DryBMS: A close look into the 8 Priority Areas in ‘Process’

The Dry Bulk Management Standard (DryBMS) includes 30 Subject Areas in total, some of which may require more focus in comparison to others. This is why they are also referred as ‘Priority subject areas’.

Namely, these areas are considered to have a potentially higher impact for injury to people and damage to the environment. Nonetheless, the overall scoring they have is equal to scoring weight of the non priority areas.

‘’Although, these priority subject areas make no difference to the overall score of a company, a company may wish to focus on improvements to these subject areas, ahead of improvements to other subject areas’’ RightShip notes. In total, seventeen priority areas have been identified as subject areas as shown on table

19. Mooring and anchoring

The generic requirement for all 4 Levels is to have procedures in place regarding Mooring & Anchoring. Some key points are the roles/responsibilities & training for such operations, the toolbox talks required, inspection and retiring procedures. Detailed record keeping for inspections, tests and in excellence level comprehensive mooring audits.

Having all these incorporated within SMS for different types of ships could be a nightmare for HSQE and technical departments. The best solution comes from Tanker Industry. An Effective Mooring/Anchoring Management Plan which may incorporate generic guidance on Company’s procedures and ship specific equipment and details will address the items required.

20. Cargo & Ballast

This is an area that most of the Dry Bulk operators are familiar and most of SMS or other documents are complete in respect of requirements. The issue of Ballast management is covered extensively in the approved ship specific Ballast Water Management Plans as required. The most valuable items on board (excluding humans and the ship itself) is the cargo.

Some items that may be considered as new are the training requirements with appropriate records for those involved with cargo operations and the comprehensive cargo & Ballast audits required in Excellence Level.

21. Bridge Procedures & Standards

This is a familiar area for all operators; safety of navigation is a key priority for the maritime industry and therefore companies have detailed procedures to address all challenges and requirements. The DryBMS require these to be “SMS procedures” so they should be incorporated to SMS.

It is worth mentioning that in the requirements of Basic Level, there is the requirement for “Contingency planning in the event of dual ECDIS failure”. Since IMO legislation has only one level of back up to ECDIS (other ECDIS or paper), in case of dual ECDIS failure a procedure should be in place in order to ensure ship’s safety.

In case of absence of ENCs (due to dual ECDIS failure) all other methods of finding position and navigating require a set of paper charts on board. The navigational audits and assessment during passage included in Excellence Level is another item new for Dry bulk operators.

22. Risk Assessment & management

This is another SMS related requirement as per DryBMS. Evidence of records are highlighted as important within requirements.

Another seriously marked item is the “Documented process of training the assessors”. Personnel preparing/reviewing and issuing risk assessments should be adequately trained through a documented process and evidence to be available.

A best practice roadmap for compliance to this Subject area is:

a.    List all operations that require Risk Assessment

b.    Have Risk Assessment & Management procedures in place

c.    Have trained personnel to conduct the assessments

d.    Create a pre-prepared Risk Assessment Library with all operations of (a) step

e.    Use these RAs during operations

f.     Review the status and effectiveness of pre-prepared RAs periodically

23. Permit to work

Most Companies have efficient procedures to address Permit to Work requirements. However, in this subject area there is a link between Permit to Work system and Lock Out Tag Out.

Some additional requirements for Lifting Permit afre also new for many Companies. The most important issue is the auditing of PTW system and analysis of findings. The PTW system is to be audited as part of internal audit (or using additional checklists, which is not recommended). The Internal Audit checklist is to include detailed items for assessing the effectiveness of PTW system ad the implementation level on board.

26. Management of change including vessel acquisition

This is a total new area for dry bulk shipping as no such requirement existed in past years (excluding Companies with quality ISO certification, which may had been subject to such requirement).

The requirement is that every change (temporary or permanent) should follow a structured step by step process with different levels of approval, involving risk assessment to all procedure and requiring a final Authorization for implantation.

Different categories of change require different levels of management and approval. MOC is not referred only to equipment, systems or procedures but also is expanded to personnel related changes. For example, in order to change the Technical Manager of the Company the MOC procedure is to be followed.

29. Emergency planning including crisis management

Since ISM code includes such requirement the basic and intermediate levels are mostly covered. Some new entries are: the Business Continuity Plan that the Company should establish; the determination of standard emergency facilities; the alternation in positions during different drills or scenarios and; the required media training for senior management (in Excellence Level).

30. Incident reporting, investigation & training

The key points included in this DryBMS area are the external training that an incident investigator should have, the detailed Root cause procedure (identification/analysis), the distribution of investigation results fleet-wide, the sharing of incidents within industry and the benchmarking with industry bodies and other companies.