The International Maritime Organization (IMO) International Management Code for the Safe Operation of Ships and for Pollution Prevention (ISM Code) first became mandatory in 1998. Twenty years and five amendments later, we reflect on how the code is doing and what still needs to be done.
The ISM Code was born out of a series of serious shipping accidents in the 1980s, the worst of which was the roll-on roll-off ferry Herald of Free Enterprise that capsized at Zeebrugge in March 1987, killing 193 of its 539 passengers and crew. The cause of these accidents was a combination of human error on board and management failings on shore.
What followed was a much-needed change in maritime safety administration. In October 1989, the IMO adopted new Guidelines on Management for the Safe Operation of Ships and for Pollution Prevention giving operators a ‘framework for the proper development, implementation and assessment of safety and pollution prevention management in accordance with good practice’. Following industry feedback, the guidelines became the ISM Code in November 1993 and were incorporated in a new chapter IX of the IMO’s 1974 International Convention for the Safety of Life at Sea (SOLAS) in May 1994 and became mandatory for companies operating certain types of ships, as from 1 July 1998.
Meeting the requirements of the code is evidenced by ships’ flag states in five-year ‘documents of compliance’ for ship operators and five-year ‘safety management certificates’ for ships, all subject to regular audits.
The ISM Code requires nearly all the world’s ship operators to write and implement on-board safety management systems (SMS) for their ships and make ‘designated persons’ ashore responsible for every ship’s safe operation. For many ship owners and operators, ISM was simply a new legal framework for the safety systems they already had, but for others it led to major and much-needed changes in operating culture and organisation.
Certainly, the ISM Code has made shipping safer and cleaner over the past two decades. In 2005 the data collected by an international group of experts, on behalf of the IMO, led them to conclude that: ‘where the code is embraced as a positive step toward efficiency through a safety culture, tangible positive benefits are evident’.
Producing more effective SMS documentation
One issue we have noticed is the tendency for SMS documentation to be too long – it should be short, simple and easily understood. Reducing the volume of text and using flow charts, diagrams to assist quick reference is advisable.
SMS documentation should also be unique to the ship. There is no point, for example, in having tanker procedures in an SMS for a dry bulk cargo ship.
A key point to note in drafting SMS checklists is that they should balance the need to remind crew members what to do and instruct them step-by-step on what to do.
Finally, new procedures and checklists should not be added to an existing SMS without properly reviewing older procedures.
Take a sensible approach to near-miss reporting
ISM has prompted some shipowners to encourage an over-the-top approach to reporting near misses and non-conformities in the mistaken belief this alone will improve safety. This method has also been encouraged by major charterers in the wet and dry trades.
There should however be no minimum target set for the number of near-miss reports. The focus should be on learning from genuine near misses and non-conformities.
Near-miss reports should be analysed and categorised so they can be combined with reports from other ships in the fleet. They should also be cross-referenced with similar statistics and categories from port state control (PSC) inspections, oil major inspections (SIRE) and RightShip inspections.
Any category standing out in key performance indicators (KPIs) needs further analysis and lessons learnt should be incorporated into the next quarterly or yearly training programme.
We also believe shipowners and operators should pay more attention to their masters’ SMS review reports.
Masters should be encouraged to discuss the SMS reviews with crew members as they are the key users of the documentation and should have the biggest input into any proposed changes. The reports should be a priority for senior management, as failure to act on what their masters tell them could lead to a major casualty or major ISM non-conformance.
Senior management should give similar attention to ship safety committee meeting reports (SCMR). These too often focus on welfare issues rather than safety.
In summary, masters and crew need to be educated in what the SMS reviews and SCMR are for and how best to conduct discussions and meetings prior to writing their reports. Equally, shore-based managers and staff need to know how to review the reports properly and, more importantly, how to improve the safety of their ships as a result.
Yves Vandenborn, Director of Loss Prevention, Charles Taylor Mutual Management (Asia) Pte. Limited, managers of The Standard Club Asia Ltd)