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Safety Management Systems
What? Why? How? Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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What is a SAFETY MANAGEMENT SYSTEM
A Safety Management System (SMS) is a systematic approach to managing safety, including the necessary organizational structures, accountabilities, policies and procedures. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Functional requirements for a Marine Safety Management System (SMS)
Safety and environmental protection policy; Instructions and procedures to ensure safe operations of ships and protection of the environment; Clearly defined levels of authority and lines of communication between, and amongst, shore and shipboard personnel; Procedures for reporting accidents and non conformities; Procedures to prepare for and respond to emergency situations; and Procedures for internal oversight and review. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Regulatory Drivers CSA 2001 and Regulations Occupational Health and Safety Regulations Environmental Regulations Company and Client Requirements Regulatory Drivers Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Do/Will I need a Safety Management System?
Transport Canada is currently in the process of amending the Safety Management Regulations. The regulatory proposal currently applies to Canadian non-Convention vessels. When these proposed amended regulations come into force, the following vessels and the companies that operate them will be required to adopt a SMS in compliance with the ISM Code: A Canadian vessel subject to Chapter IX of the International Convention for the Safety of Life at Sea (SOLAS) ; A Canadian vessel of 500 gross tonnage and upwards; A Canadian vessel that is certified to carry more than 50 passengers; and A Canadian vessel that is more than 24 meters in length and less than 500 gross tonnage. Note: even where not required by regulation, SMS may be determined to be a mandatory requirement as a condition for issuance of an MTRB. Do/Will I need a Safety Management System? Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Transport Canada Compliance and Enforcement Program (CEP)
• Canada Shipping Act, 2001 (CSA 2001) introduced a new Inspection and Enforcement Program. • CSA 2001 reflects the principle that it is the authorized representative/owner’s responsibility to ensure a vessel complies with the Act and its supporting regulations. • Focus is now more performance-based and encourages voluntary compliance through Safety Management Systems. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Authorized Representative (AR)
CSA 2001 Part 4 Safety 106 (1) The authorized representative of a Canadian vessel shall (a) ensure that the vessel and its machinery and equipment meet the requirements of the regulations made under this Part; (b) develop procedures for the safe operation of the vessel and for dealing with emergencies; and (c) ensure that the crew and passengers receive safety training. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Authorized Representative (AR)
CSA 2001 Part 1 General - Canadian Maritime Documents (2) The authorized representative of a Canadian vessel shall ensure that (a) the vessel and its machinery and equipment are inspected for the purpose of obtaining all of the Canadian maritime documents that are required under this Part; and (b) every term or condition attached to a Canadian maritime document issued in respect of the vessel or its machinery or equipment is met. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Authorized Representative (AR)
Marine Personnel Regulations – Part 2 Crewing 206 (1) The authorized representative of a vessel shall provide to the master written instructions that, at a minimum, determine the procedures and, if applicable, the policies, within the meaning of those terms in section AI/14 of the STCW Code, to be followed to ensure that each member of the complement, before being assigned any duty, (a) becomes familiar with (i) the shipboard equipment that are specific to the vessel, (ii) the operational instructions that are specific to the vessel, and (iii) their assigned duties; and (b) can effectively perform their assigned duties when performing duties vital to safety or the prevention or mitigation of pollution. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Authorized Representative (AR)
Marine Personnel Regulations – Part 2 Crewing 202 (5) The authorized representative of a Canadian Safety Convention vessel or a vessel that is required to carry an inspection certificate shall ensure that the Safe Manning Document issued by the Minister for that vessel under subsection (3) is carried on board. 207 (1) The authorized representative of a vessel shall ensure that the minimum complement of the vessel meets the requirements of section 7. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Federally Regulated – CLC MOHS Regs.
Canada Labour Code – Marine Occupational Health and Safety Regulations 120 The employer must, in consultation with and with the participation of the policy committee, or, if there is no policy committee, the work place committee or the health and safety representative, develop, implement and monitor a program for the prevention of hazards, including ergonomics-related hazards, in the work place that is appropriate to the size of the work place and the nature of the hazards and that includes the following components: Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Federally Regulated – CLC MOHS Regs.
Canada Labour Code – Marine Occupational Health and Safety Regulations 125 (1) The employer must provide each employee with health and safety education, including education relating to ergonomics and it must include the following: (a) the hazard prevention program implemented in accordance with this Part to prevent hazards applicable to the employee, including the hazard identification and assessment methodology and the preventive measures taken by the employer; (b) the nature of the work place and the hazards associated with it; (c) the employee’s duty to report under paragraphs 126(1)(g) and (h) of the Act and under section 275; and (d) an overview of the Act and these Regulations. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Provincially Regulated – WorkSafe BC
WCB Occupational Health and Safety Regulation Part 3 - General Duties of Employers Employers are responsible for the following: To ensure the health and safety of their workers and other workers on the worksite To ensure that workers are aware of all known or reasonably foreseeable hazards To establish OHS policies and programs To remedy hazards (both physical and human) To provide information, instruction, training and supervision Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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DUE DILIGENCE Due diligence defence is available where offences involve strict liability, that is where prosecutors only have to prove that an offence or breach took place and not that there was intent.“ Due diligence" is defined as taking all reasonable care to prevent the occurrence of an incident or event. Due diligence in safety management can be described as “a system approach that provides information, instruction, training, supervision, verification of knowledge, and correction of physical and human hazards. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Indicators of due diligence:
1. Audits 2. Remedial and Contingency Plans 3. Inspections 4. Training Programs 5. Policies 6. Reporting 7. Security 8. Timing of Due Diligence Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Six clear indicators of no due diligence
1. Failure to train 2. Allow the wrong person to do the job 3. Failure to have sufficient people on the job 4. Failure to provide a safe workplace 5. Failure to consider whether a danger exists 6. Not knowing what is an offense Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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What to include? Small Commercial Vessel Safety Guide TP E (2010) Manning requirements OHS Training Risk Assessments and Safe Working Practices Emergency Preparedness including drills and equipment checks Navigation including voyage planning and maintenance of charts and publications Reporting requirements – accidents, injuries, and pollution Maintenance Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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First Steps Determine Scope
Assess existing procedures for completeness and reg. compliance Develop an Action Plan to address any gaps Documentation Procedures What’s essential How much detail Who should draft the procedures? Checklists and forms Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Management Responsibilities
Administrative Implementation Oversight System Maintenance, Feedback and Review Controlling, tracking, and distributing updates. Active Reviewing and analyzing reports Verifying compliance Organizing Training Responding to emergencies Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Main Requirements of the ISM Code
Safety and Environmental Protection Policy Company Responsibilities and Authority Designated Person Master’s Responsibility Resources and Personnel Shipboard Operations Emergency Preparedness Reports and Analysis of Non-Conformities, Accidents and Hazardous Occurrences Maintenance of the Ship and Equipment Documentation Company Verification, Review and Analysis Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Safety Management objectives of the company should
.1 provide for safe practices in ship operation and a safe working environment; .2 establish safeguards against all identified risks; .3 continuously improve safety management skills of personnel ashore and aboard ships, including preparing for emergencies related to both safety and environmental protection Safe practices may be established by WCB or industry specific standards. Applicable codes and standards should be carried on board the ship. Risks may be identified during inspections, safety meetings, or as a result of reviewing operational practices, etc. Continuous improvement can be through drills and exercises, training, monitoring and reviewing the SMS etc. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Safety and Environmental Protection Policy
Has a safety and environmental policy been established? Where is it kept? Are all employees aware of the policy? How is it being implemented? The policy should be posted on all vessels and in the shore office. New employees should all be made aware of the policy. The policy should include statements identifying how the objectives will be achieved. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Company Responsibility and Authority
Is the company’s organization clearly described? Are lines of communication and levels of authority clearly shown? Has the responsibility and authority of all those who monitor, perform and verify work relating to safety and pollution prevention been documented? Are job descriptions available for all ship and shore based personnel? Do these contain selection criteria? The SMS manual should contain a narrative description of the company and its operation. Organizational charts should be used to show this. Company procedures and job descriptions should include references to responsibility and authority. Selection criteria should ensure an assessable link between qualifications and experience and assigned responsibility. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Designated Person Has the responsibility for this function been assigned? Who is the Designated Person? Are all employees aware of his/her identity? Do they understand the function he/she performs? Does the DP have access to the highest level of management? How does the DP monitor the safe operation of the fleet? Does the DP have appropriate qualifications and experience? In small companies it may be impracticable to have a Designated Person solely responsible for these functions. In these cases the functional responsibilities should be assigned to other persons such as a superintendent, operations manager, or, in very small companies, to the owner or Authorized Representative. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Master’s responsibilities
Are the master’s responsibilities, particularly with respect to the SMS, defined and documented? How does the master: Implement the Safety and Environmental protection policy? Motivate the crew to observe the policy? Review the SMS and report deficiencies with the system? The master’s responsibilities for the SMS are specific. They can be demonstrated through regular shipboard safety meetings. Crew briefings, etc. The shipboard safety meetings may take place ashore or onboard, and may involve more than one crew, e.g. for small companies a joint management/ship SMS review meeting, appropriately documented, would demonstrate the master’s role in managing the system onboard and reporting non- conformities to the company was being fulfilled. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Master’s authority IMO Resolution A 443 (XI) invited Governments to take the necessary steps to safeguard the shipmaster in the proper discharge of his responsibilities in regard to maritime safety and the protection of the marine environment, Is the master’s overriding authority with respect to safety and pollution prevention clearly stated? Is the master’s authority in other matters clear? The SMS manual should contain a clear statement to this effect. This should be contained in the job description and various procedures. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Manning Are all crew appropriately qualified?
Do they all have valid, current Continued Proficiency Certificates? Are they medically fit? Have minimum manning levels been identified and documented? Are masters aware of the minimum manning levels? Who is responsible for assigning crew to vessels? Are they aware of the regulatory requirements? Regulatory requirements should be checked, these requirements, together with any company requirements should then be included in the selection criteria and/or job descriptions. Procedures should be developed to regularly review the status of certificates including medical certificates. Procedures need to be established to ensure that vessels are always adequately manned. Procedures to check references and validity of certificates need to be established. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Familiarization What familiarization procedures do you have in place?
Do they include safety and pollution prevention aspects of their duties? Are these documented? Who is responsible for ensuring that the familiarization takes place? Are records maintained? Are any essential pre-sailing instructions included? Familiarization requirements need to be documented, including a statement identifying the master’s responsibility for ensuring familiarization is given to new or recently transferred crew members. Basic Safety Familiarization must be given to all shipboard employees. Additional training/familiarization, e.g.: DG/Oil Spill Response, for crew on oil or product barges may be necessary. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Relevant rules What rules and regulations are applicable to your operation? Where is this information available? How is it updated? Copies of relevant rules should be available on board. In some instances it may be sufficient to refer to them in the procedures and maintain full copies ashore. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Training What procedures are in place to identify training needs?
How is this training provided? Is training identified for shore personnel? Procedures should be established and documented to identify training needs. Responsibility for providing training needs to be identified. Records must be maintained. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Information on the SMS How is this information provided?
How is the understanding of crewmembers verified? Availability of the SMS manual, and crew knowledge of the contents should be verified. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Development of plans for shipboard operations
Has the company developed plans for all special and critical shipboard operations? Do they identify and address hazards? How are they maintained and updated? Are the procedures being implemented? These will be contained in the SMS manual. Identification of special and critical operations should be carried out by appropriately qualified persons. Checklists and other records should be used to verify implementation. Various OHS programs such as confined space, lock out, etc. should be incorporated into the SMS. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Contingency Plans Are there plans for dealing with the media?
Are there plans for keeping relatives informed during an emergency? Interaction with external agencies such as Rescue coordination centres and spill response agencies should be documented. Is there a procedure for reviewing and updating these plans? All masters should be involved in identifying potential shipboard emergency situations. Have shore response plans been developed? Is the shore response available 24 hours a day, or at least during all operational hours? Are emergency contact lists maintained? Are essential ship details available? Is next of kin information for crewmembers available? Have shipboard response plans been developed? Do they cover responses to each identified emergency situation? Contingency Plans Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Drills and Exercises Is there a schedule for drills and exercises for each of the plans? Do these include exercising the shore response? Are debriefs held after exercises or drills? Are there procedures for corrective action and follow up for concerns identified during the debrief? Is the ship-shore interface tested periodically? Frequency of drills should ensure compliance with any regulatory requirement; e.g. fire and boat drill, and also ensure crew competence is maintained. Records of drills should be maintained. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Reports and analysis of Accidents, Incidents, etc.
Are accidents, non- conformities and hazardous occurrences clearly identified? Are there clear procedures for reporting these? Is there clear instruction on who is responsible for completing the reports and how to fill in the form? Are these reports investigated and analysed, where appropriate? Is there a procedure for corrective or preventative action arising out of an investigation? When causes of accidents are identified is this relayed back to the crew along with instruction for any corrective action or precautions to avoid recurrence? Where there are official reporting requirements, the requirements should be documented and a supply of official report forms should be available. Company reports should be described and appropriate forms should be included in the SMS manual. Non-conformities should be tracked and followed up. Reports and analysis of Accidents, Incidents, etc. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Maintenance of the ship and equipment
Are there documented procedures or schedules for maintenance including: Hull and superstructure Safety, fire-fighting, and pollution prevention equipment Navigational equipment, Steering Gear Anchoring and mooring equipment Main engine(s) and auxiliary machinery Pipelines and valves, Bilge systems Communication equipment Fire, gas and heat detection equipment? Maintenance of the ship and equipment Training and qualifications of persons responsible for managing, verifying and performing maintenance tasks must be documented. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Maintenance of the ship and equipment
Are regular inspections carried out? Are defects identified during inspections reported and corrected? Have critical equipment and systems been identified including: Lifesaving equipment Fire-fighting equipment Safety equipment Alarms and emergency shutdowns Back-up systems Inspection schedules must be established Procedures for handling defects must be described in the SMS manual. Critical and essential equipment and systems should be regularly tested or inspected and records maintained. Maintenance of the ship and equipment Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Have procedures been established for controlling documentation and data relevant to the SMS?
Has this documentation been identified and inventoried? Does this include updates to charts and publications? Who is responsible for controlling the distribution and updating of this documentation, onboard and ashore? How are changes to documentation made? Are there procedures in place to ensure that obsolete documents are not used? How are records managed? An inventory of controlled documents must be established including company documents, manufacturers manuals, publications such as list of lights, tide tables etc. and relevant rules and regulations. Procedures for distribution and control must be established and documented and responsibility for carrying out the procedures must be assigned. Lifecycle records management must be established; when is a record required, who generates it, who is copied, when and where is it archived and when can it be disposed of. Documentation Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Internal audits and SMS review
Are there documented procedures describing the conduct of audits? Is there an audit schedule? Does this include all vessels and shore offices? How are findings reported? Who responds to the reports? What are the qualification requirements of the auditor(s) How is corrective action followed up and closed out? Who monitors the findings to identify trends and recommend improvements to the system? Is there a review procedure for the SMS? If the appropriate skills are available within the company, company personnel should conduct the internal audits. Personnel carrying out the audits must be appropriately qualified and independent from the areas being audited. This could involve masters and appropriate shore managers. Senior management should review the SMS, at least annually. This should include a review of the SMS manual, audit findings, accidents, non-conformity reports, drill reports etc. The object is to verify that the system is working and to identify areas where improvements may be made. Internal audits and SMS review Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Operational Benefits of SMS
Better safety culture Consistent, established best practices Assurance of regulatory compliance Less accidents Employees better informed and empowered to make safety decisions More safety data, better analysis and decision making Improved safety documentation Better performance on inspections/audits (i.e., better interaction with oversight agencies) Operational Benefits of SMS Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Financial and Business Benefits of SMS
Improved business reputation Reduced cost of lost/damaged equipment Possibility of lower insurance premiums Reduced damage claims Reduced payroll costs (less lost time by employees) Possibility of reduced worker’s compensation costs Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Paper or Computer Based SMS
Simpler? Cheaper? Quicker initial implementation Systems of Record – simple storage and retrieval – not connected – no analysis – no statistics Difficult and costly to maintain. Harder to monitor effectively COMPUTER BASED Easier for managing and monitoring the system – reg. compliance verification Schedule activities Data analysis easier – statistics Single data entry – less errors, less duplication Simple overviews and dashboards Stress free audits Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Further advantages of computerized systems
Cloud based systems give greater security and permit regular, automatic backups off site in differing geographical regions. Better user experience, intuitive – minimal training. Tablets allow crew to complete forms on site and can include photographs, voice recording, voice to text fields, video and photograph attachments, photograph annotation. Offline access with built in write conflict resolution. Data integration with existing systems including SQL, NOSQL and REST APIs. Can recreate existing forms to look exactly like the paper version speeding up crew adoption. Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Invicta Marine SMS DB Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Detail View Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Custom Editor for Risk Assessment Module
Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Repair Requisition Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Detail View Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Outstanding Repairs List - Autogenerated
Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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Questions? Presented by Bob Beadell, President and Principal Consulant, Invicta Marine Ltd.
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