On the sidelines of CMA’s Shipping 2018 earlier in March, Ms. Mayte Medina, chief of USCG Office of Merchant Mariner Credentialing, discussed the critical role of integrating new technology within the regulatory approval process. Increasing efficiency and reducing cost, specialized operations, increasing environmental concerns and safety are all drivers in the industry’s advancement towards autonomous shipping, she said. As such, IMO must ensure the future regulatory regime is fair and consistent.
Industry can only operate effectively if the standards are agreed upon, adopted, and consistently implemented on an international basis. Achieving this goal comes with the responsibility to accommodate new technology while ensuring safe, secure, and environmentally sound ship operations.
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Introducing technology into the IMO regulatory framework is nothing new, said Ms. Medina, who is also the chair of the IMO Sub-committee on Human Element, Training and Watchkeeping. Over the decades, IMO has accommodated many industry-driven new technologies, like the move from steam and diesel engines to unmanned engine rooms, e-navigation, and solo-watch-keeping, while it introduced the need for new technologies like BWMS. However:
The difference with past experiences is that the inclusion of autonomous ships into the regulations is going to be more comprehensive, because it will have a dramatic impact on various facets of shipping, including construction, equipment, and operations.
Establishing regulations for the use of autonomous shipping is unique, as it challenges the model upon which all regulations are based: seafarers physically onboard have the responsibility for navigation and operation. For example, when talking about autonomous ships, Medina said the question of technology extends far beyond engine room automation, into the potential use of artificial intelligence to make decisions on operations or management.
Seafarers make decisions based on the information they receive and sometimes these are judgment calls. We must understand how automated systems will interact with other ships, pilots, or shore support.
Furthermore, Ms. Medina said the STCW Convention contains competencies considered essential to the safe operation of ships at sea or in port. The transfer of responsibilities away from the ship may require that the remote operator hold most of those competencies. “How do we ensure the system or artificial intelligence can also meet those competencies?” Medina said, adding that IMO must also consider the question of responsibility and liability.
The current model is for the ship to be manned by seafarers and that the responsibility for the ship lies on the master. Some autonomous ships could change that paradigm. It may no longer be about who the ship’s master is but who is responsible in the event of a spill or marine casualty, which potentially could be a remote operator.
To answer some of the questions related to autonomous shipping challenges, IMO’s MSC will hold a scoping exercise in May 2018 to identify an inventory of gaps and provisions in the current IMO regulatory regime that may preclude or limit the use of ships with varying levels of autonomy. On this, Medina said one of the first tasks of the scoping exercise will be to establish standardized terms to define what constitutes an autonomous ship as well as the varying levels of autonomy that may exist.
The key of this work is going to be defining the terms of reference for how to conduct the review of the instruments, Ms. Medina stressed, adding that the terms of reference should include provisions that:
- May preclude unmanned commercial operation of autonomous ships.
- May be addressed through equivalencies, exemptions, or interpretations as provided by the instrument.
- Do not preclude unmanned operations but that may need to be amended.
Concluding, she said the scoping exercise will be difficult, but that the real challenge will be deciding on what regulatory changes are needed to preserve safety, security, and environmental goals with the operation of autonomous ships.
For IMO to be successful, it will need the full engagement of all stakeholders. IMO can address the technical and some of the legal issues, but it cannot address the business or public policy decisions that ultimately will need to be made.
The Danish Maritime Authority issued in late 2017 a report highlighting regulatory barriers on the implementation of autonomous ships.
