Blog 97 - Deficiencies from 'AMSA' - The Beginning of the ISM Code - Internal Audit

A Cylinder Head with Exhaust Valve - Kept Ready for Use

“Marine Musings 30”

Neptune Rhodonite - 17th March 1996 to 12th May 1996

Vessel’s name changed to

NYK Providence - 13th May 1996 to 05th Oct 1996

Second tenure on NYK Providence from 08th Feb 1997 to 03rd Oct 1997

Deck Work

On practically all ships, I used to be very friendly with the Captains and would help in any manner I could. But on this ship, I was faced with an overbearing Captain who did not like my advising the Chief Officer on deck work. When the Chief Officer was taken to task by the Captain for taking advice from me, I started keeping away.

There was a Deck Fitter on board.

After joining the ship, as is my habit, I was inspecting the decks and deck machinery. Being a container ship, I knew I would find a lot of damage to railings, walkways, walkway gratings, the main deck and gangways.

Courtesy Marine Insight

The Mate, on joining me, started explaining that he was unable to cope with the damage caused to gratings of walkways forward and aft of each cellular hold, caused by the heavy twist locks and and securing chains being thrown down from a height by the stevedores in each port. The Deck Fitter was being used exclusively for these repairs and renewals and yet falling short.

Over the course of the following week, I was on deck with the Mate. We also checked the ventilation dampers of each cellular hold, air pipes’ wastage. The dampers, casings and motors were in a bad state. Many of the air pipes were wasted away and holed at the point of entry where it pierces the main deck. Quite a few had masking tape over the holed areas, painted over to seem normal to an undiscerning eye.

The Accommodation Ladders lowering / raising mechanisms seemed to be fine, all painted or greased, but were actually in very bad shape, which showed up on a thorough inspection. The Spindle - seen in the above image - has a very small angle of rotation when in operation. The top side of this spindle - which is actually just a strong pipe with flanges at either ends - looked fine, but the underside was so badly corroded and holed that it could give way and collapse at any time. Similarly, the brackets for the sheaves over which the gang way wires pass were all wafer thin.

As far as I am concerned, to see is to act. I helped the Mate draft out a plan for improving the standards. It most certainly required a repair team to sail with us for about 6 months. Men and material were needed for these repairs.

The ship was managed by NYK, Hong Kong. Barber’s were only providing the man power.

The Mate went to the Captain with the plan. The Captain, for reasons of his own, took umbrage over the fact that I was involved in all this planning and curtly told the Mate that “The Chief has no business recommending what needs to be done on my decks. Tell him to stick to the Engine Room” or words to that effect.

My inspections were more in line with what an AMSA (Australian Maritime Safety Authority) Surveyor or a Class Surveyor would check. Present conditions were such that we were likely to get a multitude of "Deficiencies" - later known as “Non Conformities” -, with a few of them possibly leading to a “No Permission to Sail”.

A few days later, I came to know that the plan for repairs and maintenance had not been sent to the Office and was summarily shelved by the Captain, without an explanation.

I was unfazed. In spite of any opposition, I had a job to do and would not be thwarted.

When the NYK Superintendent came on board in Hong Kong, I pointed out all the defects and told him that we would not pass an AMSA inspection because of these defects. I showed him many places where masking tape had been stuck on and painted over. I also told him about Chief Mate’s report and the planning that had not been sent to the Office.

Suffice it to say that we received all men and materials within a week. Work started in earnest when we were southbound to Australia. We worked the crew hard and gave them sufficient overtime, with which they were happy.

By then, they had practically stopped drinking and their work output had risen dramatically.

It was a good thing we started this job in earnest because, when we reached Australia, we had a very thorough AMSA inspection, where many of the defects that we had planned on rectifying came to light. But the Surveyor, seeing that we already had all the items already planned for rectification, our schedule, and our commitment towards rectification, which also included all the defects that the Surveyor had noted down for his own report, did not register any ‘non-conformities’.

This was followed by the Annual Inspection by Class, with the same plan being submitted and the same result.

Off the record, we were given six months to rectify all defects.

Usually, both AMSA and Class Surveyors would have recorded them as ‘Deficiencies’ and given a time frame for rectification of these defects.

But, seeing the earnestness with which we were repairing the defects, we were spared the ignominy and indignity of at least 50 ‘Non Conformities’.

Why were these important?

These Non Conformities go into the records of institutions, Governmental or otherwise, which are accessible to private parties.

With such defects (holed ventilation ducts, holed air pipes), the safety of the vessel is compromised in the event of a fire or in the event of bad weather where the vessel may be shipping heavy seas.

Apart from the safety and watertight aspects, a run down ship with known and recorded deficiencies, will not bring in good charters for the Owners. So there is a commercial aspect to it also.

The name change from “Neptune Rhodonite” to “NYK Providence” took place in May, which necessitated a thorough inspection by Class.

After 6 ½ months, I got off the ship at Singapore and flew home to Chennai. I recollect that there was a scare of a SARS pandemic when I signed off.

Second Tenure on the NYK Providence

I was joining back a ship that was now much better maintained, more or less on the basis of my detailed planning. These were the days before the advent of maintenance software that is now very much in vogue.

Over the years, I had developed and expanded a comprehensive maintenance system that included machinery and areas that were not in focus. Using “Lotus” software, I had managed to draw up a maintenance plan that had formulae input for hours, days and months. It had taken me several years to achieve some degree of clarity and efficiency in the “Lotus” plan. A book of that period, “Lotus for Dummies”, was my constant guide.

So, getting back to a ship where, on the previous tenure, I had instituted major changes to maintenance as a whole, gave me a sense of satisfaction to see my work bearing fruit. The Office staff in Hong Kong also diligently followed up on the repairs, with regular submission of reports and inspections.

Although the ship was 18 years old, even a seasoned seafarer would have mistaken her for only a 2 or 3 year old. The dead giveaways of her age were the outdated cellular holds for the containers and the anachronistic Main Engine and Generators which, although trouble free due to good maintenance, could easily be dated as 2 decades old.

Introduction of the ISM Code:

And the ‘check lists’ came marching in.

My first contact with the ISM Code had been about 2 years ago, through a well researched and well written article in ‘Marine Engineer’s Review’, which not only outlined but went into details of the ISM Code.

(I had been inducted as a “Fellow of the Institute of Marine Engineers, India” a few years back).

Whilst in Mumbai, I had picked up a copy of the ‘ISO 9000’ book, as also books on the ISM Code where, for the first time, “Quality” was given pride of place and became the primary object.

It took a leap of faith for me to visualise the transforming of the provisions of ‘ISO 9000’ into an elaborately coded Safety Management System.

Since ISO 9000 gave the freedom to each individual company to interpret the provisions of the ISO 9000 in its own way, I realised that different interpretations would be introduced to the unsuspecting seafarer. He was clearly going to be out of his depth and thoroughly confused in the initial stages of the introduction of the ISM Code.

I sought clarity in the various books that I had bought on the subject and slowly began to see the light at the end of the tunnel during the two years before the advent of the ISM Code on board.

Those two years were a learning curve for me.

I liked the simplicity of ISO 9000, the basics being

Plan what you do.

Do what you plan.

Document it.

Although this is exactly what I had been doing for well over a decade, continuously refining it in the light of experience, it had been rather haphazard at times.

I expected the ISM Code to bring coherence and structure, clarity of command, control and responsibility and, most importantly, accountability.

It was clearly implied in ISO 9000 that accountability came very high up on the agenda.

I intend expanding on this later.

Internal ISM Audit and a Shock:

A month or so into my second tenure on board, the vessel received two sets of manuals from the Owners, NYK, one set for the Deck Department and one for the Engine Department.. They enumerated the Safety Management System of the Company in thorough detail, which we were mandated to follow.

A letter accompanying the manuals stated that the Office (NYK) will be conducting an Internal Audit to see that procedural practices had been established and everything was in place for the forthcoming External Audit.

We were given 2 months to prepare ourselves for the Internal Audit - ourselves meaning the top four were to prepare themselves thoroughly and the others to lessening degrees as per their ranks.

Having waited for this, I plunged into it with vigour and ensured that we documented all aspects of Safety and Service, as stipulated in the SMS Manuals, quoting the relevant reference number, involving all the Engineers in the process.

We were well along our way.

In a way, being the pioneers to lead the way into the implementation of the ISM Code, practically all of the clerical work in drawing up instructions as per the SMS, formulating them, introducing them to all, making them familiar with it, with the relevant assigned engineer filling check lists after using the check lists as guidelines, getting them to sign along with my signature, preparing a whole new set of files, labeling them and keeping them in readiness, making and posting instructions in various areas - kept me extremely busy.

Nearly a week later, I came to understand that the Master and Chief Mate had not taken even one step in getting to know the SMS, let alone to implement it. During a dinner discussion, I outlined the importance of readying the vessel for not just an Internal Audit but also the External Audit, as we were a little close to the cut off date for full implementation of the ISM Code. I offered to guide them on a daily basis, so that we all, together, can show good progress in the implementation of SMS when the Internal Audit took place.

I was rather taken aback at the vehemence with which the then Captain stated his disdain and dislike for the SMS Manual Instructions and refused to do anything to prepare for the Internal Audit. His reading of the situation was that this ISM Code will soon die a silent death. Soon, if it were to continue eating into the time of the already overburdened seafarer, we would be filling up check lists for personal ablutions, he stated.

I tried my level best to persuade him otherwise, stating that the ISM Code will be intertwined with our lives for the foreseeable future and sections will only be added on, it becoming as relevant and important as SOLAS and MARPOL.

I failed to convince him and, later, we paid the price.

Nearly 50 days later, the Owner’s Designated Internal Auditor boarded the vessel for an inspection and audit of Safety Management procedures.

A new Captain also boarded the ship the same day.

The top four, the new Captain and the Company Safety Auditor all sat together at a conference table.

A barrage of queries followed asking

“Do you know this?”

“Explain to me”

“Have you made a ship specific check list for that?”

“Show me”

"Have you started documenting this, that and the other?”

“Show me”

We were getting deeper and deeper into the provisions of the SMS when, after a while, it struck the Auditor that I was the one doing practically all the answering and showing him the newly prepared documentation, while the others were mute.

He started asking the Mate and Master specific questions that they were unable to answer. The more he asked them, the less they knew. No documentation had been prepared.

We had been at the table for almost four hours. The Auditor was frustrated and angry that the vessel was not prepared at all for a Safety Audit. In his frustration, he threw his anger at me saying

“Chief, you seem well prepared for the audit. How is it that the Captain and Mate are totally ignorant of the SMS? Aren’t you all sailing on the same ship?”

My reply, equally angry, was “Why are you asking me? They are here in front of you. Ask them yourself.” In order to not let down colleagues, I refrained from telling him that I had tried to persuade them and had wanted to help them, to no effect.

The Auditor was pretty astute, because he realised that a lot of unsaid things were in the air, when he saw me lose my temper for the first time, having been most cooperative all this while.

We adjourned for lunch and met again. The old Captain wanted to leave the meeting for the handing over to the new Captain, as we were to sail the same night.

Before they left, a frustrated and disappointed Auditor told us

“As the cut off date for implementation if the ISM Code for container vessels is very near, fleets the world over are finding it difficult to obtain the services of a Classification Society Surveyor to carry out the External Audit. There is a long waiting list.

Your ship is listed for the External Audit in a month’s time. The Certification that is given by Class at the end of the External Audit is as important as your SOLAS or MARPOL certificate. If you were to fail the External Audit the first time around - which is the most likely scenario, seeing the lack of preparedness of this vessel - getting a second audit done before the implementation date will be extremely difficult, as the whole world is clamouring for External Auditors and the Classification Societies are hard pressed to keep up.

I do not know what you are all going to do or how you are going to come up to the standards needed to pass the External Audit with flying colours and obtain the ISM Certification. After the ISM Code is implemented and comes into effect, ships without this certificate will not be allowed to sail.

I am asking the new Captain to follow the lead given by Chief AR and put in the needed effort to complete the External Audit satisfactorily. You have just one month’s time”.

The old Captain was roundly chastised for his lack of realisation of the importance of the Safety Management System and his zero contribution in implementing the SMS clauses.

After the two Captains left and the Chief Mate went to supervise the cargo work, the Auditor and I thoroughly reviewed the SMS manuals.

Having taken a lot of notes, I pointed out a number of flaws in the manuals, of omission and commission. In some cases, the thought processes behind the relevant sections were based on false suppositions. We had a long discussion. At the end, he said that he will be contacting me on a daily basis from the Office to ask for my opinion on sections of the SMS, as everything was in its infancy and needed good, solid input from experienced personnel.

I assured him that we will be ready for the External Audit in all aspects.

We parted amicably.

===== Continued in Blog 98 =====