With the introduction of the ISM Code in late 90s, Safety Management System, briefly SMS, remains the most important documented system for every shipping company and the new standard from RightShip could not make an exception. Namely, DBMS mentions the word SMS 38 times and has a dedicated Subject Area (No.3) under title ‘SMS governing documents’
SMS enables all personnel to implement the corporate safety and environmental protection policy and verify effective implementation for all procedures. However, it is noticed that the phrase ‘‘not included in the Safety Management System’’ has been a common remark during inspections, audits, vetting and review of compliance evaluation procedures. This is the reason, why DBMS explains all essentials in order the new standard to follow SMS concept.
The standard includes a dedicated area in which there is an elevation of requirements starting from Basic Level, to Excellence Level.
This is mainly a documentation control requirement and evidence for existing procedures, Document Management System and documentation register. The scope is to verify that Company implements official, approved and controlled documentation for use onboard and ashore through a dedicated, controlled and approved by Company procedure.
The way that the control of documents is conducted. It refers to revision procedures, roles and responsibilities for those involved in documents control, back up procedures and the involvement of Master in SMS review and control.
An effectiveness approach for existing SMS. It requires involvement of both ashore and onboard personnel to proactive feedback, electronic control. Also, classification and distribution of documents.
It refers to the external mechanism of verifying the effectiveness of SMS. This is to be external through consultancy or third-party providers. Therefore, in order a Company to achieve excellence in this Subject Area, external verification for the effectives of its system is vital.
The aforementioned levels, apart from the external verification of excellence level, do not introduce a new approach on how each company uses SMS until today and the following useful findings related to SMS can be spotted:
Subject Area No1.
- Basic Level: Senior management demonstrates commitment to SMS implementation
- Basic Level: Health, Safety, Security Environmental (HSSE) Policy is required
- Intermediate Level: Stop Work authority defined in SMS
Subject Area No 4.
- Intermediate Level: Evidence in SMS for goals and objectives
Subject Area No 5.
- Basic Level: Annual Internal Audit Plan for Verification of SMS
Subject Area 7.
- Advanced Level: SMS documentation with organization charts, roles and responsibilities
Subject Area No 16.
- Basic Level: List of critical equipment in SMS
Subject Area No 21.
- Basic Level: SMS contains navigational procedures for various stages
- Intermediate Level: SMS includes comprehensive navigational procedures
- Advanced Level: SMS procedures on managing ENCs,charts and publications
Subject Area No 22.
- Basic Level: SMS to include procedures for risk assessment
Subject Area No 25.
- Principle: Integrate environmental requirements into safety management system
Subject Area 30.
- Basic Level: Categories of incidents defined in SMS
Additionally to the above listed, there are also many other requirements referred to DBMS related to other operations already included in a typical SMS (eg Permit to work system)
Taking into consideration the above, with the new standard, there are items that have already been included in a typical SMS structure (Audit Plan, Review, Risk Assessment etc), while any new items may require additional revision of System (Navigational procedures, goals and objectives, Stop work Authority, integration of environmental requirements, Management of change etc).
‘’With the new standard, there are items that are already included in a typical SMS’’
A major change is the Policy that the SMS is structured. As per ISM code clause 2 “The Company should establish a safety and environmental protection policy which describes how the objectives, will be achieved”. Now, the new Standard requires HSSE Policy; therefore, firstly a Company should define and document it.
However, this not complicated considering that Safety and Environmental issues already exist in SMS policy, Health issues which are required by MLC are declared there and Security Issues are included in ISPS Policy. Thus, the Company needs to gather all this information and issue a combined HSSE Policy to be included in SMS.
Key actions for dry cargo operators
As it goes with all new implemented standards/regulations or guidance, the first step is to study and understand the requirements introduced.
Then, conduct a detailed GAP analysis of SMS against Dry Bulk Management System requirements. Just note that not all items should be implemented within SMS. This will indicate the status of compliance.
Decide one of the aforementioned four levels for self-assessment; this is an important step for operators, since so far there is no commercial requirement for DBMS implementation level. Choosing the appropriate level indicates what revision of SMS is required in order to achieve the level.
However, there are other additional solutions for complying with the requirement and not incorporate everything into SMS. For example, the requirement of Subject Area No2 in Basic Level: Methods of communicating HSSE excellence may include:
• Safety bulletins.
• Company newsletters.
• Vessel & shore staff interaction.
• Mission statement cards.
SMS extension may not include all these items while other means of compliance like a Company specific edition (paper magazine or web) can give solution to operators to comply with the new standard without extending the SMS to a large sized group of documents, which nobody eventually can read and be familiar with.
In conclusion, there can be found many solutions to comply with the Dry Bulk Management Standard avoiding to incorporate all items into company’s SMS, in order to keep it easy to navigate and understandable to serve its purpose