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The multiple goals of the SMS


Safety is often perceived as a standalone goal isolated from the wider activities and functions of the organisation. This is evident when designing a ‘safety management system’ as required under the ISM Code which is primarily focused on ensuring safety (and environmental protection). However, managing safety risks is not the end goal of any organisation. Rather, they are often looking to control the absence of safety for economic and reputational reasons. It is here we need to take a closer look at the ambiguous nature of checklists and procedures.


The paradox of self-regulation


A key purpose of the ISM Code was to move away from a prescriptive regulatory framework established by external authorities towards selfregulation. Instead, the ISM Code would allow companies to design a safety management system that was best suited for their requirements with minimum interference from regulatory and commercial bodies. Ideally this would mean that procedures and checklists were designed to reflect the specific nature of each ship and shipboard operations.


In practice, however, this is far from achievable. For example, the charterers may require a certain task, checklist or an entire procedure to be added to the safety management system. In the example checklist on the previous page, the requirement to carry out a ‘risk assessment’ or ‘toolbox talk’ may not be there for operational reasons, but due to a specific legal or contractual requirement. An increased number of checks may even be required in order to look good to the customer. Similarly, if a charterer has requested (but not mandated) a certain checklist or procedure, it may be included in the spirit of ‘good customer relationships’. However, since the task was introduced for non-operational reasons, its presence may not always make sense to the seafarer.


This is the paradox of self- regulation, and explains why a safety management system designed to move away from prescriptive regulations and towards goal based self-regulation may not necessarily meet its original intentions.


Responsibility aversion


The ISM Code acknowledges the problem of allocating responsibility for the SMS to the Master of the vessel alone. The Code requires every company to appoint a Designated Person Ashore (DPA) with the overall responsibility of monitoring the safety of the entire fleet. But the allocation of responsibility becomes problematic when the end goal is to manage safety risks. In the event of an accident the decisions and competence of those responsible for managing safety ashore come under scrutiny.


One ‘solution’ to the problem lies in designing generic procedures and then leaving it up to the seafarer to decide between what is relevant and what could be left out as not applicable (N/A). There are practical reasons for this as well. Since procedures cannot always be designed for every conceivable situation, keeping them generic and open-ended allows companies to reduce the level of documentation within the safety management system. All this creates discretionary space for the end user of the procedure (in this case the seafarer) to manage the gap between what can be thought out and documented in procedures and what really happens in an uncertain, dynamic work environment.


In most cases the seafarer will succeed in bridging this gap effectively. However, in the event of an undesirable outcome such as an accident, the generic nature of procedures also creates ample buffer space for the shorebased office. The investigation inevitably points to the seafarer,


demanding that they should make better choices within the same discretionary space, while leaving aside the capabilities and competencies of those responsible for the design and implementation of the checklist. The ISM Code is intended to ensure that the responsibility for safety management is effectively shared between the ship and the company. However, an undesirable outcome may lead to risk and responsibility aversion from the shore side, especially when safety risks are meshed with commercial and reputational risks.





When professional


judgement is replaced with checklists, seafarers adopt a casual approach to these control measures


The missing link


A careful examination of the sample checklist shows how responsibility is pushed downstream. While certain checks spell out clear expectations (for instance ‘AIS updated’), others are ambiguous and open-ended, such as ‘radars’, ‘GPS’, ‘auxiliary engines/generator’, ‘window wiper’ and ‘auto-pilots’. This missing text raises doubts over what is considered to be a ‘completed check’. For instance, if the auxiliary engines fail to perform prior to departure from port, does this mean that the vessel will be held up in port until the problem has been rectified? And what if one of the window wipers does not operate? How is the seafarer expected to react to this situation given the limited options on the checklist – tick off or decide it is not applicable?


The Report • March 2018 • Issue 83 | 51





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