1-232 SOLAS Chapter XI incorporates the ISM Code into the ambit of port state con-trol inspections; from 1 July 1998 for tankers, bulk carriers, passenger vessels and high-speed craft and from 1 July 2002 for other ships over 500 gt. The advent of the ISM Code offers three effective enhancements to the PSCO’s inspection armoury and poses problems to PSC regimes and the IMO and international maritime community’s endeavours to pursue the philosophy of
“Safer Ships, Cleaner Seas”.
1-233 Documentary proof of ISM Code compliance (the dates of the company’s DOC, the ship’s SMC and, probably, the name of the organisation issuing these certificates) can be incorporated into the ship’s notification of arrival papers.
A number of port states are already incorporating into their national law the abil-ity to order ships determined not to be in compliance (no certification) to leave national waters and not to return until proof of compliance can be provided.
Code
Number Designation
% of Vessels Detained
100 Certificates and documents 3
200 Crew 1
600 Life saving appliances 19
700 Fire fighting appliances 22
900 Safety in general 13
1200 Load lines 6
1400 Propulsion and auxiliary machinery 1
1500 Navigation 2
1700 Marine pollution 4
2000 SOLAS-related operational (includes drills) 20
9800 Other 9
Total 100
Port State Control (PSC) Module 1
1-234 This takes us on to the core of too much reliance on a reactive system of port state control to eliminate sub-standard shipping – the very ships which, by their failure to be able to present a legally required SMC, fall into the class of sub-standard. While refusal of port entry prevents them from, commercially, plying their trade, they are not removed from the high seas where they may continue to navigate unsafely, probably with little attention to the need to prevent marine pollution, until they find a port which will allow them entry.
1-235 PSC is undoubtedly an essential and, mainly, effective weapon in the elimination of sub-standard shipping. It remains essential that IMO and the (responsible) shipping nations continue to exert pressure on those flag states with a poor record to play a (pro) active and effective role in the drive towards improved standards.
1-236 Another aspect of any safety (or quality management system) which must be understood – there is no “quick fix”. A safety management system, depending upon the organisation’s start state, takes many months of committed effort, both on board and ashore, to put into place. IMO recognises this in so far as one of the requirements for certification is that there is evidence of the safety manage-ment system having been in operation for three months prior to audit. It is a dif-ficult decision for any port and PSC regime to elect between detaining a vessel until a safety management system is introduced, inevitably holding the vessel in port for many months, and sending it back to sea, theoretically at least, in an unseaworthy state.
1-237 For a ship with a valid SMC, the ISM Code offers very positive assistance to the PSCO. The first area of inspection is also documentary and focuses on audits, both third party and internal, and any record of non-compliances. These, or in the case of internal audits, their absence, will give a good indication of how effective the ship’s safety management system is.
1-238 The ISM Code’s other great strength is that it is very much a “show me” code which can, and should, incorporate all of the crew. Show me, linked to the stan-dard open questions of how, where, when, why will effectively reveal the way in which the vessel operates and is managed. Show me how “you plan your next passage”, “prepare to take bunkers” or “where your fire station is” can all be part of the PSCO’s approach.
SELF-ASSESSMENT QUESTION
Consider the US Boarding Criteria Matrix and discuss the advantages against the disadvantages of this system.
LEARNING OUTCOMES
After successful completion of this chapter, you will be able to:
● state what is meant by FSA; and
● describe how IMO and in the UK how MCA are looking at FSA as a means of prioritising the development of regulations.
8. RISK MANAGEMENT AND FORMAL SAFETY ASSESSMENT (FSA)
8.1 RISK MANAGEMENT
1-239 A risk-based approach has been used for a number of years by the nuclear, chemical and offshore industries and is increasingly being used in the shipping industry, partly because it is a useful and practical tool at the operational level and partly because it is being introduced by legislation. European Union regulations on health and safety require the application of risk assessment as discussed in section 4.2. and risk management is implicit in the application of the ISM Code (Chapter 6). Furthermore, IMO is exploring the potential for using the risk-based approach for managing international legislation and this is discussed in this chapter. The intention here is to give an overview of the risk management tool kit, so that the marine surveyor can understand its application and consider its use as a powerful management tool for his own professional work.
1-240 The application of risk management techniques ranges from relatively complex mathematical modelling to applied common sense and therein lies part of its problem. At one end of the scale it is too complex for the untrained practitioner and at the other, because it is so straightforward, it can be difficult to explain because . . . “it is so like common sense”. It is perhaps best thought of as a management discipline which will improve decision-making, providing an invaluable tool box of techniques which can support the proficient manager. Risk management is closely aligned with planning – if the manager takes time to plan he can use risk management effectively.
1-241 To understand the formal process of risk assessment and risk management it is essential to understand the difference between hazard and risk. This is best done by illustration. Assume a vacuum cleaner safely stowed in a locker. It is in the public area of a ferry, or passenger ship, and there is little risk of any harm or injury.
1-242 If the vacuum cleaner is left unattended, outside its locker and with a trailing lead, the likelihood of an accident increases in terms of frequency, although the consequences are not likely to be serious.
Risk Management and Formal Safety Assessment (FSA) Module 1
1-243 If the vacuum cleaner is being used with its flex stretched across the floor of a public area, the risk of an accident is even higher and the possible injury more severe – a broken arm or badly twisted ankle. Assume that the flex leads across the steps down to the dining saloon – now the potential seriousness of an accident is heightened, even to the possibility of a fatality.
1-244 If the steward is late in his work and the vacuum cleaner is in this position as lunch is announced, both the probability as well as the severity of an accident will be high.
1-245 There is little doubt that in the last scenario the vacuum cleaner is the hazard. It is however the same vacuum cleaner and the same hazard as when it was stowed in its locker. It is the level of risk that changes. This understanding is critical when concerned with hazard identification, the first step in the risk management process. The five commonly defined steps in the risk management process are:
● Step One – Hazard identification (HAZID)
● Step Two – Risk evaluation or assessment
● Step Three – Development of risk management plan
● Step Four – Implementation
● Step Five – Risk monitoring
1-246 This section will explore the first three steps using the approach which parallels the formal safety assessment process described in section 8.2.
● Hazard Identification
This is the essential first step and is often the one which causes the most difficulty because it calls for time, commitment to the process and plan-ning. In the time pressured life of a ship’s officer or a marine surveyor, it is easy to commence at Step Two – the evaluation of risk based on the assumed hazards. To be effective time has to be allocated to the consid-eration of all relevant hazards and herein lies much of the strength of risk management – the avoidance of “we didn’t think about that”.
Hazard identification (HAZID) is probably best undertaken using a con-trolled brainstorming session; it is an area where lateral thinking can be useful and where everybody’s opinion is relevant. The hazards are often better understood by those who undertake the work rather than those who manage it. Some of the more formalised HAZID techniques are described briefly on the following page.
(i) Hazard and Operability Studies (HAZOP)
This methodology involves a structured, systematic and compre-hensive examination of installation/facility layouts and procedures, activity descriptions and/or process flowsheets. The study is usually
Module 1 Risk Management and Formal Safety Assessment (FSA)
undertaken by a multi-disciplinary team who are familiar with the process under an independent chairman. HAZOPs have the benefit of being particularly appropriate for identifying hazards in “soft” sys-tems involving activities and operations.
(ii) Failure Mode and Effects Analysis (FMEA)
Again a systematic approach, usually undertaken by small teams, undertaking a “bottom up” process, beginning with a system compo-nent and looking at the effect on the overall system. This may well result in a range of possible effects from a single failure. Thus a FMEA may examine component failure in a cooling water pump and at a different stage, the effect of pump failure on the machinery plant.
Above that there is the effect of machinery failure on the vessel as a whole. FMEA is mainly applicable to “hard” (or hardware) systems and can, for example, have a beneficial influence on the selection of ships.
(iii) Structured What-if Techniques (SWIFT)
“What if” is probably the most important question in the whole field of safety management. SWIFT is a group brainstorming based around a prepared hazard checklist, considering unplanned devia-tions from normal operadevia-tions.
● Risk Assessment
Here, form and evaluation is given to the hazards, they are assessed as risks and their consequences identified. There are both qualitative and quantitative methods of evaluating the risk posed by the identified hazards and the process involves considering the likelihood of occurrence in com-bination with their consequences. This information can then be ranked in a matrix of likelihood against consequence. Again, a simplified example of this can be to consider the risk of accidents to pedestrians crossing a road.
In a city centre street many pedestrians cross at random rather than wait-ing at a controlled crosswait-ing point, but since the speed of traffic is fairly low the pedestrians can normally avoid being hit by cars. However, since there are a lot of both cars and pedestrians the number of accidents will be cor-respondingly high although the injuries incurred will generally not be too serious. At the other end of the scale, few people attempt to cross a motor-way or autobahn on foot so the frequency is low but, due to the speed of the traffic, if there is an accident the consequence is serious. A typical ranking scale is shown on the following page.
Risk Management and Formal Safety Assessment (FSA) Module 1
From this scale, a risk matrix would appear as depicted on the following page.
Module 1 Risk Management and Formal Safety Assessment (FSA)
1-247 The risk matrix gives rise to a fundamental concept of risk management, the fact that all risks cannot be avoided. Thus there is an area of risk where the level of risk is unacceptable – (something must be done) – and an area where the level of risk is tolerable and tolerated. Between these areas is the region where risk is As Low As Reasonably Practicable (the ALARP region). Risk management is
Risk Management and Formal Safety Assessment (FSA) Module 1
about moving from the region of unacceptable risk into the ALARP area as cost effectively as possible.
1-248 In order to do this it is important to know the cause and effect of the incidents of risk and two techniques which are commonly used to assist this process are:
(i) Event Tree Analysis (ETA)
These use inductive, forward-looking reasoning commencing with an initi-ating event. Event trees tend to use a true/false logic and give a good pic-torial display of event sequences. A range of outcomes can be accommodated on one event tree and a given outcome can be the result of more than one event tree sequence.
(ii) Fault Tree Analysis (FTA)
The basic process in the techniques of fault tree analysis is to identify a particular effect or outcome from the system and trace this back into the system along the logical routes to the prime cause. FTA works “back-down” after an accident or unwanted failure has been identified ie EFFECT
® CAUSE mainly using AND/OR logic gates.
1-249 Thus it can be seen that ETA feeds forward from a given event whilst FTA works backwards from that event giving a detailed analysis of cause. An example where these techniques could be useful to a surveyor might be in the event of a vessel with a problem which could take it outside its class or other survey condition. Can it be safely accepted to sail to a more suitable port for repair? – a common request with which a surveyor will have to deal. The surveyor will want to know what caused the problem, for example was it an isolated incident or was it symptomatic of more serious problems? Equally, it is essential to know the possible consequences which might flow from the defect if the vessel is allowed to sail. While risk assessment does not provide the answer, the processes improve the ability to select the best solution.
Risk Management
When the risk has been assessed, its cause identified and its potential consequence identified, it is time to look at ways of controlling or avoiding the risk and/or its consequences. There are four main ways of doing this:
Terminate
Either by eliminating the potential for the event to occur or removing the exposed personnel. An example of elimination in the shipping industry might be to stop trading in certain areas or with certain types of vessel – an approach explored by some of the major oil companies with regard to transportation of their own cargoes on their own vessels.
Transfer
One of the most common approaches is to take out insurance to cover the potential losses, probably not a viable or tenable solution on its own. Another
Module 1 Risk Management and Formal Safety Assessment (FSA)
form of transfer can be found in the charter market, and again the example of the oil majors transferring the risk (of oil pollution) by chartering third party tonnage is a good illustration.
Tolerate
By considering the risk acceptable if it cannot be reduced further in a cost-effective manner. This has major implications in the area of personal safety and the promotion of a safety culture. Just as it is common to tolerate the crossing of the road without walking 100 metres to the pedestrian crossing, so many people working at sea tolerate potential danger of not wearing the proper safety equipment or using proper procedures.
Treat
By identifying reduction measures with the ideal being to lower the frequency of the accident first and to reduce the consequence second. This can be a most cost-effective approach because the cause can often be addressed by improved procedures and through improved education and training. The ISM Code can be described as falling within this solution.
1-250 A key element in the process is the economic assessment of the preventative action against the potential consequence. A cost benefit analysis is frequently used in order to compare the various solutions. The assessment of benefit or at least its translation into a comparative monetary value requires a degree of subjective judgment, and it is here that consistency is particularly important. It is difficult enough to agree on the value of the environment in a single, relatively cohesive social group (consider the inquiries into new road building schemes and the strong protest against cutting woodland to allow way for the new road).
It can be much more complex in a supra national context where the value attributed to life and liberty may vary dramatically.
1-251 Once a risk control method, or more usually, a package of measures has been identified, assessed and selected, the next stage is implementation. This needs to be handled with a degree of forethought and planning since frequently it will involve change. Change needs both planning and managing. In addition the effect will need monitoring and this may be a complex process since the implementation may change more than one parameter. Nevertheless risk management, whether it is simply a technique used when addressing operational problems in management or a safety case designed to assess safety measures in a complex offshore unit, is a valuable discipline which more than any other can prevent or help to cope with the unexpected.