The linked post is two years old now so we could see if and how anything has changed since then. Quick answer – nothing that I can see from my corner of the world.
The recitation of what’s wrong with most implementations of ISM and the resulting SMS out there seems close to what my own experience is and that includes a great deal of time with a drilling contractor. One could be forgiven for thinking that if any group is going to get this right it would be them with dedicated HSE departments, rig based HSE personnel, a budget etc. Unfortunately that has not been my experience, they are just as apt to, in my opinion, mis-interpret the ISM code in creating their SMS. Extra layers of management/policy/procedure sometimes ill conceived, often not subject to review by “subject matter experts” and just as often harsh towards genuine “continuous improvement” comments from the field.
It is hard to find fault with his analysis of things gone wrong in SMS-land.
But while whole heartedly agreeing there has to be a better way, I’m just not picking up exactly what his/the “new view of safety management system[s]” consists of.
At the end of his post he author lists off four things. I don’t know if they were intended to be the “new view” or what is wrong with what we have.
His take-away here appears to be “Compliance must have a meaning and purpose, not be something demanded for its own sake.” After I guess decades by now of innumerable bitch and moan sessions, training, planning, training, actively contributing to HSE programs and did I mention training, this seems just plain banal. And I think it would to most senior sea-going personnel. If this is aimed at shoreside ship management then I say “from your lips to God’s ears”! Otherwise I don’t think it is at sea staff that is making this stuff up the way it comes out now.
Here I think he is arguing for something I would call professional, competent, discretion with regard to the written procedure. I’m pretty sure this is what is already going on on every ship I know of. Why do I think that? Because if it wasn’t already going on then ships would never leave port. Daily? Weekly? Monthly? Senior officers are called on to balance spirit and intent, compliance and not complying, delegating and saying oh F-it I’ll do it myself, prioritizing the vast array of requirements to the time-place-circumstance they are faced with. Which lists are important now? What’s important on this list now? This is reality, the real life we are faced with. It is a situation fraught with risk to the seamen and not much to the shoreside ship management team.
The equivalence of success and failure
Here I am unclear on his message. If he is saying it is a thin line between operating in a faulty manner and succeeding and operating in a faulty manner and failing (an incident) then to that I say – do you think? Lets look at a typical organization:
- Dense, voluminous documentation system with generic procedures, forms, reports and of course checklists. Lets say it’s poorly organized and cross referenced as well. Lets say it’s redundant in places also.
- An unforgiving operational tempo.
- Lack of crew resources (at least less than desired) – manhours and competency.
- Record of past “success” (lack of incident) when same routine employed in same situation with same resources.
There are ships very close to the edge out there. Winning some, losing some. Not the best result to be hoped for in ship ops. The SMS far from preventing going over the edge, may actually be allowing it to happen.
- Business is Safety
Here the author states “Safety is not a crime against business. Business is safety.” At first I threw up a little in my mouth but then I realized this was another way of saying something I strongly believe in. I mentioned it here sometime ago as coming from an old Getty Oil book of matches cover, “Seamanship is safety”.
In other words doing it right takes into account doing it safely.
This may be too cute by half but if I could ban the word “safety” I would. However, there is plenty of room to engineer, plan and do things “safely”. The difference being that adding a giant layer of Safety departments, Safety professionals, Safety procedures can arguably be shown to not help much in actually doing things safely.
If in the end it was only the authors intent to point all this out then I would hope shoreside ship management would read the memo. If he was pointing out to senior seagoing personnel what they face everyday then it seems redundant.
So the open questions still are, is the ISM code the best it can be and is any given SMS the best it can be?
Getting flag states and IMO in the first place and ship owners in the next place to admit that what’s in place now (despite best intentions) has resulted in a folly would be a monumental challenge. Upon such admission there is no guaranty they would come up with something better especially if only “safety professionals” are involved.
Two thoughts come to mind regarding any reform effort. One is Conways Law (paraphrasing) – “An organization (IMO) that designs a system (ISM) will invariably produce a design whose structure is a copy of the organizations communications structure”. So to my mind it would take a deliberate effort to avoid a hodgepodge of “improvements”. The second thought is something I read in “The Undoing Project” – “man is a deterministic device thrown into a probabilistic universe”.
Our imperfect organizations and the very way our brains work may have the final word on whether there can be any improvement in this arena. So keep using that discretion, doing it safely as opposed to what Safety says at times and takes your chances. Which leaves me with one last thought.
“When did you start thinking every wrong had a remedy Wu?”