goals and functional

requirements

Find gaps in functional requirements.21

These conclusions have not yet been elaborated in detail within the GBS

development. It is easily recognizable that GBS forms a rational structure and FSA a

rational methodology. “The purpose of FSA is to assess risks and identify the most

effective risk control options. At a high-level, the first part, risk assessment, is also a

necessity for defining the GBS functional requirements, and the second part may

precisely be the needed verification that rules and regulations are effective to keep risk

ALARP (As Low As Reasonable Practicable). Therefore, the FSA methodology in general

21 International Maritime Organization. (2007, July 3). Goal-based new ship construction standards.Report of the Correspondence Group on Safety Level Approach. Submitted by Germany (MSC 84/5/3).London.

Chapter 2. Risk vs Goals (FSA/GBS)

73

can be seen as fundamental for the development of requirements at different levels

within a rational GBS structure”.22

The real link of the FSA with GBS lays in the risk acceptance criteria for individual

failure mode, if it does not exist it is impossible to talk about linkages. Since the GBS

deals with individual failure modes, a total “safety level” number as the goal must be

developed and agreed. In order to do that a risk acceptance criterion needs to be

developed for the individual failure modes. The human element must be incorporated

in the analysis in quantifiable terms. All the elements placed at the top of the pyramid

as a goal must be linked through a clear and transparent process all the way down to

ship level. Thus, the safety requirements must be linked clearly to the technology

requirements for the design and construction of the ship.

But there are some glitches in the FSA, that should be rectified before applying the

SLA in GBS. Therefore, the possible differences found in those glitches are:

a) HAZID deficiencies – There is a glitch on the individual risk acceptance since

the use of historical data found in databases is not a proactive approach given

that it cannot measure the newly effects of implemented risk control options.

b) Cost-benefit assessment deficiencies – As it involves numerous assumptions

on a great number of variables, there is room for risks resulting in wrong

conclusions.

Extreme caution must be taken in calculating ΔR, ΔB, ΔC. Also, the GCAF

should have a hierarchically higher priority than NCAF. Just examine NCAF,

only if GCAF satisfies criterion. Specially caution with NCAF if <0.

22 Huss, M. Status at IMO: where are we heading with goal-based standards? SAFEDOR – The Mid TermConference, May 2007.

Goal based Standards – A new theoretical safety approach

74

c) Tolerable risk level deficiencies - The final step of the FSA as commented is

aimed at giving recommendations to the relevant decision makers for safety

improvement taking into consideration the findings during all four previous

steps. The problem lays in deciding what is the tolerable risk level. (See ALARP

principle).

d) Environmental criteria deficiencies – Lately it has become a very important

issue. So far, no FSA study has tried to assess environmental risks.

Environmental damage and clean-up costs vary tremendously depending on

which part of the world the spill occurred. SAFEDOR developed an index called

Cost to Avert one Tonne of Spilled oil (CATS). But it is unrealistic, and its value

could be further improved as gaining knowledge and creating a detailed oil

spill cost database, so further work in this area should be done. These is due to

a broad multitude of factors entering into damage estimation of oil pollution,

for instance the type of oil, location of the spills, the clean-up, the loss in the

ecosystem services, fisheries and tourism impact. Thus, the adoption of any

single figure is bound to be problematic.

e) The risk index deficiencies – In FSA “Frequency” is used instead of

“probability”, but frequency is not the same as probability, as it may only be

true if the historical data sample is large. Anyway, basing analysis on historical

data is not a proactive approach. Therefore, now the risk index is assigning

more importance to high-frequency and low-consequence events, and less to

low-frequency and truly catastrophic events, that leads to promulgated

regulations that may be tailored considering the risks previous described. The

correct one should cover both cases, and the risk should be assigned duly.

Note the definition of risk as the product of two variables. This definition

collapses when confronted against the two main determinants of an inherently

two-dimensional concept such as risk (probability and consequence) into a

single number. By doing so, it loses much of the relevant information and may

lead to some nonsensical results.

Chapter 2. Risk vs Goals (FSA/GBS)

75

f) Environmental Risk Index – In the FSA, the consideration of the

consequences and frequencies of hazards is usually carried out by the so-called

risk matrices, which rank risk in order of significance. There is a current used

Frequency Index (MSC Circ.1023, MEPC Circ.392), that can be used for

assessing environmental risk. However, the current Severity Index deals only

with injuries or fatalities on human safety and the ship itself, so a proper

Severity Index that measures effects on the environment has to be developed

and defined, and this is not an easy task.

The IMO continues to work on the GBS methodology and aspires to remove many of

the current shortcomings of the scientific approach to maritime safety. For that

purpose, all the glitches in the SLA need to be removed.

2.2.1. ALARP Principle

The ALARP principle is a tool developed by the IMO created to solve the problem on

deciding the Tolerable Risk Level.

From the IMO’s FSA guidelines, adopted in 2002, amended in 2006, the maximum

annual tolerable risk of death:

For crew members: 1/1,000

For passengers: 1/10,000

For third parties or public ashore: 1/10,000

Negligible risk: 1/1,000,000

These numbers are only indicative; no international organization has yet reached a

conclusion on what the values of these numbers should be. Therefore, the crucial issue

of what are acceptable risk criteria for the safety of maritime transport is still very

much open.

Goal based Standards – A new theoretical safety approach

76

Illustration 15. ALARP PrincipleSource: Kontovas, C.A., Psaraftis, H.N. and Zachariadis, P. The two C’s of the Risk-Based Approach to

Goal Based Standards: Challenge and Caveats. International Symposium on Maritime Safety, Securityand Environmental Protection, Athens, Greece, 20-21 September 2007.

2.3. Relation between GBS-SLA and FSA

Previous discussion about the relation between the GBS and the FSA can be the basis

of the relation between the GBS-SLA and the FSA. The relation is shown in Illustration

16, while the application of the FSA elements in the GBS-SLA development process is

presented in Illustration 17, even though it still needs further development, which will be

discussed in Further work in SLA-GBS6.1.2 Further work in SLA-GBS.

Chapter 2. Risk vs Goals (FSA/GBS)

77

Illustration 16. Flow chart characterizing the relation between GBS-SLA and FSASource: Goal-based new ships construction standards: development of interim guidelines for the safety-level approach (SLA) to the IMO rule-making process. Submitted by Germany and Netherlands. MSC

95/5/2 (3march 2015) Annex page 9.

Goal based Standards – A new theoretical safety approach

78

Illustration 17. Flow chart of the SLA frameworkSource: Goal-based new ships construction standards: development of interim guidelines for the safety-level approach (SLA) to the IMO rule-making process. Submitted by Germany and Netherlands. MSC

95/5/2 (3march 2015) Annex page 10.

Chapter 3. Alternative procedures on the current Safety Regulations

79

Chapter 3. Alternative procedures on the current Safety

RegulationsAs commented, the ongoing debate on GBS at IMO resulted into a new regulatory

framework for shipping. The goal-based standards will not be yet related to risk-

based design and approval of individual ship designs. However, there are strong

arguments for developing a generic approach to GBS in line with the philosophy of

risk-based approaches in design and approval of ships.

Currently, there are provisions in many IMO conventions for acceptance of

alternatives to prescriptive requirements in many areas of ship design and

construction which can pave the way for risk-based approaches to ship design and

approval.

In the International Convention for the Safety of Life at Sea (SOLAS), 1974, as

amended, there are general provisions for equivalents in regulation 5 of

chapter I. Furthermore, the new regulation 17 of chapter II-2 provides a

methodology for alternative design and arrangements for fire safety.

Past amendments to SOLAS, adopted by resolution MSC.216(82), which

entered into force on 1 July 2010, provide similar methodologies for alternative

design and arrangements of machinery and electrical installations (new

regulation II-1/55) and for life-saving appliances and arrangements (new

regulation III/38). Moreover, extended use of systems-, risk- and reliability

analyses is being required in order to demonstrate fulfilment of the

performance standards for safe return to port of passenger ships required by

new SOLAS regulations II-1/8-1, II-2/21.4, II-2/21.5.1.2 and II-2/22.3.1 – all

related to the safe return to port agenda item – as adopted by resolution

MSC.216(82).

The International Convention for the Prevention of Pollution from Ships

(MARPOL), regulation I/5, contains general provisions on equivalents similar to

Goal based Standards – A new theoretical safety approach

80

those found in SOLAS regulation 5 of chapter I. Furthermore, regulation

I/19(5) provides for the acceptance of alternative oil tanker design provided

that at least the same level of protection against oil pollution in the event of

collision and stranding compared to prescriptive design is ensured.

The International Convention on Load Lines (LL) contains provisions on

equivalents (article 8) and approvals for experimental purposes (article 9).

IMO has issued several guidelines on the analyses required by such regulations on

alternative design and arrangements. MSC/Circ.1002 provides guidelines on

alternative design and arrangements for fire safety, MSC.1/Circ.1212 provides

guidelines on alternative design and arrangements for SOLAS chapters II-1 and III, and

resolution MEPC.110 (49) adopted interim guidelines for the approval of alternative

methods of design and construction of oil tankers.

The MSC/Circ.1023–MEPC/Circ.392 circulars, with a consolidated text incorporating

the amendments adopted by MSC 80 and MSC 82 contained in MSC 83/INF.2, provide

guidelines for the application of the Formal Safety Assessment (FSA) in the IMO rule

making process. A number of FSA studies that have been submitted to IMO have

demonstrated the applicability of risk-based approaches in rule development, many of

which have been based on work carried out within SAFEDOR (e.g., generic FSAs on

LNG carriers, container ships, oil tankers, cruise ships and ro-ro passenger ferries).

The FSA studies were performed to document the risk level of various standard ship

types for future reference in risk-based ship design.

Thus, documentation related to risk-based design and approval of ships is available at

IMO level, albeit somewhat fragmented.

Alternative designs and approval are already made possible by existing IMO

regulations, not complying with the prescriptive requirements contained in the

chapter based to set the arrangements. What had been missing was a unified process

Chapter 3. Alternative procedures on the current Safety Regulations

81

for the practical application of risk-based approval, applicable regardless of the type

of project, which now is taking place.

3.1. SOLAS Chapter II-2

One example of the alternatives is the completely revised SOLAS chapter II-2 on

Construction - Fire protection, fire detection and fire extinction, which was completed

in 2000, and entered into force on 1 July 2002.

“Changing radically to a newer approach regarding the preparation of amendments to

SOLAS, regulation 2 of the revised chapter (Fire safety objectives and functional

requirements) contains sections on fire safety objectives, functional requirements and

achievement of the objectives. Even though the chapter II-2 regulations still contain

prescriptive requirements, each regulation now has a purpose statement and

functional requirements to assist port and flag States in resolving matters which may

not be fully addressed in the prescription requirements.

The revised chapter II-2 also contains a regulation on Alternative Design

Arrangements (regulation 17) which allows deviation from the prescriptive

requirements in the chapter by stipulating:

“Fire safety design and arrangements may deviate from the prescriptive

requirements set out in parts B, C, D, E or G, provided that the design and

arrangements meet the fire safety objectives and the functional

requirements.

When fire safety design or arrangements deviate from the prescriptive

requirements of this chapter, engineering analysis, evaluation and approval of

the alternative design and arrangements shall be carried out in accordance

with this regulation.”

Goal based Standards – A new theoretical safety approach

82

3.2. Application of the alternative options

The main purpose of these guidelines and amendments is that they could be applied

in the field when necessary in order to approve the risk-based ships projects.

Specifically, when the project approval is in accordance with the provisions and the

applicable laws and regulations prescribed by this approach. Since the project might

be alternative, differing from what prescriptive rules are stipulating, these guidelines

could be used to expose the methodology related to the risk-based verification

process.

Chapter 3. Alternative procedures on the current Safety Regulations

83

Illustration 18. Risk-based standards application visual diagram.Source: Rodrigo de Larrucea, J. Seguridad marítima: Teoría general del riesgo. 1st Edition. Barcelona,

Spain: Marge Books, 2015. ISBN: 9788416171002.

Goal based Standards – A new theoretical safety approach

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During the process of implementing the guidelines, the project measures replacement

should be taken into account in order to reduce the risk by means of operational or

procedural measures. Usually this process is not allowed. Therefore, for the purpose

of ensuring that the project measures have priority over operational measures, special

caution must be taken.

In order to apply the alternative options satisfactorily, all interested parties, for

instance, the Administration or their designated representatives, proprietary

companies and operators, designers and classification societies, should maintain a

fluid and transparent communication from the start of a specific proposal to use the

guidelines. It is vital to have an adequate amount of time to dedicate to the

calculations and the relevant documents. There are various benefits such as getting

effective projects based on costs for unique applications and improved knowledge of

possible losses in it, as well as a wide range of options for developing the project.

3.3. The SAFEDOR project

The SAFEDOR project is an integrated project in the 6th Framework Programme of

the European Commission (EC). It was initiated on February 2005 with a duration of 4

years, finished in 2009. With a total budget of €20 million, of which €12 million were

funded by EC, SAFEDOR represented one of the largest collaborative European

projects ever launched in the maritime sector focusing on ship safety. Altogether,53

partners representing all stakeholders of the maritime industry contributed to the

project under the coordination of Germanischer Lloyd (GL), a leading classification

society. The vision of the SAFEDOR was to enhance safety through innovation to

strengthen the Competitiveness of the European Maritime Industry. To pursue this,

the main idea was risk-based ship design and approval as safety concept. The risk-

based ship design describes the integration of safety as a goal in the ship systems and

design process in order to minimize the risk, alongside the traditional goals, such as

minimizing power requirements and maximized the cargo load. The risk is used as a

Chapter 3. Alternative procedures on the current Safety Regulations

85

measure to evaluate effectiveness of design changes with regard to safety. And the

risk-based approval is the process of approving the risk-based ship design and their

intended operation. The objectives of the current safety standards are compared but

considering alternative compliance options.

There were several motivations in order to use the risk-based approach. First of all,

new solutions or alternatives that are safe but cannot be approved due to current

regulations can be implemented. Secondly, optimize an existing solution which is on

the way to being approved.

Illustration 19. The SAFEDOR roadmapSource: Sames, P. C. (2007). Risk-based ship design, approval and operation [PowerPoint slides].

Initially, it was decided to focus only on the four most representative types of vessels

with greater economic significance for Europe: cruises, ro-ro / ro-pax, gas tankers and

container ships. Later on, it also included oil carriers.

Goal based Standards – A new theoretical safety approach

86

It was expected that these ships and its technology would be highly enhanced due the

new breakthroughs regarding novel systems and new ship designs. To succeed, it was

necessary to establish a risk-based regulatory framework that links performance

prediction with risk assessment and also a new design approach that includes safety

as an objective. With the application of state-of-the-art first-principle analysis tools

within an integrated and holistic design approach, a balance between costs, safety

and performance can be achieved optimally analyzing cost-effectiveness of safety-

enhancing measures. In the end, risks are reduced to as low as reasonably practical

whilst accounting for other design priorities and constraints. Also, by eliminating

regulatory restrictions new doors opened to innovative design, leading to more

competitiveness among the ship yards. So, with a proof safety compliance becoming

more complex, patenting new solutions becomes more attractive. This leads to a big

benefit for ship owners and operators from improved economics of novel solutions.

SAFEDOR project partners presented their results and conclusions at a final

conference held at the IMO headquarters in London in April 2009. The final

conference presented the fruits of all the collaborative research project by a

consortium of 53 organisations from 14 European countries23, including professionals

from the whole spectrum of the maritime industry, as well as the European

Commission and representatives of the media. The great practical and realistic

contribution of SAFEDOR, available to any interested party, is the development of a

typology of risks and hazards (HAZID: Hazard Identification) by type of vessel, which

is an essential reference for its rigor and quality, taking into account the risk of the

23 SAFEDOR: Design, Construction and Regulation for SAFETY. Final Conference, IMO London 27-28April 2009.

Chapter 3. Alternative procedures on the current Safety Regulations

87

vessel and its operation. It is a fundamental step in the treatment of maritime safety

risks in initial phases of ship design and will be the first step of FSA.

SAFEDOR developed a new methodology integrating probabilistic and risk-based

approaches in the design and approval processes for ships and its systems. Safety is

included as an additional quantified design objective – along traditional performance

requirements like speed, capacity, endurance etc. And risk is used as measure to

evaluate the effectiveness of design changes with respect to safety.24

SAFEDOR today is often associated with Goal-Based Standards (GBS) although key

differences exist. The IMO debate on GBS will result in a new framework which is then

applicable to rule makers. The GBS will be rules setting the bases for developing other

rules. SAFEDOR focuses on individual ship design and the necessary regulatory

framework to approve risk-based ships and systems. However, knowledge gained in

SAFEDOR can also be used to create risk-based rules for ships and ship systems and to

support the development of the so-called Safety-Level Approach to GBS.25

24 SAFEDOR: About SAFEDOR. http://www.safedor.org/about/index.htm

25 Idem 16.

Goal based Standards – A new theoretical safety approach

88

Chapter 4. Implementation/applicationSince the GBS regime has progressed to the implementation stage, it is really

important to know how, and to follow the stablished schedule early presented.

For the implementation of GBS, a five-level system was settled out, following a

proposal by the Bahamas, Greece and IACS at MSC78. The Committee also agreed

that the first three tiers constitute the goal-based standards to be developed by IMO,

whereas Tiers IV and V contain provisions developed/to be developed by classification

societies, other recognized organizations and industry organizations.

Tier I – Goals

• A set of goals to be met in order to build and operate safe and

environmentally friendly ships.

Tier II - Functional requirements

• A set of requirements relevant to the functions of the ship structures to

be complied with in order to meet the above-mentioned goals.

Tier III - Verification of compliance criteria

• Provides the instruments necessary for demonstrating that the detailed

requirements in Tier IV comply with the Tier I goals and Tier II

functional requirements.

Tier IV - Technical procedures and guidelines, classification rules and industry

standards

• The detailed requirements developed by IMO, national Administrations

and/or classification societies and applied by national Administrations

and/or classification societies acting as Recognized Organizations to

Chapter 4. Implementation/application

89

the design and construction of a ship in order to meet the Tier I goals

and Tier II functional requirements.

Tier V - Codes of practice and safety and quality systems for shipbuilding, ship

operation, maintenance, training, manning, etc.

• Industry standards and shipbuilding design and building practices that

are applied during the design and construction of a ship.

Illustration 20. Five Tier system

Goal based Standards – A new theoretical safety approach

90

Source: Rodrigo de Larrucea, J. Hacia una teoría general de la Seguridad Marítima. 1st Edition.Barcelona, Spain: Ediciones Gráficas Rey, 2015. ISBN: 9788461736232.

In the five-tier structure of the framework, as the pyramid of the ¡Error! No se

encuentra el origen de la referencia. show, the higher-level tiers govern the lower

ones, and these serve and support the upper ones in general.

Illustration 21. Goal-Based Standards FrameworkSource: Generic Guidelines for developing IMO Goal-Based Standards. MSC.1/Circ.1394/Rev.1. 22 June

2015.

As far as the implementation is concerned, the guidelines for verification of

conformity with GBS including the procedure and the criteria will play a key role

during the conduct of rule verification. During the development of the guidelines,

several considerations addressing the practical issues were discussed and finally

agreed in the adopted guidelines.

Chapter 4. Implementation/application

91

Illustration 22. The coverage of GBS in the maritime fieldSource: Peng, Y. An analysis of the implementation and future development of IMO Goal-based

standards. Master of Science in Maritime Affairs. Malmö, Sweden: World Maritime University, 2011.

4.1. Goals (Tier I)

On the MSC 80 meeting it was agreed in principle with the established Tier I goals,

applicable to all types of new ships. The goals defined in the Tier I are stablished in the

standard II-1/3-10 of the SOLAS as follows:

“Ships are to be designed and constructed for a specified design life to be safe and

environmentally friendly, when properly operated and maintained under the specified

operating and environmental conditions, in intact and specified damage conditions,

throughout their life.

Goal based Standards – A new theoretical safety approach

92

1. Safe and environmentally friendly means the ship shall have adequate

strength, integrity and stability to minimize the risk of loss of the ship or

pollution to the marine environment due to structural failure, including

collapse, resulting in flooding or loss of watertight integrity;

2. Environmentally friendly also includes the ship being constructed of materials

for environmentally acceptable dismantling and recycling;

3. Safety also includes the ship’s structure being arranged to provide for safe

access, escape, inspection and proper maintenance;

4. Specified operating and environmental conditions are defined by the

operating area for the ship throughout its life and cover the conditions,

including intermediate conditions, arising from cargo and ballast operations in

port, waterways and at sea;

5. Specified design life is the nominal period that the ship is assumed to be

exposed to operating and/or environmental conditions and/or the corrosive

environment and is used for selecting appropriate ship design parameters.

However, the ship’s actual service life may be longer or shorter depending on

the actual operating conditions and maintenance of the ship throughout its life

cycle.”

4.2. Functional requirements (Tier II)

MSC 80 noted the following Tier II functional requirements, applicable for the time

being to new oil tankers and bulk carriers in unrestricted navigation26, as prepared by

its GBS working group. The functional requirements have been structured to form

three groups: design, construction and in-service considerations groups.

26 Unrestricted navigation means that the ship is not subject to any geographical restrictions (i.e. anyoceans, any seasons) except as limited by the ship’s capability for operation in ice.

Chapter 4. Implementation/application

93

4.2.1. Design

II.1 Design life

The specified design life is not to be less than 25 years.

II.2 Environmental conditions

Ships should be designed in accordance with North Atlantic environmental conditions

and relevant long-term sea state scatter diagrams.

II.3 Structural strength

Ships should be designed with suitable safety margins:

1. To withstand, at net scantlings, in the intact condition, the environmental

conditions anticipated for the ship’s design life and the loading conditions

appropriate for them, which should include full homogeneous and alternate

loads, partial loads, multi-port and ballast voyage, and ballast management

condition loads and occasional overruns/overloads during loading/unloading

operations, as applicable to the class designation.

2. Appropriate for all design parameters whose calculation involves a degree of

uncertainty, including loads, structural modelling, fatigue, corrosion, material

imperfections, construction workmanship errors, buckling and residual

strength.

The structural strength should be assessed against excess deformation and failure

modes, including but not limited to buckling, yielding and fatigue. Ultimate strength

calculations should include ultimate hull girder capacity and ultimate strength of

plates and stiffeners. The ship’s structural members should be of a design that is

compatible with the purpose of the space and ensures a degree of structural

continuity. The structural members of ships should be designed to facilitate

load/discharge for all contemplated cargoes to avoid damage by loading/discharging

equipment which may compromise the safety of the structure.

Goal based Standards – A new theoretical safety approach

94

II.4 Fatigue life

The design fatigue life should not be less than the ship’s design life and should be

based on the environmental conditions in II.2.

II.5 Residual strength

Ships should be designed to have sufficient strength to withstand the wave and

internal loads in specified damaged conditions such as collision, grounding or

flooding. Residual strength calculations should take into account the ultimate reserve

capacity of the hull girder, including permanent deformation and post-buckling

behaviour. Actual foreseeable scenarios should be investigated in this regard as far as

is reasonably practicable.

II.6 Protection against corrosion

Measures to protect against corrosion are to be applied to ensure that net scantlings

required to meet structural strength provisions are maintained throughout the

specified design life. Additional measures include, but are not limited to, coatings,

cathodic protection, impressed current systems, etc.

II.6.1 Coating life

Coatings should be applied and maintained in accordance with manufacturers’

specifications concerning surface preparation, coating selection, application and

maintenance. Where coating is required to be applied, the design coating life is to be

specified. The actual coating life may be longer or shorter than the design coating life,

depending on the actual conditions and maintenance of the ship. Coatings should be

selected as a function of the intended use of the compartment, materials and

application of other corrosion prevention systems, e.g. cathodic protection or other

alternatives.

II.6.2 Additional corrosion

The corrosion addition should be added to the net scantling and should be adequate

for the specified design life. The corrosion addition should be determined on the basis

of exposure to corrosive agents such as water, cargo or corrosive atmosphere, and

whether the structure is protected by corrosion prevention systems, e.g. coating,

cathodic protection or by alternative means. The design corrosion rates (mm/year)

Chapter 4. Implementation/application

95

should be evaluated in accordance with statistical information established from

service experience and/or accelerated model tests. The actual corrosion rate may be

greater or smaller than the design corrosion rate, depending on the actual conditions

and maintenance of the ship.

II.7 Structural redundancy

Ships should be of redundant design and construction so that localized damage of any

one structural member will not lead to immediate consequential failure of other

structural elements leading to loss of structural and watertight integrity of the ship.

II.8 Watertight and weathertight integrity

Ships should be designed to have adequate watertight and weathertight integrity for

the intended service of the ship and adequate strength and redundancy of the

associated securing devices of hull openings.

II.9 Human factor

Ergonomic project criteria will be used for the design and construction of vessel

structures and accessories to ensure safety during operations, inspection and

maintenance of the vessel. Among other things, the stairs, vertical ladders, ramps,

walkways and stationary platforms used for the means of access, the work

environment, inspection and maintenance and the facilitation of operations will also

be taken into account.

II.10 Design transparency

Ships should be designed under a reliable, controlled and transparent process made

accessible to the extent necessary to confirm the safety of the new as-built ship, with

due consideration to intellectual property rights. Readily available documentation

should include the main goal-based parameters and all relevant design parameters

that may limit the operation of the ship.

Goal based Standards – A new theoretical safety approach

96

4.2.2. Construction

II.11 Construction quality procedures

Ships should be built in accordance with controlled and transparent quality production

standards with due regard to intellectual property rights. The ship construction

quality procedures should include, but not be limited to, specifications for material,

manufacturing, alignment, assembling, joining and welding procedures, surface

preparation and coating.

II.12 Survey

A survey plan should be developed for the construction phase of the ship, taking into

account the type and design. The survey plan should contain a set of requirements to

ensure compliance of construction with classification rules and goal-based standards.

The survey plan should also identify areas that need special attention during surveys

throughout the ship’s life.

4.2.3. In-service considerations

II.13 Maintenance

Ships should be designed and constructed to facilitate ease of maintenance, in

particular avoiding the creation of spaces too confined to allow for adequate

maintenance activities.

II.14 Structural accessibility

The ship should be designed, constructed and equipped to provide adequate means of

access to all internal structures to facilitate overall and close-up inspections and

thickness measurements.

4.2.4. Recycling considerations

II.15 Recycling Ships

Shall be designed and constructed of materials for environmentally acceptable

recycling without compromising the safety and operational efficiency of the ship.

Chapter 4. Implementation/application

97

From this outline it is easily noticeable that the functional requirements have been

extended from the original scope of construction to other important aspects, covering

all the service life of the ship.

4.3. Verification of compliance (Tier III)

The new standards for the design and construction of bulk carriers and oil tankers

made by an RO, should be verified as conforming to the Tier I “Goals” and the Tier II

“Functional Requirements”, based on the guidelines for verification of conformity with

goal-based ship construction standards for bulk carriers and oil tankers, adopted by

the Organization by Res. MSC.296 (87), as established in the standard XI-1/1 of the

SOLAS, or to the national Administration standards used as equivalents of on RO

conformity as stated in the standard II-1/3-1 of the SOLAS.

From these guidelines it is understood that there are two parts of requirements:

a) The verification process consists of two main elements:

a. In self-assessment rule developers (Class) demonstrate that the rule set

conform to GBS.

b. Rule set to be verified, all items required by the guidelines, etc. (Audit

of the rules).

b) Verification practice, consisting of three steps:

a. Statement of intent.

b. Information and documentation requirements.

c. Evaluation criteria.

Goal based Standards – A new theoretical safety approach

98

Illustration 23. Mechanism of rules verification.

In respect of the implementation, the guidelines for verification of conformity with

GBS including the procedure and the criteria is playing a key role during the conduct

of rule verification.

As mentioned previously, in the BOE¡Error! Marcador no definido. adopting the GBS, once it

has been verified that the rules for the project and the construction of bulk carriers

and oil tankers of a recognized Administration or organization are in accordance with

the standards, it will be considered that this compliance continues being valid in case

of modification of the rules, as long as no verification of such modifications has proved

otherwise. Unless the Maritime Safety Committee decides otherwise, any

amendment to the rules introduced because of a compliance verification will be

applied to all ships whose construction contract was awarded on the date on which

the rule change enters into force or later on.

As regards the Spanish law, , it is highly important to determine the grammatic value

of “verification”. By "verification" (and any variant of the word "verify") it is

understood that the rules for the design and construction of bulk carriers and oil

tankers described above have been compared with the Standards and it has been

Chapter 4. Implementation/application

99

determined that such rules are in accordance with the goals and functional

prescriptions established in said goals or are coherent with them.

4.4. Technical procedures and guidelines, classification rules and industry

standards (Tier IV)

Rules and regulations for ships are the detailed requirements developed by IMO,

national Administrations and/or classification societies and applied by national

Administrations and/or classification societies acting as recognized organizations to

the design and construction of a ship in order to meet the goals and functional

requirements. These detailed requirements become a part of a GBS framework when

they have been verified as complying with the GBS.

4.5. Codes of practice and safety and quality systems for shipbuilding, ship

operation, maintenance, training, manning, etc. (Tier V)

Industry standards, codes of practice and safety and quality systems for shipbuilding,

ship operation, maintenance, training, manning, etc., may be incorporated into or

referenced in the rules/regulations for the design and construction of a ship. The

responsibility for justifying the suitability of such industry standards and practices,

when referenced or incorporated in a rule set, rests with the rule/regulation submitter.

This justification should be provided during the verification of compliance process.

4.6.Monitoring

Monitoring provides the information that is required in order to ensure the

effectiveness of rules and regulations as well as the proactive identification of new

risks. In order to verify that the risk of shipping is kept as low as reasonable

practicable, safety should be continuously monitored and systematically analyzed.

The degree of detail for the data recording depends on the item to be monitored.

Goal based Standards – A new theoretical safety approach

100

As illustrated by Illustration 21Illustration 21 two monitoring processes are

distinguished:

The monitoring of the effectiveness of single rules/regulations (Tier IV, V).

The monitoring of the effectiveness of goals (Tier I), functional requirements

(Tier II) and verification of compliance (Tier III).

The monitoring system to be established should address (list without any

prioritization):

safety of passengers

safety of third parties

occupational safety and health of seafarers

safety of ship

protection of environment

safety of cargo

For both processes monitoring should consider, but not be limited to, historical data,

such as casualty reports, in-service experience, accident investigation, incident

reports, near miss reports, new scientific research results as published in the industry,

as well as risk analysis.

4.7. Specific application

As the schedule follows, in May 20016 at the MSC 96th session, the results of the

verification process will be released, since it may avoid giving a competitive advantage

to particular submitters by doing so. Mentioned previously, all the results were

positive.

According to the recently amended SOLAS Chapter II-1, the GBS regime applies to

bulk carriers and oil tankers of 150 m in length and above which:

Construction contract from July 1, 2016.

In the absence of a building contract, the keels of which are laid, or which are in

similar stage of construction on or after 1 July 2017.

Delivery date from July 1, 2020 hereinafter.

Chapter 4. Implementation/application

101

Therefore, the final decision on conformity with GBS for all rules submitted would be

taken and the results will be announced before the applicable date.

Illustration 24. Application of GBS in the maritime fieldSource: Peng, Y. An analysis of the implementation and future development of IMO Goal-based

standards. Master of Science in Maritime Affairs. Malmö, Sweden: World Maritime University, 2011.

4.7.1. Safety of large passenger ships

In May 2000, the entire IMO membership, including the cruise industry, agreed to

undertake a holistic consideration of safety issues pertaining to passenger ships, with

particular emphasis on large cruise ships. To date, the outcome of this effort has

resulted in an entirely new regulatory philosophy for the design, construction and

operation of passenger ships that will better address the future needs of the cruise

industry.

In May 2002, IMO’s Maritime Safety Committee (MSC) approved a structure approach

for dealing with passenger ship safety matters, including a guiding philosophy,

strategic goals and objectives. The Committee further agreed that the guiding

Goal based Standards – A new theoretical safety approach

102

philosophy should be viewed as a “vision statement” to provide an idealized view of

where it would like to be in the future regarding the regulatory framework for

passenger ships.

With the approval of the guiding philosophy, the MSC, in effect, also agreed to a new

way of viewing the regulatory development process. Traditionally, issues related to

fire protection, marine engineering, naval architecture and other maritime disciplines

would, in most circumstances, be considered in isolation of each other and, after

deliberations, prescriptive regulations would be prepared on a piecemeal basis to

address each specific area of safety. However, the new regulatory approach is holistic

in nature and focuses on achieving goals such as “a ship should be designed for

improved survivability so that, in the event of a casualty, persons can stay safely on

board (in a safe haven) as the ship proceeds to port”. The holistic based work method

implemented by the MSC and the desire to achieve goals in lieu of piecemeal

requirements has required the various subsidiary bodies within IMO to work in concert

to achieve the guiding philosophy and strategic goals mentioned earlier.

On January 1, 2009 the probabilistic regulations on damage stability for passenger

ships entered into force. Which represented a major step towards the achievement of

a level of security improved through the rationalization and harmonization of stability

requirements. However, there are serious concerns regarding the formulation

adopted for calculating the probability of survival on passenger ships, in particular for

ROPAX and large cruise ships. These harmonized probabilistic rules for the subdivision

initiated a new era in the development of standards in the maritime industry in line

with contemporary developments, understanding and expectations. This

achievement was the culmination of over 50 years of work, one of the longest periods

of all safety regulations gestation. We should note that this entails a radical change in

the way to regulate safety on ships.

Most large passenger ships were and still are being one of the fastest growing sectors

and, more importantly, are the core strength of the industry of European shipbuilding.

In addition, great concern was expressed by the member states of the EU and the

Chapter 4. Implementation/application

103

European Maritime Safety Agency (EMSA) concerning the abolition of the provisions

of the Stockholm Agreement for ROPAX vessels when the new SOLAS 2009

Convention entered into to force; in fact, there was strong evidence that the 2009

SOLAS Convention does not satisfactorily covered the effects of water on deck

ROPAX.

The R & D project HARDER (Harmonization of rules and design rationale) was funded

by the EU, during 1999-2003. It was the first research project with external funding

specifically to support the IMO regulatory process and greatly contribute to the

development successful new rules, constituting a milestone in the IMO. However,

many owners have chosen to follow these new rules, and some issues appeared which

required urgent examination, that affects the ships safety, and this is a very critical

aspect.

A new project appeared between 2009 and 2012 to solve all the problems previously

mentioned, the research project named “Goal Based Damage Stability” – GOALDS.

The project aimed to contribute to the regulatory work of IMO and to address the

deficiencies identified by scientific methods and to formulate a rational framework

based on objectives, adequately representing the properties of damage stability of

passenger ships. It was a project created by EU and supported by a consortium. The

project consortium consisted of eighteen European organizations and groups

representing key stakeholders of the European maritime industry (ship owners,

builders, classification societies, flag states), research institutes and universities. In

addition, an advisory committee composed of representatives of the main public

regulatory authorities and CESA was formed and intended to be a resonance body for

the consortium, as well as a platform for early discussion of the results of the project in

relation to the preparation and consolidation of regulatory proposals to IMO.

The main objective of project GOALD were:

• Enhance collision and grounding casualties’ database, conduct statistical

analysis of data and check validity of current SOLAS 2009 assumptions for

Goal based Standards – A new theoretical safety approach

104

passenger ships. Develop an enhanced formulation for the survival factor “s”

accounting for key design parameters of passenger ships and for the time

evolution of flooding scenarios.

• Develop a new survivability formulation for flooding following grounding

accidents.

• Integrate collision and grounding survivability formulations into a single

framework.

• Validate the new formulations by experimental and numerical analyses.

• Develop a new damage survivability requirement in a risk-based context.

• Evaluate the practicability of the new formulations by a series of ship concept

design studies.

• Upon completion, submit results for consideration by IMO (October 2012).27

27 Papanikolaou, A. (2012). GOALDS – Goal Based Damage Stability Objectives and Overview of Results– Relationships to FLOODSTAND.

Chapter 5. Other applications

105

Chapter 5. Other applications

5.1. Safety Level Approach (SLA)

The SLA has also the name of the Risk Based approach and involves the use of

probabilistic tools and techniques in the formulation of regulations and in the actual

design of ships28. And lately there has been much of a debate at the IMO and in other

regulatory for a center on a set of questions to deal with the possible use of the so-

called “Safety Level Approach” in modern rule-making design, like how and when.

SLA is for long-term development. To do so it is needed to stablish terms of reference,

to collect information on current safety levels, to make definitions of categories and

develop a long-term work plan.

Basic principles:

28 Kontovas, C.A., Psaraftis, H.N. and Zachariadis, P. The two C’s of the Risk-Based Approach to GoalBased Standards: Challenge and Caveats. International Symposium on Maritime Safety, Security andEnvironmental Protection, Athens, Greece, 20-21 September 2007.

Goal based Standards – A new theoretical safety approach

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• Will quantify the acceptable level of safety for an envisaged rule or regulation,

for instance, comparison of an attained safety level with a required safety

level.

• A minimum safety level that all ships, regardless of age, will have to comply

with.

• The minimum safety level should be defined by IMO.

• Will enable an assessment of the envisaged rule or regulation to be developed

in an efficient and reliable manner defined to overcome any observed

deficiencies.

Work Plan:

• Determination of current safety levels in a holistic high level manner for

individual ship types (for Tier I goals).

• Consideration of previous FSA studies for use in the development of the SLA

(for risk acceptance criteria).

• Consideration of an appropriate tier structure for use in the SLA approach.

Chapter 6. Future of GBS system

107

Chapter 6. Future of GBS systemEven though big steps such as the Generic Guidelines for developing IMO goal-based

standards and the Guidelines for the verification of conformity have been

accomplished, it is clear to everyone involved in the field that there is still a long way

to go in order to arrive at agreed general goal-based standards for all new ship

construction.

“Usually the debate on GBS has a tendency to get stuck in discussions regarding

details of methods and criteria, and if continuing so, the task of developing a holistic

and rational structure for regulations may seem to be unreachable. However, there

may also be less dramatic steps forward that gradually will lead to a common

understanding and a more transparent rule-making process”.29

The future developments of the GBS system should focus in two main ideas:

29 Peng, Y. An analysis of the implementation and future development of IMO Goal-based standards.Master of Science in Maritime Affairs. Malmö, Sweden: World Maritime University, 2011.

Goal based Standards – A new theoretical safety approach

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6.1. Application of the safety level approach to the GBS system

The SOLAS amendments on May 2010 of the current GBS for oil tankers and bulk

carriers do not have the safety level specified in the system. That is because the

regime was developed mainly through the deterministic approach, so the risk is not

assessed with the SLA and is not integrated into the safety goals yet. “As the

deterministic approach achieved a significant progress and the GBS is about for its

implementation, the core of the GBS tends to be transferred to SLA”.30

6.1.1. The safety knob

“The SLA can provide IMO a safety knob by which the safety level can be adjusted,

when necessary, in a consistent, verifiable, transparent and reliable way in order to

rectify the observed deficiencies.”31

The SLA will provide appropriate levels for several safety aspects for instance, safety

of the ship, passengers, cargo and environment, which are in GBS Tier I. Then each

safety level in Tier I should be divided into several sub-elements related to the specific

functional requirements belonging to Tier II. As mentioned in the FSA vs GBS section,

the ALARP principle should be used as risk evaluation criteria to conduct risk

assessment. “The ALARP boundaries related to individual risk, and societal risk and

acceptance criteria for safety measures are the parameters of the formal safety

assessment”, and “the safety knob controls these parameters”.32 Another important

element of the safety knob is to control the cost effectiveness criteria, which as

explained previously, follows the CAF index. FSA being the basis of rules and

30 Idem 19.31 International Maritime Organization. (2006, January 5). Goal-based new ship construction standards.Safety level approach. Submitted by Denmark, Germany, Norway and Sweden (MSC 81/6/2). London.32 International Maritime Organization, 2006.

Chapter 6. Future of GBS system

109

regulations affecting the safety level of ships by controlling all of these parameters. In

this case, if there is something wrong in the safety knob, some of the basic

parameters set up will be affected, as shown in Illustration 25.

Illustration 25. The maritime regulator's safety knobSource: International Maritime Organization. (2006, Mar 7). Goal-based new ship constructionstandards: The safety level approach – introducing the safety knob to control maritime safety.

Submitted by Denmark and Germany (MSC 81/6/8). London.

6.1.2. Further work in SLA-GBS

One of the most important tasks regarding further development on SLA applied to

GBS is to determine the safety level of the current regulatory system by analyzing the

historical data in the industry. This task includes the determination of an overall goal

of acceptable risk level and the determination of individual risk levels for individual

casualty types, therefore adapting it to the GBS.

But to do so, there are two main factors which may affect the valid use of statistical

data:

Goal based Standards – A new theoretical safety approach

110

The available data should be large and wide enough to demonstrate the safety

level. There are always unreported cases which are not recorded in statistics.

The current fleet recorded is only a part of the actual fleet all over the world.

Therefore, it is impossible to record all the accidents in the world.

The diversity in collecting, arranging and analyzing data with multiple methods

and resources is too a key factor.

The categorization of ships, fleet size and record period differ very much in different

statistical sources, so assessment according to different sources may lead to different

results.33

So, in order to address the lack of valid data, according to the statistical theory, it is

needed a long-term information collection in order to have the frequency equally to

probability. This will lead into a correct application of the SLA. Furthermore, having a

uniform mode for accident data records will facilitate a valid historical record

regarding safety level. To sum up, the determination of the safety level should be

carried out as a long-term work and it will involve a large amount of effort.

As has been pointed out, the FSA helps to determine the current safety level, because

it contains quantification of the current risk level but not the safety objectives. The

FSA process will be needed to put functional requirements into GBS structure in order

to identify gaps, as well as to aid the development of detailed requirements, as shown

in Illustration 26. As a side note, it is worth recalling that FSA glitches need to be

previously fixed.

33 International Maritime Organization. (2010, January 18). Goal-based new ship construction standards.Resource requirements and timing for GBS verification audits. Note by the secretariat (MSC 87/5/2)

Chapter 6. Future of GBS system

111

Illustration 26. Use of FSA in SLA-GBSInternational Maritime Organization. (2008, Feb 5). Goal-based new ship construction standards. Report

of the GBS correspondence group: Submitted by Germany (MSC 84/5/3). London.

The SLA should follow and take advantage of the development and future

improvement of the FSA.

Currently they are working to complete the draft guidelines for the application of

GBS-SLA to the IMO rule-making process, so in order to complete them and increase

clarity for further elaboration of GBS SLA, guidelines for developing IMO goal-based

standards safety-level approach should be developed. Furthermore, these guidelines

should address how the description of goals, functional requirements, and the

regulations can include essential items for the development of IMO instruments and

verification of conformity for rules.

To do this transition phase cannot be done at once, so several little steps should be

taken in order to reach the goal. The first step would be applying the FSA step one, so

the identification of functional requirements should be accompanied by HAZID. In this

phase the relation between regulations and functional requirements will be

established. The second phase would be to identify the current safety level of

Goal based Standards – A new theoretical safety approach

112

regulations for different functional areas by means of the FSA. Therefore, make the

risk level ALARP, and performing a risk analysis (FSA step 2) and identifying the risk

control options (FSA step 3) and finally do a cost-benefit assessment (FSA step 4). And

finally, as the last phase of the transition a restructuration of IMO instruments should

be done in order to separate long standing goals and functional requirements from

regulations.

All of this transition phase should be done bearing in mind that it might be a good

option to maintain the current high-level structure of IMO instruments such as

MARPOL, SOLAS and Codes.

Illustration 27. Hierarchy of IMO GBS-SLA instrumentsSource: Goal-based new ships construction standards: development of interim guidelines for the safety-level approach (SLA) to the IMO rule-making process. Submitted by Germany and Netherlands. MSC

95/5/2 (3march 2015) Annex page 4.

Chapter 6. Future of GBS system

113

Considering all the previous facts, having a GBS-SLA framework and that the

transition phase has been done, the first step of developing the SLA should be to

apply it for the new-building construction standard for bulk carriers and oil tankers

where the results can be calibrated with the prescriptive approach. Secondly, the

scope of work could be widened into areas or ship types where there is no much

experience.

Recent technologies adopted by the industry such as Risk-based Design (RBD) and

Structural Reliability Assessment (SRA) should be followed by IMO. That is because

these technologies are closely related to SLA and GBS and may have great influence

on further development

6.2.Generalization of the GBS system.

Currently the GBS regime is applicable just in the structure of bulk carriers and oil

tankers above 150 meters’ length. Bearing in mind that structural safety cannot be

looked at in isolation but should form part of an overall framework. Therefore, we

must notice that the ongoing GBS scope is only a small region part of the whole

maritime safety, security and environmental protection system.

That being said, the future of the GBS should focus in a Generalization of the system.

Since the very beginning of the GBS development, it was agreed in the long-term plan

to extend all its range of application, but only after earning experience with it. The

idea of extending the scope of GBS was reflected in the basic principle of GBS

previously described. It is widely recognized that the GBS tends to be applied to the

entire maritime regulatory system in order to develop the system in a high-level

manner due to the advantages that it is bringing, such as technical transparency and

openness for technical innovation.

Goal based Standards – A new theoretical safety approach

114

The approval of Generic Guidelines for Developing Goal-based Standards can be

regarded as a preparation work for further expansion of GBS in other maritime fields

as it provides the basis for further development.

6.2.1. Analysis on the process of GBS generalization

The most important step is to clearly identify the areas which are not covered by the

current GBS system. First of all, regarding the ship structure area, there are other

different kind of ships, as container ships, passenger ships, general cargo ships,

LNG/LPG carriers and so on. But there are also bulk carriers and oil tankers smaller

than 150 meters’ length not covered. Secondly, there are machinery and electrical

installations to be covered rather than just structural construction. Third, beyond the

rules related with the construction area, there are many regulations in regard to

maritime safety, such as stability/floatability, fire safety, life-saving and navigation

safety, where GBS can be further developed. At last, besides maritime safety, there

are in the same level maritime security and environmental protection. That leads us to

the whole maritime field that can be addressed by the GBS system.

There are two key elements to be considered for the generalization process of GBS:

Necessity.

Feasibility.

Therefore, sounds natural that GBS should be applied first to ship areas where GBS

are most necessary and generates more impact. Even though, before the

implementation, the feasibility of development should be evaluated in order to state if

worthy.

Since the original motivation to develop GBS in IMO was to have better control over

the rules for ship construction, there is no rush in covering other areas that IMO

conventions or regulations, such as stability, fire safety and lifesaving, already

regulate.

On account of the lack of statistical data, technical limitations and glitches, SLA

cannot, at the present time, be effectively used to develop the GBS system. That is

Chapter 6. Future of GBS system

115

why the glitches on this approach are being corrected. Meanwhile a deterministic

approach can be used.

As there is a trend in the maximization of container ships development, the structure

of container ships is gaining more attention of the shipping industry. So, it may seem

that the HSR will extend to container ships. With the gained experience from GBS for

bulk carriers and oil tankers, the time needed to set up GBS for container ships could be

estimated as relatively short.34 Therefore, it is quite feasible and intelligent to further

develop GBS for container ships as first step.

34 Peng, Y. An analysis of the implementation and future development of IMO Goal-based standards.

Master of Science in Maritime Affairs. Malmö, Sweden: World Maritime University, 2011.

Goal based Standards – A new theoretical safety approach

116

Illustration 28. New container ship orders of the world's leading operatorsSource: Statista. Number of ships in the world's leading container ship operators' order books as of

June 13, 2016.

This graph represents a ranking of the world's leading container ship operators as of

May 23, 2016, based on the number of ships in their order books

Chapter 6. Future of GBS system

117

Illustration 29. 40 years of container ship growthSource: HIS Maritime & Trade

Illustration 30. Forecast for global TEU capacity of container ships until 2018Source: Statista. Forecast for global TEU capacity of container ships from 2014 to 2018.

To support the first step towards a globalization, as said and demonstrated by the

graphics, not only there will be a significant increment on the container ship capacity

but quantity too.

Goal based Standards – A new theoretical safety approach

118

The second step would be to focus on the machinery and electrical installations, which

are already dominated by rules and are strongly controlled by statutory regulations.

That being followed of structure of other ship types. The main idea would be to

expand the GBS system to other rule related areas where IMO does not have strong

control.

Another possible step toward the generalization, in different safety-related areas such

as stability, fire safety and lifesaving, environment-related areas such as oil pollution,

air pollution and CO2 emission, and even security issues, many regulations and codes

have been developed by IMO. These regulations and codes are prescriptive standards

and belong to Tier IV of the GBS structure. Therefore, promoting the structure of the

new GBS regulatory system.

Illustration 31. Step scheme for GBS expansionSource: Peng, Y. An analysis of the implementation and future development of IMO Goal-based

standards. Master of Science in Maritime Affairs. Malmö, Sweden: World Maritime University, 2011.

Chapter 6. Future of GBS system

119

6.2.2. Practical recommendations on the GBS generalization implementation

To start, a date in every year for the classification societies to submit their new

amendments can be fixed, and subsequently the audits should be scheduled soon

after the submissions. This measure would not only shorten the waiting time for

audits, but also facilitate the management of the periodically verification.

As commented, the Member States and International Organizations should submit

further nominations for GBS auditors. They need a very high level of expertise and

background, so sufficient auditors are a key element for complying with the goals and

deadline achievements on the implementation of the GBS verification. Nominees

could be further considered and selected from the ship design or ship building

industry, research institutes or universities. In case that there are not enough qualified

auditors by the time of verification, two mitigating measures could be considered.

One is to use an appropriate grouping scheme to ensure the required expertise of

audit teams, which means to select auditors with different backgrounds and cover the

technical scope needed in a team, focusing on the integrity of expertise of an audit

team rather than an individual nominee. The other is to conduct a combination of rule

reviews in order to reduce the workload and labor resource, as mentioned in the first

point.

Last but not least, specialized GBS group or section could be established for GBS

implementation in the future. For the moment, the workload for GBS verification

could be undertaken by existing staff. However, as the GBS expands to other ship

types and aspects, the overall workload would not be able to be absorbed within the

Secretariat, so it would be necessary to establish a new specialized group or section

for GBS, in charge of management and coordination of the initial and maintenance

verifications. Furthermore, a GBS database should be developed and maintained by

IMO as a long-term task. As the GBS scheme expands its scope in the future,

Goal based Standards – A new theoretical safety approach

120

historical information regarding rules verification including each verification date of a

new revision would become vast and complicated, so a computer-based management

would be essential for successful implementation.35

6.3. Further ways of GBS development

6.3.1. Vessels for the future

Vessels for the Future was launched in Brussels, 5 November 2014, with its first

assembly on the same day. Responding to the European waterborne industry strategy

– LeaderSHIP 2020.

Vessels for the Future is a research association and an initiative that brings together a

leading group of maritime stakeholders with a common interest: To ensure that the

maritime industry has a strong and vibrant future and remains competitive through

maritime research. To do so, the association will coordinate and promote maritime

technology development & innovation. Aiming to address societal challenges for a

safer, cleaner and efficient maritime transport and the industrial challenge to

competitiveness. The association is convinced that a sustainable growth can be

achieved with maritime innovations.

35 Peng, Y. An analysis of the implementation and future development of IMO Goal-based standards.Master of Science in Maritime Affairs. Malmö, Sweden: World Maritime University, 2011. p.46.

Chapter 6. Future of GBS system

121

Illustration 32. Vessels for the Future logoSource: Vessels for the future. Sustainable growth through maritime innovation. Brochure.

Vessels for the Future represents all stakeholders of the maritime value chain, from

the ship owners, going through ship yards, system suppliers, classification societies,

until research institutes and academies. Currently, 64 members from 15 EU Member

States have joined, having half of the members representing the industry field. That is

an aim to generate a private-public partnership that will ensure a long-term

commitment.

Illustration 33. Vessels for the Future Board MembersSource: Vessels for the future. Sustainable growth through maritime innovation. Brochure.

Goal based Standards – A new theoretical safety approach

122

The main idea is to capitalize on the European strengths in research and development

(R&D), therefore helping the stakeholders to reach a leading position in high value

ship segments. Also recognize growth opportunities through the deployment of new

and developing technologies in the maritime industry. Also, the association is

convinced that the sustainable growth can be achieved with maritime innovation and

is addressing societal challenges for a safer, cleaner and efficient transport, striving

competitiveness.

Chapter 7. Conclusions

123

Chapter 7. ConclusionsIMO has proven, many times through its history, its ability to react on urgent matters

emanated from ships accidents. Over the last three years of work on GBS, IMO has

also proven its determination to fulfil its objectives towards a proactive policy for the

future.

The adoption of the amended SOLAS Chapter II-1 on GBS and the related

“International Goal-Based Ship Construction Standards for Bulk Carriers and Oil

Tankers” and guidelines for the GBS Verification, IMO has determined its key role in

the ship construction, especially of the hull structure, previously dominated by the

rules of the classification societies, thus, not controlled by them. This step set a

milestone towards the development of the GBS because the first three tiers have been

successfully accomplished. Despite this fact, as an ongoing process, more experience

will be gained through its implementation, which will contribute to further

enhancement and development of the GBS system to the maritime industry.

The basic principles for GBS, currently agreed, are not locked to specific designs or

technologies nor to specific rule formulations. Therefore, GBS could be seen as a

generic rational structure for international rules and regulations on maritime safety

and environmental protection. By focusing on the goals rather than methods, it has

introduced a clear distinction between political decisions and technical solutions while

adding transparency to the regulatory framework which are advantages towards a

technical transparency and widening the scope for expansion and innovation.

Goal based Standards – A new theoretical safety approach

124

Irrespective of whether lower tier regulations, rules or standards are formulated as

probabilistic or deterministic, risk-based or prescriptive, their evaluation will always

incorporate the judgement of risk and practicability due to the verification audit

scheme.

The GBS along with FSA are the main stream of risk assessment in the maritime

safety management resulting with a more accurate approach. In addition, the

digitization, informatization and networking will become the general trends in the

industry. GBS may add the holistic structure that is needed, but FSA will continue to

be an important methodology for identifying and evaluating the necessary

requirements.

Chapter 7. Conclusions

125

Goal based Standards – A new theoretical safety approach

126

Chapter 8. Bibliography

6.3.1.1. Books:

[1] Penny, J., Eaton, A., Bishop, P., Bloomfield, R. The Practicalities of Goal-Based

Safety Regulation, Proc. Ninth Safety-critical Systems Symposium (SSS 01).

Bristol, UK. New York: Springer, 2001. pp. 35-48. ISBN: 1852334118.

[2] Rodrigo de Larrucea, J. Hacia una teoría general de la Seguridad Marítima. 1st

Edition. Barcelona, Spain: Ediciones Gráficas Rey, 2015. ISBN: 9788461736232.

[3] Rodrigo de Larrucea, J. Seguridad marítima: Teoría general del riesgo. 1st Edition.

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based standards. Master of Science in Maritime Affairs. Malmö, Sweden: World

Maritime University, 2011.

[5] Kontovas, C.A. Formal safety assessment: Critical review and future role. Psaraftis,

H.N. National technical university of Athens, School of naval architecture &

marine engineering. July 2005.

6.3.1.2. Resolutions:

[6] Resolution A.944 (23). Strategic plan for the organization (for the six-year period

2004 to 2010). Adopted on 25 November 2003.

[7] Resolution A.943 (23). Long-term work plan of the organization (up to 2010).

Adopted on 5 December 2003.

[8] Resolution MSC.296 (87). Adoption of the guidelines for verification of

conformity with goal-based ship construction standards for bulk carriers and oil

tankers. Adopted on 20 May 2010.

http://www.imo.org/en/KnowledgeCentre/IndexofIMOResolutions/Maritime-

Safety-Committee-(MSC)/Documents/MSC.296(87).pdf

[9] Resolution MSC.287 (87). Adoption of the international goal-based ship

construction standards for bulk carriers and oil tankers. Adopted on 20 May 2010.

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[10] Resolution MSC.290 (87). Adoption of amendments to the international

convention for the safety of life at sea, 1974, as amended. Adopted on 21 May

2010.

6.3.1.3. Guidelines:

[11] Generic Guidelines for developing IMO Goal-Based Standards.

MSC.1/Circ.1394/Rev.1. 22 June 2015.

http://sitiowcontingencia.prefecturanaval.gov.ar/web/es/doc/dpsn_circulares_msc/

MSC.1-Circ.1394-Rev.1.pdf

[12] Revised Guidelines for Formal Safety Assessment (FSA) for use in the IMO rule-

making process. MSC-MEPC.2/Circ.12/Rev.1. 18 June 2015.

http://research.dnv.com/skj/IMO/MSC-

MEPC%202_Circ%2012%20FSA%20Guidelines%20Rev%20III.pdf

[13] Guidelines for the information to be included in a Ship Construction File.

MSC.1/Circ.1343. 2 June 2010. http://imo.udhb.gov.tr/dosyam/EKLER/MSC.1-

Circ.1343.pdf

[14] Guidelines for verification of conformity with the international goal-based ship

construction standards for bulk carriers and oil tankers. MSC 87/26/Add.1. Annex

12. 20 May 2010.

6.3.1.4. Regulations:

[15] Safety of life at sea (SOLAS) Chapter II-1: Construction-structure, subdivision

and stability, machinery and electrical installation.

[16] Normas Internacionales de Construcción de buques basadas en objetivos para

graneleros y petroleros, adoptadas el 20 de mayo de 2010 mediante Resolución

MSC.287(87). Boletín oficial del estado, num.308, from 23rd of December 2011,

pages. 140367 to 140373.

https://www.boe.es/diario_boe/txt.php?id=BOE-A-2011-20018

Goal based Standards – A new theoretical safety approach

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6.3.1.5. Reports:

[17] Maritime Safety Committee. Report of the maritime safety committee on its

eightieth session. MSC 80/24. 24 May 2005.

[18] Huss, M. Status at IMO: where are we heading with goal-based standards?

SAFEDOR – The mid-term conference. May 2007.

[19] Submitted by Germany in the Maritime Safety Committee. Goal-based new

ship construction standards: Report of the GBS correspondence group. MSC 84/5/3.

5 February 2008

[20] Submitted by Denmark, Germany and Norway in the Maritime Safety

Committee. Goal-based new ship construction standards: Consideration of the

GBS generic structure. MSC 84/5/4. 4 March 2008.

[21] Submitted by Denmark in the Maritime Safety Committee. Goal-based new

ship construction standards: Guidelines on approval of risk-based ship design. MSC

86/5/3. 9 February 2009.

[22] Croatian Register of Shipping. IMO goal based ship construction standards for

tankers and bulk carriers (GBS). Begovic, G. Stijelja, R. Zulim, Z. Split, Croatia.

2010.

[23] China Classification Society. Notice on Implementation of Resolution MSC.290

(87) on Goal-based ship construction standards for bulk carriers and oil tankers.

Beijing, China. June 29, 2011.

[24] Note by the Secretariat in the Maritime Safety Committee. Goal-based new

ship construction standards: Implementation of the GBS verification audits. MSC

93/5. 12 March 2014.

[25] International Maritime Organization. International Goal-Based ship

construction standards for bulk carriers and oil tankers. Focus on IMO. London,

UK. January 2015.

[26] Note by the Secretariat in the Maritime Safety Committee. Goal-based new

ship construction standards: Implementation of the GBS verification audits. MSC

95/5/1. 31 March 2015.

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[27] Report of the Maritime Safety Committee on its ninety-fifth session. MSC

95/22. 19 June 2015.

[28] Lloyd’s Register Marine. IMO Maritime Safety Committee Ninety Sixth Session

(MSC 96): Summary Report. Southampton, UK. 2016.

[29] International Association of Classification Societies. Goal-based standards

recognition launches new era in maritime safety and collaboration. Press release.

London, UK. May 13, 2016.

[30] Maritime Safety Committee. International Convention for the safety of life at

sea (SOLAS), 1974, as amended: Promulgation of rules for the design and

construction of bulk carriers and oil tankers of an organization, which is recognized

by Administrations in accordance with the provisions of SOLAS regulation XI-1/1,

confirmed by the Maritime Safety Committee to be in conformity with the goals and

functional requirements of the Goal-based Ship Construction Standards for Bulk

Carriers and Oil Tankers. MSC.1/Circ.1518. 13 May 2016.

[31] Equasis. The world merchant fleet in 2014. Statistics from Equasis, 2014.

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[32] Hoppe H. Goal-based standards – A new approach to the international regulation

of ship construction. Maritime Safety Division, International Maritime

Organization. WMU Journal of Maritime Affairs: The international Journal for

professionals in maritime administration, industry and education. (October 2005,

Volume 4, Issue 2, pp 169-180).

[33] Kontovas, C.A., Psaraftis, H.N. and Zachariadis, P. Improving FSA as a

Prerequisite for Risk-Based GBS. 10th International Symposium on Practical

Design of Ships and Other Floating Structures. Houston, Texas, United States of

America: American Bureau of Shipping, 2007.

[34] Kontovas, C.A., Psaraftis, H.N. and Zachariadis, P. Risk based rulemaking and

design – Proceed with caution. RINA conference on Developments in Classification

and International Regulations. London, UK: Rina, January 2007

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Based Approach to Goal Based Standards: Challenge and Caveats. International

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Greece, 20-21 September 2007.

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control maritime safety. Submitted by Denmark and Germany (MSC 81/6/8).

London.

[37] International Maritime Organization. (2008, Feb 5). Goal-based new ship

construction standards. Report of the GBS correspondence group: Submitted by

Germany (MSC 84/5/3). London.

6.3.1.7. PowerPoint Presentations:

[38] N. Psaraftis, H. (2006). Goal Based Standards and the “Safety-Level Approach”

debate [PowerPoint slides]. Retrieved from:

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ftis%20v2%200.pdf

[39] N.Psaraftis, H (2006). GBS vs “Safety Level Approach”: contributing to the

dabate [PowerPoint slides]. Retrieved from:

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[40] Sames, P. C. (2007). Risk-based ship design, approval and operation [PowerPoint

slides]. Retrieved from: http://www.safedor.org/press/SAFEDOR-SC-2007-08-10-

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[41] Arima, T. (2009). Goal-Based Standards – application and compliance

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[42] Lee, J-K. (2009). Shipbuilder’s Views on Risk-Based Regulatory Framework (SLA

– based GBS). [PowerPoint slides]. Retrieved from:

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6.3.1.8. Web pages:

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[57] The Society of International Gas Tanker and Terminal

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[58] The International Association of Dry Cargo Shipowners:

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[59] Laboratory for Maritime Transport, National Technical University of Athens:

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[60] IMODOCS: https://docs.imo.org/Default.aspx

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[63] SAFEDOR: About SAFEDOR. http://www.safedor.org/about/index.htm

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http://www.imo.org/en/MediaCentre/MeetingSummaries/Pages/Default.aspx

36 To a certain extent, a large measure of the appointments included include references to minutes ofthe sessions of the MSC.