In some cases, only one or two material deficiencies, i.e. broken zippers on immersion suits, oxidized coating on CO2 cylinder control head, etc. were linked to an ineffective SMS.
In April and mid-May, more vessels were issued deficiencies for their SMSs over similar issues.
Most of these detention cases began with the crew failing to “report and document a known safety-related deficiency” in accordance with their SMS.
Crew interviews, internal records and checklists, and the results of the most recent Recognized Organization (RO) survey also were used as supporting objective evidence to expand the scope of the examination and ultimately the detention of these vessels.
With respect to the above, the RMI Maritime Administrator recommends the following:
- Owners, operators, Masters, and crew should renew their efforts to fully implement and utilize their SMS daily.
- Masters and crew should be ready to answer Port State Control officers’ questions about their SMS with special attention given to identifying and reporting non-conformities, and maintenance of critical equipment.
- Companies (the Document of Compliance holder) should ensure regular documented communication between their office and their ships, including evidence that shipboard deficiencies or issues have been rectified.
- Nautical Inspectors and ROs should focus on crew knowledge of the SMS and gathering evidence of effective implementation of the system.
- RO surveyors should ensure they are verifying proper operation of all equipment associated with a statutory certificate before issuing or endorsing a certificate.
The SMS is integral to safe ship operations, crew welfare, and marine environmental protection. The RMI Maritime Administrator encourages all management companies and ship’s officers and crew to renew their focus on effective implementation of their Safety Management Systems.