A Chief Engineer Officer & PhD Research Student wrote to CHIRP in response to Maritime FEEDBACK 35 where it was reported after 10 years, there had been no improvement in the standard of Marine Operating and Maintenance Manuals.
There are a number contributing factors towards a seafarer’s reliance upon operating and maintenance manuals: failure of training and certification to keep pace with the rate of change of technology; rapid movement of Officers through ranks; reduced staffing levels, etc. Such factors contribute towards a knowledge gap and the absence of a short-term solution to such factors will ensure that procedures remain critical throughout a seafarer’s career.
Reliance upon procedures emphasizes the need to properly understand the way in which seafarers utilise operating and maintenance manuals. It has long been established through academic research that operating and maintenance procedures need to serve three primary functions: selection, inference and switching (from instruct- ion to task). These basic functions are underpinned by complex processes, which either promote or mitigate human error.
Non-seafarers often prepare the ship’s operating and maintenance manuals, they may perhaps have an in-depth knowledge of their own equipment but have little understanding of technical communication, task analysis and level of seafarers’ prior knowledge [STCW]. This leads to a failure of both user navigation and comprehension of the procedure. There is no immediate communicative feedback to the writer, so procedures are always a negotiated meaning and don’t necessarily translate to what the writer thinks is being communicated. Alternatively, there are manuals produced by specialist technical authors with little system knowledge other than that passed to them by the manufacturer (often in a foreign language). These manuals tend to be very aesthetically pleasing with a high degree of graphic design but of poor technical content.
My current Doctoral research was triggered by the earlier CHIRP report, “Marine Operating and Maintenance Manuals – Are They Good enough?” Commencing research in 2010, it became clear quite quickly that although standards and guidance’s exist, none address the critical questions of supporting systematic thinking (filling the knowledge gap) and the mitigation of human error. The answers lie within an eclectic body of research spanning risk analysis, technical communication, philosophical theories of semiotics, cognitive loading, constructivism and many other such subject matters considered outliers within the maritime professions. In early 2013, a pilot study was conducted using two groups of seafarers to validate two rule-based error-provoking markers identified through literature review. These results proved promising and with
the main study scheduled later this year, it is hoped that 2015 will add some clarity to the issue.
Standards of operating and maintenance manual content is one issue, regulatory failure is another! The IMO Maritime Safety Committee circular MSC.1/ Circ. 1253 “Shipboard Technical operating and Maintenance Manuals” states that the enforcement of accurate and up to date operating and maintenance manuals could be achieved through the mechanisms of the ISM Code. This is a wholly reactive measure and without a clear regulatory foundation, burdening shipping companies with such a responsibility is an unfair and ineffective strategy of self- regulation. The circular further recommends IACS Recommendation 71 is used as a model for shipboard technical operating and maintenance manuals. Recom- mendation 71 however was not without its problems proposing ISO 8779 (a standard for the use of poly- ethylene pipes for irrigation) as a guide for document mark up language. After 14 years in circulation the error was eventually identified and corrected. This might have been an innocent typo, but contemplate a different scenario and such an error in a torque setting might lead to an entirely different set of consequences. It does however serve to highlight how easily an error may penetrate multiple layers of editorial governance, even through the scrutiny of the IMO.
There are currently very serious issues of control asso- ciated with regulators failing to ensure that operating and maintenance manuals are fit for purpose when issuing machinery certification. The 2012 NOMAD project com- missioned by 14 EU member states examined the noise- related content of instructions supplied with machinery offered for purchase in the European Economic Area (EEA). The project reviewed 1,500 sets of instructions within 40 machinery groups from 800 manufacturers. The infor- mation in these instructions was analysed to determine compliance with the European Machinery Directive, and assess the quality of information. The report concluded that the general state of compliance of machinery instructions was found to be very poor: 80% of instructions did not meet legal requirements. In fact, the report further stated that 8% of the documents surveyed were not even in an official European Community language. One may be forgiven for questioning the competence of EU authorising bodies for presiding over such an industrial level of failure.
To supply inadequate operating and maintenance manuals is as dangerous as supplying faulty tools. Incidents such as the Isle of Arran, P&OSL Aquitaine, CSL Pacific and the Arco Adur are testimony to this. However, with a lack of validated submissions for the IMO to consider and failure to regulate the current standards of operating and maintenance manuals, perhaps we need to accept that (from seafarer to delegate) there is a collective respon- sibility to bring about change.
Maritime FEEDBACK 35 serves as an excellent reminder that after 10 years, the consequences of the inter- national community’s failure-to-act, as always, falls squarely on the shoulders of the seafarer.
The author of this letter through IMarEST submitted an information paper to the IMO SUB- COMMITTEE ON HUMAN ELEMENT, TRAINING AND WATCHKEEPING. November 2014. Now available online from the IMO web site “HTW 2-INF.3 – Human Error Controlled Language in Operating and Maintenance Manuals Supplied to Ships (IMarEST).pdf”