Interferry regulatory affairs director Johan Roos explains that work to enhance ropax fire safety requires a delicate cost-benefit calculation
What price would you pay for a human life? The question does not bear thinking about in a personal context, but it’s one that professionals in various industries must confront when justifying the cost of risk reduction measures. With SOLAS amendments due in force from January 2024, those of us involved in the current ropax fire safety work at IMO – where Interferry has consultative status – are acutely conscious of the calculation required to achieve cost-effective enhancements.
IMO fire safety regulations already incorporate very clear instructions for the prevention, detection and suppression of a fire, followed by evacuation if nothing else works. The background to the latest initiatives was a string of fires on roro cargo and passenger ships culminating in the loss of Norman Atlantic in 2014 and Sorrento in 2015. Since 2018, IMO has invested great focus on revising the regulations, building largely on comprehensive research from European Union (EU) specialists the European Maritime Safety Agency (EMSA).
The EMSA approach embodies a cost-benefit assessment. Proposals for new measures and strengthening existing requirements were assessed on their potential for saving lives and assets – the vessel and cargo – relative to the cost imposed on the ship. To do that, a life must be monetised. The current IMO rate is roughly US$7M – which means, up to this amount, implementation of a measure becomes mandatory if it is likely to prevent at least one fatality during that ship’s operational life.
In an ideal world, everyone would agree that no price can be put on saving a life – but this is the real world. Fortunately, typical potential measures cost far less to implement. For instance, fitting water cannons on the weather deck costs around US$100,000 on a newbuilding. This solution alone does not meet the ‘one life saved’ criterion but is proven to go a good way towards it. As such, water cannons on weather decks will become mandatory not only for newbuilds but also for ships built before the 2024 SOLAS amendments enter force.
Some other potential measures seem to make sense intuitively until you plug in the numbers. Banning side openings in open roro spaces was a knee-jerk suggestion by many after the Norman Atlantic accident. However, the EMSA study revealed that costs versus benefits are almost three to one against such a ban on existing ships. Issues regarding a ship’s equipment and management should be of far greater concern than side openings.
Appropriate measures came under intense discussion in March when SSE7 – the seventh session of IMO’s Ship Systems & Equipment sub-committee – continued efforts to draft the SOLAS amendments. The work was largely based on an EU submission that concerned Interferry and other major influencers for not distinguishing between requirements for new and existing ships. The meeting referred all such outstanding items to a correspondence group for ongoing discussion until SSE8 next March.
Meanwhile, Interferry is among 27 research and industry partners in the four-year, €12.2Bn (US$13.2Bn) EU-funded LASHFIRE research and development project launched last September. We were tasked with recruiting up to 10 operators to join 12 national maritime authorities in an advisory group that held its first meeting during SSE7. Historically, most ropax fires start in the cargo, usually due to faulty refrigerator unit connections or makeshift electrical connections in cars. Minimising the risk from this and the growing uptake of electrically powered vehicles will feature in the project’s agenda.
The biggest challenge in developing new fire safety requirements is to shorten the wish-list from “let’s do everything” to “let’s do what is sensible”. Current regulations are actually very good – and with continued close co-operation between member states and industry bodies, the upcoming SOLAS amendments will make risk reduction even better.