IMO group publish study about IMO regulations necessity

The Steering Group for Reducing Administrative Requirements is a member of the IMO and carried out a study about the usability of IMO regulations: 

Reducing the Administrative Encumbrance in Maritime Regulations (IMO & Co).

The dual responsibilities of safety and efficiency in the maritime industry have resulted in many administrative obligations. While maintaining thorough documentation supports these requirements, a surplus of paperwork or an unacceptable level of complication can be counterproductive.

If operatives are forced to spend too much time meeting mandatory requirements, it leaves less time to focus on the running of vessels. To determine whether this is the case in the maritime industry, the Steering Group for Reducing Administrative Requirements (SG-RAR) instigated a consultation by setting up a web site, on via which interested parties could share their opinions.

In the review, the SG-RAR primarily focused on the requirements imposed by the International Maritime Organization (IMO). Respondents were asked to comment on whether they considered any of more than 560 regulations to be so outdated, irrelevant or unnecessarily time consuming that it made it difficult for workers to comply. Aspects under investigation included record keeping, the retention of seafarer certification and the display of certain information on vessels, which all form part of a larger collection of data required to be available on request. Selected categories of the survey have been SOLAS Convention, MARPOL and SCTW Convention.

The findings

A significant proportion of information was gathered from frontline maritime workers, such as ships’ crews, senior officers and masters, rendering the findings extremely trustworthy. Other groups have been related to classes, nations and further public organizations.

Those engaging with the survey were offered the opportunity to respond, both as an individual and as a member of a company, and were free to make any relevant comments. One encouraging finding was that 66% of the maritime regulations imposed under IMO management were not viewed as too great a burden by individuals, particularly when compared to the overwhelming amount of paperwork requested by other bodies, such as charterers or port agencies.

Where a problem was perceived was in the area of volume as the cumulative effect of many individuals’ administrative tasks were believed to create a significant burden on the vessels or companies as a whole. Many regulations that had been put in place to ensure the safety of the working environment by documenting compliance were at risk of compromising safety by shifting workers’ focus from practical activities to paperwork.

182 administrational requirements were found to be especially burdensome. However, a further investigation revealed that many of the requirements are still relevant and cannot be changed.

Recommendations

Taking into account, the essential nature of the requirements in question, the SG-RAR formulated 13 recommendations:

• Use an electronic system for reporting (such as CODie ISMAN)
• Create an IMO information portal on the internet
• Permit electronic certificates as well as paper versions
• Enable electronic record-keeping
• Permit electronic documentation, aside from certificates
• Consolidate reporting to a single site to avoid the necessity of creating duplicate reports
• Review troublesome administrative requirements with a view to creating electronic solutions
• Improve awareness of the reasons for provisions seen as particularly onerous, including the International Ship and Port Facility Security Code and SOLAS Chapter XI-2, which are vital to maritime security
• Increase awareness of the potential for creating an administrative burden through the accumulation of regulations
• Increase awareness of the potential for non-mandatory tasks to create unnecessary burdens
• Comply with IMO recommendations regarding the efficiency of maritime regulations to ensure that issues of coherence, transparency and complexity are addressed, in conjunction with the avoidance of duplication
• Adopt a fluid approach to maritime regulations to allow for changing needs and the relevance and appropriateness of new and future requirements
• Consider potential burdens when discussing new regulations with a view to avoiding the creation of problems. Enable electronic solutions, such as ship management software, wherever feasible

It is likely that the burden of administrative requirements can be reduced considerably through the implementation of these recommendations by the IMO management. While ship management software and web-based certification may be practical solutions to a long-term issue, the real solution will lie within the lines of communication between those who follow regulations and those who create them.

For further reading: TheDigitalShip.com

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