What Are We Waiting Forism

This article was originally written for Maritime Risk International By Dr Phil Anderson Managing Director ConsultISM Ltd
What are we waiting for?

At the 81st session of the IMO Maritime Safety Committee a report was presented under the title: Study on the Impact of the ISM Code and its Effectiveness in the Enhancement of Safety of Life at Sea and Protection of the Marine Environment. This was an extremely important report for the entire shipping industry throwing down a range of crucially important challenges to the industry. I believe it is of vital importance that the industry rises and responds to those challenges. We must not allow this report to be filed away in the IMO archives. The report was the result of a research project which was undertaken between November 2004 and 2005. The Secretary General of IMO, Admiral Efthimios Mitropoulos deserves due credit for his splendid initiative in pulling together a very high calibre group of industry experts who worked with a team from the IMO Secretariat and researchers from the World Maritime University. I had the honour and privilege to be included in that team. Following on from a major piece of research I had undertaken four years previously 1 the IMO Independent Group of Experts developed and distributed four questionnaires for : Shipboard personnel Shore-based personnel Shipping companies, and Administrations They also solicited advice and information from Port State Control and the International Group of P&I Clubs. The agreed objectives of the project were to identify: Trends in safety and pollution prevention; and ] Impact of the ISM Code The response to the questionnaire was mixed such that 3,000 seafarers shared their thoughts but only 89 shore based personnel responded. It was conceded by the Group that meaningful hard evidence was not going to come forward which would prove in a quantitative way whether ISM was having an impact or not. Indeed it was recognised that there had been a number of other factors, in addition to the introduction of the ISM Code, which would have to be taken into account, in interpreting and analysing any statistical data. Accordingly, most of the data collected
1
Details and findings are set out the Nautical Institute publication Cracking the Code Published 2003 - ISBN 1 8700 77 63 6 Obtainable through the Institute Website www.nautinst.org
and used to prepare the report tends to be subjective opinion of the individuals who responded. That was not meant as a derogatory statement for indeed the views of those at the sharp end involved in the implementation process is extremely valuable and important in producing the qualitative findings. When I undertook my own detailed survey in year 2000, which was between the Phase 1 and Phase 2 implementation deadline dates, I was also unable to secure meaningful hard data and thus was also reliant on the soft subjective input from individual experience. However, there was a significant and import difference between the results I obtained and the results coming out of the IMO Group project. Most of the respondents to my survey were ranging from quite negative to strongly opposed to the ISM Code whereas the latest survey showed the overwhelming majority very much more positive and in favour. Although the latest results do come with something of a warning label attached from the IMO Group it was recognised and conceded that the respondents were probably not a truly representative sample from across the industry. However, I do not believe that should in any way detract from the importance of this IMO report which I believe should be disseminated and read very widely across the entire industry. Taking cognisance of comments and observations received from respondents, the IMO Group report identified a number of issues which appear to be presenting a barrier to the successful implementation and development of the Code and suggests a number of ideas which could be addressed in a further study at a later date. I would suggest that the industry should consider this as a gauntlet thrown down by IMO and we should be prepared to respond to this challenge and address these issues now. I would therefore like to consider some of the main conclusions and recommendations and suggest a possible way to maintain the momentum and move forward for the benefit of the industry and for the safety of ships and seafarers and the protection of the marine environment. The IMO report drew the following conclusions: Everyone agreed that, where the ISM Code is embraced as a positive step toward efficiency through a safety culture, tangible positive benefits are evident; ISM Code compliance could be made easier through a reduction in the administrative process by: streamlining and reducing the paperwork that supports ISM Compliance, particularly the SMS; the greater use of technology and IT to reduce paperwork; identifying common areas in the ISM Code and for example the ISPS Code and integrating documentary requirements;
motivating seafarers to use the reporting and monitoring systems in the improvement of safety management systems; involving the seafarers in the development and continuous improvement of ISM manuals; increased integrated training for all concerned; exploring measures to reduce the cost of compliance; and improving ISM compliance monitoring and developing performance indicators; and The impact of port State control in this area was not explored but certainly appears to merit further study. The following Recommendations were put forward by the Group: A further study should be undertaken, at a later date, specifically to examine: cause and effect between ISM implementation and flag State safety record; the relationship between port State control and ISM compliance; and whether textural changes in the requirements of the Code could make compliance easier and lead to an improved safety culture, In response to data produced in this study: methods to streamline the implementation of the Code through technology and increased use of IT should be explored; the alignment of ISM and ISPS in shipboard documentation should be considered; a reduction in paperwork should be encouraged; guidelines for Administrations should be revised to make them more user friendly; and new guidelines to assist companies to implement the Code should be developed, The results of the study be given widespread publicity across the industry in order to show how positive attitudes to ISM can yield tangible operational, financial and safety benefits. I suggested earlier in this article that the shipping industry should respond I would go further and suggest that the Administrations, Insurers, P&I Clubs and Classification Societies should participate - in a very direct and meaningful way. This
is not to suggest that the IMO would not have the ability to respond themselves but the reality is that to respond quickly and effectively will require full and adequate resourcing particularly funding which, unfortunately is in short supply at IMO. For progress to be made in the next phase of this important research will require, in my view, a much smaller multi-disciplinary group of industry experts who would undertake the work in conjunction with IMO and perhaps WMU. The next phase will require going beyond questionnaires and involve direct meetings with shore based and shipboard key players to identify industry best practice to identify and study safety management systems which are working well and understand why they have been successfully implemented whilst others have perhaps not produced the desired results. I am aware of ISM systems which are working very well and which have successfully reduced paperwork to manageable levels and have profitably introduced technology to assist with data recording and for information retrieval. I have also seen attempts made to reduce paperwork and introduce technology where it was not at all successful. I do not believe there will be found one single blue-print which will be suitable for all ship operating companies in all situations however, I have come to the conclusion, from my own observations, that some companies do require more of a helping hand than is presently provided in the general guidance of the ISM Code itself. I am not convinced that the helping hand many ship operators have received so far from certain ISM Consultants and Classification Societies in setting up their SMS for them has really been much of a help at all. If I was to be asked to suggest who could perhaps take this project forward I would propose the Nautical Institute possibly in conjunction with the Institute of Marine Engineering, Science and Technology (IMarEST) - whose members would include serving seafarers, shore-based staff in ship operating companies, government employees and within the industry support service sectors. A small working group liasing with IMO staff and utilising the research facilities of WMU could have the practical experience and knowledge required and have access to the sources of the information where some of the answers will be found. The only thing holding this important work back is funding for it cannot be expected that the second phase can also be undertaken on a voluntary basis. It is estimated that there are about 50,000 ships in the world which are required to comply with the ISM Code. I am in no doubt that the answers to most of the issues raised by the IMO report can be found for probably no more than US$5 per ship! The potential benefits will be immeasurable. So - Who will pick up the gauntlet? What are we waiting for?

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This article was originally written for Maritime Risk International By Dr Phil Anderson Managing Director ConsultISM Ltd

What are we waiting for?

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