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The coming of a new year often holds promise for the future. With the coronavirus pandemic dominating center-stage last year, many have their eyes keenly focused on new beginnings with the start of 2021. For some in the maritime industry, especially owners and operators of commercial vessels involved in international trade, 2021 brings a new set of guidelines for protecting vessels—the International Maritime Organization’s (IMO) guidelines on maritime cyber risk management.

These new guidelines, a milestone for maritime safety and security, are the product of collaboration and hard work among shipping industry leaders and IMO Member States. Some in the shipping industry consider this development to be game changing. Whether game changing or not, implementation of this new model is a vital step toward forging a uniform approach for combating cyber threats against vessels.

Notably, however, the 2021 guidelines leave an equally vital, and maybe just as vulnerable, part of the shipping industry—port facilities—without a similar set of principles. Now that the IMO’s vessel guidelines are in the implementation phase, Member States and maritime industry leaders should again prioritize cybersecurity and collaborate at the IMO to develop uniform cybersecurity standards for port facilities.

The IMO and International Maritime Regulation

Before exploring the need for port facility cybersecurity standards, it may be useful to review the IMO’s role in developing international regulations. In 1948, the Member States of the United Nations created the IMCO, which changed its name to IMO in 1982, to facilitate global cooperation with regulation and practices of shipping engaged in international trade. The IMO’s goal is to ensure safe, secure, and sustainable shipping, facilitating trade and friendly relations among all states. Because shipping is historically and inherently an international endeavor, the IMO depends on and promotes cooperation among its 174 Member States to build uniform regulations that support this essential goal. The IMO construct has remained durable and inclusive since its inception.

Few maritime regulatory regimes exemplify the IMO’s impactful work across the globe more than the International Convention for the Safety of Life at Sea (SOLAS). SOLAS is a treaty from the early 1900s drafted in response to, among other things, the infamous sinking of the RMS Titanic. After its initial adoption in 1914, SOLAS further evolved via multiple conventions over many years with the last convention adopted in 1974. Consequently, the treaty is commonly referred to as SOLAS 1974.

In general terms, SOLAS establishes minimum safety standards related to ship construction, equipment, and operation. Countries party to the treaty ensure vessels under their flags comply with SOLAS’s terms by way of nationally administered certification programs. At the time of this writing, 166 countries, representing about 99 percent of the world’s shipping tonnage, were contracting parties to SOLAS 1974.

Although the last SOLAS convention was adopted in 1974, the treaty has been amended various times since then via the IMO’s “tacit acceptance” procedures. And like SOLAS itself, these amendments often followed tragedy, such as when the International Safety Management (ISM) Code was added as a chapter of SOLAS after a 1987 ferry accident in Belgium killed nearly 200 people. Because casualty investigators found the company’s poor safety culture contributed to the accident, IMO Member States developed the ISM Code, a global safety management standard, to combat what one investigator called the “disease of sloppiness” on ships and ashore. Entering into force in 1998, the ISM Code has made “shipping safer and cleaner” for more than two decades.

The IMO’s 2021 Cyber Guidelines

The ISM Code serves as the foundation upon which IMO Member States have built the 2021 guidelines for cyber risk management. The guidelines were consigned in 2017 via three key declarations. First, in Resolution MSC.429(98), Maritime Cyber Risk Management in Safety Management Systems, the IMO affirmed a view that the ISM Code already requires mitigation of cyber risks. Per this view, cyber risk management is already encompassed in the code’s existing general requirement that companies establish safeguards against all risks to ships, personnel, and the environment.

Resolution MSC.429(98) also contains a second important declaration. In it, the IMO encouraged countries to “appropriately address” this preexisting requirement no later than January 1, 2021. Put in more practical terms, now that the anticipated deadline for IMO’s cyber guidelines has arrived with the start of this new year, the IMO encourages Flag States not to issue compliance documents to vessels if cyber risks are not appropriately addressed in the respective safety management system.

The third important IMO declaration is in a July 2017 circular, in which the IMO announced that its Maritime Safety Committee (MSC) and its Facilitation Committee jointly approved specific cyber risk management guidelines. Member States developed these non-mandatory guidelines in partnership with shipping industry leaders to promote compliance with the aforementioned preexisting ISM Code requirement to mitigate cyber risks. In the July 2017 circular, the IMO recommends vessels and Flag States utilize the guidelines during compliance checks to assess whether cyber risks have been appropriately addressed.

As a risk management regime, the ISM Code is expected to adapt well to the management and mitigation of cyber risks. Government officials and maritime industry leaders, experienced from roughly 18 years of ISM Code practice, are expected to rise to the challenge of applying the code in the emerging cyber arena. Moreover, by identifying in the ISM Code a preexisting, albeit seemingly dormant, cyber requirement and then complementing that requirement with non-binding industry guidelines, Member States avoided the lengthy process of amending SOLAS 1974 and the ISM Code.

This is all to say, harnessing the ISM Code’s risk management framework to mitigate cyber threats was an efficient approach. In 2021, Flag States will begin to utilize this approach and work toward global uniformity.

The Work that Remains to Secure Ports

SOLAS 1974 has been amended numerous times, often to implement subsidiary regulations such as the ISM Code. Another subsidiary regulation within SOLAS is the International Ship and Port Facility Security (ISPS) Code, the IMO’s comprehensive mandatory security regime developed after a different tragedy—the 9/11 attacks. Interestingly, as the IMO’s new model for addressing cyber threats was being considered, the MSC reported, via MSC 97/22, that some Member States felt ISPS might be more suitable for addressing cyber threats. Nonetheless, seemingly moved by the United States’ 2017 assertion that the ISM Code’s “application is sufficiently wide to include emerging risks associated with cyber-enabled systems,” the IMO chose to harness the ISM Code, not ISPS, to promote global maritime cyber standardization.

While tapping into the ISM Code’s wide framework was efficient, such resourcefulness also came with a major limitation. Unlike the ISPS Code that covers certain ships and the port facilities that serve them, the ISM Code, even with its broad risk management concepts, applies only to vessels. This limitation means owners and operators of port facilities around the world will not reap the protective benefits realized with 2021’s implementation of IMO’s new cyber guidelines.

Port facilities play a vital role in global trade and rely heavily on technology to operate. As the May 2020 incident at Iran’s Shahid Rajaee port terminal demonstrates, a cyberattack at a port facility can be crippling. Since 2017, each of the four biggest maritime shipping companies in the world have been the victim of a cyberattack, with a recent attack taking place only a few months ago in September 2020. Considering these events, one should have no doubt that port facilities across the globe are presently vulnerable to cyber threats and the potential that these vulnerabilities will be exploited is undeniably real.

With the reality of cyber threats in mind, Member States and maritime industry leaders should collaborate at IMO to develop uniform cybersecurity standards for port facilities, just as they did to protect vessels. Coincidentally, in 2016 the Islamic Republic of Iran offered this exact proposal to the MSC. In MSC 97/4, Iran stressed the critical need for cyber risk management guidelines specific to ports. This proposal, somewhat prophetically considering the 2020 events at the Port of Shahid Rajaee, underscored the serious consequences a cyberattack could have on a port and on critical infrastructure.

While the MSC did not act on Iran’s proposal, in December 2016 the MSC expressly thanked Iran for its recommendation and “invited interested Member States to submit a proposal” for consideration at a future MSC session. No record has been found that any Member State has submitted such a proposal. Now is the time for Member States to accept the invitation.

Conclusion

The IMO’s guidelines for managing cyber risks on vessels are a key development for the shipping industry. Flag States and shipping companies worldwide now have an industry-sponsored framework from which to recurringly assess cyber safeguards on ships. There is more work to be done, however, to appropriately protect the rest of the maritime transportation system. Like Flag States and their vessels, Port States and their ports require guidelines to ensure cyber risks are uniformly addressed at maritime facilities. With 2021 finally ushering in cyber standards for vessels, now is the time for Member States, in partnership with the maritime industry, to assemble at the IMO and develop similar standards to secure ports across the globe.

Commander Michael C. Petta, USCG, serves as Associate Director for Maritime Operations and professor of international law in the Stockton Center for International Law at the U.S. Naval War College. The views presented are those of the author and do not necessarily reflect the policy or position of the U.S. Coast Guard, the Department of Homeland Security, the U.S. Navy, the Naval War College, or the Department of Defense.

This article appears courtesy of CIMSEC and may be found in its original form here


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Life itself arose from the oceans. The ocean is vast and covers 140 million square miles, some 72 per cent of the Earth’s surface. The ocean has always been an important source of food for the life it helped generate, and from earliest recorded history it has also served trade and commerce, adventure and discovery. It has separated and brought people together.

Even now, when the continents have been mapped and their interiors made accessible by road, river and air, most of the world’s people live no more than 200 miles from the sea and relate closely to it.

Freedom of the Seas

The oceans had long been subject to the freedom of-the-seas doctrine – a principle put forth in the 17th century, essentially limiting national rights and jurisdiction over the oceans to a narrow sea belt surrounding a nation’s coastline. The rest of the seas were declared free for all and belonged to none. While this situation lasted into the twentieth century, by mid-century there was an impetus to extend national claims over offshore resources.

There was a growing concern over the toll taken on coastal fish stocks by long-distance fishing fleets and over the threat of pollution and wastes from transport vessels and oil tankers carrying noxious cargoes that plied sea routes across the globe. The threat of pollution was always present for coastal resorts and all forms of ocean life. The navies of the maritime powers were competing for a worldwide presence in surface waters and even under the sea.

United Nations Law of the Sea Convention (UNCLOS)

The United Nations is working to ensure the peaceful, cooperative, legally defined uses of the seas and oceans for the individual and common benefit of humankind. Urgent calls for an effective international regime over the seabed and the ocean floor beyond a clearly defined national jurisdiction set in motion a process that spanned 15 years and saw the creation of the United Nations Seabed Committee, the signing of a treaty banning nuclear weapons on the seabed, the adoption of the General Assembly’s declaration that all seabed resources beyond the limits of national jurisdiction are the common heritage of mankind, and the convening of the Stockholm Conference on the Human Environment.

The UN’s groundbreaking work in adopting the 1982 Law of the Sea Convention stands as a defining moment in the extension of international law to the vast, shared water resources of our planet. The convention has resolved several important issues related to ocean usage and sovereignty, such as:

  • Established freedom-of-navigation rights
  • Set territorial sea boundaries 12 miles offshore
  • Set exclusive economic zones up to 200 miles offshore
  • Set rules for extending continental shelf rights up to 350 miles offshore
  • Created the International Seabed Authority
  • Created other conflict-resolution mechanisms (e.g., the UN Commission on the Limits of the Continental Shelf)

Protection of marine environment and biodiversity

The UN Environment Programme (UNEP), particularly through its Regional Seas Programme, acts to protect oceans and seas and promote the sustainable use of marine resources. The Regional Seas Conventions and Action Plans is the world’s only legal framework for protecting the oceans and seas at the regional level. UNEP also created The Global Programme of Action for the Protection of the Marine Environment from Land-based Activities. It is the only global intergovernmental mechanism directly addressing the link between terrestrial, freshwater, coastal and marine ecosystems.

The United Nations Educational, Scientific and Cultural Organization (UNESCO), through its Intergovernmental Oceanographic Commission, coordinates programmes in marine research, observation systems, hazard mitigation and better managing ocean and coastal areas.

The International Maritime Organization (IMO) is the key United Nations institution for the development of international maritime law. Its main task is to create a fair and effective, generally accepted and implemented legal framework for the shipping industry.

Marine shipping and pollution

To ensure that shipping is cleaner and greener, IMO has adopted regulations to address the emission of air pollutants from ships and has adopted binding energy-efficiency measures to reduce greenhouse gas emissions from international shipping. These include the landmark International Convention for the Prevention of Pollution from Ships of 1973, as modified by a 1978 Protocol (MARPOL), and the 1954 International Convention for the Prevention of Pollution of the Sea by Oil.

Polar Code

In 2017, the International Code for Ships Operating in Polar Waters (Polar Code) entered into force. The Polar Code covers the full range of design, construction, equipment, operational, training, search and rescue and environmental protection matters relevant to ships operating in the inhospitable waters surrounding the two poles. It was an important regulatory development in the field of transport and trade facilitation, alongside a range of regulatory developments relating to maritime and supply chain security and environmental issues.

Piracy

MONUSCO peacekeepers land at beach to guard against piracy

In recent years there has been a surge in piracy off the coast of Somalia and in the Gulf of Guinea. Pirate attacks are a danger to the welfare of seafarers and the security of navigation and commerce. These criminal acts may result in the loss of life, physical harm or hostage-taking of seafarers, significant disruptions to commerce and navigation, financial losses to shipowners, increased insurance premiums and security costs, increased costs to consumers and producers, and damage to the marine environment.

Pirate attacks can have widespread ramifications, including preventing humanitarian assistance and increasing the costs of future shipments to the affected areas. The IMO and UN have adopted additional resolutions to complement the rules in the Law of the Sea Convention for dealing with piracy.

The United Nations Office on Drugs and Crime (UNODC), through its Global Maritime Crime Programme (GMCP) combats transnational organized crime in Africa focusing on countering piracy of the Horn of Africa and Gulf of Guinea. The programme has delivered support to states in the region by carrying out trials and imprisonment of piracy suspects as well as developing maritime law enforcement capabilities through the facilitation of training programmes. From the piracy prosecution model, prisoner transfers and training of members in the judicial system of the Atlantic and Indian Ocean, to full-time mentoring to coast guards and police units in Somalia, Kenya and Ghana, the UNODC GMCP has accomplished many successes in a challenging environment. This has been achieved through a variety of programmes aimed at promoting maritime safety and bolstering the countries’ rule of law and justice systems.

Resources:


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www.MaritimeCyprus.com) Developments in connectivity and the transfer of data in greater volumes between ship and shore continue to bring significant gains for fleet management efficiency and crew welfare, but they also increase the vulnerability of critical systems onboard vessels to cyber attacks.

A 2019 IHS Markit/BIMCO report recorded 58% of respondents to a survey of stakeholders as confirming that cybersecurity guidelines had been incorporated into their company or fleet by 2018. The increase over the 37% giving this answer in 2017 explained a sharp drop in the number of maritime companies reporting themselves as victims of cyber-attacks according to authors – 22% compared to 34%.

However, the enduring feature of cyber threats is their ability to adapt and evolve, with new lines of attack developed as barriers are put in place, and strategies to expose vulnerabilities constantly emerging. A June 2020 White Paper from the British Ports Association and cyber risk management specialists Astaara suggests that reliance on remote working during the COVID-19 crisis coincided with a fourfold increase in maritime
cyber attacks from February onwards, for example.

In fact, cybersecurity was ranked as the second-highest risk for shipping in 2019, behind natural disasters, according to a survey of over 2,500 risk managers conducted by Allianz.
Given that, according to IBM, companies take on average about 197 days to identify and 69 days to contain a cyber breach, it is clear that an attack on a vessel’s critical systems could threaten the safety of a ship as well as the business of shipping.

The fact that a 2019 Data Breach Investigations Report from Verizon indicates that nearly one-third of all data breaches involve phishing provides one indicator that, where cyber vulnerabilities exist, the ‘human element’ can badly expose them.

The U.S. Coast Guard has already advised ship owners that basic cybersecurity precautions
should include: segmenting networks so that infections cannot spread easily; checking external hardware such as USB memory devices for viruses before connection to sensitive systems; and ensuring that each user on a network is properly defined, with individual passwords and permissions.

From 2021, the Convention for the Safety of Life at Sea that covers 99% of the world’s commercial shipping will formalise the approach to cybersecurity permissible for ships at sea.

By International Maritime Organization (IMO) resolution, no later than a ship’s first annual Document of Compliance audit after 1 January 2021, every Safety Management System must be documented as having included cyber risk management, in line with the International Safety Management Code.

The following report offers ship owners and managers guidance covering their responsibilities under the new IMO regime.

 

source : https://www.maritimecyprus.com/2020/11/19/maritime-compliance-cyber-security-requirements-due-1-jan-2021/


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Trading worldwide without electronic tools is no longer an option, young navigators and crew are switched on to digital technology and they want to have this new technology at their fingertips rather than the messy, slow and labour and paper-intensive methods of the past.

Tor Svanes, the founder and CEO of NAVTOR, believes that electronic chart and display information systems (ECDIS) is now a must have navigational tool in the modern era.

ECDIS has become the modus operandi on all ships, even those working on vessels that are not so modern.

“Navigating the future of shipping is crucial and young navigators no longer want to use paper charts, they are time consuming and far less accurate than their electronic counterparts,” explained Svanes.

According to Svanes, modern ECDIS systems overlaid with passage planning, regulatory information and weather reports, among other things is far easier operationally for crew. Svanes accepts that in the beginning there were teething problems, but he adds, “There is very little negativity about ECDIS these days, it has more integration with other systems and other equipment while updating charts with other data is a simple download.”That means that systems are always up to date and with modern systems the standardization of the display is simple, believes Svanes. What is more with new displays all reports can be available in one window.

According to Svanes, modern ECDIS systems overlaid with passage planning, regulatory information and weather reports, among other things is far easier operationally for crew. Photo: Navtor
The biggest change for ECDIS will come in 2024

However, the biggest change for ECDIS will come in 2024 with the changes to chart formats. “Practically it won’t be that much of change,” Svanes partially corrects himself, “But the systems upgrades may mean that some operators will require new systems,” he admits.

There won’t be any “backwards regulation” says Svanes but operators will need a system that complies with the new standard. And that will offer charts with more data and more detail, finer scale and more accurate, clearer displays.

What is more is that new chart displays will have the capability of displaying new regulations or regional regulations on screen allowing crew to plan a voyage with accuracy and knowledge of the weather conditions and the different regulatory regimes it will be sailing into.

A significant example is the latest offering from the International Maritime Organization (IMO) which introduced the IMO 2020 sulfur cap on 1 January 2020. Following the sulfur regulation there will be a regulation on the carriage of HFO, ballast regulations will be in place and a raft of decarbonization measures expected in the near future.

Other more regional regulations, such as the discussions over a new Mediterranean emissions control area (ECA), which have started the process for an all Mediterranean agreement to match those in the Baltic and the US, and it is these regional rules that make the regulatory map complex for vessel operators.

In addition to the international and regional rules there are an increasing number of port rules, these regulations are very localized and can vary widely, meaning masters have a tough time knowing which regulations apply at the various destinations to which they are travelling, with a number of ports called on any particular voyage.

“Navigating the future in shipping necessarily requires the industry to navigate away from its old operational measures and into a digital realm that is developing fast, and is fast developing the maritime sector,” said Svanes. Photo: Navtor

It is important for masters to be aware of local regulations. For example Port Everglades in the U.S. prohibits the discharge of ballast water, including the discharge of treated ballast water within the port. Whereas in Abu Dhabi, in the United Arab Emirates, above the water line hull cleaning and painting is prohibited as is boiler and economizer blow down, grey water discharge and underwater hull cleaning.

Failure to meet these complex regulations can be costly with severe fines, particularly in the EU and US waters, the need for clarity is real. NAVTOR’s Memorandum of Understanding (MoU) that it signed with Total Marine Solutions (TMS) offers owners and operators the kind of clarity that is needed to avoid falling foul of regulatory authorities.

Complex regulations often require advanced and costly mitigation technologies such as ballast water treatment systems or scrubbers, or even just low sulphur fuel where crew will need to test blends, make sure that tanks are cleaned and that the switch to a more expensive fuel is safe.

As the regulations change masters need to know which rules apply in each region and what mitigating actions need to be implemented to make certain that the vessel that they are operating remains compliant in all jurisdictions.

TMS launched its Ocean Guardian software in 2017 and it is designed to offer advice to crew and simplify the regulatory requirements as the ship heads into new regional jurisdictions, pertaining to port restrictions as well as mandatory rules on emissions and ballast water, so that the crew are prepared for what lies ahead.

Alexandra Anagnostis-Irons, President of TMS, said, ““This kind of collaboration – with expert partners leveraging each other’s skills and technology – is the way forward for an increasingly demanding maritime industry.”
In offering an e-navigation system with regulatory updates NAVTOR MD Tor Svanes believes that the most pressing issue for the service provider here is to make certain that all the information is correct and is up to date.

Gaute Fossmark, the environmental officer at NAVTOR, believes that this is a crucial issue for the combined systems. “Using data supplied by TMS the updating of changes to regulations is fully automatic, so that the customer does not need to worry about updates to the software, they see no updates,” he said.

TMS’s technical department makes certain that all data is harvested and updates its systems on a bi-weekly basis, while NAVTOR updates its electronic navigation chart (ENC) every week.

Fossmark believes that the regulatory regime is becoming increasingly complex with new rules applied at ports, “regional and port regulations are the hardest to get hold of,” according to Fossmark, with special rules applied by some ports for items such as waste management.
These changes offer substantial cultural and work-related changes for crew, but the biggest change so far has been the switch to ECDIS from paper charts. The next move will be an upgrade to the systems expected in 2024 which will see higher definition charts and better software.

“Navigating the future in shipping necessarily requires the industry to navigate away from its old operational measures and into a digital realm that is developing fast, and is fast developing the maritime sector,” concluded Svanes.

Source: marinelink


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Historically, vetting was performed by retirees from the oil majors. Their judgements were to a large extent trusted by industry as they were known to the various parties and they in turn knew the values and the cultures of the various companies that they were interacting with.

In the intervening years vetting has moved on considerably, but there is a general sense that the quality of discussions between inspectors and operators has declined.

In 1992 the SIRE system came into force. One of its primary drivers was to reduce the vetting burden, and within a year a uniform inspection format was designed to replace the individual programmes in place. The system ran relatively smoothly following its introduction.

The next major step change came in 1999 in the wake of the Erika incident. Inevitably, this incident led to increased focus on clearance and vetting. Almost overnight a whole generation of vessels – notably single hull VLCCs – became unacceptable overnight.

A further step change came in the wake of the 2002 Prestige incident. Pior to that oil companies had basically taken the view that owners had a ‘right’ to get their ship inspected. Following Prestige the attitude increasingly taken was that if a vessel did not correspond with the oil companies minimum age and type requirements they no longer felt an automatic obligation to inspect the vessel. Oil companies also stopped issuing letters saying that a vessel was satisfactory, confining themselves in writing to thanking owners for participating in their onboard inspection programme: nothing more nothing less.

There is a popular view in industry that this marked an important turning point in the quality of dialogue between the stakeholders in the vetting process. Vetting organisation typically felt – for fear of litigation if something went wrong – that they could no longer tell the owner whether a ship passed an inspection.

Around 2004, the Oil Companies International Marine Forum (OCIMF) issued the Tanker Self-Management Assessment scheme, an ambitious effort to get owners to focus on a continuous quality approach.

Fast forwarding to the present, it can be seen that impressive steps have been taken toward harmonising requirements and harnessing new technology. But the cost and complexity of compliance has multiplied too. Many now see vetting ‘as an industry within the industry’, with an annual estimated cost of US$300 million – US$500 million.

Today the likelihood that an inspector is a former Master is increasingly remote. Now it is not unusual for former Masters to be lured out of retirement, back into their shipowning companies at some expense, so that the letter of an oil major’s matrix requirement can be fulfilled. It is open to question whether such an approach fulfils the spirit of oil majors’ safety requirements.

Many within the industry regard inspectors as ‘distant contractors’ with less of a relationship with the oil companies than their predecessors. In parallel, people within the vetting organisations have changed, and many new owners, operators and trading entities have entered into the market, increasing the distance between owner/operator and vetting organisation.

Wallem’s head of shipmanagement in Europe, Dave Martin, makes the point in this issue that another of the inspection companies makes it a key performance indicator for inspectors to achieve a certain number of observations per ship. “This reduces the value of the inspection from one about quality of operation to one that is purely observations,” he says.

Other tensions are being reported in the wider industry. Inspections are supposed to be done in an operational mode according to SIRE, but many oil companies will only accept them when they are done in discharge ports, which places huge constraints and pressures on crew and vessel operations. The number of inspections that vessels need to field is another concern. And there are now stories circulating of oil companies insisting that the CEO of a shipping company routinely visit vessels. While a visit from top management can be good for morale and motivation, it is questionable whether this should be enshrined within the Vessel Inspection Questionnaire that is the bible that inspectors use, and can cite as authority for a negative observation.

So what’s the bottom line? Industry needs one system that is trusted, harmonised and transparent. Useful headway is being made in this direction through industry associations, notably Intertanko and OCIMF, but the industry mood music indicates we are not there yet. TST

Source: rivieramm


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This process applies to vessels regulated by the  SIRE and EBIS programs, cargo ships, and tugs.

On May 11th, 2020 a new process has been implemented with the following main changes:

  • Vessels are required to be screened each time they are nominated by Repsol Group.
  • Repsol Vetting does not pre-approve vessels.
  • Technical Operators of the vessels that need to pass the vetting process do not need to fill out the Repsol Vetting questionnaire.

The Vetting assessment starts with a request from any Commercial department within Repsol Group and is regulated by the Repsol Vetting Process and Marine Safety Criteria document, which can be downloaded below.

If you are interested in arranging an individual inspection for your vessel at your own expense, please email us a formal request at least five days beforehand indicating the port, date, local agents, and type of operations. Our main inspection areas are located in Europe and America.

Source: repsol


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OECD figures have estimated one billion TEU in transit by 2030, with Asia leading the increase in volume. Today over 400 million lithium ion batteries and over 15 billion aerosols are said to be produced annually. All these numbers suggest that the container fire risk may get worse; it is estimated that onboard today’s largest vessels of 22,000 TEU, there is more than 4 times the risk of having that one problem container onboard and the consequences of a fire is also more than 4 times as great.

Major fire accidents at sea

2019 produced a significant number of hazardous cargo fires onboard with the most reported being as follows:

  • On 3 January, the containership “Yantian Express” sustained major fire off Bermuda. 198 containers onboard the ‘Yantian Express’ were estimated to be a total loss.
  • On 29 January, fire broke out in the engine room onboard Maersk’s Panamax containership “Olga Maersk” on route from Panama to Cartagena.
  • On 31 January, Vietnamese Coast Guard responded to a cargo fire on the container ship “APL Vancouver” off Vung Ro, Vietnam.
  • On 14 February, ER Kobe that suffered a fire when three containers on deck loaded with charcoal caught fire while the boxship was heading from Haiphong to Qingdao and later became engulfed in flames again.
  • On 10 March, Italian con/ro “Grande America” caught fire, approximately 140 nm off Finistère, forcing all 27 members of her crew to abandon ship; it sank after two days.
  • On 28 May, fire onboard KMTC containership was reported due to mis-declared chemical cargoes of calcium hypochlorite and chlorinated paraffin wax.

Tacking misdeclaration may well be a first line of defense

Experts from the Gard P&I Club noted that most container fires are associated with cargo misdeclaration which remains a key industry challenge. Namely, between 2014 and 2017, Gard was involved in 13 container cargo fire cases of some significance; six cases involved calcium hypochlorite which is very common chemical product used for water purification, but at the same time it can be very hazardous. In this regard, the International Group of P&I Clubs together with CINS jointly issue guidelines that can essentially be considered “IMDG Code plus precautions”.

‘No matter how carefully cargo is booked, there will still be fires originating in containers’, Gard’s Alf Martin pointed out during a conference on containership fires in Arendal in October, suggesting that a holistic approach is vital. TT Club mentioned that approximately two out of three fire incidents are the result of poor practice in the overall packing process of dangerous goods, which are often misidentified or undeclared. Moreover, the way large containerships are constructed today poses many challenging to the crew when a major fire breaks out since the accommodation, lifeboats and rafts are in close vicinity to containers.

SOLAS and firefighting: Where we stand

Industry stakeholders have identified that the SOLAS requirements may not be adequate for today’s larger container carriers. It is also noted that there are still certain fire safety arrangements not included in the SOLAS Regulations.

‘’We believe the mode of firefighting set out in SOLAS is not suitable for a modern containership…We suggest creating individual fire compartments below deck to prevent fire from spreading. These compartments would be fitted with fixed Co2 and water-based firefighting systems.’’ alerted IUMI’s Helle Hammer.

According to SOLAS, containerships built after 1 January 2016 must have:

  • At least one water mist lance capable of penetrating a container wall.
  • If 5 or more tiers of containers are carried on or above weather deck, ships with a breadth up to 30 meters are to have at least two mobile water monitors, and for vessels with a breadth exceeding 30 meters there are to be at least four.

However, when it comes to modern large container vessels, there is no regulation demanding firefighting means when cargo on deck rises 30meters above deck level.

IUMI calls for action

During the IMO’s 101st Maritime Safety Committee (MSC) meeting in June 2019, IUMI raised its concerns and received support from various quarters, including IACS. Now, in partnership with the German flag state, IUMI is calling for additional support from flag administrations and other stakeholders to bring this issue to IMO’s agenda in 2020.

In light of Gard’s conference in Arendal, Norwaty, Christen Guddal, Chief Claims Officer at Gard highlighted that serious cargo-related fires on board container ships have occurred at the rate of about one a month. The increased size and cargo capacity of container ships have a real impact on the potential severity of such incidents.

In addition, IUMI took the chance to alert on the situation and call the shipping industry to improve its existent onboard firefighting systems and seafarers’ training, as both seem to lack of efficiency in these challenging times. Helle Hammer, Chair of IUMI’s Policy Forum noted that fire-fighting capabilities onboard containerships are deficient and therefore, industry needs to see more headway to improve the safety of the crew, the environment, the cargo and the ships themselves.

The issue of mis-declaration or non-declaration of cargo seriously affects the safety implications of a vessel and result to incidents. This is because cargo areas have high potential of fire eruption, so all precautions should be taken to ensure that inflammable cargoes are kept in isolated conditions. Concerning mis-declaration of cargoes, Hapag Lloyd previously announced a penalty of USD 15,000 per container for those who fail to properly offer and declare hazardous cargoes prior to their shipment.

In the same length, IUMI proposes IMO to strengthen fire protection in the cargo area of container vessels; amend SOLAS by explicitly including active and/or passive fire protection on board new container vessels; and consider the need to address the firefighting equipment of existing container vessels.

Previously, IUMI had launched a position paper to IMO, providing recommendations on improving firefighting systems onboard vessels as follows:

  • Responsible authorities, class and relevant industry stakeholders should engage in discussions on how to further improve the fire detection, protection and firefighting capabilities on board container vessels.
  • Implementation of new and improved measures to fight fires on container vessels will not only protect the vessel and the cargo, but also the lives and wellbeing of the crew.

Concluding Gard’s conference, Mr Martin shared his suggestions to move forward with effective firefighting and highlighted that there is a need for much faster alarms from a cargo hold on fire; water monitors permanently installed on lashing bridges; build higher lashing bridges on deck or install “masts” to improve the reach of fire monitors; protect hatch covers by water to stop a fire going through; install water sprinkler systems in all cargo holds, not just in holds for dangerous cargoes; arrange for water curtains to protect superstructure and lifesaving craft and insulate all boundaries of the engine room in purpose- built container vessels, not just the decks.

Source: safety4sea


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A new cyber security component has been incorporated into the third edition of Tanker Management and Self Assessment: A Best Practice Guide (TMSA3), released by the Oil Companies International Maritime Forum in 2017. The cyber security component is directly addressed in two of the performance elements: management of change (element 7) and marine security (element 13).For each element in TMSA3, tanker operators should carry out a self-assessment and rate themselves (their safety management systems, operations and practices) against the key performance indicators (KPIs) defined in TMSA3. We want to support you in implementing the new cyber security component and help you to provide documentation of compliance, whether that be achieving the minimum expected level or going above and beyond and achieving level 4.

Our approach

To support the implementation of the new cyber security component found in TMSA3 (requirements 7 and 13), we have identified potential phases that can be followed and tailored to your specific needs. These start from the achievement of the minimum expected level (level 1) and can ultimately bring the company to the full achievement of the management of changes and marine security objectives, which are identified as level 4 by TMSA3.

What we offer

Cyber security procedures definition

We will you with a number of supporting documents. These are generic documents based on good industry practice. As part of a one-day workshop, we will show you how to tailor these to suit the operational model of your business. Should additional support be required after the workshop, this can be discussed and a pricing agreement reached.

Risk assessment

An example risk assessment will be provided, showing how to assess the threats and apply mitigating controls. This would be a standard template showing the approach to and methodology for conducting a risk assessment. Standard assets will be pre-populated, which would have to be tailored to suit your business model. After instruction provided by the consultants, you would need to populate the compensating controls within the template to mitigate the identified risks.

Cyber security procedures audit

We can undertake an audit of cyber security procedures based at your HQ. The audit would be undertaken by an ISO 27001-qualified auditor, and the scope of the audit will be agreed with you and will be based on a selection of agreed controls, as opposed to every control. This will ensure that the audit be completed in one day.

Onboard audit

The main aim of our onboard audit is to determine the effectiveness of the ship’s security measures, policies, procedures and preparedness for cyber-related incidents. The audit will determine whether controls, processes and procedures conform to the requirements of the TMSA3 standard, whether the policies and procedures are effectively implemented and maintained, and if they perform as expected.

Vulnerability assessment

Vulnerability assessment will be delivered on computer based systems (navigation, cargo control, power management, communication, etc.), ship networks and any automation on board the selected vessel(s).  If a specific goal is identified you, penetration testing can also be performed. Penetration testing is the attempt to actively exploit weaknesses in the environment from the perspective of an attacker with direct access to the network being tested.

Why choose LR?

We provide independent assurance and expert advice to companies operating high-risk, capital intensive assets in the marine, energy and transportation sectors, and we have a unique insight into ship and cyber security. We know both the operational technology systems that drive performance and the information technology platforms. We understand the changing regulations being faced by the industry and we know how to deliver a cost-effective solution while reducing our clients’ vulnerability to cyber threats. Our work helps to ensure that your  assets and processes are secure, safe, sustainable and compliant with the regulations.Source: Ir


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ExxonMobil’s International Marine Transportation aims to produce another significant step change in preventing oil spills at sea through adding a new element that addresses the human element to the Tanker Management and Self Assessment (TMSA) programme.

In a keynote address to the International Chemical and Oil Pollution Conference and Exhibition (ICOPCE) in Singapore, Jonathan Evans, managing director, International Marine Transportation Singapore, Fuels and Lubricants, ExxonMobil, said: “We can see a significant improvement over the last 40 years but we are still having spills to water and any spill is one too many.”

Over the last 30 years pollution incidents had been reduced by the introduction of the double hull, the SIRE programme, the ISM Code and the introduction of TMSA. Evans noted that since the introduction of the TMSA programme there had been “a very productive period in reducing number of incidents over last 15 years, yet we still have the Sanchi incident”. The Sanchi collision with the CF Crystal last year left 32 dead and the loss of the vessel and its cargo.

“We all know human error is the area we need to address, we have good sound vessels and good  management systems and yet these incidents still continue to happen and when we look at them its human error in way over 75% of the cases,” he told the conference organized by the Maritime & Port Authority of Singapore (MPA).

To address the human element the company has been working over the last 12 – 18 months on a new element to be added to TMSA. A multi-disciplinary team of industrial psychologists, TMSA experts, and marine quality assurance experts was assembled and combined with industry consultation across both large and small fleets, as well as barges. “So we have a good perspective on what will work in the industry and finally we’ve added a peer review,” Evans said.

He said the key objectives of the element were to, “equip the leaders and staff on ship and ashore with the leadership and equipment knowledge, skills and commitment to perform at the highest level essential for safe, and efficient operations”. There are five pillars of successful operations covering

  • Leading and shaping the safety culture you want
  • Well executed tasks and procedures
  • Well designed equipment and controls
  • Skills to respond to emerging situations
  • Learning before and after things go wrong.

“This will be the responsibility of senior management to develop policies and plans to allocate resources in support of each one of these pillars,” Evans said.

Work on the new element was handed over to OCIMF last week with a plan to finalise it over the next 12 months for roll out to the industry.

Source: seatrade


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