Developments Archive

Australian Transport Safety Bureau Report Published

In March 2011 the Australian Transport Safety Bureau (ATSB) published their safety report for the 2009-2010 financial year. The report analyzes safety issues and recommendations related to the 58 investigations the ATSB conducted among the rail, aviation and marine industries.

The 10 investigations specific to the marine industry resulted in a number of conclusions, including:

  • issues with procedures, including non-existing or inadequate procedures, made up 69% of the risk control safety factor;
  • over 50% of the organizational influences identified as safety factors were related to safety management system (SMS) processes, including not effectively using existing processes or having inadequate processes;
  • about a third of local condition safety factors involved a lack of knowledge, skills or experience of individuals involved in incidents.

It is all too easy for owners or operators to say, “We provided an SMS, but the crew didn’t follow it.” But vessel owner and operators, through regular audits and management and senior officer reviews, should determine if their processes and procedures are not only adequate, but relevant to existing operations. A safety management system is not a “one size fits all” endeavor and should be tailored to the unique operational characteristics of your organization. Without senior management’s steady commitment to a safety culture and its continuous improvement, incidents similar to those noted in the ATSB report are unfortunately predictable.

SMSLLC has worked with numerous commercial and municipal clients in designing unique safety management systems but also in assessing existing systems to determine their adequacy and continued relevance.

The ATSB report is viewable here.

ISM Code Revision — Risk Assessments

On 1 July 2010 the revised ISM Code went into effect.  The most discussed revision to the standard is in Section 1.2.2.2, which states:

“Safety management objectives of the Company should, inter alia: assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards”.

As many others have noted, this revision explicitly states what was always implicitly assumed—that operators will consider risk on an on-going basis, both formally and otherwise. In the opinion of Safety Management Systems, LLC, this is not a definitive directive for an all-encompassing risk assessment procedure within your SMS Manual.

However, your company should carefully consider what mechanisms for risk assessment in their system are already established and how those may need to be adapted to help meet this new requirement.

Examples of procedures most companies already have in place include:

  • Port Captain/Superintendent ship visits – When office technical personnel visit a ship an outcome should be a Ship Visit Report. A line item within the report would be to assess some aspect of risk onboard. The aspect evaluated should be specified by the Designated Person Ashore (DPA).
  • Post-Shipyard Report – Any new systems installed—ECDIS, a Ballast Water Treatment System, a new piece of engine room machinery—should initiate an assessment and discussion of strategies to mitigate possible risks.
  • Onboard reporting – Utilize normal reporting events like Safety Meeting Minutes, Master’s Reviews, Non-conformance Reporting and Internal Audits to identify and assess risks.
  • Use of industry best practices/regulations – Reviewing compliance with SOLAS, MARPOL and STCW. Determining compliance with ISGOTT, BC Code and Safe Working Practice guidelines. There is an incredible amount of industry guidance out there to be used.
  • Shore-based personnel involvement – Management Review Process, Table Top Spill/Security Exercises and fleet trend analysis.
  • Management of Change – When a new ship comes into your fleet, an in-depth risk analysis should be completed. The same is true for major new regulatory events such as Emergency Towing Procedures for non-tank vessels and the Maritime Labor Convention.

Management at all levels must spread the word that risk is to be assessed both from a macro and micro perspective. All personnel must be able to demonstrate knowledge of your company’s risk mitigation efforts during a Document of Compliance or Safety Management Certificate verification audit.

Safety Management Systems, LLC is available to assist in reviewing and revising your existing policies and procedures to meet the expectations of this important ISM Code revision.

April 2010 – ISM Code NEW Edition

ISM Code 2010 EditionApril 10, 2010 — The International Safety Management (ISM) Code 2010 Edition is available and includes some significant revisions that are applicable to Administrations and companies alike.

Visit the IMO website for specific details and ordering information.

SMSLLC is available to answer questions and offer appropriate guidance to ship managers with respect to various provisions.