“If you don’t comply, you don’t work.”
Lehtovaara represents ABB Marine & Ports in an array of trade associations and classification society working groups, perhaps most notably IACS, the International Association of Classification Societies, which serves as the principle technical advisor to IMO, the International Maritime Organisation of the United Nations.
“We are trying to lead the discussion and promote action to advance shipping on all fronts,” he says. “The underlying idea with ABB’s participation is that technical and digital development is moving so fast that it is having major implications for safe operations. This requires regulations to evolve quickly, but that won’t happen without cooperation from equipment manufacturers.”
Non-compliance with IMO regulations means you don’t operate in flag state nations.
If original equipment manufacturers (OEMs) are not involved, Lehtovaara says, “We risk a situation where we have good and safe technology, better than what’s out there, but we can’t implement it because regulations do not accommodate it.” That is why he believes that OEMs and classification societies need to cooperate earlier in the development process, to allow class to learn about capabilities and improvements as they emerge, and be ready to respond when the technology is ready for use.
The policy pyramid
Taking a look at the institutions entrusted with the task of regulating the shipping industry, Eero Lehtovaara starts at the top:
“The IMO was established under the United Nations Geneva Convention of 1948 to ensure the safety and security of international shipping. Today there are 172 flag state members,” he explains. Unless flag states stipulate otherwise, ships operating between these countries must be flagged, and all ships trafficking state ports are subject to Port State Control to assure compliance with international regulations. “Non-compliance with IMO regulations means you don’t operate in flag state nations,” Lehtovarra says.
He describes the relationship between IMO and the classification societies as fairly straightforward: “IMO determines the code, and IACS looks at the consequences of that code and sends a unified interpretation to its members. IACS also recommends actions or responses to member societies. Basically, IMO says what and why, and the class societies figure out how.”
Digging down to the roots of regulation, Lehtovaara relates that the IMO’s SOLAS Convention, Safety of Life at Sea, was established to ensure safe operations at sea. Compliance with the tenets of SOLAS is at the core of all maritime regulation designed to protect life and assets in maritime operations. “If a technology or a product is as good or safer than an existing one, it should be accepted. On the other hand, we also want to hinder features or developments that would weaken safety.”
The current challenge, he says, lies in closing the gap between the possibilities blossoming in the bright light of the 4th industrial revolution, and the abilities of the regulatory system to respond to the accelerating pace of technology.
Proceed with caution
As automation and remote operations lead the industry ever closer to the Holy Grail of shipping – autonomous vessels – Lehtovaara cautions that the prize may be best admired from a safe distance:
“Automation can reduce the burden of monotonous operations. An unmanned engine room is feasible, with escalating levels of alarms and responses,” he reflects. “But what about an unmanned bridge? If we could do the same there, is it necessary to have someone sitting on the bridge at all times?”
Continuing on the path laid out by technology, Lehtovaara inevitably arrives at the fork in the road defined by humanity: the issue of responsibility.
Automation can reduce the burden of monotonous operations.
“If we connect surveillance information to a computer, the degrees of warning can be escalated, and theoretically, the ship can eventually make decision on its own. But when the ship makes a decision, who is responsible? Today the captain delegates navigation to the officer of the watch. What if it is delegated to a computer?”
Under SOLAS and other regulations, the captain has the ultimate responsibility on a vessel, and he or she needs to be informed of all decisions made on board. “Either they give the order, or they confirm someone else’s orders. Anything that alters that system needs to be addressed,” Lehtovaara states.
Closing the loop of decision-making when a machine is doing the thinking is a new challenge for shipping: “This is only one of many issues that have to be acknowledged and resolved before we can transfer decision-making to machines.”
New technology enables remote real time inspection, and that will change business models on both sides.
Fit for fight
“A class society evaluates equipment for fitness for purpose, and nearly everything we sell needs to be classified,” Lehtovaara says. “But the rules have to allow for growth in the business arena. New products need to be discussed and regulations adjusted. With digitalisation widening in scope and accelerating development, we need a broader framework of evaluation.”
Lehtovara elaborates on a scenario likely to emerge from digital evolution: “Currently, surveys are performed on a stationary ship. You can measure plate thickness, rust, and cracks, but that information tells you nothing about what happens when the ship is sailing. New technology enables remote real time inspection, and that will change business models on both sides. Robotic inspection and remote surveillance, focusing not so much on what, but how things are done, will impact business models.”
Many OEMs are already rising to the challenge, with remote services representing an increasingly larger part of their revenue. Will regulators be obliged to address these evolving offerings? “Service should be regulated, but the definition of service is still open to interpretation. Just looking at something and offering advice does not require regulation, but making a decision or taking an action does.”
Does he believe that the current regime is able to handle the current pace and sheer volume of technological development? “Not all data has equal value. We need to narrow down and classify that technology which has a bigger effect. Business models also have to be adapted to a new reality, and that applies to owners, OEMs, and regulators.”
The big question
Eero Lehtovaara cuts to the rhetorical chase: “How much of what can be done by technology, do we accept should be done by technology?”
Answering that key question demands a process, he maintains, always with accountability as the bottom line: “At the end of the day we need to be able to verify fitness of purpose. Automatic or semi-automatic systems need to be tested in real life for extended periods of time. You cannot just snap your fingers and implement everything that is possible.”
For those expecting the tempo of change to match the pace of technology, Lehtovarra has this steadying advice: “The speed of the discussion is by far the fastest right now. Then comes development, and after that regulation.” And it is here he believes that the force of policy will make itself felt: “We need to test and verify before we implement. The speed of these processes will regulate the pace of change.”
