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The International Safety Management (ISM) Code For the Safe Operation of Ships and for Pollution Prevention

Posted 3/17/2019

The introduction of the ISM Code is believed to be an attempt to regulate human error. In many notable disasters, there were many considerations about the crewmember’s omissions or negligence. However, the appropriate analysis of an accident indicates weaknesses in the ship management company operating the unfortunate ship. It could also be argued that ineffective management is spread in all departments of a company since a problematic department will affect the proper operation and performance of other departments as well.

 

The ISM Code was written in a generic form, like any other code, in order to be applicable to different ship types in the maritime industry. Consequently, the ISM code has several similarities with the structure of ISO 9001 and ISO 14001 standards. The main difference is its scope which is limited for ship safety, life and environmental protection.  A ship management company should develop documented procedures to demonstrate that is following as minimum the flag state and the IMO regulations. The documents will consist of a safety management system (SMS) that will include procedures for continuous improvement in the areas of policy, planning, communication, emergency preparedness, emergency response, checking and corrective actions. The layout of the ISM Code is listed below:

Part A Implementation

  1. General
  2. Safety and Environmental Protection Policy
  3. Company Responsibilities and Authority
  4. Designated Person (s)
  5. Master’s Responsibility and Authority
  6. Resources and Personnel
  7. Development of Plans for Shipboard Operations
  8. Emergency Preparedness
  9. Reports and Analysis of Non-conformities, Accidents and Hazardous Occurrences
  10. Maintenance of the Ship and Equipment
  11. Documentation
  12. Company Verification, review and Evaluation

 

Part B Certification

  1. Certification and Periodical Verification
  2. Interim Certification
  3. Verification
  4. Forms of Certificates

 

The layout of the ISM code describes the steps of a management system. The paragraph 1.2.3 of the code is of particular interest and states the following:

“Safety management objectives of the Company should, inter alia: …….3 continuously improved safety management skills of personnel ashore and aboard ships, including preparing for emergencies related both to safety and environmental protection.”

 

Someone may argue that the above paragraph is not legally binding for other management or commercial activities of a ship management company. This is a misleading perception as in a high-risk industry commercial decisions are very likely to affect the safety of a ship, its crew and/or marine environment.

 

Paragraph 2 requires a policy to be signed by senior managers as evidence of their commitment to ensuring a safe environment in their ships. As a common practice, this policy is to be posted ashore and onboard as notification to all employees. Paragraph 3 of the code is requiring company responsibilities and authority. This is an essential step of any management system to provide each employee with a job description. Paragraph 3.3 of the code contains the following text:

“3.3 The Company is responsible for ensuring that adequate resources and shore-based support are provided to enable the designated person or persons to carry out their functions.”

This statement links the company’s responsibility to provide resources to DPA, Master and other Personnel as required in the other three requirements 4, 5 and 6 respectively.

 

Furthermore, section 4 of the code introduced the role of a Designate Person Ashore (DPA). A person in charge of monitoring that adequate resources are provided onboard the ship(s) he/she is responsible for.  It is the first time that a maritime regulation describes the position of an employee within a ship management company ashore. In a similar way section, 5 of the code describes management authorities and responsibilities that a shipmaster must have and he/she is legal to bind to exercise.

 

In paragraph 6.2 the following text can be read:

“The Company should ensure that each ship is manned with qualified, certificated and medically fit seafarers in accordance with the national and international requirements.”

 

Therefore it describes elements of a human resource management system for the administration of seafarers onboard ships.

 

In paragraph 7 there is a requirement for the Development of Plans for Shipboard Operations. This is the most extensively documented requirement in SMS since the operations are several such as navigation, cargo handling and bunkering. The key element to avoid unnecessary documentation to a company is to link SMS with existing publications. For instance, there could be a direct reference to IMBC code for bulk carriers instead of repeating the full text in SMS.

 

Essential is paragraph 8 about Emergency Preparedness. This statement is associated with human resource management since shore-based support should include knowledge availability from individuals ashore. Although such individuals may be consults bind with contracts it is argued that in the case of an emergency the best option for a ship management company would be those individuals to be employees.

           

Paragraph 9 is titled Reports and Analysis of Non-conformities, Accidents and Hazardous Occurrences. The purpose of this paragraph is twofold; self-monitoring and self-correction. As any management system, SMS is prone to errors in design and execution. That is acceptable as there is an information flow system established, allowing proper monitoring and corrective actions. The essential issue is the correspondence of an effective solution from the company in a reasonable time frame.

 

The maintenance of the Ship and Equipment is a requirement to be documented in paragraph 10. This paragraph is analysed in a different section of this book. However, it should be mentioned that the numerous machinery onboard can be effectively controlled only with minimum documentation.

 

Paragraph 11 is about Documentation. The requirement should comply with flag state requirements and best practices adopted by the maritime industry. Excessive documentation could lead to useless paper exercise.

 

Eventually, paragraph 12 is titled Company Verification, review and Evaluation and describes the most effective management tools; audit and management review that should be carried out at least annually. Those actions are internal giving, therefore, the chance to a company for significant improvement. Limitations could be a lack of authority of auditors, not essential reviews.

 

Part B Certification of the ISM Code is describing the certification process of a ship management company. An externally approved organisation by the flag of a ship such as a classification society should carry out audits at specific intervals. Upon successful results of a shipboard audit, a Safety Management Certificate (SMC) will be issued to the ship. In a similar way, a Document of Compliance (DOC) for each type of ship and/or flag will be issued for the ship management company.

 

By design, the ISM Code supports and encourages the development of a safety culture in shipping. The content of an SMS will be therefore affected by Company commitment, values and beliefs, which cannot be enforced through the regulatory process. The SMS should be written by the company from scrap although it will always be an attempt to adopt prescriptive management system solutions.  Such a solution is against the spirit of the ISM Code as it is very likely that it will not reflect the real structure and organisation of the company.