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A Guide to Maritime Labour Convention (MLC), 2006 for Maritime Professionals

By | Maritime Knowledge, Maritime Training | No Comments

Maritime Labour Convention (MLC), according to the ILO or International Labour Organisation, provides a broad perspective to the seafarer’s rights and fortification at work. The maritime regulation will finally entered into force on August 20th, 2013. Nearly 1.2 million seafarers will be affected by the terms and conditions of this human rights act, which will lay down a set of regulations for protection at work, living conditions, employment, health, social security and similar related issues.

On the basis of Maritime Labour Convention (MLC), the Seafarer’s Employment Contracts will be implemented and mandated against nullifying the present employment contracts. MLC will be similar to the other statutory certifications such as ISM and ISPS onboard ships and the certificate will have 5 years of validity with interim, initial and intermediate surveys. It is imperative for all seafarers to understand the importance of Maritime Labour Convention (MLC), 2006.

Under MLC, 2006, the ship owners are required to submit a DMLC or Declaration of Maritime Labour Compliance to their respective flag states which form a party to the convention. The flag states will accordingly issue the MLC Certificate to the fleet flying their flag following, surveys, inspections, paperwork and approvals. The certificate would be then required to be posted at a conspicuous position onboard.

Contents of MLC,2006 

  1. Minimum Requirements for seafarers to work on ships
  • Minimum age
  • Medical certificate
  • Training and certifications
  • Recruitment and placement
  1. Conditions of Employment 
  • Seafarer’s Employment Agreement
  • Wages
  • Hours of rest and hours of work
  • Entitlement to leave
  • Repatriation
  • Seafarer compensation for ship’s loss or foundering
  • Manning levels
  • Career and skill development and opportunities for seafarer’s employment
  1. Accommodation, Recreation, Food and Catering
  • Accommodation and recreational facilities
  • Food and catering
  1. Health Protection, Medical Care, Welfare and Social Security Protection
  • Medical care on board and ashore
  • Ship owner’s liability
  • Health and safety protection and accident prevention
  • Access to shore based welfare facilities
  • Social Security
  1. Compliance and Enforcement
  • Flag state responsibility
  • Authorization of recognized organisations
  • Maritime labour certificate and declaration of maritime labour compliance
  • Inspection and enforcement
  • On board compliance procedures
  • Port State Responsibilities
  • Marine Casualties
  • Labour Supplying responsibilities

Application of MLC,2006 to type of vessels

MLC applies to all the registered commercial vessels regardless of the flag state they belong to. This will also include leisure and commercial yachts, which are engaged on international voyages besides a few exceptions as stated in their circular discussing application of MLC on types of vessels. Vessels must be over 500 GRT to carry the MLC certificate. For vessels under 500 GRT, guidelines recommend the vessels to be voluntarily complying with the convention and as documented by the flag states.

Compliance requirements

The flag state administration is either doing the certifying process for the MLC certification or a Recognized Organisation (RO) maybe entitled to carry out the process on their behalf. The authorization may include the whole process of submission of the DMLC, inspection and ships operational verification to issuance of the MLC Certificate or a part of it. Classification societies or other third parties which specialise as recognized organisations are normally the service providers on behalf of the flag states.

Period of validity of the certificate

The MLC certificate may be issued for a period not exceeding five (5) years, following thorough inspection and verifying the vessels meet the minimum requirements of the MLC. To ascertain that the vessels which fly the flag of the member states continue complying with the requirements and standards of the convention, the competent authority of the flag may renew the certificate and maintain a public record for the same. Ships that are newly built and ships undergoing change of flag would also be issued with the certificate on interim or provisional basis for periods not exceeding six (6) months.

Survey Requirements and Port State Control (PSC)

Initial survey and inspection will be followed diligently with other inspections such as the intermediate inspection. Port State Control has the right to board any vessel at any given point of time for verifying the compliance for MLC. The Port State Control Inspectors are however entitled to detain the vessel not in compliance with the MLC requirements. With regard to PSC, the compliance for MLC is mainly subject to availability of the Declaration of Maritime Labour Compliance (DMLC), the MLC certificate issued to the fleet and a plan implementing the MLC content

Time taken to get certified

One of the main requirements of complying with MLC is that every crew member is to be in possession of an approved Seafarer Employment Agreement or SEA. The approval has to necessarily be in conjunction with the flag state and must include certain provisions that are required under MLC. The older seafarer’s contracts will be replaced or used in concurrence with the SEA and be inspected upon by the PSC. In lieu of this, time required for the certification will depend on the gap analysis, issuance of newer Agreements and also the development of plans and manuals. Moreover, Crew compensation and other benefits may be different for every ship owner apart from those required by the MLC. The length of reviewing, revising and approving of the requirements and therefore the certification time may take weeks or months together.

Fixing up or scheduling inspections

Every Flag State is wholly responsible for ensuring that the obligations under the MLC convention are implemented correctly onboard ships flying their flags. This also means that the flag state is responsible for correlating the subsequent measures related to work and living conditions and forming an efficient system for the inspections and MLC related certifications, Flag State is also entailed to appoint sufficient qualified inspectors for executing the certification processes.

The interval between the inspections should not exceed a period of 36 months. Similar to the ISM and ISPS certifications, MLC also requires the inspectors to conduct examinations, tests or enquiries to verify strict compliance to the regulations of the convention and ascertain that the deficiencies, if any, are remedied avoiding serious breach to standards of the convention or correspond to considerable danger to the health, safety and security of the seafarers. The inspectors also have the power to restrain the ship to leave port until the deficiencies are corrected. 

Dealing with Inspections

As stated earlier, the flag state has all the rights to withdraw the MLC Certificate if the vessel fails to pass the mandatory inspections and its obligations. The Inspector in his entire prowess is empowered to detain the vessel in port if it is evident that the concerned vessel failed to implement the requirements of the MLC onboard. With the number of inspections to increase exponentially, the number of detentions is also believed to increase. Failed Inspections could mean heavy commercial and financial losses for the vessel, charterers and the owners. Therefore the best way to avoid such grave situations is to ensure that the vessels strictly adhere with the guidelines as laid out in the MLC Convention.

Documentation required

In short, the member states require each vessel to maintain a hard copy of the convention at all times along with the MLC certificate, a Declaration of Maritime Labour Compliance stating the obligations of the convention that involve working and living conditions for the seafarers and measures to put in place for the MLC compliance.

Documents required to be maintained onboard for Maritime Labour Certificate (MLC 2006)
– Declaration of Maritime Labour Compliance, Parts I and II
– Maritime Labour Certificate
– Recent Inspection report
– Evidence proving that all seafarers onboard are above sixteen (16) years of age
– Evidence showing the crewing agencies comply with the MLC requirements
– A Medical Certificate of maximum one year validity for seafarers under 18 years of age
– A Medical Certificate of maximum two years validity for seafarers above 18 years of age
– Evidence proving no dangerous work or night time work being undertaken for seafarers under 18 years of age
– A Seafarer’s Employment Agreement (SEA), signed by the seafarer and ship owner or an authorized representative
– A copy of CBA or Collective Bargaining Act and its English version
– A valid COC or Certificate of Competency and valid training certificates for all seafarers onboard
– Records of training in personal safety and safety meetings held onboard
– Records of all accidents, incidents, investigations and consequent analysis onboard
– Records of seafarer’s familiarisation and the records for seafarer’s rest / work hours

The Maritime Labour Convention (MLC), 2006 is a milestone for the global maritime industry. Once implemented, MLC is expected to enhance the life of seafarers working offshore, along with increasing the safety and security of sea-going vessels.

INTLREG Conducts Maritime Labour Convention  Training Course, our next session is at Lagos, Nigeria on 26/27/28 August 2019. For more details and registration of the course, Please contact

Options for Shipboard Handling and Discharge of Garbage

By | Maritime Knowledge | No Comments

Compliance with MARPOL Annex V involves personnel, equipment and procedures for collecting, sorting, processing, storing, recycling, reusing and discharging garbage. Economic and procedural considerations associated with these activities include storage space requirements, sanitation, equipment and personnel costs and in port garbage service charges.

Compliance with the provisions of MARPOL Annex V involves careful planning by the ship’s owner and operator and proper execution by crew members as well as other seafarers. The most appropriate procedures for handling and storing garbage on board ships may vary depending on factors such as the type and size of the ship, the area of operation (e.g. special area, distance from nearest land, ice-shelf or fast ice), shipboard garbage processing equipment and storage space, number of crew or passengers, duration of voyage, and regulations and reception facilities at ports of call. However, in view of the cost involved with the different garbage handling options, it is economically advantageous to first, limit the amount of material that may become garbage from being brought on board the ship and second, separate garbage eligible for discharge into the sea from other garbage that may not be discharged into the sea. Proper management of containers and packaging coming on board and proper handling and storage can minimize shipboard storage space requirements and enable efficient transfer of retained garbage to port reception facilities for proper handling (i.e. recycling, reuse) or land-based disposal.

Every ship of 100 gross tonnage and above every ship certified to carry 15 or more persons and fixed and floating platforms are required to carry and implement a garbage management plan that specifies procedures to be followed to ensure proper and efficient handling and storage of garbage. A garbage management plan 2 should be developed that can be incorporated in crew and ship operating manuals. Such manuals should identify crew responsibilities (including an Environmental Control Officer) and procedures for all aspects of handling and storing garbage on board the ship. Procedures for handling ship-generated garbage are divided into four phases: collection, processing, storage and discharge. A generalized garbage management plan for handling and storing ship-generated garbage is presented in table above.

Refer MEPC 71/17 Annex 21 – 2017 GUIDELINES FOR THE IMPLEMENTATION OF MARPOL ANNEX V for more details.

Drill Performance onboard ships

By | Maritime Knowledge | No Comments

Drill Performance onboard ships is the most vital element of a successful emergency response. Drills are required either by legislation or as part of the Company SMS and the time and energy spent across the industry to comply with legislation and ensure a proper response when necessary is huge. Despite all good intentions, the shipboard performance across the majority of the industry (not at the top 10% or 20% of the ships) is substandard; therefore, in this article, we will try to outline the ten basic reasons and explain why this is happening.

#1 An exhaustive/excessive number of drills is required

Besides SOLAS/MARPOL etc. requiring 5-6 basic drills, there is also an excessive number of drills required to be performed due to different legislation, ISPS, Anti Piracy and other SMS requirements bringing the total number in excess of 30 for a Tanker or 25 for a dry bulk carrier. At the same time, given the lack of guidance the majority of the ships are performing these drills one by one making it a nightmare in terms of effort and paperwork. That leads many executive teams onboard ships, having to cope with intense workloads, to select to prioritize other ship tasks ahead of drills. In light of this, in order to fully understand how these drills may be better scheduled and prepared, we need firstly to understand the realities and priorities of those working onboard.

#2 The scenarios exercised are not realistic

The majority of the drills are performed on a schedule basis with e.g. every Saturday at a convenient time a fire/abandon ship drill is performed in full day light in calm seas. However the majority of the emergencies are happening during heavy weather, not necessarily during daylight and in exactly the opposite way that we train our crews. Realistic scenarios need to be provided to properly prepare with a full scale emergency, e.g. heavy weather, hull failure, flooding, personal injury and helicopter operations. Furthermore, real life constraints have to be taken into account as in many parts of the world lifeboat lowering maybe prohibited due to port or terminal restrictions. The need to plan and execute drills in groups (say one large scale drill every quarter) is of paramount importance not only for injecting reality to these emergencies but also for minimizing the burden of disruption of shipboard operations.

#3 Drill performance criteria are not set

In order to properly perform any given task, we need a performance specification as well as description of the roles and responsibilities and expected outcomes. Onboard ships all these items are missing as drills are not properly planned before they are performed, with the exception of fire/abandon where we have a Muster List/Station Bill; however, in all other cases we are missing guidance on who does what. Therefore, it would be nice to introduce Muster List/Station Bills or simple Roles & Responsibilities for each scenario or combined scenario with any role properly described and rehearsed. Furthermore, checklists need to be in place for the preparation, execution and evaluation of each drill with guidance to all involved. As long as we do not analyse what is expected from each crew member, it is inevitable that they will not be able to perform.

#4 Crew responsibilities are not properly set/defined

As said above, not all crew need to participate in all drills and we have to make sure that they know it. Instructions are needed such as security muster list and station bill, and detailed guidance for every scenario such as collision, hull failure, master station bill and so on and so forth, in order the crew to be properly prepared on the roles, responsibilities and expectations before a drill is set. Planning is required with a discussion upfront on what the objective is and what it is expected from all participants. At the end, feedback is vital both onboard and shore to ensure improvements are observed.

#5 Real Life needs are not addressed at the Drill Plan

When we are having real life emergencies, there are many instances that we need to drill in advance; it may be an ECDIS failure, a lack of GPS signal, a malfunction of the ballast water treatment system, an integrated Anti-Piracy Drill with the assistance of an armed team of PMSC, use of citadel, an entrance to a contaminated cargo tank or any other dangerous enclosed space with the use of an emergency escape breathing device for safety maintenance or rescue reasons. It may be anything that has to do with the introduction of new technology or even the real life need to have people forming an enclosed space entry team while speaking the same language. These real life emergencies need to be identified and addressed within the plan to make it worth in the long run.

#6 The way we execute drills is not in line with ship practices

Let’s take the example of the fire drill: SOLAS requires every member of the crew to participate in a fire drill every month but we have several different types of fires with totally different response strategies and tactics as well as areas happening onboard ships, e.g. fire in accommodation, in engine room, in the galley, in the cargo spaces or at the terminal,  where we have to co-operate with the shore side. As we are not properly analyzing these real life needs and we don’t properly present/explain the different response scenarios, we cannot expect the crew to properly perform a real life scenario. There are numerous instances were crews have not been able to properly perform, for example, a fire drill in the galley with at the presence of the coast guard. In that respect, we are missing guidance from either industry bodies or company SMS (how often, what, when, where, how etc.) along with a set of best practices to be employed.

#7 Industry is having a paper work approach

To set it straight: Have you done it? Show me the record! In many instances captains are having to face the challenge of keeping the records straight, along with increased workload or heavy weather or other unforeseen operational circumstances; but at the end of the day, 3rd parties (Auditors, Authorities, Inspectors etc.) are always asking for records that showcase if drills are being conducted as required etc.

#8 Paper work upkeeping is a nightmare

The only legislative requirement to have proof of every member of the crew participating in a drill every month comes with SOLAS Fire/Abandon ship requirements. However, the majority of operators have taken it to the other extreme requesting record keeping for all drills and all members of the crew and creating a chaos with respect to record keeping. Now many ship operators are requiring a risk assessment before you conduct a drill, plus a permit to conduct a drill, plus the record keeping requirements for work and rest hours that makes the whole issue a worst nightmare, especially when someone starts checking to identify same timings, signatures, marks from the copy machine etc…

#9 Drill performance is not audited in real life

We haven’t seen the majority of the ship managers and operators auditing real life drills as part of a ship board attendance or as part audit of the ship or even having a 3rd party expert to train the crew, observe and provide immediate and effective feedback with the objective to improve performance. One of the best practices observed across the industry is to video record (even with a smartphone) these trainings to circulate same across the fleet with or without video editing as a real life tool to improve fleet wide.

#10 No KPIs are set to monitor Drill Performance

The industry has failed to identify and implement a set of KPIs to monitor drill performance such as:

  • Number or % of drills not performed on scheduled time for any reason
  • Number or % of crew not performed properly during a drill
  • Number of % of violations of Rest hours due to participation in a drill
  • Hours spend per person per month onboard ship to attend drills

The above are just an indication but the lack of introduction identifies that the item is of low priority overall. KPIs may be set on a ship or fleet level or even benchmarked across the industry to enhance improvement in the long run.

All of the above may be, either separately or in combination, form a wall that it is difficult to break; overall, we should be better looking on how the industry as a whole may provide the means for a better shipboard performance while at the same time minimizing the burden placed on Master’s shoulders.

 

Tips for a successful ISPS Code internal audit

By | Maritime Knowledge, Maritime Training | No Comments

ISPS Code requires from a shipping organization to conduct security internal audits in an effort to monitor and assess the level of managed vessels’ compatibility to security regulations and the effectiveness of the implemented Ship Security Plan.

In general, internal audits should be carried out by independent personnel who have received appropriate training. The audit is carried out at the workplace, with the use of checklist(s) for recording appropriate items; however, the auditor may deviate from the list to include additional items and important issues which emerge as the audit progresses.

As far it concerns security internal audits, Company Security Officer (CSO) is responsible for the schedule of internal audits onboard, ensuring that every part of the ship security plan on board vessels is audited once per calendar year, and at any other greater frequency, as deemed necessary. However, the CSO may initiate unscheduled audits if any serious deficiency becomes apparent from dangerous occurrences, review of records or during routine operations. Additionally, it is CSO’s responsibility to assign an auditor at a convenient time prior to the audit.

Key focus areas of security internal audits

There are some major areas on which the security auditors should focus on during internal audits:

  • Auditors need to check the approval letter of SSP and ensure that it is valid. Status of SSP should be reviewed to be made sure that ship’s related personnel is familiar with it. Also, procedures should be in place for establishing and maintaining contact with shore management in an emergency. The master should provide documented proof of his responsibilities and authority, which must include his overriding authority. In addition, there should be checked if non-conformities are reported to the Company and which are the corrective actions been taken by the Company, regarding each non-conformity. It is essential to be checked if the security filling system is in place and properly implemented.
  • As long as Ship Security Plan is based on the results of the Security Assessment, auditors should review the status of the Ship Security Assessment conducted to guide the construction of the SSP and also, should be made sure that SSA has been accepted by the CSO.
  • Regarding the Company’s Security Officer, it is important to be checked if the crew is aware who the CSO is and if his/her contact numbers are available on board. CSO certificate should be valid and copies are placed on board.
  • There should also be made sure that the Ship Security Officer is aware of all his duties and responsibilities and his/ her certificates are valid and placed on board.
  • During a Security audit, all documents and records related to the ship security should be inspected, in order to be checked if the amendments/ revisions been performed to the plan have been reported accordingly and if prior to any revision the appropriate assessment been performed. Revisions and amendments should be approved by the administration. Also, there should be made sure that all documents concerning security issues are confidentially kept in restricted places on board.
  • As for the security drills and related training, auditors should check if the drills program is followed as required and so does the training program establish by the company. Moreover, during an ISPS audit there should be checked if Safety Drills reports are completed properly and if they have been forwarded to the Head Office at the required intervals.
  • By the time the auditor board on vessel, he/she will have the opportunity to check weather all the appropriate measures are followed accordingly. There should be checked if all access points are covered by patrols and watchman and if there is a log keeping for the visitors. Boundaries are placed where it is important and access onboard is properly secured.
  • SSP requires the statement of vessel’s restricted areas and it is required to ensure that these places are searched as required, doors are properly maintained and locked. If suspected stuff has been found, should be reported and the handling of such incidents should be communicated to the company.
  • Lights, projectors and other signs should be checked in order to be made sure that are in a good working condition and ready to be used during emergency situations.
  • Security equipment should be maintained and tested to ensure that it works efficiently. Security auditor is checking the relevant maintenance logs and whether the Security Equipment Reports are properly performed and forwarded to the Company.

On completion of the audit, the auditor completes the relevant checklist form where he shall indicate the audit findings, any Non Conformities raised and any other critical observations. The report shall be forwarded to the Company Security Officer who reviews it and records any Non Conformities may raised.

One of the most important issues of the security auditing procedure is the audit results to be communicated to all employees, onboard vessels and ashore. The CSO is responsible to ensure that all Department Staff related to the system problem identified, is kept updated and informed. Besides, the scope of the whole procedure is to prevent any unfavorable situations and focus on future improvements.

International Register Of Shipping Conducts ISPS Code Training Course, our next session is at Lagos, Nigeria on 29/30 July 2019. For more details and registration of the course, Please contact training@intlreg.org

 

ISM Code Updates

By | Maritime Knowledge | No Comments
The purpose of the International Safety Management (ISM) Code is to provide an international standard for the safe management and operation of ships and for pollution prevention. The Code’s origins go back to the late 1980s, when there was mounting concern about poor management standards in shipping.

In 1994, the ISM Code was formally adopted and integrated as a part of the SOLAS Convention, while later in 1998, it became mandatory for oil tankers and bulk carriers, with general cargo ships to follow by 2001.

The ISM Code has been the most controversial among all shipping legislative documents. After 20 years of implementation, the industry still examines the effectiveness of the Code, as there are plenty of seafarers and shore staff who feel that ISM Code has only brought more paper work to daily operations. However, the general idea and the objective of the Code is to enhance safety culture based on a documented and assessed operation environment in which each one has a specific role and responsibility (both ashore and on board personnel).

The Code defines that ‘Company’ holds the responsibility to take over all duties imposed by the Code, incorporating SMS into normal business operations. It also requires internal & external audits, certificates, a Designated person who will be a link between ship and shore and clarifies levels of authority and lines of communications. These are also accompanied with  checklists, related forms and procedures.

ISM Code Amendments: Timeline

  • 1 July 2002: The ISM Code was initially amended by Resolution 104(73), adding definitions and chapter 13 to 16.
  • 1 July 2006: The ISM Code was further amended by Resolution 179(79), inserting new sections to the forms of the DOC (Document of Compliance) and SMC (Safety Management Certificate).
  • 1 January 2009: The ISM Code was amended by Resolution 195(80) , adding text to the forms of the full term and interim DOC and the SMC Certificates.
  • 1 July 2010: ISM Code Resolution 273(85) entered into force, introducing among others amended definitions, addition of cross references, risk requirements, specific intervals for implementation and SMS review effectiveness criteria.
  • 1 January 2015: The latest amendments by Resolution 353(92) entered into force, updating and crosslinking the existing IMO documents

Recognizing that no two shipping companies of shipowners are the same, and that ships operate under a wide range of different conditions, the Code is based on general principles and objectives,  including Part A (Implementation) and Part B (Certification and Verification).

As the Code states ”The cornerstone of good safety management is commitment from the top. In matters of safety and pollution prevention it is the commitment, competence, attitudes and motivation of individuals at all levels that determines the end result

Contents of Part A

  1. General
    • Definitions
    • Objectives
    • Application
    • Functional requirements for a Safety Management Systems (SMS)
  2. Safety and environmental protection policy.
  3. Company responsibilities and authority.
  4. Designated person(s)
  5. Master’s responsibility and authority
  6. Resources and personnel.
  7. Development of plans for shipboard operations.
  8. Emergency preparedness
  9. Reports and analysis of non-conformities, accidents and hazardous occurrences
  10. Maintenance of the ship and equipment.
  11. Documentation
  12. Company verification, review and evaluation

Contents of Part B

  1. Certification, and periodical Verification
  2. Interim Certification
  3. Verification
  4. Forms of Certificates

The Code is expressed in broad terms so that it can have a widespread application. Clearly, different levels of management, whether shore-based or at sea, will require varying levels of knowledge and awareness of the items outlined.

PART A

1.General

The following definitions apply to parts A and B of this Code

  • International Safety Management (ISM) Code : the International Management Code for the Safe Operation of Ships and for Pollution Prevention as adopted by the Assembly, as may be amended by the Organization.
  • Company: the Owner of the ship or any other organization or person such as the Manager, or the Bare boat Charterer, who has assumed the responsibility for operation of the ship from the Shipowner and who on assuming such responsibility has agreed to take over all the duties and responsibility imposed by the Code.
  • Administration: the Government of the States whose flag the ship is entitled to fly.
  • Safety Management System:  means a structured and documented system enabling Company personnel to implement effectively the Company Safety and Environmental protection policy.
  • Document of Compliance: a document issued to a Company which complies with the requirements of this Code.
  • Safety Management Certificate: a document issued to a ship which signifies that the Company and its shipboard management operate in accordance with the approved safety management system.
  • Objective Evidence: quantitative or qualitative information, records or statements or fact pertaining to safety or to the existence and implementation of a safety management system element, which is based on observation, measurement or test and which can be verified.
  • Observation : a statement of fact made during a safety management audit and substantiated by objective evidence
  • Non Conformity: an observed situation where objective evidence indicates the non-fulfillment of a specified requirement
  • Major non-conformity: an identifiable deviation that poses a serious threat to the safety of personnel or the ship or a serious risk to the environment that requires immediate corrective action or the lack of effective and systematic implementation of this Code*.

*Refer to the Procedures concerning observed ISM Code major non-conformities (MSC/Circ.1059-MEPC/Circ.401).

  • Anniversary date: the day and month of each year that corresponds to the date of expiry of the relevant document or certificate.
  • Convention: the International Convention for the Safety of Life at Sea, 1974 as amended.

1.2 Objectives of the ISM Code

1.2.1 The objectives of the Code are to ensure safety at sea, prevention of human injury or loss of life, and avoidance of damage to the environment, in particular, to the marine environment, and to property.

1.2.2 Safety management objectives of the Company should, inter alia:

  1. provide for safe practices in ship operation and a safe working environment,
  2. assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards; and
  3. continuously improve safety management skills of personnel ashore and aboard ships, including preparing for emergencies related both to safety and environmental protection.

1.2.3 The safety management system should ensure:

  1. compliance with mandatory rules and regulations, and
  2. that applicable codes, guidelines and standards recommended by the Organization, Administrations, classification societies and maritime industry organizations are taken  into account*

* Refer to the List of codes, recommendations, guidelines and other safety and security related non-mandatory instruments   (MSC.1/Circ.1371).

1.3   Application

The requirements of this Code may be applied to all ships.

1.4 Functional Requirements for a Safety Management System (SMS)

Every Company should develop, implement and maintain a Safety Management System (SMS) which includes the following functional requirements:

  1. a safety and environmental protection policy,
  2. instructions and procedures to ensure safe operation of ships and protection of the environment in compliance with relevant international and flag State legislation,
  3. defined levels of authority and lines of communication between, and amongst, shore  and shipboard personnel,
  4. procedures for reporting accidents and non-conformities with the provisions of this Code,
  5. procedures to prepare for and respond to emergency situations, and
  6. procedures for internal audits and management reviews.

2. Safety and Environmental Protection Policy

2.1     The Company should establish a safety and environmental protection policy which describes how the objectives, given in paragraph 1.2, will be achieved.

2.2     The Company should ensure that the policy is implemented and maintained at all levels of the organization both ships based as well as shore based.

3. Company Responsibilities and Authority

3.1     If the entity who is responsible for the operation of the ship is other than the owner, the owner must report the full name and details of such entity to the Administration.

3.2     The Company should define and document the responsibility, authority and interrelation of all personnel who manage, perform and verify work relating to and affecting safety and pollution prevention.

3.3     The Company is responsible for ensuring that adequate resources and shore based support are provided to enable the designated person or persons to carry out their functions.

*Refer to the Guidelines for the operational implementation of the International Safety Management (ISM) Code by Companies (MSC-MEPC.7/Circ.5).”

4. Designated Person (s)*

To ensure the safe operation of each ship and to provide a link between the company and those on board, every company, as appropriate, should designate a person or persons, ashore having direct access to the highest level of management. The responsibility and authority of the designated person or persons should include monitoring the safety and pollution prevention aspects of the operation of each ship and to ensure that adequate resources and shore based support are applied, as required.

* Refer to the Guidance on the qualifications, training and experience necessary for undertaking the role of the Designated Person under the provisions of the International Safety Management (ISM) Code (MSC-MEPC.7/Circ.6).

5. Mater’s Responsibility and Authority

5.1     The Company should clearly define and document the master’s responsibility with regard to:

.1       implementing the safety and environmental protection policy of the Company,

.2       motivating the crew in the observation of that policy,

.3       issuing appropriate orders and instructions in a clear and simple manner,

.4       verifying that specified requirements are observed, and

.5       reviewing the SMS and reporting its deficiencies to the shore based management periodically.

5.2     The Company should ensure that the SMS operating on board the ship contains a clear statement emphasizing the Master’s authority. The Company should establish in the SMS that the master has the overriding authority and the responsibility to make decisions with respect to safety and pollution prevention and to request the Company’s assistance as may be necessary.

6. Resources and Personnel

6.1     The Company should ensure that the master is:

.1       properly qualified for command,

.2       fully conversant with the Company’s SMS, and

.3       given the necessary support so that the Master’s duties can be safely performed.

6.2 The Company should ensure that each ship is:

.1 manned with qualified, certificated and medically fit seafarers in accordance with national and international requirements; and

.2 appropriately manned in order to encompass all aspects of maintaining safe operations on board*.

* Refer to the Principles of minimum safe manning, adopted by the Organization by resolution A.1047(27).

6.3     The Company should establish procedures to ensure that new personnel and personnel transferred to new assignments related to safety and protection of the environment are given proper familiarization with their duties. Instructions which are essential to be provided prior to sailing should be identified, documented and given.

6.4     The Company should ensure that all personnel involved in the Company’s SMS have an adequate understanding or relevant rules, regulations, codes and guidelines.

6.5     The Company should establish and maintain procedures for identifying any training which may be required in support of the SMS and ensure that such training is provided for all personnel concerned.

6.6     The Company should establish procedures by which the ship’s personnel receive relevant information on the SMS in a working language or languages understood by them.

6.7     The Company should ensure that the ship’s personnel are able to communicate effectively in the execution of their duties related to the SMS.

7. Development of Plans for Shipboard Operations

The Company should establish procedures, plans and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of the personnel, ship and protection of the environment. The various tasks should be defined and assigned to qualified personnel.

8. Emergency Preparedness*

8.1     The Company should identify potential emergency shipboard situations and establish procedures to respond to them.

8.2     The Company should establish programs for drills and exercises to prepare for emergency actions.

8.3     The SMS should provide for measures ensuring that the Company’s organization can respond at any time to hazards, accidents and emergency situations involving its ships.

*Refer to the Guidelines for a structure of an integrated system of contingency planning for shipboard emergencies, adopted by the Organization by resolution A.852(20), as amended.

9. Reports and Analysis of Non- Conformities, Accidents and Hazardous Occurrences*

9.1     The SMS should include procedures ensuring that non-conformities, accidents and hazardous situations are reported to the Company, investigated and analyzed with the objective of improving safety and pollution prevention.

9.2     The Company should establish procedures for the implementation of corrective action, including measures intended to prevent recurrence.

* Refer to the Guidance on near-miss reporting (MSC-MEPC.7/Circ.7).

10. Maintenance of the Ship and Equipment

10.1    The Company should establish procedures to ensure that the ship is maintained in conformity with the provisions of the relevant rules and regulations and with any additional requirements which may be established by the Company.

10.2    In meeting these requirements the Company should ensure that:

.1       inspections are held at appropriate intervals,

.2       any non-conformity is reported with its possible cause, if known,

.3       appropriate corrective action is taken, and

.4       records of these activities are maintained.

10.3    The Company should 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 of 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 10.3 should be integrated in the ship’s operational maintenance routine.

11. Documentation*

11.1    The Company should establish and maintain procedures to control all documents and data which are relevant to the SMS.

11.2    The Company should ensure that:

.1       valid documents are available at all relevant locations,

.2       changes to documents are reviewed and approved by authorized personnel, and

.3       obsolete documents are promptly removed.

11.3    The documents used to describe and implement the SMS may be referred to as the “Safety Management Manual” Documentation should be kept in a form that the Company considers most effective. Each ship should carry on board all documentation relevant to that ship.

*Refer to the Revised list of certificates and documents required to be carried on board ships (FAL.2/Circ.127, MEPC.1/Circ.817 and MSC.1/Circ.1462).

12. Company Verification, Review and Evaluation

12.1    The Company should carry out internal safety audits on board and ashore at intervals not exceeding twelve months to verify whether safety and pollution prevention activities comply with the SMS. In exceptional circumstances, this interval may be exceeded by not more than three months.

12.2    The Company should periodically verify whether all those undertaking delegated ISM related tasks are acting in conformity with the Company’s responsibilities under the Code

12.3    The Company should periodically evaluate the effectiveness of the SMS in accordance with procedures established by the Company.

12.4    The audits and possible corrective actions should be carried out in accordance with documented procedures.

12.5    Personnel carrying out audits should be independent of the areas being audited unless this is impracticable due to the size and the nature of the Company.

12.6    The results of the audits and reviews should be brought to the attention of all personnel having responsibility in the area involved.

12.7    The management personnel responsible for the area involved should take timely corrective action on deficiencies found.

International Register Of Shipping is conducting 02 days  ISM Code Auditing Maritime Management Systems Course, our next session is at Lagos, Nigeria on 25/26 July 2019. For more details and registration of the course, Please contact training@intlreg.org

Maritime Knowledge – Bringing the ISPS Code into practice

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According to the ISPS Code, all ships must have Ship Security Plan (SSP) on board, including all safety measures to be  applied by the crew at each stage of safety.Also, SSP should demonstrate the restricted areas and provide guidelines for an effective implementation of the Code, with Risk Assessment forms and checklists to be used by key personnel during several activities on board.

Identifying the Key personnel

The key personnel are responsible for the implementation of ISPS requirements on vessels. Designated persons are placed by the company and each of them is committed to act accordingly in order to ensure vessels’ security.

Personnel involved with the implementation of the security requirements onboard are: Company Security Officer (CSO) who is responsible of ISPS implementation within Company and managed fleet; Ship Security Officer (SSO) who is responsible of ISPS and approved Ship Security Plan implementation on board and the; Master who is the ultimate authority on board the ship.

Important tips for effecting implementation

A.   Access Control

Access points of the vessel should at all times be secured and used only for the specific purposes. When pilot ladder or rope ladder is in use weather the vessel is at sea, at anchorage or in port, the embarkation area should be supervised at all times for the period the ladder is in use and further securely folded in its position on completion of its use.

Gangways should, at all times when at anchorage, be heaved up and lowered only when necessary for embarkation/disembarkation. When gangways are lowered a watch shall be positioned by the gangway for supervision and control of embarkation. When at port, whether the gangway is provided by the vessel or by shore side a watch shall be positioned at all times, controlling and logging boarding and disembarkation of persons and crew.

When at anchorage or in port access doors should be limited to a number sufficient of the vessels capability of control and supervision which at the same time will not pose a threat, in the event of an incident, to the safety of the crew and vessel.

Ropes and Chains are particularly vulnerable usually due to lack of supervision and lighting. When at anchorage, anchor chain hawse pipes should be capped and a patrol should be placed to cover the forecastle at regular intervals. When alongside, ropes and springs should be fitted with rat guards, chain hawse pipes capped and a patrol to monitor the areas aft, fore and midship should be appointed with intervals dependent on the security level of the vessel and the probability of an incident/breach occurrence.

When the vessel is at anchorage or at port, a watch is appointed by the Ship Security Officer. The Watchman shall at all times be equipped with a walkie-talkie, a flash light, and Safety clothing. All communication shall be performed via walkie-talkie, the watchman is not to leave his position under any circumstances, unless replaced.

B.  Vessel search

The restricted areas on board and areas surrounding the ship shall be monitored at all times. Such monitoring capabilities may include use of lighting watch-keepers, security guards and deck watches including patrols, and Shore / boat patrols in cooperation with the port facility. The Ship Security Plan should include a “Vessel Search Checklist” to assist the monitoring operations. In order to be easily used by the watch-keepers and patrols, “Vessel Search Checklist” should sort the searching areas, as suggested for example, into three Areas:

Area 1: Accommodation

Area 2: Engine Room Spaces

Area 3: Deck – Holds

At security levels 2 & 3, searches shall be conducted:

  • In accordance with Port Facility requirements (whilst at Port / Anchorage)
  • As per Master’s discretion with respect to partial or full extent of ship’s search
  • As may be instructed by Company

C.  Restricted area control

Any unauthorized presence within restricted areas constitutes a breach of security. Adjoining areas to restricted areas will be manned /patrolled when visitors have authorized access to restricted areas. Any other areas as may be determined by the CSO though the SSA to which access must be restricted to maintain the security of the ship must be taken into consideration.

D.  Stores and deliverables check

The security measures relating to the delivery of ship’s stores should:

  • ensure checking of ship’s stores and package integrity
  • prevent ship’s stores from being accepted without inspection
  • prevent tampering, and
  • prevent ship’s stores from being accepted unless ordered

All stores & provisions are subjected to visual and physical examination, in accordance with the appropriate security level. All stores are subject (when search is ordered) to checks for the presence of weapons, ammunition, incendiary and explosives and narcotic substances.

E.  Documentation Control

Security Controlled Documentation includes but not limited to the following:

  • Ship Security Plan
  • Ship Security Assessment (incorporated in the relevant section of the Ship Security Plan)
  • Continuous Synopsis Records

The Company Security Officer in co-operation with the designated Ship Security Officer is responsible for the periodic review of the Ship Security Plan and the Ship Security Re-Assessment at least once per year. The review of the plan is essential in order to ensure that is suitable for the vessel, crew, cargoes, area of trade etc. The Company Security Officer is responsible to ensure that the forms are available onboard vessel. Furthermore, he is responsible for the issue, revision and distribution of all new or revised forms and the updating of the Controlled Documentation List.

All records produced in support of the Ship Security Plan and which demonstrate either compliance to specified requirements or the effective implementation of the ISPS Code shall be kept in specific files both on board and office. Records should be available to duly authorized Officers of Contracting Governments to verify that the provisions of the SSP are being implemented.

Ship Security Officer and Company Security Officer are responsible to ensure that all data/records produced by Ship Security Plan implementation, ashore and onboard, are retained for a period of at least the Flag Administration’s demand, or five (5) years, whichever comes last.

F.  SSAS regular test

There are two ways of testing the SSAS:

  • Testing of the alert buttons
  • Test transmission

Each flag registry sets the frequency and the way that periodical testing should be occurred. For example, operators and/or owners of the Panamanian registry vessels through the CSO have the responsibility to schedule, -not less than 3 days before- through the platform, the annual tests of SSAS TEST in a period no longer than twelve (12) calendar months. The Republic of the Marshall Islands Maritime Administrator does not receive SSAS alerts directly from any vessel.

The CSO receives and verifies SSAS transmissions. Furthermore, the CSO acknowledges and responds to all test messages directly, ensuring the proper functioning of SSAS equipment and verifying the accuracy of the transmitted data without the need for acknowledgement of receipt by the Administrator. The M.I. Maritime Administrator involves to only those SSAS transmissions that are real alerts on unresolved alerts, which are to be immediately forwarded by the CSO to the administrator.

G.  Drills & briefings/training

Company CSO has attended relevant training courses by a training facility recognized and endorsed by the Administration or an RSO designated by the Administration. It is the Company Security Officer’s responsibility to ensure that appropriate shore-based personnel (including himself) and the designated Ship Security Officer has received appropriate training in accordance with guidance given in the ISPS Code Part B.

All other shipboard personnel and shore-based personnel visiting ships should have sufficient knowledge of and be familiar in accordance with guidance / requirements given in the ISPS Code Part B with relevant provisions of the SSP.

International Register Of Shipping Conducts ISPS Code Training Course, our next session is at Lagos, Nigeria on 29/30 July 2019. For more details and registration of the course, Please contact training@intlreg.org

Maritime Knowledge – Summary of ISPS Code Implementation

By | Maritime Knowledge | No Comments
The sea is a very vulnerable place with easy access to terrorist and pirate attacks, as there are not any boarders or limits to the activities taking place at the ocean and open seas, thus mariners face a big threat even if they operate at ports or onboard vessels. As an act to defeat one of the most challenging dangers of nowadays, IMO, under SOLAS Convention Chapter XI-2, developed the International Ship and Port Facility Code – the ISPS Code, a comprehensive set of measures to enhance the security of ships and port facilities.

The Code was adopted on 12 December 2002 and came into force on 1 July 2004; it is applicable to all vessels over 500 GRT operating on international trades, as well as the ports that service them.

ISPS Code: Key elements

ISPS Code is divided into two sections: Part A, which is a mandatory section, includes the maritime and port security-related requirements which should be followed respectfully by the governments, port authorities and shipping companies, while Part B provides guidelines on how to meet these requirements.

The main objectives of the ISPS Code include:

  • enables the detection and deterrence of security threats within an international framework
  • establishes roles and responsibilities
  • enables collection and exchange of security information
  • provides a methodology for assessing security
  • ensures that adequate security measures in place

Scope of ISPS Code is to ensure that adequate security measures are followed on board ships and in ports as well.

Except for the non-mandatory Part B, ISPS Code is framed by a variety of related IMO resolutions, circulars and letters, which actually are guides to be used by port facility personnel, company personnel or on-board personnel with security duties, assisting their activities.

Key personnel

Responsible for the implementation of ISPS requirements is the designated personnel established by the Code. The personnel assigned with these duties is in charge to assess, prepare and implement the effective security plans in order to prevent or manage accordingly security threats.

  • The Port Facility Security Officer (PFSO) is an authorized officer at port who is responsible for the development, implementation and maintenance of port facility security plan. PFSO is also responsible for liaison with the SSO and CSO.
  • The Ship Security Officer (SSO) is an authorized person on board the ship, designated by the company and is responsible to implement and maintain the ship security plan and the overall security of the ship. Also, is responsible to contact with other designated persons, PFSO and CSO.
  • The Company Security Officer (CSO) is a person designated by the company and is charged with the duty to ensure that ship security assessment is carried out properly. Moreover, is responsible to develop the ship security plan, submit it for approval and ensure that it is implemented as appropriate. Last but not least, CSO is responsible to communicate with the SSO and PFSO.

ISPS Code: Challenging areas

By the time it officially adopted in 2004, ISPS Code has arisen some questions concerning its implementation.

A very common issue related to ISPS Code has mostly to do with the relationship between it and the ISM Code about which is more important – safety or security? In shipping, both safety and security are equally needed. However, the implementation of both Codes means additional costs for operators and sometimes this leads to a dilemma on what is more important to be maintained.

In general, an operator could have a secure ship that is not safe, which in turn could lead to the ship being lost, no matter how secure it is. On the other hand, if the ship is not secure, it can be lost due to acts of piracy and other related matters. If in the professional judgement of the Master, a conflict between any safety and security requirements applicable to the ship arises during its operations, the Master shall give effect to those requirements necessary to maintain the safety of the ship. In case of conflicts between safety and security “SAFETY” prevails to security as per ISPS code.

Another challenge related to the security of the fleet is the actual absence of an official monitoring procedure regarding security issues, as there are not Office audits conducted from internal or external, like ISM audits. This also happens with PSC inspections. Except for USCG ports where PSC officers focus on security items, inspections at other ports worldwide seem to pass by security issues. This handling of security parameters results in the neglect of the security practices by vessels’ crew and even by the operating company.

There should also be noted that because of the numerous confidential information included in Ship Security Plan, sometimes maintenance, amendments and revision are difficult to take place.

Furthermore, since ISPS code is based on 9/11 outcome and the early piracy activity in the area of Somalia, no amendments or revisions have been made to the code and new types of security threats have not been identified and incorporated (i.e. attacks on Tankers in the area of Persian gulf, Hormuz straight etc).

International Register Of Shipping Conducts ISPS Code Training Course, our next session is at Lagos, Nigeria on 29/30 July 2019. For more details and registration of the course, Please contact training@intlreg.org

 

INTLREG – Expanding our operations at Philippines

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IntlReg is expanding surveyor network at Philippines with authorization  for domestic as well as
International vessels with the approval of  MARINA (Maritime Industry Authority).

Our Services include:
  • Classification & Statutory Surveys
  • ISM Internal & External Audits
  • New Build Services

Contact our Station Manager at Philippines for more details:

Engr. Felicisimo.L, Serato Jr.
Mob: +9178857759
Landline: +6325193568
Email: philippines@intlreg.org

INTLREG to attend PHILIPPINES MARINE (PHILMARINE) 2019

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The 6th Edition of PHILIPPINES MARINE (PHILMARINE) 2019 co-located with Shipbuild Philippines and Offshore Philippines 2019 is the only specialized maritime, shipbuilding, and offshore event in the Philippines that brings together an international congregation of maritime, shipbuilding, offshore, and their supporting industries gathered in the capital of Manila to showcase the latest developments in the maritime industry, to improve the current shipbuilding technology, and to equipment to help maintain the Philippines’ current status as the world’s #4 largest shipbuilding industry.

Come join us – your most reliable partner for the Maritime World #INTLREG at Booth No. 230 at SMX Convention Centre Manila, Mall of Asia Complex, Pasay City, Philippines.

Updated marine regulations you need to know about in 2019

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SOLAS damage stability, EU MRV and IMO DCS and MARPOL ANNEX
VI: To prepare and comply with what you need to know.

2019 is a busy year with the adoption of the International Maritime Organization (IMO)
regulation with the forthcoming SOLAS amendments, significant milestones for the data
collection system for fuel oil consumption (DCS) along with the EU regulation on monito
ring, reporting and verification (MRV) and the entry into force of the MARPOL Annex VI
Global Sulphur Limit in January 2020.Here is why these regulations are important to
ship-owners and operators.

Amendments to SOLAS Chapter II-1 on damage stability

Chapter II/1of the SOLAS amendments to harmonize the damage stability of cargo and p
assenger ship came into force in 2009.This made probabilistic damage stability the main
method for calculating the damage stability for passenger vessels and general cargo ves
sels. Once the amendments came into use, the need for a number of revisions became
apparent, so the IMO undertook a major review of the subdivision and damage stability
requirements in Chapter II-1 of SOLAS. Significant changes include, amongst others:

  • Requiring limiting stability information to include trim.
  • Modifying the required subdivision index, R, for passenger ships.
  • Amending the calculation for S factor.
  • Providing limits on the distance between small wells and the keel line unless a
    damage stability check is made and introducing a minimum limit for the vertical
    damage extent. Permitting a butterfly valve at the collision bulkhead on cargo
    ships.
  • Requiring testing of watertight hatches.
  • Requiring air pipes which terminate in a superstructure to be considered
    unprotected openings unless fitted with a watertight means of closure.
  • Removing the possibility of leaving watertight doors open.

These amendments need to be taken into account in the design of ships contracted from
1 January 2020.

Monitoring and reporting of fuel oil consumption and CO 2 emissions

2019 brings significant milestones in both the EU’s MRV regulation and the IMO’s fuel
oil consumption DCS requirements under MARPOL Annex VI. For EU MRV, the first year
of monitoring ended in 2018 and the first reporting is taking place in early 2019. For
IMO DCS, 2019 is the first monitoring period. In order to comply with the IMO DCS
requirements, each affected existing vessel’s Ship Energy Efficiency Management Plan
(SEEMP) will by now have been updated with a new Part II to provide the ship-specific
methodology and processes to be followed for the data collection. New ships will need
to have this upon delivery. After verified data has been reported, it will be transferred to
the IMO Ship Fuel Oil Consumption Database where it will be kept anonymised. This will
help the IMO to produce annual reports and evaluate the need for further technical and
operational measures for enhancing the energy efficiency of international shipping.

For ships subject to the EU MRV regulation, the first monitoring period has now finished
and the collected monitoring reports need to be submitted for verification. For LR
clients, all documentation (monitoring plans and emission report evidence packs),
except emission reports, should be submitted to CO2 Verifier. The regulation requires
that clients submit emission reports directly to THETIS-MRV, which is operated by the
European Maritime Safety Agency (EMSA). As the accredited verification body, LR will
then retrieve the reports from THETIS-MRV for verification and upload them to CO2
Verifier along with related LR deliverables.

Global fuel sulphur limit reduction to 0.50% and associated carriage ban

From 1 January 2020, MARPOL Annex VI will require all new and existing ships to
comply with the new global 0.50% sulphur limit using the most appropriate method for
that ship. The options include low sulphur fuels and alternative fuels, or alternative
arrangements such as an exhaust gas cleaning system (also known as scrubbers). The
global limit means that this applies to all areas outside of Emission Control Areas
(ECAs). Unless a ship has an alternative arrangement such as a scrubber, shipowners
and managers will need to consider debunkering any high sulphur fuel oil that is not
used up before 1 January 2020. The IMO has also adopted a requirement to prohibit
ships from carrying fuel oil with a sulphur content above 0.50% if its purpose is for
combustion for propulsion or operations on board, unless the ship has an approved
equivalent arrangement in place. This is to help support full global compliance. Due to
the IMO procedural requirements for amendments to MARPOL, this will enter into force
on 1 March 2020, but it is worth clarifying that this does not change the sulphur limit
reduction date.