A summary on monthly activities from the IFSMA Office.
June 2013
|
INTRODUCTION This is the first report for a few months. I will not bore you with the details, but it is sufficient to say that the missing months were due to computer problems and loss of information. IFSMA has not been idle but more so the opposite with many exciting opportunities coming to the front. This month has a whole lot of information in respect of matters immediate and for the rest of the year. The beginning of the month has seen a number of new projects that have been worked on for months are starting to come to fruition. The 15th of this month was the 1st anniversary of me holding the position of Secretary General of IFSMA. A lot has developed over this year and there will be more changes to come. IMO This month has seen two major events in the IMO Annual Calendar. Symposium on the Future of Ship Safety 10 – 11 June 2013 Symposium on the Future of Ship Safety 10 – 11 June 2013 Day 1 focused on SHIP SAFETY – WHERE ARE WE? Day 2 focused on SHIP SAFETY – ACHIEVING OUR GOAL Representing IFSMA at this Symposium was:- Captain Christer Lindvall President Intervention Day 2 – Post Lunch Session “Good Afternoon, I am representing the International Federation of Shipmasters` Associations. I want to thank all the speakers for their interesting presentations. Our concerns as representatives of the Shipmasters are mostly connected to the operational matters and the human element, where the Masters are responsible – without - in many situations - sufficient support and resources. 1. In spite of the technical development and all the successful stories relate to improvement in fuel efficiency, safety arrangements and systems it is quite frustrating that we still experience fatigue to be one of the most common causes in relation to accidents. 2. We are striving to improve effectiveness in all aspects of ship operation, but are we working in the right direction when we accept seafarers to work 98 hours pr. week for up to 10 months a year. What other industry is practicing such a work load. 3. How can we minimize the administrative work and the burden it has on board which we all know (and have been emphasized by Mr Andreas Nordseth). 4. Another subject is the amount of human and work related injuries in the engine rooms and due to poor ergonomically design. Is it not time to insert a new SOLAS regulation regarding the design of the engine room and the control room as we already have a broad regulation regarding the bridge design?” Maritime Safety Committee (MSC) 92nd Session 12 – 21 June 2013 Captain Christer Lindvall President GENERAL OBSERVATIONS (THE FOLLOWING OBSERVATIONS WERE SUPPLIED BY MR ALLAN GRAVESON BEFORE THE MEETING) MSC 92 to be held 12 – 21 June 2013. This is an eight day Meeting with an extensive Agenda and 110 Papers to date. While not as overtly political as MEPC, inevitably, there will be issues of an environmental nature where the Flag States will be divided along the usual lines. Of particular note will be the Presentation of the Accident Investigation into the Costa Concordia incident of January 2012. MSC 92 is likely to attract four or more IFSMA Representatives. This will include Representatives that do not usually attend the Sub-Committees; therefore, they may not be fully aware of issues. It is essential to ensure that not only Plenary is staffed throughout but appropriate staffing of Working Groups. I would strongly advise that WG 1 Passenger Ship Safety is staffed appropriately and to ensure both policy and technical expertise is available. It is reported that the following Working, Drafting and Expert Groups will be established: • WG 1 Passenger Ship Safety Agenda Item 2 Decisions of Other IMO Bodies – This is limited to the 38th Session of the Facilitation Committee and the 100th Session of the Legal Committee. It will be important to listen to the presentations by the Secretariat and any subsequent discussions. It may be necessary to intervene with respect to the Legal Committee, given the work undertaken there, by IFSMA. Agenda Item 3 Consideration and Adoption of Amendments to Mandatory Instruments – There are a number of amendments to various IMO Mandatory Instruments including: The 1974 SOLAS Convention and Associated Instruments; The International Maritime Solid Bulk Cargoes (IMSBC); The 1979, 1989 and 2009 MODU Codes and the DSC Code; The International Convention for Safe Containers (CSC) 1972; and The Protocol of 1988 relating to the International Convention on Load Lines 1966. In addition and perhaps of more importance will be the request for MSC to adopt the Code for Recognised Organisations ( RO Code). It is not envisaged there will be any substantive objections to these amendments, however, the possibility cannot be excluded. It is anticipated there may be some discussion with respect to reinstating the 4-year interval for the entry-into-force of amendments to the SOLAS Convention, allowing different intervals under exceptional circumstances. It is recommended that this position should be supported. Similarly, support should be given with respect to the amendments to SOLAS with respect to passenger and lifeboat drills and the mandatory requirement for prior entry enclosed spaced drills. A supportive intervention may be necessary. Agenda Item 4 Measures to Enhance Maritime Security – Of particular note is Paper MSC 92/4/1 Guidelines for the Implementation of the International Ship and Port Facilities Security Code (ISPS Code) by companies submitted by the Republic of Korea. It is reported that this is not considered necessary by Flag States. While it may be useful, there are the possibilities that the outcome may be unhelpful with respect to ship Masters. It is recommended not to intervene and remain neutral on this issue. Agenda Item 5 Goal-Based Ship Construction Standards – This is an important issue and has the potential to undermine previous prescriptive safety standards in several mandatory instruments including SOLAS, MARPOL and Load lines. It is important that Goal-Based Standards (GBS) are not considered mutually exclusive to a prescriptive approach. It is unlikely that an intervention will be required; however, it may be necessary to give qualified support to ensure that current standards are maintained or improved. Agenda Item 6 Passenger Ship Safety – Needless to say all the Papers either directly or indirectly relate to the Costa Concordia incident. i) Paper MSC 92/INF.6 and 92/6/3 submitted by Italy refers to the Report on the Costa Concordia Marine Casualty Investigation and Preliminary recommendations arising from the Costa Concordia Marine Casualty Investigation. The Report is as expected and concentrates upon the ‘Human Element’. While there are some useful recommendations contained within the Report, the scope and depth of the Report should be questioned. Regulators and Accident Investigation Specialists have said privately, if not publicly, they have grave concerns with respect to the Report and consider it to be dangerous in that it does not address the fundamental issues that affect safety within the cruise industry. The Report itself is a translation from Italian and therefore some of the text requires further explanation. Caution should be exercised with respect to being drawn into arguments concerning the ‘Human Element’ as presented within the Report. Fundamentally, this has been a failure of the International, Regional and National Regulatory Systems to ensure that vessels are constructed to the highest standards possible to ensure survivability and an orderly evacuation. Furthermore, the Report demonstrates the failure of adequate selection and training of crews to ensure adequate manning (quantity) and selection (quality). This is best illustrated by the designated working language for the vessel being Italian but which was not used on an everyday basis with subsequent problematic issues in an emergency situation. It is strongly recommended that IFSMA make a strong intervention referring to the Policy Document adopted in 2007 and amended in 2012. It is important in this context to refer to the root causes of this incident, rather than the immediate cause. The suggested line to take is that while the Master is largely responsible for the cause of the incident, he is not alone and includes other parties, both onboard and ashore. The consequence rests with the Regulatory Authorities. This is best illustrated in that this Report was not conducted by an Independent body. While it is tempting to refer continually to the Costa Concordia, it is also important to look at cruise ship safety in general in accordance with the IFSMA Policy Document in order to mitigate the consequences of a future incident of whatever nature. See Speaking Note 1 ii) CLIA have submitted a Paper 92/6/1 proposing additional measures to those already included in MSC.1/Circ. 1446/Rev.1 which addresses securing of heavy objects, harmonisation of bridge procedures and the location of lifejacket stowage. While these issues appear to be perfectly obvious and should already be in place, these proposals should be accepted to ensure adoption throughout the industry. iii) As a result of the discussions and Presentation at the 55th Session of the Sub-Committee on Stability, Load Lines and Fishing Vessel Safety, the EU Member States and the European Commission have proposed in Paper 92/6/6 that several issues related to the required Sub-Division Index “R” be discussed. The intention of the European Commission is to improve the risk factor with respect to the loss of more than 1000 passengers from a 1:20 to a 1:100 year event on ro-ro passenger vessels. This can best be achieved with respect to new vessels by an increased Sub-Division. This is not necessarily a panacea for improved stability and survivability, however, it is worthy of consideration and support. Research has confirmed that regardless of the “S” value, vessels may be subject to rapid sinking and capsize and therefore, consideration of “R” together with a holistic approach to improved Sub-Division of both passenger and ro-ro passenger vessels should be considered. With the adoption of the probabilistic framework, the concept of the Margin Line has been dispensed with. Therefore, the question arises as to whether in suggesting a limitation on the number of down flooding points; it is wise to consider a vessel as survivable when the bulk head deck is flooded up to the down flooding points? N.B. The European Commission have sought support for their Paper 92/6/6. See Speaking Note 2 Agenda Item 7 Dangerous Goods, Solid Cargoes and Containers – This is the Report of DSC 17.Issues concerning containers remain to be addressed, however, it is worth noting the continued work being undertaken in Geneva concerning the joint development with the ILO of a Code applicable to road, rail, shipping and seaports intended to replace current guidance. Therefore, there is no substantive comment to make. Agenda Item 8 Fire Protection – This is the Report of FP 56. Attention is drawn to Paper 92/INF.10 testing of automatic sprinkler systems on passenger ships submitted by the Bahamas. Of particular concern is that the evaluated failure rates suggest the scope of testing in MSC.1/Cir.1432 may not adequately assess the actual condition of automatic sprinkler systems. As an INF Paper, this is only to be noted, however, this does raise issues over the adequacy of current guidelines. Attention is also drawn to Paper 92/8/1, two means of escape from machinery control rooms and main workshops submitted by IACS. This detailed Paper considers the issues of both a separate control room and workshop and their co-location with respect to both stairway and trunk escape routes. The suggestive alternative wording, dependent upon any counter arguments are contained in Section 7 of the Paper. Support may be necessary. Agenda Item 9 Radiocommunications and Search and Rescue – This is the Report of COMSAR 17. Attention is drawn to Paper 92/9/2 Recognition of the Iridium mobile-satellite systems submitted by the United States. It is anticipated that there will be some discussion concerning the acceptability of this system in competition with INMARSAT. From a technical point of view, it is noted that INMARSAT is 99.9% reliable whereas Iridium is anticipated to be only 99% reliable with respect to essential safety communications. It is advised, should it be necessary, that IFSMA intervene to respectively point out the current reliability of the INMARSAT system and should not seek to undermine the present levels of reliability. Agenda Item Bulk Liquids and Gases – This is the Report of BLG 17. Attention is drawn to Paper 92/10/3, comments on documents MSC 92/10. The US proposes the exclusion of low flash-point diesel from considerations in the IGF Code. Consideration of flash-point is a safety issue, however, it must be recognised that residual fuel oil requires heating on board and distillate does not require heating. On balance, it is suggested to oppose any reduction in flash-point, although it is anticipated that a compromise may be suggested. Agenda Item 11 Stability, Load Lines and on Fishing Vessels Safety – This is the Report of SLF 55. It is noted that the issue of the Tonnage Measurement Convention is on-going. Paper 92/11/2 submitted by Finland and Japan and Paper 92/11/3 submitted by the United States makes comment with respect to the provisions for cross-flooding on passenger vessels. It has been noted that inadequacies exist with respect to the evaluation of cross-flooding arrangements. It is known this is of considerable concern to IACS. Depending upon the introduction of these Papers and the discussion, it may be necessary to make an intervention stressing the importance of resolution of this issue. Agenda Item 12 Flag State Implementation – This is the Report of FSI 21. i) There are 3 Papers on the investigation and reporting of serious casualties. Paper 92/12/4 submitted by the ICS and ITF refer in general to the failure to submit Maritime Casualty Reports to the IMO. Paper 92/12/3 submitted by the ITF and Paper 92/12/5 submitted by IFSMA while referring to the failure of states to investigate and report serious casualties to the IMO; specifically identify the issue of the Danny F II where a UK Master was lost. It is suggested that a supportive intervention be made with respect to the joint ICS/ITF Paper. With respect to the IFSMA Paper 92/12/5 a Speaking Note will be prepared. See Speaking Note 3 ii) While IFSMA is not directly involved in this issue, it is worth noting Paper 92/12/1 amendment to Resolution A.600 (15) on the IMO ship identification number scheme, submitted by Australia, Canada, Ghana, Nigeria, South Africa, Spain, United Kingdom, Vanuatu, FAO and WWF. This Paper concerns the numbering of fishing vessels and is likely to be opposed by countries in the Far East since this will readily identify the number of fishing boats under their flags. Intervention is not considered necessary; however, the sponsoring states are seeking support. Attention is also drawn to Paper 92/12/6, relationship between Global Regs and existing Codes submitted by Antigua and Barbuda, Jamaica and St. Kitts and Nevis concerning the relationship between Global Regs and existing Codes. It is reported that a number of countries are concerned at this move since this may bring about regionalisation of regulation with respect to non SOLAS vessels. No substantive comment to make. Agenda Item 13 Ship Design and Equipment – This is the Report of DE 57. Paper 92/13/1 making the provision of MSC.1/Circ.1206/Rev.1 mandatory submitted by the ITF is worthy of support. Currently ship Masters are placed in a difficult position when pressurised by management to conduct life boat drills in accordance with SOLAS without taking into account the guidance in MSC.1/Circ.1206/Rev.1. It is essential that the present confusion is removed and Masters are removed from the difficult position from which they are placed. The United Kingdom has submitted Paper 92/3/12 concerning the carriage of more than 12 ‘passengers’ which they refer to as ‘industrial personnel’ this issue is of particular importance to the offshore energy sector, particularly ‘renewables’. This issue requires careful consideration; however, there is a long established practice, particularly with new vessels of dockyard personnel embarking on a vessel’s maiden voyage. But, this usually does not exceed 12 except with respect to ro-ro passenger vessels and passenger vessels and are therefore compliant. This concept, providing it is limited to the offshore energy sector in particular ‘renewables’ should not necessarily be opposed. However, it should be necessary to guarantee that such vessels are specifically built for purpose and fitted out to an appropriate standard with respect to life saving appliances. Reports from this sector suggest that this is not the case. Agenda Item 14 Training and Watchkeeping – This is the Report of STW 44. There are a number of issues reported by the Secretariat and attention is drawn to a number of issues including colour vision testing and training for specific requirements such as low flash-point fuels and the requirements of MODUs. Reference is also made to the requirements of the Polar Code and it is suggested that no substantive comment be made at this time on this issue. Agenda Item 16 Capacity-Building for the Implementation of New Measures – No substantive comment to make. Agenda Item 17 Formal Safety Assessment – While this is an important issue, this industry remains reluctant to adopt FSA. No significant discussions are expected. Agenda Item 18 Piracy and Armed Robbery Against Ships – This is on-going and an important issue to ship Masters. While there has been a significant reduction in the number of incidents in the Gulf of Aden, there has been a substantial increase off the coast of West Africa. Particular attention is drawn to Paper 92/18/1 incidents off the coast of West Africa submitted by Greece. It is recommended that a short intervention of support should be made. Agenda Item 19 General Cargo Ship Safety – Other than Papers submitted by the Secretariat, no other Papers have been submitted. Apparently the Secretariat keeps this issue on the Agenda due to the large number of vessels lost. Agenda Item 20 Implementation of Instruments and Related Matters – No substantive comment to make. Agenda Item 21 Relations with Other Organisations – No substantive comment to make. Agenda Item 22 Review and Reform of the Organisation, Including Application of the Committee’s Guidelines – There is expected to be extensive discussion on this Agenda Item. While much has already been discussed, there is considerable support for the Secretary General’s plan for re-organisation of the Sub-Committees. Intervention should not be necessary. Agenda Item 23 Work Programme – Of particular importance is Paper 92/23/2 concerning proposed amendments to SOLAS Regulation ii-1/22 and MSC.1/Circ. 1380 and concerns watertight doors. The proposal for a new unplanned output to address this important issue to define precisely the conditions under which a door may be open during navigation needs to be confirmed. Furthermore, it is anticipated that this unplanned output may develop to include the redesign of watertight doors so as to prevent death and serious injury. Agenda Item 24 Election of Chairman and Vice-Chairman for 2014 – No substantive comment to make. Agenda Item 25 Any Other Business – Attention is drawn to Paper 92/INF.8 Bulk Carrier Casualty Report submitted by INTERCARGO. It is reported there has been a significant reduction in the loss of bulk carriers and loss of life. No substantive comment to make. In Paper 92/INF.13 the ILO draws attention to a meeting of experts to adopt guidelines on the training of ships’ cooks that will be held in Geneva from 23-27 September 2013. As food and stomachs are close to the heart of most seafarers, this is an issue that should not be ignored. SPEAKING NOTE 1 – PASSENGER SHIP SAFETY – PAPERS MSC92/INF.6 and 92/6/3 Thank you Chair, IFSMA representing the shipmasters notes the Papers MSC 92 INF.6 and 92/6/3 summated by Italy concerning the investigation into the Costa Concordia. Following concern amongst members IFSMA adopted in 2007 a Policy Document entitled Safety of Large Passenger Vessels. This Document raised concerns with respect to; construction, watertight integrity and stability; fire fighting systems; life saving appliances and evacuation systems; manning and training. This was revised in 2012 after further concerns were expressed with respect to power loss and stability including large angles of heel when turning. The Master shoulders great responsibility for the cause of this incident, but he is not alone. The consequence is shared by the failure of the regulators that so often adopt a ‘light touch’ - this industry is not alone in such an approach - in seeking to satisfy the short term business objectives of owners rather than ensure a long term sustainable industry. This report says a great deal, both stated and in what is implied to the reader, be they a professional mariner or a member of the public, that something is seriously wrong with the regulatory system that permits the construction and operation of ships in such a manner. This is not as the Report seeks to make out as unique. Time will be the judge of the usefulness of this Report. It is over one hundred years since the report of Lord Mersey into the Titanic. While in a different language, the language of the day, the 24 Recommendations hold good to this day and in particular with respect to construction, manning and life saving appliances. Regrettably, these have yet to be fully implemented; after 101 years the true intention of holding muster and safety instruction for passengers was implemented IFSMA requests that this statement is recorded in the proceedings of the Committee. Thank you Chair. SPEAKING NOTE 2 – PASSENGER SHIP SAFETY – PAPER MSC92/6/6 Thank you Chair, IFSMA representing the Shipmasters thanks Austria et al and the European Commission, for Paper MSC92/6/6 concerning the Survivability of passenger ships. IFSMA wishes to draw attention to Papers MSC 91/7/2, MSC 91/7/3 and MSC 91/7/4 submitted by the United Kingdom to MSC 91; lost but not to be forgotten. Ro-Ro ferries are particularly vulnerable with greater risk of capsize. It is not desirable to accept a 1:20 year event of the loss of 1000 passengers or more. This as in other industries should be set at 1:100 year event. Contrast the risk factors applied in shipping, if they ever applied at all, with those of aviation. The subdivision indices should be increased as stated in the Paper for all passenger ships. With a mind to the content of Paper MSC 92/6/7 submitted by the United States this is noted. IFSMA supports the need for greater sub-division. This is not a complex issue it is simply an issue of ‘buoyancy.’ With respect to passenger ships, a useful starting point would be the Titanic Investigation, Recommendation 1 that suggests two longitudinal bulkheads in preference to double side-skin, so avoiding the reduction of revenue earning capacity by the relocation of crew cabins on passenger ships. IFSMA rejects the ‘moderate’ approach in favour of a more ‘precautionary’ position. Society will not look favourably on an industry that chooses to ‘dilute’ sensible proposals for new vessels that could avoid significant loss of life. The accident will not wait for the regulator, we must act now. IFSMA requests that this statement is recorded in the proceedings of the Committee. Thank you Chair SPEAKING NOTE 3 (IFSMA PAPER) – FLAG STATE IMPLEMENTATION – PAPER MSC92/12/5 Thank you, Chair. This Paper is submitted due to the frustration of one of our member associations, Nautilus International, not being able to obtain the facts concerning the loss of the Panamanian registered livestock carrier Danny FII that capsize with the loss of thousands of sheep and cattle and over 40 souls – seafarers and stockmen. The British Master, a member of IFSMA went down with his ship. If the Secretary General’s objective of reducing deaths at sea by 50% is to be achieved, it is essential that full and complete investigations are carried out. Then the findings and recommendations are acting upon. This is important for the families who have lost so much. This Paper is submitted with the best of intent. IFSMA seeks improved safety for all seafarers. IFSMA requests that this Committee considers how the FSI Sub-Committee could encourage Flag States and substantially interested States to meet their international obligations so as to bring about an increased level of safety, improved protection of the environment and a reduction in the number of deaths at sea. Thank you, Chair MEETINGS NGO GROUP MEETING 20 – June – 2013
At IFSMA HQ In Attendance: HCMM Geoff Cowap IFSMA John Dickie Apologies: SRI Deirdre Fitzpatrick The meeting convened at 1230 hours and completed at 1410 hours. IFSMA acted as the co-ordinator for the meeting and provided a buffet lunch. Each member present introduced themselves to the Group IFSMA will continue to coordinate the Group and follow the suggestions for topics to be covered at the meetings. IMPA offered to hold meetings in the future. The majority of the work is by email correspondence plus 2 to 3 meetings per year. This will be determined by the Group. Peter Swift gave an introduction in respect of Maritime Piracy: Human Response Programme (MPHRP) and what it tries to achieve. In respect of expanding the group ITF suggested that BIMCO and ICS be invited. (Jeppe S. Juhl - jsj@bimco.org) was suggested. VIDEOTEL A meeting took place at the IMO with the Deputy Chairman of Videotel to discuss better cooperation and understanding between the two organizations. This will be followed up by further meetings in the future to identify areas of mutual benefit to move matters forward on potential projects. PUKKA FILMS This was an initial meeting with this company who produced the DVD “The Human Element” a film about the role of human behaviour in safety at sea. This was a fact finding meeting about who they are, where they come from and what products that can be provided. SEAFARERS’ RIGHTS INTERNATIONAL (SRI) This is an on-going and open ended relationship between both organizations. One of the topics is the project to produce a DVD or equivalent on the subject of the “Criminalization of the Seafarer”. There is also the matter of progressing human rights of seafarers throughout the maritime industry. Maritime Piracy: Human Response Programme (MPHRP) The Annual General Meeting was held at the IMO. IFSMA supports and works with this organization and is recognized as one of the organizations that are recorded as such on the organizations’ supporters list. One of the high profile cases that this organization has been involved in was the after care of the crew who were released from the ‘ICEBERG’ at Somalia after over 1000 days of captivity. NAUTICAL INSTITUTE (NI) A meeting with the NI CEO was held to identify areas of mutual interest and to look at ways of working together on future projects. It was agreed to meet after the summer and investigate the possibility of IFSMA working with the NI in reviving the Command Seminar Programme. GlobalMET A number of informal meetings with the head of this organization were held to identify how both organizations can work together on areas of mutual interest. One possibility is a joint GlobalMET, IFSMA, AMUSOP Seminar to be held in Manila on the day after the Informa M&T Conference in 2014. This will need to be negotiated and agreed upon. INTERNATIONAL MARINE PILOT ASSOCIATION (IMPA) Initial discussions have been held to discuss the use of Pilot Exemption Certificates (PECs). At this time there are no definitive statistics in respect of this matter. IFSMA does not oppose PECs as long as everyone involved is in agreement, but there are a number of unsubstantiated reports of Masters being coerced to take such action to save on pilot use and costs. No action can be taken: there has been a consensus with the member Associations and a plan has been agreed. Safety4Sea Forum This will take place in October 2013 in Athens Greece. IFSMA has once again been asked to speak at this conference and has accepted. Hanson Wade Conference – Security in Challenging Environments (28-31 October) IFSMA has been invited to speak at and also take part in plenary sessions at this conference which is being held in London. Development on speaking papers on this matter will be circulated later. Honorary Members Lunch – 25 September 2013 This special occasion is progressing well and 7 of the 9 honorary members have accepted the invitations. These include the present and previous two Secretary Generals of the IMO. All members of the Executive Council have replied and will be attending as well as the Secretariat. This will take place on the second day of the forthcoming Executive Council Meeting scheduled for 24 September 2013. Membership Malta Venezuela Outstanding Fees A number of Individual Members have outstanding fees. This is being followed up and appropriate action will be taken. AGA 40 - SandeFjord, Norway The date for this event has still to be set. The date of the IMO MSC Meeting will determine the dates for this special AGA in which a number of office bearers of IFSMA will be standing down and new personnel need to be found. The IMO Council Meeting set for Mid-July will resolve this issue and then agreed dates will be set by NMOA and IFSMA Secretariat, then circulated to all members. Special Case President Christer Lindvall has been leading this case and has now requested that the Secretariat use its connections and influence to build up support to try and obtain the release of these two Masters. Any progress will be reported each month as this matter moves forward. Currently IFSMA is trying to gain support from other NGOs to add strength to this campaign. It should be noted that both ships and the crews are still under arrest in Sao Tome waters. All crew members face the possibility of being arrested. Captain John W. Dickie
|
