Last week, Capt. John Mauger, commanding officer of the Marine Safety Center, spoke to the Passenger Vessel Association at the annual MARITRENDS convention about innovation in the maritime industry. As a courtesy to our audience, Maritime Commons is providing an excerpt of his remarks.
The maritime industry is a dynamic and innovative industry. Over my lifetime, cargo ships have gone from carrying 15 containers to 15,000 containers; offshore platform vessels have grown in complexity from simple supply boats to complex support vessels for all manner of operations; and new technologies have been incorporated into machinery and navigation systems enabling autonomous operations. This widespread innovation is particularly notable in the passenger industry where cruise ships have gone from carrying hundreds of passengers with limited amenities to carrying thousands of passengers with an unlimited array of amenities. On the smaller scale, casino boats, extremely low fire load fast ferries, submersible reef viewers, and alternative power sources are further examples of innovation within the industry. These examples all point to a framework and industry that support innovation while continuing to meet public expectations for safety.
If we consider innovation within the maritime industry today, there are three major factors that are driving new designs, manufacturing and operating methods. First, there is a growing demand by all stakeholders to increase use of the waterways and maritime transportation system. This trend is evident in the growing size and number of vessels operating on our domestic waters. The second factor is the growing demand by customers, stakeholders within the supply chain, and the public to reduce the environmental footprint at all stages of the vessels lifecycle. This factor isn’t unique to shipping, but it is causing vessel designers, builders and operators to optimize design and operations for efficiency and incorporate new machinery and technology onboard to manage waste streams. Lastly, the combined drive to increase utilization while reducing footprint is forcing more complexity into the maritime system. Machinery, automation and power systems used onboard ships are increasingly more complex in order to enable larger, faster, more efficient operations.
Faced with these challenging demands, an often-heard refrain is that the regulations are constraints and must be made more nimble, in order to better support innovation. However, as the evolution of shipping over the last three decades has shown, the existing structure is already able to incorporate innovation while sustaining safety. There are a number of methods to support innovation within the existing framework. These methods range from:
(1) redesigning materials or systems to meet the existing standards;
(2) demonstrating equivalencies to the existing standards—either through alternative standards or risk assessments;
(3) developing documented alternative policies; or
(4) petitioning for new regulations or legislation.
These methods form a continuum of options available to designers and the Coast Guard for considering innovation within the industry. Often an innovation may start with one strategy and develop into another strategy over time. There are a number of well documented examples of how these different strategies have been used to foster innovation, such as the approval of new fire-rated boundaries, the use of alternative power sources, the inclusion of long-main vertical zones, and the acceptance of very large offshore support vessels.
At the Marine Safety Center, the primary way we support innovation is through evaluating equivalencies to the existing regulations. The regulations allow the Coast Guard to accept alternative arrangements which provide an equivalent level of safety to the existing standards. The Marine Safety Center’s engineers have education and experience in more than a dozen different engineering disciplines which enable them to evaluate alternative submissions. The preferred way for demonstrating equivalency is for the submitter to demonstrate that the proposal meets alternate industry-wide standards that are appropriate for the application. In cases where no such standards exist, the submitter may demonstrate equivalency through either a ‘first principles’ approach (in the case of engineered systems) or through a risk assessment. There is a variety of guidance available to assist the industry with preparing such submissions. The Marine Safety Center is also able to hold concept review discussions with submitters to assist in further defining the equivalency approach.
The maritime industry has a proven track record for safely incorporating new methods and technology into vessel design, construction and operation. The Coast Guard’s ability to consider equivalencies to the existing standards is an important means of promoting innovation within the maritime industry. The Coast Guard’s marine safety engineers, who possess both the specialized education and broad experience needed to evaluate novel design features, are a key enabler for supporting innovation within the industry. Submitters who are interested in promoting innovation within the industry are encouraged to discuss their plans with the Marine Safety Center at the early stage of design.
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.
Categories: Commercial Vessel Compliance, Design & Engineering Standards, Emerging Policy, Environmental Response Policy, Investigations & Casualty Analysis, Navigation Systems, Operating & Environmental Standards, Ports and Facilities, Safety, Standards Evaluation & Development, Vessel Documentation, Waterways Policy