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Systemic Approach to Safety Ensurance- Russian Maritime

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					                System Approach to Safety:
              Development Trends and Priorities

   Dear participants to the Seminar, ladies and gentlemen,

     The economic globalization process requires the adequate and coordinated
measures aimed at in-depth solution of those problems, which inevitably escort
the development of any sphere of human activity and, primarily, the development
of the maritime industry, which by its scale and faceted character is hardly
comparable to the other components of the transport infrastructure.

     Amid the global financial crisis, the world maritime community continues
improving the current standards of maritime safety and environment protection,
as well as developing and implementing the new ones. Advent of such approach
is determined not only by the development of sophisticated technologies,
accumulation of experience in implementation of taken decisions, growing
demands for cargo and passenger transportation by sea, but, first and foremost,
by aspiration to minimize the fleet accident rate and ensure the relevant image of
the maritime industry.
     Confirmation of the above is the adoption in May of this year the Hong
Kong International Convention for the Safe and Environmentally Sound
Recycling of Ships. The Convention has incorporated the experience and
knowledge of hundreds of experts and we may fairly expect that, once globally
applied, it shall result in steady reducing the percentage of risk of irreparable
damage to the environment and human health. One may state that from the
perspective of the system approach this international agreement is actually the
"last, but not the least" of the IMO instruments regulating design, construction
and operation of ships, adding the document regulating the safety of ship
recycling and, thereby, covering the whole life of the ship.
   Experts from Russian Maritime Register of Shipping have participated in the
development of this Convention as members of Russian delegations. Therefore,
acknowledging the primary importance of this significant document
implementation, we have already started to develop our normative base and train
the experts for the proper activities under authorizations of the maritime
administrations within the frames of this Convention.
       Nowadays, we possess the comprehensive set of mandatory technical
instruments, which allow design of sophisticated ships and floating facilities
complying with the international safety standards. Nevertheless, have we the
right to rest on our laurels when no radical reduction of the fleet accident rate has
been achieved yet, especially with respect to the loss of ships? Undoubtedly, the
progress is obvious, and we have managed to achieve a lot, but ships and people
continue to be lost and environmental safety incurs serious risks. The foresaid is
confirmed by the statistics given in Lloyd’s Register Fairplay. Thus, in 2008, 135
ships were wrecked and 1108 persons were lost. As before, the leading positions
in this list are held by the general cargo ships, passenger and cargo ships of ro-ro
type.

     The accident rate of the Register-classed ships in 2008 is characterized as
follows: the total number of accidents is 119, herewith, the shipwreck ratio, as in
the previous years, has remained at the level of 0,1 %, which is slightly lower
than the global ratio of 0,135 %. Causes of accidents and accident situations have
been distributed as follows.

                                                                          Diagram 1

       Causes of accidents with the Register-classed ships in 2008 (%)
                    S tructural
                                  O thers
                   deficiencies
                                   4,12
  F orce majeure       15,21
        8,36




                                                    Human
                                                     factor
                                                     73,05




     As it follows from the diagram, 73 % of accidents are related to the human
factor and occur due to violation of performance standards (COLREG, navigation
rules, maintenance rules, service manuals, etc.) by the crew members. For the
last two years, this ratio has decreased by 5 %, and there is every reason to
believe that this has resulted from the joint measures taken by the Maritime
Administration of Russia and the Register on strengthening the requirements for
SMS of companies and ships under the Russian flag.

     Accidents and failures of the ship machinery and arrangements caused by
the structural deficiencies, manufacturing defects and low-quality repair made
more than 15 % of the total number of accidents.

     Force-majeure circumstances (storms, hurricanes, ice conditions) caused
accidents in more than 8 % of cases.
    The following diagram shows the distribution of accidents by types and items
of technical supervision.
                                                                            Diagram 2

                             Distribution of accidents by
                     types and items of technical supervision (%)

                            11,75
              5,08                                    Hull
       0,76                                   41,63   Main machinery
     1,93
                                                      Auxiliary machinery
    4,23
                                                      E lectric equipment
                                                      S hafting
                                                      P ropellers
   12,14                                              S teering gear
                                                      Anchor arrangements
      2,02
              3,73                                    S hipwrecks
                             16,72                    O thers




     As the diagram shows, the major "contribution" to the accident rate statistics
has been made by the hull structures (almost 42 %), main machinery (about 17
%) and shafting (a little more than 12 %). Review of reports on the accidents,
involving these items, indicates their main reason – low-quality repair. Therefore,
the elimination of this reason is our common task and direct obligation, as it
predetermines the level of safe fleet operation.

      When speaking about maritime safety, I would like to draw your attention to
the following. Analysis of the accident rate statistics on the world fleet shows that
the ship's age is not always the determining factor, lying at the root of the
accidents and accident situations. This thesis is also confirmed by the accident
rate data on the Register-classed ships for the last five years.
                                                                       Diagram 3

                            Distribution of accidents
                             by age categories (%)

  14

  12

  10
                                                                            2008
   8
                                                                            2007

   6                                                                        2006
                                                                            2005
   4                                                                        2004

   2

   0
          0-5       6-10       11-15      16-20     21-25   more than 25



     Thus, the human factor remains the cause of accidents in the majority of
cases!
     This aspect continues to be the subject of thorough investigations, and,
beyond all doubt, the analysis of accident causes and their generalization in the
international standards will make its considerable contribution to improvement of
the maritime safety.
     The main conclusion, which may be drawn on the basis of the statistics
analysis, is relative constancy of human factor percentage in the general list of
causes of accidents and accident situations for many years. In their turn, two other
conclusions may be drawn from this fact. The first conclusion: investigations
concerning the human factor are conducted quite separately, whereas the work on
merchant fleet still hardly depends on the results of these investigations. The
second conclusion: it is difficult, if at all possible, to change the human nature by
the external interference even with the best intentions. "Errare humanum est" – a
man is prone to error. In the "man – ship" system, the "man" element continues to
be not only unreliable, but unpredictable link as well.
     In the current situation with the ships being undermanned, implementation
of the results of the human factor effect analysis into practical activity may still
be expected for a long time. To our opinion, what really worth close attention is
determination of dependence between the crew number reduction and the
growth of the human factor effect on safety, thereby provoked.
      On sophisticated ships, the crew, where not isolated from the environment,
are anyway considerably removed therefrom and from the controlled item as well.
The illusion of "safety" often disserves, especially when the ship is operated
under bad environmental conditions. Besides, the ship overburden with the
electronic devices, intended to assist the crew in making decisions, may be also
considered an additional element of risk.
      Moreover, as it has been emphasized at our previous seminar, the shortage of
personnel may objectively result in the loss of training quality, for example, due
to accelerated training of specialists also caused by the shortage of personnel.
      There is one more serious issue to be discussed, relating directly to the
human factor. This issue was repeatedly considered at all levels, however, no
final decision has been made. It is related to the quality of instructions and
guidelines being at the crew members' disposal. Although even at the IMO level
the developers of such documents were repeatedly addressed with the appeals for
clarity, exhaustiveness and unambiguousness of the language used, it appears that
the proper quality of the instructions could not be achieved. In some cases, it is
connected with translation of the documents from the developer language into the
customer language. It is necessary in all cases to involve the qualified technical
experts in translation, though this alone will hardly be enough. To our opinion, it
is necessary to return to this problem once again and, perhaps, develop an
international standard on development of the instructions for the shipboard
equipment operation. At that, it would be reasonable to seek for such a language
and such a text style, which, among other things, would be understandable for the
personnel other than experts. It must be acknowledged that not everyone may
become the master in development of the instructions, but the importance of the
proper skills acquisition in this area can not be overestimated. It stands to
mention in this respect the difficulties arising during fulfilment of the
requirements of the international legal instruments, as well as their enormous
number. This also does not contribute to reduction of the human factor effect on
the accident origin. It happens because several interpretations, which in specific
cases may appear to be mutually exclusive, are developed on the basis of one and
the same regulation.
      Concluding the comments on the role of the human factor, I would like to
remind you that the year 2010 is announced the Year of the Seafarer by the IMO
Council. Let me express the hope that these comments, specially addressed to the
seafarers, will be heard and taken into consideration, if remain uncontradicted.
   Dear representatives of shipping companies,
    When considering safety issues, I cannot but turn to the statistics of
deficiencies identified by port state control on board the Register-classed ships in
2003 – 2008.
                                                                          Diagrаm 4

                   Distribution of deficiencies by categories
                              in 2003 – 2008 (%)




Translation of the categories in the diagram
15 General safety
1 ISPS Code
1 Transportation of goods
18 Fire protection
5 Radio equipment
10 Life-saving appliances
1 Signal means
1 Ship certificates
8 Maritime safety
7 Load line
6 MARPOL 73/78
14 Machinery
13 ISM Code

As in the previous years, the first place is kept by deficiencies pertinent to fire
safety (18 %), general safety (15 %), machinery installations (14 %) and the ISM
Code (13 %). The percentage of deficiencies pertinent to life-saving appliances
has slightly reduced making up 10 %. Nevertheless, its level remains absolutely
unacceptable. Actually, in case of accident the very possibility of human
salvation is put in doubt that indicates the existence of serious drawbacks in the
safety management systems of some shipping companies. The situation will be
clarified after completion on 30 November the three-month concentrated
inspection campaign held jointly by the Paris and Tokyo MOUs. This time
survival craft and rescue boats, and their launching appliances are subject to
inspections. We shall review the generalized results in order to improve the
cooperation with shipowners and operators for the purpose of enhancing the
safety of those items.

    Ladies and gentlemen,
    Despite the fact that 3 years ago at IX International Seminar we thoroughly
discussed the issues of the efficient ISM Code application, I would like to revert
to this problem and make some more statements.
    By now the Code has become a regular fixture of our industry. It has become
a usual instrument of safety assessment by agents, freighters, classification
societies, maritime administrations, underwriters, port authorities, surveyors,
auditors, technical experts. Close relationship is observed between the SMS
condition, on one side, and crew members' training, accident rate statistics,
familiarization of the crew members with the valid procedures and instructions
and their application, on the other side. The Code makes seafarers more
disciplined and competent in what has been defined as "safety culture" for many
years.
   However, the ISM Code is efficient and acceptable then and only then when
the proper and actual motivation of the crew members is provided and, which is
the most important, when its practical use is a conscious need. In case the ISM
Code is used formally,
- numerous documents may, at best, substantially lower the interest in the Code
   application, if not reduce it to nothing due to the overload with papers and
   information, i.e. it may become an irritative factor;
- there would be always a temptation to attribute corrosion in the ballast tank to
   unsatisfactory operation of the SMS, for instance. The factor leading to such
   conclusions is usually short time of the ship staying at the port, insufficient for
   the PSC inspection. However, for the company experts responsible for ship
   SMS such case may result in misestimate of the situation;
- against the background of insufficient manning, involving continuous
   overstrain of the ship members, filling-in of checklists and performing other
   routine procedures prescribed by the ISM Code may seem to be unnecessary
   and to belie the common sense. Besides, many seafarers adhere to the opinion
   that filling-in the checklists will never stand for the work on board and
   relevant training (emergency drills, etc.), and it is difficult to argue with this;
- frequent inspections and audits, including those on the part of the company,
    purely enhance the negative attitude of the personnel towards SMS and the
    Code;
- absence of the proper ship-to-shore communication, providing the continuous
    SMS improvement, as well as absence of the correct and prompt response to
    the crew proposals on the part of the company or their formal review shall
    hardly enhance the SMS significance. The crew opinion shall be respected.
    In general, the SMS shall become, so to say, "invisible" for the crew. This is
hard to achieve, bearing in mind the number of auditors and the frequency of
audits. This is also hard to achieve when the ship is manned by the trained but not
adapted crew, etc.
    Contrary to the expectations, we arrive at conclusion that, despite the
"attractive cover", a certain weakness of the Code is perceptible, as well as its
insufficient effect on the level of "safety culture".
    We are convinced that in absence of high efficiency when the work is reduced
to paper shuffling, IMO shall return to revision of the Code. The potential of this
instrument is not studied out, the whole problem comes down to audits conducted
once in 2.5 years. In practice it is remembered when finger pointing at each other
in case the non-conformities are found or accidents are investigated. In such
cases, the recognized organizations are the prisoners of the situation, although the
actual offenders are the companies operating the ships! It is sufficient to look at
the distribution diagram of non-conformities under the ISM Code, which were
identified by the Register during the ship audits in 2008.
                                                                          Diagran 5

        Distribution of non-conformities under the ISM Code in 2008
 Translation of the categories in the diagram
    Para 8       Emergency preparedness
    Para 10      Maintenance and repair
    Para 1       General
    Para 13      Certification, verification and monitoring
    Para 4       Designated person
    Para 2       Policy
    Para 12      Verification, review and evaluation
    Para 3       Company's responsibility and authority
    Para 5       Master’s responsibility and authority
    Para 9       Reports on non-conformities
    Para 6       Resources and personnel
    Para 11      Documentation
    Para 7       Plans for shipboard operations

     It may be seen from the diagram that issues connected with the ships'
maintenance, ships and crew preparedness for emergencies, as well as enhancing
the quality of ship operations are priorities for the SMS improvement on part of the
shipping companies.
   Those were the primary issues discussed at the RS seminar late in September.
The topic of the seminar was "Shipping Company: Its Mission, Responsibility and
Management Efficiency. Maritime Labour Convention". More than 50
representatives of shipping companies have taken part in the seminar. Also
discussed at the seminar were the issues connected to modern technology
implementation in the sphere of safety management system operation by the
shipping companies, efficient non-conformity management, self-assessment and
SMS expert appraisal.
       As a result of questioning, 98 % of the participants to the seminar expressed
a wish to hold the similar activities in the future. In this connection I would like to
inform you that the Register has planned the similar seminars to be held at the
regional level in Murmansk, Novorossisk, Astrakhan and Vladivostok. Companies
undertaking the self-assessment of safety management systems and efficiently
operating their fleet will be awarded a conformity mark "Efficient Safety
Management" by the Register.

    Some experts contemplate an approach known as TQM – Total Quality
Management as a means for developing genuinely informal employee morale. This
approach provides the quality maintenance in each and every trend of the
company activities. In my opinion, this is an upcoming trend, which may help the
companies to overcome the drawbacks in their activity.
   Ladies and gentlemen,
   In the Statement adopted two years ago, we stated the qualitative changes
observed in the approach of the international maritime community towards
solution of the problems pertaining to maritime safety, marine environment
pollution prevention and maritime security. These changes manifest themselves
in realization of the system analysis methods when solving the problems and,
among others, developing the new standards on the basis of risk assessment and
consideration of the human factor. Therefore, with your permission, I would try
to develop this thesis in line with the challenges.

   The system approach is applied to maritime safety in the same way as it is
applied to any other sphere of the human activity, and why should the situation
differ in fact? It is suggested that we consider an item, and in our case this is the
fleet, offshore installations and their management, as the system in the totality of
interrelations and interconnections of its components. Among other things,
system approach is an indispensable condition of management efficiency, since it
makes it possible to more rationally use the information on the system
components and interconnections. Such an approach is characterized by its
ordered structure, and it enables to take correct and conscious decisions already
on the stage of task definition, provided the task is formulated correctly.

   Reverting to the topics of our seminars, I would like to give a simple example
to substantiate the above. Last year, when considering the ship manning and the
standards of crew training, the participants to the seminar clearly demonstrated
that one of the system components, namely, qualified personnel, had an evident
tendency toward weakening in its overall structure and, thus, called for our joint
and efficient corrective actions. Besides, it was demonstrated that technical
achievements alone were of limited value if used by untrained and extremely tired
seafarers.

    We have always considered our seminars specifically from the point of view
of identifying the problem and correctly formulating the methods of its solution.
Of course we are far from saying that the only possible and ready-to-operate
solutions were found during their work. Nevertheless, we are still convinced
supporters of the belief that cooperation and partnership are one of the principal
conditions for successful solution of challenges. These important components
ensure the operation of one main principle of the system approach, namely, the
integrity principle, which enables the system to be considered from the higher-
level positions both as an integral entity and as a subsystem.

   We hope that the consideration and comparison of different view points from
different levels and positions at our seminars has at least facilitated the practical
realization of the integrity principle, for it offered a view of the system as seen by
the different states and international bodies, both intergovernmental associations
and voluntary trade associations.
     Another important principle of the system approach is the system hierarchy,
 i.e. the presence of at least two components with subordination characteristics. A
 good example of the practical realization of this principle are 5 levels or "tyers"
 of the goal-based standards of bulker and tanker construction. The Register
 closely follows the goal-based standards development process and actively
 participates therein, since our rules and guidelines, as well as the similar
 documents of other classification societies form part of the so-called "fourth"
 level of the international standard system.

     The next principle of the system approach is the structural consideration of
 the system in order to analyze the interconnections of its components, the
 significance of which for assessing the stability of the system operation may be
 higher than the characteristics of the components. In order to demonstrate this, I
 would like to give an example from a familiar sphere, namely, the feedback
 between the company, as defined by the ISM Code, and the shore-based
 management. This feedback, having the purpose of steady improvement of the
 safety management system quality, is of vital importance for the operation of
 both. In whole, I would like to note that the ISM Code is rather a successful
 attempt of the international maritime community to apply the system approach, at
 least partly, for provision of maritime safety and pollution prevention.

   One more important principle of the system approach is the numerosity
implying ability to describe the system and its links and elements by means of a
number of models of different nature (mathematic, economic, etc.) and to compare
the effectiveness of these models.
The technical progress outstrips the lawmaking activity sometimes leaving it far
behind. In essence, there is nothing special, it has always been so and this is true
now. The difference is in the scale of the gap: if it becomes critical, the situation
will call for the adequate solution.

I can express my satisfaction that methods and forms of maritime safety
assessment, measures for improving the effectiveness of pollution prevention and
security are ever more based on the methods assuming as a basis the analysis of
various types of risks. In this regard I want to outline some of directions, which to
our opinion are of prior interest and have good prospects for the future.

The innovative approach in the marine industry very often leads to decisions that
fall out of the "prescriptive" structure of regulations and rules. I would like to add
that deteriorating economic conditions contribute to finding various non-standard
decisions and we now observe such conditions caused by the economic downturn.
One of the most spectacular examples for the gap between public expectations and
real status of situation is the problem of air pollution from ships. IMO, which
announced the motto of the World Maritime Day 2009 "Climate change: a
challenge for IMO too!", by means of its Marine Environment Protection
Committee carries out without exaggeration tremendous work to create standards
of the new generation, which aim is to significantly reduce the emission of
greenhouse gases, sulphur oxides and nitrogen. According to the data of the
Committee, ships all over the world emitted about 1046 mln tons of carbon dioxide
into the atmosphere in 2007; if urgent measures are not taken as soon as possible,
the total emission may increase 3,5 times by the year 2050.

In order to remove the "label" of one of the main air polluters, the shipping
industry shall pass a hard trial of confirming its compliance with the new Annex
VI to MARPOL Convention. Meanwhile, the experts say the process of testing and
trial of ships' power plants will be long and expensive. Therefore, an alternative
solution may be an improvement of the exhaust gas cleaning system and, in
particular, the exhaust gas recirculation system, however, such systems occupy a
lot of space, thus enlarging the volume of engine rooms and reducing the useful
cargo carrying capacity of the ship. In order to find the optimal solution, it is
necessary to develop the relevant models and carry out their multifactor analysis. It
seems that one of the possible solutions of the problem is the use of gas fuel at
least for certain range of size and power. In this regard we can only greet adoption
of the Interim Guidelines on safety for gas-fuelled engine installations in ships on
the 86th session of IMO Maritime Safety Committee.
The goal-based standards developed by IMO for design and construction of ships
are an interesting and promising example of application of the system approach
methods in the area of safety of bulk carriers and oil tankers. We suppose that the
goal-based standards will prove their vitality because they do not reject
unconventional and design decisions falling beyond the scope of "prescriptive"
requirements, provided their evaluation on the basis of analysis of the relevant
types of risk is positive. Some experts express an opinion that the progressive
promotion of the shipbuilding development based on the existing legal and
production basis is exhausted or close to depletion, i.e. the production has reached
its maximum effectiveness (in particular, in the use of labour and technical
resources). This idea may be argued, however it is evident that the shipbuilding
industry needs innovative and outstanding decisions.
Therefore, the goal-based standards are the long-awaited instrument which, as we
can expect with a high probability, will show the way to solution of many
problems on the basis of new, more scientific and less empirical positions. We wait
with great interest and we are ready to take part in the distribution of the goal-
based standards in other areas of safety, such as fire fighting, life-saving
appliances, shipboard systems, etc.
Undoubtedly, the results of the 59th session of the IMO Marine Environment
Protection Committee attracted very close attention of the maritime community.
Without exaggeration the Second IMO Report on the greenhouse gas submitted to
the attention of the Committee raised a great interest. In particular, it says that
there is a great potential of technical and operational measures for reduction of the
greenhouse gas emission from ships and their effectiveness may be characterized
by 25 % – 75 % reduction as opposed to the existing level. 20 % of the above
figures of reduction can be reached free of charge or at a low cost. Therefore,
proper realization of this potential depends, among other things, on the
effectiveness of our cooperation and partnership, to which we call all the parties
involved in our seminars.
New, very tough requirements are imposed on the industry and it is necessary to
coordinate actions with other industries and transport to reach compliance with
these requirements. More specific wording of the agreed actions is expected on the
Conference of Parties to the UN Framework Convention on Climate Change,
which shall be held in December 2009 in Copenhagen.
The final document of the Conference will replace the Kyoto Protocol 1997 and
define general indices for each industry, including shipping, which shall be reached
in the coming years. As we expect, the Conference will contribute to the further
growth of understanding the importance of any measures aimed at prevention of
fatal change of climate.
The growing human activity in the polar regions, including upstream of the energy
carriers on the continental shelf, as well as the transportation of oil and gas from
the places of extraction, shall be the matter of special attention. The polar
ecosystems are extremely vulnerable and this imposes special requirements for the
safety of all of these types of activity performed in high latitudes, starting from
navigation of cruise ships to the exploration and transportation of mineral deposits
to customers.
In this regard we greet the forthcoming approval of new Guidelines for ships
operating in Arctic ice-covered waters on the 26th IMO Assembly, treating it as one
of the first steps to ensure shipping safety and environmental protection of the
Arctic and Antarctic regions. We would like to underline that the Guidelines
contain a number of new requirements for training crews, thus acknowledging that
the price of the human error if it is made in high latitudes is many times more
expensive than the usual one.
We expect that in the near future the new Guidelines will become a mandatory
document, thus confirming the IMO responsibility for saving unique ecosystems of
the polar regions of the Earth.
We closely monitor the progress of the concept of e-navigation developed by the
international maritime community. We suppose that its forthcoming practical
implementation will be really fruitful if the top-priority attention is paid to human
factor-related problems and availability of crew-friendly technical equipment.
Of course measures taken at the international level in the recent years, such as
safety of the crew handling the life-saving appliances, updated Code on Alarms
and Indicators deserve the uppermost attention.
We treat the ILO Consolidated Maritime Labour Convention as an integral element
of the system approach to ensuring the maritime safety. Its early enforcement will
be a positive factor for the whole system of the international law, because it
naturally supplements the IMO conventions on safety, marine environment
protection, training and certification of seafarers and maritime security
instruments.
Ladies and gentlemen,
We have tried to sketch some trends of the development of the international
maritime law, which confirm de-facto the existence and use of the system approach
to ensuring the maritime safety and environment protection. In no case will our
analysis pretend to be exhaustive, nor can we say that the system approach has
become by now the universal instrument for creation of international standards in
the maritime industry.
The international instruments, which have been developed for decades basically on
the analysis of causes of catastrophes and accidents, i.e "retroactively", sometimes
have a chaotic structure, which appeared "in a natural way", i.e. historically. In
recent years, the "proactive" approach has been prevailing; the conventions
include more requirements, which enable implementation of other design and
technical solutions.
It is necessary to acknowledge that such "inclusions" make the structure of
conventions even more chaotic and ambiguous. For experienced experts, such
structure seems to be natural, while it may raise questions among the newcomers.
Naturally, it would be preferable to separate "prescriptive" standards from the
standards of another nature (provision of the equivalent level of safety). However,
due to peculiarities of the current international laws this is practically impossible.
Accepting life as it is, we nevertheless state that the growing number of methods of
safety regulation on the basis of various types of risk assessment objectively reflect
the main trend, i.e. shift of the international standards from mainly "empirical"
basis to more objective basis, corresponding to the modern views.
From this standpoint the goal-based standards are an example of holistic approach
to ensuring safety, because they offer a possibility of using modern methods of
assessment and design. We can also welcome their use in other areas of safety,
because it will contribute to the renewal of the whole law-making system.
As regards the "prescriptive" standards of Annex VI to MARPOL Convention,
they may have rather serious consequences, which may be also reflected in
application of new approaches to design of the shipboard power plants. However,
this is a matter of indeterminate future.
Thank you for attention.

				
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