GOAL-BASED STANDARDS – A NEW APPROACH TO THE INTERNATIONAL

REGULATION OF SHIP CONSTRUCTION

H. Hoppe1

Maritime Safety Division, International Maritime Organization

Abstract
The development of goal-based new ship construction standards is a new subject matter of high
importance for IMO which has been included in the Organization’s strategic and long-term work
plans and also in the work programme of its Maritime Safety Committee. This paper briefly
describes the meaning of “goal-based” regulation in general and looks at its application to ship
construction. The on-going work at IMO is presented, results achieved to date are explained and
an outlook is given regarding the work still to be carried out.

Keywords: goal-based standards, prescriptive standards, ship construction, risk-based approach,

functional requirements, quality assurance, verification of compliance, implementation,
regulatory framework, ship classification

1 Goal-based regulation – What does it mean?2

There is an increasing tendency to adopt a goal-based approach to regulation in general and there
are good technical and commercial reasons for believing this approach is preferable to more
prescriptive regulation. “Goal-based regulation” does not specify the means of achieving
compliance but sets goals that allow alternative ways of achieving compliance. For instance,
“People shall be prevented from falling over the edge of a cliff” is goal-based. In prescriptive
regulation the specific means of achieving compliance is mandated, e.g. “You shall install a
1 metre high rail at the edge of the cliff”.

There are acknowledged shortcomings of prescriptive regulation. The parties applying such
regulations are only required to carry out the mandated actions to discharge their legal
responsibilities. If these actions then prove to be insufficient to prevent a subsequent accident, it
is the regulations and those that set them that are seen to be deficient, not the parties applying
them, whose responsibility, in law, it actually is. Prescriptive regulations tend to be a distillation
of past experience and, as such, may become less and less relevant over time and at worst create
unnecessary dangers in industries that are technically innovative. It is the innovator that is best
placed to ensure the safety of their design, not the regulator. Clearly, prescriptive regulations are
unable to cope with a diversity of design solutions. Also, prescriptive regulations encode the best
engineering practice at the time they were written and rapidly become deficient where best
practice is changing, e.g. with evolving technologies.

In fact, it is quite probable that prescriptive regulations eventually prevent industry from adopting
current best practice. It follows that there are clear benefits in adopting a goal-based approach as
it gives greater freedom in developing technical solutions and accommodating different standards.

1
Views expressed in this paper are those of the author and should not be construed as necessarily reflecting the
views of IMO or its Secretariat.
2
Penny, J., Eaton, A., Bishop, P., Bloomfield, R., "The Practicalities of Goal-Based Safety Regulation", Proc. Ninth
Safety-critical Systems Symposium (SSS 01), Bristol, UK, 6-8 Feb, pp. 35-48, New York: Springer, ISBN:
1-85233-411-8, 2001

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Consequently, goal-based standards for new ship construction should form the foundation for the
future advance of international regulatory standards in shipping. They need to be broad, over-
arching goals against which ship safety can be verified at design and construction stages and
during ship operation. They are not intended to set prescriptive requirements or to give specific
solutions. In order to have a level playing field for the whole of the international maritime
industry, the functional requirements of goal-based standards should be sufficient for
classification societies to develop definitive prescriptive standards that can be applied and
implemented consistently on a world-wide basis. At each stage of construction, maintenance and
operation, it should be possible to demonstrate and, more importantly, to verify that the ship
structure and design comply with the goal-based standards. The standards set by IMO need to be
readily and universally understood, unambiguous and capable of being assessed as being
achieved by the prescriptive standards to be set. While it needs to be recognized that the
intention is to set goals for a long time, it should, however, also be accepted that the actual
acceptable limits will change as technology progresses and public/political perception changes.

2 Examples for goal-based standards in IMO’s work

Goal-based standards (GBS) are not a completely new concept in the work of IMO. Over the last
few years, the Organization has started to introduce goal-based standards for certain special
subjects, albeit not in a systematic manner. Examples are the revised SOLAS3 chapter II-2 on
Construction - Fire protection, fire detection and fire extinction, which was completed in 2000,
and the on-going work with regard to large passenger ship safety.

2.1 Revision of SOLAS chapter II-2

SOLAS chapter II-2 on Construction - Fire protection, fire detection and fire extinction was
completely revised in 2000 and the revised chapter entered into force on 1 July 2002. In a
radically new approach to the preparation of amendments to SOLAS, regulation 2 of the revised
chapter (Fire safety objectives and functional requirements) contains sections on fire safety
objectives, functional requirements and achievement of the objectives. Although the chapter II-2
regulations still contain prescriptive requirements, each regulation now has a purpose statement
and functional requirements to assist port and flag States in resolving matters which may not be
fully addressed in the prescription requirements.

The revised chapter II-2 also contains a regulation on Alternative design and arrangements
(regulation 17) which allows deviation from the prescriptive requirements in the chapter by
stipulating:

“2.1 Fire safety design and arrangements may deviate from the prescriptive
requirements set out in parts B, C, D, E or G, provided that the design and arrangements
meet the fire safety objectives and the functional requirements.
2.2 When fire safety design or arrangements deviate from the prescriptive
requirements of this chapter, engineering analysis, evaluation and approval of the
alternative design and arrangements shall be carried out in accordance with this
regulation.”

3
International Convention for the Safety of Life at Sea (SOLAS), 1974, as amended

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This means that, for the first time, administrations are entitled to approve alternative designs and
arrangements not complying with the prescriptive requirements contained in the chapter on
condition that the designs and arrangements in question comply with the fire safety objectives
and functional requirements contained in each regulation.

2.2 Safety of large passenger ships

In May 2000, the entire IMO membership, including the cruise industry, agreed to undertake a
holistic consideration of safety issues pertaining to passenger ships, with particular emphasis on
large cruise ships. To date, the outcome of this effort has resulted in an entirely new regulatory
philosophy for the design, construction and operation of passenger ships that will better address
the future needs of the cruise industry.

In May 2002, IMO’s Maritime Safety Committee (MSC) approved a structure approach for
dealing with passenger ship safety matters, including a guiding philosophy, strategic goals and
objectives. The Committee further agreed that the guiding philosophy should be viewed as a
“vision statement” to provide an idealized view of where it would like to be in the future
regarding the regulatory framework for passenger ships.

With the approval of the guiding philosophy, the MSC, in effect, also agreed to a new way of
viewing the regulatory development process. Traditionally, issues related to fire protection,
marine engineering, naval architecture and other maritime disciplines would, in most
circumstances, be considered in isolation of each other and, after deliberations, prescriptive
regulations would be prepared on a piecemeal basis to address each specific area of safety.
However, the new regulatory approach is holistic in nature and focuses on achieving goals such
as “a ship should be designed for improved survivability so that, in the event of a casualty,
persons can stay safely on board (in a safe haven) as the ship proceeds to port”. The holistic-
based work method implemented by the MSC and the desire to achieve goals in lieu of piecemeal
requirements has required the various subsidiary bodies within IMO to work in concert to
achieve the guiding philosophy and strategic goals mentioned earlier.

3 Goal-based standards for ship construction

3.1 History

The notion of “goal-based ship construction standards” was introduced in IMO at the 89th session
of the Council in November 2002 through a proposal by the Bahamas and Greece4, suggesting
that IMO should play a larger role in determining the standards to which new ships are built,
traditionally the responsibility of classification societies and shipyards.

The paper argued that the Organization should develop initial ship construction standards that
would permit innovation in design but at the same time ensure that ships are constructed in such
a manner that, if properly maintained, they could remain safe for their economic life. The
standards would also have to ensure that all parts of a ship could be easily accessed to permit
proper inspection and ease of maintenance.

Over the next two years the matter was extensively discussed in the MSC, the Council and finally
the IMO Assembly which, at its twenty-third session in 2003, included the item “Goal-based new

4
IMO document C 89/12/1 (Bahamas, Greece) – IMO Strategic Plan

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ship construction standards” in the strategic plan and the long-term work plan of the
Organization.5

3.2 Methodology

From the outset there were different views in the Committee on how to approach the
development of GBS for ship construction.

Some IMO Members advocated the application of a holistic approach which would define a
procedure for the risk-based evaluation of the current safety level of existing mandatory
regulations related to ship safety and consider ways forward to establish future risk acceptance
criteria using FSA.

Other Members supported a more deterministic approach, based on the vast practical experience
gained with oil tankers and bulk carriers over the years and stressed the need for clearly
quantified functional requirements.

The Committee had extensive and wide ranging discussions on this issue, with active
participation by many different Administrations, during which support for both methodologies
was expressed. It was particularly noted that the GBS for new ship construction would not be
limited to bulk carriers and tankers, but were meant to address, at a future date, all ship types and
subsequently the current results would have to be expanded in order to make them applicable to
all ship types.

It was therefore agreed that the use of the risk-based methodology should be further explored
over the next few sessions of the Committee, while, at the same time, proceeding with the
development of GBS using the deterministic approach. But this also means that, if it were
decided to adopt the risk-based approach at some point in the future, a revisit of the goal-based
standards developed under the deterministic methodology would be required to verify
consistency and make changes where necessary.

3.3 Current status

The Maritime Safety Committee commenced detailed technical work on the development of
goal-based ship construction standards at MSC 78, in May 2004, where a comprehensive general
debate of the issues involved took place. The Committee agreed to establish a working group on
GBS at its next meeting (MSC 79 in December 2004), keeping the subject, for the time being,
under the auspices of the MSC, on the understanding that IMO’s Marine Environment Protection
Committee (MEPC) would consider the issue from the environmental protection point of view
and provide its contribution for discussion at the MSC and its working group.

There was general agreement with a five-tier system proposed by the Bahamas, Greece and
IACS6 which is explained in more detail in section 3.4 below.

5
Assembly resolutions A.944(23) - Strategic plan for the Organization (for the six-year period 2004 to 2010) - and
A.943(23) - Long-term work plan of the Organization (up to 2010)
6
IMO document MSC 78/6/2 (Bahamas, Greece, IACS)- Goal-based new ship construction standards

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Discussions in plenary and in the working group continued during MSC 79 and MSC 80,
resulting in principle agreement on the basic principles of IMO goal-based standards as follows7:

“IMO goal-based standards are:

.1 broad, over-arching safety, environmental and/or security standards that ships are
required to meet during their lifecycle;

.2 the required level to be achieved by the requirements applied by class societies

and other recognized organizations, Administrations and IMO;

.3 clear, demonstrable, verifiable, long standing, implementable and achievable,

irrespective of ship design and technology; and

.4 specific enough in order not to be open to differing interpretations.”

It is understood that these basic principles were developed to be applicable to all goal-based
standards developed by IMO and not only goal-based new ship construction standards, in
recognition that, in the future, IMO may develop goal-based standards for other areas, e.g.
machinery, equipment, fire-protection, etc. and that all goal-based standards developed by the
Organization should follow the same basic principles.

3.4 The five-tier system

The Committee agreed in principle on a five-tier system as set out below, following a proposal
by the Bahamas, Greece and IACS at MSC 78. The Committee also agreed that the first three
tiers constitute the goal-based standards to be developed by IMO, whereas Tiers IV and V
contain provisions developed/to be developed by classification societies, other recognized
organizations and industry organizations.

Tier I
Goals
↓
Tier II
Functional requirements
↓
Tier III
Verification of compliance criteria
↓
Tier IV
Technical procedures and guidelines, classification rules and industry standards
↓
Tier V
Codes of practice and safety and quality systems for shipbuilding, ship operation, maintenance,
training, manning, etc.

with the contents of the tiers as follows:

7
Report of MSC 80, MSC 80/24, paragraph 6.38

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• Tier I: Goals

A set of goals to be met in order to build and operate safe and

environmentally friendly ships.

• Tier II: Functional requirements

A set of requirements relevant to the functions of the ship structures to be

complied with in order to meet the above-mentioned goals.

• Tier III: Verification of compliance criteria

Provides the instruments necessary for demonstrating that the detailed

requirements in Tier IV comply with the Tier I goals and Tier II functional
requirements.

• Tier IV: Technical procedures and guidelines, including national and international
standards

The detailed requirements developed by IMO, national Administrations

and/or classification societies and applied by national Administrations
and/or classification societies acting as Recognized Organizations8 to the
design and construction of a ship in order to meet the Tier I goals and Tier
II functional requirements.

• Tier V: Industry standards, codes of practice and safety and quality systems for
shipbuilding, ship operation, maintenance, training, manning, etc.

Industry standards and shipbuilding design and building practices that are
applied during the design and construction of a ship.

3.4.1 Goals (Tier I)

MSC 80 agreed in principle with the following Tier I goals9, applicable to all types of new ships:

“Ships are to be designed and constructed for a specified design life to be safe and
environmentally friendly, when properly operated and maintained under the specified
operating and environmental conditions, in intact and specified damage conditions,
throughout their life.

.1 Safe and environmentally friendly means the ship shall have adequate strength,
integrity and stability to minimize the risk of loss of the ship or pollution to the
marine environment due to structural failure, including collapse, resulting in
flooding or loss of watertight integrity.

.2 Environmentally friendly also includes the ship being constructed of materials for
environmentally acceptable dismantling and recycling.

8
Organizations authorized to act on behalf of Administrations in accordance with SOLAS regulations I/6 and XI/1.
9
Report of MSC 80, MSC 80/24, paragraph 6.39

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.3 Safety also includes the ship’s structure being arranged to provide for safe access,
escape, inspection and proper maintenance.

.4 Specified operating and environmental conditions are defined by the operating

area for the ship throughout its life and cover the conditions, including
intermediate conditions, arising from cargo and ballast operations in port,
waterways and at sea.

.5 Specified design life is the nominal period that the ship is assumed to be exposed
to operating and/or environmental conditions and/or the corrosive environment
and is used for selecting appropriate ship design parameters. However, the ship’s
actual service life may be longer or shorter depending on the actual operating
conditions and maintenance of the ship throughout its life cycle.”

3.4.2 Functional requirements (Tier II)

MSC 80 noted the following Tier II functional requirements, applicable to new oil tankers and
bulk carriers 10 in unrestricted navigation 11 , as prepared by its GBS working group 12 . The
functional requirements have been structured to form three groups: design, construction and in-
service considerations. They are preliminary at this point in time and will be subject to further
consideration at future meetings of the MSC.

DESIGN

II.1 Design life

The specified design life is not to be less than 25 years.

II.2 Environmental conditions

Ships should be designed in accordance with North Atlantic environmental conditions and
relevant long-term sea state scatter diagrams.

II.3 Structural strength

Ships should be designed with suitable safety margins:

.1 to withstand, at net scantlings 13 , in the intact condition, the environmental

conditions anticipated for the ship’s design life and the loading conditions
appropriate for them, which should include full homogeneous and alternate loads,

10
The GBS working group at MSC 80 confirmed agreement that Tier II, when completed, would apply to all types of
new ships but also agreed that, for the time being, it would consider bulk carriers and tankers as a means of
focussing the discussion.
11
Unrestricted navigation means that the ship is not subject to any geographical restrictions (i.e. any oceans, any
seasons) except as limited by the ship’s capability for operation in ice.
12
For more detailed information refer to IMO document MSC 80/WP.8 – Report of the MSC working group on
goal-based new ship construction standards.
13
The net scantlings should provide the structural strength required to sustain the design loads, assuming the
structure in intact condition and excluding any addition for corrosion.

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partial loads, multi-port and ballast voyage, and ballast management condition
loads and occasional overruns/overloads during loading/unloading operations, as
applicable to the class designation; and

.2 appropriate for all design parameters whose calculation involves a degree of

uncertainty, including loads, structural modelling, fatigue, corrosion, material
imperfections, construction workmanship errors, buckling and residual strength.

The structural strength should be assessed against excess deformation and failure modes,
including but not limited to buckling, yielding and fatigue. Ultimate strength calculations should
include ultimate hull girder capacity and ultimate strength of plates and stiffeners. The ship’s
structural members should be of a design that is compatible with the purpose of the space and
ensures a degree of structural continuity. The structural members of ships should be designed to
facilitate load/discharge for all contemplated cargoes to avoid damage by loading/discharging
equipment which may compromise the safety of the structure.

II.4 Fatigue life

The design fatigue life should not be less than the ship’s design life and should be based on the
environmental conditions in II.2.

II.5 Residual strength

Ships should be designed to have sufficient strength to withstand the wave and internal loads in
specified damaged conditions such as collision, grounding or flooding. Residual strength
calculations should take into account the ultimate reserve capacity of the hull girder, including
permanent deformation and post-buckling behaviour. Actual foreseeable scenarios should be
investigated in this regard as far as is reasonably practicable.

II.6 Protection against corrosion

Measures to protect against corrosion are to be applied to ensure that net scantlings required to
meet structural strength provisions are maintained throughout the specified design life.
Additional measures include, but are not limited to, coatings, cathodic protection, impressed
current systems, etc.

II.6.1 Coating life

Coatings should be applied and maintained in accordance with manufacturers’ specifications

concerning surface preparation, coating selection, application and maintenance. Where coating is
required to be applied, the design coating life is to be specified. The actual coating life may be
longer or shorter than the design coating life, depending on the actual conditions and
maintenance of the ship. Coatings should be selected as a function of the intended use of the
compartment, materials and application of other corrosion prevention systems, e.g. cathodic
protection or other alternatives.

II.6.2 Corrosion addition

The corrosion addition should be added to the net scantling and should be adequate for the
specified design life. The corrosion addition should be determined on the basis of exposure to
corrosive agents such as water, cargo or corrosive atmosphere, and whether the structure is
protected by corrosion prevention systems, e.g. coating, cathodic protection or by alternative

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means. The design corrosion rates (mm/year) should be evaluated in accordance with statistical
information established from service experience and/or accelerated model tests. The actual
corrosion rate may be greater or smaller than the design corrosion rate, depending on the actual
conditions and maintenance of the ship.

II.7 Structural redundancy

Ships should be of redundant design and construction so that localized damage of any one
structural member will not lead to immediate consequential failure of other structural elements
leading to loss of structural and watertight integrity of the ship.

II.8 Watertight and weathertight integrity

Ships should be designed to have adequate watertight and weathertight integrity for the intended
service of the ship and adequate strength and redundancy of the associated securing devices of
hull openings.

II.9 Design transparency

Ships should be designed under a reliable, controlled and transparent process made accessible to
the extent necessary to confirm the safety of the new as-built ship, with due consideration to
intellectual property rights. Readily available documentation should include the main goal-based
parameters and all relevant design parameters that may limit the operation of the ship.

CONSTRUCTION

II.10 Construction quality procedures

Ships should be built in accordance with controlled and transparent quality production standards
with due regard to intellectual property rights. The ship construction quality procedures should
include, but not be limited to, specifications for material, manufacturing, alignment, assembling,
joining and welding procedures, surface preparation and coating.

II.11 Survey

A survey plan should be developed for the construction phase of the ship, taking into account the
type and design. The survey plan should contain a set of requirements to ensure compliance of
construction with classification rules and goal-based standards. The survey plan should also
identify areas that need special attention during surveys throughout the ship’s life.

IN-SERVICE CONSIDERATIONS

II.12 Maintenance

Ships should be designed and constructed to facilitate ease of maintenance, in particular avoiding
the creation of spaces too confined to allow for adequate maintenance activities.

II.13 Structural accessibility

The ship should be designed, constructed and equipped to provide adequate means of access to
all internal structures to facilitate overall and close-up inspections and thickness measurements.

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3.4.3 Verification of compliance (Tier III)

Although there is general agreement among the IMO membership that a credible, transparent and
auditable verification system is necessary, so far the issue of how exactly to verify compliance
with the functional requirements has not been discussed in any detail and is one of the tasks of
the Committee and its working group for the future. Preliminary views by IMO Member States
differ widely.

The GBS working group at MSC 79 had a brief and preliminary discussion on Tier III14 and
noted that, in general, verification should consist of the following four steps:

.1 verification that prescriptive rules by classification societies are in accordance

with the goal-based standards;

.2 verification that the design of individual ships meets classification societies’ rules;

.3 verification that the construction of ships meets classification societies’ rules; and

.4 verification that the ship throughout its life meets applicable rules.

Of these four steps, the new item is the verification that classification societies’ rules meet the
goal-based standards. However, it was also pointed out that, in developing Tier III, it would be
necessary to look closely at “who” would be required to show that Tiers I and II have been met.
Tier II, for instance, includes functional requirements on quality of construction and transparency
of design (see section 3.3.2 above) which relate to shipyards and designers, two entities that IMO
has not previously included in the regulatory scheme.

Further, likewise preliminary, discussions in the working group at MSC 80 clarified that the
general purpose of Tier III is the verification that the detailed requirements in Tiers IV and V
meet the Tier II functional requirements, i.e. “rules for rules” – it is not the purpose to verify that
the ship meets the detailed requirements. For goal-based standards for new ship construction,
Tier III will have the purpose of verifying that the detailed requirements of the classification
societies meet the Tier II functional requirements. As such, Tier III should provide a process for
classification societies to follow when providing information to the verification authority (still to
be determined) in order to establish that their detailed rules meet the functional requirements.

In order to progress the work on this issue, MSC 80 established a correspondence group and
instructed it to develop draft Tier III criteria for the verification of compliance for the
consideration of the Committee at MSC 81 in May 2006.

4 Future work

Although first steps, e.g. principal agreement on basic principles and goals, have been covered, it
is clear to everyone involved in the work that there is still a long way to go in order to arrive at
agreed goal-based standards for new ship construction.

The matter of risk-based and/or deterministic approach has not been brought to a satisfactory
conclusion. The issue of verification of compliance has so far only been discussed preliminarily.

14
IMO document MSC 80/6 - Report of the Working Group on Goal-Based Standards at MSC 79

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Likewise, the question of how the GBS could be incorporated into the existing regulatory
framework has only been touched upon and initial views expressed varied widely.

MSC 80 agreed on a plan for the future work on goal-based standards15, which will be regularly
reviewed and updated, as follows:

• consideration of the probabilistic risk-based methodology in the framework of GBS;

• completion of Tier II functional requirements;
• development of Tier III verification of compliance criteria;
• implementation of GBS;
• incorporation of GBS into IMO instruments;
• development of a ship construction file and consideration of the need for the development
of a ship inspection and maintenance file; and
• consideration of the need to review consistency and adequacy of scope across the tiers.

The development of goal-based standards is currently focussed on ship construction, however, in

the long term, it should also cover all other aspects relevant to new buildings, including safety,
environmental protection and quality assurance. Structural safety cannot be looked at in isolation
but should form part of an overall framework.

Acknowledgements

My sincere thanks go to Jeffrey Lantz of the United States Coast Guard, Chairman of IMO’s
working group on goal-based new ship construction standards, for his factual contribution, and to
my colleague Marie-Helene Williams for her editorial contribution.

________

15
See annex 4 of IMO document MSC 80/WP.8 – Report of the MSC working group on goal-based new ship
construction standards

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