Opening the Artic for Business: The Risk-based Approach to Polar Code

By Luis Guarin, Director, Safety Engineering, Safety at Sea Ltd. November 4, 2011

The IMO’s Sub-Committee on Ship Design and Equipment (DE) is working on a mandatory Code for ships operating in Polar waters — widely known as the Polar Code, to supplement other regulatory instruments, including SOLAS and MARPOL. The Code will seek to address the specific risks relating to operations in Polar waters, taking into account the extreme environmental conditions and the remoteness of many locations.
The International Association of Antarctica Tour Operators (IAATO), set up in 1991, to advocate and promote safe and environmentally responsible private sector travel to the Antarctic, represents over 100 private sector companies – the majority of which are passenger ship operators. It has expressed its concern that any new rules should properly reflect the diversity of operating conditions in Polar regions. Consequently, it has been working with UK-based Safety at Sea Ltd on a risk assessment - based study of passenger vessels operating in Antarctic waters. Dr. Kim Crosbie, environmental operations director of IAATO, said, “We wanted to take into account all the diverse elements associated with operating in the Antarctic, including the geography, climate, seasonable variables and the diversity of the fleet, to evaluate the hazards, risks and possible mitigation methods. Our goal is to create a tiered risk approach which could be used in the development and application of a mandatory Polar Code.”
IAATO has aimed to develop a framework for voyage risk assessment which could be used in voyage planning, preparation and execution, and for managing and authorizing activity in line with safety requirements.
The organization also wanted to get involved in the process because it was concerned that the Polar Code could become overly prescriptive using a broad-brush approach. This might have some advantages, in being relatively easy to understand and implement, for example. However, inflexibility might have an adverse impact on shipping, without any corresponding benefits in terms of safety. For example, rules that might appropriately be applied to vessels operating in the dark winter months or heavy ice conditions might not be as relevant for operations the continuous daylight of summer in ice free waters. Again, a relatively large cruise vessel that sails through ice free waters and does not land passengers, faces different safety issues to a small expedition type craft that can land up to 100 persons onshore at a time.

Cold comfort
Luis Guarin, Director of Safety at Sea, comments: “Based on the research we have carried out together with IAATO, we are now strongly advocating that IMO takes a goal-based and risk-informed approach to developing requirements under the Polar Code. What we want to avoid is a ‘one size fits all’ set of rules and regulations. The core concept is that the requirements of a Polar Code should be based on an understanding of the level of risk implicit in particular circumstances.”
An initial study carried out by Safety at Sea at IAATO’s request reviewed the current operational activities of IAATO members and created a preliminary risk assessment of passenger ship operations in Antarctic waters that could be used in the planning, preparation and execution of a voyage. The process involved defining key problems, identifying potential hazards, analysing risk and assessing various Risk Control Measures (RCMs).
The description of the activities of the IAATO members and their operational environment set the scene for the study and involved both an overview of the IAATO fleet and a detailed analysis of a representative vessel. The patterns of tourism were assessed and a representative voyage was identified and used as an example for the risk assessment.
In addition seven key environmental and defining features - sea ice cover, sea water temperature, sea conditions, air temperature, traffic levels, Search and Rescue (SAR) response and navigational chart coverage and availability - were evaluated and used to define five representative sea areas within the Antarctic region. A qualitative risk assessment was undertaken to assess the potential influence of identified factors and hazards on the level of risk. A total of 25 hazards were identified including, for instance, sea ice, unknown bathymetry, and poor surveys. Subsequently, Safety at Sea assessed the potential influence of various factors and events on potential risk, specifically in terms of the impact on people, associated with passenger vessel operations in Antarctic waters. The Safety at Sea study concluded that a high risk to human life was posed by grounding, contact with ice and medical emergencies; while a moderate risk to life was presented by a vessel becoming stranded in ice, a collision with another vessel and heavy weather damage. The most significant hazards contributing to overall risk were inexperienced crew and poorly maintained vessels. Other significant factors included localised, extreme weather; large seas and swell; and having limited assets available to carry out a rescue.

Historical analysis
The risk analysis carried out by Safety at Sea used historical casualty data and a sample voyage itinerary to assess the frequency of incidents and the incidence of exposure to grounding and ice hazards. The process also involved modelling to estimate the probability of all possible outcomes in the event of grounding or contact with ice. This included, for example, structural vulnerability, flooding vulnerability and exposure and vulnerability to environmental factors. The historic data analysed by Safety at Sea covered more than 630 ship years and 74 incidents, including 45 medical evacuations (although these were not specifically related to the operating environment), 14 groundings and five incidents of heavy weather damage.
Some 66 RCMs (Risk Control Measures) were identified, analysed and ranked. These included RCMs already implemented through international legislation such as SOLAS, STCW and ILO and IAATO’s self-management systems. They also included specific requirements implicit in the IMO Guidelines for Ships Operating in Polar Waters.
The analysis assessed the extent to which RCMs were operational, as opposed to being factors related to vessel design and construction or equipment specification. It also looked at whether they were related to crew experience; associated with poorly maintained vessels; or were related to significant Antarctic environmental hazards.
The study found that over half of the identified RCMs are operational in nature, with the remainder relating to ship construction and equipment. Similarly, more than half the RCMs are for mitigation, to influence the consequences of an eventual accident, and 36% for prevention. The remaining 12% have elements of both prevention and mitigation.
At least 15% of the identified RCMs related to inexperienced crew and 12% to measures relating to significant Antarctic hazards such as localised, extreme and unpredictable weather conditions and not having SAR assets readily available. None of the measures explicitly addressed the hazards associated with poorly maintained vessels, although Safety at Sea points out that this is clearly one of the most significant factors contributing to risk. One of the key conclusions was that the risks associated with certain events are proportional to the exposure to ice. This, it was pointed out, varies on a month to month basis within areas, and between areas of the Antarctic.

Ice strengthening
The study observed that the probability of exposure to ice hazards could be reduced to a negligible level by means of an ice routing service and by implementing effective training for ice navigation. It also came to the conclusion that it was ‘reasonable’ that any SOLAS vessels intending to operate in areas and times of the year where the probability of meeting ice hazards was high should be ice strengthened to some degree.
However, Mr Guarin observes: “Ice strengthened hulls could mitigate the severity of the consequences of contact with ice. However, measures to prevent the occurrence of grounding or contact with ice should be prioritised.”
Given that in Antarctica SAR assets might not be readily available, damage stability standards for vessels in Antarctic waters should be consistent with the principle that the vessels is its own best lifeboat. This requires the level of survivability of a vessel to be subjected to realistic ice damage and that raking damages are fully evaluated and understood.
According to Mr Guarin: “Current damage stability standards, including those implicit in SOLAS 2009, do not cover such items. These standards are based on damage characteristics relating to collisions with vessels and do not explicitly address the issues of survival time, an important consideration in the Antarctic.” Risks associated with other events, such as grounding, are voyage-specific and are almost independent from exposure to ice. The study also pointed out that factors such as the availability of search and rescue assets vary both geographically and seasonally and that this has implications for RCMs. It further recommended that measures aimed at increasing crew understanding and competence should be prioritised. “Even slight variations in factors such as itinerary, destinations, month and so on can lead to big variations in risk. These variations have to be accounted for in any regulatory framework,” suggests Mr Guarin. In the opinion of both Safety at Sea and IAATO the findings of the study justify taking a risk-based approach within the development of the Polar Code. Mr Guarin says: “If the Code is too prescriptive then there will inevitably be some inconsistencies in how it is applied and we believe the approach we are suggesting would avoid that.”
The study has now been submitted to IMO as a ‘case study’ to assist with the development of the Polar Code. Dr Crosbie concludes: “Discussions within IMO have started and, while it is early days, we are hopeful that the strength of this analysis will be recognised by the regulators.”