1. 1 IMO Goal-based Standards A shipbuilders ’ opinion September 20, 2007 The Shipbuilders ’ Association of Japan NISHIYAMA, goro

2. 2 Contents Structure of GBS Pilot panel for Tier III Performance Monitoring SAJ ’ s Opinion on IMO-MSC

3. 3 Structure of GBS Tier I Goal s INDUSTORY Tier II Tier IV Tier V Tier III Industry Standards, Practices and Quality System Verification of compliance IMO IMO IMO Classification Society Detailed Requirements Functional Requirements Already approved, in principle Might be approved, at MSC83 in principle

4. 4 Pilot Panel The trial application of the Tier III verification process using IACS Common Structural Rules (OT-CSR)

5. 5 Deliverables of Pilot Panel Draft guidelines for the verification of compliance with GBS Part A: Tier III verification process Part B: Tier III information/documentation requirements and evaluation criteria Structural performance monitoring (new proposal) And etc. will be discussed at MSC 83

6. 6 Tier III Guidelines proposed by Pilot Panel Tier Ⅲ Criteria proposed by PP contains unachievable ones even by the state-of-the- art technology for some time in the future. e.g. Fatigue by slamming or vibration, residual strength in damaged condition, etc.

7. 7 Requirements and criteria; To be appropriate to the current level of technology to avoid time consuming confusion at the application time. SAJ ’ s opinion on Tier III verification of compliance

8. 8 Detailed verification of compliance should be left to the established technical committee of each classification society. Reason; Very wide knowledge of structure will be needed to verify the compliance A lot of time to conduct the verification work will be needed if only by Group of experts. Verification by IMO should be conceptual and methodological SAJ ’ s opinion on Tier III verification of compliance

9. 9 Before approval of Tier III; Process and requirements proposed by Pilot Panel to be used for verification of Oil Tanker CSR by members similar to the Group of Experts and demonstrate their adequacy after MSC83. Members for Group of Experts should be composed of experts from research institutes, shipowners, class and shipbuilders evenly. Phase in time; Sufficient phase-in time between adoption and entry into force of the GBS requirements to be prepared. SAJ ’ s opinion on Tier III

10. 10 Introduction of the Structural performance monitoring into GBS The Pilot panel recommended to establish a requirement of continuous structural performance monitoring, which is a self- assessment of the effectiveness of the Rules.

11. 11 Content of Performance Monitoring II.16 − Structural performance monitoring Structural performance data on corrosion/steel renewal, fractures and other structural failures, including catastrophic failures, for ships designed and constructed to the Rules should be collected [periodically] [every five years] over the service life to enable continuous reassessment of the adequacy of the Rules in attaining satisfactory structural performance. The structural performance should be compared to performance metrics and the Rules duly revised if the performance targets are not met.

12. 12 SAJ ’ s position on Performance Monitoring We support the preliminary proposal “in general” as it is essential to establish transparent process in which the cause of failure is continuously analyzed and countermeasures are taken appropriately.

13. 13 Issues to be pointed out on Performance Monitoring Structural steel renewal due to corrosion or fatigue fracture depends on not only inadequacy of the rule but also defects of repair works, inappropriate operation, survey, inspection and maintenance. These incidents might be dominated by specific shipbuilders, owners, classes or operators.

14. 14 SAJ ’ s opinion on Performance Monitoring Information; adequately classified. Feedback system; not work unless unrealistic requirements and criteria excluded.

15. 15 SAJ ’ s opinion on Performance Monitoring Restructure the present information flow among flag states, owners, builders and classification societies, continuous record of operation, inspection and maintenance At present, only periodic survey by classification societies is conducted. When performance metrics are agreed to be developed appropriately, we are ready to cooperate.

16. 16 SAJ ’ s opinion on the Role of IMO MSC(1) Roles of IMO-MSC should be to focus on developing regulations to prevent loss of lives due to causalities and destruction of environments. IMO-MSC should not be involved in any too detailed requirements which do not directly lead to above things in order to avoid unnecessary confusion.

17. 17 IMO-MSC should not get too much involved in commercial issues. Corrosion Fatigue cracks etc. Above incidents can be reduced by adequate inspection, survey, operation and maintenance as well as increase in initial scantlings. SAJ ’ s opinion on the Role of IMO MSC(2)

18. 18 IMO or Class cannot intervene shipyards’ Intellectual properties. Competitiveness of any shipyard depends on Intellectual properties. R&D Experience SAJ ’ s opinion on the Role of IMO MSC(3)

19. 19 Thank you for your attention