The Adoption of Maritime Autonomous

Surface Ships - A Regulatory Framework

1
 Structure of IMO External Stakeholders
IGOs with observer status –
Internal Stakeholders AALCO, ISA, WCO, ICES, IOM,
IHO, ​Paris MoU, COSPAS-SARSAT,
Membership States
UNWTO, EC …
173 countries

Assembly NGOs in consultative status –

ACOPS, BIC, BIMCO, CSC, ICC,
Council – Members: Category A (10 ICS, ISO, ISU, IUMI, P&I Clubs,
countries), Category B (10 countries), WSC, IAPH, GloBallast …
Category C (20 countries)
Groups be founded by IMO –
Committee – WMU, IMLI.
MSC, MEPC, LEG, FAL, TC
Other IGOs – EU, UN …
Secretariat
Other NGOs – UNITAR, UNCTAD,
Intergovernmental organization (IGO); The Asian-African Legal Consultative Organization (AALCO); NIMASA, ASEAN, ILO, ICAO,
International Society of Automation (ISA); World Customs Organization (WCO); International Council for the
Exploration of the Sea (ICES); International Organization for Migration (IOM).
IMCO, EBRD, OPEC, APEC,
Source: https://www.imo.org/en/About/Membership/Pages/IGOsWithObserverStatus.aspx
Highlight in the 99th MSC, IMO
The method for this study

• Reviewing over 100 IMO

documents (mainly from
MSC, LEG and FAL)
• Using document analysis
and thematic analysis
methods
• Adopting a perspective on
policy formation
Why some stakeholders
promote autonomous
shipping ?
 Social and Economic Issues (MUNIN)

• Maritime transport within the EU faces challenges such

as significant increases in transport volumes, growing
environmental requirements and a shortage of
seafarers in the future.
• The shore based approach offers “seafaring” the
possibility to become more socially sustainable by
reducing the time seafarers spend away from their
families, which is the reason caused the unattractiveness
of seagoing professions.
• Routine tasks on board would be automated and only
the demanding but interesting navigational and technical
jobs transferred from ship to a shore side operation
center controlled by a remote operator making
“seafaring” jobs more interesting.
Source: Maritime Unmanned Navigation through Intelligence in Networks (MUNIN)
(http://www.unmanned-ship.org/munin/)
Safety Consideration (Denmark, DTU)

• Human error is the triggering factor in

62% of incidents with EU registered ships
from 2011 to 2016 .
• Work on deck is 5 to 16 times more
dangerous than jobs ashore.
• Autonomy has been tested on small
vessels for both civilian and military use
for two decades. Plans for large vessels
for military use are known.
• Increased autonomy point to the
possibility of increasing safety at
sea, in possible to reduce the
collision incidents and lookout.
(Source: MSC 98/INF.13)
 Policy and competitive considerations I (Denmark, DTU)
• The costs for the truck driver account for approx.
1/3 of total costs, a reduction of these costs will
increase competitiveness of road transport.
• EU has the goal that 30% of goods transports
over distances above 300 km should be by
either sea or in 2030.
• A decisive element in the analysis of the suitability
of autonomous ships for goods transport is
associated with the competition interface with
transport by truck.
• Logistics and document handling form part of the
business models to be considered as part of the
introduction of autonomy at a given level.

(Source: MSC 98/INF.13)

 Policy and competitive considerations II (Denmark, DTU)
• A transition to electrical propulsion of ships
will radically reduce the need to monitor the
machinery and, furthermore, probably result in
a larger degree of operational reliability and,
thus, reduced operation costs.
• MUNIN, a concept study for a fully unmanned
handymax dry bulk carrier on intercontinental
voyage. On such long free distances, the
autonomous technology can really unfold and
result in large profits, especially because of
reduced crew costs and better fuel economy.
• These elements are to counterbalance higher
construction costs.
(Source: MSC 98/INF.13)
Suitable ship types I (Denmark, DTU)

• Smaller types of ship in local traffic would be more suitable.

• This will make it possible to combine autonomy with electrical
propulsion, which may reduce the manning requirements drastically.
• The following types deserves to be mentioned:
✓ Small/minor island ferries.
✓ Tugs.
✓ Barges.
✓ Supply/service vessels for drilling platforms,
wind turbines, etc.
✓ Autonomous surface vessel for servicing
underwater and drone units for offshore
inspection.
(Source: MSC 98/INF.13)
Suitable ship types II (Denmark, DTU)

✓ Small/minor island ferries:

Isolation presents a challenge to Danish
island communities. One main reason is
the lack of frequent transportation.
Autonomous technology could make it
possible to book an electrically powered
ferry when needed (e.g. commuting,
emergency situation). The ferry could
optimize its timetable by itself and inform the
passengers when they will be picked up.

(Source: MSC 98/INF.13)

What is MASS?
The document mentioned MAS:
MSC 95-INF.20

The IMO regulatory framework

and its application to Marine
Autonomous Systems (MAS)

(Source: MSC 98/20/2)

The first document mentioned
MASS: MSC 98/20/2

Maritime Autonomous Surface

Ships(MASS)
Proposal for a
regulatory scoping exercise

(Source: MSC 98/20/2)

Unmanned Maritime Systems

Source: https://www.pinterest.com/pin/597712181764562285/ 16
Definitions for levels
and concepts of
autonomy
 Autonomy levels adapted from different parties (from 4 of 7)
Ramboll-Core M R RU A
Manual Remote Remote, Autonomous
unmanned

Bureau Veritas 0 1 2 3 4
Operated by Directed by Delegated Supervised Fully
a human a human by a human by a human autonomous

Rolls-Royce Level 0 Level 1 Level 2 Level 3 Level 4

No Partial Conditional High Fully
autonomy autonomy autonomy autonomy autonomy

Lloyds Register AL 0 AL 1 AL 2 AL 3 AL 4 AL 5 AL 6
Manual Decision- On-board Execution Execution Monitored Full
steering support or shore- with with autonomy autonomy
on board based human human
decision who who
support monitors monitors
and and can
approves intervene Source: MSC 99/5/6
The number of regulatory barriers increases as the autonomy
level is increased

(source: MSC 98/20/13, MSC 99/5/10)

Fundamental legal
questions about
autonomous shipping
Key questions for regulatory scoping exercise I
(Comité Maritime International, CMI)

1. Would a "cargo ship" in excess of 500 grt, without a master or

crew on board, which is without any human supervision,
constitute a "ship" under your national merchant shipping law?

• Is an “autonomous ship” a ship or a “structure”?

• The definitions of a ”ship” and a ”vessel”?
• Seaworthiness of a ship?
Vessel includes any ship or boat, or any other description of vessel used in
navigation; ship includes every description of vessel used in navigation not
propelled by oars.
(source: MSC 99/INF.8)
Key questions for regulatory scoping exercise II (CMI)

2. Could remote-controllers, chief pre-programmer of an

autonomous ship, another "designated" person who is
responsible on paper, but is not immediately involved with the
operation of the ship constitute the "crew" or “master” for the
purposes of your national merchant shipping laws?

• Is an unmanned ship’s remote-controllers a crew?

• The definitions and requirements of a ”seafarer”?
• Manning requirements?

(source: MSC 99/INF.8)

Key questions for regulatory scoping exercise III

3.Autonomous ships operate "side-by-side" with non-

autonomous

• During a rather long transition

phase problems could arise in
situations where autonomous
ships are operating "side-by-
side" with non-autonomous
ships. In such situations, the two
types of ships must be expected to
react in different ways.
 Why has IMO
decided to look at
the regulation of
autonomous ships?
Why we need a regulatory scoping exercise for MASS
(Denmark and other 8 member states)
• The service of a variety, size and geographical spread
using of the MASS are growing.
• Some Classification Societies have recognized this trend
and have already published design criteria and guidelines
for MASS. Some States have established national
guidelines for the operation of MASS within their jurisdiction.
• The existence of different national regulatory
frameworks may render the construction and operation of
MASS unmanageable, and may hamper innovation and
technological developments.
• IMO should take a proactive role to ensure there is a
harmonized international approach to MASS for relevant
stakeholders.
(source: MSC 98/20/2)
 The IMO’s official statement

• IMO's Strategic Plan (2018-2023) has a key Strategic Direction to

"Integrate new and advancing technologies in the regulatory
framework". This involves balancing the benefits derived from new
and advancing technologies against safety and security concerns,
the impact on the environment and on international trade facilitation,
the potential costs to the industry, and finally their impact on
personnel, both on board and ashore.
• In 2017, following a proposal by a number of Member States, IMO's
Maritime Safety Committee (MSC) agreed to include the issue of
marine autonomous surface ships on its agenda. This would be in
the form of a scoping exercise to determine how the safe, secure
and environmentally sound operation of Maritime Autonomous
Surface Ships (MASS) may be introduced in IMO instruments.
• Autonomous ships: regulatory scoping exercise (RSE) completed on 25
May 2021. https://www.imo.org/en/MediaCentre/PressBriefings/pages/MASSRSE2021.aspx 26
Stakeholders are not
on the same page in
the initial discussions
Stakeholders have diverse opinions during the initial discussions

Numbers of
Category of documents Main submitters
document
Agreeing opinions 4 Denmark, Finland, Norway, …
Disagreeing opinions 4 ITF, IFSMA
Neutral and tentative opinions 5 Japan, Turkey, China, France, …
Suggestions of working plans 5 Secretariat, ICS, US, …
Suggestions of regulatory CMI, Canada, Denmark,
5
revision Japan, …

IFSMA: International Federation of Shipmasters' Associations

ITF: International Transport Workers' Federation
ICS: International Chamber of Shipping
(source: documents from MSC 98, MSC 99, LEG 105)
CMI: Comité Maritime International
Manufacturer’s perspective (Rolls Royce)

29
(source: documents from MSC 98, MSC 99, LEG 105)
 30
(source: a special section (2018) of MSC’s 100th section)
 Questioning about MASS RSE (IFSMA, ITF)
Document no. Main points Co-sponsors
• A precise definition of "autonomous ship“ and levels of autonomy should be clarified. ITF
MSC • Human element factors should be considered. (International
98/20/13 • The output should cover all autonomous ships, partially manned or unmanned. Transport
Forum)
• UN Divisions should be consulted (UNCLOS). IFSMA
• All relevant committees within IMO should be invited (MSC, MEPC, LEG, FAL, …). (International
• As the volume of existing international instruments and the new issues may be raised, Federation of
MSC 99/5/1 the target completion date should be amended to 2023. Shipmasters'
• International voyages are not permitted to operate until an international Associations)、
regulatory framework governing their operation has been adopted and is in effect. ITF
• Need a comprehensive analysis of safety comparable to conventional ships.
• The regulatory framework would be user experienced and demand-driven,
rather than technology-driven.
• In a later phase, ships may be capable of operating in dual mode relying on semi-
MSC autonomous systems under routine circumstances with higher levels of onboard
human involvement under non-routine circumstances such as high traffic, congested ITF
99/5/10
waters, rough weather, equipment failure, or unforeseen circumstances.
• Having fully autonomous unmanned ships as the primary goal of a regulatory
framework at this time, is an unrealistic time-consuming distraction from what
could be a productive advancement in safety and efficiency through technology.
(source: MSC 98/20/13, MSC 99/5/1, MSC 99/5/10)
What maritime professionals think about autonomous shipping
(IFASMA and ITF)
1. Timeline

(Source: MSC 99/INF.5)

What maritime professionals think about autonomous shipping

2. Jobs

(Source: MSC 99/INF.5)

 What maritime professionals think about autonomous shipping

3. Safety

‘These companies are only interested

in creating a market for their products
and services and cloaking this in the
guise of safety,’ one shipmaster wrote.

(Source: MSC 99/INF.5)

 What maritime professionals think about autonomous shipping
3. Safety Risk

(Source: MSC 99/INF.5)

 What maritime professionals think about autonomous shipping
4. Optimum Safety

Level of autonomy

One officer noted:

‘If higher automation releases ships’ staff to monitor more
effectively what is happening aboard their vessels, that has to
be an advantage since crews on many types of ship are
overworked and tired, making poor decisions and accidents
more likely.’
(Source: MSC 99/INF.5)
What maritime professionals think about autonomous shipping
5. Training and certification

(Source: MSC 99/INF.5)

Phased development (Japan, Turkey)
• It will take a long time to realize the unmanned ships used for commercial
service. Unlike motor cars, ships are usually operated by crews who are
engaged in various tasks such as look-out, manoeuvring, maintenance of
engines and other equipment, cargo monitoring, berthing and mooring,
spare system, communications with control center.

(Source: MSC 99/5/9, MSC 99/5/11)

What is the
methodology for the
scoping exercise?
Method of work (note by the MSC secretariat)

• 1st step (applicability): An exploratory research with

focus on the identification of relevant instruments and
regulations that are related to MASS and, in particular,
those which may have an impact on, or may limit the
introduction of, MASS.

• 2nd step (action required): After the agreement on the

framework, the different concepts of types and levels
of autonomy, and the identification of relevant
instruments and regulations, may include a
comprehensive analysis of the best way of introducing
the concept of MASS within relevant instruments, from
both legal and technical perspectives.

(Source: MSC 99/5, https://www.imo.org/en/MediaCentre/HotTopics/Pages/Autonomous-shipping.aspx)

www.islide.cc 「 让PPT设计简单起来！」 41

(Source: MSC 100/5)

Outcome of the work
of regulatory scoping
exercise so far
Regulatory Barriers to the use of MASS (Denmark)
• Jurisdictional issues:
Flag States, coastal State, port State: UNCLOS
• Navigation and regulations for preventing collisions at sea:
COLREG
• Manning and “seafarers” of the future:
SOLAS, STCW, …
• Protection of the marine environment:
MARPOL…
• Construction requirements and technical conditions for ships:
SOLAS
• Liability, compensation and insurance issues: …
• Cybersecurity and anti-terror safeguards:
ISPS Code (Source: MSC 99/INF.3)
 Which treaties are being looked at?
Committee Treaties
Maritime Safety SOLAS, COLREG, Load Lines, STCW, STCW-F, SAR, Tonnage
Committee Convention, CSC, SPACE STP, STP
Convention on Facilitation of International Maritime Traffic (FAL
Facilitation Committee
Convention)
Conventions under the purview of the Legal Committee:
(19 treaties)
Conventions emanating from the Legal Committee, with
shared cognizance with other IMO committees
Legal Committee (2 treaties)
Joint treaties with IMO and other UN bodies, emanating from
the Legal Committee
(2 treaties)
(Source: MSC 100/5, FAL 43/19/2, LEG 106/8)
The International Regulations for Preventing Collisions at Sea (COLREG); International Convention for Safe Containers (CSC); International Convention on
Standards of Training, Certification and Watchkeeping for Fishing Vessel Personnel (STCW-F); Special Trade Passenger Ships Agreement (STP), 1971 and 44
Protocol on Space Requirements for Special Trade Passenger Ships.
 Outcome of step 1
Outcome in MSC (take STCW and SOLAS for examples):

1. it should be noted that the STCW Convention and Code only applied when seafarers were on
board;
2. there was an increasing pressure on the STCW Convention and Code to deal with the
STCW implementation of emerging technologies on board ships;
Convention 3. in particular, the definition of master would need to be clarified and a definition of remote
and STCW operator might need to be established;
Code 4. under degrees three and four there might still be seafarers on board, performing duties under
certain conventions; and
5. although STCW regulations might be considered as being the last to be amended, this could
pose a problem taking int
1. whether crew had to be on board when a MASS would carry passengers, should be considered
at a later stage;
SOLAS
2. there should be provisions which would foresee the need when people would have to be on
chapter III
board a MASS, normally sailing without crew, in special circumstances, during emergencies or
and the
for cargo management;
LSA Code
3. the role of MASS related to recovery and rescue of persons should be considered at a later45
www.islide.cc 「 让PPT设计简单起来！」

stage. (Source: MSC 102/5/1)

Outcome of step 1
Outcome in LEG

46

(Source: LEG 107/8/17)

 Interim guidelines for trials of autonomous ships
MSC 101 session, in June 2019 approved Interim
guidelines for MASS trials.
• Trials should be conducted in a manner that provides at
least the same degree of safety, security and protection of
the environment as provided by the relevant instruments.
• Risks associated with the trials should be appropriately
identified and measures to reduce the risks, to as low as
reasonably practicable and acceptable, should be put in
place.
• Onboard or remote operators of MASS should be
appropriately qualified for operating MASS subject to the
trial. Any personnel involved in MASS trials, whether
remote or onboard, should be appropriately qualifiedand
experienced to safely conduct MASS trials.
• Appropriate steps should be taken to ensure sufficient
cyber risk management of the systems and infrastructure
used when conducting MASS trials.
www.islide.cc 「 让PPT设计简单起来！」 47
(Source: MSC.1-Circ.1604)
Trails by member states (Russian Federation)

• Ongoing trials involve four

commercial vessels (tanker, bulk
carrier, dredger and barge) and
suppose testing of the same set of
solutions in the real conditions in
three different areas (Barents,
Black and Caspian Seas). . (MSC.1-Circ.1604).
• The project was started in 2019,
onboard trials planned to start in
April 2020, autonomous vessel
launched on 7 October 2021.
The 26 m LOA, 9 m beam vessel has a
displacement of 114 tons and a maximum
speed of 10 knots.
48
(Source: MSC 102/5/29)
Trails by member states (Japan)
• NYK-operated ship (Vehicles Carrier) engaged in international services

49

(Source: MSC 102/INF.8)

Are there already
autonomous ships
in operation?
First autonomous shipping company

https://www.youtube.c
om/watch?v=EF_wc1
OmooE&list=WL
"YARA Birkeland" development (Norway)

• In 2017, Norwegian agricultural

solutions provider Yara made a
significant commitment to
minimizing the impact of its
global operations on the
environment by launching the
project to build YARA Birkeland,
the world's first all-electric, zero
emission, autonomous
container ship.
• By 2020, this state-of-the-art
new ship designed by Marin
Teknikk will transport fertilizer
products from the YARA
production plant in Porsgrunn,
Norway to regional container https://youtu.be/5VBD7hVRhx0
hubs in Brevik and Larvik,
Norway.
(source: MSC 98/INF.16)
 Establishing international test area "Jaakonmeri" for
autonomous vessels (Finland)
• The One Sea ecosystem led by
DIMECC aims to create an
ecosystem for autonomous
maritime transport.
• The first application was approved
on 10 July 2017.

• Provide a real sea condition

which area is 17.85 km X 7.10 km,
depths varying between 16 and
60 meters, and also offers testing
opportunities in ice conditions
during the winter. It is available for The procedure for utilizing the test area
one organization/party at a time.

(Source: MSC 98/INF.13)

A manufacturer touts remote-controlled cargo ship as "future
of the maritime industry"

54
https://www.youtube.com/watch?v=yRwQ95vXVmM -
Source:
Lin, Shang-Min (2020), What is the new perspective of
IMO on autonomous shipping? - An analysis of IMO
documents
Adoption of Technology Acceptance Model
TRA is a widely studied model from social psychology that is concerned with the
determinants of consciously intended behaviors (Fishbein and Ajzen, 1975; Ajzen and
Fishbein, 1980) (see Fig. 2). According to TRA, a person’s performance of a specified
behavior is determined by his or her behavioral intention to perform the behavior, and
behavioral intention is jointly determined by the person’s attitudes and subjective norms.
Attitude towards behavior is defined as an individual’s positive or negative feeling about
performing the target behavior (Fishbein and Ajzen, 1975, p. 216) while subjective norm
refers to a person’s perception that most people who are important to him or her think he
or she should or should not perform the behavior in question (Fishbein and Ajzen, 1975, p.
302).

In addition, according to TRA, a person’s attitude towards a behavior is determined by his

or her salient beliefs and evaluations. An individual’s subjective norm is determined by a
multiplicative function of his or her normative beliefs and motivation to comply with
perceived expectations.
TAM was proposed by Davis (1986) and Davis et al. (1989) as an extension of TRA. TAM
replaces TRA’s attitudinal determinants with a set of two variables, i.e., perceived ease
of use and perceived usefulness, which are derived separately for each behavior and
employed in many computer technology acceptance contexts (see Fig. 3).
TPB is an extension of TRA, which
provides a useful tool to predict a wide
range of behaviors in many different
studies in the information systems
literature (Ajzen, 1991; Taylor and Todd,
1995a,b; Harrison et al., 1997; Chau and
Hu, 2001) (see Fig. 4). TRA and TPB have
provided the basis for several studies on
Internet purchasing behavior(Song and
Zahedi, 2001; George, 2002, 2004;
Khalifa and Limayem, 2003; Suh and
Han, 2003).
In organisational or inter-firm environments, decision-making is more complex
compared to individual adoption environments. This higher complexity may be
attributed to the larger number of variables found in the inter-firm setting (Asare
et. al, 2016). The different environment represents a major drawback for
individual models, such as TAM and TPB, since they are unable to account for all
relevant variables when attempting to explain technology adoption. Therefore,
researchers attempted to create new models explaining the more complex
organizational environment while sometimes borrowing concepts from individual
adoption models (Asare et. al, 2016).

However, comprehensive frameworks including the major constructs influencing a

firm’s decision to adopt inter-firm technology are almost nonexistent (Asare et. al,
2016). The only study to date that provides such a framework is the one
conducted by Asare, Brashear-Alejandro, & Kang (2016) which is referred to as
the Technology Adoption in Supply Chains (TASC) model.
Technology Adoption in Supply Chains (TASC) Model
Asare, Brashear-Alejandro, & Kang (2016) developed a comprehensive
model of inter-firm adoption by building upon the existing adoption
literature. Indeed, while onstructed on the same underlying principle of
the TAM stating that “the higher the intention to use the system, the
more likely they are to actually use it”, the TASC model addresses the
higher complexity of an inter-firm environment by assessing a
comprehensive set of key attributes which may affect the adoption of a
new inter-firm technology (Asare et al., 2016, p. 2). The model identifies
four key factor groups of inter-firm adoption, namely:
characteristics of technology, organizational factors, external factors, and
inter-firm relationships.
Characteristics of Technology
• Relative Advantage Organizational Characteristics
• Complexity • Size
• Compatibility • Centralization
• Testability • Management Support
• Observability • IT Readiness
• Cost

Technology
Adoption

Inter-firm Relationships External Environment

• Power • Environmental Uncertainty
• Justice • Competitive Pressure
• Trust • Industry Support
 Digitalization Acceptance Model in Shipping
62
BDA: Big Data Analytics
Thank you for your
listening

63
64
There are six questions in the final examination. The scope of final
examination is shown in below table. The scope of midterm assignment is
not included in the final examination.
Week Date Topics
6 7 Oct. 2021 STCW, Maritime labour standards and conventions
7 14 Oct. 2021 Chung Yeung Festival
8 21 Oct. 2021 ISPS and maritime security
(Submission deadline of middle-term assignment)
9 28 Oct. 2021 C-TPAT and CSI
10 4 Nov. 2021 Port state control and MOUs
11 11 Nov. 2021 MARPOL and prevention of pollution
12 18 Nov. 2021 Sustainability in shipping
13 25 Dec. 2021 Legal issues related to maritime technology

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