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The International Maritime Organization

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Q2. Recently, the International Maritime Organization, acknowledgeing several shortcomings in the use of prescriptive regulation, and then it has been gradually developing a new approach of goal-based standars (GBS) which related to design and construction of new ships, these ships also use tranditional patterns of verifying compliance. As we all know, regulations are introduced to minimize the risks to a reasonable and acceptable level. In my opinion, I agree with the above statement. The shortcomings of prescriptive regulation are that it provides a less wider design space and lacks innovative design space, due to these limitations, the IMO develops a new approach which is called GBS, this new approach has its advantages and disadvantages as below. Undoubtly, there are several shortcomings in the prescriptive regulation. Before GBS were developed, the International Maritime Organization (IMO) was widely using the prescriptive regulation in shipping design and construction. Because they are very easy to be used for designer and those who want to check the design and construction. IMO also thought that regulation had the advantage of empirical basis. Because it can overcome the prediction on the theoretical basis at early design stage for a model ship. However, the shortcomings of prescriptive regulation is very obvious. First of all, when using the past experience, the constraints of design on these experience may lead to more needed than conservative. Or, there will occur more conservation. For example, if there accurs a specific accident accident which is widely obtained the attention for politics, the decision makers and designers will modify the norm, and then results to problems. In the second place, according to International Ship and Offshore Structures Congress (2006), prescriptive regulation may end up being the main design driver, it will make innovation stifling, and most importantly, it will produce less useful end ships. Thirdly, prescriptive regulation provides a less wider design space and lacks innovative design space. Thus, it provides small space to designer to design a good ship, however, the freedom to the designer can determine the range of viable solutions. In other words, prescriptive regulation cannot give designer more freedom to design and then the viable solutions will be limited in a small range. Based on those shortcomings of prescriptive regulation in the area of ship design, IMO has been gradually developing goal-based standards (GBS) in relation to the design and construction of new ships. The aim of GBS is to continually reduce risk that is the main goal in safety and environmental protection regulations. This approach heavily rely on data, models, expert judgment, assumptions and decision making criteria. The regulatory decision process is made more transparent by analyzing the needs for new regulations and evaluate their impact on safety, the environment and the large scale economy. According to the international maritime organization resolution (2004a), the Bahamas, Greece and IACS have proposed in a joint submission a 5-tier Goal-Based Regulatory Framework. The first tier is goals based safety objectives; the second tier is functional requirements; the third tier is verfication of compliance criteria; the fouth tier is technical procedures and guidelines, classification rules and industry standards; the fifth tier is the codes of practice and safety and quality systems for shipbuilding, ship operation, maintenance, training, manning, etc (IMO: 2004a). With the development of the noval approach of GBS, there are lots of advantages in the design and construction of new ships. The first advantage is safety, the GBS safety level approach will provide the quantification of safety of new shipping and the guidance of the design work for improving safety. The derect benefit is that it enables IMO to take the safety into consideration when designing new building. It gives the objective of establishing a rational and transparent basis of safeguarding and enhancing safety and protecting the marine environment. Secondly, the new des ign and construction can improve environmental sustainability which is affordable and acceptable under the utilization of GBS. Through GBS, when designing new ships, we can take the detrimental impacts to society, such as loss of life and the environment into consideration when evaluating the worth or viability of any proposed activity. For the decision makers, with the GBS, they can analyse the environmental life cycle and make process regarding the alternative active activities or the acceptability of an activity. Additionally, when taking the human element into consideration, it is apparent that at the top level the GBS specifies what tools and what areas should be considered for reducing the trips, falls and slips ( ISSC:2009). During the design and construction of new ships, we can use the GBS and reduce the trips which is more important for these new ships. Besides, it is more freedom for designers to achieve more competitive, innovative and safer design, also it can assure the operating ships with compliance of societal requirements and sustainability. At last but not the least, though the GBS in relation to the construction of new ships, for the single structural elements and the assembled structure, the designer will know and cosider the materials and geometrical characteristics are the cohernet with the design program. Thus, the advantages of GBS are apparent when using it in relation to new ships’ design and construction. The advantages of GBS in relation to ship’s design and construction are obvious, however, there still are some disadvantages when using it. Firstly, in the present GBS format, it lacks a clear risk based acceptance criteria formulation. The need for this acceptance criteria setting allows classification societies to meet the goals of the standards transparently. This element is regarded as a major problem in the present GBS formulation. Secondly, the first tier and second should contain no prescriptive approaches which these approaches belong to the low levels. In the present GBS, the GBS framework has not modify or update when changing societal preferences transparently. Furthermore, GBS should take a more flexible maintenance and monitoring scheme into consideration, however, it does not good in today’s society. And for the sustainability, the difficulty is that although we can easily know the concept of sustainability’s theory, it is hard to identify practical actions which can make a significant impact. Additionally, according to Huss (2007), for the third tier, the verification of compliance has shown to be the most difficult to complete, so far only rules which are developed by the classification societies have been considered. Lastly, for the goal-based standards based on the safety level approaches, IMO primarily just focuses on developing detailed technical requirements, it is not a useful standard, the IMO should focus on establishing functional requirements and monitoring the overall safety of new ships’ design and construction rather than developing such detailed technical requirements. To be conclued, the general purpose of GBS is to define what to be achieved by these standards and not how it is achieved. It is hard for us to see the conflicts which regards at political high-level in IMO. On the contrary, it would promote understanding to start from the top in the rule making process instead of the technical details which is often like this. The IMO, acknowledging the prescription regulation has several shortcomings, such as it provides a less wider design space and lacks innovative design space. Due to these shortcomings, IMO generally develops the GBS which is related to the design and construction of the new ships, although GBS’s disadvantages are apparent, IMO should update GBS due to the change of societal preferences. More importantly, it is necessary to use the tranditional patterns of verifying compliance. References Huss, M. (2007). Staus at IMO: where are the heading with goal-based standards? SAFEDOR–The Mid Term Conference. 2007 International Maritime Organization, (2004a). ResolutionStrategic plan for the Organization, 23:944 International Ship and Offshore Structures Congress, (2006). Design principles and criteria, Technical Committee 1(1), Elsevier International Ship and Offshore structures congress (ISSC), (2009). Design principles and criteria, Technical Committee 1(1): 587-687 1
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