Managing ship safety By CDR Marvin Pontiff Increasing the level of marine safety by promoting sound ship management principles is an important goal of the Coast Guard Marine Inspection Program. The ship safety management concept, previously referred to as "incentive inspection" or "model company" efforts, has been an informal topic of conversation at various industry conferences for some time. Still in the conceptual stages, the application of ship safety management as a tool to improve the use of Coast Guard marine inspection resources is still being explored. Relying on such principles shifts more responsibility for safe ship operation to the vessel operator. Five safety nets The marine safety system can be viewed as a series of five "safety nets" surrounding a commercial vessel's operation to protect a ship, its passengers, crew and cargo. At the center, the first net is the vessel master and officers. They are directly charged with the awesome responsibility for the vessel's safe operation. The second net consists of the owner, operator and, specifically, the management company that is concerned with the day-to-day operation of the vessel. They are required to ensure that safety and maintenance measures are carried out, balancing business concerns with preventing the loss of ships and cargo. The third net is the classification society which attests to the appropriate construction of the ship for its route and service. The society coordinates with the insurance underwriters to back up the owners. Since shipping is performed in the market place, the government is responsible for ensuring the level of safety expected by the public. The flag administration, the fourth net, registers vessels and certifies their compliance with safety standards, such as the International Convention for the Safety of Life at Sea (SOLAS). The fifth net is the port state, in whose waters a vessel trades. The port state boards the vessel to verify compliance with applicable standards for ship safety and pollution prevention. Continued on page 10 Continued from page 9 Together these successive safety layers endeavor to protect life and property at sea, and the marine environment. Coast Guard role Whether the Coast Guard is in the role of flag administration or port state, the Marine Inspection Program is applied in the same manner to all vessels within specific categories of service, depending on their routes and sizes. Regulations are developed through the public rulemaking process and published in the Federal Register as the Code of Federal Regulations (CFR). The Coast Guard's objective is to enforce these regulations fairly and evenly. Clearly, some companies are managed better than others, and are easily recognized by their histories of safe, responsible operations. When safety management principles are carried out, the Coast Guard could recognize responsible companies by reducing its activities on board their vessels. The Coast Guard could then target resources to identify and discourage "bad actors" and encourage improved safety performance. Wider acceptance of safety management principles provides the Coast Guard with the flexibility to direct resources where they are needed the most at any given time. As high as the Coast Guard's interest is in a safe management enforcement program, it will not proceed without careful study and consultation with industry representatives. What is envisioned is an inspection and certification process which would be simplified for companies which promote and actively administer safety management principles. Conversely, inspections of vessels operated by companies not subscribing to safe ship management principles would be longer and more exacting in detail. This fairly new concept needs further development, but it is a worthwhile goal considering today's limitations on public resources and the general movement in the industry toward quality management. IMO initiatives Recently, the IMO has focused attention on the role of the human element in maritime safety, and the establishment of guidelines for universal shipboard safety management. IMO Resolution A.647(16), revised by Resolution A.680(17), entitled "IMO Guidelines on Management for the Safe Operation of Ships and for Pollution Prevention," addressed these subjects. At the IMO Maritime Safety Committee's 60th session in April 1992, a joint working group met to develop a draft international code for the safe management and operation of ships. Norway, taking the role of "lead country" in developing the code, presented a rough draft version to the group for discussion and comment. The Coast Guard, the United States representative, participated in the discussions and submitted comments. The new IMO code would provide guidelines for the development of a "safety management system" on each vessel to which it applies. The system would be carried out appropriately and documented. It would define the operating company's safety and environmental policy, describe the organizational structure, clearly identify levels of authority and responsibility for those individuals who work in safety and pollution prevention areas, and delineate procedures for internal audits and management reviews. It would also contain procedures for reporting system breakdowns and accidents. The final time frame for adopting this code depends upon further deliberations at the 61st session of the Marine Safety Committee scheduled for December 1992. Here decisions will be made as to which ships it will apply, whether it will be mandatory or voluntary, and whether it will be made part of the present SOLAS convention or become a separate convention. Conclusion The Coast Guard actively supports this initiative. A clear recognition of the roles and responsibilities of management and classification societies in the safe operation and maintenance of merchant vessels is a vital element in the development of any such safety management program. By incorporating the use of shipboard management principles into its inspection program, the Coast Guard will more accurately focus public resources in the areas of the marine industry that require the most attention. CDR Marvin Pontiff is chief of the Compliance and Enforcement Branch of the Merchant Vessel Inspection and Documentation Division. Telephone: (202) 267-1464. By Ms. Teresa O. Preston Improvements in the inspection of ships in the Ready Reserve Force (RRF), a component of the National Defense Reserve Fleet, were recently set in motion by an important interagency agreement. On March 25, 1992, RADM A. E. "Gene" Henn, chief of the Coast Guard's Office of Marine Safety, Security and Environmental Protection, and Mr. Harlan T. Haller, associate administrator for MARAD's Office of Shipbuilding and Ship Operations, signed a memorandum of understanding for Coast Guard RRF inspection. This memorandum between two Department of Transportation agencies constitutes a major revision of their previous agreement signed in 1989, before the experiences of Operation Desert Shield and Desert Storm. The new agreement incorporates improvements suggested by Coast Guard and MARAD studies of RRF ship activation inspections during that conflict. Background Started in 1976, the RRF was designed to support a rapid deployment of United States military forces. It is programmed for quick response beyond that which is possible for commercial ships or older, less preserved vessels of the National Defense Reserve Fleet. Soon after the RRF was established, the need for an understanding between the Coast Guard and MARAD regarding vessel inspections became apparent. The unique practice of keeping ships in a deactivated condition while maintaining a rapid response capability required that different inspection criteria than that earmarked for commercial ships should apply. Commercial ship inspections and their timetables are geared toward active trading vessels, where all ship systems are operational and scheduling of inspections can be arranged well in advance. Since RRF ships are deactivated during normal inspection intervals, and require rapid response when activated, such inspection timetables need to be altered. In response to the unique RRF inspection needs, the first memorandum of understanding was signed in 1977. This document allowed for deactivated ship inspections and delayed testing operational systems, usually until a vessel's activation. Since that time, the make up of the RRF and Coast Guard inspection requirements have changed, requiring revisions of the memorandum of understanding on several occasions. Beginning in August 1990, 79 of the 96 ships in the RRF were called up to carry national defense cargo for Operation Desert Shield/Desert Continued on page 12 New memorandum The new memorandum incorporates procedures to streamline safety inspections of deactivated RRF vessels and establishes clearer lines of communication between the Coast Guard and MARAD. One major innovation is a requirement to operationally test all RRF ships every two to three years to retain valid Certificates of Inspection. Other significant changes are in the areas of command, control and communication, and the correction of material deficiencies while vessels are in a deactivated state. Command - control - communication Procedures were added to improve coordination and communication between various levels of the Coast Guard and MARAD, and ship managers. The new procedures directly address lessons learned from inspections of the RRF during the Persian Gulf operations. Early and frequent contact between all involved parties is absolutely essential. There are many parties involved in the complex process of acquiring, deactivating, maintaining and activating an RRF ship. Ship operators, shipyards, Coast Guard inspectors, marine surveyors, port engineers, ships officers and crew, and others help maintain RRF-ship readiness for the mission of transporting national defense cargoes. The new memorandum provides a reference guide, defining roles and responsibilities of the two agencies in RRF ship inspections. Also, the agreement encourages employees of both agencies to meet regularly to discuss problems. Such advance preparation is intended to build a team approach to problem solving that will minimize confusion during RRF ship activations. Operational testing A concerted effort will be made to test, inspect and correct material deficiencies on RRF vessels during maintenance. Under the previous agreement, such tests and necessary repairs could be deferred until a vessel needed to be activated. Testing and repairing the vessels more frequently will reduce delays during activations. Conclusion Now that the new memorandum of understanding is signed, a working group is preparing a presentation for both MARAD and Coast Guard field personnel to brief all individuals involved in maintenance and inspection of RRF ships on the new requirements. These briefing sessions will provide opportunities for personnel from both agencies to openly discuss any effects the memorandum may have on their operations, and to work out any differences they might have. To make this memorandum meaningful, both Coast Guard and MARAD personnel will continue to look for better ways to maintain safe, reliable RRF ships. The hard work and commitment of everyone involved in the two agencies will be needed to make this vision a reality. The new agreement is a visible sign of that commitment and represents another significant team effort within the Department of Transportation. Ms. Teresa O. Preston is a ship operations analyst in the Division of Ship Maintenance and Repair of MARAD's Office of Ship Operations. Telephone: (202) 366-2049. In the shipping industry, the old axiom, "time is money," is the bottom line. Murphy's law will ensure that the most important or most expensive piece of gear will fail when you can least afford it. Therefore, your maintenance program should cover everything -- all machinery, lifesaving and fire-fighting equipment, electronics and electrical equipment, necessary publications -- and anything else you spend money on for your vessel. The ideal maintenance program starts with the naval architect in the design stages of your vessel. If you are not that fortunate or if you just took over M/V Disaster, get a copy of the regulations (regs) covering your vessel class and read what the Coast Guard considers minimum operating standards. Of course, these standards By LCDR Scott E. Hartley depend on the size of your vessel, how many passengers or what cargo you carry, route restrictions and other criteria. Study the regs When you sit down to plow through the regs, keep your vessel's Certificate of Inspection handy for quick reference. The regs are divided into subchapters corresponding to different vessel classes. The subchapters are relatively easy to follow with indexes for quick reference. Subchapter C -- uninspected vessels The Coast Guard does not conduct annual inspections on these vessels, which include inland tugs, fishing boats and push boats. However, if your vessel is involved in an accident or pollution spill, the Coast Guard may inspect your vessel while conducting an investigation. |