E MARITIME SAFETY COMMITTEE MSC 100/6/4...Naval Architect HoD Hull Structural Engineer IMO GBS Auditor Samsung Heavy Industry, Republic of Korea 3. AUDIT SUMMARY Functional requirement

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MARITIME SAFETY COMMITTEE 100th session Agenda item 6

MSC 100/6/4 29 August 2018

Original: ENGLISH

GOAL-BASED NEW SHIP CONSTRUCTION STANDARDS

Final report of the GBS Initial Verification Audit of Türk Loydu

Note by the Secretary-General

SUMMARY

Executive summary: This document provides the final report of the GBS initial verification audit of Türk Loydu Uygunluk Değerlendirme Hizmetleri A.Ş. (Türk Loydu) for consideration by the Committee to establish conformity with the Organization's International Goal-based Ship Construction Standards for Bulk carriers and Oil tankers (GBS Standards) (resolution MSC.287(87))

Strategic direction, if applicable:

Other work

Output: OW 7

Action to be taken: Paragraph 6

Related documents: Resolutions MSC.287(87) and MSC.296(87)

Introduction 1 The Secretary-General received the request for the initial verification from Türk Loydu Uygunluk Değerlendirme Hizmetleri A.Ş. (Türk Loydu) on 26 March 2018, together with a supporting letter, dated 27 March 2018, from the Ministry of Transport, Maritime Affairs and Communications of the Republic of Turkey. After verification that the submitted technical documentation package included all elements specified in paragraph 9 of resolution MSC.296(87) (GBS Guidelines) and after receipt of payment to conduct the audit, the Secretary-General confirmed to conduct the audit on 13 April 2018 and subsequently established the GBS Audit team. 2 The three experts audit team was led by Mr. Juan Carlos Cubisino from Argentina and supported by Mr. Stephan Assheuer from Germany and Mr. Gyoon-Joon Yoon from the Republic of Korea.

MSC 100/6/4 Page 2


Audit Findings (non-conformities and observations) 3 The audit was conducted in accordance with the Guidelines for Verification of Conformity with Goal-based Ship construction Standards for Bulk Carriers and Oil tankers (GBS Guidelines) (resolution MSC.296(87)). Non-conformities and observations in the report were decided by the audit team based on the GBS Guidelines whereby a non-conformity represents non-conformance with the related Functional Requirement of the GBS Standards (see Section 3 "Audit summary" of the report). Recommendation of the audit teams 4 In accordance with the GBS Standards, the rules for the design and construction of bulk carriers and oil tankers of an RO shall be verified as conforming to the Tier I goals and Tier II functional requirements. The final decision on verification of conformity shall be taken by the Maritime Safety Committee and the outcome will be communicated to all Contracting Governments, in accordance with the GBS Guidelines. 5 The final recommendations are included in section 1.5 "Recommendation of the GBS Audit Team" in the final report. In this regard, it should be noted that the report recommends to the Committee that Türk Loydu's rules conform to the GBS Standards, provided that the non-conformities identified in paragraph 1.4.2 of the final report are rectified and the observations are addressed, taking into account the recommendations made by the audit team, and that Türk Loydu submits a new request for verification audit, in accordance with the GBS Guidelines. Action requested of the Committee 6 The Committee is invited to consider the audit report of Türk Loydu (annex) and, in particular, the audit findings in paragraph 4, as well as section 1.5 "Recommendation of the GBS Audit Team", and take action as appropriate. ***

MSC 100/6/4 Annex, page 1


ANNEX

1. EXECUTIVE SUMMARY 1.1. Subject of audit 1.1.1 This Goal-based Standards (GBS) audit, hereinafter called "GBS verification audit", is aimed at carrying out the initial verification of "TÜRK LOYDU"1 rules for the design and construction of bulk carriers and oil tankers in accordance with paragraph 6 of resolution MSC.287(87), based on the Verification Guidelines adopted by resolution MSC.296(87). 1.1.2 The GBS verification audit carried out by the GBS Audit Team covered the rule set detailed in the annex to this report, which was submitted by Türk Loydu hereinafter called "TL". 1.2. Scope of verification audit 1.2.1 The GBS verification audit was based on the self-assessment report and the rule linkage table included in the documentation package submitted by TL, using samples of the submitted rules, as appropriate, based on expert's judgments. 1.2.2 The GBS Audit Team noted that, although TL is a non-IACS Member, TL stated in its submission letter that it adopted and applied the IACS Common Structural Rules for Bulk Carriers and Oil Tankers (CSR), IACS Resolutions (UR, UI and Proc.Req.) and some IACS Recommendations within its Rule Base. Thus, the TL CSR, as referred to in the TL documentation package, are in fact CSR 01-JAN-2017, as amended by Corrigenda 1. 1.2.3 In addition, it was noted that TL's self-assessment and, more importantly, justifications, as requested by the Verification Guidelines, were mainly based on IACS Technical Background (TB) Reports, taking into account the fact that CSR has already been found in compliance with the GBS Standards. Finally, it was noted by the GBS Audit Team that the TL rule linkage table was also submitted in the same way as IACS Members (i.e. compliance with the Standards is based on the adoption of IACS Resolutions complemented by individual rules and procedures). 1.2.4 Consequently, the GBS Audit Team agreed to avoid, to the extent possible, any overlapping with CSR initial verification and the relevant decisions adopted. Thus, the GBS Audit Team agreed to focus on the verification of CSR's proper adoption and implementation in TL's rules. In this context, since no specific version is included in the IACS Resolutions referred to in TL's rules, the GBS Audit Team assumed that the latest CSR version applies in all cases. 1.2.5 The GBS verification audit related to the Hong Kong Convention has been limited because this statutory instrument is not in force yet.

1 Namely TÜRK LOYDU UYGUNLUK DEĞERLENDİRME HİZMETLERİ A.Ş.



1.3. Auditing process 1.3.1 After distributing the TL documentation package, the GBS Audit Team carried out several rounds of discussions, which were documented in relevant circular letters, following the below procedures:

.1 all circular letters and communications with TL were copied to the IMO Secretariat;

.2 the GBS verification audit was conducted mainly by correspondence, utilizing

Internet-based tools as much as possible; .3 each GBS Audit Team member took the lead in relation to the review of a

group of functional requirements (FR); .4 the GBS Audit Team agreed on the audit fundamentals and schedule and

carried out the verification based on the following audit process:

.1 initial audit considerations and discussion rounds; .2 list of preliminary findings and clarification requests subject to

further review by the audit team; .3 draft interim report discussions; .4 submission of interim report containing both preliminary findings and

clarification requests; .5 meeting with TL at IMO Headquarters to further discuss findings and

clarifications requested; .6 assessment of TL's reply on preliminary findings and clarification

requests by auditors; .7 submission of interim report updated with the preliminary findings

qualification and possible non-conformities with resolution MSC.287(87), hereinafter "the Standards";

.8 assessment of TL's reply on possible observations and

non-conformities included in the Interim Report; .9 elaboration of draft final report; .10 consideration of final report and assessment on TL's rule set

compliance; and .11 final report submission.

.5 On 22 June 2018, the draft Interim Report was submitted to TL. After

receiving TL's comments on the preliminary findings and the relevant clarifications requested, the GBS Audit Team submitted, on 27 July 2018, the Interim Report updated with findings, qualifications and preliminary conclusions on compliance with the Standards. On 17 August 2018, the Audit Team submitted the Final Report.



1.4. Audit findings 1.4.1 As detailed in section 4 of TL/2018/NC/01, objective evidence on ambiguous adoption of IACS Resolutions in TL's rules was found. Nevertheless, the GBS verification audit was conducted assuming that timely and proper corrective actions will be adopted. 1.4.2 Conclusions reached by the GBS Audit Team on the TL rule set compliance with the IMO Goal-based Standards are summarized in section 3 of this report and the detailed Findings are contained section 4. In this regard, it should be noted that "conforming", as indicated in section 3 of this report, when referring to a FR, means that no evidence of non-compliance with the Standards was found in samples taken during the audit. Nevertheless, observations may still have been provided by the GBS Audit Team. 1.5. Recommendation of the GBS Audit Team

1.5.1 The Audit Team recommends that the Committee confirm TL rule set compliance with the Standards provided that TL adopts the relevant actions to rectify "non-conformities" and to address "observations", as referred to in paragraph 1.4.2, and submits a new request for audit, in accordance with GBS Guidelines. 1.5.2 It should be noted that since TL adopted the IACS' CSRs and IACS resolutions (including some IACS recommendations), future changes adopted by IACS will automatically mean changes in TL's rule set, which will need to be dealt with as part of the GBS maintenance audit scheme. 1.5.3 It should also be noted that incorporating IACS' requirements into non-IACS Members' rules implies no representation by IACS or its Members and that the classification society in question is operating in compliance with those requirements. 2. SUBMISSION OF PARTICULARS 2.1. Submitting Administration:

REPUBLIC OF TURKEY MINISTERY OF TRANSPORT, MARITIME AFFAIRS AND COMMUNICATIONS GENERAL DIRECTORATE OF SHIPYARDS AND COASTAL STRUCTURES

2.2. Recognized organization name:

TÜRK LOYDU UYGUNLUK DEĞERLENDİRME HİZMETLERİ A.Ş. 2.3. Title and revision date of rules submitted:

List of Rules (Rule Set) submitted are detailed in the annex to this report. 2.4. Submission date:

26 March 2018 – Submission letter Ref. RD/0976/NBP/BST. 2.5. Report type

Final report



2.6. GBS Audit Team members:

Name Country Position Affiliation

Mr. Juan Carlos Cubisino (Team Leader)

Argentina Naval Architect Structural Analysis Professor Ship Surveyor ISM/ISO/IMO Auditor

Prefectura Naval Argentina (Argentine Maritime Authority)

Mr. Stephan Assheuer

Germany Naval Architect Consultant IMO GBS Auditor

admaris GmbH, Hamburg, Germany

Mr. Gyoon-Joong Yoon

Republic of Korea

Naval Architect HoD Hull Structural Engineer IMO GBS Auditor

Samsung Heavy Industry, Republic of Korea

3. AUDIT SUMMARY

Functional requirement Conforming Not

conforming Summary comment

General TL/2018/NC/01

Design

1 Design life X

2 Environmental conditions X TL/2018/OB/01

3 Structural strength X TL/2018/NC/02 TL/2018/OB/02 TL/2018/OB/09

4 Fatigue life X TL/2018/OB/05

5 Residual strength X

6 Protection against corrosion X

6.1 Coating life X

6.2 Corrosion addition X

7 Structural redundancy X

8 Watertight and weathertight integrity X TL/2018/OB/06

9 Human element considerations X

10 Design transparency X TL/2018/NC/03 TL/2018/OB/03 TL/2018/OB/07

Construction

11 Construction quality procedures X TL/2018/OB/08 TL/2018/OB/09

12 Survey during construction X TL/2018/OB/09

In-service considerations

13 Survey and maintenance X TL/2018/OB/04

14 Structural accessibility X

Recycling considerations

15 Recycling X



4. AUDIT FINDINGS

FINDINGS

Recognized organization: TURK LOYDU Audit date: June 2018

Functional requirement: All

Non-conformity No.: TL/2018/NC/01 Observation No.:

FINDING: 1

Objective Evidence: TL's submission letter states that the RO adopts and applies IACS Common Structural Rules for Bulk Carriers and Oil Tankers (CSR), IACS Resolutions (Unified Requirements, Unified Interpretations and Procedural Requirements), and some IACS Recommendations within its Rule Base. However, the audit found texts and references in TL's rules which, in some cases, are not a reflection of this statement and, in other cases, are misleading. For example:

a) TL rules Pt.A Ch.1 Sec.1 A [1] reads Hull structural design of bulk carriers with L ≥ 90 m contracted for construction on or after 1st April 2006, is to be carried out on the basis of the IACS Common Structural Rules for Bulk Carriers and Oil Tankers, Part 1 and Part 2, Chapter 1. However, the phrase "on the basis" is normally used in recommendatory references and may impair the legally bound CSR state; besides, the phrase "hull structural design" may deviate from the goal of SOLAS regulation II-1/3-10.2, which clearly requests both design and construction.

b) TL rules Pt.A Ch.1 Sec. 27 establishes that for IACS CSR, Part 1 and Part 2,

Chapter 1 are applicable, but no references in Sec.1 A [1] are found. Except for some parts (e.g. E and D), Sec. 27 seems to apply to both CSR and non-CSR bulk carriers. However, the TL rule linkage table only refers to Sec.27 G and consistency between CSR and Sec.27 might not be guaranteed.

c) TL rules Pt.A Ch.1 Sec.1 A [1] reads double hull oil tankers with L ≥ 150 m.

the IACS Common Structural Rules for Bulk Carriers and Oil Tankers, Part 1 and Part 2, Chapter 2 are applicable from this date on. For these ships Section 28, A. is to be observed in addition. Except for some parts (e.g. E and D), Sec. 28 seems to apply to both CSR and non-CSR bulk carriers. However, the TL rule linkage table only refers to Sec.28 C [3.3.2] and consistency between CRS and Sec.28 might not be guaranteed.

d) Finally, TL rules Pt.A Ch.1 Sec.36 includes additional requirements to CSR BC & OT; however, no reference in TL rules Sec.1 [A] is found. Thus, it is unclear if other TL Sections also apply to those ships and then consistency between CSR and other chapters might not be guaranteed.

In addition, TL Procedure 1600/D, para 5.4.2 contains an introductory note that reads: TL may waive any IACS Requirements (URs) that shall/may not be implemented or shall/may be implemented differently than prescribed by IACS with the concession of IACS. Reservation process is defined in ST-D104. Consequences of these notes are particularly challenging since the TL rules' compliance with GBS basically depends on an appropriate CSR implementation. TL replied that the syntax review of the TL rules, about the application of IACS CSR will be reviewed to avoid possible misleading.



"Regarding TL Procedure 1600/D, TL replied the reservation process is common to all IACS Members. TL defines the same process according to IACS General Procedures". The Audit Team considered that the reservation process is not relevant to non-IACS Members and that TL's rules should clearly state when IACS Resolutions and Procedures referred to, are not fully adopted in TL's rules. Conclusion: TL rules' compliance with the Standards is mainly based on the adoption of IACS Resolutions and Procedures. However, objective evidence on defective and/or ambiguous references to IACS Resolutions (including CSR) and Procedures has been found. Since TL is a non-IACS Member RO, voluntarily adopting IACS Resolutions (including CSR) means legally bound references to IACS Resolutions in TL's rules are critical for supporting TL's GBS verification audit. In addition, evidence on unclear integration between TL and TL CSR rules has been found.

APPLICABLE PROVISION OF THE AUDIT STANDARD:

Auditor: GBS Audit Team Date: August 2018

Team leader: Juan Carlos Cubisino Date: August 2018

Recognized organization: TURK LOYDU Date received:



FINDINGS


Functional requirement: FR 2

Non-conformity No.: Observation No.: TL/2018/OB/01

FINDING: 2

Objective Evidence: For ships over 350 m in length, CSR Pt.1 Ch.1 Sec.2 [3.2.1] states that special consideration is to be given to the wave loads by the Society. TL Pt.A Ch 1, Sec 4 provides qualitative requirements for direct strength calculations and paragraph C [3] establishes that, for ships over 350 m in length with CSR Notation, the wave induced loads and motions shall be calculated by performing the analysis described in C [3.1] based on the wave data of IACS Rec. 34. However, paragraph 3.1 only specifies that wave induced loads and motions can be computed either in the spectral or time domain, but specific criteria in TL's rules for the methodology to be used have not been found. For example, no evidence has been found on loading patterns, hydro-model requirements, non-linear motions and wave load consideration, design wave/return period/extreme values criteria, external and internal local load determination and simultaneity, load and FEM modelling, and acceptance criteria. Additionally, according to CSR Pt.1 Ch.4 Sec.6 [6.1.2], for tanks with a maximum effective sloshing breadth greater than 0.56B or a maximum effective sloshing length greater than 0.13L, a separate impact assessment is to be carried out in accordance with the Society procedures. No objective evidence has been found in TL's rules on sloshing impact assessment when tanks dimensions are outside the range specified in CSR. With regard to sloshing effects, TL replied that it will address this finding and will prepare its own process concerning sloshing impact assessment. Regarding waves loads for ships over 350 m in length, TL replied that it will adopt the procedure as outlined in document MSC 99/INF.19 in this respect. Conclusion: TL has mainly based its rules' compliance with Standards on the adoption of CSR, but some structural requirements in those rules need to be complemented by the Society's individual rules. Objective evidence has been found that TL has not developed the complementary regulations to ensure compliance with Standards. Thus, proper CSR implementation supposes identifying all cases where CSR require complementary regulations to ensure the compliance with Standards and proceed accordingly.


FR 2 – GBS Guidelines Part B Information and documentation requirements paragraph 2.2.3






FINDINGS




FINDING: 3

Objective Evidence: GBS Guidelines, Part B, paragraph 3.2.1.14 and its relevant criterion 3.3.17 stipulates that information and documentation on application to a representative design should be submitted. TL's rule linkage table refers to IACS TB_CA_Rep. However, this TB has been carried out to determine the effect of applying the 1 January 2014 version of the Common Structural Rules (CSR-H). In the Consequence Assessment (CA) evaluation, IACS Societies have used current and representative designs from major builders in Asia. Since TL is a non-IACS RO, objective evidence on the application of TL's rules to a representative design(s) has not been found. TL replied that it is the understanding of TL that the scope of items 3.2.1.14 and 3.3.17 of resolution MSC.296(87) has already been verified (by CA of IACS CSR to representative designs) and found compliant by IMO; therefore, re-verification through TL's application would be an overlap. Later, TL added that the previous version of CSR (not-harmonized) had already been adopted by TL before TB_Rep_CA, as referenced in the TL Rule Linkage Table, and would similarly be applicable for Türk Loydu for the harmonization of CSR and, therefore, the Consequence Assessment Report of IACS. Finally, TL informed that it will prepare a report including one representative design from each type of ship (Oil Tanker, Bulk Carrier). Conclusion: The GBS Audit Team considered that, although IACS TB_CA_Rep was accepted as a common submission of an application to representative designs for IACS Members, it cannot be extrapolated to individual submissions because it is understood in paragraphs 3.2.1.14 and 3.3.17 of the GBS Guidelines that the RO is expected to provide a practical demonstration of a rule's implementation. In addition, the application to a representative design is understood as a tool to verify the influence uncertainties in scantling. Thus, it was concluded that the TL application to a representative design should be submitted.


FR 3 – GBS Guidelines Part B Information and documentation requirements paragraphs 3.2.1.14 and 3.3.17.






FINDINGS




FINDING: 4

Objective Evidence: GBS Guidelines, Part B, paragraph 10.2.1.7 addresses the information recorded in the Ship Construction File (SCF) and its updating, particularly the minimum hull girder section modulus along the length of the ship to be maintained throughout the ship's life. Although the RO rules include a procedure to that effect (ST-D05), no objective evidence has been found on who should check that the minimum hull girder section modulus is maintained throughout the ship's life and how this is carried out in a timely manner during the Enhanced Survey Programme (ESP). Additionally, the GBS Guideline, Part B, para 10.3.1 seeks for SCF updating procedure. The TL ST-D05 SCF updating procedure establishes several updating responsibilities. However, since TL ST D05 are in fact instructions for surveyors, they might be unknown for owners. TL replied that the relevant part of Türk Loydu's Classification and Surveys Rules will be revised to clearly define the responsibilities of concerned parties in updating the SCF. Conclusion: Although TL developed procedures on ESP surveys, who should maintain the minimum hull girder section modulus and how this should be done is not specified. In addition, it was found that the procedure on SCF updating is based on the owner's responsibility, but this role is established in an internal TL procedure and is not clear how the owner is able to achieve this task when technical background is requested. Thus, the TL procedures to achieve full design transparency should be reviewed.


FR 10 – GBS Guidelines Part B Information and documentation requirements paragraphs 10.2.1.7 and 10.3.1.






FINDINGS




FINDING: 5

Objective Evidence: GBS Guidelines, Part B, paragraph 13.2.1 and its relevant criterion 13.3.1 address rules design requirements to provide for spaces of adequate size for ship survey and maintenance. The TL rule linkage table refers to TL Pt.A Ch.1 G [16] as compliance evidence. However, note (7) in G [16] reads that these requirements apply to bulk carriers (BCs) with a GT ≥ 20.000 t. However, SOLAS regulation II-1/3-10 applies to BCs with L ≥ 150 m. Therefore, a gap has been found in the TL's rules in relation to the requirement for means of access for BCs with L ≥ 150 m and GT ≤ 20.000. TL replied that note (7) already dealt with this gap since it reads: "Regardless of its application scope, this sub-section UI SC 190 and UI SC191 is mandatory for bulk carriers subject to GBS". Conclusion: IACS UI 190 and 191 are not meant to address any aspect of this FR (e.g. paragraphs 13.2.1 and 13.3.1). Standards are usually satisfied in ROs' rules by extending SOLAS regulation II-1/3-6 (GT ≥ 20.000 t) to GBS BC & OT (L ≥ 150 m); however, TL's rules clearly do not cover this gap. Thus, evidence shows that TL's rules do not fully satisfy FR 13 for BC & OT with a GT < 20.000 t and L ≥ 150 m.


FR 13 – GBS Guidelines Part B Information and documentation requirements paragraphs 13.2.1 and 13.3.1.






FINDINGS




FINDING: 6

Objective Evidence CSR Pt.1 Ch 8 Sec 5 [2] addresses plate capacity. In paragraph [2.2.4], a correction factor Flong depending on the edge stiffener types on the longer side on the buckling panel is defined in Table 2. IACS TB_Rep_Pt1_Ch08_Sec05 was meant to justify values adopted for Flong in Sec. 5 Tables 2. Besides, TB_Rep_Pt1_Ch08_Sec05 provides some preliminary conclusions when U profiles are used but suggests not making the rule change proposal for the U-type stiffener. On the other hand, CSR allows using c values higher than those mentioned in Table 2 provided these values are verified by a buckling strength check of panels using non-linear finite element (FE) analysis deemed appropriate by the Society. However, no objective evidence has been found in the TL rule set on explanation and benchmarking of the method used to assess plate capacity with edge restrictions other than CSR. It is also noted that CSR Pt.1 Ch 5 Sec 2 [Appendix 2] allows alternative methods for hull girder ultimate strength capacity assessment based on non-linear FE analysis. Application of alternative methods is to be agreed by the Society prior to commencement. Documentation of the analysis methodology and detailed comparison of its results are to be submitted for review and acceptance. The use of such methods may require the partial safety factors to be recalibrated. Objective evidence in TL's rules for non-linear FE analysis assessment and acceptance has not been found. TL replied that in the current version of TL/IACS CSR (with the introduction of RCN 1 to Jan 2014 Version of TL/IACS CSR), U type profiles have already been addressed. Benchmarking methodology has already been described in Technical Backgrounds mentioned above. However, a guideline describing non-linear buckling analysis in this respect will be developed. Conclusion The Audit Team noted both IACS TB_Rep_Pt.1_Ch08_Sec05 and PL-H-CL-001 FINITE ELEMENT CHECK LIST. However, IACS TB only addresses U profiles and the PL-H-CL-001 Check List is not meant for designers since it does not include any consideration on: non-linear geometrical behaviour, inelastic material behaviour, geometrical imperfections and residual stresses, simultaneously acting loads, boundary conditions, interaction between buckling modes and structural elements among others. Since non-linear analysis is required to complement different CSR provisions, it is concluded that specific criteria on assessment and acceptance of non-linear analysis should be included in the rules to ensure full compliance with FR 3.




FR 3 – GBS Guidelines Part B paragraphs 3.2.5.4 and 3.2.5.6.






FINDINGS




FINDING: 7

Objective Evidence CSR Pt.1 Ch.9 Sec.1 [1.1.5] establishes that the "S-N" curves for steel with minimum yield stress higher than 390 N/mm2 are to be considered by the Society on a case-by-case basis. TL Pt.A Ch.1 Sec 3 [6.1.1] establishes that for steel with higher yield strength, data obtained from an approved test programme are to be used. However, design S-N curves for the calculation of the cumulative damage ratio normally include several factors to consider design uncertainties that may not be reflected in laboratory tests. Therefore, objective evidence on design "S-N" curves to be used in non-ordinary steel has not been found in the TL rule set. TL replied please refer to Ch.1, Section 3, D, 6.2 for influence factors to be applied to S-N Curves for non-ordinary steel. Conclusion Correction factor in TL's rules (Ch.1, Section 3, D, 6.2) affects "S-N" curves when minimum yield stress is higher than 235 N/mm2. However, this finding deals with CSR requests in cases when the minimum yield stress is higher than 390 N/mm2. Moreover, the correction factor in TL Section 3 (Table 3.28) would not be fully consistent with CSR Pt.1 Ch.9 Sec.3 [4] "S-N" curves, because linear relationships in CSR curves are different from TL "S-N" curves. To ensure unambiguous and consistent requirements with CSR, TL's rules should be reviewed to state which sections are applicable to CSR BC & OT and how "S-N" curves for steel with yield stress higher than 390 N/mm2 should be adjusted.


FR 4 – GBS Guidelines Part B paragraph 4.3.1

Auditor: GBS Audit Team Date: July 2018

Team leader: Juan Carlos Cubisino Date: July 2018




FINDINGS




FINDING: 8

Objective Evidence CSR Pt1 Ch.11 Sec 5 [1.3.2] requests that in case of height reduced hatch coamings scantlings of the covers, their gasketing, their securing arrangements and the drainage of recesses in the deck are considered by the Society on a case-by-case basis. However, no objective evidence of these provisions has been found in the TL rule set. TL replied please refer to TL Pt A, Ch.1, Sec. 15, B and particularly 4, 5, 6 and D. Conclusion TL's reply it turns out that Sec.15 applies to CSR BC & OT. In this case, minimum design loads included in Sec.15 B [2.1.5] seem not to be fully consistent with minimum loads requested in CSR Pt.1 Ch.4 Sec.5 [5.2]. Evidence has been found that TL's rules may need a general revision to ensure unambiguous and consistent requirements to complement CSR.


FR 8 – GBS Guidelines Part B paragraph 8.3.2.






FINDINGS




FINDING: 9

Objective Evidence GBS Guidelines paragraph 10.3.2 addresses the verification of rules to establish clear criteria and techniques for assessing alternative methods used in the design. The TL rule linkage table refers to TL rules which include provisions for updating SCF and CSR rules and procedures. However, no objective evidence of the criteria for assessing alternative design has been found in the rules submitted. TL replied that "IACS/2015/FR9-15/OB/05" covers this same topic, and the recommendation as defined in document MSC 99/INF.19 will be adopted by TL. Conclusion Although alternative designs need to be addressed on a case by case basis, the importance of having harmonized and transparent criteria for approval cannot be underestimated. It is also noted that Guidelines for approval of alternative designs have been issued by IMO. Thus, it is concluded that appropriate measures to ensure full compliance with this FR should be adopted.








FINDINGS

Recognized organization: TURK LOYD Audit date: June 2018



FINDING: 10

Objective Evidence GBS Guidelines paragraph 10.2.3 and its relevant evaluation criterion 10.3.3 addresses procedures for ensuring that all relevant design and construction information, including correspondence exchanged between the shipyard and the recognized organization, is available to the owner and flag State during the construction process. Although TL included PR03 in the internal procedure 1220/D, evidence on possible rule conflicts has been found since TL Classification and Surveys, Sec 2, A, [2.4.4.1] reads TL will not disclose any information received or reports made in connection with classification to any other party than those entitled or to those having been given the right to receive information by legislation, court decision or written permission from the owner. TL replied that TL Classification and Surveys, Section 2, A, [2.4.4.1] will be revised to avoid possible conflict. Conclusion While the current IACS PR 03 version has been included in TL's internal procedure, the TL legally bound rules clearly state the opposite. Thus, it is concluded that TL Classification and Surveys, Sec 2, A [2.4.4.1] should be reviewed to ensure full compliance with FR 10.


FR 10 – GBS Guidelines Part B paragraphs 10.2.3 and 10.3.3.






FINDINGS




FINDING: 11

Objective Evidence GBS Guidelines paragraph 11.3.2 recommends verifying whether the quality requirements include continuous design improvement based on experience. Although TL submitted several procedures (i.e. 1500/D, 1600/D, ST-D104 and Form PL-16), performance indexes and/or continuous design improvement mechanisms to assess construction quality have not been found. TL replied that IACS/2015/FR9-15/OB/06 covers this same topic, and the outcome defined in document MSC 99/INF.19 by IACS will be adopted by TL. However, IACS/2015/FR9-15/OB/06 is related with GBS Guidelines paragraph 11.3.3 (i.e. quality construction benchmarking). Conclusion The TL rule linkage table refers to the above mentioned procedures to satisfy GBS Guidelines evaluation criteria 11.3.2. It should be noted that FR 11 is meant to confirm that rules contain provisions for ensuring construction tolerances and procedures assumed during rule formulation are implemented during construction; i.e. it is expected that there is a mechanism to assess if rules are effectively implemented in the field. In this context, no objective evidence such as performance indexes and/or any other quantitative or qualitative mechanism on continuous improvement was found. Thus, an auditable system, to ensure that assumptions made during rule formulation are implemented during construction, should be developed.








FINDINGS


Functional requirement: FR 3, FR 11 and FR 12


FINDING: 12

Objective Evidence The TL rule linkage states that the TL Shipbuilding and Repair Quality Standard Additional Rule is a reflection of IACS Rec. 47. However, reference to IACS Shipbuilding and Repair Quality Standard in TL Pt.A Ch.1 Sec.22 E [2.1.1.4] is vague. In addition, although several TL procedures seem to make IACS Rec.47 the minimum quality standard applicable, TL Pt.A Ch.1 Sec.3 E [6.6.2] allows for an alternative to both IACS Rec.47 and TL Shipbuilding and Repair Quality Standard. Finally, although equivalent quality standards may be accepted by TL, evidence on benchmarking of construction requirements with recognized international shipbuilding and repair standards has not been found. Since CSR assumes alignment of all structural members according to IACS Recommendation No.47, the adoption of non-benchmarked quality standards is a source of additional uncertainty in the structural safety level. TL replied that IACS/2015/FR1-8/OB/10 covers this same topic. TL will adopt the necessary modifications in the light of IACS deliverables. (UR Z23, Rev. 7) as defined in document MSC 99/INF.19. Conclusion Selection of quality standards for shipbuilding and repairs has an impact on design life and scantlings. Since the criteria for adoption and/or selection of those standards is unclear in TL's rules, they should be reviewed to clearly state quality standards and equivalency criteria to be adopted in case alternative standards are allowed in TL's rules.


FR 3 – GBS Guidelines Part B paragraph 3.3.7 FR 11 – GBS Guidelines Part B paragraphs 11.2.6 and 11.3.3 FR 12 – GBS Guidelines Part B paragraphs 12.2.4 and 12.3.6






ANNEX

TL RULE SET AUDITED



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Documents

E MARITIME SAFETY COMMITTEE MSC 100/6/4...Naval Architect HoD Hull Structural Engineer IMO GBS Auditor Samsung Heavy Industry, Republic of Korea 3. AUDIT SUMMARY Functional requirement