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Issue link: http://uscgproceedings.epubxp.com/i/665311
24 Proceedings Spring 2016 www.uscg.mil/proceedings Further into the exam, the port state con- trol offcer learns that the company recently implemented a new policy into the SMS. As a result of a recent accident on a sister ship, the company decided that using charged air cylinders during drills was an unnecessary risk until all the cylinders could be tested. The regulations note that a drill should be "as realistic as possible," and the company did, indeed, deem it as realistic as possible without incorporating an unnecessary, identifed risk. Since the company still uses these cylinders during regular controlled training to ensure crew profciency, the PSCO should have no concern. There can be a fne line in making such judg- ment calls. Though there was no cause for concern in the previous example, one must read the SMS carefully for each situation. For example, if the ship's SMS stated that all fre- fghters were to have fully operational equip- ment during fre drills and they had to breathe air from the cylinder to promote realism, then the same situation would constitute a viola- tion of the ship's procedures. By extension, it would also constitute a nonconformity with the requirements of their safety management certifcate. Example 2 — Ship's Systems: During an exam of engineering spaces, the PSCO notes that a secondary oil content meter (OCM), commonly referred to as the "white box," isn't operating. There's no regulatory requirement for this secondary system, but it is required according to the ship's SMS. Even though neither domestic nor international regulations apply, established company policy, approved by the vessel's fag state, provides for nonconformance with the requirements of the safety management certifcate. Example 3 — The Human Factor: During vessel walk- through, the port state control offcer notices that tables and chairs block an emergency escape route. The shipboard off- cer notes they're stored there because they have no more storage space available. The PSCO makes note of this def- ciency, and later, when he or she reports this fnding to the lead examiner, it's identifed that the vessel was issued the same defciency, in the same location, with the same tables and chairs, for the last three exams. While it's obviously a problem that the tables and chairs are stored there, the big- ger problem lies in that the issue is recurring, with no cor- rective actions taken to rectify the identifed non conformity. Compliance Let's look at how USCG PSCOs use a ship's SMS to evaluate and enforce compliance. First of all, identifying the way a ship "lives" is the key to understanding a ship's safety man- agement system and its relation to the ISM Code. Beyond examining the required paperwork to ensure all the "i"s are dotted and the "t"s crossed, it's equally important — if not more so — to see how the crew manages the vessel accord- ing to the SMS. Example 1 — Fire Drill Anomaly: A port state control off- cer notices that none of the frefghters have an air cylin- der attached to the breathing apparatus during a fre and abandon-ship drill. The PSCO immediately identifes a pos- sible defciency against Chapter III of SOLAS. Any port state control offcer knows that SOLAS requires drills to be per- formed in a realistic manner, but the absence of this cylinder makes the drill unrealistic, as a frefghter would never go into a fre without an air source. Ship emergency teams discuss safety management system procedures with USCG examiners after a fre drill. Students learn how to evaluate ships' safety management systems as part of the Foreign Passenger Vessel Examiners Course.