In 2006, Smith proposed that the IACS recommendation 34 pertaining to standard wave data be modified so that the minimum design wave height be increased to 19.8 m (65 ft). He presented analysis that sufficient evidence exists to conclude that 20.1 m (66 ft) high waves can be experienced in the 25-year lifetime of oceangoing vessels, and that 29.9 m (98 ft) high waves are less likely, but not out of the question. Therefore, a design criterion based on 11.0 m (36 ft) high waves seems inadequate when the risk of losing crew and cargo is considered. Smith has also proposed that the dynamic force of wave impacts should be included in the structural analysis. The Norwegian offshore standards now consider extreme severe wave conditions and require that a 10,000-year wave does not endanger the ships' integrity. Rosenthal notes that as of 2005, rogue waves were not explicitly accounted for in Classification Society's rules for ships' design. As an example, DNV GL, one of the world's largest international certification bodies and classification society with main expertise in technical assessment, advisory, and risk management publishes their Structure Design Load Principles which remain largely based on the Significant Wave Height, and as at January 2016, still has not included any allowance for rogue waves.