LETTER TO THE EDITOR Dear Sirs,
Having read “ISM Code: The Maritime Scam of The Century” by Hon FIIMS, Past President Mr. Bertrand Apperry, in The December 2024 report, I decided to express my opinion regarding some aspects of the above-mentioned article.
First, I would like to thank the author because of the main conclusion – the ISM Code to be revised based on the 30 years of its implementation experience. As a marine principal surveyor and ISM/ISPS/MLC lead auditor/ inspector of the leading RO (30 years of activity) I think that I can express my opinion about problems pointed out in the article.
1. Introduction: Why have we created the ISM Code?
Comment: In 1993 LR organized in the Odesa Institute of Marine Engineers, Ukraine, presentation of the ISM Code for local shipping companies, mariners, etc. The speaker was Capt. Burney from LR HQ. In the very beginning of this presentation, he said that IMO did an analysis of the ship’s accidents and concluded that 70% is in the West part of the world and 30 % is in the East part of the world (At that time it was the Cold War). What was the reason for such results? That time crews of the East countries were only citizens of these countries and only one working language was used on board. The planned maintenance scheme and drills were on the top of the Captain and Chief Engineer concern. Many ships had two crews – one at sea, second on vacation, crew members considered their vessel as their second home and there was not any experience regarding cheap crew from another country.
2. The weak points of the Code and its application.
Comment: Audits by RO on board consists of two parts – documents review (in the ship office and engine room office) and tour on the ship, supervision of the drill, interview of the seafarers. DPA and CSO are not always on-board during audits. Now ISM/ISPS/MLC audits/inspections are planned for a few man-days and may be done by at least 1 or 2 auditors to manage audit during one visit (especially it is important for container vessels, tankers, car carriers). Sometimes the PSC officer is on board, and it may increase the time of the audit. According to ISM Code company to be audited annually, vessels – one time for a 5-year period. During 2-3 years on board many crews changed, some LSA, FFE, emergency, security equipment may be changed without appropriate reflection in the SMS or SSP. Such a situation is not a rare one on board now.
3. Final Conclusion.
Comment: I did not touch on some problems mentioned in the article regarding training, company responsibility, captain’s responsibility, etc. As a conclusion I can say that the ISM Code to be revised based on all criticism that may be expressed. Vessel audits to be done annually. DPA and CSO must attend at least one of the vessel's annual audits. Responsibility of the DPA and CSO to be in some items increased and it has to be reflected in the scope of the DPA and CSO training programs and certificates.
Best Regards, Oleksandr Ryzhkov Marine surveyor/auditor Odesa, Ukraine
Letter THE REPORT | MAR 2025 | ISSUE 111 | 35
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