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W A S T E M A N A G E M E N T www.vanguardcanada.com FEBRUARY/MARCH 2024 13 on handling compartment but was proba- bly slightly disappointed during the first set of domestic routines when the vent to the sewage tank was venting above their bunk. So, there's a lot to be done still to make things better from health and safety, sanita- tion and reduce maintenance requirement on the crew, and to be able to operate in lengthy patrol. MATTHEW PALMER: Thank you. I want to talk to you from a class society perspective about waste and why waste is important and how we provide assurance of those waste systems (Figures 1, 2). The first question is: Do navies have to comply to Statutory Conventions? And the answer is no, they don't. They have an exemption from the governments. They don't have to comply. What they do is have to show that they can get as close as pos- sible through equivalences. I'm not going to focus too much on ship side, I'm going to focus on the submarine code. The codes were created as a kind of naval equivalent to statutory conventions of how to comply. If you paint a ship grey, you can call it a warship. And it's obvious how you can comply with a submarine. You don't have a commercial naval submarine. It's harder to show compliance that way. So, the codes were created to show the special, unique operating things that only naval assets do and that commercial assets don't do. And it's all put into that docu- ment. Over the past few years, we've seen a big, discussion of what compliance looks like. We have one side of the fence that says you should just comply with MARPOL. The other side says, actually, we can't comply with MARPOL. We're too old, or our de- sign won't let us comply. We can't put an oil water separator in, or our grey water tank is too small. We need to discharge it. That's how we can keep operating. So INSA created some environmental guidelines that looked at all the annexes and MARPOL and wrote some naval inter- pretations of ways Navies could apply areas they need to think about and if you could follow MARPOL It's that kind of under- standing, creating that different pathway. And this is something that we could use in next Canadian submarines - actually using this to benchmark and showing regulators how we're complying. Showing how we are using these naval interpretations in these areas, but in these areas we are actually complying with MARPOL and breaking it down as well. But how do we verify against this and give the evidence to the maintainer and to the Navy to say actually this is how you meet it? With submarines, it's harder to actually do what that benchmark is. One of the reasons for that is secrecy. Secrecy is key for subma- rines. As there's not that many submarines out there to create a big rule set that can be maintained. So, what we've had to do is deconstruct the class process. Like when you go to a fancy restaurant and they do a deconstructed meal, they take the elements out and put them in a different order. When I do a course the first question I ask of the group is what's the difference between a ship and a submarine? It seems obvious. Ships aren't designed to go un- derwater and once you start teasing out those issues, it starts that thought process generating of how you provide assurance, especially if we're looking in the context of waste management systems. It was mentioned previously that a sub- marine's number-one priority is stealth. Ev- erything else comes second to stealth. And your space is limited on board. So, modi- fications are difficult because you increase the weight of submarine, which has conse- quences. It's understanding how these systems can be tailored to fit in and provide that assur- ance. And you're showing equivalence to MARPOL that way. We've looked at a kind of goal-based framework of the Naval submarine code and we've come up with the Naval subma- rine assurance framework, which is a goal- based code that sits in between the goals of the submarine code and the verification space (Figure 3). It's the part two solutions that you don't see in the submarine code because of sub- marines and secrecy. So effectively it's a glorified question set. And those kinds of questions are split between process and technical. If I've got an oil order to sepa- rate, it's Commercial off-the-shelf (COTS). Got it. I put it in commercial ships, but can I put it in a submarine? Going through this process is a way of justifying, actually yes, I can put it in that submarine based on the operating conditions that you've put in your concept of operation statement. I actually need to make some modifications to that system, and now the oil water sepa- rated becomes more Military off-the-shelf (MOTS) then COTS, but it gives a spec that Lloyd's Register can verify to and is- Figure 1 Figure 2

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