IMO FORMAL SAFETY ASSESSMENT. Report of the FSA Experts Group

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1 INTERNATIONAL MARITIME ORGANIZATION E IMO MARITIME SAFETY COMMITTEE 86th session Agenda item 17 MSC 86/WP.9 4 June 2009 Original: ENGLISH DISCLAIMER As at its date of issue, this document, in whole or in part, is subject to consideration by the IMO organ to which it has been submitted. Accordingly, its contents are subject to approval and amendment of a substantive and drafting nature, which may be agreed after that date. FORMAL SAFETY ASSESSMENT Report of the FSA Experts Group General 1 The FSA Experts Group met from 28 May to 3 June 2009 under the chairmanship of Mr. K. Yoshida (Japan). 2 The group was attended by experts from the following Member Governments: CHINA DENMARK FINLAND GERMANY GREECE INDIA ITALY JAPAN MARSHALL ISLANDS NORWAY REPUBLIC OF KOREA SWEDEN UNITED KINGDOM UNITED STATES and experts from the following non-governmental organizations in consultative status: INTERNATIONAL ASSOCIATION OF CLASSIFICATION SOCIETIES (IACS) OIL COMPANIES INTERNATIONAL MARINE FORUM (OCIMF) INTERNATIONAL ASSOCIATION OF INDEPENDENT TANKER OWNERS (INTERTANKO) CRUISE LINES INTERNATIONAL ASSOCIATION (CLIA) INTERFERRY Terms of reference 3 The experts group was instructed, taking into account comments made and decisions taken in plenary, to:.1 review FSA studies submitted by documents MSC 83/21/1, MSC 83/21/2, MSC 83/INF.3, MSC 83/INF.8, MSC 85/17/1, MSC 85/17/2, MSC 85/INF.2 and MSC 85/INF.3, and, in particular, on each FSA study, to: For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.

2 MSC 86/WP consider whether the methodology was applied in accordance with the FSA Guidelines and the Guidance on the use of HEAP and FSA;.2 check the reasonableness of the assumptions and whether the scenarios adequately addressed the issues involved;.3 check the validity of the input data and its transparency (e.g., historical data, comprehensiveness, availability of data, etc.);.4 check whether risk control options and their interdependence were properly evaluated and supported by the assessment;.5 check whether uncertainty and sensitivity issues have been properly addressed in the FSA study;.6 check whether the scope of the assessment was met in the FSA study; and.7 check whether expertise of participants in the FSA study was sufficient for the range of subjects under consideration, and provide a report on the above issues, which should include a discussion on any strengths and weaknesses, the lessons learnt regarding the FSA Guidelines and the Guidance on the use of HEAP and FSA, and their application and the evidence used to support the conclusions;.2 consider the proposed final recommendations in each FSA study and advise the Committee for consideration and decision;.3 consider the number of sessions needed to complete the review and whether there is a need for an intersessional meeting of the group and advise the Committee as appropriate; and.4 submit a report to plenary by Thursday, 4 June The group, having received presentations from the invited SAFEDOR representatives who carried out the FSA studies, reviewed the aforementioned documents, taking into account documents MSC 86/17/1 and MSC 86/17/2. The main issues discussed by the group are outlined hereunder. Common findings on FSA studies carried out by SAFEDOR 5 After its first review on FSA studies carried out by SAFEDOR, the group identified the common aspects outlined in paragraphs 6 to 21 below. Preliminary discussions on FSAs on cruise ships, RoPax ships, LNG carriers and containerships are attached as annexes 1 to 4, respectively. High-level FSA studies 6 The group recognized that the FSA studies carried out by SAFEDOR were high-level FSA studies, which aimed at estimating current risk levels of some ship types and suggesting potential risk control options (RCOs) for further enhancement of safety and/or environment protection. The group noted that the SAFEDOR FSAs did not request IMO to take any

3 - 3 - MSC 86/WP.9 immediate actions on the proposed RCOs. The group also noted that the identified RCOs are in some cases similar in the SAFEDOR FSAs. While some experts appreciated that the outcome of estimated risk levels would facilitate future consideration of risk-based approaches aiming at enhancement of ships safety, other experts expressed concerns that some of the FSA studies proposed the same recommendations (e.g., mandatory requirement of ECDIS, which has already been taken into account in IMO) and that more detailed FSA studies and ship-specific RCOs may be needed. Expertise of participants in the FSA studies 7 The group, having noted that the list of the project team was not included, and human element expert could not be identified in some FSAs, was of the view that a brief background of each expert engaged in the FSA study; the structure, selection and composition of the project team; and the method of decision making should be included in the FSA report. Validity of the input data and its transparency 8 The group noted that the current commercially available casualty data (e.g., LRFP and LMIU) lack detailed descriptions of accidents and causes, and also noted that IMO GISIS may include more precise information, but that it is not an exhaustive casualty database. The group recognized the importance of such information on causes and details of accidents and stressed the need for causes of accidents to be provided. The group also recognized that any commercially available casualty data should be examined for suitability of use in an FSA study. 9 Concerning the need for transparency of data used in FSAs, the group, while noting the benefit of disclosing casualty data used for the FSA, realized the difficulty of disclosure of commercial casualty data due to intellectual property rights and the agreement contract with data providers. Subsequently, the group agreed that reports of FSAs should indicate clearly applied selection criteria and the method of analysis of casualty data and identification of hazards (HAZID), and that this information should be examined during the review of the FSA. The group also agreed to consider further the issue of casualty databases. 10 The group also agreed that, if an FSA uses data sources of other FSAs, the link and reference to the original FSA should be clearly indicated. Gap between step 1 (HAZID) and remaining part of the assessment (steps 2 to 4) 11 It was pointed out that there could be unidentified hazards and uncommon accidents which could happen in the future. Such hazards and accidents could be identified by analysis and consideration of experts. Therefore, the selection and composition of an FSA team in HAZID is important for an FSA. 12 The group noted that near-miss data from shipping companies and survey data from classification societies may give useful information for the identification of possible hazards and accidents by experts. 13 With respect to the gap between the identified hazards (step 1) and the remaining part of the risk assessment (steps 2 to 4), while the representative from SAFEDOR explained that they had focused on major risks and RCOs which would directly relate to loss of life and that identified hazards were sometimes found to be omitted, the group thought it appropriate that steps 2 to 4 should take into account all the major identified hazards unless the selection criteria are explained and justified.

4 MSC 86/WP The group noted that the HAZID report carried by SAFEDOR would be available to the public on its website. Risk control options 15 The group, while noting the explanation by the representative from SAFEDOR that their FSA studies covered both preventive and mitigation RCOs, noted that some FSA models focused on mitigation RCOs rather than preventive RCOs of accident types. 16 The group recognized that the criteria for the selection of RCOs for cost benefit analysis were not clearly reported in some FSA reports. Sensitivity and uncertainty 17 The group noted that some FSAs considered sensitivity and uncertainty of the results of the analysis but others did not. In this respect, the group recognized that the requirement of analysis on sensitivity is not clearly indicated in the current FSA Guidelines, while the Guidance on the use of HEAP and FSA specifies that uncertainty and sensitivity is to be reviewed. Therefore, it would be necessary to consider the inclusion of the provisions of sensitivity analysis in the FSA Guidelines in future. Concordance among FSA team 18 While the representative from SAFEDOR explained that any disagreement among the project team and expert group for HAZID was solved by consensus in some FSAs, it was suggested in the group that the methodology to reach the consensus should be reported accordingly. Other matters 19 During the discussion, it was pointed out that the scopes of FSA studies carried out by SAFEDOR were somewhat limited to safety, in particular fatality, and, therefore, it was suggested that environmental issues as well as safety of property should also be taken into account in future FSAs. 20 Taking into account the fact that risk models for certain types of ships would be similar, it was suggested that generic risk models may be developed for facilitating future FSAs, although it was recognized such a development would need considerable effort. 21 Having noted that the SAFEDOR project was completed and the project team was disbanded, the results of the review on these FSAs carried out by SAFEDOR would not include any suggestions or recommendations of re-calculation, re-analysis or any further work on the FSAs. In this connection, the representative from SAFEDOR advised that they would endeavour to give necessary information and answers to the FSA Expert Group in reviewing the FSAs. Lesson learnt on the FSA Guidelines and the Guidance on the use of HEAP and FSA 22 Following the above discussion, the group found that there are some discrepancies between the FSA Guidelines and the Guidance on use of HEAP and FSA, which should be solved in future.

5 - 5 - MSC 86/WP.9 Composition of the FSA Experts Group 23 With regard to the instruction by plenary that experts who were involved in specific FSA studies should only provide information on those studies, the group recognized that some experts nominated for review work might have been related to the FSAs but were not directly involved in any of the FSA studies. Therefore, the group considered that all the nominated experts listed in document MSC 86/17/3 could remain in the FSA Experts Group for further review, which is in line with the instruction by plenary. It was also noted that each expert should work as an individual and independent expert. Number of sessions and intersessional arrangement 24 During its review of the FSA studies, the group realized that more time was needed to review the FSA studies and agreed to further examine these FSA studies, in order to complete the tasks instructed by the Committee, through correspondence among the nominated experts, coordinated by Japan, and invited the Committee to approve an intersessional meeting of the FSA Experts Group (tentatively scheduled from 2 to 6 November 2009 at IMO Headquarters), with the following terms of reference:.1 to finalize the review of FSA studies submitted by documents MSC 83/21/1, MSC 83/21/2, MSC 83/INF.3, MSC 83/INF.8, MSC 85/17/1, MSC 85/17/2, MSC 85/INF.2 and MSC 85/INF.3, and, in particular, on each FSA study, to:.1 consider whether the methodology was applied in accordance with the FSA Guidelines and the Guidance on the use of HEAP and FSA;.2 check the reasonableness of the assumptions and whether the scenarios adequately addressed the issues involved;.3 check the validity of the input data and its transparency (e.g., historical data, comprehensiveness, availability of data, etc.);.4 check whether risk control options and their interdependence were properly evaluated and supported by the assessment;.5 check whether uncertainty and sensitivity issues have been properly addressed in the FSA study;.6 check whether the scope of the assessment was met in the FSA study; and.7 check whether expertise of participants in the FSA study was sufficient for the range of subjects under consideration, and provide a report on the above issues, which should include a discussion on any strengths and weaknesses, the lessons learned regarding the FSA Guidelines Coordinator: Mr. Koichi Yoshida Dr. Yoshitaka Ogawa Director Head of Ship Structural Standards Research Group Centre for International Cooperation Structure and Materials Department National Maritime Research Institute National Maritime Research Institute Tel: Tel: Fax: Fax: koichiy@nmri.go.jp ogawa@nmri.go.jp Website: Website:

6 MSC 86/WP and the Guidance on the use of HEAP and FSA, and their application and the evidence used to support the conclusions;.2 to consider the proposed final recommendations in each FSA study and advise the Committee for consideration and decision; and.3 to submit a report to MSC Subsequently the group, taking into account the above intersessional arrangement, advised the Committee that the review on the aforementioned FSA studies would be completed at the next session of the Committee. 26 The group was of the opinion that the FSA reported to the MEPC in documents MEPC 58/17/2 and MEPC 58/INF.2 could be reviewed during the intersessional period until MSC 87, subject to the decision by the MEPC. 27 Furthermore, the group was informed that the sixth and final FSA studies by SAFEDOR, which concern dangerous goods on board open-top containerships, would be submitted to MSC 87 before the proposed intersessional meeting, and considered that the group could start reviewing these FSA studies at the intersessional meeting, if time permits. Appreciation to FSA studies carried out by SAFEDOR 28 The group expressed its appreciation to Denmark and the SAFEDOR project for their submissions of the FSA studies to the Organization and also to the representatives from SAFEDOR for providing useful presentations and information, which facilitated the group s review, and also expressed its hope for further cooperation from members of SAFEDOR, with a view to finalizing review by the FSA Experts Group. Action requested of the Committee 29 The Committee is invited to approve the report in general and, in particular, to:.1 note the group s discussion on the review on FSA studies referred to the group at this session, in particular the common aspects identified by the group (paragraphs 5 to 22 and annexes 1 to 4);.2 noted the group s view on the use of databases, in particular the importance of data on causes and details of accidents (paragraphs 8 and 9);.3 endorse the group s consideration on composition of the FSA Experts Group (paragraph 23);.4 consider the group s proposal for the intersessional arrangements, including the terms of reference, by correspondence and its request for an intersessional meeting, together with the number of sessions to complete the review, and decide as appropriate (paragraphs 24 and 25); and.5 endorse the group s view that they could start reviewing the MEPC documents, subject to the relevant decision by the MEPC, as well as the expected final FSA study carried out by SAFEDOR, if time permits (paragraphs 26 and 27). ***

7 MSC 86/WP.9 ANNEX 1 REVIEW ON FSA ON CRUISE SHIPS (MSC 85/17/1, MSC 85/INF.2) The following are the major points discussed in the FSA Experts Group at MSC 86, concerning FSA on cruise ships, in addition to issues described in the main report. Whether the scope of the assessment was met in the FSA study The group noted that the aim of the FSA was to show the current safety (risk) level of cruise ships, which would contribute to the future detailed FSA studies and/or research projects and also noted that no immediate action was recommended. Whether the expertise of participants in the FSA study was sufficient for the range of subjects under consideration (see paragraph 7 of main report) The validity of the input data and its transparency (see paragraphs 8 to 10 of main report) The reasonableness of the assumptions and whether the scenarios adequately addressed the issues involved The group agreed to further examine the FSA, in particular regarding event trees and each probability. Whether risk control options and their interdependence were properly evaluated and supported by the assessment The group noted that the work of the reported FSA focused on mitigation measures which may significantly reduce the risks of the current modern cruise ships. The group also noted that, however, the FSA included preventive RCOs by referring to a previous FSA. Whether uncertainty and sensitivity issues have been properly addressed in the FSA study The group noted that the FSA considered sensitivity/uncertainty on RCOs to improve damage stability in terms of the subdivision attained index A. Other issues The representative from SAFEDOR explained that there was no disagreement among the experts participating in HAZID. Whether the methodology was applied in accordance with the FSA Guidelines and the Guidance on the use of HEAP and FSA (to be further examined) ***

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9 MSC 86/WP.9 ANNEX 2 REVIEW ON FSA ON ROPAX SHIPS (MSC 85/17/2, MSC 85/INF.3) The following are the major points discussed in the FSA Experts Group at MSC 86, concerning FSA on RoPax ships, in addition to issues described in main report. Whether the scope of the assessment was met in the FSA study (to be further examined) Whether expertise of participants in the FSA study was sufficient for the range of subjects under consideration (see paragraph 7 of main report) The validity of the input data and its transparency (see paragraphs 8 to 10 of main report) The reasonableness of the assumptions and whether the scenarios adequately addressed the issues involved Regarding the question of the gap between the identified hazards (HAZID: step 1) and the remaining part of the risk assessment (steps 2 to 4), the representative from SAFEDOR, having explained that the purpose of FSA was for use in the rule-making process in IMO, replied that, while there were some gaps, they focused on major risks which would directly relate to loss of life (fatality) regardless of the hazard identified in the FSA. In this respect, with regard to the concern raised in the group that the FSA mainly dealt with the mitigation of consequences of the risks (i.e. flooding, fire, collision and grounding) rather than prevention of causes of the risks (e.g., prevention of collision and grounding), the representative from SAFEDOR replied that they considered that risk control options (RCOs) which would significantly reduce total risks were important, and some prevention measures were less effective. Why risk of Ropax (F-N Curve) is higher in the FSA Model than those in historical data Regarding the reason why the risk level of Ropax (F-N Curve) is higher in the FSA Model than those in historical data in spite of various amendments to SOLAS (e.g., comprehensive amendments to SOLAS chapter II-1 on damage stability which entered into force in 2009), the representative from SAFEDOR replied that the current risk level of Ropax was still high, based on their risk model (e.g., the approximate subdivision attained index A of Ropax is less than 0.8). Whether risk control options and their interdependence were properly evaluated and supported by the assessment Concerning the major RCO to improve damage stability and survivability, the group noted the complexity of the issue (e.g., these measures may cost more due to drastic changes of design and payload. The group agreed to further examine the matter, taking into account the stability requirements in SOLAS chapter II-1 (which entered into force in 2009) and ongoing work by the SLF Sub-Committee.

10 MSC 86/WP.9 ANNEX 2 Page 2 Whether uncertainty and sensitivity issues have been properly addressed in the FSA study The group noted that the FSA included an uncertainty diagram, but that it was necessary to investigate further the appropriateness of the analysis. Whether the methodology was applied in accordance with the FSA Guidelines and the Guidance on the use of HEAP and FSA (to be further examined) ***

11 MSC 86/WP.9 ANNEX 3 REVIEW ON FSA ON LNG CARRIERS (MSC 83/21/1, MSC 83/INF.3) The following are the major points discussed in the FSA Experts Group at MSC 86, concerning FSA on LNG carriers, in addition to issues described in main report. Whether the scope of the assessment was met in the FSA study (see paragraph 6 of main report) Whether expertise of participants in the FSA study was sufficient for the range of subjects under consideration (see paragraph 7 of main report) The validity of the input data and its transparency (see paragraphs 8 to 10 of main report) The reasonableness of the assumptions and whether the scenarios adequately addressed the issues involved The representative from SAFEDOR explained that major scenarios, leading to fatalities, were covered. It was pointed out the risks for the ships were well covered. However, the group noted that risk to port facilities and the surrounding environment was not well covered in case of cargo leakage. Whether risk control options and their interdependence were properly evaluated and supported by the assessment The group noted the explanation by the representative from SAFEDOR that the interdependence of RCOs was not strong and that it would not alter the result. It was pointed out that many RCOs had already been implemented by major LNG operators or taken into account in IMO, and also that hazards related to loading/unloading were not considered further in the assessment. It was suggested that the comprehensive review of the IGC Code be taken into account. Whether uncertainty and sensitivity issues have been properly addressed in the FSA study It was pointed out that the background of risk reductions of some identified RCOs was not clear. Whether the methodology was applied in accordance with the FSA Guidelines and the Guidance on the use of HEAP and FSA (to be further examined) ***

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13 MSC 86/WP.9 ANNEX 4 REVIEW ON FSA ON CONTAINERSHIPS (MSC 83/21/2, MSC 83/INF.8) The following are the major points discussed in the FSA Experts Group at MSC 86, concerning FSA on containerships, in addition to issues described in main report. Whether the scope of the assessment was met in the FSA study The representative from SAFEDOR explained that the FSA is a high-level FSA, which dealt with modern containerships, taking into account crew safety in terms of loss of life as well as environmental risks. Whether expertise of participants in the FSA study was sufficient for the range of subjects under consideration (see paragraph 7 of main report) The validity of the input data and its transparency (see paragraphs 8 to 10 of main report) The reasonableness of the assumptions and whether the scenarios adequately addressed the issues involved The representative from SAFEDOR explained that the outcome of HAZID was integrated into their risk model. While the presentation by SAFEDOR covered the explanation of the risk model well, in particular the sequence, it was pointed out that some of the identified casualty categories, such as heavy weather, were not clearly defined. Whether risk control options and their interdependence were properly evaluated and supported by the assessment The representative from SAFEDOR stated that combination of RCOs was not considered. It was pointed out that some of the proposed RCOs were already covered by the recent amendment of SOLAS or other IMO instruments on a recommendation basis. Whether uncertainty and sensitivity issues have been properly addressed in the FSA study The group noted that a sensitivity study had been performed by systematically varying some key input parameters and observing the effect on the final results. The representative from SAFEDOR explained that the high level risk model was considered to be accurate enough to be used as a basis for conclusions and further identification of needs for and assessment of possible risk control options. Whether the methodology was applied in accordance with the FSA Guidelines and the Guidance on the use of HEAP and FSA (to be further examined)

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