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Archive for February 18th, 2009

During the last 5 years, I’ve been fortunate enough to take part in a development that promises to influence the petroleum transport/tug and barge industry on a grand scale. Specifically, the move by transporters on the coastal and  inland waterways (including my employer) of adopting the ISM code and its tenets.

My initial reaction as I was presented with this idea was, “Christ, more paperwork.” All I anticipated was a confusing and overwhelming learning curve being heaped on me as I dealt with the kind of administrative work that was more suited to a ship than a tugboat.  But, the last 5 years have convinced me of the great benefit to be had by following this course.

It turns out that the curve wasn’t nearly as steep as I expected and the training necessary to bring the crew and vessel into compliance was a golden opportunity to really get things in order  the way I always thought they should be.  I could see a marked improvement in the crew and company over the term of our preparation for the ISM audit by ABS.  I would characterize it as a greater “mindfulness” of our work environment, to borrow the phrase. 

If your outfit decides to go the ISM/ISO route, here’s a general overview of what you can expect;

The first thing that one should realize as they are presented with the prospect of earning the ISM certifications titled S.Q. and E. is that its a good thing.

The quick explanations for the designations are; “S” stands for operational safety, “Q” is for Quality control, and “E” is for environmental aspects regarding hazardous materials handling, recycling, and the like, that will meet the International standards for compliance.

To begin with, the company manuals must all meet the international standard of addressing all concerns regarding the vessel and its support network.  Shore-side personnel are expected to document their interactions as well as keep a vessel history regarding maintenance items.  Operational concerns, chain of command, dealing with emergencies, maintenance, training, are all articulated by the company manual and charter in concert with the ISM/ISO code.  Anything and everything used for the safe navigation of the vessel must have a proper provenance, no bootleg copies of “Cap’n for Windows” allowed.  Proper and up to date publications on hand, the latest corrections entered on the charts and a record of those corrections.  If it’s a navigation program, it must be an approved, registered, and updated program since it’s to be used on the vessel for the navigation and voyage planning of any trip.

Following the creation (and A.B.S. approval) of a policy guide that meets the international standard, the company and vessel are subjected to an audit conducted by A.B.S. to earn the certificate by demonstrating their understanding, execution, and documentation of their newly aligned policies.

The audit on the vessel is conducted by an inspector from A.B.S. who interviews every member of the crew and quizzes them on their knowledge of policy, safety procedures, drills, maintenance items, and general items regarding the company’s policy with regard to duties and training.  The listings below are by no means complete, but they are a good indication of what to expect.

The Captain has to provide any record requested and show how they are maintained in accordance with policy.  Crew member orientations, drills, voyage plans, trash logs, incident reports, company memos, etc.  There must be proof that all documents are up to date, the proper licenses and certificates required are available for display, and all company documents are completed as designed (no blank or unused spaces).  Night order books, lock-out procedures, chart catalog updates, publications, records of office correspondence.  The list is extensive and thorough.

The Chief Mate/Pilot will need to explain his duties, show proof that his pubs and charts are up to date and kept according to policy, that he can reference the policies regarding non-conformance issues,  demonstrate his awareness his duties and responsibilities, as well as the crew’s responsibilities.  His knowledge of navigation equipment on-board will be queried and he will be asked to demonstrate the functions of that equipment.

The Chief Engineer will show his maintenance records, oil transfer log, repairs and pending issues on board.  He will need to describe  the function and limitation of any piece of equipment the auditor wishes to choose.  The fire plan will need to be accurate and properly displayed and labeled.  If policy requires it, pipeline color codes must be compliance with international convention and clearly indicated on all systems.  Everything the engineer can be responsible for is fair game in the audit.

The Deckhand will have to articulate when asked, who the DPA is, who is the VSO, what are his duties in a drill (pick one).  He’ll need to demonstrate proficiency with the SCBA if on-board.  The locations and functions of fire extinguishers, the locations of all the safety gear aboard.  Everything.

Any shortcomings found  are dealt with by the ABS auditor issuing a Non Conformance Report for each item that was either missing or lacking.  The NCR’s will need to be cleared with follow-up action as necessary and once proof is provided they have been properly addressed, the temporary Safety Management Certificate can be re-issued as a full 5 year certificate.

Follow up internal audits and a midterm ABS audit insure the standards are being maintained and the SMC certificate is valid.  The vessel master conducts an annual audit called  a “Master’s Review”, rating the cooperation he is receiving from his shore-side support and comments on any issues regarding the system in general.  This is part of the documentation that the ABS auditor will examine at the mid-term and 5 year marks.

The Mission Statement is one of the key documents along with the Quality and safety goals.  There are at least a dozen acronyms referring to job titles and reports.  DPA, NCR, QMA, VSO, CSO, QI,…….It can be overwhelming at first, but as the team gets familiar with the program it comes easier.

The most impressive document of all is the N.C.R.  The “non-conformance report” is one of the most useful documents you can find in the system.  It’s the way the system is put into action should something appear to be falling through the cracks.  An item that requires attention but isn’t getting any.

The N.C.R. is a report anyone can file, from the Captain on down to the Ordinary.  It means that a procedure or operation is not being executed in accordance with the approved and stated company policy.  It could refer to a repair item, a training issue, or procedure that is specifically articulated by a written policy or law.

If there is a problem that hasn’t been addressed in a reasonable amount of time, the N.C.R. can be used to kick-start the issue in the right direction by referring it to the DPA or Designated Person Ashore.  This person is the appointed gatekeeper of the Safety Management System should something require a helping hand.  He has the ear of the President of the company if necessary to accomplish the dictates of the policies in place.

For Example: The Captain has reported to Maintenance and Repair that the weather-deck fore-peak hatch needs a new spring loaded hinge.  It’s been reported as a safety issue, since without the spring, it is too heavy to be safely handled single-handed by the deckhand for simple access. Additionally, it’s part of the equipment necessary to secure for sea.

The item has been ignored for 2 hitches so the Captain accesses the N.C.R. document on the company computer and fills out the form according to the directions.

Citing Chapter 1 section A: Company policy states that any item concerning the seaworthiness of the vessel will be a priority item.

The one thing to keep in mind is that the form must be completed correctly and cite chapter and verse of the policy that’s being quoted as “not in conformance”.

The DPA receives the NCR and acknowledges it in writing.  He then passes the NCR to the appropriate desk , (in this case the Maintenance and Repair office) and seeks a reason why the item hasn’t been addressed.  M&R will have to respond in writing and schedule the repair ASAP in keeping with the company’s stated policy, or the vessel will be taken out of service until the repair is effected since we’re talking about a “seaworthiness” issue.  The Captain has a copy of the DPA’s signature and proof  that M&R has been notified officially. Once completed the repair would be documented as such and the NCR “closed” in writing, and CC’ed to everyone concerned.

Here, the example of the Captain filing the NCR is proof that the system addresses safety in a realistic fashion according to the stated policy of the company.  The issue was addressed in writing so there was proof the system was utilized properly and in accordance with international agreements.

By the same token, if the office has determined that the vessel has failed to comply with a written policy it will issue it’s own NCR to the vessel and seek redress of the issue through the DPA.  It goes both ways.

The hardest part of this system to “get” is that it’s a dynamic process. Things are subject to improvement and frequent review so that it becomes a practicable policy, not just paragraphs of catchphrases and caveats. The idea is that if your manual says “this is how we do it”, then that is how you do it and prove that you are by having documentation to back it up.  The NCR is a powerful tool used to refine and correct shortcomings in the process.

The true nature of the program is without a doubt the best thing to happen to our industry since forever. The old way of doing things is out the window and the old fashioned mindset is fast becoming extinct. The idea that everyone is responsible is rather appealing when you get down to the nuts and bolts of it. The old days put those of us who had the most to lose on the line and solely at risk. Only our actions were subject to scrutiny regardless of the fact the office was either forgetting or ignoring our needs in getting the job done safely. It was common for “Operations Manuals” to be so much window dressing and seldom taken seriously by anyone until something really bad happened, then we’d be taken to task for ignoring policy.

The opportunity that the ISM code presents us is a dual edged sword. The accountability aspect goes both ways. There is a paper trail for everything and everyone’s actions regarding repairs, supplies, operational training, personnel orientations, safety equipment, and on and on. There is a certain comfort in knowing everyone has an equal amount of “skin” in the game. It a great motivator.

This isn’t new to the guys sailing deep sea, those of us working the inland and coastal fleets will need a little time to get up to speed.  But it’ll be worth it.

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