Quality Management of Formal Safety Assessment (FSA) Process PDF

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Quality Management of Formal Safety Assessment (FSA) Process J. Dasgupta Indian Register of Shipping ABSTRACT The Formal Safety Assessment (FSA) process, proposed during MSC 66 at the IMO and subsequently released as Interim Guidelines (MSC/Circ.829- MCPC/Circ.335) has generated a number of applicat...

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Quality Management of Formal Safety Assessment (FSA) Process J. Dasgupta Indian Register of Shipping ABSTRACT The Formal Safety Assessment (FSA) process, proposed during MSC 66 at the IMO and subsequently released as Interim Guidelines (MSC/Circ.829MCPC/Circ.335) has generated a number of applications over the past few years, particularly in MSC 73, MSC 74, MSC 75 and MSC 76. These applications cover a wide area of interests in the marine field, most important one being the FSA Studies on Bulk Carrier Safety by various Administrations and IACS. It becomes imperative that the FSA studies being conducted now towards the development or upgrading of future Rules are based on systematic quality management principles, to avoid a wide variation in the quality and conclusions from the FSA process. The five-step FSA process is considered suitable for application of the "process approach" as per ISO 9001:2000 requirements. This application of the Quality Management Standard would ensure that the quality objectives of each of the Steps are identified, and attained through use of appropriate techniques and data by the FSA team. The "process flow" during each of these steps are required to be worked out, and the pertinent issues viz. necessary inputs, activities, subprocesses, critical parameters, controls and measurements are to be identified to arrive at the desired outputs. Such a ‘process approach’ would assure transparency of the activities behind the FSA as well as reliability of the concluded results. The paper presents a proposal for the application of the above quality management methods to the FSA procedures using a ‘process approach’. Typical ‘Process Flow Diagrams’ for the various steps of FSA process along with the quality parameters are included in the paper. A proposal for internal validation of an FSA application prior to submission to the decision makers is also covered in the paper.

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INTRODUCTION The basic methods of the FSA are the various safety management tools developed in the 70's’and 80's’ These have been adopted in a number of countries mainly by the industries like nuclear power, chemical process plants, offshore petroleum and some aspects of aerospace engineering. Traditionally, the maritime industry has been reactive in its development of rules and standards for ship safety. Table 1 lists the major maritime casualties that have resulted in IMO Rule Developments over the past few years.. Two notable

Formal Safety Assessment (FSA) is a rational and systematic process for the proactive management of safety based on principles of hazard identification, risk analysis and cost-effectiveness evaluation of the efforts in controlling the risks. FSA can be used as a tool to help in the development of new safety regulations or in analysing an existing set of regulations, and thus achieve a balance between various technical and operational issues, including human element and costs.

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problem, the following parameters may be considered relevant;

contributors to the change in industry’s attitude were the Lord Cullen Report on the Piper Alpha (1990) and the Lord Donaldson Report on the grounding of the tanker Braer (1994). As a result of the recommendations of the Lord Cullen Report, offshore platforms operating under the UK administration are required to perform safety cases for each individual platform. The Lord Donaldson Report that followed recommended that the maritime industry consider a similar approach for ship operation (Lord Donaldson, 1994). The essential aspects of FSA lie in the proactive control of risks [1]*. The ‘Interim Guidelines for the Application of Formal Safety Assessment (FSA) to the IMO Rule-Making Process’ was adopted at the 68th. Session of MSC held in May 1997 and was circulated as MSC/Circ.829 (MEPC/Circ.335) in December 1997 [2] . These guidelines were intended to facilitate trial applications of the FSA process. The trial applications covered a wide area of interests e.g. High Speed Crafts, Helicopter Landing Facilities on Large passenger Ships, Hazard Identification of Ballast Water Exchange, Safety of Lifeboat Launching Devices and most importantly the FSA Studies on Bulk Carrier Safety by various Administrations and IACS. The Interim Guidelines were revised by IMO during MSC 74, 2001, and released as the revised IMO FSA Guidelines MSC/Circ.1023-MEPC/Circ/392 published in 2002 [3]. It is likely that many more applications of FSA will now be carried out and submitted to the regulatory authorities for acceptance. 2.

a. b. c. d. e.

Table 1: Major Maritime Casualties which Influenced Rule Development March 1967 March 1978 September, 1980 March 1987 March 1989 April 1990

FSA PROCESS [2], [5]

January 1993 September 1994 February 1995 January, 1998 December 1999

The modalities of FSA application to shipping have now been established. This generic approach is designed to comprise the following steps (Fig. 1): a) Hazard identification; b) Risk Analysis; c) Risk control option d) Cost benefit assessment; and e) Decision making recommendation. The characterisation of hazards and risks should be both qualitative and quantitative, consistent with the available data, and should be broad enough to include the range of options for reduction of risks. A typical FSA exercise in a ship type according to the IMO Guideline would proceed as follows: Problem definition: The problem under analysis and its boundaries should be carefully defined. While defining the *

Ship category (e.g. type, length or gross tonnage, new or existing etc.,) Ship systems (e.g. type layout, subdivision, propulsion, etc.) Ship operation (e.g. in ports and/or during navigation, etc.) Accident category (e.g. collision, explosion, fire, etc.) Risk category (e.g. injuries and/or fatalities to passengers and crew, environmental impact, damage to ship or port, etc)

[ ] denotes References at the end of the paper.

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Torrey Canyon Amoco Cadiz Derbyshire Herald of Free Enterprise Exxon Valdez Scandinavian Star Braer Estonia

West Coast of England Northern Coast of France North Pacific Zeebrugge West Coast of Alaska Skagerak The Shetland Isles

Sea Empress

South of Uto (Finland) Milford Haven

Flare

Nova Scotia

Erika

West Coast of France

Step 1 Step 1 Hazards Hazards

FEEDBACK

Step 3 Step 3 Options Options

Step 2 Step 2 Risks Risks

Step 4 Step 4 C.B.A. C.B.A.

Step 5 Step 5 Decisions Decisions

FLOW OF STEP

Fig. 1 Information flow in FSA Process [4] Prior to application of the FSA steps additional information would require to be compiled on the following: - Identification of existing design concepts and review of existing rules/regulations - Identification of existing operational procedures/concepts - Compilation of materials under consideration and their properties. - Identification of involved parties responsible/liable for safety. In general, the problem under consideration should be characterised by a number of functions. Where the problem refers to a type of ship, these functions include carriage of payload, emergency response, communication, manoeuvrability etc. Where the problem relates to a type of hazard, for instance Fire, the functions include prevention, detection, alarm, containment, escape, suppression etc. It is imperative that a comprehensive view is taken of the ship ‘hardware’ (i.e. technical & engineering system) dynamically integrated to the ‘software’ (i.e. human behaviour governed by organisation & management infrastructure).

identification exercise e.g. Brainstorming, HAZOP, FMEA followed by qualitative Fault Tree Analysis (FTA) and Event Tree Analysis (ETA) for specific cases. The accident categories are screened and prioritised discarding scenarios judged to be of minor significance using a risk matrix or similar other technique. The screened and prioritised list of accident categories provide the input for the risk contribution tree in Step. 2. Risk Analysis (FSA Step 2): Risk is the combination of frequency and consequence. In this FSA Step the risk associated with an accident data is assessed by constructing and quantifying a diagram called ‘the risk contribution tree’, based on accident data and expert judgement to display the distribution of risk. The fault trees and event trees from Step 1 are quantified in developing the risk contribution tree (Fig. 2). The purpose of Step 2 is to identify the distribution of risk, thus allowing attention to be focussed upon high-risk areas, and to identify and evaluate the factors, which will influence the level of risk. Thus Step 2 aims to establish the relationship between the regulatory provisions and the occurrence of accidents, enabling appropriate regulatory changes to be introduced/amended to reduce risk.

Identification of Hazards (FSA Step 1): The purpose of Step 1 is to help identify the causes of accidents and to generate a prioritised list of accident categories, specific to the problem under review. There are several methods available to document this

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Fig. 2 The general structure of the risk contribution tree[2] effectiveness as per Step 2, and then passed on to Step 4 for assessment of costs and benefits.

Risk Control Options (FSA Step 3): A risk control measure is a method of controlling single element of risk and the risk control option is appropriate combination of risk control measures. FSA Step 3 comprises of 3 stages:

Cost Benefit (Effectiveness) Analysis (FSA Step 4): When the basic risk is estimated to be within an “as low as reasonably practicable”(ALARP) region, Risk Control Options (RCOs) should be developed and Cost Benefit Assessment (CBA) or Cost Effectiveness Assessment (CEA) should be carried out. CBA or CEA may be used to select reasonably practicable risk reduction measures. The purpose of the assessment is to provide a basis for decision-making about RCOs. In a conventional CBA, the acceptance criterion is simply that the benefits outweigh the costs. In CBA the analyst converts all risks to monetary units. CEA presents a ratio of costs to benefits, and avoids putting a value to the benefit (e.g. life saved). The value judgement is left to the decision-maker when deciding which RCOs to implement.

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Attention on areas needing control by identifying areas of the risk contribution trees representing risk, high consequence, high frequency and low confidence. Identification of new risk control measures not controlled sufficiently by existing measure. The techniques used include use of Causal Chains & Risk Control Attributes to encourage development of appropriate measure at a selected control point in sequence of: {Causal factors >> failure >> circumstance >> accident >> consequence} Derivation of the risk control options i.e. to first decide whether preventive or curative measures are to be adopted; and then group the suitable risk control measures as per the chosen approach to produce a number of possible and practical risk control options. The results from Step 3 comprises a range of risk control options, which are again assessed for their

Decision Making (FSA Step 5): The purpose of this Step is to compare and rank the risk control options on the basis of the principle of ALARP (As Low As Reasonable Practicable). The comparison should account for all those entities that are significantly influenced in the area under concern and ensure that they are equally affected by the proposed

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development of a training package for the establishment of a basic understanding of the FSA process. In addition to the work being carried out on bulk carrier safety, in which FSA studies play an important role. The first two issues have been completed through the publication of the revised Guidelines (MSC Circ. 1023), and IACS has already prepared and commenced the FSA Training Programmes through the Classification societies. The third issue however, remains to be finalized.

new regulation as far as practicable. The scope of this Step is also to provide a feed back to review the information generated in the previous steps so as to reiterate the process if so required for decision making. The long-term prospects of FSA implementation provide for various options for applications. These options, apart from Rule making at IMO also provide for individual Administrations or Shipowners to apply FSA as a management tool in controlling risks as a part of the Safety Management System (SMS). The five-step FSA procedure is a combination of a number of sub-processes which are enumerated in the IACS Training Manual, and are given in Fig. 3.

3.

Since the publication of the IMO ‘Interim Guidelines’, various organizations and authorities have conducted a number of studies. These FSA related studies have endeavoured to substantiate the regulatory initiatives and include the following:

Definition of Goals, Systems, Operations Hazard Identification

Step 1 Scenario definition

Cause and Frequency Analysis

Consequence Analysis

a.

FSA Studies Reported to IMO:

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Formal Safety Assessment of Helicopter Landing Area by DNV & International Council of Cruise Lines (ICCL). Formal Safety Assessment of Helicopter Landing Area by Italy. FSA Illustrative Case Study regarding accidental pollution from crude oil tankers. Bulk Carrier FSA co-ordinated by UK MCA Bulk Carrier FSA conducted by Japan Bulk Carrier FSA conducted by Korea Bulk Carrier FSA conducted by Norway / ICFTU Redundant propulsion study submitted by Germany Joint Nordic Project on Safety Assessment of HSC Operations (Sweden) High Speed Catamaran Ferries FSA submitted by UK Trial application of FSA to the transportation of dangerous goods on passenger / ro-ro cargo vessels (Finland) Research project on risk assessment (Japan) Risk analysis of large passenger ships by the United States

Step 2 Risk Summation

Options to decrease Frequencies

No

No Risk Controlled?

Options to mitigate Consequences

-

Step 3

-

Yes Cost Benefit Assessment

Step 4

Reporting

Step 5

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Fig. 3 Flow Chart of FSA Process

APPLICATIONS

[6]

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In 1999 the International Association of Classification Societies (IACS) submitted a paper to IMO providing guidance on how to incorporate the human element through the application of Human Reliability Analysis (HRA). The proposal by IACS was accepted in principle at the MSC 72 Session in May 2000 and it was decided to annex Guidance on the application of HRA to the Interim Guidelines [7]. The MSC 72 also approved the following work plan on FSA matters: finalization of the Guidelines on application of FSA to the IMO rule-making process; further consideration of the integration of the human element and FSA into the IMO rulemaking process; development of risk evaluation criteria with regard to maritime safety and the protection of the marine environment; and

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b. c.

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IACS studies: Ballast Water Exchange HAZID Bulk Carrier FSA Work Package 5 (watertight integrity of fore end) Tanker Pump-room study Individual Class Societies studies:

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DNV Cost Benefit Analysis of Safety Measures for Existing Bulk Carriers, to support IACS decision to Strengthen bulkheads between Hold 1 & 2. Formal Safety Assessment of Life Saving Appliances by DNV Joint North-West European Research Project on Safety Assessment of Passenger/RoRo Vessels Risk Analysis in connection with Solo Watchkeeping by DNV Concerted Action on FSEA by BV, DNV & GL on behalf of EEIG Unitas Paper on the application of FSA methodology to No.1 cargo hold flooding of Bulk Carriers, by Korean Register Loading and Unloading of Bulk Carriers by Lloyds Register Collaborative FSA Studies by CCS, IRS, KR & NK.

the derived potential loss of life (PLL) for each event are indicated in Fig. 6. The data, when compared to the individual risk of fatality to crew on different ship-types (Fig. 7) and the frequency of fatality per accident type for all ships (Fig. 8), indicated that fatality risk of crew on bulk carriers remained in the ALARP (As_Low_As_Reasonably_Practicable) region. Table 2: Regulations on BC Safety BC

SOLAS

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ISM Code ESP BC Code

LSA IMDG ILLC 1966 MARPOL 73/78 STCW ‘95 S12 S17

Many of these studies have actually resulted in the development / amendment to the Regulations. The IMO, based on the aforementioned FSA studies, decided that SOLAS regulation III/28.2 should only apply to ro-ro passenger ships and not to all Passenger ships above 130 metres as originally stipulated.

S18 IACS URs

The major concerted application of FSA has been on improving the safety of Bulk Carriers(BCs). The MSC 75 & 76 have seen a number of submissions on Bulk Carrier safety and have accepted regulatory changes to SOLAS Chapter XII based on the FSA reports. These Bulk Carrier FSA studies sought to address the existing safety regime of Bulk Carriers given in Table 2. The FSA study coordinated by UK-MCA (UK/INT) has been the most exhaustive and applied the FSA methodology to dry bulk shipping. The types of operations covered the complete dry bulk-shipping activities from loading to discharge terminals through passage at sea, including structural loading, stability & sea motions, ballast water exchange at sea, life saving, main machinery configurations etc. The study was initiated by considering an exhaustive range of accident & incident categories for which the data was available in commercial databases e.g. LMIS (LR-Fairplay); a total operating life of 145,582 vessel years were analysed to collect the historic data on Loss-of-life. (It is interesting to note that in keeping with IMO’s safety objectives, all the BC-FSA studies have only addressed the risk of loss of life, and not the risk to property, where the FSA can be equally applied). The initiating events of recorded incidents leading to any form of loss of life are indicated in Figure 4. The proximate initiating event for fatalities involving bulk carriers are indicated in Figure 5, and

S19 S20 S21 S22 S23 S24

Ch. XII – Safety Measures of BCs Ch. IX – ISM Code Ch. XI – ESP & IMO Res. A 744(18) Ch. II-2, VI & VII Code of Safe Practices for Solid Bulk Cargoes Ch. III , LSA Code Ch. II-2 & VII ILLC’66 & 1988 Protocol MARPOL 73/78 and associated amendments STCW Convention & Protocol Side structure of single skin BCs Longitudinal Strength in flooded condition Scantlings of Transverse WT Bhds considering Hold Flooding Scantlings of Aft Transverse WT Bhd of No. 1 Hold with Flooding Allowable hold loading of BCs Hatch cover scantlings DB Strength for No. 1/ No.2 Holds with flooding Implementation of IACS UR S19 & S22 Detection of water ingress in cargo holds

The availability of the large data meant that there was little opportunity to synthesize an accident scenario, and the risk analysis was carried out based on the data analysis. The UK/International study identified following groups of risk control options (RCOs): a.

b. c.

d.

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Closing devices e.g. hatch covers, pipes, valves etc. these were a combination of structural modifications and enhancements to reduce criticality of human factors; Hull envelop i.e. side structure to ensure integrity of primary & secondary barriers; Ship operations i.e. overall management of the ship including its interfaces with the shore-based stakeholders; and Evacuation of the crew.

In view of the risk being in the ALARP region, the Cost effectiveness of the RCOs was given the s...