Singapore Maritime Week and the Green Curriculum
Captain Jeffrey Parfitt FNIIn the April edition of Seaways, I outlined the role of the Maritime Technologies Forum (MTF) in working towards the transition to green fuels in the maritime industry. The MTF was established to provide technical and regulatory expertise, publishing research based on its members’ expertise and offering unbiased advice to industry. It recently launched a significant paper on ‘Operational Management To Accelerate Safe Maritime Decarbonisation’. This report evaluates whether existing regulations are sufficiently detailed to support the acceleration of safe maritime decarbonisation.
This analysis is primarily concerned with ammonia and methanol, stating that the use of these fuels ‘requires sound management procedures and trained personnel on board ships’. In particular, the report scrutinises the existing requirements contained within the ISM Code, STCW and the MLC. It identifies gaps that have been overlooked in the ‘perceived urgency’ to move to future fuels and makes recommendations on how these gaps can best be filled. The paper demonstrates that The Nautical Institute is in close alignment with the MTF position, and contains a reference to our own Green Curriculum. It can be downloaded here.
Speaking out
To mark the launch of the paper, The Nautical Institute was invited to participate in a prestigious MTF panel during Singapore Maritime Week. Our CEO John Lloyd represented The Nautical Institute during a discussion panel, along with Chris Wiernicki, CEO of ABS; Nick Brown, CEO of LR, Captain Ninad Sharad Mhatre, Managing Director of Zeaborn Ship Management and Caroline Yang, President of the Singapore Shipping Association. The panellists were asked to comment on a series of questions. One of these was ‘Are the ISM Code; STCW Convention and MLC sufficiently detailed to support accelerating safe maritime decarbonisation?’
In the view of The Nautical Institute, they are not, although we accept that the framework for a baseline training course does exist within the STCW IGF course structure. And this is the point of the MTF report and the panel, to highlight the gaps in the current system and to propose solutions that will enable a swift and safe transition for seafarers who need to learn to use the proposed alternative fuels within an ever contracting timeframe.
The ISM Code
The ISM Code is primarily focused on ensuring the safe operation of ships. It places great emphasis on the Safety Management System and the necessity for comprehensive risk assessments. In theory, the ISM Code already has a framework for safe handling of hazardous fuels from the perspective of safety and pollution prevention.
But establishing a basis for the safe handling of new fuels isn’t just about the theory of existing legislation and recommendations. Many of us have first-hand experience of ISM implementation, and there is a striking variance in interpretation and application, not only from company to company but often from ship to ship within the same company. Further, bearing in mind the industry has very little experience of dealing with these fuels, there is a lack of familiarity with the necessary risks, hazards and control measures. It is therefore incumbent upon all industry stakeholders to identify training needs, develop training materials and provide training.
The report places great emphasis on the importance of the Safety Management System (SMS), suggesting that an additional risk assessment is carried out by the company to assess all hazards posed by the fuels. This can be used as a basis from which the SMS can ‘be updated to include necessary measures to control identified risks, mitigate consequences of an unexpected event, and prevention measures as applicable. This includes establishing inspection and maintenance schedules and development of emergency response plans,’ the report says.
It goes on to suggest the development of a guidance document produced by industry stakeholders and submitted to the IMO, setting out a list of emergency scenarios, drills and associated guidance.
I would suggest that any significant risk assessment of this kind must encompass various emergency scenarios that in turn would require a rethink on fire-fighting techniques, safety equipment and emergency contingency training. It can no longer be taken for granted that existing traditional fire-fighting techniques will suffice. Will there be a requirement for personal breathing apparatus? Should lifeboats be re-designed to ensure survivability within a cryogenic atmosphere?
STCW
Next, we turn to STCW. The MTF review identifies a number of insufficiencies within model courses and a lack of incentives for training course developers. In order to close these gaps, they recommend that ‘industry stakeholders’ collaborate with training providers and that public and private funds should be made available to training course developers – an interesting recommendation and we await first movers on funding.
Whilst not explicitly identified, it would seem reasonable to assume The Nautical Institute could have a part to play in facilitating effective communication and in recommending and/or developing guidelines for model courses. After all, we are one of the world’s largest professional maritime membership organisations, and we are able to call upon unbiased expertise across industry. It would seem reasonable that practising mariners who know a thing or two about going to sea are consulted in this process.
In the revised Nautical Institute Perspective published in January, we identify and support the Just Transition Taskforce recommendation to utilise the existing IGF dangerous cargo courses as a template for alternative fuels training. There is a need for urgent action, and we encourage and support swift regulatory change.
It has been proposed that flag States could review the training materials and audit the training providers to ensure consistent delivery in line with the IMO model courses. Consideration should also be made to auditing original equipment manufacturer (OEM) training courses to improve consistency and alignment.
However, there is no doubt that the flag State oversight of the delivery of existing STCW courses is variable. The report labels this ‘regulatory uncertainty’ and highlights an ‘inconsistent implementation of training’. Due to the high level of health and safety risks associated with these alternative fuels, it is vital that consistency in the global training standard is achieved. Perhaps there is a requirement for an independent and unbiased auditor of this process that would allow for a harmonised application of standards?
MLC
Finally, we turn our attention to the Maritime Labour Convention (MLC). The MLC lacks reference to alternative fuels. The IMO and industry must work closer to close the identified gaps. The MTF recommend that flag states, seafarers’ organisations and shipowners forums could make submissions to a special tripartite committee to include references of risks posed by alternative fuels to the seafarers’ working and living conditions. It is important that the right industry partners are selected to cooperate – and that means involvement of professional seafarers organisations such as The Nautical Institute.
The report goes on to suggest that ‘…reference to alternative fuels could be made in Part B of the [Maritime Labour] Code and international guidelines which will ensure that the member States will address the relevant requirements in their national legislation’.
Next steps
The key stakeholders of the MTF have made an excellent job in constructing this report. It is objective and we are broadly in alignment with it. The Nautical Institute has the resources and technical outreach to advise in a professional capacity whilst remaining independent and impartial. We are, in the words of the Maritime Technical Forum, ‘unbiased’.
The MTF panel during Singapore Maritime Week proved a huge success, drawing full attendance and resulting in valuable connections with interested stakeholders, keen to learn about The Nautical Institute position and future collaboration.
Recent global events have demonstrated that the world is now well and truly in to the 4th industrial revolution. With the US announcing tens of billions of dollars of government investment in green energy and industries and the EU struggling to keep pace, it is clear there is no way back or room to stand still. The IMO is expected to announce stricter GHG emission targets, thereby contracting the timeframe for fuel transition and increasing the urgency of transformation.
Seafarer training will be discussed at the IMO during MSC 107 in June, with an emphasis on the new skills required to safely handle these hazardous fuels. Here at The Nautical Institute, we intend to remain closely involved with this debate and to collaborate with like-minded industry partners to ensure that our concerns for the safety of seafarers handling these alternative fuels are expressed at the highest level.
We shall continue to update our members.
Download the Nautical Institute’s Green Curriculum here