Last month I was on the following panel at the Global Superyacht Forum in Amsterdam:
This extended debating session following on from GSF 2007, will allow delegates to discuss and debate the various ways in which interpretations and consistency of rules would help improve the process of building and designing large yachts. In addition the session will highlight some of the key changes and developments amongst the Flag states and Class societies.
Peter Southgate - Cayman Islands Shipping Registry
David Ralph – Maritime and Coastguard Agency
Eric Goldring – Goldring & Goldring
Robert Curry - American Bureau of Shipping - Europe
Paolo Moretti - RINA
Engel de Boer - Lloyd's Register
The discussion started out with ABS (a Classification society - which is charged with "classing" or determining and assuring the structural/mechanical/operational quality of the yacht) discussing some new regulations regarding windows, port lights and some other items, followed by MCA discussing the need to regulate further and then a discussion about actual work toward some consistency between the government regulators (MCA), the shipping registries (the governmental agencies involved with "home ports" such as you see noted on the stern of ships) and the classification societies.
Discussion then led to a comment that many of the "theories" used in creating these regulations do not work in practice; that walking on a Superyacht during construction is worthwhile, but seeing how the regulations actually work in practice...when the Superyacht is in operation...is quite another thing. And, to be sure, that is not regularly done or those experiences regularly considered with the new regulations.
I then raised the subject of why "Cost Benefit Analysis" is not being done in relation to the ever increasingly stringent regulations on design and equipment, noting that the Superyacht industry has not had a fatality or life-threatening injury due to a yacht's failure in well over a year (possibly over 2 years or more); evidencing the industry is one of the safest in the world. I further stated that while I am sure there will, unfortunately, be a catastrophic accident in the future there most probably will invariably be a significant human element in that loss. (No one disagreed with my premise.)
With that preface I asked why the regulators, registries and classification societies do not run the cost benefit analysis that are run in literally every other business whether it be automotive, aviation or even the space shuttle; noting that in the present economy the concept of there is plenty of money so spending it on supposed increased safety doesn't work...if it ultimately causes yards to fail and yachts not to be built or purchased.
After not really hearing much of a substantive response, another reprsentative from the MCA noted from the audience that they had an "ethical responsibility" to generate the ever more stringent regulations. My response was "Don't get me started with the problems of regulating ethics. I could give an entire seminar on the topic."
To me that "canned" response was, as it has been in the past, shameful. Regulations are to be based upon "engineering"; not "ethics". The MCA's demand that "saving human lives!!!!!" is what is all about and anyone that doesn't prescribe to that philosophy is unethical is, frankly, horrific. To me it is a smoke screen for politicians trying to justify their existence. How can I so boldly state this? It is easy.
In an industry where there is a history of years of no catastrophic losses due to items which are the subject of these regulations we are, fortunately, already at the supposed "Theoretical Zero." You cannot improve on that kind of consistent history simply by throwing regulations and creating higher standards in the hope that it "may" at some point cause one or two theoretically possible losses from happening at some unknown point in the future.
What you can do is use the, now more than ever, finite amount of available dollars available for designing safety on what is the weakest link in the Superyacht...and cruise...industry: Crew.
Imagine how much safety could actually be improved with the millions of dollars expended on crew recruitment, education, training and safety? Dollar for dollar, euro for euro and pound for pound I do not believe there is a single soul in the Superyacht or cruise industry that could...or frankly, would...argue that my position is incorrect.
The MCA will argue that it has training requirements. The fact is that within the Superyacht industry captains, crew and managers are screaming that taking MCA required tests do not make good captains: years of actual experience (and not just sea time) does. A head in a book versus a head in an engine room, a seat in a classroom or at the helm, where do you think the knowledge actually is obtained?
When you walk on a superyacht or a cruise ship even the most novice of passengers (forget the professionals) can instantly identify the crew members that "get it", that having the training and who exude the confidence and knowledge that puts every one of us at ease.
In an emergency, do you want:
1. A supposedly "idiot-proof" designed piece of equipment with an idiot standing by the ready to use it; or,
2. A still well designed piece of equipment with a well-trained and knowledgeable crew member able to operate the equipment, even if it doesn't work perfectly, to its optimum level?
Personally, I would guess that 100% would vote for keeping the word "idiot" out of the equation!
So my question is simple: Why to the regulators like MCA insist on more regulations on equipment with a history of excellent safety, drawing millions in funds away from actual crew recruitment and improvement, when the real improvements in avoiding accidents lies with crew?
I have no answers. Do you?
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