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Ladies and gentlemen, it is a pleasure to be here before such a
distinguished audience.
I want to do
several things in the few minutes available to me.
I particularly
want to congratulate the magnificent city of St Petersburg on its
300th birthday.
I want to ask
for your help to make this a safer industry, without the need for
further intrusive regulation.
I want to spend
some time addressing the major challenges confronting class societies.
And I want to
stress that my comments are made in the spirit of continuous improvement.
I recognize
what has been achieved, while at the same time emphasize that there
is always more that can and should be done.
What do I mean
by this?
The statistics
speak for themselves.
By whatever
measure you choose, the safety record of the maritime industry is
one of quite remarkable improvement over the last few years.
Close to six
billion tons of cargo are transported by sea every year.
An infinitesimally
small proportion is lost in transit.
Right now there
are more than one million seafarers at work on more than 87,000
commercial vessels of more than 100 gross tons.
It is statistically
likely that between two and three hundred will lose their lives
in the next twelve months.
That is a highly
regrettable reality. But it is a safety performance that would be
the envy of most similarly risky industries.
Of those 87,000
vessels, 86,800 are statistically likely to safely navigate the
seas for the next twelve months.
Of the 200 that
can be projected as possible losses, only 30 will be lost due to
structural failure.
These are impressive
statistics.
They are more
than statistics, they are the reality of an industry with an outstanding
safety record.
But I have another
reality to share with you.
It is not good
enough.
When one tanker
spills oil on a populated coastline, the effectiveness of the existing
maritime safety system will be called into question.
And it will
be found wanting.
The result will
be further regulation.
It is because
our best is still not good enough that today I will suggest some
changes in the manner in which this industry functions.
The process
has traditionally been one of incremental change.
When an area
needing improvement is identified, the industry responds with targeted
remedies, whether through the IMO or within classification Rules.
It is a process
that has served the industry well.
But I do not
believe it is the appropriate response at this time.
We operate today
within a changed environment.
- The public
demands more of us.
- The nature
of shipowning has changed.
- The tools
available to the class societies are far more sophisticated today
than even 15 years ago, and
- The pressures
on the shipbuilding industry are different to those of the past.
It is time for
the maritime safety system to recognize these changes and adapt
to them in a rational and effective manner if the classification
profession is to retain any relevance in the future.
We must be prepared
to lead these changes by adopting bold, pro-active and co-operative
measures that offer renewed confidence in the classification system
to all those who rely upon our impartiality and expertise.
I want to take
a moment to contrast the circumstances of the last great tanker
building boom of the early 1970s with today.
Thirty years
ago, the majority of orders were placed by the oil majors.
In the 1970s
these organizations did not need class.
- They had
large, highly skilled technical departments.
- They had
their own construction standards.
- They had
equally rigid maintenance procedures and
- Thirty man
crews stayed on top of the continuous battle against rust and
damage.
The owners’
own requirements often went beyond those of class.
When it came
to maintenance, class was a partner with the owner, not a watchdog.
That same ship
today would be for the account of an independent owner.
No matter how
responsible that owner may be, he must operate within an unforgiving,
competitive market.
Controlling
costs is crucial to his success.
Part of that
cost control has been the elimination of most in-house technical
departments.
The classification
societies have become the de facto technical resources for the industry.
Both the classification
societies and the shipyards have extremely sophisticated computer
programs available to them to analyze and optimize designs.
As a result,
there is less steel in a modern VLCC than one built 30 years ago.
Some of that
reduction can be attributed to the use of higher strength steels
but most stems from the optimization of the design.
Quite simply
that means there is less margin for error and less margin for shortcomings
in the ship’s maintenance regime.
Today’s
VLCC will almost certainly be built in a shipyard where price and
production efficiencies are the driving forces.
Let’s
face it. Shipyards today want to build that VLCC as quickly as possible.
That means keeping
the design simple and putting as little material into the ship as
possible.
I think you
will agree, that is not a recipe for quality tonnage, built to last.
The classification
societies have the tools available to them to analyze and optimize
that modern design.
We can say that,
when the vessel leaves the yard, it conforms to class rule requirements.
It is fit for
its intended service provided it is properly maintained.
But the owner
is under intense commercial pressure.
He has a crew
of perhaps 15 people on board, not 30.
There is little
capability or incentive to maintain the vessel, to repair coatings,
to install anodes in the way that was done in the past.
He will run
that ship until his classification society determines that it no
longer meets rule requirements.
He will do everything
possible to delay that day.
He will try
and focus the class society surveyor’s attention away from
the spaces with the most significant corrosion or coating breakdown.
He may pressure
and intimidate the surveyor in an attempt to prevent inspection
of suspect spaces.
He will try
to squeeze permission to defer repairs until the next drydocking.
And when that
time comes he will try again to limit the extent of renewals.
The concept
of class as a partner is dead.
The concept
of class as a self regulating mechanism is at risk.
This is an industry
that responds only to specific and stringent regulation.
And here is
the ultimate irony.
A large number
of responsible owners are demanding tougher regulation that will
apply equally to all owners.
That is the
key – it must be applied equally to all so that no one is
unduly penalized.
If this is to
be achieved, incremental change is no longer an appropriate response.
It will not
give the industry, nor the public the ships they are demanding.
If class is
to remain relevant, it needs to remake itself for the modern world.
Self regulation
will continue to provide an effective method for establishing and
enforcing standards only if all elements of the
industry recognize that substantive overhaul is needed.
That means coming
together to jointly analyze the strengths and weaknesses of the
existing system and jointly develop the improvements that are necessary.
And those improvements
must be acceptable to all segments of the industry, particularly
the regulators, and it should include the environmentalists, the
seafarers and the general public.
Do I have a
specific blue print? No.
That must be
a jointly developed plan.
Do I have some
specific issues that the plan must address? Yes indeed.
- It must
address the issue of what role and what power is to be ascribed
to the classification societies.
Too often we
are blamed for not taking action for which we have no authority.
The power of
class is severely circumscribed at the same time that greater responsibilities
– for example ISM Code auditing and now Ship Security auditing,
are being placed on our shoulders.
Does the industry
want class to be the policeman? If it does, give us the power of
enforcement.
- It must
address the issue of who pays the class society.
It is immaterial
to us who does but we must charge for the services we provide.
Many critics
argue that we cannot be impartial when it is the owner who selects
the society and who pays the class fees.
If the industry
agrees with this negative assessment, then work with us to change
it.
If the industry
decides that the current system is effective and workable, then
support it and put these criticisms to rest.
- It must
address the issue of unlimited liability.
It makes no
sense that an entire organization can be financially ruined over
a questionable judgement call by one surveyor providing a service
for which the fee is a few hundred dollars.
- It must
address the issue of common scantlings and strength criteria and
how those standards are established and amended.
It is no longer
reasonable to place classification societies in the position where
shipyards can play one off against another for the sake of 250 tons
of steel in a vlcc with a lightweight of some 38,000 tons.
I am pleased
to confirm to you that unanimity on this point has been reached
within IACS and we are developing an implementation strategy.
- It must
address the exposure of classification society personnel to criminal
liabilities for their actions.
The latest EU
anti-pollution regulations expose our surveyors and our management
to possible jail terms for what may turn on how the field judgment
of an individual is interpreted, perhaps months later.
- It must address
the issue of transparency as it relates to classification records.
Does the public
have a right to access these?
Do charterers
have that right?
Can we continue
pulling the veil of confidentiality over such information?
Let me be quite
honest about this.
Much as I believe
this reinvention of class is needed, the classification societies
cannot and will not undertake this reform by themselves.
It is not just
that the collective courage does not exist.
Any such unilateral
action by class would be doomed to failure.
For the radical
overhaul that I am suggesting to be successful, it must be orchestrated
and accepted by the industry.
Let me repeat.
Classification is the mechanism by which this industry regulates
itself.
When it does
not meet expectations, government will step in and impose more regulation
on you and your activities.
I believe passionately
that self regulation is the preferred approach.
I believe that
it is very clear that, in the eyes of government and the public,
the self regulatory approach no longer meets expectations.
And so the choice
is simple.
Does this industry
want self regulation or does it want to be regulated.
If the choice
is self regulation, then we need to get together and remake the
process.
And we need
to do that now. We no longer have the luxury of time.
Thank you.
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