Circular No. 6/99 - The Millennium Bug - Good Practice and Contingency Planning
APRIL 26, 1999
CIRCULAR NO. 6/99
TO MEMBERS OF THE ASSOCIATION
THE MILLENNIUM BUG - GOOD PRACTICE AND CONTINGENCY PLANNING
Reference is made to the Club's last Circular on this subject (No. 5/99 of March 5, 1999). In that Circular Members were made aware of the March 3 and 4 meeting hosted by the U.S. Coast Guard at the International Maritime Organization's headquarters in London. Members were told that they would be informed of any noteworthy outcomes of the meeting in due course.
The Club has pleasure in doing this herein. Specifically, the meeting decided to support dissemination within the maritime industry of:
1. A Year 2000 Code of Good Practice; and
2. A short guide to the key elements of Y2K contingency plans for ships, ports and terminals.
Copies of these two documents are attached to this circular as Appendix I and Appendix 2 respectively.
The Code of Good Practice is based substantially on terms originally put forward by the International Chamber of Shipping.
The decisions of the meeting underpin the broadening recognition in the industry that contingency plans are essential in preparation for the Year 2000. Publication of this Code and its adoption and implementation as broadly as possible across the industry are of considerable importance.
With respect to Club cover, the preparation of appropriate contingency plans will be one of several factors which will indicate whether a Member has acted prudently in relation to millennium-related problems. Members will be aware of the continuing need to take all prudent steps to ensure their own millennium compliance.
If any Member should require any further guidance in respect of the above, the Managers will be pleased to respond.
Joseph E.M. Hughes, Chairman & CEO
Shipowners Claims Bureau, Inc., Managers for
THE AMERICAN CLUB
The Year 2000 Code of Good Practice
The Year 2000 problem, sometimes referred to simply as Y2K, is the term used to describe the potential electronic date recognition (EDR) failure of information technology systems prior to, on or after January 1, 2000. The potential exists because of the widespread practice of using two digits, not four, to represent the year in computer databases, software applications and hardware chips. For example, difficulty will arise in the Year 2000 when machines may be unable to differentiate it from the year 1900. As a result, microchip based systems may function incorrectly, or not at all.
The equipment involved may be as simple as a clock; as sophisticated as the monitoring and control system for the main engine plant; or as complex as a port's vessel traffic system (VTS). All affected parties must assess the extent of the problem in their operations, prioritize potentially non-compliant units/systems and decide on the correct action. Depending on the system, equipment or software involved, the correct action may be to repair it, replace it, or use alternative systems or manual operations.
Awareness of the nature and extent of the problem is critical in correcting it. The problem does not reside merely in mainframe or personal computer systems. It also affects programs embedded in any microchip based system. One of the first steps in addressing the problem is to conduct an inventory of equipment that may be affected in order to establish whether or not software and hardware are Year 2000 compliant. Failure to identify and correct systems that could be affected by the Year 2000 problem could result in serious safety problems such as unexpected shutdown of the main engines and ships' navigation systems or a breakdown in communications, or loss of shore utility services.
This Code of Good Practice recognizes that the risk of unforeseen Year 2000 related failures cannot be totally discounted, notwithstanding that all proper steps to rectify possible Year 2000 problems may have been taken. It is vital, therefore, that ship operators, port authority and terminal operators identify, and put in place, operational contingency plans to ensure that safety is not compromised in the event of an unforeseen Year 2000 equipment or system malfunction. The Code acknowledges the need to exchange information and assurances relating to the measures and precautions taken by shipping companies and ports respectively if navigation and port operations are to continue during Year 2000 critical periods.
Elements of the Code of Good Practice
The Code recommends measures whereby those responsible for ship, port and terminal operations can reduce the risks associated with the possible malfunction of equipment incorporating "embedded systems", as well as computer equipment, which may be dependent on electronic date recognition. It stresses the importance of
the shipmaster's freedom to use his professional judgment in accordance with SOLAS, Chapter V, regulation 10-1 1;
the shipowner's, master's, port authority's and terminal operator's respective responsibilities for safety and the environment;
compliance with rules and recommendations covering such matters as passage planning, maintaining appropriate margins of safety in case of breakdown, and prompt reporting when so required;
the exchange of information between involved parties so as to ensure that all concerned are fully informed and that the measures that have been taken are appropriate to the circumstances;
the provision of suitable additional training where appropriate.
The Code is not intended to preclude the adoption of other measures by individual shipping companies, port authorities and terminal operators. Nor does it relieve those responsible of their duty to use their discretion in light of the many factors which contribute to safety and pollution prevention.
It is recommended that for the duration of any period when there may be date induced uncertainty as to the performance or functionality of computer systems, electronic and electro-mechanical or similar equipment, the following precautions should be adopted:
1. Sufficient competent personnel should be available on ships and within ports and terminals to monitor and maintain extra vigilance on critical systems and operations, and respond immediately to equipment failure during the Year 2000 critical periods. Furthermore, if it is planned to introduce operational contingency plans in excess of normal practice, it is important that staff are fully trained and exercised in the implementation of such plans.
2. Prior to entering confined or congested waters and areas where hazards to navigation exist, the master, taking into account the prevailing circumstances and any advice or instructions received, should decide on the appropriate action to be taken to ensure the continued safety of his ship, crew, passengers and cargo, bearing in mind that not only the ship, but other ships in the vicinity, could lose power, steering or the use of electronic navigation equipment. If the master deems that the safety of the ship is at risk, the master should consider measures to minimize the risk by such means as reducing speed, delaying entry to the port or steering an alternative course.
3. The port or terminal may obtain information in advance from ship operators in accordance with the questionnaire in Annex 1. Prior to arrival in or departure from a port or terminal, or before entering port limits, information from authorized personnel should be exchanged by appropriate means between the ship and the port or terminal, as provided for in the questionnaires in Annexes 2 and 3.
4. Prior to a ship entering or navigating within a port, the port authority or terminal operator should advise the ship of any additional conditions or constraints on navigation or cargo handling that the port authority or terminal operator has decided are necessary in order to minimize the risks associated with any Year 2000 equipment malfunction. Such measures might include minimum separation between ships, speed constraints, the use of tugs, loading/discharge restrictions etc.
5. If, after exchanging information, and prior to commencing cargo handling or bunkering operations, there is doubt whether the planned operation can be conducted safely, and without hazard to the environment, property or personnel, the master, port authority or terminal operator should within their respective scope of responsibility, postpone or suspend the operation until the risk of Year 2000 equipment malfunction has passed.
6. Following a Year 2000 critical period, all equipment not used during that period, and potentially affected by electronic date recognition problems, should be tested to ensure that its performance had not been adversely affected.
To: (Name of Ship Operating Company) ________________________________________
Please answer the following questions if your company anticipates that a ship or ships operated by the company is expected to arrive at, operate in, or depart the above port during a period when there might be date induced uncertainty as to the performance or functionality of computer systems, electronic and electro-mechanical or similar equipment.
Person responsible for Year 2000 Policy, Name:________________________________
To: (Name of Ship) ______________________________________________
Please answer the following questions as fully as you can. Your response to this questionnaire will assist the Port Authority/Terminal Operator in deciding whether due care has been exercised in avoiding possible equipment failure caused by Year 2000 electronic date recognition problems, and in putting in place contingency plans to cope with unforeseen failures.
Company : _________________________________________________________________________
Ship's IMO Number : _______________________ Flag : ___________________________________
To: (Port Authority / Terminal Operator) _________________________________________ ____
Date / time of expected arrival / departure ___________________________________ __________
It is anticipated that the above ship will/may require to navigate or handle cargo within your port on or around the above dates. Please complete the following questions concerning the Year 2000 preparations made by the Port Authority/Terminal Operator.
1) Does the Port Authority/Terminal Operator have a documented Year 2000 policy in place?
2) Has an inventory check to identify and categorize non-compliant equipment been carried out?
3) Has all equipment critical to the safety of navigation/cargo handling been assessed for Year 2000 compliance?
4) Has the Port Authority/Terminal Operator investigated potential problems and solutions?
Where non-compliant equipment has not been replaced or upgraded, have alternative systems or manual operations been established?
6) Has the Port Authority/Terminal Operator sought to establish whether its critical suppliers, utilities and external services are Year 2000 compliant?
7) Is there serious doubt as to the availability of any supply, utility or service which is critical to safety?
8) Does the Port Authority/Terminal Operator have operational contingency plans in place to cope with unforeseen Year 2000 equipment malfunctions?
9) Have these contingency plans been tested and reviewed to confirm their effectiveness?
10) Has all necessary information been exchanged and agreed with the ship/shipping company or any additional Year 2000 specific requirements applicable to port/terminal operations?
KEY ELEMENTS OF Y2K CONTINGENCY PLANS FOR SHIPS, PORTS AND TERMINALS
Specific Y2K contingency plans are necessary, as the chance of successfully finding and fixing all "Year 2000" problems is small. Furthermore, others within the transportation infrastructure could let you down.
This is a short guide aimed at assisting those in the marine transportation industry to understand the elements of Year 2000 Contingency Planning which may supplement/complement existing emergency response plans.
The following are examples of some specific Year 2000 factors that could be taken into account when drawing up Year 2000 contingency plans:
Year 2000 failures may result in multiple/simultaneous failures of ships and port systems
Integrate Year 2000 specific training into existing incident training structures
Increase familiarization with and check all manual control operations
Check all user operations/instruction manuals are available and up to date.
The above is in addition to more general points that need to be considered when addressing continency plans such as ...
Identify equipment, systems, and systems integration which could be critically affected by Y2K (examples are attached in Annex 1 and 2). The lists contained in the Annexes are not exhaustive and consideration should be given to the individual requirements of the specific ship, port or terminal.
Description of failure scenarios. For each critical system, a failure scenario should be described. Failure scenarios should include when a failure is most likely to occur and the minimum and maximum amount of time the failure will exist.
An evaluation of risk. Within risk one should cover the PROBABILITY an event will occur and the IMPACT, in terms of safety and business continuity, it may have on the port/terminal or vessel. At a minimum, IMPACT should be delineated into three categories. Example definitions follow:
High Risk - Failure of a high-risk item could cause loss of life, loss of a vessel, a collision or grounding, a major pollution incident, closure of port facilities or a serious threat to company survival.
Medium Risk - Failure of a medium risk item could cause delays to operations, commercial penalties or fines for Pollution.
A listing of mitigation options. These are preventative actions that can be taken well in advance of the onset of a failure trigger date to offset or mitigate the effects of the failure. The chosen mitigation option should include the accepted risk that remains after it has been implemented.
A listing of contingency options. Contingency options are strategies for responding to failure scenarios. It is anticipated that recovery procedures will already be in place for equipment, systems and system integration to address operational recovery from minor process failures up to complete critical system failure. However, these procedures should be reviewed and supplemented as required in light of the Year 2000 problem.
ANNEX 1 : EXAMPLES OF POSSIBLE CRITICAL SYSTEMS FOR PORTS AND TERMINALS
Customs and Other Agencies
Passenger and Crew Services
Waterway and Port Management
Aids to Navigation
Pilotage and Tug Service
Power Supply and Generation
Maintenance and Repair
Health and Safety
Business Activities and Processes
Vehicles and Handling
ANNEX 2 : EXAMPLES OF POSSIBLE CRITICAL SYSTEMS FOR SHIPS
Propulsion and Utilities
Engine Control and Monitoring
Electrical Power Generation
Emergency Power Generation
Maintenance and Repair
Crew and Passenger Services
1 SOLAS Chapter V (Safety of Navigation), regulation 10-1:
Master's discretion for safe navigation. The master shall not be constrained by the shipowner, charterer or any other person from taking any decision which, in the professional judgment of the master, is necessary for safe navigation, in particular in severe weather and in heavy seas.2