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1 INTRODUCTION

Navigation of Arctic waters has always been

challenging. Large-scale maritime disasters, such as

the Titanic and Exxon Valdez incidents have shown

with all clarity the enormous consequences in terms

of loss of human life and environmental damage if

things go wrong in the harsh conditions in the Arctic.

During the last decades climate change has

improved conditions for maritime navigation and

exploitation of natural resources in the Arctic and has

consequently led to increased sea-based activity in the

area, such as transportation, fishing and tourism to

name a few. Increased maritime activities in

Greenlandic waters – and in the region as such – have

an impact on safety at sea and the risk of accidents,

for example with tourist vessels. Even through

climate change might lead to improved conditions for

navigation, the Arctic still is a difficult and dangerous

maritime environment to navigate in. And not all

maritime actors seem to be fully aware of the risks at

hand and prepared accordingly. Furthermore, a

situation as the Costa Concordia incident would most

likely have far more serious consequences in

Greenland than it had in Italy. The activity of cruise

ships in Greenlandic waters and in the Arctic in

general has considerably increased in recent years,

which leads to considerations on how to prevent

potential disasters and how to react if things go

wrong.

One way to approach the situation is to create

specific legislation to limit the risks and to ensure safe

navigation. Since the Exxon Valdez disaster in 1989

there has been intense work in the International

Maritime Organizations Safety Committee on creating

specific guidelines for safe navigation in the Arctic. In

2002 the Maritime Safety Committee under IMO

approved the Guidelines for Ship Operation in Arctic

Polar Waters. However, the guidelines were not

mandatory, but only recommendations (Engtrø et all.

Safe Navigation of Cruise Ships in Greenlandic Waters -

Legal Frame and Practical Challenges

H.B. Rasmussen

University of Southern Denmark, Aalborg, Denmark

B. Feldtmann

Aalborg University, Aalborg, Denmark

ABSTRACT: Climate change provides for improved conditions for maritime navigation and results in increased

activity in the Arctic. Those increased activities influence the safety at sea and risk of accidents. A disaster as

the Costa Concordia incident would have far more serious consequences in Greenlandic waters than it had in

Italy, therefore the question of prevention and disaster-preparedness is crucial. One approach to avoid risks is

to create specific legislation. The legal system guiding safe navigation of cruise ships in/around Greenlandic

waters is complex: the legal regime for navigation is set in different general and specific international, regional

and national legal acts, partly non-binding, therefore issues of effectiveness arise. Safety is also influenced by

practical issues, e.g. the lack of sufficient nautical charts for Greenlandic waters and “preparedness” at land to

handle potential disasters, such as the SAR-system and preparedness of different actors, for example hospitals.

http://www.transnav.eu

the

International Journal

on Marine Navigation

and Safety of Sea Transportat

ion

Volume 14

Number 1

March 2020

DOI:

10.12716/1001.14.01.26

208

2018, Jensen 2016). Drafting recommendations instead

of binding legal rules lead to the inherit question of

effectiveness of the regulation at hand. I 2007 cruise

ship “MV Explorer” came in distress and sank in

Antarctic waters with 100 passengers and 54 members

of crew onboard. All were rescued, but this incident

resulted in an intensified focus on safe navigation in

polar waters and put pressure on IMO to act. I 2009

the IMO has approved new guidelines on the issue,

which were not mandatory. I 2010 the IMO started to

work on the Polar Code, which became effective on

01.01.2017 (Engtrø et all. 2018, Jensen 2016). The aim

of the Polar Code is limiting risks by setting a legal

frame for safe ship operation and environmental

protection in the Arctic and Antarctic by primarily

binding regulation (Østergaard/Frier 2016). The

question at the core of this article is to what extent the

legal frame work for safe navigation in the Arctic

waters can improve and secure the safety of cruise

ships. One side of improving safe navigation in

Greenlandic waters is an efficient legal frame work,

however, another side of the medal are practical

issues, such as sufficient nautical charts and the

preparedness on land (and at sea) if things go wrong.

This article is dealing with safety and disaster

prevention issues connected to the increased

navigation of cruise ships in Greenlandic waters. In

this context, both the legal frame work will be briefly

presented as well as practical challenges for safe

navigation of cruise ships in Greenlandic waters.

2 SAFETY AND ACCIDENT PREVENTION

Safety plays an important role in maritime industry

and there has consequently been focus on safety

issues for many years. The same goes for the research.

The roots of safety research derive from the 19

century. In the beginning the focus was on technical

improvement of equipment, for example with view to

preventing explosions and structures from collapsing.

(Hale & Hovden 1998). In the 1960’ies and 1970’ies the

focus in research has been on the development of

probabilistic risk analysis and on the human factor

and human error, as well as on the development of

accidents models like the so-called Swiss cheese

model (Reason, 1997). Major disasters as Chernobyl in

1986, Challenger in 1986, Piper Alpha in 1988 and

Exxon Valdez in 1989 has, however, changed focus on

management systems, procedures and organizational

factors. The focus increased on safety management

systems (SMS), safety culture and safety climate.

There are different definitions of SMS. One definition

comes from the Civil Aviation Authority, which

defines SMS as following:

“SMS is an organised approach to managing safety,

including the necessary organisational structures,

accountabilities, policies and procedures. It is more than a

manual and a set of procedures and requires safety

management to be integrated into the day to day activities

of the organisation. It requires the development of an

organisational culture that reflects the safety policy and

objectives” (Civil Aviation Authority).

http://www.caa.co.uk/docs/872/30JulySMS%20Guidan

ce%20Materialversion3.pdf

The shipping industry has adopted the idea of

SMS with the introduction of The International

Management Code for Safe Operation of Ships and

for Pollution Prevention called also IMS Code in 1998.

The IMS Code obligates the shipping companies to

formulate SMS, taking into account existing risks in

shipping operations and guideline the seafarers to

conduct their work safely though the procedures in

SMS. Regulation and procedures have been seen as an

effective way to prevent accidents, however in recent

times there has been focus on negative sides of

procedures as possibility to undermine good

seamanship and to increase bureaucracy (Knudsen

2009, DMAIB 2016, Oltedal 2011). The focus on safety

culture and SMS is still intense, but the complexity of

the systems makes the prevention of accidents more

complex where SMS and safety concepts are not able

to explain all mechanisms in the organisation. In the

further development of the theoretical framework the

focus is on coping with complexity of systems in

accident prevention. The newest tend, which deals

with this area is resilience. Resilience is defined as

follows: “the ability of a system or an organisation to

react to and recover from disturbances at an early

stage, with minimal effect on the dynamic stability.

The challenges to system safety come from instability,

and resilience engineering is an expression of the

methods and principles that prevent this taking

place” (Hollnagel, Woods & Levson, 2006). The

resilience theoretical framework also developed

accident models, which include dynamic models,

such as Rasmussen’s model (1997), and the safe

envelope concept (Hale & Borys 2013). One of the

useful concept in the newer theoretical approach are

the concepts of Work-as-imagine (WAI) and Work-as-

done (WAD), which origin from the Francophone

tradition and “acknowledged the difference between

tâche and activité. Roughly translated, this is the

difference between a (prescribed) task, or what is to

be done, and the (actual) activity, or what is

done“(Dekker, 2017). The concept emphasis how

rules and regulations produced by people, who are

not involved in actually performing the job,

sometimes are drawn up in a way, which makes it

difficult for the people at the “sharp end” to meet the

demands and live up to the intention. WAI “refers to

the various assumptions, explicit or implicit, that

people have about how work should be done. WAD

refers to (descriptions of) how something is actually

done, either in a specific case or routinely”. (Hollnagel

2017). WAI and WAD are useful concepts in exploring

the legal frame work for safe navigation in arctic

waters and challenges in real life.

3 METHODS

The study uses the qualitative methods and combines

the traditional dogmatic legal method with sociology.

Thus, the data consists of legislation and regulation

on different levels, legal literature, documents and

interviews. The legal frame work consists of the

international (for example UNCLOS), regional (for

example Polar Code) and national level (specific

Greenlandic regulations). The interviews have been

collected during the period from February 2017 until

August 2017. The interviews were mostly conducted

209

as face-to-face expect one which was conducted by

telephone. The interviews lasted between 60-90

minutes interviews. Some of interviews were

conducted as individual and some as two personas’

interviews. The respondents of interviews were

maritime stakeholders and shipping companies both

in Denmark and Greenland. All interviews were

recoded and analyzed with help of Nvivo 11.

4 THE LEGAL FRAME WORK FOR NAVIGATION

IN GREENLANDIC WATERS

4.1 UNCLOS and other regulation

The legal regime for navigation of the oceans is set

out in a number of international regulations (it its

sum often called the law of the sea) with the UN

Convention on the Law of the Sea (UNCLOS) as the

central set of rules as the backbone. UNCLOS is often

described as a constitution of the oceans, however, it

is questionable, what that actually means in more

practical terms (Feldtmann/Siig, 2018). The aim of

UNCLOS is to provide comprehensive regulation of

the governing of the oceans in general and more in

particular to regulate central issues connected to the

ocean such as the issue of free navigation, the

distribution and use of resources, the rights and

duties of coastal, flag and other states. Not all states

are party to UNCLOS, however, it can be argued that

the main principles of UNCLOS are widely accepted

and regarded as customary international law.

Concerning the issue of cruise ships and save

navigation in arctic waters, UNCLOS has little specific

to offer. UNCLOS is more relevant on a general level,

distributing powers and obligations in connection

with the use and governance of the oceans. One major

principle at the core of UNCLOS is the freedom of

navigation. This means, beyond other things, that

limitations of and setting rules for navigation must be

justified by other important reasons such as the safety

at sea or the protection of the environment. Thus, a

number of specific regulations set out rules for safe

navigation, for example with view to the construction

of vessels and equipment etc. as regulated in

International Convention for the Safety of Life at Sea

(SOLAS).

Another crucial issue regulated by the

international law of the sea is the Search and Rescue

System (SAR). This topic is only party addressed by

UNCLOS and more specific regulated by other

international law, in particular the International

Convention on Maritime Search and Rescue (SAR

Convention). The SAR Convention is supplementing

the general obligation of ships to render assistance to

vessels in distress, which is a deeply rooted maritime

tradition but also codified in a number of

international treaties. Before the SAR Convention,

however, there was no specific international legal

system covering search and rescue operations and the

underlying SAR-system on land. The central elements

of the SAR Convention are the establishment of SAR-

zones and rescue co-ordination centers and

subcenters, as well as specific duties and rights of

coastal states (responsible state for a given SAR zone)

in connection preparedness and distress situations.

The polar states USA, Canada, Denmark, Iceland,

Norway, Sweden, Finland and Russia (also called the

“Arctic 8”) have in 2011 agreed on the Arctic Search

and Rescue Agreement (Agreement on Cooperation

on Aeronautical and Maritime Search and Rescue

in the Arctic) which establishes the SAR zones of

each state party. The Greenlandic SAR-zone, which as

the other SAR-zones in the Arctic covers a huge area

is, managed by the JRCC Greenland in Nuuk.

4.2 Polar Code

Polar Code has been, as mentioned above, developed

to supplement already existing IMO instruments, in

particular SOLAS and MARPOL, with aim to increase

safe ship operation and the protection of polar

environment. The Code consists of an introduction,

part I and part II The Introduction contains

mandatory provisions applicable to both parts I and

II. Part I is subdivided into part I-A, which contains 12

chapters on safety measures, and part I-B containing

12 chapters about recommendations on safety. Part II

consists of two parts A and B. Part II-A includes

mandatory provisions on pollution prevention

presented in 5 chapters, and part II-B containing

recommendations on pollution prevention also in 5

chapters. In the context of this article especially the

first part of the Polar Code is of particular interest.

Part I of the Polar Code introduces a number of

mandatory safety measures. Every ship the Polar

Code applies for should have a valid Polar Ship

Certificate (PSC) on board, which should follow the

model of form of certificate for ships operation in

Polar water presented in the appendix 1 of the Code.

The PSC includes among others information about

ship, category of ice class, equipment. Length of

validity of certificate ect. Besides the PSC, the Polar

Water Operational Manual should be also on board.

(PWOM). PWOM should include information on ship

specific capabilities and limitation in connection to an

assessment of the ship and its equipment. Assessment

should be conducted in relation to operating and

environmental conditions such as operation in low air

temperature, in ice or in high latitude. POMW should

address all aspects of operations described in chapter

II part I-A. In the case that the shipping company has

already procedures in place; there has to be reference

from PWOM to existing procedures. Besides

procedures describing ship operation in polar water,

the manual has to include risk-based procedures

about voyage planning to avoid ice, arrangements for

receiving forecast, implementation of special

measures, contacting emergency response providers.

PWOM should also include risk-based procedures for

monitoring and maintaining safety during operation

in ice. The Polar Code gives guidelines for ship

structure and stability depending on ship category.

Some of the standards are obligatory for ships

constructed after 1 January 2017. Information about

icing allowance in the stability calculations should

also be written in PWOM. The Polar Code describes

specific demands to machinery installations,

fire/safety protection, life-saving appliances, safety of

navigation, communication, voyage planning and

manning and training. According to Polar Code

adequate thermal protection to all persons on board

should be provided, which takes into account the

210

specific weather conditions of the area. The ship must

ensure safe evacuation of the persons and provide the

maximum expected time of rescue, which shall never

be less than 5 days. The crew should be Certified in

accordance with regulation II/2 of STCW Convention

and section A-II/2 of the STCW Code (Polar Code

12.3.2) and when operating in polar waters the ship

should have sufficient number of crew with

appropriate training requirements for polar waters.

In its sum, is seems obvious that the Polar Code

improving the safety of navigation in Arctic waters.

However, the combination of mandatory regulation

and non-binding regulation might lead to gaps in the

safety system. Furthermore, some regulations can be

perceived as weak, for example does the Polar Code

not explicitly demands that passenger vessels provide

for thermal survival suits for all passengers and crew.

4.3 Mandatory Ship Reporting Systems

One element in the preparedness-system is the

monitoring of traffic in Greenlandic waters through a

specific mandatory ship reporting system established

in 2003. The system is regulated in IMO circular on

the GREENPOS/COASTAL CONTROL (IMO

SN/Circ. 221 of 29 May 2002; Bekendtgørelse om

skibsrapporterings-systemer i farvandene ved

Grønland; BEK 170/2003).

There are basically two mandatory ship reporting

systems establish for Greenlandic waters, in our

context the GREENPOS-system is of particular

interest. The GREENPOS-system applies to all ships

on a voyage to and from Greenlandic waters and

inside the Greenlandic continental shelf or EEZ. The

ships are obliged to report their position, course,

speed, and actual weather information every 6 hours.

When joining the system, the ship must provide a

sailing plan including the following information:

− Ship name/call sign

− Date and time

− Present position

− Course

− Speed

− Destination and estimated time of arrival

− Weather and ice information and

− Persons onbord.

Through this reporting system the JRCC in Nuuk

is able to have a rather clear picture of the vessels

navigating Greenlandic waters and to get alert if

things are not proceeding according to plan or a

vessels is not continues to report.

4.4 The Order for Greenland on the Safe Navigation of

ships; order no 1697 (Bekendtgørelse for Grønland om

skibes sikre sejlads m.v.; Bek. 1697/2015)

The aim of the order is to enhance the safety of

navigation in Greenland waters. The order applies for

cargo ships with a gross tonnage of at least 150 and to

ships carrying more than 12 passengers (order no

1697). For passenger ships carrying more than 250

certain particular strict rules apply. Warships etc. and

other state vessels which are not used for commercial

service are not covered by the provisions in chapter 3

of the order concerning safety requirements.

According to the order Greenland is divided in two

navigations zones: the northern and southern

navigation zone. All ships navigating Greenlandic

waters have to observe ice in every area with ice

presence. The speed should be adjusted and ice

searchlight should be used in darkness. Ships shall

keep a safe distance from icebergs. During the

planning of the ship’s voyage the master has to take

into account the following:

− The safety procedures of the ship's safety

management system related to navigation in Arctic

waters;

− any restrictions in the information in nautical

charts and aids to navigation;

− information about the extension and type of ice

and icebergs in the vicinity of the planned voyage

on an ongoing basis;

− statistical information about ice and temperatures

from previous years;

− any possible places of refuge where the ship may

be protected or receive assistance;

− any sea areas designated especially protected areas

in the vicinity of the route; and

− voyages in areas with limited search and rescue

facilities. (order no 1697)

Navigation is prohibited in areas delimited in the

nautical charts by a dotted line with information

about “numerous rock”. Navigation in areas given in

the chart “foul” or “unsurveyed” is only allowed if

the ships follows previously used tracks that the

master has assessed would have a sufficient safety

margin to relation to the ship’s greatest draught and

width and the trip takes place in daylight and with

“good visibility”. Ships should have at least one

person on board with the necessary local knowledge

of the water to be navigated. The person should have

the qualification that would entitle him/her to

navigate the ship concerned or to be trained to have

several years’ experience navigating ships of similar

size.

For passenger vessels carrying more than 250

passengers in the inner and outer territorial waters of

Greenland it is mandatory to employ pilot services; in

this context it may be noted that the territorial waters

of Greenland are 3 nm. The pilot must be certificated

to perform pilotage assignments in the area

concerned. The vessel can get permission to navigate

without a pilot, if the applicant documents the

necessary qualifications and experience navigating in

the Polar waters.

According to the order, ships should have an ice

class, corresponding to the ice, which it is navigating.

The ships have to follow the recommended routes

around Nuuk. With connection to voyage planning, it

is necessary for the master and shipping company to

document the possibility to be assisted by other ships

or SAR facilities within reasonable period of time and

with sufficient rescue capacity (order chapter 4 § 15).

Furthermore, the crew must have a proper training.

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5 PRACTICAL CHALLENGES

5.1 Emergency preparedness

The biggest challenge in the Greenlandic waters is

emergency preparedness. The infrastructure in

Greenland is very limited. The only hospital is in

Nuuk and the hospital does not have the capacity to

accommodate patients from a cruise ship with 2000

passengers and crew. The nearest hospitals in the

region are in Iceland and the nearest hospitals in the

Danish are in Denmark, many hours away by plane.

The emergency preparedness is limited to a small

number of naval vessels of different sizes ships and

helicopters and planes. The Greenlandic airline Air

Greenland is in case of an emergency obliged to

support possible rescue and evacuation operations

with its aircrafts. The biggest challenge is here, that

the airline has only one larger aircraft with a capacity

of about 200 people, which can be used in an

emergency. Furthermore, there is only one larger

airport, in Kangerlussuaq in West Greenland, where

this kind of aircraft can land and take off. Other

Greenlandic airports have only capacity and runways

for smaller aircrafts (for about 30-40 passengers).

5.2 Survival chances

The climate in Greenland is cold, changeable and

complex due to ever-changing presents of ice. The

weather can change rapidly from sunshine and good

conditions for navigations to frog and challenging

conditions. The waters around Greenland are cold the

all year around and survival in the water is basically

impossible. According to Polar Code a passenger

should be able to survive not less than 5 days,

however the exercises conducted in Svalbard, which

to some degree is comparable to Greenland, has

shown that the life-boats have certain limitations and

passengers will most likely not survive for five days.

Participants in the exercise SARex1 had to leave the

lifeboats after 24 hours due too cold temperature and

insufficient insulation on the bottom of the boat. The

more resent exercise SARex2 has shown improved

technology and better insulation at the bottom of the

lifeboats, but another challenge was fresh air. It seems

impossible to remain the proper level of oxygen in a

covered lifeboat without opening “the roof” which

has an impact on the ability to secure proper

temperature for passengers (Solberg 2016 and 2017).

The results of those exercises have shown with quite

some clarity the challenges of surviving in Arctic

waters for 5 days with the existing technology.

Another challenge in connection with the survival

of cruise ship passengers if things go wrong is the

physical condition and age of at least some of the

passengers, who should be evacuated. The average

age of passengers on cruise ships is rather high and

not all passengers are very mobile, which makes it

much more difficult to evacuate.

An accident report from Danish Maritime

Accident Investigation Board (DMAIB) from 2016

illustrates another challenge with the growing

industry of cruise ships: we have not only seen an

increase of large cruise ships navigating Greenlandic

waters, but also a growing industry of smaller tourist

boats offering activities to cruise ship’s passengers.

One of those smaller vessels got in distress in

Greenlandic waters and subsequently sunk and the

biggest challenge in the rescue operation was to

evacuate passengers. There was no space on the

vessels deck where 23 passengers could be able to

dress into the survival suit. The report raises therefore

the general question whether it is possible to evacuate

the passengers from this kind of vessels (DMAIB

2016).

5.3 Navigational challenges and limitations

Greenlandic waters cover an area of about ca. 2

million km

. In this large geographical area radio

communication can be influence by atmospheric and

magnetic disturbances. Furthermore, magnet

compasses could be useless in (parts of) the region

and gyrocompasses could be unreliable. To add to the

complication, some parts of the Greenlandic waters

have not been fully measured and nautical charts can

be rather unreliable. There are currently no sufficient

digital nautical charts, which adds to the difficulties

of navigating the region.

Furthermore, complicated ice conditions are a

challenge all year around and for example some

forms of ice or underwater iceberg are not visible on

radar. The weather is in general very unstable and

unpredictable, which further adds to navigational

risks.

However, our research seems to indicate that not

all parts of the cruise ship industry are fully aware of

the particular risks and challenges of navigating in

arctic waters. And it seems that they are willing to

take some risks to provide their customers an unique

experience.

6 SUMMING UP

The legal system guiding safe navigation of cruise

ships (and other vessels) in and around Greenlandic

waters can be described as fragmented for at least

three reasons: First, the legal regime for navigation is

set in different legal acts under the law of the sea,

some of those are of a general nature, some of those

are specific to navigation in polar/arctic waters.

Second, the legal regime for safe navigation is not

only guided by international law, but also by regional

and national rules. Third, some of the “law” guiding

safe navigation in the Arctic is not binding and

therefore issues of effectiveness must be addressed.

This means in sum, that the legal framework for

cruise ships in the Arctic is complex.

This complex legal system is one side of the medal,

the other side are the practical conditions and

circumstances influencing safe navigation at sea and

the preparedness-system in place. The analysis of the

practical challenges has shown that the existing

legislation cannot stand alone and furthermore leaves

some gaps. There is for example a gap between “work

as imagine” – as described in the Polar Code – and

“work as done” – as seen in the realities of navigating

Greenlandic waters. Furthermore, there are some very

specific conditions and challenges influencing

navigation in Arctic waters. The legal frame work

212

tries to address some of those, but this need to be

mirrored by training, sufficient equipment and

effective structures on land. And at the end of the day

there will always be a certain risk navigating Arctic

waters

7 CONCLUSION

Our study has shown that there is a body of general

and specific regulation on different levels governing

safe navigation in Arctic waters and that this

regulation to some degree has indeed improved the

safety of navigation. This fragmented legal frame

work addresses some of the existing risks which must

be taken into account and sets a frame for the SAR-

system and the preparedness on land. However, we

have also identified certain short-comings, challenges

and gaps connected to the existing legal frame work.

Furthermore, it is important to note, that the legal

frame work cannot stand alone. In fact, in the

Greenlandic context an number of practical challenges

can be identified, which legislation is not able to

address fully – to name the central challenges: first, a

systematic education program for safe navigation in

Greenlandic waters for foreign shipping companies is

lacking. Second, digital nautical charts for

Greenlandic waters are not completely developed yet

and there are currently a lot of gaps in the existing

nautical charts. Third, possibly the biggest challenge

for navigating Greenlandic waters is still the complex

weather and ice conditions, which means that

knowledge and experience is a crucial part in safe

navigation.

In addition, the infrastructure at land in Greenland

is insufficient and not fully developed. It seems

therefore quite unlikely, that a major incident with a

large cruise ship of 2000-4000 passengers could be

effectively and sufficiently handled.

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