How do Safety Management Systems Work?

Professional Mariner Forum
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From Nancy Leveson’s paper linked in post #23

The safety culture in organizations having relatively high accident rates tend to have one or more of the following characteristics:

Culture of Risk Acceptance: This culture is based on the assumptions that accidents are
inevitable and that nothing much can be done to prevent them beyond exhorting everyone to
be careful.

Culture of Denial: In a culture of denial, risk assessment is often unrealistically low, with credible risks and warnings being dismissed without appropriate investigation:

Culture of Compliance: Focus here is on complying with government regulations. The underlying cultural belief is that complying with regulations will lead to acceptable results

Paperwork Culture: This culture rests on the belief that producing lots of documentation and analysis paperwork leads to safe products and services. Piles of paper analyses are produced but they have little real impact on design and operations

Culture of “Swagger”: Safety is for sissies. Real men thrive on risk.

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The best SMS I’ve used included a Management System Improvement Report. Anyone could fill one out online and everyone one was encouraged to used them. It then went to the Captain and I could close it (usually because it was a ship specific procedure that I could fix) or forward it to the DPA. From there it went to whichever manager was the owner of that doc (HSE, HR, Ops, etc). Closing it at any point required some justification. If it was a procedure that affected the whole fleet then the originator would be credited with the fix. There was no reason for outdated, unsafe, or just wrong procedures.

I remember though when ISM was new in the 90s all the auditors and DPA were Captains or Chief Engineers. Audits took days but were thorough. ABS got underway with us (on an OSV). My last audit though was two hours and the auditor never left the Captain’s office.

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64

Then submit a “master’s management review” or similar SMS critique form so you have paperwork proving you’ve reported the problem with the SMS.

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65

I’d like to hear from people sailing in the world fleet or working shoreside with those crews and vessels. What are their experiences on/with non US flagged ships? While I don’t think in the US we do well with the ISM code, I don’t have a strong opinion on how well implemented it is in other environments.

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A Safety Management System integrates information and risk management.

Used to be there was a box of rubber stamps in the wheelhouse with the required logbook entries. At some point that wasn’t cutting it anymore.

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This MAY answer some of the questions:

Otherwise the ranking of flag states by Paris MoU may be a good indicator of ISM performance:

Or the “ICS Flag State Performance Table 2021/2022”:

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I reflagged a ship into the US fleet not long ago. Paperwork was immaculate, but nothing worked, their 2ae (a us fleet 1ae) didnt know how to light off the boiler. LO purifiers hadnt ran in years, 3 out of 4 FO purifiers had major damage done to their bowls. Main engine was literally a waterfall of water and oil when you tried to run it.

But the paper work was top notch, so the internal ISM audit found it had no deficiencies, auditor actually said it just needs painted.

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69

sure, the box of stamps moved to the crew mess and there is a pile of documents the crew sign when they go to a meal every day.( and somebody stamps )
They wouldnt even notice what language they are written in but the object is to get the signature on the document.

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l never had a ‘Road to Damascus’ moment with regards to the SMS. It was several small things over time.

For example when the Right Whale regulations came along the captains did all the research while the 2/m continued producing boiler plate voyage plans.

As a result we had the information required for compliance with the regulations in one file and the rest of voyage info in another, not connected in any way.

At some point we realized that it didn’t make sense to have the administrative burden of maintaining two separate systems and put the RW info where it should have gone in the first place, in the voyage plan.

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Not unusual from what I’ve heard. Started a thread about it here: The Reflag Merry-Go-Round

As far as the miss-match: The map is not the terrain.

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There’s nothing inherent about a SMS that restricts interactions between senior officer and the crew.

The lack of a good SMS however does allow senior officer to act as information gatekeepers, restricting access to the information required by the crew to properly operate the ship.

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Wasnt trying to say that a SMS inhibits that, just saying that every good safety culture that I’ve encountered on a ship always seemed to come from the senior officers. Similarly unsafe ships also originated from the senior officers.

I’ve personally never seen one originate from an SMS or even really seen a marked improvement from one no matter how many pages it has.

I’d like to see one made well, with concise and accurate job information, with easy to create and track job permits, well thought out risk assessments that give actionable information

Also not blocked by 4 password layers and only accessible from a single crew workstation

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It’s less about the Flag than it is about the company culture. In the last 5 years I have done audits/inspections on a few hundred ships for a couple hundred different operators. I have seen a huuuuge difference among operators with the same flag/RO where some operators keep their ships in outstanding shape and have an ingrained safety culture on board where both the paperwork and material condition of the vessel are excellent. I have also seen ships that are completely trashed and no real effort put in to preventive corrective actions and a “check the box” attitude towards requirements. Some operators will only fix stuff that flag/class/psc identifies and have a toxic culture where the ship is afraid to report material defects or to self-report ISM non-conformities.

To me, the key is the internal audit. It’s every year vs twice in five years. In the 2-3 years between external audits a ship can go very far downhill.

If the company doesn’t put effort in to internal audits and take corrective actions seriously than you will not find the issues yourself and you leave yourself exposed to the RO/PSC finding problems for you. The internal audit should really put a vessel through the wringer and identify everything no matter how small, so that outside parties don’t. It’s the “more sweat on the training field, less blood on the battlefield” concept. I have seen internal audits that run anywhere from 1-3 days, I have done them myself as part of a 3-person team for 7 days.

PSC is hit/miss depending on where you trade and honestly I don’t think have the best grasp of the concept of quality/safety management systems. I have heard senior USCG personnel say some incredibly dumb things as it relates to the ISM Code. ROs are the same, even though an IACS class society operating as an RO is considered the gold standard, I have seen terrible ships with clean survey and audit reports from very reputable class societies.

Most Non-US Flags, the open registries especially, typically will use a lot of contractors to audits and inspections. Contractor oversight is difficult when there are hundreds of them globally (the same issue the class societies have) across every time zone.

Auditor training can also a problem. Many auditors write inspection type deficiency’s during an audit and just call them non-conformities themselves. Auditors write a to do list based on what they would do if they were Master/Chief Engineer without regard to whether the issue is an actual non-conformity or an actual rule, regulation, or SMS requirement is involved. This is where SMS creep comes in and you can end up with overly burdensome SMS requirements. When a company just wants to close the NC as quick a they can they may create a new checklist or add new requirements to their SMS without challenging the auditor’s findings or putting in the effort to ad common sense or efficiency of effort to their preventative corrective action.

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75

Excellent comment.You Sir hit the nail right smack in the middle of it’s head. :+1: :+1: :+1: :+1:

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How does an American “BrownWaterGuy” become an ISM Auditor for deep draft ships of every flag trading internationally?

I ask as a brown, blue, and green water guy with a tug and barge background.

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Shipping-Industry-Flag-State-Performance-Table-2022-2023.pdf (ics-shipping.org)

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BrownWaterGuy will certainly answer Your question himself.

I am 100% certain with your experience You will make an excellent auditor on condition:

a) You undergo specialised auditors training

b) You will acquire intimate knowledge ( know it like the back of your hand)
of Solas , Marpol, STCW, MLC plus locally USCG CFR and familiarise yourself as per ISM code with ; " all applicable codes, guidelines and standards recommended by the Organization, Administrations, Classification Societies and maritime industry organizations ( it is ISM requirement -see the Code)
"Refer to the List of codes, recommendations, guidelines and other safety and security-related non-mandatory instruments
(MSC.1/Circ.1371), MSC.1/Circ.1371 add 1, MSC.1/Circ.1371 add 2 "

c) Obviously You will know ISM code by heart and be familiar with some of the RO instructions /guides like : IACS_Guidance for IACS Auditors to the ISM Code and locally USCG guides which are excellent .

d) It would be a good idea to get familiar with literature written by experts which I mentioned in one of my recent comments in another thread. The list of items is in a clip below.

e) You will obviously know the Flag states requirements like Liberia, Panama, Cyprus, Singapore, Malta just to mention a few .

And the rest :wink: is easy as pie :wink: Before audit on board You will secure the copy of their SMS , read it carefully , The rest as per a,b, c,d, You already know.

Now allow me to explain why I think ( I may be wrong of course) You would make an excellent auditor.
quote:
Many auditors write inspection type deficiency’s during an audit and just call them non-conformities themselves. Auditors write a to do list based on what they would do if they were Master/Chief Engineer without regard to whether the issue is an actual non-conformity or an actual rule, regulation, or SMS requirement is involved. End quote.

Your hands on experience on deep see being limited or none at all will allow You to focus strictly/solely on audited contents of SMS and compliance with it ,plus compliance with all what I have mentioned above.

Your knowledge willl not be tainted with practical deep sea experience and you will not issue quasi- nonconformities based on Your wishfull tihinking mentioned above by BrownWaterGuy.

Hence Your nonconformities and observations will contain normative references only and not some crazy idea of how You would do it yourself.

This has always been contested by myself as a master when I disagreed with nonconformities , that did not contain normative references.

Cheers

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What issues do you mean here? The actual physical problems on the ship? Like poor housekeeping or inventory errors? Procedural errors? Or the failure to identity and properly document and correct problems?

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It can be any or all of the above. In my personal opinion the failure to identify, document, and correct problems (or at least start that process) is the thing that will get you in the most trouble. As long as your ship can identify the issues (be it material or procedural), effectively document them and communicate them to shore, and shore provide the vessel the support needed to correct the issues, then the vessel will be in overall good shape and unlikely to get in any trouble with flag/psc.

  1. Are you working your system?
  2. Does your system work?
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81

Pretty sure I didn’t say “every”, but non-US yes.

  • Academy grad
  • Only sailed brown water after graduation
  • Worked for Uncle Sam for a few years where I saw the matrix for the first time (meaning I learned to understand rules/regulation and more importantly the scheme of how they are structured and who the players are)
  • Went back to sailing brown water
  • Went to work in the office for a non-US flag
  • Learned how the rest of the maritime world works (very different from the US)
  • Learned IMO and SOLAS/MARPOL/Etc.
  • Got in on the ground floor for a TPO
  • Became a flag state auditor/inspector
  • Started my own survey/audit business

Personally, I think the maritime regulatory scheme is the greatest deficit in maritime education. It’s not taught school, it’s all OJT and it presumes Masters and Chiefs know enough to teach the 3rds … they don’t. This is true internationally, not just in the US.

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