16th, November, 2004

The Shipbuilders' Association of Japan (SAJ) here expresses great anxiety about IACS's CSR under development.

The followings were also stated at the Shipbuilders - Owners - Classification Societies tripartite meeting YOKOHAMA held on 7-9 November 2004.

There is a considerable gap between draft CSR and the present rule system while the detailed contents are still not transparent because of a little technical background released. Besides IACS's information on the ramification studies of existing ships under draft CSR is quite insufficient.

Under such circumstances, SAJ had started original verification of the 1st draft CSR and gave a technical presentation focusing on a VLCC design at the subject meeting.

The SAJ pointed out that the gross scantlings of a lot of structural members complying with present rules were found to be drastically less than so-called net scantlings required by JTP, which are to be maintained as minimum throughout the ship's lifetime. This leads to the specious logic that even newbuildings under construction should be regarded as substandard tankers according to the new safety criteria given by JTP. The major causes for these unrealistic results can be attributed to the CSR approach with too much reliance on theory and insufficient calibration based on the valuable feedback from actual ships in service. Upon a proposal for the revision of scantling rules, common practice is that the degree of the necessary improvement in the safety level should be quantified above all. On the contrary, JTP has rarely unveiled the actual damage data and/or acceptable reasoning of newly specified safety target under the general cause of "Robust". The expected increase in the steel weight of a VLCC is about 8-9 % (3,000 tons within cargo tank region and 300 tons in forward and aft regions respectively to meet the 1st draft CSR), however, it is hard to justify that the new requirements are reasonable and practicable from technical point of view.

The Korea Shipbuilders' Association also presented their ramification study of JTP-CSR. The resultant increase in steel weight of a VLCC is about 2,900 tons within cargo tank region, which is in good agreement with the SAJ's expectation. It is to be noted that the amount of expected steel weight increase is almost fixed whether the original design is on a mild steel rich basis or higher tensile steel rich basis.

The SAJ expressed serious concern with extremely stiff and inflexible framework of CSR, too. One of the easiest approaches shown in JTP's draft CSR to exclude minority poor design and construction quality can bring the harmful opposite effect on the progress and innovation in the shipbuilding and shipping industries for improved safety and economy. In this context, the Japanese Shipowners' Association stands firm for the SAJ's view.

According to IACS, there have been more than 3,000 review comments upon the 1st draft CSR from various organization/persons, to which honest replies have been left unfinished. Nevertheless IACS stated that the harmonization of CSRs between JTP and JBP will be given up halfway and the revised draft CSRs will be brought up after 1st July 2005 separately and consequently those CSRs will come into effect on 1st January 2006. JTP also announced that they had already started to reconsider their 1st draft CSR internally by adjusting the fundamental conditions for strength analyses, etc. which can result in the discount of increased steel weight. SAJ is dissatisfied with above-mentioned hasty movements without following the transparent procedure. In the first place as stated by IACS chairman on 17 May 2004, the first priority should be given to the harmonization for the technical consistency among IACS. Moreover, the discussion on Goal-based Standards (GBS) has just started at IMO for general consensus. The adoption of premature CSR prior to the establishment of GBS could result in immediate and repeated revisions and push the shipbuilding and shipping industries into fruitless confusion. The industries strongly requested IACS of reconsideration of their approach, procedure and schedule.