Commercial Vessel Compliance

10/17/2014: Confronting today’s safety issues for ferries

Last week, Jeffrey Lantz, director, commercial regulations and standards for the Coast Guard, spoke at the 39th Annual Interferry Conference. For those of you who could not attend the conference, Maritime Commons is providing Lantz’s remarks…

Delivered by Jeffrey Lantz

I believe passenger ship safety, which includes ferries, is a very topical and relevant issue for discussion.

First of all, I need to highlight the value of ferries in today’s world. The global ferry industry transports approximately 2.1 billion passengers annually – roughly on par with the airline industry. In addition, ferries transport 250 million vehicles and 32 million trailers every year. Clearly, ferries are a vital and indispensible element in today’s globalized and connected world, and often times are the only reliable form of transportation in certain parts of the world.

Now let’s consider a couple of other numbers: 9,000 – that is the number of people who have perished in ferry accidents worldwide in this century. This comes out to an average of around 650 deaths per year. This number is probably lower than the actual number of lives lost as I relied solely on information available in the public domain.

I’m sure that most of us here today are aware of the tragic accident and circumstances regarding the Sewol that occurred in the Republic of Korea in April of this year with 293 lives lost, most of them students. Tragic as this was, since that accident, there have been at least three more ferry accidents that I am aware of that resulted in the loss of well over another 100 lives. Unfortunately, the sad truth is that the frequency of these tragic accidents does not appear to be diminishing.

That said, we must consider these statistics in the proper context. Clearly, the number of lives lost is an extremely small percentage of the overall number of people carried on ferries each year and, without reservation, it can be said that, overall, ferries are an extremely safe mode of transportation. That bears repeating – ferries are safe.

It is also useful to examine the details of these accidents. Upon closer examination two aspects become immediately evident. First of all, overwhelmingly these accidents are occurring on ferries in domestic service as opposed to international service. This means the ferries are not subject to the International Maritime Organization’s international safety standards as enforced by the flag state and port state control. Secondly, they are occurring in developing countries which may indicate issues associated with crew and ship management, competency and capacity, and that these countries’ maritime administrations may have difficulty overseeing the safety of their domestic maritime transportation systems.

This really means that it is difficult for the international community to try and improve the situation and reduce the numbers of lives lost. Ultimately, the countries experiencing these casualties will need to find the will and resources to improve their own safety records. But, just because it is difficult and because we can’t directly improve the situation, I do believe the international community still has an obligation to try and help. We should consider it as a call to confront today’s safety issues.

So let’s examine what we are doing today and then perhaps we can look into the future to see what else can be done. I’m going to focus on what can be, and is being done by the international community, through the International Maritime Organization.

As mentioned earlier, and as everyone should know, IMO’s remit is limited to safety standards for international shipping, and not domestic shipping. This means that when it comes to ferries in domestic service, IMO really has no hard leverage to affect change to increase safety in this segment through its normal mechanism of legislated mandatory safety requirements. However, that said, I believe IMO has a vital role and is in a unique position to drive positive change. It has highlighted and brought awareness to the issue of domestic ferry safety. It can also bring together the right people to develop the safety standards as well as those who are willing and able to work with countries to help them improve their domestic ferry safety.

So, let’s look at what IMO is doing because actually, at this moment, there is a fair amount of work ongoing directed at the broader issue of passenger ship safety. The impetus for the current effort is the Costa Concordia incident off the coast of Italy in 2012. While the focus of the effort remains cruise ships, undoubtedly some of the outcomes at IMO will impact international ferries, especially those on longer voyages and overnight service.

IMO and passenger ship safety are inextricably linked. In fact, the world’s response to the Titanic led to the creation of IMO. More recently, this is the second time in a relatively short period of time that IMO has considered this issue. The first began in 2000, when IMO embarked on a journey to holistically examine passenger ship safety noting the increasing risk over time, primarily due to the ever- increasing size of ships and numbers of passengers along with increasingly remote voyages, and wondering if the passenger ship safety regime in SOLAS really was up to the task to address these increased risk factors. The outcome of this effort, which took the better part of a decade, amended the International Convention for Safety of Life at Sea and, in doing so, firmly established the principle that the ship is its own best lifeboat. Therefore, the design of new passenger ships needs to be such that if a casualty occurs, such as a fire or grounding, the ship would survive with the passengers being able to remain onboard instead of having to abandon the ship.

However, the Costa Concordia incident has caused IMO to once again re-examine the current safety regime for passenger ships. And in some sense, there may be somewhat of a second “Titanic moment” because here is a case where a ship had to be abandoned and could not serve as its own lifeboat. While it is true that the Costa Concordia was not required to meet IMO’s updated safety standards due to its build date, by all accounts that would not have mattered. The extent of damage was so significant that this ship, even if constructed to the new standards, would not have survived. This reinforces what we learned over 100 years ago – there is no unsinkable ship. So with this in mind, IMO is examining the Costa Concordia accident for lessons learned and also to see if there were any risk factors from the earlier study that were not adequately addressed.

As I mentioned, this work is currently ongoing at IMO, and to date there are a number of outcomes worth noting. I will briefly highlight some of them as they may relate to ferries.

The first thing IMO did was to adopt a set of Recommended Interim Measures. These were first adopted in June 2012 and have since been added to and updated twice, the last time being in August 2013. Perhaps the most significant to the ferry industry are the measures directed at making sure passengers are aware of emergency procedures, for instance, know where lifejackets are stowed and how to don them and where to go in an emergency. Other recommended operational measures addressed voyage planning, passenger muster, lifeboat training for the crew, and harmonization of bridge procedures across a company’s fleet of ships.

What is also notable about these recommended measures is that many of them came as a result of an internal review by the Cruise Lines International Association, or CLIA, which they initiated after the Costa Concorida accident. This review continues to this day, and CLIA has continued to provide IMO the results of its review along with any recommendations for improving the safety regime.

In addition to Recommended Interim Measures, IMO adopted new mandatory requirements for passenger muster and safety briefings for ships on voyages over 24 hours. IMO is also examining a number of other items focused on actions by crew and passengers after a casualty, which may lead to additional mandatory requirements. These include damage stability training for the crew, emergency response training for the crew, damage control drills for passengers and mandatory evacuation analysis.

IMO is also considering the design of passenger ships, especially the larger ships, to enhance the damage stability survivability requirements. While there is no such thing as an unsinkable ship, I do believe this is an area that must be examined. Today’s larger ships with much larger numbers of passengers and crew call for a higher standard of damage survivability.

Along with these ongoing concrete actions, IMO has also identified a number of other issues that may be considered in the future, of which I’ll highlight a couple. The first is to examine standards for ship design and arrangement of essential systems in order to preserve the functionality of these systems in the event of a casualty. The other is review the effectiveness of plans for cooperation for search and rescue. The rescue of a ship with a large number of passengers and crew is a daunting task, even for the most capable of the worlds’ search and rescue entities, but even more so when the ship is located in a remote region, such as one of the polar regions.

This brings me to highlight two other ongoing initiatives at IMO that may not initially be associated with passenger ship safety, but which undoubtedly are. The first is the Polar Code, for which the safety provisions are expected to be adopted by IMO in November of this year. The Polar Code will require passenger ships to have a Polar Water Operations Manual to address the increased risk of operating in the Polar Regions; voyage planning; navigation training for operating in ice covered waters for the crew; equipment certification for operating in low temperatures; and additional survival communications and kits in the event of a casualty.

The second initiative is the development of the International Code of Safety for Ships Using Gases or Other Low-Flashpoint Fuels, otherwise known as the IGF Code, which is expected to be adopted by IMO in June 2015. This is increasingly more relevant to ferries as the option of using liquefied natural gas, or LNG, as propulsion fuel becomes more attractive for a number of reasons. First, ferry operations involving relatively frequent and short runs are free from the problem of having to carry large quantities of LNG fuel if they can refuel at frequent intervals. Secondly, there is the relatively low price of LNG. Finally, LNG combustion yields very low emissions.

The use of LNG as fuel is especially inviting for countries that have an abundance of natural gas and which also have an Emission Control Area, such as the U.S. and Canada. For example, I know the Washington State Ferry system is actively considering the use of LNG for some of their ferries.

While the IGF Code will only apply to ships on international service, I expect a number of countries will use it as the basis for any national requirements to address ships in their domestic service that use LNG as fuel. This is what we expect to do in the United States as the Coast Guard is actively working to develop our own national standards for ships using LNG as fuel.

In addition to safety issues for passenger ships, and in spite of not having a legal remit to address through mandatory requirements, IMO is also taking positive action to improve safety for ferries in domestic service. As the Secretary General has recently announced, IMO will strengthen its Technical Cooperation Program on domestic ferry safety with a goal of providing safety recommendations and guidelines that can be used by maritime Administrations in developing countries. IMO’s technical cooperation program is well suited for this effort as it was specifically established to assist developing countries administer their programs for marine safety, security and environmental protection.

In addition to the recommendations and safety guidelines, IMO is also preparing for a major conference on domestic ferry safety in April next year to discuss how IMO and the maritime community will be able to tackle this issue. Invited to attend and contribute to this conference will be representatives from other countries as well as experts from the private sector, including industry, class societies and academia.

Earlier I had mentioned the participation and input from industry to IMO’s passenger ship safety effort. In that regard let me highlight and sincerely thank Interferry for its contribution and value to IMO. Interferry has enjoyed observer status at IMO since 2003 and is a frequent contributor to IMO on both safety and environmental issues. This is important as IMO needs the input and assistance from the industry.

In addition, and closer to the issue of safety of ferries in domestic service, Interferry has been active with IMO and signed a memorandum of understanding in 2006 to embark on a ten year effort to improve domestic ferry safety. Since then, Interferry has worked with IMO through its Technical Cooperation Program to assist developing countries and while some modest progress has been made in a number of southeastern Asian countries, clearly there is more to be done.

Ferry service is a very safe mode of transportation. However, we also need to acknowledge that there are safety issues facing passenger ships, including ferries, especially domestic ferry service in certain parts of the world, which we must continue to confront. The numbers of incidents and lives lost bear this out. Will it be simple? Will it happen overnight? In a word – No. The numbers of incidents and the reasons for them vary widely.

Individual countries must also feel the call for action. However, too often, it seems to take a massive incident with dramatic loss of life to change the course of maritime safety, either internationally or internally within a country. Let us collectively work together to ensure this doesn’t occur and I encourage all of us to think about how we can contribute to this very worthwhile effort.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.