Captain management review is one of the important means for captains to implement ship safety and anti-pollution management and ensure the effective operation of ship safety management system (hereinafter referred to as SMS), through the captain management review can find the weak links of SMS in ship operation, in order to take targeted measures to promote the self-improvement of the system. Let's look at two typical cases of non-conformity issued by the audit:
NO.1
Cases of non-compliance
Non-conformance case 1:
"Captain Management Review SMS Procedure" (SP0501): "5.1.3 Captain Review Content and Record Form "Captain Management Review SMS Report", only the equipment, management, documents do not meet their statistical analysis requirements, that is, the conclusion of the review is reached. Failure to comprehensively analyze the ship operation, good practices and existing problems of SMS in terms of resource security, training, operation, emergency response, equipment, etc., and not stipulating the processing requirements for equipment non-conformity found during the review, may lead to one-sided understanding and implementation of the requirements of the captain's review of the SMS during implementation, which does not comply with the provisions of NSM Rule 5.1.5.
Non-conformance case two:
On January 8, 2020, the comprehensive supervisor received the "Captain Review Report" reported by the "Jianhang xxx" ship, and put forward 2 opinions and suggestions on corrective measures for the defects in the system. After the interview with the comprehensive supervisor, it was confirmed that the shore base only received the archive after receiving it, and did not deal with the corrective action suggestions made by the captain. Does not comply with the company system document SP0501 "Captain's Review Procedure" 7.3 "... The captain shall fill in the "Captain Review Report" and report to the comprehensive supervisor, and shall propose corrective measures for the defects in the safety management system found in the review. "And 7.4" designated personnel promptly organize shore-based personnel to analyze and study the feasibility of corrective measures proposed by the captain's review, put forward handling opinions, and then feedback to the relevant responsible persons by the comprehensive supervisor for implementation. ".
NO.2
Case studies
The non-conformity case one is the non-conformity issued for the document review, reflecting two problems in the procedural documents: one is that the description of the content of the captain management review is not comprehensive, and it fails to fully cover the operation of the ship, the evaluation of the shore-based support of the system and the evaluation of THE SMS itself; the second is the lack of provisions for the completion of the follow-up processing of the captain management review, which cannot guide the ship-shore work, and the requirements for the captain to report the defects found in the system to the shore management department should be clarified, and the reporting method should be determined.
Non-compliance case two is the activity is not in line with the proposal for the captain's management review, the shore-based supervisor did not report to the designated personnel for follow-up processing in a timely manner, the management review failed to achieve results, resulting in the review workflow in the form, if the captain put forward the request for resources and shore-based support, the shore-based department did not respond in a timely manner, but also violated the ISM rule "6.1 The company shall ensure that the captain: ... 3 receive the necessary support in order to reliably discharge its duties" provisions.
The above problems are common non-compliance situations found in the audit, so how should we effectively carry out the captain management review work and provide positive feedback for the effective operation and self-improvement of the system?
NO.3
Rules required and understood
Let's first look at the requirements of the ISM Rules for captain management review:
ISM Rules "5 Responsibilities and Powers of the Captain."
5.1 The company shall specify in document form the following responsibilities of the master:
...... . 5 Review the safety management system and report its defects to the shore management department. ”
【Understanding】 "Review the safety management system and report its defects to the shore management department" is to require the captain to examine whether there is a problem with the structured and documented safety management system established by the company (as stipulated in the system documents) according to the actual situation of the safety management system operating on the ship. "Review" needs to be carried out in a certain form and at appropriate intervals, and the defects in the system that are found at any time and reported at any time should be summarized at the time of review. The frequency of the captain's review should be higher than the frequency of the company's review, and the captain usually has to carry out a review before leaving office.
The Captain's "Review of the Safety Management System" differs from the requirement in Rule 12.2 of this Rule that the Company "review the Safety Management System" (see Chapter 12 for understanding) if necessary. The captain's review shall be used as an input to the company's review.
NO.4
The captain manages the timing of the review
Beginning with the 2010 ISM amendment, the captain should be required to conduct a "Periodically" management review (the NSM rules do not require a regular period), but the exact time for the captain to conduct a management review is not specified.
According to the requirements of system operation, the ship review should be carried out after the internal audit of the ship and before the company's effectiveness evaluation, and the captain's review should be used as an input item for the company's effectiveness evaluation. Therefore, taking into account the internal audit of the ship and the effectiveness evaluation of the company, the captain management review is recommended to be carried out at least once a year, but if the captain's term of office is less than 1 year, a management review should be carried out before leaving office. In addition, when a ship has a grade accident or is stranded by PSC in port, in principle, a management review should also be carried out to find out the reasons from the management point of view to improve future safety management.
NO.5
Captain manages review content
The "Captain's Review" shall meet the requirements of the ISM/NSM Rules, the content of which may be adapted to the needs of the shipping company and shall generally consist mainly of, but is not limited to:
(1) The operation of the review system in the ship mainly includes the familiarity of the ship with the relevant SMS documents, whether effective measures are taken to improve the operation skills and whether the ship implements THE SMS regulations strictly, etc., including personnel training, key operations, emergency drill training and equipment maintenance, etc. For the daily work at any time, the defects in the system reported at any time should be summarized during the review.
(2) The evaluation of shore-based support mainly includes whether the crew provided by the company is certified, qualified, healthy, whether sufficient technical support is provided to the ship, whether sufficient accessories and materials are provided to the ship in a timely manner, and whether the ship's reflection problem is solved in a timely manner.
(3) Evaluation of SMS itself: mainly including the coverage of the operational system documents of the system documents, the compliance of the system documents, etc.
NO.6
Captain management review implementation steps
1. Preparation for the review meeting. The captain should formulate a management review meeting plan in advance, list the content, time, place, participants, etc., and require each department to prepare the information required for the meeting. According to the requirements of the captain's plan, the various departments of the ship prepare relevant materials in advance as an input of information for the captain's review. The captain analyzes and sorts out the information of various departments of the ship, lists all the topics that need to be reviewed and notifies the participants in advance.
2. Hold a management review meeting. The meeting is presided over by the captain, attended by the management level and operation level crew, and the participants should report the topics to be reviewed according to the requirements of the plan, discuss item by item according to the operation of the system, and put forward suggestions for improving the system. Before the end of the review meeting, the captain should summarize the defects and improvement measures found in the SMS operation during the review.
3. Prepare the captain management review report. The review report shall include: the purpose, basis, content, date of the review, the participants, a brief description and conclusion of each review item, the non-conformities found in the review that affect the effectiveness of the system and the corrective measures that should be taken, the rectification date, and the suggestions for the company to revise and improve the system documents.
4. For the non-compliance found in the captain management review, the relevant departments and responsible personnel should be required to conduct cause analysis, rectification and verification and rectification in accordance with the corrective requirements of the non-conformity in the SMS document; if the system document requirements are found to be contradictory or unreasonable with the actual operation on the ship during the captain management review, the company should be proposed to modify the system documents in accordance with the company's SMS file control requirements.
5. After the captain's management review report is examined and approved by the captain, it is issued to the various departments of the ship and submitted to the company's designated personnel.
In short, through the effective captain management review, it is enough to find out the shortcomings of the system and the weak links in the implementation process of the crew, which plays an important role in the continuous and effective operation of the captain monitoring safety management system on the ship, and is also the basis for the continuous improvement of the safety system.
Editor: Guangdong Maritime Safety Bureau Wang Yanlei
Review: Guo Weibin, Zhu Kexin