335
1 INTRODUCTION
In recent years, a remarkable development has
attracted the attention oftheshippingand maritime
sector, namely the “Unmanned” and/or
“Autonomous” (AtS) ship projects. Combined and
reinforced by Information and Communications
Technology (ICT) inventions, these projects have
broughtrevolutionarychangestotraditionalshipping
practices and reveal a new
dimension, leading
owners, operators, and manufacturers to an
innovative rethinking of shipping. (Lloyds Register,
2016).
These concepts have gained ground amongst the
shipping industry’s research projects and, as a new
trend,havegeneratedseveralongoingprototypeand
exploration endeavours. However, there are several
issuestobeaddressedbeforetheyare
fullyfunctional
and universally accepted as safe, secure, and viable
means of transportation. An increasingly positive
attitudeintheshippingindustrytowardstheissuesof
autonomy, automation, unmanned operations, Big
Data, enterprise‐grade connectivity, and analytics is
steadily expanding the shipping and maritime
agenda.
UsingthelatestICTsystems,shipsare
builtwith
enhanced control capabilities, communication, and
interfaces,andtheywillsoonberunbyremoteland‐
based or offshore services, whenever and wherever
theyarerequired.Thesesystemshavethepotentialto
enhance the safety, reliability, and performance of
shipping companies, but also pose challenges and
risks that must
be identified, understood, and
addressed so that new innovative technologies
integratewiththedesignandoperationoftheshipsto
ensuresafety.
Because the Autonomous and Unmanned ships
consistofseveralinterconnectedsystems,anddueto
the rapid evolution of technology, it cannot be
assumed that such vessels will be safe,
based
exclusively on knowledge gained from earlier
systems. Therefore, a holistic system approach is
needed(totalsystems)‐asystemthatconsidersallthe
differentsystems(asystemofsystems)onboardand
ashore, how they are designed and installed, how
The Autonomous Shipping Era. Operational,
Regulatory, and Quality Challenges
A. Komianos
TheNauticalInstitute,London,UnitedKingdom
ABSTRACT:ThearticleprovidesadescriptionoftheAutonomousship,studiesexistingrelevantprojects,and
examinestherelatedOperational,Regulatory,andQualityassurancechallengesraisedduetothedevelopment
andactualdeployment ofsuchvesselsin thenearfuture.After reviewingthe mainoperational procedures,
existing regulations, and quality assurance standards, a number of possible solutions and approaches to
overcome the identified challenges are indicated. Some of the conclusions may be used not only in the
Autonomousshipsbutalsointraditionallymannedvessels.
http://www.transnav.eu
the International Journal
on Marine Navigation
and Safety of Sea Transportation
Volume 12
Number 2
June 2018
DOI:10.12716/1001.12.02.15
336
they relate, and how they will be managed and
regulated.
Comparable to a drone, the unmanned vessel is
already in use for military, aerospace, or scientific
purposes. Submersible unmanned vehicles, such as
the autonomous underwater vehicles (AUV) or the
remotelyoperatedvehicles(ROV)whichareusedfor
deep‐sea exploration
of the seabed or of wrecks, in
additiontocruisemissiles,surfacetoairmissiles,air
toairmissiles,airtosurfacemissiles,andintelligent
torpedoes areall examples of atechnology which is
alreadyinuseandcontinuestodevelop.
The“Autonomousvessels”willbeequippedwith
systems allowing
self‐steering by sensor‐based
detectionofobjectssuchasobstaclesandwillbeable
to self‐initiate an action e.g. to avoid collisions with
other objects. This may be achieved by technical
systems installed on‐board, which use programmed
algorithms and input data gathered bysensors. The
introduction ofthe
Autonomousship concept tothe
shippingindustrymightstartaneweraandbecomea
game changer in terms of cost efficiency, accident
prevention,andhumanresources.AccordingtoRolls‐
Royce (a leading company in Autonomous ship
research)andothersupportersoftheproject,themain
advantage of such ships
is that they might reduce
maritime accidents caused by fatigue and alcohol
abuse(Rolls‐Royce,2015).
An important issue for the shipping industry,
accidents are most often related to human factors,
suchasfatigue,duetoanincreasingworkloadanda
decrease in the crew size per ship, and alcohol or
drug abuse. Although the shortage of seafarers is
becoming a global issue, a potentia l (and hopefully
controlled) decrease in the number of seafarers
neededonboardcouldeaseandresolvethisproblem.
Paradigms of applied unmanned systems can
alreadybefoundinothermodesoftransport,suchas
airplanes, trains,
and in the automobile industry,
which is already trying to develop autonomous
vehicles. However, a very distinct and serious
problemexistsintheshippingandmaritimesectors,
namely,thelackofAutonomousships’coverageand
inclusion in relevant safety, security, and
environmental protection conventions and
regulations. The initiation of a new
perspective is
therefore needed before Autonomous ships can be
introducedtocommercialshipping,inordertoensure
the prevention of maritime accidents and the
protectionoftheenvironment.
2 BACKGROUND
Thenumberofautonomousvehiclesbeingusedinthe
air, on the ground, and in the sea is increasing. As
Mindel (2015) states, humans repeatedly find
manned, “remote and autonomous vehicles evolving
together,eachaffectingtheother”.
There are already several small‐size unmanned
andautonomouscraftsin themaritimesector which
have been engaged in surface navigation, research
andscientific activities,underwateroperations, and
specific militaryactivities.Proven
safe, thesevessels
arethepathtowardstheeliminationofhumanerror
andthusaccidentminimization[32].
The European TechnologyPlatform describes the
autonomous ship as a next generation modular
control and communications technology system of
systemswhich will“enable wirelessmonitoring and
control functions both on and off board.
These will
include advanced decision support systems to
provideacapabilitytooperateshipsremotelyunder
semiorfullyautonomouscontrol”[31].
There are two generic alternatives that are
combined in an autonomous ship, namely “the
remoteshipwherethetasksofoperatingtheshipare
performedviaaremote‐control
mechanisme.g.by a
shore based human operator”, and “the automated
ship where advanced decision support systems on
board undertake all the operational decisions
independently without intervention of a human
operator”.
The Maritime Unmanned Navigation through
Intelligence in Networks (MUNIN) started in 2012
and ended in 2015. It was funded
by the European
Commission (EC), with the purpose of investigating
the technical, economic, and legal feasibility of
unmanned ships [31]. The most important
characteristicsofthisprojectincludetheabilityofthe
ship to be operated by an autonomous shipping
system on board (while having the ability to be
supervised and
controlled by land operators), its
ability to minimize the risk of collision and comply
withtheConventionontheInternationalRegulations
for Preventing Collisions at Sea (COLREG), and the
factthatitssafetyandoperationsensorscanbeused
tosearchforobjects.
This last characteristic does not satisfy Rule
5 of
COLREG,whichrequiresproperlook‐outbyeyeand
earoneveryshiptoassessthesituationandtherisk
ofcollision.
Figure1. The MUNIN project. www.unmanned‐ship.org
(AccessedOctober2017)
Another example of such a project is that of the
Advanced Autonomous Waterborne Applications
Initiative(AAWA).LaunchedbyRolls‐Roycein2015,
its purpose is to bring together universities, ship
designers, equipment manufacturers, and
classificationsocietiestoexploretheeconomic,social,
legal, regulatory, and technological factors which
need to be
addressed inorder to make autonomous
ships a reality. It will produce the specification and
preliminary designs for the next generation of
337
advancedship solutions. “Autonomousshipping is the
future of the maritime industry” argues Mikael
Makinen,presidentofRolls‐Royceʹsmarinedivision,
in a white paper published by the company. “As
disruptive as the smartphone, the smart ship will
revolutionisethelandscapeofshipdesignandoperations”
[35].
Figure2. The Advanced Autonomous Waterborne
Applications Initiative. Image from the Rolls‐Royce
www.rolls‐royce.com(AccessedOctober2017)
A third project is the ReVolt, an unmanned, 60‐
metre‐long, zero‐emission, short sea vessel,
developedby DNVGL. Thevessel iscrewless, fully
batterypowered, autonomous,and,accordingto the
company’s web page
1
, it offers “a solution to the
growing need for transport capacity”. The project was
started in order to manage the traffic congestion in
urbanareas on theEU’s road network. Thisbecame
an issue because population growth has created a
demand for transportation that exceeds the capacity
ofexistingroads.

To ease these problems, administrations all over
the EU are “trying to move some of the freight volume
fromroads towaterways.However,profitmarginsin the
short‐seashippingsegmentaresmall”.
Figure3. ReVolt dock arrival Image from
https://www.dnvgl.com(AccessedSeptember2017)
The result of a multi‐disciplinary, team‐based
development project, ReVolt is based on an
assessment of current requirements along short‐sea
routes. The ship will operate at a speed of 6 knots
with a range of 100 nautical miles and a cargo
capacity of 100 twenty‐foot containers. Being crew
‐
less,therewillbenoneedforaccommodationwhich
usuallyformsthevessel’ssuperstructure. Compared
toadiesel‐runship,thevesselcouldsaveuptoUSD

1https://www.dnvgl.com/technology-
innovation/revolt/index.html
34 million during its estimated 30‐year lifetime,
savingmorethanamillionUSDannually,duetothe
resulting increase in loading capacity and the low
operatingandmaintenancecosts.ThevisionofDNV‐
GL is the extension of the project to involve land‐
basedchargingfacilitiesandcapacitiesas
well.
TheendeavourdevelopedbyLloyd’sRegister(LR)
is named the Cyber‐enabled ship project, which
discusses the procedures and guidance for
autonomousshipoperations.UnderLRguidancefor
Cyber‐enabled ships “Deploying information and
communications technology in shipping – Lloyd’s
Register’s approach to assurance”, the cyber‐enabled
shipis
perceivedasa“systemofsystems”[28].
Figure5.Lloyd’s RegisteredLevelsofAutonomy
www.lr.org/cyberAccessedOct2017
As such, six main risks have been identified,
namely the System, the Human-system, the
Software, the Network and communications, the
Data assurance, and last but not least the Cyber
security. For each of these risks, the guideline
describes the aspects which should be studied in
addition to a short description of cyber-enabled
systems. Furthermore,
“Cyber-enabled ships:
Ship Right procedure – autonomous ships”
was
developed, naming seven levels of autonomy
ranging from a Manual-no autonomous function
to a fully autonomous operational mode.
This approach identifies the proper actions
needed, based on the desired level of autonomy.
More specifically, during the
Manual – no
autonomous (AL 0)
function, all actions and
decisions (such as navigation, surveillance, etc.)
are performed manually by humans on board,
although some systems may have a level of
autonomy, with ‘human in/on the loop’ such as
the Periodical Maintenance System (PMS) and
the engine control.
RegardingOn‐shipdecisionsupport(AL1), the crew
on board decides and acts with the optional aid of
decision support tools on the ship such asthe Dynamic
Positioning (DP) capability. The On andoff‐shipdecision
support(AL2) is similar to (AL 1) with theadditionofa
data provision option,providedbysystemsonboardor
fromashorefacility,e.g.routing
planning(onboard)
andweatherrouting(shorebasedguidance).
Withregardsto‘Active’humanintheloop(AL3), all
decisions and actions on board are performed
autonomously under human supervision. Data may
338
be provided as in (AL 2), but decisions which may
seriouslyimpactthesafetyandsecurityofthevessel
requirehumanintervention.
Similarly, as regards the Human on the loop –
operator/supervisory (AL 4), human supervision may
intercede and over‐ride autonomously performed
decisions and actions which may have a
serious
impact. A Fully autonomous (AL 5) system, which
allows some access during a mission, is an
unsupervised or rarely supervised operation during
whichdecisionsandactionsaremadebythesystem.
Finally, a Fully autonomous (AL 6) system, which
allowsnoaccessduringmissionfunction,isatotally
unsupervised
operation during which decisions are
madeandactionedbythesystem.
AnotherrelevantprojectistheAutonomousMarine
Operations and Systems (AMOS) Project 3, which was
developedbytheDepartmentsofMarineTechnology
and Engineering Cybernetics at the Norwegian
University of Science and Technology (NTNU) in
collaboration with international and
national
partners. It is related to the unmanned ships and
focusesonthefollowingtopics:Autonomoussystem
andpayloadarchitectures,Coordinatedoperationofa
sensor network of unmanned vehicles and floating
nodes,Integrated underwaternavigationand
mapping,Autonomous objectdetectionandtracking
in marine environments using infrared sensors,
Sensor‐based
guidance and path optimization,
Coordinatedandcooperativecontrolarchitecturesfor
intelligenttask execution, andcollision avoidancein
uncertainmaritimeenvironments[32].
Figure6. NTNU research areas. Image from
www.ntnu.edu/amos(AccessedSep2017)
One of the latest projects related to the
Autonomous Ship is the ʺYARA Birkelandʺ (YB).
YARA and KONGSBERG have entered into
partnership to build the world’s first fully electric
containerfeedervessel.Theprojectstartedin2017as
a manned vessel, is working towards remote
operation by 2019, and is
scheduled to go fully
autonomousby2020.Byremovingupto40,000truck
journeysinpopulatedurbanareas,itwillreduceNOx
and CO2 emissions, improve road safety, alleviate
traffic congestion, and will thus contribute to the
achievementofUNsustainabilitygoals
2
.

2 https://sustainabledevelopment.un.org/?menu=1300
Figure7. TheʺYARA Birkelandʺ/ www.km.kongsberg.com
(AccessedOctober2017)
This120TEU(Twenty‐footEquivalentUnits)open
top container vessel will be battery‐powered (fully
electrical) and is prepared for remote control and
autonomous operation. During the first stage of the
project,abridgewithcrewfacilitieswillbeusedina
containerisedform.
This compartment will be lifted off
during the
autonomous operation phase. Electric cranes and
relevant equipment will be used for automatic load
andunloadcargooperations.Insteadofballasttanks,
the ship is designed to use her battery packs as
permanentballast.Additionally,shewillbeabletobe
berthed automatically or go underway without any
human intervention by using an automatic mooring
system, which will not require any special dock
structureorextraportfacilities.
The vessel will beprogrammed to sail within 12
nauticalmilesoftheNorwegiancoast,betweenthree
ports of the country’s southern area which is safely
coveredby TheNorwegian Coastal
Administrationsʹ
VTS system at Brevik. Three control centres with
diverse operational profiles will handle all
operational issues in addition to any emergency
situations,orothersafetyandsecurityaspects.
In addition to the above‐mentioned projects, a
numberofresearchpapersareveryinformative.“The
productionofunmannedvesselsand
itslegalimplications
in the maritime industry”University of Oslo (UiO
FacultyofLaw),arguesthatanylegalproblemsposed
byunmannedvesselsareofanorganizationalrather
thanatechnicalnature[38].
Thiskindofshipdesignissonew,duetotherapid
scientificdevelopmentsinthemaritimeindustry,
that
suchvesselsarenotyetcoveredbyanyinternational
rule or regulation. The International Maritime
Organization (IMO) has not given any approval for
this type of vessel nor has it received any proposal
from the contracting governments to regulate
unmannedvessels.
Giventhelackofproperregulatoryframeworkfor
unmanned
vessels, the researchfocused on “howthe
unmanned vessels comply with the framework set by
present international maritime Conventions such as
SOLAS and ISM Code 6”. The paper concluded that
althoughtheexistingmaritimetechnologymaycover
anysafety,environmental,andcommercialconcerns,
thelackofaproperregulatoryframework
maydelay
theactualuseofsuchvessels.
This regulatory vacuum generates various issues
such as the inability of the classification societies to
339
certify the vessels. Lacking the classification
certificates, the vessels cannot be insured, thus they
cannotsail,andeventuallytheywillnotbechartered.
Althoughsomeregulatoryaspectsofmannedvessels
are also applicable to unmanned vessels, such as
specific clauses of the ISM Code, there are several
internationalregulationsthat
needtobeamended.
“A pre‐analysis on autonomous ships” (2016) by M.
Blanke, M. Henriques, J. Bang, the Technical
UniversityofDenmark(DTU),istheresponseofthe
TechnicalUniversityofDenmark(DTU)toarequest
from the Danish Maritime Authority. The concept
includedresearchintothe“connectionand
planningof
taskstobeincludedincomingeffortstoshedlightonthe
importance of unmanned ships to Blue Denmark”. The
paper briefly describes various levels of operation,
ranging from the completely manual (lowest), to
higher levels of decision‐support, where automation
fulfilsmoretasks,upto thelevel
oftotal autonomy.
Thestudy,besidesother scientificinputs,wasbased
onself‐propelledcars,unmannedaircraftexperience,
and knowledge from ongoing similar autonomous
shipprojects.
“Existingconventionsandunmannedships–need
forchanges?”(2016),byTomotsuguNoma,theWorld
MaritimeUniversity(WMU),researchesthenecessity
for changes in existing
conventions when the
unmanned ships are introduced into the maritime
transportationsystemand,amongothersubjects,his
research focuses on survey schemes, especially with
respect to regulations of SOLAS Chapter V. Having
studied existing survey schemes and having
identified the challenges related to surveys and
technical,operational,administrative,andregulatory
problems,the paperprovides definitionsof
unmannedships,listingthemaincharacteristics[32].
Theimplementationofanautonomousvesselwill
providetheopportunity toincreasethe efficiency of
shipoperationaswellasenhancethe‘sustainability’,
whichisthegreatestdriverinanyindustry[37].
As Ben Cuckson of Lloyd’s Register
argues,
minimal safety risk, minimal environmental impact,
and maximum commercial benefits are the most
important dimensions of a sustainable development
intheshippingworld.Thesefactorsareillustratedin
Figure8.
Figure8.Marineindustry’ssustainabledevelopmentfactors
(Source:Cuckson,2015)
Reports from Drewry Shipping Consultants
predict thateconomies of scale (which gave birth to
theMega‐ships’constructionanduse)willsoonbein
decline. A McKinsey analysis calculated that “slow
steaminghadaddedaround3daystotransits,costing
shipping customers $5.7 billionin additional annual
inventory and obsolescence
costs worldwide”
(Autonomous Ship Whitepaper, 2016). The
construction ofintelligent vesselswould change this
situation, creating a better, more profitable, and,
hopefully,safershippingmarket.InanearlierUnited
States Coast Guard (USCG) report, the marine
causalities caused (to some extent) by human error
wasbetween75‐96%[36].
Burmeisteretal.claimedthatthedevelopmentof
autonomous vessels such as those in the MUNIN
Projectwillofferawide‐rangingsolutiontomeetthe
main challenges of the maritime transport industry,
resulting in a decrease in the operational expenses,
betterenvironmentalprotectionpractices,andhuman
fatigueminimization [4].However,
thereareseveral
challenges to be overcome before such vessels are
commercially accepted in the international
frameworks observing the IMO’s (International
Maritime Organisation)rules andregulations onthe
seas.
Although highly advanced technologies which
enable the design and construction of autonomous
vessels already exist in the market, these systems
create
anumberofchallengesespeciallyinthesocial,
economic, and regulatory areas. On the other hand,
the upcoming introduction of autonomous ships in
the market reinforces the expectations of a potential
decrease in accidents caused by human error and a
likelycost reduction, and intensifiesthe anticipation
ofbetterservicesin
shippingoperations.
Studies conducted by Bryant [3], Mccallum et
al.[30],andRothblum[36]amongstothers,discovered
that the proportion of maritime accidents caused by
human error was as high as 64% to 96%.These
errors were the result of fatigue, poor maintenance
and standards, inadequate knowledge and
information,andpoor
communicationskills[36]).
Regarding the expected cost reduction, the main
ship operation expenses consist mostly of fuel cost
and crew compensation. According to the 2011
Drewryreport,crewcostswere“onaveragebetween
31and36%ofthetotalshipoperationcosts”forbulk
carriers.
Apart from the previously mentioned challenges
which may arise from the introduction of the
autonomousships tothe maritimeindustry, Zakirul
argues that new designs and technological features,
whileaffectingthenewbuildingcosts,theavailability
and robustness of systems, cyber security, and
harmonised standards developments, “are not
primarilycausedby technicalobstaclesand theyare
arguablytheintegrationoftheautonomousshipinto
theexistingmaritimeoperation”[40].
Regarding the human element in the automatic
systems, Endsley & Jones consider the “human‐out‐
of‐the‐loop syndrome” to be an important issue
because an Autonomous ship may be regarded as
riskier compared to a traditionally manned vessel,
and the “social acceptability” factor must be very
340
seriouslyconsideredespeciallyinpassengerships.In
addition,amassiveshiftinthefuturefrommannedto
semi‐autonomous orunmannedships may produce
unwantedresults,suchashighunemploymentinthe
seafaring profession and social discomfort to sea
nations[11].
As for the compliance of the autonomous ships
with
existingregulationsatseasuchasSOLAS(Safety
ofLifeatSea)andCOLREGS(CollisionRegulations),
there is a need to update or adjust existing
international conventions to embrace the
developmentofsuchsystems.Updatedtechnicaland
operational standards will be needed to cover the
development of the autonomous systems
including
the commercial agreements e.g. chartering,
management, and insurance [34]. Moreover, the
member states of IMO must agree on the
implementation of the autonomous vessels and the
liabilityforanyaccidentsinwhichtheseshipsmaybe
involved.
The cost impact for the operation of the
autonomousshipsseemstobe
concentratedmostlyin
newbuildingexpensesduetothenoveldesignsand
innovative technological features, without excluding
newinfrastructurerequirementsfortheshiptoshore
command i.e. the control, communication,
information, and operation centre (e.g. an advanced
VTS centre). Although costs related to the crew on
board the ship will
be reduced, additional costs for
land‐based services such as the control centre,
equipment,maintenancecrewsinportexpenses,and
shorepersonnelwageswillbeincreased[4].
All autonomous vehicles should operate safely
and effectively in a real‐world environment while
doing operations of direct commercial value and
should be manufactured,
maintained, deployed,
operated, and retrieved at an acceptable cost [34].
Furthermore, Koopman & Wagner argue that the
challenges of developing safe autonomous vehicles
aresignificant[27].Indeed,ensuringthatvehiclesare
safe requires either following the ISO 26262 V
process, or demonstrating that a set of equally
rigorous process and
technology practices has been
applied. In October 2017, Rolls Royce marine
announced that it will use Google’s Cloud Machine
LearningEngine“acrossarangeofapplications,designed
tobothmaketoday’sshipssaferandmoreefficient,andto
launchtheshipsoftomorrow”.Theprojectisenvisaged
toproducea
fullyautonomousshipthatwillsetsail
by2020[12].
Just two years before this announcement, D.
Mindelinhisbook“Ourrobotsourselves,robotics,and
themythsofautonomy”(2015)hearguesthat,“wehave
the myth of full autonomy, the utopian idea that robots,
todayorin the
future,can operateentirelyon theirown.
Yes, automation can certainly take on parts of tasks
previouslyaccomplishedbyhumans, andmachinesdoact
ontheirowninresponsetotheirenvironmentsforcertain
periods of time. But the machine that operates entirely
independently of human direction is a useless machine.
Only a rock is truly autonomous, and even a rock was
formedandplacedbyitsenvironment”.
3 ANALYSIS
The main Operational features of a sea adventure
may be summarised as follows: Seaworthiness,
desirablePropulsionandElectricPower,pre‐planned
Endurance, safe Navigation, proper Maintenance,
reliable Communications, Collision and Grounding
avoidance, continuous Risk Assessment, danger
Mitigation,timelyResponsetoANYsafetyorsecurity
issues, Environmental protection, safe and on‐time
Delivery of the Cargo, and Liability / Insurance
coverage.
Regarding the most important Regulations that
applytotheshippingindustry,nouniformseasafety,
security or environmental protection rules for
international
shipping had initially existed since the
creation of the IMO (International Maritime
Organization) in 1948 under the auspices of the
UnitedNations(ChurchillR.andLoweA.,1992).This
oversight was corrected by creating a framework of
regulationsfortheshippingindustrythatis“fairand
effective, universally adopted and
universally
implemented”
3
.Abriefoutlineofthemostimportant
signedconventionsfollows:
4

TheSafetyofLifeAtSeaconvention(SOLAS).
The International Management Code for the Safe
Operations of Ships andforPollutionPrevention
(ISMcode).
The International Convention of Standards of
Training, Certification and Watchkeeping for
Seafarers(STCW).
Convention on the International Regulations for
PreventingCollisionsat
Sea(COLREG)
TheInternationalConventionforthePreventionof
PollutionfromShips(MARPOL).
TheInternationalConventiononMaritimeSearch
andRescue(SAR).
TheInternationalConventiononLoadLines(CLL
68/88) which defines the minimum freeboard,
watertightintegrity,andsurvivabilityofships.
Other important regulatory and technology
innovationfactors
thatstrengthenthesafetycultureof
internationalshippinginclude:
The International Convention of the Maritime
SatelliteOrganization(INMARSAT).
TheInternationalConventionforSafeContainers.
The Double Hull/ Double Bottom (DH/DB)
regulation, which plays an important role in oil
spill prevention and the Inert Gas System (IGS)
which
operates in sucha way that it renders the
atmosphereofthecargotanksnon‐flammableand
maintainsincombustibility.
Theminimizationofhumanfactorerrors
5
(dueto
poor judgment, stress, inadequate staffing, poor
livingconditions,fatigue,etc.)byimprovingtraining,
safety, the culture of environmental awareness, and
communication between multicultural and
multilingual crews and Port State Control (PSC), an
internationally agreed regime which has been an

3
www.imo.org (Accessed 20 September 2017)
4
With no policing powers the IMO can only argue the
implementation of these conventions and rely on the
efficacy of flag and port state control.
5
The U.S Coast Guard defines human error as acts
or omissions or personnel which affect successful
performance.
341
important safety and security compliance tool since
1982,
6
havealsocontributedtosafetyandsecurityin
themaritimeindustry.
The main Quality assurance issues identified
through the research are, in short, the vessel’s
construction, design, equipment, information
technology, data processing, software, algorithms,
communications, training of shore based personnel,
safetyandsecurityprocedures.
3.1 SOLAS
The Convention on Safety of
life at sea (SOLAS)
specifies the minimum acceptable standards for
construction, equipment, operations, and required
certificationsofships. Theresponsibilityof
complianceis given tothe flagstates, inaddition to
the inspection right of foreign vessels visiting their
ports. (Adopted: 1974‐Into force: 1980). Following
the Titanic immersion, it
was initially entered into
force in 1914 and properly amended to its latest
version.ContractingGovernments(FlagStates),must
ensure that all ships under their flag satisfy the
requirements of SOLAS. Whentherequirementsare
met,acertificateofcomplianceisissued[20].
Intheeventthatashiporits
equipmentbreach(or
there is a suspicion of violation of) these
requirements,aPortStateControl(PSC)authorityis
allowedtoinspecttheshipwhenenteringtheareaof
PSC’sresponsibility.Oneofthemostimportantissues
which may challenge the very essence of the
Autonomous ship is Chapter V
Regulation 14 of
SOLAS, regarding the manning of ships. The other
oneisRegulation33(DistressSituations:Obligations
and Procedures) of the same chapter, which will be
analysedunderparagraph3.5SearchAndRescue.
The Autonomous ship is not excluded from
Chapter I, thus the phrases “shall be sufficiently and
efficiently
manned” and “shall be provided with an
appropriate minimum safe manning document or
equivalent”,meansthat somehow theserequirements
mustbefulfilled,otherwisetherulemustbeadapted
to reflect the new reality of a ship without crew on
board.Ontheotherhand,asalreadymentioned,most
ofthe
Autonomousshipprojectsincorporateatleast
one Remote Control Centre (Yara Birkeland project
willusethree). Theseremotestationswill(hopefully)
be manned with sufficient personnel, while the
“efficiency”requirementmaybecoveredbythewide
range of high‐tech systems (various sensors,
computers,automations,remote controlledmachines
etc.). This combination
will assist the remote
commandandcontrolofthevessel,andwillfulfilthe
requirementsofRegulation14.
3.2 STCW
TheSTCW(InternationalConventiononStandardsof
Training, Certificationand Watchkeepingfor
Seafarers) established the basic international

6
Vessels using port facilities may be subject to
inspections and additional control measures.
standards in this field [21]. The Convention was
adoptedin1978andwentintoforcein1984.
Todayitisapplicabletopersonnelonboardaship
(a.k.a. seafarers, crew etc.) not persons who are
responsibleforoperatinganAutonomousshipfroma
remote‐controlcentre(RCS)basedonshore or
atany
otherrelevantlocationotherthantheshipherself,nor
the programmers who have pre‐programmed her
autonomouscoursebeforeshegoesunderway.These
personnelarenotregulatedbySTCW,althoughthey
have been delegated the authority to control
Autonomousships.
Additionally, under UNCLOS, Art.94(4)(b), flag
statesmustensurethat
eachshipis“inthechargeofa
master ... who possess[es] appropriate qualifications, in
particularinseamanship,navigation,communicationsand
marineengineering”.AsVealandTsimplisargue[39],
the obvious question is “whether it is possible for an
unmannedship,byitsverydefinition,tohaveamaster”.
Furthermore,theworkloadof theonshorepersonnel
fortheRemote‐ControlCentresisexpectedtobequite
heavy. A “shore based master” assisted by one to
three operators may control a small flotilla of
autonomous vessels simultaneously. The minimum
number of such vessels which are allowed to be
handledatonce
hasnotyetbeendetermined.
The conditions, which vary depending on the
geographical area, the types of cargo, the weather
conditions, whethera vessel is arriving at or sailing
fromaport,thesafety,thesecurity,thefatigueofthe
operators, what the accepted minimum previous
experienceonboardsame
orsimilartypesofshipsis,
and the updated competency tests, all have to be
seriously considered. These prerequisites must be
incorporated into existing STCW, or a similar
conventionspecifically tailored for the needs of
Autonomousships.Inaddition,trainingrequirements
and certification schemes must be adopted in line
withthe
internationallyacceptedstandardssimilarto
thosewhichapplytotheVesselTrafficServices(VTS)
operators.
Finally, although labour law would apply to the
operatorsoftheRemoteControlCentresor the pre‐
programmers of a totally Autonomous ship, specific
rulessimilartothoseapplicabletoseafarers(suchas
theduty
toreportsignalsofdistress,etc.),mayneed
tobeadjustedandappliedaswell.
3.3 COLREG
TheConvention onthe InternationalRegulations for
Preventing Collisions at Sea (COLREG) (Adopted:
1972‐Into force: 1977), revised the International
Regulations forpreventing Collision at Sea of 1960
7
.
They are published by the International Maritime
Organization (IMO) and among other issues, they
definethenavigationrules(a.k.aʺRulesoftheroadʺ)
to be followed by ships and other vessels at sea to
preventcollisionsbetweentwoormorevessels[5].

7
Marsden, Reginald. G, (2003), Collision at sea,
Sweet and Maxwell
342
Theyapplytoallvesselsuponthehighseasandin
allwatersconnectedtherewithnavigablebyseagoing
vessels. Under Rule 3 “General Definitions”
paragraph(a),theexplanationofthewordʺvesselʺis
givenas“everydescriptionofwatercraft,includingnon‐
displacementcraftandseaplanes,usedorcapableof
being
usedasameansoftransportation on water.” This
definition does not exclude the Autonomous ship
from beingcharacterisedasa“vessel”.Rules2,5,6,
7, 8, 17, 19 and 20 will be analysed in relation to
Autonomousshipoperations.
Rule 2: This rule must be adjusted to
reflect the
absenceofmasterandcrewontheAutonomousship.
A possible “transfer” of responsibility from the on‐
board master and crew to the shore (or elsewhere)
basedpersonnel(e.gControlCentreetc.)mustcover
the“ordinarypracticeofseamen”.Thisseemstooblige
anyfutureControlCentremanningscheme
toinclude
personnelwithadequateseamanshipexperience.
Rule5:Althoughitmaybepossibletosubstitute
thehuman“sightandhearing”withtechnicalmeans
such as super sensitive microphones and ultra‐high
analysisandvisioncameras,thisRuleisthesubjectof
much debate regarding the effectiveness of such
means.
The expression “proper look‐out by sight and
hearing” followed by the phrase “as well as by all
availablemeansappropriateintheprevailing…”indicates
that ALL other technical means have already been
considered,andtheimportanceof humansenses (in
particularthefacultyofsight,andhearingbywhich
the
body perceives external stimuli), judgment and
experienced reaction, is deemed necessary as a last
resorttoavoidacollision.
Rule6:Thedefinitionof“safespeed”and“proper
and effective action” is related to the collision
avoidance.Intheeventthatacollisionfinallyoccurs,
thespeedthatwaschosen
wouldbecharacterisedas
“unsafe” because of the result. This rule combined
withpreviousrule, Rule 5, makes it essential to
adjust the expression or define other protective
measures. A suitable amendment might read, ‘an
autonomous ship with such characteristics (shape,
cargoload,etc.)sailingundertheseweatherandsea
state
conditions,muststayclear of any other vessel
byadistanceofxwhenunderwaywithspeedofy.’
Rule7:Thisrule,combinedwithRule5andRule6
dictatestheimportanceofappropriatejudgementand
seamanship to “determine if risk of collision exists”.
Although it is plausible for
this kind of risk
assessment and mitigation to be generated from a
remote‐control station, the “scanty radar information”
phrase indicates once again the importance of the
audioandvisualinformationtoahumanpresenceon
board.
Rule8:AsinRule2,goodseamanshipisdeemed
essential for the
prevention of collision. The
International Convention of Standards of Training,
CertificationandWatchkeepingforSeafarers(STCW)
whichintroducedthebasicinternationalstandardsin
thisfield, mustbethe guide(inpart orat leastasa
good reference) for the basic training of the shore‐
basedoperatorsoftheAutonomousships.
Rule 17: There is doubt concerning the efficient
andeffective“manoeuvreofthelastsecond”without
the intervention of a human presence on board.
However, there is the physical delay of the human
brain as it decides the execution of the manoeuvre.
Absolutely reliable, safe, and delay‐free
communications coupled
with secure and fast data
transferbetweentheautonomousshipandthecontrol
centremustexist.
Rule19: Thehearingofthe fogsignalof another
vessel as described in Rule 19, obliges the vessel in
questiontotakeallappropriatemeasuresforaltering
herspeedand/orcoursein
ordertonavigateinsuch
a way that will avoid the collision. Once again and
similartoRule5,theword“hears” impliestheneedof
ahumanpresenceonboard.
Rule 20: Navigational lights and shapes are
paramounttothesafetyoftheshipswhenunderway.
In a
hypothetical scenario where all available
electromagneticandelectroacoustic navigationaland
surveillance means of the ships in question are
operating properly, safe navigation and collision
avoidance are mostly assured. Unfortunately, there
are plenty of recorded accidents at sea where the
above were true, but the operators (Officer of the
watch,Navigator,Radar
operatoretc.)duetofatigue
or other reasons, failed to properly evaluate or
process the “message” from the machines.
Fortunately, there are numerous other examples of
last‐second course and/or speed alteration and
collision avoidances due to the recognition of the
navigational lights and shapes shown “with the
keepingof
aproperlook‐out”.
3.4 MARPOL
MARPOL (The International Convention for the
Prevention of Pollution from Ships, 1973), as
amended in 1978, sets the standards for the
prevention of pollution by oil, chemicals, harmful
substances, and garbage. It has been in force since
1983 and its objective is to preserve
the marine
environment from pollution [17]. Being crewless, an
Autonomous ship will have no garbage and human
wasteofwhichtodispose.
In addition, the intentional pollution by oil,
chemicals,andotherharmfulsubstances,whichmay
occurwiththecomplicityofsomeorallthemembers
ofacrew,is
notpossible.Strictregulationsandrecord
keeping of all electronic orders (e‐Orders) from the
RemoteControlCentretotheAutonomousshipwill
preventanysuchactions.
However, unintentional pollution, either as the
result of an accident (collision, malfunction,
cyberattack,virus,etc.)orduetounforeseenreasons
(heavy weather, capsize, explosion,
etc.) would
continuetobeaproblem.Insuchsituations,atimely
andefficientresponseisof paramount importance,
andisfurtheranalysedinparagraphs3.7and3.8.
3.5 SAR
The SAR convention (International Convention on
Maritime Search and Rescue) was adopted in 1979
andisaimedatdevelopingan
internationalSARplan
[19]. The rescue of persons in distress at sea is
coordinatedbyaSARorganizationorbyco‐operation
343
between neighbouring SAR organizations when
necessary.Theobligationofships toassistvesselsin
distress previously existed both in tradition and in
international treaties such as SOLAS. With the
adoption of the SAR Convention, an international
system was created, covering search and rescue
operationsonaworldwidescale.SARand
Guidelines
on the Treatment of Persons Rescued at Sea
(RESOLUTION MSC.167(78) adopted on 20 May
2004) involve manned vessels and no reference is
madetoAutonomousones.
SAR Regulation 3.1.9 specifically refers to the
master of the vessel, while UNCLOS Article 98(1)
Duty to render assistance, demands that every State
“requirethemasterofaship flyingitsflag,insofarashe
candosowithoutseriousdangertotheship,thecrewor
thepassengers:(a)torenderassistancetoanypersonfound
at sea in danger of being lost; (b) to proceed with all
possible speed
to the rescue of persons in distress, ... (c)
afteracollision,torenderassistancetotheothership,its
crewanditspassengersand,...”
Any seafarer who has ever been involved in a
Search and Rescue operation, knows very well the
mental,psychological,emotional,andphysicalstress,
thechallenges,
andthedifficultyinproperlyfulfilling
suchatask.Thiskindofoperationinvolvestherescue
oflifeindangeratseaandassuch,generatesnotonly
operationalandinsuranceobligationsbutalsoethical
ones. The responsibilities of Contracting
GovernmentsandMastersincludetheassistanceand
embarkation of rescued
survivors on‐board their
vessels when possible and a number of other
supportiveactionsinrelationtotheoperation.
Inthe eventthat anAutonomous shipis closeto
suchaninstance,shemostprobablywillnotbeable
toprovidetherequiredassistanceanditmayalsobe
difficultto
avoidamanoverboardoranunconscious
castaway.
FortheAutonomousship,suchactionsrangefrom
beingverydifficulttobeingimpossibletoperform.A
proper adjustment or an exemption of Autonomous
shipsfromtheSearchandRescueoperationsseemsto
bethemostappropriatesolution.However,itshould
be
notedthatanexemptionofANYkindofvesselat
seafromtheSARinvolvement andobligations,may
raisetheconcernofseafarerswithrespecttohowthe
shipping industry, various regulatory bodies, and
relativeorganizationsregardtherescueoftheirlives
atsea.
3.6 RISKASSESSMENTANDRESPONSETO
EMERGENCIES
Extensive research on the topic of Risk Assessment
and Response to Emergencies has already been
conductedintheMUNINproject,includinganalysis
of topics such as the Unmanned ship and Shore
Control Centre,Unmanned maintenance and
technical operation principles, Heavy weather
implications,Sensorsystems,andCybersecurity.
Chapter two of
“MUNIN D9.2: Qualitative
assessment”describesindetailtherisksrelatedtothe
operationofanunmanneddrybulkcarrier.Potential
hazardswereidentified,theexpectedfrequenciesand
consequencesofincidentsrelatedtothehazardswere
rated,andtheriskwascalculatedasafunctionofthe
frequency and consequences of an
incident. A
completelistoftheidentifiedhazardswiththeresults
of the risk rating project can be found in Annex B:
HazardAnalysisresultsoftheMUNIND9.2paper.
InregardtotheresponseofanAutonomousship
duringanemergencysituation,thereareanumberof
issues that
must be analysed. For example, under
UNCLOSArticle98(1)assistanceindistresssituations
istheobligationofallvesselssailingintheareaofthe
incident, although the risks such assistance could
pose to the crew, its passengers, and the ship itself
mustallbetakenintoconsideration.
TheArticledelegates
theauthorityandburdenof
initiating the task to the master, having in mind
mannedvesselsandnotacrewlessship.Ifweassume
thatthisobligationistransferredautomaticallytothe
“masteronshore”,anewissuearises,thatofthetime
neededforaresponsefromshoreduring emergency
situations(Hapag‐Lloyd,2016).
Totacklethesesituations,properequipmentcould
beinstalled onboardtheAutonomous ship.After its
efficacy had been verified, this particular solution
would have to be accepted and it may increase the
overall structural cost, minimizing the economic
benefitsofthecrewlessvessel.
3.7 MAINTENANCE
One of
the most important factors of the safety and
seaworthiness of a ship is the proper, daily,
periodical,andtimelymaintenanceofallhersystems,
structures,andhull.
Alonglistofperiodicalmaintenanceprocedures,
but also of emergency (or unforeseen failure) fixes
exists onboard all ships. Well‐trained experienced
personnel are
thekey factorresponsible for meeting
these requirements successfully. The following rule
setsthebasicprerequisitesforsuchactions.
A ship underway is a remote system usually
sailingfarfrommaintenancecentres,shipyards,ports
orotherrepairfacilities.Althoughcertainincidentsor
malfunctions may be repaired remotely either by
software
updates, orby the futuristicuse of “robots
insidearobot” (i.e. a remote‐controlled
maintenance robot on‐board an Autonomous ship),
there will be certain circumstances where the
presence of an experienced human team would be
indispensable. In such cases (if time constraints and
the situation permit), there must be
the required
proceduresinplace,sufficientinfrastructurefacilities,
andappropriatearrangementstoreceivesuchateam.
3.8 FIREFIGHTINGANDDAMAGECONTROL
Itisexpectedthatavarietyofsensorsandsystems,to
dealwithfiredetectionandextinguishmentbutalso
damagecontrolandrepairs,willbepresentonboard
the
Autonomousship.Thelevelofsophistication,the
minimum requirements, and the accepted
effectiveness shall be regulated and properly
enforced.
344
The cost to protect the Autonomous vessel with
such systems from potential fire, water inflow or
other damage will most probably be considerable
compared to the cost of methods already used on‐
boardmannedships.Intermsofareacoverage,time
efficiency, diversityofincident management,
sequenceofunpredictablefactors,
andeffectiveness,it
is difficult to duplicate the mobility and focused
intervention of the firefighting groups and damage
controlparties(varyingfromonetoeightdepending
onthetypeoftheship)whodealwiththesesituations
onmannedvessels.
3.9 ISPSCODE
In response to the terrorist acts of
September 11th
(2001) in the United States, the need to protect the
international maritime transport sector against the
threatofterrorismwasrecognised.Thus,onJuly1st
2004,anewmaritimesecurityregulatoryregimewas
introducedinto the International Conventionfor the
SafetyofLifeatSea(SOLAS),namelychapterXI
‐2on
Specialmeas ures toenhancemaritimesecurity,which
includes the International Ship and Port Facility
Security (ISPS) Code. The ISPS Code entered into
force in December 2002 and is the result of
cooperation between Governments, Government
agencies,localadministrations,andshippingandport
industries[16].
Inparticular,SOLASRegulations
XI‐2andXI‐3of
Chapter XI‐2 – “Special measures to enhance maritime
security” preserves the International Ship and Port
Facilities Security Code (ISPS Code). Part A of the
Codeismandatory,whilepartBcontainsguidanceon
how to best comply with the mandatory
requirements.
Under Regulation XI
‐2/8, “The master shall not be
constrained by the Company, the charterer or any other
personfromtakingorexecutinganydecisionwhich,inthe
professional judgement of the master, is necessary to
maintainthesafetyandsecurityoftheship. Thisincludes
denialofaccesstopersons(exceptthose
identifiedasduly
authorized by aContracting Government) or theireffects
and refusal to load cargo, including containers or other
closed cargo transport units”. Additionally, “If, in the
professional judgement of the master, a conflict between
anysafetyandsecurityrequirementsapplicabletotheship
arisesduringitsoperations,the
mastershallgiveeffectto
thoserequirementsnecessarytomaintainthesafetyofthe
ship.Insuchcases,themastermayimplementtemporary
security measures and shall forthwith inform the
Administration and, if appropriate, the Contracting
Governmentinwhoseport theshipisoperatingorintends
toenter.Anysuchtemporary
securitymeasuresunderthis
regulation shall, to the highest possible degree, be
commensurate with the prevailing security level. When
such casesare identified, the Administration shallensure
thatsuch conflictsareresolved andthatthe possibilityof
recurrenceisminimised.”
Otherregulationsinthischapterrequireallships
to be
equipped with a ship security alert system, to
provide information to the IMO, and to be in full
control in port (which includes dealing with
circumstances such as a delay, detention, and a
restrictionofoperations,includingmovementwithin
theportorexpulsionofashipfromport).
In order
to accomplish these objectives, SOLAS
Contracting Governments, port authorities, and
shippingcompanies“arerequired,undertheISPSCode,
todesignateappropriatesecurityofficersandpersonnel,on
each ship, port facility and shipping company”. These
security officers, designated Port Facility Security
Officers (PFSOs), Ship Security Officers (SSOs), and
Company Security Officers (CSOs)
must assess,
prepare, andimplement effective security plans that
areabletomanageanypotentialsecuritythreat.
Asfar as theAutonomous shipis concerned, the
absenceof“security officersand personnel”,presents a
serioussecuritygapwhichmustberemediatedeither
byapplyingappropriateriskmitigationsystemsand
methods,
orbyexcludingthisparticulartypeofvessel
fromthisobligationduringdeep‐seanavigation. The
lattermaybeachievedbyassigninggeographicareas
close to the Port Limits where a team of properly
trained,qualifiedpersonnelwillattestthatthevessel
issafeandsecuretoleaveorenterthe
port.
3.10 CYBERSECURITY
AccordingtotheMerriamWebsterdictionary,the
definitionofcybersecurityis“measurestakentoprotect
acomputerorcomputersystem(asontheInternet)against
unauthorizedaccessorattack”,whiletheonlineOxford
dictionarydefines‘cybersecurity’as“Thestateofbeing
protected against the criminal or
unauthorized use of
electronicdata,orthemeasurestakentoachievethis”.
ISO/IEC 27032 defines “Cybersecurity” or
“Cyberspace security”, as the “preservation of
confidentiality,integrityandavailabilityofinformationin
the Cyberspace”. The Cyberspace is defined as “the
complex environment resulting from the interaction of
people,softwareand serviceson
theInternet bymeansof
technology devices and networks connected to it, which
doesnotexistinanyphysicalform”
8

The International Telecommunications Union
(ITU),whichisa specialized United Nations agency for
information and communication technologies, initsITU‐
TX.1205(4/2008)document,definescybersecurityas
“thecollection oftools,policies, securityconcepts,security
safeguards, guidelines, risk management approaches,
actions,training,bestpractices,assuranceandtechnologies
that can be used to protect the cyber environment and
organization and userʹs assets. Organization and userʹs
assets include connected computing devices, personnel,
infrastructure, applications, services, telecommunications
systems,
and the totality of transmitted and/or stored
information in the cyber environment. Cybersecurity
strives to ensure the attainment and maintenance of the
security properties of the organization and userʹs assets
against relevant security risks in the cyber environment.
The general security objectives comprise the following:
Availability,Integrity(whichmayinclude
authenticityand
non‐repudiation)and,Confidentiality.”
Since the Autonomous ship concept will depend
heavilyoninformationtechnologysystemson‐board
andashore,thereisa fargreaterlikelihoodofacyber‐

8http://www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?c
snumber=44375
345
attack when compared to a conventional vessel,
although this might not be the case under certain
circumstances.Theadvanceoftechnologyhasalready
“digitised” a wide spectrum of processes and
proceduresonboardshipsfromsteering,propulsion,
and cargo control to ECDIS, GPS, AIS, and
communicationsystems.Alltheabove
computerised
processes are potential cyber‐attack targets. On the
otherhand,marineinsuranceforcyber‐attackperilsis
notnew,andthustheautonomousshipconceptmay
well be included in such provisions. Although the
threatofacyber‐attackisgenerallyexcludedfromthe
Institute Cyber Attack Exclusion Clause
(CL380)
10/11/2003(forloss,damage,orliabilitycausedeither
directlyorindirectlybytheuseofacomputerandits
associated systems and software), in the Protection
and Indemnity Insurance sector, a limit of US$30
millionpershipexiststomitigatesuchthreats(unless
theattackisanactof terrorismorwar).Althougha
plethoraofdefinitionsandaholisticapproachtothe
issue exists, as has already been shown in the
previous paragraph, on 23
rd
of November 2017, IHS
FairplayDailymaritimeshippingnewsrevealedthat
during February of the same year, hackers took
controlofacontainership’snavigationalsystemsfor
almost10hours.ThevesselwasnotanAutonomous
or remote‐controlled vessel, but a “conventional”
containership.
3.11 INFORMATIONTECHNOLOGY
TheAutonomous
shipwillbedependentoncomputer
systemsnotonlyforthevariousrequiredfunctionsto
sailwithsafety,butalsoforaseriesofupdatesrelated
totheconditionofthevesselwhenatsea,duetothe
factthatphysicalinspectionswillmainlybepossible
inport.AsRødseth,H.,
BrageMo,B.(2014)observed,
theuseofKeyPerformanceIndicators(KPIs)willbe
veryusefulinmonitoringdifferentpartsoftheship. 
Various data will be recorded, measured, and
analysedinordertomonitortheintegrityoftheship’s
structureandthefunctionalityoftheequipmentand
themachinery.
TheRemoteControlCentrewillplay
animportantroleduringthisprocessbycoordinating
andschedulingmaintenanceusingthedatareceived
fromtheship.
3.12 LIABILITY
Liability, as a part of the insurance system, protects
the insured from the risks posed by lawsuits and
claimsalike.
Someofthemostimportant
areascoveredarethe
seaworthiness (a shipʹs ability to perform the
contractedvoyage safely,either undercommon law,
orwheneverthecontractedpartiesvoluntarilyaccept
the‘Hague‐Visby’Rules),thecharter‐party(acontract
usually between a ship‐owner and a charterer), the
billoflading(adocumentsigned
onbehalfofaship‐
owner regarding the loaded cargoʹs quantity,
condition, potential harmfulness, and other
parameters),thecollision,andtheliabilityofthemaster.
Althoughmaritimeregulatorymattersareusually
enforced under the auspices of the IMO, liability
issues are subject to various national jurisdictions.
Thelawsapplicable
toamarine disputeandthecourt
to which this dispute may be brought, depend on
factors such as where the episode happened, its
nature,theflagof thevessels,andthe nationalityof
thecrews.
Additional contractual provisions and legal
requirementssuchasTheHague‐VisbyRules,require
the implementation of certain responsibilities by the
master and the crew, thus creating a dilemma for
Autonomousships.
For example, under The Hague‐Visby Rules,
Art.III r.2 the care of cargo requires a physical
inspectionandhumaninterventionwhenrequiredfor
somegoodssuchasthedangerousones.Wheneveran
unsafe or hazardous cargo needs to be jettisoned or
neutralisedwhileanAutonomousshipisunderway,
only the existence of a crew on‐board is likely to
preventaccidentsandkeepthevesselseaworthy.
3.13 INSURANCE
Marine insurance covers a wide spectrum of issues
varyingfromtheHull,Machinery,andCargotoother
Third‐Party liability coverage and is regulated
through the Marine Insurance Act of 1906 (MIA),
under English law. Not only does the Act affect
marineinsuranceforships,cargos,andtheProtection
and Indemnity cover, but it has also influenced the
subject matter worldwide and has been adopted by
otherjurisdictionsaswell.Twomodernstatutes,the
Consumer Insurance (Disclosure and
Representations) Act of 2012 (“CIDRA”) and the
Insurance Act of 2015, have made amendments to
insurancelaw.TheInsuranceActof2015inparticular
(2015c.4,aUnitedKingdomActofParliament)makes
significantreformstoinsurancelaw.
Awidelistofprerequisitesischeckedandagreed
beforeashiporitscargo(orboth)areinsured.Oneof
themostimportant termsinmarine insuranceisthe
“seaworthiness”ofaship, whichdependsonvarious
factors. Andrew Bardot (the executive officer of the
International Group of P&I Clubs whose members
insure 90 percent of the global fleet} argues that
“Unmanned ships are illegal under international
conventions, which set minimum crew sizes. If drones
don’t comply with such rules, they’d be considered
unseaworthyandineligibleforinsurance”
9
.
3.14 QUALITYASSURANCE
UNCLOS Art.94(4)(a) requires that “each ship, before
registration and thereafter at appropriate intervals, is
surveyed by a qualified surveyor of ships”. Although a
number of classification societies are already
preparing suitable checks and competent surveyors
for Autonomous Ships, no standardisation has been
agreedonorintroduced.
Anothercodeoftheutmost
importance, not only for the safety but also for the
QualityAssuranceofthemaritimeindustryistheISM
Code. The code and its compulsory nature will be
analysedinmoredetailinChapter5,whichfollows.

9
http://www.synergy.ie/index.php/articles/health‐safety/item/375‐rolls‐royce‐
are‐developing‐drone‐ships
346
In addition to these regulatory obligations, there
are a number ofQuality Standards, self‐imposed by
the industry, which are mostly based on the
InternationalOrganizationforStandardization(ISO),
aSwiss‐based privateinternational standards
development and publishing body composed of
representatives from various national standards
organizations with multiple committees.
Such
standards include amongstothers the ISO 9000:2015
(International standards for quality management)
series, the ISO 28007‐1:2015 International standards
for Ships and marine technology – Guidelines for
Private Maritime Security Companies (PMSC)
providing privately contracted armed security
personnel (PCASP) on board ships (and pro forma
contract), and the ISO/TS
29001:2010 International
standards for Petroleum, petrochemical,and natural
gas industries and Sector‐specific quality
managementsystems,layingdowntheRequirements
for product and service supply organizations. As
previously mentioned, some classification societies
have already started to lay the basis for quality
standardsfortheautonomousship.However,thereis
notas
yetasystematicapproachtothesubject.
4 ISMCODEANDTHEAUTONOMOUSSHIP
The International Management Code for the Safe
Operations of Ships and for Pollution Prevention
(ISM), which forms chapter IX of SOLAS, was
introduced after a number of serious pollution
accidents. (Adopted: 1993‐Into force: 1998). This
Chaptermakes theInternationalSafety Management
(ISM) Code, which requires “a safety management
systemtobe establishedby theshipowner oranyperson
who has assumed responsibility for the ship (the
ʺCompanyʺ)”,compulsory[15].
The objectives of the Code are the prevention of
humaninjuryorlossof
life,theavoidanceofdamage
to the environment, and to ensure safety at sea. Its
aimistoapplyasafetymanagementsysteminorder
totrainthepersonnel involvedinthe operationofa
shiptoreactappropriatelyduringpossibleemergency
situations.Everyorganisation(shippingcompany)is
allowed to develop
its own Safety Management
System(SMS)usingpolicies,procedures,instructions,
and internalaudits inorder to discover, report, and
correctanydeficiencies.
Paragraph 5 “Masters’ Responsibility and
Authority”, and paragraph 6 “Resources and
Personnel” of the Code must be either altered by
includingadefinitionofa“Shore‐based” master
and
“crew / remote control operators” with the same
responsibilities of the on‐board Master and crew, or
be adjusted to the new autonomous ship’s crewless
nature by excluding such vessels from the
responsibilitiesofparagraphs5.1.1 to 5.1.4, 6.2, 6.6ʺ,
6.7, and paragraph’s 7 phrase “the safety of
the
personnel”. Paragraphs 5.1.5, 5.2and 6.1, 6.3, 6.4, 6.5
and7(withoutthephrase“thesafetyofthepersonnel”)
should continue to apply, regardless of whether the
crewisonboardorinremotecontrolcentres.
5 CONCLUSIONS
At present, international conventions, rules, and
codes such as the
UNCLOS, SOLAS, COLREG,
MARPOL, STCW, ISM, and SAR (to name but a
few)donotincludetheAutonomousshipconcept
asadefinition,orasapotentialmodusoperandi.
Furthermore, the existing regulations and the
traditionally used phrasing challenge rather than
facilitate the operational deployment of such
vesselsinthefuture.

A cautious review of all relevant regulatory,
operational, and quality assurance frameworks,
followedbytheproperamendmentsisneededin
order to legally shield and technically assure the
Autonomousshipconceptthusmakingitaccepted
byandfavourabletothemaritimecommunityand
theshippingindustryalike.
Throughout
the research, it was observed that
there were a number of accidents caused by
human error, affirming the usefulness of the
Autonomous ship concept. No near accidents or
potential catastrophes prevented by human
interventionwere mentioned(although theyvery
oftenoccur),whichmakesanycomparison tothe
disasterscausedbyhuman
mistakesimpossible.It
issuggestedthatfurtherexaminationofsuchnear
incidentswill helpin understandingthe
Autonomous ship’s real contribution to maritime
safety.
Finally, further research on issues such as the
ethicalconcernsregardingtheuseofautonomous
systems replacing humans, the psychological
impactonseafarersofsuch
ause,thedegradation
ofseamanship,andthepotentiallossoftimeatsea
thatwouldbeexperiencedbyasignificantnumber
ofcompetencemariners,shouldbeconsidered.
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