For Himanshu and others who may be interested

Dear all,
I finally found that someone does follow me - well this gentleman did and he asked me some questions, to which I've tried to answer. For others to think over, I'm reproducing them here.

1) Can U give a note(guidance) on making loading plan for an aframax/vlcc,Where loading rate is fast (10,000 m3/hr.)


My Ans:

Loading or discharging plans for smaller / bigger vessels is the same. Most important is for you to know the limitations of the vessel. Check your stability booklet for such. If you’ve U-shaped ballast tanks etc.

Every vessel’s pumping / loading arrangements are made basis the same consideration or ratio; rate of loading / discharge vis-à-vis the tank capacities. Accordingly, if you go on a small tanker of 30000T DWT, the max. pumping rate for homogeneous cargo will be about 3000 m3/hr, while if you go to a 100000 T DWT tanker, the pumping rates will be 10000 M3/hr.

This is always designed keeping in mind the filling rate and/or so the vapour displacement rate (P/V valve throughput etc.).

For developing any cargo plan, the most practical approach will be, in my opinion, as this is what I used to do –

1)    Work out your initial (ballast, no-cargo) stowage and stability and the final (all cargo) stowage and stability conditions.
2)    Your job is half done, once you’ve the above two conditions in hand.
3)    Next, assuming your question is for VLCC / Suezmax etc., means homogeneous cargo, start first foot loading in all tanks, that is work out a stage, where all your tanks or the first set of cargo tanks are filled about 0.5 – 1 m innage. During this time, you can start the loading at slow rate as per your ship’s design and shore agreement. Also you’ll start deballasting by gravity. Work out this condition on loadicator and compute the result, always keeping stern trim and maintaining vessel stability. Drafts should always agree with MARPOL criteria of max trim and minimum propeller immersion draft.
4)    At the next stage, you can start filling up tanks and reducing ballast slowly, always approaching your final condition, which you’ve already worked out earlier in stage 1. Continue deballasting keeping in mind the draft / favourable trim and stability.
5)    Always keep the amidships tanks slackest, available for the end. This would ensure that your ship does not develop sag, and towards the end, when you’re completing cargo loading, you’ll not have to keep resolving unusual trim.
6)    Multiple conditions will have to be worked for intermediate stages of loading, and this has nothing to do with time. As you work out, each stage will tell you, how much cargo has been taken in, and you’ll find that you have the time for each stage in hand, basis the available rates.
7)    At each stage, you’ll have to be careful about de-ballasting rates, since that has to be kept up with loading condition / stage too.
8)    In case, if you find that de-ballasting may be a problem, the best solution is to commence de-ballasting as soon as possible and prolong the initial slow loading rate stage and gradually increasing the rate of loading to max. Also towards the end, you can ask for decrease of rate in view of topping off.
9)    Keep an eye on the IG rates etc. to ensure it is coping up.
10) Actual topping off can be done towards the end. From my experience of stage loading, I’ve found its relatively easy to top-off tanks without having to reduce rate right until the end. What you have to do is plan your loading in such a way that each tank has a different level towards completion. This means on a bar graph if you see, you’ll have the cargo tanks filled with max. cargo on the extreme end (foremost and last) tanks, and gradually reducing to the centre. As you start topping off the end tanks, you can continue loading in the next set of tanks, changing over as you continue topping off, and as you reach closer to the last set of tanks, ask terminal to reduce rate. However, try this only if you are sure you are able to do this.

I’ve attached the cargo plan documents that I’d made during my own service as Chief Officer and now incorporated as company docs in my present company. You’ll have to amend the wordings, as these are more suitable in the present form for the chemical tankers.

Further questions:

Pls clarify on following pts-

1)Ford most & aft most tank will have least ullage,in case of heavy wx,during pitching oil/vapours may come out from ford tanks.

2) At discharge port,I can discharge those set of tanks which are nearly same,till all the tanks have come to nearly same level.

My Answers:

1)Ford most & aft most tank will have least ullage,in case of heavy wx,during pitching oil/vapours may come out from ford tanks.

The simplest explanation for this in layman terms is the principle of moments. Consider the fact that when a vessel is making way, its centre is the pivot point. Right? Now this Pivot point gets displaced or basically you can say that the loads along the scale passing through the pivot point keeps changing, causing the vessel to roll, pitch etc. Now the closer you are to this imaginery centre of the vessel, during her movement, you’ll feel less force of movement. However, the furthermost you are from this, the higher will be the resultant motion, with smallest exertion of force (think of Leverage). This would surely explain you, why?

However, it is important for you to understand also, that this is more importantly observed on vessels, where the Cargo tank PV valve orifice is on deck plating (remember normally it should not be constructed this way; it must be in the tank dome above the level of deck plate). With a trim in heavy pitching , cargo from forward will enter the PV pipes with orifice on deck platings and cause splashing on to deck. This would also cause rapid movement of vapours, being forced out of the P/V Valves.

Due to the same leverage, it is probable, in case of poorly maintained manholes on deck, that cargo or vapours may seep through it on deck.

2) At discharge port, I can discharge those set of tanks which are nearly same, till all the tanks have come to nearly same level.

What do you think, will happen (typical of vessels with pumproom ships and COPs in pumproom), when you commence discharge from tanks with different ullage level of cargo? You always commence discharge slowly, and increase it slowly too. Assume you started discharge from two tanks with ullages 3.6m and 1.4m. You will find that most of the cargo is being discharged from the second tank, while the 1^st tank may actually not change or may show an increase only. This is because cargo is getting transferred internally. Your expectations go for a toss.

It is always prudent to discharge the more filled cargo tanks until you are able to achieve a level lower than 88% in all tanks. This gives a safety margin too, in order to act, should there be internal inadvertent transfer of cargo.

Next question:

I noted that' There are numerous blogs, nautical institute site, various flag of registry sites, which provide you a lot of information.' Can you please name some of them for which I will be very grateful to you.

My Answer:

For Nautical Institute try www.nautinst.org

Various Classification societies have their own news feed, check them on their websites BV/LR/DNV/ABS etc.

For various Flag news, check

http://www.mantamaritime.com/

Marshall Islands: http://www.register-iri.com/

Liberia: http://www.liscr.com/liscr/

Panama: http://www.segumar.com/

Other sites:

http://www.safety4sea.com/

http://shipsbusiness.com/

http://gisis.imo.org/Public/

http://www.shipinspection.eu/

http://gcaptain.com/

http://pinoymaritime.com/blog/

http://mymaritimeblog.wordpress.com/

Blogs check as follows:

http://barratry.blogs.lloydslist.com/

http://ajitvadakayil.blogspot.com/

http://internationalshippingnews.blogspot.com/

http://theworldofshipping.wordpress.com/

http://kennebeccaptain.blogspot.com

http://www.lawandsea.net/maritime

http://www.themaritimesite.com/the-best-nautical-and-maritime-blogs/

Finally, anything you wish to get the knowledge on, just do a google search on it. I personally believe people blog for the reason of sharing the knowledge and experience. 

Remain objective in your search for a query, do not be judgmental, and you'll find the answers you are looking for.

ISM 10.3 - Critical and Standby Equipment

ISM 10 MAINTENANCE OF THE SHIP AND EQUIPMENT

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, if 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 safety management system 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.

I've noted that a majority of deficiencies and / or non-conformities that are raised on vessels are dealing with non-performance of Standby Equipment. While majority of the companies have realized that the inspections by superintendents is not adequate, they've also realized that not all Stand-by Equipment are covered in the Planned Maintenance Systems of the vessels.

What are the Stand-by Equipment?

Dictionaries would define these as a secondary system identical to the main system, to be used if the main system breaks down. In principle, these would and should include all such Equipment or Machinery that would qualify to be called in action during Emergencies, thus LSA, FFA & Emergency Machinery. 

However, since ISM does not really give a clear definition of the term, it is left to wide interpretation by all individuals. In a worst case scenario, only the Emergency Equipment are treated as such.

Let's first differentiate between Critical Equipment and Stand-by equipment.

Critical Equipment and systems are those where loss of functional capability or failure to respond when activated manually or automatically, may create a hazardous situation and / or cause an accident.

Identifying Critical Equipment:

Critical equipment is identified by the Shore Management by making a risk assessment taking following aspects into consideration:

•    Which equipment;

•    Impact on crew, vessel or environment if not working;

•    Back-up equipment / system;

•    Likelihood of failure.

A proper methodology should be developed, including identification of hazards for critical equipment failure, existing control methods, and evaluate the residual risk. If the residual risk is low, the Equipment will not be called Critical. However, if the residual risk is high, and further control methods can still not lower the risk, the Equipment will have to be called Critical and thus processes will have to be identified to nullify the risk, including substitutes, minimum spares etc.

Dealing with each equipment, identified as Critical will need to have a procedure to act, in the form of a checklist, if any of these equipment fail, including any trainings, drills etc to mitigate the consequences.

Stand-by Equipment:

In very short, something that we do not use everyday on board the ships. Let’s look what all would be considered Stand-by Equipment. In my opinion, it automatically includes all Emergency Equipment, by virtue of use during Emergencies.

Therefore as a minimum the following would be included:

1)            Life Saving Appliances & Equipment;

2)            Fire Fighting Appliances & Equipment;

3)            Emergency Generator, Emergency Air Compressor and other Compressors like BA bottles charging compressors;

4)            All Vents, Flaps, Fire doors, Fire divisions;

5)            Oil Spill Equipment, including any portable or fixed pumps;

6)            Emergency Bilge Pumping arrangements;

and such other. You being on board would know better, which equipment you’ll require in Emergency. I feel, tools required to operate / repair / maintain these equipment too would come under this purview. This implies there should be an existing stock, clear description and identification of such tools, be it hydrant opening spanners or a wrench / hammer.

What else?

Let’s see, on a typical tanker (guys, I’m a tanker-man, so please work about other type of vessels accordingly), we walk from Forward to aft.

7)        Anchors, bitter end arrangements, including tools.

8)        Forepeak Store W/t door, including sealing and closing arrangements.

9)        All forward stores sealing and closing arrangements, including doors.

10)      Bow Thruster room, booby hatches, other booby hatches forward.

11)      Suez Light and lifting arrangement on Foc’s’le.

12)      Bitts, Chain Bow Stoppers, Emergency Towing Equipment forward and aft, Bollards, Fairleads, Rollers, Winches, Windlass, ropes / wires mooring as well as supporting ones like heaving lines and stoppers.

13)      Eductors

14)      Anchor Chain Wash line and valves

15)      Any hoses (cargo, hydraulic, pneumatic, FRAMO etc.) kept on board.

16)      Cleaning material (minor, but imagine, working on a chemical tanker, having used previously on caustic soda remains, the equipment is now being used trying to control an acidic cargo outflow). But then, it should have been disposed of after cleaning in the first place. That is why you are supposed to inspect, because this was not done.

17)      Any and all valves on all pipelines, store ventilators, vents, flaps, closing appliances, mechanical ventilation devices etc.

18)      All manhole covers for cargo / ballast tanks and void spaces, vents etc.

19)      The void spaces and pipelines passing through them, including any valves located in them.

20)      Ladders, MOT or ship’s gangways.

21)      P/V Valves, Mast-Risers, P/V Breakers, IG Pipelines, cargo equipment, emergency hydraulic pumps, hydraulic and manual valve actuators, controls, boxes, lines etc.

22)      Deck pipelines, shafts etc. continuity cables etc.

23)      Dresser couplings or expansion joints.

24)      All Spectacle Flanges, blank flanges, spare reducers for cargo / bunkering etc., nuts and bolts, gaskets etc.

25)      Nitrogen bottles, room, connections and lines, if applicable.

26)      VECS

27)      Drip trays drains, cocks, valves and scuppers.

28)      Deck scuppers.

29)      All Cranes, wires, associated winches, drums etc.

30)      All bunker and cargo davits, fixed and portable

31)      Bunker tank vents, valves and lines

32)      Cargo pipelines, including tank cleaning / COW lines, valves etc.

33)      Pressure / Compound gauges, thermometers, IG gauges and connections

34)      All cargo tank fixed and portable gauging devices, including vapour locks, grounding devices etc.

35)      Pilot ladders and Pilot boarding arrangements

36)      Drain lines, cocks etc.

37)      IG line, deck seals, scrubber, IGG and valves, including all locking arrangements.

38)      Deck security equipment, including all padlocks, seals etc.

39)      All W/T doors on all decks.

40)      Deck lighting, emergency as well as normal

41)      Portable cargo lights, pneumatic or otherwise.

42)      All Bridge and Radio Equipment, navigational or communication, including mast lights, flag halyards, signal lamps – fixed and portable, Comm Equipment Antenna etc.

43)      ODMCS

44)      Overboard valves, Overboard discharge Annex I & Annex II arrangements

45)      In Engine Room, all valves, stand-by pumps and all lines,

46)      Oily Water Separator and 15 ppm equipment

47)      Emergency Sludge transfer arrangements.

48)      Sewage discharge connections

49)      Bunker manifold valves

50)      All Emergency Stops on the vessel

51)      220V & 440V alarm panels

52)      All other alarm panels

53)      Sample lockers, chemical lockers etc.

54)      CO2 room lines, cocks, and alarms etc.

55)      Pumproom alarms, lines, valves etc.

56)      Pumproom Exxon connection for Sea chest

57)      All blanks and spool pieces on deck or in pumproom.

58)      All loose lifting gear including chain blocks, slings, shackles etc.

59)      All fixed / portable gas measuring devices and instruments

60)      All measuring / calibration equipment

The list is not exhaustive, and can be continued. In short, I’ll say that everything, that seems to be the least important part / equipment of the ship and the risk of getting neglected is high, and which also will continue to remain on board, despite not being used, as a part of the ship, all that you may think of, as “may be required, so let’s keep it properly’ will be included. Some may not agree with me in my this description of Standy-by equipment, but trust me, there’s always more then what meets the eye to ISM.

Some of you may feel that, it is foolish to include just about everything as stand-by equipment. To you, I’ll ask one question. You may be the best in management, take care of each part of the vessel, the safeties etc. in terms of maintenance or inspections, so then the auditor or any inspector for that matter will have nothing to observe. How many of you have come across an inspector who always picks up easily, what you thought is not worthy of attention?

Let’s just say there is no end to it, and besides as a prudent ship-manager or sailor, why do you think the owners employed you in the first place? To take care of everything on board the vessel, I guess. Do you think, parts being missed in “taking care” is appreciated?

Think and apply. Think again and apply, and if you still feel that now I’m going overboard, well, my friend, my advice to you is simple. I believe learning can be two ways, one by other’s experience, one by own experience. Whatever you may prefer! You'll see the reason someday@!

Good luck in maintaining your vessel!

Drager Toxic Gas Detector Extension Hoses Correction Factor

Drager Chemical Gas Detection Tubes - Correction Factors for Extension Hoses.


Recently, one of my friends posted a question to our alumni Group mail, in regards to correction factor required to be used for some of the Drager tubes when used with Extension Hoses. This is not really applicable to all tubes, but only to some of them.


The query was as follows:

I have recently came across documentation in a Drager instruction manual which stated that when tubes are used in conjunction with 10 or 15 metre length extension hoses, a correction factor requires to be applied for certain tubes. The reading obtained on the tube requires to be multiplied by this correction factor. As can be seen, the gases this applies to are those which are commonly encountered on board ships.

The problem now is that Drager does not manufacture hoses in lengths greater than 15 metres, but can and do supply these if they are specifically ordered. If a hose of greater length is used, there are no clearly defined correction factors available. You will note from the attachment to this message that the factors for a 15 metre length are greater than those for a 10 metre length. It therefore follows that as the length increases, the factor that requires to be applied should logically increase. I am not entirely sure for the reason for this correction factor, but it could have something to do with the atmospheric pressure differential between the pump and the tube. 

Information on the use of extension hoses with other Draeger Tubes is available upon request. 

Tel. 4511882808

Measurement by means of 1Om and 15m extension hoses

Single-stroke measurement

Draw the sampling air through the tube with 1 pump stroke. When the stroke is finished -the white indicator mark on the pump becomes visible - allow for a waiting period of 2 minutes before removing the tube from the sampling point. Evaluation is effected in accordance with the instructions for use of the tube in question. Correction of the measuring result is not required for the single-stroke  measurement. 

Several-stroke measurement

Draw the sampling air through the tube with the specified number of strokes. Always perform the next

stroke once the white indicator mark becomes visible. No waiting period is required after the final stroke. If several-stroke measurement is performed by means of 10 m or 15 m extension hoses, the tube

reading of some of the Drager Tubes must be multiplied by a correction factor (See attached pages on this blog).

Now the first question is why? Why is a correction required?

The reason is most trivial and dates back to high school physics.

With a 3 m extension hose, the error is immaterial and is not worthy of consideration. I would not be very wrong in saying the same for even 5m hose. In fact, if your measurements are based on single stroke measurement, no correction is required to be applied with 10m or 15m tube lengths. It is only required to be used, when you have multiple stroke measurements with a tube.

The reason can be found in the way the chemical reactions take place in the tube. A number of chemical reactions are used in such tubes and these include :

1. rapid reactions which are independent of the flow rate through the tube;
2. rapid reactions with secondary reactions which may depend on the flow rate through the tube; 
3. consecutive reactions in which the vapor reacts with one reagent to produce products that are detected by reaction with a second reagent; 
4. reactions where a large excess of reagent is necessary.

For tubes involving reactions (3) and (4), flow rate is often critical because the reaction rate with the reagent can be slow. In addition some tubes involve the use of a pre-cleansing layer of a reagent which is intended to remove possible interfering substances.

And the flow rate is definitely affected by the length of hose. Why? Bernoulli’s Theorem…guess simple physics. Weight of the tube, causes elongation, causes the tube dia to reduce, causes change in flow rate.

What correction to apply?

Now what correction factor to apply with a tube of greater length (>15m) will need to be confirmed from Drager themselves. However, I’ve not come across anywhere, where greater then 15m length tubes are used. So drager has not provided further guidance too.

The volume which is conveyed with each pump stroke is not changed when the extension hose is used, however, the flow characteristic which is typical of the Drager gas detector pump may be subject to changes. This in turn results in a change of the opening time of the gas detector pump. For some Drager Tubes in conjunction with 10 or 15-meter extension hoses, such change is liable to cause errors in the readings. The reading must therefore be corrected. Given a hose length of 3 m, however, the change in the opening time is so insignificant that the influence on the measuring result can be neglected in any case. 

However, my friend did come up with a possible calculation - 

Drager tubes are calibrated at an atmospheric pressure of 1013 hPa (i.e. 1013 mbar), to correct for the influence of pressure, the value read from the tube scale must be multiplied by following correction:

Correction Factor = 1013 hPa (14.692 psi) / actual atmospheric pressure in hPa

The atmospheric pressure can be calculated by following formula:
P = 101325 (1 - 2.25577 10-5 h)5.25588
Where P= air pressure (Pa) and h = altitude above/below sea level (m)

I do not agree with this correction methodology, since then it would affect all types of tubes, not only some of them. It has more to do with the flow rate. 

Should any one know more, please do let me know.

Bridge Navigational Watch Alarm System (BNWAS) July 2012 due date!

Bridge Navigational Watch Alarm System (BNWAS) requirement
New buildings and existing ships need to be equipped with (BNWAS) in order to monitor bridge activity and detect bridge officers disability which could lead to marine accidents. Although due dates for existing ships are first periodical survey (annual intermediate, renewal) after 1 July 2012 the earliest, it is advisable to arrange retrofitting in forth coming Dry Docking/SS/ITSS. In this post you will find what BNWAS is and applicable dates depending on vessels type and size.

Application dates
SOLAS Ch.V Reg.19 as amended by res. MSC.282(86), adopted on 2009-06-05, has introduced a carriage requirement for BNWAS as follows:

1. Cargo ships > 150 GT and All Passenger ships constructed on or after 1 July 2011;
2. All Passenger ships constructed before 1 July 2011, first survey after 1 July 2012;
3. Cargo ships > 3000 GT constructed before 1 July 2011, first survey after 1 July 2012;
4. Cargo ships > 500 GT but < 3000 GT constructed before 1 July 2011, first survey after 1 July 2013; and
5. Cargo ships >150 GT but < 500 GT constructed before 1 July 2011, first survey after 1 July 2014.

Description of requirement
This Bridge Navigation Watch Alarm System (BNWAS) in simple terms is a timer alarm system that forces watch officers to reset this system in periodic time intervals to insure that they are fully alerted (not sleeping, playing solitaire with bridge computer,etc).

The requirement has the following main technical characteristics:

• After the system has been activated no alarm for a period of 3 to 12 minutes. 
• After this period the system initiates a visual alarm on the bridge
• If not reset with a period of 15 seconds an audible alarm on the bridge is activated. 
• If not reset with a period of 15 seconds from last audible bridge alarm, a second stage audible alarm is activated in a remote location (ships office, master office).
• If not reset a third stage alarm is activated in a remotely location were other officers can take corrective action within 90 seconds from the initiation of second stage alarm. 
• In vessels other than passenger vessels the second and the third stage alarms may sound in all of the above location at the same time. 
• In larger vessels time delay between second and third alarm can be set up to a maximum of 3 minutes. 

RESET Function

• It should not be possible to initiate the reset function or cancel the audible alarm from a device not physically located in the bridge area providing proper lock out. 
• The reset function should be a single operation function. 
• The single operation reset action must be in such a way that will ensure mental alertness of the OOWS. 
• The dormant periods should not be able to be prolonged by continued activations or any reset devices. 

Better to start working on it now, then later.

DPA, an ISM requirement or a Commitment?

Designated Person Ashore

Recently, I was speaking to a friend, who holds a senior position in a Shipping Company. He has definitely more exposure and more experience than me ashore, and while talking to him, we did touch the aspect or the question of “Who can be the Designated Person Ashore, in view of ISM Code, 4.0”?

As per him, there are numerous shipping companies, still operating, some who have even appointed a Front receptionist or a mere graduate, non-sailor as a DPA. And surprisingly, the company’s DOC (Document of Compliance) is intact. The certifying bodies have not probably even raised Non Conformity to this aspect.

Now let’s investigate this firstly on the basis of what the preamble to ISM Code says.

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

This implies, the intent of the code is to ensure an international standard, and of course it deals with Safe and environment friendly management and operations of the ship. This part in effect really gives a common principle to the code.

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.

This gives the companies a scope to operate under various structure and processes, however, the agenda remains the same, safe and environment friendly management and operations. The general principles and objectives are the same for all companies.

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.

This highlights the importance of having appropriate knowledge and awareness.

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.

Now this is the key principle of the entire ISM Code. This is the entire reasoning behind the development of ISM Code.
1. Commitment at all levels to ensure safety & environmental protection. Believe it should start from the top management. 
2.  Competence. All personnel deputed various roles within the organization, whether onboard or ashore should be competent for at least their jobs. If we evaluate it in light of STCW, even sailing staff is supposed to be competent, be it in support role, operational role or management role. 
3.  Attitudes. But obviously, believe it is not meant that anyone should have any wrong attitudes. It means attitude to ensure safety & environmental protection. 
4. Motivation. Rarely practiced in any industry, the only motivation anywhere is money, career growth, appreciation, security and self-esteem. The personnel working onboard or ashore should be sufficiently motivated to ensure safety & environment protection, to go that extra mile to ensure compliance to ISM objective.

Before, I proceed further into investigating this aspect, let’s see what ISM Code says about the DPA.

“ ISM Code 4:  DESIGNATED PERSON(S)

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. “

Let’s break the above into parts and analyze them:

“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”

The rest of the sentence, we’ll analyze at a subsequent stage. However, those who have studied English Grammer, would identify this sentence has a meaning in itself, outside the rest of the part. 
1)    The companies are supposed to appoint a DPA 
2)    The objective of appointing DPA is

a.     to ensure safe operation of each ship; and

b.     to provide a link between company and those on board.

It is strange, that this is not considered by most of the companies. The DPA should be able to understand safety in maritime industry, which would further imply, having knowledge of SOLAS, MARPOL, STCW, amongst other codes, regulations and be able to really understand the operations, the ships undertake to be able to ensure. If I do not understand the implications, the requirements and the limitations of driving, how can you appoint me as a driver of a lorry?

Further, the 2^nd item speaks of providing link between company and those on board! This implies, that the DPA must be able to connect directly with the Master and onboard personnel? But we have DPA’s who have rarely seen the ships, some who have rarely seen the Masters on board but they are the DPAs. Unfortunately, and on the contrary, the DPAs mostly are so lost and have no situational awareness for the vessels that they rarely know what is going on board the vessels.

The Designated Person ashore is something like the Safety Officer on board the ships. Would that mean, he/she should be able to make decisions? Would that mean that he/she should be qualified to make decisions? Would that also mean that he/she should be a person with some authority and training in this scope?

My understanding is that this first phrase actually is the Objectivity about the DPA, who can be and what role is he primarily supposed to serve.

“every Company, as appropriate, should designate a person or persons ashore having direct access to the highest level of management.”

Now we talk of a functional requirement.

The DPA should have direct access to the highest level of management. This implies, if the highest level in a company is the Management Board, then DPA should be able to approach them, and if the share holders body is recognized as the highest body in the company’s management chart, the DPA should be able to have access to them.

The original draftsmen of the Code intended to have a conduit, a medium, a kind of focal point for the communication flow on matters of safety to freely pass in all directions, a unique person with multi-talented capabilities. Traditionally, the Superintendent would perform such a function. However, to facilitate such a communication flow I do believe that the DPA must be well known, trusted and respected by those on board the ship and in the office ashore. They must be seen to be effective, to have the ability to deal with all issues, to provide leadership, motivation, commitment and have the right attitude to ensure that feedback loops are always closed, that the questions and queries are answered, that problems posed are solved.

“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.”

The UK regulations take a more detailed approach in ‘SI 1998 No. 1561 The Merchant Shipping (International Safety Management (ISM) Code) Regulations 1998’ which states, at Section 8:

http://www.legislation.gov.uk/uksi/1998/1561/regulation/8/made

Designated  Person

8. (1) The company shall designate a person who shall be responsible for monitoring the safe and efficient operation of each ship with particular regard to the safety and pollution prevention aspects.

(2) In particular, the designated person shall-

(a) take such steps as are necessary to  ensure compliance with the company safety management system on the basis of which the Document of Compliance was issued; and

(b) ensure that proper provision is made for  each ship to be so manned, equipped and maintained that it is fit to operate in accordance with the safety management system and with

statutory requirements.

(3) The company shall ensure that the designated person-

(a) is provided with sufficient authority and resources; and

(b) has appropriate knowledge and sufficient experience of the operation of ships at sea and in port, to enable him to comply with paragraphs (1) and (2) above.

The DPA should be able to monitor the safety and pollution prevention aspects of the shipboard operations. I’m not sure, how many DPAs actually have access to each and every mail that originates to and from the ship. How many actually view each one of the them, raise objections, raise questions, understand the risks involved, take part in risk assessments and have an overview of each activity of the vessel. In 2005, while serving on a vessel as a Chief Mate, I once had to call the DPA of my company (Master had stepped ashore) for an operational problem, that was eventually, apart from having the potential of financial loss to the charterers / owners, could cause a statutory problem for the vessel. The DPA on hearing out the problem said he was on vacations (I as a Chief Mate of course had no idea that he was on vacations, but eventually, I found out, neither the Master had, there was no notification from him) and asked me to talk to the Alternate DPA. The alternate DP was an erstwhile Chief Engineer, who was not well aware of the Chemical trade (I was on a parcel chemical tanker) and directed me to another Superintendent who was supposed to be the company’s expert on Chemical trade. Fine no issues with this; one person is not supposed to know all. If I was in his place and someone would call me to speak about a generator problem, I too will direct him to the more technically sound person. But isn’t monitoring supposed to be within the scope of DPA? Isn’t he supposed to have the ability to monitor?

The DPA is further supposed to ensure that the ships are provided with adequate resources and shore-base support. If, I do not have the knowledge and the expertise, how am I supposed to ensure as DPA, what resources and supports I should provide.

Looking from the angle of English Merchant Shipping Regulations, the DPA should be able to judge what is required and what is not required, again a Decision Maker, and he should too be provided with sufficient authority and resources.

On a number of occasions, you will find the failure of a company stemming out of the basic reason that the DPA is practically ineffective and often not really aware or not understanding their actual role or what is expected of them as DPA.

In effect the authority and responsibility of DPA should cover the following:

a.  The designated person has to collect and analyze all the operational information regarding the implementation of the SMS of the Company, which would thus also include his ability to verify them and act upon them to firstly, prevent problems and thereafter, taking corrective actions, if needed.

b.      Discuss with all the personnel concerned any matters related to safety and environmental protection and the application of this aspect to all operations on board ships.

c.       Monitor the operation of each ship as far as pollution and safety are concerned.

d.     In the event of  deficiency, the designated person shall not only have direct access to the highest level of management to seek guidance but by virtue of section - 4, he shall also be vested of all the required resources.

The choice of the correct Designated Person and his competency are fundamental for the success of the implementation of the Code and the SMS of the company. The Companies will have to select a person who would have adequate competency and shipboard experience as a Chief Engineer or Master who can gain the respect of the personnel at sea and ashore. He should have a good knowledge of how the Company works and should be aware of his responsibility to satisfactorily deal with reporting of casualty, near misses, non-conformities, hazardous occurrences etc.

It is the Company’s responsibility to give all possible support and cooperation of all the shore staff / ship staff to the designated person in order to carry out the objectives of the ISM Code.

The main role of the designated person is preventing accidents for safe operation of ships and prevention of pollution and to carry out analysis of any accident to see whether the act of the owner or act of the person or any omission or any other intention to cause such accident, or having the knowledge that such accident would probably result so that preventive action is immediately taken to avoid the recurrence of such accident.

In view of the above responsibility any fault of the designated person in the implementation and maintenance of the SMS, could therefore have legal consequences as it could make the owner loose his right to limit his liability. The DPAs should also realize that because of the legal consequences, they are highly prone to becoming the scape-goats, after all someone needs to get the blame, if the company has to survive.

This was an argumentative reasoning, why the companies must ensure, a sufficiently qualified, competent and knowledgeable and senior person is appointed the DPA

Now lets see, if IMO is giving any more guidance. Yes it does. After a lot of deliberations and resulting inferences, IMO did come out with two circulars on the 19^th October 2007.

MSC-MEPC.7/Circ.5 and MSC-MEPC.7/Circ.6

MSC-MEPC.7/Circ.5 of 19^th October 2007 providing guidelines for the operational implementation of the ISM code by companies states the following:

4 DESIGNATED PERSON

4.1 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.

4.2 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.

4.3 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.

4.4 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.

And what does MSC-MEPC.7/Circ.6 state?

The IMO circular outlined a minimum set of criteria for formal education. It stated that the DP must possess one of the following
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.

For practical training, the IMO insists that the DP 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. 

And further, in the most important area of experience, the following is necessitated: 
9.     ability to present ISM matters to the highest level of management and gain sustained support for safety management system improvements; 
10.  determine whether the safety management system elements meet the requirements of the ISM Code; 
11.  determine the effectiveness 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; 
12.  assess the effectiveness of the safety management system in ensuring compliance with other rules and regulations that are not covered by statutory and classification surveys and enabling verification of compliance with these rules and regulations; 
13. 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 
14.  gather and analyze data from hazardous occurrences, situations, near misses, incidents and accidents and apply lessons learned to improve the safety management system.

Since verification of ISM Code compliance is achieved through a series of audits, the IMO further outlined that the company should provide training, including practical training and continuous updating. The company should also provide evidence that the DP has the relevant qualification, training and experience to undertake the duties under the ISM Code. 

I won’t be wrong, and believe the experienced professionals would agree, that certificates and mere education cannot replace real experience. Hopefully someday, the number of adequately qualified Designated Persons is more than the number of merely certified and/or nominated DPAs and possibly, then the companies would really be able to implement ISM in its true spirit.

Until then, we live with non-conformities, and inadequate enforcement of the code.

The above views are completely mine, with quoting parts of legislature in this regards from the sources, as indicated. It is difficult to imagine someone not agreeing to my views, but believe a debate on this would provide greater insight. Always, pleased to hear.

Oh, by the way, to clarify, someone commented in email on reading this, in my opinion, who should be the DPA.


Well, honestly, can be any sailor, but the most suited would be a Master, not by certification, but who has really served as Master. Who else is supposed to handle "over-riding authority"; has the "decision making experience"; has dealt with more number of scenarios then other seafarers and has been in "command". Further, in my opinion, there should be some kind of psychological analysis available for the DPA, which could conclude that he / she is suited or not. 
If the companies are really willing to implement this, one of the best courses that can really help is the "Command" course by Nautical Institute, adequately developed to serve this purpose.

Best regards,

Rajesh Baran

(+65 83033070)

rajeshbaran@gmail.com