FLP2233-Module6B-Website 1 of 2

DIPLOMA IN
SHIP MANAGEMENT
2012 / 2013
MODULE 6B
Volume II
Safety and Security in Marine Operations:
Regulation and Environment
AUTHOR
Captain John W. Dickie BA MNI

Course Director
&
Managing Director
Joint Development Associates Limited (JDass Ltd), UK
&
Secretary General
International Federation of Shipmasters’ Associations
Lloyd's and the Lloyd's crest are the registered trademarks of the society incorporated by the Lloyd's Act 1871 by the name of ‘Lloyd's’
CONTENTS
Page No.
1. GENERAL INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2. THE ISM CODE AND THE MANAGER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.1 Understanding the ISM Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

2.1.1 The Evolution of the ISM Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7
2.1.2 The ISM Code and SOLAS 74, Chapter IX – Management for the Safe
Operation of Ships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7
2.1.3 Application of the ISM Code through SOLAS 74 and the Code Itself . . . . . .8
2.1.4 The Contents of SOLAS IX and the ISM Code . . . . . . . . . . . . . . . . . . . . . .10
2.2 The Effect of the ISM Code on the Maritime Industry . . . . . . . . . . . . . . . . . . . . . . . .12
2.2.1 The History of the ISM Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12
2.2.2 The ISM Code Post-1 July 1998. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13
2.3 The Organisation’s Safety Management System . . . . . . . . . . . . . . . . . . . . . . . . . . . .16
2.3.1 The Structure of an SMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16
2.4 Audit Schedule and Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23
2.4.1 The depth, scope and types of internal audits are explained correctly
in relation to the requirements of the relevant international, national or
organisational standard and organisation systemic requirements . . . . . . . .23
2.4.2 The ISM Code Certificates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27
2.4.3 The ISM Codes Audits for Certification . . . . . . . . . . . . . . . . . . . . . . . . . . . .27
2.4.4 Maintaining Certification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .34
2.5 The Effect of the Multi-national Fleet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .35
2.5.1 Multi-national Fleets and the Problems Associated with Them . . . . . . . . . .35
3. THE ISPS CODE AND THE MANAGER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
3.1 Understanding the ISPS Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .37

3.1.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .37
3.1.2 The ISPS Code. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39
3.1.3 Security Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .40
3.2 Security versus Safety: Same or Different? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .41
3.3 The Company Security Officer and the Ship Manager. . . . . . . . . . . . . . . . . . . . . . . .42
3.4 The Ship Security Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43
3.4.1 Methodology of Certification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43
3.4.2 Maintenance of Certification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44
3.4.3 Process of Implementing the ISPS Code into a Company. . . . . . . . . . . . . .44
Diploma in Ship Management 2012 / 2013 (FLP2233) 6B-1

Contents Module 6B
3.5 Audits and Certification. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .59

3.5.1 Ship Security Alert System (SSAS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60
3.5.2 Security Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
3.5.3 The Ship Security Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .61
3.6 Amending the Ship Security Plan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .62
3.6.1 The Amendment Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .62
3.7 The Relationship between the Ship Security Officer (SSO), Company
Security Officer (CSO) and the Port Facility Security Officer (PFSO) . . . . . . . . . . . .63
3.8 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
4. PORT STATE CONTROL AND THE MANAGER . . . . . . . . . . . . . . . . . . . . . . . . . . . 67
4.1 Inspections and Degree of Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

4.1.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .67
4.1.2 Inspection / More Detailed Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . .68
4.2 Memorandum of Understanding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .77
4.2.1 Port State Control Organisations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .77
4.3 Dealing with Deficiencies and Non-conformities Raised at PSC Inspections . . . . . .80
4.3.1 Deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .80
4.4 The Position of the Ship Manager in Respect of PSC . . . . . . . . . . . . . . . . . . . . . . . .83
4.4.1 PSC and the Ship Manager . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .83
4.5 Targeted Vessels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84
4.5.1 Mandatory Expanded Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84
5. THE ENVIRONMENT AND SHIPPING: MINIMISING THE IMPACT . . . . . . . . . . . . 92
5.1 ISO 14000: Environmental Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92

5.1.1 The ISO 14000 Series . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92
5.2 MARPOL 73/78. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .93
5.2.1 MARPOL 73/78: The Structure and Contents . . . . . . . . . . . . . . . . . . . . . . . 93
5.3 Shipping and Environmental Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .98
5.3.1 Beyond MARPOL 73/78 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .98
5.3.2 Environmental Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100
5.4 How “Green” Is Your Organisation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .101
5.4.1 What Steps is Your Organisation Taking to Become an
Environmentally Aware Company. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .101
5.5 The Relationship between the ISM Code and ISO 14000 . . . . . . . . . . . . . . . . . . . .102
5.5.1 Comparison of Standards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .102
5.6 Environmental Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .102
6B-2 Diploma in Ship Management 2012 / 2013 (FLP2233)

Module 6B Contents
6. HEALTH AND SAFETY AND THE COMPANY:

THE CARE OF EMPLOYEES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104
6.1 Health Surveillance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .104

6.1.1 What is Health Surveillance? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .104
6.1.2 A Definition of Health Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .104
6.1.3 Reference Publication on Health Publication . . . . . . . . . . . . . . . . . . . . . . .105
6.1.4 Points to Consider for Health Surveillance . . . . . . . . . . . . . . . . . . . . . . . . .106
6.1.5 Application of Health Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .106
6.1.6 Health Surveillance Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .107
6.2 Hours of Work and Rest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .108
6.2.1 Hours of Work and Rest in the Workplace . . . . . . . . . . . . . . . . . . . . . . . . .108
6.2.2 STCW Convention Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .108
6.2.3 Maritime Labour Convention, 2006 Requirements . . . . . . . . . . . . . . . . . . .110
6.2.4 Comparison of STCW and MLC. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .112
6.2.5 Hours of Work and Rest and the Safe Manning Document . . . . . . . . . . . .113
6.3 Ship Medical Supplies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .114
6.3.1 Medical Standards on Board Ships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .114
6.3.2 Ship Medical Stores . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .114
6.3.3 The Ship’s Medical Log Book . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .114
6.3.4 The Ship’s Hospital. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .115
6.4 The Effect of Stress on Employees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .116
6.4.1 Stress is with us all of the Time . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .116
6.4.2 Stress and Stress Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .116
6.5 The Effect of Fatigue on Employees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .121
6.5.1 Fatigue and the Seafarer and the Ship Manager . . . . . . . . . . . . . . . . . . . .121
6.5.2 Guidelines on Fatigue. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .122
6.5.3 The Definition of Fatigue. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .122
6.5.4 Causes of Fatigue. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .123
6.5.5 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .126
6.6 Dignity and Respect at Work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .127
6.6.1 The Contents of This Section Were Covered in Module 6A Volume I:
Section 2.3.3 – Behaviours That Can Constitute Harassment . . . . . . . . . .127
6.6.2 Effective Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .127
7. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 129
LIST OF ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 130

Contents Module 6B
RECOMMENDED READING & USEFUL WEBSITES . . . . . . . . . . . . . . . . . . . . . . 131
TUTOR-MARKED ASSIGNMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 132
APPENDIX 1 – PORT STATE CONTROL CODES FOR

PARIS MOU FROM 1 JULY 2011 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 135
APPENDIX 2A – PORT STATE CONTROL CONCENTRATED

INSPECTION CAMPAIGN PRESS RELEASE . . . . . . . . . . . . . . . . . . . . . . . . . . . . 147
APPENDIX 2B – PORT STATE CONTROL CONCENTRATED

INSPECTION CAMPAIGN PARIS MOU QUESTIONNAIRE . . . . . . . . . . . . . . . . . 151
APPENDIX 2C – PORT STATE CONTROL CONCENTRATED

INSPECTION CAMPAIGN TOKYO MOU QUESTIONNAIRE . . . . . . . . . . . . . . . . . 153
PLEASE NOTE
• Self-Assessment Questions have been provided periodically

throughout this module. These questions are designed to help you
study. The questions are for your personal study only; do not send in
your answers to these questions as they will not be assessed.
• For candidates taking the Diploma option, your Tutor-Marked

Assignment is at the rear of this module. Your worked Assignment
should be sent to the TMA Administrator (details are given at the end of
the Tutor-Marked Assignment) for processing.
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1. GENERAL INTRODUCTION
The scope of material covered in this module necessitated it being split into two
volumes. Delegates should be aware that there will be some carry over between
to the two volumes and that the main list of appendices has been attached to
Volume I.
In addition, you may find that some of the concepts and ideas promoted in this
module do not correspond or match exactly what has been put forward in
previous modules. This is not a mistake.
There is no one perfect answer. If there were then all companies would use it.
Companies are individual and the way the company operates reflects the
personnel who work for it. There is no way of getting away from the fact that
legislation must be met and that if not the company will feel the effect through
the various bodies that regulate the shipping industry.
These can be flag states, port State control, classification societies, insurance,
charterers etc. Therefore, a sound knowledge of legislation is a prerequisite for
being a successful ship manager. This is only one part of a complex system of
checks and balances needed.
The International Safety Management Code (ISM Code) lays down the
framework for a company to meet the requirements of safety and pollution
prevention. The International Convention for Safety of Life at SEA, 1974, as
amended (SOLAS 74) Chapter IX – Management for the Safe Operation of
Ships, makes the ISM Code mandatory for ships operating under SOLAS. This
assists companies in constructing their Safety Management System (SMS). But,
because it only gives the framework, the actual contents of the SMS will vary to
reflect how the company does business.
The Self-Assessment Questions are important to each delegate as it gives you

the opportunity to assess what is going on in the organisation that you are
employed in. The questions have been deliberately chosen to ensure that they
apply to all delegates and not just those of a maritime background. Those who
work on board ships or in the office of a shipping company will have an
advantage, but it is hoped that those who do not will be able to adapt the
question to suit their organisation.
The main point of Modules 6A and 6B and the other modules making up the
course is that you learn and increase your knowledge of the shipping industry
and take this with you and apply it to normal daily work routines.
The most important point to remember is that there is no one ideal answer. If it
works then you have succeeded. That is what is important.
Throughout the module you will find that there are references to sections of the
ISM Code. All delegates need to have a thorough knowledge of the contents of
the ISM Code and be able to apply it to particular situations.

General Introduction Module 6B
Finally, a quotation that was made long ago, but is still relevant to the shipping
industry of today. It is food for thought as you work your way through the two
volumes that make up Modules 6A and 6B.
“We trained very hard, but it seemed that every time we were beginning to
form up into teams, we would be re-organized.
I was to learn later in life that we tend to meet any new situation by
re-organizing – and a wonderful method it can be for creating the illusion of
progress, while producing confusion, inefficiency and demoralization.”
Caius Petronious
Roman Equas (Knight)
from Marseilles
At the Court of the Emperor Nero
(27–66 AD)

2. THE ISM CODE AND THE MANAGER
LEARNING OUTCOMES
After successfully completing this chapter, you will:
• Have a better understanding of the ISM Code and its

application.
• Be more able to look at the ISM Code and its place in the
maritime industry.
• Have a better understanding of an organisation’s Safety

Management System.
• Understand the importance of Audit Schedule and Compliance.
• Understand the effect of a multi-national fleet on constructing a

SMS and controlling certification.
2.1 UNDERSTANDING THE ISM CODE
2.1.1 The Evolution of the ISM Code
6B-001 The ISM Code is nothing new and in fact it has now been about in the shipping
industry since the early 1990s. That is when it became available to the shipping
industry and its mandatory application commenced on 1 July 1998.
6B-002 The latest edition of the ISM Code that is available is the one contained in the
ISM Code 2010 Edition (ISBN 978-92-801-5151-0) which is identified by IMO
Resolution A.741(18) as amended by MSC.104(73), MSC. 179(79), MSC.
195(80) and MSC. 273(85).
6B-003 The latest amendments contained in MSC. 273(85) entered into force on 1 July
2010. The full text of this can be found in IMO Resolution A.1022(26). All previous
resolutions are revoked.
6B-004 This shows how over the years the ISM Code has been amended and adapted
to keep in step with the demands of the shipping industry.
6B-005 This continuous updating reflects the evolution of the ISM Code to meet the
ever-changing demands of the shipping industry and stay in line with current
legislation.
2.1.2 The ISM Code and SOLAS 74, Chapter IX – Management for the Safe
Operation of Ships
6B-006 When dealing with the ISM Code the contents of SOLAS 74, as amended, need
to be read. The delegate needs to be aware that there are some differences

The ISM Code and the Manager Module 6B
between SOLAS IX contained in the consolidated 2009 edition and the version
found in the ISM Code 2010 Edition.
6B-007 SOLAS Chapter IX makes mandatory the ISM Code as identified in section 2.1.1
above.
6B-008 The contents and restrictions placed by the SOLAS Convention must never be
forgotten. It must always be remembered that the contents written are the
minimum requirements necessary to achieve accreditation and application. If
your company or a flag state that you use set a higher level of application then
that is your or their choice. Your choice is voluntary; a flag state’s is mandatory.
2.1.3 Application of the ISM Code through SOLAS 74 and the Code Itself
SOLAS
Article II
Application
The present Convention shall apply to ships entitled to fly the flag of States
of Governments of which are Contracting Governments.
SOLAS
Chapter I – General Provisions
Part A – Application, definitions, etc
Regulation 1 – Application
a) Unless expressly provided otherwise, the present regulations apply

only to ships engaged on international voyages
b) The classes of ships to which each chapter applies are more precisely
defined, and the extent of the application is shown, in each chapter
SOLAS
Chapter IX – Management for the Safe Operation of Ships
Regulation 2 – Application
1 This chapter applies to ships, regardless of the date of construction, as

follows:
.1 passenger ships including passenger high-speed, not later than 1

July 1998;
.2 oil tankers, chemical tankers, gas carriers, bulk carriers and cargo
high-speed craft of 500 gross tonnage and upwards, not later than
1 July 1998; and

Module 6B The ISM Code and the Manager
.3 other cargo ships and mobile offshore drilling units of 500 gross
tonnage and upwards, not later than 1 July 2002.
2 This chapter does not apply to government-operated ships used for

non-commercial means.
ISM CODE
Part A – Implementation
Regulation 1 – General
1.3 – Application
The requirements of this Code may be applied to all ships.
The above various pieces of legislation gives the outline of what has to be
applied and how it affects shipping companies and their ships.
1. If the flag state is not a signatory to SOLAS then the ISM Code does not
need to be applied. This holds good only when the vessel remains in the
national waters of the flag State.
2. Ships of less than convention size as stated above in SOLAS, IX Reg. 2

are not required to comply with the ISM Code.
3. Ships that are not engaged in international voyages do not need to comply
with the ISM Code
4. SOLAS – Chapter I Part A – Regulation 3 Exceptions
a) The present regulations, unless expressly provided otherwise, do not

apply to:
i) Ships of war and troopships
ii) Cargo ships of less than 500 gross tonnage
iii) Ships not propelled by mechanical means
iv) Wooden ships of primitive build
v) Pleasure yachts not engaged in trade
vi) Fishing vessels
6B-009 It is possible that by further inspection of other ship types and operations it could
be identified and of course there can be special exemptions to the requirements
that can agreed by the ship manager and the flag state on behalf of the owner.

2.1.4 The Contents of SOLAS IX and the ISM Code
SOLAS IX
Regulation 1 Definitions
Regulation 2 Application
Regulation 3 Safety Management Requirements
Regulation 4 Certification
Regulation 5 Maintenance of Conditions
Regulation 6 Verification and Control
ISM Code
Preamble
1 General
1.1 Definitions
1.2 Objectives
1.3 Application
1.4 Functional requirements for a Safety Management

System
2 Safety and Environmental Protection Policy
3 Company Responsibilities and Authority
4 Designated Person(s)
5 Master’s Responsibility and Authority
6 Resources and Personnel
7 Shipboard Operations
8 Emergency Preparedness
9 Reports and Analysis of Non-Conformities, Accidents and

Hazardous Occurrences
10 Maintenance of the Ship and Equipment
11 Documentation
12 Company Verification, Review and Evaluation

Part B – Certification and Verification
13 Certification and Periodical Verification
14 Interim Certification
15 Verification
16 Forms of Certificates
Appendix – Forms of the
Document of Compliance
Safety Management Certificate
Interim Document of Compliance
Interim Safety Management Certificate
In addition, the ship manager should take note of the contents of the following:
Guidelines on Implementation of the International Safety Management (ISM)

Code by Administrations (Resolution A.1022(26));
Guidelines for the Operational Implementation of the International Safety

Management (ISM) Code by Companies (Annex to MSC – PEPC.7/Circ.5);
Guidance on the Qualifications, Training and Experience Necessary for

Undertaking the Role of the Designated Person Under the Provisions of the
International Safety Management (ISM) Code (Annex to MSC-MEPC.7/Circ.6);
Guidance on Near-Miss Reporting (Annex to MSC-MEPC.7/Circ.7).
All of the above can be found in the ISM Code (2010 Edition).
The ship manager needs to work in two stages. These are:
1. Have an in-depth knowledge of the contents of the above publications.
2. Have an in-depth knowledge of how these contents have been applied in

the construction and usage of the company’s Safety Management System
(SMS).
6B-010 This will involve researching the complete SMS and identifying the specific
needs of the ISM Code to do with the job description and where other parts fit
with other members of the office staff as well as those on board.
6B-011 There is no one particular Safety Management System (SMS) which is used by
all companies. The ISM Code is the framework that the company builds its
particular practices on. If there was one particular SMS that was the best and
met each and every section and sub-section and resulted in zero non-
conformities at every audit, then every company would be using it.

6B-012 The requirement for this unique structure for the SMS is found in:
The documents used to describe and implement the safety management

system may be referred to as the Safety Management Manual. Documentation
should be kept in a form that the Company considers most effective. Each
ship should carry on board all documentation relevant to that ship. (ISM
Code A-11.3)
6B-013 This supports the concept of the SMS being uniquely written to reflect the way
the company operates and complies with the ISM Code.
6B-014 It is important to work with the company’s SMS. The variance in size of the SMS
between companies can be considerable.
6B-015 What should be remembered is the fact that there is no right or wrong answer in
the construction of a SMS only that it is found suitable to be awarded the relevant
certification after completion of the appropriate audit.
SELF-ASSESSMENT QUESTION
Review the company’s SMS in respect of the responsibilities and authority

of the ship manager.
Choose one of the responsibilities and trace where it can be found in the
SMS. Be aware that it may appear in one or more of the volumes making
up the SMS.
If you do this task on an electronic SMS make sure that what you find is
relevant to the initial statement of this question.
2.2 THE EFFECT OF THE ISM CODE ON THE MARITIME INDUSTRY
2.2.1 The History of the ISM Code
6B-016 The ISM Code is nothing new to the shipping industry. In fact before its inception
as shown above, the ISM Code was progressing through the International
Maritime Organization (IMO) at a slow pace.
6B-017 The Herald of Free Enterprise capsize followed by the Estonia incident in 1994
resulted in the EU making the decision to implement the ISM Code for passenger
Ro-Ros from 1 July 1996. This was two years ahead of the global implementation
of Phase I ships for 1 July 1998.
6B-018 The driving force for this was the large loss of life in both incidents and the
expression that the fundamental design of large passenger Ro-Ros was flawed.
6B-019 This meant that any passenger Ro-Ro trading to any member country at that
time had to have full certification of both ship and office. The result was chaos
and in the Adriatic many Ro-Ros were detained or expelled from Italy.

6B-020 By the time of the global implementation of Phase I on 1 July 1998, the back-log
of companies and ships that left it to the last minute was incredible.
6B-021 This continued to 1 July 2002 when Phase II ships became mandatory.
6B-022 Companies had a form of Safety Management System in place way back in the
1960s and 1970s. These were known as the Company Procedures or Company
Instructions.
6B-023 By the late 1970s there was a major shift in the shipping industry and shipowners
were not operating their ships but passing them out to ship management
companies. At the same time, the rise of flags of convenience came to the
forefront as a method of saving money.
6B-024 These changes were accompanied by ship management companies being

located in new countries to the shipping world.
6B-025 These changes resulted in changes of perception about shipping which was
supported by the increase in ship losses and a large increase in loss of life.
6B-026 The perception of the shipping industry as being a “quality” industry with good
long term benefits changed to regarding it as a hazardous industry.
6B-027 By 1990 the results had become so bad that the insurance company Lloyd’s of
London took in US$ 2 billion in premiums and paid out US$ 4 billion in claims.
6B-028 Shipping companies had already started on their own forms of a structured
management system. This involved using the ISO 9000 series of Quality
Management Systems. This evolved to the DNV SEP System where the SEP
was the abbreviation for Safety and Environmental Protection, which was based
on the ISO 9001 concept.
6B-029 The IMO was working away and progressing slowly, but pressures from various
bodies within the industry ensured that a structure was put in place.
6B-030 The result was the ISM Code.
6B-031 At the same time as the ISM was progressing to mandatory application there
was the International Ship Managers Association (ISMA), but this failed, not
because it was bad but because it did not have the support of the IMO and
legislation to support it. Companies could have ISMA Certification and ISM
Code certification but the cost would nearly double.
2.2.2 The ISM Code Post-1 July 1998
6B-032 The evolution of the ISM Code will result in companies having to amend their
Safety Management Systems to meet the changes introduced by the Code.
6B-033 But this should be nothing new to companies because the SMS is under constant
change to meet the requirements of any changes in legislation which affect their
ships.

ISM Code
Regulation 1 – General
1.2 – Objectives
1.2.3 The safety management system should ensure:
.1 compliance with mandatory rules and regulations; and
.2 that applicable codes, guidelines and standards recommended by the

Organization, Administrations, classification societies and maritime
industry organizations are taken into account
In the above, the following is understood
Organization – International Maritime Organization
Administration – Flag State Administrations
Classification Societies – Members of the International Association of

Classification Societies (IACS)
Maritime industry organizations – these usually have observer status at the

IMO and include:
• International Chamber of Shipping
• International Shipping Federation
• Oil Companies International Marine Forum
• Society of International Gas Tanker & Terminal Operators
• Nautical Institute
• International Association of Ports & Harbours
• International Marine Pilots Association
• International Federation of Ship Masters Associations
The above is a sample only.
In addition, every person who works with the SMS is required to be able to
understand and interpret the legislation contained in the SMS.
ISM Code

Regulation 6 – Resources and Personnel
6.4 The Company shall ensure that all personnel involved in the Company’s
safety management system have an adequate understanding of
relevant rules, regulations, codes and guidelines.
6B-034 This requires that the company identify the level of competence that a person
needs to discharge the duties that a particular job description requires.
6B-035 This does not mean that a person has to learn legislation and be able to recite
it. The central theme must be in knowing which piece of legislation applies where
and then knowing where to find it and apply the contents.
6B-036 Many companies have Safety Management Systems that are too large and are
still growing. This growth is to respond to new or amended legislation in the
shipping industry or as a result of accidents, incidents, hazardous occurrences.
It also includes near miss reporting and reports from third-party inspections,
audits and surveys.
There is a move at this time to make near miss reporting compulsory and that a
copy of every near miss report be sent to the flag state. This is under the control
of the MAIB in the UK. It may that many other flag states will take this option
which will place another large administrative burden on the ship and office to
meet compliance.
6B-037 Trying to control the size of the Safety Management System and at the same
time meet the demands of the maritime industry is not an easy task.
6B-038 Some organisations look back at where they were and where they want to be.
The problem stopping them from taking major steps is the fact that they could
endanger the ISM Code certification.
6B-039 If any certificates were lost then the ship stops trading if it is a Safety Management
Certificate. But, if it is a Document of Compliance, then all ships linked to that
DOC could have their Safety Management Certificates withdrawn. No company
can take the risk.
6B-040 Therefore, a continuous process of small steps is required to keep up to date.

This is not cheap and it needs personnel who are fully conversant with the
Safety Management System so that they can make the necessary changes
without endangering certification.
What training and experience do you have in using legislation?
How does the company identify legislation in the Safety Management

System?
Take one SMS Volume and check the Revision Log to identify changes and
history of the Volume.

2.3 THE ORGANISATION’S SAFETY MANAGEMENT SYSTEM
6B-041 Every company will have constructed its Safety Management System (SMS) to
meet the requirements of the ISM Code. It will be unique to the company and
should reflect the way it does business.
6B-042 Companies are not allowed to choose which sections or sub-sections of the ISM
Code that fit their profile. They must be able to provide objective evidence of how
they meet each and every section and sub-section of the ISM Code. It is not
optional.
6B-043 SMSs can be in hard copy or they can be in electronic format. In many cases
the SMS is a hybrid where certain parts are electronic and others are hard copy.
It makes no difference. To obtain certification it must be able to show how it
meets the complete ISM Code.
6B-044 Auditing will determine whether the SMS meets the requirements or not.
Certification and continued certification will be awarded against compliance to
the standard. The reporting from the auditors concerned will be in the negative.
6B-045 That is to say they will report what they have found that is wrong/not meeting
minimum requirements and needs to be rectified. It is not in their remit to tell you
how good or how bad your SMS is. It either meets the standard and passes and
is awarded certification, or continued certification, or it fails and needs work to
be done to meet the required minimum standard.
2.3.1 The Structure of an SMS
6B-046 There is no descriptor identifying how to build a SMS. The only concern is how
you go about it and that in the end there is a SMS that complies with all of the
ISM Code.
6B-047 The vast majority of shipping companies have mature SMSs in place and are
working on maintaining these systems and adapting them in response to new
legislation.
6B-048 The problem with these old systems is that they are not efficient or effective. This
is not a criticism of those who had to do their normal duties and in addition create
a new concept, namely a Safety Management System. This was done with the
best of intentions and a lot of hard work went into creating these systems.
6B-049 At that time there were no standards to compare against that fitted exactly what
the ISM Code was asking. ISO 9001 – Quality Management Systems was
closest but did not quite fit. There were discrepancies and some sections of ISO
9001 did not readily appear in the ISM Code. The classification society Det
Norske Veritas (DNV) had created their Safety and Environmental Protection
(SEP) System. It was closer but not quite in line with the ISM Code.
6B-050 Many companies took the situation on board and decided to build their own
system to meet the requirements and, starting at the first section of the ISM
Code, built the system to meet that section and then moved onto the next until
they came to the end. It was an incredible journey and a lot of hard work. The

people involved did not have the support they needed and in some cases met
opposition to what they were trying to do.
6B-051 In some parts of the maritime industry there were groups who were of the
opinion that the ISM Code would never be implemented and would fade away.
They could not have been more wrong.
6B-052 If the above process was used to build the SMS there would be a lot of duplication
and even triplication of work. This produced another problem of which part of the
SMS had precedence over other sections of the SMS. It also introduced a need
to cross-reference the contents of the SMS to ensure that every section was
being met and that there was no conflict.
6B-053 One important factor was the readability of the finished product. This SMS had
be read and understood by all persons who were involved in matters of safety
and pollution prevention. This meant all of the ship’s staff and the vast majority
of those working in the shore offices.
6B-054 The following section is to give the delegate some guidance on how to approach
the need for detail if they were tasked with developing a SMS.
2.3.1.1 The Importance of Quality Assurance during the Design, Development and
Implementation Stages of a Documented Safety Management System
The design, development and implementation of a documented Safety

Management System require controls to be put in place from the start.
6B-055 The Company has the option of using the tools and methodologies of quality
assurance or can construct their own system to their own specification.
6B-056 If quality assurance is not used, then the potential for the system to be created
with certain flaws is increased.
6B-057 Where certain problems lie for the shipping industry is in resolving quality and
safety.
6B-058 Depending upon which view and who is speaking the equation can be that
safety is a sub-set of quality.
6B-059 Or quality is safety.
6B-060 Or a position somewhere in between the two standards.
6B-061 Quality lies in the ISO 9000 series or equivalent.
6B-062 Safety in shipping is now linked to the ISM Code.
6B-063 The ISM Code is mandatory through SOLAS 74 Chapter IX. Quality is voluntary
and may be something that the company takes on board to enhance its position
in the industry.

6B-064 Before the ISM Code was implemented, many companies had already started
on implementing quality systems into their company and seeking accredi-
tation.
6B-065 From this the position of quality had become a core element in the company’s
management system.
6B-066 Therefore, to replace it with the ISM Code would cause a major revision of the
company’s system.
6B-067 Initially, companies were dealing with ISO 9001. But, in the recent past the
ISO 9000:2008 was introduced and the changes that this has presented has
resulted in companies reviewing whether to continue with quality systems
certification or not.
6B-068 Perhaps the best option for the shipping company is to use quality assurance for
its guidance document, but not progress to certification.
6B-069 Problems arise once certification is gained and continued because costs rise
and there are difficulties in maintaining certification through the audit regime for
the two standards.
6B-070 The audit cycle for quality does not fit readily to the audit cycle for the ISM
Code.
6B-071 Additional problems encountered are that ISO 9000 certification is issued by an
accreditation body, whereas ISM certification is issued by or on behalf of flag
administrations.
The quality system is voluntary
The ISM Code is mandatory
6B-072 With the above established, the question is how useful can quality be to a
company when implementing the ISM Code Safety Management System.
6B-073 The answer is VERY if used in the right way.
6B-074 If a company has no experience with building a system or of implementing a

structured code within the company, then starting without a guidance document
to give details and directions can prove to be an extremely difficult task.
6B-075 The quality document gives a structure, but to obtain the best out of it, the
company must look at the quality standard as a whole and marry it up to the
requirements of the ISM Code.
6B-076 What will become readily apparent is that there are sections of the quality
standard that do not appear in the ISM Code. Therefore, the ISM Code does not
require as involved a system as quality. (Or does it?)
6B-077 Once this review has been conducted, the company has the concept of what is
to be achieved and then decide on the path to follow to achieve it.

6B-078 To follow a path means that the company has to develop a structure for
implementing the system throughout the company offices and ships.
6B-079 This sounds simple. In fact it should be kept simple but once the company
investigates the requirements of the ISM Code it appears that the concept
becomes complex because of the diversity of demands made by the ISM
Code.
6B-080 The concept to be followed should be simple.
6B-081 It demands:
Design
Development
Implementation
Once the above three titles have been completed within the company it should
be ready for audit for verification that the system meets the requirements and
achieve certification.
DESIGN
Before a system can be designed a person or team of persons should be

appointed to the project for the task involved.
The make up of the team will change depending upon the stage reached and
the requirements needed.
With the team now in place, the requirements of a design are needed.
Since the company is established it should not be a matter of going back to the
drawing board. The company already has a form of management system in
place. Therefore, the team needs to review the current status of the company.
From this revision the design of the SMS can be made.
What the team needs to resolve is where the parts of the current management
system meets the requirements of the ISM Code.
What parts of the current management system need to be revised and amended
to meet the requirements of the Code.
What parts of the current management system do not need to be continued?
What parts need to be constructed to meet the requirements of the ISM Code?
Factors that need to be addressed in the design of the SMS are:
Number of shore offices
Location of each shore office

Number of personnel per office
Nationalities of persons working in each office
Number of ships
Types of ships
Flag state of ships
Nationality of crews for each ship
When the above factors are answered along with the review of the current
system in place then the design can be decided upon.
Other factors that need to be addressed are:
Document Control Method
Structure of the Support Mechanism
(Forms, Reports, Inspections, Records)
Number of Volumes and Contents per volume
Education of Personnel
Training of Personnel
Critical Path Structure
The above allows the details of the how the SMS will be built and the timeframe
for completion. Control is very important to ensure that all the various parts
identified on the Critical Path are met within the timeframe allocated.
If this is not followed then the implementation of the SMS will be delayed and the
hold up on one particular item can have a knock-on effect on other parts of the
system.
Two important points that must be remembered at the design stage are:
Keep It Simple
Make It Flexible
The point of simplicity is that the SMS must be written in a manner that all
persons involved in the use of it can understand it.
Flexibility is very important. The reason being that companies and their
structures are under review at all times and the make up of the company
changes.

Therefore if the structure of the SMS is rigid then, any revision and amendments
will cause a major revision of the SMS because of the knock-on effect.
The larger the system the more prone it is to become static, not dynamic and
the problems arising from any amendment increases.
DEVELOPMENT
Once the design of the system has been established and the form which the
SMS is to take has been agreed, then the development of the SMS can begin.
At this stage it is important to ensure that the right people are in place and are
committed to the project.
Company personnel can be called in to assist the team with their particular
expertise in certain fields. This will be an ongoing and constantly changing
arrangement.
The rules and concepts developed in the design stage have to be translated into
the product being constructed by the team. It may be found that certain design
concepts do not translate into the practical development of the SMS. At this
stage a review is needed to amend the design.
What needs to be consulted is if there will be any disruption of the critical path
set. If there is, then it will need to be amended. Disruption should be kept to the
minimum possible.
As the ideas of the design stage become a reality then it is the responsibility of
the team to ensure that the persons that will use it are testing the SMS. This is
important, as the feedback will indicate where amendments have to be made.
The worst scenario is when a team completes the SMS and then put it out to be
used. During the development stage there has been no feedback and therefore
the potential problems that can arise have not been resolved.
The result will be a plethora of revisions and this in turn will slow down the
implementation of the SMS.
With the development of the SMS reaching its final stages, the implementation
should begin. There is no point in waiting until the SMS is complete. If the
implementation is delayed until the SMS is complete the timeframe for the
project will be increased. This is not to the benefit of the company.
IMPLEMENTATION
The implementation programme of the system should be realistic.
One of the fundamental and recurring flaws is when those that have constructed
the SMS, as built into the critical path set, is the timeframe for the implementation.
There has to be dialogue with those that have to work with the system in order
to have their input as to their understanding of the how the system will work.

In addition, the office(s) and ship(s) are workplaces. The implementation of the
SMS has to be integrated with the current workload.
It is inevitable that delays will occur. If these have not been factored into the
implementation then the control and critical path will be lost and the result will
be a large increase in the time and cost to bring the company to certification.
What has to be avoided is when the other extreme occurs. That is when the
implementation is taking far too long. This creates the same problems as if the
timeframe is too short and the momentum of the project is lost.
The implementation takes time and needs to be phased correctly. If the whole of
the SMS is dumped on an office or a ship then the process of understanding the
SMS can be damaged.
People need education and training in a system before it becomes acceptable.

They need to be shown what the benefits of a system will be to them and the
way they work. If it is forced onto them there will always be resentment, and this
will filter through in the way the system works at a particular site.
This resentment stops the SMS realising its full potential and an important
opportunity for the company will be lost.
Throughout this process from design to development to implementation there

must be one repeated question that the team must ask to keep control and
perspective.
“What are we trying to achieve?”
6B-082 The above gives a sense of what is needed to construct a SMS and bring it to
certification.
6B-083 Once certified the SMS has completed its first cycle. For many the belief was
that once certified they could sit back and let the system run itself.
6B-084 Regrettably that was not true and in many cases it has proved more difficult to
maintain certification that it was to achieve it. This comes from the problems in
the initial stages of the design of the SMS.
6B-085 If a SMS was built and hard-wired to meet the standard required it will not have
the flexibility to evolve which will have been brought about by the structure
used.
6B-086 The result will be that each and every revision/amendment of the SMS will cause
a major amount of work to ensure that it is fitted in throughout the system.
Additional checks will have to be made to ensure that nothing has been missed
or the result could be that the SMS has sections in opposition to each other.
6B-087 Problems will also arise when inserting new legislation and requirements to the
SMS. The same can also occur when removing sections.

Inspect the structure of the SMS in your company
How user-friendly do you find the contents?
Is your SMS in an electronic or hard copy or hybrid format?
Which style of format do you find most user-friendly to you?
2.4 AUDIT SCHEDULE AND COMPLIANCE
6B-088 The ISM Code is an audit regime and as a result it is dependent upon auditing,
not inspection or survey as the method for ascertaining its compliance to the
standard.
6B-089 What must never be forgotten is the fact that even if an audit does not report any
non-conformity; it does not mean that they do not exist. All that it means is that
the sampling taken by the auditor did not find any.
6B-090 The ISM Code has its own cycle for auditing. It does not match the ISO 9000 but
is sympathetic with the ISPS Code.
6B-091 It should also be noted that the ISM Code is not part of the Harmonized System
of Survey and Certification (HSSC) and never will be.
6B-092 The following section will assist the delegate in understanding the auditing cycle
for certification.
2.4.1 The depth, scope and types of internal audits are explained correctly in
relation to the requirements of the relevant international, national or
organisational standard and organisation systemic requirements
6B-093 Auditing is one of the most misunderstood concepts in the maritime industry.
6B-094 An audit is not an inspection. It is not a survey.
6B-095 The methodology of conducting an audit has its own unique requirements and
style of being conducted from beginning to end.
6B-096 The delegate is tasked to understand the concept and practices of systemic
internal auditing.

6B-097 There are three types of audit:
Internal
External
Verification (Certification).
Internal We audit ourselves
External We are audited by an outside party
Verification We are audited by a third-party organisation for the purpose

of attaining certification.
In some countries within the maritime industry the flag administrations have
decided that the verification audit for certification will be called an external audit.
This leads to some confusion. Companies and their personnel must always
ensure that the type of audit and its purpose is clearly understood by all
involved.
When an audit is being conducted everyone must be made aware of what type
of audit is being conducted.
Before anyone can conduct an audit they need to be trained in the required
techniques of auditing so as to be able to complete the task.
Many people within the maritime industry have been trained as internal auditors
to the ISO 9000 series. This is a standard for quality assurance, not for Safety
Management Systems, which is the standard to which the company is being
certified.
The reason for this was at an earlier time there were no courses for internal
auditing of Safety Management Systems and therefore the closest criteria that
could be found were the Internal Auditors Course for ISO 9000.
The best definition of an audit can be found in ISO 9000:2000:
“Systematic, independent and documented process for obtaining evidence and

evaluating it objectively to determine the extent to which audit criteria are
fulfilled.”
A maritime definition of inspection can be found in IMO Res.A.1052(27),

section 1.7.5 which states:
“A visit on board a ship to check both the validity of the relevant certificates and
other documents, and the overall condition of the ship its equipment and its
crew”
This is the Procedure for Port State Control Inspections.
The ISM Code makes reference to internal auditing in the following sections:

12.1
The company should carry out internal safety audits to verify whether safety and
pollution-prevention activities comply with the safety management system.
12.3
The audits and possible corrective actions should be carried out in accordance
with documented procedures.
12.4
Personnel carrying out audits should be independent of the areas being audited
unless this is impracticable due to the size and nature of the company.
12.5
The results of the audits and reviews should be brought to the attention of all
personnel having responsibility in the area involved.
12.6
The management personnel responsible for the area involved should take timely
corrective action on deficiencies found.
ALSO,
1.4.6
Procedures for internal audits and management reviews
The company needs to review these requirements and decide how best to meet
them.
What cannot be dismissed is the fact that any person who is to become an
internal auditor of the company’s Safety Management System needs to be
trained.
The company will be required to show how the auditors were trained.
This decision on what course to take will have a knock-on effect to the other
sections of the Code affected by the internal audit requirement.
The company can
– Send personnel on recognised courses
– Develop courses of their own and deliver them internally
– Have trained personnel from outside of the company conduct the internal
audits
The first option obtains records of persons being trained in the generic style of
auditing for SMS. It is not company specific, but shows that the company has

identified the need for training to enable personnel to conduct the required
audits. The problem is that it is expensive.
The second option can be done but requires time and effort to develop this
course to the right standard. It also requires identifying the person or persons
who will have to be trained and then design develop and implement the training
courses within the company. If the company has the resources, then this is the
best option to follow.
The company is perceived as having a lack of commitment to the SMS when it

uses this last option. Also personnel who are not working daily with the
company’s SMS tend to produce a standard format of audit questions and
responses.
The company is required by the ISM Code to produce procedures for internal
auditing (1.4.6 & 12.3).
Therefore to meet this requirement, certain criteria need to be established.
SCOPE
The scope of the internal audit is to audit the company’s SMS both ashore and
on-board ship. This is by a sampling process and where any non-conformities
are found, of whatever grade, are reported and the necessary corrective
action.
DEPTH
The depth of the internal audit is to check how the well the company complies
with its SMS. The sampling process used means that although no non-
conformities were found in the sample taken that does not mean that non-
conformities do not exist in the SMS.
When non-conformities are found, the auditor has to then check how far-ranging
and how deep into the SMS the problem goes.
TYPES
The type of internal audit conducted by the company on itself has to be

consistent. The style of auditing may vary between auditors but the format,
method of reporting and the raising of non-conformities must be consistent.
To this end, the company is required to ensure that contained in its procedures
is the complete set of requirements for internal auditing.
The internal audit can be accomplished by using a number of audits at various

times of a predetermined interval to ensure that the complete SMS has been
sampled.
For the ship, the internal audits may be conducted by the ship’s staff or by
members of the shore staff.
The principles involved carry over onto certification audits but the standard
changes from the company’s SMS to the ISM Code.

2.4.2 The ISM Code Certificates
There are four certificates and these are:
Interim Document of Compliance (IDOC)
Interim Safety Management Certificate (ISMC)
Document of Compliance (DOC)
Safety Management Certificate (SMC).
6B-098 The IDOC is a one-off certificate that has a maximum life of 12 months. Not one
year, but 12 months. This certificate cannot be extended or re-issued.
6B-099 The ISMC is valid for a maximum of six months. Under special cases being
justified it can be extended for a maximum of six months from the date of expiry
of the original period of validity.
6B-100 The DOC has a validity of a maximum of five years subject to it being maintained
by endorsement at annual verification.
6B-101 The SMC has a validity of a maximum of five years subject to it being maintained
by endorsement at intermediate verification and additional verification (if
required). Under special circumstances the date for the renewal audit can be
extended past the five year maximum. This is laid down in in part B of the code
and is shown on the SMC.
6B-102 There must be a valid and relevant DOC in place before any SMC can be
audited and a certificate issued.
6B-103 On board a ship there will be a copy of the DOC which was issued to an office.
It is the only certificate carried on board a ship that is not an original.
2.4.3 The ISM Codes Audits for Certification
6B-104 The ISM Code has the following audits conducted for certification and continued
certification.
6B-105 There will also be the identification of the audit windows. That is the time duration
when audits can be conducted.
To achieve ISM Certification the Company needs to be audited. This can be

conducted by the flag administration or administrations that the company has
ships registered with. Or a Recognised Organisation can be used (see IMO
Res.A.739(18) and IMO Res.789(19).
The company must be aware of the requirements of:
IMO Res. A.741(18) as amended by MSC.104(73), MSC.179(79), MSC.195(80)

and MSC. 273(85) International Safety Management (ISM) Code Part B –
Certification and Verification

IMO Res. A.1022(26) Guidelines on implementation of the International Safety

Management Code (ISM) Code by Administrations.
Also, any additional requirements imposed by any particular flag administration

that the ships are registered under.
SOLAS Chapter IX – Management for the safe operation of ships
This gave the dates for mandatory compliance to the ISM Code. It also detailed
the ship types and tonnage.
Phase I was 1 July 1998
Phase II was 1 July 2002
Therefore, any company now wishing to obtain ISM Code certification will be
required to undertake the additional steps of interim certification before achiev-
ing full term certification.
The exception to this may be that a flag administration has mandatory compliance
to the ISM Code for companies and ships that were outwith the requirements
imposed by SOLAS Chapter IX.
After the Safety Management System has been completed, it must operate for
a minimum of three months and have the objective evidence to hand to prove its
operation before it can be audited.
Included in the requirements is that a management review must have taken

place:
Internal audits have taken place also.
6B-106 The concept that must be shown in the initial verification audit for certification is
how the company has met the requirements of each and every section of the
Code. This includes each sub-section.
6B-107 Objective evidence will be required to show how this has been achieved.
6B-108 The Company will be required to achieve a Document of Compliance (DOC).
6B-109 If the company has a multi-flagged and multi-typed fleet, then it will have to have
made sure that the Document of Compliance from each flag administration is
correctly issued showing the ship types that are being operated by the company
for each flag. (Note: a blanket DOC cannot be issued.) The term blanket means
that the DOC is issued by each flag state for all of the ship types that the
Company operates whether there are ship ships registered with each particular
flag state.
6B-110 In addition, the company will have to show how it has met the particular
requirements that any flag administration has made in respect of the ISM
Code.

6B-111 A further potential problem with a multi-flagged fleet is who will conduct the
audit/audits.
6B-112 Some flag administrations may have decided to conduct the audits with their
own staff. Other flag administrations may have delegated full authority to certain
named Recognised Organisations (ROs).
6B-113 Another option that is used is where flag administrations delegate audits for
some particular ship types but not for others.
6B-114 Alternatively, the flag administrations can delegate only certain audits to be
conducted by Recognised Organisations, while they retain jurisdiction to conduct
the other named audits.
6B-115 The Company can face a further problem when various flag administrations will
only conduct the audits of the company and the ships under their flag conducted
separately. This can mean that the company will experience the initial verification
audit at different times. It will be a repeat but will vary depending upon the
particular requirements that the flag has made.
6B-116 Before the audit is scheduled; the company should have clarified exactly what it
will be doing in respect of audits.
6B-117 This will have been planned well in advance, and if possible, it would be hoped
that one audit body would be able to conduct one audit covering all permutations
and allowing certification to be progressed.
6B-118 Some flag administrations allow Recognised Organisations to conduct the audits
while they retain the right to issue the certificates upon receipt of the audit report
including the recommendation of the auditor.
6B-119 The Company must obtain the Document of Compliance relevant to the ship and
place a copy on board before the ship can be audited.
6B-120 This is to authenticate that the “company” named for the purpose of the ISM
Code, as being responsible for the vessel is the actual named entity.
6B-121 In addition, the information contained on the Document of Compliance can be

seen to be relevant or not to the ship.
6B-122 The format and information that must be inserted onto the DOC and SMC can
be found in the latest edition of the ISM Code.
6B-123 With the DOC in place and operating in the office, the ships have to be
audited.
NOTE: It is not possible to hold a SMC without a valid DOC being in place.
Each ship now requires to be audited. This can only be conducted on board the
vessel. Therefore, the audit has to take place on board the vessel while the
vessel is in operation.

Upon completion of the audit the auditor will recommend or decline to recommend
certification.
The restrictions and applications as mentioned for the Document of Compliance

also hold good for the Safety Management Certificate.
For the Safety Management Certificate it is the original certificate that is to be

held on board. Copies or certified copies are not acceptable.
With the certificates in place and the SMS operating, the real work then
begins.
This is keeping the system operational and ensuring the continuous improvement
is being kept and measured.
Where the company can now struggle is in keeping control of the administration
that is generated.
This is a major problem because the next cycle of audits will immediately
ascertain if the administration of the system is working.
The audits are titled
For the Office Annual Verification
and
For the Ships Intermediate Verification
The office audits take place within three months before or after the anniversary
date every year.
The ship audits take place within the second and third anniversary date.
The anniversary date definition is “the date and month of each year that
corresponds to the date of expiry of the relevant document or certificates.” [ISM
Code part A 1.1.11]
The office and ships require a renewal audit.
These audits have to take place within three months of the expiry date of the
certificate in question.
Should the audit take place within this time window then upon completion the
new certificate will commence on the date of expiry of the old certificate?
If the renewal audits are conducted before the three-month window, then the
new certificate will commence from the date of completion of the audit.
These windows for the audits are not subject to extension. The audits must be
carried out within the timeframes allowed.

The full term certificates have a timeframe of five years. This is from the date of
completion of the initial audit. For SMCs under special circumstances the ISM
Code section B 13.14 can be applied. This is not the norm but should only be
applied in special circumstances. Therefore an extension beyond the five year
limit can be applied.
The cycle once established will be maintained and the company will need to
ensure that the audit windows are met.
For the offices it is not too difficult to meet these time windows.
It is more difficult for the ships. Although, in effect a one-year window is offered
for the intermediate audit, many companies leave it until near the end of the
window. This is where the problems start. Should the ship obtain a charter where
it is not possible for an auditor to reach the ship then there is the possibility of
losing the certification?
What the company must be aware of is that any non-conformities raised at any
verification and/or certification audit must be resolved and closed out within the
time agreed on each non-conformity report.
If this is not done then the non-conformity will be raised to the status of major
non-conformity.
Any unresolved major non-conformity would result in the withdrawal of

certification.
If a major non-conformity is raised at Initial Audit, a certificate will not be

recommended for issuing until such time as the major non-conformity is
resolved.
Cycle of Audits
Office Ship
Initial Initial
Annual (every year) Intermediate (between 2nd & 3rd

Anniversary)
Renewal Renewal
Apart from these audits the Company and ships can experience “Additional
Audits”.
These can be required for a number of reasons such as:
• Clearing of non-conformities
• Clearing major non-conformities
• As a result of Port State Control inspection

• As required by flag administration
• As required by Recognised Organisation
Any of these audits may have specific criteria to be conducted.
It should also be noted that the criteria can be expanded if the auditor finds
evidence that the SMS is not working in other areas.
Interim Certification
This is now contained in the ISM Code Part B – Section 14.
Interim DOC
Newly established Company
New ship types are to be added to an existing DOC
Company to show that it has a safety management system to meet the objectives
of 1.2.3 and that a plan is in place to implement the system within 12 months.
Note: An Interim DOC will only be issued once
There is no extension
There is no renewal of an Interim DOC
If the Interim DOC is issued for a period of less than 12 months, then the
Company must implement and obtain a full term DOC within the time stated
Interim SMC
To new ships on delivery
When a Company takes on the responsibility for the operation of a ship which is
new to the Company
When a ship changes flag
Interim SMC issued for a period of six months
In special cases the Interim SMC can be extended for a further six months. This
can only be given by the flag administration
To allow the issuance of an Interim SMC the following items must be verified:
1 The Document of Compliance or Interim Document of Compliance, is

relevant to the ship concerned
• The safety management system provided by the Company for the ship
concerned includes key elements of this Code and has been assessed
during the audit for issuance of the Document of Compliance or
demonstrated for issuance of the Interim Document of Compliance.

• The company has planned the audit of the ship within three months.
• The Master and officers are familiar with the safety management
system and the planned arrangements for its implementation.
• Instructions, which have been identified as being essential, are

provided prior to sailing.
• Relevant information on the safety management system has been

given in a working language or languages understood by the ship’s
personnel.
• The Interim DOC must be in place before the Interim SMC audit can
take place.
The company must ensure that the full term DOC is in place before the full term
audit of the ship can take place.
This means that the company needs to obtain the Interim DOC in advance of
the ship.
The “special case” that the company presents to the flag administration for the
extension to the Interim SMC, needs to be exactly that, a special case.
If the flag administration feel that the case presented to them is not special, they
have the right to refuse the extension, which would have a major impact on the
operation of the company.
SPECIAL NOTE:
In too many cases the company and its ships have a major problem with
administering the SMS that was created for certification purposes.
The auditor is not required to audit how good or efficient the SMS is, but whether
it meets the criteria of the ISM Code.
If the SMS is too heavy with administration (forms, files, inspections, reports,
meetings etc.) then it will fail to meet its expectations.
This will be found at the next audit of the office. (This will cover both office and
ship’s files.)
In addition, if the SMS is not operating properly, this may well be found out at a
Port State Control Inspection, which will then raise non-conformities against the
SMS. These will have to be dealt with.
In addition, non-conformities, of whatever type have to be dealt with properly and

in time. This applies to internal, external and verification audits.
No matter how good the SMS is, unless the personnel required to work with it
are properly educated and trained in its use, it will never reach its full potential
of effectiveness and efficiency.

If the SMS is working properly, then there will be no need to prepare for an audit.
The system will work correctly and so it can be audited at any time.
If time is needed to prepare for an audit, then the SMS is not working properly.
The company needs to understand that the SMS and its audits for continued
certification work on a cycle pattern. The cycle is continuous and repetitive.
Break the cycle and lose the certificates.
Lose the certificates the company stops trading.
Remember:
Loss of the SMC and only that ship is affected.
Loss of the DOC and all ships connected to that DOC lose their SMC.
2.4.4 Maintaining Certification
6B-124 The Company needs to ensure that the DOCs and SMCs are kept up to date.
6B-125 The ship manager needs to keep on top of the certification and know where the
ship will be trading. The reason for this is to know where auditors will be available
to conduct the audits. It does not matter what you do the audit windows remain
the same so you have to ensure compliance within the required timeframe.
6B-126 In respect of the SMC for the ships, the latest edition of the certificate has two
additional parts.
“Endorsement where the renewal verification has been completed and Part B
13.13 of the ISM Code Applies”
and
“Endorsement to extent the validity of the certificate until reaching the port of
verification where part B13.12 of the ISM Code applies or for a period of grace
where Part B13.14 of the ISM Code applies”
ISM Code
Part B
Section 13.13
“If a renewal verification has been completed and a new Safety Management
Certificate cannot be issued or placed on board the ship before the expiry date
of the existing certificate, the Administration or organization recognized by the
Administration may endorse the existing certificate and such a certificate should
be accepted as valid for a further period which should not exceed five months
from the expiry date.”

ISM Code
Part B
Section 13.12
“When the renewal verification is completed after the expiry date of the existing
Safety Management Certificate, the new Safety Management Certificate should
be valid from the date of completion of the renewal verification to a date not
exceeding five years from the date of expiry of the existing Safety Management
Certificate.”
Part of the remit of the IMO is that for all of the conventions put in place it is
understood that no certificate shall have a validity of more than five years.
In your Company find the SMC for a ship and then match it up with the
relevant DOC.
What training do ISM Code Internal Auditors receive in your Company?
How is the audit schedule set for ISM Code certification audits of the
company offices and ships?
How closely is it complied with?
2.5 THE EFFECT OF THE MULTI-NATIONAL FLEET
2.5.1 Multi-national Fleets and the Problems Associated with Them
6B-127 For some of the larger companies and especially amongst the ship management
companies the rise of the multi-type and multi-flag fleet brings its own problems
and complexities in operation.
6B-128 When you add to that multi-national crews the potential for things to go wrong
are multiplied at more than an arithmetic progression.
6B-129 The complexity for a ship management company is that the ship owner may
have a number of issues that they require to be met if the management contract
is to be satisfied. In some cases these might not fit the profile that the company
has and amendments have to be made.
6B-130 Some of the facts that have to be looked into are as follows:
• Ship types (as per SOLAS Chapter IX).
• Flag States that the ship types are registered under.

• Classification societies used for the ships.
• Nationality of the crews.
• Official language of the company.
• Working language on board the ships.
• Language that the SMS is written in.
6B-131 From these results you try to build a matrix of the company and then review who
can conduct what audits and how many Recognised Organisations (ROs) that
you will be working with in respect of ISM Code audits and certification.
6B-132 Remember some flag administrations do not delegate to ROs, or only give
partial delegation to ROs.
6B-133 Therefore, before building the matrix you need to identify ship types for the fleet,
as per SOLAS Chapter IX.
6B-134 Then identify the classification societies and/or flag administrations that will
conduct the audits and the flag states where the ships are registered.
6B-135 The main point of this exercise is to identify how many organisations are going
to be involved in the auditing of the offices and fleet. The issue of language will
become important if ROs have to supply auditors with additional language skills
to conduct the audit because the working language on board is that of a
particular nationality and is different to the official language of the company.
6B-136 For the offices and the issuance of the DOCs, it must be borne in mind that
because you have a DOC for bulk carriers from Cyprus that Liberia will
automatically grant you a DOC for bulk carriers. They will probably want to
conduct their own audit.
6B-137 This makes keeping the dates for the initial audits and annual verification audits
on one date impossible. But you do want to minimise the number of DOC audits
taking place.
6B-138 Each ship has its auditing requirements and maintenance of certification
requirements, but it is subject to maintaining a relevant and valid DOC.
6B-139 The more complex the company, the more complex the demands are to enable
the auditing to be kept track of and controlled.
Check your company and how many organisations are involved to keep the
offices and the ships fully certified to the standards of the ISM Code.
SOLAS IX – Reg. 2.1.3 has the ship type “Other cargo ship”. What ship type
do you think falls into this category?

3. THE ISPS CODE AND THE MANAGER
LEARNING OUTCOMES
• Have a better understanding of the ISPS Code and its application.
• Be more able to look at the ISPS Code and the effect of security and
safety – are they the same or different.
• Have a better understanding of the role of the Company Security

Officer and the relationship with the manager.
• Understand the importance of Ship Security Plan.
• Understand the dynamics and relationship between the Ship Security

Officer, Company Security Officer and the Port Facility Security
Officer.
3.1 UNDERSTANDING THE ISPS CODE
3.1.1 Introduction
6B-140 To write this chapter the author thought it best to take the delegate through the
journey from starting out to certification. This is what companies and their
personnel have to do. In this manner the delegate is learning what the ISPS
Code requires of them and how it works in a company and on board ships.
6B-141 There is no one right way of approaching or complying with the ISPS Code. It is
a matter of complying with all sections and sub-sections but in a way that reflects
the working practices of the company.
In 2012, the IMO issued the “Guide to Maritime Security and the ISPS Code”
2012 edition. This is a major document bringing together a number of publications
relating to maritime security. The contents are as follows:-
Guide to maritime security and the ISPS Code
Section 1 – Introduction
Section 2 – Security responsibilities of Governments and their national

authorities
Section 3 – Security responsibilities of port facility and port operators
Section 4 – Security responsibilities of ship operators
Section 5 – Framework for conducting security assessments

The ISPS Code and the Manager Module 6B
Resolutions of the Conference of Contracting Governments to the International

Convention for the Safety of Life at Sea, 1974, adopted in December 2002
Conference resolution 1 – Adoption of amendments to the Annex to the

International Convention for the Safety of Life at Sea, 1974
Conference resolution 2 – Adoption of the International Code for the Security of

Ships and of Port Facilities
Preamble
ISPS Code
Foreward
Part A – Mandatory requirements regarding the provisions of chapter XI-2 of the

Annex to the International Convention for the Safety of Life at Sea, 1974, as
amended
Part B – Guidance regarding the provisions of chapter XI-2 of the Annex to the
International Convention for the Safety of Life at Sea, 1974, as amended and
part A of this Code
Conference resolution 3 – Further work by the International Maritime Organization

pertaining to the enhancement of maritime security
Conference resolution 4 – Future amendments to chapters XI–1 and XI-2 of the

1974 SOLAS Convention on special measures to enhance maritime safety and
security
Conference resolution 5 – Promotion of technical co-operation and assistance
Conference resolution 6 – Early implementation of the special measures to

enhance maritime security
Conference resolution 7 – Establishment of appropriate measures to enhance

the security of ships, port facilities, mobile offshore drilling units on location and
fixed and floating platforms not covered by chapter XI-2 of the 1974 SOLAS
Convention
Conference resolution 8 – Enhancement of security in co-operation with the

International Labour Organization
Conference resolution 9 – Enhancement of security in co-operation with the

World Customs Organization
Conference resolution 10 – early implementation of long-range ship’s identification

and tracking
Conference resolution 11 – Human-element-related aspects and shore leave for

seafarers

Module 6B The ISPS Code and the Manager
As can be seen from the above titles there has been a large expansion of
materials that personnel must be aware of when using and working with the
ISPS Code
3.1.2 The ISPS Code
6B-142 The ISPS Code required mandatory compliance for ships of convention size by
required dates. These are contained in SOLAS Chapter XI-2 Regulation 2 –
Application and Regulation 6 – Ship Security Alert System.
6B-143 This details ship types as follows:
Passenger Ships
High-Speed Passenger Craft
Cargo Ships: 500 gross tonnage and upwards
High Speed Craft: 500 gross tonnage and upwards
Mobile Offshore Drilling Units
Port facilities serving such ships engaged on international voyages
6B-144 Passenger ships will include passenger Ro-Ros, passenger high-speed craft
such as WIG craft, fast cats etc.
6B-145 Cargo ships will include bulk carriers, oil tankers, chemical tankers, gas carriers,
general cargo ships and ships of all types that are not of the passenger ship
design criteria. This can be quoted as being of the type “Other Cargo Ships”
which will include ships such as livestock carriers, container ships and general
cargo ships, as examples.
6B-146 The Ship Security Alert System had to be in place for survey for ship types and
dates of:
1 July 2004 Passenger Ships
Passenger High-Speed Craft
Oil Tankers
Chemical Tankers
Gas Carriers
Bulk Carriers
Cargo High-Speed Craft
1 July 2006 Other Cargo Ships
Mobile Offshore Drilling Units

6B-147 For those familiar with the ISM Code it will become apparent that the ship types
listed for the ISPS Code have the same notations as those given in the ISM
Code.
6B-148 The problem faced by the maritime industry was that from the Diplomatic
Conference of December 2002, the first phase had to be completed by 1 July
2004 and the second phase by 1 July 2006.
6B-149 This has not given the industry a lot of time to put in place complex systems that
required precise criteria to comply with the ISPS Code.
6B-150 Many of you will have already experienced the ISPS Code and the manner in
which it has been included into the normal day-to-day operation of the
Company.
6B-151 SOLAS Chapter XI-2 makes the ISPS Code mandatory. The ISPS Code comes
in two parts: Part A – Mandatory; and Part B – Guidance. It is not really possible
to meet the requirements of Part A without taking into account the contents of
Part B.
3.1.3 Security Personnel
6B-152 The legislation has also brought about the introduction of three new “job titles”
with the relevant descriptions for personnel in the shipping industry.
6B-153 These are:
Company Security Officer (CSO)
Ship Security Officer (SSO)
Port Facility Security Officer (PFSO).
6B-154 The complete requirements for these job titles can be found in the following IMO
Model Courses. I have referenced to the 2003 Edition for each one:
IMO Model Course 3.19 Ship Security Officer (IMO T319E)
IMO Model Course 3.20 Company Security Officer (IMO T320E)
IMO Model Course 3.21 Port Facility Security Officer (IMO T321E)
6B-155 The UK Merchant Navy Training Board (MNTB) has also set its standards for
approved courses for each of the titles given above.
6B-156 Any person who is to hold one or more of the above job titles must have
completed and passed the relevant courses, have been approved by the relevant
administration and have the certificate or certificates to show that the required
minimum standard has been achieved.
6B-157 There are no required entry standards for these courses but it is expected that
the persons attending have relevant experience in the particular course they
attend and are employed or will be employed by the appropriate body.

6B-158 When a person takes up the position of Ship Security Officer, Company Security
Officer or Port Facility Security Officer, they must be fully conversant with the
legislation and how it will affect their performance of their duties.
6B-159 For persons working on board ship and/or in the office they must be able to
place in perspective how the ISPS Code fits into the Company’s operations. No
piece of legislation can exist in a vacuum. The other pieces of the Company’s
operations impinge upon it.
6B-160 Therefore each person should be aware of how the ISPS Code interacts with the
company’s Safety Management System (SMS) that is required for compliance
with the ISM Code.
Who is the CSO in your organisation?
Which rank is chosen to be the SSO on board ships?
Is there a deputy CSO? If not, what happens if the CSO is incapacitated?
How is the relationship between the CSO and the ship managers?
3.2 SECURITY VERSUS SAFETY: SAME OR DIFFERENT?
6B-161 There have been arguments surrounding what is more important: SAFETY
versus SECURITY. The answer is both have an equal footing. If a ship is not safe
it should not sail. If a ship is not secure then it is in danger from external forces.
Therefore a ship that is completely safe but not secure is in danger. A ship that
is secure but not safe is in danger. It does not matter where the danger comes
from; if the ship is not prepared and able to protect itself then the consequences
have the potential to be extreme.
6B-162 By ensuring that the SMS is taken into account and worked with in defining the
security requirements of the ship then it is possible to ensure that no frictions
between the two codes come into play.
6B-163 An example of this is that the security equipment carried on board is required to
be kept certified and ready for use. Therefore the security equipment is liable for
inspection and test at regular intervals. The Ship Security Officer will be tasked
to ensure its ongoing effective operation. This will be found in the manufacturers’
operation and maintenance manuals. The question is in ensuring these tasks
are carried out. The schedule for maintenance, test, calibration and continued
certification needs to be identified. It may be that at times the equipment will
have to be sent ashore for continued certification or perhaps the need for
qualified technicians to come on board and carry out the specialised work for
certification.
6B-164 If the SSO is working in a vacuum he may miss the opportunity for the equipment
to be re-certified at one port where technicians are available, but the port where

he has decided to have the re-certification done does not have the required
skilled personnel.
6B-165 Although, the SSO will be required to keep the records and data, if he integrates
his requirements with that of the Planned Maintenance System of the ship then
there is less chance of something being missed and the problems that this will
entail.
3.3 THE COMPANY SECURITY OFFICER AND THE SHIP MANAGER
6B-166 Depending upon the way the company is structured it could well be that the ship
manager is also a Company Security Officer.
6B-167 In other companies the CSO will be a dedicated position. There is nothing in the
ISPS Code to stop the company having more than one CSO. But as a minimum
there should be at least one other person trained and qualified to the standard
of CSO, so that they can deputise for the CSO and be ready to cover for the
CSO when he is not available for whatever reason.
6B-168 Whatever the company set-up is, the central point must be that the CSO and the
ship manager(s) need each other to function efficiently and effectively. If this is
not the case then if there is a lack of, or breakdown in, communications there
could be problems for the safe and secure operation of the ships.
6B-169 Both need each other to operate at the optimum performance. If this is not
understood then it should be communicated to the parties involved by senior
management.
6B-170 This is especially relevant when ships are trading into areas where security is
more important due to the increased risk. One such area is that surrounding the
Somalia coastline and out into the Indian Ocean.
6B-171 This is one of the most dangerous areas in the world for ships to transit due to
the piracy issues. Every ship needs full and combined support from the office.
Fragmented support from the office resulting in miscommunications or
communications contradicting each other could cause major problems.
6B-172 Fragmentary support is the exception rather than the rule but it should be noted
that it is necessary for the two positions within the company to work together to
achieve best results.
How many CSO(s) does the company have?
Is the CSO a separate position to the ship manager?
How do the CSO and ship manager communicate? Regularly/frequently/by

e-mail/face to face/etc.

3.4 THE SHIP SECURITY PLAN
3.4.1 Methodology of Certification
6B-173 The ISPS Code is certified by auditing and the maintenance of the certificates
is based on verification, intermediate and additional audits. The requirements for
auditing and the certificates required will be explored in more depth in later
chapters of this module.
6B-174 The ship requires to be certified, but not the office of the company. The certificate
is titled “International Ship Security Certificate” (ISSC).
6B-175 The port facility is required to be certified and this requires a certificate titled
“Statement of Compliance of a Port Facility”.
6B-176 The audits for certification will be conducted by a “Recognised Security

Organisation” (RSO) which is defined in SOLAS XI-2, Regulation 1-16 as:
“an organisation with appropriate expertise in security matters and with

appropriate knowledge of ship and port operations authorised to carry out
an assessment or a verification, or an approval or a certification activity,
required by this chapter or by Part A of the ISPS Code.”
6B-177 The auditing for certification is conducted by either flag administrations or

Recognised Organisations (RO) delegated by flag administrations. In most
cases the Recognised Organisations are classification societies. In particular,
the International Association of Classification Societies (IACS) member societies
which have demonstrated to the flag administrations how they meet the
requirements.
6B-178 To this end, IACS produced its Procedural Requirements (PR) to accommodate
the ISPS Code. These have been titled:
Procedural Requirements for ISPS Code Certification
Procedure for Training and Qualification of Maritime Security Auditors
Procedure for Reporting the List of Ships complying with the ISPS Code
Transfer of ISPS Code Certification (TOSCA).
6B-179 Other Recognised Organisations that can show that they comply with the
requirements for auditing and certification to the ISPS Code may also be the flag
administration grant delegation to perform this work.
6B-180 The requirements to be fulfilled by a Recognised Organisation can be found in

IMO Resolution A.739 (18) – “Guidelines for the Authorisation of Organisations
Acting on Behalf of the Administration”.
6B-181 The requirements for being granted delegation from a Flag Administration can
be found in IMO Resolution A.789 (19) – “Specifications on the Survey and
Certification Functions of Recognised Organisations Acting on Behalf of the
Administrations”.

Who is or are the Recognised Organisations conducting the ISPS Code

audits of your company’s ships?
Who is issuing the ISSCs to your company’s ships?
Who is issuing the ISM certification to your company?
Which RO classes the ships of the company?
3.4.2 Maintenance of Certification
6B-182 Once the process of certification is completed and the ships of the company
hold the relevant International Ship Security Certificate (ISSC), it is then that the
second cycle of work begins in ensuring that the requirements of the ISPS Code
are met and records are kept so that by auditing the ships will continue to be
certified and able to trade.
6B-183 Failure to maintain the various documents and records will mean that there
could be problems for trading the vessels and also with Port State Control (PSC)
inspections and with the classification societies.
6B-184 It is important to ensure that there is an understanding by every person in the

company as to what is to be achieved and must be maintained in respect of the
ISPS Code. Therefore, training, training and retraining in cycles must be carried
out.
6B-185 The question that must be raised is how would the insurance company of a ship
view paying out after a “security incident” if it was shown that the Ship Security
Plan (SSP) appeared not to be working to the standard stated?
3.4.3 Process of Implementing the ISPS Code into a Company
3.4.3.1 The Process
6B-186 The options available to the company are varied. There are many options and it
would be best for the company to choose a process, which is sympathetic to the
way in which they operate. This will reduce the amount of disruption to the
operation of the company while the process of implementing the system and
training of personnel to cope with the additional work load that implementation
requires and then the re-organisation that will be put in place to ensure that the
system runs within the company’s normal operating practices.
6B-187 It would appear that due to the recent additional workloads that recent legislation
has imposed on companies that, perhaps, it may soon become necessary for
ships to employ an administrator to support the officers and crew to ensure
compliance is kept.
6B-188 Examples of the changes to work practices are:

SOLAS revisions
The ISM Code
STCW 95, including the 2010 Manila Amendments
ILO Convention 180 (now incorporated in the MLC 2006)
ISPS Code.
6B-189 The extra workload on smaller crews needs to be accommodated while at the
same time, where applicable, complying with the restrictions of working hours
from STCW Part A Chapter 8 Part 1 – Fitness for Duty and ILO Convention
180 – Seafarers’ Hours of Work and the Manning of Ships.
6B-190 Both of these standards have to be taken into account when complying with
SOLAS Chapter V – Safety of Navigation – Regulation 14 – Ships’ Manning and
the IMO Resolution A.890 (21) – Principles of Safe Manning.
6B-191 In the following sections we will explore how the process can be implemented
and follow one possible option to ensure compliance.
3.4.3.2 Implementation of the ISPS Code
6B-192 To explore the options of implementing the ISPS Code into a company and its
ships, it should be understood there are certian steps to be followed and also
the ongoing process of dealing with the requirements that must be met.
6B-193 The following steps are one option that could be taken and used. There are
many other variations on this theme and a Company must decide which best fits
its operations and manpower.
Step 1 Identify team members for the project of implementing the ISPS
Code into the Company
Step 2 Identify who will be CSO
Identify which personnel will Deputy CSO
Step 3 Send CSO and Deputy CSO on approved course
Step 4 Identify which rank on board ship will be SSO
Identify which personnel will be required to be trained as SSOs
Step 5 Send SSOs on approved course
(this may require several courses depending on the size of the

company)

Step 6 Identify the flag administrations for the ships
Identify Recognised Organisations, which class the vessels
Identify the Recognised Organisations, which certify the vessels to

the ISM Code
Step 7 Discuss with the flag administrations and Recognised Organisations

the options available for assistance with implementing the ISPS Code
(the simplest option would be a flag administration which also

conducts its own statutory certification and ISM Code certification.
Therefore, it would be the obvious choice for conducting ISPS
Certification)
Step 8 Choose the best option for the company to know who or whom will
be the certifying body for the ISPS Code
Step 9 Decide whether to employ a Recognised Security Organisation to

give consultancy or build own system
Step 10 Organise the Shipboard Safety Assessment (SSA) for each ship
Step 11 Identify from the SSA the work that is needed to achieve
compliance
Step 12 Construct Ship Security Plan (SSP)
Step 13 Have SSP approved by flag administration
Step 14 Implement SSP on board each ship
Step 15 Build up records on board ship, through training and drills plus
implementation of the SSP
Step 16 Organise audits of each ship (when ready) by Recognised Security

Organisation (RSO)
Step 17 Attain International Ship Security Certificate (ISSC) for each ship
Step 18 Complete all ships to ISPS Code
Step 19 Complete 1st Cycle of ISPS Code Certification
Step 20 Commence 2nd Cycle of ISPS Code Certification – Maintenance,

Control, Revision and Administration of the System

3.4.3.3 Discussion of Each Step
Step 1
In identifying the members that will make up the team, the company needs to
ensure that there is the relevant expertise and knowledge to ensure that the
project will work.
Not all members will remain in place for the whole of the project. Personnel may
be brought in at particular times to ensure the ongoing process maintains its
momentum with their particular skills.
There should be one person nominated to be in charge of the project who has
been put in place by the senior management of the company. This may be the
person who will be the Company Security Officer. This person will remain in
place throughout the complete process of implementation.
Apart from good technical skills the person in charge needs to have good inter-
personal skills and be a good communicator.
Remember, in many cases, the personnel being seconded into this team will still
have their duties to conduct as well as the additional workload generated by the
implementation of the ISPS Code.
To give a good balance ensure that ship staff are included to give their views and
expertise as to what will and will not work on the ships.
Step 2
The person who will be the CSO must hold a position that is senior enough to
be listened to and make the system work. If not, then expect delays and problems
in controlling the team and making them work as a cohesive unit.
If the person chosen is too senior then will they have the time to devote to this
process? Also, will they achieve a proper balance in decision making whereby
the other members of the team feel intimidated and as result rubber stamp the
CSO’s suggestions without proper discussion and thereby lose potential to
improve the system.
If the CSO is at too low a position in the company then they will not be listened
to and may have problems in having the necessary resources released to
ensure compliance is reached within the timeframe.
The Deputy CSO must be trained to the level and ability of the CSO. They must
be kept up to date on the state of the ISPS Code requirements within the
company and ships and be able to step in and cover for the CSO when he is out
of the office.
Step 3
Once the CSO and Deputy CSO are identified, they must be sent as soon as
possible on the recognised course and attain the relevant certification.

A prudent company may decide to send additional office personnel on the

course to ensure that they have a proper understanding of the requirements of
the ISPS Code on the company and thereby be more able to assist in the
implementation of the system.
Another practice to assist in the implementation process and construction of the

SSP would be to ensure that at a minimum the CSO and Deputy CSO also
attend the SSO approved course.
Additionally, to understand the performance and requirements of port facilities

send the CSO and Deputy CSO on a PFSO approved course.
Step 4
The first stage of this process is to ensure that a rank is chosen that will be
responsible for being the SSO as well as the other duties of that rank. This will
start the process of certification of SSOs. Depending on the size of the company
and the number of ships it operates then the personnel attending the approved
SSO courses will be carried out in a planned phased attendance.
It would be difficult for only one person per ship to be qualified as a SSO. What
about the Captain and other senior officers? If only one of them is the SSO and
trained for that position, how well will the others cope and understand the duties
and responsibilities imposed on them by the ISPS Code?
Should there not be at least two persons on board each ship who are qualified
as SSOs so that if one is taken ill or unable to discharge his duties, then the
other can step in and ensure the continuity of the procedures and
requirements?
Step 5
Each company will have to examine how it will meet this requirement and how
they are going to ensure that the correct number of personnel are trained and
suitably qualified. There is a capital outlay for placing a large number of persons
on such courses and they are not priced cheaply.
What must be ensured is that the courses attended by company personnel are
properly approved and that the certificates issued are valid for the flags that the
company’s ships fly.
The cost of training personnel should be looked at, not only at the price of the
course, but also the additional costs of travel, accommodation and incidentals,
plus fitting it into leave schedules.
Step 6
The company will have to look at its current position with regard to its ships and
where they are flagged and who classes the ships and who certifies them to the
ISM Code?

If the flag state also classed the ships and certified them to the ISM Code, then
it is a simple matter of entering negotiations with the flag administration and
setting out agreed tariffs and schedules for the work to take place.
This is not normally the case. A ship may be flagged in Liberia, with the
classification being conducted by Lloyd’s Register of Shipping and the ISM Code
certification by Germanischer Lloyd.
Therefore it is important to note which RSOs that the flag administration

recognises and then if the ships are registered under a number of flag
administrations finding out if there is one common entity that fits all flags and
also conducts the classification and/or ISM Code certification of the vessels.
If this is not possible then it will be a matter of finding out how to minimise the
number of RSOs being used by the company to ensure all ships are certified
with the minimum of disruption.
Of course there is another option of using a RSO that is not currently conducting
any business with the company. This is an option but it will create further ripples
in the management and operation of the ships and may not be beneficial to the
company in the long term.
Step 7
The company has some options to choose from in how it will go about
implementing the ISPS Code into the company.
It can either create it own system from the ground up.
It can use a ready-made package and implement this through the company.
It can use consultants to assist it in constructing its own system.
Another option is to use all three of the above and mix and match what is best
suited to its needs.
In considering this the company should have discussions with its RSO or RSOs
to ensure that what it is planning to do will meet the expectations of the RSO
when it comes to the time for auditing and certification.
It may be assumed that the company is doing most of the work itself and only
having assistance from outside organisations, that is, it is taking the most difficult
route with an increased additional workload.
This is possibly true, but the learning curve that the company will go through will
be worth it in the fact that the final system in place truly represents the company
and its work ethic.
An additional side effect of this is that the members of the team will become
more knowledgeable and conversant with the ISPS Code and thereby be in a
better position to protect the company’s interests.

Step 8
In step 6 we discussed the options available. The company must be sure that
whichever option it chooses that the RSO contracted to carry out the work will
be the most suited to its needs.
With so much written about the ISPS Code and companies offering consultancy
and other assistance (for a price), it would be quite easy for the company to
become confused as to which organisation to choose.
That is why it takes time and remember that cheapest is not always best. Neither
is the most expensive a guarantee of receiving the best.
The company needs to construct a checklist of what services it requires. How

long will it need these services and what is the price for each component?
It may be that no organisation can supply the full spectrum of services; therefore
it will be a matter of assessing who can supply the most.
After that it is a matter of identifying the cost and comparing like for like.
Remember, if someone is saying that they can supply everything, ask for
references and ask if you can speak to previous clients. If they do not want to
give such information then ask the reason why. It could be that they are not as
good as they say.
Step 9
It may be that the RSO chosen for certification may be able to supply consultancy
as long they do not compromise the independence of auditing.
If this is the case it may well be worth investigating. Their consultants will have
been trained in the RSO’s approach to auditing and certification and therefore
the system put in place will be sympathetic to the RSO.
The amount of consultancy you require will depend upon the decisions reached
earlier in the implementation stages. It could be that you use the RSO consultancy
as a means of reviewing the work you have done and suggesting amendments
to ensure compliance.
Another option would be to hand over control to the RSO consultants. But, in
doing so the company loses control over the project and may well end up with a
system that does not reflect the company which will also cause a number of
revisions to be made to the Safety Management System of the Company to
make sure that everything fits in smoothly.
Step 10
The Shipboard Safety Assessment (SSA) of each ship will need to be conducted.
This is dealt with in the ISPS Code.
Part A Section 8 – Ship Security Assessment

Part B Section 8 – Ship Security Assessment
Security Assessment
On-Scene Security Survey
A copy of the MCA Ship Security Assessment Report is contained in

Appendix 19 of the ISPS Code.
By following the steps as laid out the company will have identified its strengths
and weaknesses and where the latter will have to be attended to.
What must be remembered is that the requirements for ships will vary for
different ship types. Even when the ship type is the same the variances between
ships of different sizes and age of the ship will make it a requirement to ensure
that an SSA for each ship is carried out
This will require that the correct type and quantity of security equipment identified
by the SSA is supplied to the ship and that an allowance has been made for
spare parts and maintenance schedules to ensure the ship will always operate
to the requirements standard determined by the security level that it will be
trading in for any given port.
A RSO must be in attendance for the On-Scene Security Survey.
Step 11
On completion of the SSA the company needs to identify exactly where it stands
in respect of its standard and awareness of security. Some of the findings may
be unpalatable but they need to be redressed if the required standard of security
is to be achieved.
Without making sure that all items identified in the SSA have been resolved it is
not possible to make any real headway with the Ship Security Plan.
Ship security equipment may include the all of the following:
• AIS
• Ship Security Alert System
• Locks
• Lighting
• Handheld Radios
• GMDSS Equipment
• Closed Circuit Televisions
• Automatic Intrusion Detection Device (Burglar Alarm)

• Metal Detectors
• Explosive Detectors
• Baggage Screening Equipment
• Container X-Ray Devices
• General Alarms
The SSO will be expected to be familiar with the capabilities and deployment of
such devices and systems.
The CSO may be in the position to influence the purchase and installation of
security equipment.
The SSO and CSO should be aware of the functional limitations and operating
constraints of the security equipment that the company deploys on its ships. This
should include effective operational range, environmental sensitivities, and
operator error
Step 12
Constructing the Ship Security Plan needs careful consideration.
The ISPS Code requires that the contents of the following sections be complied
with fully:
Part A Section 9 – Ship Security Plan
Part B Section 9 – Ship Security Plan
General
Organisation and Performance of Ship Security Duties
Access to the Ship
Handling of Cargo
Delivery of Ship’s Stores
Handling Unaccompanied Baggage
Monitoring the Security of the Ship
Differing Security Levels
Activities Not Covered by the Code
Declaration of Security
Audit and Review

See Appendix 5 and 6 for full contents of Part A and Part B of the ISPS Code
Section 9.
Once the SSA has been reviewed and weaknesses identified and overcome
then the construction of the Ship Security Plan (SSP) as required by the above.
Various organisations have offered templates for the SSP to be filled in and it will
comply with the above legislation.
It should be noted that the SSP will need to be reviewed by the flag administration
or a RSO delegated authority by the flag administration for this purpose to
approve the SSP.
Once the SSP is approved, there can be no amendments made to it unless the
RSO or flag administration has first approved the changes. Therefore it is
important that the company and ships of the fleet have in place the proper
procedures and work instructions to ensure that the steps and persons involved
know exactly how the mechanism for amendments is invoked.
Step 13
As mentioned above the flag administration or a RSO delegated authority by the

flag administration will approve the SSP.
It is important that when the SSP is presented for approval that it has been
reviewed for content, spelling and grammar.
This document is the cornerstone for the ISPS Code and although it will have
restricted access to it, the contents will need to be exact and concise. This does
not mean the language used should be complex and convoluted but rather the
opposite, clear and concise.
The main problem that can arise is the delay in the approval process once the
approval body receives it. This is where the choice of organisation for certification
and approval needs to have be considered most carefully.
Step 14
As each SSP is approved for each ship then it becomes a matter of ensuring
that it is implemented on board each ship.
Remember, although you may be using a template for the structure of the SSP,
the contents must reflect the requirements of each individual ship. Certain
sections of the SSP will be consistent for every ship. Therefore, the structure
used and the way it is applied will be reflected in the training that is put in
place.
The time allowed for implementation of the SSP must be realistic. Remember,
that the implementation will take place while the ship is still operating. Therefore,
the implementation will increase the workload of the ship officers and crew. If the
timeframe has not taken this into account and there is no support from the shore
side then the requirements will not reach the efficiency and effectiveness that is
possible.

As a result the concept put forward by the ISPS Code will not be met. This will
further show up in inspections, surveys and audits conducted on board the
ship.
Step 15
As the implementation process takes place the requirement for the construction
and retention of RECORDS will become apparent.
When the requirements of the SSO are reviewed then the need for proper record
keeping becomes more apparent.
ISPS Code Part A Section 2 – Definitions states:
Ship Security Officer (SSO) means the person on board the ship, accountable
to the Master, designated by the Company as responsible for the security of the
ship, including implementation and maintenance of the Ship Security Plan and
for liaison with the Company Security Officer (CSO) and Port Facility Security
Officers.
ISPS Code Part A Section 12 – Ship Security Officer
Details the minimum requirements of the responsibilities imposed on the SSO.
ISPS Code Part A Section 10 – Records
And
ISPS Code Part B Section 10 – Records
Records will be generated especially in respect of:
ISPS Code Part A Section 13 – Training, Drills and Exercises on Ship Security
and
ISPS Code Part B Section 13 – Training, Drills and Exercises on Ship Security
The record keeping has to be coordinated and controlled to ensure that

compliance to the ISPS Code is maintained.
Step 16
Once the company feels confident that the ISPS Code in the form of the SSP
has been implemented and that the system is in place and conforming to
requirements then the ship audits for attaining the International Ship Security
Certificate can be organised.
In many cases, it would be prudent to conduct mock audits internally by the

company to evaluate exactly where they are in respect of meeting the
requirements. These internal audits can identify weaknesses that may have
been overlooked.

They should not be viewed as a tool by the office to punish the ship and its crew.
If handled in the correct manner then everyone understands what is trying to be
achieved and the reasoning behind it.
When the audits for certification are being organised the company should view
the disposition of the crew. The crew that have implemented the system should
be on board for the audit. They will have an in-depth knowledge gained from the
workload that has been handled in implementing the system.
If this crew is replaced before the audit, then the new crew may be audited
shortly after joining the ship and as a result their knowledge could appear weak.
This will be true because they are learning how to use the system and getting
up to speed.
Regrettably, the auditors will be auditing a system that is supposed to be fully

functional and as a result weaknesses in the crew will be noted and perhaps
even non-conformities will be raised.
The Flag Administration and/or the Recognised Security Organisation (RSO)

will try to accommodate the company but be aware if audits are left to near the
deadlines for compliance then they may not be so flexible due to the fact that
they will have many companies seeking compliance for their ships.
The company should also consider where the ship will be for the audit. Most
ships trade globally, and so it could be if the programme for auditing has not be
viewed in advance the ship could be at a port that is quite difficult to send an
auditor to and may cause delays to the vessel and an increase in cost.
Step 17
The result of all the hard work conducted by the company, the implementation
team, the CSO, the SSO and the ships’ crews will be the awarding of the
International Ship Security Certificate (ISSC) for each ship.
The original will be placed on board the ship. The company may keep copies in
the office.
The auditing and correction process from the audits of items found not to
conform will have taken time and in some cases felt not to be justified. After all,
the work and dedication performed by all members to reach this stage was not
taken lightly.
Remember, the auditor is only doing his job and the audit is to discover shortfalls
and weaknesses within the system implemented.
Is it not better to have a few paper problems to sort out and raise the standard
of the system put in place, rather than find out during a security incident?
Step 18
As each ship is certified, the list of outstanding ships becomes shorter until at
last there are no more ships and the company has all ships certified.

When the last ship is certified then the team brought together to implement to
ISPS Code has completed their task.
This is a time for the whole of the company personnel to be praised for their work
and effort. It may seem like a small matter, but too often this is overlooked and
can create misgivings or imagined sleights.
The only reason that the company has reached this stage is because of the
efforts of everyone employed in the company from the highest level to the lowest
level. Everyone will have had an input to the final system being operated.
This stage is a major achievement especially when the time scale is reviewed
and the workload is then placed against the time allocated. This was achieved
while the ships were still trading and all other matters of running a shipping
company were being conducted.
Step 19
You have now successfully attained the completion of the first cycle of work in
relation to the ISPS Code.
You have designed, constructed and implemented a system to meet the

requirements of the ISPS Code.
All ships are certificated and the system is running smoothly.
Catch your breath and relax; now you have to prepare to move to the second
cycle.
Life is not fair, but you have achieved another demand of the shipping industry.
Now is the time to review how the system can be improved. This will depend on
the objective evidence received from the ships and translated into continuous
improvement.
Now you can move onto step 20.
Step 20
Having completed the first cycle and attained the desired accreditation and
certification it may well be a time to congratulate everyone in the company and
sit back and catch your breath.
But that would be fatal. Time would be lost that can never be recovered. As the
first cycle is completed the second cycle starts immediately. The work of
Maintaining, Controlling, Revising and Administering the System in place must
continue. There is no time off. The second cycle will run its course and then
move onto the third cycle and so forth.
Security demands that there are no gaps or loss of control. It must be maintained
to 100% efficiency to 100% of the time. The consequences are not an option.

Remember, in respect of a terrorist incident, you have to be correct every time,

the terrorist need only be correct once to achieve their goals.
How did your company implement the ISPS Code?
How long did it take?
Who were the members of the team?
If no team, then who was responsible?
If your company has not yet been certified, do you now look forward to
being involved, or not?
3.4.3.4 Living with the ISPS Code
.1 HOW DOES THE ISPS CODE AFFECT THE DAY-TO-DAY OPERATION

OF A SHIP
Once the implementation stage has been completed and the ship is certified
then the crew serving onboard the ship have the responsibility of ensuring that
the requirements of the ISPS Code are met every day.
In this section we will look at various parts of the Code and how it affects you as
a ship manager
.2 SECURITY LEVELS
The ship will always operate at a security level. These are found in the ISPS
Code and at the progression from the lowest level of security to the highest the
expectations of the precautions that the ship’s crew have to work to increase.
SOLAS Chapter XI-2 Regulation 1.14 states:
Security Level means the qualification of the degree of risk that a security
incident will be attempted or occur.
ISPS Code Part A Regulation 2 states:
Security Level 1 means the level for which minimum appropriate protective
security measures shall be maintained at all times.
Security Level 2 means the level for which appropriate additional protective
security measures shall be maintained for a period of time as a result of
heightened risk of a security incident

Security Level 3 means the level for which further protective security
measures shall be maintained for a limited period of time when a security
incident is probable or imminent, although it may not be possible to identify
the specific target.
ISPS Code Part B Section 1.8 states:
Setting the Security Level
The setting of the security level applying at any particular time is the
responsibility of Contracting Governments and can apply to ships and port
facilities.
Therefore the requirement to know at which level of security the ship is to

operate at will be required to receive a “Declaration of Security”. The requirements
are found in ISPS Code Part A Section 5 – Declaration of Security.
The ship will request a Declaration of Security from the port facility that it will be
arriving at next.
The port facility may request it from a ship.
The persons who can complete a Declaration of Security are:
• The Master
• Ship Security Officer
• Port Facility Security Officer
Any other body responsible for shore-side security, on behalf of the port
facility or ship (if the Contracting Government determines otherwise)
The ISPS Code Part B Section 4.8 to 4.13 – Setting the Security Level
Deals with the requirements needed.
The Ship Security Plan will have identified the requirements of the ship’s security
that need to be implemented and followed depending upon the level of security
the ship will operate at.
More information can be attained from ISPS Code Part B – Section 9 – Ship
Security Plan subsections 9.14 to 9.49
Remember it is possible for the ship to operate at a security level higher than the
port facility, but never lower.
A copy of a Declaration of Security can be found at the end of this module under
“Certificates and Documents”.

Training, Drills and Exercises on Ship Security
Every ship complying with the ISPS Code will have to ensure that security drills
and exercises are conducted at regular intervals and comply with the
requirements of the Code.
These come under the ISPS Code Part A Section 13
and
The ISPS Code Part B Section 13
Part B Section 13.1 deals with the training of the CSO, SSO and
appropriate shore-based company having knowledge
and training
Part B Section 13.2 deals with particular additional training of the SSO
Part B Section 13.3 deals with shipboard personnel having specific

security duties
Part B Section 13.4 deals with other shipboard personnel having

knowledge of the SSP
Part B Section 13.5 deals with objectives of drills and exercises
Part B Section 13.6 deals with time scale of drills and conditions that
require a drill to be conducted
Part B Section 13.7 deals with the various type of drills and who would
take part as well as ship and company personnel
Part B Section 13.8 deals with recognition of drills conducted with

another Contracting Government
It is the responsibility of the company to identify which of the drills and exercises
are relevant to the company and its ships.
Once identified, how they will be conducted. The SSO is responsible for keeping
the records for each and every drill and exercise.
3.5 AUDITS AND CERTIFICATION
6B-194 The ship will hold an International Ship Security Certificate.
6B-195 This will be liable to audit by either the flag administration or a Recognised
Security Organisation (RSO) delegated by the flag administration.
6B-196 At these audits the ship and its crew will be audited to ensure compliance to the
ISPS Code. The main concern is to ensure that the ship’s personnel are
complying with the contents of the approved Ship Security Plan (SSP).

6B-197 The CSO is responsible for arranging the audits with the RSO.
6B-198 These audits can be:
• Initial
• Intermediate
• Additional
• Renewal.
6B-199 These audits are responsible for the issuing of an ISSC, verifying its continued
validity or for the Renewing of the ISSC.
6B-200 Therefore it is essential that when any of these audits are to take place that all
crew members are up to date and aware of their duties and any new personnel
are given the necessary training to comply with the SSP.
6B-201 The SSO is responsible for ensuring that all records are available for the
audits.
6B-202 The ship may also carry out internal auditing of the system. This is the
responsibility of the SSO who should have an auditing schedule from the CSO.
The internal security audits should be conducted, whenever possible, so as not
to come into conflict with ship operations.
6B-203 At internal and verification audits all and every deficiency and non-conformity
raised needs to be resolved within the required timeframe and objective evidence
supplied to verify the actions taken.
3.5.1 Ship Security Alert System (SSAS)
6B-204 See SOLAS Chapter XI-2 Regulation 6.
6B-205 The details of the operation and control of the SSAS will appear in the SSP.
6B-206 The SSAS should only be activated when required due to a security incident
occurring.
6B-207 It has to have as a minimum two activation points, one of which will be on the
navigation bridge.
6B-208 The activation points must be designed so that they cannot be inadvertently
activated.
6B-209 The location of the activation points shall have a restricted number of persons
knowing of its presence and how to access it.
6B-210 When activated the following steps will occur:

• initiate and transmit a ship to shore security alert to a competent authority

identifying the ship, its location and indicate that the security of the ship is
under threat or compromised
• will not send the security alert to other ships
• not raise the alarm on board the ship
• continue to send the security alert until deactivated or reset
6B-211 When an administration receives notification of a security alert, it shall notify the
state(s) in the vicinity of the ship.
6B-212 If an administration receives a security alert from a ship that is not registered
under its flag it shall inform relevant administrations and the state(s) in the
vicinity of the ship.
6B-213 It must conform and perform as a minimum to the standards set by the IMO.
3.5.2 Security Equipment
6B-214 The SSO and the personnel delegated security duties shall be aware of the
security equipment carried on board.
6B-215 They must be aware of how to operate it and of its limitations.
6B-216 Security equipment must be stowed away and the necessary maintenance
carried out and testing on it before use.
3.5.3 The Ship Security Plan
6B-217 This is an approved document containing a vast amount of sensitive information

that should not be for public consumption.
6B-218 Therefore the list of persons who will have access to this document will be
limited.
6B-219 It may well be that the Master of the ship, the Ship Security Officer and the
Company Security Officer are the only persons who have access to the original
and copy in the office. This would be the minimum.
6B-220 What should be taken into account is who can and cannot be given access to
the SSP when the vessel is in port. It is important that this has been identified
because it may be that certain persons visiting the ship on business may wrongly
believe that inspection of the SSP is under their remit when it is not.
6B-221 To remove any potential for misunderstanding, the company should issue a list
to the Master. Any person who requests access to the SSP who is not on that
list should be referred to the CSO.

SELF-ASSESSMENT QUESTIONS
How has the ISPS Code impacted on the way you do your work?
What training have you received in ship security?
What awareness do you have of the security equipment used in your

company and do you know how to operate it and its limitations?
What rating would you give your company out of ten on its position in
respect of the ISPS Code? (0 is very bad, 10 is very good)
3.6 AMENDING THE SHIP SECURITY PLAN
3.6.1 The Amendment Process
6B-222 The SSP has a restricted distribution list for viewing and is supposed to be
limited on board ship.
6B-223 Because it is approved by the flag administration it cannot be amended as and

when required, but needs the approval of the flag administration before it can
have the amendments inserted.
6B-224 This ensures that the SSP copy that the flag administration has and the original
on board all have the exact same contents.
6B-225 It may be that there is additional copy kept in the office under the care of the
Company Security Officer (CSO). That will mean that all three copies must be
kept in line at all times.
6B-226 The procedure for change should be included in the SSP but perhaps it may be
kept by the company as it sees fit.
6B-227 The following steps are a suggested format. It may be that the company has
secured an arrangement with the flag administration for making amendments to
the SSP.
6B-228 When one SSP has noted an item for amendment the CSO will have to check if
this applies to other ships to ensure that the amendment is conducted fleet-wide
and improves the security of the fleet. The procedure for making an amendment
is as follows:
• Item(s) for amendment is identified.
• Item noted and suggested amendment is written down.
• Item is forwarded to office for the attention of the CSO.
• CSO reviews suggested amendment and makes decision.

• CSO supports amendment and constructs it to fit the SSP in the correct
section and language.
• CSO forwards to flag administration requested amendment to SSP.
• Flag administration receives and reviews requested amendment.
• Flag administration approves amendment and informs CSO.
• CSO forwards amendment to ship with copy of approval from flag

administration.
• Ship receives amendment and follows instructions and inserts amendment

into SSP.
• Ship confirms to CSO that amendment has been inserted into SSP.
6B-229 This may appear long-winded but each step requires confirmation and that all
parties are in agreement so that there are no errors.
6B-230 It is important that whatever format is used for amending the SSP that it is
followed exactly at all times.
If allowed, check the procedure in place in your company for the revision of
the SSP.
Compare it to what is written down in this section.
3.7 THE RELATIONSHIP BETWEEN THE SHIP SECURITY OFFICER (SSO),

COMPANY SECURITY OFFICER (CSO) AND THE PORT FACILITY
SECURITY OFFICER (PFSO)
6B-231 The relationship between these three people is most important because of the
communications loop needed.
6B-232 The flag state sets the security level that the ship has to operate at. This might
vary depending on where the ship is trading in the world.
6B-233 This is passed to the Ship Security Officer who is made aware of the security
level that is required for each ship.
6B-234 The organisation that sets the security levels for ships operating under the UK
flag is “TranSec”. This is short for the Transport Security Committee. This will
vary from country to country.
6B-235 Each ship is required to complete and send a Declaration of Security before it
arrives in port. Every ship must be at the same level of security or higher than
the port. If not it will be refused entry.

6B-236 The person responsible for promulgating the Security level that the port is
operating at is the PFSO.
6B-237 It is important that the protocols are followed and the appropriate person is
making the communications in the correct sequence to ensure that there are no
delays to ships arriving at the port.
3.8 CONCLUSION
6B-238 The ISPS Code is relatively new to the shipping industry. We have all worked
with security issues in the past.
6B-239 The events of 9/11 2001 in the USA have made the maritime industry review its
position in respect of acts of terrorism and ships.
6B-240 Most security experts would agree that the potential of the next major terrorist
incident would involve ships.
6B-241 What must never be assumed is that terrorists are stupid, mad or stand out in a
crowd.
6B-242 They are sophisticated and raising the stakes at every atrocity that they
achieve.
6B-243 Shipping has to be ready to meet the challenges that it is going to have to
face.
6B-244 If ships and the shipping industry as a whole can be perceived as not being a
“SOFT TARGET” then it will deviate the terrorist to other potential targets.
6B-245 The problem lies in the fact that as shipping trades and patterns and the
construction of ships advances, the potential for a major incident involving
shipping increases.
6B-246 Think about it?
• A passenger with 7,500 persons on board.
• A container ship carrying 12,000 TEU.
• A 225,000 m3 LNG carrier.
6B-247 All have to potential to create a major incident that would receive major media
attention.
6B-248 Ships have their potential problems, but for an oil rig statically positioned these
are vastly increased.
6B-249 In June 2012, in Nigeria, a rig was boarded by armed men and several of the
personnel kidnapped and held for ransom. This was after a gun battle with
armed security guards on board. The battle left 2 security guards dead and 2
security guards wounded. The escalation of violence in the Nigerian area is

cause for concern and it is not the only area where such acts are being
committed.
6B-250 An act of terrorism or an act of piracy? It depends upon which point of view you
take.
6B-251 The question is did the rig have an operational security system in place.
6B-252 No person is expected to stand up to armed intruders; that is not what seafarers
are employed for. The job is to operate a ship safely and meet commercial
requirements.
6B-253 The ISPS Code is giving the shipping industry a tool, which if used properly will
help protect the crew and their ship from such acts.
6B-254 Remember, security is the responsibility of everyone involved in shipping.

Security is not just about countermeasures against terrorism. It is also about
stopping piracy, stowaways, thieves and other persons gaining access to ships
that have no right to be there.
6B-255 This module has been written as an introduction to the ISPS Code. To go in
depth to the complete requirements of this Code would require a book of at least
four times the content as presented here.
6B-256 The ISPS Code is in its infancy. It will mature, it will evolve, but it will never lose
sight of the principal objective of the Code, that prevention is better than cure.
6B-257 As understanding and living with the Code become the norm it will fade into the
background of being just another standard and certificate that needs to be met
so that the ship can be certified to trade.
6B-258 This can never be allowed to happen or the shipping industry will reap the
rewards that it does not need.
6B-259 The responsibility will lie with the companies, the administrations and the
Recognised Security Organisations to ensure that this never happens.
6B-260 Conducting strict audits and ensuring that companies are reminded of the
consequences of failure to comply should hopefully maintain the standard.
6B-261 Working with the ISPS Code has given the author an insight into the requirements
of the ISPS Code and how it will have to be applied to work in with the other
sectors for ship operation.
6B-262 Security management is going to become one of the core skills that all companies
are going to have to embrace to ensure that the maximum efficiency and
effectiveness is achieved.
6B-263 When reading this text and then referencing to the appendices attached it will
seem that it is complex and convoluted.
6B-264 A complex item can be broken down into a number of simple items. It is a matter
of building a secure base of knowledge and then expanding it with items that
appear to be the natural building blocks on the base.

6B-265 Everyone will have a unique perspective of how this works and how it can be
achieved. And everyone is right. There is no one answer and one way to apply
the ISPS Code. If there was, then everyone would be using it and it would be the
same for every company and every ship and every country.
6B-266 The additional new step that the IMO has taken is that, for the first time, it has
become involved with the auditing and certifying of port facilities.
6B-267 The ISM Code saw for the first time that the IMO became involved with auditing
and certifying companies and not just ships.
6B-268 The ISPS Code has taken it a step further.
6B-269 I have not explored at this time the requirements of the port facility and the Port
Facility Security Officer (PFSO) to any depth. The reason being was to give a
better insight to the personnel involved in shipping.
6B-270 It will require in future that those working on or with the ships have a understanding
of how the ISPS Code works for the port facilities to ensure that they are able to
fully meet all the requirements of this Code.

4. PORT STATE CONTROL AND THE MANAGER
LEARNING OUTCOMES
• Have a better understanding of the various PSC inspections and the

degree to which they are applied.
• Be more able to understand the set up of MOUs and their relationships

with each other.
• Have a better understanding of the role of the ship manager in

dealing with and resolving deficiencies and non-conformities raised
at PSC inspections.
• Understand the importance of the position of the ship manager in

respect of PSC.
• Understand what targeted vessels are and avoid having your vessels
becoming one.
4.1 INSPECTIONS AND DEGREE OF INSPECTION
4.1.1 Introduction
6B-271 The aim of this chapter is to make the delegate aware of the importance of
dealing with Port State Control inspections in their role as ship manager. It is
important to understand the legislation and workings of Port State Control
organisations.
6B-272 There is no ship that exists that does not have at least some deficiencies. That
is a fact of life. The problem arises when the ship’s staff does not know of them,
or the shore-based staff.
6B-273 It is also important to understand the progression of Port State Control

inspections from the ship being inspected to detention.
6B-274 On 1 July 2002 Phase 2 of the ISM Code became mandatory. From the position
of shipping companies, the impact was felt. The reason for this is that many Port
Sate Control MOUs have stated their intention to conduct an intensive inspection
regime on those vessels having attained mandatory certification for the ISM
Code.
6B-275 By the end of 2002, the results were known. These results will then give the
shipping industry an indication of where problems lie. The finger of blame was
pointed and then the arguments will arise. Each interested party took a stance.

Port State Control and the Manager Module 6B
6B-276 It is hoped that this chapter will give some concepts to the ship manager of what
is to be done to ensure that his/her ships are not detained. It is not possible to
give all the answers, but being able to understand better the role and position of
the Port State Control Officer (PSCO) while conducting his inspections will
provide some guidance.
6B-277 It is recommended that all persons having to deal with PSC have in their
possession a copy of Procedures for Port State Control (2000 Edition).
4.1.2 Inspection/More Detailed Inspection
6B-278 Every ship will be inspected by PSC, the number of inspections per year will vary
depending upon the trading pattern of the ship and the results of previous PSC
inspections.
6B-279 It is not always consistent and the fact of the matter remains, that due to the
disparity of the various PSC MOUs (Memorandum of Understanding) the
application of the PSC procedures vary.
6B-280 The global starting point for the procedures for PSC inspection is taken from the
IMO publications. These are “Procedures for Port State Control 2011” (2012
edition. This contains IMO Resolution A1052(27) Procedure for Port State
Control 2011.
6B-281 This is broken down into five chapters and 19 appendices. See Module 6A for
the list of contents.
6B-282 With so much legislation in place and the diversity of interpretation of legislation
by individual flag states, the problem facing the ship manger is how to ensure
that he keeps abreast of each flag state’s requirements. How can a ship manager
be competent in all legislation? The answer is simple. It is not possible.
6B-283 Therefore, specialisation is required. Also the support of a concise Safety

Management System as required by the ISM Code to give the ship manager the
necessary expertise to do the job required of them.
Does the Safety Management System of your company have procedures

in place for dealing with Port State Control inspections and detentions?
6B-284 Ships are not just detained; there is a progression leading to detention. In many
cases it is the lack of response from the ship and/or the office that results in the
detention. In some cases there can be a breakdown in communication between
the PSCO and the ship’s crew. In other cases there has been hostility from the
crew and lack of co-operation. If the PSCO cannot complete his inspection then
the ship can be detained.
6B-285 Every one has a job to do. The responsibilities imposed on the ship’s crew and
the lowering of numbers means that every person has an increased workload.

Module 6B Port State Control and the Manager
6B-286 Ships are being continually inspected and audited. Certain ship types have more
inspections and audits than others. An example of this is oil tankers inspected
under the OCIMF SIRE system.
6B-287 One fact that has recently come to the forefront is that PSC MOUs are requesting
SIRE reports for tankers before conducting a PSC inspection to identify shortfalls
in operational practice.
6B-288 Due to this continuous inspection and audit, ships must be ready for inspection
at all times. The preparation for inspections and audits is part of the normal day-
to-day operation and maintenance of the ship.
6B-289 What must be borne in mind is that having excessive demands placed upon
them must not fatigue the crew. The hours of work and rest as contained within
STCW 95 Part A Chapter VIII Section 1 – “Fitness for duty” should be followed.
In addition to this, the contents of ILO Convention 180 – Seafarers’ Hours of
Work and the Manning of Ships – should be consulted. Some flag states have
made this mandatory.
6B-290 ILO Convention 180 will be absorbed into the Maritime Labour Convention 2006.
There has been a major revision for the STCW 2011 to match the hours of work
and rest closer to the MLC requirements. There are still some differences.
6B-291 Therefore, it requires the support of the company which will allow the crew to
meet all of the relevant legislation pertaining to each particular ship. Additionally,
the work practices and record keeping should be kept to a minimum to reduce
the administration of the working system and therefore release time for practical
work.
4.1.2.1 Inspection
6B-292 To understand the requirements and scope of an inspection and what it entails,
the following section has been taken from the Port State Control Procedures.
Inspection
In the pursuance of control procedures, under the applicable conventions,

which, for instance, may arise from information given to a port State
regarding a ship, a PSCO may proceed to the ship and before boarding
gain, from its appearance in the water, an impression of its standard of
maintenance from such items as the condition of its paintwork, corrosion or
pitting or unrepaired damage.
At the earliest possible opportunity the PSCO should ascertain the year of
build and size of the ship for the purpose of determining which provisions
of the conventions are applicable.
On boarding and introduction to the master or the responsible ship’s officer,

the PSCO should examine the vessel’s relevant certificates and documents,
as listed in appendix 4. When examining 1969 International Tonnage
Certificates, the PSCO should be guided by appendix 4A.
If the certificates are valid and the PSCO’s general impression and visual
observations on board confirm a good standard of maintenance, the PSCO

should generally confine the inspection to reported or observed deficiencies,

if any.
If, however, the PSCO from general impressions or observations on board

has clear grounds for believing that the ship, its equipment or its crew do
not substantially meet the requirements, the PSCO should proceed to a
more detailed inspection, taking into consideration chapter 3.
In pursuance of control procedures under chapter IX of SOLAS 74 on the

International Management Code for the Safe Operation of Ships and for
Pollution Prevention (ISM Code), the PSCO should utilize the guidelines in
section 3.7.
Each of the above subsections are now discussed below using the same
numbering as above.
Who may report a ship? Any interested party may report. The problem being that
there is no exact definition of who is an interested party. Port State Control must
decide if the report is legitimate or not. This is a difficult position to take. If a
report was not followed up on and the ship then experienced difficulties, the PSC
would be required to explain their actions. What has to be taken into account, is
malicious rumour being presented to the Port Sate. For that reason the PSC may
take the action of inspecting the condition of the ship from ashore before
deciding to board or not. These inspections can be generated outwith the normal
cycle of inspections.
The reason for an inspection is laid down in section 2.1.2 of the procedures.
Such inspections may be undertaken on the basis of:
.1 the initiative of the Party;
.2 the request of, or on the basis of, information regarding a ship provided
by another Party; or
.3 information regarding a ship provided by a member of the crew, a

professional body, an association, a trade union or any other individual
with an interest in the safety of the ship, its crew and passengers, or
the protection of the marine environment.
The information required for obtaining accurate information concerning the year
of build and size of the ship is to ensure that the relevant legislation for a ship of
its size are being referred to during the inspection.
The inspection of the vessel’s certificates and documents should confirm the
current status of the ship with regard to the requirements of the legislation.
From these two sources of information the vessel should be able to ensure that
all relevant certificates and documents pertaining to the ship are onboard and
up to date.
Upon completing the inspection of certificates and documents, the PSCO will
conduct an inspection of the vessel and ascertain the standard of the ship.

Deficiencies may be found. Remember all ships have deficiencies. The fact that
none are found does not mean that there are none.
It is the failure to meet the requirements laid down in subsections 1 to 4 that will
generate the inspection to the level of a more detailed inspection.
The ISM Code is an integral part of the shipping industry. It is now mandatory
for a large percentage of merchant ships. If the ship and company are certified
to the ISM Code and hold valid full term certificates, then it should never
experience a more detailed inspection. The fact that such a situation exists
would indicate that the SMS is not functioning.
6B-293 So what is to be done?
6B-294 The PSC inspection commences from the moment that the PSCO arrives at the
quayside. Therefore, the ship, as normal practice, will have everything in good
order, starting with the boarding arrangements, ship security and the path to the
Master’s Cabin or Office. First impressions last. If the ship is not being presented
well and the basic functions not being attended to, then the first hint of
dissatisfaction will be raised in the mind of the PSCO.
6B-295 Once in the Master’s Office, the PSCO will want to inspect the certificates and
documents. These should be ready and in place. One problem that does arise is
that ship’s staff keeps old certificates. If these are retained on board, then it
should be in a separate file and each expired certificate or document should be
suitably identified. This will remove the possibility of confusion arising as to what
is and what is not current and valid.
6B-296 All certificates are issued to the ship, not the company and therefore only original
certificates should be on board. The only exception to this is required in respect
of the Document of Compliance issued to the company in respect of the ISM
Code.
6B-297 In many cases, the failure of the Master to produce a complete set of certificates
and documents and delays in completing a full set of certificates and documents
may raise the matter of clear grounds to raise the inspection to a more detailed
inspection.
6B-298 If the review of the certificates and documents is completed to the satisfaction
of the PSCO, then an inspection of the ship will be conducted. This should be
conducted with the PSCO being accompanied at all times by a ship’s officer. If
one is not available, then a member of the crew should be made available. At no
time should the PSCO be left unaccompanied while inspecting the ship.
6B-299 The main point being looked at is the general standard of the ship. This should
reflect the current status of the certificates and documents. The ship should
show it to be well maintained. There may be maintenance ongoing during the
stay in port.
6B-300 Remember that the feelings gained by the PSCO should be that safety and
pollution prevention are top of the agenda. Everyone is aware of what their
responsibilities are and conducts himself or herself in a professional manner.

Deficiencies may be found. If the ship is aware of them and these have been
progressed and are integrated into the planned maintenance of the ship, then
they should not be a problem.
6B-301 If a deficiency is found that is not known, then this should be looked upon, as a
problem to be fixed not the reason for an argument with the PSCO. Any unknown
deficiency should be reviewed and discussed with the PSCO. It may be
necessary to return to the place where the deficiency has been found and
ensure that an agreement is reached on how best to resolve the problem.
6B-302 Sometimes, ships accept the deficiencies without checking and then have a
problem in identifying the necessary action to take after the PSCO has left the
vessel. Every Master should ensure that they are 100% aware of the exact
nature of every deficiency raised against his ship before signing the PSC
inspection report.
6B-303 Remember it sometimes take a person looking from the outside to identify
problems within a system.
6B-304 If handled correctly, then a PSC inspection becomes a normal routine part of
calls at port. It is not a major problem and positive and constructive dialogue
between the PSCO and the ship’s staff creates an air of professional courtesy.
This leads to a better relationship while the inspection is being carried out.
4.1.2.2 More Detailed Inspection
6B-305 A More Detailed Inspection does not automatically mean that the ship will be
detained. It means that during the inspection of the ship, certain items were
found that led the PSCO to believe that “CLEAR GROUNDS” exist. The List of
Clear Grounds can be found in Module 6A.
6B-306 If this situation arises, the ship should ensure that the company is made aware
of the situation at the earliest possible time.
6B-307 Once the PSCO has explained the items of concern and explained that the
inspection has now generated the next step, it is a matter of the ship’s staff
giving the fullest co-operation. Hostility and/or a lack of co-operation will not
resolve the situation; in fact it may well make matters worse.
6B-308 Once the items of concern have been explained, then it is a matter of taking the
necessary action to resolve them. At this stage it is necessary to understand
fully what the concerns of the PSCO are and what actions need to be taken to
resolve them. In some instances it may be necessary for ship’s staff to take steps
to rectify the items or it may mean bringing shore-side contractors on board to
resolve the necessary items.
6B-309 In some cases it may not be possible to rectify the items at the port due to the
fact that there are not the necessary facilities available. This may be completed
at the next port.
6B-310 Remember that the PSCO needs to ensure that the ship is safe and is not
substandard. How this is achieved, can only be accomplished by the crew

working with the PSCO during the inspection. This is a matter of both parties
working together to achieve the best result.
6B-311 If this attitude does not exist and there is a failure to conduct the necessary work
and resolve matters, then the ship will be heading for a detention. If this occurs
then the time and effort required resolving the situation is greatly increased.
6B-312 In addition, there is the commercial impact on the ship and the company that a
detention can have on the suitability of the ship for future charters.
6B-313 Although, safety and pollution prevention is paramount, we live in the real world
and the effects that detentions can have on a company cannot be
underestimated.
6B-314 If the ship is not detained and the items raised at a more detailed inspection are
resolved, then after departure from the port, the crew and the company would
be well advised to review the event and then initiate the necessary amendments
to the SMS to ensure that such a situation does not arise again. Other ships
within the fleet should be made aware, as soon as possible, after the event and
before the amendments are completed to ensure that the necessary inspections
and preventive actions are taken to ensure that they do not experience a similar
situation.
6B-315 A more detailed inspection means that problems exist in the way the ship is
operated. How these are rectified is a matter for the company and crew. Only full
co-operation with the PSCO will resolve the matter.
What system is in place in your company to deal with deficiencies raised

by a PSCO? Is there an early warning system in place, should a ship
experience a more detailed inspection?
6B-316 Due to a nature of a more detailed inspection and the variety of potential items
that can be raised, it is not possible to go into full details in this module. A review
of the contents of “CLEAR GROUNDS” should be made and identified where
these items relate to the sections of the company’s SMS.
6B-317 A More Detailed Inspection is generated due to the failure of the ship at an
Inspection.
4.1.2.3 Detentions
6B-318 The detention of a ship is not taken lightly by any PSCO. It must be justified by
clear and concise evidence that indicates the failure of the ship to meet the
requirements. A detention is defined in section 1.7.4 and clear grounds are
found in section 1.7.2 which refers the reader to section 2.4 of the procedures.
Delegates should take note of this and apart from reading them need to be able
to make interpretations.

6B-319 Procedures for Port State Control, Chapter 3 – Contravention and Detention,
section 3.5 states:
“Notwithstanding the fact that it is impracticable to define a ship as

substandard and solely by reference to a list of qualifying defects, guidance
for the detention of ships is given in appendix 2.”
Appendix 2 – Guidance for the Detention of Ships.
1 – Introduction
2 – General
3 – Detainable Deficiencies
Areas under the SOLAS Convention
Areas under the IBC Code
Areas under the IGC Code
Areas under the Load Lines Convention
Areas under the MARPOL Convention, Annex I
Areas under the MARPOL Convention, Annex II
Areas under the MARPOL Convention, Annex IV
Areas under the MARPOL Convention, Annex V
Areas under the MARPOL Convention, Annex VI
Areas under the STCW Convention
Areas which may not warrant a detention, but where, e.g. cargo
operations have to be suspended
6B-320 Any detention must be responded to quickly and effectively. It will usually require
the assistance of the shore-based office to assist and organise the necessary
assistance to resolve the situation. The sooner the detention is lifted the sooner
the vessel will be back in operation.
6B-321 Whether the crew feel that the detention is justified or not, or there are grounds
for an appeal against the detention, the detention is in place and must be
resolved. Therefore, the company must have in place a system of dealing with
detentions.
6B-322 The first step is that the lines of communications must be laid down and everyone
is made aware of what has taken place. The page from procedures for port state
control titled “Detentions – Passing of Information” gives a proposed chain of
communications. The following paragraphs discuss the relevant bodies and their
responsibility in resolving a detention.

6B-323 Upon receiving the detention report the items listed must be identified and what
were the causes of the deficiencies. A copy of this report should be sent
immediately from the ship to the company. This should be for the attention of the
person responsible for dealing with detentions as laid out in the SMS. Additionally,
a telephone call should be made to the same person to ensure that they are
aware of the situation and the correspondence that will be sent.
6B-324 Once received at the office the person responsible will then follow the relevant
procedures for dealing with the detention.
6B-325 The ship manager needs to become familiar with the various reports and their
formats that are found in the Appendices for PSC Inspections and the results
generated. These can be found in appendices 13, 14, 15 16, and 17.
6B-326 The Company should immediately inform the relevant Recognised Organisation
or Organisations, so that they are aware and can render assistance. Where
problems arise is when the company has been trying to deal with the detention
itself and the PSC sends a copy to the RO. This results in the RO contacting the
company instead of the other way round. Also a time delay has transpired and
this results in the RO arriving later in the detention and then having to try to
catch up on what has taken place, before being able to render effective
assistance.
6B-327 It should be noted that on the page “Detentions – Passing of Information” the RO
has been identified three times: RO – Class; RO – DOC; and RO – SMC.
6B-328 This is due to the fact that at this time the company can have three different ROs
being responsible for the issuing of the different certificates involved.
6B-329 What must be remembered is that if the ship is certified to the ISM Code and is
detained the relevant RO that is responsible for certifying to the ISM Code will
want all the information regarding the detention.
6B-330 The reason is simple. A ship certified to the ISM Code should never be detained
if the SMS is working correctly. The detention indicates that the SMS is not
functioning correctly. This may result in an additional ISM Code audit being
requested.
6B-331 If deficiencies are raised directly against the ISM Code, then the ship and
company do have a major problem and the continued existence of the ISM Code
certification could be put at risk, especially if there is a delay in informing the
relevant RO.
6B-332 The second step is ensuring that the flag administration for the ship is informed.
If this is not done, and they are informed first by PSC, there can be a shift in the
response and the way the detention is dealt with. Flag administrations do not like
to be told by PSC that one of their ships is detained and not be aware of it or
able to give an answer as to what steps are being taken or initiated.
6B-333 Once all necessary persons and organisations have been made aware of the
situation then it is important that rapid and effective action is taken.

6B-334 The ship’s staff should have identified clearly which items they can deal with and
which require assistance. The items that have been identified as being able to
be resolved by the ship’s staff should be commenced immediately, informing the
company of progress made.
6B-335 The company needs to find the relevant expertise available to render assistance
to the ship. This will probably require that assistance of the ship’s agent at the
port. They should have a complete knowledge of which companies are most
suitable for giving the required assistance for resolving each of the detainable
deficiencies.
6B-336 In some case, it may require that those persons and/or equipment are sent to
the port of detention.
6B-337 Detentions occur to substandard ships. The deterioration in the ship is usually
gradual and there have been indicators that the ship is heading towards
detention.
6B-338 These may be:
• An increase in work load to retain class and statutory certificates
• An increase in the deficiencies recorded at PSC inspections
• Problems in meeting the requirements of charterparties
• Increase in maintenance budgets
• Increase in the number of malfunctions, breakdowns, and repairs
The above list is not exhaustive and other factors may affect the ship.
6B-339 There are of course the recorded instances of ships being detained that should
not have been. These are in the minority.
6B-340 What has to be learned is that no ship is exempt from the potential of a
detention.
6B-341 What is important is that the company has in place the relevant support
mechanism to resolve a detention.
6B-342 Crews and office staff need to be trained in PSC inspections and the methodology
used. They also need to be trained in the practicable application of PSC and how
to deal with the inspections.
6B-343 Remember it is a long way from a PSC inspection to a PSC detention. What
went wrong that the ship passed through the stages until it was detained?
6B-344 Serious questions must be asked of the management of the ship. The blame
should not be shifted solely to the Master and crew.

6B-345 In some cases, ships have the detention lifted without completing all of the
deficiencies. Appendix 14 of the Procedures for Port State Control – Report of
deficiencies not fully rectified or only provisionally repaired – may be issued.
6B-346 All too often, once the ship has the detention lifted and sails from the port, the
items contained on it are not rectified. Or are rectified without the proper follow
up to the PSC to ensure that the records are completed and recorded to the
satisfaction of all parties. This can lead to further inspection by other PSC
organisations.
6B-347 The file containing the records of a detention can only be closed when all
matters relating to the detention are 100% completed. This includes all the
required follow-up action and the reporting requirements attached to it.
6B-348 When a company is of the opinion that a detention was not warranted for its ship,
then it must make protest to the PSC.
6B-349 Procedures for Port State Control (2012 Edition) Chapter 2 – Port State
Inspections, Section 2.1.4 states.
“All possible efforts should be made to avoid a ship being unduly detained
or delayed. If a ship is unduly detained or delayed, it should be entitled to
compensation for any loss or damage suffered.”
6B-350 Regrettably, there have been a few cases in which this course of action has been
taken.
6B-351 The best action is to ensure the ship is not detained in the first place.
What training do ship mangers receive in respect of PSC inspections and

dealing with matters raised at Inspection?
4.2 MEMORANDUM OF UNDERSTANDING
4.2.1 Port State Control Organisations
6B-352 Included in the Procedures for Port State Control (2000 Edition) is Appendix 10
– Contact Addresses of Responsible National Authorities.
6B-353 The list identifies 153 individual flag authorities. These are broken down into
MOUs giving global coverage.
6B-354 The page titled “Port State Control” shows the list of current MOUs.
6B-355 What the above shows is that PSC is now global. There is no escape from
inspection.

6B-356 The first PSC MOU was the Paris MOU which covered countries in Europe. This
has been expanded from the initial signatories.
6B-357 The benefits of the MOUs are that countries acting together with a common
reporting system for a global region give access to more information.
6B-358 Already the databases of the Paris and Tokyo MOUs have been electronically
linked for the passing of PSC inspections and detentions.
6B-359 The use of electronic databases is on the increase. There is already the
“EQUASIS” database located in France that gives information concerning ships
and their records of PSC inspection and results, listing deficiencies and
detentions. This is available to interested parties and access may be given upon
application.
6B-360 As the use of computers and databases increases, in the end there will be one
global database for PSC inspections and detentions. If all MOUs are party to it
then the full and exact history of a vessel will be available to a PSCO before
attending a ship for inspection.
6B-361 At this time, there is no one set of identical forms being used by all the MOUs
for the reporting of PSC inspections.
6B-362 Although the Procedures for Port State Control contain the required details of
the construction and information to be contained therein, all parties have not yet
accepted this.
6B-363 This is regrettable, the reason being that companies and ships would be able to
compare like with like when reviewing performance and the results of PSC
inspections.
6B-364 While there are many rumours and accusations of the disparity between the
various MOUs in completing their tasks, there. There has been action taken.
6B-365 This can be reflected in the fact that there is no one global standard being used
for the training of PSCOs (2.4).
6B-366 The procedures identify the “Professional Profile of PSCOs” and the “Qualification
and Training Requirements of PSCOs” (2.5).
6B-367 The IMO has further assisted in this matter with the publication:
MODEL COURSE 3.09
Port State Control Course + Compendium
The use of this publication and the interpretation of its requirements would go a
long way in dispelling some of the uncertainty held by shipping companies as to
the veracity of the PSC inspections carried out on their vessels.
A number of countries have very stringent course requirements for the training
of PSCOs. This can take up to three months to complete and are full time
attendance courses with examinations throughout the course.

4.2.1.1 Language
6B-368 In the past, part of the problems with PSC inspections has been because of the
difficulty of communications. This may or may not have been true. But this has
now been resolved.
6B-369 The two pages titled “PSC – Language” show how the legislation is moving to
bring English into being the official language of shipping. It is no accident that
this has taken place and it should resolve many of the previous problems
encountered, not just at PSC inspections.
6B-370 This language further reinforces certain requirements for the application of the
ISM Code. Namely:
Section 6.6 – “The Company should establish procedures by which the

ship’s personnel receive relevant information on the safety management
system in a working language or languages understood by them.”
Since the other requirements of the legislation mentioned above requires the
use of English, then perhaps in time, it may be that English is used as the
language of choice for meeting the requirements of this section of the ISM Code.
This would then further the integration of certain work practices and reporting
methodologies.
Furthermore, it would prove useful and helpful to a PSCO during an inspection.

Some items that may pose the potential of a deficiency or even a detention could
be resolved by the ability of the PSCO to inspect fully the records and other
items contained in the companies’ management systems.
SELF-ASSESSEMNT QUESTION
How does your company deal with the item of language in both the
communications within the company and with external parties/interested
parties?
4.2.1.2 Conclusion
6B-371 Very few persons in the maritime industry are not aware of Port State Control
and the effect a detention can have on the company and its ships.
6B-372 Yet, how many people have the time to really study the procedures and
mechanism that comprise Port State Control.
6B-373 Courses are run for managers, crew and others to attend. But the real answer is
education by the company for the company employees.

6B-374 This further strengthens the understanding and application of the company
management system as a whole in relation to the PSC regime. This covers more
than the SMS put in place for the ISM Code.
6B-375 With a better understanding of what the objectives and targets are for PSCOs
and the way that they conduct their inspections, the ship’s staff will be able to
better respond to the questions and requirements.
6B-376 All ships have deficiencies. If there are ships out there that have none and
continue to trade with none, then those companies are to be commended. It is
a target that all others should strive to attain.
6B-377 The process from inspection to detention is taken in steps. It is not taken lightly.
PSC is a safety net. Its job is simple, stop substandard ships that do not conform
to the relevant conventions.
6B-378 Also, to ensure that ships will not sail until they can proceed to sea without
presenting a danger to themselves or the persons onboard, or without presenting
an unreasonable threat of harm to the marine environment.
6B-379 It is not a lot to ask and as companies and their ships work with PSC regimes
the statistics will soon show those companies that strive for successful
inspections and those that do not. There are other factors that make this a more
complex matter and statistics are only as good as the data put in.
6B-380 Cooperation, consideration and understanding of what others are doing, such as
PSCOs, go a long way to resolving items that have the potential to create
problems for the ship.
Check your PSC inspection results for the company over the last year.
Check if you can identify any trends (repeated items) within the deficiencies
raised.
4.3 DEALING WITH DEFICIENCIES AND NON-CONFORMITIES RAISED AT

PSC INSPECTIONS
4.3.1 Deficiencies
Definitions – 1.7.3 – Deficiency states “A condition found not to be in

compliance with the requirements of the relevant convention”.
6B-381 So what are the relevant conventions?
6B-382 At the end of this chapter of the page titled “PSC – Inspection – Legislation” lists
the six main conventions of concerned.
6B-383 Each of these Conventions contains a large amount of information and the
requirements to meet international legislation.

6B-384 Not all legislation applies to every ship and therefore the company must be
aware of which pieces of legislation apply to which ship. This is further reflected
in the matter of which certificates and documents relate to which ship type.
This is further defined by Appendix 18 titled “List of instruments relevant to port

State control procedures.” This lists 68 instruments that are applicable to all ship
types. The ship manager must ensure that all instruments that affect the ships
that are under his/her responsibility are known and a certain amount of content
from each one is understood.
6B-385 Because of the diversity of the way that deficiencies can be written, it is therefore
necessary to have a methodology of identifying deficiencies. To assist in this
matter there is a four-page document titled “Port State Control Code”. This is
used by the Paris MOU.
6B-386 The PSCO must ensure that any deficiency raised is accurate and reflects
correctly against a certain piece of legislation.
6B-387 He must be able to justify a deficiency exactly and there can be no room for
misinterpretation. Although, sometimes he may observe items that do not
appear to be correct in his own mind and experience, deficiencies should not be
raised unless he can justify by the legislation.
6B-388 The labyrinth of legislation makes it difficult for a ship to be incomplete comp-
liance at all times. Assistance in maintaining compliance can be shown by the
status of the relevant certificates and documents. To ensure this is met the
requirement for a maintenance system on board the ship is required. How this
maintenance system is constructed and what methods are used are totally at
the discretion of the company.
6B-389 Many companies have or are about to change to an electronic system and either
manufacture one for them or take a ready-made one.
6B-390 The main point is that no matter what system is used, the identification of all the
structure of the ship, its components and systems needs to be fully assessed. If
this initial assessment is flawed then the system put in place will be flawed.
6B-391 The PSCO will raise deficiencies against the ship, its systems and its personnel.
In addition, deficiencies can be raised against failure to meet the requirements
of the ISM Code. Therefore, it is important that the hardware, software and
personnel are totally integrated. This will result in a uniform working practice,
whereby the structure of work practices removes duplication of work and the
reduction of the administration to accomplish it.
6B-392 Every PSC deficiency will have to be dealt with and should be identified in the
maintenance system.
6B-393 The problem that is raised, is how to resolve a deficiency raised against the ISM
Code. Any PSC deficiency is raised against the SMS, which will have the
maintenance system as part of its structure.

6B-394 But, how do you resolve a deficiency against a system that is not inspected, but
audited and has non-conformities raised against it, not deficiencies.
6B-395 In the Procedures for PSC, Appendix 8, titled “Guidelines for port State control
related to the ISM Code” gives guidance to the PSCO, when dealing with ISM
Code matters.
6B-396 The company and ship’s staff should be aware of this section and its application
when dealing with such matters at an inspection and should deficiencies be
raised.
6B-397 On each page the category “OTHER” appears. At first this may appear confusing,
but when the pages titled “Port State Control Codes” are inspected it will be
noted that this title appears under every section. It is where a deficiency cannot
be exactly categorised under a specific heading.
6B-398 If the pages are inspected closely it can be seen that the majority of deficiencies
found are not some unusual or an item of operation of a ship not commonly
noted, but they are fundamental problems that have to be addressed.
6B-399 It would appear that many of the deficiencies raised show a failure to meet basic
standards of good seamanship.
6B-400 Delegates should review these pages and check against PSC deficiencies
raised against the ship they are serving on. Or, if office based, refer to the PSC
inspection deficiency database for the company against the items raised here.
Do the trends match?
How does your company keep records of PSC deficiencies raised against
each ship and for the fleet? Are these statistics circulated throughout the
fleet?
6B-401 The lack of consistency of PSC inspections makes it more difficult to deal with
the issue of deficiencies. Also the frequency of inspections and the diversity of
results may lead to a lack of understanding as to the supposed condition of the
ship.
6B-402 In the example below, the geographical locations were chosen at random and
should not be taken as any inference to the PSC inspection regime practised in
these locations.
6B-403 An example of this may be that the ship is inspected in the USA and two
deficiencies are raised. Both are rectified while in port during cargo operations
and the vessel sails without delay.
6B-404 Three weeks later the ship is in West Africa and the PSC inspection raises 15
deficiencies and the vessel is detained. Time lost three days.

6B-405 The first question to be asked is how did the ship deteriorate to such a degree
within such a short time?
6B-406 Was the inspection in the USA not conducted correctly?
6B-407 Was the inspection in West Africa conducted incorrectly?
6B-408 How does the company/ship appeal against the detention?
6B-409 Having complete records of all PSC inspections of the ship will show how it has
performed. If the inspection is completely out of character for the ship, an
investigation must be carried out.
6B-410 But first and foremost the necessary work must be completed to lift the detention
and have the ship back at work.
6B-411 The investigations must take place later.
6B-412 This disparity in the conduct and results of PSC inspection by various MOUs is
having a detrimental effect on how PSC inspections are viewed by sections of
the maritime industry.
6B-413 The main context is to identify the deficiencies, deal with them and move on.
Constructive arguments or requesting a clearer identification and understanding
of the contents of deficiencies go a long way to resolving situations.
6B-414 Constructive dialogue will resolve matters. Once the dialogue has broken down,
then it is usual for the situation to deteriorate, rather than be resolved.
4.4 THE POSITION OF THE SHIP MANAGER IN RESPECT OF PSC
4.4.1 PSC and the Ship Manager
6B-415 The ship manager has an important part to play in setting up the PSC inspections;
dealing with the results; and giving support and assistance to the Master.
6B-416 The ship manager will need to liaise with the Designated Person and also with
those who have responsibility for dealing with deficiencies or non-conformities
raised at inspection.
6B-417 Depending upon what has been raised and the actions to be taken the ship
manager will need to ensure that all actions taken are resolved within the allotted
time period.
6B-418 Should a ship be detained then the ship manager will need to work to have the
ship released. Then in the aftermath identify what went wrong.
6B-419 This will mean working with others in a team to follow up every action to ensure
the ship is cleared and no outstanding issues are left open.
6B-420 There will also be the matter of having the deficiencies and non-conformities
raised and the actions taken entered into the database for the fleet.

6B-421 An additional problem can be if the ship has experienced a bad inspection result
up to and including a detention and the ship also holds full term ISM Certification.
This could result in the ship being required to undertake an additional ISM
audit.
4.5 TARGETED VESSELS
4.5.1 Mandatory Expanded Inspections
4.5.1.1 Introduction
6B-422 Port State Control Memorandums of Understanding have identified that certain
ships require additional requirements for inspection.
6B-423 This identification has been generated from the statistics gathered from previous
inspections and the resulting findings.
6B-424 This chapter allows persons involved with ship operations and ships that may be
categorised as requiring a mandatory expanded inspection to be better prepared
and understand the mechanism that they will be involved in.
4.5.1.2 Ship Types and Age for Mandatory Expanded Inspection
• Gas and chemical tankers older than 10 years of age, as determined on

the basis of the date of construction indicated in the ship’s safety
certificates.
• Bulk carriers older than 12 years of age, as determined on the basis of the
date of construction indicated in the ship’s safety certificates.
• Oil tankers with a gross tonnage of more than 3,000 gross tonnes and
older than 15 years of age, as determined on the basis of the date of
construction indicated in the ship’s safety certificates.
• Passenger ships older than 15 years of age other than passenger ships
referred to in Article 2(a) and (b) of Council Directive 1999/35/EC of 29
April 1999 (as amended by Directive 2001/106/EC of the European
Parliament and of the Council)* on a system of mandatory surveys for the
safe operation of regular ro-ro ferry and high speed passenger craft
services (OJ L 138, 1.6.1999, p. 1).
4.5.1.3 Information to be Notified to the Competent Authority
Name
Flag
IMO identification number, if any
Deadweight tonnage
Date of construction of the ship, as determined on the basis of the date indicated
in the ship’s safety certificates

For tankers
f.a. configuration – single hull, single hull with SBT, double hull
f.b. condition of the cargo and ballast tanks – full, empty, inerted
f.c. volume and nature of the cargo
Probable time of arrival at the port of destination or pilot station, as required by

the competent authority
Planned duration of the call
Planned operations at the port of destination (loading, unloading, other)
Planned statutory survey inspections and substantial maintenance and repair

work to be carried out whilst in the port of destination.
6B-425 Every vessel requiring a mandatory expanded inspection is required to complete

the relevant Notice (a copy of the Notice for arrival in a UK port is attached as
7.5.16).
4.5.1.4 Procedures Relating to Expanded Inspection of Certain Categories of Ships
6B-426 (taken from MCA MSN 1775)
6B-427 Subject to their practical feasibility or any constraints relating to the safety of
persons, the ship or the port, the following items at least must be part of an
expanded inspection. Inspectors must be aware that it may jeopardise the safe
execution of certain on board operations, for example, cargo handling, if tests
having a direct effect thereon are required to be carried out during such
operations.
SHIPS IN GENERAL (categories in section A)
Black-out and start of emergency generator
Inspection of emergency lighting
Operation of emergency fire-pump with two fire hoses connected to the fire
main-line
Operation of bilge pumps
Closing of watertight doors
Lowering of one lifeboat to the water
Test of remote emergency stop for e.g. boilers, ventilation and fuel pumps
Testing of steering gear including auxiliary steering gear
Inspection of emergency source of power to radio installations

Inspection and, to the extent possible, test of engine-room separator
GAS AND CHEMICAL TANKERS
In addition to the items listed under section 1, the following items are to be
considered as part of the expanded inspection for gas and chemical tankers:
• cargo tank monitoring and safety devices relating to temperature, pressure

and ullage
• oxygen analysing and explosimeter devices, including their calibration.

Availability of chemical detection equipment (bellows) with an appropriate
number of suitable gas detection tubes for the specific cargo being
carried
• cabin escape sets giving suitable respiratory and eye protection for every
person on board (if required by the products listed on the International
Certificate of Fitness or Certificate of Fitness for the Carriage of Dangerous
Chemicals in Bulk or Liquefied Gases in Bulk, as applicable)
• check that the product being carried is listed in the International Certificate
of Fitness or Certificate of Fitness for the Carriage of Dangerous Chemicals
in Bulk or Liquefied Gases in Bulk, as applicable
• the fixed fire fighting installations on deck, whether they be foam or dry
chemical or other as required by the product carried
BULK CARRIERS
considered as part of the expanded inspection of bulk carriers:
• possible corrosion of deck machinery mountings
• possible deformation and/or corrosion of hatch covers
• possible cracks or local corrosion in transverse bulkheads
• access to cargo holds
• verification that the following documents are on board, review them and
confirm that the flag State or classification society has endorsed them:
– reports of structural surveys
– condition evaluation reports
– thickness measurement reports
– descriptive document referred to be IMO resolution A.744(18)

OIL TANKERS
considered as part of an expanded inspection of oil tankers:
• fixed deck foam systems
• fire fighting equipment in general
• inspection of fire dampers in engine room, pump room and

accommodation
• control of pressure of inert gas and oxygen content thereof
• ballast tanks – at least one of the ballast tanks within the cargo area to be
examined from tank manhole/deck access in first instance and entered if
inspector establishes clear ground for further inspection
• verification that the following documents are on board, review them and
confirm that the flag State or classification society has endorsed them:
– reports of structural surveys
– condition evaluation reports
– thickness measurements reports
– descriptive document referred to by IMO resolution A.744(18)
PASSENGER SHIPS NOT COVERED BY DIRECTIVE 1999/35/EC
In addition to the items listed under section C1, the following items may also be
considered as part of the expanded inspection for passenger ships:
• testing of the fire detection and alarm system
• testing of proper closing of fire doors
• test of public address system
• fire drill where, as a minimum, all sets of firemen’s outfits must be

demonstrated and part of the catering crew take part
• demonstration that key crew members are acquainted with the damage
control plan
If deemed appropriate, the inspection may be continued while the ship is on

passage to or from the port in the Member State, with the consent of the ship’s
master or the operator. Inspectors must not obstruct the operation of the ship,
nor must they induce situations that, in the master’s judgement, could endanger
the safety of the passengers, the crew and the ship.

4.5.1.5 Ships to be Considered for Priority Inspection
Overriding Factors
Regardless of the value of the target factor, the following ships shall be
considered as an overriding priority for inspection:
• Ships which have been reported by pilots or port authorities as having

deficiencies which may prejudice their safe navigation (pursuant to Council
Directive 93/75/EEC and regulation 15 of the Regulations)
• Ships which have failed to comply with the obligations laid down in Council
Directive 93/75/EEC (see MSN 1741 (M))
• Ships which have been the subject of a report or notification by another

Member State
• Ships which may have been the subject of a report or complaint by the
master; a crew member, or any person or organisation with a legitimate
interest in the safe operation of the ship, shipboard living and working
conditions or the prevention of pollution, unless the Member State
concerned deems the report or complaint to be manifestly unfounded. The
identity of the person lodging the report or complaint must not be revealed
to the master or the shipowner of the ship concerned.
Ships which have been:
– involved in a collision, grounding or stranding on their way to the

port;
– accused of an alleged violation of the provisions on discharge of

harmful substances or effluents;
– manoeuvred in an erratic or unsafe manner whereby routing

measures, adopted by the IMO, or safe navigation practices and
procedures have not been followed, or
– otherwise operated in such a manner as to pose a danger to persons,

property or the environment
• Ships which have been suspended or withdrawn from their class for safety
reasons in the course of the preceding six months
Overall Targeting Factor
The following ships shall be considered as priority for inspection:
• Ships visiting a port in the MOU region for the first time or after an absence
of 12 months or more. The Maritime and Coastguard Agency shall rely
upon the available Sirenac data and inspect those ships which have not
been recorded in the Sirenac database following the entry into force of that
database on 1 January 1993
• Ships not inspected by any Member State within the previous six months

• Ships whose statutory certificates on the ship’s construction and equipment,

issued in accordance with the Conventions, and the classification
certificates, have been issued by organisations which are not recognised
under the terms of Council Directive 94/57/EC
• Ships flying the flag of a State appearing in the black list as published in
the annual report of the MOU (PARIS)
• Ships which have been permitted to leave the port of a Member State on
certain conditions, such as:
– deficiencies to be rectified before departure
– deficiencies to be rectified at the next port
– deficiencies to be rectified within 14 days
– deficiencies for which other conditions have been specified
• If all deficiencies have been rectified this is taken into account
• Ships for which deficiencies have been recorded during a previous

inspection, according to the number of deficiencies
• Ships which have been detained in a previous port
• Ships flying the flag of a country which has not ratified all relevant
international conventions referred to in regulation 2 of the Regulations
• Ships classed with a classification society with a deficiency ratio above

average
• Ships in a category for which an expanded inspection is required by

regulation 7 of the Regulations
• Other ships above 13 years old
In determining the order of priority for inspection of the ships listed above, the
competent authority shall take into account the overall target factor shown on the
Sirenac database, according to Annex I Section I of the MOU.
A higher target factor is indicative of a higher priority.
The overall target factor is the sum of the applicable target factor values as
defined within the framework of the MOU. Items 5, 6 and 7 shall only apply to
inspections carried out in the last 12 months.
The overall target factor shall not be less than the sum of the values of items 3,
4, 8, 9, 10 and 11.
For the purpose of regulation 7(4) the overall target factor shall not take into
account item 10.

NOTE:
Under the PARIS MOU an expanded inspection must be carried out if the ship
has a target factor of 7 or more at its first port of call after 12 months from the
last expanded inspection, or is selected for inspection under regulation 8.
The target factor of 7 referred to in regulation 7 ignores the value awarded to

ships in a category subject to expanded inspection (+5 points).
However the value displayed in Sirenac or in the PARIS MOU website calculator
will include this element and the corresponding target factor will be shown as 12
or more.
4.5.1.6 Notice of Ship Arrival for Mandatory Expanded Inspection
Fax to Dover MRCC
Fax number +44 (0) 1304 204 253
Notice of Ship Arrival for Mandatory Expanded Inspection
Applies to –
• gas and chemical tankers over 10 years of age
• bulk carriers over 12 years of age
• oil tankers of more than 3,000 gross tonnes and over 15 years of age
• passenger ships over 5 years (except ro-ro ferries and high-speed craft)
Name of Ship Flag
IMO Number Deadweight tonnage

Date of build (on ship’s safety Ship type (see
certificates) above)
For Tankers
Configuration of hull single hull / single hull with SBT / double hull
Condition of cargo tanks full / empty / inerted
And ballast tanks full / empty / inerted

Volume and Nature of Cargo
Port of Destination
ETA Planned duration of

call
Planned Operations loading / unloading / other
Planned statutory survey inspections / Substantial maintenance and repair

work
From (ship master / agent / operator)

Contact
Tel
fax
Email
Date / time
It is the Master’s responsibility to ensure that suitable notification has been given
to the PSC of the vessel’s arrival and readiness for inspection
Choose one of the older ships in the fleet of your company and check if it
meets the requirements for a Mandatory Expanded Inspection.
Or
How does your company prepare a ship for a Mandatory Expanded

Inspection?

5. THE ENVIRONMENT AND SHIPPING:
MINIMISING THE IMPACT
LEARNING OUTCOMES
• Have a better understanding of the ISO 14000 series – Environmental

Management Systems.
• Be more able to understand the contents of MARPOL 73/78 and its

application to your ships.
• Have a better understanding of the relationship between shipping

and the environment and the issues that they raise.
• Understand how “Green” issues and addressing them is important to

the company.
• Understand the relationship between the ISM Code and ISO 14000.
• Understand the need for environmental training both on board and

ashore.
5.1 ISO 14000: ENVIRONMENTAL MANAGEMENT
5.1.1 The ISO 14000 Series
6B-428 This topic has been covered earlier in the course and this chapter is to take it
further and investigate environmental issues in the shipping industry.
6B-429 ISO 14000 delivers a framework for environmental management and what is
expected to meet the requirements for auditing to attain certification.
6B-430 Because it is so broad, details of the requirements for individual industries

cannot be covered. This is why for ISO 14000 they bring process experts for the
industry they are auditing as part of the team.
6B-431 The maritime industry is making inroads to the environmental issues surrounding
it and it has been a major agenda at the IMO for the decade since 2000.
6B-432 Over the next eight to nine years there will be major changes to the way shipping
companies and their ships operate.
6B-433 The surprising part of all of this is that the ISO 14000 series is more
complementary to the ISM Code than the ISO 9000 series.

Module 6B The Environment and Shipping: Minimising the Impact
6B-434 What is most important with the ISO 14000 series is setting objectives and
targets in the Environmental Policy. These should not be a wish list but be
attainable and be built on year by year.
6B-435 At this time the major convention for environmental issues is MARPOL 73/78.
This will be discussed in the next section.
6B-436 There are other environmental conventions and codes that are being implemented
in shipping.
6B-437 They can be linked under the umbrella of ISO 14000 and, by expanding upon
this, it will be relevant to the standard and show how the company is meeting
any obligations that it feels are necessary.
Is your company implementing ISO 14000 at this time?
Can you identify any environmental issues that your company are
addressing that do not require to be addressed as a mandatory
requirement?
5.2 MARPOL 73/78
5.2.1 MARPOL 73/78: The Structure and Contents
6B-438 The full title of MARPOL 73/78 is the “International Convention for the Prevention
of Pollution from Ships, 1973, as modified by the Protocol of 1978”.
6B-439 What any person must understood when using MARPOL is that it is geared to
preventing pollution of the marine environment. It just so happens that in doing
so it meets environmental responsibility.
6B-440 In its first format there was only one annex. Now, to meet the requirements of
legislation, it has six annexes. There is no doubt that over the years to come it
will increase in size and the number of Annexes will also be increased.
6B-441 It is not the only maritime convention dealing with environmental issues. But, it
is the one that everyone thinks of when they think of environmental protection
and pollution prevention.
6B-442 The structure of MARPOL has been the same since it was first initiated and
follows a set pattern. It is not an easy convention to read and the referencing to
other elements contained within it means that you have to ensure that you do
not become lost while navigating through the contents and remain focused on
the original fact you were working on.
5.2.1.1 The Structure of MARPOL 73/78
6B-443 International Convention for the Prevention of Pollution from Ships, 1973.

The Environment and Shipping: Minimising the Impact Module 6B
6B-444 Protocol of 1978 relating to the International Convention for the Prevention of
Pollution from Ships, 1973.
Protocol I: Provisions concerning Reports on Incidents Involving Harmful

Substances
Protocol II: Arbitration
Protocol of 1997 to amend the International Convention for the Prevention of

Pollution from Ships, 1973, as amended by the Protocol of 1978 relating
thereto
MARPOL Annex I: Regulations for the Prevention of Pollution by Oil
Chapter 1 General
Chapter 2 Surveys and certification
Chapter 3 Requirements for machinery spaces of all ships
Chapter 4 Requirements for the cargo areas of oil tankers
Chapter 5 Prevention of oil pollution arising from an oil pollution incident
Chapter 6 Reception facilities
Chapter 7 Special requirements for fixed or floating platforms
Appendices to Annex I
Appendix I List of Oils
Appendix II Form of IOPP Certificate and Supplements
Appendix III Form of Oil Record Book
Unified Interpretations of Annex I
Appendices to Unified Interpretations of Annex I
Appendix 1 Guidance to Administrations concerning draughts recommended for

segregated ballast tankers below 150 m in length
Appendix 2 Interim recommendations for a unified interpretation of regulations

18.12–18.15 “Protective location of segregated ballast spaces”
Appendix 3 Connection of small diameter line to the manifold valve
Appendix 4 Specifications for the design, installation and operation of a part flow
system for control of overboard discharges
Appendix 5 Discharges from fixed or floating platforms

MARPOL Annex II: Regulations for the Control of Pollution by Noxious

Liquid Substances in Bulk
Chapter 1 General
Chapter 2 Categorization of noxious liquid substances
Chapter 4 Design, construction, arrangements and equipment
Chapter 5 Operational discharges of residues of noxious liquid substances
Chapter 6 Measures of control by port States
Chapter 7 Prevention of pollution arising from an incident involving noxious

liquid substances
Appendices to Annex II
Appendix 1 Guidelines for the categorization of noxious liquid substances
Appendix 2 Form of Cargo Record Book for ships carrying noxious liquid
substances in bulk
Appendix 3 Form of International Pollution Prevention Certificate for the Carriage

of Noxious Liquid Substances in Bulk
Appendix 4 Standard format for the Procedures and Arrangements Manual
Appendix 5 Assessment of residue quantities in cargo tanks, pumps and

associated piping
Appendix 6 Prewash procedures
Appendix 7 Ventilation procedures
MARPOL Annex III: Regulations for the Prevention of Pollution by Harmful

Substances Carried by Sea in Packaged Form
Regulation 2 Packing
Regulation 3 Marking and Labelling
Regulation 4 Documentation
Regulation 5 Stowage
Regulation 6 Quantity limitations
Regulation 7 Exceptions

Regulation 8 Port State control on operational requirements
Appendix to Annex II
Appendix Guidelines for the identification of harmful substances in packaged

form
Unified Interpretation of Annex III
MARPOL Annex IV: Regulations for the Prevention of Pollution by Sewage

from Ships
Chapter 1 General
Chapter 3 Equipment and control of discharge
Appendix to Annex IV
Appendix Form of International Sewage Pollution Prevention Certificate
MARPOL Annex V: Regulations for the Prevention of Pollution by Garbage

from Ships
Regulation 1 Definitions
Regulation 3 Disposal of garbage outside special area
Regulation 4 Special requirements for the disposal of garbage
Regulation 5 Disposal of garbage within special areas
Regulation 6 Exceptions
Regulation 7 Reception facilities
Regulation 8 Port State control on operational requirements
Regulation 9 Placards, garbage management plans and garbage record-

keeping
Appendix to Annex V
Appendix Form of Garbage Record Book
MARPOL Annex VI: Regulations for the Prevention of Air Pollution from
Ships

Chapter 1 General
Chapter 2 Surveys, certification and means of control
Chapter 3 Requirements for control of emissions from ships
Appendices to Annex VI
Appendix I Form of IAPP Certificate
Appendix II Test cycles and weighting factors
Appendix III Criteria and procedures for designation of SOx emission control
area
Appendix IV Type approval and operating limits for shipboard incinerators
Appendix V Information to be included in the bunker delivery note
Unified Interpretations of Annex VI
As can been seen from the above the MARPOL Convention is quite a
formidable document which requires careful reading and interpretation of the
contents.
6B-445 The fist step is to know which Annexes affect the ships you are responsible for
and then knowing where to find the relevant details.
6B-446 Legislation is under constant review for shipping; therefore it would be a waste
of time learning any. The most important point is in knowing where to find the
relevant legislation
6B-447 In addition to this structure there is an important part of the MARPOL Convention.
This is contained in Additional Information.
Item 10 is titled “Certificates and Documents required to be carried on board

Ships”
6B-448 This lists all the certificates and documents to be carried on board ships covered
by IMO Conventions. It clearly references each to the particular convention or
code that it is taken from. An exact copy of this can be found in the SOLAS
Convention under Annex I: “Certificates and Documents required to be carried
on board Ships”.
6B-449 It is broken down into the requirements for individual ship types and will be of
great assistance to ship managers. Of course it does not cover other publications
that are industry related.
6B-450 An example of this is the Tanker Safety Guide – Chemicals or the OCIMF SIRE
VIQ.
6B-451 Every ship will need to meet the Annexes of MARPOL that apply to that ship and
sections within each Annex that are relevant.

6B-452 There is a curious point in Annex 3. This has a direct link to the International
maritime Dangerous Goods (IMDG) Code. The IMDG Code is also found in
SOLAS 74 Chapter VII – Carriage of Dangerous Goods – Part A – Carriage of
Dangerous Goods in Packaged Form.
6B-453 Therefore, to cover all aspects of the IMDG Code it requires two conventions to
make it work: namely, the MARPOL and SOLAS Conventions. This is the
exception rather than the rule but it shows that the ship manager must be vigilant
to ensure that all legislation is being met.
Choose one ship from the fleet that is operated by your company.
Then check against the MARPOL Convention for which Annexes apply.
Remember, to look at all of the annexes to identify if any section applies to

that ship.
5.3 SHIPPING AND ENVIRONMENTAL ISSUES
5.3.1 Beyond MARPOL 73/78
6B-454 The ship manager must not concentrate only on MARPOL 73/78 as the sole
legislation for shipping in respect of the environment.
6B-455 ISO 14000 is a voluntary standard and helps a lot in understanding and applying
environmental legislation to your company. It also improves environmental
awareness amongst employees and their needs.
6B-456 An additional factor that must be considered is that of the public relations of how
a shipping company is viewed by the general public. If it meets and is certified
to ISO 14000 then that is a recognisable standard whereas complying with
MARPOL 73/78 means nothing, except to those who work in the maritime
industry.
6B-457 That is not to say that the shipping industry has been sitting doing nothing. The
following are a couple of environmental issues that have been dealt with and will
be in the future.
1. The Ballast Water Management Convention
2. Banning of Tributyltin anti-fouling paint
3. Vapour Recovery System from cargo spaces and not just main engines
4. Noise Levels on Ships
5. Vibration on ships

6. Sustainability
7. Life cycle of Ships
8. Review of the Scrapping of Ships.
6B-458 Each of these items has a major impact on shipping. Yes they are environmental
issues but the companies have to pay for the fleet to comply with the
standards.
6B-459 The Ballast Water Management Convention was first brought to the forefront to
stop the spread of pathogenic organisms through ballast water transfer. This was
causing major problems, especially in port areas where the loading and
discharging of untreated ballast water was interfering and damaging the eco-
system of one location by introducing alien parasites to a new location where the
indigenous wildlife and plants had no defence.
6B-460 Tributyltin anti-fouling paints only caused problems when the ships were stopped
in port. When the ships were in port areas operating cargo this anti-fouling paint
would leech out tin in large amounts into the local waters. This is turn would
cause a lot of damage to the local eco-system.
6B-461 Vapour recovery systems are for tankers. Oil tankers would eject large amounts
of inert gas with cargo hydrocarbon vapour during loading operations. This is not
acceptable and systems have been produced to recover and clean the gas and
release only fresh air, with the bad stuff being retained on board.
6B-462 Noise levels on ships have been an issue for many years and are being
addressed now with noise reduction levels and looking at how these can be
reduced further. Noise and background noise affect the crew as they are exposed
24/7 to its affects. This is then transferred to local inhabitants if their homes are
close to a shipping terminal. It can have a major effect on people and their life-
styles and more so to the crews.
6B-463 Vibration is an issue on ships. This can be from the vibrations of the power plant
being transferred through the structure of the ship. It can also be caused by the
operation of cargo pumping equipment or transfer of cargo by cranes or other
systems.
6B-464 Vibration can also be caused by the motion of the ship through the seaway. This
is greatly increased when navigating in bad weather and the motion of the ship
is greatly increased and a number of different forces come into play and act on
the hull and this is passed through the hull structure.
6B-465 There is also the issue of operating vibrating tools on board ship and the impact
of long-term use on the personnel operating such equipment.
6B-466 Sustainability is a big issue that is just getting started in shipping. It is looking at
the whole of the maritime industry and how it operates and then on how to
reduce or negate its impact on the bio-sphere. It will take in all parts of how a
company operates and will look not only at ships but at the offices and
personnel.

6B-467 Life cycle of ships is going where the motor car industry has been for some time.
It is not enough just to build a ship but it should be built with “green” issues in
mind during the construction; operational life time; and scrapping of the ship so
that as much as possible can be recycled and not wasted. This is slowly being
taken on board and being thought of and applied. It adds cost to the design and
construction of the ship and at first it cannot be seen how this money will be
recouped. It will be and as it gains more acceptances it will become the standard
not the exception.
6B-468 The scrapping of ships is a contentious issue. Many of the scrap-yards used are
located in the poorest countries of the world. The workers have no protection
and work in extreme conditions with no thought of safety. Should this be allowed
to continue? There are arguments from both sides which when looked at may
have merit. This will depend upon the stance that you take and the viewpoint that
you hold. In these countries there are large profits to be made on scrapping of
ships on the backs of poorly paid workers.
6B-469 Death or major injury is a common occurrence in these scrap-yards.
6B-470 The technology is already here and has been for some time to build and operate
ships that have a zero aspect and impact on the environment and especially the
marine environment.
6B-471 Environmental systems cost money to build and install. It will cost more money
to operate and maintain them. This is probably the most important factor affecting
the progress.
6B-472 Most shipping companies are ethical and do want to be environmentally friendly,
the problem is finding the money to pay for it.
6B-473 This becomes even more apparent when you look at issues that have been
enacted, such as tanker design and the requirement of double-hulled tankers.
6B-474 Shipping is getting there but it is hard going and everyone’s point of view needs
to be considered.
5.3.2 Environmental Matters
6B-475 The shipping industry has in place insurance systems to cover the costs of
clean-ups after oil spills and losses of ships.
6B-476 There are global requirements and national requirements that need to be met.
6B-477 One country that is ahead of most is the USA. After the Exxon Valdez disaster
they reviewed their environmental legislation and the way clean-up operations
were conducted and the cost. The Americans saw that no matter what you did,
there is always the possibility of an oil spill from oil tankers.
6B-478 The result was the Oil Pollution Act 1990 (OPA 90).

6B-479 This required that shipping companies retained the services of Qualified
Individuals (QI) and Oil Spill Response Organizations (OSRO) to deal with
spills.
6B-480 In addition, shipping companies had to put in place insurance cover to deal with
the oil spills. This took the form of a Certificate of Financial Responsibility
(CoFR). This was for US$ 700 million with a top up of US$ 300 million to cover
certain states.
6B-481 The concept at the core of this national legislation was that the polluter pays.
6B-482 In addition, no ship would be allowed to trade to American ports or pass through
American waters without first having these requirements in place. There would
be no exceptions.
6B-483 After a spate of oil spills and environmental damage the EU is preparing to
introduce its own equivalent standard to the United States’ OPA 90.
Choose any one of the topics listed above and research what your company
is doing to meet its demands?
5.4 HOW “GREEN” IS YOUR ORGANISATION
5.4.1 What Steps is Your Organisation Taking to Become an Environmentally

Aware Company
6B-484 This section is more about the delegate reviewing the environmental issues
raised in this module and previous modules of the course.
6B-485 It is then a matter of identifying these various items and then checking to see
which ones your company is actively pursuing or not as the case may be.
6B-486 There is no right or wrong answer. What is important is that the company will
comply with mandatory and statutory requirements.
6B-487 The question that must be asked is what is it doing to prepare itself for other
environmental legislation that is coming in the future?
6B-488 Also does it have programmes in place for reducing waste and garbage?
6B-489 Are any environmental programmes running in the company? For example:
environmental awareness training.
6B-490 There is no Self-Assessment Question for this section. It is about taking time to
sit back and reflect on the issues raised and where your company was, where it
is now and where it is going in the future.
6B-491 Can you see where it is going and is it sympathetic to environmental issues?

5.5 THE RELATIONSHIP BETWEEN THE ISM CODE AND ISO 14000
5.5.1 Comparison of Standards
6B-492 The ISM Code has become known as a Safety Management Code and in doing
so a lot of people have forgotten that the full title is the International Management
Code for the Safe Operation of Ships and for Pollution Prevention.
6B-493 This is backed up with the need for a Safety and Environmental Protection Policy
(ISM Code A-2) and throughout the whole body of the Code there are references
to environmental protection and pollution prevention.
6B-494 This is why the ISO 14000 standard and the ISM Code are more compatible
than the ISM Code and ISO 9000.
6B-495 ISO 14000 takes matters in a more generic way and expands upon what is
contained in the ISM Code and as a result places more emphasis on
environmental matters.
6B-496 ISO 14000 can be used to enhance the SMS. This is achieved by using the
terminology and sections of the ISO 14000 and blending them into the SMS.
6B-497 The problem arises when a company decides to achieve accreditation to both
standards. The ISM Code is mandatory and the audit schedule is set and the
windows must be complied with. ISO 14000 is voluntary and the audit schedule
for maintaining certification does not match up with the auditing schedule for the
ISM Code.
6B-498 What is required is to find an accreditation body who will work with the company
to try and reduce the number of audits and match whereever possible the ISM
Code auditing schedule.
6B-499 The final result of this is that anyone working in the maritime industry needs to
be aware of environmental matters and their application to the workplace.
6B-500 ISO 14000 series deals with more than just environmental management systems
and should be read to give support to learning about environmental issues.
5.6 ENVIRONMENTAL TRAINING
6B-501 There are a number of different training packages available:
6B-502 There are Environmental Internal Auditor Courses.
6B-503 There are Environmental Lead Auditor Courses.
6B-504 There are DVDs on environmental issues.
6B-505 There are distance learning courses on environmental issues.
6B-506 But there are other matters that involve the environment.

6B-507 These can be to do with the Carriage of Dangerous Goods.
6B-508 Also to do with MARPOL.
6B-509 What must not take place is a focus solely on the ISM Code and ISO 14000?
6B-510 How the Company decides to tackle this issue is for them to inform employees.
By making training available to employees the company is assisting in
environmental awareness amongst its staff.
What environmental training does your company provide for its

employees?

6. HEALTH AND SAFETY AND THE COMPANY:
THE CARE OF EMPLOYEES
LEARNING OUTCOMES
• Have a better understanding of health surveillance issues.
• Be able to understand the contents of Hours of Work and Rest

legislation and its application to your ships.
• Have a better understanding of Ship Medical Supplies and their use

and recording of them.
• Understand the effect of Stress on Employees.
• Understand the effect of Fatigue on Employees.
• Understand the need for Dignity and Respect at Work being applied
to all employees.
6.1 HEALTH SURVEILLANCE
6.1.1 What is Health Surveillance?
6B-511 Health surveillance of employees is very important for any organisation because
the health and well being of its workers is an important factor in the performance
of the organisation.
6B-512 There are a number of different facets that need to be looked at. The sections of
this chapter all focus on linking the employees and their welfare and care. This
section covers those on board ship and those in the shore offices.
6B-513 It should be looked at in the context of prevention is better than cure. That is if
an early intervention takes place in respect of health issues then this can
dramatically reduce the severity of the illness or condition and therefore reduce
the time before the employee can return to work.
6B-514 Of course, it is better that the employee does not become ill in the first place and
this can only be achieved by indentifying the risks to employees and taking
actions so as to reduce the risk to as low as reasonably practicable (alarp).
6.1.2 A Definition of Health Surveillance
6B-515 There is no definitive definition of health surveillance but one that gives a sense
of what it is about states it as:

Module 6B Health and Safety and the Company: The Care of Employees
a means of identifying early signs of ill health caused by occupational

hazards so that action can be taken to protect individuals at an early stage
from further harm.
6B-516 How this is achieved is varied and in some cases will be dependent upon the
ship type and the cargoes carried on board.
6B-517 It should not be forgotten that health surveillance should also be conducted on
those who work in the offices of a shipping company and that signs of ill-health
should not be dismissed but observed and recorded.
6.1.3 Reference Publication on Health Publication
6B-518 One of the publications that lays out the core concepts of Health Surveillance as
it applies to seamen can be found in:
Maritime and Coastguard Agency (UK)
Code of Safe Working Practices for Merchant Seamen (COSWP)
Section 1 – Safety Responsibilities / Shipboard Management
Chapter 2 – Health Surveillance
This is published in the UK by The Stationery Office (TSO).
Although this publication is a Code it is given mandatory status on board UK

registered ships because it is controlled by a Statutory Instrument of UK Law.
There are other publications of which the Maritime Labour Convention (MLC),
206 is probably the most important. The following parts of the Convention should
be looked at closely as they conform most closely to the health surveillance
requirements.
The main point is that the whole of the MLC is dealing with seafarers, their
welfare and health.
Title 3 Accommodation, Recreational Facilities, Food and Catering
Regulation 3.1 Accommodation and Recreational Facilities
Regulation 3.2 Food and Catering
Title 4 Health Protection, Medical Care, Welfare and Social Security

Protection
Regulation 4.1 Medical Care on Board Ship and Ashore
Regulation 4.2 Shipowners’ Liability
Regulation 4.3 Health and Safety Protection and Accident Prevention

Health and Safety and the Company: The Care of Employees Module 6B
Regulation 4.4 Access to Shore-based Welfare Facilities
Regulation 4.5 Social Security
Once the MLC is ratified and becomes the global standard then national
legislation will be required to be amended if the flag state is a signatory to the
MLC.
6.1.4 Points to Consider for Health Surveillance
.1 Employers must provide health surveillance that is relevant and appropriate

which has been identified by risk assessment and other means.
.2 Health surveillance can be used as a means of identifying the early

signs of ill health in employees.
.3 Health surveillance can be used to install protective measures to

safeguard employees from occupational hazards. Examples of this are:
• Exposure to hazardous substances is limited and employee removed

from such exposure when nearing legal limit.
• If an employee is experiencing minor ailments this should be

investigated to stop it progressing to becoming a major health
problem.
.4 Health surveillance can be used to provide:
• Checks for the effectiveness of health control measures
• To provide feedback on how accurate health risk assessments have

been
• To protect employees from identified increases in risks to health
.5 Health surveillance is not to be used as a substitute for controlling risks to

health and safety.
.6 Health surveillance is not to be used as a replacement of

medical examinations and to assess fitness for work.
6.1.5 Application of Health Surveillance
6B-519 When risk assessment identifies potential harm such as:
1 a work activity that may cause ill health;
2 disease or health condition that is adverse and related to work;
3 testing methods for detection of work disease or condition;

4 potential of disease or condition occurring because of related

working conditions;
5 surveillance is required to ensure protection of employees.
6B-520 In addition, certain work types should be identified that must have health
surveillance. These are:
1 exposure to hazardous substances;
2 working with vibrating tools;
3 being exposed to high noise levels;
4 exposure to materials/substances with a track record of causing

dermatitis;
5 exposure to dusts (in particular that given off from asbestos).
6.1.6 Health Surveillance Records
6B-521 It is important that a full set of health surveillance records be kept for each
employee.
6B-522 Central to keeping these records is that a system has been implemented to
ensure the confidentiality of the records.
6B-523 This will include the restricted access to these records.
6B-524 Any person accessing these records should have a date, time and reason for
inspecting the records.
6B-525 The release of any of the health surveillance records of an employee by any
individual or organisation can only be allowed after the individual concerned has
been contacted and has given written permission for the records to be
released.
What health surveillance has been introduced in your company?
Does it cover both those onboard and those ashore?
What issues of health surveillance would you consider for those working in
an office?

6.2 HOURS OF WORK AND REST
6.2.1 Hours of Work and Rest in the Workplace
6B-526 It is a very difficult equation to balance. On one side there is the legislation to be
met. On the other side there is the need for the ship to perform and meet the
requirements of the charterparty.
6B-527 All too often the legislation is dismissed and work is carried out. The records are
amended to show that no excessive hours were worked and everyone is
happy.
6B-528 But reverse the situation. Personnel are working excessive hours and an
accident occurs. On inspection the person injured was way over their working
hours. What will happen now?
6B-529 Excessive hours can cause stress and fatigue and the guidelines for limiting
hours worked were not invoked for fun. It was to try and control and reduce
stress and fatigue and the link to accidents and injuries.
6B-530 Sometimes difficult choices have to be made. If the working day needs to be
increased to meet the workload it can perhaps be said that the crew numbers
on board are not enough.
6B-531 There are arguments from both sides of this point of view but how can breaking
the law for routine work practices be justified?
6.2.2 STCW Convention Requirements
6B-532 The contents of requirements for Hours of Work and Rest are defined under
“Fitness for Duty”:
STCW 78, Convention
STCW Code as amended
Part A, Chapter VIII – Watchkeeping
Section 1 – Fitness for Duty
Administrations shall take account of the danger posed by fatigue of seafarers,

especially those whose duties involve the safe operation of a ship.
All persons who are assigned duty as officer in charge of a watch or as a rating
forming part of a watch and those whose duties involve designated safety,
prevention of pollution and security duties shall be provided with a rest period of
not less than:
.1 a minimum of 10 hours of rest in any 24-hour period; and
.2 77 hours in any 7-day period

The hours of rest may be divided into no more than two periods, one of which
shall be at least 6 hours in length, and the intervals between consecutive periods
of rest shall not exceed 14 hours.
The requirements for rest periods laid down in paragraphs 2 and 3 need not be
maintained in the case of an emergency or in other overriding operational
conditions. Musters, fire-fighting and lifeboat drills, and drills prescribed by
national laws and regulations and by international instruments, shall be
conducted in a manner that minimizes the disturbance of rest periods and does
not induce fatigue.
Administrations shall require that watch schedules be posted where they are
easily accessible. The schedules shall be in a standardized format in the working
language or languages of the ship and in English.
[The IMO/ILO Guidelines for the development of tables of seafarers’ shipboard

working arrangements and formats of records of seafarers’ hours of work and
rest may be used.]
When a seafarer is on call. Such as when a machinery space is unattended, the

seafarer shall have an adequate compensatory rest period if the normal period
of rest is disturbed by call-outs to work.
Administrations shall require that records of daily hours of rest of seafarers be

maintained in a standardized format, in a working language or languages of the
ship and in English, to allow monitoring and verification of compliance with the
provisions of this section. The seafarers shall receive a copy of the records
pertaining to them, which shall be endorsed by the master or by a person
authorized by the master and by the seafarers.
[see note below 5 above para]
Nothing in this section shall be deemed to impair the right of the master of a ship
to require a seafarer to perform any hours of work necessary for the immediate
safety of the ship, persons on board or cargo, or for the purpose of giving
assistance to other ships or persons in distress at sea. Accordingly, the master
may suspend the schedule of hours of rest and require a seafarer to perform any
hours of work necessary until the normal situation has been restored. As soon
as practicable after the normal situation has been restored, the master shall
ensure that any seafarers who have performed work in a scheduled rest period
are provided with an adequate period of rest.
Parties may allow exceptions from the required hours of rest in paragraphs 2.2
and 3 above provided that the rest period is not less than 70 hours in any 7-day
period.
Exceptions from the weekly rest period provided for in paragraph 2.2 shall not
be allowed for more than two consecutive weeks. The intervals between two
periods of exceptions on board shall not be less than twice the duration of the
exception.

The hours of rest provided for in paragraph 2.1 may be divided into no more than
three periods, one of which shall be at least 6 hours in length, and neither of the
other two periods shall be less than one hour in length. The intervals between
consecutive periods of rest shall not exceed 14 hours. Exceptions shall not
extend beyond two 24-hour periods in any 7-day period.
Exceptions shall, as far as possible, take into account the guidance regarding
prevention of fatigue in section B-VIII/1.
Each Administration shall establish, for the purpose of preventing alcohol abuse,
a limit of not greater than 0.05% blood alcohol level (BAC) or 0.25 mg/l alcohol
in the breath or a quantity of alcohol leading to such alcohol concentration for
master, officers and other seafarers while performing designated safety, security
and marine environmental duties.
6.2.3 Maritime Labour Convention, 2006 Requirements
Maritime Labour Convention (MLC), 2006
Adopted: 23 February 2006
Title 2. Conditions of Employment
Regulation 2.3 – Hours of Work and Hours of Rest
Purpose: To ensure that seafarers have regulated hours of work or hours of

rest
Each Member shall ensure that the hours of work or hours of rest for seafarers
are regulated.
Each Member shall establish maximum hours of work or minimum hours of rest
over given periods that are consistent with the provisions in the Code.
Standard A2.3 – Hours of work and hours of rest
For the purpose of this Standard, the term:
Hours of work means time during which seafarers are required to do work on
account of the ship;
Hours of rest means time outside hours of work; this term does not include short
breaks
Each Member shall within the limits set out in paragraphs 5 to 8 of this Standard
fix either a maximum number of hours of work which shall not be exceeded in a
given period of time, or a minimum number of hours of rest which shall be
provided in a given period of time.
Each Member acknowledges that the normal working hours’ standard for
seafarers, like that for other workers, shall be based on an eight-hour day with
one day of rest per week and rest on public holidays. However, this shall not

prevent the Member from having procedures to authorize or register a collective

agreement which determines seafarers’ normal working hours on a basis no less
favourable than this standard.
In determining the national standards, each Member shall take into account of
the danger posed by the fatigue of seafarers, especially those whose duties
involve navigational safety and the safe and secure operation of the ship.
The limits on hours of work or rest shall be as follows:
Maximum hours of work shall not exceed:
14 hours in any 24-hour period; and
72 hours in any seven-day period
Or
Minimum hours of rest shall not be less than:
Ten hours in any 24-hour period; and
77 hours in any seven-day period
Hours of rest may be divided into no more than two periods, one of which shall
be at least six hours in length, and the interval between consecutive periods of
rest shall not exceed 14 hours.
Musters, fire-fighting and lifeboat drills, and drills prescribed by national law and
regulations and by international instruments, shall be conducted in a manner
that minimizes the disturbance of rest periods and does not induce fatigue.
When a seafarer is on call, such as when a machinery space is unattended, the

seafarer shall have an adequate compensatory rest period if the normal period
of rest is disturbed by call-outs to work.
If no collective agreement or arbitration award exists or if the competent authority

determines that the provisions in the agreement or award in respect of paragraph
7 or 8 of this Standard are inadequate, the competent authority shall determine
such provisions to ensure the seafarers concerned have sufficient rest.
Each Member shall require the posting, in an easily accessible place, of a table
with the shipboard working arrangements, which shall contain for every position
at least:
The schedule of service at sea and service in port; and
The maximum hours of work or the minimum hours of rest required by national
laws or regulations or applicable collective agreements
The table referred to in paragraph 10 of this Standard shall be established in a

standardized format in the working language or languages of the ship and in
English.

Each Member shall require that records of seafarers’ daily hours of work or of
their daily hours of rest be maintained to allow monitoring of compliance with
paragraphs 5 to 11 inclusive of this Standard. The records shall be in a
standardized format established by the competent authority taking into account
any available guidelines on the International Labour Organization or shall be in
any standard format prepared by the Organization. They shall be in the languages
required by paragraph 11 of this Standard. The seafarers shall receive a copy of
the records pertaining to them which shall be endorsed by the master, or a
person authorized by the master, and by the seafarers.
Nothing in paragraphs 5 and 6 of this Standard shall prevent a Member from

having national laws or regulations or a procedure for the competent authority to
authorize or register collective agreements permitting exceptions to the limits set
out. Such exceptions shall, as far as possible, follow the provisions of this
Standard but may take account of more frequent or longer leave periods or the
granting of compensatory leave for watchkeeping seafarers or seafarers working
on board ships on short voyages.
Nothing in this Standard shall be deemed to impair the right of the master of a
ship to require a seafarer to perform any hours of work necessary for the
immediate safety of the ship, persons on board or cargo, or for the purpose of
giving assistance to other ships or persons in distress at sea. Accordingly, the
master may suspend the schedule of hours of work or hours of rest and require
a seafarer to perform any hours of work necessary until the normal situation has
been restored. As soon as practicable after the normal situation has been
restored, the master shall ensure that any seafarers who have performed work
in a scheduled rest period are provided with an adequate period of rest.
6.2.4 Comparison of STCW and MLC
6B-533 The MLC has not been ratified and brought into force but should be before the
end of 2012.
6B-534 What is important is that the latest revision of the STCW and the MLC brings
both into line with each other.
6B-535 There are still differences but these have been reduced and the STCW has had
a number of additions made to it.
6B-536 Delegates are reminded that to have a full comprehension of these documents,
that the STCW has the Code Part B – Guidance for this standard, and the MLC
has Guidelines B2.3.
6B-537 The difference is that the STCW concentrates on the minimum hours of rest,
whereas the MLC concentrates on the maximum hours of work and the minimum
hours of rest.
6B-538 The minimum hours of rest are nearly the same in both standards, that is:
10 hours in any 24-hour period (STCW)
11 hours in any 24-hour period (MLC)

77 hours in any seven-day period (STCW & MLC).
6B-539 The maximum hours of work:
14 hours in any 24-hour period (MLC)
72 hours in any seven-day period (MLC).
6.2.5 Hours of Work and Rest and the Safe Manning Document
6B-540 The Safe Manning Document as found in SOLAS Chapter V Regulation 14 –

Ships’ Manning – has been made mandatory by IMO Res. 890(21), as amended
by resolution A.955(23).
6B-541 Depending upon which standard has been chosen the company has to show
that the Manning Levels for the ship type and the trade that it will be engaged
on will ensure that the crew do not suffer from fatigue.
6B-542 This could be brought about by the workload not being able to be completed by
the crew numbers on board in the hours of work allowed by the legislation.
6B-543 In some cases ships’ have tried to give a defence of being over the hours
allowed for work by stating crews operations on board the ship were none
standard, This could include: tank cleaning or hold cleaning on passage; crude
oil washing on tankers in port; or extended stand-by operations from the pilot
boarding until alongside a berth.
6B-544 None of these are exceptional or emergency situations. They should have been
allowed for in the manning level set for the ship when the Safe Manning
Document was applied for.
6B-545 The ship manager needs to understand the principles involved and liaise with the
Crewing Department to ensure the correct manning levels are maintained. This can
also apply if the normal trading pattern of the ship is changed by a new charterparty.
The increase in workload may require an increase in the manning level.
6B-546 It is too late if this is found by third-party inspection such as Port State Control,
flag state inspection, ISM audit or ISPS audit.
Check the Safe Manning Document of ships in your company.
Then, if possible, check the hours of work or rest for one month of the same
ship.
Refer to the ship’s operational rota with the number of port visits, anchorage
and cargo operations.
Check whether STCW or the MLC is the standard being used on board.

6.3 SHIP MEDICAL SUPPLIES
6.3.1 Medical Standards on Board Ships
6B-547 Depending on the ship type and the number of crew carried on board the
requirement of carrying a doctor varies.
6B-548 Passenger ships require doctors and medical staff to be carried. The majority of
cargo ships of various types do not.
6B-549 The requirements of the medical supplies to be carried will vary depending on
the danger imposed by the cargoes carried.
6B-550 Tankers will require more medical supplies to be carried than bulk carriers. This
will be increased for chemical tankers which will have to carry antidotes for a
number of cargoes that it carries.
6.3.2 Ship Medical Stores
6B-551 The Flag Administration will determine the minimum medical stores that have to
be carried on board.
6B-552 This will be supplied as a minimum or surpassed by the Company and will be
placed on board by a Pharmacist who will issue a certificate to be kept in the
ship’s Certificate and Document File.
6B-553 This will be checked annually and the stores replenished and a new certificate
issued.
6.3.3 The Ship’s Medical Log Book
6B-554 One of the most misunderstood documents on board any ship.
6B-555 From the date of issue of the Pharmacist’s Certificate every item of consumption
must be recorded in the Medical Log Book.
6B-556 It is not a record of treatment given for every accident or incident, but for every
time any item is consumed.
6B-557 All too often the Medical Log is checked by PSC or third-party inspections and
discrepancies are found between what is found in the medical locker compared
to the Pharmacist’s Certificate and records in the Medical Log Book.
6B-558 Since supplies have been consumed but there is no record it would appear that
an accident has taken place but not been recorded. This will probably not be the
case but it is the appearance that the findings give.
6B-559 Therefore, when any member of staff requires any medical substances it must
be recorded whether this is Ibuprofen for a headache or some lotion and cotton
pads for sunburn.

6B-560 The consequences can have a major impact on the ship.
6B-561 When medical stores are consumed, a requisition order should be completed
and sent to the company for delivery as soon as possible. Part of the problem
can be forwarding the medical stores to the ship. Some countries will not allow
them to be transhipped. Other countries may not be able to provide the supplies
requested.
6B-562 Special requirements for tankers and in particular chemical tankers and container
ships require a large number of antidotes carried for the cargoes carried. These
antidotes need to be kept refrigerated and have a short limited shelf life.
6B-563 This requires additional work to check that they are still in date.
6.3.4 The Ship’s Hospital
6B-564 The ship’s hospital will also include the bathroom attached to it with a bath.
6B-565 This must be kept in a sterile condition and must not be used as a storeroom or
for visiting or sailing additional staff.
6B-566 Many ships have limited accommodation spaces and if requested to carry a
riding squad for, for example, blasting ballast tanks, then there is not enough
space. To resolve this situation the hospital is used to carry personnel.
6B-567 This is a breach of regulations and if found by PSC is a detainable item.
6B-568 Therefore, any plans made should not include the hospital as an accommodation
space.
6B-569 To retain a standard of a sterile space requires a lot of work by ship’s staff to
ensure the standard of cleanliness meets medical requirements.
6B-570 The solution is not to think that it is sterile because it is not in use; rather it is
sterile because it is cleaned regularly.
Check the Pharmacist’s Certificate for two different ship types.
Check the General Arrangement Plan of a ship and locate the hospital and
then check the maximum number of persons it is allowed to carry.
Then check the cabins on the General Arrangement Plan and see if
everything matches up.

6.4 THE EFFECT OF STRESS ON EMPLOYEES
6.4.1 Stress is with us All of the Time
6B-571 In fact stress helps us perform better, but there is a limit to the amount of stress
that is good and once exceeded it becomes bad for you. In the past it was not
realised that the effect of stress could be detrimental to the performance of
personnel and in extreme cases could lead to health issues.
6B-572 These could be physical or mental or in some cases both.
6B-573 The following notes are given to be as aid to ship managers to look for the signs
of stress in others and themselves.
6B-574 Remember stress issues are not limited to ship’s staff but also to those who
work in the office.
6.4.2 Stress and Stress Management
6B-575 The following passage was edited from Chapter 3 (“Stress and its effect on
health”), of a project entitled “Workplace Bullying” by Andy Ellis of Oxford
University, available on the Internet at www.stress.org.uk.
6B-576 The word stress derives from the Latin word “stringere” meaning to “draw tight ”
and was used during the seventeenth century to describe hardships or
affliction.
6B-577 The chart in Figure 1 shows how stress in the early stages can “rev up” the body
and enhance performance in the workplace, thus the phrase “I perform better
under pressure”. If this condition is allowed to go unchecked however, and the
body is revved up further, then performance will ultimately decline and the
person’s health will degenerate as demonstrated in the Figure.

Optimum
Effective Reduced Efficiency
Creative Reduced Alertness
Decisive
Overload
Alert
Stimulated Difficulty Concentrating

ABILITY
Indecisive
Under-involvement
Irritable
Boredom Anxious
Frustration Confused
Fatigue
Rust-out
Exhaustion
Burnout
DEMANDS
Figure 1
6B-578 The symptoms of stress outlined below in Figures 2 and 3, are believed to stem
from our primitive “fight or flight” response to perceived dangers. This response
produces surges of chemical reactions in the bloodstream as outlined in Figure
3, which can cause psychological problems such as Post Traumatic Stress
Disorder or Cumulative Stress Disorder for example.
6B-579 It is believed that man has retained much of his primitive hormonal and chemical
defence mechanisms intact throughout the centuries which enabled the cave
man to either fight the perceived danger or to retreat, thus the phrase “fight or
flight”. Unfortunately, the lifestyle we live today does not allow us to react
physically to the problems that we face. We are not, for example, able to punch
our boss, when he or she is acting aggressively as such actions is all forms of
behaviour that are not tolerated in today’s society. Similarly, in today’s society we
are not able to use the “flight” response either. The consequences for a manager
who flees from a stressful meeting are likely to be sweeping. It is believed that it
is this denial of our primitive responses that causes the strains on our body and
leads to stress-related disease and illness, as the adrenaline that runs through
our body and prepares us for our basic responses has no outlet.
6B-580 It has been argued that our thought patterns regarding ourselves and the
situations we are in trigger events within two branches of our central nervous
system, the “sympathetic” and the “parasympathetic”. In short, the “sympathetic”
reaction is where the body “revs up” the adrenaline and other hormones in the
bloodstream in response to a perceived danger and the “parasympathetic” is
where the body “revs down” and unwinds itself. The “rev up” activity is designed
to improve performance in the body, however, if the stress that launches this
activity continues unabated, the human body begins to weaken as it is

bombarded by stimulation and stress-related chemicals. The long-term effects of

pressure are shown in Figure 3.
Hypertension: high blood Nervous syspepsia: flatulence and

pressure indigestion
Coronary thrombosis: heart attack Depression

Migraine Hyperthyroidism: overactive thyroid gland
Hay fever and allergies Diabetes mellitus
Asthma Skin disorders
Pruritis: intense itching Tuberculosis
Peptic ulcers Colitis
Constipation Indigestion
Rheumatoid arthritis
Figure 2
List of Ailments recognised to have stress background.
Source: Cary Cooper. Stress and Employer Liability (p9).
6B-581 There can be little dispute against the ever-growing research that stress has a
significant negative impact on the wellbeing of both the individual and the
organisation. Links have been demonstrated between stress and the incidence
of heart disease, alcoholism, mental breakdowns, job dissatisfaction, accidents,
family problems and certain forms of cancer.
6B-582 In the UK during the 1980s, stress in the workplace proved to multiply similar
costs due to industrial action by more than tenfold. Figures released by the
Confederation of British Industry (CBI) in 1995 calculate that alcohol and drink-
related diseases cost the UK economy approximately £1.7 billion and 8 million
lost working days, with coronary artery disease and strokes costing a further 62
million days lost and mental health at £3.7 billion and 91 million days lost.
Normal Under Acute Chronic Pressure

(relaxed) Pressure Pressure (stress)
Brain Blood supply Blood supply up Thinks more Headaches or

normal clearly migraines, tremors
and nervous tics
Mood Happy Serious Increased Anxiety, loss of
concentration sense of humour
Saliva Normal Reduced Reduced Dry mouth, lump in
throat
Muscles Blood supply Blood supply up Improved Muscular tension
normal performance and pain
Heart Normal rate & Increased rate Improved Hypertension and
blood pressure and blood performance chest pains
pressure
Lungs Normal Increased Improved Coughs and asthma
respiration respiration rate performance
(Continued)

Stomach Normal blood Reduced blood Reduced Ulcers due to

supply and supply and blood supply heartburn and
acid secretion increased acid reduces indigestion
secretion digestion
Bowels Normal blood Reduced blood Reduced Abdominal pain
supply & supply and blood supply and diarrhoea
bowel activity increased bowel reduces
activity digestion
Bladder Normal Frequent Frequent Frequent urination,
urination urination due prostatic symptoms
to increased
nervous
stimulation
Skin Healthy Decreased blood Decreased Dryness and
supply. blood supply rashes
Dry skin
Biochemistry Normal: Oxygen More energy Rapid tiredness
oxygen consumption up, immediately
consumed, glucose and fats available
glucose and consumption up
fats liberated
Figure 3
Effects of Stress on Bodily Functions.
Source: A. Melhuish, Executive Health, London Business Books, 1978.
6B-583 The indirect costs to employers of stress-related illnesses are staggering but
unfortunately employers rarely actually attempt to estimate those costs. Instead,
employers simply treat absenteeism, high labour turnover ad low productivity as
an intrinsic part of running a business or simply blame the problems on the work
force with the allegation that the workers are simply lazy, old or slow.
6B-584 Cooper (Stress and Employer Liability p.15) argues that the second source of
growing costs is that:
“More and more American employees are litigating against their employers
in America through the worker compensation regulations and laws, in
respect of job related stress or what is being termed as ‘cumulative trauma’.
We are in the UK beginning to see a similar move towards this type of
litigation by workers as several British Trade Unions are supporting claims
by individual workers. The trend of cases coming through the courts is
certainly in the direction of mental; disability claims and damages being
awarded on the basis of workplace stress.”
6B-585 When we are faced with such overwhelming cost benefits in relation to reducing
stress and yet so little is done to minimise it, one has to wonder about the
mentality of British management in ignoring this vital issue.

6B-586 The quotation above clearly illustrates the possible effects of stress on the
individual and on organisations, and highlights the need to manage stress
effectively. The ability to identify the early stages of stress in oneself and in
others is vital to the successful management of stress. To manage stress in
oneself it is first necessary to identify one’s own personality. In a study on the
causes of heart problems, two distinct types of personality were identified and
categorised Type A and Type B.
6B-587 Type A personalities were found to be more likely to have heart problems and
were identified as being ambitious, competitive, hypercritical, perfectionist and
workaholic.
6B-588 Type B personalities were less likely to suffer heart problems and were identified
as being able to take time to reflect, were more laid back and relaxed, have a
more balanced approach to work in relation to life in general, but were still able
to perform and respond to situations effectively.
6B-589 Another identified factor is the concept of a “Hardy Personality”, someone who
can perceive clearly where they are going in life, know that they are in control
and accept responsibility for their behaviour. A “hardy personality” will see
potential new stressors as opportunities rather than threats and manage them
accordingly. Some people then, can tolerate potentially stressful situations better
than others, although everyone has a threshold. When that threshold will be
crossed depends on the context, the length of time that the person is exposed
to the situation and the value of worth that the ‘suffering’ represents to the
person.
6B-590 One study of stress outlines four possible stress-reducing measures that may be
employed, either separately or in combination, to reduce stress in oneself:
• Palliative the short term fix; smoking drinking; overeating. May be

effective in the short term but will become counter-productive if solely
relied on in the longer term.
• Direct modifying the demands of the job; changing the system; changing
the culture of the organisation.
• Indirect the use of peer support and counselling.
• Compensatory developing outside interests, perhaps exercise or

socialising; developing a more balanced lifestyle.
6B-591 To manage stress within oneself the following questions should be considered:
1. In what aspects of my life do I need to reduce stress the most?
2. What stresses should I reduce now and which can wait?
3. What stress-reducing techniques are best suited to my lifestyle/

personality?
4. How can my family help, if at all?

5. How can my friends and colleagues help?
6. How much time should I give to stress-reducing activities?
6B-592 The direct approach outlined above leads us back to the organisation and the
management of stress in others. As evidenced by the quotation at the beginning
of this section, an increasingly important management and leadership activity is
to identify and address the sources of stress that may lead to de-motivation or
even “burn-out” and illness. Three levels have been identified at which things can
be managed to reduce or minimise stress within organisations:
• Structurally the way the structure is organised including communications,

role assignation and teamwork.
• Culturally focusing on the positive aspects (rather than the negative) of

the shared values, thoughts, actions and feeling within the organisation.
• Personally being available to listen, counsel and support staff/colleagues,

perhaps to help them to identify how their own personalities may induce
stress and to establish their own stress reduction strategies.
6B-593 The subject of stress and stress management rounds off this brief discussion of
management. This final part has brought us back to the discussions and
significance or organisational structure, management activities, leadership,
motivation and teamwork. It illustrates that no single aspect or element of
management can be viewed in complete isolation.
Have you ever felt really stressed?
How did you cope with it?
How would identify stress in others?
Would you be able to discuss it with them or would you bring it to the
attention of a line manager?
6.5 THE EFFECT OF FATIGUE ON EMPLOYEES
6.5.1 Fatigue and the Seafarer and the Ship Manager
6B-594 Fatigue is linked to seafaring but not enough attention is given to the ship
manager and others who work ashore for the company. Shipping is global and
the demands have to be met on a 24/7 basis.
6B-595 There is no Hours of Work and Rest (review 8.2) for those ashore and it has to
be noted that shore staff work long hours and are on call 24/7 depending on the
position they hold.

6B-596 In addition, the effects of stress as noted above (review 8.4) add to fatigue and
can have a long-term and lasting affect on personnel.
6B-597 In many cases the effects of fatigue can be mental and/or physical and can have
short-term through to long-term and even permanent effects on individuals.
6B-598 It is not a matter of watching out for yourself but also fatigue in others. In many
cases the individual or individuals concerned do not want to recognize or admit
to fatigue as it will mean that they could be conceived as not being able to do
the job. This could not be further from the truth.
6B-599 Fatigue, tiredness whatever you want to call it has a major contributing factor to
many accidents.
6.5.2 Guidelines on Fatigue
6B-600 The following notes have been taken from the IMO publication titled Guidelines
on Fatigue (ISBN 92-801-5128-2):
List of Contents
Module 1: Fatigue
Module 2: Fatigue and the Rating
Module 3: Fatigue and the Ship’s Officer
Module 4: Fatigue and the Master
Module 5: Fatigue and the Training Institution and Management Personnel in

Charge of Training
Module 6: Shipboard Fatigue and the Owner/Operator/Manager
Module 7: Shipboard Fatigue and the Naval Architect
Module 8: Fatigue and the Maritime Pilot
Module 9: Fatigue and Tugboat Personnel
Appendices: Fatigue-related Documents
6.5.3 The Definition of Fatigue
6B-601 There is no universally accepted technical definition for fatigue. However,

common to all the definitions is degradation of human performance.
6B-602 The following definition is found in IMO’s MSC/Circ.813/MEPC/Circ.330.
6B-603 List of human element common terms:
“A reduction in physical and/or mental capability as the result of physical,

mental or emotional exertion which may impair nearly all physical abilities

including: strength; speed; reaction time; coordination; decision making; or

balance.”
6B-604 A person may suffer one of the above or a combination of the above but not all
of them. If that was the case they would be in a very bad way.
6.5.4 Causes of Fatigue
6B-605 The most common causes of fatigue known to seafarers are a lack of sleep, poor
quality of rest, stress and excessive workload. There are many other contributors
as well, and each will vary depending on the circumstances (i.e. Operational;
Environmental).
6B-606 There are many ways to categorise the causes of fatigue. To ensure thoroughness
and to provide good coverage of most causes, they have been categorised into
four general factors:
(i) Crew-specific factors
(ii) Management factors (ashore and aboard ship)
(iii) Ship-specific factors
(iv) Environmental factors.
6B-607 Each of the above can be broken down further to give a better understanding of
what is taking place:
Crew-specific factors
These are related to lifestyle behaviour, personal habits and individual attributes.
Fatigue varies from person to person and its effects are mainly dependent on
the particular activity being performed.
These factors may include the following:
• Sleep and rest
• Quality, quantity and duration of sleep
• Sleep disorders/disturbances
• Rest breaks
• Biological clock/Circadian rhythms
• Psychological and emotional factors, including stress
• Fear
• Monotony and boredom

• Health
• Diet
• Illness
• Stress
• Skill, knowledge and training as it relates to the job
• Personal problems
• Interpersonal relationships
• Ingested chemicals
• Alcohol
• Drugs (prescription and non-prescription)
• Caffeine
• Age
• Shift-work and work schedules
• Workload (mental/physical)
• Jet lag
Management factors (ashore and aboard ship)
These relate to how ships are managed and operated. They can potentially
cause stress and an increase in workloads, which in turn result in fatigue.
These factors include:
Organisational factors
• Staffing policies and retention
• Role of riders and shore personnel
• Paperwork requirements
• Economics
• Schedule-shift, overtime, breaks
• Company culture and management style
• Rules and regulations
• Recourses

• Upkeep of vessel
• Training and selection of crew
Voyage and scheduling factors
• Frequency of port calls
• Time between ports
• Routeing
• Weather and sea conditions en route
• Traffic density en route
• Nature of duties/workload while in port
Ship-specific factors
These include ship design features that can affect/cause fatigue.
Some ship design features affect workload (i.e.: automations; equipment

reliability); some affect the crew’s ability to sleep while others affect the level of
physical stress on the crew (i.e.: noise; vibration; accommodation spaces; etc)
These factors include:
• Ship design
• Level of automation
• Level of redundancy
• Equipment reliability
• Inspection and maintenance
• Age of the vessel
• Physical comfort in work spaces
• Location of quarters
• Ship motion
• Physical comfort of accommodation spaces
• Environmental factors
These can have a major impact on performance and because they are all
around us they are sometimes taken for granted.
These can include:

• Temperature variation
• Humidity
• Excessive noise levels
• Vibration
• Ship motion
All of the above can have a detrimental effect on a person but when taken
together can have an even more drastic effect.
Environmental factors can be considered in two categories:
These are internal factors and external factors
Internal factors are those found within the ship such as:
• Temperature
• Humidity
• Noise
External factors are those found outwith the ship such as:
• Port
• Weather
• Vessel traffic
All have a part to play on the performance of personnel and also impair the
judgement of personnel in making decisions.
One small item that has a massive impact of fatigue is moving around a ship
when the vessel is moving in a seaway.
The additional energy expended just to move about or maintain a position

increases as the motion increases but as time goes on and this movement
remains the fatigue on personnel begins to show.
6.5.5 Conclusion
6B-608 This section has been to introduce the delegate to fatigue and what it means and
how it can be measured.
6B-609 There are no new concepts being brought forward. The items listed are known
and accepted as part of working in the shipping industry. But are they? Is it not
time to question some of these and think of how they can be overcome?

6B-610 Part of the solution must be in ship design and how designs can be altered to
improve the ship and reduce fatigue. The problem is that it will cost money and
there is not always money available for items that do not appear, at first, to be
beneficial and will improve ship performance.
6B-611 The publication noted at the beginning of subsection 6.5.2 should be consulted.
It contains a lot of information that takes what has been discussed so far onto
the next level.
6B-612 Also, the ship manager should check how they are performing and review the
office space that they work in and the work station where they perform their
duties.
6B-613 There are certain requirements in respect of lighting, temperature, seating,

computer screens and other matters that although each taken separately have
only a minor impact, when taken together can vastly improve work performance.
How are fatigue factors identified in your workplace?
Have you ever suffered from fatigue or chronic fatigue?
Can you remember how it felt?
How would you identify fatigue in others?
6.6 DIGNITY AND RESPECT AT WORK
6.6.1 The Contents of This Section Were Covered in module 6A Volume I

Section 2.3.3 – Behaviours That Can Constitute Harassment
6B-614 It is only by treating others the way that we want to be treated ourselves that we
can truly remove bullying and harassment from the workplace.
6B-615 In most cases, the person inflicting the pain and suffering on another crew
member or office colleague is not even aware that they are doing it.
6B-616 If they do know that they are doing it and continue deliberately to do so, they
should be reported to senior management. No one deserves such abuse.
6B-617 It is the responsibility of everyone to take steps to stop such behaviour if they
observe it.
6.6.2 Effective Communications
6B-618 Open communications where everyone is permitted to have their say goes a
long way to reducing such unacceptable behaviours.

6B-619 Part of the problem can be that there is such a heavy workload and personnel
are stressed out meeting deadlines that it is easy to forget that not everyone
works at the same level or has the same stamina for work.
6B-620 Effective communications have a very important point in that we listen to what
people are saying, not just hearing noises and dismissing them.
6B-621 In addition, when personnel are trying to learn another language for improving
themselves or seeking promotion, never belittle their efforts. Such behaviour will
result in resentment and barriers will be put in place that might never be able to
be removed.
6B-622 Just take a minute to think about how your skills are at their language. Perhaps
they are NIL. So who is right and who is wrong.
6B-623 This is just one example of how ill-timed or ill-intentioned behaviour can have
far-reaching effects.
6B-624 It does not matter if you are on a ship or working in an office there is no extra
workforce and it is dependent on everyone to meet the objectives and targets
set by the company. By marginalising a person or group of persons it makes it
nearly impossible to meet these set objectives and targets.
6B-625 Everyone counts and has something to contribute. Never forget that and never
dismiss out of hand what someone has said. Stop and think about it. Ask
questions for clarification and then take the time to consider the proposal. It may
not be feasible, but having taken the time and then explained to that person what
you have decided and how you came to that decision will go a long way.
Have you ever witnessed discrimination in the workplace?
Was anything done about it?
Did you do anything about it?
It is not easy as in many organisations a person who stands up for someone

else can then be branded a trouble maker.
But is doing nothing really the solution?

7. CONCLUSION
6B-626 As the first volume of this module is completed, delegates will note that it has
raised more questions than it has answered.
6B-627 This is the nature of the industry in which you work or hope to work.
6B-628 Shipping is a multi-faceted industry which is truly international. Some companies

have expanded so much and have offices scattered across the globe that in
effect they have become transnational in their scope and operations. The
likelihood of working in an office or on board a ship where there is only one
nationality is highly unlikely.
6B-629 The one core element that crosses over all parts of shipping is “safety”. This is
essential for ships to operate and for the shore staff to work to a standard
needed.
6B-630 All of the conventions and codes and guidelines issued by the maritime industry
bodies whether they are the IMO, flag state, classification society or other
maritime industry bodies set the minimum standard that has to be achieved, not
the maximum.

LIST OF ABBREVIATIONS
The list of abbreviations used in this module is placed here for quick reference.
List of abbreviations is in alphabetical order.
ABBREVIATION FULL TEXT
alarp as low as reasonably practicable

CDI Chemical Distribution Institute
DP Designated Person(S)
HR Human Resources
ICS International Chamber of Shipping
ILO International Labour Organization
IMO International Maritime Organization
IMSBC Code International Maritime Solid Bulk Cargoes Code
ISF International Shipping Federation
ISGOTT International Safety Guide for Oil Tankers and Terminals
ISM Code International Safety Management Code
ISPS Code International Ship & Port Facility Security Code
ITU International Telecommunications Union
KPI Key Performance Indicator
MOC Major Oil Company
OCIMF Oil Companies International Marine Forum
SI Statutory Instrument
SIRE Ship Inspection Report
SMM Safety Management Manual
SMS Safety Management System
SOLAS International Convention for Safety of Life at Sea, 1974,
and its Protocol of 1988, as amended
STCW International Convention on Standards of Training,
Certification and Watch-keeping for Seafarers, 1978, as
amended
UNCLOS United Nations Convention on the Law of the Sea
VIQ Vessel Inspection Questionnaire
VPQ Vessel Particulars Questionnaire
WHO World Health Organization

RECOMMENDED READING &
USEFUL WEBSITES
The list represented below is for reference to chapters contained within the
course material. The delegate may have found other documents or books, which
have been helpful in completing the course.
TITLE ISBN No.
Guidelines on Fatigue 92-801-5128-2

ISM CODE (2010 Edition) 978-92-801-5151-0
Guide to Maritime Security and the ISPS Code 978-92-801-1544-4

(2012 Edition)
SOLAS 978-92-801-1505-5
STCW Convention and STCW Code 978-92-801-1528-4
Guidelines on the IMO STCW Convention (3rd ----------------------
Edition)
ISGOTT (5th Edition) 1-85609-291-7
USEFUL WEBSITES
International Maritime Organization (IMO) www.imo.org

Maritime and Coastguard Agency (MCA) www.mcga.gov.uk
International Chamber of Shipping (ICS) www.marisec.org
Nautical Institute (NI) www.nautinst.org
International Shipping Federation www.marisec.org

TUTOR-MARKED ASSIGNMENT
DELEGATES, Please Note: This TMA covers both Modules 6A and 6B (Volumes
I and II). Therefore you are able to work on it while studying both modules and
create a full account for marking. The TMA is to be presented once you have
completed Module 6B (Volume II).
You have been head-hunted to take up the position of Operations Manager of a

new company.
This will require you to control the construction of the Company’s Safety
Management System (SMS) to comply with the ISM Code.
The company will be based in the United Kingdom with the office being in
Glasgow, Scotland. It will have the name of Creative Shipping Solutions Limited
(CSS Ltd).
The company has been tasked with conducting the operational, technical and
crewing requirements for all ships.
It will operate a fleet of 10 ships. The fleet will consist of 5 × ULCCs of 310,000
dwt, all registered in Cyprus and classed by Det Norske Veritas and 5 × Cape
Size bulk carriers of 195,000 dwt, all registered in Liberia and classed by
American Bureau of Shipping.
It has been decided that crewing of all ships will be:
Senior Officers British
Junior Officers Bulgarian
Crew Filipino
The working language of the company will be ENGLISH.
The following questions require you to construct and present solutions.
Question 1.
Part A
Construct a list of the job titles you would expect to create to cover the manning
requirements of the office in Glasgow.
Part B
From the list of job titles construct a flow diagram showing the hierarchy and
relationships between the job titles.
(Remember that there is limited finance to pay for shore positions and that you
need to anticipate the amount of floor space that would be required to house
personnel. This is a limited company and needs to make a profit to continue to
trade.)

Module 6B Tutor-Marked Assignment
Question 2.
Part A
The company requires that all preparations are made for third-party inspections
taking place.
You are required to identify the various inspections/audits/surveys that will be

conducted and construct a format for ensuring that the observations or
deficiencies or conditions of class are collated to ensure that trends are identified
and that coordinated action can be taken to resolve them.
Part B
The Maritime Labour Convention deals with the seafarers employed on board
your vessels.
What actions would you expect the company to take, under your direction, to
ensure that the rights of the seafarers and the conditions in which they work and
live are fulfilled?
Guidance Notes for Completion:
For candidates taking the Diploma option, a Tutor-Marked Assignment must be

completed for each core module. There is a minimum pass mark for each
assignment and candidates will be expected to reach this minimum standard.
Collectively, the assignments represent a possible one-third of the candidate’s
final mark.
On the cover page of your assignment, could you please include the
following information:
• Your name
• Course Name – Ship Management
• Course Code – FLP2233
Order Number (the number quoted on your enrolment confirmation letter)

Tutor-Marked Assignment Module 6B
To speed the processing of assignments, please return your typed assignment

by post, fax or email directly to the TMA Administrator:
Post: Mrs Parmjit Gill

TMA Administrator
The School of Maritime Operations and Logistics
North West Kent College
Lower Higham Road
Gravesend
Kent
DA12 2JJ
United Kingdom
Tel: +44 (0)1322 629684
Fax: +44 (0)1322 629667
Email: mol@nwkcollege.ac.uk
Remember to keep a copy of your completed assignment in case of loss in the

post. Please also state if you would like confirmation of receipt of your
assignment. If so, you must include your email address, as confirmation by post
or fax is not possible.
Emailing assignments will only be accepted if they are sent as attachments to

the email message.
You should attempt to complete each assignment within four weeks of receipt of
the module.
In order to be able to sit the exam, at least 50% of the assignments must be
submitted three months before the exam and 100% of assignments must be
submitted one month prior to the exam.
Please see your Course Handbook for full details.

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DIPLOMA IN

Captain John W. Dickie BA MNI

2. THE ISM CODE AND THE MANAGER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

2.1 Understanding the ISM Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

3. THE ISPS CODE AND THE MANAGER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

3.1 Understanding the ISPS Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .37

Diploma in Ship Management 2012 / 2013 (FLP2233) 6B-1

3.5 Audits and Certification. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .59

4. PORT STATE CONTROL AND THE MANAGER . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

4.1 Inspections and Degree of Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

5. THE ENVIRONMENT AND SHIPPING: MINIMISING THE IMPACT . . . . . . . . . . . . 92

5.1 ISO 14000: Environmental Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92

6B-2 Diploma in Ship Management 2012 / 2013 (FLP2233)

6. HEALTH AND SAFETY AND THE COMPANY:

6.1 Health Surveillance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .104

LIST OF ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 130

Diploma in Ship Management 2012 / 2013 (FLP2233) 6B-3

RECOMMENDED READING & USEFUL WEBSITES . . . . . . . . . . . . . . . . . . . . . . 131

TUTOR-MARKED ASSIGNMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 132

APPENDIX 1 – PORT STATE CONTROL CODES FOR

APPENDIX 2A – PORT STATE CONTROL CONCENTRATED

APPENDIX 2B – PORT STATE CONTROL CONCENTRATED

APPENDIX 2C – PORT STATE CONTROL CONCENTRATED

• Self-Assessment Questions have been provided periodically

• For candidates taking the Diploma option, your Tutor-Marked

© Copyright IIR Limited 2012. All rights reserved.

6B-4 Diploma in Ship Management 2012 / 2013 (FLP2233)

The Self-Assessment Questions are important to each delegate as it gives you

Diploma in Ship Management 2012 / 2013 (FLP2233) 6B-5

Roman Equas (Knight)

At the Court of the Emperor Nero

6B-6 Diploma in Ship Management 2012 / 2013 (FLP2233)

After successfully completing this chapter, you will:

• Have a better understanding of the ISM Code and its

• Have a better understanding of an organisation’s Safety

• Understand the importance of Audit Schedule and Compliance.

• Understand the effect of a multi-national fleet on constructing a

2.1 UNDERSTANDING THE ISM CODE

2.1.1 The Evolution of the ISM Code

Diploma in Ship Management 2012 / 2013 (FLP2233) 6B-7

Chapter I – General Provisions

Part A – Application, definitions, etc

a) Unless expressly provided otherwise, the present regulations apply

Chapter IX – Management for the Safe Operation of Ships

1 This chapter applies to ships, regardless of the date of construction, as

.1 passenger ships including passenger high-speed, not later than 1

6B-8 Diploma in Ship Management 2012 / 2013 (FLP2233)

2 This chapter does not apply to government-operated ships used for

The requirements of this Code may be applied to all ships.

2. Ships of less than convention size as stated above in SOLAS, IX Reg. 2

4. SOLAS – Chapter I Part A – Regulation 3 Exceptions

a) The present regulations, unless expressly provided otherwise, do not

i) Ships of war and troopships

ii) Cargo ships of less than 500 gross tonnage

iii) Ships not propelled by mechanical means

iv) Wooden ships of primitive build

v) Pleasure yachts not engaged in trade

vi) Fishing vessels

Diploma in Ship Management 2012 / 2013 (FLP2233) 6B-9

2.1.4 The Contents of SOLAS IX and the ISM Code

Regulation 3 Safety Management Requirements

Regulation 5 Maintenance of Conditions

Regulation 6 Verification and Control

1.4 Functional requirements for a Safety Management