Marine safety issues and actions

Inadequate standards and regulation

Issue number: MO-2018-011-SI-02
Issue owner: Australian Maritime Safety Authority, Lloyd’s Register, and International Association of Classification Societies
Transport function: Marine: Other
Background: Investigation Report 346-MO-2018-011
Issue release date: 11 May 2021
Current issue status: Open – Safety action pending
Issue status justification:

Response by the Australian Maritime Safety Authority

On 18 February 2021, the Australian Maritime Safety Authority (AMSA), advised that it would work with the ATSB to raise the deficiencies highlighted by the investigation report with the International Maritime Organization (IMO).

On 8 April 2021, in response to ATSB’s request for relevant detail on AMSA’s proposed course of action, AMSA advised that as the IMO’s Maritime Safety Committee (MSC) must approve new work items based on papers submitted by Member States (countries) and IMO sub-committees, Australia (AMSA and ATSB) would use the Sub-Committee on Implementation of IMO Instruments (III) and the Casualty Analysis Working Group (CAWG) that reports to III to initially highlight the issue and to seek like-minded support.

ATSB comment

The ATSB welcomes the intent of the safety action proposed by AMSA and undertakes to assist AMSA as required by highlighting this safety issue at IMO forums to seek improved regulations and standards. However, given the importance of this safety issue, the ATSB is concerned by the absence of a detailed proposal and/or timeframe to raise this issue with IMO through the appropriate process and best ensure the MSC approves work items aimed at addressing this issue.

Any such work items assigned to the CAWG will be actively promoted by the ATSB as a member of that group. In addition, the ATSB will use its membership in the IMO’s Casualty Analysis Correspondence Group (CACG) and the Marine Accident Investigators’ International Forum (MAIIF) to highlight the safety issue and seek like-minded support. In the interim, the ATSB issues the following safety recommendation.

Safety issue description

The cargo handling spaces of specialised self-unloading bulk carriers continue to present a very high fire risk due to the inadequacy of standards or regulations for self-unloading systems, including for conveyor belts, and dedicated fire detection/fixed fire-extinguishing systems. This has been a factor in at least three major fires over a 25-year period, including Iron Chieftain’s constructive total loss.

Safety recommendation

Action number: MO-2018-011-SR-015
Action organisation: Australian Maritime Safety Authority
Date: 11 May 2021
Action status: Released

The Australian Transport Safety Bureau recommends that the Australian Maritime Safety Authority takes steps to formally raise this safety issue with the International Maritime Organization to seek safety action aimed at addressing the risk of fire in the cargo handling spaces of self-unloading bulk carriers due to the inadequacy of the current associated standards/regulations.

Additional correspondence

Response date: 06 August 2021
Response from: Australian Maritime Safety Authority
Action status: Released
Response text:

The Australian Maritime Safety Authority (AMSA) has accepted the recommendation in full and agreed that the safety issue should be taken to the International Maritime Organization (IMO) for consideration. AMSA has suggested that an information paper highlighting the findings of the report be submitted by Australia to the next meeting of the IMO Sub­-Committee on Implementation of IMO Instruments (III) in 2022 with a request that the Working Group on Analysis of Marine Safety Investigation Reports considers the report and information provided. AMSA proposed that ATSB and AMSA liaise to further discuss this approach in the lead up to the next III Sub-Committee meeting.

ATSB comment date: 03 November 2021
ATSB comment:

The ATSB notes AMSA’s response and undertakes to assist AMSA in the submission of an information paper to highlight this safety issue at the next meeting of the IMO Sub­Committee on Implementation of IMO Instruments (III) in 2022. In addition, the ATSB will also use its membership of the IMO’s Casualty Analysis Correspondence Group (CACG) and the Marine Accident Investigators’ International Forum (MAIIF) to highlight the safety issue and seek support for its resolution.

Noting that consideration of the paper at the meeting will determine the next steps, the ATSB encourages AMSA to take the necessary action to best ensure the proposal’s progress to a work item aimed at addressing this issue at the IMO’s Maritime Safety Committee (MSC).

Proactive action

Action number: MO-2018-011-NSA-018
Action organisation: Lloyd’s Register
Date: 11 May 2021
Action status: Monitor

On 19 February 2021, in response to a draft of this investigation report, Lloyd’s Register noted the investigation’s conclusions and agreed that the arrangements of conveying machinery spaces of self-unloading bulk carriers merited improvement to address the risk.

Lloyd's Register proposed to support an approach to the International Association of Classification Societies (IACS) to seek a Unified Interpretation for the requirements for conveying spaces, to mitigate the fire risk in these spaces.

On 8 April 2021, Lloyd’s Register advised that a submission had been made to the General Policy Group of the International Association of Classification Societies (IACS) and was awaiting a decision as to when this would be assigned to the IACS Safety Panel.

Lloyd’s Register advised that the support received from other IACS members would dictate proceedings and that an interim approach via an IACS Unified Requirement (UR) may be desirable as it was a quicker route to action given the long gestation time for a Regulation change at the International Maritime Organization (IMO). This approach would at least get IACS members to a position of implementing a preventative requirement for new ships, although retrospective application may be problematic.

Lloyd’s Register provided the following estimated timeline to develop a UR should the approach to the IACS safety panel progress:

  • End of May 2021 – agreement by IACS Members at Safety Panel to develop a UR
  • June 2021-June 2022 – IACS internal governance and development activity
  • 1 July 2023 – UR enters into force in members’ Rules

Lloyd’s Register advised that, while an IACS-based action would provide a more expedient interim solution, in the longer term, changes to the International Convention for the Safety of Life at Sea (SOLAS) 1974, as amended, and associated IMO instruments would also be required to ensure safety across the board.

ATSB comment:

Date: 11 May 2021

The ATSB welcomes the course of safety action proposed by Lloyd’s Register with regard to addressing this safety issue and seeking improved standards and regulations, and the action it has taken to initiate that process. It is also acknowledged that safety action may take some time. Consequently, the ATSB will continue to monitor the safety issue.

Additional correspondence

Response date: 29 July 2021
Response from: Lloyd’s Register
Action status: Monitor
Response text:

On 10 June 2021, Lloyd’s Register advised the ATSB that a proposal for a Unified Requirement (UR) to address fire detection and extinction for self-unloading bulk carriers had been raised with the General Policy Group of the International Association of Classification Societies (IACS). Following review, the proposal was expected to go to the IACS Safety panel for further work.

On 29 July 2021, Lloyd’s Register advised that a majority of IACS members preferred to await any new regulations or guidelines from the International Maritime Organization (IMO) rather than pursue the development of a UR.

Recognising that safety action by IACS was being requested primarily due to the relatively long time frame for safety action at the IMO and that safety action by IACS could have a positive safety impact, Lloyd’s Register have escalated the issue within IACS to the General Policy Group with an objective of issuing an instruction to Safety Panel to develop the required UR.

ATSB comment date: 03 November 2021
ATSB comment:

The ATSB welcomes the action taken by Lloyd’s Register (LR) in proposing and pursuing the development of a Unified Requirement (UR) to address the inadequacy of fire standards or regulations for cargo handling spaces of self-unloading bulk carriers. The ATSB encourages LR and the International Association of Classification Societies (IACS) to continue to work towards addressing this safety issue and ATSB will continue to monitor progress towards its resolution.

Proactive action

Action number: MO-2018-011-NSA-019
Action organisation: International Association of Classification Societies
Date: 11 May 2021
Action status: Monitor

On 18 January 2021, the International Association of Classification Societies (IACS) advised the ATSB that, in accordance with its guidelines, draft marine accident investigation reports containing matters relevant to class were to be directed to the classification society that classed the involved ship, in this case, Lloyd’s Register.

On 8 April 2021, consistent with those IACS guidelines, Lloyd’s Register confirmed it had initiated the process for an IACS Unified Requirement (UR) aimed at providing an expedient interim solution to addressing the safety issue through class rules pending changes to International Maritime Organization (IMO) regulations. Lloyd’s Register also indicated that the process, if successful, should result in the UR entering force on 1 July 2023.

ATSB comment:

Date: 11 May 2021

The ATSB welcomes the proposed course of safety action being progressed through the International Association of Classification Societies (IACS) by Lloyd’s Register to address this safety issue and will continue to monitor the issue.

Additional correspondence

Response date: 29 July 2021
Response from: International Association of Classification Societies
Action status: Monitor
Response text:

On 10 June 2021, Lloyd’s Register advised the ATSB that a proposal for a Unified Requirement (UR) to address fire detection and extinction for self-unloading bulk carriers had been raised with the General Policy Group of the International Association of Classification Societies (IACS). Following review, the proposal was expected to go to the IACS Safety panel for further work.

On 29 July 2021, Lloyd’s Register advised that a majority of IACS members preferred to await any new regulations or guidelines from the International Maritime Organization (IMO) rather than pursue the development of a UR.

Recognising that safety action by IACS was being requested primarily due to the relatively long time frame for safety action at the IMO and that safety action by IACS could have a positive safety impact, Lloyd’s Register have escalated the issue within IACS to the General Policy Group with an objective of issuing an instruction to Safety Panel to develop the required UR.

ATSB comment date: 03 November 2021
ATSB comment:

The ATSB welcomes the action taken by Lloyd’s Register (LR) in proposing and pursuing the development of a Unified Requirement (UR) to address the inadequacy of fire standards or regulations for cargo handling spaces of self-unloading bulk carriers. The ATSB encourages LR and the International Association of Classification Societies (IACS) to continue to work towards addressing this safety issue and ATSB will continue to monitor progress towards its resolution.

Last update 11 May 2021