Good comic to start with.
Where I work we do not have a SMS. We have an alternative way of handling roughly the same issue. I was curious about one thing. An underlying basis of our system here are past statistics on injuries within the company. We have in-house injury statistics going back to 1994. The injuries are cataloged by body part injured, and by cause of injury. Further sub-cataloged by boat the injury occurred on.
When we have our annual week of safety training for each crew, the training is based, in part, on the in-house statistics. Example: most of our vessels use yard-and stay cargo gear. The casual observer would reckon it quite dangerous, and suppose we must spend a lot of time on specific safety training for the cargo gear.
However, statistically speaking, injuries re: yard-and-stay cargo gear at our company are vanishingly rare. Far more common is falling down stairs in the house. Whatever we are doing to prevent cargo gear injuries works. Therefore, the training to avoid falling down interior stairs from the berth deck to the galley is more important than for avoiding cargo gear injuries.
The main point here is that our safety training and manuals reflect the in-house injury statistics.
Is this common to SMS also? Is it common for vessels/companies operating under SMS to compile in-house injury statistics and share them with their mariners?
In my experience, yes companies do compile inhouse injury statistics. Sometimes it’s hard to get good accurate data going back as far as yours is though, that’s impressive. If you’re spending time doing it though, it’s easy to keep up with since you’re already submitting 2692s and insurance claims, so hypothetically you have all the data, it just needs to go into a spreadsheet. The companies I’ve worked for have tracked this info, and analysed year to year trends and compared against industry averages. For example the AWO compiles injury stats and trends, which are collated from submissions from member companies.
Now when it comes to training, there’s the basic stuff you should be doing on an annual basis, or drills and their frequencies, but when for all the non-mandatory stuff, see what’s affecting you the most. Most places I’ve worked at they will do a risk assessment for how to tackle risks like you mentioned. Falling down stairs would probably be higher on the probability, but maybe moderate consequence, either way you might address that with some type of training. The cargo one you mentioned is gonna be low probability but high consequence, so that’s why you’re training on that even though hopefully nothing bad happens. Probability x Consequence = Risk.
I’m more surprised you don’t have an SMS, but someone’s bothering to keep the spreadsheet of injuries, updated and detailed. Another next step might be analysing the payouts of those injuries, and the value of the lost time from the worker not being able to work.
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SMS that is part of the ISM code is safety management of the (entire) vessel and the environment. Personnel injuries are part the vessel management and incident reports record this. You must have the NCR and CA system. You must also have the DPA (designated person ashore) who is your first person of contact for any incident.
(DPA generally reports directly to the top dog of the company).
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The company is in the fishing industry. SMS not required for fishing industry. I sometimes think, (maybe incorrectly) that the need for SMS came about, in part, because of the long lines of communications in some companies, and the need to systemize info so that people at a distance from each other can keep track of what is going on. You may have a ship that travels around the world, owned by one company, but operated by another company. The ship may have two or three unions involved on it, or maybe hiring outsourced to other companies, so there is a certain amount of turnover involved in staff . The ship may have no home facility, and may complete repairs anyplace in the world. In that sense I could see why a SMS would be useful, because the lines of communication between people who make decisions are long, and the chain of command for decision-making complex, yet everyone has to have the same playbook/data to work from.
Compare that to a fishing industry operation like ours where the owner is the operator, and all voyages begin and end a few yards from his office. The officers and crew report to the port captain, who is also located on the dock, a few yards from the owner. Boat repairs are made by an in-house repair crew also on the dock, led by the port engineer, who schedules any shipyard work always at the same local shipyard. The lines of communication are much closer, and the chain of command simpler.
That’s pretty common in a fishing company but it often gets simpler than that. In the fishing industry the owner/operator/captain/chief engineer are often just a single person.
That being said, we have here our Vessel Operation Manual and a host of checklists, and a system of maintenance checks, and statistical analysis, which I have been told by people does pretty much the same thing as a SMS. Same concept, different tools.
I see where you’re coming from. In my mind that is a SMS. It may not be a fully fleshed out SMS, or one that meets ISM standards, it might not have more advanced features like having a bunch of stuff computerized, or include all the PMS stuff, but it still counts as a Safety Management System. Most of what I’ve worked on has been Tugs and Passenger Vessles, all domestic. With smaller towing companies, it can be pretty similar, an owner or a Port Capt might have numerous roles such as being the DPA, CSO, QI, etc. a smaller company like that though is much less likely to have truely implemented Near Miss reporting, or other kinds of incident/injury analysis. It’s all scalable.
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Did this thread lose a bunch of posts? I recall a lot of angst over checklists and documents that become out of date but still are supposed to be followed.
A suggestion from the aviation world: The plane comes with a POH - aka owner’s manual - and any new equipment added gets its own documents added to the POH. Thus for an EPIRB that needs a new battery once a year being removed and an EPIRB being added that needs a new battery every 5 years, the old EPIRB documents go and the new ones get added. Thus the documentation always corresponds to the equipment that is actually there 
The core of ISM is about 15 pages.
Yet, most SMS are several hundred pages and attempt to micromanage far too much minutiae. Therefore, they merely result in a lot of pencilwhipped psudeo compliance without a second thought.
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Your system is very likely nearly fully compliant with the ISM code requirements for an SMS. Most companies have an SMS that is way, way more complicated than it is required to be though it’s a good legal CYA for the company so that’s probably why they do it.
This is thread #2. Maybe those posts were in the original?