Norwegian shipowner achieved compliance by leveraging class society’s dedicated tools and services, writes Dan Oldford, Principal Engineer, ABS.
When the IMO Polar Code was adopted in 2017, it was a new type of regulation. Designed around goal-based standards, where a high-level target is set and functional requirements are given to achieve the goals, then semi-prescriptive regulations to meet the functional requirements.
In general terms, the functional requirements of the Polar Code are applicable where a specific hazard is applicable to the intended vessel operation. This means that compliance with a goal-based standard is based on thresholds for rule application. Recognizing these thresholds can be a significant challenge for a shipowner or operator.
Among the misconceptions about the Polar Code is that it will necessarily require major modification of the vessels concerned.
Obtaining certification does not require the vessel to be certified as ice class; rather it is a process of developing procedures in the company and onboard the vessel that demonstrate an understanding of the hazards and their mitigations. Critical to obtaining certification is that shipowners correctly identify and address risks and provide required information in the correct format to the inspecting authority.
In order to help industry with these requirements, the ABS Harsh Environment Technology Centre (HETC) has developed a suite of unique tools and services to calculate the data required for an accurate assessment and present it in a user-friendly way.
Based at Memorial University in St. John’s, NL. Canada, HETC has unrivalled experience with the Polar Code. HETC engineers took part during the development of the code, chaired the IACS Expert Group Polar Code and assisted various flag administrations around the world to implement the code into their regulations.
Tools and services
To support clients in the compliance process, ABS provides dedicated solutions to help them understand and mitigate the risks. The ABS Polar Suite is an in-house software tool that inspects datasets such as seasonal sea ice and provides output in the form of easy to interpret charts of predicted ice conditions at the times and locations of the intended vessel operation.
The derived data can be used to support decisions for voyage planning in accordance with Polar Code Part I-A/11.3.4. The Polar Suite can also serve to fulfil the requirement for owners and operators to examine statistical sea ice and temperature data in former years by processing multiple year data for output.
A key aspect of Polar Code compliance is the Operational Assessment (OA). This is a process where the regulations are examined, operational hazards are identified and risk assessments for each are conducted, Risk Control Measures (RCMs) are decided and operational limitations defined.
The outcomes of the OA feed directly into the Polar Water Operational Manual (PWOM) making it critical that the OA is an effective and representative process. The relevant hazards must be considered together with their control measures, all in the context of the code’s regulations. The HETC nominates a polar Subject Matter Expert (SME) to facilitate the OA, walking the owner or operator through a series of formal risk assessments.
These assessments address the hazards noted in the code plus any additional issues identified by the group. If any of the risks are identified as being outside the company’s risk acceptance level, RCMs are developed to address the specific risks. A thorough examination of the regulations and the ship’s systems and equipment is conducted to ensure all risks are addressed.
An OA report is then produced that serves as a companion document to the PWOM during the review process and also serves as the basis for any future or further Polar Operational Assessments.
In preparing for the OA, it is possible for owners to over or under compensate for perceived risks, usually based on the level of understanding of that hazard. During the OA process, the ABS polar SME will provide guidance to identify realistic, practical, cost effective and functional control measures.
Practical owner assistance
Based in Hafrsfjord, Norway, Tananger Offshore has a long history of safe offshore operations including seismic support in polar waters. Among its fleet is the ABS-classed Guard Celena, a 2008-built OSV which engages worldwide operations.
With the Polar Code in force, Tananger Offshore and ABS worked together through the process which ultimately led to Guard Celena being issued a Polar Ship Certificate. ABS provided guidance to blend Tananger’s operational experience with the code’s goal-based approach and facilitate compliance with the code.
Tananger contracted ABS to support with the OA, but due to the Coronavirus pandemic, it was necessary to design a modified process that could be performed remotely, requiring Tananger to perform the OA without the polar SME expert in the room.
To overcome this challenge, ABS produced a pre-OA report, that gave Tanager guidance on how to work through all of the hazards as they pertained specifically to Guard Celena’s polar operations.
Combining the pre-OA report and its extensive safe polar waters operational experience, Tananger was able to quickly and easily progress through the OA; ABS reviewed the report to ensure all issues were addressed before Tananger developed its PWOM.
Tananger’s PWOM and OA report were submitted for review and were approved with only minor comments. Upon completion, an ABS surveyor attended Guard Celena, conducted a survey and issued the vessel its Polar Ship Certificate.
At the successful conclusion of the process, Nancy Shen, QHSE Manager at Tananger Offshore commented. “Our clients require that we demonstrate the highest possible safety standards both ashore and among our crew, wherever our vessels are operating. The Polar Code represents a very specific set of challenges in terms of procedures for compliance and ABS provided the support that we needed every step of the way, including providing us with the guidance we needed ahead of time to address issues in the OA and Polar Waters Operations Manual.”