Flag and Class
A NEW “NAME AND SHAME” LIST TARGETS POOR PERFORMERS
Not content with the black, white and gray lists of flag-state performance, port state control agency Paris MOU has published a new list that focuses on the role of classification societies.
By Wendy Laursen
Whether they like it or not, ship registries know that Port State Control (PSC) agencies such as Paris MOU – a consortium of 26 European countries plus Canada – have a lot to say about their performance. In addition to the usual black, white and gray lists, Paris MOU introduced a new metric at the most recent Flag State Implementation (FSI) meeting in March. General Secretary Richard Schiferli cited the clear relationship between black-listed flags and the Recognized Organizations (ROs), often classification societies, which undertake inspections on their behalf, and the new combined list identifies poorly performing combinations.
The list will be updated and published at each FSI meeting. While admitting there are some flags that are uncomfortable about seeing PSC officers board their ships, Schiferli is proud of how he can help flags improve their performance. Panama, for instance, has moved from black to gray to white over the last few years with support from Paris MOU by introducing a more rigorous inspection regime, closer follow-up on detentions and the removal of poorly performing ships from its registry.
The Good Guys
The last FSI meeting took important steps toward making the currently voluntary IMO Member State Audit Scheme mandatory, and this is expected to take effect by late 2013. “If full disclosure of audit results is not mandatory, it will be difficult to ensure consistent and effective implementation of SOLAS, the ISM Code and other mandatory instruments regulating safety,” said Captain David Pascoe, Senior Vice President of the Liberian Registry. “Liberia will continue to publish its full audit report.”
Liberia also supports the Code for Recognized Organizations (RO Code) that was considered at the last FSI meeting. “Liberia only recognizes class societies that are members of IACS (International Association of Classification Societies) and, as such, are already undergoing external quality audits, including audits by us. We are hopeful that the RO Code will level the playing field in ensuring the quality of ROs that are currently not audited,” Pascoe added. Like many top-performing flags, Liberia prides itself on its ability to be proactive in preventing deficiencies and detentions. The flag has started using advanced notice of arrivals and zone notifications copied to them by masters to assess the probability of a PSC boarding and to advise on any necessary actions.
Marshall Islands is a white-list registry that has seen a steady increase in fleet size. While ROs issue statutory certificates on its behalf, the registry also uses its own inspectors to ensure its obligations are being meet. Marshall Islands looks at casualty statistics and uses them to determine the age limit, currently 20 years, for new vessels coming into the registry. The average age of the Marshall Islands fleet is about eight years.
Marshall Islands finds Long-Range Identification and Tracking (LRIT) a useful tool, not only in search-and-rescue and piracy situations but also in tracking potential problem vessels and establishing alert zones around areas of strict PSC inspections. The registry can send a message to owners with information regarding common deficiencies the PSC officers have found previously and alert its own inspectors of the vessel’s imminent arrival.
“I welcome that,” said Schiferli. “Our business is not in detaining ships. We want safe ships.” This sentiment was echoed by Allan Schwartz, General Manager of Maritime Operations at the Australian Maritime Safety Authority (AMSA). “We are better off not having substandard ships coming here than dealing with them when they get here.”
AMSA inspects both Australian-flag and foreign vessels visiting the country’s ports – both are treated exactly the same from an inspection point of view. AMSA purchases satellite Automatic Identification System data that has a number of uses, including safety regulation. If a ship has stopped or broken down, AMSA is able to see what is going on “over the horizon” and follow up when the ship comes to port. Taking its proactive approach further, AMSA routinely visits China, Taiwan and Japan, Australia’s main trading partners, to discuss safety with inspectors, owners and operators.
Old vs. New
Well-established open registries have been shown to have lower shipping casualty and crew fatality rates than newly emerging ones. A historical analysis of UK shipping incidents between 1970 and 2005 revealed that two relatively new open flags – Belize, established in 1992, and St. Vincent & the Grenadines, established in 1984 – experienced high casualty and detention rates during the rapid expansion of their fleets. The study, led by Dr. Stephen Roberts of Swansea University, examined 12 flags commonly used by UK shipping. While casualty rates overall have dropped over time, it is clear that flags that are newly emerging or expanding rapidly should be monitored, said Roberts.
In 2003, Belize began the process of cleaning up its registry and removed hundreds of potentially dangerous ships. The flag is also pushing to reduce the number of non-IACS vessels in its fleet and has introduced tough rules on detentions.
St. Kitts & Nevis Registry, often frustrated at how having a small number of ships operating in a region can skew PSC statistics, announced in March that it had reduced its detention rate by 60 percent and its deficiency rate by 50 percent. The flag reported to FSI that it had enhanced its regulatory oversight in 2011 with a range of measures including daily monitoring of PSC Web sites, engagement with the 13 classification societies they have delegated as ROs, and risk-profiling of applicants. Nonetheless, the registry remains loyal to owners and managers from developing nations, who often operate older tonnage.
Flag and class societies are quick to point out that it is the quality of a ship’s maintenance program that is important, not its age. An old ship is not necessarily a dangerous ship. However, most Paris MOU white-listed registries have comparatively young fleets. The Review of Maritime Transport published by the United Nations in 2011 cites the Marshall Islands as having the youngest fleet, followed by the Isle of Man, Liberia, and then Antigua & Barbuda, all high-performing flags. The oldest fleet was St. Vincent & the Grenadines, which is currently on a number of black lists.
The Human Element
Loss statistics published at the beginning of the year by the International Union of Marine Insurance (IUMI) do implicate older ships, but the numbers should be viewed with caution, said IUMI Secretary General Fritz Stabinger. “We can generally say that traditional flags have lower loss ratios than non-traditional flags. It can also be said that vessels classed with IACS societies tend to have a lower loss ratio than others,” he explained. “But it can be said that the more strictly flags interpret the need for professional training of their crews, the lower the loss ratio is.” The human element is fundamental to Stabinger: “Most causes of loss are, ultimately, due to the human element: Machinery damage, collisions, groundings, weather – all of them would not happen (or happen much less) if shipowners would take training and high-quality crews to heart.”
Paris MOU’s latest annual report lists class society RINA as the best performing RO, and Stabinger’s sentiments are echoed there. “We don’t look at numbers or ship types when we think about risk,” stated Paolo Moretti, General Manager of Marine. “We look at the people who run the ships and the people who crew them.”
A growing focus on the human element is seen by Bernard Anne, Managing Director of the Marine Division at Bureau Veritas. “There are fewer ships being lost every year, whereas there are more of them in operation. Of course certain ship types statistically seem more at risk than others, but this is the result of different operating modes and trading patterns and, above all, differences in the safety practices and culture of crews and companies. What had to be done in terms of enhancement of structural surveys has been done and has borne fruit. Now we try hard to work with owners to help them get the right safety culture in place, through ISM and through training, so that they become safe, low-risk companies.”
Germanischer Lloyd (GL) sees risk‐based ship design and approval procedures as an additional approach toward having safer vessels and has been involved in a four-year research project focused on practical aspects like systems availability, fire and navigational safety, damage survivability and rescue. Seeing safety treated as an objective rather than a constraint imposed by design rules was the initial goal of the EU‐funded project. Ship designers now have increasingly sophisticated tools for advanced and risk‐based ship design, said Uwe Bullwinkel, U.S. Regional Manager for GL. “Risk evaluation criteria are eventually becoming explicit and accepted also at maritime administrations to enable holistic decision‐making.”
Paris MOU introduced a new regime for determining which ships to inspect in 2011. It continues to look at ship type, age, flag and RO, but an operator’s fleet status is also given priority. A new guidance for PSC officers in the ISM Code includes changes that mean ship management companies have to be involved if a ship has been detained or has had a number of deficiencies, stated Shosuke Kakubari, Executive Vice President of ClassNK. “It is expected that owners or management companies will take the steps necessary to improve the quality of their management systems in cooperation with their ROs,” he added. ClassNK supports owners and managers by providing a technical information service and information about PSC activities such as concentrated inspection campaigns. It also provides a Port State Inspections Checklist and a Maintenance Checklist for Ship Masters.
Providing a high level of support is typical of IACS members. Lloyd’s Register, for example, has a Fleet Quality Management Program to help owners raise their standards and is actively involved in supporting owners wishing to operate well beyond compliance levels. DNV offers PSC Wizard software, a quick-reference booklet, and the recently released PSC: Synopsis of Frequent Findings and Detention Items. As well as company-specific analysis reports, new in 2011, DNV also offers various workshops tailored to company needs and delivered to crew onboard vessels.
Toward a Global Standard
The new Paris MOU inspection regime is widely perceived as resulting in poor performing ships being inspected more frequently and more extensively than good performers. It is anticipated that it will be taken up more widely, and Schiferli is already in close contact with Tokyo MOU. “I am confident that with the support of our members and the industry we can substantially reduce the operation of substandard ships and their operators in our region,” he stated. “At the same time, it should be possible to prevent them from seeking employment elsewhere in the world. If other regional PSC agencies adopt a similar regime, this could be realized and maritime safety on a global basis could benefit.” – MarEx
Wendy Laursen is the magazine’s Australian correspondent.
The opinions expressed herein are the author's and not necessarily those of The Maritime Executive.