GUIDANCE FOR AUDITORS TO THE ISM CODE 2005-10-18 MTPNO342 Maritime Management Systems 000035GUIDANCE FOR AUDIT TO THE ISM CODE Page 2 of 57 GUIDANCE FOR IACS AUDITORS TO THE ISM CODE IMO Resolution A.741(16) a5 amended by MSC.104(73) ‘ANNEX [IVTERNATIONAL MANAGEMENT CODE FOR THE SAFE OPERATION OF SHIPS AND FOR POLLUTION PREVENTION (INTERNATIONAL SAFETY MANAGEMENT (ISM) CODE) PREAMBLE, 1 The purpote ofthis Code to provide an international standard forthe safe shanagement and ‘operation of ships and fr pollution prevention 2. Te Assembly adopted resolution A430) by ‘which invited all Governments to tke the necessary sles to safeguard the shipmaser in the proper lischarge of his esponsibilties with regard to maritime safety and the protection of the marine 2, The Assembly also adopted resolution A.680(17) by which further recognized the need for appropriate organisation of management lo erable ito respond wo the need of those on board ships to achieve and mainsin high standards of safety and environmental protection. 3. Recognizing that no two shipping companies or ship owners are the same, ad that ships operate lunder a wide range of different condition, the Code is based oa general principles and objectives. 44. ‘The Code is expressed in broad tems 50 that it ean have a wide application. Carly, diferent levels cof management, whether shore-bated ra sea, will equire varying levels of knowledge and awareness of the items outlined, 5, ‘The comerstone of good safety management is commitment from the tp. In matters of safety and pollation prevention tis the commitment, competence altudes and motivation of individuals at ll Tevels tht determines the end result INTRODUCTION ‘Scope and application ‘This guidance is intended for use by DNV Auditors when performing certification under the ISM Code, unless the relevant Administration has provided special instructions that indicate otherwise. ‘This document is also intended to promote audits’ consistency and uniformly among |ACS by providing examples, which, however, are not to be interpreted as prescriptive solitons or checkists. Reference is made to the following Resolutions adopted by the Intemational Maritime, Organisation (IMO): a. the “international Management Code for the Sate Operation of Ships and for PollutionPrevention® (ISM Code), adopted by Resolution A.741(18) as amended by MSC.104(73) and made mandatory by Chapter 1X “Management for the Safe Operation of Ships" of the SOLAS Convention; b. "Revised Guidelines on the Implementation of the ISM Code by Administrations”, adopted by Resolution A.913(22) and referred in this document as the “IMO Guidelines", which are applicable to Recognized Organizations (RO) when acting at the request of Flag Administrations; 1 Waragement Sten Cera 1k Safely Managerial CeieaontS19 suction and GulanceIGLIDANCE FOR AUDITORS oct asians 000036bg) GUIDANCE FOR AUDIT 70 THE ISM CODE Page 3 of 57 ‘Guidelines for the Authorization of Organizations acting on behalf of the Administration’, adopted by Resolution A.739(18) and made mandatory by Chapter XI"Special Measures to Enhance Maritime Saloly" of the SOLAS Convention. 2. Application of the ISM Code by Companies By design, the ISM Code supports and encourages the development of a safety culture in shipping. The content of a Safely Management System (SMS) will therefore be affected by Company commitment, values and beliefs, which cannot be enforced through the regulatory Process. In developing and implementing their systems, Companies may have used indust'y guidelines, such as the ICS/ISF "Guidelines on the Application of the intematfonal Safety Management Code”. Assessing compliance with the [SM Code trom detailed prescriptive management system Solutions is not practical and would be inconsistent with the intent of the ISM Code, which allows a Company to develop solutions which best suit the Company and their parlicular ‘operation and ship type(s), whist ensuring basic internationally agreed standards of safely ‘management. 3. Certification process ‘The verification of compliance with mandatory rules and regulations, required as part ol the 1SM Code, neither dupiicatss nor replaces the surveys required by the other statutory certificates. Compliance with the ISM Code does nol relieve the Company, the Mastar or any ‘other entity oF person involved in the management or operation of the ship of their own responsibilities ‘The verification process invoives interviews of Company personnel and review of SMS documentation and records. Audit is a sampling process and is not exhaustive in nature. 'ssuance of cerification is based upon verification that the sample is in compliance with the 'SM Code. Where non-conformities have not bean found and reported, itdoes not mean that ‘none exist. Basic procedures for performing ISM Code verfication are contained in the |ACS “Procedural Requirements for ISM Code Certification", PR. 9, which reflect the IMO "Revised Guidelines for Administrations on the Implementation ofthe ISM Code’, Resolution A. 913(22), as applicable. 4. Editorial principles For convenienee, this document incorporates the actual text ofthe ISM Code, followed by the relevant recommended guidance for IACS auditors. The document will be updated as ‘necessary consistent with JACS Member Societies’ experience in the aucit process, Guidance and recommendation given by DNV (not ISM-code nor IACS guidelines) are marked by italics. (2231 Managemen Systm Cericatons1’3 ISM Saat Management Carictor33 lntetons and Guidencl GUIDANCE FOR AUDITORS oct OSen2, 000037eo GUIDANCE FOR AUDIT TO THE ISM CODE Page 4 of 57 — IST OF CONTENTS 4. General 5 2. Safety and Environmental Protection Policy 13 3. Company Responsibiities and Authority 14 4, Designated Person(s) 7 5. Master's Responsibility and Authority 20 6. Resources and Personnel 25 7. Development of Plans for Shipboard Operations. 33 ‘8, Emergency Preparedness 36 8, Reports and Analysis of Non-conformities, Accidents and Hazardous Occurrences 40 10, Maintenance of the Ship and Equipment 42 11. Documentation a7 12. Company Veritication, review and Evaluation 49 (0,01 anagerent Stem Ceznson019 GM Safely MensgomentCeriietonits9 nc sl GuderceGUIDANCE Fon AUOMORS oct {FOR AUOTTORS 6 8. 000038GUIDANCE FOR AUDIT TO THE ISM CODE Page 5 of 57 PART A - IMPLEMENTATION ‘Misc.10473) 1. GENERAL 11 Definitions ‘The following definitions apply to parts A and B of this Code. 1.1.1 “Intemational Sefety Management (ISM) Code" meane the Intemtional Management Code forthe Safe Operation of Ships and for Pollution Prevention as adopted by te Assembly a8 may be amended by the Organization 1.1.2 “Company” means the Owner ofthe ship or anyother organiation or person such asthe Manager 6 he Bareboat Charterer, who has assumed te responsibilty fer operation ofthe ship from the Skip ‘owner and who on assuming such esponsibility has apreed to take overall the dates and respensbiily imposed by the Code, 1.1.3 "Adminisvation” means the Government ofthe State whose flag the sip is ented to Ny 1.1 “Safety Management Syste” (SMS) means a stuctwed al documented system enabling Company personel to effectively implement he Company safety and enviontoental proetion policy, 1.15 "Doctanent of Compliance” means document ised oa Company which complies wid the requirements ofthis Code. 1.1.6 "Safe Management Cetficate” means 2 document sued to ship which signifies thatthe Company and its shipbossd management operate in accordance with tbe approved sfety mangperoent system, 1.1.7 “Objective evidence” means quatiative or qualitative information, records or statements of fact Peraining to safety or tothe existence and implementation ofa SMS lernen, which is based on ‘observation, measurement or (stand which ean be verified. 1.1.8 “Observation” means a sitement of fact made ding a safety management audit and substanated bby objective evidence. 1.1.9 "Nor-conformity" means an observed siuation where objective evidence indicates the non- fulfilment of a specified requirement. 1.1.10 "Major non-confority* means an idetifsble deviation which poses a serious heat othe safety ‘of personnel or the sip ra serious risk tothe environment that quires immediate carective action and includes the lack of effective and systematic implementation of requirement of this Code 1.1.1 “Anniversary date” means the day and month ofeach yea that comesponds tothe date of expiry ofthe relevant document or certfiele. 1.1.12"Conventon” means th Inerational Convention fo the Safety of Life at Se, 1974, s smendsd, (fs Management Stem Cartfcato3 ISM Safely Managemen Caer 35 Inston and Guance\GUIDANCE FOR AUDITORS et Sse, RRA eee eee 000039@ GUIDANCE FOR AUDIT TO THE ISM CODE Page 6 of 57 1.2 Objectives 1.2.1 "The objectives ofthe Code are to ensure safety at sea, prevention of human injury or loss of if, and voidance of damage tothe environmen, n particular, tothe marine environment and to property 1.2.2 Safety management objectives ofthe Company shoul, inter <1 provide for safe proctces in sip operation and a sae working environment, 2 establish safeguards against ll denied risks; and 3 continuously improve safety management skills of personnel ashore and aboard ships, including preparing for emergencies celated both to safety and environmental protection 1.23 Theafety management system should ensure: 1 compliance with mandatory ules and regulations; ed 2 that applicable codes, guidelines and standards recommended by the Organization, ‘Administrations, classification societies and maritime industry organizations are taken into account 13 Application ‘The requirement of his Code may be applied to all ships. 114 Functional requirements for a Safety Management System (SMS) Every Company should develop, implement and msiniin «Softy Management System (SMS) which {includes he following functional requirements 1 9 safety and environmental protection policy: .2instactins and procedures to ensure sfe operations of ships and protection ofthe environment in ‘compliance with relevant international end flog Slate legislation; 3 defined levels of authority and lines of communication between, and amongst, hore ané Shipboard personnel; A procedures for reporting accidents and non conformities with the provisions of this Codes, .5 procedures 1o prepare for and respond to emergency situations; and .6 procedures fr internal avis and maragesment reviews _ ISM Code ~ item 1.1 Definitions in SOLAS Chapter IX (1996) “Bulk cartler" as defined in Regulations IX / 1.6 of the SOLAS Convention means a ship which is exempltied in paragraphs 2.2, 2.3 and 2.4 of ACS Unified Requirement 211 "Mandatory Ship Type and Enhanced Survey Programme (ESP) Notations” Renae unseen On cuanto On CUootovn (nso ee Definitions from IACS PR 9 “Audit? means a systematic and independant examination to determine wether the SMS activites and related results comply with planned arrangements and whether these ‘arrangements are implemented effectively and are suitable to achieve objectives. (043) Management Sytem Corian IM Selly Management Cortatoni83 nsuctrs and GuanceGUIDANCE FOR AUOITORS oe: 3. _FORAUDITORS 05 06 000040GUIDANCE FOR AUDIT TO THE ISM CODE Page 7 of 57 “Aucitor” means a person performing vertication of compliance with the requitements of the ISM Gode and who fullis the personne! qualification and other pertinent requirements, contained in Section 1 of PR 10. “Lead Audiior” means an auditor who is authorized to lead a team of two or mare auditors as specified in Section 1.6.2 (i) of PR 10. {Branch Office" means an oftice thats part of the Company, under its control and covered by the same SMS, ;Salety Management Manual” is the documentation used to describe and implement the Safety Management System (SMS), “Safety management aut" means a systematic and independent examination to determine whether the SMS activities and related resulls comply with planned arrangements and whether these arrangements are implemented effectively and are suitable to achieve objectives. “Technical deficiency" means a defect in, or failure in the operation of, a part ofthe ship's structure or its machinery, equipment or fitings. 'Non- conformity” means an observed situation where objective evidence indicates the non- {uffllment of a specified requirement. “Major non-conformity’ means an identifiable deviation that poses a serious threat to the safety of personnel or the ship oF a serious risk to the environment that requires immediate corrective action and includes the lack of effective and systematic implementation of a requirement of this Gode. Any ane of these situations may be considered a major non-conformity. ‘The following definition has some differences from the Cade, as explained: Observation’ — the definition from the Gode was complemented, in the IACS PR 9, stating that: it may also be a statement made by the auditor referring to the SMS which, if not corrected, may load to a non-contormity in the future. DNV: For a ship management company, a management agreement signed by the Company and the ‘over and stating that the ship management company has assumed responsibily forall duties «and responsibilties imposed by the Code, should be available ta the Auditor, ‘A Company may contract with thid parties to manage speciic acivlies e.g. manning, {echnical support and maintenance. It is the responsibilly of he Company to identily in the ‘SMS the role of each subcontractor performing elements covered by the ISM Code. With such @ contracting arrangement, only one DOC can be issued to the Company. Se 25S! sane Systam Corian ISM Satay Wanegemen Ceriston129 incon and GidencelGUIDANCE FOR AUDITORS ox Gone 000041(GUIDANCE FOR AUDIT TO THE ISM CODE Page 8 of 57 ISM Code - paragraph 1.2.2 (1996) 1.22 Safety management objectives of te Company shoul, inter la <1 provide for safe practices in ship operation and a safe working environment; _Destabish safeguards against al dentfed risks nd 3 continuously improve safty management sil of personnel ashore and aboard ships, including preparing for emergencies reed both o safety and environmental protectin. ee In accordance with the IMO Guidelines (Fes. A.913(22)}, the objectives of mandatory application of the ISM Cade are to ensure: 4. compliance with mandatory rules and regulations related to the safe operation of ships and protection of the environment; and 2. the effective implementation and enforcement thereat by Administrations, Effective enforcement by Administralions must include verification that the SMS complies with the requirements as stipulated in the ISM Code, as well as verification of compliance with mandatory rules and regulations. ‘The mandatory application of the ISM Cade should ensure, support and encourage that applicable codes, guidelines and standards recommended by the IMO, Administrations, Glassification societies and marlime industry organisations are taken into aecount. “These objectives encompass the effective and on-going implementation of the SMS and, to a large extent, depend on reactive and proactive improvement of the SMS functions, as part of the ISM Code. Although itis not often referred to as such, the development and implementation of a documented safely management system is an exercise in risk management. The drafting or ‘Amendment of written procedures involves looking at the company's activities anc operations, identifying what could go wrong, and deciding what should be done to try fo prevent it. The documented procedures are the means by which ihe controls are applied. To help all the companies in establishing safeguards against all identified risks the |ACS had developed * A GUIDE TO RISK ASSESSMENT IN SHIP OPERATIONS” DNV: For the purpose of auditing it is important to recall that the objectives above do not empower the auditor to set requirements beyond those already stated in the Code. However, from a certification point of view, ifthe requirements of the Gode are fuly met, then the objectives above are achieved. Example no 1: Safe Practices From a certification point of view, safe practices have been established ifthe SMS ensures that the ship, operation and manning complies with the requirements in mandatory rules and regulations; and ifthe safe practices recommended by IMO, Administrations, Classification ‘Socialies and other maritime industry organisations are taken info account, ‘0181 aanagement Stem Ceraior919 ISM Saal VanegemetCorlcari29tnsntors end Gudence\GUIDANCE FoR AUDITORS ot 05.00 000042ca GUIDANCE FOR AUDIT TO THE ISM CODE Page 9 of 57 Example no 2: Identified risks ‘Safeguards against all identified risks have, from a certification point of view, been established it they cover the risks considered by mandatory rules and regulations; and the ones addressed (in the recommendations from IMO, Administrations and maritime industry organisation, Examote 10 9): “Continuous improvements" The Code includes requirements tor safely management functions such as: non- Familiarization of the master and olficers are familiar with guides and guidelines DNV: Together with 1.2.3.1 this objective defines the specific levels of safety that the SMS shall ensure in terms of the condition of the ship, operational standards, and * qualification and competency of crew. Together with mandatory requirements, the recommended codes, gules and slandards defines ie industys perception of safe practices in ship operation, Quotation fiom A T69), 2.36: "ihn an SMS, inplementtion of codes, guides and standards recommender IMO, Acininisratons, elassitcation soceties and other martina indusiyerganisalone cote, fol make these recommenations mandatory under the ISM Code. Nevertfotes scorers Shauld encourage companies to adopt these recommendations whenever applicable to the Company.” To meet the requirements of A.786(19) on this equites that DNV Aurstors have thorough nowiedge an codes, gideines and standards recommended by IMO, Admnstonene lassiication societies and other maritime indusiry organisations. (This was and fs ome ofthe ‘reasons why ISM Code cetifoaion was let to organtcations with profound renting competency.) The comments to Section 7 of the Gode show the implication of this objective on Company and shipboard audit. DNV Guidance to paragraph 1.2.3 ( both .1 and .2) ‘The Auditor Guidance to 1.2.3.1 and 1.2.3.2 shows how the special character of the ISM Gode audits andl the purpose of ISM Code certiticaiton calls for auditing methodologies which are basically citferent from those used for aucits to other management standards. SS GER Agnepement System Corcaton'St9 EM Saety Management Celcaono19 Insineton snd GulencsiGUIDANGE FORAUOITORS ot 3g 000045GUIDANCE FOR AUDIT TO THE ISM CODE Page 120f 57 ISM Code - paragraph 1.3 1.3 Applicaton “The requirements ofthis Code may be applied toll ships. eee “This Code is mandatory for all ships to which the SOLAS regulations apply and to any other ship, if required by the Flag Administration. For vessels not required to comply with this Code, a “voluntary” certificate may be issued by the RO. Normally, this wil be done only for vessels classed by an |AGS member, but ROs may do so in special circumstances at their own discretion oe ISM Code - paragraph 1.4 1.4 Fonetional requirements fora Safety Management System (SMS) [Every Company should develop, implement and maintain Safety Management Sytem (SMS) whieh ‘nce the following funetionl requirements: <1 a safety and environmental protection policy; 2 instvetions and procedures to ensure safe operations of sips and protection of th envionment in ‘Compliance with relevant international sad flag Stae legato 3 defined levels ofeuborty and lines of communication between, and amongst, shoe and hipboard persoael; 4 procedares for reporting accidents and non conformities withthe provisions ofthis Code; 5 procedures to prepare for and respond co emergency situations; and 6 procedres for intemal audits and management reviews, eee ‘The functional requirements of the [SM Code are intended to ensure the implementation of sale practices in ship operations through written procedures and work instructions, These functional requirements summarise the detailed SMS requirements that are described in the remainder of the ISM Code. se oe MSC.104(73) 2. SAFETY AND ENVIRONMENTAL PROTECTION POLICY 2.1 The Company should establish a safety and environmental protection policy which deseribes how the ‘objectives, given in paragraph 1.2, wil be achieved. 2.2"The Company should ensure thatthe policy is implemented end maintained etal eves ofthe ‘organization both ship based us well as shore based ‘0131 tanagement System Ceca SM Sally Merogorer Ceca 39 sts end GuidanestUDANCE For AUDITORS act aoe ooo04sGUIDANCE FOR AUDIT TO THE ISM CODE Page 19 of 57 RR AU TO THEISM CODE Page 13 of 57 ISM Code - paragraph 2.1 2.1 The Company should establish a safety and environmes ‘objectives, given in paragraph 1.2, willbe achieved. 1 protection policy which describes how the {tis the company’s responsiblity to define and document ts safety and pollution prevention policy, which must describe how the objectives in paragraph 1.2 will be achieved. This document is fundamental to, and forms an integral part of, the company's safely management system. The procedures and all lower-level objectives must act in support of the: overall objectives established in the policy. Where, in an effort to improve safety and pollution prevertion, the company has chosen to incorporate and make mandatory some of the applicable codes, guidelines and standards mentioned in paragraph 1.2.3.2, this should be supported and encouraged by the auditor. Examples of objective evidence that may be found bath in the oifice and on board include: = Acopy of the policy dacument ~ Established safety and pollution prevention objectives DNV: ‘Note that the Company policy should describe how the abjectives stated by the ISM Code are {0 be achieved. To this end, the Company management should not only provide a brief “salty and environment statement, but state their general and specific safely objectives and describe the measures adopted io achieve them. This makes the “ISM Code Safety Policy” diferent in character from the mast common qualily poligy statements. The safely management objectives of a Company may include more than the objectives required by the ISM Code. Such objectives, consistent with an intent to improve safety and pollution prevention, should be encouraged and supported by the auditor. Inadequato achievernents of such objectives should not be used for the issue of non-conformily statements at audits. They may be reported as “Observations”. SSeS ISM Code - paragraph 2.2 2.2°The Company shoulé ensure that the policy is implemented and mainnine a all levels ofthe ‘organization both ship based as wel shore based. eee eee (023! Management Sytem Carteafon3t3 St FOR AUDITORS ox! 03.00 ly Management Crlicatoni33istucions ae GuldancXSUIDANCE 000047oo GUIDANGE FOR AUDIT TO THE ISM CODE Page 1401 57 “The Company is responsible for ensuring that all relevant personnol at all levels of the Company, including shipboard personnel and sub-contractors with responsibilities relevant 10 the SMS, are aware of and understand the policy. Comprehensive and effective intemal audits, management reviews, corrective and preventative action, and other management processes are essential in ensuring that the policy isimplemented and maintained. Examples of objective evidence thal may be found both in the office and on board are: = Interviews with relevant personnel to establish the level of awareness and understanding = records of internal and external audits = records of corrective and preventative actions and their evaluation = maintenance plan and records of maintenance of the ship and equipment ‘isc.10473) 3. COMPANY RESPONSIBILITIES AND AUTHORITY '3.1 If the entity whois responsible forthe operation ofthe ships ober than the owner, he owner must repat the fall name and detais of such enty to tbe Adminstration, 3.2 The Company should define and document the responsibility, authority and interrelation ofall personnel who manage, perform and verity work relating to and affecting safety and polution prevention, 33 The Company is responsible for ensoring that adequate rescurees and shore-based support are ‘provided fo canbe the designated person or persons to carry ou thelr function. ISM Code - paragraph 3.1 3.1 Ifthe entity whos responsible or the operation ofthe shipis oer than the owner, the over must ‘pot the fll name and details of sich entity co the Administration. eee ‘The *Company’, 2s defined in 1.1.2 of ISM Code, other than the owner of the ship, is a synonym for the “entity” referred to in 3.1 ‘The Flag Administration is to have full details of the entity(es) other than the awner who have assumed the responsibility for operation of the ship and who on assuming such responsibilty has agreed to take over all the duties and responsibilty imposed by the ISM Code. Examples of objective evidence found at the office may include: - Acopy of letter rom owner to Flag Administration delegating the responsibilty for ‘operational and technical support to the ship manager/operator (0351 Monagament Sle Cerise IM Suey Managemen Cerca 18 Inston and GulncetGUIDANCE FoR AUDITORS oat 35. FOR AUOTTORS 6 5.0¢ 00048GUIDANCE FOR AUDIT TO THE ISM CODE Page 15 of 57 EMMI TOE ISMCODE Page 15 0f 57 Examples of objective evidence found onboard the vessel may include: ~ The details of the ownerfoperator are given in the SMS and agree with the details contained in valid DOGs and SMCs, ~The auditor isto verity that the Company details given in DOC and SMC are identical to the information given in the GSR (Continuous Synopsis Record) ee ISM Code - paragraph 3.2 3.2 The Company should define and document the responsibility, authority and intrtelation ofall Personnel who manage, perform and verity week relating to and affecting safety and pollution prevention SS ‘The Company is to define and document the distribution and interrelation of authority within the SMS. ‘This should include the following: = person(s) or position(s) with the highest authority in developing, implementing and ‘maintaining the SMS; = person(s) or position(s) with the overall operational responsibilty, and authority relevant to safely and protection of the environment; and ~ _ person(s) responsible for safety and protection of the environment on a routine basis. ‘The Company is to define responsibilty in key job descriptions for shore-based and shipboard positions thal have duties related to the SMS. ‘The job descriptions should contain details of the following: ~ position (for instance, second enginaar / superintendent / operations manager / Master, etc.) = name and type of ship: ~ communication ines for reporting including DPA; ~ _ausliication required forthe postion; ~ general responsiiltes relating to safety and protection of the environment; ~ specie duties; = emergency duties; ‘and may include substitution of personnel in case of absence thoreot. The Company is to doling the level of knowledge required for the ship types that the Company is operating. (0191 Manogement System Careatonsts ISM Salty Msnegemert Criicaloni 19 Inston and GultneeiGUIDANCE FoR AUOTTOAS ox tare 000049GUIDANCE FOR AUDIT TO THE ISM CODE Examples of abjective evidence found at the office may include: =the Company has developed organization chart and defined job descriptions defining the responsibilty and authorty of the personnel involved in the SMS; ~ how the Company exercises effective control of the responsibilities ofits subcontractors involved in the SMS; = verification that the subcontractor fully meets the requirements set out in the SMS; ‘Examples of objective evidence found onboard the vessel may include: = _ job descriptions of the personnel onboard involved in the SMS; = shipboard personnel are aware of who bears full responsibility and has authority relating to SMS, and how they relate to the SMS. ISM Code - paragraph 3.3 133 The Company is responsible for ensuring thet adequate resources and shore-based support are provided o enable the designed person or persons to cary out their factions. ‘The designated person(s) may formally require the top management to provide resources, ‘when deemed necessary to carry out their functions. The top management is responsibie for ‘evaluating the proposal and decide accordingly. ‘The Company top management is to state that appropriate resources and shore-based support wil be provided at al imes, and adopt this as its policy. “The Company is to develop procedures for determining the resources needed for maintaining the operational safety of the fleet. “The resources may be defined as personnel, raining, drils, supplying vessels with sutficient spare parts and stores, etc. ‘The Company is to carry out evaluations to ensure thal shore-based support is provided onboard, Examples of objective evidence found al the office may include: = records of internal audis, management review, master’s review, ship's condition and performance reports, etc. - how the Company deals with the requests for resources. ‘Examples of objective evidence found onboard the vessel may include: ~The ship's condition shows that necessary resources were allotted and relevant shore- based support was provided. (0:51 Manegarent Sten Centeion33 1S Setty Management Corifaon9135shucons and GuidanosGUDANCE, POR AUDITORS ext Soe 000050aa GUIDANCE FOR AUDIT TO THE 'SM CODE Page 170187 = records of training and ills ~ _fecords of spare parts and equipment supplied to the vessel ~ Evidence that the Master's requests for shore-based support have been fulilled sc.104(73) 4. DESIGNATED PERSON(S) ‘To ensue te safe operation ofeach ship and to provide a link between he Company and those oa board, ‘every Company, a appropriate, should designate person or persons ashore having eect acess to the highest level of management. The responsibilty and autboityof the designated person or persons shold ‘clude monitoring the safety and pollution presenton aspects ofthe operation of each ship and ioenoute that adequate resources and shore based support are applied, as required. — ISM Code — paragraph 4 Essential to the Designated Person's (DP's) abilly to satisty the requirements of this paragraph is the direct access he or she must have to the highest levels of the Company's management, The auciior must be satisfied not only that such access exisis, but also that the DP is able to use it effectively in ensuring that adequate resources and shore-based support are applied, ‘Tho Code specifies neither the qualifications the OP should have nor the position he should ‘occupy in the Company's organization. Nevertheless, in practice, if the DP is to exercise any influence in the Company's decision-making processes, then he must be given the authority 10 do so and must have the personal and professionel qualities that give him the necessary ‘weight in the competition for scarce resources. Direct access to the Company's senior management may be formally established in organization charts, job descriptions or olher documents in which authorities and responsibilities are defined. Evidence that the access is real and effective may be found in, for example, routine and ad hoc reports, assorted correspondence, minutes of management ‘meetings in which the OP participates, and actions arising. This is especially important given the expectation that the courts will assume (in the evant of an accident and based on the ‘requirement for direct access) that the Gompany’s management knew what the DP knew. In order to be able to monitor the safety and pollution-prevention aspects of the operation of each ship, the DP must have knowledge and experience of shipboard operations, and must be ‘thoroughly acquainted with the Company's system and is documentation. Evidence of {qualiications, experienca and training should be available to demonstrate the DP's competence. Tho monitoring itsel! and the provision of a tink between the ship and the shore-based organization may include activities such as ship visits, the review and analysis of reports of 2231 Managament System Ceriiatenst3 15M Salety Managemen Ceifleaion 159 Instone ard Gusanca\GUIDANCE Fan AUDITORS oct foe 000051e a GUIDANCE FOR AUDIT TO THE ISM CODE Page 180 57 accidents, hazardous occurrences and non-conformances, internal audit reports, inspection reports, the minutes of shipboard safely and management meetings, and reports of drills and exercises. All such information should be appropriately summarized and reported to those responsible for the areas concerned. is commonly believed that the DP must be made responsible for the entire administration of the management system documentation, for the planning and conduct of internal aucits, and ‘must act as the sole conduit forall contacts between the ships’ staff and the organization ashore. This is not the case. ILis better to think of the DP as the person responsible for ensuring that such processos are in place and oparating as required, a role that is more likely to be eflective when separated from the practical implementation. ‘The DP's role is often combined with others such as Technical Superintandent or Operations, Manager, and the auditor should be aware of the possibilty of a heavy workload and other responsibilities having a detrimental effect on the position’s effectiveness. Conflicts of interest may also arise. For example, a DP who should be arguing for expenditure on safety-related items may also be the manager who contvols the corresponding budget ‘The wording of several of the Code's requirements is based on the assumption that, in the ‘companies to which it applies, there will be a separation of roles and responsibilities that is ‘impracticable in single-ship, owner-master operations. In particular, the DP is stated to be a shore-based position, and therefore distinc! from that of the master. {In order properly to assess the management of owner-master companies, the auditor must Understand that such separation will not always be possible. There are two approaches that such companies may adopt to ensure compliance with the Code's requirements: i) Toassign two or more roles to the same person, or ji) To employ outside contractors to full the role of designated person. Whatever solutions the company may choose, the auditor must be concerned with ensuring that operational and adminisraive controls are effective, rather than with trying to identily the organizational structure implied by the wording of the Cade. For example, are effective reviews of the management system carried out, and are its deficiencies identified, analysed and corrected, even though the entire process may be administered by the master? ‘The owner-mastor may act as the DP provided that he can demonstrate that the safety and polution prevention aspects ofthe operation of his ship are being monitored effectively. As the | oer, he isthe highest level of mantagement, he is responsible forthe application of adequate resources, and may ensure adequate shore-based support by, for example, establishing communications and contingency arrangements with agents or other third parties. Where the company has chosen to employ outside contractors, a number of additional factors need to be considered: i) The precise nature of the contractual relationship with the contractor, including any obligations imposed on the company. ji) The bases on which the choice of contractor was made. iil) The suitability of the contractor to undertake the assigned roles. iv) Thetimeliness, frequency, completeness and effectiveness of the communications (0121 Managemen Systm Ceriestiono19 6M Suety Mnagomert CeisenS129Ieruons and Gudanc\GUIDANCE FOR AUDITORS ect 5 000052 po) eeeGUIDANCE FOR AUDIT TO THE ISM CODE Page 19 of 57 between the contractor and the company. The company may not be the only cient of the contractor, and the provision of such services ‘may not be the contractor's only activity. itis, therefore, important to verity that the contractor is dedicating sufficient time and resources to fuliling his commitments to the company, and that the company is able to contact the contractor when necessary |n some cases, he ship wil ba the company’s only “site", and provision will need to be made lot the remote back-up of computer systems and fles, and the retention ashore of copias of important paper decumants. ~ Examples of objective evidence found at the office may include: ~ description of responsibities, authorities and reporting lines ~ interviews to establish awareness of DP's role and identity ~ _videnca of monitoring ofthe safety and pollution prevention aspecis ofthe operation of the ship such as review of audit reports, accidents, hazardous ocourrences and non. conformites, et. Examples of objective evidence found on board the ship may include: ~ inlerviows to estabish awareness of DP's role and identity = contact details ~ reporting requirements DNV: {tthe OP is the Company Safely and environment co-ordinator he may be considered to be ‘aking care of his responsibilies for monitoring the safe operation of ships through his day to day involvement, internal audits included. fhe isnot the safely co-ordinalor he should immediately receive all audit reports and be obligated to keep himselt informed about the results of shipboard audits, (0201 Managemen stem Ceilcaion219 SM Seley Management Coreon123 incon ard Guidance GUIDANCE FOR AUDITORS oct 3a, eee 000053Eo GUIDANCE FOR AUDIT TO THE ISM CODE Page 20 01 57 sc.104(73) 5. MASTER'S RESPONSIBILITY AND AUTHORITY ‘5.1 The Company should clearly define and document the Master's responsibility with regard to: <1 implementing te safety and environmental protection policy ofthe Company; 2 motivating the exew inthe observation of that policy, 3 issuing appropriate orders and instructions in clear and simple manner; A verifying tht specified requirements ae observed and 5 reviewing the SMS and reporting its deficiencies tothe shore based manogement '5.2-The Company should ensure that the SMS operating on board the ship contains 2 clear statement ‘emphasizing the Masters authority. Tae Company should establish in the SMS that the Master as the ‘overiding aubority andthe responsibility to make decisions with respect to safety ad pollution [prevention and to request the Companys asisiance as may be necessary. ISM Code - paragraph 5.1 ‘5.1 The Company should clealy define an document the Master's responsiblity with regard to: ‘The Company, taking inlo account its organisation, type of ships and service, should define ‘and document the responsibilities and mathods expected by the Master to carry out these functions. ‘The Master's responsibilty in a broad sense may be found in any part of the documented system. ISM Code - paragraph 5.1. 5.11 Implementing the safety and environmental protetion policy of the Company: Implementation of the safety and environmental protection policy” on board is under the responsibilty o the Master. Etfective implementation of this could be verified through salsfaciory audit of various depariments on boar. Examples of objective evidence found at office may include: ‘Acoldent, near miss and non-conformity reports for injury / pollution and follow up by company. (0331 Management System Cortcatri19 SM Salely Management Celealona183 nstucsons and Guidance GUIDANCE, FOR AUDITORS ext 5.00eo GUIDANCE FOR AUDIT TO THE ISM CODE Page 21 of 57 ~ Evidence that Safety Committee Meetings, Emergency Drils, training on safety related ‘matters are carried out effectively as per schedule Example Of objective evidence found on board the ship may include: ~ Display of the policy at common places ~ Understanding of the policy by officers and crew during interview ~ Accident and near miss reports for injury / pollution + Evidence of safe working environment and safe practices SS ISM Code - paragraph 5.1.2 5.1.2 motivating the rew in the observation ofthat policy; OO “Motivation of the crew” may be achieved by the Master explaining to them how they can pperscnally benefit from tha implementation of the policy as well as encouraging their perception of ownership. This could be achioved through meetings betweon the Master or a delegated Senior Officer (2.9, at embarkation, during raining or safety dls) and crew members who are requested to Participate in the fulllment of the Company objectives and continuous improvement of the safety management system. Motivation of the crew may be ascertained through interviews. Examples of objective evidence found al office and on board ship may include ~ Evidence that Safely Committee Meetings, Emergency Drils, raining on safety related ‘matters, sreening of safety films carried out effectively as per schedule ~ Evidence that with an aim to promote motivation following are being carried out organising safely debates, lectures, competitions, presentation of safety awards etc. enn ISM Code - paragraph 5.1.3 eS 5.1.3 issuing appropriate orders and instructions ina clear ond simple manner; SS Examples of objective evidence on board ship may include Masters standing orders and bridge night order book. (O83 Mansgemert Systm Coriaton319 ISM Salt Management CaricatonS133 nections and GuanceiGLIDANCE FFOR AUDITORS cet coo nnn a eee 000055GUIDANCE FOR AUDIT TO THE ISM CODE Page 22 of 57 ISM Code - paragraph 5.1.4 5.14 verifying that specified requirements ae observed and see “The Master may delegate verification to Olficers but retains responsibilty to ensure that the methods detined and documented by the Company are used. ‘A checklist could be useful for the Master to verity that specific requirements are observed through actions/actvilies performed by crew members. ‘The auditor may verity how these activities are carried out on board through direct observation ‘and/or by interviewing the crew. Examples af objective evidence on board ship may include: = avarification checklist used by the master ~ veritying during master's audit that various requirements of the Safety Management ‘System are complied with such as deck log book, stability calculations, oll record book, voyage plan, dril records. Sees ISM Code - paragraph 5.1.5 5.1.5 reviewing the SMS and reporting its deficiencies othe shore based management a “The Master, as responsible person onboard, should inform the Company whenever there are deficiencies in the SMS relevant to the ship's operation. Information on SMS deficiencies should include proposals for corrective action and recommendations for improving the SMS, as far as possible. “The auditor should expect that the Company has defined when and how the Master carries out the SMS reviews aboard ship. Examples of objective evidence found at office may include: = Evidence that Master's Review of SMS have bean received from ships al defined interval (not more than a year) ~ Evidence that that findings of the Master's Review received from ships have been studied, analyzed and necessary follow up action taken if necessary. (151 Management Sysem Carteateriat 15M Salty MansgomestCeietioni819 Instuctns srl GuidancelGUIDANCE. FOR AUOHIORS ot S50 000058Ee] GUIDANGE FOR AUDIT TO THE ISM CODE Page 23 of 57 - That all agenda items of the Master's Review have been reported, ~ That the Master’s Review gives a clear picture ofthe status of implementation of SMS. on board and that necessary suggestions/modilications to SMS have been rellected In the review. Examples of objective evidence found on board the ship may include: ~ Evidence that Master's Review of SMS have been forwarded to company office at efined interval (not more than a year). = That all agendia items of the Master's Review have been reported, ~ That the Master's Review gives a clear picture of the status of implementation of SMS on board and that necessary suggestions/modifications to SMS have been reflected in the review. ~ Timely follow up and response by the Company to issues raised in the Master's review DNV: In order to perform a complete review of all aspects of the SMS the Master needs to communicate with officers who are responsible for the management of operations and activities. Minutes from meetings are safely recards and may be used as objective evidence by the auditor. ‘Master's reports should also include proposals for improving the SMS. Reports in which the ‘Master only has signed that the review has been performed, but without any recommendation {for improvement, indicate that the methods, pracedures and guidance provided by the Company do not ensure that the intent ofthis requirement effectively fs met, or hat they aro ‘not used by the Master. Sa ISM Code - paragraph 5.2 ‘52 The Company should ensore th the SMS operating on board the ship contais a clea statement ‘emphasizing the Master's authority. The Company should establish inthe SMS thatthe Measles has the ‘overriding aubority andthe responsibility to make decisions with respect o safely and pollution ‘revention aad io equest the Company's assistance as may be necessary. — ‘The SMS should state the Master's overriding authority and discretion to take whatever action 's considered necessary in the best interest of crew, passengers, the ship and environment, ‘The overriding authority of the Master applies to all circumstances, ‘The auditor should verity that the Company has definitively documented that the Master has an over-riding responsibilty and authority on shipboard operations as prescribed in Resolution 258 Management Sytem Ceriiatons19 ISM Saely Manapemont Cereateni130 Insucton nd Guitance\GUIDANCE FOR AUDITORS oe! Sau, 000057GUIDANCE FOR AUDIT TO THE ISM CODE. Page 24 of 57 ‘A.443(Xi) "Decision of the Shipmaster with regard to Maritime Safely and Marine Environment Protection”. Examples of objective evidence found at office may Include: = Evidence that masters have exercised the "overriding authority" under SMS (if any) Examples of objective evidence found on board the ship may include: = Evidence that master has exercised the “overriding authority’ under SMS (If any). Verity during audit of master that the master of the vessel understands the meaning of “overriding authority” as per SMS and that he has the authority to make decisions with respect to safety and pollution prevention and to request for company assistance if necessary. Interview with Master confirm practical understanding of his overriding authority in matters such as requesting tug assistance, use of Lloyd's open form for salvage assistance, deviation from procedures if the situation so dictate. DNV: Itis a common misperception that the overriding authority of the Master applies to ‘emergencies only. Hence, the statement should make it clear that the overriding authority of the Master is nat limited fo emergency situations. It applies to all circumstances affecting safely and prevention of poltution. Auditors should know that this requirement is the practical implementation into the shipboard ‘SMS of IMO Resolution A.443(X1) "Decision of th Shiomaster with regard to Maritime Safely and Marine Environment Protection’. ee ‘o's Managers System Goifcatot3t9 ISM Safely Menagenen Cereaton\39 nstuctons and GuidsnooGUDANCE Pom AUONES oo ne casaees ae Tanner TE TEETER 00058GUIDANCE FOR AUDIT TO THE ISM CODE Page 25 of 57 NE RAMI TOTHEISMCODE Pago 25 01 57 /sc.10473) 6. RESOURCES AND PERSONNEL 6.1 The Company shoulé ensure that the Master is +1 propery qualified for command; .2 fully conversant withthe Company's SMS; and 3 given the necessary support so hat the Masters daies canbe safely performed. 62 The Company should ensue hat each ships manned with qualified, cenfcaed and medically Ot seafarers in accordance with national and inernational requirements, 63 The Company should establish procedures to ensure that new personnel and personne transfered to ‘ew assignments related to safety and protection of the environment sre piven proper failarzation with ‘their duties. Instructions which are essential be provided port slingshot be identified, ‘ocurmented and given, 6.4 The Company should ensure that all persomel involved i the Company's SMS have an adequate lunderstanding of relevant rules, regulation, codes and guidelines. 6.5 The Compeny should establish and maintain procedures for identifying any traning which may be ‘required in suppor of the SMS and ensure tha uch waiting is provided forall personnel concerned. {66 "The Company should establish procedures by which the ship's personnel receive relevant information ‘on the SMS in& working language or languages understood by ther {617 The Company should ensure thatthe ships personnel ae able to communicate effectively inthe ‘execution of their dues related tothe SMS. a ISM Code - paragraph 6.1.1 6.1.1 properly qualified for commands Ss ‘The Master's quaitication for cammand to be verified by the Company before assignment to a ship may be determined with reference to the following: |) cortiicate of competency, including validity and authenticity, complies with relevant Flag State and STOW requirements; li) previous seagoing experience on the same type of ship; lil) performance reports, including those from previous employers, if available; iv) additional specific company requirements. Examples of objective evidence found at the office may include: (010: Manapomen Stam Certeatori13 ISM Salty Management Cotcsion\0¥9 losectos and Guanes!GUIDANCE FOR AUDITORS ect sane FOR AUDITORS ct. f0g 00058co GUIDANCE FOR AUDIT TO THE ISM CODE Page 26 of 57 Master's Cerificate of Competence copy appropriately endorsed according to STCW requirements Master's CV stating previous experience on the same type of ship — Company's written minimum requirements for the Master's qualification and experience Examples of objective evidence found on board the ship may include: Master's Cerificate of Competence appropriately endorsed according to STCW requirements = Standing orders and night orders, ISM Code - paragraph 6.1.2 6.12 fully conversant with the Companys SMS; and The Company should ensure that the Master is “fully conversant” with all requirements ralating to the Company's safety and environmental protection policies. ‘The auditor should expect the Master to demonstrate familiarly with the SMS during onboard interviews. To assist this purpose, the auditor may find records of participation in regular ‘meetings with the Company's management, aitencance al seminars or training sessions on the SMS. Examples of objoctive evidence found at the office may include: = Master's appraisal records and evidence of their monitoring and evaluation by the Company Records of regular briefings on the SMS in the Company with the Masters = The Master's periodical SMS review for the Company Examples of objective evidence found on board the ship may include: = Knowledge, assessed by means of interviews, of lhe Company's SMS related procedures safety and safety management system meetings as applicable DNV: ‘Most Companies have provided for traning arrangements to ensure that their Masters and ‘Senior officers are famifar with and fully understands the SMS, ret. also 6.5. Veriying that these training arrangemenls are effectively implemented is pat ofthe ISM Code audi. If the Master is not conversant with the Company SMS this should qually forthe issue of a non conformity statement or an “Observation” against this requirement and 6.5. 051 Management Sem Ceriisenata 1S Salty Management Cenestor53 nscsons and GukanceGUIOANCE FOR AUTOR ox 5 oe 000060bac GUIDANCE FOR AUDIT TO THE ISM CODE Page 27 of 57 ES ISM - paragraph 6.1.3 16.1.3 given the necessary support so that the Maser’ duties cn be safely performed. Through the interview process, auditor ensures the Master is given full suppor to full is duties in maintaining the Company's safely and environmental policies. Evidence ofthis, support would be how the Company responds to requests made by the Master. Examples of objective evidence found at the office and on board the ship may include: ~ written review and feedback from the Company of the safety mestings ~ Company timely feedback to the Master's requests for technical suppor, spare parts, imination of deficiencies, additional training of personnel, response to emergencies, etc, ~ deficiencies identitied in Master's handover forms have been taken care of by the ‘Company ———— ISM Code - paragraph 6.2 {62:The Company should ensure that each ship is manned wth qualified, certificated and medically fit ‘seafarers in arccrdance with national and international requirements. ee “Manning requirements” are described in Flag Administration's regulations and may be ‘exceeded as required by the Company The standards for certification and training of specie. shipboard assignments for licensed and unlicensed personnel are described in the S"CW Convention, as amended. The Company has to be familar with such requirements consistent with ship type(s) and operation. “Qualification of personnel” may be ensured by adopting a policy for recruitment (e.g, evaluation of personal CV, information from other Companies, interviews), selection of personnel (2.9. by an appraisal system) and, as far as possible, embarkation of personnel already known by the Company. ‘The Company should have a system in place for selecting personnel, especialy i obtained ‘through @ manning agent. A procedure may then be expecied to detail how the selection brocess is carried out to comply with the STCW Convention, as amended. ‘When recruitment or manning Is obtained through a manning agent, the Company should ‘adopt a procedure for checking that its policy is followed by the agent. A procedure may be expected providing details on how the recruilment and selection process is carried oul, (0891 Management Sytem Catzacra 19 ISM Seley Management Cacao rsiucion and GuldanciGUIDANGE FOR AUOTORS ax Ose ceereneee ee eee 000061jon GUIDANCE FOR AUDIT TO THE ISM CODE Page 28 of S7 “Medical fitness”, as required in the amended STCW Convention, should include that a reasonable policy éxists and it has been implemented. Evidence of such a policy includes certificates or endorsemenis in seaman books and that crew members have undergone ‘medical examination within the intervals established by the Flag Administration. ‘Some companies have their own medical department providing pre-employment and existing ‘employees medical examinations, Such 2 policy, while beneficial, does not always detect ‘medical problems which can exist when a crew member joins the ship. ‘Some Companies have established a formal drug and alcohol policy and process of screening, ‘crow. Such policy is a method by which a Company may help ensure that ship personnel remain medically fit or duty on a day to day basis. Should this exist, the auditor may include ‘hese activities in the auctt Examples of objective evidence found at the office may include: = written recruiting procedures and minimum requirements for the Oficers' qualification =the Officers’ CVs satlslying such minimum requirements ~ the Company's established and documented procedures for monitoring expiring Certilicates, when applicable Examples of objective evidence found on board the ship may include: = the vessels are manned accordingly to the minimum safe manning required by the flag ~ the watchkeeping Otficers’ Certificates of Competence appropriately endorsed by the flag as applicable = valid certificates according to spacilic ship types as required by STCW convention - valid mecical fitness cerifcates and medical examination reports as required ISM Code - paragraph 6.3 63 The Compony should establish procedares to ensure tbat neve personne] and persone transfered © new assignments elated to safety and protection ofthe environment are given prope Fmiiarizalion with theie duties Instructions which ae essential lobe provided prior ossiling shouldbe denied, documented and given. eee “The Company shall provide, in accordance with STCW, written instructions to the Master of each ship to which the Convention apples, setting forth the policies and procedures to be followed to ensure that al seafarers who are newly employed onboard are given a reasonable ‘opportunity to become famifar wih the shipboard equipment, operating procedures and other arrangements needed for the proper performance oftheir dulfes, before being assigned to those duties. "New assignments” related to ship personnel may include another ship, a different job or promotion. ‘0451 stanogement Sytem Cenoaserst' IS Seely Management CeiicaorAS133nstuctons and Guidance GUDANCE Fon AUDITOn@ ox Gs.GUIDANCE FOR AUDIT TO THE ISM CODE Page 29 of 57 Essential Instructions" are thase that clearly define the crew members role within the ship's organisation and ensure that they are prepared prior to taking up their duties on board. These instructions may include crew member's responsibilly, aulhority and interrolationships with thers involved in the SMS. “Instructions prior to sailing” may include lifeboat station and responsbblles, fie station ‘esponsibilties and making available specitic additional reference material associated with safety requirements from the SOLAS training manval. “Famillarisation” is the process that allows a person embarking forthe fist time on a ship or transferred to new assignments to become familiar with that ship, its machinery, systems, equipment and operations. Famiarisation may be accomplished for instance by: ) embarking as supernumerary, il) receiving essential information in a language the seafarer understands, ii) shore side seminars sponsored by industry or Company, iv) ebserving onboard overlap while vessel in port, v) visual alds such as videos, manuals and.operal ‘The choice and level of detall to assist familiarization will depend on individual experience and ihe job responsibilies. Should individuals require essential familiarization with an assignment prior to sailing, then the Company should identify such requirements and develop an appropriate plan. Examples may be familiarization with the equipment on the bridge or in the engine room, ‘A system of familiarization should also be applied to new or transferred shore staff where their esponsibiliies include safety and pollution prevention. This could include superintendents who are not familiar with a type of vessel being operated by the Company. Examples of objective evidence found at the office may include: = a documented training program for crew members = records of seminars and training courses = evidence of evaluation by the Company of appraisal Examples of objective evidence found on board the ship may include: ~ evidence, obtained by means of interviews and observation of behavior, when possible, that crewmembers have appropriate knowiedge of SMS onboard procedures (ex Working permits, bunkering checklists, etc) ~ correct performance of diils as required by SOLAS regulations, the SMS manual, the SOPEP Plan, etc. ~ familiarization checklists duly signed by trainer and trainee eer re nsnsnraeene er nETETEnEEE (8 Management Sistem Cone 19 FM Slay Norogemen Cosenlon212lntnetons nd GuldanceiGLMDANCE FOR AUDITORS oct 00 RAT ee a eee 00063GUIDANGE FOR AUDIT TO THE ISM CODE Page 30 of 57 ISM Code - paragraph 6.4 64°The Company should ensre tha: al persone] involved he Companys SMS have an adequate ‘derstanding of eevant ues, regulation, codes and guidelines, [ae Dn na ‘The Company should have a plan on how to provide all personnel involved in safety and pollution prevention with information on mandatory requirements of the relevant ‘Administration(s) and applicable codes and guideiines. Such information may be communicated by: i) written instructions, )) description a jab responsi, ii) formal ciscussions wih Company representatives. Examples of objective evidence found a the office may include: ~ company brary completa, controled and updated = contol and updating procedure for the company forary Examples of objective evidence found on board the ship may incude: shipboard brary complete, conolled and updated = contol and updating procedure forthe shipboard brary = crewmember's knowledge, assessed by means of interviews, of rues, regulations, codes and guidelines ISM Code - paragraph 6.5, 65 The Company should establish and muatain procedures fr ideaifying any training which may be ‘equtedia suppor ofthe SMS and ensure that such waning is provided forall personnel concerned eee ‘The Compsny should identify the individual(s), ashore and onboard, having responsiblity to define training needs appropriate for specific tasks, Laking into account factors such i) previous raining and experience, 21 Managenent Stam Corinna IM Salty Manapemant Coit nso nd GulsnceSSUDANCE on nubrTonS ot bso eo e 90 TAGS Roc.4t, Rev, ooo064un GUIDANCE FOR AUDIT TO THE ISM CODE Page St of 67 ii) required proticiency in operation of equipment, iil) famiiary with new equipment, 'v) familiarity with equipment when transferred to diferent typo vessel, ¥) dis for emergencies, vi) results of internal aueitng, Training may be supplemented by using visual aids, such as videos, manuals and operating instructions, or direct supervision by a superior. Examples of objective evidence found at the office may include: ~ Company and shipboard training plan ~ Flecords of shore-side drills and training Examples of objective evidence found on board the ship may include: ~ records of drils and training = internal audit repons ee ISM Code - paragraph 6.6 {66 The Company should establish procedures by which te ship's personact receive relevant information ‘on the SMS ina working language or lnguages understood by them. — ‘The Company should establish the working language(s) onboard and the requested level of knowledge of foreign languages for the crew members, The details and the amount of documentation should be determined by what is necassary to ensure all appropriate shipboard personnel can understand their respective roles, { absence of documentation translated into the working language of the crew members, the auditor would expect to find objective evidence that proper familarisation with the safely ‘management system, as far as applicable, had taken place. Records of respective training sessions should be maintained. Examples of objective evidence found at the office may include: ~ internal audit reports, technical reports, circulars, etc. Examples of objective evidence found on board the ship may include: ~ _ standing orders, night orders, work orders, emergency stations, etc. {2851 Manegeren Systm Corsicana SM Salty Manegemert Gefen nso FOR AUDITORS oct O5ne GuidarceGUIDANCE 0006sis} GUIDANCE FOR AUDIT TO THE ISM CODE Page 32 of 57 DNV: Objective evidence on the non-fulfilment of this requirement may also indicate that there are reasons to question 5.1.1 ISM Code - paragraph 6.7 {62 The Company should ensore that the ship's personnel are abe to communicate effectively in the ‘execution oftheir dutes related tothe SMS. nea Sufficient instructions in a suitable language need to be verified, as well as ensuring an understanding of them by the crew. This could be verified by witnessing an exercise. Verification that the ship's personnel are able to communicate may be accomplished by verifying the execution of orders given by Officers as requested by the auditor. “The auditor should verly f procedures exist that ensure effective communication on board. Documented evidence must be available, e.g. from manning agencies at the recruitment stage ‘and during crew appraisals. Those responsible for the care ol passengers during shipboar ‘emergencies should be able to communicate with them effectively. Examples of objective evidence found at the office may include: = what is the established working language of SMS = Company's minimum requirements in relation to language knowledge of crew members = Sample of crew list Examples of objective evidence found on board the ship may includ = capability, assessed by means of observation of behavior, of crewmembers 10 Understand each other during simulation of emergencies and during shipboard procedures — crowmembsrs understanding, assassed by means of Interviews, of amergency and operative signs onboard and safely guidelines. Msc.104¢73) 7. DEVELOPMENT OF PLANS FOR SHIPBOARD OPERATIONS “The Company shoul establish procedures fo the preparation of plans and insirctions, inching checklists a appropriate, for key shipboard operations concerning the ssetyof the ship andthe prevention of poluon. The Yarous tasks involved shook be defined and assigned to qualified personel (0381 Maropemert System Caeforia19 ISM Seley Manageme Crete Fon AUDITORS ex Gaze “FOR AUOTTORS oc do OO 0006s neucons ae Guidance GUIDANCE eoGUIDANCE FOR AUDIT TO THE ISM CODE Page 33 of 57 —_a_ OPE age 33 01 57 ‘Key shipboard operations” in the safety and pollution prevention context mean: |) all those operations for which mandatory rules and regulations prescribe performance requirements or specific requirements for plans, procedures, Instructions, records and checklists; those connected to the particular ship's typa and which may atfect safely and Pollution prevention, o the extent established by the Company; |i) those for which safe practices in ship operations and a safe working environment (tes, 1.2.1) have been recommended by the IMO, Administrations, classification Societies and other industry bodies (raf. 1,2.3.2) ') those which the Gompany considers may create hazardous sitvations if not ‘controlled by plans and instructions, ‘The ISM Code does not specity any particular approach to establish plans, instructions and checklists and itis for the company to choose methods appropriate to its organizational structure, its ships and its trades. ‘The methods may be more or less formal, but they must be systematic if assessment and response are to be complete and effective. Methods of Company identilication of key shipboard operations may include the follow ') Company experience on those operations which may create hazardous situations if ‘not controlled by plans and instructions; il) feedback provided from the SMS elements such as the Master's review of the SMS (tel. 5.1.5), internal audits, reports and analysis of non-conformities, accidents and hazardous occurrences; |i) formalized systematic methods which the Company may decide to use as a tool for hazard identtication. Furthor details on risk assessment methodology is given in IAGS'*A GUIDE TO RISK ASSESSMENT IN SHIP OPERATIONS” 'Non-confarmities should not be raised against the adequacy, but on the implementation of ‘such methods decided by the Company to identity key shipboard operations. “Plans and instructions” include plans, procedures, instructions and checklists which aro ‘meant to govern or support shipboard activites related to the safety of the ship and the prevention of pollution. These should also deal with naw ship types when relevent, Examples are those routine activities which it not correctly handled could lead to hazardous | situations, @.9. watch keeping, loading, discharging, gas frecing, tank cleening, sang (confined waters), passage planning, pollution prevention, etc “Procedures for the preparation of plans and instructions” should have safely and pollution prevention as a primary objective and should include, inter alia, measures to prevent ‘dentified risks as referenced in 1.2.2.2 and 1.42 of the ISM Code. mandatory rules and regulations and applicable codes, guidelines and standards for the type(s) of ship covered by the SMS. This information should be kept updated by the Company The development of procedures shou tek nto account evant irterational and ntonel | | 10 take into account its operational experience. } | St Aenaogrert System Cortfoahong1 6M Salty ManapamestCerifleston 3123 Ierusions and Guldansh GUIDANCE, FOR AUOTTORS oct Sado, 00067oe GUIDANCE FOR AUDIT TO THE ISM CODE. Page 34 of 57 ‘The development process shall ensure that ship and trade specific issues are adequately dealt with. It having the same shipboard procedures for multiple ship types, care must be taken to clearly identiy the procedures that are relevant for each ship. ‘The Company should be involved to confirm that the list is consistent with the Company's particular operational experience and procedures. Non-conformities may be raised against the adequacy of methods decided by the Company to identily key shipboard operations and when thera is evidence that such plans, procedures and instructions are inadequate. “The approval of the performance of operations for which plans, procedures and instructions are required by mandatory rules and regulations, such as damage control plans, are dealt with separately and independently of ISM Code audits. “Qualified personnel” means those who are qualified o identity key shipboard operations, and cary out actions requested by plans, procedures and instructions. ‘When developing plans and instructions for key shipboard operations, the foous is on prevention, which requires the use of personnel who have adequate technical andlor ‘operational knowledge relevant to the Company's operations. “The auctor should not prescribe particular requirements for qualified Company personnel 10 perform the review process. Identification of tasks assigned to appropriately qualified personnel fs an important consideration. Chacklists may be used to facilitate the process. The auditor shoud expect the ‘Company to have identified risks associated with a particular type of vessel and trade. Such identification should be documented in some form. Identified risks may simply be indicated in tables of contents. Examples of objective evidence found at the Orfice may include: = Documented procedures for the preparation of plans and instructions for key shipboard operations concerning the safety of the ship and the prevention of pollution ~ Documented evidence of the decision making process and outcome thereof “The effectiveness of the process should be evaluated based on the following evidence: |) evidence that a systematic review of mandatory rules and regulations applicable to ‘each ship type included in the DOC is carried out by the Company (ref, 1.2.9.1 and 8.4) for the purpose of identilication of the plans, procedures and instructions that are required by mandatory rules and regulations for the type(s) of ships operated by the Company. This evidence may include the existence of an appropriate library of applicable rules and regulations; ji) evidence of a systematic review of recommendations given in form of codes, ‘uidelines and standards by the IMO, Administrations, classification societies or bther industry bodies, which the Company has decided that are applicable to their operation. This evidence may include vertication that - there is alist of these references, (0831 nrageren Stem Catenion 13 ISM Salty Management Colcalor4810 ncrueon and GuisenesiGUIDANCE, Fon AUDITORS et 5 90 assesses ceaRSEEAT EOS OnE Te ooo068GUIDANCE FOR AUDIT TO THE ISM CODE Page 35; ~ these recommendations are made available for those responsible for developing the plans and instructions for key operations; {esting the completeness of the review by choosing a random sample of the operations for which thera are requirements for plans, procedures or instructions in mandatory rules and regulations; ii) verifying that the Company has established their own qualication requirements for {hose who are to be responsible for the development of plans, procedures and instructions for key operations; and 'v) that this has been used as a basis for a systematic identification ofthe plans, procedures and instructions that are required by mandatory rules and regulations for the type(s) of ships operated by the Company; The shipboard audit should include: ¥)__verfeation that key operations are under contol by random sampling of those operations. This would involve the need to witness operations an conf thet tho operation is conducted in accordance with procedures and instructions and will include discussion with crew members on their specific responsibities associated withthe key operation. The random sampling would depend on the typeof ship, fhe ship operator, time available and availabilty of ship's personnel i) verification that an appropriate library of applicable rules and regulations, Guidelines, codes and standards exists, MSC.104(73) 8 EMERGENCY PREPAREDNESS 81 ‘The Company should establish procedures toideniy, describe and respond to potential emergency shipboard sitions. 82The Company should establish programmes fr dil and exercises o prepare for emergency actions. 83 The safety management sytem should provide for measures ensuring thatthe Company's organization can respond at any Gime to hazards, accidents and ensrgeny situaions nv ing is ships, O53! Mansganent Stam Coriaiera%2 16M Solely ManagarentCafeaion319 scons and GulanesiGUIDANCE FOR AUDITORS oe! Bedoe 000069GUIDANCE FOR AUDIT TO THE ISM CODE Page 26 of 67 ISM Code — paragraph 8.1 8.1 The Company should establish procedures to deny, describe ad respond to potetal emergency shipboard situations a —— Usually the following scenarlos should be addressed by emergency plans as required by the specific ship types: = structural fale / heavy weather damage = allure of main propulsion - steering gear faire = electrical power failure = collision = grounding / stranding = shifting of cargo = cargo / ol spillage /jttison * = flooding = fire / explosion = abandoning ship = man over board = search and rescue operations = serious injury = piracy / terrorism * = helicopter rescue operations * Remark: reterences should be made to other separate emergency plans like SOPEP, SMPEP, SSP. Depending on vessel's type and trade, some of emergency scenarios may be omitted (e.g shifting of cargo on passenger vessels, piracy in ceriain trades). However, the list is not ‘exhaustive and the Company shall identify all possible situations where shipboard contingency planning would be required relative to the ship's type, equipment and trade. Examples of abjective evidence found at the Office may include: (0431 Management System Cetcaion12 ISM Sally Management Carian istusions end GudaesiGUIDANCE For AUOTORS oat aoe aan easane eeu ESE 000070 eeGUIDANCE FOR AUDIT TO THE ISM CODE Page 37| + records of drills = records of training ashore + emergency response plans Examples of objective evidence found onboard the ship may include: + SOPEP manuals = records of drills + emergency response plans DNV: Possible examples of emergency shipboard situations may include: - "Shore terminal related’, @.9. overloading, fre, explosion; ~ "Ship related”, e.g. heavy weather damage, colision, grounding, fire, explosion, cargo shitting, pollution involving cargo or bunkers, flooding; ~ "Personnel related”, ©.9. abandon ship, man overboard, serious injury, enclosed Space rescue, terrorism, pracy. International Conventions contains requirements for emergency plans. There are also ‘adcitional national requirements. Some governments have made their requirements applicable {0 foreign flag ships, as a condition for calling at their parts. ‘Most of these plans are subject to approval by the (Hag State) Administration or by the ‘maritime administration of the country which imposes its national requirements on loreign flag ships. In such cases assessing the adequacy of emergency/contingency plans falls outslds the ‘scope of the auucit, The auditor shal, however, verily that the planned arrangements are implemented, onboard {and ashore when relevant. This has mainly tobe based on interviewing personnel to verily, {thelr familarty with the planned arrangements to the extent they wil be involved when the plan is activated. Consistent tack of familiarity may bear evidence to inadequate arrangements for the ‘implementation (familarisation withthe plans and arrangemenis) and may be subject to the fasue of a nan-canformiy to this end. Isolated examples should be subject tothe issue of an observation. Governments may requie that Company procedures for identifeation of emergency situations include the use of formal methodologies to bo used for the idenification of hasards, Companies may also choose to do this voluntary. Auditors may not require formal hazard ‘dontiication methods except when this is mandated by flag State or Gaast Stato in which waters the ship is to trade. Assessment ofthe adequacy of formal hazard analyses is beyond the scope of ISM Code Audis. Se (9251 Management Star Certiateia19 ISM Safely ManagorentCeticeoG1S3 nshuesons and GeldancelGUIDANGE FOR AUDITORS ect Saab TS ee ee eee 00071fe fu GUIDANCE FOR AUDIT TO THE ISM CODE Page 28 of 57 ISM Code — paragraph 8.2 8.2The Company should establish proprammes for ills and exercises to prepare fr emergency actions. SSS For all emergency scenarios identilied by the Company (see 8.1) a dill schedule should be prescribed by the Company; for this drill schedule no certain format is required, however, following information should be provided: = Frequency of the particular drills. = Extend of the particular drills (e.g. table top dri only, or practical dill followed by de- briefing and watching of a certain safety video). - The Company might lay down whe on board is responsible for the detailed planning of a drill scenario, Furthermore it appears to be prudent thal a Company wil instruct the vessels to perform practical drils under conditions with reduced personnel due to simulated casualties, Le, back up / deputy stalf should be involved in leadership and all tasks of a certain dell = Inadditon it may be baneticial for audit purposes to witness a shipboard safety dri or other practical cemonstration (e.g. starting of fe boat engine, donning of fire suit, frst measures in case of detecting a cabin fre, etc). Examples of abjective evidence found at the Office may include: = dill schedule for ships, shore-side and joint exercises = records of drills and training = analysis or evaluation of drils and exercises Examples of abjective evidence found onboard the ship may include: = dill schedule for ships, shore-side and joint exercises ~ records of drills and training = analysis or evaluation of drills and exercises DNV: Log books will normally contain sufficient objective evidence of drills being performed as required. The effectiveness of drills may be assessed through interviews of personnel testing their familiarity with their duties in his respect and that they have gained the knowledge needed for, safe and efficient performance of their duties. (0131 Menzgemert System Cetin 12M Gala Menagsmart Cofesiont319 nsitons anc GubtinctGUNDANCE FoR AUOHTORS oat Jaze FOR AUDITORS ot 05:00 000072[on] GUIDANCE FOR AUDIT TO THE ISM CODE Page 39 of 57 The company may decide to include drils in addition to the ones stated in mandatory rules and regulations. Auditors should verily that these are effectively implemented. Lack of or in. effective implementation of such Company requirements shall nat lead to noncantormites. ISM Code ~ paragraph 8.3 8.3 The safety management system should provide for mensures ensuring that the Compeny's ‘erganization can respond at anytime to hazards, accidents and emergency situations invelving is ships. ee 'tis important that Company shore and shipboard contingency planning is consistent and appropriately integrated, ‘Shore based emergency plans should include: ~ Procedures for the mobilisation of an appropriate Company emergency response team {incl. back up arrangements in the event of a prolonged emergency) ~The composition and duties of the persons acting within the contingency plan - Procedures / checklists, etc. appropriate to the type of emergency which may assist in the = _ systematic questioning of the ship during the response- The availabilty of vessel's, contact ~ numbers, ship particulars, plans, stability and cargo information, and salety and = environmental protection equipment carried on board ~ Details and contact numbers of ail relevant parties including subcontractors, ‘administrations, port slates, Class emergency services, etc. who may need to be notified and consulted ~ Procedures for notifying and faising with the next of kn of shipboard personnel ~ Procedures for issuing information bulletins to and answering queries from the media might also be included, Examples of objective evidence found at the Olfice may include: = emergency response plans ~ contact points forall relevant parties (ERT, owners, charterers, insurance, ete.) -24 hr contact number between the ship and the Company back-up arrangement 38 Munagarent System Cariestori19 ISM Seely Management Cacao 19 aston end Guidane\GUOANCE FOR AUDITORS oo ne Or eee eee 000073e GUIDANCE FOR AUDIT TO THE ISM CODE Page 40 of 57 ~ specific drawings for ship types Examples of objective evidence found onboard the ship may include: = emergency response plans = contact points forall relevant parties (ERT, owners, chart contact number between the ship and the Company , insurance, ete.) - 24 hr = specitic drawings for ship type = status and location of emergency equipment and oll spill response gear sc.104(73) 9. REPORTS AND ANALYSIS OF NON-CONFORMITIES, ACCIDENTS AND ‘HAZARDOUS OCCURRENCES 9.1 The SMS should include procedures ensuring tat non-confrmiies, accidents and hazardous Situation ae reported to the Company, investigated and analysed with the jective of improving safely tnd polladon prevention 9.2The Company shoud establish procedures forthe implementation of comective action. Se ISM Code - paragraph 9.1 9.1 The SMS should include procedures ensuring that non-coaformies, accidents and hazardous situations ae reported tothe Company, investigated and analysed wit the objective of improving safety ‘and pollation prevention. eee Records of non-conformities, accidents, hazardous situations and relevant investigations produced by shipboard personnel and/or by the Company from operations or internal ausits, Should be provided to the auditor during aualts to demonstrate effective functioning of the SMS, Non-conformity means an observed situation where objective evidence indicates the non- {ullilment of a specified requirement. Non-conformities may be identified as result of such activities as internal and external audits, lass surveys, flag or port state inspections. The NCS may include nor-tulfilment of technical as wall as operational requirements. ‘Accidents are events that lead to unintended harm or damage such as deaths or injuries, pollution or property damage. Hazardous situations include near misses/near accidents and are often defined events that under slightly different circumstances may lead to an accident, ‘0401 Management System Cecaona9 SM Sate Management Crieao19129irstsons and GidancGUIDANCE FoR AUDITORS oct Oso (FOR AUDITORS oc 05.55 000074a GUIDANGE FOR AUDIT TO THE ISM CODE Page 41 of S7 ‘The auditor should be aware that terminology in reporting such events vary from company to ‘company. The auditor would also expect to see the effective implementation of a dacumented procedure dealing with the reviow and analysis of the events stated above. Analyses should aim to determine basic causes, not only symptoms. This should include the objective for improvement, Corrective action shovid include both the “repair to deal with the immeciate situation as well ‘4S measures taken to prevent or reduce likelihood of recurrence. DN In this context, conditions of class (CC) and conditions of authorities (CA) are to be considered {as non-confarmities and subject to investigation and analysis as required by 9.1. (This folows ‘rom what the Code, 1.2.3 state to be the objective of the SMS} Reports from investigations of accidents and near misses should place emphasis on the description of the conditions and circumstances at the time of the event, in order to allow for the best possible analysis, Analyses should determine basic causes, not symptoms. Auditors should have sufficient knowledge to support Companies in establishing practices that Contribute to SMS improvements. The auditor should examine reports of non-confornities, and from investigation of accidents and near misses and the records trom analyses performed to determine thoir causes. Complete lack of Fleports and records indicate beyond reasonable doubt that tne Company has not succeeded in thelr implementation of this requirement. There are stil perceptions within the industry that incident reporting may expose a Company to liabillies. These attitudes can only be conquered if the Companies understand the ideas behind these requirements and the benefits that may be achieved by its effective implementation. This is why inadequate fullment of these requirements today should not be the basis for the issue of a major non-conformity and why Auditors should lim? their statements to noncontormitios or observations. —_—_ ISM Code - paragraph 9.2 9.2 The Company should establish procedures forthe implementation of corrective seton, a ‘The Company should have procedures for carrying out the corrective actions suggested by analysis relevant to non-conformities, accidents and hazardous situations identiied from internal audits and during operations. Auditors should focus on the effectiveness of the procedure(s) for implementing corrective actions. Failure to comply with these issues in a timely manner shouid qualiy for a nore SR Mseenert Sytem Cerficaons12 ISM Solely Manepement Cerio 139 Instuctons and GudaneGUIDANCE FOR AUDCORS oct dScn0 ate ee eee 000758) an GUIDANCE FOR AUDIT TO THE ISM CODE Page 42.01 57 conformity. Consistent, grave inability to comply in time should result in the issue of a major ‘non-contormity. Examples of objective evidence found at the Oifice and onboard the ship may include: = Personnel aware of procedure procedures ensuring that non-conformities, accidents ‘and hazardous situalions are reported, investigated, analyzed and followed up Records of non-conformites, accidents and hazardous situations reported (check against documents such as class, tlag and port state reports, medical logs and interviews) = Records of accident investigation and analysis ~ Evidence of corrective action including actions to prevent recurrence - Evidence of effective and timely implementation of corrective action ‘MSC.10473) 10, MAINTENANCE OF THE SHIP AND EQUIPMENT 10.1‘The Company should establish procedures to ensure thatthe ship maintained in conformity with the provision of he relevant oles ad regulations and wilh any addtional requirements whieh may be established by the Company. 10.2 In meeting these requirements the Company should ensure that 1 inspections ae eld at appropriate intervals, 2 any non-conformity i reported wit is possible use, known; 3 appropriate corrective action is taken; and At reerds ofthese activities are maintained. 1003 The Company should establish procedures in SMS to ideatly equipment and technical systems the ‘uulden operational feiuce of which may result in hazardous sinatiors. The SMS should provide for Specific measure simed at promoting the reliability of sich equipment or sytem. These meastres should ‘nclude tho regula testing of stand-by arangemens and equipment or technical systems ha are notin continuous use. 10.4 The inspections mentioned in 102 as well asthe measures referred (010.3 should be integrated in the ships operational maintenance routine. ‘O46! Management System Ceifcaoria13 IM Salty Manegament CerseatoiS189 skucons and Guidanes GUIDANCE POR AUDITORS ox Osdoe {FOR AUDITORS oe 5 000076GUIDANCE FOR AUDIT TO THE ISM CODE Pago 43 of 57 ISM Code - paragraph 10.1 10.1 The Company should establish procedures to ensue thatthe ships malosind in conformity with the provisions ofthe relevant rales and regulations and with any adilonal requirements which my be csablished by the Company. The maintenance of the ship and equipment should be in acoordance with the procedures eslablished by the Company. These procedures should take into account international conventions, Flag and Port State regulations, classification rules, requirements from ‘manufacturers, feedback information fram failures, damages, defects and malfunctions. There are a number of acceptable systems associated with maintenance of equipment. The choice depends on ship design and Company philosophy. The auditor should expect lo find ‘maintenance process documentation and records indicating compliance with maintenance Program requirements. Objective evidence is necessary to confirm conformance with established maintenance requirements Examples of objective evidence found at the Oifice and onboard the ship may include: ~ documented procedures and instructions for the onboard work routine; verilication oftheir implementation in the day-to-day operation ofthe ship by tho appropriate personnel, ee ISM Code - paragraph 10.2.1 10:2 In meeting these requirements the Company should ensure tha 1 inspections are held at appropriate intervals; PY eee ‘The Company should define the appropriate intervals and may be expected to justly their selection, ‘As part of shipboard responsibites, there should be formal routine inspections of machinery, systems, equipment and structural integrity of the ship. Examples of objective evidence found at the Oifice may include: ~ shipboard inspection reports from ship stalfs and/or company superintendents at intervals as required by the maintenance plan; (381 Managment Stan Corifaten913 1S Salely Manegament Confson82 Insets and OidarciGUIDANGE FOR AUDITORS act 5 da0 000077GUIDANGE FOR AUDIT TO THE ISM CODE Page 440157 definition of inspection criteria such as manufacturer's recommendations; and = mor ring of maintenance status. Examples of objective evidence found onboard the ship may include: = shipboard inspection reports; condition of ship; and = results from other surveys and inspections. DNV: ‘The inspections should cover all tems subject to class and statutory surveys (and additional Company requirements). Inspections may be part of the maintenance procedures, or operational procedures/instructionsiroutines, or taken care of by dedicated inspection ‘ystems, some of which even have specific class or statutory requirements, e.g. safely ‘equipment weekly/monthly inspections. Inspections may also be performed by Company personnel visting the ship. oo ISM Code - paragraph 10.2.2 Ty ncenecy opin por @ a “This section of the Code refers to damage, defects, malfunctioning, deficiencies conceming ship and equipment, etc... Therefore, the term "non-conformity” in this context refers to @ {echnical defect and/or ineffectiveness of maintenance system, not the definition of non~ conformity against the ISM Code used in the audit process. Shipboard personnel, as part ofthe day-to-day operation of the ship, should have procedures which ensure that detects are reported promplly and rectified within a specified period of time. ‘Asystem should be in place to notify appropriate personnel both ashore and on board of defects and appropriate correcive actions. Examples of objective evidence found at the Office may include: receipt of defect reports (damage, Inspection reports, ete. rom the ship = analysis of defect and identification of causes; ~ root cause analysis, i necessary Examples of objective evidence found onboard the ship may include: ‘1 Morapament ysem Cotes ISM Saey Marapement Crear nstcion and @Jéance]GUDANCE Pom AubrOns este vey ors 000078GUIDANCE FOR AUDIT TO THE ISM CODE Page 45 of 57 =O ISM GODE age 45 of 57 + reporting of defects; ~ analysis of defect and identification of causes; ~ root cause analysis ISM Code - paragraph 10. 3 10:23 any non-conformity is reported with its possible cause, if known; and SS ‘The Company should have documented procedures for corrective action of defects which cannot be promptly corrected by the shipboard personnel. Corrective action should involve solutions which may reduce or prevent re-ocourtence of detects. Detects which, for any reason, cannot be promplly dealt with by the ship personnel (@.9. due to lack of resources or material) or whos repair may be posiponed (e9. tothe next dry dock or Jong stay) and which do not afect the ship's safety and enwironmenial protection, should be e {included in a continuously updated list, to be available onboard and ashore. ‘The SMS should include instructions when ship's personnel are unable to correct a defect affecting the ship's safety or protaction of the environment with available resources and ‘material, in ordor to inform the appropriate person in the Company of the nature of the problem, whenever possible with proposals for corrective and preventive resolution, Examples of objective evidence found at the Oifice may include: + list of maintenanes and repair carried out onboard; ~ control, monitoring and supply of spare parts; = evidence of preventive actions taken; evidence of timely follow-up and effectiveness of corrective action: Examples of objective evidence found onboard the ship may include: ~ list of maintenance and repair carried out onboard; ~ control, monitoring and receipt of spare parts; = evidence of preventive actions taken; ~ evidence of timely follow-up and effectiveness of corrective action {2531 Manaorort System Cermestion:19 ISM Sas Manapamet Covextoni59 Inston and GidarceGUNOANCE Fon AUDTTORS et Ooo 000079GUIDANCE FOR AUDIT TO THE ISM CODE Page 46 of 57 DNV: Appropriate corective action inthis context includes both the immediate rectification of non- ‘conformities and corrective actions related to the SMS (rel. 9, 5.1.5, 12.2 and 1.4.6) in order to prevent re-ocourrence. ‘Appropriate corrective action also includes the responsibilities ofthe Company for reporting ‘damages to the classification sociely as stated in the Rules. Auditors should verily that the ‘Master and senior officers are aware of their responsibilites in this respect. Inadequate fulliment of this cequirement, particular as to rectification of non-conformities revealed through inspections may inocate that the superintendenlCompany does not pffectively respond to requests from the ship, the effectiveness of the Designated Person in ensuring that adequate resources and shore based support are applied or that there are other management systems flaws or non-conformities, which are the basic cause for inadequate compliance. a ISM Code - paragraph 10.2.4 10:24 records ofthese sesvities are man poe Records of inspections, maintenance, damages, defects and relevant corrective actions should be kept as objective evidence of the effective functioning of the SMS. The records may be ‘maintained in electronic format Examples of objective evidence found at the Olfice and onboard the ship may include: - evidence of all records addressed above. es ISM Code - paragraph 10.3 | 10.3 The Company should establish procedores in SMS to identify equipment and technical systems the iden operational failare of which may result in azardous situations. The SMS should provide for | “Specie measures aimed at promoting the reliability of such equipment or system. These measures should | include the regular testing of stand-by strangements and equipment or echnical systems that are not in continuous use. (Ost Management Stam Cerin ISM Seley Manigarert Cefn 189 Intuctons and GléanceSUDANCE FOR AUDTIORS oc oe 000080GUIDANCE FOR AUDIT TO THE ISM CODE Page 47 of 57 The testing and maintenance of stand-by equipment and infrequently used systems should be part of the company maintenance procedures. Once identilied, appropriate tesis and other Procedures should be developed to ensure reiabiity Examples of such equipment and systems may be: ) alarms and emergency shutdowns, 1) fuel oil system integrity, ii) cargo system integrity, iy) emergency equipment (EPIRB, portable VHF, ete), ¥) safety equipment (portable gas and CO2 detectors, etc.), vi) _pre-arrival and pre-departure tests (of emergency steering gear, generators, ‘emergency fie pumps, telegraphs, elc.) Examples of objective evidence found at the Office may include: + evidence of identification of such equipment; ~ records of inspection and testing; Examples of objective evidence found onboard the ship may include: ~ records of inspection and testing: ~ evidencs of ably to test, operate and maintain such equipment to promote their reliabilty; + condition of relevant equipment; ee ree eee eerseeeeesee ere eter mE ISM Code - paragraph 10.4 104 The inspections mentioned in 10:2 aswell as the measoes refered 0 103 should be integrated in the ships eperational maintenance routine. (2831 Management Stem Certara 13 ISM Suey Maragement Corfcaor 20 Instructions an Guianes\GUIDANCE Fon AUOTIORS 0 tao TO ee 000081ea GUIDANCE FOR AUDIT TO THE ISM CODE Page 48 of 57 ‘MSC.104(73) 1 DOCUMENTATION 11.1'The Company should establish and maintain procedures to contol all documents and dts which re relevant tothe SMS. 11.2 The Company should ensure that: 1 yalid documents are avilable at all relevant locations; 2 changes to documents are reviewed and approved by authorised personne 3 obsolete documents are promptly removed. 11.3 The documents used to describe and implement the SMS moy be referred to asthe “Sefety “Management Manual”. Documentation shouldbe kept ins form tht the Company considers most effective. Each ship should cary on board all docurnentation relevant to thal stip \Well-designed and well-managed documentation is vital to the health and i system. Itis essential in clarifying and communicating the company's requirements, establishing and maintaining lines of communication, defining and claritying responsibilities ‘and authorities, and in developing a safety culture. Itis important to remember that the issue of a certificate means thal the system complies with the requirements of the ISM Code. It is not a guarantee that it does so in the most efficient way possible. Some very inefficient systems have received ISM certificates! The management ‘system should not create a large and unacceptable bureaucratic burden, but if it does, then the documentation has been badly designed and should be reviewed. ‘Aithough the Code does not speciticaly require the auditor to address the efficiency of the ‘systam, serious inelficiencies can reduce its effectiveness, and should not be ignored. The ‘auditor can do much ta contribute to the system's improvement by identifying duplication, repetition, ambiguity and redundancy. “The more concise a document, the more likely people are to read it, and the easier it will be to understand. Flow charts and well-designed forms and checklists can de much to reduce the umber and size of the procedures, and keeping cross-references to @ minimum makes ‘amendment much easier {A straightiorward review and approval process is essential. To concentrate document authorization in one very senior position, for example, is likely to result in delay. It may be better to approve documents at lower levels more direclly associated with the activities concerned, and with the flexibility of one or two alternative signatories. This has the added advantage of increasing the sense of ownership of those responsible for implementing the procedures. Both internally and externally generated documents must be controlled where necessary. Where the Company has chosen to incorporate external documents into its management (0151 Management Sem Cerlicatonit5 SM Salty Managemert Ceesto9190nsiucfons and GuidncesGUIDANCE, FOR AUDITORS ct ase FOR AUDITORS 0 5.300 000082GUIDANCE FOR AUDIT TO THE ISM CODE Page 49 of $7 ee OU TO THE ISICOPE Page a9 of 57 system dacumentation by reference, then those documents must be available where needed, ‘and must be of the appropriate revision, |tmay be helptul to visualize the general structure of management system documentation as portrayed in the diagram below, bearing in mind that detaled arrangements will vary ‘considerably from one company to another. Controls may be applied atthe lovel of individual procedures (which may be re-issued as changes arise) or whole manuals (for which minor ‘amendments are accumulated to be included in regular revisions). = MANAGEMENT SYSTEM DOCUMENTATION ‘OBLIGATORY BY REFERENCE Instructions Standing Orders SOLAS, Marpol, ete Technical Manuals Flowcharts Gharis Standard Checklsts Checklists ‘Nautical Publications Industry Guidance Forms ct. le ele. L INTERNAL EXTERNAL ‘Thore is a balance to be struck between insisting on the control of every piace of paper in every area and excessive reliance on uncontrolled documents. The auditor should adopt a reasonable and practical approach, taking into account the nature of the document, the frequency with which its likely to change, and the impact of the activity on safety and pollution Prevention. ‘The same control principles apply to elecironic documentation: only the means of application are different. There are also some additional considerations such as security of access, back- Up, virus protection and the rellabilly of power supplies Examples of objective evidence found at the Office and onboard the vessel may include: ~ Avaitabilty of documents & amendments where needed ~ Removal & destruction or storage of obsolete documents = Proper review & approval of documents & amendments ~ Accurate identification of documents & ravision status + The establishment of rules governing the availabilty & use of uncontrolled documents (0181 Management System Ceca SM Salty Management Cerfestona133Isnatons and Goldene\GUIDANCE FOR AUDITORS oat Codon 000083= ‘4 aa GUIDANCE FOR AUDIT TO THE ISM CODE Page 50 01 57 MSC-104(73) 12, COMPANY VERIFICATION, REVIEW and EVALUATION 12.1 The Company shoud cary out itera audits to verify whether safety and polltionprevension ‘setvities comply with the SMS. 12.2 The Company should periaicelly evaluate the efficiency and when needed review the SMS in ceordance with procedures established by tne Company 12.3 The audits nd possible crectve actions should be cari out in accordance with documented procedures 12.4 Personne! carrying out audits shouldbe independent of the reas being audited ness this is ‘impracticable due tothe size and the nature of the Company. 12.5 The results ofthe sudits and reviews shouldbe Brough! to the stention of al personnel having responsibility in the aren involved. 12.6 The management personnel responsible forthe area involved should taks timely cmectve ection on

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