Files
Abstract
Abstract for joint Paper between Stehr Consulting Ltd and Safeguard Engineering Ltd to be submitted into IMarEST International Naval Engineering Conference and Exhibition (INEC) – 5-7 November 2024 (IMarEST | INEC/iSCSS 2024).
Objective: increase visibility of both respective organisations within this sector by showcasing our capabilities and thought leadership. Be subtly disruptive to the ‘normal’ stakeholders by submitting a paper that leverages our distinct experience and expertise.
This collaborative paper aspires to combine our unique perspectives as independent Subject Matter Experts, harnessing our collective companies’ expertise from pivotal roles at the Maritime and Coastguard Agency (MCA) and Defence Maritime Regulatory (DMR). Our engagements with project teams, owner operators, and technology developers in both Defence and Commercial domains afford us a comprehensive, understanding of the opportunities and challenges in safely implementing cutting-edge and complex systems, particularly those incorporating increased levels of Automation and Autonomy across these two industry sectors.
While we acknowledge the deliberate provocativeness of our title, designed to ignite discussion and curiosity, we recognise the sector's exciting potential alongside its inherent traditions of prescriptive applications and challenges of applying goal based regulations. In parallel with industries embracing disruptive technology, criticisms often target regulatory bodies, with comments often suggesting that the main barrier to development and adoption is due to regulation.
Our perspective diverges subtly. While acknowledging substantial regulatory barriers, we contend that the key issue lies in demonstrating safety assurance of technology, especially in Autonomy. The nuanced distinction between Regulation and Assurance, frequently overlooked, contributes to a somewhat misguided allocation of responsibility in the industry. This paper aims to explore diverse observations and insights within this domain, drawing parallels between Defence and Commercial Maritime landscapes considering key aspects such as:
1. The current industry landscape, shedding light on the challenges impeding the transition of Autonomous Marine platforms from concept to successful trials to operational contexts.
2. Industry dynamics driving the sector forward, exploring potential divergences or convergences between Commercial and Defence domains.
3. Observations on the industry's forward momentum in technology development, emphasising the need for a clear strategy for assurance from inception to enable transitions from test environments to real-world applications.
4. High-level challenges in assuring Autonomy and ongoing efforts to address them.
5. Overview of strategies to overcome challenges in assuring Autonomy and potential avenues for further improvements.
While Maritime Autonomy specific remains the primary focus, the paper will also delve into broader challenges faced by Maritime regulatory approaches, encompassing:
1. The transition from a prescriptive to a goal-based safety case regulatory approach, exploring increased flexibility for innovation at the expense of certainty and technical effort required. Whilst defining a framework in which a goal based approach can be applied consistently;
2. Challenges faced by regulators in terms of resourcing demands and meeting industry needs.
3. The necessity for more delegation, its challenges including risk ownership and commercial competitiveness.
4. Implications on the international regulatory model, including port state control and the competitive landscape.