Table of Contents
- Safety Management objectives of the company:
- Safety and Environmental Protection Policy
- Duties of DPA
- Master’s Responsibilities:
- Resources and Personnel
- Development of plans for ship board operations
- Emergency Preparedness
- Reports and analysis of non-conformities, accidents and hazardous occurrences
- Company Verification, Review and Evaluation
- Certification, Verification and Control
- Requirements on board ship
- Examples of the type of documentation the auditor will wish to see to verify compliance with the ISM are as follows:
- Pollution Prevention and OPA 90
- Non Conformity (NC)
Safety Management objectives of the company:
- provide for safe working practices and a safe working environment
- establish safeguards against possible risks
- continuously improve safety management skills of personnel ashore and aboard ships,
A Safety Management system (SMS) meeting the requirements of the ISM code requires a company to document its management procedures and record its actions to ensure that conditions, activities and tasks that affect safety and the environment are properly planned, organised, executed and checked. A SMS is developed and implemented by people and clearly defines responsibilities, authorities and lines of communication. A SMS allows a company to measure its performance against set criteria hence identifying areas that can be improved. The increase in Safety Management skills improves morale and can lead to a reduction in costs due to an increase in efficiency and a reduction in claims
The safety management system should ensure:
- compliance with mandatory rules and regulations
- applicable codes and guidelines both statutory and organisational are taken into account.
- Promulgation and understanding of company and statutory regulations and guidelines. (It is the task of a visiting surveyor to test the general knowledge of company and statutory regulations and instructions)
The functional requirements for a Safety Management System;
- a safety and environmental policy
- instructions and procedures to ensure that safe operation of the vessel in compliance with relevant international and flag state legislation
- defined levels of authority and communication between shore and ship personnel
- procedures for reporting accidents and non-conformities with the code
- procedures for responding to emergency situations (drills etc)
- procedures for internal audits and management reviews
- A system is in place for the on board generation of plans and instructions for key shipboard operations. These tasks may be divided into two categories :
- Special operations-those where errors only become apparent after a hazardous situation or accident has occurred. E.g. ensuring watertight integrity, navigational safety(chart corrections, passage planning), maintenance operations, bunker operations
- Critical shipboard operations- where an error will immediately cause an accident or a situation that could threaten personnel, environment or vessel. e.g. navigation in confined waters, operation in heavy weather, bunker or oil transfers, cargo operations on tankers.
Safety and Environmental Protection Policy
The company should establish a safety and environmental protection policy which describes how objectives listed above will be achieved. The company should ensure that the policy is implemented and maintained at all levels of the organisation both ship based as well as shore based.
The ISM guideline is in the Chapter IX of SOLAS. It is mandatory for all vessels after 1st July 2002. There are two parts in ISM:
- Part-A: Implementation.
- Part-B: Certification and Verification
- General ,objective,application, functional requirements
- Safety & environment protection policy.
- Company responsibility & authority.
- Master responsibility and Authority.
- Resource & personnel.
- Development of plan for ship board operation.
- Emergency preparedness.
- Report & analysis on non conformities, accidents & hazardous occurrence
- Maintenance of ship equipments
- Company verification, review and Evolution.
- Certification and periodical verification
- Interim certification.
- Form of certification
SMS – Safety management system enabling the company personal to effectively implement company safety & environment protection policy.
DPA means Designated Person Ashore. A person who is provides a link between the company & the ship. He has a direct access to the highest level of management.
Duties of DPA
- Monitoring the safety & pollution prevention aspect of ship & to ensure adequate resources & shore base support for ship.
- person or persons who has direct access to the highest levels of management providing a link between the company and those on board.
The responsibility and authority of the designated person is to provide for the safe operation of the vessels. He should monitor the safety and pollution prevention aspects of the operation of each vessel and ensure their are adequate shore side resources and support
Master responsibilities are to implement the SMS on board ship.
- Implement of safety & environment protection policy.
- Motivation of crew in observing the policy.
- Issue order & instruction.
- Review SMS & report.
Resources and Personnel
- The company should ensure that the Master is suitably qualified and fully conversant with the SMS. They should also ensure that the ship is correctly manned.
- The company should ensure that there is adequate familiarisation with safety and protection of the environment for new personnel. They should ensure that the personnel has an adequate understanding of the relevant rules, regulations, guidelines and codes.
- Training is to be provided where necessary. Relevant information for the SMS should be promulgated and be written in an easy to understand method.
Development of plans for ship board operations
The company should establish procedures for the generation of shipboard plans and instructions with regard to the prevention of pollution and that these should be generated by qualified personnel
The company should establish procedures for the response actions to potential emergency situations. Drill programs should be established and measures taken to ensure that the company’s organisation can respond to hazards and accidents.
Reports and analysis of non-conformities, accidents and hazardous occurrences
The company should ensure that:
- there is a procedure for the reporting and analysis of accidents, hazardous occurrences and non-conformities, and for the corrective action. Maintenance of the ship and equipment
- vessel is properly maintained. Procedures within the SMS should be in place to identify, record and plan for repair defects. A system of preventive maintenance should be in operation.
- Regular inspections integrated with the ships operational maintenance routine should take place to ensure that the vessel is in compliance with relevant regulations.
- The company should establish and maintain procedures for the control of all documentation relevant to the SMS. This should include;
- valid documents are available at all relevant locations
- changes to documents are reviewed and approved to authorised personnel
- obsolete documents are promptly removed
- All documents, carried in a company approved relevant form, should be present on board
Company Verification, Review and Evaluation
- The company should carry out periodic audits to verify that safety and pollution preventions are complying with SMS. The audits and corrective actions should be carried out as per laid down procedures.
- Personnel carrying out the audits should be independent of the areas that they are carrying out the audit unless size of the company is such that this is impractical.
- Deficiencies or defects found should be brought to the attention of the personnel in that section and the management team so effective corrective action can be carried out
Certification, Verification and Control
The following documentation is issued by whichever administration, complying with ISM, is relevant to the shipping company:
- A DOC is issued to all companies who can demonstrate that they have complied with the code should be held. A copy of the DOC should be held on board to allow the Master to produce it to the relevant authorities is required.
- An SMC (Safety Management Committee) is issue to the ship following verification that the ship and company comply with the requirements of SMS. Future verification that compliance with SMS should be carried out by the administration.
Requirements on board ship
- Proof that the vessel is being maintained in a satisfactory condition at all times, and not only at the time of surveys-objective evidence in the form of no overdue surveys, no overdue recommendations from port or flag state inspections and that planned maintenance is being carried out and records kept.
- Applicable codes and guidelines are being taken into consideration when operating the vessel. Vessels staff must be able to demonstrate that operations are carried out in a controlled manner utilising information contained in these codes, guidelines and standards.
- That emergency situations have been identified and drills are conducted to ensure the vessel and company are ready to respond to emergency situations.
- The master is expected to be fully conversant with Company safety management system. Officers and crew would be expected to be familiar with the parts of the system relevant to their safety responsibilities as well as a thorough understanding of their operational responsibilities- auditors will ensure compliance.
- Log books
- Safety and management meeting minutes and follow up actions
- Medical log
- Company circular letters
- Planned maintenance records
- Records of verification
- Records of masters review of the system
- Records of internal audits and follow up
- Records of chart corrections
- Class quarterly listings
- Records of passage planning
- Oil record books
- Garbage logbook
- Company manual and forms
Pollution Prevention and OPA 90
Tied into the ISM code are the requirements to meet OPA-90 to wit a Federal Response Plan. Each company that trades in US coastal waters must have in place a suitable response plan. They must have a designated person resident in the United states ready to act as consultant. There is an IMO regulations which is equivalent to OPA90. A company must be in possession of a valid DOC to trade, and it must be able to clearly demonstrate its ability to respond to situations such as oil spillage.
Non Conformity (NC)
- An observed situation where objective evidence indicate the non-fulfillment of a specified requirement.
- Non-conformance report (NCR) raised by department managers. Any one can inform his superior of a non-conformance.
- DCR means Document Change Request. It is a recommendation for change/correction of company SMS documents.