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52 Maritime Reporter & Engineering News in the early failures of ships caus- ing unaccept- able pollution and loss of life. "It could even be said that this opti- mization is no more than built-in design obsolescence."

The current functional requirement is that the corrosion addition or allowance be sufficient for the specified design life. However, no percentage is speci- fied; rather, the addition is to be deter- mined based on "exposure to corrosive agents and atmospheres and whether the structure is protected by a corrosion pre- vention system." The addition of the last qualifying phrase is significant because at least one delegation had earlier pro- posed that the design life corrosion addi- tion should be based upon bare steel and therefore independent of any coating; the coating or any other corrosion pre- vention system, if applied, should serve as a safety margin. A corrosion addition sufficient for the design life and inde- pendent of corrosion protection would have been quite novel in an industry notorious for designing and building to minimum standards.

It is now quite unclear how the current functional requirement will account for coating systems that will undoubtedly have design lives (and most certainly service lives) much shorter than the 25 year design life. Further, the coating life functional requirement no longer speci- fies a design life and reads as not much more than a general exhortation that sur- face preparation and coating mainte- nance shall be in accordance with man- ufacturers' specifications.

There is a functional requirement for design transparency: the process should be reliable, controlled and sufficiently transparent to confirm the safety of the new, as-built ship, consistent with pro- tection of intellectual property rights.

Similarly, construction should be in accordance with controlled and trans- parent quality production standards, also consistent with intellectual property rights. However, the working group rejected a proposal by Japan to include a footnote that IMO would develop con- struction quality guidelines. A construc- tion survey plan is to contain require- ments to ensure compliance of construc- tion with classification rules and GBS.

The working group also rejected a pro- posal by Japan that IMO develop stan- dards for ship maintenance, limiting the functional requirement to design and construction to facilitate ease of mainte- nance.

The working group was unable to con- sider Tier III verification and compli- ance criteria. These are intended to be methods, practices and procedures, to confirm that classification societies' pre- scriptive rules accord with Tiers I and II, that the designs of individual ships meet class rules and that their construction enables them to satisfy class rules throughout their design lives. This veri- fication is to be "credible, transparent and auditable."

Tiers IV and V will be the detailed class requirements and the codes of practice for construction, maintenance and operation, respectively. At this time, MSC intends that these nuts and bolts standards should be developed by class or other recognized organizations.

Plainly the serious additional com- plexity arises with Tier III's verification requirements, especially the require- ment that the Tier IV and V rules and regulations comply with the Tier I and II goals. Most important is the question of who will perform those verifications? Is it a role for Classification Societies who, as a practical matter, are obliged to ver- ify that design and construction com-

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