Some shipbuilders and designers assert that lack of competition among IACS members has resulted in impractical and vague rules, but is it accurate to talk of collusion as explanations are sought for EU dawn raids on five societies?
The common structural rules (CSR) of IACS (the International Association of Classification Societies) came into force on 1 April 2006. The purpose of these rules is:
• to eliminate competition between societies with regards to structural requirements and standards
• to employ the combined experience and resources of all societies to develop a set of unified rules
• to ensure that vessels built to these rules will be recognised as being at least as safe and robust as would have been required by any existing rules
• to fully embrace the intentions of IMO’s anticipated requirements for goal based new ship construction standards.
At present, there is a lack of operational experience with CSR due to the fact it was only introduced in April 2006 and that a lag is inevitable, due to contractual negotiations and the construction process. However, many shipyards and naval architectural consultancies have CSR designs drawn up and have been able to compare these with previous designs.
German naval architectural and marine engineering consultancy INEC GmbH, based in Raisdorf has calculated it would actually make technical and commercial sense to reduce the length of one of its most successful designs by 3m in order to avoid CSR regulations altogether.
“We have a proven design for a 19,990 dwt oil/chemical tanker with stainless steel tanks and GL ice class E3 that has been successfully built for European owners at Chinese yards since 2000,” says company managing director Jörg Walter. The most recent version, Monte Rosa, was built to GL class and entered into service at the end of 2007.
In April 2006 INEC secured its most recent contract for this design, and the 151.37m long ship is currently being built in China in accordance with CSR. However, a comparison between building this contract to CSR and reducing the design by 3m to meet GL’s rules for tankers under 150m in length, has according to INEC, highlighted a number of key advantages in favour of the latter.
“By reducing the hull length, CSR’s significantly higher demands on corrosion allowances can be avoided,” says Mr Walter, who feels the rationale behind these increases is unclear. “The load assumptions used in CSR for determining scantlings may apply for a pure oil tanker, but some of them bear no relation to our design, and would not translate into higher design moments or an extended vessel lifetime – they would result in a heavier ship.
“Mismanagement and lack of maintenance cannot be replaced by higher corrosion allowances. Somewhat paradoxically, in CSR there is no provision for regular inspections of coatings in cargo and ballast tanks. Reliable and more frequent inspections by owners, class or independent third parties may be a better way.”
Other requirements, such as the construction of corrugated bulkheads and permissible stresses, could be avoided, too. These only result in a heavier and more expensive “but not necessarily better” design.
“In reducing the length, both deadweight and displacement are reduced by 2.5 per cent. The resulting loss in cargo tank volume can be absorbed, to some extent, by an extension in the cargo tank length, meaning it can be loaded at a density of around 0.74 tonne/m3 at 98 per cent full."
If the vessel is built using stainless steel for its cargo tanks, the hull will be around two per cent lighter. If black steel is specified, the weight difference is even more pronounced. Overall, the power requirement for a design speed of 15.5 knots on the GL classed vessel is reduced by more than 3.5 per cent.
“We also believe that going with a single class society will streamline administrative aspects,” continues Mr Walter. “Further, as questions relating to design and construction arise, we believe we will obtain a speedier and more flexible response then would be possible under the IACS rules. What is more, as our vessel is built to Germanischer Lloyd's E3 standard which is equivalent to the Finnish Maritime Authority’s ice class 1A, transverse framing system is included within the ice belt. There is no provision for this in CSR.” Despite these criticisms, Mr Walter thinks the CSR approach is very good “but needs to be tailored to meet the needs of all the ship types at which it is aimed.”
For those who are engaged in building to CSR designs there are a number of industry forums at which experience and information can be exchanged by the industry. One such meeting was the recent Tanker Structure Co-Operative Forum (TSCF) shipbuilders’ meeting which was hosted by the Korean Register in Busan, Korea, in October 2007.
This is an informal meeting, held every few years, at which naval architects from shipowners, oil majors and classification societies link in order to share experience and best practice between themselves, and with the rest of the industry through TSCF publications. The meeting in October was the first since the introduction of IACS’ CSR and a number of papers were presented on this subject.
The consensus of most builders seems to be that CSR results in an increase of steel weight within the cargo area, and a common view expressed by the yards was that, although CSR will likely improve overall safety levels, structural reliability and operational reliability, there are still some irrational requirements which need to be re-investigated.
Perhaps the most trenchant criticism came in a paper from Hyundai Heavy Industries (HHI), entitled IACS CSR on Tankers. In this paper, HHI, which enjoys a world class reputation for series production of ships – many to standard designs, detailed its CSR design experiences for a 105,000 dwt Aframax tanker, a 165,000 dwt Suezmax tanker and a 317,000 dwt VLCC.
Among those ‘irrationalities’ identified in the paper was the requirement for additional corrosion protection, given the “enhanced ballast coating requirements already in effect and more stringent cargo tank requirements soon to enter into force.” The paper also suggested the rules be amended to allow for a reduced volume of higher tensile steel (30 to 35 per cent versus the 40 to 45 per cent at present).
The paper also found “the prescriptive rule requirement for the thickness of the double bottom floor is too severe and impractical.” The authors suggest that the CSR rule requirement exceeds the level that a finite element analysis would deem necessary by a huge 40 to 50 per cent.
A further area that the paper claimed was in need of urgent attention was the effect of toe grinding on fatigue strength. CSR specifies that, with some carefully defined exceptions, “the benefits of weld toe grinding should not be taken into consideration at the design stage”. HHI says that this position fails to take into account systematic research which has shown that fatigue strength is greatly enhanced by toe grinding and “consideration is urgently required in CSR for a rational structural design.”
HHI concluded its paper by calling for these critical areas to be examined without delay and for a more flexible rule set to emerge that will recognise a great range of proven designs.
In response to these (and other) requests for re-investigation or further explanation, IACS now implements the CSR maintenance programme (IACS Procedural Requirement No 32) via the IACS CSR Knowledge Centre (KC).
All the agreed questions and answers (Q&As) and common interpretations (CI) are now published on the IACS web site in order to assist its member societies and industry in implementing CSR in a uniform and consistent manner. IACS has also put in place a long-term plan to further increase harmonisation between the tanker and bulk carrier rule sets.
Since compliance with IMO’s Performance Standard for Protective Coatings (PSPC) is required by the IACS CSR, and in view of the need to provide industry with best practice guidance for application of PSPC, IACS and industry have established a joint working group on coatings (JWG/Coating). Agreed Q&As and CIs relating to coatings are also published on the web.
Currently, many of the questions and much of the feedback received relates to design and construction matters, and these have now been included in IACS actions. In a few years time when there is operational experience in place, then there will be further feedback and IACS will again feed this into the rule set. There will also, of course, be other opportunities to share experience through various organisations.
However, while IACS waits for further experience to be fed through, CSR has potentially fallen under even more immediate and intense scrutiny, following simultaneous dawn raids in early February by European Union inspectors on five IACS class societies, as well as the central secretariat in London. The word ‘potentially’ is used because, according to IACS chairman Tor Svensen of DNV, the Commission has not divulged the reason for its raids or what or who has precipitated them; apparently, the organisation is under no obligation to disclose this information.
“I am still a little bit puzzled about what is going on and I do not really understand it in the big picture. There is an investigation into class, and many inspectors want to see files and gather information; they have not however, told us what they are looking for or why they are there,” Mr Svensen told Tanker Shipping & Trade.
“All that I have found out is that they are investigating anti-competitive behaviour, and whether there is a cartel. In addition, I understand from other sources that the heart of the matter is that they believe that common rules and the evolution of CSR are anti-competitive, because this stops any competition on standards.” In the CSR context this would mean ‘rules that have been jointly designed so as to exclude non-IACS members from participation.’ But with CSR, while societies agree the same rules, we differentiate on price, service (including CSR-compliant software) and so on.
“The industry has jointly been trying to raise standards. We do not want anyone to take commercial advantage through a lowering of standards and firmly believe there should be no competition on safety. That is why we have set minimum levels.
“I am also puzzled,” continues Mr Svensen, “because we are actually obliged to work together with the EU Transport Commission on harmonising standards. Everything we do is transparent; it is even enshrined in European regulations, in the class directive, that in order to secure full recognition in Europe a society has to be a member of IACS.
“So, it is quite a shock to be raided in this way. We see ourselves as part of a regulatory system that has been developed with all stakeholders and has been, actually, very efficient. Class has been the custodian of safety standards and the primary custodian of technology and technical knowledge.
“It is such a coordinated sweep thus one would hope – as a taxpayer – there was something behind it. Nevertheless, we remain in the dark and if they want to change anything we have to do that in cooperation with all the stakeholders, government, flags and IMO – everyone. It is part and parcel of how the system works.”
Mr Svensen says that an extraordinary meeting of the IACS membership is being considered and thought is being given as to how IACS would operate, given the current investigation.
Until such time as the EU chooses to reveal more, or indeed the investigation is dropped, motivation for the dawn raids, remains unclear. However, what is not in doubt is that CSR has invoked a strong response, especially in the shipbuilding and design communities.
It will be interesting to see whether a common consensus can be achieved in the short-term among the societies as to how to proceed, and how this will dovetail, not only with the expectations of naval architects, builders and regulators, but with the goal based standards currently under development at IMO. TST
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