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
36 Proceedings Spring 2016 www.uscg.mil/proceedings While meeting this overall objective, a vessel's operational system should: • conform to ISM Code requirements, thus becoming a safety management system; • connect all vital vessel systems, from the keel to the master captaining the ship; • include all the aforementioned safeguards. The addition of a separate SMS documentation system seems burdensome — disconnected from the crew, port engineers, and other stakeholders. A separate documentation system is benefcial for auditors and inspectors, but how benefcial is a safety management system for the actual vessel operators? I relate this closely to my quality management system research and experience, where an organization may have an actual production sys- tem but also maintains a QMS with its own documentation control, procedures, and processes distinct from the actual operations of the organization. Often a QMS or SMS is imple- mented just so a company can market that they have one. The key is the overall objective and performance expectation clarity — not necessarily whether enough documentation exists to support a safety management system. Expectation and mission clarity is essential for any system to operate effectively. This is no different for vessel operations, where operational systems should connect to and be a subsystem of an overarching company system. The ISM Code appears to imply a need for additional pro- cesses or procedures. For example, clause 5 of the ISM Code requires vessel masters to review their company's safety management system and report any defciencies back to the vessel's company management, 4 implying that the SMS is distinct and separate from vessel operations. This can be confusing, considering that all the vessel master really needs to do is report any defciencies regarding a vessel's opera- tional system, not vessel-related defciencies and specifc SM S -r elat e d def ic ie nc ie s — t hey should be one and the same. Does a master need to report an engine defciency and also document a safety management system defciency for the same issue separately? Isn't clause 5 met any time a vessel master reports to shoreside management regarding any defciency occurring in a vessel's operation system? Do safety manage- ment system manuals, procedures, checklists, and other documentation need to exist for companies and ves- sels to meet the ISM Code? One System I understand requiring that a safety management system exist, in part, for a company's external stakeholders to con- nect vessel operational systems to company processes. However, consensus standards like the ISM Code are much more manager- and process-focused than employee-centric. A company's SMS needs to be less emblematic, and more focused on employees — in this context, the mariners — who can make vessel operations safer. 5 Mariners and vessels are the safety management system. In a real-life example, I investigated one incident where a vessel captain hadn't followed company policy regarding emergency notifications. However, the company admit- tedly never provided the emergency notifcation informa- tion to the masters; the procedure was in a lengthy company document not readily available. To make it "one system," the company could have provided the master a checklist to follow when an emergency occurred. Then the master wouldn't necessarily need to know the policy, but still could have followed it because the system connected the shoreside offce to vessel operations. In summary, what good is a safety management system if mariners are not really engaged with it? When SMS non- compliance is noted after a casualty, it may behoove an investigator to assess whether the given safety manage- ment system was embedded into the actual vessel opera- tions — and ultimately, into the practices of the mariners doing the work. The IMO study regarding ISM Code implementation 6 rec- ommended: • involving seafarers in developing and continuously improving ISM manuals; • streamlining and reducing the paperwork supporting ISM compliance, particularly the SMS; Similar Requirements International Safety Management (ISM) Code Requirement International Ship and Port Security (ISPS) Code Requirement Clause 9 — Reports and analysis of nonconformities, accidents, and hazardous occurrences Clauses 11.2.7 and 12.2.5 — Company and ship security ofcer reporting requirements Clause 10 — Maintenance of the ship and equipment Clauses 9.4.15 and 9.4.16 — Ship security plan Clause 11 — Documentation Clause 10 — Records Clause 12 — Company verifcation, review, and evaluation Clause 9 (numerous cites) — Ship security plan