The road from minimum compliance to performance excellence requires a self-assessing process and reporting. In essence, the DryBMS will demand more involvement from shore side personnel, as its implementation requires a series of evidence to verify scoring.
The Subject Areas of the new RightShip standard include a number of specific items for shore side personnel, similar to those of oil shipping sector. An organizational chart accompanied with job descriptions for each position is a starting requirement. Nonetheless, the majority of dry bulk companies use a generic chart where all departments are illustrated; in addition, these need to clarify all positions, lines of communication, roles and responsibilities in order to provide a complete corporate picture.
A dedicated Subject Area (No2) has been assigned to vessels visits by shore staff. Until now, the ISM code requires an Internal audit for implementation of SMS. But with DryBMS, shore staff should visit vessels with specific agenda including Health, Safety, Security and Environmental items. Furthermore, a proper follow up and close out need to be conducted.
At present, companies conduct the Internal Audit for SMS compliance and one or more technical superintendent’s visits. But, is this enough for DryBMS compliance? The answer depends on the way that the audit or visits are being planned. For example, does the Auditor conduct a typical SMS implementation audit or focus deeper on HSSE implementation? Does the Technical superintendent only check the machinery performance and condition or focus on additional items as per Subject Area No 2 requirements?
The technical Superintendent’s visits are included in Subject Area No 14 “Maintenance”, so the Standard expects something additional to this. In order to fulfill this requirement, good practices for companies could be the following:
- use already planned visits (audits, inspections)
- give additional time to auditors/inspectors and
- conduct additional checks covering all aspects of ship’s activities with a use of a detailed checklist.
Needless to say that the auditors/inspectors should be qualified properly while if a Company aims for Excellence Level, senior management visits are also required, again planned, structured and documented accordingly.
Furthermore, in Subject Area 5, in Intermediate Level, there is a requirement for managers to have audit as part of their job description and evidence to be in place for line managers audit. Therefore, combining the subject areas No 2 and No 5, the standard expects from shore managers their participation in audit process, in office (intermediate level) and on board (Advanced Level).
The Subject Areas covering Shore office structure and organization are No7 under the title “HR management and recruitment (office)” and No 8 “Technical & HSSE training (office)”. A list of requirements are included in these sections for head office.
As already mentioned, organizational Chart, defined roles and responsibilities, appraisals, personal development plan, retention rate are some of the requirements included. Therefore, each office should follow a clearly defined procedure in order to employ personnel fit for position and be periodically appraised, following specific personal plans. Training, familiarization and training matrix are required for all positions. Also, a hand over procedure is vital.
Therefore, to comply with the above, companies need to take action and include the following:
- a detailed organizational chart featuring all positions
- job description for each position (including substitutes)
- a detailed qualification matrix based on all job descriptions
- The handover procedure for shore staff should include the transfer of duties to a new employee from another who is no longer in Company (eg due to retirement or other reason), and the temporary transfer of duties due to other reasons ( eg summer holidays or illness). In such case, a minimum period for absence without substitution should be included.
- Attention should be given to appraisal procedures, the background checks procedures and other personal related procedures in respect of General Data Protection.
A new entry for shore office are the security requirements, included in Subject Area No 27 “Security Management”. There are some key points here like the Policies and procedures covering physical security of shore offices (Basic Level). This means that Company many need to develop a Company Security Plan, similar to Ship Security Plan, and include standardization of procedures in order to protect Company for unauthorized access or similar risks. As best practice this should be a stand alone document with procedures for entering, leaving, monitoring the areas of office, in respect of physical security only.
Cyber Security will be covered as per IMO Resolution MSC.428(98) and Subject Area No. 28 “Cyber security”, which requires a Cyber Security Plan to cover Companies. Therefore, to address the risk of cyber security in SMS, as required by IMO and taking into consideration DryBMS, a Company may need to develop a Cyber Security Management Plan as supplement to SMS.
Concluding, Dry Bulk operators need to take into consideration all the above requirements and organize their offices accordingly. But first and foremost, they need to decide which level they wish to achieve and determine all actions. The new standard requires shore office not only to be properly organized but also to be actively involved in HSSE policy implementation and in achievement of the objectives for excellence.
