NOR Shipping ISM the Tanker Owners Perspective Howard Snaith Marine

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NOR ShippingISM the Tanker Owners
PerspectiveHoward Snaith
Marine Chemical Director INTERTANKO
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Views from the INTERTANKO Vetting
Committee
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What is ISM?
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Does ISM Really Work Today?
Are We Doing It Right?
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For the quality owner/manager - YES is the
answer.
Because they were doing it right before ISM. ISM
has simply formalised their operating procedures
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But what about the sub-standard operator?
Raises the question is ISM correctly implemented
across the whole industry?
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One of our membership criteria requires the owner
to not only have an ISM system but an IMPLEMENTED
ISM system
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The Paris MoU Tokyo MoU have just published
reports recently
The Media may be surprised at the results!
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• BUT we are not. Because what we have known all
  along is-

The Tanker Owner is shown as the best operator
from all ship types
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A total of 3191 ships of all ship types were
detained during 2002(By the Tokyo MoU, Paris MoU
USCG)However, only 9.5 were Tankers
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We believe it noteworthy that ONLY 1.9 were
INTERTANKO members' tankersISM was quoted as
the reason for the detention in only 0.18 of
INTERTANKO detentions
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Conclusion ISM works in the INTERTANKO fleet
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Can we improve more?We can always improve and
this is in the sprit of the ISM codeAuditing
could be made more stringent to weed out the
substandard operator. ISM is made by humans and
its implementation is done by themThe system
draws to our attention its failures, not its
successes.These failures are brought to the
attention of others via casualty reports, Non
Conformities and Near Misses, the system is then
improved and safety enhancedIt is therefore the
failures in the system that strengthen it and
makes it work.The key element that keeps ISM up
to date and alive is the continual improvement
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Has it improved and raised standards in the
tanker industry? Judging by some press reports
regarding various measures being adopted
worldwide, to try and rid the world of
substandard tankers - one would think not.
However, PSC and ship vetting have probably
done more to raise standards than ISM.
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Do we pay lip service to ISM or does it fulfil
its intentions? The Quality owner/manager uses
ISM as a tool to improve safety of operations as
the system was intended to do. But there remain
those on the fringe who do pay lip service to ISM
PSC has a positive effect and is the final
safety net. However, this is not how it should
be. Flag and Class need to do more to ensure
correct implementation across the world fleet
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What does ISM mean to a tanker operator today?
It is the new minimum standard. Everybody has
it - good and sub standard.
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• If the quality operator is to differentiate
  himself from the rest of the pack then he must do
  more than ISM. Unfortunately the market does
  not always want to pay more for that higher
  standard.

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Text for slides
Slide 1 Good morning Ladies Gentlemen, thank
you for the opportunity to be able to come here
today and speak on this very interesting topic. I
have been involved with ISM for some years now
and also directly involved with its
implementation onboard when it was in its early
days. I therefore came to know very quickly the
difficulties that needed to be overcome when ISM
was first introduced at sea.     Slide 2 However
one of the roles that I have at INTERTANKO is to
act as secretary to the INTERTANKO Vetting
Committee, a body of about 20 INTERTANKO members
that work closely with the many aspects of ship
inspections including, Port State Control,
Commercial vetting inspections, EQUASIS, the
CDI/SIRE systems, Detentions, Appeal procedures
and ISM issues. Therefore when I was preparing
this paper I thought what better than to seek the
views of our Vetting committee members when
compiling the The Tanker Owners Perspective I
have therefore collated the views from this
committee which are the views or senior people
working closely with ISM on tankers on a daily
basis.
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Text for slides
Slide 3 But what is ISM? It is stated that the
ISM code is to improve safety at sea, prevent
human injury or loss of life, and avoid damage to
the marine environment and property. But the fear
is that the full implementation of a living
breathing working safety management system has
only partially been achieved and if the ship
owner does NOT make it work as intended then
governments will introduce another layer of
inspections and stricter regimes. The Code
requires a safety management system (SMS) to be
established by "the Company", which is defined as
the shipowner or any person who has assumed
responsibility for operating the ship. The SMS
sets out the procedures by which the safety and
pollution prevention aspects of a ship are
managed, both ashore and on board. The Company
should be able to follow the set procedures to
check that it complies, and continues to comply,
with the various rules and regulation, e.g. the
Load Line Regulations, MARPOL, STCW, other
chapters of SOLAS, etc. The Company is required
to provide the necessary resources and
shore-based support to implement the SMS. The
Company is also expected to designate a person or
persons ashore (DPA) having direct access to the
highest level of management to ensure the safe
operation of each ship and to provide a link
between the Company and those on board. The
Administration (the State whose flag the ship is
entitled to fly) or the organisation(s)
recognised by the Administration is responsible
for verifying compliance with the requirements of
the ISM Code and for issuing the appropriate
certificates.
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Text for slides
Slide 3 cont A Document of Compliance (DOC)
will be issued by the Administration or
recognised organisation(s) after having verified
that the Company has properly developed and
implemented a SMS which complies with the ISM
Code. The Company must produce objective evidence
to show that the SMS has been in operation for at
least three months on board at least one ship of
each type operated by the Company. A Safety
Management Certificate (SMC) will be issued by
the Administration or recognised organisation(s)
to each ship operated by the Company after an
initial verification of compliance by way of an
external audit on board the particular ship.
The DOC has a validity of five years, subject
to annual verification to check that the SMS is
still functioning properly. The SMC also has a
validity of five years but, unlike the DOC,
requires at least one intermediate verification
within the validity period Slide 4 So the big
question remains, - Does ISM really work today?
And are we doing it right?
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Text for slides
Slide 5 If we look at the Quality Owner/Manager
then the answer is yes they are doing it right
and Yes it does work. Why is that? because
these guys were doing it right before ISM was
implemented. The introduction of ISM to them has
simply formalised what they did anyway.   Slide
6 So we dont need to worry about the quality
owner, but what about the sub-standard operator?
Is he doing it right? Does it work for him?
Before ISM became mandatory for tankers several
fears were raised that not all tanker operators
would have the ISM code implemented in time.
However, as far as we are aware all met the
deadlines. Sub-standard operators do exist, so
the question is is ISM correctly implemented
across the while industry, are all of the
existing certified ISM systems living, breathing
working systems, i.e fully implemented? It is of
course questionable if this is the case. Slide 7
INTERTANKO has several membership criteria, one
of these was that all our members should have an
ISM system. In the days before this was mandatory
in the tanker industry this was a very strong
statement indeed, however now ISM is a mandatory
requirement we decided to re-assess this.
Therefore, with regards to this particular
criterion what we now say is that not only will
all our members have an ISM system but that they
will have an IMPLEMENTED ISM system.
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Text for slides
Slide 8 One other area where we have monitored
our members for some time now is by reviewing and
assessing detentions. The Paris MoU and Tokyo MoU
have recently published their reports. As always,
these are very interesting, but they are also
very useful as a tool for assessment and problem
identification. We think the media may be
surprised by some of the data that can be drawn
from these reports,   Slide 9 However,
INTERTANKO is NOT surprised because this is what
we have known all along, THE TANKER OWNER IS
SHOWN AS THE BEST OPERATOR FROM ALL SHIP
TYPES.   Slide 10 We can see that although the
percentage of inspected ships that have been
detained have reduced since 1997 the percentage
of inspected tankers that have been detained has
always been considerably less
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Text for slides
Slide 11 This slide breaks down the detentions in
to MoU regions, for example we can see that the
Tokyo MoU detained 1437 ships in 2002 but only
166 tankers. The United States Coastguard
detained 178 ships but only 15 tankers, and The
Paris MoU detained 1576 ships but only 125
tankers.   Slide 12 A total of 3191 ships of all
types were detained during 2002 by the Tokyo MoU,
Paris MoU and USCG. But of all these ships only
9.5 were tankers!   Slide 13 But we what we
believe is very noteworthy from this is when we
look at the INTERTANKO membership is the fact
that of these 3191 detained ships ONLY 1.9 were
INTERTANKO tankers   Slide 14 Now if we look at
the reasons given for these detentions what is
also we can see that ISM was the given reason for
the detention in only 0.18 of the cases within
INTERTANKO.   So what can we conclude by
this?        
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Text for slides
Slide 15 The Conclusion is that ISM works in the
INTERTANKO Fleet    Slide 16 We may still ask the
question though, can we improve, and of course we
can always improve, this is embedded into the ISM
code, auditing could be made more stringent to
weed out the sub-standard operator, but it must
be remembered that ISM is made by humans and it
is implemented by humans, the system is designed
such that it draws our attention to its failures
rather than its successes. These failures are
then brought to the attention of others via
casualty reports, Non conformities and near miss
reports. By virtue of this the system is improved
and safety enhanced.   It is therefore the
failures in the system that strengthens it and
makes it work.   The key element that makes ISM a
working living breathing form is continual
improvement.   Slide 17 But has ISM improved and
raised standards in the tanker industry? If we
look at some of the press reports regarding
various measures being adopted worldwide to try
and rid the world of the sub-standard tankers one
would think not. But in essence it is probably
PSC and Tanker vetting that have done more to
raise standards more than ISM
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Text for slides
Slide 18 But the quality owner/manager will use
and does use ISM as a tool to improve the safety
of operations as intended by the system. But
there remain some who operate on the fringe and
only pay lip service to ISM.   Port State Control
does has a positive effect and is the ultimate
final safety net, but should it really be
necessary for PSC to have to do this? Flag and
Class need to do more to ensure the correct
implementation of ISM across the worlds
fleet   Slide 19 So exactly what does ISM mean to
the tanker operator today?   It is the new
minimum standard, every body has it the quality
operator and the sub-standard vessel   Slide 20
So if the quality operator is to differentiate
himself from the rest of the pack then he needs
to do more than ISM -         unfortunately the
market is not always prepared to pay for that
higher standard.   Slide 21 Thank you very much