Tag Archives: safety

The long and winding pilot ladder

This picture has just come across my WhatsApp…


… and the pilot scaled that.


2014/04/03 · 20:33

Efficiency x Thoroughness: What people know about the cost of multitasking

Researchers emphasize there are very few circumstances in which you can do two things at once without cost (relative to doing each on its own). Yet some drivers sneak a look at their phone while on the road, and some students have the television playing while they complete an assignment.

Why? One possibility is that they don’t understand the cost of multi-tasking very well. A new study (Finley, Benjamin, and McCarley, 2014) investigated that possibility.

Subjects initially practiced a tracking task: a small target moved erratically on a computer screen and the subject was to try to keep a mouse cursor atop it. 

Interleaved with practice on the tracking task, subjects practiced a standard auditory N-back task: they heard a series of digits (one every 2.4 seconds) and were asked to say whether the digits matched the one spoken 2 digits earlier (or in other versions of the task, 1 digit or 3 digits earlier). 

After a total of 3 phases of practice for each task, subjects were told that they would try to do both tasks at the same time. They were told to prioritize the tracking task; just as a driver must keep the car in the lane, they should do their best to keep the cursor near the target, but they should do their best on the N-back task. 

Then subjects got feedback on their performance on the three phases of tracking task (expressed as percent time they had the cursor on the target) and they were asked to predict their performance on the tracking task when simultaneously doing the N-back task. 

The results showed a significant drop in tracking performance when subjects had to do the N-back task at the same time. What did subjects predict?

Subjects did predict a decrement. What they could not do was predict the size. 

Read more at http://www.danielwillingham.com/1/post/2014/03/what-people-know-about-the-cost-of-multitasking.html

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‘Human error’: The handicap of human factors, safety and justice | Humanistic Systems

As someone who think that the maritime industry still is an error-inducing, blame-attributing system, I recommend this link:


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SHORTIES: Safety first — for whom?

In 1994, the American scholar Charles Perrow wrote an article named “Accidents in High-Risk Systems”, in which he reviews his theory of “normal accidents”.

On pages 14 and 15, he writes:

“Another interesting systemic factor that influences the number of accidents and their prevention is the matter of close proximity of elites to operating systems. (…) Thus, the nature of the victims im contact with the system should have some effect upon the safety of that system.”

This can be useful to understand why airplane hijackings are usually treated so differently from ship hijackings and why the aerospace industry is error-avoiding, while the maritime industry is error-prone, for example. The elite may be involved with shipping, but is committed to flying.

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[The] perceptio…

[The] perception that the masters and OOWs know well the local conditions and routines can lead both pilots and ship officers to take a lot for granted. Both groups can assume that they share a common mental model of the area and the plan, without having to review it together. This situation can lead to the bridge personnel and the pilot surprising each other. In a dynamic situation, this can easily get out of hand. One person assuming that another shares the same assessment of a situation can take action which the other does not expect. This places both of them in a difficult situation. Misunderstandings can build on each other, destroying mutual support or teamwork, and even leading to conflict. Prior discussion and agreement on the plan and mutual acceptance of duties and responsibilities, however, will usually foster teamwork.

Transport Safety Board of Canada (1995). A Safety Study of the Operational Relationship Between Ship Masters/Watchkeeping Officers and Marine Pilots. Available at <http://ntl.bts.gov/data/letter_nz/pilot.pdf&gt;

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2013/06/24 · 18:30

Increased complexity, cheap regulation, expensive crises: the price of (un)safety

This article of James Kwak was published on 2013.05.09 in The AtlanticAlthough it does not deal with the maritime industry, much of it seems to be applicable in our case. Consider the Deepwater Horizon…

When you get on a plane, you would prefer that it not catch fire in mid-air, right? You would feel better knowing that someone had checked out the plane’s designs to make sure that it wouldn’t spontaneously combust, yes? And you would hope that the person doing the checking was not working for the plane’s manufacturer, yeah?

Well, that’s not what happened with the Boeing 787 “Dreamliner.” Instead, as reported in The Wall Street Journal:

“Only about two dozen FAA officials were assigned to oversee certification of the 787. FAA manager Steve Boyd told the NTSB last month that the team started with scant knowledge of the plane’s advanced battery technology. Then it allowed FAA-designated industry experts from Boeing and its suppliers to run all tests and conduct final safety reviews ‘with confidence that they [would] make the right call,’ he said.”

There’s a reason for this. Modern airplanes are unbelievably complicated, and the FAA has nowhere enough staff with the necessary expertise in the latest technologies. That leaves the FAA with little choice but to depend on Boeing employees and contractors to review and test the systems they designed and built themselves.

This should sound familiar. There is perhaps no area in which increasing complexity outruns regulatory capacity more than in the financial services industry. Prior to the financial crisis, regulatory changes allowed large, supposedly sophisticated banks to calculate their own capital requirements using their own risk management systems–the thinking being that they understood the risks they faced much better than any poor federal bureaucrat could hope to. Even today, after those banks blew up the financial system, it is conventional wisdom in many circles that the only people who can understand derivatives — and who therefore should be allowed to weigh in on derivatives regulation — are Wall Street traders (and their lawyers).

What is the solution? For some, it is more of the same:

“Clay Jones, who is retiring as chief executive of aircraft-parts-maker Rockwell Collins Inc., recently said industry should receive a bigger role in vetting new planes because the gap between the technical expertise of regulators and manufacturers has widened over the past decade.”

But as an air traveler, is that really what you want? And as a human being, do you really want JPMorgan or Bank of America deciding whether or not they pose a risk to the financial system?

Lack of regulatory capacity is a real problem. We want the FAA to be able to evaluate whether a new battery technology is safe, just like we want the SEC and the CFTC to understand the derivatives markets that they oversee. If they can’t, that’s bad.

But the problem of incentives in the private sector is at least as bad. We know that bankers were willing to structure transactions that would later blow up their own banks because of the fees they would generate in the short term. Outsourcing risk evaluation to private third parties doesn’t work, either (can you say “credit rating agency”?).

There’s no way to fix the problem of private incentives. Executives at private firms will want to minimize or ignore risks, whether because they are trying to beat competitors to market, they are under pressure from shareholders to deliver in the short term, they are unwilling to admit that their pet project was a bad idea, or they suffer (like all of us) from optimism bias.

The only good way to make sure that our planes–and our financial system–are safe is to make sure we have enough regulators with enough skills and enough motivation to do the job. That means that regulatory agencies have to be able to hire more people than now, at near-private sector salaries, and keep them for long periods of time (with a rule preventing them from working at firms they regulated for several years). Only then can we have product safety reviews that aren’t tainted by obvious conflicts of interest.

Regulatory capacity is expensive. There are two ways to pay for it, either of which is fine with me. One way is through general government revenues, meaning taxes. Since that means individual income taxes in practice,* this would be somewhat progressive.

The other way is by levying sharply higher fees on regulated firms. These higher fees would, of course, be passed on to customers in the form of higher prices. But that’s only appropriate, since proper safety reviews are a cost that the market should take into account when deciding whether or not a new airplane (or a new derivative) increases social welfare.

Either way, we have to pay for it. But as a taxpayer or as a consumer, I would be happy to pay more if it means that the airplane I’m getting on was reviewed and tested by someone qualified who wasn’t being paid by its manufacturer.


* Payroll taxes are dedicated to specific programs; corporate income taxes and other taxes are only a small part of the overall tax system.

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MARITIME SAFETY: Playing the pilot

HFW’s Joseph Botham explains why proposed UK pilotage changes have global influence

[Originally published in Port Strategy, 2013.03.29. Comments within brackets]

As the UK-Government supported Marine Navigation Bill (No.2) comes under close scrutiny by the national Parliament, there are wider implications for the Bill than its UK-centric focus implies.

Although comments, contributions and discussions surrounding the Bill are primarily UK directed, it would seem that the Bill is providing a platform for the consideration of issues which are of interest and of relevance to the industry internationally.

In the words of the International Marine Pilots Association, “…shipping is a global business and the position in the UK in terms of pilotage has to be considered in this international setting”.

Against this backdrop, the outcome of the consultation of the Bill may prove very interesting and influential in the call for a review and the shaping of international standards, regulation and requirements in respect to pilotage.

The Bill makes provisions in relation to marine navigation and harbours in the UK by proposing amendments to the current UK legislation relating to pilotage, harbour authorities, the general lighthouse authorities, the manning of ships, marking of wrecks, as well as extending the powers of port police in the UK.


Repeat business 

A previous draft marine navigation bill was presented to the UK Parliament by the UK Department of Transport and consulted on in 2008. The current Bill revives much of the contents and scope of this 2008 draft bill. Most importantly it revives certain provisions which came under close scrutiny during the previous consultation and the discussions which remained open. These relate largely to the levels of training and proficiency, and the standards required for pilotage in UK harbours in respect to the holding of a Pilot Exemption Certificate.

The Bill aims to reduce the burden on ports and the shipping industry while reducing regulation and improving safety for ships navigating in and out of harbours and the seas around the UK.

In particular, the Bill seeks to reduce the risk of potentially expensive accidents involving the improper use of PECs and providing ports with new powers to help implement their safety responsibilities under the UK’s Port Marine Safety Code which establishes an agreed national standard for port safety in the UK.

Under the current regime, only the Master or First Mate of a ship may hold a PEC.

A PEC effectively allows a Master or First Mate of a ship to act as his own pilot. Without any PEC holder onboard, a ship would need to make use of a pilot provided by the relevant competent harbour authority, which would involve the payment of pilot’s fees to the harbour authority providing such service – qualified pilots provide their services to ships for a fee, calculated in relation to the ship’s tonnage, draught and other criteria. 

Both a pilot’s expertise and that of a PEC holder relate to the specific navigational conditions in relevant specified harbours. This means that in order to be granted a PEC the applicant Master or First Mate must satisfy the relevant competent harbour authority of their experience and knowledge of the particular waters in respect to which they are applying for a PEC. It also means that PECs are not transferable between harbours/harbour authorities.

The Bill seeks to make the process of granting PECs more flexible by proposing to: (i) remove the restriction on the granting of PECs to exclusively the Master or First Mate of a ship; and (ii) extend the eligibility criteria and process for the granting of a PEC.

[The result would be that someone less prepared and probably more fatigued than a pilot could do his or her job, corroding the layer of safety represented by the pilots. This is mediocracy in action.]


Clamp down 

Initially, it was proposed that any bona fide crew member may hold a PEC. However, following certain comments and stages of consultation in the UK Parliament this wording of ‘bona fide crew member’ has since been amended to the now agreed term of ‘deck officer’.

This amendment of the wording sheds light on the central point of concern – the rank and level of experience that must be met for the granting of a PEC. There has been much discussion as to whether the pilotage of any ship might now be placed ‘in the hands of a deck boy, the cook or the man on the street’. 

In order to grant a PEC, the relevant competent harbour authority must be satisfied that the applicant has the skill, experience, local knowledge and sufficient knowledge of English to be capable of safely piloting one or more specified ships within its harbour without a qualified pilot onboard. 

[The level the applicant would have to attain must be at least as high as the one where the pilot is. Will it?]

The supporters of the Bill argue that this shift from the level of rank to the level of experience will ensure enhanced security while promoting efficiency and cost savings in respect to the execution by harbour authorities of their legal obligations.

[Nobody is in favour of inefficiency. Too much protection, and bankruptcy results. But one should not ignore that more efficiency often comes at the expense of ‘thoroughness’, as Erik Hollnagel puts it. In other words, there will be (over)simplifications, shortcuts and other actions that tend to erode safety.]

This proposed relaxation and widening of the requirements for the granting of a PEC has proved to be controversial. It has paved the way for an industry discussion in respect to the position onboard ship of a PEC holder and, the level of expertise and experience required by a PEC holder to navigate the passage of a ship in or out of a harbour both in the UK and internationally.


Safety first 

In particular, the level of personal knowledge and expertise of the local safe routes and hazards has been discussed and it is feared that the proposal could result in a reduction in pilotage standards among ships using UK ports. 

Some commentators see the changes as threatening safety in complex and often congested waters. In their view, the standard of training and examination of the PEC holder should be no more or less onerous than that of the pilot replaced. Others expect that the proposals would amount to a ‘dumbing down’ of pilotage capability and, in turn, increase the risk of accidents in UK coastal and restricted waters.

These concerns are not new; during the consultation of the 2008 draft bill it was also argued that pilotage requires experience, skills and professional judgment at a level which staff of lower ranks are unlikely to possess. One view was that a level of qualification for PEC holders should be set rather than empowering individual harbour authorities to assess each individual applicant’s merits.

In response, the UK Government has confirmed in the current consultation, that PEC regulation exemptions would only be made on the basis of demonstrable pilotage skill – harbour authorities will only be empowered under the Bill to award PECs to those who have the skill, experience and local knowledge sufficient to pilot a ship in the relevant harbour waters. 

The UK Government has also emphasised that, as a result of the proposed amendments, it would be easier for Harbour Masters to revoke PECs from individuals found to be lacking in ability.

Whatever the outcome of the consultation on the Bill, it has thrown an uncomfortable spotlight on the UK pilotage industry, one that has drawn global attention.

Joseph Botham is an associate at Holman Fenwick Willan, a law firm advising businesses engaged in international commerce.

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