One way of ensuring that action is taken before a disaster occurs is the use a process known as formal safety assessment.
This has been described as "a rational and systematic process for assessing the risks associated with shipping activity and for evaluating the costs and benefits of IMO's options for reducing these risks."
It can be used as a tool to help evaluate new regulations or to compare proposed changes with existing standards. It enables a balance to be drawn between the various technical and operational issues, including the human element and between safety and costs.
FSA - which was originally developed partly at least as a response the Piper Alpha disaster of 1988, when an offshore platform exploded in the North Sea and 167 people lost their lives - is now being applied to the IMO rule making process.
The Guidelines for Formal Safety Assessment (FSA) for use in the IMO rule-making process were approved in 2002 (MSC/Circ.1023/MEPC/Circ.392). The Guidelines have since been amended by MSC/Circ.1180-MEPC/Circ.474 and MSC-MEPC.2/Circ.5. The above Guidelines have now been superseded by MSC-MEPC.2/Circ.12/Rev.2.
The amendments include revisions to section 3 Methodology, including the addition of a paragraph outlining the need for data on incident reports, near misses and operational failures to be reviewed objectively and their reliability, uncertainty and validity to be assessed and reported. The assumptions made and limitations of these data must also be reported.
The MSC agreed to establish a Correspondence Group to further consider unresolved issues in particular concerning inconsistent results of different FSAs on the same subject and clarifications of the technology used for particular FSAs.
The MSC also agreed on the establishment, when necessary, of an FSA Group of Experts for the purpose of reviewing an FSA study if the Committee plans to use the study for making a decision on a particular issue. A flow-chart for the FSA review process was agreed. The MSC agreed in principle that the proposed expert group would undertake to review FSA studies on specific subjects submitted to the Organization, as directed by the Committee(s) and prepare relevant reports for submission to the Committee(s). The structure of the group of experts was left open for future discussion, though the Committee agreed, in principle, that members participating in the expert group should have risk assessment experience; a maritime background; and knowledge/training in the application of the FSA Guidelines.
What is FSA?
FSA is a structured and systematic methodology, aimed at enhancing maritime safety, including protection of life, health, the marine environment and property, by using risk analysis and cost benefit assessment. FSA can be used as a tool to help in the evaluation of new regulations for maritime safety and protection of the marine environment or in making a comparison between existing and possibly improved regulations, with a view to achieving a balance between the various technical and operational issues, including the human element, and between maritime safety or protection of the marine environment and costs.
FSA consists of five steps:
- identification of hazards (a list of all relevant accident scenarios with potential causes and outcomes);
- assessment of risks (evaluation of risk factors);
- risk control options (devising regulatory measures to control and reduce the identified risks);
- cost benefit assessment (determining cost effectiveness of each risk control option); and
- recommendations for decision-making (information about the hazards, their associated risks and the cost effectiveness of alternative risk control options is provided).
In simple terms, these steps can be reduced to:
- What might go wrong? = identification of hazards (a list of all relevant accident scenarios with potential causes and outcomes)
- How bad and how likely? = assessment of risks (evaluation of risk factors);
- Can matters be improved? = risk control options (devising regulatory measures to control and reduce the identified risks)
- What would it cost and how much better would it be? = cost benefit assessment (determining cost effectiveness of each risk control option);
- What actions should be taken? = recommendations for decision-making (information about the hazards, their associated risks and the cost effectiveness of alternative risk control options is provided).
Application of FSA may be particularly relevant to proposals for regulatory measures that have far reaching implications in terms of costs to the maritime industry or the administrative or legislative burdens that may result.
This is achieved by providing a clear justification for proposed regulatory measures and allowing comparison of different options of such measures to be made. This is in line with the basic philosophy of FSA in that it can be used as a tool to facilitate a transparent decision-making process. In addition, it provides a means of being proactive, enabling potential hazards to be considered before a serious accident occurs.
FSA represents a fundamental change from what was previously a largely piecemeal and reactive regulatory approach to one which is proactive, integrated, and above all based on risk evaluation and management in a transparent and justifiable manner thereby encouraging greater compliance with the maritime regulatory framework, in turn leading to improved safety and environmental protection.
One area where FSA is already being applied is bulk carrier safety. In December 1998, the Maritime Safety Committee, IMO's senior technical body, agreed to a framework setting out project objectives, scope and application, namely:
- to inform IMO's future decision-making regarding measures to improve the safety of bulk carriers;
- to apply FSA methodology to the safety of dry bulk shipping; and
- to secure international collaboration and agreement.
FSA is highly technical and complex. But it does offer a way forward and a means of escaping from the dilemma of the past in which action was too often put off until something went wrong - with the result that the actions taken often owed more to public opinion and political considerations than they did to technical merit.