Enough suits spent the latter end of 2008 discussing the benefits and curses of the International Safety Management Code and its tenth birthday last July so MAC isn’t inclined to be one of them but an article in the American Club’s magazine, Currents, happened to mention the dreaded words “SMS”, “Off the shelf” and “compliance”.
Compliance does not bring safety in its wake. One only has to consider the number of victims of lifeboat on-load releases that are downright dangerous but compliant to get the picture. When it comes to SMSs the same situation seems to apply – a desire to comply rather than a desire to make ship operations safer.
It is those shipowners who buy off the shelf, generic SMS.
Time after time maritime investigators note that SMS procedures haven’t been followed. Dr. Bill Moore, Senior Vice President, Risk Control Shipowners Claims Bureau, Inc., and Chairman, Joint Maritime Safety Committee & Marine Environmental Protection Committee -Working Group on the Human Element, International Maritime Organization, notes “In the fall of 2007, a three month Concentrated Inspection Campaign, CIC, was carried out during port State control inspections by both the Paris Memorandum of Understanding (MoU) and the Tokyo MoU to verify whether the ISM Code was being effectively implemented. One out of five inspections yielded at least some deficiency in the ship’s SMS including 1,868 non-conformities and 176 detentions. Is there room for improvement? Based on these figures, absolutely!”
Captain Richard Gayton, Vice President and principal surveyor for the Shipowners Claims Bureau writes: “When asked to comment on the Code, many mariners today will immediately respond with, “There is too much paperwork.” Increased paperwork and the amount of electronic correspondence for the master is giving cause for concern. It would appear that the master is being sidetracked from his primary purpose of working the ship. Checklists have always been useful guides to procedures, but is the mariner becoming a slave to procedure and just ticking boxes on some checklist, rather than using his/her training, basic knowledge and common sense to identify and manage the risk attached to a particular activity?
Reduced manning is another area of concern and mariners have complained that they don’t have the manpower or time to complete the extra work involved with the SMS.
“Other familiar complaints include such statements as: “There are voluminous procedure manuals,” “The SMS is just a paperwork exercise” and “There is no support from the company.
“It is a fact that many owners continue to struggle to implement the ISM Code, because of an inadequately functioning SMS. Unfortunately there are also owners around, who would still like to have the code’s Document Of Compliance without putting any systems in place. It is also evident that many SMSs are simply bought off the shelf and as such are generic and normally voluminous in order to cover various vessel types and scenarios. A shipowner who places this type of SMS on board, simply because it is a regulatory requirement, will probably have a weak safety culture.”
A generic SMS must be voluminous just to cover everything, whether or not the ship needs that information. That makes the document, and its procedures less relevant and because its less relevant it becomes regarded as just a paperwork exercise, and it is about paperwork: a nice document of compliance.
Captain Gaynor is undoubtedly right when he suggests that a generic SMS is probably a symptom of a weak safety culture at management level that will certainly be reflected in practices onboard ship.