Blue water and brown water operations are vastly different, though SMSLLC appreciates those differences and claims numerous inland operators among its satisfied client list.

SMSLLC will offer its best in class consulting services to towing operators who seek to establish beneficial, practicable and lasting solutions to pending regulatory challenges.

SMSLLC is tasked to assist Weeks Marine with ISM Code compliant safety management system development for a new construction vessel. The project kicks off during April 2012 with an initial assessment and training at the company’s New Orleans offices.

The September issue is devoted to World Maritime Day 2011 and this year’s theme–Piracy: Orchestrating the Response. World Maritime Day activities will take place the week of 26-30 September with World Maritime Day celebrated on 29 September. This year’s parallel event will be hosted in Rome, Italy, 13-14 October. The agenda for the parallel event can be found here.

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.

“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.

The agenda for each meeting focused on four topics:

• The possible regulatory approach for an I2P2 rule;
• The scope and application of a rule;
• The organization of a rule; and,
• The potential economic impact of a rule.

While it’s reasonable to assume that nearly all employers are interested in the welfare of their employees, many stakeholders have deep reservations about how this proposed standard will affect their businesses.   The general consensus for business owners and operators, however, is that if OSHA indeed intends to move forward with a new standard that it should so do while being mindful of industry experience and input.

Concerns among the stakeholders include how I2P2 would relate to already existing standards, how implementation might affect small versus large businesses, how the new rule might be structured, the scope of the rule, how the rule might be organized, cost-benefit for employers, and how much assistance OSHA would provide to aid in the development and implementation of a safety management system.

The I2P2 initiative is a fundamental part of Dr. Michaels’ desire to foster a safety culture in the workplace.  Speaking in June at the American Society of Safety Engineers’ professional development conference, Dr. Michaels reaffirmed OSHA’s commitment to I2P2:

“Our goal must not be to punish or react, but to require employers to plan, prevent and protect. Plan, Prevent and Protect is the new enforcement strategy announced in the Labor Department’s spring regulatory agenda. This strategy is echoed in the proposed OSHA standard that would require employers to implement an Injury and Illness Prevention Program tailored to the actual hazards in their workplaces…under this rule, workers would have a greater voice in the workplace. Workers would participate in developing and implementing the safety and health plan, and have a role in evaluating the plan’s effectiveness in achieving compliance.”

Michaels also continued to emphasize keywords already common to industries in which safety management systems are the norm:

“Having a “safety plan” filed in a drawer or on corporate computers isn’t enough. An effective injury and illness prevention program requires management leadership and worker participation, hazard assessment and abatement, setting goals, and continual improvement.”

SMSLLC will continue to monitor OSHA’s efforts to develop and promulgate the I2P2 standard, as well as advise and assist clients curious to know more about workplace safety expectations.

While the immediate cause of the accident was a track circuit module failure of the Automatic Train Control system, NTSB Chairman Deborah Hersman noted that, “The layers of safety deficiencies uncovered during the course of this investigation are troubling and reveal a systemic breakdown of safety management at all levels.”

Investigators reached numerous conclusions, including:

• Before the accident, the position of Chief Safety Officer lacked the necessary resources and authority within the organizational structure of WMATA to adequately identify and address system safety issues, ensure the distribution of safety-critical information throughout the organization, or manage the system safety program plan as required by 49 CFR Part 659;
• Shortcomings in WMATA’s internal communications, in its recognition of hazards, its assessment of risk from those hazards, and its implementation of corrective actions are all evidence of an ineffective safety culture within the organization;
• Previous attempts at non-regulatory oversight failed to compel WMATA to maintain the organizational structure necessary to ensure effective identification and communication of safety-critical information throughout its Metrorail operations.

Recommendations included:

• Elevate the safety oversight role of the WMATA Board of Directors by (1) developing a policy statement to explicitly and publicly assume the responsibility for continual oversight of system safety, (2) implementing processes to exercise oversight of system safety, including appropriate proactive performance metrics, and (3) evaluating actions taken in response to National Transportation Safety Board and Federal Transit Administration recommendations, as well as the status of open corrective action plans and the results of audits conducted by the Tri-State Oversight Committee;
• Develop and implement a non-punitive safety reporting program to collect reports from employees in all divisions within your organization, and ensure that the safety department; representatives of the operations, maintenance, and engineering departments; and representatives of labor organizations regularly review these reports and share the results of those reviews across all divisions of your organization;
• Develop a formal process by which the General Manager and managers responsible for WMATA operations, maintenance, and engineering will periodically review, in collaboration with the chief safety officer, all safety audits and open corrective action plans, and modify policy, identify and commit resources, and initiate any other action necessary to ensure that the plans are adequately addressed and closed within the required time frame.

For ship operators and other transportation professionals working within the framework of the ISM Code or similar safety management systems, much of the terminology noted above should be quite familiar.  Safety culture, risk assessment, policy statement, process implementation, corrective action plans, audits, resources and authority–these are all critical to the successful implementation of a safety management system.

See www.galinj.com/ for additional details regarding Great American Lines, Inc.

See www.fmslnj.com/ for additional details regarding Fairfield-Maxwell Services, LTD.

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