On 28 August 2007, the Paris MOU on Port State Control confirmed that they would be conducting a Concentrated Inspection Campaign (CIC) aimed a verifying compliance with the ISM Code. The CIC will run from 01 September to 30 November 2007 and will be conducted in conjunction with the Tokyo MOU on Port State Control.
At every Port State Control inspection during the CIC, inspectors will be verifying that the Safety Management System (SMS) onboard is being effectively implemented and is not merely a “paper exercise”. This will entail ensuring that the master is fully conversant with the SMS and that ship’s personnel are able to effectively communicate in the execution of their duties related to the SMS. The inspection will focus on 12 key areas of the management system relating to documentation, critical equipment, maintenance and communication.
To ensure consistency between inspections, the Paris and Tokyo MOUs have developed a standard questionnaire on areas and items to be inspected. This questionnaire and the guidance to inspectors are reproduced below.
To evaluate the effectiveness of the maintenance the PSCO should consider the overall condition of the ship. For example severe corrosion to the hull or structure, inoperable critical equipment, repetitive deficiencies from PSC inspections or multiple technical deficiencies will be considered as evidence that the system is not effective.
Item to be considered as a major non-conformity: All detainable deficiencies related to hull, structure or equipment.
The PSCO should examine at least the last two inspection reports to identify any repeated deficiencies.
When repeated deficiencies have been identified the PSCO shall seek what corrective action has been reported to the company in accordance with the SMS and what action has been taken by the Company to avoid such a recurrence. During the inspection the PSCO should also verify that the items have been rectified.
- Is the Safety Management Documentation on board (both manuals and certificates)?
In addition to verifying the existence of the DOC and SMC, the PSCO should verify that the company identified on the SMC is the same as that shown on the DOC and that the endorsements on both certificates have been made. The PSCO should note that the SMC requires a verification audit between the second and third years and the DOC requires annual verification. In this regard, the ship should hold a copy of the DOC endorsement. This does not need to be an original copy but can be a fax or email copy.
Item to be considered as a major non-conformity: ISM certificates not on board
The PSCO should be able to ask for samples of the documented SMS. It should be easy accessed and could consist of manuals and/or material from a computer. Not all parts of the system have to be documented, however for practical reasons and for verification most companies will have documented all requirements of the Code.
Item to be considered as a major non-conformity: Safety Management documentation not on board
- Is there evidence that the master has carried out a review of the SMS?
There should be some form of records of the master’s review of the system and if any deficiency has been reported to the Company. The present master may not have carried out a review so a PSCO may have to accept records made by previous masters. The PSCO should not necessarily expect to see a dedicated review report. It is common for the review to be incorporated into other reviews and meetings onboard such as the safety committee meeting. In order to determine the process, the PSCO should request the master to provide the relevant SMS procedure that details how the review is conducted. Regardless of how the review is conducted, a record should be available. Should the physical inspection of the ship reveal significant failures in the observance of onboard procedures then this review process may be revisited to investigate further the effectiveness of it.
- Can senior officers identify the “designated person” responsible for the operation of the ship and the means to contact that person?
The master must know the identity and be aware of the role of the DP. Other senior officers should be aware of the identity and role of the DP. The DP does not have to be directly contactable and may not even have any role to play in an emergency. The master should be able to explain the means of contact, including the route of non-conformities that the DP will be seeing.
Item to be considered as a major non-conformity: Senior Officers unable to identify the designated person responsible for that ship.
- Have procedures for establishing and maintaining contact with shore management in an emergency been tested?
Example; A reference to the company contacts in the SOPEP could be sufficient if so stated in the SMS. PSCOs cannot expect to see a neat list posted in the radio room although many ships will have this type of list. Records from drills and exercises may provide evidence that the means of contact has been tested. If not, the PSCO may ask for this to be demonstrated.
Item to be considered as a major non-conformity: No procedure to contact the company in emergency situations.
- Have procedures to report non conformities, accidents and hazardous occurrences been followed?
The PSCO may ask the crew on how to report non-conformities, accidents and hazardous situations to the Company. For example, if the onboard SMS requires it, have deficiencies from previous PSC inspections been reported. If reports have been issued the PSCO may ask for records. In this case, the PSCO may note an individual non-conformity, accident or hazardous occurrence that has been reported and note what corrective action has occurred. During the physical inspection of the ship, the PSCO could verify that the item has in fact been effectively dealt with. A PSCO may have to accept that the need to report has not yet occurred. If this is the case it will be recorded in the form as "N/A".
- Does the ship’s SMS have maintenance routine which includes the testing of standby equipment and critical equipment and are records available?
The system should include routines the testing of standby equipment and critical equipment/systems. Records of these tests should be available. The PSCO should ask to see the SMS procedure and the records associated with it. The PSCO could then note one or two items recently recorded as tested and verify these during inspection. Such tests should be requested early to allow the ship to implement any preparations and any such testing should not unduly interfere with shipboard operations.
Item to be considered as a major non-conformity: Stand by equipment or critical equipment not in the maintenance routine or tested.
- Is the relevant documentation in a language or languages understood by the ship’s personnel?
The documented SMS does not need to be in a particular language. It is for the company to decide on the "working language" of the ship and then provide pertinent and relevant information to the ship's personnel in a language understood by them.
It is not a requirement for the SMS to be in a language understood by the PSCO. The PSCO may ask for parts of the SMS to be explained verbally. In doubt as to the completeness of the SMS the PSCO may ask for drills to be conducted or witness the operation of machinery and systems.
Item to be considered as a major non-conformity: Relevant safety management information not in a working language or a language understood by the crew members.
- Are programs for drills and exercises to prepare for emergency actions available onboard and are records available?
The programme should cover statutory requirements (SOLAS, Chapter Ill - Regulation 19), and other emergency situations identified in the approved Safety Management System. The crew's responses to potential emergencies should be practised in drills. These drills should cover all documented responses to critical and emergency situation. Records of all emergency drills and exercises onboard should be maintained and be available for verification.
The records sighted could be verified by the PSCO during the inspection by asking relevant questions of the crew.
Item to be considered as a major nonconformity: Drills have not been carried out according to programme.
- Is there evidence of an effective maintenance system?
- Are introduction/familiarization procedures for crew members carried out?
Crew members may be asked during the inspection of the ship if and how they were introduced to the SMS. Some of the introduction may have been carried out before coming on board. The PSCO may ask for documented records of the introduction/familiarization of some crew member.
Item to be considered as a major non-conformity: Crew members are not familiar with their duties within the SMS.
- Are the crew members able to communicate effectively in the execution of their duties related to the SMS?
The PSCO may test the crew's ability to communicate effectively with each other during a drill or exercise. During all work relating to the SMS the crew should be able to communicate without translators (meaning other crew members).
Item to be considered as a major non-conformity: Crew members can not communicate with each other.
- Is there evidence of repetitive deficiencies from previous PSC inspections?
Where items considered to be “major non conformities” are found during the inspection, the ship is likely to be detained until sufficient immediate corrective action has been put in place to remove any immediate danger to persons, the ship or the environment. A ship may also be detained if sufficient “non major” non conformities are present such that it could be considered that the implementation of the SMS is failing.
The Cayman Islands Shipping Registry welcomes such initiatives as this CIC, recognizing the important role they play in enhancing the safety of life at sea and for protecting the environment.
We also urge companies to ensure that the masters, officers and crews of all ships are aware of this CIC and take what ever actions may be required to ensure defect free PSC inspections now and into the future.
For further information contact: Corporate Communications