1. ISM Code 2010: Part A - Implementation Malcolm Maclachlan

2. Safety management objectives of the Company should, amongst other things … (para. 1.2) 1. Provide for safe practices in ship operation and a safe working environment. 2. Assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards. 3. Continuously improve safety management skills of personnel ashore and aboard ships, including preparing for emergencies related both to safety and environmental protection.

3. Safety management system should ensure … (para. 1.2) 1. Compliance with mandatory rules and regulations. 2. Applicable codes, guidelines and standards recommended by IMO, flag State Administrations, classification societies and maritime industry organizations are taken into account.

4. Safety management system functional requirements (para. 1.4) 1. A safety and environmental-protection policy. 2. Instructions and procedures to ensure safe operation of ships and protection of the environment in compliance with relevant international and flag State legislation. 3. Defined levels of authority and lines of communication between, and amongst, shore and shipboard personnel. 4. Procedures for reporting accidents and non- conformities. 5. Procedures to prepare for and respond to emergency situations. 6. Procedures for internal audits and management reviews.

5. Designated Person (para. 4) Link between ship and shore management with direct access to top management. Link between ship and shore management with direct access to top management. Responsible for proper implementation & improvement of SMS on ship(s). Responsible for proper implementation & improvement of SMS on ship(s). Logs reports of accidents and NCs; initiates corrective actions. Logs reports of accidents and NCs; initiates corrective actions. Gathers/analyses data from hazardous occurrences, hazardous situations, near misses, incidents and accidents and applies lessons learnt to improve SMS within Company & ships. Gathers/analyses data from hazardous occurrences, hazardous situations, near misses, incidents and accidents and applies lessons learnt to improve SMS within Company & ships.

6. Master’s responsibility & authority (para. 5) 1. Implement Co’s Safety and Environment Prot’n Policy. 2. Motivate the crew in observation of the S&EP Policy. 3. Issue appropriate orders and instructions in a clear and simple manner. 4. Verify that specified requirements are observed. 5. Periodically review the SMS and report its deficiencies to shore-based management. SMS must contain clear statement emphasizing master’s authority. SMS must contain clear statement emphasizing master’s authority. Co. should establish in SMS that master has overriding authority and responsibility to make decisions with respect to safety & pollution prevention & to request Co’s assistance as may be necessary. Co. should establish in SMS that master has overriding authority and responsibility to make decisions with respect to safety & pollution prevention & to request Co’s assistance as may be necessary.

7. Resources & personnel (para. 6) 1. Co. should ensure master is properly qualified for command, conversant with SMS & given necessary support. 2. Co. should ensure ship is manned with qualified, certificated & medically fit seafarers as per regs. 3. Familiarisation training to be given. Pre-sailing instructions to be documented & given. 4. Personnel involved in SMS to have adequate understanding of relevant rules, regs, codes & g’lines. 5. Co. should - identify and provide training in support of SMSidentify and provide training in support of SMS ensure SMS info is provided in working language(s)ensure SMS info is provided in working language(s) ensure ship personnel can communicate effectively.ensure ship personnel can communicate effectively.

8. Plans for Shipboard Ops (para. 7) Emergency preparedness (para. 8) Co. should establish procedures, plans and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of personnel, ship and protection of environment. The various tasks should be defined and assigned to qualified personnel. Co. should identify potential emergency shipboard situations, and establish procedures to respond to them. Co. should establish programmes for drills and exercises to prepare for emergency actions. SMS should provide for measures ensuring that Company's organization can respond at any time to hazards, accidents and emergency situations involving its ships.

9. Reports of accidents & non- conformities (para. 9) SMS to include procedures ensuring non- conformities, accidents & hazardous situations are reported to Co, investigated and analysed with the objective of improving safety and pollution prevention. SMS to include procedures ensuring non- conformities, accidents & hazardous situations are reported to Co, investigated and analysed with the objective of improving safety and pollution prevention. Company should establish procedures for implementation of corrective action Company should establish procedures for implementation of corrective action, including measures intended to prevent recurrence.

10. Maintenance of ship & equipment (para. 10) Co to establish procedures to ensure ship is maintained as per relevant rules & regs and with any add’l Co. requirements. (= PMS) Co to establish procedures to ensure ship is maintained as per relevant rules & regs and with any add’l Co. requirements. (= PMS) Inspections at appropriate intervals; NCs reported (with poss. cause if known); corrective action taken; records maintained. (All in PMS) Inspections at appropriate intervals; NCs reported (with poss. cause if known); corrective action taken; records maintained. (All in PMS) Critical equipment to be identified & given priority for maintenance. Testing of back-up arrangements & unused gear. (All in PMS) Critical equipment to be identified & given priority for maintenance. Testing of back-up arrangements & unused gear. (All in PMS)

11. Documentation (para. 11) Co. to maintain controlled document system for SMS docs/data: Co. to maintain controlled document system for SMS docs/data: –Valid docs available at relevant locations. –Changes to docs reviewed & approved by authorised personnel. –Obsolete docs promptly removed. SMS docs = “Safety Management Manual”. SMS docs = “Safety Management Manual”.

12. Company verification, review & evaluation (para. 12) 1. Co. should carry out internal safety audits every 12 months max*: Are S&PP activities as per SMS? *In exceptional circumstances interval can be increased by max 3 months. 2. Co. should periodically evaluate effectiveness of SMS. 3. Audits & corr. actions as per documented procedures. 4. Personnel carrying out audits should be independent of audited areas unless impracticable due to size/nature of Co. 5. Results of audits and reviews brought to attention of personnel with responsibility in area involved. 6. Management personnel responsible for area involved should take timely corr. action on deficiencies found.