HNC and HND in

Marine Surveying

UNIT 20
The International Safety
Management Code
UNIT 20 | The International Safety Management Code

Version 1
This material is the property of the International Institute of Marine Surveying, copyright of which is vested with IIMS, is confidential and
is non-transferable. It must not be copied, reproduced, kept in any data bank, stored in any retrieval system or transmitted in any form or
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PART A
STUDY, INTERPRETATION and ENFORCEMENT
of the ISM Code (2010) and IMO Resolution A 1022
SUMMARY...................................................................................................................................page
General Introduction ..........................................................................................................................11
1. Study of the preamble of the ISM code
1.1 Text ......................................................................................................................................................12
1.2 Comments
1.3 Self-assessment questionnaire

2. Section 1 of the ISM code: GENERAL

2.1 Text ......................................................................................................................................................16
2.2 Further Comments
2.3 Objectives of the Code
2.4 Objectives of the company’s SMS
2.5 SMS requirements
2.5 Contents of a Safety Management System
2.6 Elements to be investigated during an internal audit
2.7 Self-assessment questionnaire
2.8 Typical structure of a SMS

3. Section 2 of the ISM Code: SAFETY and ENVIRONMENTAL PROTECTION POLICY

3.1 Text: Safety and Environmental Protection Policy......................................................................25
3.2 Example of a “Declaration of the Company Management”
3.3 Definitions of the Objectives of the Company
3.4 Application of the Policy inside the Company
3.5 Example of an Application of a Policy
3.6 Elements to be investigated during internal audits
3.7 Self-assessment questionnaire

4. Section 3 of the ISM Code: COMPANY RESPONSIBILITIES and AUTHORITY

4.1 Text: Company Responsibility and Authority .............................................................................31
4.2 Theoretical Structure of a shipping Company
4.3 Elements to be investigated during internal audits
4.4 Self-assessment Questionnaire

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5. Section 4 of the ISM Code: DESIGNATED PERSON(S) ..................................34

5.1 Text: Designated Person(s)
5.2 Comments
5.3 Additional Comment
5.4 DPA’s Responsibilities
5.5 “DP” Extracts from MSC-MEPC.7/Circ.5
5.6 Elements to be investigated
5.7 Self-assessment Questionnaire

6. Section 5 of the ISM Code:

MASTER’S RESPONSIBILITY and AUTHORITY ...............................................40
6.1 Text: Master’s Responsibility and Authority
6.2 Comments
6.3 Captain’s Authority must be emphasized
6.4 Form of the Captain’s Review
6.5 An Example of Writing Statement
6.6 Elements to be investigated during audits
6.7 Self-assessment questionnaire

7 Section 6 of the ISM Cod: RESOURCES and PERSONNEL ...........................48

7.1 Text: Resources and Personnel
7.2 Comments
7.3 Qualification of the Crew
7.4 Familiarization
7.5 Knowledge of Existing Codes and Rules for the Personnel Involved in the SMS
7.6 Necessary Training
7.7 Information on the SMS in a Language Understood by the Crew
7.8 Communication Onboard
7.9 Familiarization Procedure
7.10 Recent IMO guidelines on ISM Training
7.11 Example of Record
7.12 Anti-drugs and Alcohol Procedure
7.13 Elements to be investigated during audits
7.14 Self-assessment questionnaire

8. Section 7 of the ISM Code: SHIPBOARD OPERATIONS ...............................61

8.1 Text: Shipboard Operations
8.2 Comments

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8.3 Principal Shipboard Operations

8.4 Procedures, Plans and Instructions
8.5 The Tasks should be Defined and Assigned to Qualified Personnel
8.6 Conclusion
8.7 Training List for the Crew
8.8 Elements to be investigated during internal audits
8.9 Self-assessment questionnaire

9. Section 8 of the ISM Code: EMERGENCY PREPAREDNESS .......................66

9.1 Text: Emergency Preparedness
9.2 Comments
9.3 Identification of Emergency Situations
9.4 Description of Emergency Situations
9.5 Setting up a Plan of Exercise and Drills
9.6 Elements to investigate during internal audits
9.7 Self-assessment questionnaire

10. Section 9 of the ISM Code: REPORT and ANALYSIS........................................72

10.1 Text: Reports and Analysis of Non-conformities,
Accidents and Hazardous Occurrences
10.2 Comments
10.3 The REX Card
10.4 MSC-MEPC.7/Circ.5 guidelines
10.5 Comments on these guidelines
10.6 Elements to be investigated during audits
10.7 Self-assessment questionnaire
10.8 Example of Feedback Management
10.9 Example of feedback flow chart
10.10 Example of Feedback Card

11. STUDY OF SECTION 10 OF THE ISM CODE ........................................................80

11.1 Text: Maintenance of the Ship and Equipment
11.2 Comments
11.3 What are Critical Elements in Section 10.3 of the Code
11.4 List of elements to be investigated during audits
11.5 Self-assessment questionnaire
11.5 Example: Company Database

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12. STUDY OF SECTION 11 OF THE ISM CODE ........................................................85

12.1 Text: Documentation
12.2 Comments
12.3 Controlled Documents
12.4 Non-controlled Documents
12.5 Accessibility of Documents
12.6 Mandatory Documents
12.7 Data-processing Management of Documents
12.8. Development of a Procedure
12.9 Elements to be investigated during internal audits
12.10 Self-assessment questionnaire

13. STUDY OF SECTION 12 OF THE ISM CODE ........................................................90

13.1 Text: Company Verifications, review and evaluation
13.2 Comments: Summary of Requirements
13.3 Internal audits: what, who, when, how
13.4 Management review
13.5 Publicity of reports
13.6 Treatment of Correctives actions
13.7 Extract from MSC-MEPC.7/Circ.5: Review
13.8 IMO circular: Internal audits
13.9 Elements to be investigated
13.10 Self-assessment questionnaire

14. SECTION 13 of the ISM CODE:

CERTIFICATION & VERIFICATIONS..........................................................................96
14.1 Text
14.2 Comments
14.3 What are the modifications after the amendments 2008 in force 2010
14.4 Self-assessment questionnaire

15. SECTION 14 of the ISM CODE: INTERIM CERTIFICATION........................101

15.1 Text
15.2 Comments
15.3 Comments on the 2008 small amendments
15.4 Self-assessment questionnaire

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16. SECTION 15 of the ISM code: VERIFICATION.....................................................104

16.1 Text
16.2 Comment

17. SECTION 16 of the ISM CODE: FORMS of CERTIFICATES..........................105

17.1 Text
17.2 Comments
17.3 Self-assessment questionnaire

18. STUDY of IMO RESOLUTION A 1022 or ISM EXTERNAL AUDITS ......106

18.1 New IMO resolution 1022
18.2 Process of Certification
18.3 Practice
18.4 Different audits
18.5 Restitution of an audit
18.6 Auditors’ qualification
18.7 Conclusion
18.8 Self-assessment questionnaire

PART B
INTERVENTION OF THE CONSULTANT
19. INITIAL ASSESSMENT, ACTION PLANS for CREATING
and IMPLEMENTING a SMS .............................................................................................111
19.1 Evaluation and drafting of documents
19.2 Choice of the DPA
19.3 Preparation of an action plan
19.4 Preparation of drafting the SMS documents
19.5 Self -assessment questionnaire

20. OPERATION of the SMS ASHORE ...............................................................................115

20.1 Role of the Company
20.2 Watch-keeping System
20.3 The Crisis Cell
20.4 Visits and Inspections of the Management aboard Ships
20.5 The ISM Structure
20.6 Activities of an ISM Structure
20.7 Conclusion
20.8 Self-assessment questionnaire

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UNIT 20 | The International Safety Management Code

21 OPERATION of the SMS on BOARD ..........................................................................120

21.1 Posting
21.2 Site of the SMS Documentation
21.3 Safety Management Manual
21.4 Emergency Situations Manual
2.15 Familiarization Manual
21.6 Operations Manual
21.7 Deck Maintenance Register
21.8 Engine Maintenance Register
21.9 Environment Manual
21.10 The other ship’s official documents
21.11 Self-assessment questionnaire

22. ISM TRAINING of PERSONNEL ...................................................................................123

22.1 Introduction to ISM Sections 6.2 and 6.6 of the Code
22.2 IMO circular in 2007
22.3 Level 0
22.4 Level 1
22.5 Level 2
22.6 Level 3
22.7 Conclusion
22.8 Self-assessment questionnaire

23. INTERNAL ASSESSMENT

and PRESENTATION for CERTIFICATION.............................................................126
23.1 Subject
23.2 Internal Audit of the Company Headquarters
23.3 Internal Audit of a Ship
23.4 Conclusion
23.5 Self-assessment questionnaire

24. CONTINUOUS COMPLIANCE ASSESSMENT .....................................................132

24.1 Monitoring and Weekly Review
24.2 Shipboard Review
24.3 Conclusion
24.4 Self-assessment questionnaire

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25. HOW to PRESENT YOUR SYSTEM to the POSSIBLE

CUSTOMER (STARTING COMPANY) ........................................................................134
25.1 Foreword
25.2 ISM Certification
25.3 Why a Consultant?
25.4 Characteristics of ISM Certification
25.5 Practice of the Certification
25.6 Philosophy of our Consultancy
25.7 Details of Consultancy
25.8 Commercial Conditions
25.9 Self-assessment questionnaire

26. INTERNAL ASSESSMENT AUDITS of a

SAFETY MANAGEMENT SYSTEM ..............................................................................140
26.1 Foreword
26.2 Operation of Your System
26.3 Could your SMS Run Better?
26.4 Why Call an External Consultant?
26.5 Process
26.6 Fees
26.7 Self-assessment questionnaire

27 HOW to MEASURE the OPERATION of a SAFETY

MANAGEMENT SYSTEM and the IMPROVEMENT of the
SAFETY CULTURE of a COMPANY..............................................................................143
27.1 Introduction
27.2 Use of Performance indicators
27.3 Measurement of the safety culture level
27.4 In conclusion
27.5 Self-assessment questionnaire

28. HOW to RESTART a DORMANT EXISTING SMS ............................................146

28.1 Introduction
28.2 Causes of mis-functioning
28.3 Restarting of a SMS
28.4 Conclusion
28.5 Self-assessment questionnaire

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29. THEORETICAL EFFICIENCY of the ISM Code ....................................................148

29.1 General
29.2 Definition of Safety Objectives
29.3 Organization and Activities of the Company in the Field of Safety
29.4 ISM Structure
29.5 Self-checking
29.6 Confidentiality
29.7 Responsibilities
29.8 Conclusion
29.9 Self-assessment questionnaire

30. NECESSARY EVOLUTION .................................................................................................151

30.1 Amendments to the ISM Code
30.2 Why Checklists
30.3 Other Modifications which we Consider Necessary
30.4 Conclusion
30.5 Self-assessment questionnaire

31. PROBABLE IMPROVEMENT of the ISM Code .....................................................154

31.1 Probable Future Modifications to the ISM Code
31.2 Necessary Improvement of the Quality of Certification Audits
31.3 To be More Specific Concerning Experience Feedback in the Code Itself
31.4 Reinforcement of the Presence of ISM Specialists in IMO rather
than those of the Classification Societies
31.5 Issuing Mandatory Training on the Human Element for Merchant
Marine Officers
31.6 Self-assessment questionnaire

PART C
APPENDICES
Appendix 1 Author’s Article: critical have you said critical ?.......................................................156
Appendix 2 Example – Company Safety Management Manual (CSM) summary....................162
Appendix 3 Example of an ISM Internal audit report...................................................................164

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 The International Safety Management Code | UNIT 20

PART A
STUDY, IMPLEMENTATION and ENFORCEMENT of the
ISM CODE (2010) and IMO Resolution A 1022

GENERAL INTRODUCTION

This module is intended to prepare the marine surveyor to comprehend the implementation and assessment of the International
Safety Management Code.

It is designed to help surveyors having sufficient understanding of the ISM Code so they may act as internal auditors and/or as ISM
compliance officers, or train consultants acting as ISM specialists and/or internal auditors and/or ISM compliance officers.

The course is aimed also at external auditors from a flag administration or a certification body.
You will find that each lesson starts with the official text of the code (2010 text).
An excellent introduction to the ISM Code is given by the former Secretary General of the International Maritime Organization
(IMO), Mr William O’Neil:

“The ISM Code is one of two features that have been designed specifically to address the human element in safety at sea – which
continues to be cited as a causal factor in the majority of all transport accidents. The other ‘human element’ measure is the
STCW Convention, which tackles the training, education and certification of members of the crew.

The mandatory ISM Code provides an international standard for the safe management and operation of ships and for pollution
prevention. It places direct responsibility on shore side management to ensure that its ships operate to the prescribed level of
safety.

Evidence so far suggests that the impact of ISM implementation has had a positive effect and is beginning to achieve its aim of
creating a culture of safety within shipping companies throughout the world. Indeed, the reduction of accidents and incidents
following ISM Code implementation reported by some companies and the encouraging results reported by port state control
authorities with respect to ISM Code implementation on the phase one ships, both point to the positive effect of the code on
operational standards.

It is of the utmost importance that the ISM Code is implemented effectively and with the proper degree of commitment from all
concerned, and that is one of the major challenges facing the shipping industry during the next few years. It has the potential to
make a huge contribution to maritime safety.

However, it will only do so if it is fully understood and embraced throughout the industry, on board ships as well as in boardrooms.
It is in that spirit that this new guide has been prepared for and targeted specifically at members of the crew. It provides a
straightforward explanation of the basic concepts that underpin the ISM Code and will leave members of the crew in a better
position to play their part in its successful implementation.”

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1. PREAMBLE
Learning Outcomes

After completing this chapter, you will:

• have an understanding of some particular aspects of the ISM Code; and
• be aware of the history of IMO Resolution A.443.

1.1 PREAMBLE OF THE CODE

1- The purpose of the code is to provide an international standard for the safe management and operation of
ships and for pollution prevention.

2- The IMO Assembly adopted resolution A.443 (XI), by which it invited all governments to take the necessary
steps to safeguard the shipmaster in the proper discharge of his responsibilities with regard to maritime safety
and the protection of the marine environment.

3- The assembly also adopted resolution A.680 (l/7), by which it further recognized the need for appropriate
organization of management to enable it to respond to the need of those on board ships to achieve and
maintain high standards of safety and environmental protection.

4- Recognizing that no two shipping companies or ship-owners are the same, and that ships operate under a wide
range of different conditions, the code is based on general principles and objectives.

5- The code is expressed in broad terms so that it can have a widespread application. Clearly, different levels of
management, whether shore-based or at sea, will require varying levels of knowledge and awareness of the
items outlined.

6- The cornerstone of good safety management is commitment from the top. In matters of safety and pollution
prevention it is the commitment, competence, attitudes and motivation of individuals at all levels that
determines the end result.

1.2 COMMENTS

International Standard
It is essential that all involved in the operation and management of ships approach the following key groups in the
same manner:

• The safety of the ships

• The safety of the personnel and passengers on board
• The protection of the marine environment

Resolution A.443 (Adopted on 15 November 1979)

Resolution A.443, adopted on 15 November 1979 is as follows:
“Decisions of the shipmaster with regard to maritime safety and marine environment protection

The Assembly,
Recalling Article 16(h) of the Inter-governmental Maritime Consultative Organization concerning the functions of
the assembly,

Desiring to ensure that ships comply at all times with maritime safety and marine environmental protection
standards and procedures prescribed by conventions in force,

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Noting the numerous reports of contravention of the provisions of conventions,

Considering that the maritime safety and the protection of the marine environment must be the shipmaster’s
prime concern in all situations which arise and that economic and other pressures on the shipmaster should not at
any time interfere with the decisions he must take in that regard,

Considering further that the decisions on maritime safety and marine environment protection by the shipmaster
should not be unduly influenced by instructions given by shipowners, charterers or others concerned,

Invites governments to take necessary steps to safeguard the shipmaster in the proper discharge of his
responsibilities in regard to maritime safety and the protection of the marine environment by ensuring that:

a) The shipmaster is not constrained by the ship-owner, the charterer or any other person from taking in
this respect any decision which, in the professional judgment of the shipmaster, is necessary.

(b) The shipmaster is protected by appropriate provisions, including the right of appeal contained in, inter
alia, national legislation, collective agreements or contracts of employment, from unjustifiable dismissal or other
unjustifiable action by the ship-owner, charterer or any other person as a consequence of the proper exercise
of his professional judgment.”

Comments

The Master’s discretion has been at last introduced in SOLAS (V reg 34.3) and thanks to the ISPS code, has
been reviewed again in Chapter XI-2 reg 8 to include security.

In fact the second part of the resolution, which requires the administrations to protect the shipmaster against
possible sanctions from the shipowner after an expensive decision concerning the safety of the ship, the men
on board and environmental protection, appears to have been disregarded by all in spite of a recall in the
preamble of the ISM
Code itself.

It is nevertheless a little hard to understand: This resolution (A.443) adopted by the IMO assembly on the 15
November 1979, followed the investigation into the Amoco Cadiz accident which more than 20 years later, has
never been applied completely and which everyone would like to forget.

Questions have been asked but the administrations do not answer; nor do the shipowners. It may be that no
shipmaster has put it to the test but one wonders whether the maritime industry really wants to this question to
be raised.

The Principles and Objectives are General in Nature

Each shipping company and every ship is different. They work in different areas or regions of the world and,
therefore, have different needs. It is the role of the ISM Code to cover the thousands of shipping companies and
the 70,000 International Convention for Safety of Life at Sea (SOLAS) ships that are trading in the world today.
Therefore, it stands to reason that the code must be general.

General Terms
As with the general objective and principles the terms have to be of a general nature also. But by being general
they are open to various interpretations with the risk that imposes. Already many clarifications have been
published by IMO or certain administrations. The last amendments came in 2008 to enter in force in July 2010.

Corporate Commitment
It is obvious that there will be different levels of knowledge on the SMS carried out in the company from the

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UNIT 20 | The International Safety Management Code

chairman, the ISM structure, the captain and the AB on board. The cornerstone is commitment at the highest
level of the shipping company: It will be seen that it is necessary to start at the top. The highest level is really at
chairman level where a Responsible Person will be designated.

However, it is important for all personnel to be committed to the ISM Code. This will also require levels of
competence, not only International Convention on Standards of Training, Certification and Watch-keeping (STCW)
certificates but also competencies in the ISM Code itself. Training courses in Maritime Academies include a
minimum level of ISM; These specific training (DPA, auditors, Masters) should be improved as soon as possible.

Attitude is also important, particularly on board ship where it concerns individual safety. So in accordance
with the safe manning document, still decided by the Administration of the flag, the companies shall ensure and
verify documentation and certificates, suitable training and familiarization to their duties on board any ship for
coordination and effective internal oral communication for all seafarers.
Ref:

Rule I/14: Responsibilities of the Companies (STCW 2010)

“Each administration shall, in accordance with the provisions of section A-I/14, hold companies responsible for the
assignment of seafarers for service in their ships in accordance with the provisions of the present Convention, and
shall require every such company to ensure that:

1. Each seafarer assigned to any of its ships holds an appropriate certificate in accordance with the provisions of
the Convention and as established by the Administration.
2. Its ships are manned in compliance with the applicable safe manning requirements of the Administration.
3. Seafarers assigned to any of its ships have received refresher and updating training as required by the
Convention
4. Documentation and data relevant to all seafarers employed on its ships are maintained and readily accessible,
and include, without being limited to, documentation and data on their experience, training, medical fitness, and
competency in assigned duties.
5. Seafarers, on being assigned to any of its ships, are familiarized with their specific duties and with all ship
arrangements, installations, equipment, procedures and ship characteristics that are relevant to their routine or
emergency duties.
6. The ship’s complement can effectively co-ordinate their activities in an emergency situation and in performing
functions vital to safety or to the prevention or mitigation of pollution.
7. At all times on board its ships there shall be effective oral communication in accordance with chapter V reg 14
§3 and 4 of the SOLAS Convention

SOLAS reg 14, § 3 &4

“3. On all ships, to ensure effective crew performance in safety matters, a working language shall be established
and recorded in the ship’s log-book. The company, as defined in reg IX/1 (NB ISM code definition), or the master, as
appropriate, shall determine the appropriate language. Each seafarer shall be required to understand and, where
appropriate, give orders and instructions and to report back in that language. If the working language is not an
official language of the State whose flag the ships is entitled to fly, all plans and lists required to be posted shall
include a translation into the working language.
4. On ships to which chapter 1 applies, English shall be used on the bridge as the working language for bridge-to-
bridge and bridge-to-shore safety communications as well as for communications on board between the pilot and
bridge watchkeeping personnel, unless those directly involved in the communication speak a common language
other than English.”

1-3 SELF ASSESSMENT QUESTIONS:

1- What is really the ISM Code?
2-What are the objectives of the IMO Assembly Resolution A 443?
3- What are the essentials points for a successful management of the safety?
4- Which part of Resolution A 443 is still not fully implemented 25 years after?
5- Is the Master’s discretion in term of safety and security a long process in the SOLAS convention? And what is
the last text concerning this discretion?
6- Could you summarize the responsibilities of the companies regarding the seafarers as well as the SOLAS oral
communication regulation for safe navigation operations.

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2. SECTION 1 OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will:

• be able to understand the objectives of the ISM Code
• be able to understand the objectives of a company SMS ; and
• be able to identify the minimal parts of a company safety management system.

PART A - IMPLEMENTATION

1 GENERAL

1.1 Definitions
The following definitions apply to parts A and B of this Code.

1.1.1 International Safety Management (ISM) Code means the International Management Code for
the Safe Operation of Ships and for Pollution Prevention as adopted by the Assembly, as may be amended by the
Organization.

1.1.2 Company means the owner of the ship or any other organization or person such as the manager, or the
bare boat charterer, who has assumed the responsibility for operation of the ship from the ship-owner and who,
on assuming such responsibility, has agreed to take over all duties and responsibility imposed by the Code.

1.1.3 Administration means the Government of the State whose flag the ship is entitled to fly.

1.1.4 Safety management system means a structured and documented system enabling Company personnel
to implement effectively the Company safety and environmental protection policy.

1.1.5 Document of Compliance means a document issued to a Company which complies with the
requirements of this Code.

1.1.6 Safety Management Certificate means a document issued to a ship which signifies that the Company
and its shipboard management operate in accordance with the approved safety management system.

1.1.7 Objective evidence means quantitative or qualitative information, records or statements of fact pertaining
to safety or to the existence and implementation of a safety management system element, which is based on
observation, measurement or test and which can be verified.

1.1.8 Observation means a statement of fact made during a safety management audit and substantiated by
objective evidence.

1.1.9 Non-conformity means an observed situation where objective evidence indicates the non-fulfilment of a
specified requirement.

1.1.10 Major non-conformity means an identifiable deviation that poses a serious threat to the safety of
personnel or the ship or a serious risk to the environment that requires immediate corrective action or the lack of
effective and systematic implementation of a requirement of this Code.

1.1.11 Anniversary date means the day and month of each year that corresponds to the date of expiry of the
relevant document or certificate.

1.1.12 Convention means the International Convention for the Safety of Life at Sea 1974, as amended.

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2.2 FURTHER COMMENTS

It should be understood that the ISM Code is dynamic and may be amended by IMO – indeed, it evolves and the
amendments has been carried out in 2002, 2006 and the last in 2008 for entering in force in July 2010.

It is very important in the definition of a company, to identify who in the company is answerable for the ISM Code.
The code does ask for who ensures responsibility for the operation of the ship: manager; ship manager, bareboat
charterer etc.

The administration may also be called the flag state of the ship.

NB Some definitions placed in Resolution A 788 (19) has been introduced in the code itself under the 2002
amendments for better impact and harmonization of some important elements as the definition of a Safety
Management System and of the results of an ISM audit (observation and non-conformity).
It is surprising that the definition of an audit has been cancelled. We will use the ISO definition.

2.3 OBJECTIVES OF THE CODE

1.2.1 The objectives of the code are to ensure safety at sea, prevention of human injury or loss of life, and
avoidance of damage to the environment, in particular to the marine environment and to property

1.2.2 Safety management objectives of the company should, inter alia:
.1 provide for safe practices in ship operation and a safe working environment;
.2 assess all identified risks to its ships, personnel and the environment and establish safeguards and
.3 continuously improve safety management skills of personnel ashore and aboard ships, including preparing for
emergencies related both to safety and environmental protection.

1.2.3 The safety management system should ensure:

.1 compliance with mandatory rules and regulations; and
.2 that applicable codes, guidelines and standards recommended by the organization, administrations,
classification societies and maritime industry organizations are taken into account.”

It is essential when setting an international standard to clearly lay down objectives.

The objectives of the ISM Code are very explicit. These objectives are:
• ensure safety at sea by preventing of bodily injuries or loss of human life;
• prevent attacks on the environment, in particular the marine environment; and
• prevent material damage.

2.4 WHAT is the DIFFERENCE between the OBJECTIVES of the ISM Code and the OBJECTIVES of
the SHIPPING COMPANY

It was common to see the company’s safety objectives written exactly as the objectives of the ISM Code. In fact
the assimilation makes nonsense!
If the code is elaborated to improve safety at sea and has the objective to ensure this safety, a company could only
participate to this final objective by having at a minimum the objectives defined in § 1.2.2.

NB Author’s opinion: The title of the paragraph should have been” Objectives of the ISM code and those of the
Company Safety Management system: It would have been more clear!

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2.5 OBJECTIVES OF THE COMPANY SAFETY MANAGEMENT SYSTEM

If the ISM code can have very paramount objectives as Safety at Sea, the ISM Code requires that each company sets
up a safety management system for its ships.
In order to participate to the improvement of Safety at Sea, the objectives for the SMS should be:

• To Provide for safe practices in ship operation…

This requires the establishment of ship’s operating procedures.

• “and a safe working environment ”:

Provide safe working places: a seaworthy ship, properly maintained, kept in a good state of cleanliness etc.
Provide safe working conditions – taking into consideration training, competence, practice, fatigue etc

• “assess all identified risks to its ships, the personnel and the environment”
and
• “Establish appropriate safeguards ”

Before establishing measures against the risks of the job, it is obvious that they should be identified. Here the ISM
Code tries to set up a culture of prevention and this is a significant part of that code.
So the Company should identify, evaluate and take all measures to try to reduce these risks.

Note that first SMSs were set up by the classification companies of International Association of Classification
Societies (IACS) and they also proposed a risk assessment study.

So it is important to identify the risks in the company with which you are concerned. These risks will be many and
subject to the type of ship, its traffic, its age, its level of maintenance, the type of crew etc…
We will re-examine that when discussing the risk management sub-system.

You will know, nevertheless, that companies and ships that are presented with such a risk assessment are becoming
more and more frequent.
NB the European Directive 89/391 CEE was requiring already an identification and assessment of risks in the
industry which includes of course the Marine Industry.

Example
A cross channel company had just been confronted with an accident which could have been avoided if the risk
had been studied after being identified, thus permitting it to take some preventive measures. In fact the loading
operations at the link-span were not stopped when a big ship was passing by, so foot passengers fell down after
an abrupt movement of the gangway following an abrupt movement of the ferry alongside. After this incident
a shipboard procedure requires to stop the loading when there is a movement of a big ship in the channel.
Communications are maintained between the harbor master/the pilot of the big ship and the Officer on watch on
the ferry.

Results: Some passengers in hospital with fortunately slight wounds, but certainly a final decision not to cross
the Channel with this company any more.

• “continuously improve safety management skills”...

The above quote caused some concern for shipowners who saw that here was an attempt to impose continuous
training in the terms “constantly improving competencies of the personnel ashore and onboard”.

Finally, the maritime community was satisfied by the directives of IMO on this point, which stated that it was only
an objective of the company to achieve the superior objectives of the ISM itself.

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2.6 SMS (SAFETY MANAGEMENT SYSTEM) REQUIREMENTS

• “The SMS should ensure compliance with mandatory rules and regulations”.
The management of this compliance must appear in the SMS. This is the most important requirement
of the code. This cover all the regulations which applied to the ship and her personnel ie: SOLAS, MARPOL,
COLREG, STCW, etc… (all IMO or ILO mandatory instruments)… as well as the regional or national legislation as
European Regulations or Directives. The national or ports regulations as well as the coastal regulations apply also
to the ship and must be taken into account in the SMS.
Company’s instruction to shipmasters to observe these rules, procedures to check this compliance (inspections
and internal audits – corrective action plan – periodic state of follow up of non-conformities, control of knowledge
etc) and keeping records will be specified in the SMS.

Indeed, this chapter is one of the most important requirement of the code. In fact the first goal of the code is to ensure that
the company, the ship and the crew are in conformity with existing rules coming from conventions or regional regulations.

To ensure that, the SMS shall organize:
- A periodical check of conformity on board (continuous implementation of SOLAS existing or new rules for
example) carried on during internal audits for example.
- An organization of a “International rules watch-over” inside the company (the designated person could be
responsible for providing new amendments or rules and to transmit to the department concerned on board as
well as ashore)

It is quite obvious that this always the hardest part of the ISM internal audit and the most frequent reason why the
ships are detained in ports
By experience, I strongly insist on that aspect of the ISM certification: a certified SMS must cover this conformity
with applicable rules. If not, the system is not working and the certificate should be removed if correctives actions
are not in reasonable progress.
During audits on existing ships we should find not any non-conformity on old rules, and we check if the new rules
have been taken into account (by company orders) or are in visible progress.
NB. With this kind of analysis, it is obvious that the ISM code Audit could replace soon the safety visits of the flag
or Port State Control. Shipowners and captains are waiting for that believe me!

• “That applicable codes, guidelines and standards recommended by IMO, administrations (flag and port state),
classification societies and maritime industry organizations are taken into account.”

This chapter also caused concern because the recommendations are not mandatory, but this chapter encourages
companies to observe them as far as possible.
That means, some resolutions or strong recommendations of competent organizations as Port facilities or Ship-
owners or pilots associations, classification societies, major industrial companies etc… are known and partly or
fully taken into account in the company’s or ship’s procedures.
In one word, a recommendation or code concerning the operation of a ship should be taken into account when it
is “reasonably” possible.

Section 1-3 Application

• “The requirements of this Code may be applied to all ships”.

You may refer back to the significant remarks at the beginning of this module and see that the code could be
applied to every construction afloat. In Europe the ISM code apply to the national shipping trade and the MCA
recommend a mini-ISM for pleasure boats above 24 meters, which could be an adaptation of the present code.
This adaptation is both possible on paper and realistic in practice.
For the fishing boats, we will have to wait a little bit more as usual!

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2.7 CONTENTS OF A SAFETY MANAGEMENT SYSTEM

Contents of a safety management system are as follows:

Section 1-4
Every company should develop, implement and maintain a safety management system (SMS), which includes the
following functional requirements:

.1 a safety and environmental-protection policy; § 2
.2 instructions and procedures to ensure safe operation of ships and protection of the environment in
compliance with relevant international and flag state legislation; § 7
.3 defined levels of authority and lines of communication between, and amongst, shore and shipboard personnel;
§ 3, 4, 5, 6
.4 procedures for reporting accidents and non-conformities with the provisions of this Code; § 9
.5 procedures to prepare for and respond to emergency situations § 8; and
6 procedures for internal audits and management reviews § 12

Note the importance granted to the term “procedure”.

In French or in English it is the same word (of French origin), meaning: manner to proceed. The current
tendency is to put all activity in a form of procedure; with regard to the system that I propose, things will be quite
clear now.
This procedure is in general accompanied by an operational checklist whose objective is the control-not forgive- of
all elements of the activity described in the procedure.
In numerous cases, a procedure may be reinforced by a flow chart.

This chapter summarizes in a few words the minimum content of a SMS. It is to establish, implement and to
maintain a SMS; these three obligations will have to be found in each sector mentioned which results in:

• establishment of the requirements in a company manual;

• implementation in a shipboard manual for each ship; and
• operational running of the system by an activity, training, checks, tests and audit program.

Apparently, one could be satisfied with the six requirements listed above. However, it seems to me that some
elements have been forgotten like: Designated person, Maintenance of the ship, Human resources and document
control.
My experience leads me to propose a safety management system (SMS) made up of 10 sub-systems to answer all
the requirements of the ISM Code.

The structure of the SMS, which I advise to be set up, is represented schematically hereafter:

• The SMS is divided into 10 sub-systems that cover all the requirements of the ISM Code.
• These sub-systems are managed by a company ISM structure.
• This ISM structure revolves around a designated person (DPA/Designated Persons Ashore – see Chapter 3).
• It ensures complete management and control of the SMS in collaboration with the ships’ captains.

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2.8 NEW GUIDELINES

have been agreed by IMO in 2007 in the scope of developing a SMS in the company. Hereafter this is an extract of
these recent guidelines:

DEVELOPMENT OF THE SAFETY MANAGEMENT SYSTEM

The ISM Code requires that Companies establish safety objectives as described in
section 1.2 of the ISM Code, and in addition that Companies develop, implement and maintain a safety management
system (SMS) which includes functional requirements as listed in section 1.4 of the ISM Code.
Given the self-regulatory principles of the ISM Code, the internal verification and review processes are key elements in
the implementation of each SMS.The Company should consider the outcome of internal audits, internal SMS reviews
and analysis of non-conformities, accidents and hazardous occurrences to enhance the effectiveness of operations and
procedures within their SMS.To comply with the Code, the Company should:
.1 designate a person or persons with direct access to the highest level of management who should monitor the safe
operation of each ship (section 4);
.2 ensure that adequate resources and shore-based support are provided to enable the designated person or persons to
carry out their functions (section 3.3);
.3 define and document the master’s responsibility with regard to reviewing the safety management system and
reporting its deficiencies to the shore-based management (section 5.1);
.4 establish procedures for reporting and analysis of non-conformities, accidents and hazardous occurrences
(section 9.1);
.5 periodically evaluate the effectiveness of, and when needed, review the safety management system (section 12.2); and
.6 perform internal audits to verify whether safety management activities comply with the requirements of the safety
management system (section 12.1).

2.9 ELEMENTS TO BE INVESTIGATED DURING INTERNAL AUDITS:

- That the objectives of the company were clearly laid down, for example in an official
statement of the top management
- That identification, assessment and mitigation of the risks related to its activity are in the
company culture and exist in a form of a document: each procedure takes account of it.
- That the company clearly expressed in a document its intentions to constantly improve
competences of the personnel in safety and that objective evidence of continuous training exists
(onboard or ashore training)
- That the company stressed conformity with:

SOLAS and its last amendments (presence of the documents or corresponding instructions of the company and
effective fulfilment of the applicable amendments) as well as the codes which are attached to it (LSA, FSS etc..)

MARPOL and its last amendments (presence of the documents or corresponding instructions of the company and
effective fulfilment of the applicable amendments)

STCW: management of crew certificates (the company sends only certified sailors on board !)

COLREG: up dated document on the bridge and known by OOWs

ILLC (Load Lines): up dated document in the Captain’s or chief officer’s library

Corresponding Codes to the ship’s activities (MODU, IBC, HSC etc…)

ILO Applicable conventions (crew working conditions, 2006 consolidated convention) etc…
Regional, coastal, national (flag) and port regulations

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- That the company took necessary measures to ensure that new rules or amendments with
the existing regulations are automatically received within the framework of a coherent
organization of lawful watch-over: a person is responsible, subscription with IMO or other
maritime publications or websites (ICS, BIMCO, OCIMF, EU, Lloyds etc..)

- That IMO resolutions concerning safety (recommendations or guidelines) or the company

activities (passengers / HSC/bulk carriers / roro etc…) are known and taken into account when
possible. The list of IMO resolutions is quite long but somewhere in the Safety Management
Manual we must find a bibliography which lists the recommendations or codes taken into
account in the SMS.

- That the SMS contains at least the 6 elements quoted in the § 1.4

2-10 SELF-ASSESSMENT QUESTIONS

1- What are the differences between the code objectives and the company objectives in the scope
of the ISM Code?
2- What are the essential points that a SMS must ensure ?
3- What are the 6 elementary functional requirements of a SMS ?
4- What are the clarifications made by the ISM code 2008 amendments
5- Do you think the § 1.2 should have been divided in two parts? Which ones?

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2.11 A TYPICAL STRUCTURE OF A SMS

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3. STUDY OF SECTION 2 OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will:

• be able to identify the most suitable shipping company safety and environment protection
objectives; and
• be able to help the company to word its corresponding policy.

3.1 SAFETY AND ENVIRONMENTAL PROTECTION POLICY

The safety and environmental protection policy is as follows:

2.1 The Company should establish a safety and environmental protection policy that describes how the
objectives given in paragraph 1.2 will be achieved.

.2 The Company should ensure that the policy is implemented and maintained at all levels of the organization
both ship-based and shore-based.”

The Company must develop a “company policy” defined by the chief executive officer or the Board and specified in
the company safety management manual (CSMM) made up of:

• a solemn declaration by the president;

• a definition of the company objectives; and
• the precise details on the implemented policy.

The solemn declaration of the chief executive or president will announce initially the will of the company to
practice this policy. This declaration will be signed by the president and the senior managers and will be posted in
the main office and on board all the company’s ships.

3.2 EXAMPLE OF A “DECLARATION OF THE COMPANY MANAGEMENT”

An example of a “declaration of the direction” is as follows:

“Our safety and environmental protection policy is based on the international standard of management for the
safety of ships and prevention of pollution called ISM Code (International Safety Management) adopted by the
Assembly of IMO on 4 November 1993 (International Maritime Organization of which our flag is a part).

Our major objectives are to ensure the carriage of the goods which are entrusted to us, the safety of our crews
and the prevention of pollution by the safe management of ships.

Our total strategy aims at mobilizing the competencies and energies of the entire personnel ashore and on
board in order to train a powerful team working for safety, environmental protection and the satisfaction of our
customers in compliance with the rules.

Our policy is based on the motivation, competencies and responsibility of all.

Our associates, through the intermediary of the president, undertake to support with all their authority the actions
undertaken with the aim of carrying out our objectives and everyone in the company undertakes to respect the
provisions described in the manuals, procedures, instructions and other memorandums.

• We set up in our company an ISM structure responsible for managing the system of safety.
• Mr So-and-So” is the person in charge within the board as the Responsible Person (RP)
• We designate ‘Mr So-and-So’ as designated person ashore (DPA) in accordance with Section 4 of the ISM Code.
• We designate also Messrs So-and-So and So-and-So as deputy DPAs in accordance with Section 4 of the ISM
Code.

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UNIT 20 | The International Safety Management Code

The operation of the ISM structure and the co-ordination of actions aiming to implement the above-defined
policy, to make the safety management system work and ensure its progression, are under the responsibility of the
Responsible Person who as a direct link with DPA.
The DPA structure has a direct link with the crews on board our ships and the company stipulate that the SOLAS
XI-2 Reg 8 applies to the shipmasters in matter of safety or security of their ship and crew.

President’s Signature

3.3 SPECIFYING THE OBJECTIVES OF THE COMPANY

Nowadays a policy, whatever it is, must lay down its objectives in writing in the Safety Management manual..

Example of Objectives of Shipping Company or Management Company

“The objectives of the company are :

• ensure safety at sea for our ships;

• ensure the prevention of bodily accidents and loss of human life for our crews and our passengers;
• prevent damage to the environment, in particular the marine environment;
• transport in full safety the goods entrusted to the ships; and
• prevent material damage.”

To Attain That

“The company has set up a safety management system (SMS), whose objectives are to:

• offer practices of operation without danger to the ship and her environment;
• offer a work environment without danger to our crews or other persons working on board;
• establish safety measures countering all the risks of maritime transport;
• recruit only qualified personnel and crews;
• constantly improve safety management competencies of the personnel ashore as well as on board our ships; and
• prepare our personnel and crews for emergencies ashore as well as on board to preserve the safety of people
and the marine environment.”

“Our SMS, managed by an ISM structure:

• will guarantee that the obligatory rules and regulations relating to us are observed; and
• will also ensure that the applicable rules, codes, directives and standards recommended by IMO, our maritime
administration, the classification societies and the various organizations of the maritime sector will be taken into
account on publication.”

3.4 APPLICATION OF THE POLICY INSIDE THE COMPANY

This involves the means employed to carry out the policy that has been defined. There should be a clear
understanding of the objectives toward safety. The effectiveness of that application will depend on the management
of the personnel:

The employees must be competent, have motivation and have knowledge of the policy.

Indeed, without these three essential factors an accident prevention policy could not be adhered to. Therefore, we
should find in the SMS a recruitment organization taking qualified people, actions by self-motivated managers to
encourage the personnel and training activities on the ISM Code.

In the management of personnel, the other means employed will, therefore, be the installation of a safety
management system including a group of sub-systems covering at least all the requirements of the ISM Code.

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3.5 EXAMPLE OF AN APPLICATION OF A POLICY

Definition of Our Policy

“Our safety and environmental protection policy is based on a safety culture within the company either ashore or
on board ships.

This policy is based on:

• the competence of all the personnel;

• the safety culture of all the personnel; and
• the motivation of all the personnel.

The safety of the people and the goods transported, as well as environmental protection, must become one of our
major concerns.

Our company is a commercial company for the management of ships and to this end with respect to our
customers we could not do without a policy of safety and quality of service.

This safety policy, clearly defined in our manual, must be applied by the entire personnel:

• president/CEO;
• superintendent and other managers;
• crews; and
• employees.

All the personnel must follow the procedures or instructions defined in the company and shipboard manuals.

In order to carry out its objectives, the company is committed to using every possible means today or in the
future.”

How to Apply this Policy

“In order to apply this policy, the company has set up an organization that will ensure the management of safety.

This organization must include:

• A definition of the responsibilities within the company.

• The installation of an ISM structure in which people are designated ashore to supervise the operation of the
ships within the framework of our safety policy and to ensure the link with the ships. They are Responsible
Person, DPA and deputy DPAs.

• A definition of the responsibilities and the authority of the function of Master.

• The obligation for all to observe the obligatory rules and regulations whether they are international, national or
local coastal or harbor rules).

• The installation of an entire management system for operations which respects relevant rules to a minimum and
takes into account, as far as possible, the rules, codes, guidelines and standards applicable recommended by IMO,
the classification society and the other organizations of the maritime sector which concern us, as follows:

1-An organization of the company which includes the ISM structure in charge of communication between the
governing board and the personnel on board the ship and ensure the operation of the Safety Management
System

2-A system of risk management inherent to the sea transport of goods or passengers on our ships (identification,
assessment and reduction of risks system).

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3-A system of management of critical situations in an integrated system of emergency plans in conformity with
resolution A.852 of IMO (contingency plan).

4-A system of management of human resources including a continuous assessment of knowledge or qualifications
and the organization of continuous training. (recruitment and training system).

5-A system of instructions and plans for the principal operations of the ship, guaranteeing that the corresponding
tasks will be entrusted to qualified personnel (operations system).

6-A system of maintenance and planned inspections of the ships and equipment including the recording of the
activities and a historical part (maintenance system) which includes also the identification of equipment or critical
systems or in stand-by and the specific measures of maintenance which result (critical systems and operation in a
degraded mode).

7-A communication system for reporting and analyzing non-conformity (irregularities, incidents, accidents, near-
misses etc) and the implementation of the experience feedback gained.

8- A shipboard health, safety and environmental programme (SOHSP)which follows the MSC-MEPC.2 Circ 3
(June 2006) and in which we have added the measures concerning the protection of the environment (pollution
prevention measures and shipboard waste management plan)

9- A system of elaboration and management of the documents and documentation of the safety management
system (documentation system).

10-A verification system of checks and controls of the application of the company policy, including internal audits,
as well as the captain’s and management’s periodical reviews to satisfy Section 2-2 of the ISM Code.

NB
The environmental procedures can be included either in the Operation System N°5. I prefer to include this part
of the ship operations in the SOHSP because an assessment of performance of the ship in matter of safety and
health must, in my point of view, include the operation of the ship which can cause pollution (management of oily
waters, cleaning of tanks, management of garbage, bunkering procedures). For tankers the loading and unloading
procedures are of course in the Operations system.

3.6 ELEMENTS TO BE INVESTIGATED DURING INTERNAL AUDITS

During audits we will check the existance of the following elements within a general declaration:
- SOLAS XI-2 reg 8: Master’s discretion for Safety and Security
- § 2.1: Company’s safety policy and objectives
- § 3.3: Company’s support to the Designated Person,
- § 6.1.3: Company’s support to the Captain
- § 2.2: Obligation for all the personnel for shore or onboard personnel to apply this policy and obligation for the
subcontractors to adopt this policy when they are working for the Company
- § 6 Preamble: the declaration of intent of president/motivation etc…

3.7 SELF ASSESSMENT QUESTIONNAIRE

1-Who has to set up the Company Safety policy?

2-Who has to apply the Company policy?
3-How the Company can ensure that its policy is implemented?
4-What are the 10 sub-systems usually included in a SMS?
5-With these 10 sub-systems are you sure to comply with the ISM code?
6- Has the chapter been modified in the last amendments?

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4. STUDY OF SECTION 3 OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will understand the importance of
clearly defining:
• the company in charge of the implementation of the ISM Code;
• the responsibility of the entire personnel ashore as well as on board; and
• the resources attributed to the ISM structure.

4.1 COMPANY RESPONSIBILITY AND AUTHORITY

The company responsibility and authority is described as follows:

“3.1 If the entity that is responsible for the operation of the ship is other than the owner, the owner must
report the full name and details of such entity to the Administration.
3.2 The company should define and document the responsibility, authority and interrelation of all personnel who
manage, perform and verify work relating to and affecting safety and pollution prevention.
3.3 The company is responsible for ensuring that adequate resources and shore-based support are provided to
enable the designated person or persons to carry out their functions.”

Operation of the Ship

It is really the operating entity of the ship which is in charge of the management of safety, i.e. it is the entity which
will set up a SMS which will have to be certified.

The operator thus becomes the most significant entity in relation to the code and this is rather logical. However,
certification being related to the operator, any change of operator will provoke the loss of the certification
(transitional measures exist in this case as well as for a newly built or newly purchased ship in the company – see
Part B of the code § 14– an interim certificate can be granted subject to certain minimum conditions of safety
management).

An operator is thus owner of his SMS and may implement it on the different or successive ships that he operates.
In the same way, a newly started company will ask for an interim ISM certification in order to be able to start its
business subject to a minimum safety management system ashore as well as on board the ship.

The SMS must include written definition of the responsibilities in the management, execution and verification of
activities related to safety and prevention of pollution.

To simplify: the routine operation belongs to the normal services of the company – ashore
and on board – while safety management and verification will be for a particular structure
called the ISM structure.

To satisfy these regulations of the code, we should define in writing the responsibilities (Jobs description in
which the responsibilities for the SMS are included) for:

• all heads of service and shore personnel as regards management, operation and the verification of the
activities related to safety and environment; and
• all officers and crews of the ships.
It may be advantageous if these definitions could be accompanied by a corresponding flow chart.

In October 2007, a MSC/MEPC circular (MSC-MEPC.7/Circ. 5) has recommended that a Responsible Person
(RP) should be designated within the board in order to ensure that there is a name behind the term ‘highest level
of the management”.

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The responsibilities for the Responsible Person and the Designated Person are highlighted in these definitions.

It is significant to highlight Section 3-3 of the code. The external auditors always seek proof that the designated
persons have the means to carry out their tasks: time, support from high executives etc…. when they belong to
the already existing operating structure.

When the designated persons are nominated exclusively for the ISM Code, which is often the case in large
companies or those companies that have the means to dedicate an ISM Code officer, the auditors will certainly
want to know the budget allocated to this ISM structure.

It is recommended to install a parallel structure (integrated or not) called the ISM Code structure, where one
will find management and verification of activities relating to safety or pollution prevention linking with the normal
operational structure of a shipping or management company.

4.2 THEORETICAL STRUCTURE OF A SHIPPING COMPANY

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4.3 ELEMENTS TO BE INVESTIGATED DURING INTERNAL AUDITS:

- Authority and responsibilities for all the persons having responsibilities in safety or environmental aspects of
company operations are clearly defined
- their reciprocal relations are clearly expressed: who reports to whom!
- The designation of a Responsible Person is not mandatory but the auditor will recommend to set up this
responsibility
- The designated Person has, in writing, supports of his management for the achievement of his tasks, and also a
sufficient budget.
NB This statement can be included, like other obligations, in the general policy claimed by the President. Then it is
not necessary to repeat it.

4.4 SELF-ASSESSMENT QUESTIONS

1-Who is responsible for the implementation of the mandatory SMS?

2-What sort of support the Company has to bring to the Designated Person?
3-How to represent a company organization?
4-How a company can presents definitions and responsibilities of personnel involved in the SMS?
5-What is the “Responsible Person” inside the Governing Board of the company
6-Do you think this new “Responsible Person” has an important role in the process of the Safety Management
System?

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5. STUDY OF SECTION 4 OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will:

• be able to understand the importance of the designated person(s); and
• be able to help a company manager to choose this or these persons.

5.1 DESIGNATED PERSON(S)

Designated person or persons is described as follows:

“To ensure the safe operation of each ship and to provide a link between the company and those on board, every
company, as appropriate, should designate a person or persons ashore having direct access to the highest level of
management. The responsibility and authority of the designated person or persons should include monitoring the
safety and pollution-prevention aspects of the operation of each ship and ensuring that adequate resources and
shore-based support are applied, as required.”

5.2 COMMENTS

The objective is impressive: ensure safety. This means “trying all that is possible to ensure the safety and
environmental aspects of operation of every ship”.

The Importance of the Link

It is important to ensure there is a link between the company and the persons onboard. It must be an effective
connection not only between the marine superintendent and the ship master, as is often the case, but really a link
between the company, i.e. the decision makers and the operators, i.e. the entire crew.

This link has always been a difficult problem in ships. Still too often the crews are completely ignored while
the captain often gets the impression that he only exists when he is alongside in the home port or when he
is requested to visit the head office. The code’s insistence on this link is not insignificant, and a number of
investigations after accidents have proved that the captain was often quite alone on his ship and that his attempts
to liaise with the company were not always welcome. Consider the Erika incident. Will the ISM Code change this
situation? It is not certain at all.

In the author’s opinion most links between the company and the ships are the result of official visits and are not
always very pleasant (internal audits for example). An effort must be made today everywhere to install more
human connections between the representative of the company and the ship’s crew.

Moreover the term “audit” which unfortunately today is carried out as an inspection is one example. The auditors
must consider the internal audit of course as control but also as an action of privileged communication on one or
more subjects that are the day-to-day work of our members of the crew.

The designated person ashore (DPA) needs consideration. If the company has the means, this person will
be detached with an office and a secretary, but if not this person will be, frequently, a marine or technical
superintendent also carrying out his existing responsibilities.

The designated persons could be several depending of the size of the company.

Having direct access to a high level of management the DPA must be a high level executive in order to have some
weight near the general manager, a necessary condition for certification perhaps but especially for the satisfactory
operation of the SMS.

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Let us consider the power and responsibility for monitoring the safety and pollution prevention aspects of ship
operation. This supervisory power is not welcomed. Many managers see a structure of control as a way of
supervising the way in which they manage the ships. It is certain that the position of the designated person in
certain companies is not a piece of cake: either he is in permanent conflict with the operations management
(marine and technical superintendent, commercial) or, without any capacity or credibility, he plays a secondary role
in a poor scenario of phony audits and reviews.

Appointing a marine superintendent as the DPA causes suspicion. It means acting as judge and jury at the same
time. But the job of designated person requires a deep knowledge of the crew members’ work and in 90% of
cases the DPAs are former ship’s captains or at least they have a full knowledge of control, operation, maintenance,
safety, training of crew members.

Being both decision maker and safety officer does cause concern because, when the responsibilities are analyzed,
those of a marine superintendent who is also a designated person are doubled in the event of an accident. It
may be tested in the event of an accident where the consequences of this joint role will be an important part of
the investigation. The author fears that flag state acceptance of the marine superintendent/DPA dual function is
perhaps too close to what was happening before the ISM Code ( M/V Herald of free enterprise).

However, the code does not prohibit this double function. The two conditions of skill and responsibility exist and
experience proves that this system often works better than other more formal systems.

To take care of resources and support to the captain from the company, it is necessary for the designated person
to organize himself to make sure that the ship’s captain receives what he ordered (if his orders are adequate and
justified) and that he can rely on the top management in the event of problems. Once again the position of the
marine superintendent or operations manager allows awareness of the requests from the ships and also a better
judgment of the “adequacy” of these requests.

The SMS will also specify how the designated person should supervise safety aspects by internal audits, visits on
board as well as by the analysis of experience feedback and the captain’s reviews; and finally by the organization
of information and instructions to the captains and technical department, he should know about the orders or
applications from the ship, as well as the answers given by the decision makers.

In particular, requests for carrying out work during the periodical technical refit, acceptance and reality of the
carrying out of the work will have to pass through the designated person.

5.3 ADDITIONAL COMMENT

The designation of the DPA has already had much written about it, and experience proves that the personality of
the designated person plays a key role in the operation of a SMS and the success of the ISM code.

The motivation of this head of the ISM structure is essential; therefore, it should not be a systematic or random
designation, but really a selection which motivates support for the ISM Code. However, in reality, it is very
different. Often for reasons of cost, the role is entrusted to the fleet manager or the marine superintendent who
is not perhaps the most justified, but who has certainly the best knowledge for such a job. Today, sadly, only a few
persons criticize this choice.

5.4 DPA’S RESPONSIBILITIES

Responsibilities of the designated person(s) in an ISM structure:

1. In order to ensure that the system works as it was intended, the DPA is in charge of the monitoring of all activities
related to safety in the company ashore as well as on board.

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The monitoring and checking procedure of the system consists of a constant control of the ship’s reports and a periodic
analysis by means of visits, internal audits or inspections carried out mainly by the DPA and its assistants.
For the constant monitoring of operations on board they can be done only by the captain: it is his responsibility anyway! For
me the Captain is the direct representative of the DPA on board. (See following chapter and Annex 4)

2. Link with the persons on board. In order to run the safety system, good communication must exist between the persons
ashore and the persons on board. To this end, a communication procedure is developed within the company. The DPA must
ensure that there is a liaison between the general management and the ships’ captains and crews.

3. To take care that adequate resources are available and that shore-based support is provided to the ships according to
their needs.
The needs expressed by the ship’s crew have to be analyzed by the ISM structure. As the person in charge, the DPA will
have to make sure that effective support and resources are provided to the relevant actions suggested for the efficiency and
the improvement of the SMS.

4. The designated persons are, in general, company managers or officers, and they must have privileged contacts with the
chief executive of the company, e.g. the president.

5. The management of the SMS is ensured by an ISM structure: in particular, analysis of the captain’s reviews, internal
audits, accidents, non-conformities reports, feedback cards and management reviews.

6. The DPA will either direct or be a member of the crisis management group. The crisis management group ashore
consists of, preferably, the marine superintendent and/or the DPA, as well as secretary for the communications or recording
of events. One of the members of the crisis cell is in charge of connections with crew families and the media.

7. The ISM structure manages SMS training in the company. Good ISM/SMS training is essential for correct operation and
improvement of the system. This training is compulsory for the captain and the crew.

8. The management of SMS documentation is held up to date by the ISM structure:The person in charge of the
management of the ISM structure is also in charge of the updating of all SMS documents.

5.5 DESIGNATED PERSON (extracts of MSC-MEPC.7/Circ.5)

The Marine Environment Protection Committee at its fifty-sixth session (9 to 13 July 2007) and the Maritime Safety Committee
at its eighty-third session (3 to 12 October 2007) further agreed that it was essential to review the existing guidelines and develop
new guidelines to assist companies in effective and efficient operational implementation of the ISM Code. The following guidelines
were proposed:

“5.5.1 A key role, as identified by the ISM Code, in the effective implementation of a safety management system is that of the Designated
Person.This is the person based ashore whose influence and responsibilities should significantly affect the development and implementation
of a safety culture within the Company.

5.5.2 The designated person should verify and monitor all safety and pollution prevention
activities in the operation of each ship.This monitoring should include, at least, the following internal processes:
.1 communication and implementation of the safety and environmental protection policy;
.2 evaluation and review of the effectiveness of the safety management system;
.3 reporting and analysis of non-conformities, accidents and hazardous occurrences;
.4 organizing and monitoring of internal audits;
.5 appropriate revisions to the SMS; and
.6 ensuring that adequate resources and shore-based support are provided.

5.5.3 To enable the designated person to carry out this role effectively, the Company should provide adequate resources and shore-based
support.These include:
.1 personnel resources;
.2 material resources;
.3 any training required;
.4 clearly defined and documented responsibility and authority; and
.5 authority for reporting non-conformities and observations to the highest level of management.

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5.5.4 Designated Person(s) should have the qualifications, training and experience as set out in MSC-MEPC.7/Circ.6, to
effectively verify and monitor the implementation of the safety management system in compliance with the ISM Code”.

These guidelines, which are not mandatory as we know, are closed to my comments above.
In addition, the circular above has defined, again as non mandatory guidance, guidance on the qualifications, training
and experience necessary for undertaking the role of the designated person under the provisions of the code.
As you could see there is nothing new for us but we are happy to see IMO detailing the important key role of the
DPA as we have already stigmatized.
The guidance is copied here after for your interest.

“QUALIFICATIONS of the DESIGNATED PERSON

Designated Person should have a minimum of formal education as follows:

.1 qualifications from a tertiary institution recognized by the Administration or by

the recognized organization, within a relevant field of management, engineering
or physical science, or

.2 qualifications and seagoing experience as a certified ship officer pursuant to the

International Convention on Standards of Training, Certification and
Watchkeeping for Seafarers (STCW), 1978, as amended, or

.3 other formal education combined with not less than three years practical senior
level experience in ship management operations.

TRAINING

Designated Person should have undergone training relating to safety management

elements in compliance with the requirements of the ISM Code, particularly with regard to:

.1 knowledge and understanding of the ISM Code;

.2 mandatory rules and regulations;

.3 applicable codes, guidelines and standards as appropriate;

.4 assessment techniques of examining, questioning, evaluating and reporting;

.5 technical or operational aspects of safety management;

.6 appropriate knowledge of shipping and shipboard operations;

.7 participation in at least one marine-related management system audit; and

.8 effective communications with shipboard staff and senior management.

EXPERIENCE

Designated Person should have experience to:

.1 present ISM matters to the highest level of management and gain sustained
support for safety management system improvements;

.2 determine whether the safety management system elements meet the requirements
of the ISM Code;

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.3 determine the effecti veness of the safety management system within the Company and the ship by using
established principles of internal audit and management review to ensure compliance with rules and regulations;

.4 assess the effectiveness of the safety management system in ensuring compliance with other rules and regulations
which are not covered by statutory and classification surveys and enabling verification of compliance with these rules
and regulations;

.5 assess whether the safe practices recommended by the Organization, Administrations, classification societies, other
international bodies and maritime industry organizations to promote a safety culture had been taken into
account;
and

.6 gather and analyse data from hazardous occurrences, hazardous situations, near misses, incidents and accidents
and apply the lessons learnt to improve the safety management system within the Company and its ships.

COMPANY REQUIREMENTS AND RECORDS

The Company should provide training courses covering qualification, training and experience and the appropriate
procedures connected to compliance with the ISM Code including practical training and continuous updating. The
Company should also provide documentary evidence that the Designated Person has the relevant qualification,
training and experience to undertake the duties under the provisions of the ISM Code.

NB See for your information on www.AFCAN.org web site (dossiers /réglementation/ISM) a bi-lingual article on the job of
DPA up dated in 2009!

5.6 DURING INTERNAL AUDITS, THE FOLLOWING ELEMENTS WILL BE INVESTIGATED:

- The existence of a direct and privileged connection between, on one hand the ISM Designated Person Ashore
and the most decisional level of the company hierarchy (The responsible person) and on the other hand
between the Designated Person Ashore and the ships’ crews; checking, using the task description of the ISM
Designated Person, the operation flow chart of the Company and/or a special Safety flow chart management.
- Privileged link between the ship’s captain and the DPA (see Chapter 6)
- Crew information via meetings, individual booklet or posting on board.
- Objective evidence of the monitoring of the Designated Person via: the checking of the company and ship
procedures, carrying out and/or analysis of the internal audits, visits on board (recorded) and that he is in copy
of orders/ deliveries of safety material and the requests /execution of repairs on safety equipment especially
during dry-docking repairs.
- Background and training of the Designated Person
- That the Designated Person is a full member of the crisis cell.

5.7 SELF ASSESSMENT QUESTIONS

1. What are the three essential tasks of a Designated Person?

2. What means a direct access to the highest level of the Management?
3. How a DPA can monitor the operation of each ship?
4. What is practically this link between the “Company and those onboard”
5. What is the ideal minimum background of the DPA?
6. Is a specific training necessary for the DPA?

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6. STUDY OF SECTION 5 OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will:

• understand the importance of the captain’s role in the ISM Code; and
• be able to help the company to write down this captain’s authority and responsibility.

6.1 MASTER’S RESPONSIBILITY AND AUTHORITY

The master’s responsibility and authority is described as follows:

“The company should clearly define and document the master’s responsibility with regard to:

1 implementing the safety and environmental protection policy of the company;

2. motivating the crew in the observation of that policy;

3. issuing appropriate orders and instructions in a clear and simple manner;

4. verifying that specified requirements are observed; and

5. periodically reviewing the SMS and reporting its deficiencies to the shore-based management.

The company should ensure that the SMS operating on board contains a clear statement emphasizing the
master’s authority. The company should establish in the SMS that the master has the overriding authority and the
responsibility to make decisions with respect to safety and pollution prevention and to request the company’s
assistance as may be necessary.”

6.2 COMMENTS

The code is very clear and it states that it is the responsibility of the shipmaster to
implement the company policy. This will be specified in the company instructions to the shipmaster in the
company management manual (CMM).

The master must encourage the members of the crew to apply this policy and ensure his crew is aware of the
company’s safety and environmental protection policy.

This awareness will depend on:

• A good knowledge of the SMS through an essential initial training and a personal effort of continuous training
by the captain himself.

• Meetings of awareness for the crew directed by the captain: SMS Training meetings.

• The shipmaster must be motivated to carry out this task. The author has observed how
remarkable it is to find how the SMS works very well on board a ship with a motivated captain but that it no
longer functions with his uncommitted substitute.

It is well known that the ISM Code brings nothing new from the safety point of view on already well managed
ships in the majority of the large traditional good shipping companies. A safety culture will have existed
before the arrival of the code in many respected companies.

The executives of these companies were trained throughout their careers with this culture and this is culture
never lost. But the internationalization of crews, brought about for the traditional reasons of crew cost,
has shaken this traditional culture even in the largest companies.

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The ISM Code is there to help them in a context of this “new culture”, which, inevitably, is most of the time
definitely inferior to the vertically integrated system that inherited from the past. The author believes one of the
reasons for the creation of the ISM Code was not only a reaction to the great number of recent accidents, but
proactively to deal with the changes in the way ships are manned and managed.

It is quite alarming to find some ships and companies have little safety culture. Safety is sometimes used as a
euphemism by some shipmasters totally lacking motivation for the ISM Code. By presenting the safety culture
within a logical, precise and international framework, the code can only help all worldwide shipping companies to
manage their safety in order to decrease the number of accidents.

The shipmaster must give orders and suitable instructions in a clear and simple way. Here,
the code invents nothing new, the captain’s standing orders should really be in the culture of any company, worthy
of its name. Each captain would have his own “orders” or would pass on instructions general and particular to
the officer on watch at sea or in the port allowing for some small differences such as: “Inform me if the visibility is
close to two miles”, whereas another captain would specify one and a half miles.

Within the framework of the SMS we will see these captain’s orders in a different way:

• On the one hand, the captain must apply on his ship the company’s general instructions
and procedures (major safety procedures) contained in the company management manual (CMM).

• General orders concerning the application of the SMS on board for the organization and distribution
of the tasks of the SMS management have to adapt, including other particular orders, to the operational safety
procedures and the corresponding checklists relating to his ship and the business. This shipboard manual
will include the captain’s particular orders for the watch officers. These particular orders are
written either by the captain himself or the captain uses those proposed by the company.

• The captain will nevertheless be able to supplement these orders by special instructions according to
circumstances and which can be directly written in the logbook.

• Finally, the captain’s standing orders (and also chief engineer’s standing orders) could be based on those of
STCW Chapter VIII.

The captain must verify that the specific instructions of the company concerning the
company or shipboard safety procedures, the use of the checklists, drills and exercises or
safety meetings, ship’s maintenance planning and periodical tests are fully observed.
These tasks are carried out as a monitoring activity which belongs to the DPA. As the DPA cannot physically
“monitor the safety and pollution aspects of the operation of each ship” himself… the ship’s captain is the
natural representative of the DPA on board !

The captain can delegate some of these controls to his officers (chief officer or chief engineer for example) while
preserving the responsibility that these checks are carried out according to the methods defined by him or by the
company.

Reviewing the SMS is a significant part of the system. Indeed periodically, according to the company
instructions, the senior captain of the ship will proceed to a complete assessment of the operation of the
company’s SMS on board his ship.

Again, this is not a new responsibility for shipmasters. Many companies already required a voyage report or an
annual report on the complete activity of the ship. It is, therefore, a report that could be in the form of a letter to
the ship-owner. It is advisable to create a standard company form for the captain’s review to avoid any oversight.

Putting this review in a standard format will allow a more systematic analysis of these reviews coming from all the
ships. This analysis will contribute to the management review that will follow.

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6.3 CAPTAIN’S AUTHORITY MUST BE EMPHASISED

The SMS must stress the shipmaster’s authority and the company must specify that the higher authority belongs
to the captain and especially that he has the responsibility to take decisions concerning safety, security and the
prevention of pollution of his ship..

This authority of the captain does not create any problems in traditional merchant navy vessels but this is not
the case on certain specialized ships – mobile platforms, scientific research ships, pipe-
layers etc – where the responsibilities are often shared between the captain and the mission manager.

Certain organizations place the authority with the head of mission during the ship’s operations and with the
captain only in emergencies. In the author’s opinion these situations are not compatible with the spirit of the ISM
Code and thus could constitute a major non-conformity.

However, IMO has started to put this in order by proposing Resolution A.891 on “minimum training for all
personnel on board offshore units”. This resolution adopted in November 1999 proposes only one authority on
the unit: the OIM (the offshore installation manager), who would be at the same time the captain of the ship. At
the moment the oil industry is asking itself if it has to train a captain for drilling or vice-versa. The solution is
obviously to train a captain for drilling. The hierarchy will then be the same as on a traditional ship:

Indeed the tool pusher/site manager or head of mission is then regarded as a head of department as well as the
safety officer or the maintenance manager or chief engineer. The bi-cephalous command is the heritage of shore
organizations that the ISM Code does not accept.

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6.4 FORM OF THE CAPTAIN’S REVIEW (EXAMPLE)

CAPTAIN’S REVIEWS

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6.5 AN EXAMPLE OF WRITING STATEMENT

An example of writing a statement by the manager of an offshore company to be in conformity with:

• SOLAS Chapter V Rule 34.3;

• ISM Code Sections 5.2 and 6.3;
• STCW Code Section A-I/14; and
• IMO Resolution A 891 Sections 2.8, 5.2 and 5.3.

STATEMENT OF THE GENERAL MANAGER

I undersigned, A B, general manager of ABC Offshore states that on board our drillships, at any time, the Captain, as
the Offshore Installation Manager:

• has complete and ultimate command of the unit to whom all personnel on board are responsible (Ref IMO
Resolution A 891 Section 2.8);
• has the responsibility to ensure familiarization of the new personnel coming on board (Ref STCW Code
Section A-I/14 and ISM Code Section 6.3);
• has the responsibility to take any decision concerning safety of all personnel or company assets and prevention
of pollution. (Ref ISM Code Section 5.2).
In this respect I, and the base managers, will not constrain the Ship’s Captain from taking any decision which
in his professional judgment is, particularly in emergency situation, necessary for the safety and security of the
personnel, the ship itself and pollution prevention (Ref SOLAS XI-2 reg 8).

6.6 DURING THE INTERNAL AUDITS WE WILL SEEK OBJECTIVE EVIDENCE OF:
- That the company has specified the responsibilities of the captain in the official statement or in the captain’s
tasks definition.
- That the Captain implements the SMS (he can delegate certain tasks), organizes meetings of motivation carried
out by himself.
- That the Captain’s orders exist.
- That the watch or duty officers have ridden them and signed
- That they are observed (captain’s verification or monitoring)

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- That the Captain inspect and controls accommodations and working areas, checks application of shipboard
procedures and Checklists, engine, safety and bridge maintenance of equipments, assists and evaluates the
shipboard safety drills and exercises, analyzes on this occasion the state of preparation of the crew to answer
the emergencies, controls the update of documentation etc…
- That the Captain as the discretion capacity in terms of safety in accordance with SOLAS XI-2 reg 8
- We will ask moreover to consult the Captain’s reviews (generally, an annual review is a minimum) where we
will seek serious analyses and in particular the global analysis of the operation of the SMS on board which must
include an assessment of the progression of the system and proposals for improvements.

6.7 SELF ASSESSMENT QUESTIONS

1- What the essential responsibilities of a Captain with regard to the SMS?

2- For a Shipping company what is the best manner to state the Master’s authority?
3- What means “Master’s discretion”?
4-What is the master’s review?

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7. STUDY OF SECTION 6 OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will understand:

• the importance of the recruitment of qualified personnel;

• the importance of the familiarization on ship’s safety including the SMS when
embarking;
• the need to detect the training needed for every member of the crew; and
• the importance of a compulsory common working language among the crew.

7.1 RESOURCES AND PERSONNEL

The code says:

“6.1 The Company should ensure that the master is:

• properly qualified for command;

• fully conversant with the company’s SMS; and
• given the necessary support so that the master’s duties can be safely performed.

6.2 The company should ensure that each ship is manned with qualified, certificated and medically fit member of
the crews in accordance with national and international requirements.

6.3 The company should establish procedures to ensure that new personnel and personnel transferred to new
assignments related to safety and protection of the environment are given proper familiarization with their duties.
Instructions which are essential to be provided prior to sailing should be identified, documented and given.

6.4 The company should ensure that all personnel involved in the company’s SMS have an adequate understanding
of relevant rules, regulations, codes and guidelines.
6.5 The company should establish and maintain procedures for identifying any training which may be required in
support of the SMS and ensure that such training is provided for all personnel concerned.

6.6 The company should establish procedures by which the ship’s personnel receive relevant information on the
SMS in a working language or languages understood by them.

6.7 The company should ensure that the ship’s personnel are able to communicate effectively in the execution of
their duties related to the SMS.”

7.2 COMMENTS

The ISM Code is intended to influence the behavior of crew members so it may be expected that the chapter
dealing with the human element would be most significant.

The code points out a fundamental truth of our industry – it is necessary to have a qualified and competent
shipmaster and crew, able to communicate between each other.

Qualification of the Captain

The qualification of the captain to command the ship must be ascertained before the vessel’s departure.
Historically, the master used to be part of the company’s staff, promoted in ability and experience having attained
the required qualifications. Nowadays it is no longer the same and ship owners or ship managers are often
constrained, although they may prefer the old procedure, to directly recruit the captain via a manning agent.

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It is, therefore, necessary to have a procedure of recruitment for the shipmaster, which will have to include the
following requirements:

• The shipmaster has to be in possession of necessary STCW 95 certificate from a country on the white list
and up to date with revalidation, corresponding to the size of the ship or its navigation, endorsed by the flag or
recognized by it.

• Vigilance will need to be exercised in controlling qualifications of the recruited captain because fake STCW
certificates are starting to circulate.

• If possible, he should have experience of command on the same type of ship. Indeed, everyone has to begin
somewhere; therefore, sufficient experience as chief officer on the same type of ship will also be a proof of
qualification.

A CV must appear in the procedure, including references and information coming from other companies which
have used his or her services.

For a promotion within the company, an assessment of the confidential reports of competence and service relating
to him.

All this may appear elementary, but it must nevertheless appear in the procedure.

Knowledge of the SMS

The captain will have to be fully aware of the safety management system set up in the company. We touch here an
obligation of the code, which is hardly appreciated by the shipowners nor sometimes the captains themselves. It is
really about a thorough knowledge of the SMS, and this knowledge is obtained by personal study and training.

We should remember that the SMS was created and implemented by the company according to the requirements
of the ISM Code. It is thus logical to envisage the captain training on ISM Code first and on the SMS of the
company afterwards. This training could be carried out during seminars in the company head office.

Note that sadly the ISM Code seemed to overlook something – the mandatory training of the code itself.
Unfortunately shipowners nowadays tend to speak only about mandatory training, and that is all.

It may be noted that in the companies and on the ships, once again we have put the cart before the horse and
often men are trained more or less on the spot.

ISM Code training exists but is not approved (in France only obligatory training can be approved): in the UK,
Philippines, USA, Norway etc and in France recently “basic training” is given at the end of the STCW training
requirements, and this is insufficient in the author’s opinion.

During certification audits it will have to be proven that the SMS has encompassed training courses within the
company for the shipmasters, captain’s seminars, meetings on board or ashore, continuous training by information
on evolution and prospects of the code provided by the ISM structure (articles, IMO circulars or resolutions etc).

Finally, because it is the responsibility of the company, the obligation of ISM knowledge for the captain will be
specified in the “Instructions for the captain” as in the job analysis and responsibilities for the captain.

Necessary Support

The Company must specify in its SMS how it will support the captain in order that he can ensure his tasks in full
safety.

Assistance needs to be continuous and can take the form of ongoing training of the captain and especially a
response to non-conformities or captain’s suggestions carried out by the intermediary of the experience feedback
process.

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7.3 QUALIFICATION OF THE CREW

The code, which provides in addition that the company must comply with the obligatory rules and regulations,
refers to the flag rules as regards the qualification, the certificates and the physical fitness of the crew members.

The SMS, through the recruitment procedure, will specify the requirements of the company with regard to:

• composition of the crew;

• certificates (including revalidation);
• medical examinations; and
• recruitment criteria.

It is relatively easy today to be in conformity with the ISM Code while referring to the STCW convention, up to
date for the 95 amendments, and valid for the maritime personnel.

On ships where the embarked personnel are not entirely from the seafaring discipline (offshore units, research
ships, cable laying etc) the recruitment procedure will have to include the safety training of these special personnel.

Note that the IMO has just published a standard of training for all personnel on offshore units. The other special
ships will follow as soon as possible.

The fishing sector is also involved and currently the STCW-F convention is ready for signature. (sadly only a very
few governments have already signed up this convention)

Regarding manning levels, the recruitment procedure will have to provide that the flag rules apply as well as the
recommendations of the STCW code. The company can, as is often the case, include a medical examination
specific to the company before boarding. It is indeed in its interest to embark only medically fit personnel: it is in
fact to decrease the risks of death or disease on board with the consequences that may result, expensive medevac
(medical evacuation) for example. However, such a policy will never be able to detect a disease which occurs
during the time on board.

An anti-drug and alcohol policy (even smoking policy) is not obligatory but is becoming increasingly required
by some flags for their ships or ships in their seas (UK/US) or the customers of the shipowner. It is strongly
recommended to have one. “Dryships” are becoming more and more frequent.

When recruitment is carried out entirely or partly by a manning agent, the SMS will have to include:

• Very precise instructions to the manning agent on the company recruitment criteria.
• A checking procedure of the certificates of crew members thus recruited (control carried out on board and
transmitted to the company).
• An assessment of competence procedure and services rendered by the member of the crew, carried out on
board and transmitted to the company.

These procedures will normally bring to the company a selection of the best recruits.

7.4 FAMILIARIZATION

This is a significant chapter of the code, indeed the Scandinavian Star disaster showed the dangers of boarding an
unknown ship for, perhaps, a qualified crew which is unfamiliar with the ship.

The Company must now give precise instructions to its masters and work out a procedure called familiarization.
For us, this situation is relatively logical: handover periods still exist where it is possible. However, the crew change
on the other side of the world or “en route”, ship dead slow ahead, is nowadays more frequent and the procedure
will have to be adapted.

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Familiarization, which in fact can be included in a change management policy, today is more a question of putting
under supervision during a certain time a new crew member depending on his position and experience. The
tutorial method will have to be under captain’s responsibility in agreement with the heads of ship’s departments
(engine, catering or other operations)

For traceability (to keep an historical trace), a record of this familiarization will have to be elaborated.

Note that the familiarization period will normally have to be devoted to familiarization with the ship and with the
position the new personnel will hold.

Indeed the embarking member of the crew is normally qualified for the position, i.e. in which he has general and
particular knowledge and also on safety and environmental protection (Attention: familiarization could never
replace basic safety training.)

In order to try to solve this problem, the familiarization procedure should include a control of the safety training of
the member of the crew with the help of the safety activities recording card (or booklet) belonging to the member
of the crew, which he would then present when boarding (this information could also be recorded at the company
office via a suitable software).

This record signed by the ship’s captain will also be a great help for, on the one hand, the captain in his decision
on the familiarization period and on the other hand for the chief officer in charge of safety drills or continuous
training.

The instructions which are necessary to give before departure, i.e. familiarization before departure, are:

• Individual role of the member of the crew in the event of emergency.

• Means of evacuation (escape ways, life boats).

• Visit and explanations around the ship.

7.5 KNOWLEDGE OF EXISTING CODES AND RULES FOR THE PERSONNEL

INVOLVED IN THE SMS

There must be initial and continuous training for the members of the ISM structure including the crew members.

This information appears in:

• Company and ship’s databases constantly updated by the ISM structure (new rules, amendments to existing
rules, codes, resolution etc).

• The continuous training organized in the company for the captains, who will then transmit all the information
during safety meetings on board.

Note that in order to satisfy this requirement, the company will organize the database and the continuous training
and will give sufficient instructions to the captain for the transmission of the information.

7.6 NECESSARY TRAINING

In order to determine the training necessary for the personnel, the company must set up an assessment and
training procedure.

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Assessment

Tools: Safety questionnaire, questions during exercises and meetings, assessment of the safety drills and exercises,
analysis of internal audits – captain’s and management reviews. The detected training needs will have to be the
subject of further training.

Training

Tools: Training on board, training ashore in specialized schools, documents and/or video disks or cassettes etc. An
evaluation of the training courses will be carried out (assessment form) and the captain will also analyze the value
of the training given on board.

Today, the normal crew of a ship does not have enough time to spend on intense safety training during normal
trips; so it has started to become commonplace to embark periodically a flying team in charge of safety training
in general. This small team, also called ISM compliance team (one officer, one boatswain for example), will be on
board for a trip and will help the crew to follow the continuous training scheme set up by the company.

Note that usually they board the ship a few weeks before the ISM internal or external audit: clever initiative isn’t it?

7.7 INFORMATION ON THE SMS IN A LANGUAGE UNDERSTOOD BY THE CREW

It is perhaps the most significant problem today. Indeed all crews are now multilingual and the level of knowledge
of the common language (generally English) can vary greatly.

If the officers generally speak English due to their STCW certificates (in fact often the level of English is
inadequate) it is not necessarily the same for the rest of the crew.

The proposed solutions are not original:

• English training course on board (based on IMO publication, the SMCP)

• SMS documentation in English.
• Basic SMS documents in the language of the majority of the crew (for example familiarization or individual SMS
manual in Polish for a ship with 80% Polish).

Caution

Frequently on foreign ships, the administration requires documents in the flag state language and in English.

7.8 COMMUNICATION ON BOARD

Communication is of primary importance within the company and on the ships so I advise a communication
procedure that should include:

• Shore to shore communications: managers between themselves and personnel between themselves within the
framework of the SMS (management meetings – SMS meetings for the shore personnel).
• Shore-ship communications: frequent visits by managers on board and not only for audits or inspections.
• Communication of information obtained by other company ships: experience feedback, information on a new
port etc.
• Internal communication on board.
• Meetings of officers and crew: kind of “brain storming” on safety and pollution prevention.
• Handover between officers (setting up of a procedure).

Finally, this is an interpretation of the International Association of Classification Societies (IACS). To be understood,
the shipboard instructions must be written in an accessible language to all. The officers will check that these
instructions are well understood by checking their application; and furthermore, for example the members of the
crew having to deal with the passengers in the event of emergency must speak the majority of the passenger’s
language or at least know a minimum of key words that the company will have to set up. A teaching and control of
knowledge procedure should be issued.

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In conclusion, the requirements of ISM and STCW (1-1/14) codes are covered.

The company documentation will have to include:

• A recruitment procedure.
• A familiarization procedure (example hereafter).
• A record of this familiarization.
• A statement of individual information for each member of the crew: valid certificates with dates, medical
examinations, languages, experience at sea and in the job.
• An assessment and training procedure (including in English language).
• A statement of the SMS activities (example hereafter).
• A form of individual confidential performance report, to be filled up by the head of service and the captain:
- A record of manager visits on board.
- A handover procedure (example hereafter).
- A new port procedure.
- An experience feedback system.
- A drug and alcohol policy (example hereafter).

7.9 FAMILIARISATION PROCEDURE (EXAMPLE)

Subject

This procedure defines the methods of the familiarization of new personnel embarked on board or in a new
function.

Goal

On the one hand, to allow the crew member who has newly joined or is starting a new function to familiarize
himself with the ship and the function which he will occupy, and on the other hand to know the company SEP
system and its application on board as well as procedures or instructions related to it.

References

ISM Code Sections 6.3 – 6.4 and 6.6 and STCW Code A I/14-2.

Risks Management
Identification of the consequences of an error of a member of the crew (officer or crewmember) in his functions:

• Damage to the ship:

- collision;
- grounding;
- deterioration of equipment (bad handling).
• Fire/explosion.
• Damage to the cargo: inappropriate lashing or loading.

Inventory of the causes;

immediate causes related to the ship; ignorance of the ship, the procedures and instructions, or the SMS.

• Causes mainly related to the human factor, in particular:

- Incompetence of the new member of the crew to carry out the function which he has been assigned
(insufficient knowledge).
- Physical inaptitude of the new member of the crew to the sea (seasickness).
- Mental inaptitude of the new member of the crew to life at sea.
- Inaptitude of the new member of the crew to carry out his work as a consequence of alcohol or drug-abuse.
- Laziness or refusal to familiarize himself with the ship.

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• Control options:
- Interview on arrival on board.
- Familiarization with the ship by the intermediary of a tutorial system.
- Control of knowledge before being released “alone”.
Processes

The captain is informed by the company office of the arrival of the member of the crew. The captain has all
personal information about the member of the crew.

The member of the crew himself is informed of the company safety policy and the elementary safety instructions
by the intermediary of the SMS individual manual, which is given to him at his first embarkation (given by the
management or by the captain).

Appointment

For captains and chief engineers an interview is organized with the president if possible.

For French officers a discussion with the superintendent is organized if possible.

For other officers and crew members an interview with the ship’s captain on arrival on board is obligatory.

This interview is centered on the motivation of the member of the crew to achieve his tasks in the company’s and
ship’s interest.

During the interview, a summary is made on the application of the SMS on board as well as a talk on the ship’s
planning and the particular instructions related to the ship or the function of the member of the crew.

It is specified to the member of the crew that any additional information can always be obtained from the heads of
department and the captain.
The practical conditions of the familiarization are also specified: tutorial system, duration and control knowledge.

Familiarization
An experienced member of crew occupying a corresponding function is designated by the captain or the head of
department to familiarize the member of the crew with his function on board.

This familiarization involves:

• The “tour” of the ship.

• The location of the instructions in the event of an emergency.
• The location of the documents of instruction and special orders.
• The location of the SOLAS training manual.
• The location of SMS documents.
• The location of the plans and various notes.
• The operation of equipment or systems corresponding to his assignment.
• Usual crossings and ports visited by the ship.

The tutors are preferably:

• The captain himself or the chief officer for a deck officer.

• The chief engineer for an engineer.
• The boatswain for an able seaman.
• The second engineer for a motorman.

Note 1 The captain in agreement with the superintendent decides the duration of training. This will be
based on experience, qualifications and the position occupied.
Note 2 The conditions of training periods for the heads of department and the captain are individually
specified by the marine superintendent.

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Note 3 The newly arrived officer or crewmember can be new in the company, or have long service in the
company but be new to the ship, have long service on board but be new to the assignment: the
conditions of the familiarization are obviously adapted to each case.
Note 4 As far as possible there must be sufficient familiarization time before sailing.
Note 5 A signature on the form used for this purpose must confirm any knowledge of a document of the
system.

Control of knowledge

At the end of the familiarization period, a recognition of knowledge of ship and assignment is obligatory and is
recorded (Form 17). This authorization is made by the head of department or the captain. It can be made in oral
or written form; it concerns the ship’s safety, the member of the crew’s assignment, the company safety policy and
its application on board.

The record for an officer is made with the help of a questionnaire (one for deck officers and one for engineer
officers). These records, evidence of the good function procedure, will be recorded in the corresponding SMS
folder under the title “familiarization”. A copy of this record is transmitted to the superintendent.

Decision

Finally, the ship’s captain must decide whether the member of the crew is ready to carry out his assignment. It is
advised to ask the following question: “Are you ready to take over the assignments for which you are appointed?”

In the event of refusal from the captain or the member of the crew, management will undertake the process of
replacement as soon as possible.

Assessment Report

At the end of each appointment or for a captain’s relief (or chief engineer) an assessment report (confidential
performance) will be filled out by the captain and will be transmitted to the marine superintendent.

7.10 RECENT IMO GUIDELINES ON ISM TRAINING

The Marine Environment Protection Committee at its fifty-sixth session (9 to 13 July 2007) and the Maritime
Safety Committee at its eighty-third session (3 to 12 October 2007) further agreed that it was essential to
review the existing guidelines and develop new guidelines to assist companies in effective and efficient operational
implementation of the ISM Code.(MSC-MEPC .7 Circ.5)
Notably these guidelines stressed the necessity of ISM training of personnel involved in the SMS which means
almost all personnel.

“QUALIFICATIONS, TRAINING AND EXPERIENCE

The ISM Code requires the Company to ensure that all personnel involved in the Company’s SMS have an adequate
understanding of relevant rules, regulations, codes and guidelines.The Company should ensure that all personnel have the
qualifications, training and experience that may be required in support of the SMS”.

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7.10 EXAMPLE OF RECORD

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7.11 ANTI-DRUGS AND ALCOHOL PROCEDURE (EXAMPLE)

Goal

To prevent any accident due to the consumption of alcohol or drugs within the company

Reference Documents

• Ministerial note (from the High Committee for professional risks prevention).
• ISM Code Section 6
• STCW B VIII part 5.
• Company drug and alcohol policy (in conformity with OCIMF guidelines 95)

Risk Management

Identification:

• Ship and environment damage.

• Physical or material damage for the crew (or passengers).
• Moral damage for the company.

Inventory of the causes:

• Chronic alcoholism or state of dependence to narcotics of a member of personnel.

• Intoxication or effects resulting from a specific drug-taking (narcotics or drugs with comparable effects).

Risk control options:

• Not to recruit personnel who are alcoholic or drug abusers.

• To replace a person presenting symptoms of alcoholism or drug-taking.
• To inform the recruited person of the company policy by providing manuals, individual and SMS training.
• To follow the recommendations of the STCW code.
• To adopt the OCIMF guidelines.

Process

The implementation of the company policy could not be done without control. Indeed with regard to the
operation of the ship, the risks incurred by the company and its customers means they cannot tolerate cases of
alcoholism or of drug taking amongst the crew.

For office personnel, the marine superintendent must inform the general manager of any failure in compliance of
the company policy.

For the crew, the captain is naturally the person to inform the marine superintendent of the behavior of his crew
with the company drug and alcohol policy.

The Company reserves the right to require a blood test for alcohol or a drug control of any member of its
personnel.

Alcoholic breath tests should be done on board by the captain.

These tests will be made with discretion due to the respect of the private life (confidentiality) but a confidential
report to the marine superintendent will be issued. A doctor or an approved laboratory will do blood tests for
alcohol or drug abuse.

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Immediate Measures

In the event of evidence of alcohol abuse or inaptitude to work as a consequence of alcoholism or drug-taking, the
person concerned will be immediately replaced in his duties. If required, an alcohol level blood test will be done as
soon as possible.

Disciplinary measures are taken by the superintendent and can provoke the immediate exclusion from the
company.

Note that in case of illegal traffic or consumption of drugs, the company has signed a standard BIMCO contract
with the most visited countries. This contract envisages search and suppression for any traffic of narcotics. This
security aspect of such activity includes:

• Particular vigilance by the captain.

• Radical disciplinary actions.

7.12 Elements to be investigated during an internal audit

During an internal audit we will look for conformity with ISM Code § 6
- Evidence that the SMS has envisaged ISM and SMS training for captains: training courses within the company, training
seminars, meetings on board or ashore, continuous training by information on the evolutions and the prospects of the
code provided by the ISM structure (articles, IMO circulars etc…).
- Obligation of ISM knowledge for the captain is specified in the Company’s “Instructions to the Captain” or in the
Captain’s job description and responsibilities.
- Checking documents (mail, reviews, REX) and interview of the Captain on the effective assistance of the company.
- Licenses and various certificates of crew members (obligatorily originals) corresponding to the ship and its activities
and mode of management/control employed by the company.
- Certificates of medical fitness for the seafarers or other personnel
- Record of individual assessment of every seafarers
- The contract between the Company and the Manning Agent and if necessary, the instructions which were given to him
and the possible audits carried out by the company at the manning agency.
- The existence of a drug and alcohol policy and its effective application (ethylo-meters, obligatory or random medical
checks)
- The familiarisation procedure for shore or shipboard personnel
-The recordings of this familiarisation (possible interrogation of a sailor on the conditions of familiarisation carried out
for him)
- The knowledge of the SMS of the key personnel i.o personnel responsible for the safety of the others (officers and
petty officers)
- Methods of awareness of the SMS documents by the crew
- Possible training followed by the key personnel in charge of safety ashore or on board
- The management of transmission of the information carried out by the Company
-The transmission of information carried out then by the Captain to his crew
- The detection of the needs for safety training and answers brought back by the company.
- English language knowledge of crewmembers
- Quality and the simplicity of instructions: clarity/ situation
- Means of communication employed by the Management and/ or the Designated Person Ashore
- Minutes of the safety meetings ashore as on board
- Records of management visits on board (CEO/Superintendent/DPA)
- Hand over between captains and between all persons in charge of safety (officers/petty officers))
- Hand over between watch and duty officers)
- The inscription of the working language on the log books (wheelhouse, radio and engine)
- In Logbooks, check the use of the common language of work

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7-13 SELF ASSESSMENT QUESTIONS

1- What means qualified personnel?

2- How to ensure a new crew member is qualified for his tasks?
3- Why familiarization is essential for the ship’s and personnel safety?
4- What the most important problem today with mixed crews?
5- How to detect a necessary training need?
6- Do you know what is the “change management”?
7- Do you think the recommendations for experience, training and qualifications of persons involved in the
Company’s SMS is enough?

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8. STUDY OF SECTION 7 OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will:

• understand what “key shipboard operations” means for the code; and
• be able to check the shipboard operations of a shipping company.

8.1 SHIPBOARD OPERATIONS

Shipboard operations are described thus:

“The Company should establish procedures, plans and instructions, including checklists as appropriate, for key
shipboard operations concerning the safety of the personnel, ship and the environment. The various tasks
concerned should be defined and assigned to qualified personnel”.

8.2 COMMENTS

Section 7 deserves close study. There is on the one hand:

• Principal shipboard operations concerning safety and prevention of pollution.

• Establishment of procedures, plans and instructions for these operations defined by the company.

On the other hand:

• The corresponding tasks should be defined and assigned to qualified personnel.

8.3 PRINCIPAL SHIPBOARD OPERATIONS

By preserving the objectives of the code (prevention of accidents and pollution), it is relatively easy to list the ship’s
operations that have an influence on safety.

For example, a ship-owner would not want to include a cleanliness procedure in his SMS sometime after a
motorman injures himself as a result of a fall on an engine room slippery floor tile due to a lack of cleaning.

It will be necessary to list the principal shipboard activities, to group them in order to avoid an endless number of
procedures, plans, instructions or checklists.

In a SMS, in order to avoid repetitions, it is necessary to differentiate the significant operations of the ship which
are directly related to a section of the code: documentation, risk management, preparation for emergencies,
occupational health, safety and pollution prevention, experience feedback, maintenance of the ship, communication,
training, verification are collated in a corresponding sub-system.

All the operations which do not arise from the preceding sub-systems or are particular to the ships will be
collated in another sub-system called: operations of the ship.

This sub-system will have to encompass all the ship’s operations often very different, and relating to a very different
type of traffic. In addition it is logical that the company leaves to shipmasters the responsibility of elaborating
procedures particular to their ship.

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8.4 PROCEDURES, PLANS AND INSTRUCTIONS

The company writes up the procedures and checklists (when following the IMO or industry recommendations)
which accompany them: the operations considered or declared as presenting great risks for the safety of the
persons on board and the protection of the environment, or having caused many accidents in the past and which
were the subject of recommendations on behalf of IMO; or those which engage the responsibility of the company
directly. In general, those which can be written by the company and are applicable to all the ships.

As an example, here is a list of operations, appearing in the system “operations of the ship”, that the company will
undertake to put in the form of procedure:

• Entering in an enclosed space procedure.

• Hot work procedure.
• Navigation with pilot procedure.
• Drug and alcohol policy.
• Recruitment procedure.
• Familiarization procedure.
• Handover procedure.
• Waste management procedure.
• New port procedure.
• Replacement of the captain procedure.
• Bunkering procedure.
• Stowaway procedure.
• Water ballast management procedure.
• Crude oil or products loading and unloading procedure.

On the other hand, we will leave to the ship’s captain the responsibility of elaborating procedures and checklists
which relate to the ship herself, its traffic or the personality of the captain himself.

So that the objectives of the company and the code are respected, the company will give instructions to the
captain for the development of the plans, procedures and checklists.

These various procedures belong to the ship and sometimes to the captain (particular orders) and are collated in
the shipboard management manual.

In order to standardize, the company defines a single model of procedure, proposes lists of tasks considered as
ordinary or critical, carried out in ordinary or critical conditions.

As an example, here is a list of the instructions given by the company for the development of the procedures, plans
and checklists on board:

• Instructions for the development of the bridge and engine safety patrols.
• Instructions for ship at sea or in port.
• Instructions for commercial operations.
• Instructions for work carried out on board.
• Instructions for the tasks carried out in critical condition: visibility, weather etc.

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All will be found, with the associated check-lists, in the shipboard management manual in the form of:

• Captain’s standing orders.

• Captain’s special orders for the implementation of the SMS on board.
• Captain special orders for officers on watch.
• Departure procedure and checklist.
• Arrival procedure and checklist.
• OOW handover procedure.
• Commercial operations procedure.
• Ship’s cleanliness procedure.
• Chief engineer standing orders.
• Procedure for the ship’s maintenance.
• Job description of the entire crew.
• Shipboard waste management procedure.
• Shipboard work procedure.
• Shipboard emergency situations procedure.
• Management of ship’s documents procedure.

This is the summary of the shipboard management manual:

This provision allows a certain logic, and has the advantage of being more realistic. It is nevertheless on board that
counts and a company procedure too rigid or too general has very little chances of being applied. It is better to
have a procedure worked out by the crew, which can evolve easily, and which will be applied for the benefit of the
code objectives.
NB The security procedures and responsibilities are now collected in a mandatory document (Ship’s security Plan
or SSP) which belongs to the implementation of the ISPS Code. Anyway the enforcement of the ISPS code can be
included in an Integrated Safety Management System.

8.5 THE TASKS SHOULD BE DEFINED AND ASSIGNED TO QUALIFIED PERSONNEL

This requires definition of all the tasks on board the ship such as navigation, commercial operations, safety or
maintenance of the ship.

It is in fact the whole shipboard organization that is concerned and we will present it in the form of task cards by
assignment on one hand, and on the other hand the collective roles will define the exceptional tasks of the crew
members.

By allotting a task to a qualified person we are in conformity with the requirement of the code to entrust a task
only to one qualified person.

For example, the non-attribution of a task concerning safety would oblige us to record the name of the person
having carried out this task on this particular day in order to prove that the task was carried out by a qualified
person: This will require considerable organization as any contrary provision will be a non-conformity. So the role
of a crew member in a SMS will not be forgotten.

8.6 CONCLUSION

• The company procedures are elaborated according to the rules or various recommendations that are listed in
a company database.
• The company’s experience can lead it to issue additional procedures.
• The company database gives lists of elements (equipment, conditions) likely to create a danger.

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These lists will be used by the procedures writers (ISM structure or captain) for their obligatory study of risks:

• The experience feedback in place will be perhaps a source of new procedures but certainly a source of
improvement of the daily procedures.
• The collective roles (muster lists) define the role of the crew members in emergency situations.
• The task cards define the individual tasks for all on board.
• All the shipboard tasks are thus allotted, written and recorded.
• The record will be reduced by allotting a number to the task (patrol or maintenance checklist for example).

8.7 TRAINING LIST FOR THE CREW

What is the Role of a Crew Member in a SMS?

By agreeing to join an ISM certified company:

• You hold an adequate certificate and you are qualified and physically fit.
• You promise to take care of your own safety as well as the safety of others.
• You promise to adhere to the company safety policy, to know and respect all the provisions of the safety
management system implemented on board.
• You agree to promote the company’s quality and safety spirit and to take part in the improvement of the system.
• You agree, as soon as you are on board, to take note of the general and safety instructions as well as
instructions of your head of department concerning your function on board.
• You agree to accept your assignment on board only when you feel fully ready and to announce immediately to
the captain any health problem (moral or physical), which could affect the quality of your work.
• You agree to carry out only tasks for which you are qualified.
• You agree, in the event of doubt, to request any information or explanations from your head of department
before any operation.
• You agree to quickly take note of instructions or training documents (including the SMS documents) and to
sign after having read them. This annotation being a “proof of awareness”.
• You agree to announce any accident, incident or near-accident, anomaly or doubt concerning your activities or
those of the others on board.
• You agree to leave a written handover in the event of replacement.

8.8 LIST OF ITEMS TO LOOK FOR CONFORMITY WITH THE ISM CODE § 7

we will check if:

- The company has worked out the major procedures and has given instructions for the drafting of the
particular procedures of the ship
- The checklists used for procedure application or control correspond effectively to the ship and are not general procedures
- The instructions given by the Captain in the shipboard manual correspond to the ship and its activities
- The task cards of all personnel are realistic
- The recordings carried out in the log-books are in conformity with the reality
- We will focus ourselves on the critical tasks which are assigned to qualified personnel (Authorization of Use of
the oilseparator for example)
- We will also verify if every member of the shipboard personnel having responsibilities in safety has a copy of
the tasks which are assigned to him

8.9 SELF ASSESSMENT QUESTIONNAIRE

1- Which procedures can be gathered in the Company Management Manual?

2- What means Company’s instructions?
3- How to try to standardize company and ships’ procedures?
4- Why the tasks on board must be defined and assigned to qualified personnel?
5- What is a task card?
8- Can we collect the health/environment procedures in a specific sub-system?
9- Are security measures included in the Safety Management System ?

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9. STUDY OF SECTION 8 OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will:

• understand what the code means by crew preparedness; and
• be able to prepare a system for emergency preparedness of a ship’s crew.

9.1 EMERGENCY PREPAREDNESS

The code says:

“8.1 The Company should identify, potential emergency shipboard situations and establish procedures to respond
to them.

8.2 The company should establish programs for drills and exercises to prepare for emergency actions.

8.3 The SMS should provide for measures ensuring that the company’s organization can respond at any time to
hazards, accidents and emergency situations involving its ships.”

9.2 COMMENTS

This requirement goes well beyond previous SOLAS requirements or national rules and regulations.

The reason for this is because with every investigation after a maritime accident, it was realized that the training in
answer to an emergency was always found to be inadequate. The courage of the crew was not often questioned,
but their preparedness often was.

As crew members we cannot deny that with the usual abandonment and fire drills, we rarely involved ourselves
with other situations that could occur. Often the usual drills were regarded as useless and tedious, a drudgery !

Today the code lays down two significant aspects of the preparation of the company and its ships, on board and
ashore

9.3 IDENTIFICATION OF EMERGENCY SITUATIONS

We will call this SITUR to simplify; it is obvious that the situations should initially be identified corresponding to
the ship itself, its traffic, its lines etc.

Here below, a personal list suitable for cargo ship or ro-ro freight vessel:

No 1 Abandon ship / evacuation of the ship.

No 2 Fire / explosion (escape from smoke).
No 3 Fuel overflow on deck or on the quay.
No 4 Pollution.
No 5 Fuel leaking in the engine room.
No 6 Accident / serious illness of passengers or members of the crew.
No 7 Man overboard.
No 8 Intervention or medical evacuation by boat or helicopter.
No 9 Steering gear failure.
No 10 Search and rescue.
No 11 Propulsion / electrical supply failure.
No 12 Grounding or sea-bed touching.
No 13 Collision or heavy contact with the quay.
No 14 Flooding.
No 15 Abnormal list or trim.
No 16 Collective intoxication.
No 17 Blackout in heavy traffic zone or during a manoeuvre in the port.

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No 18 Very bad weather (hurricane, typhoon, storm, tornado).

No 19 Hull or structure failure.
No 20 External dangers: close accident.
No 21 Illicit acts against the ship, the passengers or the crew (terrorism/piracy).
NB : Detailed in ship’s security Plan
No 22 Immobilization of the ship by cable or line in the propeller or the rudder.
No 23 Shifting of cargo.

Additionally, for tankers:

No 24 Pump-room rescue.
No 25 Incident at the manifold.
No 26 Escape of toxic fumes.

Additionally, for passenger vessels:

No 27 Summoning, muster and evacuation of passengers.
No 28 Assistance to disabled passengers.
No 29 Missing person routine.
No 30 Security situations (see SSP)

Additionally, for mobile offshore units:

No 31 Helicopter emergency.
No 32 DP failure/uncontrollable drift.
No 33 Blow-out.
No 34 Ionizing radiation.
No 35 Gas concentration.

9.4 DESCRIPTION OF EMERGENCY SITUATIONS

“Description” was a former requirement which has been forgotten in the recent amendment 2010. Why ? this is
necessary! How to prepare to respond without describing or imaging the situation?
Anyway I propose to keep this search which will help you a lot.
Indeed the sources of such information can only be the various reports of nautical investigations, the studies
or reports of emergencies (at national-BEA and international level- IMO or USCG website), the possible
recommendations of IMO or other maritime organizations (International Chamber of Shipping (ICS), International
Safety Guide for Oil Tankers and Terminals (ISGOTT) etc), the code of practice and possibly our imagination.

Note 1
New techniques in 3D animation will certainly help us soon in training where we can simulate emergencies.

Note 2
Following IMO Resolution A.849 (code for investigation of marine casualties and incidents), most of the major flag
states have organized the investigation of marine accidents and recently an amendment (Resolution A.884) of this
resolution has introduced specific guidelines for investigating the human factors in marine casualty and incidents.

Note 3
Experience feedback was not really common in our industry. Recently some organizations such as MARS (Marine
Accident Reporting Scheme) investigate and publish the results of accidents and near misses according to a
form of experience feedback provided by the ships or companies concerned. This is certainly the future, already
drawn up by commercial aviation where a project of experience feedback management at global level is under
development.

Investigations after marine casualties was made compulsory by SOLAS I/21.
A Code of Investigation of marine accidents in their waters or under their flag by a government body is proposed
to flag states by IMO Resolution A 849 (20). But the reports are always “official” and sometimes could not reflect
the exact causes or responsibilities because of “the politically correct” concept.
A new project in EUROPE is to entrust all accident enquiries to an independent structure. For us and for the
safety at sea it seems a good idea.

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For the moment in a shipping company, in accordance with the ISM Code, we will have to be satisfied to set up
an experience feedback management system on emergencies, in order that the other company ships may benefit,
while waiting for the world fleet to benefit also from this experience.

To consider each emergency we will envisage a response concerning the measures to be taken, both the immediate
ones and later measures like notification or analysis.

Of course, these measures are adapted to the ship concerned.

Finally, for more effectiveness:

• We will present intervention and notification measures according to a single form.

• This company form will take the shape of a checklist.
• For greater effectiveness, we will gather these checklists in a red coloured special file, which will have to be
always close to the officer on watch on the bridge or in the engine control room.
• The checklists could be in the form of a plastic-coated list or under a small plastic file (strong paper).

Note that these checklists are intended for real situations and exercises, therefore, able to be moved or carried
away: so copies will have to be available in reserve.

Certain checklists consist of a list to tick (record of the activities): a new sheet each time. For the emergency
checklists, the record will be kept on the “Intervention and Control Plan for Shipboard Emergencies”. Advantages:
only one list to be filled and filed (this method is employed by the aviation industry).

9.5 SETTING UP A PLAN OF EXERCISE AND DRILLS

This is a program of preparation for all emergency situations that have been identified. Obviously, in the SMS we
will adopt the minima required by SOLAS on fire and abandon drills. A report will be filled up every time, in the
era of photocopies and computer.

A minimum program of drills will be established by the company in the emergency situation manual covering every
emergency situation. An exercise will cover a group of emergency situations.

This program is posted on board each ship and must be followed as far as possible, the reasons for postponements
being noted in the logbook (justification).

The exercises are divided into two categories:

• Real Exercises
Emergencies which can be simulated full-scale with a gathering of the crew and measures of intervention.

• Paper Exercises
Which will be more a control on knowledge of the procedures and a discussion between the persons in
charge on the situation itself and possibilities of control.

All drills and exercises will have to be organized as follows:

• A briefing on the topic of the exercise or drill; during which the officer in charge will take time to explain the
exercise and the scenario envisaged.

• A debriefing after the exercise or drill in order to analyze the actions undertaken and draw conclusions from
them. The debriefings are also used to criticize the checklists or the safety cards (one by compartment or

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zone). The anomalies or even the suggestions which result from this will be the subject of an experience feedback
report.

A safety drill or exercise is something individual, so each report will have to note the name of all the participating
persons. This record moreover will be individualized on a nominative list for each member of the crew. This list is
communicated to the company when disembarking, and a copy is also given to the crew member: he will have to
present it on the next ship.

An individual training record book with a supplement for emergency drills and exercises has been published by ISF.
This recording system is adapted to prepare every member of the crew for compliance with: SOLAS, ISM, SOPEP
and STCW (continuous training for certificates being revalidated).

IMO, within the framework of the ISM Code, differentiate drills and exercises.

An exercise means a test of the emergency response arrangements carried out on the ship and in which the entire
crew takes part under as near realistic conditions as possible.

A drill means any type of activity which provides the opportunity to practice elements of the system. Drills are
carried out under realistic conditions while allowing instruction and training, e.g: training of the firemen to use
breathing apparatus, or EEBD, casualty handling for first aid and stretcher teams etc.

Finally, within the framework of the ISM, a continuous assessment of the aptitude of the crew to respond to an
emergency is necessary in order to prevent the crew becoming complacent, which the author often sees. Indeed
today within the framework of port state control (PSC) the controllers can and they do so exert their authority
by asking the crew to carry out a safety drill, usually the most random exercise: fire in the engine room, in order
to show conformity with the section of the code. It is then easy for them to ask for example, the cook to use an
extinguisher etc.

Non-conformity is then in general guaranteed and the ship is held for a few hours: enough time to discuss this
decision and to train the cook. In certain countries you can quickly lose 12 hours, and half a day off hire may mean
US$15,000 less in the owner’s pocket: this makes the ignorance of the cook expensive!

In order to protect the ship against this kind of non-conformity, it is suggested crews use the personal safety
drills and exercise record book with the remarks and recommendations of the ship’s captain (in fact this is an
assessment of competency required by STCW.)

In conclusion on this aspect of the code, captains and chief engineers must understand it is their responsibility to
prepare the crew to answer to any emergency.

Today in the event of an accident the complainant always takes action against all the persons in charge: if you lose
one man by his own imprudence or ignorance or his taste of danger during a fire for example, the family could
then take action claiming you have badly controlled the attitude or the aptitude of this man.
You must think about this.

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9.6 ELEMENTS TO BE INVESTIGATED DURING INTERNAL OR ASSESSMENT AUDITS

- The emergency situations corresponding to the ship and her activities are listed
- A checklist of response for every emergency situation exists
- The general alarm is in conformity as well as the means of general announcement
- A planning of safety exercises and drills exists and it is in conformity with SOLAS (as a minimum)
- The posting of the emergency telephone numbers exists in the Captain’s room
- carrying out a test if possible.
- The composition of the crisis cell is known and posted.
- Check course and reports of exercises or emergencies and their conformity with SOLAS
(Abandonment, Fire, SAR, MOB)
- Assessment of the members of the fire team is carried out at each drill or exercise
- The Pollution exercises or drills are carried out in conformity with the SOPEP
- The emergency situations included in the SOPEP are the same as those of the SMS.
- A report of an exercise with the crisis cell ashore exists
- It is recommended to provoke a fire drill involving the entire crew (fire in the machine for example with
evacuation of a casualty)

9.7 SELF ASSESSMENT QUESTIONNAIRE

1- What is the average of emergency situations for a cargo ship?

2- What is the difference between a drill and an exercise?
3- How often it is recommended to organize a Company safety exercise?
4- What is a paper work exercise?
5- What is the normal process of a drill or an exercise?
6- Does the planning for drills and exercise has to be strictly followed?
7- What to do in case of postponement of an exercise or drill?
8- Where we can find studies of marine accidents?

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10. STUDY OF SECTION 9 OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will:

• understand reports of non-conformities and the feedback system; and
• be able to create and implement such a system in a shipping company.

10.1 REPORTS AND ANALYSIS OF NON-CONFORMITIES, ACCIDENTS

AND HAZARDOUS OCCURRENCES

The code says:

“9.1 The SMS should include procedures ensuring that non-conformities, accidents and hazardous situations are
reported to the company, investigated and analyzed with the objective of improving safety and pollution
prevention.
9.2 The company should establish procedures for the implementation of corrective action, including measures
intended to prevent recurrence.

10.2 COMMENTS

To satisfy the requirements of this paragraph, we will set up a system of experience feedback, which will include:

• a procedure of management of this experience feedback; and

• an instrument of management: the card of experience feedback or REX card.

10.3 THE REX CARD

This REX card is a privileged instrument of the experience feedback, which is in conformity with the requirements
of the ISM Code:

“3.1 Reporting to the company:

• Irregularities or non-conformities discovered in the company ashore as well as on board.
• Various accidents or incidents.
• Where an accident has almost occurred – a near-miss.

3.2 An investigation at the time of the accident.

3.3 An analysis of the event by the various persons in charge and the designated person in order to determine:
corrective measures to either cancel the non-conformity, or prevent the same accident or near-miss
eoccurring aboard the ship or on another ship of the company”.

Although it is not required by the code we will include in this experience feedback: remarks or suggestions of
personnel concerning safety and the prevention of pollution.

It is true that this new approach in the industry appears more a step in quality, but it has such an impact on the
safety culture that we cannot do without it.

Note 1: A global analysis of such an experience feedback will be made at the company level and for this purpose
the instruments of this analysis will have to be determined by the company according to its activities, i.e. the
elements of an analysis grid.

Note 2: These cards will be recorded and then diffused on the level of the concerned sectors of the company.

Note 3: REX card “goes up” from the transmitting writer/towards the designated person while passing via the
captain of the ship or the head of department and “goes down again” towards the transmitter (see the following
flow chart)

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Note 4: The analysis of near-misses remains the most difficult part of the experience feedback. It is not in human
nature to analyze its errors and particularly its judgment errors. If the experience feedback exists under these
conditions, it is most certainly a personal one. The author has difficulty in imagining a mate reporting to the
Captain in the early morning: “Sir, I almost collided with another ship last night.”

Recently at an IMO meeting the Japanese delegation announced an analysis of about 2,000 near-misses. It was
interesting to note that although the near-misses were studied the unfortunate result was that in all the situations
the Japanese have found that the great majority were the fault of the other ship.

What a shame this try was not converted. But do not be discouraged, the day will come when particular interest
will disappear to finally leave in place the general interest among the Japanese and others.

10.4 The Marine Environment Protection Committee at its fifty-sixth session (9 to 13 July 2007) and the Maritime Safety
Committee at its eighty-third session (3 to 12 October 2007) further agreed that it was essential to review the existing guidelines
and develop new guidelines to assist companies in effective and efficient operational implementation of the ISM Code. The MSC-
MEPC.7/Circ.5 guidelines (§ 6), hereafter, insist on the treatment of non-conformities and recommend to analyze accidents or
near-misses to get a feedback aiming at improving our industry. These guidelines stressed the role of the Responsible person in
implementing corrective or pro-active actions which will be prepared by the DPA.

“REPORTING AND ANALYSING OF NON-CONFORMITIES, OBSERVATIONS, ACCIDENTS AND HAZARDOUS

OCCURRENCES

The SMS should contain procedures to ensure that non-conformities, observations and hazardous occurrences are reported to the responsible
person of the management.The Company should have a system in place for recording, investigating, evaluating, reviewing and analyzing such
reports, and to take action as appropriate.
The system should ensure such reports are reviewed and evaluated by the responsible person(s) in order to determine appropriate corrective
action and to ensure that recurrences are avoided.The evaluation of reports may result in:
.1 appropriate corrective actions;
.2 amendments to existing procedures and instructions; and
.3 development of new procedures and instructions.
The responsible person should properly monitor the follow-up and closing-out of the non-conformities/deficiency reports.The receipt of
reports should be acknowledged to those persons who have raised the reports.This should include the status of the report and any decisions
made.
6.4 The Company should encourage the reporting of near-misses to maintain and improve safety awareness (see MSC/Circ.1015). A near
miss can be defined as hazardous situation where an accident was avoided.The reporting and analysis of such incidents are essential for an
effective risk assessment by the Company, especially where accident information is not available.

NB Opinion of the author about the title of this requirement:

The title of this paragraph seems not fully correct. I would have preferred if they took the opportunity
to modify hazardous occurrences by “hazardous situations” it would be more in adequacy with the text
of the requirement and finally more clear for the seafarers!

10.5 COMMENTS on these new guidelines

The concept of the Responsible Person has not been really explained by the IMO working group. Everything appears as an attempt
to create this new role and … to analyze the results/comments/opinion during the coming years.
It seems that the Responsible Person is in charge of monitoring the follow-up and closing out of the non-conformities. This
recommendations clarify the following question: who is responsible for following up the action plans?
Without precise requirement from the ISM Code itself, we used to give this responsibility to the DPA. Anyway we are prepared to
add this responsibility to the Responsible Person (RP) within the Governing board of the Company and to confirm that the DPA
will be in charge to inform the RP of the status of the Non-conformities or other deficiencies!As a specialist, the author does not
criticize the creation of this new role. Al contrario, it seems to him that the spirit of the ISM Code which was created after the
HOFE disaster, is followed. In fact the DPA as a key role but many times cannot decide himself especially when resulted costs are
important. The reality of a Responsible Person inside the governing board is more close to the intention of The Honorable Mr
Justice SHEEN when he analyzed the lack of connection between the ship’s personnel and the high level of decision within the
Townsend/Thoresen ferry company.

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It is obvious that this concept of the “Responsible Person” will be developed in the next years to clarify
the gap between the DPA and the highest level of the company.

10.6 ELEMENTS TO BE INVESTIGATED DURING INTERNAL AUDITS

- The procedure for notification and analyzes of accidents, incidents and near misses exists
- Evidence of investigations when accident happen exists
- Evidence of actions taking into account the feedback
- Examples of circulation. with successive analyses and corrective actions carried out in a reasonable time can
be consulted
- The possibility for the members of crew of emitting suggestions or remarks and the feedback (safety
observation, improvement ideas) exists
- The Designated Person is on the circuit of information about accidents.

10.5 SELF ESSESSMENT QUESTIONNAIRE

1-What are the three situations to be taken into account by the Company’s SMS?
2- What to do with these reports?
3- What is a feedback report?
4- Do you thing analysis of crew’s suggestions could be valuable?
5- What is the new concept issued in the ISM structure at the end of 2007?
6 – What is the possible relationship between the RP and the DPA ?

10.6 EXAMPLE OF FEEDBACK MANAGEMENT

COMPANY FEEDBACK PROCEDURE

Subject: Systematic treatment of any event relating to safety or environmental protection

Goal: To allow all personnel of the company to know the various phases of the feedback process in order to ensure a
constant evolution of the quality of the service of the company, safety and environmental protection on board
managed ships

Ref: ISM Section 9

Definitions

Event: Accident, incident, near – miss, non-conformity, proposal of correction, suggestion of improvement – information
Accident: Event having caused damage or injuries
Incident: Minor event having caused minor damage
Near-miss: Accident avoided
Non-conformity: Operation, document, condition of equipment, which is not in conformity with what was established or required
Corrections
to documents: Corrections of errors or draft proposals for amendment of text
Suggestions concerning safety, its organization or its improvement

Conditions

The feedback will have to be carried out in all the necessary cases, such as:
• At the time of an accident, incident, damage, near-miss.
• In the day to day work, on board or ashore.
• In the various contacts with the customers: litigations, future contracts.
• At the time of internal or external audit results.
• At the time of direction and captain’s reviews.
• At the time of safety drills or meetings.

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Examples
• Accidents, damages or near-misses analysis.
• Suggestions of improvement on safety or quality.
• Comments and corrections on the company’s manuals or procedures.
• Information on equipment, material, ships, work etc.
• Comments on the company’s ISM structure and service.
• Comments on the quality of our ship manager services.
• Information on competitors.
• Feedback process.

Any feedback such as defined previously is described on a feedback form called REX CARD.
It includes several parts used for the various analysis, decisions, the action follow-up and the grid of a global
analysis.

Part I: Immediate Description and Reactions: category, date, event itself, and transmitter.

First analysis:

Captain or head of service who issued the information will analyze it firstly and send it then to ISM structure, i.e.
to the DPA. This first analysis is compulsory, the captain’s signature on board or head of department ashore being
the authentication.

REX card is dispatched towards the ISM structure (DPA).

Part II: Analysis: Classification and second analysis:

The classification of the REX card and the end analysis is carried out by the DPA.
First return: A first return towards the originating department and the transmitter itself takes place at this stage.

Part III:
Third analysis:
The DPA can request qualified opinions or transmit simply for information (opinion or obligatory visa with date)
Part IV: Decision

The decision is made by the DPA after the president’s opinion if necessary.

A second return of the card towards the originating department is organized.

Part V: Realization

If there is a decided action, a follow-up of the action is organized. An action pilot is appointed and a time of
realization is decided.

For the realization, control and information to the other services or ships are organized. Closed or not, the card
goes back to the transmitter whose review with the personnel involved will be confirmed.

History and Global Analysis

An analysis grid is carried out by the ISM structure. This grid corresponds to quantified elements in order to
undergo an analytical treatment.

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10.7

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11. STUDY OF SECTION 10 OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will:

• understand this requirement of the code; and
• be able to propose to the company a monitoring system for maintenance and tests of
normal and critical systems.

11.1 MAINTENANCE OF THE SHIP AND EQUIPMENT

Section 10 of the code says:

“10.1 The company should establish procedures to ensure that the ship is maintained in conformity with the
provisions of the relevant rules and regulations and with any additional requirements which may be
established by the company.
10.2 In meeting these requirements the company should ensure that:

.1 inspections are held at appropriate intervals;

.2 any non-conformity is reported, with its possible cause, known;
.3 appropriate corrective action is taken; and
.4 records of these activities are maintained.

10.3 The company should identify equipment and technical systems the sudden operational failure of which may
result in hazardous situations. The SMS should provide for specific measures aimed at promoting
the reliability of such equipment or systems. These measures should include the regular testing of stand-by
arrangements and equipment or technical systems that are not in continuous use.

10.4 The inspections mentioned in 10.2, as well as the measures referred to in 10.3, should be integrated into
the ship’s operational maintenance routine.”

11.2 COMMENTS

We start here one of the essential sections of the ISM Code: the maintenance of the ship and her equipment.

This large chapter should not surprise us: we have been trained to maintain our car, our fishing boat or the ship on
which we are embarked to earn our living.

So certain cultures “drive” their ship by only informing the company when she does not function very well any
more...we are used to maintaining our working tool in order to prevent any failure which could cost us either our
life or our work.

According to the type of transportation or activities carried out, it is true that the risks are different: we cannot
compare a container ship with an oil drilling platform or with a ro-ro ship for safe transport of passengers except
by our concern of preventing the risks whatever they are. In fact here we consider primarily the purely technical
aspect after having considered the real human element.

By “technical” we mean the question of maintaining the ship and equipment in good operating condition, i.e. the
whole ship, hull and all that there is inside, all that “runs” normally to advance, work the ship, all that is used in the
event of accident: fire, evacuation and all that is on stand-by.

Note that this has always been done: maintenance of the main and auxiliary engines, the various compressors,
separators, boilers of damping or recovery, various pumps etc according to the requirements of the class, the
recommendations of the manufacturers or the instructions and usual practice of the company.

Periodical testing for safety appliances or stand-by equipment was programmed on board in the same manner.

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So, what is new?

• The code obliges us to prove this routine maintenance, so equipment should be identified with precision and
registered (numbered for example), i.e. maintenance checklist for every apparatus.

• The code obliges us to identify and index the various routine inspections of our equipment, i.e. routine
checklists.

• The code obliges us to entrust any task to a qualified person; we will allot the various tasks of the ship to a
well-defined person, i.e. task list by assignment on board.

• The code obliges us to identify equipment in stand-by (mainly safety appliances: fire pumps, ship’s main,
extinguishers, CO² installations, life boats etc and to test them at regular intervals with the single aim of being
sure that they will function at the time when we will need them.

As previously mentioned, we will allot each one of these periodic tests to a qualified crew member and these
periodic tests will be added on the individual checklists.

It is obvious that all this is recorded either by the intermediary of the checklists, which are then filed, or, more
effectively, by inscription of the number of the checklist on the official logbook (bridge, radio or engine).

Finally, and I kept the best for the end, the code obliges us to identify the elements or systems which could in
the event of sudden breakdown put the ship or its crew in danger, in order to provide specific measures (more
maintenance for example, more frequent tests or compulsory feedback).

11.3 WHAT ARE CRITICAL ELEMENTS IN SECTION 10.3 OF THE CODE

This subject has caused a lot of ink to flow and will continue to do so. Each company, each administration, each
captain or chief engineer, has his or her own idea on this. For some of them, everything is critical. This last opinion
is obviously too easy to state, but it is true that the problem exists and that it will be necessary at company level
to deal with it.

It is, of course, an ambitious project sometimes impossible to do on board. The classification societies propose
their services for this project at a price. It is not a necessary approach and the identification of the critical systems
by the study of risks is the simplest and cheapest method.

Indeed from the moment when a case study proves that a certain element, if it suddenly breaks down, can
endanger the ship, it will be necessary to ensure a substitute, i.e. a second apparatus maintained in stand-by (a
back-up).

The risk study may not lead you to install a second apparatus in stand-by (pump) because, for example, in a
degraded situation without all equipment normally in service, you will be able either to finish the voyage at slow
speed, or to carry out repairs or to divert to a close port etc.

Nowadays for new ships, such a study comes under the authority of the formal safety assessment (FSA), and it is
true that to study the total safety of a ship during its design is better than trying to adapt once the ship is built.

The example of commercial aviation is still relevant here: the engineers who specialize in the marine FSA are often
also in aviation.

In short, the critical equipment will be identified on board (a progressive complete study using a list provided by
the company as a database).

To be able to answer to the certifying auditor or the port state controller we can emphasize these critical
elements as well as the safety appliances in stand-by on our checklists or maintenance registers (for example, by
filing them in a red folder underlined in bold type).

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Note 1: The maintenance of the ship may be grouped, for obvious practical reasons, in two registers:

• bridge; and
• engine.

However, the use of calendars of maintenance by apparatus also has its supporters; it is necessary to adapt the
system to the company culture.

Note 2: Here too we will try to simplify:

• by multiplying the test and checklists;

• by numbering them; and
• by recording them only under their reference number (list or operation).

NB the 2010 amendments do not change the meaning of the § 103: it is clearer that’s all.
For me it is a pity that the term of “critical equipment or system” had not been clarified at
this occasion, leaving us with the possibility of interpretations! Next time may be?

Note 3: More and more frequently provided by the shipyard at the construction stage of the ship or performed
later by a risk management specialist, the FMEA (Failure mode equipment analysis) for each critical equipment will
help the crew to conduct the ship in a degraded mode.

11.4 LIST OF ELEMENTS TO BE INVESTIGATED DURING THE INTERNAL AUDITS

- There is a planning of maintenance of all the shipboard equipment: bridge, hull, deck equipment, Safety and
engine and the various persons in charge for this maintenance are identified.
- A simplified maintenance planning appears posted on the bridge, or in deck or engine office.
- The maintenance planning of evacuation and fire equipment respects at least the requirements of SOLAS (III
rules 20 and 36 – II-2 Rule 14)
- are visits and inspections carried out in accordance with the planning? (if not so what is the reason) … and
recorded in a document or a computer software.
- are the various rounds (deck/garage/engine) defined (plan and checklist) and are they carried out by a qualified
personnel and then recorded?
- are the use of the back-up systems obviously posted close to the equipment concerned (steering gear, remote
and local / emergency fire or bilge pump/local orders for pitch control, quick closing of emergency valves etc…) ?
- Periodic tests of these back-up systems are carried out and recorded
- Critical elements and systems are identified (list or mark in our lists of maintenance), they were the subject of a
particular study (maintenance or back-up).
- Tests in degraded mode are periodically carried out and recorded according to company instructions and
reports have been carried out if necessary.

11.5 SELF ASSESSMENT QUESTIONNAIRE

1- What kind of procedures the Company has to establish for the maintenance of its ships?
2- How to prove that your ship is maintained in conformity with the SMS?
3- What is a critical element or system?
4- How to identify the critical elements of a ship?
5- What is the reason of defining critical systems?
6- What is FMEA?
7- Do you think the study of the operation in “degraded mode” will be valuable for all ships?

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11.6 EXAMPLE: COMPANY DATABASE

An example of a company database is shown below:

IDENTIFICATION OF CRITICAL EQUIPMENT OR SYSTEM

Official Text

“ISM Section 10.3: Equipment and technical systems the sudden operational failure of which may result in
hazardous situations.”

The management of this equipment or technical system is defined in an SMS sub-system called ”management
system for vital apparatus and systems”.

List of Apparatus and Systems

• Bridge

- Radars
- Navigation lights
- Whistles
- Internal communications: tannoy-telephone-interphone
- External communications:VHF – radio-satellite communications: phone/fax/e-mail
- Fire detection and alarm
- Gyro and magnetic compass
- Rudder indicator
- Electrical distribution
- GPS system
- SSAS and activation buttons
- Other security equipment (cameras, presence detection)
- Nautical charts and documents

• Deck

- Fire mains
- Power and control circuit of mooring winches
- Bilge pumping system
- Anchoring system
- Fire detection and alarm system
- Extinguishing system
- Stern ramp closing system
- Evacuation system
- Mooring system
- Personal breathing apparatus
- Pyrotechnic and emergency beacon

• Engine Room

- Fuel tanks double level alarm system

- Propulsion system
- Steering system
- Power generation and distribution
- Monitoring system for machinery

• Miscellaneous

- Collection of drawings, plans or technical manuals

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12. STUDY OF SECTION 11 OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will:

• be able to complete the library of a shipping company; and
• be able to implement a controlled documentation system.

12.1 DOCUMENTATION

The code requires:

11.1 The company should establish and maintain procedures to control all documents and data which are
relevant to the SMS.

11.2 The company should ensure that:

1 valid documents are available at all relevant locations;
2 changes to documents are reviewed and approved by authorized personnel; and
3 obsolete documents are promptly removed.

11.3 The documents used to describe and implement the SMS may be referred to as the safety management
manual. Documentation should be kept in a form that the company considers most effective. Each ship
should carry on board all documentation relevant to that ship.”

12.2 COMMENTS

Summarized requirements and measures to be considered:

• Control of the documents of the SMS: checking procedure of documentation.

• Availability of the documents: ashore and on board.
• Room dedicated ashore (crisis room for example).
• Instruction to the captain for shipboard access procedure to the documents for all the crew members.
• Approval of the corrections in the same way as the documents themselves.
• No out-of-date documents in service: instruction to the captains and check during internal audits.
• Documentary system appropriate to the choice of the company.
• List of documents concerning the ship to be established: ship’s official documents or others and list of the
other documents available in the company.

Below is an example of a documentary system.

12.3 CONTROLLED DOCUMENTS

Controlled document means that every page is named, checked and approved. They are:

• safety management manual;

• individual manual;

• training manual etc.

All these documents are referred and the pages numbered. They are dated, checked and approved page by page
according to the company groundwork below:

Document Creation date: Drafting by: Index doc/revue:

Approved by: Checked by: No page/total:

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1. Index of the Document

Document abbreviation and number of order in the manual and revision number (0 for the original) example: MAN
03/0.

Abbreviations used for the index are as follows:

• CSMM (Company Safety Management Manual).

• SSMM (Ship’s Safety Management Manual).
• TRAIN (Training).
• CDB (Company Database). If necessary!
• S (Summary) List, Form etc.

2. The document is compiled by or corrected by X (consultant, DPA – head of service – initials). The document
is checked by DPA (initials). The document is approved by the chief executive or the general manager (initials).

3. The corrections are controlled and recorded at the beginning of document.

4. All the documents are accompanied by a signing sheet: each member of the personnel must sign as proof of
awareness.

Note that, for example, an individual manual is distributed to all the members of the company personnel with
a visa.

Correspondence

Memorandums and memos etc:

• Memorandums are instructions of managers and are recorded by the letters NDS/memo and service and
number of order in the year (ex: NDS DA 98/13).

• Memorandums are fast correspondence documents between departments and are recorded by the letters
memo and direction and number of order in the year.

12.4 NON-CONTROLLED DOCUMENTS

The maritime information memo in connection with the operation of the ships managed on international lines are
gathered and transmitted by the ISM structure.

The origin of these documents can be a subscription to a specialized magazine or other information coming from
another database or information coming from our industry (CCAF-ISF)

12.5 ACCESSIBILITY OF DOCUMENTS

The manuals and the databases are at the disposal of any permanent personnel: the captain will specify in his
standing orders the manner and the place.

The documents are at the disposal of the officers and the heads of service.

All the handbooks and sorters are of white color for example and personalized. The operational manuals are of
different colors according to their use. For example:

• Emergency situations checklists (SITUR) – red.

• Operations checklists (OPS) – blue.
• Engine checklists (ENG) – black.
• Familiarization manual – yellow.
• Garbage record book – green.

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12.6 MANDATORY DOCUMENTS

The provision and updating of the official company documents is the responsibility of the ISM structure.

The ISM structure has the responsibility to communicate to every ship the corrections to its documents and the
provision of new editions.

Out-of-date documents are obligatorily withdrawn on arrival of the latest edition.

12.7 DATA-PROCESSING MANAGEMENT OF DOCUMENTS

Measures to protect all the company documents are carried out by the fleet manager for example on data discs
or CD/DVD-Rom updated each week and preserved in a different place.

Note 1

Documentation is significant and impossible to circumvent in a SMS. The trap to be avoided is bulky
documentation made up of long and unpleasant procedures, which do not attract anybody and especially not the
members of the crew.

How must we proceed?

We initially work out the company and shipboard procedures in a formal way (see hereafter the procedure
“development of a procedure”) by writing only what is essential.

Then we will use the checklists as envisaged in Section 7: these checklists are part of the manual; we avoid
repetition of items either into the procedure or into the checklist.

In order to be more effective we gather the checklists in three kinds of files:

• Emergencies (red sorter).

• Deck operational procedures and checklists (green sorter).
• Engine operational procedures and checklists (blue sorter).

Finally, to be more effective and less time-consuming, we avoid filling in a checklist each time and thus avoid
useless storage and for this reason we name each checklist and each item (for example each check of equipment
or document, each action of routine maintenance or each test of an apparatus).

This system allows us the following:

• To record briefly but in a regular manner in the logbook (bridge, engine and radio).
• To have in hands of the crew, in their place of work, a really effective operational document to deal with an
emergency.
• Finally, classification will allow better data-processing management.

Note 2

Our basic system of data supposes a complete inventory of the company documentation and on board updated
by the ISM structure.

You will find hereafter these examples:

• A list of the checklists used on board.

• A list of documentation concerning the company and the ships.

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12.8. DEVELOPMENT OF A PROCEDURE

This procedure establishes the methods of drafting a procedure.

The headings below appear normally in any procedure worked out by the company or the ship’s captain.

The headings “definitions” and “reference documents” disappear when they are inapplicable.

• Object of the procedure.

• Definitions of certain terms concerning this procedure.
• Objectives of this procedure.
• Reference documents
(Section ISM, Section ISO, IMO resolution, safety committees (MSC, MEPC, fire protection etc) resolution
or circular, STCW, MARPOL, Load Lines or ILO conventions – national regulation or company policy).
• Applicability: who is concerned and how.
• Risk assessment in the implementation of this procedure:
6-1: Identification of the risks.
6-2: Inventory of the causes.
6-3: Control options.

• Process In short:

1. Object.
2. Definitions.
3. Objectives.
4. Reference documents.
5. Applicability.
6. Risk assessment.
7. Process.
NB The last amendments (2008) to the ISM Code has not changed anything to this chapter

12.9 ELEMENTS TO BE INVESTIGATED DURING INTERNAL AUDITS

- Is the documentation (shore or shipboard) up to date and there is no out-of-date documents under the trails
- All signatures are present: writing/ verification / approval
- All corrections are recorded
- All personnel (shore or ship) has access to these documents: adequate place (not in the Superintendent or captain’s
office for example)
- The documents have been consulted by the personnel
- The checklists used are those in service and up to date
- The personnel cannot carry out wild copies without authorization

12.10 SELF ASSESSMENT QUESTIONNAIRE

1. Why the control of SMS documents is important?

2. How to build a practical documentation system?
3. How to ensure the personnel is aware of all the SMS documents and can easily consult them?
4. How to establish a rules/regulations watch-over?
5. Can we replace all paper documents with a software ?

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13. STUDY OF SECTION 12 OF THE ISM CODE:

COMPANY INTERNAL VERIFICATIONS (AUDITS AND
REVIEWS)
Learning Outcomes

After successfully implementing this chapter, you will:

• understand the auto-control system required by the ISM Code; and
• be able to implement such a system in a shipping company.

13.1 TEXT

The text of Section 12 of the code is as follows:

“12. Company Verification, Review and Evaluation

12.1 The company should carry out internal safety audits on board and ashore at intervals not exceeding
twelve months to verify whether safety and pollution-prevention activities comply with the SMS. In
exceptional circumstances this interval my be exceeded by not more than three months.

12.2 The company should periodically evaluate the efficiency of and, when needed, review effectiveness of the
SMS in accordance with procedures established by the company.

12.3 The audits and possible corrective actions should be carried out in accordance with documented
procedures.

12.4 Personnel carrying out audits should be independent of the areas being audited unless this is impracticable
due to the size and the nature of the company.

12.5 The results of the audits and reviews should be brought to the attention of all personnel having
responsibility in the area involved.

12.6 The management personnel responsible for the area involved should take timely corrective action on
deficiencies found.”

NB The 2010 amendments insist on the internal audits on board as well as ashore and the periodicity of them.
Apparently some companies were taken the opportunity not to perform internal audits on board their ships,
incredible!
The modification of § 12.2 is only semantic. Efficiency includes a notion of cost effective I guess; so, for the ISM
Code, effectiveness is sufficient.

13.2 COMMENTS: SUMMARY OF REQUIREMENTS

The summary of requirements is as follows:

• Procedure for internal audits.

• Procedure for management review.
• Choice of auditors.
• Publicity of the results: audits and reviews.
• Action plan following the audits and reviews.

The organization of internal audits is very simple for ships calling regularly at a port but becomes more difficult
when it is about ships tramping around the world.

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13.3 INTERNAL AUDITS – WHAT, WHO, WHEN, HOW?

What ?

Definition of Internal audit: Methodical and independent examination aiming at determining if the activities and
results satisfy pre-established provisions, and if these provisions are implemented in an effective way and are
efficient to achieve the goals previously led down within the company or on the ship.

The goals of internal audit are:

- To assess the reality of the Safety Management System
- To determine conformity or nonconformity by searching for objective evidence
- Seeking the cause of the non conformities detected
- To determine the efficiency of the Safety Management System
- To improve knowledge of the audited person
- To allow the improvement of the SMS

Who?

Many attempts have been carried out all over the maritime world: head of department auditing; the captain or the
captain of a ship auditing the captain of another company ship; financial manager auditing the captain of a tanker
etc; all with mitigated success.

The current experience feedback encourages us to:

• specialize the auditors: indeed an audit is not a control using a checklist but rather an inventory of regular and
which can bring on the one hand the auditor to better evaluate the evolution of the culture of audited person
ship and the audited ones to put in order the safety management in the company and on board;

• choose a person having natural facilities for such a dialogue so that it is constructive;

• choose an auditor with an important past well-known by the crew and whose professional competence cannot
be put in doubt to avoid any rejection from the top of the hierarchy on board or ashore; and

• choose, for financial reasons, a person qualified for audits and who goes on board regularly due to his original
responsibilities in the company.

With experience, the choice of a technical superintendent is often judicious:

• Technical skill is a large part of the SMS, e.g. maintenance.

• Maritime competence: always a former member of the crew.
• Sufficient level: almost always a former chief engineer.

However, we will have to prepare other auditors who could be:

• the designated person himself obviously: good knowledge of how the SMS is running in order to perform an
essential permanent evolution;

• other designated persons in the ISM structure for perhaps more targeted audits, such as document control,
assessment of training courses, audit of third party contractor etc…

How?

There is no need to write a novel on audit techniques, as has been too often the case in the past. As said
previously, an audit must be able to locate the dysfunction or the weaknesses of an entire system or a targeted
part on the one hand and on the other hand facilitate an exchange of ideas between the audited persons and the
auditors on the performances of the SMS.

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UNIT 20 | The International Safety Management Code

A periodical internal audit must always start with the review of the report of the preceding internal audit.

If the dysfunctions are to be analyzed and corrected, the cultural exchange on prevention of accidents is a general
analysis, which can then be the subject of a more total analysis and an action plan at company level.

The auditor will benefit from these privileged contacts (this did not exist at all in our industry) to explain again
the objectives of such a step in order to improve the motivation of all the people who are the cornerstone of a
system which functions, and improve accident prevention.

When?

It is not necessary to multiply the audits. Experience proves that such a practice exasperates crew members
quickly.

Therefore, an annual internal audit, sufficiently extended to the whole of the SMS operation on board, with
additionally a knowledge analysis of the audited persons should allow a good analysis which will suitably furnish the
management review.

13.4 MANAGEMENT REVIEW

The objective of this analysis is clear: evaluate the efficiency of the SMS and revise it if need be.

The management review, which I recommend should be carried out annually, will be provided by the captains’
reviews and the analyses of the internal or external audits.

The management review is a very important part of the system – it acts as:

• an assessment of the SMS over the past year;

• an analysis of the necessary measures to decrease non-conformities and improve the system;
• a definition of company’s new objectives; and
• a development of action plans to try to reach these objectives.

13.5 PUBLICITY of AUDIT RESULTS

The restitution of an audit is of the first importance because it is made just after the audit, it is a kind of debriefing
on the spot. The corrective actions and implementation dates are indeed often to be found between the auditor
and the audited sector except when the company is directly concerned.

The internal audits are followed by a report which presents all non-conformities and observations, already decided
corrective measures and the deadline decided in common with the audited persons when possible. Certain more
significant corrective actions or requiring investments higher than a certain limit, require the decision of the
highest levels of the company.

A SMS which functions without nonconformities does not exist!

After an internal audit nonconformities and observations will be numerous including major nonconformities
(external auditors are always suspicious, rightly, of internal audits without nonconformities!)

Alternatively, after an external audit, the number of nonconformities must be as low as possible and obviously
without any major nonconformity.

The results of the management review must be communicated to company personnel involved in safety and
environment protection

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However, the code does not require that ALL the results should be communicated.

It is agreed that parts of audit or reviews (management or Captain) must be communicated to persons involved in
the corresponding sector of the SMS.

Particularly for the management review, some analyses are obviously confidential and the communication has to
be controlled.

Anyway, this decision is in hands of the top management

13.6 TREATMENT of CORRECTIVE ACTIONS

It is common to use a nonconformity card or quite simply a REX card (2 pages) when the corrective action
requires so: importance of non conformity, necessary opinion of several qualified people and information to
the other ships for example.

Indeed, much of nonconformity cards were insufficient to analyze and deal with the problem; the current tendency
is to deeply treat and in a precise way nonconformities within the whole company and to avoid too general
answers which could make a real doubt on the willing of the company to rectify or to improve… which will lead
towards major nonconformity!

In internal audits, the solutions worked out during the restitution of audit, especially on board, often requires an
analysis on behalf of the shore management mainly when the organization of the company is concerned or
when the recommended actions imply budget decision (authorizations of exceeded expenses for example).

It is an internal problem according to the company and its means, but which external auditors will be able to see
during their annual verifications or renewal audits.

The subject is delicate but it is required by the ISM code:

No one is perfect and to detect or evaluate ones insufficiencies is already a step in the right direction provided
that all possible and reasonable measures are then taken within realistic limited times.

We will speak again of all that for the study on the results of an external audit.

13.7

The Marine Environment Protection Committee at its fifty-sixth session (9 to 13 July 2007) and the Maritime
Safety Committee at its eighty-third session (3 to 12 October 2007) further agreed that it was essential to
review the existing guidelines and develop new guidelines to assist companies in effective and efficient operational
implementation of the ISM Code.
Notably these new guidelines ( MSC-MEPC.7/Circ.5 ) stressed on the management reviews and the internal audits.
Hereafter find the extracts of these recommendations:

“ REVIEW OF THE SAFETY MANAGEMENT SYSTEM

The Company should, when needed, review and evaluate the effectiveness of the SMS in accordance with procedures
established by the company. Further, it is one of the master.s
responsibilities to review the safety management system and to report its deficiencies to the shore-based management.
Shore based and ship board internal audits should be performed at least once a year.
Management reviews support companies. efforts in achieving the general safety management objectives as defined in
section 1.2.2 of the ISM Code. Based upon the results of such reviews, the Company should implement measures to improve
further the effectiveness of the system.The review should be performed on a periodical basis or when needed, e.g., in case of
serious system failures. Any deficiencies found during the management review should be provided with appropriate corrective

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action taking into account the Company’s objectives.The results of such reviews should be brought to the attention of all
personnel involved in a formal way.The management review should at least take into account the results of the internal
audits, any non-conformities reported by the personnel, the master’s reviews, analysis of non-conformities, accidents and
hazardous occurrences and any other evidence of possible failure of the SMS, like non-conformities by external parties, PSC
inspection reports, etc”.

13.8 INTERNAL AUDITS

“Companies should carry out internal audits at least once per year to verify whether
shore-based and shipboard activities comply with the SMS.These internal verifications should be prepared and conducted in
accordance with procedures established by the Company.
The procedures should at least consider the following elements:
.1 responsibilities;
.2 competence and selection of auditors;
.3 audit scheduling;
.4 preparing and planning the audit;
.5 executing the audit;
.6 audit report; and
.7 corrective action follow-up ».

These new elements are a confirmation of our own analysis of the ISM Code requirement.

13.9 ELEMENTS TO BE INVESTIGATED DURING INTERNAL AUDITS

- Check internal audit reports and state of corrective actions

- Check frequency of the audits, the audited sectors and the quality of the auditors
- Absence of nonconformity must attract our attention on the quality of the audits; on the contrary when
nonconformities are discovered and the corrective actions clearly taken that proves a correct operation of the
SMS.
- If major nonconformities were discovered we will check deeply on corrective actions taken and deadlines.
- The non closure of nonconformities in the intended deadlines must challenge us: a dysfunction is quasi certain
often on the level of means engaged by the company and perhaps the willing of the company to follow is
policy!
- Reports of management reviews which must include an analysis of the efficiency of the system in place and
measures for improvement are entrusted to authorized personnel (protected diffusion).

13.8 SELF ASSESSMENT QUESTIONNAIRE

1- What is the average of internal audits frequency?

2- What is the philosophy of an internal ISM audit?
3- Could you find a major non-conformity during an internal ISM audit?
4- What is really a management review?
5- How to publish the results of an internal audits or a management review?
6- Explain how to follow a corrective action?

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CERTIFICATION and VERIFICATION (part B of the code)

14. STUDY OF SECTION 13 OF THE ISM CODE:

CERTIFICATION AND PERIODICAL VERIFICATION
Learning Outcomes

After successfully completing this chapter, you will:

• understand the certification and renewal process; and
• be able to inform and prepare the company for the ISM initial, periodical and renewal
audits.

With the 2002 amendments of the code, the methods of certification did not change much. However the fact of
integrating these methods in the code itself, makes them ipso facto obligatory whereas in Resolution A 788 they
were only strongly recommended!
It is the same for the form of certificates which are in appendix in the code.

14.1 TEXT

The text for section 13 of the code is as follows:

13 CERTIFICATION AND PERIODICAL VERIFICATION

13.1 The ship should be operated by a Company which has been issued with a Document of Compliance or
with an Interim Document of Compliance in accordance with paragraph 14.1, relevant to that ship.

13.2 The Document of Compliance should be issued by the Administration, by an organization recognized by the
Administration or, at the request of the Administration, by another Contracting Government to the
Convention to any Company complying with the requirements of this Code for a period specified by the
Administration which should not exceed five years. Such a document should be accepted as evidence that
the Company is capable of complying with the requirements of this Code.

13.3 The Document of Compliance is only valid for the ship types explicitly indicated in the document. Such
indication should be based on the types of ships on which the initial verification was based. Other ship
types should only be added after verification of the Company’s capability to comply with the requirements
of this Code applicable to such ship types. In this context, ship types are those referred to in regulation IX
of the Convention.

13.4 The validity of a Document of Compliance should be subject to annual verification by the Administration
or by an organization recognized by the Administration or, at the request of the Administration, by another
Contracting Government within three months before or after the anniversary date.

13.5 The Document of Compliance should be withdrawn by the Administration or, at its request, by the
Contracting Government which issued the Document when the annual verification required in paragraph
13.4 is not requested or if there is evidence of major non-conformities with this Code.

13.5.1 All associated Safety Management Certificates and/or Interim Safety Management Certificates should also
be withdrawn if the Document of Compliance is withdrawn.

13.6 A copy of the Document of Compliance should be placed on board in order that the master of the ship,
if so requested, may produce it for verification by the Administration or by an organization recognized by
the Administration or for the purposes of the control referred to in regulation IX/6.2 of the Convention.
The copy of the Document is not required to be authenticated or certified.

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13.7 The Safety Management Certificate should be issued to a ship for a period which should not exceed
five years by the Administration or an organization recognized by the Administration or, at the request
of the Administration, by another Contracting Government. The Safety Management Certificate should be
issued after verifying that the Company and its shipboard management operate in accordance with the
approved safety management system. Such a Certificate should be accepted as evidence that the ship is
complying with the requirements of this Code.

13.8 The validity of the Safety Management Certificate should be subject to at least one intermediate
verification by the Administration or an organization recognized by the Administration or, at the request
of the Administration, by another Contracting Government. If only one inter- mediate verification is to
be carried out and the period of validity of the Safety Management Certificate is five years, it should take
place between the second and third anniversary dates of the Safety Management Certificate.

13.9 In addition to the requirements of paragraph 13.5.1, the Safety Management Certificate should be
withdrawn by the Administration or, at the request of the Administration, by the Contracting Government
which has issued it when the intermediate verification required in paragraph 13.8 is not requested or if
there is evidence of major non-conformity with this Code.

13.10 Notwithstanding the requirements of paragraphs 13.2 and 13.7, when the renewal verification is
completed within three months before the expiry date of the existing Document of Compliance or Safety
Management Certificate, the new Document of Compliance or the new Safety Management Certificate
should be valid from the date of completion of the renewal verification for a period not exceeding five
years from the date of expiry of the existing Document of Compliance or Safety Management Certificate.

13.11 When the renewal verification is completed more than three months before the expiry date of the existing
Document of Compliance or Safety Management Certificate, the new Document of Compliance or the
new Safety Management Certificate should be valid from the date of completion of the renewal verification
for a period not exceeding five years from the date of completion of the renewal verification.

13.12 When the renewal verification is completed after the expiry date of the existing Safety Management
Certificate, the new Safety Management Certificate should be valid from the date of completion of the
renewal verification to a date not exceeding five years from the date of expiry of the existing Safety
Management Certificate.

13.13 If a renewal verification has been completed and a new Safety Management
Certificate cannot be issued or placed on board the ship before the expiry date of the existing certificate,
the Administration or organization recognized by the Administration may endorse the existing certificate
and such a certificate should be accepted as valid for a further period which should not exceed five
months from the expiry date.

13.14 If a ship at the time when a Safety Management Certificate expires is not in a port in which it is to be
verified, the Administration may extend the period of validity of the Safety Management Certificate but this
extension should be granted only for the purpose of allowing the ship to complete its voyage to the
port in which it is to be verified, and then only in cases where it appears proper and reasonable to do so.
No Safety Management Certificate should be extended for a period of longer than three months, and the
ship to which an extension is granted should not, on its arrival in the port in which it is to be verified, be
entitled by virtue of such extension to leave that port without having a new Safety Management Certificate.
When the renewal verification is completed, the new Safety Management Certificate should be valid to
a date not exceeding five years from the expiry date of the existing Safety Management Certificate before
the extension was granted.

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14.2 COMMENTS

Certification of conformity of the company SMS with the ISM Code: DOC, Document Of Compliance

The checking of conformity is carried out, in the form of an audit, by the Administration or the Administrations of
the flag of the ships or by an organization recognized by them (RO) or at the request of the flag Administration, by
another contracting government (with SOLAS). When the company uses its ships under several flags, it is judicious
to choose the same RO when it is possible. Indeed, except an agreement between these organizations including
the Administrations, the process of certification includes every time the audit of the Company head quarters and
the ship.
A DOC (Document Of Compliance) will be delivered to the company if the Company Safety Management System
is recognized, at least, conform with the requirements of the ISM Code. Then, every ship of the company must
obtain a Safety Management Certificate or SMC.

First of all, it is necessary that the company was certified to be able to use a ship: the certification starts always
with the company and then the ships.
The question is to certify a Safety Management System particular to this company; all the ships which the company
takes under management must enter in the new system although they have already a SMC (this one is not valid any
more)!

The Recognized Organisations (RO) are in general Classification Societies but not all of them for example SGS
also does it by its subsidiary company ICS (International Certification Service)…

The presence of a DOC is a proof of conformity: this is significant because during a PSC, it will be necessary, in the
presence of a DOC and a SMC to have sufficient reasons to, for example, proceed to a detailed or reinforced visit
on the safety management in the company or on the ship.

A copy of the DOC (photocopy) up dated of the annual checks will have to be on board.

The DOC is issued for one or more types of ships: Passenger ship- Passenger High Speed Craft or cargo-
Container ship-High Speed Craft- Bulk carrier -Tanker -Chimical tanker- Gas tanker-Mobile Offshore drilling unit
- Other cargo- roro ship etc…
When a new type of ship enters in the company, a verification is made by the body which has issued the former
DOC on the aptitude of the company to satisfy the requirements of the code applicable to the new type of ship.

After the annual audit or a renewal audit, a type of ships can be excluded from the DOC if the Company does not
prove an adequate application of the requirements of the code for these types of ships.

The DOC is issued for one period fixed by the certification body, a period which cannot exceed 5 years. The
certifier can thus issue a DOC valid for a certain period less than 5 years (one year for example) for a SMS which
requires improvements. After this period a new audit of conformity will take place.
NB this is independent of the interim certification which relates only to new companies or new ships (new or
newly bought or long term chartered ships or even change of flag)

The DOC is stamped annually following a verification (annual audit) in the three months which precede or follows
the DOC anniversary date, by the certification body

The DOC can be withdrawn only by the authority which has delivered it due to a non-request for the verification
audit or a major nonconformity with the ISM Code; Obviously the company has to submit an official request to
the administration or the certification body. This role is generally for the DPA.

In the event of a withdrawal of the DOC, all the SMC of the company ships die at the same time: all ships stop !

At the end of the period decided by the certifier, the company must undergo a verification of conformity with the
ISM Code, it is the audit for the renewal of the certificate.

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This audit is carried out in the same manner as the initial certification audit and then the DOC is renewed for a
new period not exceeding 5 years. It is also possible to renew for a lesser period when the SMS, for example, does
not work correctly.

Certification of conformity of the operations of each ship with the approved SMS of the Company: the Safety
Management Certificate (SMC) a verification is carried out on each ship

It is to check that the Company SMS, already approved in conformity with the ISM Code, is correctly applied on
board and that means that the shipboard SMS is in conformity with the ISM Code and that it is effectively applied
on board.

The certification body for the ship is not obligatorily the same one as for the company. In practice they are the
same because, except for an agreement between them, we don’t very often see an organization accepting a
company audit carried out by another organization!

The original of the SMC will have to be in possession of the captain

This SMC is delivered for a certain period, which can be of a maximum of 5 years: that is to say to say that a SMC
can be issued for a short period (1 year for example) if the SMS of the company is not completely or badly applied.

A ship is subjected to, at least, an intermediate verification of conformity independent of the period of validity of
this certificate. When the validity of the SMC is 5 years this audit will take place between the second and the third
anniversary of the certificate.

This certificate can be removed only by the certifier except obviously when the Company loses its DOC.

Because of the trips of the ships, it is not always easy to have in accordance the dates of calls in the ports, the
expiry dates of the certificates and the planning of the certification body, so audits ordered in advance (+ 3 months
before the expiry dates for example) should not penalize the ship-owners: it is the date of the former certificate
which determines the expiry date of the new certificate (can be significant of course).

Today there is still strong lobbying in IMO from the major classification societies to make an annual verification
mandatory.

Note that the largest classification societies of IACS are sharing the largest part of the cake. Despite a recent
effort from these societies to reduce their costs, in my opinion they are still too high.

The original of this SMC will have to be in the captain’s possession.

Note that the author stresses the concept of “ISM certified” because sometimes this question of certification is
badly misunderstood:

• The safety management system set up in a company and on board its ships is certified in conformity with the
ISM Code.

• A company, a ship, a person cannot be “ISM certified”; that does not mean anything.

• A ship sold to another company or managed by a new shipmanager loses its SMC and must apply the SMS of
its new owner or manager and undergo a new certification audit later via the interim certification... to confirm
that the company’s SMS, already ISM certified, is really applied on board.

• Nevertheless, in order to allow this ship to continue to trade normally an interim SMC will be issued.

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14.3 What are the modifications after the 2010 amendments

-§13.12 Details on the date of the SM Certificate during its renewal, in order not to penalize the ship-owners who
ask for the visit of renewal before the deadline of the existing certificate… it is logical!
-§13.13 In the event of problems during the renewal of the certificates (corrective actions to set up for
example) an extension by 5 months maximum of the existing SMC is possible (time to set up the corrective actions
certainlyt)… It is also very logical!
-§13.14 Possibility of extension of 3 months maximum of a SMC to allow the ship to go to the port planned for the
renewal audit. On the other hand the 5 years limit after the validity date of the existing SMC remains… Re-logical
to help the ship-owners without leaving to them the possibility of trying… “to gain” 3 months!

14.4 SELF ASSESSMENT QUESTIONNAIRE

1. What is the validity of a DOC?

2. Do you need a DOC for all the types of ships you manage?
3. Is the DOC subject to periodical verification?
4. Who has to request for all these verification?
5. What happen when a DOC is withdrawn?
6. Does the ship need a certified copy of the company’s DOC?
7. What is the validity of a SMC?
8. How many verifications during the validity period?
9. What is a renewal verification?
10. What are the new delays permitted for the renewal of some certificates?

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15. STUDY OF SECTION 14 OF THE ISM CODE:

INTERIM CERTIFICATION
Learning Outcomes

After successfully completing this chapter, you will:

• understand the interim certification process; and
• be able to inform and prepare the company for the entire ISM certification process.

15.1 TEXT

The code says:

14 INTERIM CERTIFICATION

14.1 An Interim Document of Compliance may be issued to facilitate initial implementation of this Code when:
.1 a Company is newly established; or
.2 new ship types are to be added to an existing Document of Compliance,

following verification that the Company has a safety management system that meets the objectives
of paragraph 1.2.3 of this Code, provided the Company demonstrates plans to implement a safety
management system meeting the full requirements of this Code within the period of validity of the Interim
Document of Compliance. Such an Interim Document of Compliance should be issued for a period not
exceeding 12 months by the Administration or by an organization recognized by the Administration or, at
the request of the Administration, by another Contracting Government. A copy of the Interim Document of
Compliance should be placed on board in order that the master of the ship, if so requested, may produce it for
verification by the Administration or by an organization recognized by the Administration or for the purposes of
the control referred to in regulation IX/6.2 of the Convention. The copy of the Document is not required to
be authenticated or certified.

14.2 An Interim Safety Management Certificate may be issued:

.1 to new ships on delivery;
.2 when a Company takes on responsibility for the operation of a ship which is new to the Company; or
.3 when a ship changes fag.

Such an Interim Safety Management Certificate should be issued for a period not exceeding 6 months by
the Administration or an organization recognized by the Administration or, at the request of the Administration, by
another Contracting Government.

14.3 An Administration or, at the request of the Administration, another Contracting Government may, in
special cases, extend the validity of an Interim Safety Management Certificate for a further period which
should not exceed 6 months from the date of expiry.

14.4 An Interim Safety Management Certificate may be issued following verification that:
.1 the Document of Compliance, or the Interim Document of Compliance, is relevant to the ship concerned;
.2 the safety management system provided by the Company for the ship concerned includes key elements
of this code and has been assessed during the audit for issuance of the Document of Compliance or
demonstrated for issuance of the interim Document of Compliance
.3 the Company has planned the internal audit of the ship within three months;
.4 the master and officers are familiar with the safety management system and the planned arrangements
for its implementation;
.5 instructions, which have been identified as being essential, are provided prior to sailing
.6 relevant information on the safety management system has been given in a working language or languages
understood by the ship’s personnel the ship’s personnel .

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15.2 COMMENTS

Fortunately, a provisional certification is possible:

To allow a new starting company to be able to use its ships quickly
To allow a company to run, without waiting too much, either a new ship (newly built or newly bought or simply
taken into management or new type of ship)
To allow a ship which changes its flag to continue to sail without waiting too much.

An interim DOC valid for a maximum of 12 months can be issued to a new company which sets up or which
wants to exploit a new type of ships, provided that the company has a SMS which at least fills the objectives
required within the § 1.2.3 of the ISM Code:
That means the SMS ensure the conformity with the obligatory rules and regulations and includes the key
elements of the ISM Code. One audit of evaluation takes place before the emission of provisional DOC. In
general the new company puts a provisional system which ensures this conformity with SOLAS/MARPOL/STCW/
COLREG/ILO etc… and the flag regulations.

Key elements means: elementary organization of the company able to ensure the safety of exploitation at the early
beginning and which can gradually implement all the requirements of the code.

This is a minimum and is variable according to the Administration concerned, the activities of the ship or attended
areas. As always, the advance and the quality of the SMS will have to be in connection with the risks of the
exploitation (Passenger ships, fast ships, ships at risks, dangerous waters etc…)

A valid provisional SMC (6 months maximum - sometimes 12 months in certain special cases) can be delivered
for a new ship, recently brought into service or going under a new flag provided that:
A DOC or provisional DOC covers this type of ship
The SMS set up on board covers the key elements of the ISM code ie finally the 10 requirements we have seen
before
The Company has planned internal audits (Company and/or ship) in the 3 months maximum.
Captain and the officers are familiar with the SMS and the stages of implementation (training needed for these
officers).
The essential instructions are given before the departure: means instructions of the company to the captains
(assistance ashore etc…),
The familiarisation of the crew with the new ship and their tasks as well as the captain’s orders has been carried
out
The crew has received necessary information on the SMS in a language he understands: means familiarisation with
the SMS.

SIGNIFICANT: Before the limiting date of validity of the provisional documents, the Company must ask for the
certification of its SMS and its ships.

Provisional certification: it is not so easy as that to obtain, because the certifier puts his responsibility at risk. For a
new company beginning in the maritime area or in a new activity, the presence of qualified personnel in the sector
or new sector is necessary.

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15.5 COMMENTS on the 2088 small modification

Amendments to the § 14: it is about the interim certification. It seems that in fact we needed a precision
concerning the action plan necessary to obtain the interim SMC, and programming the mandatory internal audit
within the 3 months from the date of the interim certificate.

NB the internal audit of the company (head office and branches) is included in the code itself (§ 12) and must be
carried out during the validity of the interim DOC. (normally a year, but often less) In cases of the DOC is valid
only 6 months, we have to carry out the internal shore base audits just after the audit of the ship!

15.3 SELF ASSESSMENT QUESTIONNAIRE

1- List all the conditions when an interim ISM certification is required

2- How long an interim DOC can be valid?
3- How long an interim SMS can be valid?
4- Which elements have to be included in the first draft of a Safety Management System?
5- What is the delay for the first internal audit of a ship with an interim SMC?

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16. STUDY OF SECTION 15 OF THE ISM CODE:

VERIFICATION
Learning outcomes

After completing this text you will be able to understand:

That verifications procedures are entrusted by the Administration itself, but
They have to take into account the guidelines set up by IMO

16.1 TEXT
Chapter 15 of the code

15.1 All verifications required by the provisions of this code should be carried out in accordance with procedures
acceptable to the Administration, taking into account the guidelines developed by the Organization*.

16.2 COMMENTS

A new Assembly resolution has been issued to help Administrations or Recognized organization to perform
correctly their certification audits
Finally some § of the former Resolution A 788 has been introduced in the code itself in creating a new part B.

As everybody knows, an IMO Resolutions is not mandatory as a convention except when the text of the
resolution has been made mandatory by the convention itself.

Taking into account does not been to carry out exactly as written

The spirit of the guidelines issued in the resolution has to be followed but practical implementation can be
different

So, you can find differences in application of the code from a country to another

The most common differences are situated in the conduct of external audits performed by the Administrations or
the ROs.

This problem is very important

It is important to note that all the premises of the company will be audited on a period of 5 years which is the
longer period of validity of a DOC.

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17. STUDY OF SECTION 16 OF THE ISM CODE: FORMS

OF CERTIFICATES
Chapter 16 of the code

17.1 Text

16.1 The Document of Compliance, the Safety Management Certificate, the Interim Document of Compliance
and the Interim Safety Management Certificate should be drawn up in a form corresponding to the models
given in the appendix to this Code. If the language used is neither English nor French, the text should
include a translation into one of these languages.

16.2 In addition to the requirements of paragraph 13.3, the ship types indicated on the Document of
Compliance and the Interim Document of compliance may be endorsed to reflect any limitations in the
operations of the ships described in the safety management system.

17.2 COMMENTS

By introducing this chapter in the code, we have made the form of certificates mandatory.

This was a good idea indeed.

In some cases, limitations in the operation of the ship could be decided by the Administration: sector of navigation
for example. These limitations can be added on the DOC or the interim DOC

17.3

Due to the modifications presented in Chapter 13 (§ 13. 13 and 14) endorsements of extension of certificates
have been prepared in annex of the amendments.

17.4 SELF ASSESSMENT QUESTIONNAIRE

1- In which languages the full or interim certificates should be written?

2- What is the advantage to have mandatory forms of certificates?

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18. STUDY OF RESOLUTION A 1022 or

ISM EXTERNALS AUDITS
or
“Guidelines on implementation of the ISM Code by Administrations”

18.1 NEW RESOLUTION

This resolution (14 pages) dated January 2010 cancels and replaces Resolution A 913 from 1st of July 2010.
Due to the 2008 amendments to the ISM Code the existing guidelines needed some small corrections as well. So
another Resolution was thus necessary.

There are only little modifications in the texts:

- objectives of the company on the assessments of risks and
- reminder of the procedure in case of major non conformities ( MSC circ 1059 of 2002)

18.2 PROCESS OF CERTIFICATION:

A- Guidelines
We will not develop the successive stages of one external audit which are clearly expressed in the resolution.
We will recall only the characteristics on the practice of certification audits:

a) Resolutions are directives with a vocation of strong recommendations, for the Administrations or their
representatives, in order to guarantee a certain uniformity of the practices in ISM audit process

b) The certification body must:

- Check the complete conformity of the company SMS with all the requirements of the ISM code
- Check that these requirements are actually observed ashore as on board: objective evidence will be required.
- Check that the SMS is able to carry out the laid down objectives of the company which will, at least,
participate to the objectives of the code itself!
- Check that the obligatory rules and regulations concerning the Company or the ship are observed: objective
evidence of procedure guaranteeing this observation.
- Check that the company has taken into account the recommendations mentioned with the § 1.2.3.2 of the
code: we must find evidence of observation of these recommendations when they are applicable.
- Check that the additional or new requirements, which could be worked out by the company itself in its own
SMS, are in conformity with the spirit of the ISM Code.

c) It does not :
- Take the general objectives of Code ISM to determine if the requirements of the Code are observed or not
(see § 2.2 2).
Indeed: above text of resolution A 1022 § 2.2.2
“These objectives provide clear guidance to Companies for the development of safety management system
elements in compliance with the ISM Code. Since, however, the ability of the safety management system in
achieving these objectives cannot be determined beyond whether the safety management system complies with the
requirements of the ISM Code, they should not form the basis for establishing detailed interpretations to be used
for determining conformity or non-conformity with the requirements of the ISM Code”.

This text always seemed strange when the history of its drafting is not known.
The IMO Safety Committee which is in charge of the drafting of the texts did not want to change the general
objectives of the ISM Code whereas certain delegations of state members found them too difficult to achieve.
This ambiguous text tried to bring back these objectives, which were likely to become requirements of the code, to
ultimate goals...... that only… a complete conformity with the code can help us to achieve!
This is a subtlety which succeeds finally only… to decrease the means taken by the industry to achieve the goals of
the ISM code!

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However:
- To create the material terms of a safe working environment is not impossible today.
- We will not save the not easily controllable morals conditions entirely (NB: the causes of more than 80% of
the accidents are mostly human errors!)…we can only try to reduce their impact.
- To identify and assess the risks and to take corresponding measures are nevertheless quite natural and even
obligatory recently in numerous countries.
- Finally, an ambitious policy of continuous training should be sufficient to improve constantly competences of
the crews in particular in emergency situations.

It is this last objective especially which pushed the MSC to work out such a strange text but nevertheless
restrictive.

In a single word these objectives are goals to reach and the auditors must, for the moment, to help and encourage the
audited persons to carry them out by the means of “observation or recommendations”..

And thus for the moment, the sole method of valid analysis remains the verification of conformity with the 10 requirements
of the ISM Code !

18.3 PRACTICE

A SMS cannot be presented at the ISM certification (delivery of DOC.) before:

- a minimum operation of three months in the company and three months also at least on the ships of each
type to certified.
In the same way,
- a ship cannot be presented at the ISM certification (delivery of a SMC) before a minimum operation of three
months and also before an internal audit was carried out.

As we have just seen it, they are guidelines for the control of external audits by Administrations. For internal audits, if
the general process of the audit is necessarily different, the methods of assessment can be the same ones.

In theory if the Company does what it wants during an internal audit, we can take example on these directives in
particular in the execution of the audits, the establishment of the audit and /or nonconformities reports and in the
follow-up of corrective measures.

A fundamental difference however exists in the research of corrective measures:

“Administrations are recommended to limit the development of criteria in the form of prescriptive management system
solutions. Criteria for assessment in the form of prescriptive requirements may have the effect that safety management in
shipping results in Companies implementing solutions prepared by others, and it may then be difficult for a Company to
develop the solutions which best suit that particular Company, that particular operation or that specific ship”.

In internal audit it is the reverse,

The auditors and the audited persons, have to find the solutions together, but especially for the auditor
representing the company, they have to impose the company solution to the other departments or ships!

Attention:The external auditors do not have the right to impose the corrective actions and have only the right “to advise”
if they are able to do so.The restitutions of audit are sometimes sufficiently sensitive nonconformities concerning it is not
necessary thus to look for additional subjects of discord!

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18.4 DIFFERENT AUDITS

Initial or renewal audits are mainly conformity audits, while the intermediate audits are primarily verification audits.

We have to say that we are actually on a system of quinquennial revalidation frequent with IMO (cf STCW for
example) and that the audits of renewal must be treated by the companies as serious as the initial audits and
perhaps even more!

Today by 2010, ie after around 10 years after the beginning, the SMS are going better and…the nonconformities
with the code appears dangerously numerous for those which did not have already the intelligence to improve
their initial system.

18.5 RESTITUTION

The restitution meeting of the audits are compulsory

Indeed a nonconformity can be annotated to you whereas the lead auditor quite simply missed the “objective
evidence”, it is thus necessary during the initial audit meeting to specify that each nonconformity discovered and
even each observation will have to be discussed before recording in the audit report.
Indeed it is not always the case unfortunately. And this kind of accomplished fact is very often at the origin of
the dissensions at the end between auditors and audited persons.

18.6 AUDITORS’ QUALIFICATION

The external listeners must be qualified (training and certification), the standards of competences are specified in
the appendix of the Resolution. If that was difficult at the beginning of the implementation of the code, today it is
very different.

18.7 In conclusion

Thus charged by the UN, IMO has determined standards for maritime industry within a safety and environmental
protection culture and request all to apply them.

Not having the means itself of ensuring a control of implementation, it entrusts to the Flag and Port
Administrations, the care of verification of the application of these standards: ISM Certification on one hand and
Port State Control on the other hand.

The Organization, which is an assembly of governments, has always promulgated a “no blame” policy leaving with
the national authorities the care to blame and penalize.

In the case of the ISM Code, IMO decided moreover to grant a certain confidence to the shipping companies in
the management of safety of their ships entrusting them to verify:
Conformity of the SMS with the ISM Code
Reality of implementation and operation of the SMS
Efficiency to achieve the goals led down by the Company.

… verification carried out during an internal process: reviews/inspections/audits

So, a certain confidence, but a quite relative confidence nevertheless, indeed:

The ship having obligatorily a flag, it is requested from its Administration to check periodically that the Safety
Management System applied in the company and on the ships is always in conformity with the ISM Code and that it
really functions.

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… verification carried out during an external process of control: audits for certification of conformity.

So, there is a great difference between the two steps:

On one side there is a self-checking and we measure the efficiency and on the other one there is only a
verification of conformity with a standard and a verification of effective operation.

In practice:

When the company is serious, the Flag Administration, after an initial audit of conformity, will have nothing to do,
except an easy verification of operation.

If the company is not serious, the intermediate audits will quickly detect the failure of the system previously
declared in conformity the ISM Code.

There is thus a great difference between the internal audits and the external audits.

Note: This difference, the sailors understood it well, the organizations working on behalf the flags also, some flag
administrations not always. Some of them continue to play the role of the internal controller going even until
taking again, on their account, the observations or non- conformities made by the internal auditors, these non-
conformities having been already the subject of corrective measures as the code requires it, thus throwing an
unquestionable confusion in the spirit of the companies and the seafarers: why a self-checking if a control of the
flag makes the same thing? .... in this case the sailor and the ship-owner tend to let the external auditor find itself
the non-conformities whatever they are!
We falls down in the verification/sanction… that the ISM Code wanted to avoid! It is not astonishing then that
the results of common internal audits are very poor… a scalded sailor will never offer again the least stick to be
beaten again!

IMO early feel the danger and from the first “Guidelines on the application of the ISM Code by Administrations”
as amended – it recalled heavily that Administrations were there for an insurance of conformity to the code and a
verification of operation only.
The reasons of these errors are certainly multiple but primarily reside on, at the beginning, a bad interpretation
of the objectives of IMO which were those of a self-management of the maritime industry. The ship-owners
understood very well this philosophy, their associations are very well represented within IMO and work in this
direction: it is significant that the best directives on the application of the ISM Code (and those of code ISPS today)
are from ship-owners! (ref. ICS GUIDELINES one the application of the IMO/ISM Codes ED 93, 94 and 96)

18.8 SELF ASSESSMENT QUESTIONNAIRE

1- What is the difference between internal and external audits?

2- Are the external auditors authorized to give recommendations to company or ships’ Captains?
3- What is the difference between effectiveness and efficiency?
4- What is the difference between an initial verification audit and an intermediate audit?
5- What are the necessary background of the auditors (lead auditor and auditor) for initial/renewal audits?

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Part B INTERVENTION of the ISM CONSULTANT

19. INITIAL ASSESSMENT, ACTION PLANS FOR
CREATING AND IMPLEMENTING A SMS
Learning Outcomes

After having successfully completing this chapter, you will:

• be able to evaluate the existing culture of the company and detect the missing
requirements of the ISM Code;
• be able to propose a SMS to the general management of the company; and
• be able to propose the designated person ashore.

19.1 EVALUATION AND DRAFTING OF DOCUMENTS

It is necessary to study and evaluate the company’s existing culture in comparison with the requirements of the
ISM Code.

To achieve this it will be necessary to find both the missing elements of the code and those that exist:
• it is simple to deal with the missing elements, they have to be created and set up; however
• for the existing elements, a detailed analysis will have to be carried out to see if they are in full conformity with
the requirements of ISM Code.

By fully understanding the requirements of the ISM Code and by having at your disposal all the information relating
to the company and its ships, this evaluation perhaps will take a few hours.

The best method is to use a checklist taken from the requirements of the ISM Code and then to check them in a
systematic process. With regard to the requirements of the code:

• Does a response to this requirement exist?

• Is the requirement entirely covered?
• Does a corresponding procedure exist?
• Does a systematic recording of the corresponding activity exist?

Very often certain requirements of the ISM Code exist in the shipping company and on the ships, but often in an
informal manner. The ISM Code is often applied in a routine way, without a well defined procedure and especially
without valid records.

The modifications, additions and gaps must form the elements of your action plan for acquiring conformity.

The loopholes often encountered are:

• There are reports of accidents but no systematic analysis and almost never the required feedback.
• The risk analysis of activities either does not exist, or is never formalized and remains random belonging more
to the individual himself than to the system.

• The maintenance of the ship and its equipment is disordered and completely between the hands of the
technical manager and the chief engineers: certain parts of equipment are often forgotten or neglected.
• The level of criticality of equipment or systems is almost never approached – no study has been undertaken –
and the existing measures to reinforce their reliability are only those taken at the start of the ship’s life and
relate only to some of the equipment.
• The preparation of the crew to answer to emergencies is almost always insufficient. Not all the possible
emergency situations are identified and emergencies are limited to abandon ship, fire and man overboard.
Few ships are prepared to fight against accidental pollution and the situations of collision, grounding, collective
intoxication or heart disease are seldom described and simulated.

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• The abandon ship drills are, in general, carried out properly, particularly because they are not difficult to
simulate.
• On the other hand the fire exercises are too often carried out in the same places on board the ship whereas
fires in at risk compartments of the ship should be studied and simulations carried out in order for the captain
to have at his disposal all the necessary information to fight any outbreak of fire quickly.
• Finally, few companies make the difference between drills and exercises so the rescue squads are sometimes
well organized but the members of these teams are not well prepared. In addition from the outset, it will
be necessary to choose a common working language for the company and the ships. When only one language
is usually spoken, the solution is easy: all the documents will be in this language. When several languages are
used in the company and on board, it is often necessary to choose English.

If the shipping company is new and/or everything has to be created and set up, the following action plan should be
elaborated by the consultant:

Three phases are envisaged:

• Creation of the SMS and drafting of documents.

• Implementation and training.
• Internal audits and reviews plus coaching during the certification audits if necessary.

One of the most significant moments of our preliminary action will be the choice of the designated person ashore
(DPA).

19.2 CHOICE of THE DESIGNATED PERSON ASHORE

It is a question of helping the top management of the company to choose a person with the ideal profile.

Many considerations will have to be taken into account such as:

• Is there a person who is already an executive of the company who presents this profile?
• If so, could this person support the load of the DPA?
• If not, can the company recruit an executive at this level? etc

All precautions will have to be taken in the choice of this person, his role is crucial and no mistakes can be made: it
is essential for the correct operation and, therefore, the survival of the SMS.

If the company fails initially to find this rare bird, it is possible to designate a temporary DPA who will be in
operation at the time of the certification audits which will leave time for the management to calmly choose this
important person.

The role of the designated person is difficult and the risks of such a responsibility should not be understated: It is
sometimes advisable not to insist too much on this responsibility when recruiting
.
With the recent IMO circulars it is now more easy to present the background requirements of the DPA when
advising on the designation or the recruitment of a person.

In large companies it is sometimes necessary to create one ISM structure, but to nominate several persons under
Section 4 of the ISM Code – because how can one person supervise the safety and prevention of pollution aspects
of each ship?

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19.3 PREPARATION OF AN ACTION PLAN

With the elements acquired in the first part of this course and your checklist you will be able to propose to the
customer a quantified action plan.

It is suggested that you propose your advice in the form of working days. It will soon become apparent that the
drafting of a procedure will take one half-day; the development of a recording form between one and two hours
etc.

A permanent dialogue with the top management will have to be ensured during this initial phase.

The best means is to build a SMS according to examples given in Chapters 1 to 14 of this module and to propose a
draft quickly that will be able to be rectified progressively. It is essential to sit down with the general management
during a few hours to decide the structure of the system, the various policies and the actions of internal
verifications and the various managers for the more technical parts like: recruitment, job descriptions, experience
feedback system, the maintenance program and the critical systems, the recruitment of the internal auditors etc.

Then the more practical parts concerning each ship will be prepared according to a single groundwork for the
same type of ship. They are:

• operational procedures;
• the contingency plan;
• the emergency checklists;
• the familiarization manual;
• the management plan for refuse and waste;
• the engine, bridge and safety maintenance plans; including
• the periodic testing of appliances in stand-by.

A draft will be prepared by category of ships and will be rectified later on board according to the ship itself and
what already exists there. Note that you will find later in the module as an example, a summary of some manuals
.

19.4 PREPARATION OF DRAFTING THE SMS DOCUMENTS

A significant element of the SMS will have to be considered at the same time. It is necessary to consider the
documentation of the company first and then each ship after.

The SMS will have to include a person in charge of the “regulations watch” and corresponding information: a very
simple procedure should be implemented at the marine superintendent level for example.

The Company will have to provide the mandatory up to date documentation and sometimes in several languages
and will provide the ships with the official or essential documents that we discussed in Chapter 12.

All documents of the SMS must be in the language of the ship, i.e. understood by the whole of the personnel.
When there are several nationalities on board, it is useful to choose English as the language of the ship. However,
this is not always the case.

When all the documents are in a certain language, it is possible to publish in supplement certain documents in
another language which will be the mother tongue of certain crews in particular for the familiarization and training
manuals.

Take care not to fall into the trap of publishing all the documents in several languages. The control of these SMS
documents will be more difficult and it will increase the risk of having non-conformities during internal or external
audits because some of the documents are not up to date.

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In conclusion, after having defined the SMS with the general management and selected the designated person
ashore, a drafting or an updating will have to be carried out in the company and on board the ships.

It is judicious to quickly create an ISM structure, which will then help you in the installation of the SMS and
especially in formatting and publishing the documents of the SMS.

19.5 SELF ASSESSMENT QUESTIONNAIRE

1- Could you present some common loopholes usually found in a SMS?

2- Which person in the company is to be searched with great caution?
3- What is the most important proposition to present to the Company when starting your job?
4- Which trap is to be avoided when starting to create the SMS documents?

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20. OPERATION OF THE SMS ASHORE

Learning Outcome

After successfully completing this chapter, you will:

• be able to install and start the safety management system in the company headquarters.

20.1 ROLE OF THE COMPANY

After having laid down its policy, worked out the SMS and set up the ISM structure, the company must ensure the
operation of the system.

Based on an ISM structure ashore, the safety management system must be able to function without stopping.
Indeed, a SMS must function in a continuous manner like a ship, i.e. 24 hours a day and seven days a week.

So it will, therefore, be necessary to have a full time operation ashore in the company headquarters and in the
subsidiary companies if necessary. This operation will set up a watch system, a crisis cell, a system of visits,
inspections or audits and the ISM structure.

20.2 WATCHKEEPING SYSTEM

With reference to ISM Section 8.3: The company must be able to respond at any time to emergency situations
concerning its ships. An executive of the company must be designated each week, for example, and must stay in
touch 24 hours a day.

Either he has a company GSM whose number is known and posted on board each ship and in each subsidiary
company or a system of forwarding calls transmitted towards his private telephone to receive all communications
to the company after business hours.

The first solution is the most tempting one. The responsibility for the executive on duty is, as far as we are
concerned, to judge if information coming from one of the ships justifies a meeting of the crisis cell.

In the event of an emergency on board a ship, the captain must inform the company. If the ship is managed within a
subsidiary company, the captain informs the executive on duty...who will judge if it is necessary to involve the local
crisis cell and the headquarters crisis cell.

20.3 THE CRISIS CELL

A crisis cell is created at the headquarters and in each subsidiary company. A procedure defines the composition
of this cell and the tasks assigned to each member.

An office must be allocated to this crisis cell. This office must be able to receive all the members, to have effective
means of communication with the subsidiary companies and the ships (e-mail, telephones, fax), the nautical charts
of the zones attended by the ships, the general safety drawings of all the ships of the company as well as the
following documents:

• SOPEP, the contingency plan of each ship and the local contingency plan.
• Fixed or portable flip charts intended for the various demonstrations (exposure of the situation to the
media for example) will be laid down.

The following tasks will be distributed between the members:

• liaison with the ship;

• liaison with the charterers or customers;
• liaison with the media and local authorities or of the flag;
• liaison with the classification society and the insurers; and
• connection with the families of the crew members.

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Note that the relationship with the media is, nowadays, very significant for the company image or the charterers
(oil companies for example). The current means of transmission of information are such that, on one hand, a
spectacular accident concerning one of the company ships is likely to appear on television worldwide in a very
short time and on the other hand the company, or subsidiary headquarters risks being assailed by questions from
the media looking for the facts. Thus, an unfortunate word, a refusal to answer, or an inadequate explanation of the
emergency or its consequences are likely to bring serious damage to the company and its customers’ image.

In order to safeguard the interests concerned, it is recommended that the representatives designated to
communicate with the media are trained in this exercise. Special training should be provided to keep them calm
and avoid the traditional traps of the interviewers.

The DPA must belong to the crisis cell but he is not obligatorily the head of the crisis cell as is often thought.
Indeed the roles of monitoring, liaison and control of resources and support to the ship of the DPA find their
place in this cell.

After the new concept of the Responsible Person of the Management, it appears for us that this RP will be leading
the Crisis cell. The management ashore of an emergency concerning one of its ships returns quite naturally to the
general management of the company and its operational structure.

The company crisis cell already set up in the SOPEP can be appropriate; emergencies are no longer simply limited
to pollution.

Within the framework of the assistance which the crisis cell can bring to a captain alone in the middle of the
ocean, in an emergency situation, it is possible that another captain knowing the ship well or a chief engineer with
full knowledge of the broken down apparatus can advise those on board.

In the same way, the experts of the classification company of the ship could also be questioned and will be able to
bring answers or advice from a distance.

Note that for tanker or bulk carrier companies, a service of calculation of stability after damage, called ship
emergency response system (SERS) with Lloyd’s Register (LR), could certainly be of invaluable help to the captain
in his decision-making concerning the safety of the ship and the prevention of pollution.

20.4 VISITS AND INSPECTIONS OF THE MANAGEMENT ABOARD SHIPS

Within the framework of communication, visits of management aboard ships can be programmed or not. These
visits can be of a routine nature or be the result of a precise problem.

It is recommended, quite simply, to record these visits either on the ship’s log book or in the form of a visit report
worked out by the visitor himself or the captain.

The ships’ inspections are a complete or targeted inventory of fixtures (bridge and deck for example,
accommodation, engine room etc) These inspections will be made according to a plan and the inspectors
appointed by the general management.

Checklists of inspections could be prepared and will be recorded with the survey report which is a part of the
verification activities of the company .The planning and the realization of the inspections can be entrusted to the
ISM structure. In addition, inspections and audits can be grouped.

Note that the internal audits are the subject of Chapter 26 of this module.

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20.5 THE ISM STRUCTURE

For a small or medium company, one designated person will be sufficient; on the other hand, it seems difficult for
me to imagine only one person to ensure all the tasks of the DPA when there are several ships in the company
and often different types or traffics.

As we saw the ISM Code allows the designation of several persons. We suggest creating an ISM structure, which
will be made up of:

• A Responsible Person in the Company’s governing board ensuring monitoring of actions plans concerning
the operation of the SMS and leading the Management review
• a DPA ensuring the organization of tasks, the regulation watch, the practical aspect of the follow-up of
actions and the final analysis (preparation of the management review headed by the RP);
• DPA assistants ensuring the monitoring of a part of the fleet and its operations (for example an assistant
DPA for the tankers, another for bulk carriers etc);and
• ISM secretaries ensuring the follow-up of the records and especially the updating of the SMS documentation.

All these people will be designated by the company and their tasks and responsibilities defined.

20.6 ACTIVITIES OF AN ISM STRUCTURE

The tasks assigned to the ISM structure concern:

• monitoring of the safety and prevention of pollution aspects of the operations of each ship;
• liaison with the persons on board;
• access to the highest level of the company (the responsible person); and
• control of the means and the support brought by the company for each ship following their needs or their
requests.

Monitoring of Activities

To ensure such a monitoring the ISM structure has in its possession the following tools:
• Knowledge of ships’ rotations and operations and possible modifications (change of destination, special
operations etc).
• Knowledge of the loading plans (stability/dangerous goods).
• Knowledge of damage and accidents and the corresponding reports.
• Knowledge of the technical programs of stop-over or repairs.
• Knowledge and analyses of ships’ procedures concerning the safety and pollution aspects and follow-up of
possible amendments.
• Knowledge and analyses of the shipboard maintenance program and periodical tests and follow-up of their
realization.
• Knowledge and analyses of ships’ purchase and work requests and follow-up of their realization.
• Knowledge of the crew members’ tickets and certificates and follow-up of their revalidation.
• Knowledge of emergencies drills and exercises program on board and ashore and follow-up of possible
actions for improvement.
• Knowledge of suggestions or corrective actions suggested by the personnel within the framework of the
experience feedback.
• Knowledge of the reviews of the application of the SMS on board their ships by captains.

In order to be able to ensure such a monitoring, the system will have to make sure the information of DPA, i.e. the
DPA (or ISM structure) is obligatorily in a copy of the documents corresponding to these activities.

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Liaison with the Persons Onboard

In order to ensure this connection, the telephone number (or any other means of liaison such as e-mail) of the
designated person will have to be known by all and if possible to be posted in the common areas ashore and on
board.

Note that to avoid the DPA becoming the “tears office”, it is necessary to ensure that the crews are informed on
the reason of this method of communication special to the ISM Code.

Liaison with the persons on board as well as the monitoring of the DPA is also ensured by frequent visits of the
DPA on board ships.

The specific function of liaison of the DPA with the top management must exist and the link thus established
between the persons on board and the highest level of the hierarchy is one of the keys of good operation of the
system. This special liaison will thus be materialized in the flow chart of the company and the objective evidence of
this privileged liaison will have to be presented as follows:

• Relevant declaration of the general manager and his personal telephone number known by the DPA.
• Ensure support of the shore-services and appropriate resources to the ships when necessary.
• By being informed of the requests of the ships relating to safety, the DPA must be capable of judging if these
requests are justified. A deep knowledge of the operations and equipment of the ships themselves is thus
essential. For the support to the ships, consider the assistance the captain may require such as safety
information, assistance in emergency etc.

Operation of the SMS

The operation of the SMS is not obligatorily ensured by the ISM structure. Indeed on the one hand, the
traditional safety departments of the company continue to play their role. The HSE department or quite simply
one superintendent is in charge of safety and in addition each manager ensures the application of the SMS in his
department.

The role of the DPA is, therefore, that of a supervisor monitoring the operation of the SMS, and this monitoring
will mainly take the form of internal audits and the analysis of the captain’s reviews. Finally, this analysis of the
operation of the SMS by the DPA will quite naturally enable him to prepare the periodical management review.

The updating of the SMS documentation (re-examined procedures, corrections, and additions) could naturally be
entrusted to the DPA mainly in small and medium size companies.

In large companies, where a HSE department exists, the DPA will have to be informed of the modifications made
to the SMS documents and their application.

20.7 CONCLUSION

Thus structured the SMS must function to the satisfaction of the certification auditors.

20.8 SELF ASSESSMENT QUESTIONNAIRE

1-What are the main arrangements to be installed in the Company ashore?

2- Could you list the knowledge to be maintained by the ISM structure?
3- Could you list the four mandatory responsibilities of a DPA ?
4- Who can be the Responsible Person?

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21. OPERATION OF THE SMS ON BOARD

Learning Outcome

After successfully completing this chapter, you will:

• be able to install and start the safety management system on board a ship.

This chapter addresses the question of setting up all the practical elements of the SMS on board.

21.1 POSTING

Posting of the various company policies signed by the general manager, namely:

• Company or group hygiene safety environment and security policy (HSES).

• Company drug and alcohol policy.

And possibly:
• Company smoking policy.
• Environment protection and waste management policy.

These policies will be posted on board, preferably framed, in the captain’s or access gangway for visitors or
customers information. They will be posted of course in the common areas for officers and crew.

Please note the quality of this posting will be evaluated by the certification auditors. It is the first element we look
at when arriving at the company headquarters or while boarding the ship.

21.2 SITE OF THE SMS DOCUMENTATION

The specific documentation of the SMS must be at the disposal of all the members of the crew and not only for
the captain and his officers.

A dedicated library, accessible to everybody, will have to be installed. In order to prove that the members of the
crew have access to these documents it is wise to carry out an access procedure – free loan with recording of the
name of the borrower and starting/return dates.

A signature of awareness is required for all the members of the crew.

In order to limit the risks of having non up-to-date SMS documents in circulation, limit the number of controlled
documents.

In the beginning, however, it will be difficult for all the employees and members of the crew to consult the few
specimens in service. Provide copies in black and white (i.e. not controlled) carrying the stamp: not controlled copy
or for information only.

Lastly, the signature of awareness is always obligatorily on the controlled document.

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21.3 SAFETY MANAGEMENT MANUAL

It must be signed by the company management and authors, persons who approve or verify, and finally by the
recipient (head of department or captain).

Only one controlled copy by department or ship and the procedure of awareness will have to prove that all the
members of the personnel can consult it.

No handwritten mention may be affixed on the pages of this document, no copy can be carried out without the
authorization of the company (the corresponding warning appears at the head of the document).

Observations or questions will be the subject of ISM/SMS meetings.

21.4 EMERGENCY SITUATIONS MANUAL

This includes the ship’s contingency plan with the collective roles, the checklists, the safety cards of the
compartments or zones at risks (see Chapters 8 and 11) and downgraded situations.

This document is an operational document: a specimen is always at the disposal of the officer on watch on the
bridge and it is advised to provide another copy for the engine control room.

A reserve and/or reference document will be available in the ISM library.

Please note that if the operations in degraded situations are too numerous due to the complexity of the ship, a
special document of downgraded conditions could be prepared for bridge/deck and engine (particularly on special
ships or liners/ferries)

21.5 FAMILIARISATION MANUAL

This includes information on the SMS and the safety of the ship as well as the general captain’s instructions
concerning this familiarization and the tutorial procedure.

This document could be published in several copies: The proof of awareness is done on the document itself or via
the “recording of familiarization” form.

21.6 OPERATIONS MANUAL

It includes all the operations of the ship (procedure and checklist) in connection with safety and the environment,
namely:

• departure / arrival;
• passage planning;
• loading / unloading;
• bunkering / transfer;
• ballasting;
• critical work (work permit); and
• routine patrols for deck, cargo, accommodations, cool chambers and kitchen etc.

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21.7 DECK MAINTENANCE REGISTER

This should be kept in the office of the duty officer or on the bridge.

Planning of maintenance and records (dates) of the periodical tests and inspection and maintenance actions of the
equipment or elements of the ship concerning: navigation, radio, cargo operation, safety or administrative.

Note that the critical elements are located as well as specific measures to reinforce their reliability.

A historical register is always linked to this register. This can be presented in the form of a history by apparatus or
as a group of intervention cards. It is wise to use a checklist of the ship’s certificates to avoid forgetting a renewal
(very frequent).

21.8 ENGINE MAINTENANCE REGISTER

This should be kept with the chief engineer or in the ECR.

This has the same role as the preceding document. Control and periodical tests of critical equipment or systems.
Maintenance and revision of the other equipment or elements of the ship under engineers’ responsibility and the
historical register. This could be arranged by apparatus or group of apparatuses (MP, GE, separators, SW pumps,
FW pumps, air conditioning, freezing installation etc).

21.9 ENVIRONMENT MANUAL

This manual includes:

• the management plan for refuse and waste with the treatment or removal register;
• the management plan for ballasting; and
• the management plan for grey and black water.

21.10 THE OTHER SHIP’S OFFICIAL DOCUMENTS

will be checked:

• Bridge, radio and machine logbooks.

• Handover register for the officers on watch (bridge and engine).
• SOLAS survival training manual.
• Stability booklet.
• Cargo securing manual (as appropriate).
• Oil record book.
• Safety management activities:
- planning and reports of meetings,
- exercises and drills.
• Official ship’s documents.
• STCW certificates of all the crew members (original stocked by the captain).
• Continuous training plan (individual recording of the safety activities).
• Passengers announcement manual.
• Other decision-making aids for the captain.

21.11 SELF ASSESSMENT QUESTIONNAIRE

1- Which are the posters to be posted on board?

2- How to make the SMS documents accessible?
3- List the essential SMS documents to be on board?
4- How to ensure the up-dating of SMS documentation ?

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22. ISM TRAINING OF PERSONNEL

Learning Outcome

After successfully completing this chapter, you will:

• be able to install the training of the entire personnel of the company.

22.1 INTRODUCTION TO ISM SECTIONS 6.2 AND 6.6 OF THE CODE

On one hand the captain must “be fully conversant with the company’s SMS” and on the other hand “the personnel
of the ship must receive relevant information on the SMS in language or languages understood by them”.

In order to satisfy these requirements, one must organize the complete training of the captain and his substitutes,
as well as a lesser training for the remainder of the personnel according to their responsibilities in the system.

Finally, in order to prepare the company to carry out good quality ISM internal audits, I suggest that volunteers
within the company are trained as ISM internal auditors.

22.2 The IMO 2007 circulars have at last focalized on the ISM training:
-On the one hand §8 of MSC-MEPC.7/Circ.5 recommend that “all personnel involved in the Company’s SMS have
an adequate understanding of relevant rules, regulations, codes and guidelines. The company should ensure that all
personnel have the qualifications, training and experience that may be required in support of the SMS”

As you can see this is partly the §6.4 of the ISM code. The last sentence which talk about training will, in my
opinion, introduced later in this part of the ISM code.
-On the other hand, the training recommended in the MSC-MEPC.7/Circ.6 § 3, is quite clear but still…
recommended!
In conclusion, the specific training on ISM of the Designated Person Ashore is just starting in our industry but
should become mandatory in some years!

Any way, the author believes that four training levels are necessary:

• Level 0
• Level 1
• Level 2
• Level 3
And a specific training for the DPA which includes level 2 and 3.

22.3 LEVEL 0

Short information on the existence of a SMS in the company and on board the ships. Information for all the
personnel of the company, including the visitors, ashore as onboard, in the languages understood by them.

This information can be posted at the same time as the other company’s policies and be the subject of information
during the welcome meeting of the new personnel. On offshore units, this information can be carried out during
the obligatory induction meeting.

Example of Level 0 Text

You have just received a minimum familiarization on offshore safety. This familiarization is one of the measures for
prevention of marine accidents required by the safety management system set up by the company in the bases and on
board offshore units.

It is an organization of safety in accordance with a code made compulsory for most of the ships of the world:The ISM Code
(International Safety Management Code) elaborated by IMO (International Maritime Organization) an agency of the UN
(United Nations).

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This code is made up, in the company, as well ashore as on board each unit, of a thorough management of human resources
including in particular the definition of the responsibilities for everybody, the preparation to respond to emergencies, the
continuous training of the personnel and the maintenance of the units and their equipment, in order to establish a culture
for reduction of the risks related to our activities and relating to the safety of the crew, the units and the prevention of
pollution.

Finally, in order to prevent that a simple malfunction in the chain of decision and orders of the company can lead to an
accident, our general manager has designated captain SOSO (DPA-designated person shore) to supervise the application of
our safety policy and to ensure the connection between the company and the persons onboard when necessary.

22.3 LEVEL 1

Training in an approximately one hour meeting carried out for the permanent personnel ashore as well as on
board.

This training can be given during a routine safety training session in the form of video projection in the various
languages of the personnel.

It is a simple and clear presentation:

• Reasons and causes of the ISM Code;

• Our SMS;
• Necessity of certification; and
• Requirements of the code.

22.4 LEVEL 2

Complementary ISM/SMS training which may be composed of the lessons of this module in Chapters 1 to 14 and
completed by examples of application in the company’s SMS. This training can be given in the form of a course of
20 hours.

Training of the persons in charge, at present and or in the future, of the application of the SMS in the company.
Designated person and heads of departments ashore, captains and heads of departments on board, as well as the
other officers called soon to fulfill the functions of heads of departments.

Such a course relates to the study of the requirements of the ISM and their application within the company and on
board.

22.5 LEVEL 3

Complementary training to level 2: training of internal auditors

Specialized training of the internal ISM auditors in the form of six hours of theory on ISM internal audit techniques
and a practice of the ISM internal audit (six hours approximately).

This special training on ISM audit is considered to be essential for the quality of future internal audits. Such
training is delivered by classification societies for their own auditors but this is training on external audit
techniques which as we have seen is quite different from the internal audit.

However, it is possible to carry out this special training within the company if it has good teachers.

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22.6 CONCLUSION

ISM training is not very frequent. However, there are some schools which offer courses. Level 1 can be given
on board. Levels 2 and 3 can be given only during specialized seminars, for example, at the time of a visit to the
headquarters or in the training centre of the company if one exists.

22.7 SELF ASSESSMENT QUESTIONNAIRE

1- Is the ISM training mandatory?

2- How many levels of training have we fixed?
3- How long to train an internal auditor?
4- Do you think the ISM training needs to become mandatory?

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23. INTERNAL ASSESSMENT AND PRESENTATION FOR

CERTIFICATION
Learning Outcome

After successfully completing this chapter, you will:

• be able to carry out a mock audit and present the company and ships to ISM
certification.

23.1 SUBJECT

To define the methods for the internal audit ashore and on board necessary for the preparation for certification.

One audit carried out by an external consultant will be closer to the certification “mock audit”; it will be a
particular internal audit carried out by a professional using his own methods and checklists.

The audit reports of the internal audit of the company headquarters and one internal audit by type of ship will
be required by the certification auditors.

23.2 INTERNAL AUDIT OF THE COMPANY HEADQUARTERS

Pre-audit meeting with the representative of the company top management and the ISM designated person ashore.

Exposure of methods of audit: determination of objective evidence for ISM conformity of the system by the
study of the documents and interviews with the persons in charge of company departments.

Checking of the Documents

All the documents of the system must be presented: we are looking for the proof that all the requirements of
the code are covered.

Each item will be analyzed in: presentation, contents and possibilities of achievement (official policy, procedures,
checklists, analyses, action plans etc).

Note that the table of conformity with ISM Code as previously presented in this part of the course could be used.

Organization of the Company

The letter of assignment of the DPA must be presented; it has to be signed by the general manager. The flow
chart of the company will be studied to check if the DPA can play his role of:

• Monitoring Company Activities Related to Safety and the Environmental Protection

All ship planning, loading forecasts, crew modifications, purchase orders for material or works etc… to be
addressed directly or in copy to the DPA.

• Link between Personnel on Board / Management

The flow chart must show this direct and easy link towards the Responsible Person at the Board level.

• Operation of the SMS

List of internal auditors, training of personnel, planning of visits, inspections and internal audits, captains’
and management reviews, analysis of accidents and near-misses or feedback, planning of exercises on the ships
with or without participation of the company crisis cell.

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Checking of the Documents

The documents need to be checked as follows:

• Presence of all ships’ SMS documents.

• Up to date status of all SMS documents.
• Analysis of corrections made since the creation date.
• Checking of the awareness of all the heads of service.
• Follow-up of the various regulations: flag, class, PSC.
• Checking of reports on visits, inspections, audits.
• Thorough analysis of the operation of the experience feedback system with particular attention to the
delays of transmission and analysis of REX cards.

Operation of the Regulation Watch

Person in charge and proof of subscription or supply process of documents and/or reception of information
from the flag administration and IMO.

Training

The company will be asked for objective evidence of analysis for the needs for training and actions undertaken.

Organization of Recruitment and Familiarization

This includes the personnel ashore and on board: recruitment procedure, contracts with crewing agents etc,
the procedure of control for medical fitness of the crew members, the control of application of drug and
alcohol policy and the written instructions to the shipmasters for decision-making concerning safety.

Restitution of Audit

During the restitution we will expose only the non-conformities or observations and the corrective measures
will be elaborated between the consultant and the company representative and/or the DPA.

Audit Report

The corresponding report will be communicated to the ships.

23.3 INTERNAL AUDIT OF A SHIP

Pre-audit with the Captain and the Chief Engineer

Exposure of audit methods: determination of objective evidence for operation of the system by the study
of the documents, interview of the crew members or the observation of the ship’s activities related to safety or
environmental protection.

Checking of the Documents

All the shipboard documents of the SMS must be presented to the auditors to check that they are up-to-date
according to the company procedure, and the checking of the records of safety activities

Note that it is to check the documents, to prove that the activities are carried out. A more complete analysis
can be made and the auditors can ask for the organization of a meeting, a safety exercise or to be present
during a commercial activity.

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Safety Meetings

Check the frequency, outline of the subjects to be covered, search for objective evidence of the captain’s action
in motivating and training his crew.

Emergency Drills and Exercises

Check the frequency, topics and quality of the reports, debriefing, proposals, safety cards, conformity and
adequacy of the procedures, qualification of personnel and the suitability of the material used.

Notification of Irregularities and Experience Feedback

Check the volume/transit of the cards. In case of doubt about the notification of accidents, incidents or
near-misses (for example no near-miss at all); the auditor will be able to seek in the logbooks and with the crew
members the possibility of irregularities or incidents not having been notified to the company.

Maintenance Registers for Bridge / Deck and Engine

The checklist should be as follows:

• Check the good condition of the maintenance registers. Check presence of a drafting list for proposition
of repairs to be done during the next dry-docking. Random checking of the activities listed by the
company, for example: visits of hull, double bottoms, ballasts, cofferdams etc. Check that each maintenance
task or test is carried out as it was envisaged. In the event of modifications, seek the crews’ willingness to
propose this correction to the company via REX system.

• Officers hand-over procedure: look for the presence of the hand-over log books – literature about these
hand-overs.

• Operations of familiarization: checking of the conformity of this activity with the company procedure.
Study existing documents of a precise case of a newly embarked crew member.

• Captain’s and chief engineer’s standing orders: check the presence of “STCW Orders” on the bridge and in
the engine control room and the awareness of the officers.

• Evaluation of the particular orders and additional instructions of the captain and chief engineer according
to circumstances: safety during dry docking for example.

• Evaluation of the observation of the company’s instructions for the captain’s relief.

• Organization of work: checking of the posting of the crew working schedules and conformity with the
company instructions.

• Checking of tests of knowledge carried out by the Master or the officers during the safety meetings or
drills: checking of records.

• Management plan for refuse and waste: checking of the records and signature of the Master

• Random checking of in-service checklists for bunkers, entry in enclosed spaces, departure/arrival etc.

• Checking of state of realization of the action plans issued after a captain’s review, a former audit, a meeting
or exercise etc.

• Checking that the requirements issued after the various visits have been taken into account (follow-up of
flag state, port, class visits).

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Note that the presence and the accessibility of the following documents will also be checked: SOPEP and SOLAS
training manual.

The up-to-date state of all the documents, including the bridge documents (charts) will also be checked (no out-
of-date documents in circulation for example).

Interviews of the Crew Members

The members of the crew will be interviewed as follows:

Captain

• Evaluation of ISM/SMS knowledge of the captain:

Objectives, tools and responsibility in the operation of the SMS.
• Evaluation of the captain’s motivation:
Observation of the company procedures and participation in the improvement of the system.
• Assessment of captain’s actions in motivation his crew:
Organization of safety meeting by himself for example.

The following questions will have to be asked to the captain:

• Do you think that your crew is sufficiently prepared to answer effectively all the emergencies which were
identified by the company?

• Do you think you take an effective part in the evolution of the company’s SMS for example by issuing your
opinion on the proposed procedures?

Chief Engineer

• Evaluation of ISM/SMS knowledge of the chief engineer.

• Evaluation of his motivation.
• Evaluation of the level of observation of the company procedures and his participation in the improvement
of the system (technical cards – procedures for downgraded mode etc).

Chief Officer

• Evaluation of ISM/SMS knowledge and motivation.

• Level of comprehension of the captain’s instructions.
• Level of English.

Officers, Mates and Engineers

• Evaluation of ISM/SMS knowledge and motivation.

• Level of comprehension of the captain’s and chief engineer’s orders.
• Level of English.

Boatswains and Able Seamen

• Evaluation of SMS knowledge and motivation.

• Evaluation of comprehension of heads of department orders.
• Level in English language.

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Cook and Steward

• Evaluation of SMS knowledge and motivation.

• Knowledge/evaluation of the risks related to their job.
• English level.

Note that in each interview an evaluation to make sure that the risks concerning the tasks have been taken into
account will be required.

The following question will have to be asked to all the crew members:

• Do you think that the ISM Code will be able, in the long term, to improve safety in the maritime transport?

Organization of the Results of Checks and Interviews

All the irregularities must be noted in writing for presentation to the captain in the meeting of pre-report. Each
irregularity of the company instructions should be the object of non-conformity or observation (see audit section).

Results of the Interview

Each interview is the object of comments to be analyzed jointly by the audit team and communicated to the
captain.

Observations could be made on the levels of knowledge and motivation of the crew members.

At the end of the checking operations, the audit team meets in order to prepare, if possible, a pre-report which is
presented to the captain (orally or written).

The comments of the captain and the representatives of the company are taken into account in particular on the
completion dates of the agreed corrective actions.

The official audit report is then presented or dispatched to the captain accompanied by the REX cards or action
plans for communication to his crew.

23.4 CONCLUSION

It is wise to have practiced one internal audit by ship before the initial certification audits. The definite corrective
actions during these audits should be in the process of treatment and the evidence of achievement or closure have
to be presented: it is good to present a brief complete summary and progress report of the definite corrective
actions.

23.5 SELF ASSESSMENT QUESTIONNAIRE

1- How to start an internal audit?

2- What kind of support do you need for such an audit?
3- As an internal auditor can you propose corrective actions to the DPA or the Captain?

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24. CONTINUOUS COMPLIANCE ASSESSMENT

Learning Outcome

After successfully completing this chapter, you will:

• be able to propose a system for the continuous assessment of the SMS.

The continuous assessment of a SMS is internally ensured by:

• visits;
• inspections;
• internal audits;
• periodic reviews of the captains; and
• periodic reviews of the management.

All the above we have already studied including the last amendments of the code as well as the recommendations
for reviewing the SMS set up in the corresponding IMO circular (MSC-MEPC.7/Circ.5).

24.1 MONITORING AND WEEKLY REVIEW

There are, however, other tools for evaluation, indeed the monitoring of the safety activities and environmental
protection carried out by the designated person ashore and the day to day analysis of the experience feedback
cards enables him to ensure a continuous survey.

Sometimes the author suggests the companies set up a weekly review of the operation of the SMS by the DPA: The
results are then communicated to all managers including the captains.

24.2 SHIPBOARD REVIEW

On large ships or in the offshore industry, captains or offshore installation managers have been known to carry out
a weekly review of the operation of the SMS on board their ship or offshore unit. This review is made during a
heads of department safety meeting.

A report is dispatched to the DPA in order to facilitate its monitoring.

This solution is recommended for:

• Large passenger ships where safety events are numerous.
• Tramping companies disseminated all around the world.
• Management companies which have many ships of all types to manage.

24.3 CONCLUSION

For ships with frequent port calls, a weekly review should avoid any oversight which could bring fines or retention in the port.

For large cruise ships, ferries or offshore units the safety activities are so numerous that the weekly follow-up is obligatory.

For other ships, a two or three monthly review should be sufficient unless communication with the headquarters is
not easy.

It is, nevertheless, recommended to prepare the port state control with a conformity checklist. This leads to a
rapid SMS review.

24.4 SELF ASSESSMENT QUESTIONNAIRE

1- What means continuous compliance?

2- Who could be in charge of this assessment on board and ashore?

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25. HOW TO PRESENT YOUR SYSTEM TO THE

POSSIBLE CUSTOMER (STARTING COMPANY)
Learning Outcome

After successfully completing this chapter, you will:

• be able to propose your consultancy to companies for initial implementation.

The following proposition must be prepared and mailed to the starting company.

25.1 FOREWORD

A shipping company could encounter various major risks when carrying out its trade of transport by sea:

• risks to the health and life of the passengers and/or the crew;
• risks to the cargo:
• risks of damage or total loss of the ship;
• risks of pollution to the environment and compensation for the damage;
• risks for the company’s image; and
• risks of losing its customers.

In order to decrease these risks and their consequences, the International Maritime Organization (IMO) has
worked out a code of management of safety in the companies and on board ships: the ISM Code (International
Safety Management Code).

25.2 ISM CERTIFICATION

The ISM Code was made compulsory by its introduction into the SOLAS Convention which is mandatory.
Different deadlines were fixed to leave time for the shipping companies to set up their system and to the states to
certify the ships under their flag.

1 July 98 was the deadline for the ships noted “at risk”: passenger ships, bulk carriers, gas-oil or chemical tankers, all
carrying out international navigation.

For all the other cargo ships or mobile offshore drilling units of a gross tonnage equal or higher than 500 UMS
carrying out international navigation, the deadline was 1 July 2002.

A safety management system, called SMS, is a complex process to set up and experience proves that it takes a
minimum period from 10 to 12 months, including creation, implementation, the first audits and reviews, to be able
to present it to certification with any chances of success.

The transport administration recommends companies to set up a safety management system as soon as possible
so they are ready to certify them after a minimum obligatory operation period of three months.

In addition, as the ISM Code can apply to all ships, IMO recommends governments to include already in their program
the certification of ships of a tonnage between 150 and 500 UMS (SOLAS Conference of 94, Resolution 3).

25.3 WHY A CONSULTANT?

It is an illusion to believe oneself capable of implementing, without problems, a safety management system in one’s
own company.

The consultant is a technician of the ISM Code who will be present to tally and translate the problems of the
company, always specific: a SMS copied from an equivalent company can never be appropriate. Moreover, the job
of the consultant is to transmit his knowledge to the “customer’s system” so that he can adapt it, an underlying
condition to the success of the operation.

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It will also show to the company managers that the installation of the SMS, although mandatory, could be a
productive investment particularly through a better management of the spare parts. He will ensure a total
confidentiality to the company in this domain which is always very sensitive.

Finally, he is the passport for the success of the job by putting his entire competence at the service of the company.

25.4 CHARACTERISTICS OF ISM CERTIFICATION

SOLAS Chapter IX and Resolution A.1022

ISM certification is mandatory and is delivered by the flag state (or an organization recognized by it). The ISM
certificates can be controlled at any time and the safety management system can be checked by a state: in a port of
call at the time of an unscheduled visit within the port state control (PSC of the local MOU).

In their pursuit against false certificates and “phoney” SMS, certain states have warned the users of their ports that
they will be very vigilant on the presence of the certificates firstly and then on the real value of the management of
safety carried out on board (the United States and The Netherlands in particular).

This certification brings the delivery of:

(a) A document of compliance (DOC) with the ISM Code for the safety management system of the company
for the types of ships used.

Note that a company recently created, or a new activity in the company on new types of ships, is the subject of an
interim certificate which will have to be confirmed within a maximum of 12 months. The document of compliance
is valid for five years subject to an annual control.

(b) A safety management certificate (SMC) for each ship.

Note that the introduction of a new ship into the fleet (new ship or second hand) will be delivered with an interim
certificate valid for a maximum of six months.

The SMC delivered to a ship is valid for five years subject to an intermediate control within 30 months.

When the safety management system is in place and works onboard ships, but requires important modifications
or evolutions, the administration can issue interim certificate valid for one year. These certificates will be renewed
then for five years only when all non-conformities are closed.

25.5 PRACTICE OF THE CERTIFICATION

The ISM certification includes the installation of a safety management system (an SMS) which includes:

• The Drafting of Documents

- The company management manual (CMM), which describes how the company intends to conform with the
requirements of the ISM Code; the procedures required at company level and the company’s instructions to
the captains.

- The shipboard management manual (SMM), which includes the instructions, the operational shipboard
procedures and the checklists for tests or inspections in manuals.

- The company forms of recording of the specific activities.

- The database related to the SMS.

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• The Staff Training

- Managers, employees, officers, seamen.

- A general training for all: conferences ashore, on board and manuals.

- A special training for the designated persons for ISM, the internal auditors and for the Masters.

• The Implementation of the System

The implementation of the system, which includes:

- Follow-up of the company and ship’s procedures or instructions.

- The use of the shipboard checklists.

- The use of the forms and company or external database.

• The Operation of the SMS

The operation of the SMS, which must prove that:

- The actions undertaken are recorded and under control.

- The non-conformities are notified and analyzed.

- Improvements are already planned.

The carrying out of mock audits in the company and each ship which must simulate closely the examination to be
passed by all.

25.6 PHILOSOPHY OF OUR CONSULTANCY

The ISM Code is mainly intended to introduce, on an international basis, a new safety culture in the maritime
world.

To modify a safety culture in a company and on board ships, necessary time is required. Therefore, we spread
our days of consultancy over six months approximately, by periods of 10 days per month for a company having its
headquarters in Europe, four to five periods of 10 days for a company abroad.

Our method also consists of respecting to a maximum the existing culture in the company for obvious reasons, and
also so that the message passes more easily, particularly to the crews.

The SMS proposed is the result of an already long experience in the field and which benefits from the last national
and international recommendations.

We ensure, moreover, a practical training (included in our proposal) for: the management, the deputy managers
concerned and especially the crews. The message is conveyed better when it comes from seafarers like themselves.

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25.7 DETAILS OF CONSULTANCY

For a company of less than 10 ships, the assistance proposed is as follows:

• Initial Presentation

Initial presentation of the philosophy and methodology of assistance for the implementation of the SMS in the
company and on its ships.

• Estimated Duration

One day with two persons.

Operation suggested for a first approach, and finalized by the drafting of a contract after discussions based on
desiderata of the company.

1st Phase

(a) Assistance in the development of a safety management system adapted to the company, i.e:

- definition of a safety policy with objectives and means;

- development of a line of responsibilities to achieve these goals;

- development of a safety management in conformity with the code: designation of a person in accordance
with the Section 4 of the ISM Code;

- installation of an internal structure for controls and checks: practical organization of the audits; and

- organization of the communication structure shore-ships: who, how, when?

(b) Assistance in the development of the documentation in English:

- company management manual (CMM): company procedures, instructions, databases and forms;

- shipboard management manual (SMM), (one per ship): shipboard instructions and procedures, checklists
and shipboard databases: emergency situations manual, operation manual, maintenance manual, environment
management manual: waste and ballast company forms of recording;

- familiarization manual; and

- SMS training manual.

Estimated duration of the first phase: approximately 15 days of consultancy.

Note: the company to provide a secretary on request and provision of a PC with Windows XP on site.

2nd Phase

(a) On one hand, such a safety management system requires to be launched and followed in its beginnings by a specialist, so:

- assistance for the installation in the company and on board ships: assistance to the management, the
designated person and the captains;

- assistance for the realization of the operational follow-up: internal audits, captain’s and management reviews;
and

- analysis of feedback, development of action plans etc.

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(b) On the other hand, the success of such a system rests on the imperative elements which form part of the
intervention, namely: training, motivation of the management and the operators ashore and the crews, the captains
in particular.

Estimated duration of the second phase: 15 to 20 days of consultancy, to be adapted according to each individual case.

3rd Phase

(a) Mock audits of preparation to certification: program, realization and general analyses for company
(headquarters) and ships’ audits.

(b) Assistance during certification audits and assistance in the development of the possible necessary corrective
actions.

Estimated duration of the third phase: 15 to 20 days of consultancy, to be adapted according to the number of
ships.

Note that a secretariat service will have to be provided on request for formatting and publication of documents.

25.8 COMMERCIAL CONDITIONS

G-2528 We propose to carry out the above proposals in the following economic conditions:

• Price
- Fees – US $ before tax per day of consultancy, ashore or on board ships.
- Travel costs – all inherent costs with proof, return travels and/or possible waiting on site and on board are
in addition to the days of consultancy, they will be invoiced to 60% of the daily rate, i.e. US $ before tax per day.
- Invoicing: on monthly basis, 25th of the month.
- Payments: by check or transfer at the latest 30 days after reception of invoice.

• Estimated Duration
- Initial evaluation: one day with two persons.
- Assistance on creation, operation and preparation to certification:
- 45 to 55 days over a period of six months, flexible as follows:
- 25 to 30 days approximately on site, in the headquarters or on board ships;
- 20 to 25 days approximately of work for drafting and synthesis at our office.
Note that this duration is only an estimate and remains flexible according to the individual situation.

25.9 SELF ASSESSMENT QUESTIONNAIRE

1- What will be the philosophy of your consultancy?

2- How many phases to elaborate, implement and verify a SMS?

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26. INTERNAL ASSESSMENT AUDITS OF A SAFETY

MANAGEMENT SYSTEM
Learning Outcome

After successfully completing this chapter, you will be able to propose an assessment audit
to a company.

The following proposition must be prepared and mailed to the starting company.

26.1 FOREWORD

On one hand:

• Your company has committed itself very early to safety and quality. You are one of those companies, pioneers
in ISO certification, then ISM, via the products proposed by the major classification societies.

• Your ISO certification was carried out at the beginning of the 1990s and the ISM certification as soon as
possible afterwards for periods of five years validity. Your ISM certificates thus expire soon and the audits of
renewal are already planned.

On the other hand:

• Your verification system is running well and your internal audits follow one another without too many
problems: in short, the system is humming now.

26.2 OPERATION OF YOUR SYSTEM

On one hand:

• The first systems set up were mainly of ISO origin because...the ISM Code did not exist then. The maritime
world recognizes today you were a pioneer in the improvement of maritime safety and environmental
protection. However, the experience gained in the operation of a SMS and its normal evolution may make
you feel perhaps today the need for a “lifting” despite all the improvements made during the past years with
the observations of your IACS partner.

On the other hand:

• In the sectors to audit some, more commonplace than others, are not as well audited as they should be: the
reports are flat and, except for some small details, we could conclude each time with “nothing to report”.
In spite of the fact that the system is running smoothly, you may feel that an external point of view could be
necessary in sectors inaccessible to your normal auditors, e.g. top management, senior captains or chief
engineers.

26.3 COULD YOUR SMS RUN BETTER?

Yes, because:

• The first procedures have dug too far for fear of forgetting something...whereas the simpler a procedure is, the
more effective it is.

• The first instructions to the captains were far too much like nautical school books...whereas the code requires
only the application of the mandatory rules and regulations, which are in possession of the captains on board
and well known by everybody.

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• The first checklists were filled up conscientiously and have grown too large, whereas the commercial aviation
principle of plastic-coated checklists creates better records and is in conformity with the ISM Code.

• The original documentation became too elaborate and was not really well accepted by the crews whereas
perhaps it would be enough to have a company management manual giving clear instructions to the captains
for the application of the company policy in order to build a shipboard management manual: collection of
shipboard procedures and checklists using to the maximum the already existing safety culture in the company
and on board.

• The requirement of notification of non-conformities, accidents and near-misses perhaps functions but it is still
not clear to the crews who cannot see very well the goal whereas one simple feedback system well organized
would motivate all the crew, from the captain to the cook, and would prove to all that the system functions.

• The first SMSs have completely or partly forgotten the management of risks in this trade. This is, however, one
of the objectives of the code whereas a systematic study of the risks for any operation is one of the bases of
the prevention of accidents and a present day concern and uppermost in the minds of our sailors.

• The identification of the critical equipment or systems required by the code was often slapdash, whereas only
a study of the operations in a degraded mode is capable of bringing answers to the questions which your
crews ask themselves as to the real utility of the code.

• The code has always envisaged training for this new management of safety and environmental protection but
not STCW, whereas an awareness and a training “on the job” by a specialist will have every chance of creating
better interest from your crews.

• The first audits were like inspections or vetting done by persons too inexperienced in ISM, whereas an audit
well targeted, carried out by a specialist will give you better information on the actions to be undertaken to
improve your system.

26.4 WHY CALL AN EXTERNAL CONSULTANT?

The role of a certification auditor is not to require modifications to a SMS which evolves slightly. His observations
will help you perhaps a little whereas the role of the consultant is to bring advice for its improvement.

As a specialist and with the advantage of an external point of view, he will be able to propose solutions for
the simplification and working order of your system during one assessment audit which will take several days
according to the size of your company.

He will then be able, if you wish, to help you on some points...to finally “transmit the message” to the persons
ashore as well as on board.

As a former seaman himself, he can sail with the crew, he will be certainly better listened to by your crews, who
are too busy during the port call and who are not very interested in listening to speeches during their vacation
rest.

With a title of expert and above all completely independent of the company, he will certainly be listened to and
this may be the opening you have been waiting for.

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26.5 PROCESS

For One Audit of General Assessment

Following a meeting (traveling expenses to be divided by each party) or a simple exchange of mail, one assessment
audit could be realized in a few days in the following way:

• One or two days for the headquarters: documents review and audits of the persons in charge: managers and
ISM structure.
• One or two days of audits for, at least, two of your ships.
• One day of drafting and audit restitution.
• A full report within a fortnight.

That is approximately five full days of consultancy.

For One Specific Audit at the Headquarters or On Board a Ship

Two days of consultancy for the main office or two days of consultancy for a ship according to the circumstances.

26.6 FEES

Consultant fees – US $ per day – transport towards the office or the ships and the standby days are invoiced at
50% + traveling expenses (trips, food and hotels).

Note – international flights: business class; domestic flights: coach class

26.7 SELF ASSESSMENT QUESTIONNAIRE

1- What is the main objective of an assessment audit?

2- What is the approximate duration of an assessment audit?

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27. HOW TO MEASURE THE OPERATION of a SAFETY

MANAGEMENT SYSTEM and the IMPROVEMENT of THE
SAFETY CULTURE of the COMPANY
Learning Outcome

After successfully completing this chapter, you will be able to measure the level of
conformity of a Safety Management System and in addition the level of the safety culture
of the company.

27-1 INTRODUCTION

All along this module we have explained that the operation of a SMS must be assessed by internal auditors.
But for assessing something instead of subjective tools we need some objective tools which can allow us to
measure.
When being able to measure we have the possibilities after to compare following measurements on the same
criteria and deduct a progress or a decrease of the SMS.
For measuring something we need some performance criteria. These criteria can differ a little bit from one
Company to another but generally they are the same.
The elements scored can show a level of the SMS in reference of an ideal one, completely in conformity and
performing in a superior manner all the requirements of the code and the objectives of the company.
So, the level of the SMS is reflecting the level of the safety culture of the Company and its ships
IMO has already studied some grid of safety culture level.
This new chapter will propose a measurement system used during audits and reviews in order to calculate the
safety culture level and allow the Company’s managers to see the progress of the SMS.
The OCIMF has already defined some guidance to measure the company’s management system status. All member
companies are trying to measures their own system with a great number of criteria contained in the TMSA (tanker
Management and Self Assessment) which is at its 2nd edition(2008).
The Key Performance Indicators or KPI are 12:
1- Leadership and accountability
2- Recruitment and management of shore-based personnel
3- Recruitment and management of vessel personnel
4- Reliability and maintenance standards
5- Navigational safety
6- Cargo, ballast and mooring operations
7- Management of change
8- Internal incident investigation and analysis
9- Safety and health management
10- Environmental management
11- Emergency preparedness and contingency planning
12- Measurement, analysis and improvement
The level of each KPI can go from 1 to 4 and some indicators are divided in two or three parts due to the number
of indicators
The TMSA was proposed originally as a “ISM Code PLUS”. For me it is not the right word (which has been
abandoned in the 2008 version) but it is a good practical measurement system to apply and to measure the
effective implementation of the ISM Code

In conclusion, we can propose the company to use this TMSA. If the company realize that the TMSA is a little
bit too high for it, we can propose a softer measurement system which is finally able to measure and which is
implemented in a number of non-oil carrier companies.

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27-2 USE of PERFORMANCE INDICATORS

N° Performance Score
1 The company has a SOHSP 0 to 5
2 Feedback system and continuous improvement 1 to 5
3 Internal audits 1 to 5
4 Captain’s and Management reviews 1 to 5
5 Analysis of NC-incidents (including near-misses) and 1 to 5
personnel suggestions
6 Emergency preparedness and contingency plan 1 to 5
7 Internal enquiry in case of incident 0 to 5
8 Company’s Crisis cell 1 to 5
9 Continuous training 0 to 5
10 Change management 0 to 5
TOTAL

Score can be from 0 to 5 in function of the level of implementation, however some items (in red) are mandatory requirements of
the ISM Code so the minimum score is 1.
0 means doesn’t exist
1 is existing but at a minimum level state
2 is still insufficient
3 the level of implementation is acceptable
4 Level is good
5 level is excellent
The level of implementation is an objective assessment based on objective evidence (documents, registers, interviews)
This is a proposition and as I already said, items can be added as
Level of implementation of non mandatory codes and guidelines
Level of integration of safety and security
Level of implementation of a specific environmental protection system
Etc…

27-3 MEASUREMENT of a SAFETY CULTURE

Recalled in the preamble of the ISM Code, the aim of the code is to ensure Safety at Sea by improving the level of the safety
culture of all seafarers.

As for the performance indicators, to be able to measure the safety culture of ship’s crews, we need some indicators.

Some years ago in IMO we have studied this issue and 5 levels of the safety culture were proposed:

Level One: coming out of a safety culture

Level Two: Safety is managed, all items are taken into account
Level Three: Commitment of management and personnel in the improvement of safety performances is effective
Level Four: Improved standing of personnel and effective cooperation of them in management of safety
Level Five: Continuous improvement of safety in the Company and in personnel’s own lives

We can use these levels as an example for measuring the safety culture of a shipping company using our KPI precedent results.

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The grid will be as follows:

Score Safety culture level Detailed results

Inf to 6 Insufficient The conformity with the ISM code is not ensured: The company is under
a major non-conformity!
6 Minimum acceptable The SMS is just in conformity with the ISM code
7 to 10 Level One Coming out of a safety culture
10 to 20 Level Two Safety is managed all items are taken into account
20 to 30 Level Three Effective involvement of the management and personnel in the
management of safety
30 to 40 Level Four Improved standing of personnel and its cooperation in the management
of safety
40 to 50 Level Five Continuous improvement in the Company and also in the personnel’s
own lives

27-4 IN CONCLUSION

The need for “ISM plus” is mainly due to the insufficiency of the existing systems in place. In fact the ISM code includes all the
items regarded as essential by OCIMF.
I agree that the TMSA is good guidelines for the oil tanker companies and could be implemented by companies other than oil
tanker companies.

27-5 SELF ASSESSMENT QUESTIONNAIRE

1- Why the OCIMF has proposed the TMSA to its members ?

2- Is the TMSA process a kind of ISM plus ?
3- When measuring the implementation of ISM requirements, how to mark the level?
4- Why some marks must be superior to 0?

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28. HOW TO RESTART A DORMANT EXISTING SMS

Learning Outcome

After successfully completing this chapter, you will be able to:

• restart a dormant SMS.

28.1 INTRODUCTION

Many SMSs do not function as they should, especially those which were elaborated in the beginning of the ISM
Code. There is much work in perspective for us, specialized technicians, called to rescue a SMS in poor condition.

Indeed, at the time of the renewal of the ISM certificates (DOC and SMC), a SMS which may have been certified 5
years ago, but a little on the short side in conformity with the code will be delivered with many non-conformities
which it will be necessary to close quickly.

The march of time and the “almost finished” old system is catching up on companies and they will often have to
call for your services.

28.2 CAUSES OF MISFUNCTIONING

The principal causes of failure or faulty operation of a safety management system are always the same and your
action will be repeated with different clients and on various ships. These causes are as follows:

• Too complicated a system where quality and safety are mixed.

• Over-developed procedures appearing too complicated.
• Lack of checklists.
• Over-complicated double records giving useless impression of bumpf.
• Bad choice of the designated person ashore: no motivation or competence in this role.
• Incomprehension, in the entire company, of the role of the designated person: no monitoring.
• Insufficient communication between the office and the ships: very little information, no feedback.
• Internal audits carried out like inspections: no feedback, no improvement.
• Lack of motivation of the principal players of the SMS: managers, DPAs and captains.
• Absence of an operating feedback system.
• Lack of analysis of the safety drills.
• No hygiene and safety meetings.
• Confused and uncontrolled documentation.

28.3 RESTARTING OF A SMS

While having identified the causes of failure it will be easy with your training acquired here in this course to bring
about adequate remedies.

An action plan will have to be drawn up with designation of pilots and deadlines. It is advised to treat the
restarting measures like the corrective actions emitted during a traditional audit.

The principal axes of these corrective actions will certainly be the following:

• ISM training of all the participants.

• Review of the documentation.
• Practical organization of the implementation on board each ship.

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28.4 CONCLUSION

The ISM consultant has an important role to play in such a situation. With this course and a little experience, he or
she is the ideal person for:

• Ensuring ISM information.

• Ensuring the advanced training of the players of the SMS, including the training of the internal auditors.
• Reducing the documentation, improving the presentation and setting up a more simple control.
• Answering questions.
• Finally, helping the captain to motivate his crew during ISM meetings.

Note that the presence of a specialist is always accepted by the seafarers.

28.5 SELF ASSESSMENT QUESTIONNAIRE

1- What is a dormant SMS?

2- Could you list the main deficiencies?
3- Could you list the possible corrective actions to restart such a system?

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29. THEORETICAL EFFICIENCY OF THE ISM CODE

Learning Outcomes

After successfully completing this chapter, you will be able to understand:

• the intended efficiency of the ISM Code; and
• the main problems encountered today affecting its effectiveness.

Of course, we assume that the SMS was certified in conformity with the ISM Code by an entity which could be the
flag administration or a competent organization recognized by it (classification society or others)

29.1 GENERAL

The principle of operating a SMS, as we have seen, is:

• to write what we must do;

• then do what we have written; and
• finally, record what we have just done.

While basing ourselves on this principle, we realize that the SMS is as an open book on the:

• objectives of the company;

• organization of the company; and
• responsibilities for all the players within the company.

29.2 DEFINITION OF SAFETY OBJECTIVES

There is an unquestionable advantage to see written, in black and white, that the company is resolutely in favor of human
safety and environmental protection as well as noting that it provides resources, i.e. means to achieve these goals.

The means are the men of course, but also a budget. Without a budget, the certifying auditors could well have
doubts on the achievement of the objectives.

On the other hand, it is not sufficient to stipulate that we have safety or environmental policies, but we will have to
prove that we have elaborated procedures to verify if these policies are implemented in the entire company.

29.3 ORGANISATION AND ACTIVITIES OF THE COMPANY IN THE FIELD OF SAFETY

Organization of means: operational structure of the SMS and self-checking.

29.4 ISM STRUCTURE

The large companies can often “pay” for a true parallel organization in charge of ISM control–monitoring says the
original text – which will not be without problems: the structures of internal audits are never very well accepted in
any company.

Such a structure will not be limited to control after the job, within the framework of the periodical analysis of
safety management or in the internal investigations following accidents but will have the task of “monitoring the
aspects of the exploitation of each ship and to take care that resources and a suitable support are provided”.

This structure is not required to decide nor to provide the adequate means which always remain in the hands of
the owner but to take good care that they are provided according to the needs...not exactly the same thing and
not very easy to achieve.

In addition, this structure could be in charge of the other elements of the SMS, such as: the management of
documentation and information, the management of the experience feedback and perhaps the continuous training
of the personnel.

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29.5 SELF-CHECKING

The Company organizes its self-checking on the aspects of safety and environmental protection: inspections and
audits will, of course, be required in the tasks of the ISM structure.

The inspections of the ship everyone knows: we inspect the ship herself, i.e. her state, the state of maintenance of
the equipment which makes it a means of transport “in good condition of navigability”.

These inspections are in general made by third parties: the flag administration and classification societies and also
authorities of the port of call and sometimes the charterers and the insurers (vetting).

Moreover, the company can indeed organize a program of inspections with the aim of being ready for the
preceding inspections, sometimes vital for the company, (contract of chartering) or for the ship (obtaining the
ship’s certificates).

The ISM Code does not require this kind of inspection made by the company, but they are logical in themselves
because: how can we supervise the safety aspects of the exploitation of a ship without inspecting the ship herself
and her operating equipment (navigation – safety – propulsion – equipment of exploitation etc).

Moreover, how to set up an accident prevention policy without ensuring that the equipment is in good condition.
ISM audits are less familiar.

Globally, if an inspection is relatively easy to carry out, an audit is very much more delicate. To be an internal
auditor is a real job and the international community has understood this: good auditors are rare. Simple training
is not enough; a tutorial system is recommended by IMO and IACS, as well as a continuous revalidation of
competences.

The confidentiality of the activities is, nevertheless, apparently preserved since they are internal audits.

But this confidentiality is only on the surface because in the event of accidents the court will be able to consult
the records of activities in order to find the causes of the accident and the distribution of responsibilities, which
seems completely logical.

29.6 CONFIDENTIALITY

Currently a significant problem affecting the effectiveness of the ISM Code is raised by the captains and the
companies: the administrations or their representatives tend to search in the records during the audits of
conformity. This attitude is dangerous and can, if we do not take care, kill the effectiveness of the ISM Code.

Self-checking makes it possible for everyone to discover their own oversights, errors or weaknesses in order to
correct or try to improve them, provided that all that information remains inside the company.

If the administration wants to assert control over the records of these activities in order to be able to blame or to
penalize the captain or the ship owner, the result will not be in any doubt: all the records will be perfect...and the
ISM Code will be of no use to anyone.

The risk is great and the maritime community is conscious that if we do not take care, the SMS will become a
virtual system and the ISM Code will not be able to achieve its goals.

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29.7 RESPONSIBILITIES

The responsibilities must be clearly defined in the SMS from the top to the bottom, from the president of the
company to the last member of crew.

29.8 CONCLUSION

As you see, the clearly established role of accident and pollution prevention of the ISM Code involves everyone
in the safety of the operations of a ship. To involve everybody in the safety of maritime transport is, I believe, an
excellent thing. As a former captain, I always found it astonishing that the superb responsibility of the captain can
be often used to do anything, often by lure of gain for the ship-owner or the charterer but also very often to
counter the incompetence of the other parties: charterers, shipping agents, stevedores etc.

The ISM Code thus seems to be the solution to all the problems of maritime transporters. However, the concept
was too beautiful – reality is much more down to earth.

29.9 SELF ASSESSMENT QUESTIONNAIRE

1- What are the principles to operate a SMS?

2- What is the main tool for evaluating the efficiency of a SMS?

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30. NECESSARY EVOLUTION

Learning Outcome

After successfully completing this chapter, you will be able to:

• understand the necessity of some amendments to the ISM Code.

30.1 2002 AMENDMENTS TO THE ISM CODE

Like any code, international or not, the ISM Code needed updating after nine years of application.

The IMO however, has a principle, not to touch a text before its total implementation. In the case of the ISM
Code, the last group of ships (the most important group) will have to apply it from 1 July 2002 as we have seen
before.

Naturally, for a few years already the specialists in ISM representing their country at IMO have worked on future
corrections to the code and the first amendments have just appeared.

From 1 July 2002, the ISM Code has comprised of two parts:

• A – for the code itself; and

• B – for the methods of verification and certification.

Only one modification was made to the text of the code itself: in Section 7 “including checklists as appropriate”
was added in the mandatory procedures of the ship concerning safety and environmental protection.

30.2 WHY CHECKLISTS

The interest of checklists does not surprise anybody any more, therefore, we have decided (I was in the working
group) to include this term in the requirements of Section 7.

This, on the one hand, forces certain maritime cultures to employ them (Latin, for example) and, on the other hand,
clarifies their use and prevents a ship being retained because it did not have a checklist for, say, preparing the meals
for the crew. (I exaggerate a little bit only and some inspectors of the PSC have already had this kind of zeal.)

In addition, some minor modifications are carried out in the methods of implementation. Finally, significant
definitions which appeared in Resolution A.788 are included in the code itself for clarification.

Resolution A.913 clarifies certain points of the procedures of assessment by the flag administrations has been
finally replaced in 2010 by IMO 1022 following the 2008 ISM Code Amendments.

All along the present module, we have studied the 2008 amendments which become mandatory July 2010. They are
important of course but in my opinion they are not going far enough to clarify certain parts of the code as:
- The ISM specific training which must be made mandatory
- The critical systems and the operation in a degraded mode which must be specified in a better manner

30.3 OTHER MODIFICATIONS WHICH WE CONSIDER NECESSARY

Other modifications which we consider necessary are as follows:

(a) To modify the interval of control of the SMC – ISM certificate of the ship, bringing it back to one year like the
other certificates.

It is quite logical even if the company’s certificate is renewed annually. A two and a half year interval had been
decided particularly for cost reasons: visits for the renewal of certificates not taking place obligatorily at the same
date. At present, the harmonized system for survey and certification (HSSC) being applicable since the beginning
of year 2000, it will be easier perhaps to return to a common annual visit for the ships, and the control of
management will be able to take place at the same time as the other controls.

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All that seems logical, to permit a SMS to function during nearly 36 months on a ship whereas the crew changes
nearly ten times. It is absurd when you look at the international crews today. But the logic of certain flag
representatives is sometimes surprising: some are systematically against everything.

(b) Add to this a concept of quantity in the requirements for the quality of the crew (ref Section 6.2).

Indeed, the number of crew members should be taken into consideration when looking at the aptitude of the
crew to:

• ensure the day to day ship’s safety according to the international conventions (SOLAS, COLREGS or STCW
cluding ISM and ISPS Codes);
• ensure day to day maintenance of the ship and her equipment; and
ensure day to day security prevention measures;
• ensure by its actions a reduction in the consequences of an accident.

Note that the safe manning certificate relates to only safety, and not prevention, which ship’s maintenance or
crew preparation for emergencies represents: If we want well prepared crews and well maintained ships it will
be necessary to pay the price to start with – namely the price of some more men (or women) which is not so
expensive at all (this is in the agenda of IMO).

(c) To demand in the code itself an adequate ISM competence of the external auditors or inspectors of the PSC:
training to be defined in STCW which would make it automatically applicable to the industry.

Indeed, how can an ordinary PSC inspector be credible in front of a captain or a chief engineer highly specialized.
The only credible inspectors today are the specialized contractual ones from the merchant marine having been at
least chief officer or second engineer and preferably captain or chief engineer.

For example, the state of a LPG carrier on its arrival in US waters is controlled by one Coast Guard captain, a
specialist in gas transport.

This problem is very significant. It is of no use multiplying controls or practicing them in a contradictory way
(double control) if the controllers are not qualified.

In France, a working group is in place to study the contents of the training for future inspectors: we wish them a
lot of luck... it needs a lot of time to train a captain or a chief engineer according to STCW.

For me, the only solution must be through recruitment at the highest level of merchant marine officers with
diplomas obtained after sufficient experience at sea.

30.4 CONCLUSION

The proposals are timid and in spite of the Erika disaster (first disaster after ISM) certain countries respond slowly
to modifications always considered as constraining and the source of additional costs for the ship owners who, it is
true, have not been rolling in money for many years.

30.5 SELF ASSESSMENT QUESTIONNAIRE

1- What are the main modifications by the 2002 amendments of the ISM Code?
2- Why have we insisted on check-lists?
3- Could you list the necessary future modifications of the ISM Code?

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31. PROBABLE FUTUR IMPROVEMENT OF THE ISM CODE

Learning Outcome

After successfully completing this chapter, you will be able to:

• understand the probable evolution of the requirements of the ISM Code.

31.1 PROBABLE FUTURE MODIFICATIONS TO THE ISM CODE

If we cannot turn back the clock on the obligation of ISM certification (which was perhaps an error), it would be
perhaps more judicious to create three levels of certification: passable mention, well and very well perhaps (ISM 3,
ISM 2 and ISM 1) in order to decide between the good, the average ones and the bad ship owners.

New constraints of period of validity would be imposed on these certificates considered to be passable, six
months for example (always penalizing financially and commercially the owner) and an extension or exemption of
the controls for the best (which indeed do not need any).

Such a system would be fair and just: on the one hand an incentive to be a good ship owner by decreasing the
expenses and on the other an incentive to be better by decreasing the expenses.

Thus assessed the safety management system would be able to become a commercial argument (including a
reduction in insurance premium… we can dream!.)

31.2 NECESSARY IMPROVEMENT OF THE QUALITY OF CERTIFICATION AUDITS

These audits should be carried out in a contradictory way, i.e. by two ISM specialists of different origin – a
civil servant of the flag and an independent specialist or an auditor of the selected certification body and an
independent (as French law already allows in the decree on 12 July 1996 Article 10-1.11)

Note that the independent specialists should be approved in the same manner as the other auditors or inspectors,
theoretically more free from any pressure, because they are released from any duty of reserve. They are rather
rare today perhaps, but an international recruitment drive should solve the problem.

31.3 TO BE MORE SPECIFIC CONCERNING EXPERIENCE FEEDBACK IN THE CODE ITSELF

It is true that for those who want to remain blind, the requirement of the experience feedback is not obvious in
the ISM Code.

However, it is sufficiently suggested and only bad ship owners can create this impasse. Experience feedback is
today of such value that we do not have the right to overlook it.

Personally, it is often necessary for me to answer the following question: I am responsible for this, in the event of
serious accident to what extent can I be considered as fully responsible? I always have the same answer whether
in Brazil or the US or in France – you will certainly be inducted but you will only be able to benefit from the
extenuating circumstances if you can prove that:

• you have taken every risk into consideration as usual; and

• you have taken into account experience feedback (feedback of the same accident in your company or
elsewhere).

On the other hand, if you have done nothing at all...so much the worse for you.

Finally, we are many who think that starting from a company experience feedback on safety management, it would
be possible to set up a national management and then an international management of this experience feedback
under the aegis of IMO, for example via the administrations and the certification bodies (the essential safeguards
on confidentiality should be easily set up).

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Commercial aviation has implemented such a management.

Hopefully, the MSC circulars of 2007 have initiated an exploitation of the feedback without naming it (see Chapter
10 of this book )

31.4 REINFORCEMENT OF THE PRESENCE OF ISM SPECIALISTS IN IMO RATHER THAN THOSE
OF THE CLASSIFICATION SOCIETIES

There are who have made ISM their exclusive domain and, of course, we find in the national delegations a lot of
representatives from the large classification societies in addition of those from IACS as consultants.

The hard core is impressive, but it is certain that the ISM specialists in the administration or quite simply the
independent ones are few and far between.

31.5 ISSUING MANDATORY TRAINING ON THE HUMAN ELEMENT FOR MERCHANT MARINE
OFFICERS

Training on the management of the human element on a navigation bridge initially and in the entire ship later is in
the process of implementation everywhere in the world. Large international companies have quickly understood
that an improvement in human behavior in any circumstances comes from a better knowledge of human
performance: this is exactly the ISM Code.

Copied from commercial aviation, such a formation is now systematic for the captains of cruise ships, supertankers,
fast ships, ferries or of large containerships.

Always for reasons of cost, certain ship owners reply that they will be interested only when it is obligatory.
BRM which was only recommended in STCW 95, will become mandatory thanks to STCW 2010. This is an
important part of the safety culture.

ISM specific training is not yet mandatory but it knock at the door. Classification societies training department have
launched specific ISM training for crews and officers as well as for DPA/managers and internal auditors. Some ship-
owners are starting to follow the IMO recommendations.
It is noticed that when we started to prepare the ISPS code, the IMO secretary General was reminding us in our
mandate “ don’t forget training!”
I hope that the ISM specific training will become mandatory in the next years (2014 ?)

31.6 SELF ASSESSMENT QUESTIONNAIRE

1- How to improve low level safety management systems?

2- How to improve the verifications?
3- What kind of training must become mandatory for merchant navy officers?

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PART C APPENDIX
Appendix 1
A study on a remaining hard point in the ISM Code
THE AUTHOR’S ARTICLE PUBLISHED
IN FRANCE AND THE UK

CRITICAL, have you said CRITICAL?

INTRODUCTION

Called critical, vital or sensitive, certain equipment of the ship specified in Section 10.3 of the ISM Code must be
the subject of all our attention if we want to be declared “in conformity with the code”.

A priori, that seems very simple, but by wanting to remain too general, the code leaves such possibilities of
interpretation that the auditors are often uncomfortable at the time of the analysis of conformity.

Moreover for the French-speaking people, an IMO official translation often too approximate does not help matters.

1. Official Texts

Original English:

“10.3 The Company should establish procedures in its SMS to identify equipment and technical systems the
sudden operational failure of which may result in hazardous situations. The SMS should provide for specific
measures aimed at promoting the reliability of such equipment or systems. These measures should include
the regular testing of stand-by arrangements and equipment or technical systems that are not in continuous
use.

10.4 The inspections mentioned in 10.2 as well as the measures referred to in 10.3 should be integrated into the
ship’s operational maintenance routine.”

Official translation in French:

“10.3 La compagnie devrait établir dans le cadre du système de gestion de la sécurité des procédures permettant
d’identifier le matériel et les systèmes techniques dont la panne soudaine pourrait entraîner des situations
dangereuses. Le système de gestion de la sécurité devrait prévoir des mesures spécifiques pour renforcer
la fiabilité de ce matériel et de ces systèmes. Ces mesures devraient inclure la mise à l’essai à intervalles
réguliers des dispositifs et du matériel de secours ainsi que des systèmes techniques qui ne sont pas utilisés
en permanence.

10.4 Les inspections mentionnées au paragraphe 10.2 ci-dessus ainsi que les mesures visées au paragraphe 10.3
devraient être intégrées dans le programme d’entretien courant.”

2. Characteristics of the Translation

On one hand:

“Sudden operational failure” means “sudden breakdown” of course, but also “unforeseen unavailability (or failure)
of exploitation (or operation)”.

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On the other hand:

“Hazardous situations” relates to situations of danger or risk or hazard concerning the persons onboard, the ship
itself and the environment.

So, not only does equipment or systems in service suddenly break down but a group of equipment, if they are not
available at the precise moment when needed, can put the men, the material and the environment in danger:

The elements to be identified are already clearer.

In addition, we must envisage specific measurements to reinforce the reliability of these pieces of equipment or
systems.

Here there is no problem: it is necessary for us within the framework of a specific prevention, to ensure that this
equipment or systems are able to function normally or at the desired moment.

Lastly, in order that we do not forget anything, the drafting group of the code insists that certain tests of the
devices in stand-by (apparatus in redundancy or procedures of replacement) be carried out regularly. As well as for
the technical materials or systems which are not in continuous use.

There is here in my opinion a mistranslation: indeed “equipment and technical systems” are linked in the first part
of the Section, therefore, they must logically remain so at the end of the Section and we must thus read as above
and not as in the French translation where equipment is related to “arrangements”.

When we are an “habitué” of the code this does not have much importance, but I wish to point this out because
these “stand-by systems” will take greater importance in the future in the prevention of accidents at sea, the single
objective of the code.

In conclusion, this stand-by equipment and these materials or technical systems which are not in continuous use
are critical systems that the code encourages us not to forget.

See Note 1 on page G-177.

3. What it is About Really?

We must:

• identify these critical systems;

• define specific measures to enhance their reliability by including periodic tests; and
• furthermore, the tasks involved will be assigned to qualified personnel.

4. Process

4.1 An apparatus or a system is required to function during the operation of the ship, i.e:

• Propulsion, navigation and their management.

• Port operations: manoeuvre and commercial operations.
• Power and its management.
• Permanent safety: detection, lighting and eventually automatic fire extinction.
• Response elements: extinction, fire or drainage pumps.
• Survival: abandon, search and rescue.

For example, practically the whole ship’s life; we must therefore, proceed to an inventory of the totality of the
equipment of the ship.

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4.2 If this apparatus or system stops functioning (breakdown) or cannot be used (does not start or is in such bad
condition preventing it from fulfilling its role):

• either this unavailability is unlikely to put anyone in danger: that is non-critical equipment; or

• there is a risk and it is the responsibility of the SMS to ensure the safety of the persons on board, the ship
itself and the environmental protection: this is critical equipment.

We must thus identify Equipment Called Critical.

4.3 This equipment does not all have the same degree of “criticality”, i.e. some is more critical than others, i.e.
for some its absence is already an emergency whereas others can be replaced by another apparatus in stand-
by (redundancy) or a procedure of replacement can be implemented to ensure nevertheless the service of this
apparatus but under less comfortable conditions called degraded conditions or status (manual operation or
local etc).

We, therefore, will give a level of criticality to each piece of equipment by taking account of those that can function
in a degraded mode.

4.4 For the critical equipment the code obliges us to envisage measures of reinforcement of reliability.

To reinforce this reliability the means used are:

• an enhanced maintenance;
• redundancy or more simple stand-by device (back-up);
• the replacement procedures if the apparatus or system can function in degraded mode;
• the ordering of spare parts;
• repairs on the spot when possible or in a shipyard in emergency or deferred;
• to define the frequency of these measures; or
• to assign these measures to qualified members of the crew.

5. Elements of our Ship

5.1 Critical Materials or Systems (Non-Exhaustive List)

Bridge:
Radars, navigation lights, whistle, internal communications: tannoy-telephone-interphone, external communications:
VHF – radio-satellite communications: phone, fax, e-mail, fire detection and alarm etc.

Deck:
Fire mains, power and control circuit of mooring winches, bilge pumping system, anchoring system, fire detection
and alarm system, extinguishing system etc.

Engine room:
Fuel tanks double level alarm system, propulsion system, steering system etc.

Miscellaneous:
Collection of drawings, plans or technical manuals etc.

Stand-by arrangements and technical systems that are not in continuous use:
• Lifeboats, liferafts, lifeboat davits.
• Lowering system for lifeboats, lowering system for liferafts.
• Chain locker clench, fire dampers, and signal lamp.
• Emergency lighting, emergency bilge pump.
• Emergency fire pump, remotely closed valves.
• Remotely operated electrical equipment, towing equipment.
• Throw-line equipment etc.

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5.2 Level of Criticality

A – Critical without redundancy nor procedures of replacement.

B – Critical with procedure of replacement.
C – Critical with redundancy.
D – Critical with redundancy and procedure of replacement.
E – Not critical.

5.3 Specific Measures (Hardware and Software)

• Automatic power supply.

• Redundancy and/or replacement procedure.
• Reinforced maintenance or more frequent tests by ship’s crew.
• Periodical control by specialized company.
• Spare parts on board for a possible repair by the ship’s crew in the nearest shipyard. Copies of the collection
of drawings and plans in a safe place (including digital documents).
• Familiarization and preparation of the ship’s crew.
• Special training of operators.
• Experience feedback from shipboard, company or equipment builder.

5.4 Replacement Procedures

1. Second line of command.

2. Hand drive operation on the spot.
3. Emergency power or fuel supply by derivation.
4. Emergency power supply in the event of partial or total blackout.
5. Emergency drainage by derivation.
6. Etc (up to 45 for a large ferry).

5.5 Risk Analysis and Operation in Degraded Mode

Resolutely modern, a new method of risks analysis in our industry allows us, even before the construction of the
ship, to evaluate the future risks in the operation of the ship and thus to determine, if required, modifications of
design or procedures to reduce these risks.

Nowadays, the manufacturers of equipment offer operation in degraded mode, allowing a minimum service.

The classification societies propose a plan study (safety case) according to the methods of the formal safety
assessment (FSA). This study is effective (as been seen) but still extremely expensive except for those, with
foresight, who do not forget to include it in the building specifications.

A risks analysis is thus necessary for all the shipboard operations and it is what a member of the crew normally
carries out each time he undertakes something on board. However, a more formal approach of this evaluation can
only help us to reduce risks inherent in transport by sea.

Nevertheless, the author remains persuaded that, in spite of the new methods of analysis, experience remains
irreplaceable. This experience, initially personal, will be really effective when the operation of its corollary, the
experience feedback, is in use firstly in the shipping companies then at the level of the whole maritime industry.

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6. In Conclusion

Once all measures above are applied, we are apparently ready for ISM certification for the requirements of the ISM
Code Section 10.3.

However, have we forgotten perhaps the most critical element on board? I mean the person, the member of the
crew. No, of course not, because the code itself is finally an “attempt at a reduction of the risks related to human
activities on board a ship” (see Note 2), but maritime transport has difficulty in recognising that the human being
remains at the centre of safety and environmental protection.

With probably more resources, the commercial aviation industry has understood for a long time that an efficient
management of safety in transport cannot be achieved without a specific effort on the human element itself.

In addition to his training and physical condition (which we already taken care of), it is on the improvement of his
own performance that this modern world is preoccupied, in particular in a situation of stress:

• to know how and when to take good decisions and to know his own limits;
• to know how to manage a team in an emergency situation; and
• to know how to manage his own stress etc.

For me, the merchant navy has been lagging behind but it is finally waking up. The “marine crew resource
management” is already well launched by other European countries (perhaps more marine inclined than us), but is
now arriving in France finally.

August 2008
SOURCES

• UK P&I Club, “ISM Code, legal and insurance implications” PH Anderson

• Listing of “Management in Degraded Status” of the Normandy (CE M Lasvaladas)

NOTES

Note 1 Draft Amendment of Section 10.3 of the ISM Code (proposition)

The company should establish procedures in its SMS to identify the technical material and systems or stand-by
arrangements, the sudden operational failure or impossible operation or poor condition of which may result in
hazardous situations for the crew, the ship or the environment.

The SMS should provide specific measurements of redundancy, maintenance and periodic tests as well as
replacement procedures for the equipment, which can function in a degraded mode in order to reinforce its
reliability and to ensure its operation according to the need.

Note 2 Anomalies

A traceability of only one link of a cold chain or a quality certification applied to only one element of a chain does
not make sense. A safety and environmental protection certification for only one element of maritime transport
(the company and its ships) does not make sense either.

What is the point if the ship is ISM certified if the pilot drives you aground, if the tug makes a hole in the hull, if
the longshoreman releases a steel wire spring in the propeller, if the port officer imposes a dangerous berth, if the
MRCC takes your damage lightly, if the charger in whom you have confidence (sic) mixes something in its container,
if the classification society delivers you a certificate of convenience etc.

The “attempt at reduction of the risks related to human activities” should logically be imposed soon on the other
participants in maritime transport, don’t you think?

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APPENDIX 2: Summary of a SMS

EXAMPLE TABLE OF CONTENTS of a SMM

N° ISM ITEM Date of Rev Date of Nb

ref issu. Ind. rev page
1 Cover sheet Dec 07 1 30.01.08 1
2-SUM Table of contents Jan 08 1 30.01.08 2
3-SIGN 6 Signing Sheet Nov 07 1 30.01.08 NA
4CORR 11 Corrections, Modifications, New document Jan 08 1 30.01.08 NA
5CONT 11 Control of documentation & distribution Nov 07 1 30.01.08 NA
6-POL 2 COMPANY POLICY 1 30.01.08 1
7-LA 4 Letter of assignment of the DPA/CSO “ 1 30.01.08 1
8-LA b 4 Letter of assignment of deputy DPA/CSO 1 28.01.08 1
9-OBJ 1.2.2 COMPANY OBJECTIVES and performance indicators “ 1 30.01.08 2
10MD 5.2 Master’s discretion for Safety and Security “ 1 30.01.08 1
§ 01 1 & 3 COMPANY’s Organization “ 1 30.01.08 1
1-1 1.4 Organization in RIO de JANIERO “ 1 30.01.08 1
1-2 “ Organization in MACAE “ 1 30.01.08 1
1-3 “ Organization on the MODU “ 1 30.01.08 1
1-4 4 ORGANIZATION for ISM and ISPS Compliance “ 1 30.01.08 1
1-5 4 JOB DESCRIPTION of the DPA/CSO “ 1 30.01.08 2
1-6 8.3 Crisis cell “ 1 30.01.08 1
1-6.1 Lista de contatos de emergência 30.1.08 0 2
1-7 1.4 Applicability of the SMS Nov 07 1 30.01.08 2
1-8 5.2 Company instructions to the Captain “ 1 30.01.08 3
§ 02 2 STRUCTURE of the SMS ( Flow chart) “ 1 30.01.08 1
§ 03 1.2.2 RISK REDUCTION System “ 1 30.01.08 1
3-1 1 Risk management “ 1 30.01.08 3
3-2 7 Permissao de trabalho “ 1 30.01.08 17
3-3 10 Management of critical or stand-by equipment “ 1 30.01.08 2
3-4 6 Safety meetings Procedure “ 1 30.01.08 4
3-5 7 Pre-job meetings procedure “ 1 30.01.08 2
04 8 EMERGENCY PREPAREDNESS “ 1 30.01.08 4
04-1 8 P 1 drills & Exercises plan for the year “ 1 30.01.08 1
04-2 8 Form: Emergency, drill or exercise report 1 30.01.08 2
05 6 Management of HUMAN RESOURCES System “ 1 30.01.08 3
5-1 6.1-2 Recruitment Procedure “ 1 30.01.08 2
5-1.1 Form for recruitment & questionnaire 1 30.01.08 1
5-2 6.3-.4 Safety Familiarization and Training Procedure “ 1 30.01.08 6
5-2.1 Form: for Familiarization of crew 1 30.01.08 1
5-2.2 Form for familiarization of 3d party employees 1 30.01.08 1
5-3 6-7 Internal Communication Procedure “ 1 30.01.08 2

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5-4 8 Replacement of Captain Procedure “ 1 30.01.08 1

5-5 6-7 Hand over procedure “ 1 30.01.08 2
06 7 PLANS & INSTRUCTIONS for KEY SHIPBOARD “ 1 30.01.08 2
OPERATIONS
07 10 SHIPBOARD MAINTENANCE SYSTEM “ 1 30.01.08 2
(MAXIMO SOFTWARE)
07-1 List of safety critical equipment 30.1.08 0 5
08 9 COMPANY ACCIDENT REPORTING and ANALYSING & Nov 07 1 30.01.08 4
FEEDBACK System
8-1 Form for relatorio de acidente de trabalho 30.1.08 0 2
8-2 Form: REX card for feedback report 1 30.01.08 2
09 1.2 HEALTH, hygiene and Environmental System “ 1 30.01.08 2
9-1 Drugs, Alcohol and Smoking Policy “ 1 30.01.08 4
9-2 Bunkering Procedure “ 1 30.01.08 2
9-2.1 Bunkering and state of capacities CL 30.1.08 0 2
9-3 Waste management Procedure Nov 07 1 30.01.08 1
9-4 Ballast management Procedure “ 1 30.01.08 1
10 7-11 SYSTEM for Management of ISM DOCUMENTS “ 1 30.01.08 3
10-1 Documents flowchart for ISM compliance “ 1 30.01.08 1
10-2 List of publications on board the MODU 1 30.01.08 6
10-3 List of publications ashore in MACAE office 1 30.01.08 2
10-4 List of publications in RIO office 1 30.01.08 2
11 4-12 VERIFICATION & REVIEWS System “ 1 30.01.08 3
11-1 Form: ISM Internal audit report 30.1.08 0 3
11-2 Form: Captain’s review 30.1.08 0 3
11-3 Form: Management review 30.1.08 0 3
GLOS Glossary of terms NOV 07 1 30.01.08 2
DEF Definition of terms used in this manual “ 1 30.01.08 5
Ann 1 Safety card 30.1.08 0 1
TOTAL 144

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APPENDIX 3
EXAMPLE OF ISM INTERNAL AUDIT REPORT

REPORT of INTERNAL ISM AUDIT ENG AUDIT N° 1 /2010

AUDITED SERVICE : COMPANY SITE OFFICE IN MUADI and Drilling Ship PELICAN

Date : 28th of April to 3d of May 2010

Lead auditor : Captain APPERRY ABC Services

Persons met ashore and on board Captain PRAD & DP officers

S. (General Manager) and DPA Rig Superintendent
Luiz as RIG Manager Maintenance supervisor
Walnei as HSE Manager 1st engineer
Vitor HR Manager IT Mauricio
Crew management RSTCo-ordinator
IT engineer Commissario
1- S.W.O.T analysis
Strong points:
In the company, there is a real will to be in conformity with the ISM code requirements. The safety culture of the company
is improving. The safety culture of the shipboard personnel is good or very good. This personnel has a good experience of
Offshore safety coming from different famous operators. The adaptation of the embarked personnel will be faster.
Weak points:
Communication on safety between the ship and the company is at a minimum.
The DPA has the suitable level for the job but being the General Manger at the same time, this situation doesn’t comply with
the philosophy of the ISM code. The link with the head of the company is ensured. The knowledge of the DPA in his key role is
not enough understood. Specific training on safety management is needed for the DPA.
Opportunities:
Shore and shipboard personnel is prepared to issue and consolidate a company safety culture. ISM training need be organized
ASAP for both shore personnel and key personnel on board
Threats:
The SMS has been verified in conformity with the ISM code (0 NC and 0 observations) by ANC of behalf the flag.
At the actual state, the SMS doesn’t operate enough to be presented to the initial verification of operation. More proofs of
contacts/reactions/control/involvement of the DPA and the directors must exist.

2-Assessment of performance (ref ISMCM §2)

Code Remarks Score
1 Health and safety program exist and some elements are implemented 1
2 The feedback system exists and start to work only (no formal use of the feedback card) 1
3 Internal audit is performed only by external consultant 3
4 Captain and management review is expected 1
5 Accident were analysed and corrective actions taken 5
6 Safety observation cards are used 3
7 Drills are conducted in a formal way and assessment done 3
8 Crisis cell is organized/ one drill has been performed by consultant 3
9 Continuous training is organized. Formal recordings are partly missing 1
10 Attempts to integrate safety and security exist 1
Total Conclusion: Safety is managed; all indicators are taken into account Personnel are involved in improvement 22/50
of safety of personnel and pollution prevention. More training is needed.

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3- Audit results
The main part of the ship were visited including engine room and kitchen and store/cool chambers
An exercise of “crisis cell meeting” has been performed Friday afternoon; a report will be issued by the QHSE co-ordinator.
Summary of non conformities and remarks
Non-conformities N°: 10
Remarks N°: 5
NC 1 - The General Alarm signal is not conformity with the regulation (SOLAS III reg 6 § 4.2)
NC 2- The muster list concerning fire teams 1and 2 does not define the substitute of person in charge and smoke divers (ref
SOLAS III reg 37 § 5
NC 3- Obsolete documents are still available or posted ashore or on board (ref ISM code § 11)
NC 4- ISM (paper) documents in use on board and ashore have not been amended
NC 5- Electronic documents have not been amended correctly
NC 6- Letter of assignment for S. as DPA/CSO has not been apparently issued by the company top management
NC 7- The specific measures aiming at improving the reliability of the critical equipment are not yet finalized in the software
NC 8- Training for the use of the software has not been completely performed
NC 9- Training of the DPA has not been completed
NC 10- The de-insectization of the kitchen is not effective

Remark N° 1 - Copy of the DOC could be posted in the shore office and on board the ship (Captain’s deck for example)
Remark N° 2- Seafarers training certificates matrix can be completed by more mandatory items
Remark N °3 - Training of internal auditors has not been completed
Remark N°4 - the escape ways are clearly marked in the engine room and on the decks. Such a marking should be extended on the other rig.
Remark N°5 - Comments on training under IMO resol A 891

Conclusion
As the Interim DOC is valid until 28th of July 2010, it is suggested to inform the RO of postponing of the ISM initial audit until the first
weeks of Sept 2010.This will allow the company to:
- Improve the operation of the SMS ashore
- Improve the communication between the ship and the DPA
- Give enough time for the new DPA to be trained in ISM, ISPS and audit techniques
And:
As the task of General Manager and DPA at the same time doesn’t correspond completely to the philosophy of the §4 of the ISM Code,
and
As the SITE general manager is normally busy with his job, and
As the requirements for the other M.O.U are close and will increase the work of the DPA/CSO, …it is suggested that the company study
another solution for designation of the DPA/CSO; two solutions can be chosen:
- Designate another DPA as an assistant of the CEO.This assistant should be preferably a marine officer with good
knowledge of the Offshore industry.
- Externalize the job of DPA or assistant DPA to a sub-contracting company which will propose on full or part time,
by contract, the right person.The designation of this kind of designated person by Company Director could be
normally done in conformity with the ISM code.This person could also prepare the ship security assessment and
plan of the other rig and run the integrated system on both the two offshore units and ashore (ABC services
can issue a proposition).
Another internal ISM audit should be performed in September in order to assess the progress on the operation of the SMS ashore mainly
on the following items:
- DPA training and involvement - operation of feedback, training of internal auditors, Captain’s and company’s review.

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NON conformities

NC N°1 (ref : SOLAS III reg 6 § 4.2) :The General Alarm signal is not in conformity with international regulation
In SOLAS only one signal has been defined: the general alarm signal !.. consisting in 7 short blasts minimum and one uninterrupted long
signal of minimum 7 seconds.
The situation on board is the following:
For Fire and emergency- intermittent ringing during 10 seconds
To prepare to abandon- a long blast of ten seconds
For Man overboard: 3 long blasts
Dismissal from emergency: 3 shorts blasts
… with the correct precision that any signal will be accompanied by an announcement on the ship’s PA system.
Proposed corrective action:
A study should be initiated to check if a modification can be easily conducted (If not the modification shall be postponed to the dry-docking).
The modification could be the following: only one ALARM SIGNAL from ship’s whistles and alarm bells (fire and smoke detection): 7 short
blasts and one long. Followed immediately by a formal PA announcement concerning the type of emergency (fire, H²S, man overboard,
accident, security alert or any other emergency including preparation to abandon)
Information must be carefully prepared for the crew explaining the modification; all crew must receive this information via induction meeting
or PA announcement repeated many times for the two shifts.
At the same time all the posters should be corrected as well as the documents (SOLAS training manual- individual information safety sheet).
Placard can be sufficient. All relieve crew will be informed accordingly.
A special attention should be required for this change.The solution to wait the repairs could be the best because it allows enough time to
change the documents and to inform the present crew and the crew embarking after the repairs during the transit trip.
Pilot of action:
The ship’s Captains are the best pilots for these actions
Delay:
It is suggested to carry out this modification during the next dry-docking (Jan 2009)

NC N°2 (ref SOLAS III reg 37 § 5) Muster list concerning fire teams 1 and 2 does not define the substitutes of person in charge
and smoke divers
In fact this SOLAS requirement is: “The muster list shall specify substitutes for key persons who may become disabled, taking into
account that different emergencies may call for different actions”
In case of emergency some key persons in the fire teams can be occupied elsewhere or disabled (dead, injured, tired, overstressed). At the
same time, it is the responsibility of the Captain to prevent to give responsibilities in such emergencies to non-qualified, non-physically or
mentally ready members of the crew. So substitutes shall be designated in order to ensure a proper action. Substitutes have to be qualified
and trained as the persons designated to be in charge.
Corrective action:
Designate a substitute for the person in command of both fire team 1 and fire team 2. Add the possibility for the master to modify the
composition of the teams due to instant conditions. Modify the muster lists accordingly. Control the qualification of SCBA holders and provide
as many as possible BST qualified team members in order to be able to replace tired or non-available personnel.
Action pilot:
The ship’s Captains are the right persons to perform this action
Delay:
This modification must be performed ASAP

NC N°3 Obsolete documents are still available or posted ashore or on board (ref ISM code § 11.2.3)
During the induction meeting on arrival on board, a document called “ORIENTATION of SMS’ has been found available in the meeting room.
This document has been replaced by another document called “ FAMILIARIZATION of the SMS”
Shipboard personnel flow chart posted in the office ashore and on board the ship are not updated.
Corrective action
These documents have to be destructed
Preventive action
A reminder has been carried out on immediate destruction of obsolete documents.This reminder should be carried out frequently during ISM
meetings.

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NC N°4 ISM documents in use on board and ashore have not been amended (ref ISM 11.2.1)
ISMCM in use on board and in the Main office are not amended.The corrections were not carried out from the last external audit.
Corrective actions
The main office documents will be amended
All amended pages will be issued and sent to the ship for replacement
Pilote of action:
QHSE coordinator will carry out
Delay:
End of week 19

NC N°5 Electronic documents have not been amended correctly

A general amendment for ISMCM has been carried out and all documents reviewed as rev 2.The initials of the approving person have been
modified from ECS to SLC.This is not the document control system explained in ISMCM 10 § 5.
Only the electronic documents have been amended;
Corrective action
Reminder on the document control system in place: only the ISMCM xx modified document rise a new revision step.This revision is also
recorded in the summary (ISMCM SUM) which rises to another step ahead also. It is important not to forget to modify this summary grid
and sheet itself
Correct revision N° of amended documents,
Correct revision N° of non amended documents (back to rev 0 or 1)
Pilote of action: HSE
Delay week 19

NC N°6 Letter of assignment for S. as DPA/CSO has not been apparently issued by the company top management
Corrective action
Issue the letter to be signed by the Responsible Person
Pilote of action: S.
Delay: ASAP

NC N°7 Specific measures aiming at improving the reliability of the critical equipment are not yet finalized in the maintenance SOFTWARE
(ref ISM code 11.3 and ISMCM §3.3)
Analysis
The ISM code requires that the safety critical elements (able to put lives, the ship or the immediate environment in jeopardy)
- “are identified”: this has been done. In fact all safety equipments of the ship have been identified as critical
- Level of safety criticality: this has not been carried out
-“specific measures have to be implemented to ensure the reliability of such equipments or systems”: this has not been carried out.
As explained in ISMCM § 3.3, to be in conformity with the ISM Code, specific measures even already existing must be defined in a document.
This is the only manner to solve this problem
Corrective action proposed (ref ISMCM §3.3)
The list created in the software data base must be checked for reliability existing measures such as redundancy/back up, emergency system
or procedures)
An example is proposed hereafter (from the list ISMCM 07.1):

N° Safety critical element Level Type of SM Observations

22 Fast Rescue boat D 2 The fast rescue boat has two engines and
also other lifeboats can be used for SAR
Etc…
Pilotes of action: Captain/chief engineer/IT
Delay: ASAP and before next internal/external audit

NC N°8 Training for the use of Maintenance software has not been completely performed
More training for the use of the maintenance software is apparently needed
Corrective action:
Training sessions must be organized by suitable persons or sub-contracting company
Pilot of action
S. and Maintenance manager
Delay
Continuous training

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NC N°9 Training of the DPA has not been completed

Training of the first DPA was carried out on time. S. was designated as the new DPA without proper training.Training references don’t officially
exist. IMO has not yet issued a proper training course as for the ISPS. In recent circulars, issued as guidelines, the safety and environment
committees of IMO (MSC-MEPC 7/circ.6 of October 2007) have focused on a specific training of the DPA mainly:
The “requirements of the code and
.1 knowledge and understanding of the ISM Code;
.2 mandatory rules and regulations;
.3 applicable codes, guidelines and standards as appropriate;
.4 assessment techniques of examining, questioning, evaluating and reporting;
.5 technical or operational aspects of safety management;
.6 appropriate knowledge of shipping and shipboard operations;
.7 participation in at least one marine-related management system audit; and
.8 effective communications with shipboard staff and senior management.”

“5.1 The Company should provide training courses covering qualification, training and
experience and the appropriate procedures connected to compliance with the ISM Code including
practical training and continuous updating. The company should also provide documentary
evidence that the Designated Person has the relevant qualification, training and experience to
undertake the duties under the provisions of the ISM Code”.
That is only recommendations but the ISM code and the Company’s SMS requires they are taken into account
Corrective action proposed:
The DPA and possible assistants must be trained on all elements define above. ISM training is still very rare all over the world.
Forum Services can propose a suitable training on site. This training could be the opportunity to improve the ISM knowledge of
the captains and officers, DPA substitute, QHSE coordinator, etc..
Delay
This training must be organized during the validity of the interim DOC

NC N°10 De-Insectization of the kitchen is not effective

Cucarachas (beattles) are numerous.
Corrective action
An action must be carried out rapidly.
Delay: ASAP

REMARKS/OBSERVATIONS
Rem N°1:
Copy of the DOC could be posted in the main office and on board the ship (Captain’s deck fore alleyway for example)
Action: HSE
Delay: ASAP

Rem N°2 :
The verification of training matrix could be improved to show the seafarers certificates. In fact the Safe Manning crew is the
minimum crew on board while any officer or seafarer embarked in addition must hold valid certificates.
All STCW and other certificates should appear in the matrix.
Action: V.
Delay: before end of interim DOC validity

Rem N°3: Training of internal auditors has not been completed

Due to operational load of work, the training of auditors has not been completed. A specific training should be completed for the
DPA and one Captain.
Action: DPA
Delay: before end of validity of the interim DOC

Rem N°4: Some comments are made on the necessary training of rig personnel under Resolution A 891 see annex to ISM audit.

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4-ACTION PLAN (Ref Internal Audit n° 1/2010)

NC/ Remark ITEM (short) Pilot Delay Realization Remarks

NC 1 General alarm on Ship’s Captain Dry-docking
board must be
modified
NC 2 Review of fire teams Ship’s Captains ASAP
muster list
NC 3 Review of documents QHSE/ RSTC ASAP
to eliminate obsolete
ones
NC 4 Up-dating of paper HSE End of week 19
ISMCM documents
(shipboard and Main
office)
NC 5 Correction of HSE Week 19
electronic documents
NC 6 Letter of assignment GM/DPA ASAP
for S.
NC 7 Study of critical Ship/’s crew IT ASAP
elements
NC 8 Training for Company continuous
Maintenance software
NC 9 ISM Training of DPA Company Before end of
2011
NC 10 Kitchen anti insect Capt/Commiss ASAP
treatment
Rem 1 Posting of DOC HSE ASAP
Rem 2 Complement of Crew management Before end of
seafarers training DOC validity
certificates matrix
Rem 3 Training of auditors Company Before end of
DOC validity

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