Speaking on behalf of the ICS, what is the shipowners’ perspective on regional vs. international policies? Are regional policies strictly a threat to efficiency and profitability, or are there some cases where they may promote improvements in shipping, e.g. regarding the environment, safety, or technology?
Shipping is one of the great global industries, and it cannot function efficiently if the rules are not truly global. National and regional requirements that differ from the internationally agreed standards cause confusion and increased bureaucracy, and do not promote the raising of standards across the world’s fleet. Ships need to be able to leave one port, make the passage, and arrive in the next port under the same rules.
We understand of course that regional vulnerabilities can be quite specific, and in these cases, nations should approach the IMO to have their particular characteristics addressed in a global framework. A good example of this is the SECA, where regional exposure to sulphur emissions are addressed in an arrangement that forms part of MARPOL Annex VI.
There are many aspects of digitalisation that will require regulations to ensure compliance across the board. What are the issues getting most attention among shipowners right now? Cyber security? Reporting?
Cyber security has been well addressed in industry-wide guidelines, and is a good example of where industry self-regulation is able to keep up with fast-changing developments, where national or international mechanisms simply could not keep up with the growing threat.
ICS is fully supportive of the single-window approach to reporting. Unfortunately the much discussed single window has become ‘multiple windows’, all with differing approaches as states move at different speeds toward digitalisation. The whole idea of the concept was to provide ships with a standard reporting system wherever they were operating in the world, the ideal being an on-board data base from which ports could extract the data required for, say, port entry. However, the variety of systems employed worldwide has actually increased the bureaucratic burden for shipmasters.
In general, is the regulatory focus on the effects of digitalisation appropriate in relation to its actual impact on daily operations?
Digitalisation is a growing fact of life, and some form of regulation is obviously helpful, especially if it leads to global standards. The greatest problem today is the lack of standardisation.
If you are advising your members on which regulations to focus on now and in the near future, which would they be? In the longer term?
Compliance is compliance! We expect all members to promote compliance with regulations as the operative dates approach. Unfortunately, identification of the specific requirements and the applicable dates is not always straightforward. The confusion over compliance options for the Ballast Water Convention, the length of time taken to achieve the ratification criteria, and the problem of understanding which equipment will fulfil both international and US requirements are very serious concerns. ICS has been working since 2004 on trying to get some clarity in this area and has had some success through resolutions that address specific aspects of entry into force, but the focus now has to be on making supportive changes to the Convention as soon as it enters into force.
ICS is also very mindful of the upcoming switch to lower sulphur fuel on 1 January 2020, which on paper requires all ships to switch at the same time to lower sulphur fuel, or to have a scrubber in operation. Clearly some form of transition is required in both cases, and we are not quite there yet in regulatory terms.
Any other perspectives on regulations and policy that you would like to share on behalf of your members? Based on your own observations and experience?
The extended entry into force of the aspirational Ballast Water Convention and the lack of clarity on the sulphur requirement around 1 January 2020 both suggest that the regulatory system needs some enhancement. We would like to see IMO take ownership of a cost-benefit analysis and impact assessment as regulation is being developed. Some people criticise this aspiration as a potential source of delay to implementation. However, we say that time spent at the beginning of the process would be time well spent. It would lead to a much faster transition from adoption to entry into force, as governments would have greater confidence in the enforceability of regulation and much more knowledge of the impact on the global supply chain.