E

SUB-COMMITTEE ON IMPLEMENTATION III 8/INF.2

OF IMO INSTRUMENTS 19 April 2022
8th session ENGLISH ONLY
Agenda item 12 Pre-session public release: ☒

DEVELOPMENT OF GUIDANCE ON ASSESSMENTS AND APPLICATIONS OF

REMOTE SURVEYS, ISM CODE AUDITS AND ISPS CODE VERIFICATIONS

Verification and validation of inspections carried out with

the assistance of digital and robotic technologies

Submitted by Italy

SUMMARY

Executive summary: This document contains technical information for developing

guidelines for inspection techniques in support of remote inspections
and informs, in particular, on current R&D activities to assess the
effectiveness and reliability of inspections and surveys carried out
with the assistance of digital and robotic technologies.

Strategic direction, if 1
applicable:

Output: 1.18

Action to be taken: Paragraph 22

Related documents: III 7/INF.30; SDC 7/10; MSC 102/22/11, MSC 102/24
(paragraphs 22.18 to 22.20); Circular Letters No.4204/Add.6,
Add.16 and Add.19/Rev.2; MSC 104/15/3, MSC 104/15/6,
MSC 104/15/12, MSC 104/15/24 and MSC 104/18

Introduction

1 During MSC 102, the Committee recalled Circular Letter No.4204/Add.19/Rev.2 on

Guidance for flag States regarding surveys and renewals of certificates during the COVID-19
pandemic, as it was deemed advisable to consistently manage the exceptional extension
beyond three months of safety certificates by flag States, which often delegate recognized
organizations (ROs) to act on their behalf as far as surveys and inspections are concerned.

2 The Committee also considered document MSC 102/22/11 (Republic of Korea),

proposing to develop guidelines for the application of remote surveys for safety inspections
when traditional physical inspections on board are impossible. The proposal highlights the
need to ensure that survey quality is preserved in all cases.

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3 MSC 102 noted that the application of digital and robotic technologies for the
inspections of ships, including remote surveys, will increase, even beyond exceptional
circumstances like the COVID-19 pandemic. Hence the Committee agreed that the
development of technical guidelines for the implementation of such technologies is desirable
and invited interested Member States and international organizations to submit a new output
proposal to the Committee in accordance with the Committees' method of work
(MSC-MEPC.1/Circ.5/Rev.2) (MSC 102/24, paragraph 22.20).

4 Furthermore, amendments to the 2011 ESP Code to include provisions for remote
inspection techniques (RITs) for ESP surveys were discussed at SDC 7 in consideraton of
document SDC 7/10 (IACS).

5 During the pandemic, a few flag State Administrations provided instructions and
requirements to replace physical surveys and audits with digital remote inspections, allowing
their own inspectors and surveyors of ROs acting on their behalf to carry out surveys and
audits according to commonly agreed provisons and procedures, on a case by case basis,
even without physical attendance by surveyor(s)/auditor(s) on board the ship.

6 In the light of the above and accounting for the intrinsic global nature of the shipping
industry, the practice of surveys/audits carried out with the assistance of digital and robotic
technologies, either remotely or not, needs harmonization and standardization to assure a
uniform safety level, equivalent to that of traditional surveys/audits carried out onboard by
human surveyors/auditors.

7 In addition, considering the rapid development of digital and robotic technologies, it

seems likewise appropriate to outline wide-ranging verification and validation methodologies
to ascertain whether surveys/audits assisted by digital and robotic technologies ensure, as a
minimum, a level of safety equivalent to that of traditional surveys/audits and are applicable
not only to present technologies but also to those that will become available in the future.

8 MSC 104, in consideration of the documents submitted agreed to include a new output
on "Development of guidance on assessments and applications of remote surveys, ISM Code
audits and ISPS Code verifications", in the biennial agenda of the III Sub-Committee
(MSC 104/18, paragraph 15.5).

Background

9 Noticeably, IMO Goal-Based Ship construction standards (GBS), i.e. overarching

criteria for development of ship construction rules, require ships to be designed, constructed
and operated for a specified design life. The GBS contain particular provisions on ship's
structures, fittings and arrangements providing for safe operations, access, escape, inspection
and maintenance and thus explicitly underlining the need for adequate condition assessment
of the ship during its service life.

10 While the current regulatory regime for surveys/audits is mainly built on inspections
carried out by humans onboard; rules, guidelines and recommended practices have recently
been updated allowing for the use of digital and robotic technologies. Following this trend, ship
managers and surveyors are exploring the possibility of using digital and robotics technologies
to carry out inspections, possibly simplifying tasks and enhancing both the effectiveness of
inspections and safety conditions. Noticeably, such technologies may have a different level of
autonomy implying a corresponding wider or narrower human intervention. Additionally, they
can be applied either onboard or remotely, depending on their features and on survey type,
scope and goals.

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11 Presently, structural assessment of ship hulls is entirely entrusted to field surveyors.

Hence, it seems impossible to suddenly change the survey system by introducing new
technologies allowing completely autonomous decisions. The final decision about the
applicability of digital and robotic technologies is the decision of the individual surveyor in
charge, as provided for, e.g., in IACS Recommendation No.42. Hence, digital and robotic
technologies can support the survey performance as an autonomous information collector
even when piloted without the onboard presence of the surveyor, who may examine collected
data by streaming video. The surveyor, possibly remotely, examines live images transmitted
by the robotic system, instructing the pilot to approach zones required for a closer inspection.
Recorded information may be also reviewed offline, e.g. for later accident investigations as
recorded evidence.

12 In principle, the adoption of digital and robotic technologies can improve current
inspection practices by ensuring, at least, the same survey quality and thus level of ship safety
as traditional inspections, while reducing time and costs and enhancing the safety of the
surveyor and crew by avoiding exposure of the surveyor to dangerous onboard inspections.
However, complete solutions ready for massive adoption of digital and robotic technologies
are not yet available and autonomy is still limited to pre-defined inspection paths and
operations. Hence, technology, as well as applicable regulations, need to take one step
forward and fill some gaps. Furthermore, although in some cases technology readiness
provides satisfactory solutions, standard testing protocols to assess efficiency in improving
surveys/audits are still largely missing.

Validation and testing of digital and robotic technologies for the inspection of ships

13 The assessment of digital and robotic technologies requires a practical demonstration

in which it must be proved that the test objectives can be achieved in a realistic test
environment within agreed acceptance criteria. The demonstration must be performed
according to standard and recognized verification procedures and by comparing them to
traditional human inspections from different viewpoints. Hence, testing protocols and objective
equivalence criteria are necessary to assess the capability to perform inspections at least at
the same quality level as onboard inspections by measuring technology effectiveness as well
as outcomes of inspections. In fact, the abilities of pilots as well as robots, such as piloting
skills, localization system, dexterity and mobility, operating time, measurements, data quality,
etc., must be evaluated since most of the available technology is not autonomous.
Surveyors/auditors should also be sufficiently skilled to be able to exploit inspection outcomes
from digital and robotic technologies.

14 For the time being, inspection procedures mostly lead to the completion of checklists
filled in by surveyors during and after onboard inspections. In principle, the equivalence
criterion to assess digital and robotic inspection versus those normally conducted on board
may be defined as obtaining the same filled-in checklists for a specific survey, performed
following different approaches (i.e. with and without digital/robotic assistance). The proposed
assessment method is detailed in recent studies1, 2 , suggesting that, in order to compare
inspection outcomes, the very same item should be inspected with the same survey scope and
extension. Hence, in principle, the same hull at the same time and location must be used as a
test case in a well-defined and controlled manner. However, this is practically impossible and

1
Poggi L., Gaggero T., Gaiotti M., Ravina E., Rizzo C.M. 2020. Recent Developments in Remote Inspections
of Ship Structures, International Journal of Naval Architecture and Ocean Engineering
DOI: 10.1016/j.ijnaoe.2020.09.001
2
Poggi L., Gaggero T., Gaiotti M., Ravina E., Rizzo C.M. 2020: Robotic inspection of ships: inherent
challenges and assessment of their effectiveness, Ship & Offshore Structures,
DOI: 10.1080/17445302.2020.1866378

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calls for alternative approaches. Moreover, while automatic filling in of checklists or similar
documents is today conceivable, appropriate instruments and approved algorithms should still
be developed.

15 Due to logistical and trading issues, a shipyard performing proposed tests of digital
and robotic technologies on board faces challenges because of limited time and space
available. For this reason, a dedicated testing environment is proposed where well-defined and
repeatable tests can be performed in a controlled environment, also providing an economical
and suitable provision for pilot training and technology development.

16 The testing facility can be composed of different sections, which represent different
steps in the assessment of technological developments. In general, the first step consists of
passing specific and separate tests in a time sufficient to guarantee adequate information
quality. Once digital and robotic technologies have been proved to work in particular situations,
the second step is to carry out a set of actions normally carried out by a surveyor during
surveys, simulating a significant part of a survey event and considering time taken and
accuracy of acquired data. Hence, another section of the testing facility may consist of a
reproduction of ship parts at different degradation levels into a unified structure where survey
events can be performed.

17 Such assessment approach of digital and robotic technologies also determines the
degree to which digital devices and robots can create an effective team with humans, who
remain those having the decision burden at the end. Indeed, another fundamental aspect of
digital- and robotic-assisted inspections is the interaction and collaboration between inspection
team members, i.e., besides the robot itself, its pilot and surveyor(s), who come from different
industry fields and speak different languages. As a matter of fact, human factor still represents
a key to obtain satisfactory results.

18 The proposed assessment procedure of digital and robotic technologies aims at filling
both technological and regulatory gaps, bearing in mind that if unreliable inspections are
carried out on ships in operation, consequences of undetected damage may become
catastrophic.

Conclusions

19 The shipping industry may be hesitant to introduce digital and robotic technologies as
they may be perceived to involve complex and risky inspection procedures. Indeed, current
international regulations do not address in detail their use, and judgment in their application is
substantially left to the field surveyor on a case-by-case basis. If the surveyor is not on board,
this could become very problematic.

20 Data collected by digital and robotic technologies have advantages and

disadvantages: on the one hand, they contain a broader and more objective information data
set (e.g. images and videos) but on the other hand, suitable and agreed data processing is
needed to extract and elaborate data to meet hull condition assessment purposes. While the
potential of already available digital and robotic technologies is fit for successfully assisting
inspection of ship and offshore structures, the main gap in their application consists of
establishing adequate verification protocols demonstrating at least the equivalence between
digital- and robotic-assisted inspections and traditional human-based ones, supported by an
appropriate regulatory framework.

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21 The abovementioned equivalence criteria and assessment approach for verification

and validation of digital and robotic technologies can be used in guiding research into new
inspection tools and may be the starting point for quantifying robotics’ inspection
performances. The assessment activities aim to define and consolidate inspection processes
and to continuously improve them. Repeatable work processes and appropriate data collection
and analysis of huge amounts of records are fundamental to achieving the goal of effectively
introducing digital and robotic technologies in ship inspections.

Action requested of the Committee

22 The Sub-Committee is invited to note the information provided and take action, as
appropriate.

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