The study hereafter is of course the result of my experience as a ship’s captain at sea (20 years!) confronted from 1993 with the ISM Code but also the result of my personal analyses in the objective of a code to be finally correctly applied.
Totally enthusiast of the experience feedback, I also draw from the experience from my colleagues of AFEXMAR, AFCAN and IIMS who write to me on this subject (remember: firstname.lastname@example.org ) but also by a significant research in the adequate international publications as well as by a participation in more or less effective professional seminars.
This article must be regarded as an activity of utopian advice and especially not a review of already accomplished actions.
In addition, I am an adept of contradiction, so other interpretations of these § of the ISM Code will be thus welcome.
Thank you for your comprehension
Called critical, vital or sensitive, certain equipment of the ship specified in §10.3 of the Code, must be the subject of all our attention if we want to be declared " in conformity with the code ".
A priori, that seems very simple, but by wanting to remain too general, the code leaves such possibilities of interpretation that the auditors are often uncomfortable at the time of the analysis of conformity.
Moreover for the French-speaking people, an IMO official translation often too approximate does not arrange things.
- Official texts
10.3 The Company should establish procedures in its SMS to identify equipment and technical systems the sudden operational failure of which may result in hazardous situations. The SMS should provide for specific measures aimed at promoting the reliability of such equipment or systems. These measures should include the regular testing of stand-by arrangements and equipment or technical systems that are not in continuous use.
10.4 The inspections mentioned in 10.2 as well as the measures referred to in 10.3 should be integrated into the ship's operational maintenance routine.
Traduction officielle en français
10.3 La compagnie devrait établir dans le cadre du système de gestion de la sécurité des procédures permettant d'identifier le matériel et les systèmes techniques dont la panne soudaine pourrait entraîner des situations dangereuses. Le système de gestion de la sécurité devrait prévoir des mesures spécifiques pour renforcer la fiabilité de ce matériel et de ces systèmes. Ces mesures devraient inclure la mise à l'essai à intervalles réguliers des dispositifs et du matériel de secours ainsi que des systèmes techniques qui ne sont pas utilisés en permanence.
10.4 Les inspections mentionnées au paragraphe 10.2 ci-dessus ainsi que les mesures visées au paragraphe 10.3 devraient être intégrées dans le programme d'entretien courant
- Characteristics of the translation :
On one hand,
" sudden operational failure " means " sudden breakdown " of course, but also " unforeseen unavailability (or failure) of exploitation (or operation) "!
" hazardous situations " relates to situations of danger or risk or hazard concerning the persons on board, the ship itself and the environment!
So, they are not only equipments or systems in service which suddenly break down but a group of equipments which, if they were not available at the precise moment, when needed, can put the men, the material and the environment in danger:
The elements to be identified are already clearer!
We must envisage specific measures to reinforce the reliability of these equipments or systems.
Here no problem, it is necessary for us within the framework of a specific prevention, to ensure that this equipment or systems are able to work normally or at the desired moment.
In order that we do not forget anything, the drafting group of the ISM code insists by specifying that, certain tests or tests of the devices in stand-by (apparatus in redundancy or replacement procedures) are carried out regularly ; as well as for the technical materials or systems which are not in continuous use.
There is here, in my opinion, a mistranslation: indeed “equipment and technical systems " are linked in the first part of the §, therefore they must logically remain also at the end of the § and we must thus read as above and not as in the French translation where equipment is related to " arrangements ".
When we are an “habitué” of the code that does not have much importance, but I wish to point out that because these "stand-by systems" will take greater importance in the future in the prevention of accidents at sea which is the main objective of the code.
In conclusion, these stand-by equipments and these materials or technical systems which are not in continuous use are …critical systems that the code encourages us not to forget.
* (see NB 1)
- What it is about really ?
- Identify these critical systems
- Define specific measures to enhance their reliability by including periodic tests
- And furthermore, the tasks involved will be assigned to qualified personnel
- An apparatus or a system is required to function during the operation of the ship ie:
- Propulsion, navigation and their management
- Port operations: manoeuvre and commercial operations
- Power and its management
- Permanent safety : detection, lighting and eventually automatic fire extinction
- Response elements: Extinction , fire or drainage pumps
- Survival : abandon, Search And Rescue
ie practically the whole ship’s life ; we must thus proceed to an inventory of the totality of the equipment of the ship
If this apparatus or system stops of working (breakdown) or cannot be used (does not start or is in such bad condition preventing it from ensuring its role)
We must thus identify this equipment called critical
These equipments do not have all the same degree of " criticality " ie some are more critical than others, ie for some of them their absence is already an emergency whereas others can be replaced by another apparatus in stand-by (redundancy) or a procedure of replacement can be implemented to ensure nevertheless the service of this apparatus but under less comfortable conditions called degraded conditions or status (manual or local command etc.).
We thus will give a level of criticality to each equipment by taking account of those which can operate in a degraded status.
For the critical equipment the code obliges us to envisage measures of reinforcement of reliability.
- either this unavailability is unlikely to put anybody in danger : that is a non critical equipment
- or there is a risk and it is the responsibility of the SMS to ensure the safety of the persons on board, the ship itself and the environmental protection: we have there a critical equipment
To reinforce this reliability the means used are:
Elements of our step
- An enhanced maintenance...
- A redundancy or more simple stand-by device (back-up)
- The replacement procedures if the apparatus or system can function in degraded mode
- The order of spare parts
- Repairs on the spot when possible or in a shipyard in emergency or deferred
- To define the frequency of these measures
- To assigned these measures to qualified members of the crew
5-1 critical Materials or systems (non exhaustive list)
- Matériels ou systèmes critiques (liste non exhaustive)
Radars, Navigation lights, whistles
Internal communications : tannoy-telephone- interphone
External communications : VHF – Radio- Satellite communications : phone-fax-e mail
Fire detection and alarm
Fire mains, Power and control circuit of mooring winches
Bilge pumping system, Anchoring system
Fire detection and alarm system, extinguishing system
Fuel tanks double level alarm system
Propulsion system, steering system
Collection of drawings, plans or technical manuals
Stand-by arrangements and technical systems that are not in continuous use:
Lifeboats, Life rafts, Life boats davits
Lowering system for lifeboats, lowering system for life-rafts
Chain locker clench, Fire dampers, Signal lamp
Emergency fire pump, remotely closed valves
Emergency lighting, Emergency bilge pump
Remotely operated electrical equipment, Towing equipment
- Level of criticality
- Critical without redundancy nor procedures of replacement
- Critical with procedure of replacement
- Critical with redundancy
- Critical with redundancy and procedure of replacement
- not critical
- Specific Measures (hardware and software)
- Automatic Power supply
- Redundancy and/or replacement procedure
- Reinforced maintenance or more frequent tests by ship’s crew
- Periodical Control by specialized company
- Spare parts on board for a possible repair by the ship’s crew
- Spare parts on board for a possible repair in the nearest shipyard
- Copies of the collection of drawings and plans in a safe place ( including digital documents)
- Familiarization and preparation of the ship’s crew
- Special training of operators
- Experience feedback from Shipboard, Company or equipment builder
- Replacement procedures:
- Second line of command
- Hand drive operation on the spot
- Emergency power or fuel supply by derivation
- Emergency power supply in the event of partial or total blackout
- Emergency drainage by derivation
- Etc… (up to 45 for a large ferry)!
- Risk analysis and Operation in a degraded status :
Resolutely modern, a new method of risks analysis in our industry allows, even before the construction of the ship, to evaluate the future risks due to the operations of the ship and thus to determine, if required , modifications of design or procedures in order to reduce these risks.
Nowadays, the manufacturers of equipments propose operation in degraded mode allowing a minimum service.
The Classification Societies propose a plan study (Safety Case) according to the methods of the FSA (Formal Safety Assessment). This study is effective (as been seen) but still extremely expensive except for those, with foresight, who will not forget to include it in the building specifications !
A risks analysis is thus necessary for all the shipboard operations and it is what a sailor normally carries out each time that he undertakes something on board !
However a more formal approach of this evaluation can only help us to reduce these risks inherent in the transport by sea.
Nevertheless, I remain persuaded that, in spite of the new methods of analysis, experience remains irreplaceable. This experience, initially personal, will be really effective when the use of its corollary , the experience feedback, will be in use firstly in the shipping companies then at the level of the whole maritime industry.
This ISM Code requirement was sometimes the subject of rather astonishing interpretations including at IMO (you know that an interpretation of an IMO text is only the result of a consensus after the opinion of IMO members and some NGO. Sometimes the consensus is difficult to find and we remain in the dark… by hoping that the next amendment will finally clear up the text!).
The goal of the ISM Code is really to ensure (and not to “guarantee” as the French translation says!) safety at sea, prevention of the body lesions, loss of human lives, attacks to the environment and material damages (nevertheless!).
Indeed existing instruments such as SOLAS or other regulations have the same goal and apply to already equipment which can be critical. These specific equipment or systems were identified and improved since the beginning of this regulation and continue to improve.
These equipment or systems are now well identified and maintenance or control measures exist.
The ISM Code imposing the exhaustive identification of technical systems whose sudden failure could involve in dangerous situations, does not repeat with SOLAS itself: it only asks to evaluate the criticality of this equipment (thing completely forgotten by other instruments), classify them by order of criticality and… deduce some specific reinforcement of reliability measures, that’s all!
The IMO working group, in charge of the proposed text, sought already to a methodological working risk assessment related to this equipment or systems.
For many users this chapter did not causes useless polemic:
- The risks related to the equipment and technical systems were assessed
- Measures for reduction of risks were given for each equipment.
- When these measures where already taken, because of SOLAS or class specific requirements, they were included and supplemented, if necessary
When applying all measures above, we are apparently ready for ISM certification and precisely for the requirements of chapter 10.3 !
However have we forgotten perhaps the most critical element on board, I mean the man, the sailor? No, of course, because the code itself is finally an "attempt at a reduction of the risks related to the human activities onboard a ship " * * (see NB 2), but the maritime transport has difficulties to recognize that the human person remains the centre of the safety and environment protection .
Probably richer, commercial aviation has understood for a long time that an efficient management of safety in transport could not be achieved without a specific effort on the human element itself.
For the seafarer, in addition to his training and physical condition (which we already take care of), it is on the improvement of his own performances that this modern world is preoccupied in particular in a situation of stress; To know how and when to take the good decisions, to know his own limits, to know how to manage a team in an emergency situation, to know how to manage his own stress etc…
For me, the Merchant Marine has been lagging behind but it awakes finally; the "Marine Crew Resource Management " is already well launched by our neighbours (perhaps more “salt-blooded” than us!) and also arrives in France... finally!
UK P&I Club, "ISM code, legal and insurance implications" PH ANDERSON
Capt B. APPERRY
AFEXMAR President, MIIMS, AFCAN, IFSMA
Listing of “Management in Degraded status “of the M/V NORMANDY (CE M.LASVALADAS)
||* NB 1: Draft amendment of the § 10.3 of code ISM (proposition)
10.3 – The Company should establish procedures in its SMS to identify the technical material & systems or stand-by arrangements the sudden operational failure or impossible operation or poor condition of which may result in hazardous situations for the crew, the ship or the environment.
The SMS should provide specific measures of redundancy, maintenance and periodic tests as well as replacement procedures for equipment which can operate in a degraded mode in order to reinforce their reliability and to ensure their operation according to the need.
** NB 2: Anomalies
A traceability of only one link of a cold chain or a quality certification applied to only one element of a chain does not have a sense; a SAFETY and ENVIRONMENTAL PROTECTION certification for only one element of maritime transport (the company and its ship) does not have more .
What is the point if the ship is ISM certified if the pilot gets you aground, if the tug boat makes a hole in the hull, if the mooring gang releases a steel-wire spring in the propeller, if the port officer imposes you a dangerous berth, if the MRCC takes your damage “lightly”, if the charterer - in whom you have confidence (sic) - mixes anything in your container, if the Classification Society delivers you a certificate of convenience, etc...!
The "attempt at reduction of the risks related to human activities" should logically be imposed soon to the other participants of the maritime transport, don't you think ?
Attempt at the Critical equipments
or systems operational flow chart
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