Interferry: New Eco and Safety Rules Lack Practicality

Originally formed back in 1976 as the International Marine Transit Association in order to provide the ferry industry with a platform for networking and information exchange, Interferry soon evolved into the only world-wide industry association, currently representing 225 members from 38 countries.

Interferry has also assumed the role of the industry representative regarding regulatory matters, attaining Consultative Status at the International Maritime Organization and Observer Status at the European Community Shipowners’ Association (ECSA) to fulfill this role.

World Maritime News spoke to Interferry’s Regulatory Affairs Director Johan Roos to find out how the industry is tackling the latest safety and environmental issues.

Current proposals to prevent the spread of invasive species go too far.

WMN: What are the most important projects you are currently involved in?

Roos: There are several regulatory issues of high importance on our agenda. The most immediate is ballast water management. In our view, current proposals to prevent the spread of invasive species go too far – measures to restrict inter-continental spread are laudable but we cannot see the point of imposing them on short stretches of water between two nations. In effect, this would require spending half a million dollars per ship on equipment to kill organisms that are common in the same water. 

Therefore, at the IMO’s Marine Environment Protection Committee meeting in May, Interferry and other sponsors will propose that neighbouring states should be allowed to reach bilateral agreements on whatever action they see fit. This would spare them from the onus of applying for exemption from a requirement to fit expensive, voluminous and – in their cases – unnecessary equipment.

On passenger ship safety we are engaged in three parallel issues of high relevance and concern. The first one is domestic passenger ship safety, where we are in close collaboration with the IMO in trying to devise new ways of reducing the large number of passengers that are lost every year, primarily in south-east Asia.

In our view, if all flag states put in place the requirements we have in for instance North America and Europe, the problem would be solved. We realise however that the resources to make such an investment are not available to all countries and therefore we need to find other ways to reduce the greatest risk factors. At the end of the day, it will come down to the member states concerned taking their responsibility.

The second issue relates to a ship’s ability to stay afloat after a collision or grounding. For many years a sophisticated and, to us, rather academic approach called ”probabilistic damage stability” has been pursued by the IMO to put in place requirements on a more theoretical basis rather than building new rules from experience. 

This general line of thought is good – it means that, rather than waiting for the next accident and adjusting the regulations accordingly, clever people can predict risk scenarios and design regulations to prevent such risk scenarios leading to catastrophic consequences. The concern we have is that the process has been very academic and non-transparent – looking forward, the ship’s captain may almost need to be a professor in naval architecture in order to ascertain whether his ship will sink if it is involved in an accident.

The third safety issue is more hands-on and is prompted by the recent Norman Atlantic fire. We note that several previous fires on Ro-Pax ships all relate to vehicles on the car deck and that the on-board systems for detecting and fighting fires have not been perfectly in tune with what we expected.  We do not yet know the details of the Norman Atlantic, but we believe it is important to have another look at fire safety on ferries so that any systemic or technical shortcomings can be properly addressed.

BC Ferries

The recent Norman Atlantic case was the first accident to claim passenger lives in this sector in more than a decade.

WMN: How would you assess the overall safety conditions across the industry? Would you say that there is an ever growing number of accidents (groundings/capsizing) in the ferry/Ro-Ro industry, often with tragic consequences?

Roos: Firstly, we do not see an ever growing number of accidents in the ferry/RoRo industry, especially if measured in relative terms i.e. the number of accidents in relation to the number of ships. Secondly, it is very important to categorise ferry accidents in relation to the regulatory framework that governs their respective operations.

International ferry routes governed by IMO rules in OECD countries have an excellent safety record.  The recent Norman Atlantic case was the first accident to claim passenger lives in this sector in more than a decade.  With 700 million passengers per year in Europe alone, ferry travel in OECD states can be considered extremely safe. 

At the other end of the spectrum, there are some less developed countries where domestic operations account for the vast majority of the 15,000 lives lost in ferry accidents since 2000.  This is truly an unacceptable situation but it is important to keep it in perspective – the World Health Organization reports that 1.24 million people died on the world’s roads in 2010.

WMN: What are the crucial issues that need to be addressed in order to prevent similar tragedies from happening?

Roos: First and foremost, adequate enforcement of already existing rules for domestic operations. In some cases, the domestic rules themselves may not be fully adequate, but we consider that sub-ordinate to flag states taking their responsibility to ensure that safe operations are conducted. Very basic measures – such as ensuring that the number of passengers on-board is within the ferry’s limits and that adequate life saving equipment is readily available – would immediately save many lives.

For international operations, we see no crucial issues to be addressed. The regulatory framework is exhaustive and predominately very well enforced. The only area of potential improvement we note is that cooperation between flag and port states could be improved in some areas to ensure that any local agreements are properly scrutinised.

WMN: The global shipping industry has been pursuing a “bigger is better” policy.  Can this kind of approach to building vessels be applied to ferries in the future?

Roos: We have already been through that phase and have probably reached the upper limits.  Ferries are more dependent on quick turnaround in port than tankers or container ships.  Many ferries also operate on routes and into ports that restrict their size. Furthermore, ferries serve as the lifeline for many scarcely populated island communities, where a super-sized ferry could not be filled even if the entire population was lined up.  

The ferry sector is very diverse, ranging from very small to very large ships, all of which try to be optimised for the routes they serve and the benefits they provide to society.

Scandlines

The new sulphur regulations have certainly diminished the ability of northern European ferry operators to compete for the same business with rival modes such as railways, motorways and low cost airlines.

WMN: How has the January 1 sulphur switch influenced the ferry industry?

Roos: The recent drop in fuel prices came as a fundamental relief to operators who have chosen to use low sulphur distillate fuel.  Even though the price difference between Heavy Fuel Oil and Marine Gas Oil remains at around USD 250 per ton, the lower oil prices in general have meant that operators are paying more or less the same today as one year ago.

The much dreaded overnight price hike of 20-40% on ferry tariffs has been avoided, so fears of a modal shift have also been diluted – although we must bear in mind that the road option has also benefited from the low fuel prices.  However, no-one knows if this price level is only temporary.

Long term, the new sulphur regulations have certainly diminished the ability of northern European ferry operators to compete for the same business with rival modes such as railways, motorways and low cost airlines. 

WMN: What has been the feedback from your members so far on meeting the new requirements?

Roos: A vast majority of the ferries operating in SECA areas have switched from 1% HFO to 0.1% MGO, with few reported technical issues.  Apart from some clogged up filters and separators, the transition has been remarkably smooth.

Also the port states seem to have been wise enough to refrain from any draconian inspection campaigns.  This recognises that contamination from old HFO in the on-board systems can significantly influence the sulphur content of a fuel sample and generate unintentional non-compliance, which obviously should not be punished.

WMN: What has been the preferred option among ferry companies to meet the new requirements?

Roos: Distillate fuels were already commonplace for many domestic operations and high-speed international crossings and most other ships have now switched to MGO.  In addition, a handful of LNG-fuelled ships have been introduced over the past few years and the world’s first methanol-powered ferry is now entering service. 

We have also seen a significant uptake of scrubber technology.  Some 40 ships under Interferry’s membership have installed or are currently fitting scrubbers on one or more engines in their fleet – the total of individual scrubbing units is approaching 100. 

The main concern among operators right now is that, despite the EU Commission promoting scrubbing as an alternative compliance solution since 2010, there is still no legal certainty that the units already installed may actually be used in all SECA ports and waters.

WMN: Many companies have opted for LNG-powered newbuilds. However, there have been various safety concerns regarding the location of fuel tanks on LNG-powered ships. Have there been any developments on this debate? What would be the ideal scenario for ferries in this respect?

Roos: There never were any real safety concerns as such. Our concerns were over a rather puzzling academic approach to LNG tank location – and consequently their size – in order to prevent impact damage. This approach took into account mostly irrelevant accident statistics derived not primarily from modern ferry operation but from a muddled dataset ranging back to the 1980’s and largely populated with container ship accidents – since there were too few ferry accidents to be statistically significant.  

If LNG prices prove to be at the levels promised by the fuel’s proponents over the years, there is no reason to be overly concerned by the current lack of infrastructure.

At the IMO, Interferry and others successfully argued that the very same safety provisions that have effectively safeguarded huge LNG tankers for decades should also be applied to LNG propulsion tanks. We will now be able to build new LNG-powered ferries that will not have to refuel after each and every crossing.

WMN: Is LNG a sustainable solution for ferry operators having in mind that LNG bunkering is still under development?

Roos: With any new fuel there is always a gradual transition period as supply and demand seek a balance. If LNG prices prove to be at the levels promised by the fuel’s proponents over the years, there is no reason to be overly concerned by the current lack of infrastructure.

The EU Commission has put in place a requirement for ports to provide LNG, but Interferry considers this to be slightly misguided and a matter best dealt with by the market. Instead, the EU should support individual ship owners in their investment in LNG-powered ships, which would also entail investment in the necessary infrastructure.  

Furthermore, the EU would be perfectly placed to support the bunker suppliers investing in LNG provision, including shore-side tanks.

Interview Interferry

WMN: How has the oil price fall influenced ferry operators and their investment in environmental solutions?

Roos: It has given them some breathing space to cope with the SECA situation, but the general sensation in the market is that today’s oil prices will not last for very long. 

Further ahead, in addition to the increased uptake of scrubbers and LNG, we also see some very interesting developments on electrically-powered ferries, either as hybrids or as pure electric drive.

80% of maritime incidents are due to human error

WMN: How would you describe the outlook for the ferry industry having in mind the ongoing trends and push for technologically-superior vessels? Can we expect SMART (autonomous) ferries to be introduced soon?

Roos: We would like to see an informed discussion on how we could better utilise modern technology to reduce risks in maritime operations in general and ferry operations in particular – but this must go hand in hand with increased focus on the human element in safety.

At IMO level, improved safety is too often equated with adding more steel and equipment on the ship – seemingly with the unrealistic end goal of making ships unsinkable. That mentality is hampering the industry and should be compared to what has been done in aviation over a long period of time. Aircraft are not expected to be collision proof but rather to operate in a system that prevents them colliding or crashing in the first place.  

We are confident that very much could be done with a systems approach for ferries, but we would not consider autonomous ferries to be realised in the near or even medium term.

Meanwhile we also wholeheartedly support the growing trend to think beyond enhanced technical safety solutions by combining them with improved operational control. We know that 80% of maritime incidents are due to human error, so the industry is increasingly committed to crew training programmes that build a leadership and teamwork safety culture.

The experience and competence of on-board personnel must be acknowledged as a paramount factor in helping to avoid or mitigate an incident.

World Maritime News Staff

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