Proceedings magazine is a communication tool for the Coast Guard's Marine Safety & Security Council. Each quarterly magazine focuses on a specific theme of interest to the marine industry.
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35 Spring 2016 Proceedings www.uscg.mil/proceedings However, it creates some confusion when the ISM Code appears to mandate creating a separate safety system within a company, and, consequently, aboard a vessel. For example, why does a vessel need to maintain a safety man- agement system when the functional requirements of ISM Code clause 1.4 (such as overarching safety, environmen- tal, emergency, communication, and management policies) should already be a part of the vessel's operational system as a result of other requirements? A company SMS should already be built into a vessel's existing procedures, process, and operations. This is similar to the process in which manufacturing com- panies become ISO 9001 certifed through implementing a separate quality management system (QMS). Manufactur- ing companies don't need to implement a QMS, but rather ensure their system conforms to the QMS standard. Ves- sels and their parent companies don't need to maintain a separate system for safety management when that safety management should already be a part of a company's and vessel's operational system. I relate it to asking a vessel master, "May I see your regula- tory compliance system manual?" Why would a separate regulatory compliance system need to exist? The bottom line is that vessels and companies do not need to create a new and separate safety management system when they can incorporate their existing systems, procedures, and manu- als into a safety management system to comply with the required standard. A System-Based Perspective A commercial vessel's main objective is to transport cargo or passengers from point A to point B safely, in a timely man- ner, and with minimal impact to the marine environment. To facilitate this, commercial vessel crews have regulations, company policies, drills, safety management systems, bridge resource management systems, plans, procedures, and a plethora of other safeguards to follow, meet, or implement. The International Maritime Organization (IMO) developed the International Safety Management (ISM) Code, which requires all ships to maintain a safety management system (SMS). However, in my experience as a U.S. Coast Guard marine inspector, quality management auditor, and inves- tigating offcer, I have noticed some detachment between documented management systems and actual operations. In fact, the IMO found that the administrative burden for safety management systems was an issue regarding SMS use and implementation, according to a 2005 study, 1 and a 2013 vessel collision study found that SMS-related non- compliance and human error were the two main causal factors for the collisions. 2 Thus, when safety management systems aren't connected well to actual operations on a ves- sel, human error may be more likely to occur. While the ISM Code is still a critical component of support- ing safe vessel operations, it's clear that safety management systems may not connect to vessel operations as well as they should. While it's important for a vessel's operations to conform to the ISM Code and have an inherent SMS, in my opinion, the safety management system need not be a separate system. Conforming to the ISM Code In 2002, it became mandatory for each company operating ships applicable to the ISM Code to develop and maintain safety management systems for its vessels. The objectives of the ISM Code, particularly within the marine environment, are to: • ensure safety at sea, • prevent human injury or loss of life, and • avoid damage to the environment. 3 In essence, the ISM Code seeks to protect all stakehold- ers within the world's maritime transportation system. Its objectives align directly with a vessel's adherence to existing IMO requirements. One System Connecting SMS requirements to vessel operations. by LT Josh BuCK Investigating Offcer U.S. Coast Guard Sector New York USCG Mission Management System