As most of you are aware that new ISM Code amendments have come in force from 1st of July 2010, and we expect that all our vessels are having the 2010 Edition of the ISM Code on board. Below is a summary of the amendment features with implications as per our understanding. Hope the vessels shall, under the able guidance of the Management Team be able to understudy the same and bring about the change in the systems as we need on board today. This can be one of the topics for the Master’s Management Review in future, for which, the Master’s and vessel Management can choose independently.
Summary of amendments to the ISM Code 2010 Amendments & Implications
Details of the specific amendments to the relevant provisions of the ISM Code are attached to this guidance notice. In summary, the amendments include:
1) Changing the definition of “major non-conformity” – this gives a less restrictive definition of a major non-conformity.
This implies in basic sense, that any deficiency identified as a Major Non Conformity, needs to be resolved or downgraded prior to the vessel leaving port. All other normal deficiencies would have a due date for maximum 3 months to resolve.
This further implies that even a lack of effective & systematic implementation of a SMS element or any element as in the ISM Code will be also treated as a Major Non-conformity.
It goes on to understand from here that lack of awareness of the ISM Code and / or the Company’s SMS is the first Major Non-conformity.
2) Adding “assess all identified risk to its ships” in the objectives of the Safety Management of the Company.
We’ve been all doing jobs on board, sometimes with a risk assessment, mostly without one. ISM Code now requires the company to identify and assess and provide for all identified risks to its ships. While a lot has been taken care of in the SMS, plenty of Risk Assessments are made up and included in the SUNCE Cds sent to your vessels, together with a power point presentation how to carry out Risk assessment. Further, please note, that any job being done on board, which comes under the purview of the Permit to Work system, needs to have a Risk Assessment done prior commencing the work. While we understand that most of the risks can be mitigated or reduced by the ships alone, we still expect the vessels to keep office in concurrence, whenever a job that is being done, does not have an adequate guidance in the QMS Manual. Further the policy regarding hot work stands as it is. Outside the designated areas, all hot work being done, needs office approval.
3) Adding a periodical review of the SMS as a master’s responsibility (previously masters were only required to review the SMS with no periodic requirement given).
Earlier the review of company’s SMS was supposed to be done, but no period was required. It was left on Master’s, unless the company comes up with a period in its SMS. All Master’s on board SUNCE Vessels are reminded, that prior your sign off, you together with the vessels management is required to do a Management Review of the SMS. This would include all aspects of the SMS. The SMS tiers are based on a PDCA cycle (PDCA (plan-do-check-act) is an iterative four-step problem-solving process typically used in business process improvement).
Tier 1: PLAN:
This is described by the Company Mission Statement and Establish the objectives and processes necessary to deliver results in accordance with the expected output. By making the expected output the focus, it differs from other techniques in that the completeness and accuracy of the specification is also part of the improvement. This would mean the company Goals and Policies.
Tier 2: DO:
Implement the new processes. This would mean all the SMS documentation, in our case the QMS Manual for the Ships, and the Company QPM in the office, supported by various other manuals – that is the Emergency Procedures Manual (EPM), Ship Security Plan (SSP) etc.
Tier 3: CHECK:
Measure the new processes and compare the results against the expected results to ascertain any differences.
This tier would mean Operations – Manuals, PMS, Circulars, fleet alerts etc. which would directly deal with the aspect of vessel general operations, basis the type of vessel and exact measures to process them, quantify and carry out the requirements.
This would further encompass all forms and Checklists that are to be used for Operations – in our Case, all SUNCE Checklists & Forms, except the MG, SP, QMS & SF labeled forms.
Tier 4: ACT:
Analyze the differences to determine their cause. Each will be part of either one or more of the P-D-C-A steps. Determine where to apply changes that will include improvement. When a pass through these four steps does not result in the need to improve, refine the scope to which PDCA is applied until there is a plan that involves improvement. This includes the aspects within the QMS that deal with Management Review, and the forms and checklists used to carry out the same.
All the above constitutes the company’s SMS and everything is under the purview of Management Review.
4) Adding “measures intended to prevent recurrence” in the procedure for the implementation of corrective action reflecting the need to put in place both corrective and preventative actions.
Until now, we were getting half hearted attempts from vessels with respect to their responses to deficiencies on board, be it in the SMS or in the Crew documentation or on board the vessels. However, with the implementation of the amendments to ISM Code, this would no longer suffice.
Root Cause analysis is mandatory, Corrective Actions need to be reported and placed immediately. Preventive Measures have to noted and undertaken to prevent any more recurrence.
5) Requiring companies to identify equipment and technical systems for which sudden operational failure may result in a hazardous situation (previously, companies were only required to establish a
procedure for this).
This implies a risk assessment type of module to be developed for identifying all such equipment and technical systems that may result in to a hazardous situation, if they fail. We at SUNCE are in the process to establish one such procedure, in order to ensure that nothing is left behind. Any suggestions and as such, any identifications from the Ship board personnel is welcome.
6) Setting a mandatory internal audit frequency of one year (previously the requirement had been for internal audits and periodic assessment of the efficiency of the SMS).
7) Introducing a need for the company to assess the effectiveness of the SMS, rather than its efficiency.
This is one of our most unfortunate area. Some how, we at SUNCE believe that we’ve endeavored to make an efficient SMS. However we’ve been finding mostly that due to some reasons, it is not effective. While we are trying to identify the root cause for this, we hope the onboard management team shall help us to identify this. In some of the Master’s Management reviews, we’ve come across Master’s writing that they’ve no problems with the SMS, and that it is good. We here are very well aware that they don’t know it in the first place. The causes are yours. One of the reasons we’ve definitely identified is behavioral responses from the personnel in question. Attitudinal changes are required. We understand that we do not have the best of the vessels, however, we at SUNCE office have taken this as a challenge to convert them to good running vessels. We expected support from most of the personnel serving on board, hoping that professionalism will prevail and they’ll enable us to meet our objective. Surprisingly while some vessels have done extremely well, we still have some vessels where the attitude of persons on board needs a change or such persons should be “written off”. Masters that are the eyes of the owners, have to support us in identifying such personnel. Further they have to support us by using the training medium, use the training material in SUNCE Cds and try to create more professional attitude on board.
8) Introducing possible 3 months extension of certificate, if a ship is not in a port (including change in the certificate form).
For this, please see above.
The Definitions, when elaborated with Respect to deficiencies:
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.
1.1.7 "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.
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