Purpose

To ensure ISM, ISPS and MLC procedures are implemented on board and ashore and that shipboard and shore management activities comply with rules and regulations.

Procedure

1. General
The auditor should hold a certificate of training issued by competent authority (Classification Society, Maritime Administration of recognised Training Centre) or have knowledge and expertise sufficient to plan and conduct combined ISM, ISPS, MLC audits.

2. Internal Audits
Internal audits will be carried out on board and ashore at intervals not exceeding twelve (12) months. In exceptional circumstances, this interval for shipboard audits may be exceeded by not more than three (3) months, provided that flag administration has been notified. The exceptional circumstance will be recorded and the next internal audit will be due one year from the date of the missed internal audit.

For ISM, MLC and ISPS audits, a specific audit checklist should be used to facilitate the sampling process.

The scope, plan/schedule and results of the audit should be recorded on form DP-0102 Internal Audit Report, covering ISM, MLC, ISO and ISPS topics.

All findings and related actions shall be properly documented and recorded on forms DP-0103 Internal ISM, MLC & ISO NCR/OBS Report and/or DP-0103a Internal ISPS NCR/OBS Report or similar document issued by external auditors should be used for this purpose.
3. External Audits
Harmonised ISM, ISPS and MLC audits will be arranged with the flag Administration or Recognised Organisation (RO). The initial, annual, intermediate, and renewal audits will be performed in the auditing window required by the regulations.

4. Follow up and analysis
The results of the audits should be brought to the attention of all personnel having responsibility in area involved.
Where deficiencies have been identified during internal and external audits, the DPA/CSO or the person designated by the DPA/CSO shall analyse the root causes and ensure that appropriate and timely corrective actions have been implemented.
Follow up actions should be tracked in the Corrective Action Tracker (form DP-0107). Completed Non-Conformities/Observations should be closed with applicable closing comments sent to the ship. Evidence (if required) of implemented corrective actions should be saved in dedicated folders on board and ashore.
During the next internal audit, the deficiencies raised during previous internal and external audits will be verified.

Related Documents/Forms

• DP-0101 Implemetation Plan
• DP-0102 Internal Audit Report – covers ISM, ISPS, MLC, ISO audits (as required)
• DP-0103 Internal ISM, MLC & ISO NCR-OBS Report
• DP-0103a Internal ISPS NCR-OBS Report
• DP-0104 Vessel ISM Audit Checklist
• DP-0105 Vessel ISPS Audit Checklist
• DP-0106 Vessel MLC Internal Audit Checklist
• DP-0107 Corrective Action Tracker

Purpose

To review PSC/Flag State inspection reports in order to improve the System.

Procedure

All PSC/Flag State inspection reports will be reviewed and suitable corrective and preventive actions will be proposed and implemented.
If suitable, results will be circulated.

Related Documents/Forms

• Accident/Hazardous Occurrence Reports
• Deficiency Reports (Ship/Class/Flag/PCS)
• Masters Review
• SSP Review

Purpose

To ensure an continuously effective System.

To ensure that the changes are effectively managed and mitigate risks associated with a change.

Procedure

All results of internal/external audits, PSC inspections, Management Reviews and others will be reviewed for any necessary changes to the system.
If applicable, a revision will be issued and made available to all relevant personnel.

Filing Systems to be kept uptodate (Office and Shipboard).

DP-0302 will be kept uptodate by the DPA/CSO and shall be used as Ship Interest Contacts in the SOPEPs.

Document Transmittal

If the whole or parts of the SMS shall be made available to third parties, the Company Management will control these releases.

Management of Change

Management of Change (MoC) is a structured approach to ensure an effective transition from a present state to a future state.

Following steps represent the Management of Change process:

1. Plan

• Inspect all relevant tools, worksites, materials required for the task.
• Identify and evaluate hazards, risks, aspects and impacts
• Effectively communicate the plan to all personnel currently or anticipated to be involved or affected by the plan
• Anticipate changes that may require plan modification.

2. Implement and Monitor
• Is the plan still good for the task
• Are the tools and equipments still suitable for the task at hand
• Are the risks still the same as identified in the plan
• Are more or less people involved in the plan.

3. Recognize changes like
• Changes in expected progress / results
• Changes in participating personnel
• Changes in environment for work conditions
• Changes in priorities

4. Interrupt the task to evaluate the change and assess the risk

5. Revise the current plan or develop a new plan and initiate the improvement process if required.

Change proposals may come from anybody within the Company and this is encouraged. The use of a change request form should be completed.

The following processes should be considered for inclusion in MoC:

• New business, change in ship management, etc.
• As part of any decision-making process where the senior management, deems there are additional or nonroutine risks involved.
• New equipment and/or components.
• New policies and new procedures or changes to IMS policies and major changes in procedures.
• New rules and regulations.
• Major Changes to the shore organisation, line management and restructuring.
• Changes that may affect safety and environmental aspects if not properly monitored.
• Changes in IT Hardware or Software.

Related Documents/Forms

• DP-0102 Internal Audit Reports
• DP-0301 Document Control & Filing System
• DP-0302 Communication Lines
• DP-0303 Vessels Particulars
• DP-0304 Document Transmittal
• DP-0305 Management of Change Request
• DP-0305a Management of Change Impact Assessment
• DP-0305b Management of Change Process Flow Chart
• DP-0305c Management of Change Log

Purpose

To review management procedures

Procedure

Once a year, together with the CEO, the complete system, all inspection/audit results, HSE Statistics and Master's Reviews will be reviewed and taken as additional input for DP-03.

HSE Department is to collate the monthly HSE Statistics report from the vessels and update them in the fleet HSE data sheet. This is included in the monthly safety bulletin and in the management reports. This compilation is also used during tender process.

• DP-0401 Management Review
• SO-0901 HSE Statistics

Purpose

Emergency preparedness, both ashore and on board

Procedure

Once a year, one exercise will be held with one ship of the fleet. Each year, another topic covering safety/pollution and security will be tested.
The report, including evaluation will be sent to all ships of the fleet.

All previous exercise reports shall be made available on the SMS CD.

Related Documents/Forms

• DP-0501 Annual Safety and Securty Exercise Report

Environmental Management Representative (EMR)

Deputy Environmental Management Representative (DEMR)

Purpose

To describe responsibilities of EMR and DEMR.

Procedure

EMR responsibilities:

• Demonstrating commitment to HSEQ excellence.
• Monitoring the environmental aspects of the Company’s and ships’ operations and the EMS implementation.
• Coordinating the MRC meetings, keeping documented information, and ensuring the implementation of any subsequent Planning Actions and Environmental programs.
• Monitoring the applicable regulatory framework through form EMS-02 and ensuring the Company’s timely compliance.
• Ensuring proper internal communication of the Company’s Environmental aspects/impacts, objectives, and EPIs.
• Collecting all the necessary information and extracting the Company’s environmental performance.
• Keeping records of shore personnel qualifications and performance regarding environmental management.
• Ensuring that internal/external environmental audits are timely according to the established schedule.
• Communicating with 3rd parties (Class, Flag, etc.) for issues related to the Company’s environmental compliance.
• Participating in the implementation of the Company’s Planning Actions and proposing new Planning Actions based on information from all Managers and Masters of the ships.
• Ensuring the continued validity of the ship’s Certificates related to EMS.
• Communicating issues of environmental concerns to the entire Company’s organization.
• Ensuring that all Company personnel (onboard & ashore) receive proper familiarization regarding EMS issues.
• Reporting suggestions for the EMS improvement.
• Reporting directly to the Joint MD on significant EMS issues (compliance, audits, programs, and corrective action plans).

DEMR responsibilities:

• Demonstrating commitment to HSEQ excellence.
• Monitoring the environmental aspects of the Company’s and ships’ operations and the EMS implementation.
• Participating in implementing the Company’s Planning Actions and proposing new Planning Actions based on information from all Managers and Masters of the ships.
• Keeping all data/records (e.g., form EMS-04) and benchmarking the EPI values. In case of unexpected deviations from the schedule, he proceeds to necessary corrective actions and informs the EMR.
• Maintaining all the ships’ forms.
• Updating the environmental impacts/aspects of the operation of the Company and the managed ships.
• Updating form EMS-02.
• Composing forms EMS-01 and EMS-03.
• Taking over EMR duties during his absence.

Related Documents/Forms

• EMS manual

Purpose

The DP/CSO will provide required resources to the vessel.

Procedure

All orders from the ship will be checked and (if required) discussed with the Master or Chief Engineer. Then proper delivery will be arranged.

Related Documents/Forms

• Orders from the ship
• Reminders
• Follow up reports
• Delivery notes

Purpose

Frequent inspections of the vessel provides a suitable working environment and promotes the communication between ship and shore.
Furthermore, it promotes the safety and health on board.

Procedure

One inspection should be done in a 12 month period (+/- 3 Months).
In case of deficiencies, the corrective action shall be agreed with the ships command.

Related Documents/Forms

• DP-0801 Inspection Report