The MOL Comfort broke into two approximately 200 nautical miles off the coast of Yemen in June 2013. Photo: gcaptain.com
On the ship-building front, work continues on bringing goal-based construction standards into international mandatory regulations through the IMO, with the aim of improving ship strength and construction. Goal-based standards are comprised of at least one goal, functional requirement(s) associated with that goal, and verification of conformity that rules/regulations meet the functional requirements including goals[i]. These standards offer an alternative to the traditional prescriptive-based regulations for ship construction which have proved to be inflexible when it comes to regulating construction standards for modern ship designs. AGCS’ Klimczak believes that goal-based standards offer the flexibility that traditional rules lacked, opening the door to innovation in ship design.
In addition to the progress of goal-based standards, 2015 saw the adoption of two unified requirements by the International Association of Classification Societies (IACS), designed to improve the safety of large container ships by enhancing consistency between existing classification society requirements. The rulings, known as UR S11A and UR S34, set a longitudinal strength standard and deal with loading conditions for containerships[ii]. Both are in response to the findings of the Japanese report into the 2008-built, 8,110 teu MOL Comfort casualty, which sank suddenly in 2013 about 200 nautical miles off the coast of Yemen.
The rulings only apply to new ships, which AGCS experts find disconcerting. “The key issue here is that the new safety measures are for the construction of new ships, but that implies there is a question mark over the structural integrity of existing ships,” says Kinsey. “We are concerned about this. The rules are certainly welcome but was the investigation of the MOL Comfort robust enough to address structural issues completely and entirely? These are questions that remain unanswered.”
Fatigue guidance review: The IMO’s subcommittee on Human Element, Training and Watchkeeping (HTW), initiated a revision of fatigue guidance in 015, agreeing that the review should be completed by 2017. The review will adopt a risk-based approach and will consider the impact of fatigue at all levels[iii]. The original guidance on fatigue mitigation and management dates back to 2001.