The International Safety Management (ISM) Code

The International Safety Management (ISM) Code for the safe operation of ships and for pollution prevention and its application in the Marine Environment

The ISM code sets an international standard for the safe management and operation of ships and requires companies to document and implement clear procedures, standards and instructions for safety management ashore and afloat.

The ISM code does not replace the requirement for compliance with existing regulations.

The purpose of the code is to provide an international standard for the safe management and operation of ships and for prevention of pollution

The objectives of the code are to ensure safety at sea, prevention of human injury or loss of life, and avoidance of damage to the environment.

The Code will be introduced on a mandatory basis in three stages depending on the type of vessel but regardless on date of construction.

European requirement- Ro-Ro Passenger vessels will require to comply by 1 January 1996, Ro-Ro ferries from 1 July 1996

International requirements- The new chapter IX to SOLAS 1974, Management for the Safe Operation of Ships requires compliance of Passenger Vessels and high speed Passenger Craft over 500 GRT by 1 July 1998. Oil Tankers, Cargo high speed craft, Chemical Tankers, Gas Carriers and Bulk Carriers to comply by 1 July 1998. Other Cargo ships and mobile Offshore drilling rigs of over 500 GRT to comply by 1 July 2002

The MSA will be responsible for the system audit, issue and renewal of ISM Convention Certificates and the periodic verification. The use of independent organisations to guide and assist in the setting up of the SMS is encouraged but the choice such consultants is a company decision.

Certification

The application of the code will lead to the issue of two certificates

The Document Of Compliance (DOC)

·         will be issued to the company following a successful audit of the shore side aspects of the Safety Management System

·         evidence required that the system as been in operation on at least one type of ship in the companies fleet for a period of three months.

·         Specific to ship types at time of audit

·         valid for 5 years

·         subject to annual verification ( within 3 months of anniversary date)

The Safety Management Certificate (SMC)

·  issued to each ship following audit

·  evidence that SMS has been in operation for 3 months prior to audit

·  valid DOC required

·  valid for 5 years

·  subject to one verification between the second an third anniversaries with a proviso for more frequent audits if necessary. This is more likely in the early days of ISM Code implementation.

Temporary certification-A 12mth valid DOC may be issued to a newly formed company or a company acquiring a new type of vessel as long as they have a SMS meeting the minimum requirements of the ISM code and can demonstrate plan for full compliance.

- A 6 mth valid SMC may be issued to a new building or when a company takes of the responsibilities for the running of a vessel.

Safety Management System

Safety Management objectives of the company.

1.     provide for safe working practices and a safe working environment

2.     establish safeguards against possible risks

3.     continuously improve safety management skills of personnel ashore and aboard ships,

A Safety Management system (SMS) meeting the requirements of the ISM code requires a company to document its management procedures and record its actions to ensure that conditions, activities and tasks that affect safety and the environment are properly planned, organised, executed and checked. A SMS is developed and implemented by people and clearly defines responsibilities, authorities and lines of communication. A SMS allows a company to measure its performance against set criteria hence identifying areas that can be improved. The increase in Safety Management skills improves morale and can lead to a reduction in costs due to an increase in efficiency and a reduction in claims

The safety management system should ensure;

1.     compliance with mandatory rules and regulations

2.     applicable codes and guidelines both statutory and organisational are taken into account.

3.     Promulgation and understanding of company and statutory regulations and guidelines. (It is the task of a visiting surveyor to test the general knowledge of company and statutory regulations and instructions)

The functional requirements for a safety management system;

1.     a safety and environmental policy

2.     instructions and procedures to ensure that safe operation of the vessel in compliance with relevant international and flag state legislation

3.     defined levels of authority and communication between shore and ship personnel

4.     procedures for reporting accidents and non-conformities with the code

5.     procedures for responding to emergency situations (drills etc)

6.     procedures for internal audits and management reviews

7.     A system is in place for the on board generation of plans and instructions for key shipboard operations. These tasks may be divided into two categories
Special operations-those where errors only become apparent after a hazardous situation or accident has occurred. E.g. ensuring water tight integrity, navigational safety(chart corrections, passage planning), maintenance operations, bunker operations
Critical shipboard operations- where an error will immediately cause an accident or a situation that could threaten personnel, environment or vessel. e.g. navigation in confined waters, operation in heavy weather, bunker or oil transfers, cargo operations on tankers. .

Safety and environmental protection policy

1.     The company should establish a safety and environmental protection policy which describes how objectives listed above will be achieved.

2.     The company should ensure that the policy is implemented and maintained at all levels of the organisation both ship based as well as shore based.

Company responsibilities and authority

1.     There must be disclosure from the owner to the administration as to who is responsible for the operation of the ship. The company should define and document responsibility, authority and interrelation of all personnel who manage, perform and verify work relating to and affecting safety and pollution prevention

2.     The company must ensure there are adequate resources and shore based support for the designated person or persons to carry out their function.

Designated Person(s)

1.     A person or persons who has direct access to the highest levels of management providing a link between the company and those on board.

2.     The responsibility and authority of the designated person is to provide for the safe operation of the vessels. He should monitor the safety and pollution prevention aspects of the operation of each vessel and ensure their are adequate shore side resources and support

Master's responsibility and authority

1.     The roles and responsibilities of the Master should be clearly defined by the company with regard to the implementation of the companies policies with respect to SMS and methods for review and reporting deficiencies to the shore based management.

2.     The company should ensure that the SMS operating onboard the vessel contains a clear statement emphasising the masters authority. The company should make it clear that the Master has the overall responsibility for decision making and has overriding authority with the option of adequate shore back up.

Resources and Personnel

1.     The company should ensure that the Master is suitably qualified and fully conversant with the SMS. They should also ensure that the ship is correctly manned.

2.     The company should ensure that there is adequate familiarisation with safety and protection of the environment for new personnel. They should ensure that the personnel has an adequate understanding of the relevant rules, regulations, guidelines and codes.

3.     Training is to be provided where necessary. Relevant information for the SMS should be promulgated and be written in an easy to understand method.

Development of plans for ship board operations

1.     The company should establish procedures for the generation of shipboard plans and instructions with regard to the prevention of pollution and that these should be generated by qualified personnel

Emergency Preparedness

1.     The company should establish procedures for the response actions to potential emergency situations. Programmes for drill should be established and measures taken to ensure that the company's organisation can respond to hazards and accidents.

Reports and analysis of non-conformities, accidents and hazardous occurrences

1.     The company should ensure there is a procedure for the reporting and analysis of accidents, hazardous occurrences and non-conformities, and for the corrective action.

Maintenance of the ship and equipment

1.     The company is to ensure that the vessel is properly maintained. Procedures within the SMS should be in place to identify, record and plan for repair defects. A system of preventive maintenance should be in operation.

2.     Regular inspections integrated with the ships operational maintenance routine should take place to ensure that the vessel is in compliance with relevant regulations.

Documentation

1.     The company should establish and maintain procedures for the control of all documentation relevant to the SMS. This should include;

                                            i.  valid documents are available at all relevant locations

                                           ii.  changes to documents are reviewed and approved to authorised personnel

                                          iii.  obsolete documents are promptly removed

2.     All documents, carried in a company approved relevant form, should be present on board

Company verification, review and evaluation.

1.     The company should carry out periodic audits to verify that safety and pollution prevention's are complying with SMS. The audits and corrective actions should be carried out as per laid down procedures.

2.     Personnel carrying out the audits should be independent of the areas that they are carrying out the audit unless size of the company is such that this is impractical.

3.     Deficiencies or defects found should be brought to the attention of the personnel in that section and the management team so effective corrective action can be carried out

Certification, verification and control

1.     The following documentation is issued by which ever administration, complying with ISM, is relevant to the shipping company.

2.     A DOC is issued to all company's who can demonstrate that they have complied with the code should be held.

3.     A copy of the DOC should be held on board to allow the Master to produce it to the relevant authorities is required.

4.     An SMC is issue to the ship following verification that the ship and company comply with the requirements of SMS.

5.     Future verification that compliance with SMS should be carried out by the administration.

Requirements on board ship

1.     Proof that the vessel is being maintained in a satisfactory condition at all times, and not only at the time of surveys-objective evidence in the form of no overdue surveys, no overdue recommendations from port or flag state inspections and that planned maintenance is being carried out and records kept.

2.     Applicable codes and guidelines are being taken into consideration when operating the vessel. Vessels staff must be able to demonstrate that operations are carried out in a controlled manner utilising information contained in these codes, guidelines and standards.

3.     That emergency situations have been identified and drills are conducted to ensure the vessel and company are ready to respond to emergency situations.

The master is expected to be fully conversant with Company safety management system. Officers and crew would be expected to be familiar with the parts of the system relevant to their safety responsibilities as well as a thorough understanding of their operational responsibilities- auditors will ensure compliance.

·         Examples of the type of documentation the auditor will wish to see to verify compliance with the ISM are as follows;

·         Log books

·         Safety and management meeting minutes and follow up actions

·         Medical log

·         Company circular letters

·         Planned maintenance records

·         Records of verification

·         Records of masters review of the system

·         Records of internal audits and follow up

·         Records of chart corrections

·         Class quarterly listings

·         Records of passage planning

·         Oil record books

·         Garbage logs

·         Company manual and forms

Pollution prevention and OPA 90

Tied into the ISM code are the requirements to meet OPA90 to wit a Federal Response Plan. Each company that trades in US coastal waters must have in place a suitable response plan. They must have a designated person resident in the United states ready to act as consultant.

There is an IMO regulations which is equivalent to OPA90. A company must be in possession of a valid DOC to trade, and it must be able to clearly demonstrate its ability to respond to situations such as oil spillage.