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world's tonnage, and to date, this is lacking. So far, only Sweden, Norway, Singapore, the Bahamas and the Marshall Islands, representing 15.8 per cent of the world's tonnage, have ratified the Annex. At this rate, it is believed that Annex VI will not come into force until perhaps as late as 2007. It was clear that this was unacceptable in Capt de Keyzer's point of view. He called on IMO to give MARPOL a "facelift", or else the industry would have to bow to the will of Brussels. Another important issue is that of sulphur emissions, a key factor in the generation of acid rain in Europe. This has become a major issue for ship operators, who may be subject to the EU's Directive on Sulphur in Fuels. The Directive may require ships to store and burn at least two different types of fuel in different geographical areas. There are several alternatives being discussed within the industry, not least the emissions trading scheme being championed by BP Marine and the suggestion that economic instruments, in the form of higher port dues, could be used to reduce sulphur emissions. According to Capt de Keyzer, the latter is unacceptable. "Over our dead bodies," he said; economic instruments such as that suggested above could reduce the competitiveness of Rotterdam and distort competition between European ports in general. The balance between the environment and the economy must be safeguarded, he said, and a productive, pro-active approach must be adopted.

In the public eye The concept of risk management has taken hold in the shipping industry in recent years, and particularly so in the tanker sector, where one misstep can result in negative headlines for years afterwards (witness the Erika). According to Patrick Russi, general manager for quality assurance, safety, ship vetting and regulatory affairs for the Stolt-Nielsen Transportation Group, owners have to have an adequate strategy for managing their operational risk. He delineated four areas where owners and operators have to exercise vigilance, and these were: safety risk, environmental risk, equipment risk and continuous improvement processes. Dealing with safety risk involves targeting the 80 per cent human error factor, and this can be done by putting quality assurance programmes into place, overseeing hiring practices and instituting training programmes for existing staff. Stolt-Nielsen, for example, adheres to what Russi termed as "the most comprehensive standard for shipmanagement", the International Ship Management Code (ISMA), which involves a stringent quality audit regime and the maintaining of proper management controls. In the realm of hiring practices, minimum requirements should be identified and verified; skills and language testing should be carried out on a regular basis; and turnover needs to be monitored and controlled and perhaps minimised, as lower turnover reduces the incidence of human error. Environmental risk is a major component of any operator's overall risk. Russi suggested putting comprehensive environmental operating procedures into place. Stolt-Nielsen, for instance, has extensive emergency response planning, training and testing, as well as a 52-week drill schedule for all ships. In addition, the company's new ships (of the P-37 class) have been specifically designed to be environmentally friendly, with medium speed engines, resulting in lower levels of emission, propulsion redundancy and efficient stripping systems. Stolt-Nielsen also carries out annual contingency exercises with the US Coast Guard and other authorities and was chosen this year to participate in a safety drill with ExxonMobil, DowUCC and governement agencies, at a cost of $60,000 to the company. Russi also advocated a straightforward approach to media relations in the event of an incident occurring. Equipment risk primarily involves the condition of the ship itself and of the equipment onboard. Russi pointed out that the construction of chemical tankers (multiple, small tanks and double hulls) means that only the cargo in the penetrated tank is at risk. Stolt-Nielsen's ships are built to trade in the chemicals market (Russi emphasised

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