February 21, 2019
Most major marine operators require that chartered vessels are “classed” by an independent group such as the American Bureau of Shipping (ABS), DNV/GL, Lloyd’s Register, or one of the many others. These groups have assembled very detailed standards for classing everything from oil tankers to auxiliary ship equipment like Remotely Operated Vehicles (ROVs). Many of these standards are based on industry practice or covered by regulations such as reserve buoyancy, the number of life rafts, the types of materials that can be used on a hull, etc.
Classing assures ship owners, insurers, and regulators that vessels are designed, constructed and inspected to accepted standards. Classing may be effective at filtering out unsatisfactory designers and builders, but the established standards do little to weed out subpar vessel operators – because classing agencies only focus on validating the physical vessel. They do not ensure that operators adhere to proper operating procedures and decision-making processes – two areas that are much more important for mitigating risks at sea. The vast majority of marine (and aviation) accidents are a result of operator error, not mechanical failure. As a result, simply focusing on classing the vessel does not address the operational risks. Maintaining high-level operational safety requires constant, committed effort and a focused corporate culture – two things that OceanGate takes very seriously and that are not assessed during classification.
When OceanGate was founded the goal was to pursue the highest reasonable level of innovation in the design and operation of manned submersibles. By definition, innovation is outside of an already accepted system. However, this does not mean that OceanGate does meet standards where they apply, but it does mean that innovation often falls outside of the existing industry paradigm.
While classing agencies are willing to pursue the certification of new and innovative designs and ideas, they often have a multi-year approval cycle due to a lack of pre-existing standards, especially, for example, in the case of many of OceanGate’s innovations, such as carbon fiber pressure vessels and a real-time (RTM) hull health monitoring system. Bringing an outside entity up to speed on every innovation before it is put into real-world testing is anathema to rapid innovation. For example, Space X, Blue Origin and Virgin Galactic all rely on experienced inside experts to oversee the daily operations, testing, and validation versus bringing in outsiders who need to first be educated before being qualified to ‘validate’ any innovations.
As an interim step in the path to classification, we are working with a premier classing agency to validate Titan’s dive test plan. A licensed marine surveyor will witness a successful dive to 4000 meters, inspect the vessel before and after the dive, and provide a Statement of Fact attesting to the completion of the dive test plan.
In addition to designing and building an innovative carbon fiber hull, our team has also developed and incorporated many other elements and procedures into our operations to mitigate risks.
OceanGate’s submersibles are the only known vessels to use real-time (RTM) hull health monitoring. With this RTM system, we can determine if the hull is compromised well before situations become life-threatening, and safely return to the surface. This innovative safety system is not currently covered by any classing agency.
No other submersible currently utilizes real-time monitoring to monitor hull health during a dive. We want to know why. Classed subs are only required to undergo depth validation every three years, whereas our RTM system validates the integrity of the hull on each and every dive.
Our risk assessment team looks at the entire expedition and completes a detailed, quantified risk assessment for each dive. The risk assessment takes into account 25 specific factors that can influence a dive outcome. Using that information, a dive plan is written to mitigate against these known risks. These risk factors include things like weather forecast, sea state, sub maintenance, crew fatigue, predicted currents, dive site experience, recent dive history, schedule expectations, crew experience, and more. In this assessment, the actual operational risks are almost always concentrated on the surface operations not the subsea performance of the submersible.
Another simple risk mitigation step we take, that we believe to be unique to OceanGate is that we draw a small vacuum on the inside of the sub at the start of each dive. This step verifies the integrity of the low-pressure O-ring seal and eliminates the risk of leaks – a proven problem that even some other classed submersibles experience.
Classing standards do have value. In fact, our first submersible, Antipodes, has always been ABS classed and our entire team is well aware of the classing standards and the value of using them as a benchmark for vessel performance. But by itself, classing is not sufficient to ensure safety. In part this is because classing does not properly assess the operational factors are vital for ensuring a safe dive, and because classing assessments are done annually (at best) and do not ensure that the operator follows procedures or processes that are the key to conducting safe dive operations.
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