(This article is part of the workshop conducted at PJZ Marine Services Sdn. Bhd., Malaysia - My full appreciation to International Marine Organization, International Marine Contractors Association, Standards of Training Certification & Watchkeeping, Master (1st) Class Mariners/DPA, Marine Department of Malaysia, Royal Navy of Malaysia, Shell Malaysia and so many more)
OSHA ACT 1994 DOES NOT FULLY APPLY
TO YOU BUT SERVES AS A GUIDELINE
OSHA
1994 :
First
Schedule,
Section
2, Sub-Section 3 : Mining:
The process or
business of obtaining or extracting any mineral from above or below
the ground or in or below the sea. • Coal mining • Crude
petroleum and natural gas production
• Metal mining (Applicable
to Client)
Section
10 (3) :
This
Act also applies
to offshore installations
as included in premises defined in Section 3 (1). The Petroleum
Mining Act 1966 interprets off-shore
land to mean the area of the continental shelf. Under section 21 (2)
of the Exclusive Economic Zone Act 1984 the government has exclusive
jurisdiction over artificial islands, installations and structures in
the zone and on the continental shelf, including jurisdiction with
regard to customs, fiscal, health, safety and immigration law.
(applicable if
you’re involved in supporting offshore installations)
Example:
Nothing
in this Act shall apply to work on board ships governed by the
Merchant Shipping
Ordinance
1952 (Ord. 70/52), the Merchant Shipping Ordinance 1960 of Sabah
(Sabah Ord. 11/60) or Sarawak (Sarawak Ord. 2/60) or the armed
forces.
This
Act is not applicable
to persons working on board ships except on board of ship
exempted
by the Merchant Shipping Ordinance 1952 (Ord. 70/52), the Merchant
Shipping Ordinance 1960 of Sabah (Sabah Ord. 11/60) or Sarawak
(Sarawak Ord. 2/60).
Ships
include every description of vessels used in navigation not propelled
by oars. Ship repair dockyard and public dry docks not
covered under this
Act except
when the owner or ship master engaged a contractor to do the
maintenance or repair work. (applicable
if you’re a contractor doing maintenance or repair work)
Harbour
of commerce or port is covered under this Act but
not the ship anchor at the harbour or port
. Under Merchant Shipping Ordinance 1952 the Minister of Transport
may make port rules to ensure the safety of employees employed in
ports and on ships using ports.
Section
28 : Safety Officer
Under
this order it is compulsory to employ a safety and health officer for
an employer of any building operation or work of engineering
construction where the total contract price of the project exceeds
twenty million ringgit, any
ship building,
gas processing activity or petrochemical industry and any chemical
and allied industry employing more than a hundred employees.
(Applicable to
ship builders and NOT you)
WHAT
IS NOT COVERED BY OSHA ACT, IS AUTOMATICALLY COVERED BY SOLAS AND ISM
AND ALL OTHER REGULATIONS AND RULES
A. OBJECTIVES
To assist in understanding and
implementing a formal management system of Offshore Marine Support
Vessel benchmarked to :
- The
International Safety Management Code (ISM) – an International
Management Code for the Safe Operation of Ships and for Pollution
Prevention,
- Others
as necessary such as : IMCAM 149 Issue 7 – March 2009, Standards of
Certification, Training & Watchkeeping (STCW) OHS Act 1994, OHSAS
18001:2007 and applicable safety standards and codes of practice.
Where necessary the QMS ISO 9001:2008 (ISO 19011) and EMS ISO
14001:2004 requirements shall also be applied.
- The system shall be
customized to the scope and services by the client as far as if
practicable.
1.0 GENERAL
OVERVIEW OF OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT SYSTEM PRACTICE
1.1 GENERAL
Scope :
Provision of Marine Services
(Which
consist of
a)
integrated services solution for operations and main fixed and
floating offshore,
b)
fast crew boat vessel)
generallly
- scope to include contractors, sub-contractors, vendors, suppliers
etc.
With
this scope, you must identify
:
With
this scope, you must have
:
ISM
Clause 1.2 & 1.4
Objectives
: 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
Among
others (interalia):
provide
for safe practices in ship operation and a safe working
environment;
establish appropriate safeguards
against all identified risks; and
continuously
improve safety management skills of personnel ashore and aboard
ships, including preparing for emergencies related both to safety
and environmental protection.
Also
to ensure:
compliance
with mandatory rules and regulations; and
that
applicable codes, guidelines and standards recommended by the
Organization, Administrations, classification societies and maritime
industry organizations are taken into account.
Must
develop, implement and maintain Safety Management System (SMS) :
OHSE
protection policy, instruction, procedures (for ship safe operation
& protecting environment)
Authority
and communication defined – shore & shipboard
Procedures
– accident reporting, nc, emergency preparedness, internal audit
and MRM
NOTE
TO AUDITORS
The company
Safety Management System (SMS) : provide for methods of
identification of risks and establishment of safeguards against the
same. During audit : Evidence to be shown – risk assessment
procedures. Verified during audits of the company for DOC issuance.
Random
sampling may be needed – verified for effectiveness. Any
inadequacies require closer look. Tips for sampling –
incidents/accidents on board of vessels.
TYPICAL SAMPLE OF SMS STRUCTURE
1.2 POLICY
(ISM Code Clause 2)
What to
cover : (at both ship level and shore (HQ as well)
Most
important : All applicable
relevant aspects of Safety, Health, Environment including security
where necessary.
What are
the aspects :
Consistent
with the scope of OHSE Management System
Appropriate
to the nature, scale and risks in its services
(related
only to integrated services solution
for operations and main fixed and floating offshore, fast crew boat
vessel)
Commitment
for :
Continual
Improvement – (get
revised when new updates received, e.g. CI upon closing NCR,
discussion in annual review meeting, inspections, audits etc.)
Prevention
(injury related & ill health)
Comply
to relevant legislation and regulations in handling OHSE hazards.
Provide
framework for setting/reviewing objectives
documented,
implemented, maintained and communicated
readily
available for assessment
periodical
review
training
and resource management
Signed
and approved by top management (MUST) and overseen by relevant
authorized & competent person.
ISM
says :
ESTABLISH
- safety and environmental protection policy which describes how the
objectives will be achieve
ENSURE
- the policy is implemented and maintained at all levels of the
organization both ship based as well as shore based
NO POLICY DENOTES NO
COMMITMENT
NOTE
TO AUDITORS
The
policy statement(s) should be clear
and concise,
with emphasis on the Company’s commitment to OHSE. Identify a
strategy by which the Company aims to achieve objectives with methods
to encourage improvement in safety awareness and safety management
skills. The
policy should be endorsed
by the Senior
Management
of the company
The
strategy for implementation of the policy should
be clear
so that it can be understood
at all levels within the Company.
During
audit (both shore and ship) Members of the Company’s management
team* should be interviewed during an assessment. This is an
effective means of establishing whether there is commitment to the
Safety Management System at the highest levels within the Company
*
Shore
|
Ship
|
Managing
Director
|
Master
|
Operations
Manager
|
Chief
Engineer
|
Technical
Managers
|
Safety
Officer
|
Designated
Person
|
Chief
Officer/Mate
|
Quality
Manager
|
Training
Officer
|
Safety
Manager
|
Engineer
/ Deck Officers
|
Personnel/Training
Manager
|
Bosun
/ CPO
|
Superintendents
|
Sample
of Deck / Engine / Catering Ratings
|
Other
Office Staff
|
Cook
& Galley Staff
|
Junior
personnel should be interviewed on a random basis concerning their
responsibilities within the SMS. They must have the background and
experience appropriate to their role, received suitable training, and
possesses adequate knowledge of the SMS. Training procedures
required.
1.2 RESPONSIBILITIES
AND AUTHORITY (ISM Code
Clause 3)
ISM : 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.
NOTE
TO AUDITORS
The
operator to ensure that the owner fulfils the requirement of this
section of the Code. Details reported to the interested parties (port
authorities, client, top management etc) . The identification of the
Manager on the relevant form issued by the interested parties serves
as evidence of compliance with this requirement. (Sub-Contractor,
specialists, consultants etc)
ISM : 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.
NOTE
TO AUDITORS
To document
R & A so that personnel involved in the SMS
know what is expected of them
and to ensure that the OHSE functions have been allocated. Documented
management system should contain clearly worded, descriptions of the
R & A (JD
& Master Responsibility Matrix/Process Owner spelled out in
procedures)
together with the reporting lines of personnel within the management
structure (organization
chart).
Schematics
or flowcharts
to document lines of authority and inter-relations between roles
would be acceptable.
ISM : 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.
NOTE
TO AUDITORS
Company
to be committed
providing the support necessary for the Designated Person to fulfil
his / her duties. This may include reviewing correspondence between
the Designated Person and the management board, the budget
for safety training
(including the necessary infra) and the attitude towards safety
issues at management level. Commitment
must start at the top
and be prevalent throughout the Company.
SAMPLE
JD & R & A
CHIEF
ENGINEER
Personnel
- Manage the operation of the vessel systems at department level
through supervisors and subordinate staff.
- Exercise
appropriate authority with regard to career development, providing
training and support in terms of competence assurance system.
- Ensure
probationary and annual appraisals are completed fairly and
consistently in timely manner.
- Manage
welfare and disciplinary issues at departmental level with
appropriate reference to Captain and HR.
Works
- Efficient
operation of unit systems having due regard for Health and safety.
- Ensure
full compliance with PTW system, and Risk assessment and
verification.
- Ensure
full compliance with Class, Flag and Port State requirements,
preserving the vessel's operational status.
- Effective
supervision of project, sub contract and vendor personnel.
- Efficiency improvement and pursuance of company goals.
- Responsible for condition monitoring, maintenance and repair of
vessel and process systems.
- Manage parts control, inventories
storage record keeping, shipping and receiving by use of maintenance
plan or maintenance software application.
3)
Contract
- Manage
operations in conjunction with all department heads to maximize
efficiency and uptime.
- Maintain effective cost control and
promote cost awareness in others.
- Maintain awareness of key
issues relating to client and sub contractor relationships.
Note
:
(Competent
Personnel – Master Mariner, Engineer Class 1 with experience
associated associated with offshore production floating facilities in
a supervisory/management capacity, knowledge of Marine, Production &
Engineering and Maintenance Management. Able to manage all aspects of
the marine operation) good communication (written & oral) Skills
OHSE and management skills, understanding human behaviours,
leadership, counselling & coaching)
1.3 DESIGNATED
PERSON(s) (ISM
Code Clause 4)
ISM
: ensure safe operation of ship (vessel) - provide a link between the
Company and shipboard, designate a person or persons ashore having
direct
access to the highest level of management.
(SMS MR) The responsibility & authority of MR to include
monitoring the safety and pollution- prevention aspects of the
operation of vessel and ensuring adequate resources and shore-based
support are applied.
NOTE
TO AUDITORS
In order
for any system of management to be adequately maintained it is
essential that it is monitored at regular intervals. This will ensure
that:
• implementation
is verified;
• deficiencies
are reported; and
• those
responsible for corrective action are identified and that appropriate
action is taken.
The
task of implementing & maintaining SMS is a management
responsibility with Designated Person holds a key role in the
monitoring process. He/She should be suitably qualified;
experienced in ship operations and be fully conversant with the
Company’s OSHE protection policies and SMS. Working independently
and having authority to report to the highest level of management
Also in charge of coordinating the Company’s safety audits.
How
so?
minimum
of formal education as follows:
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 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, or other
formal education combined with not less than three years
practical senior level experience in ship management operations.
should
have undergone training relating to safety management elements
in compliance with the requirements of the ISM Code, particularly
with regard to:
knowledge
and understanding of the ISM Code, mandatory rules and regulations,
applicable codes, guidelines and standards as appropriate, assessment
techniques of examining, questioning, evaluating and reporting,
technical or operational aspects of safety management, appropriate
knowledge of shipping and shipboard operations, participation in at
least one marine-related management system audit; and effective
communications with shipboard staff and senior management.
should
have experience to:
present
ISM matters to the highest level of management and gain
sustained
support
for safety management system improvements;
determine
whether the safety management system elements meet the requirements
of the ISM Code;
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;
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;
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
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.
1.4 MASTER'S
RESPONSIBILITY AND AUTHORITY
(ISM Code Clause 5)
ISM
: clearly define
and document the master's
responsibility with regard to :
implementing
the safety and environmental-protection policy of the Company;
motivating
the crew in the observation of that policy;
issuing
appropriate orders and instructions in a clear and simple manner;
verifying
that specified requirements are observed; and
periodically
reviewing the SMS and reporting its deficiencies to the shore-based
management.
NOTE
TO AUDITORS
The
responsibility for overseeing and implementing all relevant aspects
of the Company’s SMS on their vessels rests with the Master. Clear
guidance should be provided to Masters concerning their
responsibility on matters affecting the safety of the ship, its
passengers and/or cargo and the environment.
ISM
: Ensure SMS operating on board contains a clear
statement emphasizing the
master's authority. 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.
NOTE
TO AUDITORS
Masters
should get support
& encouragement
from the Company at all times. There must be a clear statement
(documented) that the Master has overriding authority to deviate
from the documented system in time of crisis
& seek assistance from the Company if required. Both statements
must be clear
& unequivocal
with the appropriate emphasis placed on the Master’s
overriding authority.
SAMPLE
: MASTER AUTHORITY/RESPONSIBILITY
The
Master has full responsibility and command of the vessel and all its
personnel. His/Her lawful orders must be strictly and promptly obeyed
by all officers, crew, and any others onboard. The Master shall
require a high degree of professional competence from his officers
and seaman-like conduct from all onboard.
The
Master is the Company representative, and their actions and decisions
are generally binding upon the Company.
Job
Duties & Responsibilities:
Master
will supervise the preparation, execution, and documentation required
and necessary to conduct ship’s business. Some of the duties and
responsibilities of this position are:
Thorough
familiarity with all applicable governmental regulations and Company
policies and shall ensuring strict compliance by all parties onboard
Implementation
of safe practices and promotion of “safety-mindedness” in all
hands onboard
Administration
of health and welfare of the crew, their training, and employee
relations
Ensuring
good appearance & condition of the vessel
Overseeing
& supervising safe navigation and cargo/ballast operations of
the vessel
Efficient
transportation of vessel's cargo
Ensuring
that the vessel is adequately provided with sufficient spares,
stores and bunkers.
Ensuring
that the necessary training required by flag state, port state,
class society, or Company is obtained by the crew
Taking
prompt and necessary actions in the event and for the prevention of
any environmental pollution or spill
Safeguarding
vessel’s documents and narcotics stores
Implementation
and management of Company’s ISM safety management system
Successful
performance in vettings and customer inspections
The
Master must also perform other duties and tasks as assigned.
Job
Requirements:
This
position requires minimum of International Merchant Mariners Master's
License for motor vessels with radar endorsement or STCW or
equivalent, Good communication skills, experience in various vessels,
good bridge management, Ship Handling training,Experience with
computerized planned maintenance system (NS5/Safenet) Ability to work
in a culturally diverse environment and in close quarters with
international crew
1.5
RESOURCES AND PERSONNEL
(ISM Code Clause 6)
Master
– properly qualified for command, conversant with SMS, is supported
for the sake of safety.
Company
to :
Ensure
ship
(vessel) is manned with qualified, certificated and medically fit
seafarers in accordance with national and international
requirements.
Establish
procedures to ensure that new personnel & 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.
Ensure
that all personnel involved in the SMS have an adequate
understanding of relevant rules, regulations, codes and guidelines.
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.
establish
procedures by which the ship's personnel receive relevant
information on the SMS in a working language or languages understood
by them.
ensure
that the ship's personnel are able to communicate effectively in the
execution of their duties related to the SMS.
NOTE
TO AUDITORS
The
Company has a clear
responsibility
to employ properly qualified
and medically fit seafarers
and to be satisfied that they are familiar
with the management
system
operated by the Company. The company should be able to satisfy the
auditors, by whatever means, that this requirement of the Code is
being adequately addressed. Copies
of certificates may be held on file in the office or it may be
necessary to have a random sample of certificates faxed in from a
cross section of the fleet.
STCW
A-I/14 (Responsibilities of Companies) requires the Company
to provide written instructions to the Master setting forth the
policies and procedures to be followed to ensure newly joined
seafarers are familiar with their duties before they are assigned to
tasks on board.
This shipboard familiarisation should include sufficient
time to become acquainted with:
•
emergency / evacuation procedures and arrangements to perform
assigned duties properly.
•
ship specific duties related to the role the seafarer will fulfil
onboard
•
ship specific knowledge of any safety and environmental protection
procedures with which the seafarer should be acquainted
A
knowledgeable crew member should be designated to ensure that
essential information is provided to newly joined seafarers in
a language they understand.
The STCW Code requires mandatory training in crowd management for
some personnel serving on passenger ships. Records of familiarisation
and instructions received by crew members should be available for
examination by the auditor(s). (e.g. TBM, refresher etc.)
SMS
must embrace all existing International Conventions, national rules
and regulations, industry guidelines and codes of practice. It is
acceptable for the SMS to encompass such documents as the Code
of Safe Working Practices for Merchant Seamen, the Bridge Procedures
Guide
and the Tanker
Safety Guide
etc.
The
means of identifying the training needs of individuals, both ashore
and onboard, is for the Company to address. This may be achieved by a
staff
appraisal, the end of contract report for seagoing staff, by results
of internal audits, drills and analysis of accidents.
Training requirements could be met by refresher
training
courses and on the job experience.
The
SMS, in whatever form, must be available to all personnel, both
ashore and afloat. It is the responsibility of the Company to ensure
that the Manuals are in a language(s) understood by the crew. The
Company’s procedures should detail
the process by which crew members are selected and detailed to its
ships and are familiarised with their responsibilities prior
to taking up a position on board.
The
ability of crew members to communicate
effectively
is fundamental
to the safety of the ship.
This
should be assessed
at the recruitment stage and manning agencies should be vigilant in
this exercise. The Company should ensure that there are procedures in
place to monitor the manning agencies which they use.
1.6
DEVELOPMENT
OF PLANS FOR SHIPBOARD OPERATIONS
(ISM
Code Clause 7)
The
Company should establish procedures for the preparation of plans
and instructions,
including checklists
as appropriate, for key shipboard operations concerning the safety of
the ship and the prevention of pollution. The various tasks involved
should be defined and assigned to qualified personnel.
NOTE
TO AUDITORS
The
Company should establish the key shipboard operations and ensure that
procedures and instructions are laid down for carrying out these
operations. While shipboard operations will vary from ship type to
ship type, it is suggested that plans and instructions for the
following operations should be documented:
• general
shipboard operations
• port
operations
• preparation
for sea
• conduct
of the voyage
• preparation
for arrival in port and
• emergency
response organisation
The
auditor(s) should verify that the operations established by the
Company are pertinent and comprehensive for the ship type(s) that the
Company operates.
1.7
EMERGENCY PREPAREDNESS
(ISM Clode Clause 8)
The
Company should :
identify
potential emergency shipboard situations, and establish procedures
to respond to them.
establish
programmes for drills and exercises to prepare for emergency
actions.
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.
NOTE
TO AUDITORS
The
procedures
should integrate
the response to potential emergencies by shore-side and shipboard
operations.
The Maritime Safety Committee of the IMO has developed ‘‘Guidelines
for an Integrated System of Contingency Planning for Shipboard
Emergencies’’
The
drill
programme should exercise the emergency plans and
where appropriate, mobilise
the shore-side emergency contingency plans.
Drills
should be carried out at regular intervals in order to test the
Company’s emergency response organisation and the competence of
those who will be called upon in a real emergency. The
ability of the personnel ashore to respond to emergencies should also
be tested periodically. Records of all drills and exercises should be
kept and be made available for examination.
In the event of the Company having to respond to a real emergency
this may be considered in lieu of an exercise drill, providing that
records have been retained and analysed.
TYPICAL
CONTENTS CONTIGENCY PLAN
Contingency
Plans may include:
• the
role and responsibilities of shore and ship personnel at the time of
an emergency
• a
list of names and contact numbers of all relevant parties
• procedures
to be followed in response to varying emergency scenarios
• procedures
for communication between ship and shore
• a
database of plans, particulars of vessels, emergency response
capabilities, damage stability information and pollution prevention
equipment
• checklists
for a range of emergencies (the use of checklists is strongly
encouraged)
• procedures
for notifying next of kin
• guidelines
for liaising with the press and media; and. procedures for requesting
emergency services from third parties
Emergency
scenarios for which contingency plans might be developed, include,
but are not restricted to:
• structural
failure;
• main
engine failure;
• failure
of steering gear;
• failure
of electrical power;
• collision;
• grounding;
• shift
of cargo;
• pollution
(spillage of oil or other cargo);
• fire;
• flooding;
• abandon
ship;
• man
overboard;
• entry
into enclosed spaces;
• terrorism
or piracy;
• helicopter
operations for medical evacuation;
• heavy
weather damage; and
• treatment
of serious injury
1.8
REPORTS AND ANALYSIS OF
NON-CONFORMITIES, ACCIDENTS AND HAZARDOUS OCCURENCES
(ISM Clode Clause 9)
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.
The
Company should establish procedures for the implementation of
corrective action.
NOTE
TO AUDITORS
The
SMS should contain procedures that
require reports to be prepared and forwarded to the Company on all
accidents, hazardous occurrences and non-conformities.
They should be monitored by the Designated Person and the appropriate
corrective action determined with the ultimate aim of avoiding a
recurrence of the incident or non-conformity.
Any
deviation
from the SMS procedures and instructions, that represents a
non-conformity, should be recorded,
raised on a non-conformity note and forwarded to the Designated
Person. The system should be designed to allow for continual
updating, amendment and improvement as a result of the reporting
procedures.
The
reports should be recorded,
investigated, evaluated, analysed and acted upon
as necessary. There should be procedures
for feedback to the reporting ship and for circulation
around all appropriate areas. Motivation is a significant factor in
the success of the management system and feedback is a powerful
motivator. Feedback should be recorded. Evaluation and analysis may
lead to:
• identification
and implementation of corrective action;
• benefits
to the whole Company;
• amendments
to existing procedures;
• development
of new procedures.
The
Accident Reporting and Investigation Regulations (S.I. 2005 No. 881)
define accidents, serious injuries and dangerous occurrences along
with statutory reporting requirements.
1.9 MAINTENANCE
OF THE SHIP AND EQUIPMENT
(ISM
Code Clause 10)
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.
To
meet the requirements :
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.
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.
(Critical Equipments)
The
inspections mentioned as well as the measures should be integrated
into the ship's operational maintenance routine.
NOTE
TO AUDITORS
Procedures
should be developed to ensure that maintenance,
surveys, repairs and dry-docking
are carried out in a planned and structured manner with safety as a
priority. All personnel responsible for maintenance should be
suitably qualified and familiar with national and international
legislation as well as classification society requirements. The
shore-side management team ashore shall provide technical support and
advice to the seagoing staff.
Maintenance
procedures must also include work instructions
to ensure that machinery
or systems undergoing maintenance
have been rendered safe prior to starting work i.e. that
systems under pressure such as engine cooling water, oil fuel and
steam systems
have been securely
isolated and de-pressurised.
The
Company should arrange for inspections of its vessels to be carried
out at regular intervals. These inspections should be executed in
compliance with the appropriate procedures by competent and qualified
personnel. Records of maintenance, inspections, certificates and
reports may be maintained both on board ship and ashore if considered
appropriate by the company.
(IMCAM
149 Issue 7)
TYPICAL
CONTENTS OF MAINTENANCE PROCEDURES
Maintenance
procedures should include:
• hull
and superstructure;
• life
saving, fire fighting and anti-pollution equipment;
• navigational
equipment;
• steering
gear;
• anchors
and mooring equipment;
• main
engine and auxiliary machinery including pressurised systems;
• cargo
loading and discharge equipment;
• tank
venting and inerting systems;
• fire
detecting systems;
• bilge
and ballast pumping systems;
• waste
disposal and sewage systems;
• communications
equipment;
• emergency
lighting; and
• gangways
and means of access.
There
should be procedures for reporting non-conformities and deficiencies
that should include a time scale for completion of corrective action.
It is the Company’s responsibility to ensure that reports are
investigated and feedback provided to the reporting officer. The
Company should be seen to be providing support to enable the SMS to
function effectively.
It
is the Company’s responsibility to identify critical systems and
equipment. Once the critical systems have been identified, procedures
should be developed to ensure reliability of these systems or the
provision of alternative arrangements in the event of sudden failure.
The procedures implemented should include the regular testing of
stand-by systems in order to ensure that one failure does not result
in the total loss of that critical function. Maintenance routines
should include the regular and systematic testing of the all such
critical and stand-by systems.
Critical
equipment listings may include:
• navigational
aids including radar;
• fire
pumps including emergency fire pump(s);
• generators
including emergency generator;
• steering
gear;
• fuel
systems;
• lubricating
oil systems;
• emergency
stops and remote closing devices;
• communications
systems;
• main
engine propulsion systems.
The
auditor(s) should examine the measures which have been developed to
promote reliability including records, frequency of
inspection/testing and maintenance procedures.
1.10
DOCUMENTATION (ISM Code Clause 9)
The
Company should establish and maintain procedures to control all
documents and data which are relevant to the SMS
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.
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.
NOTE
TO AUDITORS
Procedures
should be in place for the control of all documentation, which should
be approved prior to issue and assessed for its user friendliness.
This is an essential element of any SMS Personnel at all levels
within the Company should be familiar with the procedures and with
the latest version of the documentation. Obsolete documentation
should be removed from all locations, otherwise, there is the risk
that superseded procedures may remain in use.
Companies
should be
encouraged to limit their documentation
to that which is necessary to meet their safety and environmental
protection requirements. The
Keep it Short and Simple (KISS) principle should
be promoted in the development of procedures and instructions. The
documentation developed by the Company should be that which is most
effective for its operation. Excessive documentation may be counter
productive to the effective functioning of a SMS and will certainly
be more cumbersome for the personnel implementing the system.
COMPANY
VERIFICATION, REVIEW AND EVALUATION
(ISM
CODE CLAUSE 10)
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 may be exceeded by not more than three
months.
The
Company should periodically
evaluate the effectiveness of the SMS
in accordance with procedures established by the Company
The
audits and possible corrective actions should be carried out in
accordance with documented procedures.
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.
The
results of the audits and
reviews should be brought to the attention of all personnel having
responsibility in the area involved.
The
management personnel responsible for the area involved should take
timely corrective action on deficiencies found.
NOTE
TO AUDITORS
Internal
audits should be conducted in order to verify that the SMS is
functioning effectively. All
sections of the SMS should be audited on
a regular basis. While there is no stated period for audit, most
Companies opt to audit each office or vessel annually. The company
must complete internal audit procedures prior requesting for an
External Audit.
A
periodic review of the SMS should be carried out by company
management. This
review will form part of the safety management strategy
of the Company and will be conducted in accordance with documented
procedures. Minutes
of the management review meetings should be recorded
and corrective actions allocated to appropriate members of the
management team with a view to improvement. The management review
should be
an opportunity for a critical review by the company and ship of the
performance of the SMS over the past year, or other period. Audit
reports, inspection reports, non-conformities, accident reports, risk
assessments, permits to work, near miss reports, defect lists,
complaints, etc should be reviewed with the object of identifying
trends, root causes, areas of concern, etc with a view to continually
improve the operation of the SMS both ashore and on board.
Internal
auditors should be Independent
of the operation being audited however this may not always be
possible in small companies with limited management resources.
Wherever
practicable, the auditor should not normally be involved in the
working of the area being assessed. Personnel
carrying out internal audits should, have received appropriate
training.
In
order to improve the SMS it is important that the results of the
Company’s internal audits and reviews are promulgated to all
persons having responsibility for the SMS. Findings, conclusions and
recommendations should be recorded. The persons with responsibility
for that area should take timely corrective action.
