Help with audit

I got dinked with an item on an audit the other day. They want to see factors for determining safe waiting position defined in our SMS. Apparently ‘Don’t hit nothing’ wasn’t what they were looking for. Can anyone steer me to something more official/regulatory that we can use to build a procedure? Not finding much on a web search. I guess if all else fails, there is always good seaman’s sense.

Quoting from my current vessel’s SMS :

The following directions are therefore in force:

Coastwise Navigation Generally - All Vessels
Navigation along coastlines shall be so planned as to obtain maximum safety against collision and grounding. The Passage Plan shall include an evaluation of a sufficient minimum distance from shore, taking into consideration conditions of wind and current and the risk of a steering or engine failure or reduced propulsion power.

In passage planning, the IMO traffic separation schemes shall be taken into consideration and shall be followed.

When the logical course leads safely out of one traffic-separation and into the next one, the course to be followed shall be so planned as to avoid crossings, which may hamper other traffic and increase the risk of collisions.

Likewise, especially when keeping clear of islands and shoals, the route shall be so planned that the best possible room is left for potential course alterations due to other traffic.

Safe Distance - North American Coast
Whenever possible, routes along the North American coast shall be at a minimum distance of 25 nautical miles from the shore. Where passage through narrow waters makes it impossible to maintain a distance of 25 nautical miles from shore, navigation shall be carried out at the safest possible distance.

Safe Distance - Alaska
Recommending vessels to keep at least 3 nm clear of the Alaskan coast, if not directly heading for Alaska in which cases the Insurance Department should be notified in due time to arrange coverage for Financial Responsibility.

Safe Distance - Florida Strait
When passing through Florida Strait a distance of at least 10 nautical miles from the reefs shall be maintained.

If a port within the Strait is to be called this minimum distance shall be maintained until approaching the port makes it necessary to close the distance.

Santa Barbara and San Pedro Channel
Container vessels can navigate the Santa Barbara Channel.

A mandatory “VTIS” (Vessel Traffic Information Service) operated by the “Marine Exchange” exists within a range of 25 Nautical Miles from the Point Fermin Light.

Java Sea
Vessels may pass through the Java Sea initially by the ASL, then through the Selat Gelasa-Buar into the South China Sea - or vice versa - as described in Adm. Sailing Direction No 36.

If this route is chosen, however, due consideration shall be taken to a strong tidal current - up to 3 knots - and the many wrecks and shallow spots shall be given the best possible berth, clearly marking in the charts if coming closer than 2 NM to such obstructions, and indicating applicable positions where to call the Master.

Particularly Sensitive Sea Area (PSSA)
The IMO (MEPC) has adopted resolutions granting Particularly Sensitive Sea Area (PSSA) status to:

the Great Barrier Reef, Australia (designated a PSSA in 1990)
the Sabana-Camagüey Archipelago in Cuba (1997)
Malpelo Island, Colombia (2002)
the sea around the Florida Keys, United States (2002)
the Wadden Sea, Denmark, Germany, Netherlands (2002)
Paracas National Reserve, Peru (2003)
Western European Waters (2004)
Extension of the existing Great Barrier Reef PSSA to include the Torres Strait (2005)
Canary Islands, Spain (2005)
the Galapagos Archipelago, Ecuador (2005)
the Baltic Sea area, Denmark, Estonia, Finland, Germany, Latvia, Lithuania, Poland and Sweden (2005)
Such PSSA shall be transited with the utmost caution, in particular with regard to avoiding any kind of pollution.

Risk Areas.
Some sea areas present dangers such as shallow depth, shoals, narrow passages, dense traffic, confused traffic such as local boats and fishing vessels, strong current, poor visibility due to sand storms or smoke, ice blockage, unreliable charting, piracy, etc.

Such areas should be avoided by circum-navigation, if this can be achieved with reasonable consideration to the extra distance involved.

[QUOTE=Sea Opus;112774]I got dinked with an item on an audit the other day. They want to see factors for determining safe waiting position defined in our SMS. Apparently ‘Don’t hit nothing’ wasn’t what they were looking for. Can anyone steer me to something more official/regulatory that we can use to build a procedure? Not finding much on a web search. I guess if all else fails, there is always good seaman’s sense.[/QUOTE]

That is from the OVID question set. Typically, it will be answered “YES” by the auditor based on DP/500 meter entry procedures, which always defines safe waiting positions - in one way or another. Some safety management systems, through bridge management procedures, defines the same thing, but in a different context. It does not matter which context it is in, only if it’s defined.

Looking for something “official” or “regulatory” is pointless. You may not even find it, and it only becomes official if it’s defined through vessel procedures - either client or company driven. The OVID audit is grounded in regulation for the most part, but OCIMF, as a collective group of oil companies that are more interested in what they deem as a perceived risk. The question made it in the set for one reason or another, and the auditor is only there to answer “YES” or “NO”. One thing with the audit software. If the answer is “YES”, the auditor moves on, but if the answer is “NO”, he/she must comment, and justify the reason with a simple statement of fact that brings value to the commissioning oil company - without opinion of the auditor involved. So, it’s not a ding, or even a requirement. The commissioning oil company may not give a rats ass over that particular question. It depends on what enfolds during the 14 day answer window between operator and oil company - if that particular question is one in which they hold a high value.

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[QUOTE=Sea Opus;112774]I got dinked with an item on an audit the other day. They want to see factors for determining safe waiting position defined in our SMS. Apparently ‘Don’t hit nothing’ wasn’t what they were looking for. Can anyone steer me to something more official/regulatory that we can use to build a procedure? Not finding much on a web search. I guess if all else fails, there is always good seaman’s sense.[/QUOTE]

That is from the OVID question set. Typically, it will be answered “YES” by the auditor based on DP/500 meter entry procedures, which always defines safe waiting positions - in one way or another. Some safety management systems, through bridge management procedures, defines the same thing, but in a different context. It does not matter which context it is in, only if it’s defined.

Looking for something “official” or “regulatory” is pointless. You may not even find it, and it only becomes official if it’s defined through vessel procedures - either client or company driven. The OVID audit is grounded in regulation for the most part, but OCIMF, as a collective group of oil companies that are more interested in what they deem as a perceived risk. The question made it in the set for one reason or another, and the auditor is only there to answer “YES” or “NO”. One thing with the audit software. If the answer is “YES”, the auditor moves on, but if the answer is “NO”, he/she must comment, and justify the reason with a simple statement of fact that brings value to the commissioning oil company - without opinion of the auditor involved. So, it’s not a ding, or even a requirement. The commissioning oil company may not give a rats ass over that particular question. It depends on what enfolds during the 14 day answer window between operator and oil company - if that particular question is one in which they hold a high value.

[QUOTE=Sea Opus;112774]I got dinked with an item on an audit the other day. They want to see factors for determining safe waiting position defined in our SMS. Apparently ‘Don’t hit nothing’ wasn’t what they were looking for. Can anyone steer me to something more official/regulatory that we can use to build a procedure? Not finding much on a web search. I guess if all else fails, there is always good seaman’s sense.[/QUOTE]

They’re preobably looking for what you actually do. A good auditor can tell when something is what is actually done and when it’s just something that was cit and pasted to look good. If you just add something for appearance, you might be digging the hole you’re in even deeper. If you do add something from an outside source, be prepared to show how you will implement it and start doing it.

Yes, it was in fact an OVID question. You hit the nail on the head on everything. We do have a 500 meter checklist, but no procedure in place (that was another dink). I think I’m beginning to see the bigger picture now, it’s a matter of a subsection within the new 500 meter procedures. Thank you all very much. Love this forum.

Thank you very much fro your help Rich. That has to be the most complete statement on safe distance offshore I have seen.

[QUOTE=RichMadden;112778]Quoting from my current vessel’s SMS :[/QUOTE]

Thank you Rich. That has to be the most complete statement on safe distance offshore I have ever seen.