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Notes on reading the IMO International Safety Management (ISM) Code

by Russell Lunt

(This article was first published in the PYA News, 2000. Copyright 2000 Russell Lunt)

WHAT IS IT ?

The International Safety Management (ISM) Code means the International Management Code for the Safe Operation of Ships and for Pollution Prevention adopted by the International Maritime Organization by resolution A.741 (18). The ISM Code is the standard for establishing a system for the safe management and operation of vessels and for pollution prevention. It sets rules for the organisation of the owner or company management in relation to safety and pollution prevention, and for the implementation of a Safety Management System (SMS). The system will have to be approved by the flag Administration, or an organisation recognised by it (normally Classification Societies), then a Certificate is issued.

An owner can manage his own ship or appoint a management company, but for the first time, the owner or company ashore (the office – not just the ship) has to be approved and have a Certificate.

WILL IT APPLY TO YOU ?

Chapter IX of SOLAS requires compliance to the ISM Code. This new chapter to SOLAS was added by the 1994 Amendments, and is mandatory for yachts over 500 Gross Tons, which are ‘engaged in trade’ (considered as ‘cargo ships’ for the purpose of SOLAS). The ISM Code applies to passenger ships, tankers, high-speed craft over 500GT and larger ships as from 1st July 1998, but not to other cargo ships (including yachts ‘engaged in trade’) over 500GT until 1 July 2002.

The management company or owner ashore and the ship must comply with the requirements of the ISM Code, and the ship must be operated by a person or company holding a Document of Compliance.

SIZE DOES MATTER!

Don’t relax yet if you have a smaller yacht which is operating commercially – Resolution 3 of the Conference of Contracting Governments to SOLAS (adopted 1994) strongly urges Governments to implement as far as practicable the ISM Code for cargo ships (which includes yachts ‘engaged in trade’) of 150 GT and over, and requests Governments to inform IMO of the action they have taken to implement the ISM Code for those smaller ships.

As at January 2000, the IMO advised that only one or two Member States had advised IMO of their action in this respect, and this was along the lines of a watered down version of the ISM Code.

The UK Maritime and Coastguard Agency (MCA) were addressing the situation, and working on a simplified version of the Code for use by domestic passenger ships. They thought that that Code may also suit cargo ships between 150 and 500GT which operated on domestic voyages, and said that compliance with the Code for ships between 150 and 500GT engaged on International voyages is voluntary.

WHAT IT’S ABOUT.

Like most Codes and Conventions from IMO, the ISM Code is a practical set of requirements that should have the following ‘good news’ results for yachtsmen:

  • It improves safety standards on board, so making a safer working environment.
  • It promotes pollution prevention, so making a better marine environment.
  • It defines tasks and responsibilities, so making your job easier for you.

Although obviously written with ‘ships’ (as we understand them) in mind, not yachts, the ISM Code contains general guidelines on which the SMS should be based, and owners and skippers should have no problem in developing a SMS which is practical and which relates exactly to the particular vessel.

The following quote from the Code serves to illustrate the general broad terms of wording of the ISM Code:

Recognising that no two shipping companies or shipowners are the same, and that ships operate under a wide range of different conditions, the Code is based on general principals.

The Code is expressed in broad terms so that it can have a widespread application. Clearly, different levels of management, whether shore based or at sea, will require varying levels of knowledge and awareness of the items outlined.

IS THIS THE THIN END OF THE WEDGE ?

Management companies, who will be ‘operating’ a number of yachts for different owners may tend to standardise their operational procedures relating to safety and pollution prevention. This will lead to lower costs all round. Shipboard procedures in these areas are pretty standard anyway, so shoreside procedures could easily be the same for each vessel IN THESE AREAS. As each yacht owner wants his or her yacht operated in a manner which reflects their own very specific requirements, it is important that implementation of ISM Code is not taken as the ‘thin end of the wedge’ and lead to any attempts to standardise other aspects of yachting.

THE DETAILS.

The ISM Code is divided into 13 sections, as follows:

1. GENERAL.

As a general object, the SMS should ensure compliance with mandatory rules and regulations, and that applicable codes, guidelines and standards recommended by the IMO, Flag Administrations, Classification Societies and Maritime Industry Organisations are taken into account.

The responsibilities of the owner or manager, and the skipper, are serious, and there is absolutely no room for conflict between the ‘office’ and the ship. The SMS will normally be drawn up so as to best suit the particular type of operation of the yacht and the owners or managers. It must be straightforward, based on normal ways of working, and it must be practical – it must work and be shown to work.

The SMS will be a written description and details which covers the normal operating procedures adopted for the running of the yacht, the identifying of possible risk areas and procedures to be adopted to eliminate risk, and procedures to be used in the case of emergency. Based on the SMS, shore based staff at the owners or management company office will fulfil the roles assigned to them, and the SMS should provide for a self-assessment of the success of the operation of the system. The logging of the exchanges of information between ship and office will be a valuable part of this self-assessment.

The functional requirements of the SMS are:

  • A safety and environmental protection policy.
     
bulletInstructions and procedures to ensure safe operation of ships and protection of the environment in compliance with relevant International and Flag State legislation.
 
bulletDefined levels of authority and lines of communication between, and amongst, shore and shipboard personnel.
 
bulletProcedures for reporting accidents and non-conformities with the provisions of the Code.
 
bulletProcedures to prepare for and respond to emergency situations.
 
bulletProcedures for internal audits and management reviews.

2. SAFETY AND ENVIRONMENTAL PROTECTION POLICY.

The owner or his appointed shore-based managers (the ‘Company’) should establish a safety and environmental protection policy which describes how the objectives given above will be achieved.

The Company should ensure that the policy is implemented and maintained at all levels, on board and ashore.

3. COMPANY RESPONSIBILITIES AND AUTHORITY.

If the entity who is responsible for the operation of the yacht is other than the owner, the owner must report the full name and details of such entity to the Flag State Administration.

The Company has to define and document who does what – responsibilities and authority - (ashore and on board), and make sure that enough resources are available to enable the persons responsible to carry out their tasks.

4. DESIGNATED PERSONS.

To ensure the safe operation of each yacht, and to provide a link between the Company and those on board, the Company should designate a person or persons ashore having direct access to the highest levels of management. The responsibility and authority of the designated person(s) should include monitoring the safety and pollution prevention aspects of the operation of the yacht and to ensure that adequate resources and shore based support are applied, as required.

The designated person(s) should be suitably qualified and experienced in the safety and pollution control aspects of yacht operations.

5. MASTERS RESPONSIBILITY AND AUTHORITY.

The Company should clearly define and document the Master’s responsibility with regards to implementing the Companies safety and environmental-protection policy, and the SMS should include a clear statement emphasising the Master’s authority.

Any system of checks used by the Company should allow for and take account of the Master’s overriding authority to take whatever action he considers to be in the best interests of persons on board, the yacht and the marine environment.

6. RESOURCES AND PERSONNEL.

The Company should ensure that the Master and crew are fit and properly qualified; that everyone involved with the implementation of the SMS understands it as well as relevant rules, regulations and guidelines; and identify and provide any training which may be required in support of the SMS.

7. DEVELOPMENT OF PLANS FOR SHIPBOARD OPERATIONS,

The Company should establish procedures for the preparation of plans and instructions for key operations on board concerning the safety of the ship and the prevention of pollution. Instructions and agreed procedures for operation to be produced and documented in clear language(s) so as to readily available and understood to everyone concerned with the operation of the yacht.

8. EMERGENCY PREPAREDNESS.

The Company should establish procedures to identify, describe and respond to potential emergency shipboard situations, and establish programs for drills and exercises to prepare for emergency actions. The SMS should provide for measures ensuring that the Companies organisation can respond at any time to hazards, accidents and emergency situations involving its ships.

9. REPORTS AND ANALYSIS OF NON-CONFORMITIES, ACCIDENTS AND HAZARDOUS OCCURRENCES.

The SMS should include procedures for the above to be reported to the Company, and procedures should be established for the implementation of corrective action.

10. MAINTENANCE OF THE SHIP AND EQUIPMENT.

The Company should establish procedures to ensure that the yacht is maintained in conformity with the provisions of the relevant rules and regulations and with any additional requirements which may be established by the Company.

The SMS should identify critical equipment and systems, the failure of which may result in hazardous situations. Stand-by arrangements to be tested regularly.

11. DOCUMENTATION.

The Company to establish and maintain procedures to control all documents and data which are relevant to the SMS.

The documents used to describe and implement the SMS may be referred to as the ‘Safety Management Manual’. All relevant documentation to be carried on board.

12. COMPANY VERIFICATION, REVIEW AND EVALUATION.

The company to carry out internal checks (audits) to verify whether safety and pollution prevention activities comply with the SMS.

13. CERTIFICATION, VERIFICATION AND CONTROL.

The yacht should be operated by a Company which is issued with a Document of Compliance (DOC) relevant to that yacht. A copy to be placed on board.

The yacht to be issued with a Safe Management Certificate.

HOW TO GET GOING.

READ THIS:

Buy and study the publications listed at the end of this article. Pass copies to everyone (ashore and on board) who will be involved with the Operation Procedures and the formulation and operation of the SMS.

WHAT DO YOU THINK OF THE SHOW SO FAR ?

Meet together, and make an initial and honest assessment of the existing Company and on board procedures. Identify areas where improved or new procedures are needed. Discuss which systems may already be in place which could be integrated into the SMS. Shore based responsible person to be designated.

CLOCK THIS:

Establish the program to achieve ISM Code Certification. What has to be done, and by who. Make a timetable, as best fits into the yacht’s schedule. Discuss requirements for personnel and equipment. Agree the best format of the various documentation. Centralise available information, and gather missing details.

SHARPEN YOUR PENCIL!

The Companies Safety & Environmental Protection Policy should then be drafted.

LISTEN UP.

All employees should then be informed of the Policy, the importance of the project, and the importance of their role. Responsibilities and authority are to be clearly defined, and internal systems kept simple. As an example, first contact personnel (e.g. telephone switchboard operators) should be totally conversant with the importance of accurate receipt of urgent messages, and the need to immediately recognise that they may have an emergency situation.

THE NITTY-GRITTY.

The detailed work of cataloguing documents, agreeing and writing new procedures, and building up the whole Safety Management System with the Safety Management Manual(s), Operational Procedure Manuals & Checklists and whatever else is needed, can then get underway ashore and on board. This is a time consuming business, but given the use of PC’s & printers, loose leaf type presentation, ease of copying plans etc., the documentation can be assembled section by section, and procedures implemented one by one over a realistic timescale. Flow chart type presentation is a useful way of setting out some (especially emergency) procedures, and plastification of A4 and A3 size procedure cards is an obvious and sensible extra. As an example, the following subject matter could be taken as headings for the various Operational Procedures which are used whilst the yacht is in port:

 

M.Y. "NONAME"

Operational Procedures

Chapter 3. YACHT IN PORT

(see also separate EMERGENCY PROCEDURES)

 

3.1 Contact details for Port Authorities and local emergency services.

3.2 Harbour watches.

3.3 Precautions to be taken to avoid pollution.

3.4 Bunkering.

3.5 Electric and water supplies.

3.6 Control of tally of persons on board.

3.7. Security.

3.8 Safe working practices on board.

3.9 Safety and Information Briefing for contractors working on board.

3.10 Contact details for crew if ashore.

3.11 Arrangements for collection and disposal of garbage, oil and noxious products.

3.12 Policy for containment of noise.

3.13 Policy for visitors on board.

3.14 Accidental spillage or discharge of oil or noxious products.

3.15 Monitoring of stability and safety of mooring.

3.16 Embarkation and dis-embarkation of passengers.

3.17 Procedures if yacht is out of commission.

3.18 Action to be taken if fire or emergency on other vessel.

3.19 Hours of work.

3.20 Documents available for inspection by authorities.

3.21 Special safety procedures and requirements not separately itemised.

3.22 and so on...

 

The Operations Procedure Manual(s) could also include separate chapters dealing with (as an example)

General Information

Crew Matters

Administration

Domestic Systems

Maintenance

Yacht in Port

Pre Depart Checks

Yacht at Sea

Yacht at Anchor

Pre Arrival Checks

and so on.

 

Given a loose leaf format, the Manual(s) can be continually improved and updated as best suits the operation of the yacht.

The Safety Manual would contain chapters dealing with all identified risks. As an example the following subject matter could be taken as headings for the various procedures which are used in case of fire:

 

M.Y. "NONAME"

Safety Manual – Emergency Procedures

Chapter 1. FIRE

1.1 IN CASE OF FIRE

1.2 Fire Plan.

1.3 Fire Prevention.

1.4 Fire Detection and Fire Alarm.

1.5 Muster.

1.6 Fire Fighting.

1.7 Mayday.

1.8 Abandon Ship.

1.9 Fire Fighting Manual.

1.10 BA Manual.

1.11 Fire Drills.

1.12 Operation and Maintenance of Fire Fighting Appliances.

Some subjects may be duplicated – for example the muster and abandon ship and mayday procedures may well be included in any of the risk management procedure sections as appropriate.

CLASS 4 FOR THE TYPIST?

Training programmes – for shore based as well as on board personnel - can then be agreed and put into place.

STAMP OF APPROVAL.

The SMS can then be finally tuned up, and application made to the yacht’s Flag State Authority (the MCA for UK-ships) for Certification. Both the Company and the yacht will be inspected, and SMS must be demonstrated to work smoothly and to have been working for 3 months, and of course comply with the ISM Code.

Inspectors (Auditors) will satisfy themselves that the various procedures as set out in the Manuals are understood and followed. It is essential therefore (and common sense) that the procedures are drafted so as to exactly suit the yacht’s personnel and equipment and the manageable way of safe operation – not merely a hypothetical description of how things should happen in a perfect world. This is not to say that a SMS will pass muster if it is drafted in vague and casual terms and relies only upon a history of safe operation. The whole process of creating the SMS and setting down the procedures is a good opportunity to make a detailed analysis of the various operational procedures on board, and upgrade them as appropriate.

As an example, there may be a procedure for the launching of the yachts tenders, which requires the Chief Officer to hold a brief meeting with the crew involved to explain which boat is being launched by which crane, agree hand signals, allocate duties, identify risks, make pre-launching checks, advise the Master before launching &/etc. During his audit, the auditor may wish to witness the operation and confirm that the Chief Officer does hold the briefing with the crew, that he does advise the Master before launching , and does follow the procedures. Failure to do so may lead the auditor raising a non-conformity.

The Companies DOC is valid for 5 years, and subject to annual verification. The yacht’s Safe Management Certificate is also valid for 5 years, and subject to one intermediate verification and the validity of the Companies DOC.

SUMMARY.

Until Flag State Authorities decide if and how they may implement the ISM Code to yachts ‘engaged in trade’ over 150GT but below 500GT (2008 Note - Commercial Yacht less than 24m now need to comply with a diluted version of the Code), the ISM Code will apply (after 2002) only to those yachts over 500GT being ‘engaged in trade’. Some smaller yachts may decide to voluntarily comply, with personnel ashore and on board gaining useful and early experience of the working of the system. A widespread appreciation and adoption of the ISM Code would certainly set the operational side of our business up a notch or two, and handled sensibly by capable professional yachtsmen and women on board and ashore who know the importance of ‘freedom of choice’ to yacht owners, it should not lead to any loss of fun nor encroach upon the valuable and traditionally close and confidential relationship which yachtmasters enjoy with owners.

 

INTERNATIONAL SAFETY MANAGEMENT CODE (ISM CODE)

AND GUIDELINES ON IMPLEMENTATION OF THE ISM CODE

English Language Version IMO-117E

and

GUIDELINES FOR THE DEVELOPMENT OF

SHIPBOARD OIL POLLUTION EMERGENCY PLANS

English Language Version IMO-586E

Available from:

International Maritime Organization, 4, Albert Embankment, London, SE1 7SR.

Tel: +44 (0) 20 77 35 76 11 Fax: +44 (0) 20 75 87 32 41

http:www.imo.org

e-mail  info@imo.org

 

GUIDELINES ON THE APPLICATION OF THE

IMO INTERNATIONAL SAFETY MANAGEMENT (ISM) CODE

Published by:

International Chamber of Shipping, and

International Shipping Federation,

12, Carthusian Street, London, EC1M 6EB,

Tel: +44 171 417 8844 Fax: +44 171 417 8877

 

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