Blog 11:
Essential ISM Code Documentation for a Recently Procured 30-Year-Old Cargo Vessel.
As the newly appointed Chief Engineer on a 30-year-old cargo vessel recently acquired by its owners, your primary responsibility is to ensure the vessel is compliant with the International Safety Management (ISM) Code for immediate sailing. The ISM Code, established by the International Maritime Organization (IMO) as part of the Safety of Life at Sea (SOLAS) Convention, Chapter IX, sets an international standard for the safe management and operation of ships, emphasizing pollution prevention and safety for personnel, vessels, and the environment. For an older vessel, compliance requires meticulous preparation, especially given its age and recent change in ownership. This blog provides a comprehensive guide to the documents required for immediate sailing under the ISM Code and outlines strategies to achieve compliance within a short timeframe, tailored to the unique challenges of a 30-year-old cargo vessel.
Understanding the ISM Code and Its Relevance
The ISM Code, adopted in 1993 and made mandatory in 1998 for certain vessels, applies to cargo ships of 500 gross tonnage (GT) and above engaged in international voyages. A 30-year-old cargo vessel, likely exceeding 500 GT, falls under this mandate. The Code requires the ship’s operating company to establish a Safety Management System (SMS) that ensures safe operations, environmental protection, and compliance with international regulations. For a recently procured vessel, the Chief Engineer must verify that all necessary documentation is in place, the SMS is implemented, and the vessel is seaworthy.
The primary objectives of the ISM Code are:
Ensuring safety at sea.
Preventing human injury or loss of life.
Avoiding damage to the environment, particularly the marine environment.
Maintaining the vessel’s seaworthiness and operational readiness.
Given the vessel’s age, you’ll face unique challenges, such as outdated systems, potential maintenance backlogs, and the need to align with the new owner’s SMS. Below, we’ll explore the required documents, their purpose, and a step-by-step approach to achieve compliance swiftly, with practical examples to illustrate the process.
Key Documents Required for ISM Code Compliance
To sail immediately under the ISM Code, the vessel must hold two critical certificates: the Document of Compliance (DOC) for the company and the Safety Management Certificate (SMC) for the vessel. Additionally, a robust SMS and supporting documentation are essential. Here’s a detailed breakdown of the required documents:
1. Document of Compliance (DOC)
Purpose: The DOC certifies that the company operating the
vessel has an effective SMS that complies with the ISM Code. It is issued to
the company by the
Relevance for a New Vessel: Since the vessel is newly procured, the new owners must either transfer an existing DOC (if the vessel was previously under a compliant company) or obtain a new one. For a 30-year-old vessel, the DOC must reflect the company’s ability to manage an older ship with potential maintenance challenges.
Details: The DOC is valid for five years, subject to annual verification audits within three months of the anniversary date. It specifies the types of ships the company is authorized to operate (e.g., bulk carriers, general cargo).
Example: If the vessel is a 10,000 GT general cargo ship, the DOC must confirm the company’s SMS covers general cargo vessels. If the previous owner’s DOC does not align with the new owner’s operations, a new DOC audit is required.
2. Safety Management Certificate (SMC)
Purpose: The SMC verifies that the vessel’s management operates in accordance with the company’s approved SMS. It is issued after an onboard audit confirms compliance with ISM Code requirements.
Relevance for a New Vessel: For a recently procured vessel, the SMC from the previous owner may not be valid unless the new owner’s SMS is identical or compatible. A new SMC audit is often necessary to ensure the vessel aligns with the current company’s SMS.
Details: The SMC is valid for five years, with an intermediate verification audit between the second and third years. An interim SMC (valid for six months) may be issued if immediate compliance is not fully achievable.
Example: During an SMC audit, auditors may check the vessel’s maintenance logs for critical systems like the main engine or lifeboats, which are critical for a 30-year-old vessel prone to wear and tear.
3. Safety Management System (SMS) Manual
Purpose: The SMS Manual is the cornerstone of ISM compliance, documenting the company’s policies, procedures, and responsibilities for safe ship operation and pollution prevention. It must be tailored to the vessel’s specific characteristics, including its age and operational profile.
Key Components:
Safety and Environmental Protection Policy: A statement from the company committing to safety and pollution prevention.
Roles and Responsibilities: Clear delineation of duties for the master, crew, and Designated Person Ashore (DPA), who links the ship to shore management.
Operational Procedures: Instructions for routine operations (e.g., cargo handling, engine room checks) and emergency scenarios (e.g., fire, grounding).
Maintenance Plans: Schedules for inspecting and maintaining critical systems, crucial for an older vessel.
Training and Drills: Records of crew training and emergency drills (e.g., abandon ship, fire-fighting).
Risk Assessments: Identification of risks specific to the vessel, such as corrosion or outdated navigation equipment.
Cybersecurity Measures: Since 2021, the SMS must include cybersecurity risk assessments to address digital threats.
Relevance for a New Vessel: For a 30-year-old vessel, the SMS must account for potential issues like aging equipment, hull corrosion, or obsolete systems. The Chief Engineer must ensure the manual reflects the vessel’s current condition and operational needs.
Example: The SMS Manual might include a procedure for inspecting the vessel’s 30-year-old fuel oil purifiers, specifying weekly checks for wear and monthly overhauls to prevent breakdowns.
4. Maintenance and Inspection Records
Purpose: These records demonstrate that the vessel is maintained in a seaworthy condition, as required by the ISM Code. For an older vessel, comprehensive records are critical to prove that aging systems are functional.
Key Records:
Planned Maintenance System (PMS): Logs of routine maintenance for engines, generators, pumps, and other critical systems.
Repair Records: Documentation of recent repairs, especially for systems prone to failure in older vessels (e.g., piping, electrical systems).
Dry-Dock Reports: Evidence of the last dry-dock, including hull inspections and repairs, critical for a 30-year-old vessel.
Class Surveys: Records from the classification society confirming the vessel’s structural and mechanical integrity.
Relevance for a New Vessel: The Chief Engineer must verify that maintenance records are up-to-date and transferred from the previous owner. Missing records may require immediate inspections to establish a baseline.
Example: If the vessel’s main engine was overhauled six months ago, the Chief Engineer should obtain the overhaul report, including details of replaced parts (e.g., pistons, bearings) and performance tests.
5. Crew Training and Certification Records
Purpose: The ISM Code requires that all personnel are qualified and familiar with the SMS. This includes certificates of competency, medical certificates, and training records for safety and emergency procedures.
Key Documents:
Certificates of Competency (CoC): For the Chief Engineer, master, and other officers,
issued by the
STCW Certificates: Compliance with the Standards of Training, Certification, and Watchkeeping (STCW) Convention, including endorsements for specific vessel types.
SMS Training Records: Evidence that the crew has been trained on the company’s SMS, including familiarization with procedures and emergency drills.
Medical Certificates: Valid medical fitness certificates for all crew members.
Relevance for a New Vessel: The Chief Engineer must ensure the crew is trained on the new owner’s SMS, which may differ from the previous operator’s system. For an older vessel, additional training on handling aging equipment may be necessary.
Example: The Chief Engineer might organize a training session on the SMS, focusing on procedures for operating the vessel’s 30-year-old boiler, which may require manual adjustments not covered in modern systems.
6. Emergency Preparedness Documents
Purpose: The ISM Code mandates documented procedures for emergency scenarios, such as fire, collision, or oil spills, to ensure the crew can respond effectively.
Key Documents:
Emergency Procedures Booklet: A quick-reference guide on the bridge and in the engine room, outlining steps for emergencies.
Drill Records: Logs of recent fire, abandon ship, and oil spill response drills, including dates and crew participation.
Contingency Plans: Plans for specific risks, such as engine failure or hull breaches, which are more likely in an older vessel.
Relevance for a New Vessel: The Chief Engineer must verify that emergency procedures are updated for the vessel’s current configuration and that the crew is familiar with them through recent drills.
Example: A drill record might document a fire drill conducted on the vessel, noting that the crew successfully operated the 30-year-old CO2 fire suppression system in the engine room.
7. Master’s Review and Internal Audit Reports
Purpose: The ISM Code requires the master to conduct an annual review of the SMS’s effectiveness and the company to perform internal audits to identify non-conformities.
Key Documents:
Master’s Review: A report assessing the SMS’s performance, including any deficiencies or recommendations for improvement.
Internal Audit Reports: Records of audits conducted by the company, identifying compliance gaps and corrective actions.
Relevance for a New Vessel: For a recently procured vessel, the Chief Engineer should review the previous master’s review (if available) and coordinate with the DPA to schedule a new internal audit to align with the new owner’s SMS.
Example: The Master’s Review might note that the vessel’s 30-year-old navigation radar occasionally malfunctions, recommending a replacement or enhanced maintenance schedule.
8. Non-Conformity and Corrective Action Records
Purpose: These records document any deviations from the SMS (non-conformities) and the corrective actions taken to address them. A major non-conformity, such as a critical system failure, requires immediate action and may prevent sailing until resolved.
Key Documents:
Non-Conformity Notes (e.g., MSF 1902): Formal records of identified issues, such as a malfunctioning lifeboat or missing SMS procedure.
Corrective Action Plans (CAPs): Plans outlining how non-conformities will be resolved, including timelines and responsible parties.
Relevance for a New Vessel: An older vessel may have accumulated non-conformities, such as corrosion or outdated equipment, requiring immediate attention. The Chief Engineer must ensure all major non-conformities are resolved before sailing.
Example: A non-conformity might be identified during an audit, noting that the vessel’s 30-year-old bilge pump is unreliable. The CAP would detail its repair or replacement within a specified timeframe.
9.
Purpose: The
Key Documents:
PSC Inspection Reports: Records of past inspections, noting any deficiencies that must be addressed.
Relevance for a New Vessel: The Chief Engineer must ensure the vessel’s registration is updated with the new owner’s details and that any PSC deficiencies from the previous owner are resolved.
Example: A PSC report might note that the vessel’s 30-year-old life rafts were overdue for servicing, requiring immediate action before sailing.
10. Cybersecurity Risk Assessment
Purpose: Since 2021, the ISM Code requires SMS to include cybersecurity risk assessments to protect navigation and communication systems from digital threats.
Key Documents:
Cybersecurity Risk Assessment Report: Identifies vulnerabilities in the vessel’s systems (e.g., GPS, AIS) and mitigation measures.
Cybersecurity Training Records: Evidence that the crew is trained to recognize and respond to cyber threats.
Relevance for a New Vessel: A 30-year-old vessel may have outdated electronic systems, increasing cybersecurity risks. The Chief Engineer must ensure these systems are assessed and protected.
Example: The assessment might identify that the vessel’s old Electronic Chart Display and Information System (ECDIS) lacks modern encryption, requiring a software update or replacement.
Achieving Compliance Within a Short Timeframe
For a recently procured 30-year-old cargo vessel, achieving ISM Code compliance quickly is challenging but feasible with a structured approach. Below is a step-by-step plan, tailored to the vessel’s age and the urgency of immediate sailing:
Step 1: Assess Existing Documentation (Days 1–2)
Action: Review all available documents from the previous owner, including the DOC, SMC, SMS Manual, maintenance records, and audit reports. Verify their validity and compatibility with the new owner’s SMS.
Challenges for an Older Vessel: Missing or outdated records, especially for maintenance and repairs, are common. The previous SMS may not address the vessel’s aging systems.
Solution: Collaborate with the DPA to obtain missing documents or conduct a gap analysis. For example, if maintenance records for the vessel’s 30-year-old generators are incomplete, schedule an immediate inspection by a qualified technician.
Timeline: 1–2 days to compile and assess documents.
Step 2: Conduct a Vessel Condition Survey (Days 3–5)
Action: Perform a thorough inspection of the vessel’s critical systems, including the main engine, auxiliary machinery, navigation equipment, and safety systems (e.g., lifeboats, fire-fighting equipment). Focus on areas prone to issues in older vessels, such as corrosion, wiring, and piping.
Challenges for an Older Vessel: Aging equipment may not meet current standards, and repairs may be time-consuming.
Solution: Engage a classification society to conduct a survey and issue a Condition of Class report, identifying any deficiencies. For example, if the vessel’s 30-year-old hull shows signs of corrosion, schedule immediate repairs or dry-docking.
Timeline: 2–3 days, depending on the vessel’s condition and surveyor availability.
Step 3: Update or Develop the SMS (Days 6–10)
Action: If the previous owner’s SMS is incompatible, develop or update the SMS Manual to reflect the new owner’s policies and the vessel’s specific needs. Include procedures for operating and maintaining aging systems.
Challenges for an Older Vessel: The SMS must address unique risks, such as frequent maintenance for outdated equipment or manual overrides for obsolete systems.
Solution: Work with the DPA and shoreside management to customize the SMS. For instance, include a procedure for daily checks on the vessel’s 30-year-old steering gear to prevent hydraulic failures.
Timeline: 4–5 days to draft and review the SMS Manual.
Step 4: Train the Crew (Days 11–13)
Action: Conduct SMS familiarization training for all crew members, focusing on emergency procedures, maintenance protocols, and cybersecurity awareness. Verify that all crew hold valid certificates.
Challenges for an Older Vessel: The crew may lack experience with older systems, requiring additional training.
Solution: Organize hands-on training sessions, such as operating the vessel’s manual fuel transfer system or conducting a fire drill with the aging CO2 system. Use simulators if available to replicate emergency scenarios.
Timeline: 2–3 days for training and verification.
Step 5: Schedule Internal and External Audits (Days 14–20)
Action: Arrange an internal audit by the company to identify
non-conformities, followed by an external audit by the
Challenges for an Older Vessel: Major non-conformities, such as faulty safety equipment, may delay certification.
Solution: Address non-conformities immediately. For example, if an audit identifies a malfunctioning emergency generator, replace or repair it within 48 hours and document the CAP. Request an interim DOC or SMC if full compliance is delayed.
Timeline: 5–7 days, including audit preparation and corrective actions.
Step 6: Obtain
Action: Submit all documentation to the
Challenges for an Older Vessel: PSC inspectors may scrutinize older vessels more closely, focusing on maintenance and safety systems.
Solution: Conduct a mock PSC inspection to identify potential issues. For instance, ensure the vessel’s 30-year-old life rafts are serviced and certified.
Timeline: 4–5 days for approvals and preparation.
Step 7: Final Preparations for Sailing (Days 26–30)
Action: Conduct pre-sailing checks, including engine trials, navigation system tests, and emergency drills. Verify that all documentation is onboard and accessible.
Challenges for an Older Vessel: Unexpected failures during trials may require last-minute repairs.
Solution: Maintain a contingency plan, such as spare parts for critical systems (e.g., fuel pumps, alternators). For example, if the main engine fails during trials, have a repair team on standby to address issues within 24 hours.
Timeline: 4–5 days for final checks and trials.
Practical Example: Case Study of a 30-Year-Old Bulk Carrier
To illustrate, consider a 30-year-old, 15,000 GT bulk carrier recently acquired by a new owner. The Chief Engineer joins and finds that the previous owner’s DOC is valid but not aligned with the new owner’s SMS. The SMC is expired, and maintenance records are incomplete for the vessel’s aging ballast water system.
Day 1–2: The Chief Engineer reviews the DOC, SMC, and partial maintenance records, identifying gaps in ballast system documentation.
Day 3–5: A classification society conducts a survey, revealing minor corrosion in the ballast tanks and a faulty emergency fire pump. Repairs are scheduled.
Day 6–10: The DPA updates the SMS Manual, adding procedures for inspecting the ballast system and operating the vessel’s outdated radar.
Day 11–13: The crew undergoes training on the new SMS, including a drill to test the repaired fire pump.
Day 14–20: An internal audit identifies a non-conformity in the emergency generator’s fuel line, which is repaired. An external audit by DNV grants an interim SMC.
Day 21–25: The Flag State approves the updated registration, and a mock PSC inspection confirms compliance.
Day 26–30: Engine trials and a final fire drill are conducted, and the vessel is cleared for sailing.
This process, completed in approximately 30 days, demonstrates how proactive planning and collaboration with the DPA and RO can achieve compliance swiftly.
Challenges and Solutions for Older Vessels
Older vessels present unique challenges under the ISM Code:
Aging Equipment: Systems like boilers, pumps, or navigation equipment may be obsolete, requiring frequent maintenance or replacement.
Solution: Implement a robust PMS with daily checks and carry spare parts for critical systems.
Corrosion and Structural Issues:
Solution: Conduct ultrasonic thickness measurements and apply protective coatings during dry-docking.
Crew Familiarity: New crew may struggle with older systems.
Solution: Provide hands-on training and maintain detailed procedure manuals.
Documentation Gaps: Previous owners may not have maintained comprehensive records.
Solution: Reconstruct records through inspections and audits, and digitize them for accessibility.
Best Practices for Sustained Compliance
To ensure ongoing ISM compliance after sailing:
Regular Audits: Schedule internal audits every 12 months and
external audits as required by the
Continuous Training: Conduct regular drills and SMS training to keep the crew proficient.
Maintenance Oversight: Use a digital PMS to track maintenance and flag potential issues early.
Engage the DPA: Maintain open communication with the DPA to address non-conformities promptly.
Cybersecurity Updates: Regularly assess and update cybersecurity measures to protect aging systems.