As drone technology has recently seen an increased popularity in maritime surveillance, Ben Burkard, Underwriting Director, and Julian Hines, Loss Prevention Manager at the Standard P&I Club, consider the risks, rewards, as well as the potential regulatory issues surrounding the use of drones in shipping.
What are the potential uses in shipping?
Companies are currently experimenting with drone delivery services for ships at anchorage, for items such as spare parts, mail, stores, documentation and medical equipment. Drones launched from onshore are capable of delivering to ships up to two miles away and it is estimated that the use of drones could reduce the cost of these services by a factor of ten.
Currently, the biggest single use of drones in shipping is for inspection purposes and some class societies are already using drones as part of their survey programme. This allows for a much more comprehensive survey given the ease with which drones can access hard-to-reach areas as well as reduce risks. Examples include:
- inspection of flare stack, tops of cranes and confined spaces. If repair work is necessary, the drone’s findings can be used in writing job specifications and access requirements
- remote inspection of the hull exterior or interior of tanks and other areas where surveyors cannot get to during typical on/off-hire condition surveys or routine inspections
- inspection during repair, conversion and newbuilding of ships or prior to handover
- damage surveys (aerial/tank) after an incident
- inspection prior to reactivation of ships
- inspections of moorings and anchorages
- inspection of tow arrangement from tow lines through to the unmanned towed object
- aerial videography for ship launch, delivery, mobilisation, demobilisation, loading of project cargo
- port authorities testing ships’ emissions as they enter port
- search and rescue.
Legal and regulatory issues
It is likely that Flag states will continue to drive the legal side. In the UK, for example, if a drone is to be operated for commercial purposes, it must follow UK CAA guidelines. Under these guidelines, drone operators must first be approved and have appropriate insurance in place prior to submitting an application. The USA and countries in Europe and South-East Asia follow similar regulations. It is probable that most countries and classification societies will require drone pilots to have completed some form of BVLOS certification (Beyond Visual Line of Sight) for the flying of drones outside the line of sight.
Currently, the only industry standard is for operations in the UK offshore sector: Unmanned Aircraft Systems (UAS) Operations Management Standards and Guidelines – Issue 1 2017.
Loss prevention advice
A prudent owner considering the operation of drones onboard their vessel should:
- gain clarification of regulatory approval (Class) to use the drone
- ensure pilots have BVLOS certification and type-approved training for the use of drones
- where necessary, have a valid Activity Permit from the relevant civil aviation authority for every flight
- complete a detailed risk assessment for the use of the drone
- have appropriate operating procedures in place, including a permit to work.
Are liabilities arising from drones operated onboard ships covered by P&I? Whether the use of drones is, or should be, excluded by the pool has been considered by the International Group, and whilst it is acknowledged that it is an area that should be subject to ongoing debate, the position currently remains that liabilities arising from the operation of a drone is not included within the list of excluded losses set out in the Pooling Agreement.
However, in order to meet the requirements for pooling, the other provisions in the rules and the pooling agreement must be complied with. These will include the fact that the use of drones must be able to be considered to be part of the management and operation of the entered ship, and any contractual arrangements must meet the requirements of the general contracting principles set out in the pooling agreement. In relation to services being provided by the ship, we would require either a knock for knock allocation or that the member does not assume responsibility for liabilities that they would not otherwise have had at law. Any services to the entered ship should be considered under the principles of best endeavours.
In the case of uncertainty of whether these principles have been met or if an extension is required, please get in touch with your usual club contact.
Above article was initially published at the September edition of Standard P&I Club’s Technology Bulletin and is reproduced here with the authors’ kind permission.
The views expressed in this article are solely those of the authors and do not necessarily represent those of SAFETY4SEA and are for information sharing and discussion purposes only.
About Ben Burkard
Ben Burkard joined Charles Taylor on 14 March 2016 as an Underwriter within Europe Division. He has worked for 4.5 years as a Syndicate Executive in Steamship Insurance Management Services assisting with the underwriting of the European membership and, latterly, those in the Middle East and India. He has also completed Modules 1 and 2 of the IGP&I Qualification.
About Julian Hines
Julian Hines, Loss Prevention Manager at Standard P&I Club, graduated from Plymouth University in 1993 (Marine Technology). He is an independent marine consultant, including ISM/ISPS audits, Marine Commercial, Vetting & Technical Management; FMEA surveys; Marine warranty surveyor. He joined the Standard Club in 2005 as a marine surveyor dealing with blue water tonnage. He is specialised in offshore energy support ships and units providing loss prevention assistance for offshore division members.