ISM CODE
- There is no willingness from the ROs to see the companies putting in place an effective internal audit system that would take away any usefulness from the RO and some power from the Flag Administration.
- We use more and more heterogeneous crews than ever, for cost reasons firstly, so significant difficulties to apply a company safety culture appear (M/S COSTA CONCORDIA Syndrome).
- Procedures are always unknown by crew members. At every accident there is always a lack of knowledge of the procedures, which is not explained, except to suspect officers to "keep them to themselves" and to leave the Filipino or Indonesian "rating" away (M/T BOW MARINER Syndrome).
- The "reporting" required by chapter 9 of the code is never encouraged in a company's SMS, perhaps to reduce paperwork - except in the offshore and oil industry, however with sometimes a rather strange obligation of a minimum number of "near-misses" per month? Or maybe there is another more subtle reason? (See later).
- ISM training still does not really exist. It is rare for the DPA, absent for internal auditors and crew members, weak in training schools and almost absent elsewhere, even at the Master’s level. What's the reason? The cost perhaps. (LOW-COST Syndrome).
- An SMS can lead to false confidence because the shipowner thinks he is getting away with issuing a large number of technical manuals to help the crew to apply the procedures, except that the crew never reads them and therefore doesn't apply them! So, we often still work as before.
- Continuous training, essential for the maintenance of knowledge, is generally poorly organized and it was even necessary to wait until 2017 in some countries to realize the revalidation of the essential knowledge of the sailor - all knowledge, except those on the ISM of course! This is finally a major non-conformity with the SOLAS convention.
- The company's and crews’ preparations for responding to any emergency have remained at a basic SOLAS level which appears at each accident as the major cause of crew members or passengers’ casualties. Indeed on board, due to rehearsals, you can perform a minimum of safety exercises in a soft manner as on a simulator. (We often simulate simple operations like cutting the arrival of fuel to MPs for example instead of really doing it) and then we let you work your imagination to simulate an extension and escalation of the incident! So, dubious on the effectiveness of drills and exercises which are supposed to enter in the continuous training (M/V NORMAN ATLANTIC Syndrome).
- Even if all, or almost all of the ISM code chapters start with "the Company should”, no other text clearly specifies the responsibility of the company manager contrary to the Master. During the trial of the COSTA CONCORDIA accident (2014) the
application of the ISM code was only touched on and even if the liability of the company was highlighted, only our colleague Francesco Schettino goes to prison. So, still no will preventing the Master from always being the best scapegoat (HOFE Syndrome).
- Internal audits which are the fuel of an SMS, are always sloppy by companies because, as external auditors consult the reports, internal auditors are asked to do a soft audit in order to avoid double punishment. This is the "not seen, not caught" syndrome which has the opposite effect of the desired target!
- There is no desire to clarify the role of the DPA which for many Companies remains unclear and this prevents it from coming in the legs of the transverse directors of the various departments with the terrible possibility of shunting them and going to the big boss directly. (DPA syndrome).
- An ISM Chapter 7 "Shipboard operations" far too short seems to forget the main operations of the ship that are the conduct of the ship's navigation in all conditions and commercial operations in port (S/S EL FARO Syndrome).
- In the Flag Administrations, attempts have been made to take the ISM certification with the seriousness it deserves, it must be acknowledged. But for reasons, mainly of ignorance of the subject, the applications of certifiers were not numerous and therefore the choices were limited resulting in poor flag lead auditors sometimes acting in an atmosphere of general disinterest. Other more cautious flags have let the ROs taking care of it, and thus leave it to the specialists of the ISM code but, more engineers or naval architects than sailors who are unfortunately often not competent enough for management. (RO Syndrome).
- The main error in the application of the ISM, the parallel with ISO 9000 standards, was fatal. This standard being mostly administrative, in contrast to the ISM code, which claims to play on the human factor, this parallel was the origin of SMS in the form of a mountain of paperwork, which instinctively pushed the sailor back. To reinforce this very bad image, we continue to train ISM certifiers as ISO inspectors, and we have come to this glaring anomaly of wanting to ensure a safety culture of excellence through an administrative quality process which is the opposite of the operational seafarer’s culture (ISO 9000 Syndrome).
- The ISM code has failed to clarify the fuzzy passages of maritime safety such as the difference between the safe manning crew and the muster list; on the one hand a theoretical minimum crew that has nothing to do with safety versus a crew always ready to respond to any emergency situation which is one of the objectives of the code. (SMC Syndrome).
- Presented to the seafarer by people with no experience at sea, as something new that would finally teach him/ her his/her job, the ISM code provoked a reaction of rejection sometimes very strong among Masters and other seafarers who had great experience at sea. (THIS WAS BETTER BEFORE Syndrome).
THE REPORT | DEC 2024 | ISSUE 110 | 97
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