7.
Is the lack of initial training the root cause of this disillusionment?
In the training centres they propose sometimes an inhouse training as the corresponding IMO model course does not exist. Well, but it's amazing. IMO has accustomed us in the STCW code to put everything in the shape of a table including knowledge, understanding, proficiency to be acquired as a result (KUP) for all the subjects of our trade except for the ISM code which is drowned in general training!
- The ICS “Guidelines for the application of the ISM Code” was the first and the last valid information document on the application of the ISM code (4th
edition today).
These instructions, intelligently, state that "the task of implementing and maintaining SMS is a line management responsibility (while) monitoring activities must be carried out by a person independent of the responsibility for implementation" - (page 16 of the 1996 edition).
- Philippe Anderson, courageously, it must be said, studied the code well from the beginning by publishing his books. Remember, his analysis in "cracking the code" published
8.
in 2003, he noted: "The full meaning of the role of the designated person ashore is still far from clear. There is still much speculation about the role and legal exposure of the DP among lawyers and academics, but to the extent that the author is aware, there have been no court
decisions providing clarification on the area of doubt. The author is also not aware of possible lawsuits against a DPA by the (British) Courts!". NB. He has unfortunately completely forgotten the training part!
- In most of the syllabus of the ISM courses I've studied, not many of them have really understood the role of the DPA, even if some made a great effort thanks to the support of the IMO circular of 2007 ("Guidelines on qualifications, training and experience of the DPA") and the other in 2013 for its responsibilities. They are clearly expressing "check and monitor aspects of the operation of each vessel, related to safety and pollution prevention" or the designated person "must ensure the effective enforcement of the safety management system." It is therefore a job of verification and monitoring for an existing management system and not application or implementation of the system itself that belongs to the management and its directors involved.
All of this smells of a scam doesn’t it?
The ISM code is already more than 30 years old, and it is already remembered more that the quality assurance of safety management is based on a structure of verification and monitoring even if Lord Justice SHEEN had deemed "it necessary the presence of a sailor in the organization ashore" thing which was already in use everywhere in the world, except in the Townsend Thoresen company at that time apparently!
We often see this terrible misunderstanding, which is to confuse the enforcement officer and the verification officer, who must be necessarily independent of the operational sector of the first. It's still quite amazing that we invent the designated person with a major original function and then we forget it - to maybe allow all companies to work - do you know many companies that have been removed from the DOC for non-compliance on the DPA?
Shipowners, lawyers, fleet-managers all have the same fight! In a state of slight paranoia, you could say that it is a conspiracy, yes a conspiracy but to protect who?
Indeed, it is. On the one hand, we follow the proponents of a DPA completely responsible for safety which leads towards new disasters because nothing can avoid the laxity of the manager in charge (as at Townsend Thoresen line) when modern management standards require a monitoring close to control for quality insurance, in addition to the control of production (equipment or services) itself. And on the other hand, while the arrival of artificial intelligence (AI) pushes us to review the basics and content of the seafarers of the future’s basic training, it would be good to admit our original mistake which was not to include specific ISM training in STCW and finally include it with a special section in the STCW code with model courses and certification.
So, the STCW code needs a review by introducing specific training on the ISM code. This shouldn't be too hard finally, but that does not mean that all IMO members will sign up easily, far from it!
THE REPORT | DEC 2024 | ISSUE 110 | 101
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