Not if they’re actually written into the SMS and not just “as per manufacturer’s instructions”.
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Why not initiate a SMS modification/feedback procedure statement e.g., “recommend shipboard personnel follow manufactures maintenance and inspection specifications. Current SMS procedures do not represent onboard shipboard operational equipment.”
In the past, I have seen this style of statement sent on to the corporate safety managers e.g., SMS Document Control Officer, DPA, operational managers, corporate safety committee, internal auditors, and a blind copy was kept by the sender. The sender later used his copy to identify everyone who he send emails to regarding a non-functioning general alarm.
Also, where are the internal and external auditors. Your audit reports should identify the issues and bring into question the functional objectives and requirements of the Code as it relates to the company’s implementation of the SMS.
Additionally, the audit summaries should indicate the company’s or the ship’s ability to comply with the Code. Especially, if there is an indication of “pencil whipping” operational checklist(s) or maintenance requirements for procedures and/or equipment not onboard the vessel. If deficiencies are identified and noted then the follow on comments should include how ship’s personnel are relating specific issues to corporate levels of authority and any breakdowns in the lines of communication including those issues sent to the the Designated Person(s) ashore and any corporate response(s).
Eventually, based on objective evidence as to any non-conformities or major non-conformities the auditors and flag administration will possibly need to consider discussing the possibility of withdrawing of a vessel’s Safety Management Certificate or the Company’s Document of Compliance.
One area of major concern would be the lack of effective and systematic implementation demonstrated by the lack of an effective communication feedback trail between shipboard personal and corporate levels of authority regarding the use of checklist(s), operational and maintenance procedures, that do not properly represent the vessel(s) or lack of documented corrective actions as to shipboard to corporate request for adequate support and resources.
The whole point of this discussion is that many companies don’t bother revise the system when things like this are pointed out.
Yes, that’s what you do. That way, when an auditor catches the error, you have proof that you did all you could and they blame the office instead of the vessel.
Many companies have strict policies about voluntarily sharing company emails with flag/port state for just this reason.
I’m also not sure how effective an SMS can possibly be when it is thousands of lines of just repeating “see manufacture instructions” or “perform checks per maker’s instructions”.
Really? They have policies against proving that you’ve reported an issue with the SMS?
There’s a lot more to an SMS than instructions on how to perform safety inspections.
If that proof is giving them company emails voluntarily, then usually yes. The wording is usually something like “Dissemination of sensitive information by officers or crew” or something of this sort, or a policy clarifying that company email is company property. I’ve never heard of anyone getting in trouble for ‘telling’ them what you have tried to do but if you give them company emails you run a risk of breaking company policy. (although the only people I know of who got in trouble for this did not get fired for it)
I’m aware of this. Just seems like it drops a lot of practical real world usefulness when this practice is the mindset when as it is made.
Domestic boat operating companies only spend money on SMS , to comply with the rules. They just smile and waive and pretend to go along. They don’t want the SMS actually followed if doing so is going to cost them money. SMS is just window dressing.
Probably, it’s a lot different on deep draft ships.
The vehicle for doing this was a Corrective action report, which would be tracked and require documented follow up, making paperwork for everyone involved. Ive had resistance ranging from “i guess if youre really bored and you want to, but it will be a pain…” to “ABS is watching everything you do on NS5 and this will cause me trouble on an vetting, never do this”
Im not at that level of being vetted, but I think whatever you want to call the feedback loop of amending policy is a metric your vetters will track in an ISM audit, both on the ship or on shore.
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I don’t know why I asked, it’s clear from your precious post they do not. That was a good answer though.
The shore-side approval process for low-level documents should be changed. If there’s no response from the company after 5 working days any changes to documents are automatically approved.
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Freudian typo sarcasm?
No, I thought what I was asking had already been answered.
Anyway, point is mariners are apparently having problems with being able to update / change the procedures. Some of it seems like bad design and some a lack of buy-in.
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When the official SMS manuals arrived on the ship we already had elements of a functional local sms in place, as presumably did all ships. For example the third mate had a binder with instructions and inspection forms for their safety checks.
Couldn’t toss out the local shipboard sms and very difficult to change to official SMS so the simplest solution was just linking the two systems that way so the ship could continue to function.
Which is why the massive safety book spreadsheet just gets attached to the monthly PM for the safety stuff!
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Back during the Jurassic era of the 1970s and very early 80s, shop’s crews totaled 30-35 people. Now, the normal ship’s crew is around 19-20. ISM works but the paperwork burden is overwhelming for this size crew. I investigated a case of a contamination of diesel by a ship last spring. It was a foreign flag BP chartered ship with an excellent crew. The cargo plan (a BP form) was 17 pages and it identified every valve on deck BUT didn’t include a spool-piece in an outboard mixmaster. The c/m was relatively new to the vessel and the paperwork and winter storms kept him from going out on deck and tracing lines. During the line displacement, the ship sent gasoline up the diesel cargo hose and contaminated a 1 1/2 mile ships diesel pipeline which the terminal has opened. There were many causes to the accident but the ISM paperwork for a watchstanding chief mate was a major contributor.
Back in the Jurassic era product tankers on a coastal schedule ran with 4 mates. The chief mate a non watch keeper. The present manning has the chief mate watch on stop on and the two mates watch and watch. Put this together with sometimes multiple berths at on port call and you have all the ingredients for a cluster*****.
You’ve pinpointed and exposed a critical system error, or perhaps, like some colleagues, you may not be fully informed on the matter.
SMS related communication or “feedback loop” is an integral part of Safety Management Systems. This process involves the crew providing feedback, reports, suggestions, or observations to the ship operator regarding safety-related actions and procedures on the vessel. It is a crucial aspect of maintaining a proactive approach to safety, allowing for continuous improvement in safety measures and practices aboard the ship, as well as addressing identified errors or inconsistencies.
Such correspondence is mandatory to be archived for verification by regulatory authorities.
The lack of documented correspondence may raise suspicions about an inappropriate policy and lead to accusations of the ship operator not fulfilling its obligations. In extreme cases, this could result in the withdrawal of the Document of Compliance (DOC) by the classification society.
The Safety Management System is not just a set of static procedures; it’s a living system that evolves with our operational needs and should be actively utilized on a daily basis. As I said earlier, SMS creates an appropriate work culture and is not dependent on the existing one.
Without ISM paperwork (whatever that means) were there fewer cargo contaminations and/or other undesirable events in the “Jurassic era”?
You’re an idiot.
Yes SMS is supposed to be a living document. I have never experienced that. Neither have many others. Your tone is extremely patronizing.
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This is still the case on most tankers. Maybe a little on the skinny side because we’re short on 3rd mates, but a full crew is still 2 3rds, a 2nd and a Chief mate.
Can you please tell the auditors this? Because my experience has been to the contrary on nearly every ISM vetting I’ve been through, and ive been actively discouraged from reporting discrepancies at multiple companies.
If the DPA has a change in the SMS they would like to make they could ask one of the ships to submit a report of non-conformance. When the change is then made it creates the appearance of compliance.
Or the company can “pre-approve” reports they find acceptable.