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.
Issue link: http://uscgproceedings.epubxp.com/i/665311
8 Proceedings Spring 2016 www.uscg.mil/proceedings those who survey the ship and those who audit the SMS. In cases where two separate ROs are employed for a vessel or company, the Coast Guard and the owner must ensure that the surveyor and auditor enjoy unrestricted access to relevant information. In the mid-1990s, the audit and survey were viewed as wholly separate, unconnected activities. With the passage of time, however, the Coast Guard and their recognized organizations have come to realize that good SMS process control leads to good conditions throughout the survey through factors such as preventative maintenance planning. Recognizing that communication between auditors and surveyors is critical, the International Association of Clas- sifcation Societies implemented Procedural Requirement 17 (PR 17) to allow surveyors to note conditions indicative of poor safety management and pass that information along either internally to their own class society ISM depart- ment or externally to the RO providing ISM certifcation. By agreement with our recognized organizations, the Coast Guard receives notice of all PR 17s issued to U.S.-fagged ves- sels, whereupon we fully engage with the RO to investigate. Likewise, the Coast Guard is notifed if a major noncon- formity is noted during an audit of a U.S.-fagged vessel. Coast Guard and RO personnel then discuss downgrading a major nonconformity to nonconformances if the company initiates a root cause analysis as well as a corrective action plan. Otherwise, a major nonconformity is reason for the Coast Guard to suspend or revoke the ISM certifcate. Where a major nonconformity has been downgraded, Coast Guard and recognized organization personnel evaluate whether or not the corrective action has been fully implemented. When the RO conducts a follow-up audit within 90 days of the major nonconformity, in most instances, the Coast Guard will assign a marine inspector to attend the follow-up audit. The marine inspector and the RO personnel will then evaluate if the corrective action for the major nonconformity is suffcient. Coast Guard stewardship over its recognized organization delegation for ISM Code is essential for full and effective implementation of the ISM Code on U.S.-fagged vessels. About the author: LCDR Aaron Demo is a graduate of Massachusetts Maritime Academy and has served in the U.S. Coast Guard for 15 years. He has also served as chief of the Inspections Division at Sector Houston-Galveston, assistant chief of the Domestic Vessel Branch at Sector Hampton Roads, and chief of the Inci- dent Management Division at Sector New Orleans. Additionally, LCDR Demo holds a license as a 1600-ton Master Upon Oceans, Master of Towing Vessels Upon Oceans, and a Third Mate Unlimited Upon Oceans. ISM Code Certifcation Delegation Like many fag administrations, the United States elected to delegate authority to recognized organizations (ROs) to conduct ISM audits and issue ISM certifcates on behalf of the Coast Guard. All of the recognized organizations del- egated ISM authorization are also Coast Guard-recognized classifcation societies. ROs for ISM Code certifcation cur- rently include: • ABS, • DNV-GL, • RINA, and • Class NK. It is not required that a U.S.-fagged vessel use the same rec- ognized organization for ISM as they do for classifcation, and some companies have expressly elected to use a recog- nized organization separate from their ship's classifcation society to gain an independent evaluation of their company and vessel operations. This is a well-intentioned motive, but vessel owners need to be aware that it reduces the free fow of information between The author, LCDR Demo (right), discusses a liquefed natural gas fuel system. U.S. Coast Guard photo by LCDR Lee Bacon.