Facebook for Ships Proposed to IMO

IMO has published the results of its first-ever public consultation on the administrative burdens imposed by its mandatory instruments, and one of the suggestions was to create a Facebook for ships.

The suggestion was made as a way of providing ships’ certificates to be accessed electronically by accredited authorities, and it came with the question: why do inspectors spend more time pouring over certificates than physically looking over the ship?

As part of the consultation, IMO made a webpage available for six months in 2013 to gather the opinions of industry stakeholders. About 60 percent of the responses came from ship masters, officers and crew. 

Comments were invited on 563 of the administrative requirements associated with regulations such as SOLAS, MARPOL and STCW.

The study found that 351 out of the 563, some 66 percent, were not perceived as being burdensome on their own by any respondents. One respondent even said IMO requirements were minimal compared to the voluminous paperwork imposed by charterers, ship management companies, P&I Clubs and port agencies.

However, the combined volume of IMO requirements caused ship crews to spend considerable time on paperwork rather than operating the ship, and this may compromise safety. IMO notes that it could be indicative of a litigious culture where there is the tendency to “smother everything with paper”.

The results noted that for inspectors, much of their time is spent checking conformity through checklists and reports, making their actions “control of control”. This results in a tendency to evaluate the quality of the oversight system rather than the quality of the ship and crew.

Of the 182 administrative requirements where at least one person thought were burdensome the study did identify problems with excessive paperwork, and some respondents suggested urgent change was needed. 

Key amongst the conclusions of the study was the need for greater use of electronic record-keeping and a need to recognize electronic certificates.

“The report is excellent and well overdue, says Arthur Bowring, Managing Director of the Hong Kong Shipowners Association. “But we do need to realise, as pointed out in the report, that most of the administrative burden does not come from the IMO’s work. Yes, there is much that the IMO can do to reduce the burden, and it is good that they recognise the work that will have to be done, but the industry as a whole has to do much more to reduce the burden. Electronic record keeping is all very well and good, but unless we use electronic process to reduce the number of forms and repetition (this is not just record keeping as such) then the burden will not be reduced.”

David Tongue, Secretary General of Intercargo and member of the steering group for reducing administrative requirements that worked on the study, highlights that the consultation process only covered mandatory instruments while the majority of shipowners have got to comply with the non-mandatory instruments as a result of ISM or flag state requirements. He believes these should be evaluated further in the future. 

As the IMO council has accepted the report, the move to electronic record keeping both on ships and at IMO will be advanced. “That is a positive outcome,” says Tongue. “There is a move within the committees such as MSC and MEPC, and now it is up to them to take it forward.” 

However, it is difficult to enact a new regulation without some administrative burden, and some port state control organizations may need regulatory changes before they can accept some electronic documents, he says.

The steering group has made 13 recommendations as a result of their analysis of the public consultation:

1. Use electronic means for reporting
2. Establish IMO web-based information portal
3. Recognize electronic certificates
4. Accept electronic record-keeping
5. Recognize electronic documents (other than certificates)
6. Avoid multiple reporting
7. Accept other electronic solutions
8. Improve maritime security awareness
9. Avoid accumulation of administrative requirements
10. Avoid burdens from non-mandatory instruments
11. Adopt IMO resolution on efficient regulation
12. Monitor and review existing regulations
13. Increase efforts to avoid future administrative burdens