INTERNATIONAL MARITIME ORGANIZATION

E
IMO

MARITIME SAFETY COMMITTEE MSC 78/INF.5

78th session 16 December 2003
Agenda item 24 ENGLISH ONLY

WORK PROGRAMME

Revision of the Code on Intact Stability

Submitted by Germany

SUMMARY
Executive summary: This document informs on a Formal Safety Assessment on making
mandatory the stability criteria contained in the IMO Code on Intact
Stability (IS Code), carried out by Germany
Action to be taken: Paragraph 2
Related documents: MSC 78/24/1

1 The following Formal Safety Assessment is directed exclusively to the cost-benefit

relation of the proposal to make the design criteria of the IS Code mandatory as contained in
document MSC 78/24/1. It does not address the substance or appropriateness of the criteria
themselves, nor does it consider the cost-benefit relation of other possible measures for
enhancing the safety against capsizing of ships.

Action requested of the Committee

2 The Committee is invited to take note of the information provided in the context of its
consideration of document MSC 78/24/1.

***

For reasons of economy, this document is printed in a limited number. Delegates are
kindly asked to bring their copies to meetings and not to request additional copies.
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Formal Safety Assessment

on the
Making Mandatory of Stability Criteria
contained in the
IMO Code on Intact Stability

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Table of contents
Introduction and scope of Formal Safety Assessment................................................................. 4

Identification of hazards................................................................................................................. 5
• General mechanism of stability accidents ............................................................................ 5
• Stability accidents (case studies) .......................................................................................... 6
• "Lime Bay" .......................................................................................................................... 6
• "Sun Breeze"......................................................................................................................... 8
• "Dongedijk" .......................................................................................................................... 9
• "X" (anonymous report) ..................................................................................................... 10
• "Rautz"................................................................................................................................ 11
• Present status of the IMO Intact Stability criteria .............................................................. 12
• Relation to SOLAS and other Conventions........................................................................ 12
• Status perceived by ship owners and mariners ................................................................... 13
• Status perceived by carriers (charterers) and shippers ....................................................... 13
• Status perceived by flag State authorities........................................................................... 14
• Status perceived by port State authorities........................................................................... 14
• Status perceived by classification societies and underwriters ............................................ 14
• Status perceived by naval architects ................................................................................... 14
• National stability criteria .................................................................................................... 15
• Australia.............................................................................................................................. 15
• Germany ............................................................................................................................. 15
• Japan ................................................................................................................................... 16
• Sweden................................................................................................................................ 17
• USA .................................................................................................................................... 17
• Common practice of ship stability management ................................................................ 18
• Ships with critical operational stability .............................................................................. 18
• The role of the owner, the charterer and the shipper .......................................................... 19
• On-board stability monitoring and assessment................................................................... 20
• Practical consequences of deficient departure stability ...................................................... 22
• Summary of hazard identification ...................................................................................... 23

Risk assessment ............................................................................................................................. 24

• Methodology....................................................................................................................... 24
• Hazard and Operability Study (HAZOP) ........................................................................... 25
• Event Tree Analysis of stability accidents (ETA) .............................................................. 26
• Average cost of stability accidents and monetary risk ....................................................... 29
• Estimated consequences of mandatory IMO Intact Stability criteria ................................. 30
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• Indirect influence of mandatory criteria ............................................................................. 30

• Reduction of calculated risk ............................................................................................... 31
• Summary of risk assessment............................................................................................... 31

Risk control options ...................................................................................................................... 32

• Improvement of ship design and equipment....................................................................... 32
• Ship design ......................................................................................................................... 32
• Equipment for control of stability....................................................................................... 33
• Improvement of ship operation........................................................................................... 34
• Enforcement of SOLAS Regulation VI/2 (information from the shipper)......................... 34
• Review of loading and stowage procedures ....................................................................... 34
• Review of education and training of masters and deck officers ......................................... 34
• Enhancement of administrative supervision....................................................................... 35
• Flag state control ................................................................................................................ 35
• Port state control (PSC) ...................................................................................................... 36
• Revision of the IMO Code on Intact Stability .................................................................... 36
• Re-structuring the IS-Code ................................................................................................. 36
• Mandatory status of the stability criteria ............................................................................ 38
• Summary of risk control options ........................................................................................ 38

Cost-benefit assessment ................................................................................................................ 39

• Benefit of mandatory intact stability criteria ...................................................................... 39
• Regulatory consequences ................................................................................................... 40
• Revision of the IMO Intact Stability Code ......................................................................... 40
• Revision of SOLAS Chapter II-1 ....................................................................................... 40
• Revision of national regulations ......................................................................................... 41
• Consequences for ship design and classification................................................................ 41
• Consequences for ship operation ........................................................................................ 41
• Strengthening of legal demands on shippers and carriers .................................................. 41
• Standardisation of key shipboard operations regarding stability management .................. 42
• Optional supervision by port state authorities .................................................................... 42
• Summary of cost-benefit assessment.................................................................................. 42

Recommendations for decision making ...................................................................................... 43

Literature....................................................................................................................................... 44

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Introduction and scope of Formal Safety Assessment

The Code on Intact Stability for All Types of Ships Covered by IMO Instruments (IS-Code), was
adopted by the IMO Assembly in Resolution A.749(18) in 1993 and amended by Resolution
MSC.75(69) in 1998. It is a non-mandatory code.

The IS-Code in its present form contains general provisions against capsizing, distinguished
design criteria for all ships and for certain types of ships, and specific guidance on certain issues
related to stability. The structure of the IS-Code is shown by its chapters as follows:

Chapter 1 – General
Chapter 2 – General provisions against capsizing and information for the master
Chapter 3 – Design criteria applicable to all ships
Chapter 4 – Special criteria for certain types of ships
Chapter 5 – Icing considerations
Chapter 6 – Considerations for watertight integrity
Chapter 7 – Determination of light-ship displacement and centres of gravity
Annex 1 – Detailed guidance for the conduct of an inclining test
Annex 2 – Recommendations for skippers of fishing vessels on ensuring a vessel's endurance in
conditions of ice formation
Annex 3 – Determination of ship's stability by means of rolling period test (for ships up to 70 m
in length)

The presently non-mandatory status of the IS-Code is considered as unsatisfactory in the light of
its importance for appropriate ship design and safe ship operation. Thus a proposal for
re-structuring the IS-Code is envisaged having in view

• a mandatory part A, containing all design criteria,

• a recommendatory part B, containing guidance and explanations, and
• a recommendatory part C, containing explanatory notes on compliance with the criteria.

This step would require an appropriate amendment to SOLAS and/or ILLC Conventions. IMO
has decided to back future decisions on safety regulations by a specific Formal Safety
Assessment (FSA). FSA is "a structured and systematic methodology, aimed at enhancing
maritime safety, including protection of life, health, the marine environment and property, by
using cost-benefit assessment". The FSA methodology shall consist of the five steps:

1. Identification of hazards
2. Risk assessment
3. Risk control options
4. Cost-benefit assessment
5. Recommendations for decision making

The following Formal Safety Assessment is directed exclusively to the cost-benefit relation of
the envisaged decision to make the design criteria of the IS-Code mandatory. It does not address
the substance or appropriateness of the criteria themselves, nor does it consider the cost-benefit
relation of other possible measures for enhancing the safety against capsizing of ships.

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Identification of hazards

General mechanism of stability accidents

The purpose of the existing Intact Stability Code, as lined out in its paragraph 1.1, is to
"recommend stability criteria and other measures for ensuring the safe operation of all ships to
minimise the risk to such ships, to the personnel on board and to the environment". The nature of
this risk is not specified, but can be generally assumed as the risk of capsizing.

Consequently, the Code provides stability criteria, which are to be uniformly used for ship
design, for ship approval and for ship operation. It further provides instructions and guidance for
determination of light ship parameters, of effects of free surfaces of liquids in tanks,
considerations for watertight integrity (recapitulation of relevant SOLAS and ILLC Regulations)
and general provisions against capsizing and information for the master.

However, the typical mechanisms of capsizing of ships are not specified in the Code. There is,
for example, no particular clause, which limits the applicability of the stability criteria to
situations where cargo and other masses on board do not shift, except for the crowding of
passengers. There is also no clear definition of the "stability accident" in the Code. But such a
definition is necessary for the identification of hazards within a Formal Safety Assessment (FSA)
on the legal status of IMO Intact Stability criteria.

For the purpose of this study, a "stability accident" shall be understood as an incident, where

• a ship capsizes, or
• a ship suffers a large heeling angle, or
• a ship suffers heavy rolling.

There are many causes for stability accidents, like

• neglecting minimum stability criteria (design and operation),

• faulty assessment of stability,
• excessive stability (design and operation),
• heavy weather (wind and waves),
• ingress of water (leakage, fire fighting),
• increase of top masses (water soaking, icing),
• grounding, docking,
• towing operation,
• changing course at high speed,
• transverse shifting of masses (cargo etc.).

While the first nine causes can be referred to as primary causes, the transverse shifting of masses
is mainly a result of one of those, but often has the deciding impact. The consequences of a
stability accident under the above definition are in line with the risks to be minimised according
to paragraph 1.1 of the Code, namely

• threat to persons (health or life),

• damage to or loss of cargo,
• damage to or loss of the ship,
• damage to the environment.
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Figure 1.1: Stability accident in port

• Stability accidents (case studies)

In this chapter a number of cases are presented for demonstrating the variety of influences, which
contribute to a stability accident, and the consequences, which such accidents may have.

• "Lime Bay" 1
On Saturday, 8th February 1997, at about 04.00 hours, the Antigua and Barbuda flag container
feeder vessel "Lime Bay" (Loa = 85 m) was about to enter the port of Alexandria in Egypt with a
full cargo of containers. Last loading port was Damietta, Egypt. The weather was fine and the sea
smooth. A few minutes after the pilot had boarded the vessel and the speed was brought to about
5 knots again, a sudden list of 15° developed without any external reason. The pilot prohibited to
enter the port in this condition and left the ship. At about 05.00 hours two tug boats took the
vessel in tow and she berthed at about 08.30 with her starboard side alongside a jetty.
The port list had grown in the mean time. The master, uncertain about the reasons of the list,
decided to order a careful counter-flooding by means of the starboard side tank. The vessel
righted up after some minutes, but then fell over to the starboard side with a list greater than
before. Containers of the top tier on deck came to rest on the jetty. Further flooding was not
stopped because the chief engineer had already left the engine room. The master, the chief
officer, the chief engineer and the other three crew members jumped ashore at this time.
Port authorities assumed the responsibility for initiating the salvage operation. But before any
measures had been effected the vessel sank to the bottom of the harbour due to water ingress
through various vent pipes and other small apertures. Later the vessel was unloaded, refloated,
and taken to the Netherlands for repair by end of September 1997.
An investigation of this accident was carried out in Egypt and later in Emden, Germany, because
the master and the chief officer were holding German Certificates of Competence. The following
findings were reported:
• The ship was equipped with an approved loading and stability computer. The software
was, however, not compatible with the planning computer of the charterer's agents in
Damietta. Thus, a precise pre-calculation of stability for the departure condition had to be
left until the ship had arrived in Damietta and was actually loading.

1
Report by Seeamt Emden, Germany, 17.12.1997 – DI 13/97 E

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• The amount of cargo to be loaded, according to the stowage plan issued by the charterer's
agents, was 2545 t. The chief officer calculated the stability, trim and draught and
informed the master that all were within acceptable limits.
• After leaving the port of Damietta at about 10.00 hours on Friday, 7th February, the chief
officer informed the master that his final draught reading indicated that about 120 t excess
cargo were on board. The master was concerned and informed the charterer. However,
there were no signs of difficulties with the behaviour of the ship and the master decided to
continue heading for Alexandria.
• A re-calculation of stability, carried out by a British consulting company on behalf of the
charterer, revealed a GMC = 0.15 m for departure using the cargo data as supplied in the
stowage plan. This GMC-figure was insufficient to satisfy the IMO Intact Stability
criteria.
• Another calculation by the same company, using identical stowage positions but the
weight figures from the cargo manifest, which was not available to the charterer's agent at
the time of cargo planning, revealed a GMC = − 0.00 m for departure with 2801 t of
cargo.
• Later, a further re-calculation was carried out by an expert from Germanischer Lloyd with
updated cargo weights and a reasonable assumption of the somewhat lower centre of
gravity of containers. The result was GM = 0.08 m with 2813 t of cargo, yielding a GZ30°
of 0.02 m. This condition was assumed to be the closest approximation to the actual
condition at departure from Damietta.

Figure 1.2: Accident of "Lime Bay"

It appears, that this accident was caused by wrong cargo weight figures in the first place. But
there was also a lack of diligence within counter-checking the cargo intake by draught readings,
not to mention the possibility of checking the actual stability by an in-service measurement at a
reasonable time prior to completion of loading. It remains further unclear, whether the chief
officer and the master were fully aware of the interpretation and application of the IMO Intact
Stability criteria. Finally the measures of controlling the initial list to port were obviously not
taken in a proper way.
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• "Sun Breeze"

On Saturday, 21st August 1999, at 18.00 hours, the Panamanian flag general cargo vessel "Sun
Breeze" left the West Australian port of Bunbury with a full cargo of packed sawn timber. The
weather was fine with a gentle north-east wind of Beaufort 2.

After the harbour master had disembarked the engine revolutions were increased to sea speed and
the 3rd mate changed from manual steering to auto pilot. Due to some disorder the vessel started
turning to starboard and the 3rd mate changed back to manual steering. In his attempt to bring the
vessel back on course a list developed, first to port and then to starboard.

The master, who had left the bridge immediately before this incident, returned and found a list of
about 15° to 20°. He stopped the engine while the list increased to 30° and settled at about 25°.
Nine packs of timber stowed on deck were lost overboard from hatch No. 1 at this time.

A distress message was sent at about 18.48 hours and the anchor let go at about 19.00 hours. The
master ordered all personnel to muster at the life boat deck with lifejackets. After an initial check
for damage the master decided to ballast Nos. 3 and 4 side tanks for correcting the list back to 5°
starboard and lowering the ship's centre of gravity. During the late evening some crew members
were taken off the vessel and the harbour master, who had returned to the scene, investigated
together with the master how to handle the case. The owners of "Sun Breeze" arranged for a
surveyor to board the vessel next day.

After a thorough establishment of the ship's stability by the surveyor appointed by the owner's
P&I Club the vessel was permitted to re-enter the port of Bunbury, where the cargo was
restowed, existing gaps filled and chocked off, in holds as well as on the hatch tops. The vessel
eventually sailed on 25th August and arrived on 10th September at the port of destination in China
without further incident.

Figure 1.3: "Sun Breeze"; Loa = 109.3 m, B = 19.8 m

The Australian Transport and Safety Bureau investigated the case2 and found the following facts
from ship's documents and interviews with the master, the mate and the 2nd and 3rd mates:

• The master's voyage instruction were to load a minimum of 10,000 m3 of timber with a
stowage factor of 1.6 m3/t. The cargo description indicated that there were in total 2,140
packs with 14,354 m3 net to load. Loading cargo on the hatch top appeared necessary.

2
Report No. 150 of the Australian Transport Safety Bureau, June 2001
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• The packages of timber were not marked with their weights as required by Australian
law. The gross stowage factor turned out to be about 2.35 m3/t, partly due to lost or
broken stowage under deck.
• The master had asked the mate to calculate the stability for departure. He required to
maintain a GM of 0.50 m as a minimum. The calculation had to be carried out manually.
A righting lever curve had not been plotted and hence not been checked against the IMO
Intact Stability criteria.
• Prior to completion of loading a rolling test was carried out with the result of 19-20
seconds, indicating a GM of about 0.50 m. It is unclear how much cargo was loaded after
that, but it appears that some was loaded on the hatch top.
• The harbour master, being concerned about the vessel's stability, contacted the master in
the afternoon of 21st August, the day of the initial sailing, and was given a stability
calculation showing a GMC of 0.47 m, corrected for free surfaces.
• The cargo in the holds and tween decks had not been stowed perfectly tight. Gaps
between cargo blocks had not been stuffed or chocked. The cargo on deck was not
adequately secured. The ship's Cargo Securing Manual did not contain instructions on
securing a timber cargo. The master did not have a copy of the IMO Timber Deck
Cargoes Code on board.
• The ship's stability documents had several deficiencies. It was found out that the initial
inclining test at the building ship yard had been conducted with a heeling angle of about
0.365° only. The test condition included a total mass of liquids on board of 52.6 % of the
light ship mass. Thus the obtained position of centre of light ship mass KG in the stability
booklet appears doubtful. Furthermore, the tabulated imax of No. 1 fuel tank was given
with 439 m4, but it was found that the correct figure was greater than 1,300 m4. This
discrepancy caused a specific error in the stability calculations carried out before
departure of about 0.07 m difference in GM.
• The chief officer's stability calculations did not allow for free surfaces in a number of
tanks, which were assumed by him as full but in fact were slack.
The conclusions were, that the vessel actually sailed on 21st August 1999 with a GM close to
zero. This and the insufficient securing of cargo brought the ship and the crew to the brink of a
disaster. It remains unclear whether the master was fully aware of the interpretation and
application of the IMO Intact Stability criteria.

• "Dongedijk"
On Tuesday, 15th August 2000, at about 04.00 hours, the Dutch flag container feeder vessel
"Dongedijk" capsized shortly after departure from Port Said in Egypt on an intended voyage to
Lattakia in Syria. The crew of 12 were rescued by pilot boats and fishing vessels. The ship in fact
took the ground when heeling over. This apparently prevented her from fully turning over and
drowning at least some of the people on board.
One year later the case was investigated by the Dutch "Raad vor de Scheepvaart" with the
following findings3:

3
CESMA Newsletter

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• During the initial loading planning it had already become apparent that the vessel was
overbooked, indicated by calculated insufficient stability and excess draught. For this
reason the master had already cancelled 12 containers from the loading plan. The ship
was equipped with an approved loading and stability computer.
• In order to reach an acceptable loading condition regarding load line requirements, all
double bottom tanks except No. 2 had to be emptied. The stability in this condition
complied with the IMO Intact Stability criteria indicated in chapter 3.1 of the IS-Code but
not with the weather criterion in chapter 3.2. However, this outcome was obviously
accepted by the master.
• The final draught readings on departure revealed that excess cargo had been loaded. But
this indication was obviously not properly comprehended by the ship's command.
• After the ship had been recovered and brought alongside in Port Said the actual weights
of the containers were traced and found to exceed the planning figures by 180 t.

Figure 1.4: The accident of "Dongedijk"

This case clearly shows, that the safety of this ship was put at risk almost deliberately. One main
reason is again the supply of uncertain and actually wrong weight figures of a considerable
number of containers. The other reason is the readiness of the master to accept a departure
condition where the recommended IMO Intact Stability criteria were only partly satisfied.

• "X" (anonymous report)

This report was earlier presented in the IMO document SLF 43/9/1. A feeder container vessel,
partly loaded, was bound to load another 350 containers with about 5000 tonnes in a small
modern container terminal in the Mediterranean area for another port in the region. Cargo
planning was carried out on board in advance by booking lists received from charterer's agents
via satellite. The onboard computer revealed that the vessel would be loaded down to her marks.
The stability would be at the limit using all the appropriate low ballast capacity. Care had to be
taken because experience gave reason to suspect the booking figures.

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During loading the planned container positions were strictly followed, draught readings were
taken and roll periods were observed at regular intervals. At about 02.00 hours in the morning the
chief officer stopped the loading because the summer draught was reached and the rolling period
was at the limit. There was no chance for de-ballasting. Unfortunately there were still about
40 containers to load.
The agent appeared and tried to convince the master to load the rest of the containers with the
argument that the batches with common B/Ls (Bill of Ladings) could not be separated. The
proposal of the chief officer to unload broken batches and complete others had to be dropped
because the agent was not in the possession of copies of the B/Ls which had been forwarded
from Far East directly to the final port of destination. The vessel departed without the rest of the
cargo with marginal stability.
In the port of unloading the receipt of the broken batches was denied. The containers had to be
re-loaded with uncertain commercial consequences. At this occasion the master could take a look
into the shipping documents where it quickly turned out that the booking lists did not reflect the
tare weight of the containers and above that there was a difference in weight of 120 tonnes,
needless to mention inconsistencies in the declaration of IMDG containers.
The following claim of consignees reproached the ship's command with wrong stability
calculation, wrong ballasting and such things.
This case did not end with an accident like a similar case described in the document
SLF 42/INF.6. But it makes clear that masters of certain vessels, not low in number, are in need
of tools to assess the stability of their ships in a fast and accurate manner, which is also accepted
by other commercial parties. This assessment should be independent from any booking
documents or remote tank gauging device readings. These masters are also in need of support by
mandatory intact stability criteria.

• "Rautz"
On Monday, 13th July 1998, at about 01.00 hours, the Austrian flag multi purpose vessel "Rautz"
capsized and sunk west of Gibraltar straits with a cargo of about 2950 t copper ore concentrate on
her way from a North African port to Poland.
Six of the ten persons on board survived in a life raft, including the master, and were rescued by
a fishing vessel about two days later. The fishing vessel had been directed to the survivors by an
SAR-plane within the search action triggered by the EPIRB of "Rautz".
An investigation of the accident, initiated by the Austrian Maritime Authorities, revealed the
following facts:
• The master had accepted the cargo for loading without having received the demanded
certificate from the shippers, indicating the moisture content of the fine-grained material.
He had assured himself by close inspection of the cargo and different tests, that it were
safe for carriage, also considering his past experience with such cargoes. The cargo was
loaded and the ship sailed close to midnight on 11th July.
• There were no signs of lack of seaworthiness of the vessel. Ship and company had been
certified according to ISO and ISM-Code. The weather during voyage prior to the
accident was fine with moderate wind and swell. There was no significant rolling or
pitching of the vessel.

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• When the first list of the vessel of about 5° was discovered in the evening of the 12th July,
an immediate inspection of the two cargo holds showed that a small portion of the cargo
in the after parts of both cargo holds had liquefied in the form of slurry. The majority of
the cargo appeared firm and dry.
• Course and speed of the ship were adapted to reduce ship motions and to a head for a port
of refuge at the Portuguese coast. The crew was alerted and assembled. Some ballast was
taken in to reduce the list. Inspections were repeated at about hourly intervals. The
situation appeared to remain stable.
• At about 01.00 hours the list increased again fairly rapidly and then the ship turned over
to 90° within about one minute. Eight of the crew managed to assemble on the side of the
vessel and six of them emerged after the vessel had disappeared a few minutes later. They
manned one of the two life rafts released from the sunken ship.
• A certificate approving the suitability of the cargo for sea transport was issued in the
loading port on 13th July, the day when the vessel had capsized at 01.00 hours. The
investigation proved that not only the visibly liquefied part of the cargo had shifted. Also
the apparently dry part shifted on a "wet foot", where compression had caused saturation
with water.
This stability accident has a completely different character compared to the previous cases.
Minimum stability criteria did not play a role at all. Instead, there were deficiencies in
information exchange and in the appreciation of the critical nature of the cargo leading to a fatal
result in the end. The master had virtually no chance to avert the capsize of his vessel once the
liquefaction of the cargo had started.

• Present status of the IMO Intact Stability criteria

• Relation to SOLAS and other Conventions

The Code on Intact Stability for all Types of Ships Covered by IMO Instruments comprises the
annex to Resolution A.749(18). In this resolution the IMO Assembly recognises the need for
development of an internationally agreed code on intact stability and invites Governments
concerned to use the provisions of the Code as a basis for relevant safety standards, unless their
national stability requirements provide at least an equivalent degree of safety. This recognition
and invitation present a high level of importance given to the Code. However, in its Preamble the
Code is clearly denoted as providing recommended provisions and the criteria being based on the
best "state of art".
SOLAS, Regulation II-1/22 on Stability Information for Passenger Ships and Cargo Ships
requires to provide a stability booklet on board to enable the master to determine the ship's
stability and also to have an initial inclining test carried out to establish the necessary light ship
particulars. The Code on Intact Stability is addressed to in a footnote only, together with the
MSC/Circulars 456, 706 and 707.
SOLAS, Regulation II-1/25-8 repeats, in the context of damage stability for cargo ships built
after 1992 and after 1998, the requirement of having sufficient documents for the assessment of
stability on board, in particular curves or tables of minimum metacentric height or maximum KG,
according to applicable intact and damage stability criteria. However, the intact stability criteria
themselves are neither described, nor a reference is given to the IMO Code on Intact Stability.
This particular SOLAS Regulation is remarkable insofar as it prescribes the provision of limiting
curves or tables based on relevant intact stability requirements and the requirements of
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regulations 25-1 to 25-6, i.e. on intact stability criteria acceptable to the flag state and on
mandatory damage stability requirements laid down in the Convention. In many cases the
requirements from damage stability supersede those of the intact stability, depending on the
individual design and sub-division of the vessel, and the actual draught and trim.

The International Load Line Convention contains in Annex I, Chapter I the principal provision
that the rules under this Convention imply sufficient stability and the observation of all
internationally applicable regulations on stability. Thus, a ship may be considered being
over-loaded in a legal sense, if there is deficient stability, although it remains unclear, which
"yardstick" shall be used to define the borderline between sufficient and deficient stability.
Another similarly vague reference to the provision of sufficient stability documents to the master
can be found in Regulation 10 of the Annex.

MARPOL, Regulation I/25A contains mandatory intact stability criteria for oil tankers of
5000 tdw and above, built after 1999/2002. These criteria are identical with those stipulated in
Chapter 3.1 of the Code on Intact Stability. In addition, Regulation I/25A requires for these
tankers a minimum GM, corrected for free surfaces, of 0.15 m during stay in port.

Another important reference to the IMO Code on Intact Stability is found in MSC/Circ.707,
containing Guidance to the Master for Avoiding Dangerous Situations in Following and
Quartering Seas. The applicability of this guidance for operating a vessel at sea is connected to
the condition that IMO stability criteria are satisfied.

Altogether, with the exception of MARPOL Regulation I/25A, and the very successful "Grain
Code" (Resolution MSC.23(59)), the legal weight of the IMO Intact Stability criteria appears to
be very low. There is, indeed, no explicit recommendation on their use, neither in the SOLAS
Convention nor in the Load Line Convention or any other mandatory Codes. There is just a
reference by a footnote in SOLAS, which legally is not part of the Convention.

• Status perceived by ship owners and mariners

Ship owners or ship managers and ship masters are obliged, since 2002 latest, to run their ships
under the regime of the ISM-Code. This Code requires to perform so-called key shipboard
operations in accordance with prepared plans and instructions issued by the Company. A limited
survey among shipping companies has revealed that the instructions regarding the onboard
management of stability simply refer to the approved loading and stability manual without
reference to specific intact stability criteria. Thus the application of the IMO Intact Stability
criteria depends on the flag the vessel flies.

However, in all cases of the limited company survey, covering different flag registers, it were the
IMO Intact Stability criteria which were practically used, and in some cases the interviewed
persons were even unaware of the recommendatory status of these criteria. They considered them
as mandatory. This applies to many ship masters and officers as well.

• Status perceived by carriers (charterers) and shippers

Carriers, often today charterers of tonnage, and their clients the shippers, feel mainly bound to
the freight contract based on private law. Although the safety of the vessel and the safe
performance of the voyage plays an important role in these contracts there is no mentioning of
technical details of stability in them. As the responsibility for the safe conduct of the voyage
remains with the master who represents the owner, he has to defend the vessel against undue
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expectations of the carrier, e.g. regarding the amount of deck cargo affecting the stability, and
against the implications of incorrect cargo information supplied by the shipper.

It remains unclear whether both, carriers and shippers, are generally aware of the presently
recommendatory status of the IMO Intact Stability criteria. However, there is a vague impression
that both, carriers and shippers, perceive limits of ship's stability as a negotiable issue.

• Status perceived by flag State authorities

The perception of the IMO Intact Stability criteria by flag state authorities differs largely. It
appears that most traditional flag states have adopted the IMO Intact Stability criteria to a great
extent but use national modifications. A limited survey has shown that the criteria listed in
chapter 3.1 of the IS-Code are generally applied while certain types of ships are exempted from
the application of the weather criterion in Chapter 3.2, and a selective use is made of the special
criteria in chapter 4 of the IS-Code. These modifications appear to provide an at least equivalent
level of safety against capsizing and are generally laid down in national legislation.

There are some other flag states who have adopted the IMO Intact Stability criteria without
modification as national law or apply them without legal approval, mainly by commissioning a
classification society with the technical approval of vessels applying to fly their flag.

• Status perceived by port State authorities

Port state authorities are generally bound to international mandatory legal instruments as basis
for their inspection and detention regimes. The non-mandatory status of the IMO Intact Stability
criteria presently prevents the implementation of "stability inspection campaigns" beyond the
control of documents that must be on board under SOLAS regulations.

This restriction does not apply to the inspection of "grain stability" where the mandatory Grain
Code provides the necessary legal instrument for substantial controlling by port states.

• Status perceived by classification societies and underwriters

Classification of ships is a private law issue introduced in the 19th century as a tool of risk
assessment for hull and machinery underwriters. Sufficient stability is an indispensable safety
parameter. Therefore all IACS-classification societies and most other classification societies
apply the IMO Intact Stability criteria or equivalent criteria of the particular flag state for the
classification of ships.

It should be noted that in many cases classification societies also act on behalf of the flag state
when stability documents of a new or converted vessel are assessed and approved.

• Status perceived by naval architects

The Code on Intact Stability and the stability criteria therein play an important role within the
practical design process of a ship, in particular of containers ships, where stability limits are the
prevailing parameters for the cargo carrying capacity. Since the charterer may change several
times during the life-time of a vessel, most owners are interested in a common yard-stick for her
stability and agree on the application of IMO criteria in the building contract, unless the intended
flag state requires a modification.

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This becomes quite obvious for design bureau's and software producers who are prepared to offer
all national variations of the IMO criteria to their customers on demand.

Another more critical issue among naval architects is the suitability of the IMO Intact Stability
criteria for new types of vessels, e.g. large passenger cruising vessels and fast ferries. An ongoing
scientific discussion questions the applicability of the existing criteria for vessels other than those
for which these criteria have been developed. In particular the "statistical" criteria in chapter 3.1
of the IS-Code are prone to being "misused" in design optimisation [1].

This, however, addresses the challenge of developing new criteria, providing an equivalent level
of safety and adapted to the needs of new ship types and their desired performance. The
worthiness and value of the existing criteria for more conventional ships remains unquestioned
among ship designers and approving authorities.

• National stability criteria

This chapter is intended to give a short insight into the nature of some national applications and
modifications of the IMO Intact Stability criteria, selected by availability. It can be seen that the
development of national intact stability criteria in traditional shipping countries has an own
history in most cases but has common grounds with IMO criteria, the research work by Rahola in
the early 20th century.

• Australia

Australia4 gives mandatory effect to the criteria of chapter 3.1 of the IS-Code, contained in
Appendix 2 to Marine Orders Part 12. Australia gives mandatory effect to the weather criterion
of chapter 3.2 of the IS-Code in relation to passenger ships only, but may also require it to be
applied to fishing vessels of 45 m in length and above and to high-sided cargo ships, e.g. car
carriers.

With regard to chapter 4 of the IS-Code effect is given to various sub-chapters as follows:

• Mobile offshore drilling units must comply with the criteria specified in sub-chapter 4.6
of the IS-Code.
• Pontoons must comply with the criteria specified in sub-chapter 4.7 of the IS-Code.
• Dynamically Supported Craft (DSC) must comply with the criteria specified in
sub-chapter 4.8 of the IS-Code.
• Offshore supply vessels, which cannot comply with specified national criteria, may
comply with requirements reflecting sub-chapter 4.5.6.2 of the IS-Code.
• Ships carrying timber on deck may be permitted to comply with the criteria specified in
sub-chapter 4.1 of the IS-Code in place of specified national criteria.
• Container ships of a length greater than 100 m may be permitted to comply with the
criteria specified in sub-chapter 4.9 of the IS-Code.

• Germany

Germany had used national criteria until 31st March 2001. After that date the IMO Intact Stability
criteria have been made mandatory for new ships with the keel laid on 1st April 2001 or later. The

4
http:/ / www.amsa.gov.au/sd/mo/MO_main/MO12.pdf

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main features of the previous national criteria, which are still applicable for existing ships under
German flag, are:

General criteria:

− GZ30 ≥ 0.20 m for L ≤ 100 m,

− GZ30 ≥ 0.002⋅L for 100 < L ≤ 200 m,
− GZ30 ≥ 0.40 m for L > 200 m,
− GMC ≥ 0.15 m,
− A30 ≥ 0.055 m⋅rad,
− A40 ≥ 0.090 m⋅rad,
− A30-40 ≥ 0.03 m⋅rad,
− Range of positive GZ values ≥ 50°,
− GZ30 to be increased by 1 cm for each degree of range less than 60°.

Ships with large windage area, except passenger vessels:

− Consideration of wind pressure 0.3 kN/m2 in coastal voyages, 0.6 kN/m2 in short range
voyages, and 1.0 kN/m2 in medium and long distance voyages; heel less than 18° or less
than an angle producing 10% residual freeboard on the low side.

Container vessels with mass of deck cargo exceeding 10% of cargo in holds:

− Wind heel criterion as above, and

− GMC ≥ 0.30 m for L ≤ 100 m,
− GMC ≥ 0.005⋅L – 0.2 for 100 < L ≤ 120 m,
− GMC ≥ 0.40 m for L > 120 m.

There are special additional criteria for tankers, pontoons, tugs, passenger vessels, hopper
dredgers, offshore supply vessels, vessels carrying timber on deck, vessels carrying crushed coke
on deck, and ships handling heavy lift units with own gear. As mentioned above, these criteria
have been replaced by the IMO Intact Stability criteria for new ships from 1st April 2001.

• Japan

Japan applies chapters 3.1, 3.2 and 4.1 (only) of the IMO Code on Intact Stability for cargo ships
as mandatory criteria. However, for passenger ships and for fishing vessels national criteria
apply5.

These national criteria provide, according to a sample calculation carried out in 1995, almost the
same limiting GM-values as those by the IMO IS-Code. Critical GM-values found by the IMO
weather criterion are slightly smaller than those by the Japanese weather criterion.

In this way Japan applies the IMO Intact Stability criteria in general, with modifications for
certain ships. These modifications are at least equivalent to IMO criteria standards.

5
described in: Yamagata, M., Standard of Stability Adopted in Japan, Transaction of RINA, Vol. 101, 1959

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• Sweden

Sweden applies chapter 3.1 of the IMO Code on Intact Stability for cargo ships as mandatory
criteria with one exception, that is, the maximum righting arm shall occur at a heeling angle of at
least 30° instead of 25°, and one additional requirement for a range of positive stability of at least
60°. Both modifications can be considered as more demanding for ships with low freeboard.

The weather criterion according to chapter 3.2 of the IMO Code on Intact Stability is not used.
The IMO special criteria in chapter 4 of the IS-Code are applied for ships carrying grain in bulk,
for supply vessels and for mobile offshore drilling units.

Sweden has additional criteria as follows:

− Ships with a length of less than 24 m shall have a righting arm GZ at 60° heel of at least
0.2 – L/120.
− Ships with certain design parameters may be permitted a range of positive stability
(φvanish) of less than 60° and a maximum GZ at an angle of less than 30°, but not less than
15°, if compensated by an area under the righting arm curve of at least 0.055 + 0.001 ⋅
(30° − φ) m⋅rad counted to an angle φ, which is the smaller of φGZmax and 0.5⋅φvanish.

There are criteria deviating from IMO criteria, but presumably equivalent, for

− passenger vessels, road ferries and unmanned barges in coastal trade,

− passenger vessels in unlimited trade,
− tugs,
− fishing vessels,
− sailing vessels,
− ships with timber on deck, and
− ships carrying solid bulk cargoes.

• USA

The Code of Federal Regulations contains in Subchapter "S" on Subdivision and Stability within
the Parts 170 to 174 a number of regulations with regard to intact stability criteria.

Section 170.170 describes a weather criterion that is applicable for all ships, unless superseded or
replaced by special requirements. This weather criterion is in fact a wind criterion with wind
pressures modified according to trade areas and aiming at limiting heeling angles to 14° or less to
immerse not more than one half of the freeboard of the vessel. The result is a minimum GM,
which increases with reduced freeboard.

Section 170.173 contains criteria for vessels of unusual properties and form up to 100 m length.
These criteria are in fact identical to those of chapter 3.1 of the IMO Code on Intact Stability, but
they present a modification for ships with a maximum GZ at a heeling angle of less than 25°.

Section 171.050 contains special criteria for passenger vessels, section 171.055 for monohull
sailing vessels.

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There are further sections for special ship types as follows:

− barges carrying hazardous liquid substances (section 172.090),

− gas tankers during cargo transfer (section 172.165),
− vessels engaged in lifting operations (section 173.020),
− vessels engaged in lifting operations, counter-ballasted (section 173.025),
− deck cargo barges (section 174.015),
− mobile offshore drilling units (section 174.045),
− tugboats, towboats (section 174.145),
− offshore supply vessels (section 174.185).

It should be noted that all the above criteria apply to ships approved according to the Code of
Federal Regulations. However, the majority of US cargo vessels obtain SOLAS certificates and
must therefore comply with the criteria of the IMO Code on Intact Stability.

• Common practice of ship stability management

• Ships with critical operational stability

The operational stability of a ship may become critical, either by the way she is loaded with
cargo or by the way she behaves or is handled in rough seas.

Ships designed to carry a considerable proportion of their cargo on deck, are more frequently
operated close to their stability limits. These are typical modern container vessels, in particular
the smaller container feeder vessels, ships carrying timber on deck and in some cases also
ro/ro-vessels. These ships require regular and close attention to statutory stability limits during
cargo operations.

Another cargo related threat to stability is introduced by cargoes that are liable to shift. These are
bulk cargoes in general with specific emphasis on grain and on minerals liable to liquefaction,
and non-bulk cargoes with difficult stowage and securing like vehicles, steel coils and other
break bulk cargoes. In this context it is important to note that shifting of cargo is often triggered
by excessive stability in a seaway that is not necessarily exceptional. Proper stowage and
securing is the most important means of controlling stability in these ships.

In certain cases also liquid bulk cargoes, in particular mineral oils, can cause stability problems
during loading or unloading, if carried on so-called "Single Tank Across Design" (STA) tankers
or on Ore-Bulk-Oil (OBO) carriers. These "tankers" do not possess an overall transverse
subdivision that excludes negative initial stability in any possible intermediate stage of loading
and ballasting. Therefore the observation of approved loading and ballasting sequences is
imperative in these ships.

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Figure 1.5: Typical low freeboard feeder vessel of about 700 TEU

The behaviour of ships in rough seas depends a lot on their under water hull form, their windage
area and their speed capacity. In particular the under water hull form of modern container ships,
ro/ro-vessels and passenger vessels shows a pronounced bow and stern flare with otherwise fine
lines. This creates periodic fluctuations of stability in large head or stern seas and bears the risk
of parametric resonance.

A large windage area, although providing a considerable roll damping in strong winds, may
create a dangerous heel, unless counteracted by large initial stability. However, large initial
stability may be a drawback with regard to harmonic resonance.

Speed capacity, if used recklessly, can be another threat to stability, in particular in stern or stern
quartering seas, causing pure loss of stability on a wave crest or surf riding and broaching to.

• The role of the owner, the charterer and the shipper

Safe transport of goods by sea, in particular in the container trade, is today markedly
characterised by the splitting of interests between the charterer and the owner. The owner, or
managing owner – in the ISM-Code addressed to as the Company – is responsible for the safe
operation of the ship. He will have to identify potential risks and to establish procedures for the
safe conduct of so-called key shipboard operations. Monitoring and managing ship's stability is
certainly a key issue on a container vessel. Great effort can therefore be expected from the master
of the vessel in keeping cargo distribution, ballast management and cargo handling operations
under control.

The charterer of the vessel is in principle interested in the optimal use of the vessel's cargo
carrying capacity and speed potential. The time or voyage charter party of course contains the
necessary restrictions to the use of the vessel for protecting the interest of the owner regarding
safety and integrity. However, the non-mandatory status of the IMO Intact Stability criteria may
weaken the implementation and observation of strict stability limits under the gentle pressure
exerted to the master by the charterer's super cargo, even if the flag state of the vessel has
adopted these criteria or appropriate national criteria in a mandatory regulation.

The third important partner is the shipper. His contract with the charterer is governed by the
freight contract, laid down in the Bill of Lading. In this document the gross weight of the goods
to be transported has to be declared by the shipper. The clauses attached to a Bill of Lading
usually contain a provision reading: "The Shipper warrants to the Carrier that all details given
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by him to the Carrier ... are correct." It is consistent that another clause reads: "The Shipper shall
indemnify the Carrier against all losses, damage, fines and expenses, arising from any breach of
any of the warranties." In that way the carrier, i.e. the charterer, protects himself against liability
for damages and losses caused by incorrect declaration of cargo weights. But this does neither
protect the owner's interest nor the lives of his people on board. This is left to public legislation
and thereby without consequences, unless inconsistencies are denounced to authorities or an
accident has happened.

SOLAS, Regulation VI/2 requires: "The shipper shall provide the master or his representative
with appropriate information on the cargo sufficiently in advance of loading to enable the
precautions which may be necessary for proper stowage and safe carriage of the cargo to be put
into effect. Such information shall be confirmed in writing and by appropriate documents prior to
loading the cargo on the ship.

The cargo information shall include, in the case of general cargo, and of cargo carried in cargo
units, a general description of the cargo, the gross mass of the cargo or of the cargo units, and
any relevant special properties of the cargo. For the purpose of this regulation the cargo
information required in sub-chapter 1.9 of the Code of Safe Practice for Cargo Stowage and
Securing, adopted by the Organization by resolution A.714(17), as may be amended, shall be
provided.

Prior to loading cargo units on board ships, the shipper shall ensure that the gross mass of such
units is in accordance with the gross mass declared on the shipping documents."

This regulation is clear and well understood by all parties concerned. But obviously, there are a
number of mechanisms, which by intent or unintended cause a notorious misinformation on
cargo weights, in particular within the complicated network of long distance carriers and
sub-contractors, who operate feeder vessels.

• On-board stability monitoring and assessment

The typical procedure of on-board stability monitoring and assessment has been demonstrated in
the above case studies. The usual procedure for container feeder vessels and other dry cargo
ships, where stability may become the critical parameter during down loading, is:

• There is a cargo booking process well in advance of the arrival of the ship. This task is
carried out by the carrier's agents in the loading port or, in certain cases, in a regional
planning centre of the carrier. Along with this booking the agents have to take care that
the vessel will not be overbooked in terms of dead weight and in terms of stability. In
some cases this task is solved by the preparation of a complete stowage plan and
associated computer based stability and draught calculation. In other cases only a rough
estimation on the suitability of the booking is made.

• The cargo information used in this booking process originally comes from the Bill of
Lading, which has been issued by the principal carrier, who is often responsible for the
full distance of a multi modal transport. Extracts of these data are assembled in cargo
manifests. However, it seems not unusual that a sub-contracting carrier's agent will not be
supplied with these manifests, for commercial reasons, but will receive only a simple
cargo list.

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• The booking list and/or the prepared stowage plan is presented to the master of the vessel
on arrival in the loading port. Somehow, the master has to approve this plan or advise
alterations in a very short time, generally in less than half an hour. This process is assisted
by the chief officer who generally uses the ship's approved loading and stability computer
to check the proposal against stability criteria, load line requirements, sight line
requirements and commercial parameters. Cargo operations are started in the mean time
and any alterations to the plan must be advised to the stevedores and the terminal
operators as soon as possible. Particular attention must be paid to the commercial
procedure of feeder vessel operators who declare "open booking end" to their customers,
allowing the latter to bring cargo alongside until the vessel is bound to sail.

• It should be noted that this process takes place immediately after the ship has arrived
from a more or less strenuous sea passage, port entry and mooring procedure, with port
entry clearance administration people sitting in the ship's office, charterer's agents and
stevedores advising or waiting for orders. In short, the important decision on cargo
distribution has to be made under time-pressure in an atmosphere of stress and under the
possible effects of fatigue. This situation will repeat in short intervals, in particular in the
container feeder trade.

• During cargo operations, consisting of simultaneous unloading and loading in general, a

close supervision must be exercised by the ship's staff with regard to:

− Complying with the stowage plan as approved by the master.

− Deciding on suitable deviations from the stowage plan, if late changes of the
booking list are advised.
− Monitoring the correct stowage of dangerous goods according to the approved
plan.
− Carrying out appropriate ballast operations following a pre-arranged plan,
controlling list and trim.
− Checking cargo intake by draught readings at suitable intervals, associated with
simultaneous tally checks.
− Checking stability by observation of rolling motions from crane operations or
in-service inclining test if available.
− Considering commercial parameters (avoiding re-stow, care for reefer containers).
− Care for and supervision of cargo securing according to approved plan in the
Cargo Securing Manual.

• Although the pre-planned cargo stowage and distribution of ballast should guarantee a
safe passage, there must be a final assessment of sea-worthiness, including the checking
of the water-tight closing of hatches and other openings, the careful pressing up of all
ballast tanks intended to be in a full state, the confirmation of the intended fuel
consumption and transfer modalities from bunker tanks to settling tanks, and the
appropriate documentation within the company's Safety Management System.

However, it appears from accident reports, that in many cases the necessary skill and carefulness
with these tasks of ship masters and cargo officers suffer from lack of education, experience, or
simply lack of motivation, superimposed by fatigue. Thus it may happen that ships sail with
insufficient stability, although these cases are not too frequent in number.

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There is, in particular, the occasional observation of incorrect interpretation of intact stability
criteria. The use of KG-limits or GM-limits, given on board in the form of curves or tables
according to SOLAS Regulation II-1/25-8, should rule out any doubt about the required
minimum stability. But the awareness of certain easy to retain specific criteria like the minimum
GM of 0.15 m has been found to create serious mistakes. If, e.g., a GM of 0.30 m is actually
obtained in an assessment, while the minimum table requires 0.60 m, the responsible officer or
master may still be satisfied by the conception that the limiting table is not complied with but the
minimum GM still exceeded by 100% and the ship may sail safely.

Another simple "trick" is to trim the vessel by the stern and thereby increase the KM-value. In
this way KG can be further increased, without violating GM-minimum requirements. The
outcome of this procedure is often deficient stability with regard to righting levers beyond
20° heel.

• Practical consequences of deficient departure stability

When considering the practical consequences of deficient departure stability, it appears useful to
distinguish unknown deficient stability, suspected deficient stability, and tolerated deficient
stability.

Unknown deficient departure stability, as being a possible result from unknown errors in light
ship data or other ship's parameters, but mainly from incorrect cargo figures, unreliable ballast
management or wrong interpretation of stability criteria, is obviously the most dangerous option.
Minor additional effects on stability, like fuel oil transfer, trim corrections by ballast, crane
operations, tug assistance, hard rudder, and even moderate wind and seaway can trigger the
disaster, often accompanied by a shift of cargo in the late stage of the accident. Unknown
deficient stability is often also the source of unsuitable counter-measures against an unexpected
heeling of the ship. Most stability accidents can be considered as resulting from unknown
deficient departure stability.

Suspected deficient departure stability, which is sometimes a permanent burden of masters and
mates on container feeder vessels, is much less dangerous. The awareness of the possible
deficiency leads to an increased care-taking with regard to all of the above mentioned effects on
stability. It can further cause the master to attempt an additional assessment by an in-service
stability measurement. However, the consequences of a measuring result, which might reveal
deficient stability, are not easily accepted and appreciated by charterers, terminal operators, and
shippers. Masters, who have refused further loading after having proved deficient departure
stability, have been "sacked" in some cases and replaced by another more daring, not to say
foolhardy individual. Thus, it is not unusual, that masters choose the "silent" solution that is
ballasting after de-berthing to improve the stability, without respecting the Plimsoll mark.

Tolerated deficient departure stability, with regard to IMO Intact Stability criteria or other
equivalent criteria, presents a legal situation that is open for a wide discussion as long as no
accident happens, i.e. the ship arrives safely at the destination. There are only rare cases where
authorities detect deficient departure stability prior to sailing of the vessel.

In a case where the flag State has adopted the IMO Intact Stability criteria or other equivalent
criteria as national mandatory regulation, authorities in a port of the flag State will be entitled to
detain the vessel until the criteria are complied with. The same will not necessarily work in a
foreign port by local port state authorities.

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If neither the IMO Intact Stability criteria nor other equivalent criteria are adopted as national
law there is generally no legal means to detain the vessel in any port, unless the deficiency of
stability appears as an obvious or immediate threat to the port environment and the people on
board. However, the discussion following a detention on how far the stability must be improved
until the vessel can be released, suffers considerably from the presently non-mandatory status of
the IMO Intact Stability criteria.

The legal situation appears more simple considering private law. A tolerated deficient departure
stability is not made public by the owner or charterer. It does not come to the knowledge of the
designated classification society or the underwriters. The validity of the classification certificate
is not affected. Nothing will happen as long as no accident occurs. However, there will be severe
legal consequences regarding loss of insurance protection of the owner and also regarding the
right of limiting liability of the charterer, if an accident has happened resulting from such
deficient stability.

In this case, there may also be a public prosecution of the master for neglecting principal
obligations resulting from the International Load Line Convention and for disregarding
recommended standards, if the accident can be attributed to ignoring IMO Intact Stability
criteria.

The practical consequence of tolerated deficient departure stability will be an extremely careful
master in avoiding additional threats to stability, like turning the ship with hard rudder at high
speed or tank adjustments with undue free surfaces. Additionally, the tolerated margin below the
criteria level will be kept limited, contrary to a situation with unknown deficient stability, where
GM and other relevant stability parameters have been found close to zero in some cases.

Summary of hazard identification

This Formal Safety Assessment is directed to the consequences of making the presently
recommendatory IMO Intact Stability criteria mandatory. This task requires a specific
investigation of the hazards, which can be avoided or minimised by a mandatory status of these
criteria. The following definition of a stability accident of a vessel, either in port or at sea, has
been proposed for the purpose of this study:

• a ship capsizes, or
• a ship suffers a large heeling angle, or
• a ship suffers heavy rolling.

A close investigation of the mechanisms, which can lead to such accidents, has shown that the
classical threat, heavy weather with severe wind and waves, is not the dominating influence.
Instead, there are a number of other more trivial but nonetheless stochastic parameters, in
particular inadequate loading control procedures, which may lead to either

• unknown deficient departure stability,

• suspected deficient departure stability,
• tolerated deficient departure stability.

These situations, if combined with other usual effects and threats to stability including heavy
weather, can lead to a stability accident.

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From the underlying mechanisms it appears that a limited scope of ship types is affected and
should be given priority with regard to legal measures of protection against stability accidents.
These are in particular container feeder vessels, break bulk vessels carrying timber or other cargo
on deck and in some cases also ro/ro-vessels, because stability criteria determine the operation
and profit of these vessels.

Stability accidents according to the above definition can also be the result of excessive stability,
in combination with shifting of cargo. However, this situation has not been included into the risk
assessment within this study, because excessive stability is not addressed by the present IMO
Intact Stability criteria, and will therefore not be controlled by a mandatory status.

The IMO Intact Stability criteria, although not being mandatory, are already widely applied in
ship design, ship approval and ship classification. An obviously large number of flag states have
them in place as national regulation, often with modifications, which provide an at least
equivalent level of safety, measurable by the mandatory GM- or KG-limiting curve for a
particular ship. Port state control authorities, however, are not readily in a position to expand
their inspection regime to stability matters beyond document control, due to the lack of a legal
instrument, i.e. mandatory criteria.

• Risk assessment

• Methodology

The principal methodology to be applied in an FSA on the present task is the determination of the
absolute risk of capsizing of representative types of seagoing vessels during their life-time.
Within this determination the influence of the non-mandatory status of the IMO Intact Stability
criteria on that risk must be established. In a second step the change of risk due to making these
criteria mandatory must be identified. This change of risk should appear as a reduction, which
can then be compared with the effort, cost and other consequences of making the criteria
mandatory.

To make it perfectly clear, it is not the suitability of the present IMO Intact Stability criteria that
shall be investigated, as discussed in [1], but their application dependant on their legal status.
These criteria are applied within two main areas, that is ship design and ship operation.

The ship types being considered are those where the use of stability criteria during operation is
considered important and a change of risk can be expected from a change of the legal status of
those criteria. These ships are:

• Container vessels,
• Ro/ro-vessels,
• Multi purpose (break bulk) vessels.

This selection excludes bulk carriers and tankers. Bulk carriers in fact suffer from stability
accidents at times due to shifting of cargo, but not due to insufficient observation of stability
criteria. Tankers, in particular those with critical design parameters (STA-design or
OBO-carriers), are obliged to satisfy mandatory criteria as set out in MARPOL,
Regulation I/25A. Also passenger vessels are excluded, because there are no distinguished
mechanisms of compromising stability by the non-mandatory status of the IMO Intact Stability
criteria.

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• Hazard and Operability Study (HAZOP)

A Hazard and Operability Study is a basic analysis of procedures, events and possible deviations,
which can cause accidents. It is carried out generally without considering the probability of
events and critical deviations in the first place, but with the aim to generate the basis for a
quantified risk assessment.

The deciding parameters leading to a ship departure with deficient stability measured against
intact stability criteria are external sources, mainly:

− ship design and approval below IMO Code on Intact Stability standards,
− errors in light ship data as documented for onboard use,
− errors in cargo information supplied to ship planners and/or to the master of the vessel,

and lack of ship staff competence, leading to:

− errors in the assessment of stability, including errors in tank management,

− misinterpretation of applied intact stability criteria, and
− neglecting intact stability criteria.

Another frequent event, excessive departure stability, can be attributed to both, external sources
and lack of operational competence, and may also result in a stability accident via the
mechanisms of poor ship behaviour in waves and subsequent cargo shifting. But this cannot be
easily related to the influence of the legal status of intact stability criteria.

After a ship has departed with deficient stability, a number of further events are usually necessary
for triggering a stability accident. These are mainly:

− operational events, like turning at high speed, normal towing operations, dry-docking,
additional free surfaces, usual tank adjustment and operational increase of top masses,
− heavy weather or extremely heavy weather, combined with unsuitable course and speed,
− consequences of heavy weather, like shifting of cargo and/or ingress of water, and
− wrong counter measures in an early state of the accident.

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Figure 2.1 shows the result of a relevant Hazard and Operability Study.

Lack of ship staff competence:

External sources:
Faulty assessment of stability
Ship design and approval
below standards Misinterpretation of stability criteria
Errors in light ship data Neglecting stability criteria
documents intentionally
Errors in cargo information Excessive departure stability

Unknown deficient stability Known deficient stability at Excessive stability at

at departure departure departure

Additional events: Perils of the sea: Perils of the sea:

Usual turning at high Heavy weather Extremely heavy
speed weather
Unsuitable course
Normal towing assistance
Shifting of cargo
Usual dry-docking
Ingress of water
Usual tank adjustments
Operational increase of
top masses

Inappropriate counter Inappropriate counter Unsuitable ship

measures measures handling

Stability accident
Figure 2.1: Procedures and events leading to a stability accident

• Event Tree Analysis of stability accidents (ETA)

An event tree analysis combines possible pre-conditions, events and counter-measures, which in
combination may lead to a stability accident. The pre-conditions, events, and counter-measures
are given individual probabilities, derived from statistical analysis and/or expert opinion. A
mathematical processing of these individual probabilities, reflecting the appropriate logical
connection (AND, OR, EXOR), will lead to the final probability of a stability accident.
Calibration of this final result by means of casualty statistics increases the reliability of the
model.

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The following parameters are of importance, related to critical types of ships, which may lead to
unknown and to known deficient departure stability. The category known comprises of
suspected and tolerated deficient stability, having the common feature of raised awareness.

Number of ship departures per year at stability limits = dp

Proportion of those ships with incorrect light ship data = p1
Proportion of severely wrong cargo information at these departures = p2
Proportion of severe errors within stability assessment at these departures = p3
Proportion of misinterpreted stability criteria at these departures = p4
Proportion intentionally neglected stability criteria at these departures = p5

The event "ship design and approval below IMO Code on Intact Stability standards" has not been
included into the above list of parameters, because it seems that the vast majority of shipyards
and classification societies keeps design and at least class approval within these standards.

The in fact important issue of departures with excessive stability has been left out as well,
because there is no direct relation to the legal status of the IMO Intact Stability criteria.

Deficient departure stability must be combined with additional events to create a stability
accident. There are a number of events of normal routine ship operation, which can happen in
AND/OR-combinations. They may cause an accident if AND-combined with unknown deficient
stability only, because it can be assumed that these events are avoided if the deficient stability is
known to the master. The relevant probabilities are:

Probability of usual turning with hard rudder at high speed = p6

Probability of severe transverse pull during towing assistance = p7
Probability of a critical situation during dry docking = p8
Probability of usual tank adjustment including free surface effects = p9
Probability of temporary additional top masses during operation = p10

Another event, which cannot be avoided in general, is heavy weather and extremely heavy
weather. These two issues are distinguished by the assumption that extremely heavy weather will
cause an immediate capsize if deficient stability is present and wrong ship-handling is applied by
the master, while normal heavy weather tends to require additional events like cargo shifting
and/or water ingress for that outcome. The relevant probabilities are:

Probability of meeting heavy weather = p11

Probability of steering an unfavourable course = p12
Probability of a severe cargo shifting or asymmetrical loss of deck cargo = p13
Probability of severe water ingress = p14
Probability of unsuitable remedial measures in case of heavy list = p15
Probability of meeting extremely heavy weather = p16
Probability of improper ship handling in an extremely heavy weather = p17

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The above probabilities have been calibrated in such a way that their appropriate combination
just produces one stability accident, i.e. a situation where the ship capsizes or suffers a heavy list
or dangerous rolling. Figure 2.2 shows the arrangement of the Event Tree Analysis.

Number of departures per ship

and year at stability limits

AND AND

Incorrect light ship data

AND/OR Intentionally neglected stability criteria
Severely wrong cargo information
AND/OR
Severe errors within stability assessment
AND/OR
Misinterpretation of stability criteria

Number of departures with unknown Number of departures with known

deficient stability deficient stability

AND AND AND AND AND

Usual turning with hard Heavy weather Extremely heavy weather

rudder at high speed AND
AND/OR Steering an unfavourable
Severe transverse pull course
during towing assistance
AND/OR
Critical situation during dry AND
docking
AND/OR
Usual tank adjustment Severe cargo shifting or AND
including free surface effects asymmetrical loss of deck
AND/OR cargo
Temporary additional top AND/OR
masses during operation Severe water ingress

AND AND

Unsuitable measures in Unsuitable measures in Improper ship handling in

case of heavy list case of heavy list extremely heavy weather

Number of accidents type 1 Number of accidents type 2 Number of accidents type 3

per ship and year per ship and year per ship and year

Figure 2.2: Event Tree Analysis

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Accident type 1 is generally not a capsize, but will often end in a severe list (refer to the case
"Sun Breeze"). Cargo shifting can be involved as well, but this is not shown in the ETA above,
because it should not be considered as deciding.

Accident type 2 can also end with a large heeling angle. Cargo shifting is more important here,
because a heavy seaway will cause repeated heavy rolling motions with an increased probability
of cargo shifting.

Accident type 3 is the pure capsize in extremely heavy weather, although cargo shifting may
accelerate the process.

The numbers of the three accident types per sensible ship and year is calculated as follows:

Number of departures with unknown deficient stability:

uds = dp ⋅ (1 – (1– p1) ⋅ (1– p2) ⋅ (1–p3) ⋅ (1– p4))

Number of departures with known deficient stability:

kds = dp ⋅ p5

Number of accidents type 1:

acc1 = uds ⋅ (1 – (1– p6) ⋅ (1– p7) ⋅ (1–p8) ⋅ (1– p9) ⋅ (1– p10)) ⋅ p15

Number of accidents type 2:

acc2 = (uds + kds) ⋅ p11 ⋅ p12 ⋅ (1 – (1– p13) ⋅ (1– p14)) ⋅ p15

Number of accidents type 3:

acc3 = (uds + kds) ⋅ p16 ⋅ p17

A sensible estimation of the influencing parameters by experts and a calibration of the results by
means of casualty statistics has provided the following figures:

Entry parameters Results

dp = 10 p5 = 0.10 p10 = 0.02 p15 = 0.10 uds = 1.2449
p1 = 0.01 p6 = 0.10 p11 = 0.15 p16 = 0.01 kds = 1.0000
p2 = 0.06 p7 = 0.02 p12 = 0.20 p17 = 0.03 acc1 = 0.0196
p3 = 0.02 p8 = 0.005 p13 = 0.15 acc2 = 0.0012
p4 = 0.04 p9 = 0.02 p14 = 0.03 acc3 = 0.0007
Within the determination of the important influence p2, i.e. the proportion of severely wrong
cargo information, the usual distrust of masters and cargo officers against these data has been
taken into account. Otherwise the figure of p2 would have been much greater.

The total number of accidents per ship and year will then be 0.0215 or one accident in 46.5 years.
With an estimated number of 6000 sensible ships this is 129 accidents per year. A minimum of
four of these 129 accidents will be pure capsizes in extremely heavy weather. But there will be
some additional capsizes under less extreme conditions (refer to the case "Lime Bay").

• Average cost of stability accidents and monetary risk

A stability accident, as defined for the purpose of this study (see chapter 1.1), has a wide
variation in cost. The most severe option, the capsize, would easily be attributed to a total loss,
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the cost of which would exceed the value of the ship and the cargo by the amount of usually
noninsurable cost of loss of business related to the lost cargo. Additionally, there may be the cost
of wreck removal and loss of business of other parties, if the wreck, e.g. blocks a jetty or port
entrance or river for a certain time.

Most remarkable, however, in the case of a capsize, is the high probability of loss of life. Even if
the process of capsizing is slow or foreseeable there is a high risk that not all persons manage to
clear from the vessel in time and to be rescued.

The less severe options, large heeling, either in port or under way, or heavy rolling with cargo
damage, causes less cost in all aspects and also bears less probability of injury or loss of life, if
there is a chance to get the ship and the possibly shifted cargo under control. The lightest case
would probably cause only some delay to the voyage and the nerves of the master.

Unfortunately, there are no specific statistics available, which distinguish precisely between
causes of stability accidents, as defined above, in particular in the light of deficient stability. It
should be noted that a considerable number of accidents at sea with heavy rolling, subsequent
cargo shifting and potentially ending in a capsize can be attributed to excessive stability, apart
from improper stowage and securing. Therefore estimates gathered from experts, mainly hull and
cargo underwriters must be used to get figures for the costs involved.

These estimates give the following figures, covering the critical ships:

• Three percent of the stability accidents are total losses accountable for 30 Million Euro
per case.
• Sixty-seven percent or two thirds of the stability accidents are moderate cases with
consequences accountable for 400,000 Euro in average per case.
• Thirty percent of the stability accidents are light cases with negligible costs.

These estimates give an average figure of 1.168 Million Euro per case. This figure is combined
with the probability of one stability accident per ship and year of 0.0215 resulting in a monetary
risk of about 25000 Euro per ship and year.

This risk can be compared to the average insurance cost of a 1000 TEU container vessel of about
500000 Euro per year6, including hull and machinery, liability (P&I) and cargo. The figure of
25000 Euro appears plausible, bearing in mind that probably only two thirds of the cost included
in this risk figure are covered by underwriters, and the figure of 25000 Euro applies to ships,
which are sensible with regard to operational stability.

• Estimated consequences of mandatory IMO Intact Stability criteria

• Indirect influence of mandatory criteria

Mandatory intact stability criteria would obviously not have a direct influence on the operational
performance of ships, because the present recommendatory status is widely applied through class
rules and/or distinguished flag state requirements. Moreover, in case of an accident due to
deficient stability the recommendatory stability criteria will generally be treated as standards or

6
Figure obtained also in the Formal Safety Assessment on the proposed expansion of mandatory Emergency Towing
Systems in merchant vessels.

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rules of good seamanship, and any offend against them used as prima facie proof of neglecting
the necessary care, in private as well as in public jurisdiction.

However, there may be a number of indirect influences from a mandatory status of the IMO
Intact Stability criteria. A mandatory status could be used to create a greater awareness of safety
margins among charterers and shippers with a certain improvement of the reliability of cargo
information. The mandatory status could also lead to a certain amount of port state control
activity directed to departure stability of critical ships and hence improve the performance of
onboard stability assessment and interpretation of the criteria themselves. Finally, a remarkable
reduction of cases with intentionally neglected stability criteria can be expected for the same
reasons.

A careful estimation of these indirect influences can be used for re-calculating the risk of a
stability accident.

• Reduction of calculated risk

The parameters liable to change by mandatory IMO Intact Stability criteria are, as mentioned
above, the following four with their attached probabilities:

Proportion of severely wrong cargo information at critical departures = p2

Proportion of severe errors within stability assessment at critical departures = p3
Proportion of misinterpreted stability criteria at critical departures = p4
Proportion intentionally neglected stability criteria at critical departures = p5

The estimated potential changes of these probabilities are indicated in the following table,
together with the changed results:

Entry parameters Results

dp = 10 p5 = 0.10→ 0.05 p10 = 0.02 p15 = 0.10 uds = 1.2439→ 0.5881
p1 = 0.01 p6 = 0.10 p11 = 0.15 p16 = 0.01 kds = 1.0000→ 0.5000
p2 = 0.06→ 0.03 p7 = 0.02 p12 = 0.20 p17 = 0.03 acc1 = 0.0196→ 0.0092
p3 = 0.02→ 0.01 p8 = 0.005 p13 = 0.15 acc2 = 0.0012→ 0.0006
p4 = 0.04→ 0.01 p9 = 0.02 p14 = 0.03 acc3 = 0.0007→ 0.0003

The total number of accidents per ship and year will then be reduced from 0.0215 to 0.0101 or to
one accident in 99.0 years instead of 46.5 years. With an estimated number of 6000 sensible
ships the number of accidents is reduced from 129 to 61 per year with a minimum of two pure
capsizes in extremely heavy weather. The monetary risk is reduced to about 12000 Euro per ship
and year.

This result is based on expert opinion only, but indicates that the risk of failure related to the
control of operational stability would be considerably reduced by common mandatory stability
criteria.

• Summary of risk assessment

The risk assessment has been restricted to ship types where the legal status of the IMO Intact
Stability criteria has a distinguishable influence on the operation of these ships. These are:

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• Container vessels,
• Ro/ro-vessels.
• Multi purpose (break bulk) vessels.

A Hazard and Operability Study has revealed why ships occasionally depart with deficient
stability and which additional operational events may lead to a stability accident. This complex
scenario was simplified into an Event Tree Analysis with distinguished probabilities of all
influencing events.

The identification of these particular probabilities has been solely based on expert opinion
because statistical material on stability accidents is rare in the first place and does hardly contain
any information on events and parameters.

However, the results have been counter-checked by statistical summary figures and adjusted to
meet the global picture. Again, expert opinion, mainly from underwriters, was used to judge the
plausibility of the results. This also applies to the estimation of the cost of stability accidents.

The results obtained as a consequence of deficient stability at departure are in summary:

The total number of accidents per ship and year will be 0.0215 or one accident in 46.5 years.
With an estimated number of 6000 sensible ships this is 129 accidents per year. A minimum of
four of these 129 will be pure capsizes in extremely heavy weather.

The probability of a stability accident, multiplied with the average cost of such an accident, is the
risk. The resulting figure is 1.17 Million Euro per case. This figure, combined with the
probability of one stability accident per ship and year of 0.0215 results in a monetary risk of
about 25000 Euro per ship and year.

This risk figure includes damage to ship and cargo and cannot, of course, account for loss of
health and life.

The figures of those probabilities of events, which can be influenced by a mandatory status of the
IMO Intact Stability criteria, have then been reduced. This reduces the number of accidents per
ship and year to 0.0101 or to one accident in 99.0 years. With an estimated number of 6000
sensible ships then number of accidents is reduced 61 per year with a minimum of two pure
capsizes in extremely heavy weather. The monetary risk is reduced to about 12000 Euro per ship
and year.

Risk control options

Although the risk assessment in chapter 2 of this study has already shown that common
mandatory intact stability criteria would have a remarkable benefit for reducing the risk of
stability accidents, some light shall be shed on other possible risk control options with the view
of a feasible implementation through IMO initiative.

• Improvement of ship design and equipment

• Ship design

The main commercial goals of ship design are to meet the contracted cargo or passenger carrying
capacity, the contracted speed with minimum fuel consumption, and a low light ship mass for
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meeting the budget of the customer. Compliance with class rules and flag state requirements is
indispensable in most cases for reasons of public and private law. In this context, the
recommendatory status of the IMO Intact Stability criteria does not appear to be a noticeable
hindrance for proper ship design, because the majority of classification societies apply these
criteria in principle.

Considering the sensitivity of certain types of ships, e.g. ferries and passenger vessels, against
combined wind and sea effects to stability, a revision of the criteria can be expected. However,
such a revision will not noticeably change the situation for the critical ships in the sense of this
study, i.e. small container vessels, ro/ro-vessels and multi purpose vessels with heavy deck cargo.
Therefore, improvement of ship design, within the framework of the present intact stability
criteria, will not readily reduce the risks associated with the control of operational stability,
notwithstanding the considerable progress in ship design through IMO initiatives with regard to
survival in damaged condition.

• Equipment for control of stability

The risk assessment in chapter 2 of this study has shown a considerable influence from incorrect
cargo information, in particular wrong mass statements of containers in cargo documents, and of
errors in onboard stability assessment to the risk of a stability accident. This influence is
attributed to the procedure of loading planning and stability assessment by means of a "desk top"
exercise, i.e. a calculation, which completely relies on the entered figures collected by the
operator. Apart from the uncertain cargo masses there are also quite often errors in the onboard
tank management.

A possible solution of this particular problem would be the onboard measurement of stability by
means of an in-service inclining test. Extensive studies on the feasibility and suitability of this
option have been carried out in the past 15 years with the result that a limited number of
container vessels and ro/ro-vessels have been fitted with such equipment and approved by flag
state authorities. This has been brought to the attention of the SLF Sub-Committee.

There is, however, a general reluctance of the shipping industry to apply this measure of safety in
a broad scale due to several reasons, which include cost of installation, delay of cargo operations
and a pretended lack of competence of onboard personnel. IMO has not been prepared to
recommend the in-service inclining test or relevant equipment.

Other suitable equipment, e.g. on-line monitoring of displacement through automated draught
measurement and on-line monitoring of the filling state of ballast and bunker tanks, has been
developed and installed at a limited scope. The effect of this equipment with regard to prevention
of stability accidents is not so clearly determinable, although it allows a closer control of loading
parameters. Misinterpretation and intentional neglecting of stability criteria cannot be directly
prevented by such advanced equipment.

Another equipment option for preventing stability accidents in heavy weather would consist of a
monitoring and warning system for avoiding course and speed combinations, which could lead to
harmonic and parametric resonance, prolonged loss of stability on a wave crest and the risk of
surf riding and broaching to. The MSC/Circ.707 is a first step into that direction. Advanced
computer based systems are presently under development. However, such systems may prove
helpless and ineffective, if the ship's departure stability is deficient in the first place. Such
equipment can therefore take a supportive role only.

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• Improvement of ship operation

• Enforcement of SOLAS Regulation VI/2 (information from the shipper)

An effective enforcement of SOLAS Regulation VI/2, in particular regarding the correct gross
weight declaration and marking required in paragraph 2.1, would be quite helpful to eliminate a
substantial source of uncertainty to ships' departure stability assessments. Quite often the
proposal has been raised to prescribe a mandatory weighing of export containers at their arrival
in a terminal or after their packing in that terminal. But apart from the undue delay through this
procedure and the associated cost, the established weight would be available far too late because
ship loading planning takes place well in advance of the physical availability of the containers,
either ashore or/and aboard ship.

The enforcement of SOLAS Regulation VI/2, however, should be worth to consider and should
address the individual shipper or packer of the container, possibly in the context with other
associated declaration requirements regarding maritime security measures. A mandatory status of
the IMO Intact Stability criteria would certainly support any effort into that direction.

• Review of loading and stowage procedures

A review of loading and stowage procedures appears not very promising with regard to
improving the control of departure stability of ships. Cargo operations in ports have undergone
drastic processes of rationalisation, including the respond to multi modal transport chains and
productive warehousing, since the introduction of the container and other "fast" modes of cargo
handling.

Commercial competition between ports and regions have brought all relevant cargo operations to
a high degree of perfection, including the care for ship safety, so that it seems hard to imagine
how substantial changes could be initiated by IMO. What is needed, is simply a refinement with
regard to the reliability of cargo data, as discussed under 3.2.1.

Stability accidents are quite often related to cargo shifting, with a focus on ro/ro-vessels. This
includes departures with excess stability. In that area IMO has produced appropriate tools
(CSS-Code, Cargo Securing Manual), which have the potential to be effective and sufficient in
the long term, but certainly depend on sustained training and qualification of personnel, ashore as
well as on board.

• Review of education and training of masters and deck officers

The revision of the STCW-Convention of 1978 and the specification of mandatory competencies
of masters and deck officers in the Tables A-II/1 and A-II/2 of the STCW-Code in 1995 is
certainly a great step forward to providing common grounds for the performance of merchant
shipping and safety at sea. However, the overall profile of nautical competence in these tables
appears somewhat one-sided in favour of "Navigation". Of course, collision, grounding and
stranding contribute the majority of marine accidents and deserve the greater attention in
maritime education and training. But this should not permit the underscoring of the remaining
areas cargo handling and ship management.

In the late 1960s, when the standard container was introduced in shipping, rumours appeared that
very soon the importance of the cargo officer would vanish. He would become superfluous in the

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end, because care for cargo operations would completely be taken over by shore based
organisations under the responsibility of the carrier.

This did not come true for mainly two reasons, the higher cost of effective shore based cargo
care, and the undeniable responsibility of the master and his officers for the safety of the ship.
Today we can observe a quiet revival of the role of the cargo officer on board, together with an
increasing lack of care-taking ashore. This affects the management of stability as well.

Therefore it seems worth to carefully investigate the future role of mariners in cargo operations,
taking into account their responsibilities stipulated by the ISM-Code, and to review the above
mentioned STCW-Code competence tables with particular attention to the competencies:

• Plan and ensure safe loading, stowage and securing, care during the voyage and
unloading of cargoes;
• Control trim, stability and stress.

In this context, a mandatory status of the IMO Intact Stability criteria would prove very
supportive by providing a clear and unambiguous reference for the specific training objectives of
shipboard stability management.

Although, as mentioned above, the function "Navigation" in the nautical competence tables has
been given an abundant share and details, in particular for the competence "Manoeuvre and
handle a ship in all conditions", there appears a certain weakness in the formulation of the
competence for ship handling in heavy weather. The appropriate text under the column
"Knowledge, understanding and proficiency" reads:

.12 management and handling of ships in heavy weather, including assisting a ship or
aircraft in distress; towing operations; means of keeping an unmanageable ship out of trough of
the sea, lessening drift and use of oil.

This text needs, of course, the interpretation by a professional maritime course designer or
lecturer like all the other descriptions in the STCW competence tables. But the inclusion of
important keywords like avoidance of resonance, surf riding, loss of stability on a wave crest, or
the direct reference to the MSC/Circ.707 would be helpful to support the intended common
standard of competencies, notwithstanding the need to replace the doubtful phrasing "means of
keeping an unmanageable ship out of trough of the sea".

• Enhancement of administrative supervision

• Flag state control

The means of a flag state to enhance the avoidance of stability accidents beyond the presently
attained level appear to be very limited. The mechanisms described in chapter 1 of this study,
which are responsible for a stability accident, cannot be influenced directly by a flag state.
Indirect measures, like approval of the ship and stability documents, appropriate manning with
competent officers and regular preventive inspection is all what can be done and has been done
for a long time.

A more stringent requirement for keeping records on stability assessments, e.g. through the ISM
inspection regime, could improve the performance in an indirect manner. However, this would
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imply a mandatory status of relevant intact stability criteria in the first place, addressing either
the IMO criteria or equivalent national criteria. Some shipping companies already have these
controls included in their approved Safety Management System and require a consistent
recording of loading and stability parameters.

• Port state control (PSC)

Port state control organisations, like the Paris MOU, are based on IMO and ILO Conventions for
justifying their inspections of ships. Therefore, the means of port state control organisations to
enhance the avoidance of stability accidents are very limited, although port state authorities are
generally much closer to the scene of relevant events than flag state authorities. Port state control
officers are virtually present in the actual loading ports and can decide on the spot to inspect a
critical vessel with obviously heavy deck load. The main hindrance to do this is the simple lack
of a "legal instrument" in the case of cargoes other than grain. The mandatory "grain rules" have,
in fact, established a long and successful tradition of shore based inspection and controls in major
grain exporting countries, which always have included the assessment of grain stability.

This situation may radically change to an expansion of inspections to other critical cargoes like
containers, ro/ro-vehicles and timber on deck, if the presently recommendatory stability criteria
for those ships would become mandatory. According to the opinion of a distinguished PSC
representative, a mandatory status of the IMO Intact Stability criteria would immediately lead to
the development of guidelines for the common approach to checking certain aspects of the
onboard management of ship's stability. In this way a pro-active approach for the prevention of
stability accidents would become feasible and certainly appreciated by many ship masters seeing
themselves under constant commercial pressure.

• Revision of the IMO Code on Intact Stability

Having noted above that in a number of risk control options, like

• better enforcement of SOLAS Regulation VI/2,

• review of education and training of masters and deck officers,
• enhanced flag state control,
• enhanced port state control (PSC),

the lack of internationally agreed mandatory stability criteria appears as a "missing link", the
making mandatory of the IMO Intact Stability criteria shall be given a closer look.

• Re-structuring the IS-Code

The present lay-out of the IS-Code appears as a historically grown conglomerate of instructions,
provisions and technical standards. There is general advice for the layout of stability booklets,
general precautions against capsizing, advice for ship handling in heavy weather, stability criteria
for various types of ships and certain cargoes, instructions to naval architects regarding the
preparation of stability information, icing considerations directed to masters and naval architects,
consideration for watertight integrity directed to naval architects and detailed standards and
instructions for the determination of light-ship displacement and centre of gravity.

It seems impossible to transfer the Code in the present composition into a mandatory status.
Therefore Germany has proposed within the Intact Stability Correspondence Group a
restructuring of the IS-Code into three parts as follows:
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• Part A shall contain intact stability criteria applicable to all types of ships,
• Part B shall contain recommendatory provisions for all types of ships,
• Part C shall contain explanatory notes useful for compliance with Parts A and B.

A preliminary overview shall provide the relation between the existing contents of the IS-Code
and the proposed new structure.

Proposed new structure of the IS-Code Contents related to existing Code

Part A – Criteria for All Types of Ships

Chapter 1 – General
1.1 Purpose identical to 1.1
1.2 Application identical to 1.2
1.3 Definitions identical to 1.3
Chapter 2 – Design criteria applicable to all ships
2.1 Static intact stability criteria identical to 3.1
2.2 Dynamic intact stability criteria to be developed with reference to 3.2
Chapter 3 – Special criteria for certain types of ships
3.1 Cargo ships carrying timber deck cargoes identical to 4.1
3.2 Fishing vessels identical to 4.2
3.3 Special purpose ships identical to 4.3
3.4 Cargo ships carrying grain in bulk identical to 4.1
3.5 Offshore supply vessels identical to 4.2
3.6 Mobile offshore drilling units (MODUs) identical to 4.3
3.7 Pontoons identical to 4.1
3.8 Dynamically supported craft (DSC) identical to 4.2
3.9 Containerships greater than 100 m identical to 4.3

Part B – Recommendations for All Types of Ships

Chapter 4 – Stability information
4.1 Effect of free surfaces of liquids in tanks identical to 3.3
4.2 Assessment of compliance with stability criteria identical to 3.4
4.3 Standard loading conditions to be examined identical to 3.5 and including 2.4
4.3 Calculation of stability curves identical to 3.6
4.4 Stability booklet identical to 2.1
4.5 Operating booklets for certain ships identical to 2.2
Chapter 5 – Operational provisions against capsizing
5.1 General precautions identical to 2.3 and expanded as appropriate
5.2 Ship handling in heavy weather identical to 2.5 and expanded as appropriate
5.3 Measures in special cases and in emergencies to be developed
Chapter 6 – Icing considerations identical to Chapter 5
Chapter 7 – Considerations for watertight integrity identical to Chapter 6
Chapter 8 – Determination of lightship parameters identical to Chapter 7
Annex 1 – Detailed guidance for the conduct of an ... identical to Annex 1
Annex 2 – Recommendations for skippers of ... identical to Annex 2
Annex 3 – Determination of ship's stability by ... identical to Annex 3

Part C – Explanatory notes

Chapter 9 etc. as appropriate to be developed

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It appears from this overview that the majority of the contents of the existing Code may remain
unchanged. A major task will be the re-development of the "weather criterion" of the present
IS-Code. Further expansion and development may be desirable in a new Chapter 5, Operational
Provisions Against Capsizing, which would contain comprehensive advice for the master.
Finally, development will be needed for the proposed Part C of the new IS-Code.

• Mandatory status of the stability criteria

The above overview provides the opportunity to declare Part A as mandatory in general. This
shall mean that the criteria mentioned therein would be obligatorily applied for ship design and
approval as well as a common yardstick in ship operation. This does, however, not affect the
mandatory application of relevant damage stability criteria, which may be more stringent for
certain ship designs or certain loading conditions.

It should further be noted, that a mandatory status of intact stability criteria as a risk control
option will not be a perfect warranty for the avoidance of stability accidents, although this status
would be beneficial in several ways by influencing positively the enforcement of SOLAS
Regulation VI/2, the education and training of mariners, and enhanced flag state and port state
control. As mentioned earlier, stability accidents can also be the result of excessive stability,
improper cargo securing and of poor ship handling in heavy weather.

However, a mandatory status of the IMO Intact Stability criteria will be perceived as an
indispensable corner stone of the overall safety concept of shipping, best proved by the surprise
of many mariners and shipping operators when confronted with the "news" that the well known
IMO-criteria were only recommendatory at this time.

• Summary of risk control options

A number of risk control options has been investigated and presented above with the following
results:

• Improvement of the situation by alternative ship design appears not feasible without
severe reduction of the profitableness of the ships involved.

• A certain progress of making departure stability assessment more reliable would be

expected from the use of advanced equipment for onboard stability management.

• An important step towards the avoidance of ship departures with deficient stability would
be achieved by more realistic cargo figures through a legal enforcement of SOLAS
Regulation VI/2. However, this would necessarily imply to make the IMO Intact Stability
criteria mandatory.

• A review of usual procedures of loading cargo vessels, e.g. by weighing containers,

appears neither useful nor feasible.

• A review of the STCW-based competence's of masters and deck officers with regard to
stability management, cargo handling and manoeuvring in heavy weather appears
suitable, but would also benefit from mandatory IMO Intact Stability criteria.

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It appears that making the IMO Intact Stability criteria mandatory is not the only possible and
successful measure, but all other suitable measures are less effective without such mandatory
criteria.

Cost-benefit assessment

In this chapter only the option "mandatory intact stability criteria" is considered and discussed
with regard to cost-benefit relation, although some of the other options will benefit indirectly
from mandatory criteria.

• Benefit of mandatory intact stability criteria

The possible benefit of mandatory intact stability criteria has been numerically estimated in
Chapter 2.2 of this study and can be addressed as "considerable", not only in terms of financial
savings but also in terms of preservation of life and health. This benefit can be identified by the
following estimated effects:

− The proportion of severely wrong cargo information, which remains undetected by

suspicious masters and cargo officers, can be reduced under the assumption that
mandatory intact stability criteria create a greater public awareness of the importance of
correct data for the safety of shipping. This effect may be further supported by more
effective prosecution of offences against the requirements of SOLAS Regulation VI/2.

− The proportion of severe errors within stability assessment at critical departures can be
reduced under the assumption of improved training and education of mariners and
enhanced port state control activities on stability management, both produced and
favoured by mandatory stability criteria. Also advanced onboard equipment for stability
management may be promoted in this way.

− The proportion of misinterpreted stability criteria at critical departures can be reduced

under the assumption of improved training and education of mariners and enhanced
instructions in the Safety Management Manual of the company, both favoured by
mandatory stability criteria.

− The proportion of intentionally neglected stability criteria can be reduced taking into
account that mandatory stability criteria may reduce the pressure from the charterer on
masters and/or strengthen the back of masters with regard to respecting the limits of
downloading the vessel.

The numerical effect of this reduction of negative influences, estimated in chapter 2.2 in a
conservative manner, is a potential reduction of the risk of stability accidents to about 50% of the
existing level.

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• Regulatory consequences

• Revision of the IMO Intact Stability Code

The anticipated revision of the IMO Code on Intact Stability, in particular with regard to
developing "performance based criteria" for types of ships where the traditional "statistic based
criteria" appear no longer applicable, is a task that will take a huge effort of research and debate,
to find solutions which provide an at least equivalent level of safety. The proposed re-structuring
of the Code into a mandatory Part A and two recommendatory Parts B and C is a comparably
easy task.

Bearing in mind the possible benefit for the indicated "critical" types of ships, i.e. small container
vessels, ro/ro-vessels and similar multi purpose vessels, a preliminary restriction of the
mandatory status to those types of vessels would make this task even easier.

There are no specific costs related to this task, in particular no direct costs for the shipping
industry. It should be borne in mind, that the majority of cargo ships already apply the IMO
Intact Stability criteria in practice as if they were mandatory.

• Revision of SOLAS Chapter II-1

A mandatory status of the anticipated Part A of the IMO Code on Intact Stability must be laid
down and confirmed in the SOLAS Convention. This can be done by a simple re-wording of
Regulation II-1/25-8, Stability information, in sub-paragraph 1.

The existing text reads:

1 The master of the ship shall be supplied with such reliable information as is necessary to
enable him by rapid and simple means to obtain accurate guidance as to the stability of the ship
under varying conditions of service. The information shall include:

.1 a curve of minimum operational metacentric height (GM) versus draught which

assures compliance with the relevant intact stability requirements and the requirements of
regulations 25-1 to 25-6, alternatively a corresponding curve of the maximum allowable
vertical centre of gravity (KG) versus draught, or with the equivalents of either of these
curves.

The proposed amendment would consist in a change of the words "relevant intact stability
requirements" into the words "applicable criteria laid down in the International Code on Intact
Stability, Part A,".

The new text would read in full:

1 The master of the ship shall be supplied with such reliable information as is necessary to
enable him by rapid and simple means to obtain accurate guidance as to the stability of the ship
under varying conditions of service. The information shall include:

.1 a curve of minimum operational metacentric height (GM) versus draught which

assures compliance with the applicable criteria laid down in the International Code on
Intact Stability, Part A, and the requirements of regulations 25-1 to 25-6, alternatively a

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corresponding curve of the maximum allowable vertical centre of gravity (KG) versus
draught, or with the equivalents of either of these curves.

It should be noted that the appended formulation "or with the equivalents of either of these
curves" contains the optional application of national criteria, which are at least equivalent to the
IMO criteria with regard to the information "minimum GM" or "maximum KG" for the
distinguished draught of the vessel.

The cost of this particular amendment for Administrations will be shared with other
SOLAS-amendments introduced at the same SOLAS Conference. There are no direct costs for
the shipping industry.

• Revision of national regulations

A revision of national regulations would only be necessary if existing national criteria would fall
below the standard set by the IMO criteria. This can be identified by comparing the GM- or
KG-limit curves of the particular ship.

From the survey of IS-Code application by flag states it appears that this will rarely be the case.
Therefore the cost for Member Governments will be negligible.

• Consequences for ship design and classification

Since classification societies under IACS and many other societies have already adopted the IMO
Intact Stability criteria as mandatory requirement for the allocation of a class certificate there will
be no change of procedures and consequently no extra costs.

The present concern among scientists in ship theory and naval architecture about the
appropriateness of the existing IMO Intact Stability criteria may be seen as prohibiting a
mandatory status at this time. However, any attempt to develop criteria, which would
substantially improve safety against capsizing by in-built features, appears infeasible [12]. It is
therefore preferable to uniformly apply the existing criteria, at least for critical ships in the
context of this study.

A mandatory status of the IMO Intact Stability criteria will strengthen the common basis for fair
competition among ship builders and national economy interests, at least from a technical point
of view.

• Consequences for ship operation

• Strengthening of legal demands on shippers and carriers

An indirect positive effect of mandatory stability criteria can be expected on the correct supply of
cargo information by shippers and on easing the pressure to ship masters from carriers
(charterers) with regard to down loading the vessel. This will, of course, imply a certain effort to
be taken for generating and forwarding correct cargo figures and on thorough assessment of
operational stability.

This indirect effect can be established and controlled by enhanced public attention, e.g. by
prosecution of offences against regulations, and/or by private effort of the industry. The cost of
this additional effort must be borne by the customers of sea transport service in general.
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If the maritime community succeeds to raise the level of reliability of cargo information and of
thorough stability management evenly throughout the world, no imbalance of competition will
arise and the additional cost will pay back in the long term by a reduction of delays and
accidents, possibly also by a reduction of insurance premiums.

• Standardisation of key shipboard operations regarding stability management

A mandatory status of the IMO Intact Stability criteria may promote the existing sound practice
of shipboard stability management within many major shipping companies to become standard
among all companies, thereby providing fair competition on a higher level of safety. The training
and education of deck officers and masters will harmonise regarding stability management, and
progress of development of technical tools for stability management and their implementation
into shipping practice will be encouraged.

The costs of these measures are either negligible or, in the case of specific technical tools, will
pay back by more reliable service and customer orientation.

• Optional supervision by port state authorities

Port State Control regimes will obtain the necessary legal instrument and the justification to
formally check the assessment of ship's stability before departure and detain a vessel where
necessary. Such expansion of PSC-activities is certainly not cost-neutral, but beneficial and
justified with respect to tax-payers if carried out proportional to the needs.

• Summary of cost-benefit assessment

The benefit of mandatory IMO Intact Stability criteria for the safety of shipping can be judged as
considerable, while there are no direct cost for the industry for the legal implementation. The
public cost for the legal implementation are negligible.

Ship design and classification will not be affected, because the presently recommended criteria
are already widely applied by naval architects and classification societies.

There is a certain additional private effort to be expected if the mandatory status of the criteria
would lead to an enhancement of legal demands on shippers, regarding more realistic cargo
information, and on carriers, regarding the consequences of an improved assessment of departure
stability. Another cost related consequence would be the expansion of onboard equipment for
stability management, to be borne by the owners. But these additional cost can be expected to
pay back in medium to long term by improved safety and reliability.

Expansion of PSC-programs towards operational stability will cause public costs, but this would
be justified by necessity and controlled by public interest.

In summary, there is no reason to be seen why the IMO Intact Stability criteria should not
become mandatory.

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• Recommendations for decision making

The above Formal Safety Assessment has shown that the presently non-mandatory status of the
IMO Intact Stability criteria, although widely used by ship yards, classification societies, flag
states and ship operators, bears a distinguished potential of creating hazardous situations which
may lead to stability accidents. There is, in particular for certain types of ships, a compelling
need to eliminate the "grey zone of negotiability" of this important safety margin and to reverse
the trend towards compromising safety of life, the marine environment and property in shipping.

A conversion into a mandatory status would substantially improve the situation through several
mechanism. The costs of this measure are comparably small and largely controllable by the
shipping industry itself.

If a mandatory status of the existing IMO Intact Stability criteria would create difficulties for the
design and approval of certain types of ships this mandatory status could be provisionally limited
to the critical types of ships as identified in this study.

It is therefore recommended to make the IMO Intact Stability criteria mandatory. The following
steps of action are suggested from the outcome of this study, notwithstanding the formal
application for inclusion of this proposal into the work program of the Maritime Safety
Committee and relevant subsidiary bodies:

1. Discussion of and agreement on a structural revision of the existing Code on Intact

Stability in the sprit of the draft presented in chapter 3.4.1 of this study.

2. Discussion of and agreement on a revision of certain provisions of the existing Code on

Intact Stability taking relevant submissions of Member Governments into account.

3. Discussion of and agreement on a possible temporary exemption of certain ship types

from the mandatory application of the criteria taking relevant submissions of Member
Governments into account.

4. Discussion of and agreement on an amendment to SOLAS Regulation II-1/25-8 in the

sprit of the draft presented in chapter 4.2.2 of this study.

Relevant subsidiary bodies would be:

− SLF Sub-Committee for the revision of the IS-Code and the amendment to SOLAS
Regulation II-1/25-8, as proposed above,

− STW Sub-Committee for the revision of the STCW-Code with regard to on-board
stability management, if considered appropriate,

− DE Sub-Committee to consider equipment for stability management if requested by the

SLF Sub-Committee.

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Literature

[1] Francescutto, A.: Intact Ship Stability – The Way Ahead; Proceedings of the
6th International Ship Stability Workshop, Webb Institute, 2002

[2] Kobylinski, Dr. L. K.: Performance Oriented Intact Stability Criteria; Comments by
Poland to the Intersessional Correspondence Group on Intact Stability; March 2003

[3] Bruinsma, W.A.: Safe Transportation of Containers by Sea and Safe Unloading and
Loading of Container Vessels; The Hague, 2001

[4] Kaps, H., Kastner, Dr. S. and Knickmann, A: Pilotstudie Ladungssicherheit Seeverkehr,
Fe-Nr. 40099/84; Hochschule Bremen, 1985

[5] Kaps, H. and Kastner, Dr. S.: Beurteilung der Stabilität von Schiffen in der Praxis; Fe-Nr.
40199/87, Hochschule Bremen 1989
[6] Kaps, H. e.a.: Stabilität Seeschiffe; Fe-Nr. 40301/93, Hochschule Bremen, 1994

[7] Institut für Seeverkehrswirtschaft und Logistik (ISL): Shipping Statistics Yearbook 2002,
Bremen, December 2002

[8] Institut für Seeverkehrswirtschaft und Logistik (ISL): Shipping Statistics and Market
Review; World Merchant Fleet, Bremen, January/February 2003

[9] Institut für Seeverkehrswirtschaft und Logistik (ISL): Shipping Statistics and Market
Review; World Shipbuilding, Maritime Casualties, Bremen, August/September 2002

[10] Institut für Seeverkehrswirtschaft und Logistik (ISL): Shipping Statistics and Market
Review; General Cargo and Container Shipping, Bremen, June 2002

[11] International Maritime Organization: SOLAS, Consolidated Edition, London, 2001

[12] Kobylinski, Dr. L. K.: Stability Standards – Future Outlook; Proceedings of 7th
International Conference on Stability of Ships and Ocean Vehicles; Lauceston,
Tasmania, 2000

[13] International Maritime Organization: MSC/Circ. 931; MEPC/Circ.366; 1999

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