Collected the right data? Now comes the challenge of reporting and verification, writes Christian Rae Holm, CEO, Coach Solutions
A recent industry conference saw a straw poll of delegates asked for their biggest challenge in regulatory compliance. The answer? Data collection of course.
But with the next phase looming of EU regulations, the challenge goes beyond collecting data and into making accurate, verifiable reports.
Twelve months ago, a tidal wave of incoming maritime emissions regulation saw shipowners scrabble to sign up to software platforms that promised to support their data collection and submission process. In many ways this was progress; it spelled the beginning of the end of the era of spreadsheet data collation.
Now, with reporting set to start in earnest for EU ETS and FuelEU Maritime, owners are finding out whether their investments will pay off. Certainly, what we are hearing from operators is that some are struggling to bridge from the first phase to the second, with data quality a significant cause of submission failures.
This poses a significant problem for operators who had assumed that the data they were gathering would be of good enough for their verifier. The reality it seems is that there are significant gaps and inconsistencies in the information submitted.
Part of the challenge arises because, in the case of FuelEU Maritime, the data to be collected has a wider scope than before. Including information from the Bunker Delivery Note (BDN) creates a challenge that even some big systems find it hard to cater to.
Errors tend to be around the sequence of events that support the integrity of a voyage – port arrivals, bunkering and departure as well as key data on calorific value of fuel and its CO2 intensity. Crew are required to enter these data manually but it’s far more than miles sailed divided by fuel consumed.
This is only going to become more complicated as the requirements tighten and the IMO Net Zero Framework achieves approval and adoption. Let’s not forget, failures in data verification push the problem straight back to operators. And that could mean correcting data all the way back to January 2024.
It’s an enormous task for a technical superintendent who is likely already over-burdened with administrative tasks. Many vessel operators simply don’t have the resources in house to check and re-validate data, even if they have records of BDNs. On a large fleet, the task could quickly grow from inconvenient to unmanageable.
From customer conversations we believe these problems are arising thanks to a misunderstanding of the importance of collecting low frequency – but highly valuable – data that can be structured and presented for verification.
Even operators using high frequency data collection sensors still need a baseline of manual low frequency data for certain data points. The growth in HF data collection promises interesting developments for vessel operators but is not a panacea.
Low frequency data reporting should never be an afterthought but a core process. It is not enough to collect data, it needs to be validated and structured to have value. We have worked with verifiers to understand the quality of data sent to submission to understand where errors occur and how they can be corrected.
Verifiers are neutral in this process; they do not take responsibility for the data collected. They require operators to report data in a format they specify – very likely different to the format it is collected in – requiring the software partner to perform some translation. If the ‘computer says no’ there will be different levels of support to figure out what is wrong.
Moves are afoot to standardise the data formats used by verifiers but there is little point in hoping that all providers will generate harmonised data that is good enough for other uses. And while digital solutions are being developed for electronic BDNs, maturity of such systems and their acceptance will vary by port and by region. Paperwork is still needed and that means manual process will be maintained for the foreseeable future.
In fact, this type of data challenge is not new to the shipping industry. We saw something similar when the EU Monitoring Reporting and Verification scheme was first introduced.
It’s frightening to think that some operators are reliving that particular nightmare when they can take action to avoid it. Probably the most important lesson is not to attempt to do the same thing the same way and expect a different result.