ADAPTED BY TIM CARTER FROM SECOND EDITION BY A J ULVEN AND L HOLDERNESS
A.2.1 Risk Based Approach
The management of risk in the maritime industry has a long history. Risks of concern to the industry are many and varied and include:
- Ships and their cargoes may be lost or damaged at sea.
- Payment for delivered cargoes may not be made
- Damage or breakdown of a ship may delay completion of a voyage.
- A ship may cause damage to another ship or to a fixed structure because of collision.
- The demands for shipping capacity depend on wider economic factors. These in turn affect the profitability of the industry. Capital spending decisions about building new ships and scrapping old ones depend on estimates of the risk of such decisions on the company’s ability to meet future demand and remain profitable.
- The demand for competent seafarers to crew ships depends on the growth or contraction of the industry, on labour costs and on reductions in crew numbers secondary to automation of tasks. Ship operators have to balance the risks to their viability from the costs of training and retaining a skilled workforce against the lower cost option of recruiting seafarers with uncertain skills and corporate commitments from the maritime labour market on short-term contracts.
- Injuries, illnesses and deaths may occur in crew or passengers. Infections or disease vectors may be transmitted from port to port
- Loss of containment, release of harmful agents or routine discharges such as flue gasses or sewage may harm the environment.
Shared ownership of ships and their cargoes was an early form of risk pooling. Insurance markets then developed to cover financial losses associated with maritime risks. Classification systems for assessing a ship’s seaworthiness were developed and used to determine the level of premium required to insure vessel and cargo. Capital spending and crewing policies, while not amenable to cover in the normal insurance market, often have their risks managed by ship chartering or by outsourcing of ship and crew management to specialist contractors.
The systematic management of health, safety and environmental risk has been a relatively late addition to the risk reduction techniques used in the maritime industry. The industry rarely developed active approaches, except in sectors where risks to corporate image mattered, such as passenger transport and tanker fleets owned by oil majors. Thus, most developments have been the result of international agreements such as the IMO conventions on control of pollution and the introduction of risk based approaches in the International Ship Management (ISM) code.
A.2.2 Models for Safety, Health and Environmental risk assessment
What is a risk assessment?
A risk assessment is a structured examination that includes
- the identification of what could potentially cause harm or loss (hazards),
- how likely it is for this hazard to cause harm or loss and to what extent or severity and with what consequence or impact (risk)
- identifying steps that can be taken to eliminate the hazard or, if this isn’t possible, reducing the risk.
If measures are already in place the risk assessment will also include an assessment of the effectiveness of these measures. Components of a risk assessment may also include evaluating the likelihood of events happening together. The assessor must make a best estimate of how probable or likely a harm or loss is to occur and an estimate of the worst-case impact or consequence if it does occur, that is, the most severe rational scenario of harm. Risk assessment requires the assessor to ask a lot of ‘what if’ questions and is ideally an objective evaluation of risk based upon reliable data. However, due to a lack of objective data, it is often based on subjective assumptions of potential loss and probability of occurrence. The assessor must consider and assess uncertainties, and the chance of error in the assumption of potential and probability is large.
It is good practice for a risk assessment to be undertaken, and all identified necessary measures implemented, before carrying out a task. All tasks should be risk assessed in a depth that is proportionate to the level of anticipated risk. A risk assessment is a practical exercise and needs to relate to the situation in which the risk occurs. Hence, in order to fully understand the nature of the activity, a visit to the workplace or a representative worksite is often necessary in the course of a risk assessment.
A.2.3 The Risk Assessment Process
Identify the Hazards
A hazard is something with the intrinsic potential to cause harm. This could be a technology, substance, form of energy, biological agent etc. Wikipedia, the free encyclopedia provides a concise definition: “A hazard is any biological, chemical, mechanical, environmental or physical agent that is reasonably likely to cause harm or damage to humans, other organisms, or the environment in the absence of its control.”
The identification of potential hazards is the first step in performing a risk assessment.
Assess the likelihood and severity
Assess the likelihood and severity of the harm that could be caused to people, ship operations or the environment. What are the potential consequences?
The likelihood of a hazard causing harm should be within the business, within the wider company group or within the industry sector. Data may or may not be available for the incidence of such events.
The severity is the amount of harm or loss that the hazard is able to cause if there is human or environmental exposure to it. In considering the potential for harm and loss, the following factors should be taken into account:
- How can the hazard cause harm or loss – consider health impacts, levels of injury, damage to the environment, equipment loss, and damage to community and financial or reputational impact.
- What are the key health effects or injury potential? For health hazards, data from toxicology, epidemiology and other sciences are of great value in this process.
- How many people will be involved in performing the task or be exposed to the hazard?
- Where will the task be performed?
- How often will the task be carried out, how likely is exposure each time?
- How long will the task take to perform and how long will exposure be for?
- Who could be affected? Remember less visible ancillary people (maintenance, cleaners), contractors, visitors.
- How could the environment be harmed: air or water pollution, consequences of fire or explosion, accumulation of persistent materials in soil and water or in food chains
- Are there any simultaneous operations (simops) or tasks being undertaken at the same time that will alter the impact of the hazard?
- How effective are any control measures already in place for preventing or controlling harm or loss? These might include engineering controls, written procedures, procedures for mishaps or emergencies, signs or restricted areas, permit systems etc.
- What steps are taken to check the effectiveness and use of engineering controls, procedural controls and personal protective equipment?
Assess the risk
Risk can be defined as the probability or likelihood that exposure to a hazard will lead to a negative consequence. The level of risk is often evaluated considering the equation below.
Risk = Likelihood or probability of the harm or loss occurring x How much harm or loss/severity/consequence
Many organisations and advisers utilise a risk matrix that is based on a scale of likelihood or probability and impact or consequences. Many such matrices are available and the terminology may differ. It is important to be clear on the terminology to be used in each risk assessment as different phrases may mean different things to different people. (Cross reference AMH medical selection). Evaluating the level of risk on such a matrix provides the initial level of risk.
If the level of risk is not acceptable measures to remove the hazard, decrease the likelihood of the hazard causing harm and/or reduce the severity of the harm or consequence must be considered. I control measures are currently in place their effectiveness can be asessed’. If additional control measures are necessary to bring the degree of risk down to a level that is tolerated these must be implemented and assured. The level of risk should be reduced so far as is reasonably practicable. Some methods of control are inherently more reliable than others. The more reliable methods should always be the preferred choice.
Record the findings and implement them
Each stage of the risk assessment should be recorded and communicated to all personnel who are involved in the task.
Review the assessment and update if necessary
Risk assessment is an ongoing process and must be reviewed regularly. A review should be undertaken immediately if there is reason to believe that the assessment is no longer valid, for instance an injury or a health problem that may be attributable to it, or if there has been a significant change in the work to which the assessment relates.
A.2.4 Precautionary principle
The ‘precautionary principle’ underlies any ethically sound risk assessment. Its basis is to assume that the worst case can happen, both in terms of uncertain severity and uncertain probabilities. It is important to have in mind the uncertainty of possible harmful effects even if exposure is lower than the level considered to be safe. The precautionary principle is a well-established approach to the assessment of major hazards and depends on a realistic consideration of worst-case scenarios.
A working definition of Precautionary principle is given by the World Commission on the Ethics of Scientific Technology (COMEST):
http://unesdoc.unesco.org/images/0013/001395/139578e.pdf (accessed 2 Jan 2020)
“When human activities may lead to morally unacceptable harm that is scientifically plausible but uncertain, actions shall be taken to avoid or diminish that harm.
Morally unacceptable harm refers to harm to humans or the environment that is:
- threatening to human life or health, or
- serious and effectively irreversible, or
- inequitable to present or future generations, or
- imposed without adequate consideration of the human rights of those affected.
The judgment of plausibility should be grounded in scientific analysis. Analysis should be ongoing so that chosen actions are subject to review.
Uncertainty may apply to, but need not be limited to, causality or the bounds of the possible harm.
Actions are interventions that are undertaken before harm occurs and that seek to avoid or diminish the harm. Actions should be chosen that are proportional to the seriousness of the potential harm, with consideration of their positive and negative consequences, and with an assessment of the moral implications of both action and inaction. The choice of action should be the result of a participatory process.”
A.2.5 Principles of risk management
Risk management implies the use of risk assessment to develop and implement effective preventative strategies (see 7.2).
The International Organization for Standardization (ISO) identifies the following principles of risk management.
Risk management should:
- create value – resources expended to mitigate risk should be less than the consequence of inaction, or the gain should exceed the pain
- be an integral part of organizational processes
- be part of decision making process
- explicitly address uncertainty and assumptions
- be systematic and structured
- be based on the best available information
- be tailorable
- take human factors into account
- be transparent and inclusive
- be dynamic, iterative and responsive to change
- be capable of continual improvement and enhancement
- be continually or periodically re-assessed
A risk with a large potential loss and a low probability of occurring is often treated differently from one with a low potential loss and a high likelihood of occurring. In theory, both are of nearly equal priority, but in practice it can be very difficult to establish priorities when faced with a scarcity of resources, especially time, in which to conduct the risk management process. Also the political and media response to risk will push those involved in taking steps to avoid rare major events, even at the expense of far more common low level ones that account, on average for a larger number of casualties. This can be well seen in the priority given to preventing rare ship disasters, while paying little attention to the far larger toll of individual death and disability from injuries and occupational disease in the maritime workplace.
The hierarchy of control options for safety, health and environmental risk is reviewed in 7.4. 33-37 detail the measures used to manage work related health risks.
Monitoring is the measurement or observation to check that risk management is working as expected.
The objectives of risk monitoring and updating are to:
- systematically track the identified risks
- identify any new risks
- capture lessons learned for future risk assessment and allocation efforts
Evaluation is the process of confirming that the whole risk management system is adequately controlling the anticipated risks.
A risk management plan can never be perfect. Critical evaluation at every stage is of great importance. Especially at an early stage it is necessary to match the outcomes of the risk management plans with its objectives. A thorough investigation of each activity in a risk management plan is required. After evaluating the effectiveness and efficiency of all the activities, it is may be necessary to make changes in the action plan to get the desired results. If the risk management plan produces the desired results, it may not need any changes.
Review of changes
It is necessary to review in order to confirm that any changes to the risk management system that have been implemented have led to reductions in risk.
This may be done by recording the possible outcomes of the changed activity and matching them with the main objectives of the risk management plan and then looking for changes to the frequency and severity of the actual outcomes
Evaluating a risk management plan is sometimes a time consuming process that requires expertise, knowledge and experience.
Clear communication to inform all those who may be at risk is essential, but it is also important to enure that anyone who could either reduce on increase risk to themselves or to others understands the nature and severity of risk. They also need to be personally committed to taking the actions needed to maintian control and prevent harm to themselves, fellow workers or to the integrity of vessel operations. All levels of management have roles to play in supporting this as well as avoiding giving conflicting signals about the relative importance of safety, speed or economy.
Seven cardinal rules for the practice of risk communication have been proposed (U.S. Environmental Protection Agency):
- Accept and involve the public/other consumers as legitimate partners (e.g. stakeholders).
- Plan carefully and evaluate your efforts with a focus on your strengths, weaknesses, opportunities, and threats (SWOT).
- Listen to the stakeholders specific concerns.
- Be honest, frank, and open.
- Coordinate and collaborate with other credible sources.
- Meet the needs of the media.
- Speak clearly and with compassion.
A.2.6 Hierarchy of Risk Control
The hierarchy of reliability for control measures is well established, especially in relation to good occupational hygiene practice for the control of chemical (Ch. 6.4) and physical agents (CH. 6.3) that pose a risk to health. However, the same principles apply, with some minor modifications, to the control of injury risks and threats to the wider environment [cross reference needed]. Elimination of the risk or engineering controls are always better than those which rely solely on task management or personal protective equipment.
The following questions need to be answered in sequence when control measures based on the results of a risk assessment are being planned.
Can the hazard be eliminated?
This is the most effective option but is only possible where there are viable alternatives. Alternatives may increase capital or operating costs. Examples include:
- asbestos is no longer used in ship construction because of its long term health effects
- the use of marine diesel rather than residual fuel oil for propulsion greatly reduces emissions of sulphur in flue gasses
- ceasing to use caustic soda for tank cleaning reduces the risk of chemical eye injuries.
Can exposure to the hazard be prevented by technical/engineering means?
It is usually far more cost-effective to introduce engineering controls at the design stage for a ship. Retrofitting can be expensive and is not always practicable. Examples include:
- noise exposure in engine spaces has been the cause of deafness in marine engineers. Design to reduce noise levels, engines spaces that can be left unmanned and noise insulation for engine control rooms greatly reduces exposure.
- on board sewage and ballast water treatment systems prevent the release of harmful substances or alien species into the marine environment.
- the use of inert gasses to blanket flammable bulk liquid cargoes, such as hydrocarbons reduces the likelihood of explosions and fires.
- the design of shipping containers to eliminate work at a height when they are stowed reduces the risk of falls.
Can work practices be introduced that reduce exposure to the hazard?
The consistent use of safe working practices depends on the workforce understanding their rationale and regarding them as practicable, and on active supervision by managers who believe in their importance, even when they can delay task completion. Examples include:
- uncontrolled work in confined spaces is associated with a range of health and injury risks. Well defined procedures, if always followed, can greatly reduce risk.
- permit to work systems that ensure that, for instance, power supplies are switched off and equipment isolated prior to work prevents risks health surveillance is performed.
A.2.7 The effectiveness of risk control
Monitoring and the frequent (re)evaluation of control measures and any changes to them, (7.3) form the basis for assessing the effectiveness of risk control. At one level, it is possible to use the volume and cost of claims to insurers to assess the adequacy of control in financial terms. However, for health, safety and environmental risks this method will underestimate the scale and severity of harm.
The primary measures that can be used are specific indicators, for example, the frequency of death, injury or illness in people and measures of environmental harm such as loss of biodiversity of the seas, coastal areas and the air. However these measures often show a long lag period between the existence of a risk factor and the harm becoming apparent, for example an occupational cancer or noise induced deafness, even when methods are in place to measure relevant indicators. It is also ethically questionable to await such effects if the risk assessment has anticipated their occurrence.
Where the assessment process identifies specific risks it is often possible to use secondary monitoring measures to evaluate the adequacy of control. For instance, levels of noise may be measured to give an early warning of the risk of deafness, thus enabling better noise controls to be introduced. Similarly levels of flue gas emissions may indicate the risks of air pollution – especially in port areas where onshore populations may be harmed. This can indicate the need for measures, such as the use of less polluting fuels or supply of electricity from ashore to allow ship’s generators to be taken off line and reduce emissions.
No risk assessment will be perfect. While it should be based on the best current knowledge there will always be new and unexpected hazards. Alertness is needed to recognise these at the earliest opportunity so that action can be taken across the industry to minimise harm. An example of this was the recognition that deaths were occurring on ships carrying wood pellets, where the cargo was unexpectedly releasing toxic carbon monoxide into enclosed hold areas. Recognition has enabled new controls such as ventilation prior to hold access and the use of gas detectors to bring this new risk under control.
 https://www.hse.gov.uk/simple-health-safety/risk/index.htm Accessed January 5 2020