CBT 1 - Understanding the ISM Code

1. Introduction – Management System

 Abbreviations

 ISM - International Safety Management System

 DOC - Document of Compliance
 SMC - Safety Management Certificate
 ISMA - International Ship Manager Association
 ISO - International Standardizing Organisation
 DP - Designated Person
 Management Systems

At the end of this introductory session,

participants should be able to define what is
meant by a “Safety Management System” (SMS);
It’s role in “Quality Management”;
The functional requirements of a Safety or Quality
Management System; and
Understand the requirements for focusing on the
software elements of the system rather than on
the hardware elements as in the past.
What is Safety?

Safety can be defined as: -

The state in which the risk
of harm (to persons) or
damage (to property or the
environment) is limited to
an acceptable level.
What is Safety?

It can also be thought of as

“Freedom from Danger”;
In the maritime sense, this
refers to freedom from
danger for the ship, the
crew and the environment.

Safe Ship Management is

the major aspect of
Quality Ship Management.
Managing Safety
It is never possible to eliminate all
risk, but through careful and
systematic management of onboard
activities, we can considerably reduce
the risk of accidents occurring.
Ways to control or eliminate risks
and dangers include: -
Following Procedures;
Proper communication;
Use of PPE;
Planning & Supervision of Work;
Training/Familiarisation; &
Permits to Work, etc
Inter-Relationship

Safety Management Systems

are 85 % of

Quality Management Systems

What is Quality?
Quality is the totality of features and
characteristics of a service to satisfy stated or
implied needs;

Examples of features & characteristics of a

shipmanagement service are: -

– Price, Economy of Use, Experience, Safety,

Communication & Reputation.

You as crew onboard have a direct

impact on all of the above 6 items.
What is Quality Management?

A Quality Management System is specifically

designed to offer independent assurance that
the supplier (SHIPMANAGEMENT
COMPANY) is capable of consistently
delivering the service to the specifications
required by the customer (OWNER OR
CHARTERER).
Hardware v Software
What has the greatest effect on safety ?

The provision of equipment (hardware), does not, in

itself make the ship safe. It merely provides that the ship
has the capabilities to prevent some eventualities from
endangering the ship.

Of more significance, is the ability of the crew

(software) to operate a ship and its equipment in a
safe manner.

Studies of casualties have shown, that on a number of

occasions, the human element was a major
contributing factor (up to 85%)!
Hardware v Software
Previous regulations focusing only on hardware
(remember: equipment focused) include: -
SOLAS;
MARPOL 73/78;
Load Line;
ILO 147; &
Classification Society Survey Rules.

Recent legislation (the ISM Code & STCW 95) focuses on

the ability of the shore management and crew onboard
(remember: software) to operate the ship and its
equipment in a safe manner, with continuous regard for
environmental protection.
Safety Management

Activities of shore based organization that

determines the safety policy, objectives,
responsibilities, support and controls the work
activities of the crewmembers onboard;

It is the responsibility of all levels of a

company’s management. Its implementation,
involves all personnel in the organization;
Company Objectives
Safety Management objectives of the
Companie`s are to: -
provide for safe practices in ship operation and
a safe working environment;
establish safeguards against all identifiable
risks; and
continuously improve the safety management
skills of personnel ashore and onboard,
including preparing for emergencies, related
both to safety and environmental protection.
In Addition

The Safety or Quality Management System

must ensure: -
compliance with mandatory rules and
regulations; and in addition
that applicable codes, guidelines and
standards recommended by IMO,
Administrations, Classification Societies and
other maritime industry organizations are
taken into account.
Why We Have A System?
Because most accidents occur due
to violations of basic safety
principles; or
the failure to follow established
work instructions or procedures; or
due to lack of proper training or
familiarization.
Having a written system onboard
ensures that all crew are given
sufficient guidance and training to
operate the ship the way the
company wants it done, there is no
room for flexibility.
Functional Requirements of a Safety
Management System

A Safety & Environmental Policy;

Defined Levels of Authority between and amongst Shore
and Shipboard Personnel including the Designated
Person;
Clear statement regarding Master’s Authority;
Written Instructions & Procedures for tasks onboard
related to safe operation of the ship and protection of
the environment;
Maintenance, Testing & Inspection program;
Emergency Preparedness & Contingency Planning;
Functional Requirements of a Safety
Management System

Procedures for Reporting Accidents & Non-

Conformities;
Crew Training & Familiarisation;
Procedures for Internal Audits, Master’s & Management
Reviews;
Record Keeping; and
Document Control Procedures.
The 3 “C’s”
Commitment, Common
Sense & Communication;
These are the cornerstone
of onboard quality &
safety management;
Communicate with each
other at all times; &
Apply common sense to
all aspects of your work;
If you’re unsure - ASK.
Commitment
Without your commitment, a Safety and Quality System can not work!

Effective safety
management is hard work
but not impossible;
Do not leave safety to the
Captain, Chief Engineer
and Chief Officer;
All seafarers have a
responsibility for the safe
operation of their ship and
for pollution prevention.
Recap - Management Systems

What is a Management System ?

The application and documentation of “Common

Sense”.

Basis for more effective management control.

Requires commitment from the top.

Requires total company involvement.

 2. The ISM Code

The International Management Code for the

Safe Operation of Ships and for Pollution
Prevention
or
The International Safety Management Code
or
The ISM Code
 Part 2 is aiming at
At the end of this session, participants: -
should be able to state the the objective, purpose and intent of the ISM
Code;
will have an insight into the history and relevant dates relating to the
development and implementation of the Code;
should understand how the ISM Code translates into the Operations
Manuals onboard the ship;
will understand the ISM certification arrangements for both Company
and ships; and
will also be made aware of the benefits and advantages to a
shipmanagement company in complying with the ISM Code.
The ISM Code - What is it?

The only internationally

accepted standard for the
safe management and
operation of ships & for
pollution prevention;
Chapter IX of SOLAS
convention;
Therefore compliance is
mandatory under
international maritime
law.
Objectives of the ISM Code

• to ensure safety at sea;

• the prevention of human

injury or loss of life; and

• the prevention of damage to

the environment,
particularly, the marine
environment and to property.
 Purpose of the ISM Code
Is to ensure appropriate management by shipping companies,
covering ALL aspects of their shipmanagement operations: -

Cargo Operations;
Navigation;
Machinery or Engine Room Operations;
Maintenance;
Testing & Inspection of Equipment of Machinery/Equipment;
Emergency Preparedness & Contingency Planning;
Recruiting, Selection and further training of Crew;
Control of all documentation; &
Supplying of Stores & Spare Parts, etc.
To whom does it apply?
Company management
from the very top
level; to
All shore staff;
The Master;
Officers; and
Ratings onboard the
ships.
 Intent
• The ISM Code is intended as a means of encouraging
“continuous improvement” of safety management
skills for persons within the maritime industry, that
can be applied to all ships;

• The Safety Management System becomes a “living”

system and must allow for continual updating
through reviews, audits and a reporting system being
established between ship and shore.
Continuous Improvement
Nothing is perfect;
As in life, we are always striving to
make things better;
The management system requires
that companies learn from past
experiences and take steps to
prevent the recurrence of past
problems;
Be open to suggestions for
improvement in your work; and
Look for ways to improve safety
onboard and report them.
 History
• IMO Resolution A.647 (16) - 1989.
“Guidelines on Management for the Safe Operation of Ships and for Pollution
Prevention” was the first set of management guidelines for the marine
industry.
• IMO Resolution A.680 (17) - 1991.
Recognised the need for an appropriate organization of management to
respond to the unique needs of shipboard personnel.
• IMO Resolution A.741 (18) - 1993.
A shift from the IMO philosophy of hardware regulations to the software
element of ship management.
 Relevant Dates
• Adopted into SOLAS in 1994.

• Mandatory for passenger ships, including high speed

craft, tankers, bulk carriers and high speed craft
carrying cargo of 500 grt and over on 1st July 1998.

• Mandatory for all other cargo ships, and self

propelled mobile offshore drilling units of 500 grt
and over on 1st July 2002.
Why the Manuals / Electronic Systems ?

 The ISM Code gives guidance only, it

does not tell the Company how to
operate their ships;
 To comply, the Company using its
specialized knowledge and
experience has written their own
Safety or Quality Management
manuals for their fleet;
 These manuals cover ALL aspects of
shipboard operations and shore
based support;
 They clearly define the way the ships
are to be operated;
The Safety or Quality Management System

 Other companies manuals

may look different, but the
intent is just the same, it’s
just that different companies
operate in slightly different
ways;
 Once implemented onshore
and onboard, the system is
audited for compliance with
the ISM Code requirements;
 Once compliant, a certificate
is issued.
ISM Certification
The shipmanagement company is
issued with a Document of
Compliance (DoC), this confirms that
their management system complies
with ISM requirements;
Each ship, upon compliance, will be
issued with a Safety Management
Certificate (SMC), this confirms that
the ship complies with the company’s
management system;
Both certificates are valid for 5 years,
but their status is reviewed on a
regular basis.
ISM Certification
All seafarers must be aware
that without a valid SMC,
your ship will not be allowed
to trade (sail);
A ship that cannot sail does
not need a crew - jobs will be
put at risk;
Commitment to safety is not
a one time event, it is
ongoing everyday whilst you
are onboard and on vacation
The ISM code applies to all
Ship managers around the
globe with the same
standards and requirements!
 What are the Benefits ?
Quality/Safety awareness program for all staff;
Significant savings in efficiency, productivity, insurance, and an
increase in profit and customer confidence and satisfaction;
Less exposure to critical liability claims in the event of a major
casualty
Avoidance of duplication and waste of effort;
Continuous improvement of the system and therefore company
performance; and

Improvement in morale throughout the company.

 What are the Advantages ?
Reduction in operational errors, therefore costs;
Reduction of accidents to personnel;
Protection and safe guarding of property
Protection of our nature and environment;
Formal control of the system and of non-conformance;
Can be used as a marketing aid;
International acceptance of the company’s management standard;
and

An accepted means of interface between the Client and the Company

regarding the quality of service.
 Part 2 - review
During this session, we have: -
stated the the objective, purpose and intent of the ISM Code;
studied the history and relevant dates relating to the development and
implementation of the Code;
explained how the ISM Code translates into the Operations Manuals
onboard the ship;
explained the ISM certification arrangements for both Company and
ships; and
covered the benefits and advantages to a shipmanagement company in
complying with the ISM Code.
 Part 3 –
The HSC Quality Management System

Hanseatic Shipping Co. Ltd

 W a r n i n g !
• Quality & Safety Systems are living documents
that are continually updated and modified to
improve their ease of use and effectiveness;
• Any reference to the Hanseatic QMS is correct at
the time of writing this presentation;
• The information given here referring to the HSC
QMS must treated with caution, reference must
always be made to the latest appropriate
shipboard documentation or electronic stored data
when cross referencing with this presentation.
ISMA

The International Ship

Managers Association;
Founded by HSC and four
other leading ship
management companies in
1989;
Objective was to promote the
highest standards of safe ship
operation and environmental
protection, at a time when no
other standards for safe
shipboard operations existed.
The ISMA Code

ISMA members wrote their own guidelines for

These guidelines were issued before the ISM

Whereas the ISM Code focuses on the ship

 Which Code applies?

Hanseatic’s QMS complies with both the ISM Code and

the ISMA Code. Our offices and ships will therefore be
audited against the requirements of BOTH codes;
All ships are audited in line with the ISM Code as this is
a mandatory requirement;
Only selected ships are audited against ISMA
requirements - this is sufficient for HSC to prove
compliance;
However, we at Hanseatic firmly believe that our
compliance with the ISMA Code produces a higher
quality ship management service to our clients.
 HSC Objectives
Closer Communication - leads to better understanding
for all concerned regarding safety & environmental
issues;
Strict Compliance - with Company policy, mandatory
rules & regulations;
Understanding - Company policies to ensure safety of
human life and protection of the environment;
Accepting Criticism - on day to day working practices
both onboard and ashore; &
Continuous Improvement - in all that we do.
The Onboard Quality Management System

 Composed of: -
- The Quality Manual;
- Safety & Environmental Policy;
- Work Procedures and Instructions
(Fleet Manuals Vol 1, 2 & 3 +
Operational Procedures and
Contingency Plans Manual);
&Forms and Records.
Think of it as a shipboard operation
& safety reference library. It is
available for use at any time.
Computerized SMS on most FM
ships since 2003 (Infomanager)
ISM Chapter 2 - HSC Safety & Environmental
Policy

It is a statement of
Hanseatic’s commitment
to operate ships safely and
also to protect the marine
environment;
We also make a
commitment to you as our
crew onboard that we will
extend all possible support
in order to ensure that your
ship is a safe and healthy
place to work;
HSC Safety & Environmental Policy

In order to meet our

commitment, we require
all our seafarers to follow
all instructions/procedures
provided in our Quality
Management System.
Only this way can we be
sure that our ships are
operated to consistently
high safety and pollution
prevention standards.
HSC Safety & Environmental Policy

Each policy is signed

by the HSC senior
management; &

It is available in
various locations
around your ship;

Study it and
remember what it
stands for.

(It is a key question in every audit!)

ISM chapter 3 – Responsibilities & Authority

Anyone within the

Company who has a task
related to safe ship
operations, must have
their duties &
responsibilities defined;
This also includes any
persons who, should they
do their job wrongly,
could cause an accident;
It therefore applies to all
crew onboard the ship.
Responsibilities & Authority

Refer to Fleet Manual Vol 3,

Chapter 3, Appendix 01
where main duties and
responsibilities for all crew
onboard ship can be found;
It is YOUR responsibility to
know what others expect of
you when you work;
If you have questions,
address them to your Head
of Dept.
Responsibilities & Authority

Responsibilities & Duties are stated in

order to avoid misunderstandings, avoid
duplication of work and to ensure that all
tasks are completed by the appropriately
trained and competent crewmember;
They cannot be changed without the
permission of the Company;
Dept Heads are responsible for ensuring
compliance.
ISM chapter 4 – Designated Person

Is the person
onshore that has
been placed in
charge of monitoring
the safe operation
and pollution
prevention activities
of all the vessels
under management.
Designated Person

He has direct access to the

highest levels of company
management;

He is also responsible for

ensuring that the
management makes
adequate resources and
shore based support
available to the vessels.

Knowing his Name and

Contact details is essential!
It is a key question in every audit!
Designated Person

He is part of the QMS Dept and is

“your link” between the ship and
the shore;
He is your point of contact if you
require any assistance regarding
safe ship operation or pollution
prevention;
He has the technical expertise of
Hanseatic behind him to help
answer your questions relating to
the implementation or compliance
with the HSC Quality Management
System onboard.
 HSC Designated Person (DP)

Captain David Bell

ISM chapter 5 - Master’s Responsibility

To implement and maintain the

HSC Quality Management
System onboard the ship;
To ensure that ALL crew
understand and follow the
company instructions;
To manage all activities onboard,
ensuring safety and pollution
prevention at all times; and
To motivate crew to constantly
improve and demonstrate their
safety knowledge.
Master’s Responsibility

the Master must verify that ALL

Company requirements are
followed;
that he carries out a review of
the Quality Management System
during each contract onboard.
ISM chapter 5.1.5 - Master’s Review

Refer to Quality Manual Chapter 1, Section 3.5.1 (v);

As the system is a “living system” that is constantly
capable of improvement, the Master through the
Shipboard Management Committee is required to
provide feedback to the Company regarding the
effectiveness of the system onboard;
As it is the ship’s crew that follow the system on a
daily basis, he is best placed to give detailed
information regarding areas for improvement.
 ISM chapter 5.2 - Master’s Authority

Refer Quality Manual Chapter 1, Section

3.5.1 (i);
The Master is issued “over-riding authority”
in matters relating to Safety, Pollution
Prevention & Requesting Company
assistance as required!
ISM chapter 6 - Resources & Personnel

It is Hanseatic’s responsibility to
supply crew that are qualified,
certified for the rank and
medically fit;
The Master must be properly
qualified for command; and
Hanseatic also makes available
resources for training and
upgrading of crew knowledge.
ISM chapter 6.3 - Onboard Training &
Familiarization

All seafarers must be

familiarized with the ship,
the safe operation of
equipment onboard and
their duties/responsibilities
under our Quality
Management System;
In order to achieve this,
onboard training must be
carried out regularly.
Onboard Training

Training must not be limited

to Fire & Boat drills;
It must include the correct
use of all machinery and
equipment onboard as well
as;
The training of crew for their
next rank; &
All onboard training is to be
recorded (Master’s File 3.7).
ISM chapter 6.5 – shore based Training

Hanseatic is responsible for

providing training which
may be required in support
of the QMS;
Training Requirements for
ship’s crew must be
identified and reported on
the Appraisal Report (Form
22);
HSC Agencies will then
arrange training during the
vacation period.
ISM chapter 7 - Procedures & Work
Instructions

Clearly states how HSC wants

the ship to be operated;
Contains: -
- Details of Responsibilities;
- Instructions on how to carry out
critical tasks in order to promote
safe ship operations and protect the
marine environment;
- Record Forms and Checklists
- Good safety advice.
The Quality Manual

Presents a general overview

of the Quality Management
System;

Known as the “what”

manual;

Describes, in general, what

management controls the
Company has put in place,
to meet the ISM Code
requirements.
Fleet Manuals

Know as the “how”, “who”, “when” &

“where” manuals or the shipboard
operations manuals;
Fleet Manual Vol 1 contains
information on Safety & Risk
Management;
Volume 2 contains information
relating to the Technical Management
of the vessel; &

Volume 3 contains information

relating to General Onboard
Administration and Cargo Matters.
 INFOMANAGER (IM)

In 2003 HSC has introduced an electronically based SMS on

most vessels of the FM fleet which is deemed to greatly reduce
the paperwork on board our ships.

Alterations and amendments in Forms and Procedures

will be updated directly and are immediately available online.
IM becomes an approved “controlled” tool!
Manuals, on vessels equipped with IM will automatically become
uncontrolled.
Any printout from IM will be an uncontrolled document!
Operational Procedures & Contingency Plans

Part general and part ship

specific;
To be reviewed by shipboard
management committee and
any suggestions or
requirements for change
must be presented to the
QMS Dept and/or Designated
Person.
Operational Procedures & Contingency Plans

Contents:
Operational Procedures;
Cargo Handling Procedures;
Distress Message
Transmission;
Fire Detection & Protection
System;
Security Procedures;
Emergency Contingency Plans;
Resource Conservation;
Mooring & Mooring Winches; &
List of Essential Equipment.
Record Keeping - Master’s File 5.2

It is necessary to keep a record of

all activities that have been
undertaken as part of the QMS;
Can use reports, forms, checklists
and log book entries;
Required by any Quality Assurance
System as it provides evidence
that the system has been followed
correctly;
Auditors will examine samples of
shipboard records during the audit.
Record Keeping
In the event of an accident,
investigators will look for the
“paper trail”;
Documents in a chronological order
showing what, when, how, who,
where and why things happened;
Good records will help protect the
parties that you represent from
un-necessary claims;
More importantly, they will show
that you acted with due diligence.
ISM chapter 8 - Emergency Preparedness

Even on the best managed

vessels, things can still go
wrong;
Crew must be confident to
respond to any type of
emergency situation;
There are programs for
emergency drills and
training in the use of
emergency equipment.
 ISM chapter 9 –
Reporting & Analyses of Non Conformities,
Accidents & Hazardous Occurrences

Onboard safety will only get

better by reporting what
has gone wrong and then,
making changes to improve
things;
You must report ALL non
conformities, accidents and
hazardous occurrences to
your Dept Head.
Non Conformities

Defined as:
An event where something or
someone has not complied
with an element of the HSC
QMS; not in accordance with
system or procedure
It maybe potentially
hazardous and requires
improvement to prevent
recurrence;
Usually highlighted as a
result of an inspection.
Accidents

Accidents are defined

as “unexpected
happenings where
someone is injured,
something is damaged
or pollution has
occurred”;
Hazardous Occurrences (Near Miss)

Are
situati
ons
that
have
the
potent
ial to
beco
me
accide
nts;
This
time
we
were
lucky,
the
dange
r was
identif
ied
before
it
result
ed in
an
Hazardous Occurrences (Near Miss)

Occur frequently in
everyday life;
These are the situations
that we must learn from;
This time, no injury,
damage or pollution
resulted, however without
improvement - who
knows what will happen
the next time?
ISM 9.2 – Corrective Actions

The work instruction or

procedure may require review,
amendment or updating;
More supervision or training
maybe required; or
Better quality equipment may
need to be provided;
Whatever corrective action is
decided, it must prevent
recurrence of the original
deficiency.
Benefits of Reporting

Lessons are learnt, updates and

changes to the system are made
and passed on to other vessels
within the HSC fleet;
Statistics can be compiled and
provided to 3rd parties upon
request, promptly and accurately!
Reoccurrence might be avoided on
other ship under HSC management
ISM chapter 10 - Maintenance of the Ship
& Equipment

Planned Maintenance
Systems are in place on
your ship to ensure that:
- The ship and all onboard
equipment is kept in good
operating condition;
- Standby equipment is
regularly tested and ready
for immediate use.
ISM 10.2 - Inspection & Test

Routines for the inspection and

testing of all shipboard
equipment are in place;
Ensure that these routines are
followed and records of
inspection & test are maintained;
Any deficiencies discovered must
be reported to HSC and rectified
as soon as possible.
ISM 10.2 - Reporting of Maintenance Non
Conformities

Machinery failure, repair or

maintenance must be
reported to the Technical
Superintendent;
Only if the equipment
failure affects safety of the
ship or pollution
prevention, should these
deficiencies be reported to
QMS using forms 106/107.
ISM 10.3 - Critical Machinery/Equipment

Is identified as “machinery, the

sudden failure of which may
place the ship or the crew in a
hazardous situation”;
The RMS provides specific
maintenance aimed at
promoting the reliability of all
equipment and systems
onboard the ship.
ISM chapter 11 - Documentation

All management systems

involve paperwork;
Instructions, records,
checklists & requisitions, etc;
Also includes maker’s
instructions and ship’s
plans/drawings;
Effective document control
helps keep all this paper in
order.
ISM 11.1 - Document Control

Control is exercised to ensure

that ALL information in use
onboard is the latest edition;
Changes to any documents
are reviewed and approved by
authorized persons;
Obsolete documents must be
removed.
Copying Controlled Documents
Copies of selected pages can be
made for training purposes;
i.e. duties/responsibilities or
specific procedures;
Any copied documents MUST be
clearly marked
“UNCONTROLLED”;
Copied pages are to be used for a
short time only and then disposed
of.
Printouts from Infomanager are
uncontrolled documents
 Directives & Circulars

Issued by individual departments within HSC;

Advises manual holders of the parts of the

system that have been updated or revised;

As such, the information contained in the

Directive or Circular supersedes all the
applicable contents within the manuals;

For ease of reference, Masters must indicate

sections of the manuals that have been
superseded by a Directive or Circular.
Directives & Circulars

Printed on blue and green paper &

kept in a separate file for ease of
reference;

Crewmembers must review all

latest Directives & Circulars
(Master’s File 5.2) upon re-joining
the vessel - this will bring you up
to date with latest revisions;

Directives and Circulars are

incorporated into the QMS at the
end of each year, so as to reduce
constant revision of the system.
ISM 11.2 - Documentation

Hanseatic has established a filing

system for your ship;
Ensure that all files, documents
are labeled and stored in the
correct location. Refer to FM Vol 3
Ch 2 - Senior Officer’s Files;
Filing cabinets or lockers must be
clearly labeled, this will make
reference easier and assist with
onboard organization.
ISM chapter 12 - Company Verification,
Review & Evaluation

Company confirms the

effectiveness of the system
by performing audits;
Quality & Safety Officers
will audit your ship at least
once per year;
An audit is a means of
comparing the actual
practice onboard against
the written procedures.
ISM 12.1 - Audits

Any discrepancy between actual

practice and written procedure
will be noted as a Non
Conformity and will require
corrective action to remedy the
deficiency;
Internal Audits are useful tools
for identifying system
weaknesses and for ensuring
continuous improvement.
ISM 12.2 - Management Review

After a series of shipboard

audits, patterns of non
conformity can be established;
These are used by
management to review the
effectiveness of the system;
Other data used includes
Master’s Reviews, Accident &
Hazardous Occurrence Reports,
3rd Party Audit Reports, etc.
ISM 12.2 - Management Review
ISM chapter 13 - Certification, Verification
& Control

A copy of the DoC must be

available onboard the ship;
The original SMC must be
available onboard the ship;
Both certificates are trading
certificates
The Hanseatic Quality Management System

You have just completed a basic introduction

into:
The 13 elements of the ISM Code; &
How the 13 elements have been incorporated
into the Hanseatic QMS.
In order to become fully familiar with the QMS,
you must make time onboard to read the
manuals / consult Infomanager and apply what
you read.

With the knowledge you have now, please take

the questionnaire and check on all questions
again!