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.

Tags: ISM Code 2010, Risk Assessment