- the proposed changes would not have affected the accident with Combat boat #848
- the proposed rule to implement was neither understood nor analysed by the Swedish Accident Investigation Authority, and
- the proposed changes most likely affect safety culture negatively, as the changes prescriptive nature of safe and unsafe sea areas contradicts the general need to develop the crews’ risk understanding.
Friday, 13 April 2018
Safety on board naval vessels – does the specific operational conditions make safety efforts and safety lessons based civilian maritime work irrelevant?
Today, the safety work on military vessels is influenced by civilian approaches, regulations and codes. This influence introduces important civilian lessons into naval vessel design, but can also potentially be in conflict with military task solving. One regulation, which is largely influenced by IMO codes, is the Swedish Military Ship Code formulated by the Military Safety Inspectorate. Risk management could present an approach for investigating if the civilian influence on the code leads to decisions and solutions that hinder military task solving. IMO’s Formal Safety Assessment (FSA) is a risk-based approach for such an investigation.
The effect of using IMO and classification society-based codes for the design of naval vessels has been found to assist in the engineering process and to guarantee a basic level of safety. However, the civilian naval engineering practices are not sufficient for guaranteeing survivability and thus safety in military cases. However, there could be a potential conflict between the rules that prescribe aspects of vessel use, and military task solving.
In 2010, the Swedish Navy introduced a new rule re-defining the sea area of safe operation for respective classes of vessels. The new rule is based on an EU directive developed for European passenger vessels. The Swedish Military Ship Code is not intended to limit military (wartime) operations. However, a Swedish naval vessel does (as most naval vessels do) always operate under a basic readiness level and therefore under military conditions. The potential conflict between rules that limit vessel use (rules for areas such as operations) and military task solving have not, so far, been investigated.
The objective of the published article was to describe the investigation performed and to focus on the meta lessons identified by applying the FSA structure to a military maritime safety case. The investigation analysed the safety level in the Swedish navy as a result of the regulation on sea areas of safe operation. The objective of the described investigation was to investigate the safety impact of the new sea areas given the Swedish Navy’s concept of operation, staffing structure, and competence. An additional objective was to determine if the rule is cost effective, and whether, if needed, sufficiently low risk can be achieved by an alternative rule, which has less impact on the Navy’s operations.
The investigation identified that it in the period studied there have been safety issues leading to risks higher than negligible. For the studied severe accidents, the identified risk levels are a result of decisions made on-board when solving military peacetime tasks. However, the quantitative analysis of the nine severe accidents shows that not only the human element affect the probability of an incident. Thanks to the military education, training, organization and personal safety equipment severe incidents that involve high speeds, cold water and vessels lost or severely damagedalso often result in relatively low levels of consequences. Such incidents would typically lead to multiple fatalities for a civilian vessel.
The less severe incidents leading to injuries were most often a result of maintenance work performed on-board independent of the vessel operation. Therefore, in the material, there is a low number (<1) of accidents per year related to the vessel operation with potentially severe consequences and a higher number (>5) of accidents per year related to work on-board leading to injuries.
An investigation in accordance with the FSA, as performed in the described investigation, in qualitative terms analyses both the effectiveness and the effects of the rule. Therefore, an analysis
can show if a regulation affects safety in the manner intended and if there are other means by which the regulation affects the operations. However, in order to reach high validity, the FSA approach needed to be supported by more explicit support on uncertainty treatment and propagation and by a peer review with strong contextual knowledge. The quantitative risk estimated was not, and should not, be in focus.
The investigation particularly highlights the need for an approach for analysing proposed safety changes both in terms of effectiveness and in terms of suitability. In 2008, after the accident in which Combat boat #848 was lost, the Swedish Accident Investigation Authority recommended 11 changes. One of those changes was to implement new sea areas of safe operation according to the civilian regulation; in addition, there were several regarding strengthening the crews’ risk understanding. In this investigation, the recommendation to implement new sea area limitations is shown to be problematic in several ways:
From this example, it can be identified that the effectiveness of the proposed changes must be analysed by the Accident Investigation Authority or by the Armed Forces. The result of an accident investigation is a set of recommendations; however, these recommendations must be analysed before they lead to new rules, particularly if the recommendations affect operation types that the Accident Investigation Authority have limited insight into. It must be ensured that new rules have the intended effect on safety; this responsibility must be taken by the organization deciding the new rules.
This investigation has shown that the recommendations to change the sea area rule led to a rule that has very limited positive effects, possible far-reaching negative effects and substantial operational costs.
The safety level for a vessel is a complicated relationship between several factors including the vessel type, the quality of the vessel’s maintenance and the vessel operation (seamanship). This finding is also identified in this investigation. It is stated in earlier studies using the FSA approach that “human error problems” can and must be included. However, this study shows that human element strengths also can and must be included, as they had an important impact on the link from incident to consequence and are an important part of the seamanship. The study identified that the high level of safety training of the persons on-board was important to making sure that severe incidents often lead to relatively limited or minor injuries.
An approach in accordance with the FSA structure is suitable even for areas outside the IMO’s typical scope. The FSA structure does not limit the approach to operational conditions as defined by civilian ships. However, the analysis needs to incorporate operational knowledge suitable for the area under study.
The military vessels’ concept of operations differs from civilian ships in such way that civilian safety rules can become irrelevant.
The case examined also raises many questions such as about how to articulate the actual difference between civilian and military contexts, especially in peace time; about how risk to individuals should and could be compared to national security risks as a result of operational limitations put on armed forces; and about how different types of hazards combine to create risk. These types of questions that are dependent on the connections between the organizations and technology under study and the Swedish society in general are largely here left unanswered. However, answering such questions without concrete examples easily becomes abstract and will therefore not affect decision makers. The hope here is that the case studied and described can be used as one example that together with other suitable and complementing examples can assist in making future conclusions that assist decision makers and increase the understanding of applicability and validity of risk management in state safety and security issues. However, it is unlikely that the perspective on risk presented by the FSA alone can answer such important and complex questions. Compared to traditional risk analysis of technical systems the FSA covers more aspects of the socio-technical system studied. However, the analysis power provided is not, and not intended to be, an approach that can be said to fully represent risk and safety in socio-technological systems.
Also more specifically in relation to this case further work, both in regard to how central parameters should be measured or calculated and more overarching questions, is needed. In relation to the definition of central parameters, it is important that such definitions (such as how to calculate the number of ship years) are clear and communicated. Two overarching questions that need further investigation are how risk limits in relation to military tasks should be defined and how to define and assess operational costs in general and quantitatively.
The extra risk introduced by antagonistic threats is not assessed, and the crews have not been tested in relation to such conditions. Therefore, the negative effects of the rule (as a result of the civilian and commercial background), which reduce the crews’ need for continuous risk assessment on-board, could be even more harmful to war-like military operations than what is shown in the material studied.
Tuesday, 10 April 2018
I was recently asked to write a text about maritime administrations. I choose to focus on maritime security and what a Swedish maritime administration in regards to maritime security is or should be: Below are some of the points I tried to make:
To enable economic stability and commerce, it is necessary to protect the free flow of goods shipped by sea (Council of the European Union, 2014, MNE 7, 2012, Secretary of Defense, 2012, Swedish Maritime Administration, 2014, Till, 2009). The shipping system is composed of many autonomous, but interconnected, actors (Swedish Maritime Administration, 2012) ranging from small local ship owners to large international ship operators.
Maritime security is addressed at many levels, from international bodies such as the United Nations (UN) and the International Maritime Organization (IMO) to single ship operators, but also by both military and civilian organizations. These levels and organizations are interconnected and a security decision made by one will affect the others (Liwång et al., 2015, Swedish Maritime Administration, 2012).
In this text a Maritime Administration is understood as the national body/bodies that issue government policy for ships and boating in relation to maritime safety and security (other important tasks in relation to areas such as environmental control, certificates of competency and representing the country on IMO and so on are not under study here).
For civilian ships and ports, today’s threats are managed through international maritime safety efforts regulated in the International Ship and Port Facility Security (ISPS) code (IMO, 2002) which puts substantial responsibility in relation to ship security, on the operators. The code was developed in the aftermath of the September 11, 2001, terrorist attacks in the United States. According to ship operators and security experts, the code does not guarantee secure shipping (Liwång et al., 2013, McNaught, 2005) and can only be considered as a first step (Mitropoulos, 2004). Also, the risk based security decisions taken by ship operators will only, at best, consider the specific operator’s commercial rationality, not the strategic interests of a region. Several Swedish studies has indicated a need for strengthening national transport coordination in response to crises, both as a result of a disruption of the transport system itself (Mötesplats Transporter, 2009, Samverkansområdet Transporter, 2007, Swedish Civil Contingencies Agency, 2014, Swedish Maritime Administration, 2012), but also to avoid that a crisis in other areas and sectors affect the transport system (Samverkansområdet Transporter, 2006, Swedish Civil Contingencies Agency, 2014, Swedish Maritime Administration, 2013, 2014). However, specific Swedish efforts for maritime security are hard to identify.
In Sweden the public debate in regard to maritime security has mostly been limited to piracy off Somalia and legal aspects of armed guards on ships, two issues with little relevance for maritime security in European waters. However, outside the public eye there have also been specific studies, analyses and exercises initiated by Swedish government agencies such as the Swedish Maritime Administration (Swedish Maritime Administration, 2006), the Swedish Radiation Safety Authority (the exercise Pilot 2015) and the Swedish Armed Forces (a staff exercise regarding maritime security 2016) and academic studies, see for example University of Helsinki (2009). These works typically deal with a single terrorist attack against a ship under Swedish flag and includes several organizations and government agencies, but not a complete maritime security system perspective based on the nation’s strategic transport needs.
All states must consider the capabilities needed to ensure maritime security in relation to relevant security threats. According to a workshop with representatives from transport security stakeholders in Sweden there is a need for better knowing and understanding the risks in the transport system and for identifying an acceptable minimum level of the society’s protection (Mötesplats Transporter, 2009). Subsequently, a need for strengthening also the understanding of the maritime security system has been identified. Also, the existing research in maritime security is limited. Previous research, such as Bichou (2008), Liwång and Ringsberg (2013), Liwång et al. (2013) and Psarros et al. (2011), show that empiric data on the shipping system as well as on specific incidents is needed to be able to discuss measures and risk control options. It is also clear from the previous research on society protection in general, such as Cedergren and Tehler (2014), and on maritime security specifically, such as Schneider (2012), that measures are needed on several different levels of the system (Cordner, 2014).
To reduce the above-identified challenges there is a need for systems approach that examine different aspects and levels of the maritime security system and how the system delivers utility to a nation or region. Therefore, it must be made sure that maritime security capability (from a system perspective) is correctly designed and distributed between different system levels to ensure sufficient security. A nations maritime administration has a central role to play. However, also other stake holders take decisions that greatly affect maritime security. Such stake holders include autonomous ship operators as well as law enforcement agencies that both lack a system level knowledge. This aspect presents specific challenges for the region, nation, organization responsible for ensuring sufficient maritime security. From this it also follows that a system perspective on maritime security here means that maritime security is viewed in relation to the shipping system and its roles in a region. It also means that the focus is on a nation’s (or set of nations’) capabilities and efforts needed.
A need for a risk governance approach
Risk is not constant and especially security risks are subject to considerable degrees of uncertainty. The rarer the event, if predictable at all, the less reliable the historical data and the estimates based on them are (Aven & Krohn, 2014, IACS, 2012). Regulations, guidelines and methods in the field of maritime safety have a history and culture of systematic research, development and implementation (Kuo, 2007). In contrast, international security is highly politicised and therefore not as transparent (Wengelin, 2012). Therefore, the tradition of maritime security is not well established (McNaught, 2005), this affects the work performed at maritime administrations in relation to maritime security. Applying risk-based approaches to security areas requires special considerations. Therefore, there is a need for both further research and applied development of methods and tools. This development must be able to manage the new, more complex demands within maritime security (Department of Defense, 2007, McNaught, 2005).
It has been identified that a whole systems approach is needed for transport studies in general (Swedish Civil Contingencies Agency, 2014) and for maritime security specifically (Bateman, 2010, Schneider, 2012, Schofield et al., 2008) and therefore a framework for understanding the maritime security risk governance is here adopted. Here a risk governance process is understood as a set of activities and actions taken by various stakeholders to manage risk in a context characterized by uncertainty, complexity and ambiguity. To be able analyse conditions where no single stakeholder can dictate the conditions the concept of risk governance has been introduced (Bateman, 2010, Cedergren & Tehler, 2014, Schneider, 2012). According to the research by Cedergren and Tehler (2014) there is, in risk governance, a need for taking into account the ways in which risk-related decision-making is performed in settings where many stakeholders are involved, and where these different stakeholders may hold diverse meanings of the concept of risk (Rasmussen, 1985). The approach therefore here aims to answers questions about the purpose, function, and form of a maritime security risk governance (Cedergren & Tehler, 2014).
Identified Maritime Administration challenges
Performance of organizations, such as ship operators as well as maritime administration agencies, should be assessed by their contribution to the risk governance system. Therefore, an investigation was performed to identify such contributions from the Swedish Maritime Administration and the Swedish Transport Agency since 2006.
In 2006 the Swedish Maritime Administration (2006) based on the yearly risk and vulnerability analysis stated that the sector had, compared to other types of risks, the “best ability … to handle the event terrorism”. However, this claim was done without any extensive explanation and since then no risk and vulnerability analysis has been performed in relation to maritime security. The latest Swedish maritime safety report Säkerhetsöversikt 2016 has no mentions about maritime security, ship protection measures, crime at sea, or the effects of criminal activities on shipping (Swedish Transport Agency, 2017). Also, the Swedish Transport Agency has no specific maritime security information for Swedish conditions or for the sea areas of specific interest such as the Baltic Sea. Therefore, there is very little evidence of that, and how, the Swedish government agencies implement and enforce maritime security (other than administrative tasks in relation to the ISPS code).
The lack of clear maritime administration activities contributing to the maritime security risk governance system coupled with exercises examining single events (rather than system events) lead to a system understanding. This makes it challenging to other system stake holders, such as the Police, the Coast Guard and the Navy, to understand and adapt their activities in an effective manner.
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