NOR Shipping
ISM the Tanker Owners Perspective
Howard Snaith
Marine & Chemical Director
INTERTANKO
Views from the
INTERTANKO Vetting
Committee
What is ISM?
Does ISM Really Work Today?
Are We Doing It Right?
For the quality owner/manager “YES”
is the answer.
Because they were doing it right before ISM.
ISM has simply formalised their operating
procedures
But what about the sub-standard operator?
Raises the question is ISM correctly implemented
across the whole industry?
One of our membership criteria requires the owner
to not only have an ISM system but an
IMPLEMENTED ISM system
The Paris MoU & Tokyo MoU have just published
reports recently
The Media may be surprised at the results!
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
Port State Control
Percentage of inspected ships detained
14%
14%
Tankers
12%
12%
All ships
10%
10%
8%
8%
6%
6%
4%
4%
2%
2%
0%
0%
1997
1998
1999
2000
2001
2002 est.
Port State Control detentions - 2002
1,800
1,600
1,576
1,437
All ships
1,400
Tankers
Number
1,200
1,000
800
600
400
200
166
178
15
125
0
Tokyo MoU
USCG
Paris MoU
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
We believe it noteworthy that ONLY 1.9%
were INTERTANKO members' tankers
ISM was quoted as the reason for the detention in
only 0.18% of INTERTANKO detentions
Conclusion
ISM works in the INTERTANKO fleet
Can we improve more?
We can always improve and this is in the sprit of the ISM code
Auditing could be made more stringent to weed out the
substandard operator.
ISM is made by humans and its implementation is done by them
The 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 enhanced
It 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
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.
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
What does ISM mean to a tanker operator today?
It is the new minimum standard.
Everybody has it - good and sub standard.
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.
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.
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.
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?
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 don’t 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.
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
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?
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 substandard 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 substandard 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
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