Common Structural Rules (CSR) for tankers The presentation, the introduction and the failures

Stavros X. Hatzigrigoris 1), Spyros V. Karapanos 1), Nikiforos Papadakis 2)

2)

Maran Takers Management Inc., Greece, mail@marantankers.gr Anangel Maritime Services Inc., Greece, Email mail@anangelmar.com increased between 4 % and 7 % to meet the new rules. Similar figures were presented for the CSR-compliant bulk carriers. Reportedly, the major improvements introduced by the JTP were a fatigue life of 25 years based on North Atlantic environmental conditions and the net scantlings concept which as mentioned above resulted to an increased hull weight i.e. presumably a stronger structure. Furthermore, IACS argued that the new rules were to achieve optimum steel distribution and not just a weight increase. This paper will discuss the experience of the authors with the CSR design of a Very Large Crude Carrier (VLCC) developed by a major Far Eastern yard. This showed that despite the promises given by the JTP and IACS, skilled design engineers had taken advantage of loop holes in the first version of the Rules and produced a structure that was significantly weaker than the preCSR design. The major items in which the CSR have to be improved can be summarized as follows: 1. Better use of the experience gained after the mid 90s with the pre-CSR designs. 2. Introduction of a tapering formula that will produce structures equal or better than before outside the 0.4 L area. This is especially critical because there is no analytical tool to assess the structure in that region, unless of course a complete ship model is utilized. This implies strengthening of the forward and the engine room areas and was partially done by January 2010. 3. Enhancing of the maximum allowable bending moment and shearing force Envelopes. 4. Limitation of the liberty given to designers to skip detailed strength analysis in case the calculated stresses do not exceed 95 % of yield. Buckling analysis should be based on fine mesh stress calculations and not on coarse FEM results. 5. The slamming effects should apply to the hull girder and not only to the flat bottom areas of the ships. The paper will also discuss the IACS Rules improvement procedures and how same should be modernized to allow for quicker changes, made more transparent

1)

Abstract
The Common Structural Rules (CSR) were developed at the request of the shipping industry in an effort to stop competition between Class Societies on the weight of the structure of ships. One of the major objectives was also to reduce the possibility of Builders negotiating in a non-transparent way with the selected Society using arguments like, you have to accept what your competitor is accepting, that resulted in designs that were following the minimum rules of each and every individual Society. The CSR were introduced in 2004 and implemented for ships contracted after the first of April 2006. Yards could opt between two different approaches the first being to apply the new rules on existing designs and the second to start with a blank piece of paper. The first approach has given satisfactory results whilst the second has produced questionable structures.

Keywords
IACS; CSR; VLCC; Structure; JTP; JBP.

1. Summary
The preparation of the Common Structural Rules started somewhere back in 2002 by ABS, DNV and LRS, i.e the three LAN societies. In 2004 the JTP group was formed as a result of political negotiations within IACS when it was decided to introduce Common Rules for both Bulk Carriers and Tankers. IACS allocated the development of the CSR for tankers to the JTP and for bulk carriers to the JBP which was formed with the participation of BV, Class NK, GL, RINA, KR, CCS and the Russian Register. The Tanker Rules were ready in 2005 and became compulsory for all New Buildings contracted after the 1st of April 2006. During the preparation stage and for the first time in the history of Classification Societies the new Rules were presented to the industry in a grandiose way and were subject to discussion over a period of more than one year. Several ramification studies were released indicating that the hull weight of the CSR tankers was to be

and more democratic in allowing acceptance by the majority of the IACS members instead of asking for unanimous decisions that make changes almost impossible to process.

2. IACS Common Structural Rules

The rules for the construction of tankers after the mid 90s improved a lot in comparison to the rules that were available before the introduction of fatigue assessment. The need to improve originated from the serious structural problems that kept appearing in ships delivered in the late 80s and early 90s even during their one-year guarantee period. SafeHull, Nauticus, Shipright, Veristar and other Class-developed software helped in the construction of much better ships which have not presented any serious structural problems until today as they approach their third special survey. However, competition between Class Societies and the continued pressure from the shipyards was causing a downgrading of the rules. Super optimization was the word of the day. Moreover, the deterioration of the rules was becoming an issue and at the same time there was no clear and rational link between the requirements for new buildings and the Ships in Service requirements. It is interesting to note that the scantling renewal criteria in the pre-CSR rules were different for each class society. Several owners were opting for optional class notations like the ABS DLA notation in an effort to make sure that the ships that they were getting from the yards would be structurally sound. Other societies were introducing enhanced scantlings notations. In private talks Class Societies were claiming that the structural rules had not kept up with design development in terms of using advanced design tools (they were simple and prescriptive). Several Class Societies were supporting that considerable improvements and more robust ships could be produced if the rules were rewritten. The aim of the International Association of Classification Societies was to develop a set of unified Rules and Procedures for the determination of the structural requirements for oil tankers and bulk carriers. The Joint Tanker Project (JTP) was initiated by ABS, DNV and LR in January 2002 to develop common structural Rules for tankers. The Chief Executive Officers of the three classification societies determined that a joint project should be undertaken to develop a common set of Rules for the hull structure and a promise was given that the best parts in the pre-CSR rules were to be used in creating the new rules. The major objectives were also to eliminate competition between class societies with regard to structural requirements and standards, to employ the combined experience and resources of all three societies (for the tanker rules) to develop a single common standard, or set of Rules. They also wanted to ensure that a tanker meeting this new standard will be recognized by the industry as being at least as safe and robust as would have been required by any of the existing Rules and to fully embrace the intentions of the anticipated IMO requirements for the goal-based new construction stan-

dards. Another target was to reduce the cost of dealing with a number of similar but different sets of Rules and to insure that the resulting rules and procedures are written in such a way as to result in common scantling requirements. For each set of rules, these goals were developed by the project team and the JTP steering committee in response to requests from owners and shipyards for standardization. Individual working groups were formed to deal with loads, longitudinal strength, design principles, fatigue, buckling, local strength, general requirements, FEM, administration and testing. The general approach was to adhere to the overall project objectives, to work under a coherent framework, to include some new approaches where there was sufficient confidence and justification for their adoption, to incorporate best and most transparent methods and to ensure that Rules are internally consistent and reflect the service experience. Also the rules had to result in common scantling requirements and to include the industry input and the feedback. The basic criteria for the Dynamic Load Model were based on simple Rule load formulations for basic load components (ship motions and accelerations, external pressure, internal pressures, global loads), wave headings applying to the North Atlantic scatter diagram according to IACS Rec. 34, on existing Rules (sloshing pressures, bottom slamming pressures, bow impact pressures) and finally on the existing IACS URs when available. 2.1 Net Thickness The CSR are formulated using a net thickness approach. This approach assumes that various degrees of corrosion will occur to the structural members during the life of the vessel. The net scantling approach sets out to determine and verify the minimum hull scantlings that are to be maintained from the new building stage throughout the ships design life to satisfy the structural strength requirements. The net thickness philosophy aims to provide a link between the assumed reduction in strength during new building strength evaluations and the in-service gauging assessment criteria. Renewal values were to cover general and local corrosion given in millimeters and to be indicated in the vessel s drawing. Large areas like the girder cross section do not corrode uniformly. Any assumptions made during new building evaluation need to be followed up during the operation of the vessel. IACS claimed that the actual corrosion values included in the rules were established based on the extensive work of the IACS working party on strength that assembled a database of over 600,000 thickness measurements. This database covers measurements taken over a wide variation of corrosion associated with exposure to the marine environment such as various types of dry cargo, crude oil and products cargoes, ballast water, temperature variations, etc. and covers the structural members to which the margins are applied. Corrosion processes from initial occurrence and during propagation were investigated based on extensive thickness

measurement data. A corrosion process model was developed based on probabilistic theories thus estimating the thickness diminution of structural members.

A statistical analysis of the database was performed in order to extract the margins associated with a probability of the margin 95% for 25 years. Pre-CSR strength evaluations were made based on gross thickness or local simplified buckling evaluations. In CSR well defined margins in millimeters are set instead of percentages of initial thickness. In addition, field stresses on Pre-CSR are based on gross scantlings. In CSR, same are based on hull girder properties with a 10% Diminution. One issue that has to be considered in the future is the fact that for smaller vessels built with thinner members the CSR corrosion margins look excessive.

Fig. 1 Net Thickness General Corrosion

2.2 Local Strength Basic Rule Requirements for local strength are built on the basis of First Principles consistent with other rule sections (Net Thickness, FE Analysis, Fatigue), on Load-based formulas for thickness and a section modulus based on 25-years life, on minimum thickness, stiffness / minimum depth and in some additional empirical requirements. 2.3 Fatigue Strength Assessment Basic Rules Requirements for Fatigue strength assessment are the JTP wave-induced loads, two loading conditions (full load/normal ballast), the JTP net thickness concept, the Palmgren-Miners linear damage model, and the long term stress range distribution (two approaches, i.e. normal stress in conjunction with a stress concentration factor and hot spot stress). 2.4 FEM Analysis Strength analysis by FEM at Midship cargo region is required as part of the rules to verify that the ship structure is within the Class requirements. FEM analysis is also applied for various Load Cases. Fine Mesh analysis is applied at high stress areas and also in openings and main brackets on two typical transverse web frames. 2.5 Advance Buckling Analysis Buckling analysis is based on non-linear analysis techniques. The JTP rules give general requirements for advanced buckling analysis and for the application of structural modeling principles and assessment criteria.

The JTP Rules allow the use of the ultimate strength for certain structural elements subject to lifetime extreme loading. Ultimate strength assesses the section as a whole. 2.6 CSR Advantages All Classification Societies will use the same structural rules so if a design is approved by one Classification then it will automatically meet the requirements of any other Society. In addition, the technical basis of the Rules was open to public scrutiny not mentioning the fact that many comments submitted by the Industry have been largely ignored by the JTP.

3. Ramification Study for a VLCC Tanker

As per IACS and for the Midship cargo region of a VLCC tanker the thickness of the deck plating in way of cargo tanks had to be increased due to buckling. Bottom and side shell plating had to be also increased in some locations for the same reason. In addition, plating thicknesses for the mid and upper part of the inner longitudinal bulkhead were increased due to local requirement basically because of yielding and buckling. Plate thickness was increased in the upper part of the side longitudinal bulkhead due to prescriptive buckling. The dimensions of the longitudinal stiffeners were increased for the bottom and the inner bottom, the hopper area, the inner longitudinal bulkhead and in the bottom & upper part of the side shell. Plate thickness was increased as well in way of side cargo tank transverse bulkhead (mid and upper part) due to buckling. In a typical Web section, in the swash bulkhead and in the stringers, panel stiffeners have been modified due to buckling or yielding.

INTERTANKO LATIN AMERICAN PANEL, IACS Common Structural Rules, Rio de Janeiro, 25 April 2006

4. The discussion on the Common Structural Rules

During the discussion on the CSR a number of questions summarized the agony of the technical people in the industry towards improving the structure of tankers. We will quote below a number of questions and answers as published in the JTP documents. 4.1 Dennis Arnett, Chevron Texaco (ref. No. 947): Going into this project, it was stated that the tanker that would result from JTP Rules will be at least as good as one from the current Rules of any other three class societies involved. From the limited consequence calculations provided, it is difficult to readily see that this aim in fact has been achieved, and this is not to say that such result is necessarily the realistic one to the expert. However, it would be fair to say that related clarifications and education / communication are needed to facilitate more ready acceptance of the proposed rules. Reply from JTP: The consequence assessments to date have demonstrated that scantlings increase in most cases. The critical areas targeted for increases have yielded these increases. Of course, the change of approach also shows some areas as reducing in scantlings although the overall safety level increases. The ship designs that have been heavily optimized see the largest increases. The new Rules should therefore create a ship with higher gross scantlings overall. It is fair comment that more feedback is needed from consequence studies. The current consequence document is dated 23rd July. Further work is in process to update this. 4.2 S. Hatzigrigoris, Kristen Navigation (ref. No. 157): Ref:#703 - The JTP common Rules should be at least as safe and durable, equivalent or better than the current Rules. To avoid misunderstandings and missimplementations this should be clearly stated in the preamble of the Rules. Reply from JTP: JTP agrees with the statement and considers that sufficient documentation exists in the background documents. The foreword to the Rules contains the sentence "It is to be particularly noted that in developing these Rules due cognizance has been taken of ensuring that the overall safety of the hull structure is equivalent or better than existing design criteria, has sufficient durability in terms of corrosion margin and fatigue strength, and the need to transparently define the relationship between the required scantlings for design and those for renewal". 4.3 Dennis Arnett, Chevron Texaco (ref. No. 821): Do the new joint tanker Rules increase or decrease the existing deck local design head, such as for green water shipping effect? Please provide related comparisons for review. Reply from JTP: The JTP Rules increase the existing deck local design head, e.g. green water head. As the deck scantlings required by the present class Rules are

mainly dominated by the buckling requirements. The impact of the increased green sea pressure is not substantial. 4.4 S. Hatzigrigoris, Kristen Navigation (ref. No. 298): In the proposed Rules the maximum allowable still water bending moments are extracted from vessels Loading Manual. We have seen Aframax designs (basically sister ships) with maximum allowable BM varying from 250000tm to 340000tm. The minimum allowable values should be determined by the Rules and not left to the skilful shipyard engineer. Reply from JTP: Your comment is noted and we agree to include a Rule minimum still water bending moment. This is presently being worked on and will be included in the rules prior to publication. 4.5 Hideaki Naoi, Kawasaki Shipbuilding (ref. No 249): Please explain the detail of feedback from service experience and measurement. Reply from JTP: Feedback from service experience refers to experience obtained from structural damage and is embodied with current classification Rule requirements and hence incorporated into the JTP Rules. 4.6 Ou Kitamura MHI (ref No 385): JTP states that draft JTP-CSR brings about increased scantlings above those given by the existing Rules of either ABS, DNV or LRS. From technical point of view, the lower bound scantlings among the three or more Class Rules can be most likely to give the minimum figures, provided that feedback from successful/unsuccessful experience in service has been continued. Otherwise the structural safety level cannot be controlled consistently. It is obvious that the thorough review of the consequent impact given by the draft CSR has not yet been completed by JTP. This means that no calibration has been made systematically. In some cases overestimation of the safety level may be found as well as underestimation as the results of a series of calibration. Reasoning or technical background must be presented for Each Rule revision based on not impracticable theory but actual results in principle. Reply from JTP: JTP is continuing to calibrate and fine tune the Rule requirements to ensure the structural safety level is controlled consistently. The preamble of the June 2004 edition of the CSR stated: It is to be particularly noted that in developing these Rules due cognizance has been taken of ensuring that overall safety of the hull structure is equivalent or better than existing design criteria, has sufficient durability in terms of corrosion margin and fatigue strength. The preamble of the January 2006 final edition of the CSR stated: The objectives of the Rules are to establish requirements to reduce the risks of structural failure in order to

help improve the safety of life, environment and property and to provide adequate durability of the hull structure for the design life.

5. Structural Drawing Comparison between a pre-CSR and a CSR VLCC design

In this part of the paper we will compare the structure of a pre-CSR and a CSR design developed by the same Far Eastern yard. The Frame spacing on the CSR design was increased from 5,110 mm to 5680 mm. This will normally produce thicker plating requirements. Given that the scantlings are roughly proportional to the square of the span, the geometric properties such as section modulus for example need to be increased by about 23%. The percentage of the high tensile steel on the CSR design was increased to 45 % up from 30 %. This is an issue to be discussed since one of the effects of the CSR seems to be the tendency to increase HTS in an effort to reduce cost to the yard. 5.1 Midship Section In the hopper area the lower plate thickness was decreased by as much as 4.5 mm and the upper plate by 3.5 mm. This thickness difference reduces the total sectional area of the hopper by 17%. Size of longitudinal stiffeners in the hopper area has been reduced in the CSR design but the material has been upgraded to high tensile steel so the strength is similar. This thickness reduction is probably acceptable by the analysis but it is contrary to all rules of shipbuilding where we try to keep uniform strength in critical areas such as the hopper and the bilge areas.

In addition for the CSR design the cross ties height was reduced from 2,120 mm to 1,920 mm. whilst the plate thickness was increased by as much as 2 mm. Given that the section modulus of the cross tie is proportional to the square of the height, the thickness needs to be increased by more than (2.12/1.92)2 = 1.22 or 22% to have equivalent structure (1.22x18 = 22 mm). Lack of attention to structural details was evident and scallops were allowed in high stress areas.

Reduction in breadth and slight increase of plate thickness appear also in the forward transverse web frame section, where the frame breadth is reduced by 730 mm. and the plate thickness increased by 2 mm. In addition the radius of the lower bracket in way of the wing cargo tanks has been reduced from R 4,000 to R 3, 375.

The bottom plate thickness was reduced by 1.0 to 1.5 mm but the sectional area for the bottom longitudinal was increased by 15%. The inner bottom plate thickness was reduced by 0.5 to 1.0 mm and the sectional area for the inner bottom longitudinals increased by 2%. The double bottom is an area in which the CSR produced a better structure than before. 5.2 Typical transverse bulkhead Significant differences appeared in the design of the stringers. For the No 1 stringer in way of the center tanks the length was reduced by 300 mm, the plate thickness reduced by 3mm. and the shear area for the center part of stringer reduced by 21%. The number of the transverse stiffeners was reduced from three to two. Similar reductions appeared for the No 2 and the No 3 stringers in the center tanks.

The main deck plate thickness is reduced at the center tank by 1.5 mm at wing cargo tanks by 1.0 mm and in way of the ballast tanks by 2.0 mm. The sectional area for the under deck longitudinal increased by 25% in center tanks and by 15% in wing cargo tanks.

In addition for the No 1 stringer in way of wing tank the stringer the breadth was reduced by 300 mm, the plate thickness reduced by 2mm and the shear area reduced by 18%. The number of transverse stiffeners below the plate was reduced from three to two. Breadth and plate thickness reductions were applied in way of No 2 strin-

ger of Swash Bulkhead.

Similar dramatic reductions were also effected on the stringers of the swash bulkhead. 5.3 Construction profiles and deck plans The main deck plate thickness in way of No 1 tank has been decreased for the CSR design. At the forward part of the tank the thickness was reduced from 17.0 mm to 14.5mm, at the mid part from 18.5mm to 14.5mm and at the aft part from 18.0mm AH to 15.5mm

The main deck plate thickness in way of No 1 tank has been decreased for the CSR design. At the forward part of the tank the thickness was reduced from 17.0 mm to 14.5mm, at the mid part from 18.5mm to 14.5mm and at the aft part from 18.0mm AH to 15.5mm.

Similar thickness reductions were observed also in way of the No 5 Cargo Tanks where the thickness was reduced from 22.0 AH to 20,0 AH and in way of the Slop Tanks from 18.5 mm to 15.0 mm

5.4 Shell expansion The side shell plate thickness was reduced in several locations. For example in upper part of Engine Room the plate thickness at Pre-CSR design was 20.0 mm. For the same area the thickness in the CSR design was reduced to 16.5 mm and in some locations to 15.0mm.

5.5 Fore body construction The under deck stiffening for Main Deck as well as for below platforms was substantially weaker. Also the Inner Bottom structure (3,000 A/B) that had been installed at Pre-CSR design was removed in the new design.

6. Corrosion Margins
One of the promises given during the presentation of the CSR was that the structure of a ship, based on the net scantlings approach was to be more robust than the preCSR ships. This implies that if renewal thicknesses are to be compared between the two sets of rules the CSR net scantlings should be higher. In the table prepared below the pre-CSR corrosion margins of 20 % are compared with the CSR renewal thicknesses. The conclusions are that the CSR rules allow for lower renewal thicknesses than the pre-CSR rules for several areas of the ship. This is something that should be studied by the JTP and it will be difficult to prove how a more robust ship is a ship with thinner minimum scantlings.

7. The shortcomings of the CSR

There is an urgent need for harmonization. The two sets of rules (Bulk Carriers and Tankers) are different in fundamental aspects of the scantling assessment such as buckling, fatigue, loads and direct strength analysis. IACS have initiated the harmonization process two years ago but there are no progress reports so far on what has been achieved or on what is in the pipeline. An honest harmonization has to be done that will take into account the different loading and operating conditions between tankers and bulk carriers. If there are differences and harmonization in a set of formulae is impossible, then different calculations should apply to the two different types of ships. Harmonization should not result in any downgrading of the tankers or the bulk carriers rules. The problem with the CSR is that they do not specify basic structural dimensions such as for example depth of bulkhead girders or stringers, sizes of brackets, number of tripping brackets and stiffening patterns. The Yard has freedom to optimize the design and reduce the aforementioned stiffening and sizes accordingly. Our experience is lowering of the pre-CSR standards as far steel distribution is concerned. This type of design is passing through the approval process, since the direct stress analysis is lenient and forgiving. Zooming analysis with mesh refinement would probably have reflected the problems. One solution may be to ask for zooming analysis for certain critical details. It is reminded that these members (also called primary supporting members) are estimated in the tanker CSR rules primarily on the basis of direct strength analysis. The prescriptive formulation is also applied and a 15% reduction in the resulting scantlings is acceptable if allowed by the direct strength analysis. This CSR requirement was fiercely opposed by the Industry but without any action from the JTP group. Even worst, in bulk carriers there are not even prescriptive rules for the primary support members. The rules are problematic towards the ends of the vessel. A known deficiency of the three hold model is that it cannot be applied to the first and last cargo holds. In that case the only way is the conservative way, i.e. to prescribe the same scantlings as the ones in the mid-ship region. Even more importantly, there is no specific and clear method to assess the structural integrity of the stern and the bow. Bow is subject to high frequency slamming loads as well as increased inertia loads. Stern is where the propulsion of the vessel is located and is subject to a spectrum of loads at a range of frequencies. Neither bow nor stern area of the ship are addressed in the CSR in a clear cut way. The recent common interpretation procedure (published on 01 January 2010) improves the situation but the ends of the ship are far weaker than the pre-CSR rules. The problem is aggravated by the lack of transparency on the tapering of the scantlings and associated bending moments and shear forces at the ends. The lack of common software to assess the CSR scan-

tlings creates discrepancies in various designs. IACS has abandoned the practice followed in the first days of CSR application. In the beginning of CSR application, the MOU between Class Societies dictated that the scantling evaluation will be performed by all. Nowadays, the MOU dictates that only the initial scantling assessment is necessary and the next classification society accepts the results of the first. Two class societies merged their man-power to develop common software. Two questions result immediately from this news. Why not a common software for all class societies? What about the validity of the scantlings of the designs approved by these two class societies before the merging of their software? There are no clear criteria for the analysis of high stress areas. It seems that in areas of high stresses (which are somewhat arbitrarily defined), there is a need for mesh refinement and further analysis. The stresses in the refined models are allowed to exceed the yield strength. This is a physical impossibility. Of course it is understood that it is not feasible to perform an elastic-plastic analysis for each critical structural detail. On the other hand it appears that IACS has set a series of acceptance limits on the maximum stress which are not based on clear grounds and analysis. There are areas which are not handled in the CSR, as for example the problem of ship response to torsional loads. Torsional loads might be critical for bulk carriers. Even more so, since IACS accepts the so called hybrid bulk carriers which have hopper and top side tanks at either the first and/or the last cargo holds. The remaining cargo holds do not have hopper and top side tanks, resembling a typical containership and suffering from the effects of torsion in the same way. To the best of our knowledge, the strength of the scantlings of the inner bottom and hopper plate to withstand steel coils is defined in error and need to be re-evaluated. Potentially there are numerous errors and carry-over material which is never implemented like for example Section 5, Chapter 8 of the CSR for Bulk Carriers regarding the stress assessment of hatch corners. So far the Rules dictate that if the thickness of the hatch corners is increased by up to 60% related to the thickness of the surrounding deck plate, then there is no need for further analysis. It remains to be seen if this simplistic consideration will result in crack-free hatch corners. It is also a common secret that IACS recommends weld grinding at the intersection of the tank top with lower stool. The latter appears to be the most critical part of the vessel and impossible to comply with the required fatigue life of 25 years. IACS was quick to reduce this number to below 20 years in case grinding is applied on the weld as demanded by the Shipyards of Korea and Japan where labor cost is high. Results of fatigue analysis in tankers are somewhat unrealistic due to prediction of critical areas in the deck and bottom. It is well known that cracks in tankers are more prevalent in the side shell longitudinal stiffenerweb-bulkhead crossings for the area between the full load and normal ballast waterlines. Shear strength for tankers and bulk carriers is based on

semi-empirical formulations instead of the well established shear flow distribution techniques. In other cases, very advanced techniques like nonlinear buckling analysis are employed in the rules but the method utilized is lacking solid theoretical foundation and it represents a black box for the practicing naval architect. It appears that IACS has still to agree on the size of the insert plates required at the critical stress areas as well as on the type of analysis required in these areas. For example the lower and upper hopper connections with the inner shell are highly stressed areas and need to be analyzed by refined mesh and evaluated by finite element based stresses in fatigue strength. Resulting insert plate thicknesses are unrealistically high compared to the surrounding plate. CSR revisions and corrigenda (?) are invariably reducing the scantlings. This is done without first getting experience/operational feedback from the first version of the rules. This practice should be stopped unless there are sound technical reasons proving that scantlings could get lighter. The reaction of the shipyards to the CSR was to increase the HTS portion in order to get a similar steel weight for designs of standard dimensions. This, coupled with the problems mentioned above, is now resulting in lighter hull weights. Buyers (based on the information provided on the erroneous ramification studies published before the introduction of the CSR) have more or less accepted to pay a premium for CSR designs. Now it is common knowledge that they are not getting any value for the extra money that they paid. For certain areas of the ships the new corrosion margins result in smaller net scantlings than that in the pre-CSR era. This has been done without any justification from the experience gained from the operation of the ships. The introduction of the PSPC requirements will improve the situation as far as ballast tanks corrosion is concerned but it will be interesting to monitor the net scantlings approach of the CSR on large bulk carriers carrying corrosive cargoes.

8. The IACS procedure for Rule Changes

As already mentioned above there have been serious concerns about the way that was followed during the development of the CSR, the methodology used and the political power games that influenced the development process. It has also been shown that the theoretical approach followed and the subsequent calibration of the structural models (used to reduce CSR scantlings to values close to the pre-CSR rules) have resulted in scantlings that could be lower than the pre-CSR rules. Shipyards have followed two different approaches: Using the CSR in order to improve pre-CSR designs and starting for a blank piece of paper and taking advantage of the CSR loopholes. The designs produced by shipyards that followed the first approach seem to be satisfactory although there is

no guarantee given that the same calculation methods will be followed specially after comparing their work with the work done by builders that followed the blank paper solution. The increase of frame spacing and HTS percentage are issues that may cause problems in the future and will have to be studied further together with the general trend seen to avoid the use of tripping brackets, reduce the size of primary and secondary supporting members and other similar issues. Furthermore, buckling preventing devices such as large tripping brackets and supports should be examined with fine mesh analysis and reduced buckling coefficients in particular in areas where unstable buckling is to be expected. IACS in their effort to maintain the political stability in their organization have issued Procedural Requirement No 32 according to which a very complex organization has been set up for further developing the CSR. This organization includes the Council, the Steering Group for the CSR, the CSR Secretariat, the Hull Panel, the CSR Maintenance Project Teams, the CSR Harmonization Management Team and the CSR Harmonization Project Teams. If we consider that most of the CSR changes (with the exception of the UI on tapering) that have been published until today have mainly reduced the scantlings required by the original version of the CSR, it is reasonable to assume that either no improvement proposals have been submitted or that improvement proposals are impossible to pass through the complex mechanism discussed above. If this is coupled with the existence of numerous loop holes in the CSR and the ingenuity of shipyard design engineers, it will become obvious that a large number of ships will be delivered before any improvement of the CSR can be achieved. Unfortunately if this comes true, it will bring the industry back to the late 1980s early 90s where a number of serious structural damages that were attributed to inadequate building rules rocked the shipping industry. It was during that period that the image of Class Societies reached its nadir and prompted underwriters to ask for their own structural surveys on ships. The only way to save the day for IACS is for them to revise their procedures and create a more flexible, democratic and transparent way for improving the rules. Accidents, today, receive a lot of publicity and Societies should consider seriously the liabilities associated with the possible structural failures of ships.

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9. Conclusions
The new CSR rules leave space for a lot of substantial improvements. Class Societies are invited to decide if the new CSR rules are better than the rules that they replaced and in particular if: a. We have seen a real substantial improvement. b. If, within the near future, a common interpretation will prevail to the individual ones that we are currently getting from the Societies. c. If and how they will control the innovative yard engineers. d. If changes will improve or water down the rules. e. If harmonization between the JTP and the JBP will work to the detriment of the tankers rules. f. If the higher use of HTS that the yards are using as an antidote to the CSR will enhance tanker safety. This is of particular importance for yards that do not have extensive experience with the use of HTS. It has to be said at this point that the opinion of the authors is that changes are needed on an urgent basis and that we do not have the time to wait to get experience from the application of the new rules. We do not see any radical changes in the methodology used for the development of the rules and we do not want to end up with a generation of structurally problematic ships as happened during the late 80s and the early 90s. .

10. Acknowledgements
Our special thanks to all the Class Societies people that were involved in the development of the CSR. The discussion that will follow the first pure CSR designs will give the industry the opportunity to deepen and enrich the understanding of the structural problems associated with the design of large tanker structures. Our appreciation to the Far Eastern yard VLCC design engineers that gave us the opportunity to spend a number of late evenings evaluating their work instead of watching Greek TV channels of questionable quality (this goes both for the news / political and the entertainment broadcasts).