USCG - NAVIGATION AND VESSEL INSPECTION CIRCULAR NO.

04-05 Port State Control Guidelines for the enforcement of management for the safe operation of ships (ISM code) Purpose: This navigation and vessel inspection circular provides guidance for US Coast Guard sector commanders, Captains of the port, officers in charge, marine inspections and port state control officers concerning enforcement of and compliance with the ISM code. Please find below USCG ISM Compliance Tool which has been brought to a more user-friendly format. We have tried to provide some references to assist you. Most of you are well aware about our system but some of your colleagues are new with CSM and maybe not yet completely familiar with the system and may appreciate the reference section. USCG did not provide an all inclusive list of questions and they do not want to create the kind of checklist mentality where the PSCO sticks strictly with the list and checks his or her brain at the gangway. In this area, the NVIC also reminds PSC inspectors and other personnel as follows, "If it appears the Master has a good grasp of the program, move along and do not belabor the process".

ISM Compliance Assessment Tool ISM Code Reference 1.1.11 1.1.11 1.4 4 5 6 Description of Non Conformity (NC) Are deficiencies present that pose a serious threat to personnel, the ship, or serious risk to the environment, and require immediate corrective action Is there a apparent lack of effective and systematic implementation of a requirement of the ISM code The adherence to the ships approved, self developed Safety Management System? The responsiveness of the companys DPA to the ship non-conformity reporting and assistance/corrective action? The Masters defined responsibilities, authority, and his performance of those responsibilities? Critical crewmembers knowledge and familiarity with the ship specific SMS Are the SMS-specified reporting and documentation procedures being followed? (Note: this is a broad, catch-all topic. Use judiciously when hard documentation of NCs posing serious threat are apparent due to lack of adherence to the reporting and documentation requirements throughout the code. Cite the specific code ref. for the evidence discovered.) Do the maintenance procedures for the ship systems Guidance

Shipboard Quality Manual QM010/ORG.02

1, 4, 7, 8, 9, 10, 11, 12

OPS Manual QM011/MTE.01

identified in the SMS, include frequency, scope and supported by the PMS documentation for the maintenance and necessary OPS Manual for Tankers corrective action(s)? QM013/MTE. Does the overall performance of the crew indicate that 6 they have been trained to perform their assigned tasks in accordance with the training needs identified in the SMS? Familiarity with the code is critical to the identification of specific SMS breakdowns. The PSCO must document on the boarding report (Form B) those items suspected to the ISM-related deficiencies, citing the ISM code element(s) associated with the non-conformity (deficiency). The throughness of the explained non-conformity will play an essential role in the external audit, enabling the auditor for RO to focus on the non-conformities identified by the PSCO as the impetus for the external audit. Captain, who is your designated person ashore? OPS Manual QM011/MAN.03 + 4 Are you in regular contact with this person? OPS Manual QM011/SAQ.13 DPA How do you contact this person? OPS Manual QM011/SAQ.13 Captain, may I please see your SMS manual? Can you explain the companys Quality and Safety Shipboard Quality Manual Policy in your own words? QM010/PLY.01+02 5 Did you receive training for your SMS duties prior PLEASE SEE COMMENT BELOW taking over command? *1* Masters How often are you required to conduct a masters Once a year at the end of review of the SMS? January. Respons. Can you show me the procedures for this review and OPS Manual QM011/SAQ.01 documentation of your last review? How often is the company required to conduct an Every 12 months internal audit? Can you show me the procedures for internal audits OPS MAUAL QM001/SAQ.04 and documentation for the last internal audit? Captain, can you show me the procedures for change OPS Manual QM011/PER.04 of command? Do you have documentation of this SM322 323 344 / Logbook activity? 6 Captain, are you required to familiarize new joining OPS Manual QM011/PER.03 crew with there duties when they join the ship? Can Onboard Familiarization Form you show me the procedures and documentation of SQ610 this activity? Resources Captain, may I interview your crew? And Personnel Questions for the Chief Officer Did you receive training in your SMS duties by the company prior to reporting onboard the ship? Do you have documentation of this activity? What certificate indicates the types of cargo this ship may load? What publication would assist you in knowing the proper handling procedures for these cargoes Can you show me the procedures for drafting a stowage plan? Can you explain the ships stability calculations? What shipboard manual would assist you in developing these calculations? Please refer to *1* if you do not have a documentary evidence. IOPP, Certificate of Fitness, Certificate of Compliance, Carriage of Grain BCH Code, ISGOTT, IMDG code etc Dry Cargo OPS Manual QM011/Part B/CAR.03 Tanker QM013/TOP.01 QM011/TEM.07 Cargo Securing Manual Stability & Trim Booklet

10

Can you show me the procedures in your SMS for making a tank safe for entry? Can I see the documentation for the last such tank entry. What are the requirements for the use of PPE in your SMS? Can you show me the procedures in your manual? Questions for the Second Mate Second, did you receive training in your SMS duties prior to assuming them onboard the ship? Are you responsible for voyage planning? Can you show me the procedures in your SMS for drafting a voyage plan? Can you show me the most recent voyage plan? Are you responsible for chart corrections? Can you show me the documentation of this activity? Can you show me the procedures for making the ship ready to get underway? Can you show me documentation of this activity? What nautical publications are you required to maintain onboard the ship? Questions for the Chief Engineer Chief, did you receive training in your SMS duties from the company prior to assuming them onboard? Do you have documentation of that training? Can you show me the procedures for reporting damage to machinery and associated systems in your SMS? Can you show me your last damage reports? What equipment onboard is critical equipment in your SMS? Can you show me the procedures for performing preventive maintenance in your SMS. Can you show me when the last PM was done to the OWS (or any other identified critical piece of equipment)? Chief, does your SMS require you to issue night orders? May I see your last set of night orders?

QM011/SWO.03 Enclosed Space Entry permit Training Manual

Safe Navigation Manual A5.4 / D.04 SNM A5.3 / BB04 / D01 Chart SNM A7.8 / SNM C15-18 SNM A5.2

Refer to *1* OPS QM011/MTE.05 OPS QM011/OPE.04 Handling Defects OPS QM011/MTE.09 General Circular 68 25.06.2003 OPS QM011/MTE.01 PMS

OPS QM011/TEM.02

NOTE: At this point in the expanded exam, the PSCO should have a clear idea of the senior officers knowledge and complicity with SMS requirements. The following questions deal more specifically with the deficiencies identified during the boarding. Captain, what is the definition of a non-conformity in your SMS? 9 NCs Can you give me some examples of issues you would raise a non-conformity? Are damages to equipment and ship structure Main Quality Manual QM010/Gen.06 OPS Manual QM011/SAQ.03 3.1 No. We are classifying them as

considered non-conformities in your system? Accidents And Hazard. Occurren. Who is authorized to raise a non-conformity in your SMS? Can you show me the procedures for reporting nonconformities to the company? I see here in your procedures that several of the deficiencies I have noted are considered nonconformities in your SMS. Can you show me documentation on reporting these deficiencies to your company in accordance with your SSM procedures? Captain, may I interview your Chief (Mate/Engineer based on the department with deficiencies)? Chief Mate, could you show me your maintenance procedures related to maintaining compliance with your Load Line Certificate? Chief mate, I see here your maintenance procedure requires inspection of the cargo hold hatch covers, coamings and holds prior to loading, do you have documentation of this activity? Captain, can you explain to me how your company maintains control of SMS documents? Can you show me the list of controlled documents I see here on your control list a damage report form. Can you show this form in your SMS? How are obsolete documents disposed of?

above. Non-fulfillment of a requirement. The Master OPS QM011/SAQ.11 Internal/External Auditors SAQ.04

10 MTE

OPS QM011PartB/MTE.01 OPS QM011PartA/MTE.01

Main Quality Manual QM010/DOC.07 OPS Manual QM011/DOC.01

Main Quality Manual QM010/DOC.10

*1*

Although the new Masters passing through our office do receive such a certificate, our guys around from 1996 have not. That is like asking Jesus for his baptism certificate from John the Baptist. We have however contacted USCG for clarification and have been informed as follows: Please note this question is just one angle through which to get at the Master's knowledge in this area. I think a good answer to the question could be, "I am fully conversant in the ship's safety management system" and through a few follow up questions or information volunteered by the Master, the Master can show that he or she is fully conversant with the Company's SMS.