2. DNV'S APPROACH TO FSA
2.1 FSA at IMO
IMO (1997) defined FSA as a 5-step process, consisting of:
1. Hazard identification
2. Risk assessment
3. Risk control options
4. Cost-benefit assessment
5. Recommendations for decision-making
The purposes of the FSA are to identify areas of concern in the existing regulations, to set priorities for new regulations, or to analyse the implications of proposed amendments. The FSA is applied to generic ships or systems, characteristic of the type affected by the regulations under consideration. Step 1 involves identifying relevant hazards, and Step 2 requires a quantitative estimation of the resulting risks for people, property and the environment. Step 3 considers various options for managing the risks (i.e. through new regulations), and estimates their benefits in reducing the risks. Step 4 compares these benefits with the costs of implementing the option for all stakeholders. Step 5 recommends to decision-makers which regulatory options should be adopted to make the risks as low as reasonably practicable.
2.2 DNV's Philosophy for FSA
Using FSA for improving classification rules is fundamentally no different to using it for IMO regulations. Class Societies are able to make decisions rather more swiftly than IMO, but is still constrained by the need to reach agreement with IACS in many areas, and by the essential need to retain the support of shipowners. For DNV this provides an incentive to align itself closely with the international approach to FSA, and to contribute positively to developments at IMO and IACS.
Being a single organisation, DNV may take advantage of a more consistent approach to FSA than is realistically possible among the many governments and organisations that contribute to IMO. This is why DNV decided to develop a common foundation for all its FSA work, which will allow different units to apply FSA to different rule topics while making consistent assumptions about overall risk levels.
The scope of services from classification societies is wider than IMO's remit, since class rules are intended to ensure that the ship is fit for purpose, as well as safe. This provides some degree of protection against interruptions of the owner's business, and is in general provided by rules for voluntary class notations. This makes it Important for DNV's FSA to distinguish clearly between rules that are required to achieve safety of life and the environment, and those that help protect the owner's assets and optimise business efficiency, which should be optional provided that fundamental safety goals are met.
2.3 DNV's Foundation for FSA Based Rule Development
A comprehensive FSA of all class rules is a massive undertaking. The rules have evolved over many years, incorporating immense practical experience, but there is little documented evidence on which hazards they address and how effective they are. Most rule sections can apply to any type of ship, so that their costs and benefits will differ in different applications. Underlying the formal rulebook are various survey schemes, customary interpretations and supplementary guidance, so that rules can not always be interpreted in isolation. The rules are intended to function as a coherent whole, and cannot always be readily broken down into independent units for analysis.
While an FSA of class rules could be done in an informal qualitative way, giving rules that are loosely "risk-based", establishing a fully transparent risk basis for the rules requires a more rigorous approach. DNV therefore decided to quantify the costs and benefits of its rules, as far as possible, consistent with the 5-step FSA methodology. Completing this will take many years and involve contributions from each of various discipline units involved in rule development. To achieve consistency within such an undertaking, a firm supporting foundation is required.
DNV's foundation for FSA based ship rule development will include:
・ Outline risk estimates for all major generic ship types.
・ Detailed FSAs of key generic ship types (tanker, bulk carrier, container ship etc)
・ A "rule map" showing the purpose of each section of the DNV Rules
・ Acceptance criteria defining whether particular aspects of ships satisfy the Rules
・ Pilot Rule FSAs of selected rule topics, identifying cost-effective rule amendments
・ An FSA guideline, explaining how FSA will be used in the rule development process
The combination of generic ship FSAs and the rule map will form an "FSA Platform", supplying the essential information needed for an FSA of any given rule topic. The actual FSAs of rule topics will be an ongoing part of rule development, but the current project will illustrate how this will work by means of a few pilot rule FSAs. Our long-term vision is that a full set of rule FSAs for each rule topic area will complete the FSA of the DNV Rules (Figure 1).
Development of the foundation provides many benefits for DNV and its customers, in addition to establishing the platform for efficient rule FSAs:
