Legislative Decree 81/08
Technical standards UNI EN
Military Standards (NAV, MIL, …)
Military Ship Risk Assessment - MMI Approach
For the construction of new Naval Units commissioned by the MMI under the so-called “Naval Law,” a gradual updating of procurement specifications and procedures for acceptance of military ships by the Administration has been initiated.
From the point of view of occupational safety, it is clear that the intent is to improve control of the entire construction process, from preliminary design to final implementation, by forcing Manufacturers to provide adequate technical and “certification” guarantees based on the applicable technical regulations.
In the context of complex systems such as Military Ships (living quarters, galleys, apparatuses, engines, but also hospitals, workshops, complex installations, weapon systems, auxiliary units, …) this increased control translates into the contractual requirement to provide, upon delivery of the ship, a document summarizing the entire “course” taken by the Builder aimed at minimizing risks to future operators.
In the definition of these new standards by MMI (in which NEMOTEC has actively participated, starting in 2019 with the delivery of the ), the documents necessary for the future Employer (Master of the ship) to manage the safety and health of workers in accordance with the current legal standards have been included in the path of the delivery of the ship, thus reinforcing the importance of this process towards the private Industrial.
First, the purpose of the Manufacturer’s responsibility to MMI at the time of delivery of a Military Ship was clarified:
• The design, and then later the final installation, must be demonstrated and documented as complying with applicable technical (safety) standards: these standards may be military (e.g., weapon systems), naval (e.g., RINA regulations), or even simply industrial (e.g., CE certification of apparatus and machines bought equivalently for the civilian market and then installed on board, e.g., a workshop lathe or waste shredder, a portable hoist, or a small compressor);
NOTE: This principle was present even before the new standards (in fact it is enshrined in the law, Legislative Decree 81/08), but the way in which evidence is now required has changed considerably.
• The residual risks that the use of the Vessel will present to the operators (the MMI staff) under a number of operational configurations must be minimized through the provision of sufficient additional safety measures if the quality (given also the functional constraints) of the design is not sufficient to guarantee it; these measures must be tracked and documented, to create awareness to the operators, of their purpose and importance.
• This entire process must be documented by the Constructor in a final document, consisting of multiple sections, called the Technical Risk Assessment Report (RTVR), which considers not only all of the ship’s workplaces (rooms, areas, etc.) but also plant and equipment.
In addition, MMI clarified that:
The military equivalent of the Employer of a manufacturing plant in the civilian field is the Ship’s Commander, and his responsibility in issuing and approving a Risk Assessment Document (DVR), in accordance with the occupational safety law, Legislative Decree 81/08, cannot be delegated to either the Ship’s Constructor or any other Navy Entity.
From the preceding point, it follows that everything related to the safety of the work organization-including such aspects as task assignment, training, supervision, time exposure to particular previously identified risks (e.g., noise risk, chemical risk, manual handling of loads), and the application and definition of “safe behaviors”-remains the responsibility of the Ship’s Master, who must document and manage them with his or her own organization within the DVR.
Thus, a distinction should be made between an RTVR document – in charge of the Builder, and a DVR document – in charge of the Ship’s Master, issued through his direct organization and his RSPP.
Who approves these documents in the acceptance pathway of a Ship?
• In the case of RTVR, it is the responsibility of the UGECOPREVA (central body to Navy safety and prevention based in Rome),
• In the case of DVR it is the Shipboard Command itself (Employer), in which case UGECOPREVA provides in-house assistance and “advice.”
RTVR vs DVR
Prior to the distinction between these two documents, private industry was required to provide a document, called a Risk Assessment, whose limitations not being so clear constantly generated perplexity of approach.
How can a Builder get into the merits of training of personnel not his own?
How can a Manufacturer get into the actual time of exposure of a certain operator to the noise hazard if it is not the Manufacturer who specifically defines the task and mode of work? On what basis can precise safety prescriptions be given?
UGECOPREVA, having revised its application standard for Legislative Decree 81/08 in the military, has made the process clearer.
The RTVR is a risk assessment document that:
• It addresses upstream risks generated by the overall project and demonstrates how appropriate precautions were taken during the project in line with regulations.
• Identifies and assesses residual risks that may still be present based on foreseeable operational use (taking into account certain operational configurations of the Vessel) and documents what safety measures (mitigations) have been taken to minimize these risks.
• Defines what precautions, work methods, training requirements, organizational actions are recommended (based on the Manufacturer’s knowledge and experience) to be taken by the Employer to minimize further risks to operators.
• Suggests, based on various conceivable cases, what type of PPE is thought useful and advisable to the Employer to minimize further risks.
In addition, the RTVR:
• It does not go into the operational details of the work (roles and tasks), which are instead the responsibility of the DVR (Command of the Board) based on the actual and real exposure and work mode adopted.
• Because of the points described above, it becomes the main input document for the Shipboard Command in producing its DVR.
• It must be delivered with the Vessel to enable the Ship’s Command to issue the DVR in time with the future operation of the Vessel.
Some of the risks posed by physical agents, certainly identifiable during design and installation (therefore assessed in the RTVR by the Constructor), are strongly related to the exposure factor that depends on the role that personnel play in the organization and their job description (therefore assessed in the DVR by the Shipboard Command)
In order to enable the Board Command to organize the work with adequate prevention to these risks, it is important for him to know the level of presence of hazardous factors, based on which he can take appropriate improvement actions.
These evaluations are made against instrumental surveys to be conducted at the end of outfitting under the most recurring ship-use conditions possible (operational condition).
Example: if the shipboard command knows the noise levels of certain ship zones based on the operational configuration, it may be able to assess the hazardous exposure of certain tasks by taking into consideration the time spent in that zone and defining appropriate PPE.
Here, then, the RTVR is not only composed of qualitative safety analysis, but is required by contractual specification to provide for a series of measurements regarding, for example: air quality, noise, vibration, electromagnetic emissions, drinking water quality, etc…