Please forgive the disruption

Dr William Moore , Senior Vice President and Global Head of Loss Prevention Shipowners Claims Bureau, Inc., Managers

of the American Club looks at the the benefits of the International Safety Management (ISM) Code for shipowners

The International Safety Management (ISM) Code entered into force for shipowners and operators in July 1998 and brought both high expectation and apprehension as well.

At the time, there was a critical mass of shipowners and operators that had already adopted a more holistic safety management philosophy and culture approach that incorporated the objectives of the ISM Code.

On the other hand, most of the maritime industry at the time were primarily focused on complying with mandatory statutory instruments that were significantly prescriptive in nature. These included, for example, classification society rules and IMO conventions (SOLAS, Load Lines, MARPOL, etc.). Implementation of the ISM Code has led to changes in the way our industry approaches safety.

Compliance with the requirements of the ISM Code, oversimply stated, boils down to three simple things: “Say what you do, then do what you say and then prove you’re doing what you say.” Furthermore, the ISM Code takes account of constant consideration and review of risk exposure and importance of the process to regularly review and consider those risks with an objective of continuous improvement.

This is reflected through two interrelated components that are key to effective safety management: An assessment of identified risks (Section 1.2.2.2) and non-conformities, hazardous occurrences and accidents are to be analysed and reported (Chapter 9).

These are key precursors to ensure compliance with ensuring vessels are manned with sufficient resources and personnel (Chapter 6), safe shipboard operations (Chapter 7) and well prepared for any emergencies that arise (Chapter 8).

Vessel Risk Management

How should one consider the risks for a vessel? What are they? How critical are each of the risks to safe operations? Should all risks be considered? How can the risks be reduced, eliminated or mitigated?

These questions depend on many contributing factors that include, but are not limited to, the vessel’s design, cargoes carried, trading pattern, qualifications, motivation, training and working conditions of the crew and the like.

The US Coast Guard in their commercial vessel compliance mission management work instruction, US Flag Interpretations on the ISM Code (CVC-WI-004(2) of 30 July 2020), have set forth 21 risks that should be considered at a minimum in establishing emergency preparedness as required under Chapter 8 of the ISM Code.

Despite this prescriptive list of risks, it does provide a list of well-known risks that many ocean-going vessels are exposed to. However, there are no requirements or guidelines on effective methods to assess those risks while considering the contributing factors.

Furthermore, there are several challenging factors that impact the reporting of non-conformities, hazardous occurrences and accidents that include but are not limited to:

(1)Inconsistencies in understanding what constitutes non-conformities and hazardous occurrences;

(2)A lack of training, experience and procedural support of seafarers to properly perform investigations of incidents;

(3)Striking a balance on the details of what to report and format it is to be reported; and,

(4)Having a strong company and shipboard “just” culture that regularly promotes honest reporting as human errors are understood to occur, but, whereby individuals are also held accountable for willful misconduct or negligence.

Moreover, the reporting non-conformities and hazardous occurrences is viewed by many as being disruptive to the work process whereby seafarers are already under pressure of commercial demands and the normal daily tasks associated with shipboard life.

Disruptive Burden

I recall reviewing a shipowner’s documentation for tanker chartering that stated that each vessel was required to make two “near miss” reports per month.

In that company, reporting was seen as a disruptive burden rather than an important component of enhancing safety and environmental protection.

At the American Club, we grappled with the constant challenges of developing effective means of disseminating guidance to our shipowners and operator members and tools for their seafarers.

The global seafarer community includes a broad range and diversity of nationalities, many of which are native English speakers, possess significant ranges of seafaring knowledge and experiences. They also differ widely in age whereby generational differences influence how they have been educated and trained in the use of technology.

In 2021, we launched a seafarer focus initiative named

Good Catch that is featured both on the American Club’s website and mobile application in both English and Mandarin languages.

The initiative combines alerts and animations on safetyrelated issues in a focused format aimed principally at seafarers themselves.

Good Catch recognizes that, although there may be differences in detail between individual safety management systems, they all have a common purpose in ensuring seafarers’ situational awareness and their personal responsibility for their own safety, that of their shipmates, the marine environment and the many other interests involved in their service at sea.

The importance of a strong safety culture that identifies, assesses and reports unsafe conditions, unsafe acts and near misses, cannot be overstated. As seen in Figure 1, we emphasize the importance of situational awareness.

In addition, Good Catch also features safety animations, many which feature case studies of incidents and measures to take to prevent such incidents as seen in Figure 2 (above left) that demonstrate a line handling incident.

We also emphasize the importance of situational awareness in the prevention of slips, trips and falls. In 2017, the American Club in cooperation with the American Bureau of Shipping and Lamar University ascertained that from 2013 to 2017, 34% of injury claims accounting for 32% of injury related claims costs were the direct result of slips, trips or falls. We’ve brought attention to these risks through the Good

Catch animated artwork media format as well as our regularly featured Alerts (see Figure 3 above and Figure 4 below).

Many of us hark back to the days of old when maritime life was simpler. Well-established prescriptive rules and standards applied and not the plethora of safety and environmental regulatory requirements we now find ourselves subjected to. We cannot bring those days back.

However, we can do our best to reduce the misconception that reporting of non-conformities, hazardous occurrences (including hazardous situations and near misses) and accidents are not disruptive but key to their own personal safety. With better reporting, we gain a better understanding of what personnel, operational requirements and emergency preparedness.

Sometimes, taking small steps thought to be disruptive are are the necessary steps to truly improve safety.

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