Seeking an industry solution to safety issues
around power-operated watertight doors
At the end of May 2013, Gard hosted a conference for a wide range of industry participants, to raise awareness of safety issues and debate how to possibly reduce the risks around watertight doors on board ships and offshore units.
Over 70 participants, including representatives from six leading European door manufacturers, five flag states, five class societies, three leading ship yards and ship and offshore owners, gathered at Gard’s headquarters in Arendal, Norway to discuss the dangers and risks associated with watertight doors.
at the conference for future ships to have
a minimum number of watertight doors.
Flooding is the greatest threat to ship stability and many believe that the problem has lacked attention. Gard has worked hard to highlight its concerns and spotlight some of the cases where problems have arisen relating to watertight doors, which are key components in a casualty situation.1 As a leading P&I Club and hull insurer, Gard feels the time is right to take more active steps to help the industry seek improvements and solutions by getting a discussion going and trying to build consensus for a way forward. This is the first initiative of its kind which was eagerly applauded by all those attending and has led to the formation of an international association of European door manufacturers to focus on safety issues. Momentum continued in June 2013 with the IMO Symposium on The Future of Ship Safety and presentation of the proposal from some flag states to IMO to review the SOLAS regulations and current guidelines which allow for watertight doors to be open during navigation.
Watertight bulkheads below the bulkhead deck are critical to ensure the safety of the ship when water ingress occurs following a casualty. On passenger ships, areas such as engine rooms and service rooms are deep down in the vessel, spread over several bulkheads and are accessed horizontally for the efficient operation of the ship. As a result, power-operated watertight doors are used in bulkheads to enable the crew to move around the service areas of the vessel and to provide escape routes in emergencies. As cruise and Ro-Ro Pax ships get bigger, the number of subdivision bulkheads increases as well as the need for watertight doors – some cruise ships can carry over 8,000 people and there are vessels which have 40, 50 even over 70 such doors on board. In an ideal world, there should be no such things as watertight doors, as they can have an impact on the watertight integrity of the ship. A challenge faces the regulators and industry – on the one hand, doors can adversely affect the safety of the ship, on the other, they are needed by shipowners for efficient operation of their ships.
Over the years Gard has seen watertight doors, fitted below the bulkhead deck, either being left open or not well-maintained. If the hull is breached these have contributed to the ship capsizing or sinking in a number of high- profile casualties. There has also been a number of cases where crew have suffered serious injury or even death while using power operated watertight doors. The best solutions will be where regulators, ship designers and door manufacturers work hand in hand to find the optimal answer.
Meeting prior to the Gard conference, the door makers agreed that IMO and flag states need to pay more attention to the safety of watertight sliding doors and that knowledge and maintenance were key to ensuring that doors were watertight and operated safely. They decided to form an international association to work on safety issues and made an action plan to get them started, which was presented at the conference.2
At the Gard conference a range of speakers looked at the topic from the perspectives of regulation, design, manufacturing and insurance. Some of the main considerations and conclusions are described below.3
SOLAS Regulations and Guidance4
There was consensus that IMO and flag states need to get back to the original concept of watertight bulkheads being really watertight and being kept watertight.
Regulation 22, relating to the prevention and control of water ingress by watertight doors, currently provides that all doors shall be kept closed during navigation, subject to a number of exceptions, which has provoked intense debate over which doors may be left open. This led to the introduction, in December 2010, of a (non-mandatory) guidance for passenger ships, providing guidelines for when a flag state may permit a certain category of door to remain open during navigation. Prior to 2010, it was up to each administration to decide whether to grant an exemption, though there were no criteria in place governing when such exemptions should be given. Regrettably, the guidance contains inconsistent provisions relating to meeting floatability criteria, which can lead to a door being open at all times under all conditions. The debate continues as to whether the regulatory framework has resulted in safer ships or more open doors. The UK has reserved its position on use of the guidance and is supported by Norway, Spain and the US. In June 2013, these flag states presented a joint paper (MSC 92/6/8) to the IMO proposing a complete review of both SOLAS Regulation 22 and the guidance in order to remove the ambiguity.
Dr Andrzej Jasionowski, Director of Stability and Ship Dynamics, at the Brookes Bell Group has campaigned for seven years for changes to safety legislation relating to ship stability. He is a forensic stability scientist and believes the requirements of built-in stability must be raised to reduce the intolerably high risk of catastrophic failure, and door use should be abandoned to mitigate its adverse effect on watertight integrity. His theory is that the current regulatory framework (SOLAS 2009, MSC216, Regulation 6) does not provide a high enough level of safety for Ro-Ro Pax ships to ensure passenger survivability in many feasible cases of flooding. He believes if the required stability is increased, then risk and vulnerability will be drastically reduced, provided use of watertight doors is also regulated to the same level of stringency. He challenges designers to abandon door use altogether and door manufacturers to build a new generation of doors, which ensure 100 per cent closure and watertightness.
Further concerns are that there are two different sets of rules depending on whether the ship was built before or after 1st February 1992: it is confusing to have a different set of rules for older ships, not least for seafarers who frequently move from ship to ship. The current SOLAS regulations for doors are more detailed for passenger than cargo ships, resulting in somewhat different safety standards. Door manufacturers feel strongly that IMO and flag states pay less attention to the safety of watertight doors than to life-saving appliances and this needs to change.
Unfortunately, clarification of regulations can not be forced and experience shows from other areas, like lifeboat hooks, that change can take many years. The conference agreed that in the meantime it is critical to focus on other safety improvements.
Watertight doors should be kept closed while at sea
There was consensus that too many watertight doors are left open while at sea.
Professor Emeritus Anders Ulfvarson, of Chalmers University of Technology in Sweden, an expert in ship design research, is a believer in closed doors. He presented the DESSO study,5 which was commissioned because Ro-Ro Pax ships stand out as high risk and need to be made safer. The main focus of the research was to maximise survival on board and involved designing a concept Ro-Ro Pax ship which, even if sinking after severe damage, would never capsize – the like of which does not exist today. Closed watertight doors were considered clear prerequisites in the design in improving stability and survival aboard and the study proved that it is possible to design a ship that remains upright, even if she ultimately sinks.
It takes time to pass safely through watertight doors – one shipowner representative at the conference advised it can take at least 20 minutes to move through a 200m ship. As a result, short cuts and risks are taken. Sometimes crew do not wait until it is safe to pass through and others modify the safety precautions on the door, such as its opening/closing speed and alarms.
Gard highlighted that insurance claims arising out of a casualty may be compromised if watertight doors are found to have been left open contrary to regulatory requirements. The conference was reminded of the basic principle of marine insurance that the incident giving rise to the claim must have been unforeseeable and accidental, occurring without any gross negligence on the part of the shipowner, general wear and tear excluded. For a marine insurer, open doors during navigation contradict the concept of watertight bulkheads, hence, even if a vessel has been granted an exemption to run with open doors, the insurer will closely examine whether other measures were taken by owners to evidence that they have acted prudently. A judge may consider an open door in a rather different way to a flag state.
New ships should have fewer doors
There was consensus at the conference for future ships to have a minimum number of watertight doors, a principle provided for and intended by the current regulations, though often sacrificed to enable easy access to frequently used areas. One should never lose sight of the fact that the bulkheads, where the doors are fitted, are required to be watertight, so the doors in fact represent a weakness in the watertight integrity of the ship.
Delegates agreed that too many watertight doors are left
open while at sea.
Henning Luhmann, Head of Basic Design at Meyer Werft, believes that operational needs have not been considered carefully enough in the past and ships have been designed without the right balance between effective daily operation and damage stability through effective sub-division. These can be conflicting interests and striking the right balance is a challenge for designers when safety is one of the key objectives. However, he was able to illustrate how ship designs can be adapted to minimise the number of watertight doors, as well as allowing doors to remain closed when at sea, while at the same time maintaining efficient daily operations. Given the current regulatory framework, permitting certain watertight doors to remain open during navigation, he stressed the need for designers to find ways to minimise the impact of open doors on vulnerability in a casualty. The key to achieving this balanced approach is to align design and operation from an early stage in the design process.
Existing fleet issues – Crew awareness and training
At the conference, the door manufacturers issued the following joint statement:
“A considerable number of doors are found on board ships in bad condition, meaning not watertight. We attribute this to lack of knowledge and maintenance.”
Shocking pictures of poorly-maintained and dangerously “modified” doors were presented, which they had come across on service visits. They believe crews are mostly ignorant of the dangers this poses and do not take watertight doors seriously. The doors close like a guillotine with a force of two tons and can kill, maim and seriously injure people. It was agreed that they are not mere doors but machines, which should be regulated in the same way as hazardous machinery. The door makers also announced at the conference that they would make safety operating videos available on their websites’ home pages and would lobby regulators to require crew training on the safe use and maintenance of watertight doors and mandatory periodical service checks by a qualified competent company. Language is also an issue; attention is therefore being focused by one door maker on developing a graphic training video without words.
Andrew Scott, Policy Lead for Stability, Subdivision and Ro-Ro Pax of the UK’s Maritime & Coastguard Agency, believes that making the crew aware of the dangers of open watertight doors and training them in operation and maintenance are key to improving safety in this area. He presented the findings of the report on the Ro-Ro Pax STENA NAUTICA casualty in 2004, when nine out of 14 watertight doors were open at the time of the collision when carrying 94 passengers and 34 crew. Had the doors been closed, only one engine room would have been partly flooded and the vessel would have been able to continue under its own power to port. The crew routinely kept the doors open in the engine room areas because they took one minute to open and close, which hindered them in their daily operations and which they felt would delay emergency fire-fighting. The engineers felt safe knowing the bridge staff would close the doors if needed. There had been no training drills to practise routines in an emergency situation, so nobody knew what to do when the bridge triggered the closing of all doors and no training had been given in how to operate the doors from the control station on the Ro-Ro deck. This situation is not uncommon today and is exacerbated by seafarers moving from ship to ship and encountering different door types, different age doors which are subject to different regulations and different configurations of “permitted” open doors.
Awareness must be raised of the need to properly operate, maintain, inspect and service these doors, not least because some of these doors will continue to operate for up to another 40 years and some open and close up to 400 times a day, that is, every four minutes.
There were also calls for old doors to be required to be upgraded to conform to the latest rules, for tightness testing of all doors to be compulsory and for consideration to be given to the fitting of anti-crushing devices.
Gard is delighted to have been instrumental in bringing the industry and other important stakeholders together to focus on this life-threatening problem. The creation of an association of door manufacturers to lobby for improvement should add weight to the debate. There is no easy solution to the challenge of balancing the safety and stability of the ship against operational needs for access via watertight doors, but a lot of optimism was generated and it is hoped that work will continue to bring about change.
1 See articles “The dangers of power-operated watertight doors”, “Ship disasters involving watertight doors”, “Injuries and deaths caused by watertight doors” and “Improving the safety of watertight doors” in Gard News issue No. 207 and Loss Prevention Circular No 07-12, “Dangers of power-operated watertight doors”.
2 See more details at www.gard.no.
3 For further details of the presentations see www.gard.no.
4 Chapter II-1, Regulations 13 to 25 and MSC.1/Circ. 1380.
5 DESSO is a concept ship.
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