Environmental regulatory changes triggers administrative burden for crew

Too many regulations can carry implications for crew and vessel safety. Credit: Joachim Affeldt
Too many regulations can carry implications for crew and vessel safety. Credit: Joachim Affeldt

High levels of administrative burden are nothing new for shipping. It has long been afloat on a rising sea of paperwork. Every ship sailing in and out of ports across the globe generates a colossal information trail, most of which is created not digitally, but rather manually, on paper documents that are handed over to the authorities.

This paper-based bureaucracy is an administration-heavy way of working, which is the norm for seafarers manning the global shipping fleet. Of course, the majority of individual administrative functions are justified.

However, their combined volume and repetitive nature often forces crews to spend considerable time performing bureaucratic tasks rather than manning and operating the ship, and this could impede safe navigation. Poor paperwork management can also add significant stress to the captain and crew, again raising the risk of accidents.

There is also the commercial aspect to consider. Even slight administrative negligence in complying with reporting requirements may block port access and result in harsh consequences such as reduced earnings, higher costs, and damaged reputations.

Now the industry faces a new hurdle with the rapid rollout of regulation aimed at reducing the environmental impact of shipping operations. In the past few years, shipping has seen the continued implementation of emission control areas, the Ballast Water Management Convention, which came into force on 8 September 2017, the International Maritime Organization’s (IMO’s) mandatory fuel consumption data reporting rules, which came into force on 1 March 2018, and European Union monitoring, reporting, and verification regulations, which became fully effective on 1 January 2018. Also to come is the IMO’s sulphur cap in 2020 and the various regional environmental dictates that ship operators must meet.

Monitoring and reporting requirements accompanying these dicta stand to increase the administrative burden on crews. For many, it’s not hard to see this as an incoming administrative tsunami.

Drowning in paperwork

However, some shipowners say it is not the regulations themselves that pose the threat. Ardmore Shipping argues that regulations do not create administrative burden if they are integrated with what is already being reported and collected and if crews are trained correctly.

Ardmore’s chief operating officer and executive vice-president, Mark Cameron, told IHS Markit sister title Safety at Sea (SAS) that administration duties associated with environmental rules had been established with good intent and contrasted them with some “more painful” administration work required by other functions, such as port clearance, that require a lot of documentation and the completion of great volumes of paperwork by hand.

Cameron believes that, for the crew, there must be an adequate balance between documentation and ‘proper’ job function. “We all accept that administration elements are part of everyone’s core function, but it’s when those percentages start to increase to unrealistic amounts that they start to affect the quality of the job that is being performed,” he said.

Georgina Alderman, Ardmore’s marine and insurance manager, told SAS that environmental regulation paperwork was not the problem, but that there were “purely bureaucratic paper reporting exercises that are much more of a burden and are of no benefit to anyone”.

Shoreside support

Highly skilled staff members often spend huge amounts of time filling in the same paperwork with the same data each time they enter a new port and this constant administrative headache, Cameron said, can keep crew from “highly valuable work”.

Therefore, Ardmore has built infrastructure around administration, and it believes shoreside support with environmental regulation compliance is essential. “It’s all about load sharing,” said Abhijit Ghosh, a senior marine superintendent at Ardmore.

In the Ardmore tanker fleet, each ship has a designated environmental officer on board. This crew member has been specially trained and works in conjunction with an environmental management representative on shore who monitors compliance with environmental procedures across the entire fleet. This practice is relatively commonplace for companies operating under the ISO 140001 environmental management standard.

As new administrative requirements materialise, staff must be adequately trained to ensure that reporting is conducted correctly and compliance can be demonstrated. Ardmore ardently advocates for continued crew training as a function for reducing administrative burden. “Ardmore’s approach is an integrated one whereby the more bureaucratic elements of ship operation are part of the curriculum,” Cameron said.

The company has adopted computer-based training for its crews. This is specific to different areas of environmental regulations. Seafarers undertake this training on board the Ardmore fleet on a weekly or monthly schedule.

Training of crew, both on board and on shore, is conducted by Ardmore’s ship management company, Thome Ship Management, at its training institutes.

Claes Eek Thorstensen, president and chief commercial officer of Thome Ship Management, told SAS, “Undoubtedly, environmental protection is an area that is experiencing a lot of regulatory changes. Consequently, there is an ever-growing addition in compliance requirements that necessitates high crew engagement.”

To engage seafarers with the changes, Thome employs a multipronged approach. Depending on the nature of the equipment upgrades, training is delivered in a variety of ways: on board; computer-based modules; in-house programmes, and using facilities offered by manufacturers or other third parties. For Thome, the intention is to achieve smooth and seamless integration of any new environmental requirements with the existing processes and procedures as far as possible. The aim is “to not put any further administrative burden on the crew”, Thorstensen said.

Technology throws a liferaft

Technology can potentially ease the burden of all the additional documentation that usually follows regulatory procedure. Although this paperphile industry may not switch to digital reporting any time soon, hardware and software combinations for collecting and monitoring data on board can pick up some of the slack.

For example, ships equipped with direct CO2 emissions measurement equipment can use it to measure fuel consumption if needed for reporting fuel or CO2 usage, as opposed to creating a paper trail of bunker delivery notes and manual entry reporting methods.

These systems enable the use of digital content for easier information management, the ability to reuse available data, and the pre-filling of many necessary forms. They also allow for automated data processing and trending, enhancing the vessel’s operating economy.

The industry’s tendency to smother everything in paper and cumbersome administration is being addressed by regulators at an international and regional level. However, if shipowners are smart in their approach to complying with environmental regulatory requirements, ship crews need not fear a sudden tsunami of paperwork.

Contact Catherine Austin