USCG issued in August 2005, the NVIC 04-05, containing guidance to ensure foreign vessel compliance with the requirements of ISM Code as well as a complete assessment tool to assist PSCOs when elevating a PSC Exam to an expanded examination of the Safety Management System
The following extract is from the aforementioned USCG Circular, addressing questions that the ISM compliance assessment tool should include.
Questions for the Description of a Non-Conformity (NC)
ISM 1.1.11 Are deficiencies present that pose a serious threat to personnel, the ship, or serious risk to the environment, and require immediate corrective action?
ISM 1.1.11 Is there an apparent lack of effective and systematic implementation of a requirement of the ISM Code? If so, does such apparent failure apply to:
ISM 1.4 The adherence to the ship’s approved, self-developed Safety Management System?
ISM 4 The responsiveness of the Company’s Designated Person(s) to the ship’s non-conformity reporting and requests for assistance/corrective action?
ISM 5 The Master’s defined responsibilities, authority, and his performance of those responsibilities?
ISM 6 Critical crewmember’s knowledge and familiarity with the ship-specific SMS?
ISM 1,4,7,8,9,10,11,12 Are the SMS-specified reporting and documentation procedures being followed? (Note: This is a broad, catch-all topic. Use judiciously when hard documentation of NCs posing serious threat are apparent due to the lack of adherence to the reporting and ISM Code documentation requirements throughout the Code. Cite the specific Code ref for the evidence discovered.)
ISM 10 Do the maintenance procedures for the ship systems identified in the SMS; include frequency, scope, and documentation for the maintenance and necessary corrective action(s)?
ISM 6 Does the overall performance of the crew indicate that they have been trained to perform their assigned tasks in accordance with the training needs identified in the SMS?
Conducting the Expanded Exam
The purpose of the expanded exam is to identify the weak or neglected areas of the ship’s SMS. The PSCO can take a clear snapshot of the system by focusing on six key elements of the SMS:
- Designated Person, Section 4, ISM Code
- Master’s Responsibilities, Section 5, ISM Code
- Resources and Personnel, Section 6, ISM Code
- Non-Conformities, Accidents and Hazardous Occurrences, Section 9,
- Maintenance, Section 10, ISM Code
- Documentation, Section 11, ISM Code
Questions that PSCO may ask during an Expanded Exam
DPA, Section 4, ISM Code
- Captain, who is your Designated Person Ashore (DPA)?
- Are you in regular contact with this person?
- How do you contact this person?
Remarks: Caution, do not make this an interrogation process. Use common sense and a non-judgmental attitude.
Master’s Responsibilities, Section 5, ISM Code
- Captain, may I please see your SMS manual?
- Can you explain the company’s Quality and Safety Policy in your own words?
- Did you receive training for your SMS duties prior to taking command?
- May I see the documentation for that training?
- Do you feel that you can take all necessary action to protect the ship, crew, and environment in the case of emergency without approval from the company?
- How often are you required to conduct a Master’s review of the SMS?
- Can you show me the procedures for this review and documentation of your last review?
- How often is the company required to conduct an internal audit?
- Can you show me the procedures for internal audits and documentation for the last internal audit?
Remarks: Review the SMS manual and any documentation presented. If it appears the Captain has a good grasp of the program move along and do not belabor the process.
Resources and Personnel, Section 6, ISM Code
Qs for Captain
- Captain, can you show me the procedures for change of command? Do you have documentation ofthis activity?
- Captain, are you required to familiarize new joining crew with there duties when they join the ship? . Can you show me the procedures and documentation of this activity?
- Captain, may I interview your crew? Remarks: Ask the following question to key crewmembers.
Qs for Chief Officer
- Did you receive training in your SMS duties by the company prior to reporting onboard the ship? Do you have documentation ofthis activity?
- What certificate indicates the types of cargo this ship may load? Remarks: IOPP, Certificate of Fitness, Sub O Endorsment
- What publication would assist you in knowing the proper handling procedures for these cargoes? Remarks: BCH Code, ISGOTT, etc.
- Can you show me the procedures for drafting a stowage plan?
- Can you explain the ship’s stability calculations? What shipboard manual would assist you in developing these calculations? Remarks: Stability Book
- Can you show me the procedures in your SMS for making a tank safe for entry? Can I see the documentation for the last such tank entry?
- What are the requirements for the use of personal protective equipment in your SMS? Can you show me the procedures in your manual?
Questions for the Second Mate
- Second, did you receive training in your SMS duties prior to assuming them onboard the ship?
- Are you responsible for voyage planning?
- Can you show me the procedures in your SMS for drafting a voyage plan? Can you show me the most recent voyage plan?
- Are you responsible for chart corrections? Can you show me documentation of this activity?
- Can you show me the procedures for making the ship ready to get underway? Can you show me documentation of this activity?
- What nautical publications are you required to maintain onboard the ship?
Questions for the Chief Engineer
- Chief, did you receive training in your SMS duties from the company prior to assuming them onboard? Do you have documentation of that training?
- Can you show me the procedures for bunkering the ship? Do you have documentation of this activity?
- Can you show me the procedures for reporting damage to machinery and associated systems in your SMS? Can you show me your last damage reports?
- What equipment onboard is critical equipment in your SMS?
- Can you show me the procedures for performing preventive maintenance in your SMS? Can you show me when the last PM was done to the OWS (or any other identified critical piece of equipment)?
- Chief, does your SMS require you to issue night orders? May I see your last set of night orders?
Questions about the deficiencies identified during the boarding
Non-conformities, Accidents and Hazardous, Occurrences, Section 9, ISM Code
- Captain, what is the definition of a non-conformity in your SMS?
- Can you give me some examples of issues you would raise a non- conformity?
- Are damages to equipment and ship structure considered non-conformities in your system?
- Who is authorized to raise a non- conformities. conformity in your SMS?
- Can you show me the procedures for reporting non-conformities to the company?
- I see here in your procedures that several of the deficiencies I have noted are considered non-conformities in your SMS. Can you show me documentation on reporting these deficiencies to your company in accordance with your SMS procedures?
Remarks: The PSCO should determine through this line of questioning and if any of the deficiencies noted are considered non- in the ship’s SMS. Deficiencies with critical equipment will always be non- conformities.
Maintenance, Section 10, ISM Code
- Captain, may I interview your Chief(Mate/Engineer based on the department with deficiencies)?
- Chief Mate, could you show me your maintenance procedures related to maintaining compliance with your Load Line certificate?
- Chief Mate, I see here your maintenance procedure requires inspection of the cargo hold hatch covers, coamings and holds prior to loading, do you have documentation of this activity?
(1) Inspection routines carried out and documented in the SMS should reflect the true condition of the equipment or ship structure.
(2) Non-confonnity may exist if:
- The documented inspection activity identifies the equipment or structure as “OK” and the PSCO finds it damaged
- The maintenance procedures exist but are not carried out,
- Maintenance procedures do not exist for the equipment or Structure found damaged and damage was sufficient enough to render the ship non-compliant with the related certificate
The PSCO should continue questioning the individual responsible for the related maintenance of deficient equipment or structure until he/she has a clear understanding of why deficiencies exists.
In general, maintenance problems will fit into four categories:
- Lack of training in proper inspection and maintenance routines.
- Lack of procedures on specific items or areas requiring inspection and maintenance.
- Lack of implementation of company maintenance procedures.
- Lack of support from the company
One or all of these categories may contribute to the conditions found onboard.
Documentation, Section 11, ISM Code
- Captain, can you explain to me how your company maintains control of SMS documents?
- Can you show me the list of controlled documents (may also be called a forms list)?
- I see here on your control list a Damage Report Form, No.xxxxx, can you show this form in your SMS?
- How are obsolete documents disposed of?
Remarks: All procedures, forms, schedules and checklists identified in the SMS must be controlled. this means they should have a control number and revision date on the document and be registered on a control list.
Verify proper form identification number and revision date, matching the control list. Check several other forms.
Typically the company wants them sent back so they know they have been removed.