You can trust us to evaluate your system and propose the proper procedures to be included in your Safety Management Manual in line with the meaning of the recent ISM Code amendments. We have the knowledge to guide you when a Risk Assessment is really necessary.
Our Role in the ISM Revision during IMO meetings
The Risk Analysis issues started after the amendments of ISM came in force after 01-07-2010. A lot of controversial views were expressed with a lot of consultants or auditors requesting ships and companies to assess all risks.
We were in IMO during this discussion and the Real History of this revision follows:
The initial proposal for modification of paragraph 184.108.40.206 of ISM code, was enabled with the paper FSI 13/10/1, prepared by IACS and was then modified after proposal of joint working Group MSC – MEPC. This group was established to examine relative proposals (MSC 84- WP 6 –Annex 1 page 3) and the final text to the IMO plenary as prepared by the working group was:
“220.127.116.11 Assess all risks to its ships, personnel and the environment and establish appropriate safeguards”
With our intervention as Greek Delegation and support by the majority of delegations the text was modified and incorporated in the final report of MSC (MSC 84/24/Add2) to the following text
“18.104.22.168 Assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards”, and this was the final version.
During the Discussions in IMO we said that identified risks:
- -should be those arising from incidents, near misses, break downs, accidents, emergencies mainly in our ship – this means incident HISTORY and RECORDS,
- -arise from the background of damage reports, accidents, near accidents etc. in a company from all ships within its fleet ,
- -cover all work hazards during the normal execution of duties and operations on board, but do not cover hazards that are not reasonably visible,
- -with data from other companies, general statistical data that do not concern our company, but could arise in theory, may lead us to take excessive measures and establish procedures for hazards that are unlikely to happen upon the specific Company/Ship/Crew,
- -arising from general statistical data will be considered carefully whether they can occur in our ship/company, and
- -should be POSSIBLE (P=possibility) and have a concrete CONSEQUENCE (C=consequence), so R=PxC.
The meaning of this ISM code revision is:
- -To lead us to take measures based on common sense and operational practice for the given Company, keeping in mind the way that the management operates its ships.
- -To make a procedure more safe and simpler taking into account the SMS/SMM.
- -To maintain an SMS that works properly, but at the same time make our SMS better and simpler.
- -For the risk to be a Company-Ship-Crew specific and identified.
Therefore a satisfactory assessment must be prepared for the identified risks that occur from a repeated or not procedure on board, the relative works or the duties of crew, aiming at:
- Finding crew or other personnel that are exposed to a specific risk during the execution of their duties on board.
- Taking measures to prevent an identified risk e.g. Fatality, injury, loss or damage to the ship or other property loss or damage to the environment.
- Making existing procedures simpler and more comprehensive.
Risk assessment takes into account STCW working hours because we have to avoid one procedure and in practice reduce the time left for another. The SMS /SMM changes must be prepared having in mind the crew rest hours.
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