New amendments to the ISM Code
Adoption of Amendments to the International Management Code for the Safe Operation of Ships and for Pollution Prevention (International Safety Management (ISM) Code) with Resolution MSC.273(85)
The resolution MSC.273(85) adopted on December 2008 introduces modifications to the ISM Code.
The ISM Code requires vessel operators to implement a safety management system that will help them to achieve incident-free operations. However, since its introduction more then 10 years ago, there has always been a clear distinction between the standards of those vessel operators that embrace the spirit of the ISM Code and those that aim to fulfil only its minimum requirements. With this in mind, we believe that some of such modification will greatly affect the Safety Management System (SMS) when its amendments will enter into effect on 1st July 2010. In other words, the legislator has now layed the bases for including “Risk Management” approach with the ISM Code implementation and maintenance.
The major modifications are listed as follows:
Objective, Section 1.2
The initial stated objective of the Code — “The purpose of this Code is to provide an International standard for the safe management and operation of ships and for pollution prevention” — has been expanded and fully outlined in section 1.2 . The new amendment now includes what we used to define risk assessment concepts. The revised section 1.2 states:
“The Safety management objectives of the Company should assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards..”
Development of plans for shipboard operations. Section 7
As consequence of the modification in the above “ISM Objectives”, “the Company should establish procedures, instructions, including checkilist as appropriate, for key shipboard operations” not only limited “to the safety of ship and prevention of pollution” but for “the safety of personnel, ship and and protection of the environment”.
Emergency preparedness, Section 8.1
An additional amendment details the proactive requirement provided by section 8, already focused on anticipating a risk assessment procedure to identify and deal with potential emergency situations. The current Section 8.1 states:
“The Company should establish procedures to identify, describe and respond to potential emergency shipboard situations.”
The amended section 8.1 reads as follows:
“The Company should identify potential emergency shipboard situations, and establish procedures to respond to them”.
This statement reflects the adoption of a risk assessment concept within the ISM Code. Now companies need to consider in advance all potential emergency situations in order to anticipate any possible hazard. Companies are also required to conduct an evaluation to establish in advance the necessary procedures to face such potential hazards.
Reports and analysis of non-conformities… Section 9.2
The amendments to section 9.2 are aimed at enforcing risk assessment and quality principles.
The current section 9.2 states: “The Company should establish procedures for the implementation of corrective actions”
The revised version reads: “The Company should establish procedures for the implementation of corrective action, including measures intended to prevent recurrence”.
If a reactive improvement can easily address a non-conformity situation, then the proactive improvement is a major change in a company’s management approach to prevent such non-conformity from occurring. Therefore companies should first fully understand non-conformity situations and those measures able to prevent them, before trying to implement a successful proactive improvement program. Benjamin Franklin once said, “An ounce of prevention is worth a pound of cure” — a sentence seemingly fit to the goal of amended section 9.2.
ECM Europe can review your existing SMS and provide a gap analysis report with suggestions and/or best practice reccommedations for aligning your SMS with the ISM Code Edtion 1st July 2010.
Please do not hesitate to contact us for any question or request you might have.
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