002 Procedures 30-09-22

Prime Tanker Management Inc.
Prime Gas Management Inc.
Manual Code: PRO (002)
IMS PROCEDURES MANUAL
Authorized by
Chief Operating Officer (COO)
George A. Kouleris
DOCUMENT CONTROL
No part of this document may be reproduced, utilised, stored in any retrieval system or transmitted in any
form or by any means, electronic or mechanical, including photocopying, recording or by any information,
storage or retrieval system without the permission of Prime Tanker Management Inc and Prime Gas
Management Inc.
GENERAL
IMS Procedures Prime Gas Management Inc.
Manual (002) Revision: 17
GENERAL
Eff. Date: 30/09/2022
RECORD OF AMENDMENTS
Amendment Date Position /
Section / Page No. Date Issued Initials
Number Amended Rank
All Procedures
00 Newly issued 01/03/2016 N/A CAC S&Q Mgr
Manual
Procedures
Amended
01-02-03-04-05-
06-07-08-09-10-
11-12-13-14-
01 01/03/2016 30/09/2016 CAC S&Q Mgr
15-16-17-18-19-
20-21-22-23-24-
25-26-27-28
PROC 28-Annex B –
G-02 Critical Equip. RA
Procedures
Amended
01-02-03-04-05-
06-07-08-09-10-
02 11-12-13-14-15- 01/03/2016 28/02/2017 CAC S&Q Mgr
16-17-18-19-20-
21-22-23-24-25-
26-27-28
PROC 28-Annex B
Procedures
Amended
01-04-08-12-14-
17-20-21-22-23-27
PROC 28-Annex B
New
03 PRO 23- Annex - 01/03/2016 31/03/2017 CAC S&Q Mgr
Training Program
New
PROC 14- Annex 1-
Root Cause Analysis
New
PROC 14-Annex 2-
Guide to
Investigation
Reporting
Page 1 of 8
GENERAL
GENERAL
Eff. Date: 30/09/2022
RECORD OF AMENDMENTS
Number Amended Rank
Procedures
Amended
01-02-03-04
05-06-07-08
09-10-11-12
13-14-15-16
17-18-19-20
21-22-23-24
25-26-27-28
04 01/03/2016 30/11/2017 CAC S&Q Mgr
PROC 14-Annex 2
PROC 28-Annex B
( G-02)
PROC 28- Annex C
( RA Matrix )
New
27A
Procedures
Amended
01-03-04-05
06-07-08-12
13-14-17-18
21-22-23-24
25-26-27-28 01/03/2016
05 PROC 28-Annex B 31/05/2019 CAC S&Q Mgr

G-02 Critical Equip.
RA
Cancelled
31/05/2019
PROC 20
New
31/05/2019
20A-20B
Page 2 of 8
GENERAL
GENERAL
Eff. Date: 30/09/2022

Number Amended Rank
Version created by
Danaos automatically,
06 during failed attempt to
uploaded the Manual
Procedures
Amended
01-02-04-06-
08-10-14-16-
17-20B-21-22-23
27-28
01/03/2016
07 30/09/2019 CAC S&Q Mgr
28-ANNEX C6
28-ANNEX-B G-02
20B
31/05/2019
Procedures Amended
01-02-03-04-05
06-07-08-09-10-11
12-13-14-15-16
17-18-19-
20A-20B-21-22
23-24-25-26-27-27A
27A-ANNEX A1
27 A-ANNEX A3 01/03/2016 29/02/2020
28
28-ANNEX C1
08 28-ANNEX C2 CAC S&Q Mgr
28 ANNEX C4
28- ANNEX C5
28-ANNEX C6
28- ANNEX B –G-02
NEW
23-Annex 2 29/02/2020 N/A
28 ANNEX D
Page 3 of 8
GENERAL
GENERAL
Eff. Date: 30/09/2022

Number Amended Rank
Procedures Amended :
01-03-05-07-08-09-
10-11-12-13-14
16-18-20B-21-23-27-28
01/03/2016
28 Annex B- G-02
31/08/2020
20B
09 31/05/2019 CAC S&Q Mgr
23-Annex 2
28-Annex D
29/02/2020
New
(transferred from SOM
Manual)
31/08/2020 N/A
Procedure 01A
Procedures Amended
01-14-21-23
10 23-Annex I 01/03/2016 31/10/2020 CAC S&Q Mgr

27A-Annex A1
28- Annex C1
Amended Procedures
09-17-21-22
01/03/2016
11 28- Annex B –G-02 31/01/2021 CAC S&Q Mgr
28- Annex D 29/02/2020

Amended Procedures
01-07-14-
20A-20B
21-22-23-27
01/03/2016
12 28 Annex B- G-02 30/04/2021 CAC S&Q Mgr
23 Annex 2 29/02/2020
Page 4 of 8
GENERAL
GENERAL
Eff. Date: 30/09/2022

Number Amended Rank
Amended
Procedures/ Annexes
01-01A-02-
05-07-09
10-11-12
14-14 Annex 2
19
20A-20B-
01/03/2016
21-22-23
27-27A
27A-Annex 2
27A-Annex 4
13 27A-Annex 5 30/11/2021 CAC S&Q Mgr
28-G-02 –Annex B
Cancelled Annexes
27A-Annex 1
27A-Annex 3
30/11/2017
New Procedure
20C
NEW Annexes 30/11/2021

23-Annex 3
23-Annex 4
Procedure
14 20B 31/05/2019 28/02/2022 CAC S&Q Mgr
Amended Procedures/
Annexes
01-01A-05
01/03/2016
15 08-10-14 30/04/2022 CAC S&Q Mgr
16-21-22
28-Annex B
23- Annex 3 30/11/2021
Page 5 of 8
GENERAL
GENERAL
Eff. Date: 30/09/2022

Number Amended Rank
Amended Procedures
PROC 09-14-21
01/03/2016
16 PROC 28-Annexes 31/05/2022 CAC S&Q Mgr
C1-C2
PROC 28- Annex D 29/02/2020
Amended Procedures
01A-06-07
08-09-12
13-14 Annex 3
14-17-20A-20B
21-22-
23-23 Annex B
27-27A
28
28-Annex C1
17 01/03/2016 30/09/2022 CAC S&Q Mgr
28-Annex C2
28-Annex C3
28-Annex C4
28-Annex C5
28-Annex C6
28-Annex C7
28-Annex C8
28-Annex D -CHR
28- G-02Annex B-
Page 6 of 8
GENERAL
GENERAL
Eff. Date: 30/09/2022
CONTENTS
Procedure No. Procedure Title Issue Issue
Status Date
GENERAL: 17 30/09/222
Record of Amendments and Contents
PROCEDURE 01 Document Control 12 30/04/2022
PROCEDURE 01A Vessel’s Reports, Records and Log Books 03 30/09/2022
(transferred from SOM Manual (007) – Section
07)
PROCEDURE 02 Control of Records 06 30/11/2021
PROCEDURE 03 Identification and Traceability 06 31/08/2020
PROCEDURE 04 Acquisition of New Vessels and New-Building 07 29/02/2020
Policy
PROCEDURE 05 Certification, Verification and Control 08 30/04/2022
(External Audits)
PROCEDURE 06 Infrastructure 07 30/09/2022
PROCEDURE 07 Communication 09 30/09/2022
PROCEDURE 08 Purchasing 10 30/09/2022
PROCEDURE 09 Suppliers and Subcontractors 09 30/09/2022
PROCEDURE 10 Internal Audits 08 30/04/2022
PROCEDURE 11 Corrective and Preventive Actions 06 30/11/2021
PROCEDURE 12 Management Review 09 30/09/2022
PROCEDURE 13 Master’s Review 07 30/09/2022
PROCEDURE 14 Accidents, Incidents and Near Misses, First Aid 14 30/09/2022
Cases and Behavioural Safety
PROC 14-Annex 1- Root Cause Analysis Table 00 31/03/2/017
PROC 14-Annex 2-Guide for Incident Notification 02 30/09/2022
and Reporting
PROCEDURE 15 Customer Feedback 04 29/02/2020
PROCEDURE 16 Third Party Inspections 07 30/04/2022
PROCEDURE 17 Company Representatives’ Visits onboard 09 30/09/2022
PROCEDURE 18 Control of Monitoring and Measuring Equipment 06 31/08/2020
Page 7 of 8
GENERAL
GENERAL
Eff. Date: 30/09/2022

Status Date
PROCEDURE 19 Contract Review 05 30/11/2021
PROCEDURE 20A Shore-Based Personnel – Pre-Recruitment 04 30/09/2022
PROCEDURE 20B Shore Based Personnel 07 30/09/2022
PROCEDURE 20C Promotion and Position Changes 00 30/11/2021
PROCEDURE 21 Shipboard Personnel 15 30/09/2022
PROCEDURE 22 MLC Requirements 12 30/09/2022
PROCEDURE 23 Training 12 30/09/2022
PROC 23A- Annex A– Training Program 01 31/10/2020
PROC 23B-Annex B-Cadet Training Standards 03 30/09/2022
PROC 23C-Annex C- Onboard Training Matrix 01 30/04/2022
PROC 23D-Annex 4- Information Security Users 00 30/11/2021
Training Requirements
PROCEDURE 24 Environmental, Energy Efficiency, Occupational 05 29/02/2020
Health and Safety Management Programs
PROCEDURE 25 Environmental Issues 05 29/02/2020
PROCEDURE 26 Energy Efficiency Issues 05 29/02/2020
PROCEDURE 27 Management of Change 11 30/09/2022
PROCEDURE 27A Isolated Operation Technology (OT) Software 03 30/09/2022
Management
Annex 1 Cancelled : Office IT Software Management 02 31/10/2020
Inventory
Annex 2 Office Isolated OT Software Management Inventory 01 30/11/2021
Annex 3 Cancelled :Vessel Generic IT Software Management 01 29/02/2020
Inventory
Annex 4 Marine Isolated Software Management Inventory 01 30/11/2021
Template
Annex 5 Technical Isolated Software Management Inventory 01 30/11/2021
Template
Page 8 of 8
GENERAL
GENERAL
Eff. Date: 30/09/2022

Status Date
PROCEDURE 28 Risk Assessment 08 30/09/2022
PROC 28-Annex A PROC 28-Hazards Identification Guidance 03 01/03/2016
PROC 28-Annex C INFORMATION SECURITY
RISK ASSESSMENTS
Annex C1 Office ICT Information Security Risk Assessment 04 30/09/2022
Template
Annex C2 Vessel ICT Information Security Risk Assessment 03 30/09/2022
Template
Annex C3 ICT Information Security Risk Assessment 01 30/09/2022
Controls
Annex C4 Office OT Information Security Risk Assessment 02 30/09/2022
Template
Annex C5 Marine OT Information Security Risk Assessment 03 30/09/2022
Template
Annex C6 Technical OT Information Security Risk 04 30/09/2022
Assessment
Annex C7 OT Information Security Risk Assessment 01 30/09/2022
Controls
Annex C8 Common Infrastructure Information Risk 01 30/09/2022
Assessment Controls
Annex C9 Risk Assessment Matrix 00 30/11/2017
PROC 28- Essential Systems Criticality and Risk Assessment 14 30/09/2022
G-02 Annex B
PROC 28-Annex D COMPANY HAZARD REGISTER- V.03/22 04 30/09/2022
Page 9 of 8
IMS Procedures PROCEDURE 01
Manual Prime Gas Management Inc.
(002) Revision: 12
DOCUMENT CONTROL Eff. Date: 30/04/2022
Contents
1. PURPOSE .................................................................................................................................... 2
2. PROCEDURE .............................................................................................................................. 2
2.1 General...................................................................................................................................... 2
2.2 Creating the IMS –IMS Levels ................................................................................................. 2
2.2.1 Level 1 – IMSM Manual................................................................................................................................ 3
2.2.2 Level 2 – IMS Procedures Manual ................................................................................................................ 4
2.2.3 Level 3 – All other IMS Manuals and IMS Forms ........................................................................................ 4
2.2.4 Level 4 –Secondary Manuals ......................................................................................................................... 4
2.2.5 Level 5 –Log Books, 3rd Party Forms, Software, Manufacturers’ Manuals ................................................... 5
2.3 Preliminary IMS Documentation.............................................................................................. 6
2.4 Development of IMS Manuals.................................................................................................. 6
2.5 IMS Format............................................................................................................................... 7
2.5.1 IMS Manuals’ Format .................................................................................................................................... 7
2.5.2 IMS Forms and Checklists ............................................................................................................................. 8
2.5.3 Company Circulars ...................................................................................................................................... 10
2.6 Approval of IMS ..................................................................................................................... 11
2.7 Distribution of IMS ................................................................................................................ 11
2.8 Validity of Documents............................................................................................................ 13
2.8.1 Shipboard Forms .......................................................................................................................................... 13
2.8.2 Office Forms ................................................................................................................................................ 13
2.8.3 Controlled documents - IMS Manuals & Circulars ..................................................................................... 13
2.9 Changes and Amendments ..................................................................................................... 14
2.9.1 Reason for Amendments .............................................................................................................................. 14
2.9.2 Proposal for Amendments............................................................................................................................ 14
2.9.3 Record Keeping / Filing of Proposals for Amendments .............................................................................. 15
2.9.4 Frequency of IMS Amendments. ................................................................................................................. 15
2.9.5 Amendment Process .................................................................................................................................... 15
2.9.6 Identification of Amended IMS Documentation.......................................................................................... 16
2.9.7 Notification of Amendments........................................................................................................................ 16
2.9.8 Records of Amended IMS Documentation .................................................................................................. 17
2.10 Updating the IMS with New Amendments. ........................................................................ 17
2.10.1 IMS Manuals & Forms – Maintained Electronically ................................................................................... 17
2.10.2 IMS Manuals – Hard Copies........................................................................................................................ 17
2.10.3 Vessel’s Standard Filing System ................................................................................................................. 18
2.11 Obsolete Documents............................................................................................................ 18
2.12 Document Control – As to Distribution of IMS Related Hard-Copy Items ........................ 19
2.13 Document Control of Oil Pollution Plans (sopep / smpep /ccp /pcsopep /vrp). ................. 19
2.14 Updating & Distributing the Emergency Contact List ........................................................ 21
3. RECORDS. ................................................................................................................................ 22
Page 1 of 22
(002) Revision: 12
1. PURPOSE
This section defines the procedures which are followed for the control of Integrated Management
System documentation (issuance, approval, review, amendment, distribution and cancellation).
2. PROCEDURE
2.1 GENERAL
The control of all documents and data relevant to the IMS is a vital element in the effectiveness of the
system.
The basic elements of the IMS Document Control procedure are the following:
 Approval of all IMS Documentation by the Chief Operating Officer (COO) or Deputy COO or by
the Authorized DPA.
The HR and ICT documentation are approved by the Chief Operating Officer (COO) or the
Authorized HR and ICT Managers respectively.
 Identification of the levels of the IMS Documentation.
 Indexing of the IMS Documentation.
 Distribution to all Holders of valid and controlled IMS Documentation.
 Amendment of the IMS through detailed and documented procedures.
 Control of all IMS Documentation from their issuance to their withdrawal.
 Withdrawal of all obsolete IMS Documentation.
Official verification of Document Control is conducted, both in Office and Onboard during the Annual
ISM Internal Audits.
2.2 CREATING THE IMS –IMS LEVELS

The Company has established an Integrated Management System, which includes Instructions,
Procedures and Checklists in order to ensure that both Office and Shipboard Personnel implement the
requirements of the mandatory and voluntary International Codes and Standards, Flag Administration
Requirements, IMO Regulations and the Best Industry Practices.
The Company IMS Documented Information has:
 Identification and Description (e.g title, date, reference number, version number).
 Format (e.g language, software version, graphics) and Media (paper, electronic).
 Review and Approval for suitability and adequacy.
All the Company Manuals, Procedures, Instructions, Forms and Circulars are written in plain and
simple English, and contain sufficient details to ensure that tasks can be competed correctly and
consistently.
The Company’s Integrated Management System consists of five (5) Levels.
These levels prescribe the controls which are essential to maintain a service always in compliance with:
 ISM Code [IMO Resolution A 741(18)].
 Adopted ISO Standards (mentioned in paragraph A. below).
 Requirements of the International Maritime Organization (IMO).
 Requirement of the Flag Administration and Classification Societies.
Page 2 of 22
(002) Revision: 12
2.2.1 Level 1 – IMSM Manual

A description of the elements of the Integrated Management System and their interaction (IMS) –
(First Level Documentation).
The IMS Manual (001), describes the functional requirements of:
 ISM Code.
 ISO 9001:2015
 ISO 14001:2015
 ISO 27001:2013
 ISO 45001:2018
 ISO 50001:2011
and their implementation by the Company.
In addition, it includes:
 The Company Policies
1. Quality, Safety & Health Policy
2. Environmental Protection & Energy Efficiency Policy
3. Drug and Alcohol Policy
4. Master’s Ultimate Authority
5. Security Policy
6. Mission Statement
7. Vision Statement
8. Corporate Social Responsibility
9. Anti-bribery Policy
10. Anti-bullying Policy
11. Sexual Harassment Policy
12. Social Media Policy
13. CCTV Policy
14. Company Travelling Policy
15. Office Building Security Policy
16. General Data Protection Policy
17. Whistle Blowing Policy-Shipboard
18. Whistle Blowing Policy-Officer
19. Computer, E-mail and Internet Usage Policy
20. Mobile Phone Use Policy-Office
21. Workplace Violence Prevention Policy
22. Remote Work Conduct Policy
23. Information Security Policy
24. Clean Desk and Clear Screen Policy
25. Information Classification Policy
 The Company Organization Charts (Lines of Authority and Responsibility)

o Shore-Based Organization.
o Ship-Based Organization.
o Emergency Communications Organization.
Page 3 of 22
(002) Revision: 12
2.2.2 Level 2 – IMS Procedures Manual

Level 2 includes procedures, applicable ashore and on board and consists of two (2) Manuals as
follows:
 Integrated Management System (IMS) Procedures Manual (PRO 002)
 Information Security Management System (ISMS) Procedures Manual (PRO 002A)
2.2.3 Level 3 – All other IMS Manuals and IMS Forms

Work Procedures / Instructions (Third Level Documentation) explain in detail the actions to be taken
to perform defined activities within the service provided and includes the following:
 003 – Shipboard Safety Manual (SAF)
 004 – Emergency Procedures Manual (EMP)
 005 – Maintenance Manual (MTN)
 006 – Navigation & Mooring Manual (NAV)
 007 – Shipboard Operations Procedures Manual (SOM)
 008 – Office Manual (OFF)
 009 – Environmental Manual (EMS)
 010 – Cargo Operations Manual- Oil/Chemical Tankers (COM)
 010 – Cargo Operations Manual – Gas Carries ( LPG) (COM)
 Registered IMS Office and Shipboard Forms
These Manuals provide detailed Procedures and Instructions, references to International Rules and
Regulations, references to Forms, and to the Company’s Filing System.
2.2.4 Level 4 –Secondary Manuals

Level 4 of the IMS consists of the following Manuals:
 Secondary IMS Manuals.
Secondary Manuals, are all stand-alone Manuals which have been developed in-house or by
Third Party Organizations /Consultants.
 Manuals in other Languages.
SECONDARY ISM MANUALS

SOPEP Shipboard Oil Pollution Emergency Plan ( OT & LPG)
SMPEP Shipboard Marine Pollution Emergency Plan ( CT)
PCSOPEP Panama Canal Shipboard Oil Pollution Emergency Plan
VRP Vessel Response Plan
CCP California Contingency Plan/ Response Manual
VGP Vessel General Permit
SSP Ship Security Plan
BWMP Ballast Water Management Plan
MSLMP Mooring System & Line Management Plan
SOLAS SOLAS Training Manual (012- STM)
FF BOOKLET Fire Training Manual & Fire Safety Operations
Continuing on next page
Page 4 of 22
(002) Revision: 12
SECONDARY ISM MANUALS

PIW Plans and Procedures for Recovery of Persons from the Water
STS STS Operations Manual
SEEMP Shipboard Energy Efficiency Management Plan
CEEMP Company Energy Efficiency Management Plan
ETB Emergency Towing Booklet
VOC Volatile Organic Compounds Manual
VEC Vapour Emission Control Manual
DAMAGE Damage Stability Booklet
SERS Ship Emergency Response Service ( Lloyds Register )
IHM Inventory of Hazardous Materials
Biofouling Management Plan & Record Book
SECURITY MANUALS
SSP Ship Security Plan ( made Ship Specific )
Office Security Plan
2.2.5 Level 5 –Log Books, 3rd Party Forms, Software, Manufacturers’ Manuals
Level 5 of the IMS consists of the following:
 Company Circulars issued by the Company
 All Log Books:
a) Articles of Agreement.
b) Deck Log Books.
c) Engine Room Log Books.
d) Cargo Log Book ( replaced by SF/OPS/334) .
e) Radio / GMDSS Log Books.
f) Oil Record Books.
g) Garbage Management Log Books.
h) Night Order Book.
i) Radar Log Book.
j) Chronometer Log Book.
k) Compass Error/ (Observation) Book.
l) Cargo Record Book for Ships carrying noxious liquid substances in Bulk.
m) Ballast Water Record Book
 Forms and checklists provided by Third Parties (Port Authorities, OCIMF, CDI).
 Flag Administration Forms, Checklists and Circulars.
Page 5 of 22
(002) Revision: 12
 All Company developed and/or purchased Software :

a) Planned Maintenance System,
b) Crew Department Database,
c) ASTRIS / Communication Software,
d) Purchasing Department Database,
e) Accounting Department Database,
f) Vetting / Marine Department software,
g) S&Q Department Software.
In addition,
 Manufacturers’ Manuals,
 MSDS: Material Data Sheets,
 Informative / Training CDs ( Seagull etc),
 Posters, Documentation and Checklists provided by Third Parties, Suppliers, P&I Club, Oil
Majors etc.
2.3 PRELIMINARY IMS DOCUMENTATION

Before their official issuance, complex IMS Documentation (i.e. Forms) may be examined for
adequacy and user-friendliness.
This is implemented by the Company as follows:
 For Procedures through issuing a relevant Circular.
A Circular detailing proposed procedure is being issued. This is put to the test for some time and if
found satisfactory and adequate while taking under consideration any suggestions from Office and
Shipboard personnel, the contents of the Circular is incorporated into the IMS Manuals and the
Circular is being cancelled.
 For Forms, by issuing "Preliminary Forms".
The Preliminary Form is forwarded throughout the fleet, requesting suggestions and feedback.
Following input from the Vessels, the form is improved and officially issued.
2.4 DEVELOPMENT OF IMS MANUALS

The DPA, as authorized by the Chief Operating Officer (COO) or Deputy COO, is responsible to
make the final decision of whether a new Manual will be developed in-house using Company resources
or will be assigned to consulting organizations, except the HR and ICT functions, where authorization
and responsibility is granted to the HR and ICT Managers respectively.
The S&Q Department in close cooperation with the DPA and all other Office Departments, is
responsible for the development and review of all IMS Manuals.
All Office Departments are responsible to contribute to the development of the IMS Manuals, each
Department in its own area of responsibility.
The S&Q Department is responsible for coordinating, consulting, formatting, issuing and distributing
the newly issued IMS Manuals on a per need basis.
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(002) Revision: 12
2.5 IMS FORMAT

Company’s IMS Manuals, Forms and Circulars follow a certain Format, which enables the reviewer to
immediately locate the Procedure Number, the Amendment Number and Issue Date, the Form Number,
the Circular Number etc.
The Font Type used for the Company developed IMS Manuals is Times New Roman - Size 12.
2.5.1 IMS Manuals’ Format

Company-developed IMS Manual have a common format:
A. All have a cover page, which states:
 Manual Name, Code & Number,
 Issued date & Status,
 Company Name,
 Authorized by,
 Approved by.
The first page is signed by the DPA & Chief Operating Officer (COO) or Deputy COO confirming
Top Management commitment to the contents of the Manual.
B. All have a "Record of Amendments" page, which lists:

 The Amendment Numbers.
 The Chapter / Procedure / Section which were amended during each amendment process.
 The Date on which a procedure was amended.
 The Position & Rank of the person updating the Manual.
C. All have a "Contents Page", listing the Title and Number of each Chapter / Procedure / Section
included in the Manual.
D. All IMS Manual Chapters / Procedures / Sections have unique Numbers.
E. Each Chapter is divided in the following parts:

 References (ISM, ISO, TMSA, etc).
 Text.
 Procedure, Section or Manual associated with Chapter’s requirements.
F. Each Procedure / Section is divided in the following parts:

 Purpose.
 Procedure.
 Records.
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(002) Revision: 12
G. All Chapters / Procedures / Sections have standard "Page Header" & “Page Footer”. The "Header"
states the following:
 Companies’ Names.
 Manual Title / Number.
 Chapter / Procedure / Section Number, Title, Revision and Effective Date.
Only the latest amendment process Revision Date & Number is being mentioned.
The date of the original issuance of a specific Chapter / Procedure / Section is only stated on the
"Record of Amendments" page at the beginning of the Manual.
 The “Footer” states the page numbering.
Indexing of the IMS Manuals.

All Manuals are "indexed" for easy identification and review. Each one has a "Contents’ Page" at
the beginning. The "Contents’ Page" is always amended following any Amendment Process, if new
Chapters / Procedures / Sections are being added and / or when existing items are being re-titled or
cancelled.
2.5.2 IMS Forms and Checklists

A. Forms’ Categories.
The IMS Forms are divided in two (2) major categories:
 Office Forms (OFF).
 Shipboard Forms (SF).
The numbering format of the Forms is as follows:
 OFF or SF/ Number /Reference Manual/Reference Procedure or Section.
Example:
S&Q Office Forms are numbered OFF/SAQ/400+
S&Q Shipboard Forms are numbered SF/SAQ/400+
Department Form Group Initials Group Number

Emergency SOS 000 +
Technical TEC 100 +
Marine Safety MRS 200 +
Operations OPS 300 +
Safety & Quality SAQ 400 +
Crew CRW 500 +
Purchasing PUR 600 +
Accounting ACC 700 +
Bunkering BNK 800+
Security Forms (ISPS) SEC 900+
Environmental Forms EMS E 001+
continuing
Page 8 of 22
(002) Revision: 12
Department Form Group Initials Group Number

Marshall Islands Forms MSL N/A
Posters POST 01-02-03 etc
Cyber Security CBS 001+
Training TRN 001+
Human Resources ( HR ) HR 001+
Uncontrolled (Temporary) TEMP 01-02-03 etc
Uncontrolled ( COVID-19) COV 01-02-03 etc
Solas Training Manual- Ship Specific STM 01-02-03
Forms
International Requirements None None
General ( Office Only) GEN 000+
Information and Communication ICT 001+
Technologies (ICT)
B. Forms’Format.
Both Office & Shipboard Forms have a standard Format including a standard "Page Header" &
"Page Footer".
The “Header” states:
 The Name(s) of the Company(s).
 Form’s Number.
 Relevant IMS Procedure
 Issue Date.
 Authorized by DPA.
 Form’s Title.
 The “Footer” states the page numbering.
Note: Some Forms are Vessel-Type Specific i.e.

 Operations Forms - Specific for Oil and Chemical Tankers.
 Operations Forms - Specific for Gas Carriers.
 Marine Forms - Specific for Oil and Chemical Tankers.
 Marine Forms - Specific for Gas Carriers.
In the above cases, only the name of the Company to which the forms apply is mentioned on the
Header.
C. Forms’ Register.
This is available as a Report through the standard ERP electronic system used to log and distribute
forms throughout the Company & onboard.
Page 9 of 22
(002) Revision: 12
2.5.3 Company Circulars

A. Issuance.
All Company Circulars are strictly controlled documents, having unique Code Numbers and Issue
Dates. Circulars may be issued for the following reasons:
 To introduce a new Procedure, International requirement or ISO Standard requirement(s),
until it is officially entered in the IMS.
 To explain in detail existing procedures, providing guiding examples.
 To explain in detail the amendments to the IMS.
 To analyze Accidents, Incidents and Near Misses (Hazardous Occurrences).
 To analyze Non-conformities resulting from Company and 3rd Party Inspections.
 To distribute to all Fleet Vessels the Quarterly Management Review Meeting Minutes.
 To communicate to all Fleet Vessels the Quality Targets (KPIs) which have been set for the
specific year (sent at the beginning of the year).
 Other Matters, as required.
B. Circular Categories.
Depending on their contents, the Company Circulars are grouped into the following categories:
 General GEN
 Technical TEC
 Marine MRS
 Operations OPS
 ISM ISM
 IMS Amendments IMS
 Crew CRW
 Training TRN
 Purchasing PUR
 Security SEC
 Environmental EMS
 Hygiene HYGIENE
 COVID-19 COV
 Office-Vessel Drills DRILL
 Office-Vessel Table Top Exercises TTX
 ICT ICT
 Publications PUB
 Vessel Accident Investigations
 Vessel Safety Incidents Investigations
 Marshall Islands Circulars
 Marshall Islands Advisories
 Marshall Islands Guidelines
 Marshall Islands Forms
 Marshall Islands Notices
 Office Circulars
 Office Security
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Oil Pollution Plans are uploaded in Danaos as Circulars i.e:

 SOPEP/SMPEP
 PCSOPEP
 VRP/NTVRP
 SEEMP
Flag Administration Forms are uploaded in Danaos as Circulars i.e

 Marshall Islands Forms.
C. Company Circulars Register.

This is available as a standard report through the electronic ERP system used to log and distribute
Circulars throughout the Company & onboard. This includes:
 Circular Category / Number.
 Status (In Effect / Amended / Cancelled).
 Version.
 Issuer.
 Issue & Amendment Date ( Later if applicable),
 Topic.
2.6 APPROVAL OF IMS

All IMS Documentation is being approved before their official issuance. The DPA has been authorized
by the Chief Operating Officer to review and approve on his behalf all Procedures of the Integrated
Management System, except the HR and ICT functions where authorization has been granted to the
HR and ICT Managers respectively.
Records of approval for the issuance or amendment of the IMS are kept by the S&Q Department in the
relevant electronic files.
 Record of Manual Amendments & IMS Amendment Meetings.
 Record of Forms’/ Filing System Amendments.
 Amendment Process Management of Change (MOC).
The Approval process is being performed electronically through the company ERP system responsible
for document management & distribution throughout the Company and onboard of all IMS
Documentation including relevant Log of Amendments.
2.7 DISTRIBUTION OF IMS

The S&Q Department has been appointed to be responsible for the control, amendment, approval and
distribution of IMS documentation as well as the relevant record keeping.
This activity is monitored by the DPA.
A. IMS Manuals Distribution List:
 Company Headquarters.
 All Company Vessels.
 The Manning Agent(s).
 Seagull Online CBT Training.
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B. Distribution
Both in Office as well as onboard, Company IMS is being distributed and becomes accessible
through the electronic ERP system.
Any amendment is first communicated through issuing a relevant Circular while a relevant Log of
Amendment is also available in the electronic ERP system.
Focusing on the Vessel side and apart from electronically distributed IMS Manuals, Forms, Posters
& Circulars, there are other Manuals onboard that can be distributed electronically but must
always be available in hard-copy as follows:
MANUAL TITLE NUMBER OF COPIES

SOLAS Training Manual - English Three (3)
Enclosed Space Training Manual - English Two (2)
Fire Training Manual & Fire Safety Operations - English Three (3)
Recovery of Persons from Water One (1)
Shipboard Oil Pollution Emergency Plan – SOPEP. One (1)
Shipboard Marine Pollution Emergency Plan – SMPEP. One (1)
Vessel Response Plan – VRP. One (1)
Panama Channel SOPEP - PCSOPEP One (1)
California Contingency Plan - CCP One (1)
Ship Security Plan SSP One (1)
Ballast Water Management Plan - BWMP One (1)
STS Operations Manual One (1)
Mooring System & Line Management Plan One (1)
Ship Energy Efficiency Management Plan - SEEMP One (1)
Emergency Towing Booklet Three (3)
( Bridge, Cargo Control Room and Forecastle )
Damage Stability Booklet One (1)
VOC Manual One (1)
VGP Manual One (1)
The Navigation & Mooring Manual (006) is distributed both through electronic ERP system as well
as in a Hard Copy, which must be kept on the Bridge.
As shown on the above table the Vessels shall have three (3) copies of a ship specific “Emergency
Towing Booklets”.
Copies of the ETB must be located on the bridge, forecastle space and the Cargo Control Room.
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 Manning Agent(s).
The Manning Agent is provided with an electronic copy the IMS Manuals, including Shipboard
Forms, Posters, Int'l Requirements and Company Circulars.
 Training Online Data Base
After each IMS Amendment Process, the Training Manager is responsible to upload in the
Online Training Data Base the amended IMS Manuals.
The Company IMS must not be distributed to any 3rd Parties, before authorization is granted as
follows:
For the Integrated Management System : Authorization by the DPA
For Information Security Management System Authorization by the ICT and HR Manager.
and documentation of the IMS related to the ICT
and HR Functions :
Additionally,
Before the Company IMS and ISMS and the related documents are distributed to any 3rd Parties, a
Non-Disclosure Agreement (OFF/ICT/010) must be signed as per Procedure Manual –
PROC 09-“Suppliers and Sub-Contractors”.
2.8 VALIDITY OF DOCUMENTS

This procedure describes the steps taken by the Office to ensure that all IMS Manuals and Forms being
used are of the latest version.
2.8.1 Shipboard Forms

Shipboard forms’ Document Control is guaranteed by the ERP system used to receive from Office,
create and file forms onboard. At any time, the relevant ERP functionality only makes available the
Latest release of any form applicable at any particular date. That way all electronic records created are
based on the latest release available on this date.
Regarding records to be completed by hand, clear guidance has been provided fleet-wide stating that
any such record must be opened and printed using as source the last release automatically provided by
the ERP system. No other forms’ repository is allowed onboard.
2.8.2 Office Forms

Same guidance note as per Shipboard forms and ERP Document Control handling applies here as well.
2.8.3 Controlled documents - IMS Manuals & Circulars

Document Control onboard is under the responsibility of the Master. New / new release IMS Manuals
and / or Circulars are being forwarded and maintained onboard through the ERP electronic system.
Upon any such new document being forwarded, Office notifies Vessels accordingly.
Upon receipt, Vessel side must perform relevant acknowledgment using ERP system corresponding
functionality.
Compliance with Document Control requirements is also ensured during the Internal Audit –
performed at least once every twelve (12) months.
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Only IMS Forms distributed through the Official ERP system by S&Q Department must be used.
Forms must not be modified by Office or Vessel personnel. Obsolete forms must be removed and not
be used for reporting.
2.9 CHANGES AND AMENDMENTS

Company IMS has been designed to be dynamic and allow changes in a controlled manner.
Amendments must be readily identifiable. All relevant Office and Shipboard personnel must be notified
and the IMS Amendments must be distributed through the ERP system. Personnel affected by
amendments must always be involved in identifying and implementing the changes.
Periodic Meetings are held with the participation of the DPA and all Department Heads and in order
to discuss and agree on the IMS Amendments which must be made. Depending on the level of
changes, these meetings may also be attended by the Chief Operating Officer (COO) or Deputy COO.
All IMS Amendments must be integrated by the S&Q Department ONLY.
2.9.1 Reason for Amendments

The main reasons for amending Company’s IMS are the following:
1. Changes in International Requirements, Flag Regulations, Legislation or Industry Codes of practice
etc.
2. Identification of mistakes, inconsistencies or missing procedures during Internal Audits and Fleet
Performance Results evaluation.
3. Requirements resulting from External Audits.
4. Proposals for improvements and simplifications by Shore and Shipboard staff.
5. Requirements resulting from USCG, PSC, Flag Administrations and Vetting Inspections.
6. Lessons Learnt from Accidents, Incidents, Near Misses and Drills.
7. Periodic Gap Analyses of the IMS.
8. Adoption of new Standards, i.e. ISO 27001, ISO 45001, ISO 50001 etc.
2.9.2 Proposal for Amendments

Any member of the Office or Shipboard staff may submit suggestions for IMS amendments.
All these suggestions and proposals must be submitted to the S&Q Department for review as follows:
 Office Personnel:
o OFF/SAQ/404 - Form - IMS Amendment Proposals or
o Through corporate e-mail with “cc” to own Department Manager.
 Shipboard Personnel:
o SF/SAQ/402 - Master’s Overall IMS Review.
o SF/SAQ/403 - Master’s Brief Review Report.
Shipboard personnel must initially submit their suggestions to the Master for review. If the Master
considers these suggestions appropriate, he must then submit them to the S&Q department for review
and processing.
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2.9.3 Record Keeping / Filing of Proposals for Amendments

The S&Q Department is responsible to keep record of all the proposed amendments to the IMS. This
is done as follows:
 IMS Amendments Proposals by Office Staff.
o Electronically under the ISM File – Amendments Records.
o Through ERP system – those submitted using OFF/SAQ/404.
 Master’s Overall & Brief Review Reports – SF/SAQ/402 & SF/SAQ/403:

o Through ERP System.
2.9.4 Frequency of IMS Amendments.
As a standard procedure, the need to perform MAJOR amendments

is reviewed Quarterly during regular Management Review Meeting and
implemented at least ANNUALLY as a minimum.
However, the need to perform Amendments may be evaluated more frequently, depending on
circumstances as per Paragraph 2.9.1 above “Reason for Amendments” that require immediate /
urgent attention.
All newly employed Office staff must review the IMS Documentation.
Furthermore, all Office Departments’ staff must continuously review and refresh their knowledge of
the Company’s IMS, especially the Manuals and other documentation which is directly related to
their work. Following these actions, any office employee may wish to make some suggestions for
improvement etc. In addition, mistakes which need correction may have been identified.
All proposals for improvement, change and correction must be submitted to the S&Q Department.
A Gap Analysis of the IMS, will be a carried out

at least every two (2) years, by External Consultants
in order to ensure that the IMS is maintained updated.
2.9.5 Amendment Process

The stages of an Amendment process are the following:
 Initiating a Management of Change process.
 Collecting all proposals for Amendments from Office and Vessel personnel.
 Create new ERP version of Document to be amended and making notes to easily identify the
changes intended (different color, highlights etc).
 Start completing amended Documents “Log of Amendments” and recording changes made in each
document and the person (s) who suggested these changes.
 Periodically holding meetings with the Departments concerned in order to discuss, agree and
finalize the changes.
 Finalizing amended Document and relevant Log of Amendments and holding an “Amendments
Meeting” with the Department Heads, the DPA and / or responsible Management Representative,
for the final approval, as per paragraph 2.6 above, of the IMS Amendments.
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 Finalizing the Change Request Form and securing the signatures of the Department Head and / or
responsible Management Representative concerned, the S&Q Manager, the DPA and the Chief
Operating Officer (COO) or Deputy COO.
 Distributing the Amended IMS Onboard and in Office through ERP system.
 Issuing Official Circulars to the Vessels, detailing the changes and the reasons together with
relevant Log of Amendments.
All amendments are outlined in the Management Review Meeting.
2.9.6 Identification of Amended IMS Documentation

The amendments to the IMS must be immediately and easily identifiable. For this reason the Company
is using the following rules:
 Manual Amendments.
Each IMS Manual is divided into separate Chapters / Procedures / Sections. When a Manual
Chapter / Procedure / Section is cancelled, the following Chapters / Procedures / Sections are not
renumbered but instead the number of the cancelled procedure is reserved, in order to be used for
any new procedure in the future. This is done to avoid confusion to company personnel who are
familiar with the IMS procedure numbers and mistakes in the numerous cross-references which
exist in all Manuals.
When any section of a Chapters / Procedures / Sections is amended, the entire procedure is given a
new amendment number and date. All Manual Amendments are being assigned Amendment
Numbers.
All the Amendments in each Chapter, Procedure and Section are easily identifiable,
typed in “ITALICS”.
 Forms Amendments.
 Forms amendments are identified by their Issue Date.
 Every time a Form is amended the Issue Date is changed.
 The changes are detailed in the ERP system Log of Amendment record applicable to each form.
 Amendments to the Vessel’s Standard Filing System.
The amendments to the Vessel’s Standard Filing System are made by simply changing the Issue
Date of the “Filing Plan Sheet”. Changes are highlighted on Vessel’s Filing System – General
Outline in bold blue letters and on the last column of the form, the latest amendment date is
mentioned.
2.9.7 Notification of Amendments

Personnel affected by the amendments must always be involved in defining and implementing the
changes.
 Office Departments.
All Office Departments are notified for any amendment in the Office or Shipboard IMS
Documentation through the issuance of a relevant Circular or E-mail.
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 Vessels.
The S&Q Department notifies the Vessels of the amendments to the IMS held onboard by:
o Issuing a relevant Circular to all the Vessels with all the amended documentation attached
and the relevant "Log of Amendments".
o By forwarding amended Manuals & Forms as well as corresponding Log of Amendments
through the ERP system.
After each major IMS Amendment,

the S&Q Department makes an overall review of the IMS to ensure its integrity.
2.9.8 Records of Amended IMS Documentation

ERP system keeps detailed records of all amended IMS Documentation including Content, Revision
and Log of Amendments.
2.10 UPDATING THE IMS WITH NEW AMENDMENTS.
2.10.1 IMS Manuals & Forms – Maintained Electronically

Amended IMS Manuals Forms are forwarded onboard and circulated in the Office as well as to the
Manning Agent through the ERP system. An e-mail is sent throughout the fleet informing of newly
issued Manuals & Forms. Officers onboard must acknowledge receipt of the Manual using the relevant
ERP system control mechanism while Log of Amendments is available also through the same system.
2.10.2 IMS Manuals – Hard Copies

This refers to certain manuals that must be available onboard in hard copy as per paragraph 2.6 – IMS
Distribution – sub-paragraph B of current procedure. Amendments are distributed in Hard Copy and/
or electronically through ERP system. Some Manuals are distributed in Hard Copy as well.
The steps to be followed to update the Hard Copy Manual are:
 Remove the procedures which have changed, being guided by the “Log of Amendments”.
 Insert the newly amended procedures.
 Insert the amended page “Record of Amendments” at the front of the Manual and add the initials
and the rank of the person who is updating the Manual.
 Check and ensure that all the newly amended procedures, as per the “Record of Amendments” are
in the Manual Folder.
 Destroy the obsolete procedures which were removed from the Manual Folder.
 Provide written notification towards S&Q department that amendment process has been completed.
 The Holders must follow the above procedures for all the controlled Hard copies of the Manuals
available onboard (some Manuals are distributed in more than one copies).
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2.10.3 Vessel’s Standard Filing System

Amendments to the Vessel’s Standard Filing System are only distributed to the Vessels. When
amendments are made to the Filing System, they are sent in both Hard Copy and Electronically in CD.
 Hard Copy
An amendment in the Filing System, usually involves a change in the Filing Plan Sheet, or the
internal separators. Sometimes it may involve addition or cancellation of a Folder. All the
amendments in the Vessel’s Standard Filing System are provided to the Vessels, grouped per Filing
System Category (Master, Chief Officer, Chief Engineer, Bridge, Safety Officer, and Security
Officer).
Each separate set is accompanied by detailed instructions. The Holder of each Filing Category must
remove the obsolete “Filing Plan Sheets” and insert the new ones and any new separators which
may have been added or remove any cancelled separators.
Each amendment to the Vessel’s Standard Filing System, which involves additions / cancellations
of Files or changes in their contents, is accompanied by an updated “IMS & Vessel Filing System
- General Outline”. - Form OFF/SAQ/421. This “General Outline” is sent in five (5) copies – one
for each Filing Category onboard (Master, Chief Officer, Chief Engineer, Bridge, Safety Officer).
When new Files are added in the Vessel’s Filing System, these Files are prepared by the S&Q
Department and are sent onboard all the Vessels.
 Electronic Copy (CD)

Each time there is a major amendment in the Vessel’s Standard Filing System, the entire Electronic
layout is copied in CD and is sent to all the Vessels, in line with the ISMS-PROC 02B-Physical
Media Transfer Procedure– Section 6.5, to be copied in their computers, replacing the previous
version. If only a few “Filing Plan Sheets” are amended, then they are sent through e-mail.
An official Circular together with a “Log of IMS Amendments” must always be sent, explaining
the changes.
Vessel’s Filing System amendment process must be performed under Master’s monitoring that upon
completion must send written notification towards S&Q Department.
2.11 OBSOLETE DOCUMENTS

ERP system contains detailed records of old / obsolete document including also details such as date of
issue / cancellation etc. All company stakeholders must monitor ERP system and make sure that
obsolete documents are not used but instead are removed from files.
 Obsolete Certificates.
Obsolete Certificates must be filed in Master’s File TEC 03“Obsolete Certificates” (A or B -
depending in the type of Certificate) or must be suitably identified as obsolete.
This identification may be done by making a note “Obsolete” across the document or by “crossing
it out” (preferably in red ink).
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Filled-in forms are not IMS Documents - they are REPORTS / RECORDS.
They must not be removed and destroyed.
This is possible only after Office advice e.g. usually after the ISM /ISPS / MLC-2006 Intermediate
Verification Audit and as per the retention period of each kind of report - usually three (3) years.
When a ship leaves the Company, all IMS documentation is destroyed in the Vessel’s incinerator or
otherwise. This process is carried out under the supervision of the Company representative who is
present onboard for the Vessel’s delivery to the new Owners.
2.12 DOCUMENT CONTROL – AS TO DISTRIBUTION OF IMS RELATED HARD-COPY ITEMS

 Dispatch.
o For the items which are sent out in hard copy, an accompanying “Confirmation of Receipt” letter
is issued.
o If applicable, the letter will also provide details as to filing onboard, the reason why the item has
been sent, etc.
 Final Filing.
When the Master’s duly signed / stamped / dated confirmation letter is received in Office, it will
be filed in the corresponding hard or electronic S&Q Department files.
2.13 DOCUMENT CONTROL OF OIL POLLUTION PLANS (SOPEP / SMPEP /CCP /PCSOPEP /VRP).
This procedure describes the process for document control of all Oil Pollution Plans and related
Approval Letters.
 New Oil Pollution Plan
When a new Vessel is to be acquired:
o A new plan is created in collaboration with an External consultant.
o The External Consultant also submits the plan to the relevant Organizations / Authorities
to receive and forward back the Initial Submission and / or Approval Letter(s).
o Plans & relevant Submission / Approval Letter(s) are sent onboard in hard-copy together
with a “Confirmation of Receipt” letter.
o Electronic copy is also submitted through the ERP system.
o The plan in hard-copy is received onboard. The Master signs / dates / stamps the letter and
returns it by mail to Office.
o The original signed letter is filed inside the S&Q Department Filing System - File 104 - as
proof of safe receipt onboard.
 Office & Vessel Side Amendments

Office side changes refer to Company-specific information such as changes in personnel or their
contact numbers, Vessel-specific information changes in Class, P&I Club, Vessels’ contact
numbers, etc.
As per standard DPA instructions, the Shipboard Oil Pollution Plans are reviewed Annually,
by the Fleet Vessels and by the S&Q Department
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Amendments necessary are triggered by the following processes:

o Plans are continuously reviewed by the S&Q Department for mistakes, inconsistencies, and
/ or obsolete information. A detailed review is carried out in order to ensure validity of:
 Contact Lists,
 Vessels’ equipment ( i.e. CCTV),
 Company Procedures
 Classification Society
 P&I Club
 Legislation, USCG Requirements etc
o Masters onboard are requested, to review their Vessel’s Emergency Response Plans, in
order to identify any inconsistencies, mistakes or omissions. If they identify mistakes, etc.,
they will note it in a Master’s Brief Review, which must be submitted to the ERP system
for review by S&Q Department.
o If any Office Personnel identifies any needed changes, they will notify the S&Q
Department.
On a Quarterly basis all these Amendment proposal are compiled and forwarded towards the
External Contactor ( i.e Marispond, Gallagher ) in order to amend the Plan(s).
o The completed amendments are sent back via e-mail to the S&Q Department as a draft.
o Once the draft(s) has been reviewed and approved, External Consultant is notified to
finalize the amendments.
o Once the final amendments are received by e-mail, the office copy is being updated.
o Amendments are sent through the ERP system onboard.
o An e-mail with detailed instructions on how to make changes is sent to the Vessel(s).
o Upon amendments becoming available onboard, the Master makes necessary changes in
hard-copy onboard and notifies by e-mail the ISM Coordinator as proof of concept.
 External Contractor Amendments

These relate to changes in international regulations, QI contact numbers, etc. or any other piece of
information NOT related to Vessel-specific or company-specific details. Amended plan is
forwarded towards S&Q Department for approval and the same process in order to notify Vessel
as per previous section also applies.
 SOPEP / SMPEP List of Operational Contact Points - IMO MEPC.6 / Circ.15 - Amendments
This List is being updated by IMO every January, April, July and October.
The S&Q Department checks the IMO Website.
When the new List becoming available, the S&Q Department forwards it to all Vessels through the
ERP system.
An e-mail with clear instructions to insert this list in the SOPEP / SMPEP as “Appendix A”,
replacing the previous version, is also being forwarded.
As a fail-safe measure, same changes are also communicated by the contracted External consultant
within scope of regular External Contractor Amendments. SOPEP / SMPEP amended “Record of
Changes” page is forwarded to S&Q Department and through the ERP system onboard. A second
e-mail is sent onboard to notify Vessel and make sure the relevant changes have been made.
Process above is applied in order to make sure that List of Operational Contact Points is updated
upon this becoming available from IMO without any delay e.g. by the External Contractor post-
processing, since this item is frequently checked by Vetting Inspectors.
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The Master is responsible to make relevant changes, confirm towards S&Q Department
amendments being implemented and always check and verify that Contact Points are up-to-date.
 Company & Employee Contact Information Amendments.

Depending on the urgency of the Contact Information amendments these will be performed as
follows:
o If the change(s) in the contact list are very urgent, the contact list is immediately sent to the
External Consultant, requesting the amendment to be made as soon as possible.
o If the change(s) are not urgent, as determined in cooperation with the DPA and / or
Department Manager (i.e. an employee acquires a 2nd mobile telephone), then this will be
included in the scope of Office side amendments as per relevant section above.
2.14 UPDATING & DISTRIBUTING THE EMERGENCY CONTACT LIST

This procedure describes the steps taken by the S&Q Department for updating and distributing the
Official Prime Emergency Contact List.
 Document Control
The official Company Emergency Contact List is a controlled document with an “Issue Date” and
“Revision Number”, and is controlled / updated / distributed by the S&Q Department. It includes
all contact numbers for the Office, key personnel and the Vessels.
 Identifying Changes
Any needed changes will be conveyed to the S&Q Department as follows:
 New personnel / changes in personnel HR Department

 Changes to contact numbers of existing personnel ICT Support Manager
 Changes to Vessels’ contact numbers ICT Support Manager
 Issuance of New Emergency Contact List

When a new Emergency Contact List is issued with a new Revision Number and Issue Date:
o The electronic record in "Archive" filesystem is updated.
o The new list is posted in the "Emergency Preparedness Cabinet" (removing the obsolete
version).
o The Updated Emergency Contact List is distributed to all Office personnel and Vessels through
the ERP system.
 Distribution of the Emergency Contact List to the Fleet Vessel

o As soon as file is distributed through ERP system, an e-mail is sent throughout the Fleet Vessels
with instructions where to post:
o Ship’s Office
o Master’s Officer
o Bridge,
o Engine Control Room
o Cargo Control Room
o Officers Messroom
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o Crew Messroom
o In Citadel – close to the Iridium Telephone
o Hospital Room
o In addition the Master is instructed to make copies of the contact list – to be filed in the front
of the Oil Pollution Plans onboard (always removing the obsolete versions).
3. RECORDS.
IMS Amendment Record PRO/PR01/ OFF/SAQ/401
Log of IMS Amendments PRO/PR01/ OFF/SAQ/402
Company Circulars Register PRO/PR01/ OFF/SAQ/403B
IMS Amendment Proposals/Office Staff PRO/PR01/ OFF/SAQ/404
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IMS Procedures PROCEDURE 01A
(002) VESSEL’S REPORTS, RECORDS Revision: 03
AND LOG BOOKS Eff. Date: 30/09/2022
Contents
1. PURPOSE .................................................................................................................................... 2
2. PROCEDURE .............................................................................................................................. 2
2.1 Monthly and Periodical Reports ............................................................................................... 2
2.1.1 Reports – Filling-in and Sending to Office .................................................................................................... 2
2.1.1.1 Sending Reports by E-Mail ............................................................................................................................ 3
2.1.1.2 Sending Reports by Mail ............................................................................................................................... 3
2.2 Vessel’s Standard Filing System & Retention Time of Records .............................................. 4
2.2.1 Vessel’s Standard Filing System ................................................................................................................... 4
2.2.2 Retention Time of Records ............................................................................................................................ 7
2.3 IMS Sources of Information & Log Books .............................................................................. 7
2.3.1 Minimum Publications Onboard .................................................................................................................... 7
2.3.2 Library Organization...................................................................................................................................... 7
2.3.3 Inventory of IMS Publications ....................................................................................................................... 8
2.3.4 Use of Library Books Onboard ...................................................................................................................... 8
2.3.5 Supply of Publications & Vessel’s Logbooks ................................................................................................ 8
2.3.6 Marshall Islands Requirements ...................................................................................................................... 8
2.4 Posting of Certificates, Policies & Other Placards .................................................................. 9
2.4.1 ISM Certificates & Other ............................................................................................................................... 9
2.4.2 Marshall Islands Requirements ...................................................................................................................... 9
2.4.3 Company Policies ........................................................................................................................................ 10
2.4.3.1 Additional Company Policies ...................................................................................................................... 10
2.4.4 Company Forms, Placards & Posters which must by Posted ....................................................................... 11
3. RECORD ................................................................................................................................... 14
Page 1 of 14
1. PURPOSE
This procedure describes the arrangement for submitting reports from the ship to the Office.
Reference is also made to the IMS Procedures Manual (PRO 02):
 PROC 02- “Control of Records”.
 PROC 07- “Communication”.
2. PROCEDURE
2.1 MONTHLY AND PERIODICAL REPORTS
Reports must be submitted to the Office in accordance with the latest version of form
SF/SAQ/431 “Vessel’s Standard Reporting to Office”.
This report has separate Sections for each Office Department i.e
S&Q, Crew, Technical, Vetting/Marine, Security and Operations.
The form lists the Title of Forms, their IMS Number and the Mode of Sending the reports to the Office.
Presently, the forms are processed as follows:
 Sent by e-mail attachments, signed electronically.
 Sent through the ERP- ISM (through Daily Replication).
 Some forms, although processed in one of the two modes above, are also requested to be sent
in Hard copy, in cases where with original signatures are important.
2.1.1 Reports – Filling-in and Sending to Office

As a general rule, reports submitted to the Office must be typed. (i.e Safety Meetings, Master’s
Reviews, Inspection of LSA & FFE, etc)
However, in certain cases, Hand written notes are acceptable or even mandatory.
Some important checklists, must always be in HAND-WRITING, because this is the natural way to
be filled in during the various Shipboard Operations.
All forms which have to be in hand-writing have a note in RED Colour requesting this.
These Checklists are the following:

 Bridge Checklists,
 Cargo Operations Checklists,
 Work Permits,
 Crew Familiarization Checklists,
 Contractor’s Familiarization Checklists,
 Visitors Familiarization Checklists,
 Stowaway Search and Bomb Search Checklist etc,
 Armed Guards Familiarization Checklists etc.
Page 2 of 14
Each report must have the signatures of the Officers and the Master, as indicated on the IMS Form
(electronic signatures accepted).
The Company has installed the ERP ISM, and gradually, all the Vessel’s reporting will be processed
through the ERP ISM.
However, until this is fully implemented, the following procedure still applies for reports which are
sent to the Office by e-mail and documents which are sent by mail.
2.1.1.1 Sending Reports by E-Mail

When sending the reports by E-MAIL, separate messages must be sent to each Department having
attached the reports for the particular Office Department i.e.
 January Reporting–Bunker Forms –Part 1
 January Reporting- Bunker Forms -Part 2 etc
Do not attach reports to various Office Departments in one e-mail addressed to a specific Office
Department, as there is the danger that some reports will be missed by the other Departments.
When sending the reports or other Documents to the Office by MAIL, they must be grouped per
department i.e.
A. For Technical Department.
B. For S&Q Department.
C. For Crew Department etc.
2.1.1.2 Sending Reports by Mail

The Reports on IMS Forms are processed through the ERP or are sent by e-mail.
However, some other Documents, may be sent by Mail (i.e drawings etc).
Each Monthly dispatch of Vessel’s Reporting to the Office must be accompanied by the Mail
Dispatch List (SF/SAQ/430).
This form includes a space in order to note down, any Documents which are sent to the Office.
In case of loss of the mail package, the UPS or DHL Code Number, enables the Office to seek it and
if not found, it enables the Vessel to immediately identify which Documents have been lost and
resend them.
When the Vessel’s Master sends a Mail package to the Office on the day of dispatch, a Mail
Notification Report (Form SF/SAQ/430A) must be sent by e-mail attachment or fax, whichever is
convenient, notifying the Office of the Package ID number, Airway bill, Date of dispatch, Port of
Dispatch, Agent’s Name.
In this way, the Office will be aware of what to expect and will be alert in case the Mail Package
delays and will take all necessary actions to trace it.
The Agent, who will mail the package to the Office must be notified of the full address of the Office
premises.
This is done by sending the form TEMP 12 -“Notice to Agent”, which has the Company’s Full
Address.
Page 3 of 14
2.2 VESSEL’S STANDARD FILING SYSTEM & RETENTION TIME OF RECORDS

This section describes the Vessel’s Standard Filing System and defines the retention time records.
2.2.1 Vessel’s Standard Filing System

The company has established a uniform Vessel’s Standard Filing System to be followed by all Fleet
Vessels.
Upon acquisition of a new Vessel, the Office prepares the entire Filing System, with Labels, interior
separators, Filing plan pages and sends it onboard to be implemented immediately upon receipt.
A. Filing Categories:
The Vessel’s Filing System is divided into the following Filing Categories:
 Master’s Filing System:
o Master’s Technical Files numbered TEC 01, 02 etc
o Master’s Crew Files numbered CRW 01,02 etc
o Master’s S&Q Files numbered SAQ 01, 02 etc
o Master’s Operations Files numbered OPS 01, 02 etc
o Master’s Purchasing Files numbered PUR 01,02 etc
 Bridge Filing System numbered BGR 01,02 etc
 Chief Engineer’s Filing System numbered CHE 01,02 etc
 Chief Officer’s Filing System numbered CHO 01,02 etc
 Security Officer’s Filing System numbered SEC 01,02 etc
 Safety Officer’s Filing System numbered SAF 01,02 etc
 Galley Files numbered GAL 01,02 etc
This numbering system enables to add, if necessary, more files in each Filing Category, without any
problem in the numerical continuity, within the category.
The numbers to be used for the files of the Official Vessel’s Filing Plan are from
Numbers: 01 to 49
In case a Vessel’s Masters and Officers would like to keep additional files, in excess (not instead) of
the Official Files then their numbering must start from Number 50+
Examples: if the Master would like to keep an additional Crew File he may number it CRW 50, 51,
etc.
If the Chief Engineer wants to keep an additional file it must be numbered CHE 50, 51, etc.
In this way, the Non Official files are very easily identifiable.
When the forms will be fully processed through ERP, the majority of Files will be cancelled.
The only Files which will remain will be those, which will include reports which are filled–in by
hand, External Audit Reports, and 3rd Party Reports etc.
Page 4 of 14
B. Colour of Files
Each Filing Category has a different colour:
Master’s Filing System BLUE
Bridge Filing System YELLOW
Chief Engineer’s Filing System BLACK
Chief Officer’s Filing System RED
Security Officer’s Filing System AQUA
Safety Officer’s Filing System GREEN
Galley Files ORANGE
C. Quality – Type of Files

The files to be used must be of good quality, with plasticized cover and must have fasteners with
two (2) holes (not four).
The files must have a plastic pocket for the Label.
In this way, the label is protected and does not wear out.
However, the initial Filing System is sent from the Office, and annually, spare files are sent for the
replacement of old, worn-out files.
D. File Labels
All the Vessels must strictly use the File Labels, exactly as sent from the Office.
Other Labels must not be used, as it is very important to have uniformity on all our Vessels, to
enable rotating Masters and Officers to immediately familiarize themselves on any Company
Vessel.
The entire Standard Vessel’s Filing System is sent in the IMS CD, on acquisition of the Vessel,
and is resent when there are amendments to the Filing System.
Therefore, it is very easy to find and produce the labels, as required.
Each Label is divided into four parts:
 PART 1 - Company Logo (Prime)
 PART 2 - File Number (e.g. SAQ 01)
 PART 3 - File Title (e.g. ISM External Audits)
 PART 4 - File Category (Master)
E. Separators
The standard separators used for the Filing System are:
 Green Plastic Separators (“Durable” – full Page A4 size)
 Green Carton Separators (small size)
These separators are sent from the Office.
In order to maintain uniformity, it is suggested to request such separators from the Office, when
required.
Separators of other kinds and colours must not be used.
Page 5 of 14
F. Filing Plan Page

For each separate file, there is a “Filing Plan” page.
This “Filing Plan” explains in detail how the File must be organized and maintained.
It describes the names of the internal separators, their sequence, the retention period of the
documents included, etc.
The “Filing Plan” page must be filed in plastic pocket as Cover Page in each separate File for quick
and easy reference.
In this way, even a new Officer will be able to file all Documents correctly and easily.
The Filing Plan page also has reference to the relevant IMS procedure.
G. Filing Plan in IMS CD

The entire Vessel’s Filing System is included in the IMS CD, which is always sent to the Vessel
upon acquisition under the Company Management.
All information included in the CD must be copied in the Vessel’s Computers.
The existence of the Standard Filing System in CD enables the reproduction onboard of any Filing
Plan, Label, etc. at all times.
H. Vessel’s Standard Filing System – General Outline
For a quick and easy reference of the Vessel’s Standard Filing System, S&Q has issued
a “Filing System – General Outline” (Office Form OFF/SAQ/421)
This Outline lists the IMS System of the Company (all the Manuals, copies available onboard,
Circulars Files, etc.) as well as all the Vessels Standard Files listed per Filing Category (Master,
Bridge, Chief Engineer, etc.).
In addition, it includes the Forms, which must be filed in each file as well as their retention period.
Five (5) copies of this “Filing System – General Outline” are provided onboard for the Master,
Bridge, Chief Engineer, Chief Officer / Safety Officer.
They are provided in soft plastic folders.
The Standard Filing System like any IMS Documentation is subject to amendments and
improvements.
When a change is made, the Vessels’ Personnel are notified accordingly and new Files, Filing Plan
Pages or Interior Separators are sent onboard.
It must be stressed that an organized, presentable Filing System is always appreciated by Third
Party Inspectors/Auditors, since it defines the professionalism of the Company and of the Vessel
Organisation.
Additionally, it enables our rotating Masters and Officers to adjust immediately on any Company
Vessel.
The Vessel’s Standard Filing System must be strictly followed.
Page 6 of 14
2.2.2 Retention Time of Records
A. General Rule
The retention time of records is as follows:
 Deck, Engine and Cargo Log Books, Oil Record Books must be retained for at least three (3)
years, roughly covering the period between two (2) successive ISM External Audits.
This retention period is being reconfirmed with Certification Body during the Annual Office
Verification Audit.
 Shipboard Records must be retained on board for at least three (3) years, roughly covering the
period between two (2) successive ISM External Audits.
 ISM External & Internal Audit Records must be kept for five (5) years covering the period
between the Initial Audit and the SMC Renewal Audit.
 Voyage Records and related correspondence must be retained on board for two (2) years, and
then they must be sent to the Office.
 Bridge Daily Checks must be retained onboard for minimum three (3) months.
 Weather Reports must be retained for minimum (6) months and maximum one (1) year.
 All records kept by the Chief Engineer, Chief Officer / Safety Officers as copies, in addition to
Master’s Filing System, may be kept for a shorter period as long as needed (e.g. one year).
All retained documentation must be reviewed annually and time expired material must be disposed
of.
2.3 IMS SOURCES OF INFORMATION & LOG BOOKS

This section describes the procedure for the supply and control of Information sources related directly
to the IMS.
The provision of these Publications is to enable a greater understanding of the Rules, Regulations,
Codes and Guidelines, related to operation of the ship.
It also describes the procedure for ordering Log Books.
2.3.1 Minimum Publications Onboard

The Publications which must always be available on board at all times, are as per the latest version of
IMS Form SF/MRS/228-“IMS Sources of Information”.
(Hard Copy and Electronic Publications are included).
2.3.2 Library Organization

Each document must be marked with a Control Name/Number.
An Index of the publications must be maintained stating:
A. Ship’s name
B. Title
C. Location
Publications may be held on CD, when available.
(Instead of keeping a separate Index, the Inventory IMS Form is acceptable, since it provides all the
information mentioned above)
Page 7 of 14
2.3.3 Inventory of IMS Publications
An inventory of all the above publications must be carried out every three (3) months, to ensure that
they are available on board.
The Company is responsible for forwarding updates of the Publications to the ship.
In order to ensure that the Fleet Vessels are always supplied with the Publications of the latest edition,
the Company has made Contract Agreements with the suppliers for “Automatic Supply”.
The Master is responsible for ensuring that the publications are marked with the “Control Number”
before placing them in the Vessel’s Library.
2.3.4 Use of Library Books Onboard

If a Library Book is removed from the Vessel’s Library location in order to be studied, then a note
must be posted on the Library, stating the Name of the Officer and the Date the book was taken and
the date returned.
The Publications must be returned to the Vessels’ Library, the soonest possible, and must not be left in
Officers’ Officers or cabins.
It has happened that during Vetting Inspections, books that had been reported as existing, could not be
found during the Inspection and as a result, a Comment was raised.
2.3.5 Supply of Publications & Vessel’s Logbooks

The Marine /Vetting Department is responsible for the supply of Publication and Log Books.
All Vessels Masters and Officers must submit requisitions to the Marine/Vetting Department for the
supply of:
 Charts and Publications.
 Deck and Engine Logbooks.
 Oil Record Books.
 Bell Books.
 Garbage Books.
 Radio Logs.
 GMDSS Logbooks etc.
2.3.6 Marshall Islands Requirements

(Maritime Regulations – General – Chapter 1)
Administration of Regulations – Combined Publications Folder §1.03
On board all Marshall Island Flags the MI-300 Publications must be available, either in Hard Copy, in
CD or in ERP.
A combined Publication Folder (Hard Copy, or CD or Electronic Folder) containing the Marshall
Islands Maritime Act 1990, as amended, Maritime Regulations, Investigation and Hearing Rules,
Marine Notices, Vessel Registration and Mortgage recording procedures and Requirements for
Merchant Marine Personnel Certification shall be carried out on board each Vessel in the Registry.
The latest MI-300 contents must be present on board at all times.
Page 8 of 14
The Contents of the MI-300 Publication or CD are found in the website of the Administration of
Marshall Islands : www.register-iri.com
2.4 POSTING OF CERTIFICATES, POLICIES & OTHER PLACARDS

This section describes the procedure for the posting of Ship’s Certificates and Company Policies.
2.4.1 ISM Certificates & Other
SOLAS and the ISM Code do not clearly require that the Certificates must be posted but state that
they must be readily available onboard.
However, since this is required in many Ports, copies of the Ship’s ISM Certificates may be posted up
in a prominent and accessible place in the ship.
This includes:
A. DOC-Document of Compliance (DOC)
B. SMC-Safety Management Certificate (SMC)
C. ISSC-International Ship Security Certificate (ISSC)
D. Safe Manning Certificate
MLC 2006, requires the Posting of the following Certificates:

E. MLC 2006– Maritime Labour Certificate
F. DMLC– Declaration of Maritime Labour Compliance
(MLC 2006-Regulation 5.1.3-Standard 12 )
G. Manning Agent’s MLC 2006 Certificate
H. Financial Security Certificate-for compensation in the event of abandonment ( repatriation)
(MI-108- § 7.52.4 f)
G. Financial Security Certificate-for compensation in the event of contractual claim involving
death or long term disability ( MI-108- § 7.52.4 f)
The above Certificates must be posted in Ship’s Office and/or Master’s Office.
2.4.2 Marshall Islands Requirements

Maritime Regulation – Merchant Seafarers – Chapter 7
A. Minimum Safe Manning Certificate (§7.38.6)

Safe Manning Certificate must be conspicuously posted.
The other Certificates issued under SOLAS Chapter I, Regulations 12 & 13 are not required to be
posted, however they must be readily available in Master’s Certificates Files.
Page 9 of 14
2.4.3 Company Policies

A. The following Company Policies must be posted:
 Quality, Safety and Health Policy.
 Environmental Protection and Energy Efficiency Policy.
 Drug and Alcohol Policy.
 Statement of Master’s Ultimate Authority.
 Security Policy.
 Vision Statement
 Mission Statements.
 DPA & CSO Placard.
 Anti-Bullying Policy (required by MLC 2006).
 Whistle-blowing Policy.
The above Policies must be posted in the Master’s Office/Ship’s Office, Officer’s mess-room and
Crew Mess-room.
2.4.3.1 Additional Company Policies

The Company has issued additional Policies as follows:
 Corporate Social Responsibility Policy
 Anti-bribery Policy
 Sexual Harassment Policy
 Social Media Policy
 CCTV Policy
 Company Travel Guide/Policy
 Office Building Security Policy
 General Data Protection Policy
 Whistle-blowing Policy-Office
 Computer, E-mail and Internet Usage Policy
 Mobile Phone Use Policy-Office
 Workplace Violence Prevention Policy
 Remote Work Conduct Policy
 Information Security Policy
 Clean Desk and Clear Screen Policy
 Information Classification Policy
The above Policies, at present, are not required to be posted, however, the Masters and Officers must
be well aware, that they are found as Appendices in the IMSM (01) Manual- and can easily be retrieved,
during Audits and Inspections.
Additionally, in the Officers’ and Crew Messrooms, copies of the above mentioned Policies are found
filed in Folders, for review, familiarization, and refresher training.
Page 10 of 14
2.4.4 Company Forms, Placards & Posters which must by Posted

The following Table serves as a guide of where to post some of the IMS Posters:
Number Title Locations to be posted

SF/TEC/124 Engine Room Standing Orders To be posted in the Engine Control Room
SF/MRS/201 Bridge Standing Orders To be posted on the Bridge
N/A DPA Placard This is provided in six (6) copies and must be
posted in:
 Ship’s /Master’s Office
 Bridge
 Engine Control Room
 Cargo Control Room
 Officer’s Messroom
 Crew Messroom
N/A CSO Placard This is provided in six (6) copies and must be
Company Security Officer posted in:
 Ship’s/Master’s Office
 Bridge
 Crew Messroom
N/A EMERGENCY CONTACT This is provided in Nine (9) copies and must be
LIST posted in:
 Ship’s Office
 Master’s Office
 Bridge
 Crew Messroom
 Citadel- close to Iridium Telephone
 Hospital Room
N/A Crew Complaints In conspicuous places (i.e in Officers and Crew
Office Designated Person Messrooms)
Placard (Form SF/CRW/521)
and
Contact Points of Competent
Authority in various countries
for Crew Complaints
SF/SOS/100 Master’s Media Statement To be posted on Bridge – near Bridge
Telephone
Page 11 of 14

N/A Ship Medcare Doctors To be posted :
 in Hospital Room
 on Bridge
Posters Responsibility Posters These must be posted in the crew cabins per rank.
01-14A
PPE Matrix Tables To be posted in conspicuous places in the
MATRIX SAF (003) -Section 03 Accommodation and Engine Control Room spaces.
Posters 15B Galley Safety Posters A number of them may be posted in the Galley
Spaces, Laundry Spaces, etc
Mandatory: Poster 4C- Deep Fat Fryer
Poster 4D- Laundry Dryers
Poster 16- No Smoking Poster To be posted in locations where smoking is not
16A allowed, as required.( Messrooms, CCR, ECR etc )
Poster 22 Food Choking First Aid To be posted in Hospital Room

Poster 23 Brazilian Sanitary Authority At a conspicuous place near the Galley and/or
A-BC-C Requirements Provision rooms (when Vessels are calling at
Brazilian Ports )
Poster 24 Man-Overboard manoeuvres This must be posted on the Bridge.
Poster 25 Calling the Master This must be posted on the Bridge.
Poster 26 Calling the Chief Engineer This must be posted in the Engine Control Room.
Poster 27 Safety Procedures in E/R This to be posted in Engine Control Room.
Poster 28 Bridge Watch Types This to be posted on the Bridge.
Poster 30 SSO Poster This must be filled-in onboard with the name of the
Ship Security Officer current SSO and must be posted in conspicuous
places onboard.
( Bridge, Messrooms etc)
Poster 31 Inert Gas Procedures This must be posted in the Engine Control Room.
Poster 33 Shipboard Incineration This must be filed near the Incinerator.
Poster
Poster 34 Mooring joining shackles This must be posted in the Bosun’s store room.
connecting the wires to the
tails.
Poster 35 Environmental Poster In a conspicuous place onboard i.e messrooms and
used for training
Poster 36 VDR Poster Must be posted on the Bridge
Poster 39 Shipboard Environmental To be posted in conspicuous places
Instructions
Page 12 of 14

Poster 40 Cleaning of M/T To be posted in the Engine Room,
Turbocharger & Exhaust
Gas Boilers
Poster 41 AIS Poster To be posted on the Bridge
Poster 42 COT Pressure Alarm To be posted in the CCR
Poster
Poster 43 UKC ( Underkeel To be posted on Bridge
Clearance)
Poster 44 Oil Transfer Procedures To be posted in the ECR
Poster 45 Engine Log Book Entries To be inserted in Engine Log Book for reference
Poster 45A Deck Log Book Entries To be inserted in Deck Log Book for reference
Poster 47 IMO Required Boarding To be posted on the Bridge
Arrangements for Pilot
Poster 48 Incinerator Poster To be posted at the Incinerator control
Drainage of Incinerator
Storage Tank to the bilge
system is prohibited
Poster 49 Warning for isolation o To be posted on systems and equipment which must
systems and equipment for be remain isolated during Diving Operations
safe Diving Operations
POSTER 50 Keep Portholes closed To be posted next to Portholes
POSTER 51 Drug Abuse and To be posted in the Officers’ and Crew Messrooms
Trafficking
POSTER 52 CCTV Warning Poster To be posted on the Bridge and in the ECR
POSTER 53 Clean Seas Award To be posted in the Officers’ and Crew Messrooms
POSTER 54 Bunker Accountability To be posted in the Officers’ and Crew Messrooms
Whistle- As found in IMSM (001)
Blowing Appendix X
Policy
POSTER 55 STOP WORK To be posted in the Officer’s and Crew Messrooms
AUTHORITY
/OBLIGATION
SF/SOS/056 Information Security To be posted near the Vessel’s Computers
Emergency
Response Plan
POSTERS 56 Information Security To be posted near the Vessel’s Computers
(A-J) Posters
POSTER 56A Information Security To be posted near the Vessel’s Computers
Emergency
Vessel’s Business
Continuity Plan –
Server’s Malfunction
Page 13 of 14

SF/TEMP/07 Master’s Contingency  Bridge
Contact List  Ship’s Office
 Master’s Office
 Satellite Phone
 DMSS Console
 Cargo Control Room ( SIRE 2.0 §5.1.3)
POSTER 57 Mental Health Symptoms To be posted in the Officers and Crew Messrooms
& Support Networks
POSTER 58 Safety in the Ship’s Gym- To be posted in the Ship’s Gymnasium
Lifting Heavy Weights
POSTERS 59 Anti-bullying Posters To be posted in the Officers and Crew Messrooms
(A-E)
Placard 1 SF/MRS/212A To be posted near the Galley, Messrooms, Laundry
Summary of at Sea Rooms, Corridors and in the Main Garbage Storage
Garbage Disposal Location or Garbage Storage Room
Regulations of Marpol
Annex V
Placard 2 SF/MRS/212B- Garbage To be posted near the Galley, Messrooms, Laundry
Management Plan Rooms , Corridors and in the Main Garbage Storage
Location or Garbage Storage Room
SF/COV Posters COVID -19 Posters To be posted at conspicuous places.
P-01 to P-06 Series SF/COV/P01- to P06 and any other guiding
Posters from WHO and other Organizations.
3. RECORD
For all Standard reports to all Departments:
 Vessel’s Standard Reporting to Office
(Monitoring List) PRO/SECTION 01A/ SF/SAQ/431
This report is in a small soft cover file – and must be kept on Master’s desk.
This report does not have to be sent to Office – it is just to assist the Vessels’ Personnel in
monitoring the Standard reporting to the Office.
For Mailing Reports in Hard Copy only

 Mail Dispatch List PRO/SECTION 01A/ SF/SAQ/430
 Vessel’s Standard Reporting to Office. PRO/SECTION 01A/ SF/SAQ/431
 Mail Notification PRO/SECTION 01A/ SF/SAQ/430A
 Notice to Agent PRO/SECTION 01A/ TEMP 12
SF/SAQ/430 must be sent accompanying the Mail Package.
SF/SAQ/430A must be sent by e-mail or fax on the day of mail dispatch.
Page 14 of 14
(002) Revision: 06
CONTROL OF RECORDS Eff. Date: 30/11/2021
Contents
1. PURPOSE ............................................................................................................................. 2
2. PROCEDURE ....................................................................................................................... 2
2.1 Office Forms ................................................................................................................... 2
2.1.1 Electronic Records ................................................................................................................................ 2
2.1.2 Hard Copy Records ............................................................................................................................... 2
2.1.3 Retention Time of Hard Copy Records ................................................................................................. 3
2.1.4 Storage of Hard-Copy Records ............................................................................................................. 3
2.2 Control of Environmental Records ................................................................................. 3
2.2.1 Environmental Records ......................................................................................................................... 3
2.3 Updating & Control of the “ISM LIBRARY” Inventory ............................................... 6
2.4 Control of Third Party Documentation ........................................................................... 6
3. RECORDS ............................................................................................................................ 7
Page 1 of 7
(002) Revision: 06
1. PURPOSE
This procedure describes the process which is followed for maintaining Records of Company
activities.
Records are considered all the filled-in IMS Forms, the Log Books, various Certificates, and
Receipts etc.
Each Office Department and Vessel is responsible to establish and maintain their own Control of
Records in the relevant Files of their Filing System.
2. PROCEDURE
2.1 OFFICE FORMS

The Company keeps records of all correspondence and documentation, in hard copy and/or
electronically.
Each Department has its own Filing System (Hard Copy and/or Electronic).
The Forms and Reports are also available in the ERP IMS Module, which has significantly reduced
the hard copy records.
2.1.1 Electronic Records

The Company has purchased a “Document Management System” that automatically handles
archiving of all Company e-mails (incoming and outgoing).
Confidential information is being filtered based on the security profiles available in the Document
Management System.
The Company’s electronic records are protected from:
 Damage, deterioration and loss through the Backup procedure
(ISMS-PROC 05I-Backup Procedure”,
and
 Unauthorized access through the Access Management Procedure
(ISMS-PROC 04A-Access Management Procedure”).
2.1.2 Hard Copy Records

Some Hard Copy Records are held by each Department.
Each Office Department must establish a "Department Filing System" which must enable records
to be readily identifiable and retrievable.
The Filing System of each Department must be officially established
For easy reference, the relevant Form OFF/SAQ/420 "Office Filing System- Outline" may be
maintained (optionally). If used, it must be periodically, reviewed for consistency.
The following must apply to Hard Copy Records:

o Hard copy Records must be filed in good quality Folders. Any damaged Folders must be
replaced.
o All Folders must have labels (as per Company format), stating the Number of the File and
the Contents.
o Documents of a different subject, year etc, filed in the same Folder, must be sorted by
separators, to enable a quick review with no loss of time.
Page 2 of 7
(002) Revision: 06
o Certificates and other important Documents, which are to be retained for many years, must
be filed in plastic pockets to avoid deterioration.
o The numbers and the contents of the Folders must be in accordance with the Filing System
of each Department, as found documented in the "Archive" Database.
o All Hard Copy records must be clearly identified, filed and stored to facilitate ease of
retrieval.
o IMS records must be kept in an environment suitable to minimize deterioration or damage,
to prevent loss and must be easily retrievable.
o All Holders must be responsible for updating their files.
o Highly confidential information must be secured.
2.1.3 Retention Time of Hard Copy Records
The retention time of Hard Copy records is five (5) years for all Documents.
Records which are necessary for Legal purposes and Claims must be retained as long as required.
2.1.4 Storage of Hard-Copy Records

Each Office Department is responsible for the storage of Hard Copy Records (if such are
maintained) of previous years.
The storage must be in an organized way.
Files containing records of a particular year must be stored on shelves for each Department,
suitably labeled and with a "Department Name" posted on them for easy identification.
The Office Administrator is responsible to ensure that the storage space provided is suitable for
the protection of the Company records, from damage, deterioration and loss.
2.2 CONTROL OF ENVIRONMENTAL RECORDS

This section describes the procedures followed by the Company for the control of Environmental
Records as per ISO 14001:2015 requirements.
2.2.1 Environmental Records
The Environmental records which must be retained are the following:
o Office Records
- EMS Programs;
- Environmental Work Instructions ;
- Environmental Risk Assessments;
- Environmental Management Reports;
- Management Review Meeting Minutes;
- Internal and External Environmental Management Audits;
- Environmental Training Records of Office and Shipboard employees;
- Declaration of Environmental Compliance of Hull/ Steel Contractors;
- Receipts for Recycling etc;
- Receipts for the purchase of Photocopy paper, electricity bills, water bills etc;
- Vessel’s Environmental Reporting: “Environmental Workbook”;
- Other records, as required
Page 3 of 7
(002) Revision: 06
As a general rule, hard copy records are kept in the Office for a period of five (5) years.
Records of sold Vessels are retained for one (1) year after their sale, except for documents which may
be required for claims.
o Shipboard Records
- Environmental Work Instructions issued by the Company (other than Manual
Procedures);
- Environmental Training Records;
- Environmental Audits;
- Environmental Risk Assessments;
- Ozone Depleting Substances List- (Marpol Annex VI) included in Environmental
Workbook;
- Bunker Delivery Notes ( BDN ) - (Marpol Annex VI );
- Records of Statutory Bunker Samples - (Marpol Annex VI );
- Vessel’s Environmental Reporting: “Environmental Workbook”.
- Biofouling Management Plan.
With regard to the Environmental Workbook (which constitutes part of SEEMP) the
following apply:
o “Environmental Workbook” has to be submitted by the Vessel to the
Environmental Department at the end of each month, as a Monthly report.
o The monthly “Environmental Workbook” will be post-processed by Office
Environmental Engineers and each Vessel’s results will be evaluated and / or
corrected.
The aforementioned corrected reports will be:

o Forwarded back to each Vessel quarterly and will be electronically filed as
SEEMP Annex, under directory Common/SEEMP.
o Used to create the Office Environmental Management Review Meeting report
which will be sent back to each Vessel quarterly and will be electronically filed as
SEEMP Annex, under directory Common/SEEMP.
The above mentioned SEEMP Annex will be updated every three months following
Office Management Review Meetings. In MRM document, Company’s
Environmental Performance Indicators (EPIs), Vessels’ individual performance for
each EPI and Company’s average values are indicated. Relevant graphs and statistics
are also included.
o Other Records must be maintained , as required

Log Books
- Oil Record Book
- Garbage Record Books
- Engine Log Book
- Cargo Log Book
- Fuel Type Change-over Logbook
- Ballast Water Record Book
Page 4 of 7
(002) Revision: 06
Various Receipts
- Receipts for the disposal of Garbage to Shore Facilities
- Receipts for the disposal of Slops to Shore Facilities
- Receipts for the landing of Ozone Depleting Substances to Shore Facilities
- Receipts for landing Statutory Bunker Samples
Various Analysis Reports
- Lub-Oil Analysis Reports
- Fuel Analysis Reports
- MSDS Sheets
- Various other Laboratory Reports (e.g. from potable water tanks etc).
All above records are maintained onboard as per the Vessel’s Standard Filing System.
As a general rule, hard copy records of documentation are kept on board the Vessels for a period
of three (3) years,
with some exceptions, depending on the nature of the documents and on International Requirements.
 Third Party Environmental Bulletins

Third Party Environmental Bulletins (i.e. HELMEPA) are kept both in Office and Onboard.
The Environmental Management Representative has a special file in his Filing System. Onboard,
such Bulletins are filed in the Master’s File (Electronic Filing is acceptable).
 Law, Regulations, Codes, Directives etc.

Laws, Regulations, Codes and Directives are maintained by the Environmental Management
Representative, in electronic form or in hard copy.
Copies of all environmental legislations are kept in the Filing System of the Environmental
Management Representative (Hard copy or electronically).
 Environmental related Certificates

Environmental related Certificates are the following:
o ISO 14001 Certificate. The Original Certificate must be held by the S&Q Department. The
EMR must have a copy in his own Filing System.
o A copy of this ISO 14001 Certificate must be sent to the Vessels.
Other Vessel Certificates related to the Environment:
o International Oil Pollution Preventions ( IOPP )
o International Air Pollution Prevention Certificate (IAPPC)
o Engine International Air Pollution Certificate ( EIAPP)
o Vapour Emission Control System (VEC) Certificate.
o Incinerator IMO Type Approval Certificate etc.
o Noxious Liquid Substances Certificate
o Sewage Pollution Certificate
o Garbage Pollution Prevention Statement/Certificate
o Oil Separator Statement ( Applicable to all Vessels)
o ODME Statement ( Applicable to Oil & Chemical Tankers)
The above Certificates are maintained onboard, as per the Vessel’s Standard Filing System.
Copies are retained in Office, by the Technical Department.
Page 5 of 7
(002) Revision: 06
2.3 UPDATING & CONTROL OF THE “ISM LIBRARY” INVENTORY

This section describes the steps taken for the updating and control of the “ISM LIBRARY
INVENTORY”.
 General Information
A. The ISM Library is held by the S&Q Department in a clearly marked cabinet, for the
use/reference of all Office Personnel.
B. Inside the cabinet, the current Inventory List (Title / Control Number) is always posted.
C. The ISM Library consists of various forms of Publications, which include, but are not limited
to, Books, Pamphlets, Compact Discs, and Reports etc.
 Assignment of Control Numbers

All Publications, whatever their format, are given a control number.
A. Control Numbers are grouped according to the Publisher. For example, all items published by
IMO have a control number beginning with the letter ‘A’, and all items published by OCIMF
have a control number beginning with the letter ‘B’.
B. Following the first letter is a decimal point and then the actual publication number. For
example, SOLAS has the ID number ‘A.1’ and STCW has the ID number ‘A.2’ – as both are
published by IMO.
C. If a separate Amendment or Annex to a specific Publication is issued, it will be entered directly
after the parent publication. For example, if a separate amendment to SOLAS is issued, it will
have the ID number ‘A.1.a’ (as the SOLAS has the ID. number ‘A.1’).
 Supply of Publications
A. The S&Q Department is responsible to arrange for the Office supply of all current publications
that are directly related to International Safety Management and for keeping the Inventory
updated.
B. The ISM Library Inventory will be updated accordingly – removing obsolete versions if
necessary, and posting the new Inventory List inside the Library Cabinet.
2.4 CONTROL OF THIRD PARTY DOCUMENTATION

It is the responsibility of shore-based staff and Vessels crew to ensure that the use of these
reference documents is correct and up-to-date.
The documents, therefore, are located in Office and Vessels’ libraries.
Where only a reference is given in the instructions on board ship, the relevant part of the third
party document must be available, accessible and suitably identified and controlled.
The Company maintains a contract with an approved supplier to provide updated information with
respect to:
 Navigation charts,
 Nautical publications,
 IMO amendments (includes SOLAS and MARPOL),
 OCIMF new editions,
 ICS new editions,
 Other (SIGTTO etc).
Page 6 of 7
(002) Revision: 06
Classification Regulations are updated through direct contract with the appropriate Societies.
For legal or knowledge purposes, obsolete copies, clearly marked as "superseded", may be retained
by the Safety & Quality department. All other copies will be destroyed.
 Legal, Regulatory, Statutory and Other Requirements

The purpose of this paragraph is to create a list of those regulatory requirements that are already
being addressed to the Company.
The Legal Department identifies and organizes Vessel and shore-based services, data,
operations and activities that have, or may have, regulatory relevance. For each record or
activity, the Legal Department investigates whether there is a regulatory relevance, and if so,
which specific laws, regulations, or other requirements are involved.
For each relevant law, regulation, or other requirement, the responsible Management
Representative ensures that copies of the regulations are available, or can be easily accessed
(for example, on the internet or through an attorney or consultant).
 Identification of Legal and Regulatory Requirements

The purpose of this paragraph is to identify applicable laws, regulations and other
requirements; to establish a library of relevant laws, regulations, and standards (or ensure
access to these documents); and to document results in a list that will help in managing
compliance programs and in evaluation of compliance status.
Applicable laws, regulations and other requirements are listed in the corresponding procedure,
for environmental matters reference is made to procedure “Environmental Issues”.
3. RECORDS
 Office Filing System –Outline PRO/PR02/ OFF/SAQ/420

 IMS & Vessel Filing System – General Outline PRO/PR02/ OFF/SAQ/421
 ISM Library Inventory PRO/PR02/ OFF/SAQ/422
Page 7 of 7
(002) Revision: 06
IDENTIFICATION & TRACEABILITY Eff. Date: 31/08/2020
Contents
1. PURPOSE ..................................................................................................................................2
2. PROCEDURE ............................................................................................................................2
2.1 Product Realization and Processes..........................................................................................2
2.2 Control of Documents .............................................................................................................3
2.3 Filing System of Office Departments .....................................................................................3
2.4 Vessel’s Standard Filing System ............................................................................................3
2.5 Documentation and Records ...................................................................................................4
2.6 Confidentiality ........................................................................................................................4
3 RECORDS .................................................................................................................................4
Page 1 of 4
(002) Revision: 06
1. PURPOSE
This procedure describes the steps to be followed in order to ensure identification and traceability of
the company’s processes.
2. PROCEDURE
2.1 PRODUCT REALIZATION AND PROCESSES

It is very important for the Company to be able to identify the “Product/Service” throughout the
service realization.
Processes must be easily identified and traced, measured, evaluated and monitored.
This is achieved by developing official IMS forms, which are used for the issuance of relevant
Reports and other Documentation.
It is also achieved by keeping relevant Official Log Books (either provided by the Flag
Administration or developed by the Company).
For example:
 The Management Services which have been agreed between the Company and the Owners are
traced by referring to the "Management Agreement".
 The Vessel’s Certification is traced by referring to the Company and Vessels’ Certificates as
well as to the relevant Form for Certificates Status (SF/TEC/112A-B-C) and Classification
Quarterly Status Reports.
 Recruitment of Shipboard Personnel is traced by referring to Crew Personal Files of the Crew
Department in Office, and in Shipboard Files Onboard as well as in the ERP-Crew Module.
 The Current Manning level of the Vessels is traced by referring to Crew Lists.
 Charter Party Fixtures are uniquely numbered and traceable to the Vessel’s Voyage Files.
 Cargoes onboard are traced by referring to Cargo Manifests and other Cargo Documentation,
MSDS, etc.
 Purchased Material, Equipment and Services are traced by referring to Purchase Orders,
Inventory Lists etc.
 Vessel’s Maintenance Status is traced by referring to Planned Maintenance System records
(ERP PMS Module).
 The Vessel’s Electronic and Navigation equipment are traced by referring to
Inventory/condition lists –"Navigation and Electronic Equipment".
 Garbage Management is identifiable and traceable by referring to the Garbage Management
Plan and the Garbage Log Book.
 Visitors and Contractors’ Staff onboard are traced by referring to "Visitor’s Log Book" and the
Deck Log Book, Visitor’s Safety Familiarization Checklists, Contractors Safety Familiarization
Checklists, and Armed Guards Safety Familiarization Checklists.
 The progress of Ship Maintenance can be traced through the “Superintendent’s
Recommendations for Ship Staff Maintenance” Procedures.
The “Recommendations” List is updated on a continuous basis in the PMS.
 The Vessel’s Vetting Status, Flag Inspection Status, Port State Inspection Status may be traced
by referring to the relevant software.
Page 2 of 4
(002) Revision: 06
The Company has evaluated the processes which are important and must be traced immediately,
and has developed adequate Software (electronic PMS, specific Purchasing and Crew Management
software), as well as IMS Forms to be used for the implementation of the IMS.
Additionally, the Office Departments have developed a number of uncontrolled forms, serving for a
quick and easy reference in tracing the status of various activities and processes.
2.2 CONTROL OF DOCUMENTS

The traceability of all records, in Office and onboard is achieved by developing and maintaining an
official and well documented Filing System, which may be:
 hard copy,
 electronic,
 in the ERP Module,
 or a combination of all above.
2.3 FILING SYSTEM OF OFFICE DEPARTMENTS

Each Department must establish and maintain an Official & Documented Filing System, which may
be Hard Copy, electronic or a combination of both.
The Electronic Filing System of all Departments is found in the ARCHIVE Data Base, and can be
accessed by all Office Employees.
Periodically and definitely before the Annual IMS Verification Audit of the Office, by the
Recognized Organization, each Office Department must review the Filing Plan as found in the
"Archive" database, and must ensure that it is precise, valid and well organized.
As a general rule, hard copy records are kept in the Office for a period of five (5) years.
Also refer to PROCEDURE 02- “Control of Documents” of this Manual.
2.4 VESSEL’S STANDARD FILING SYSTEM

In order to achieve Filing uniformity on all Fleet Vessels, the S&Q Department has developed a
Vessel’s Standard Filing System, which is detailed, well documented and controlled ( Form
OFF/SAQ/421- IMS and Vessel Filing System –General Outline.
Masters and Officers rotating on Company Vessels are able to immediately identify and trace all
Vessel’s Certificates, Reports, Inspection Status etc.
It provides information as to:
 Filing Sets: Master / Chief Officer / Chief Engineer / Bridge / Safety Officer / Security Officer.
 Files Sizes, Numbers and Contents.
 IMS Forms to be included in the files.
 Retention Period of Records.
The Vessel’s Standard Filing System is controlled and cannot be changed by Shipboard Personnel.
Any change must follow the rules of the "IMS Amendments" procedure.
Page 3 of 4
(002) Revision: 06
Periodically, the Vessel’s Standard Filing System must be reviewed, by the S&Q Department, and
Hard Copy folders must gradually be removed, as documented information are become available
through the ERP ISM Module.
As a general rule, hard copy records are kept onboard for a period of three (3) years.
A detailed procedure regarding the Filing System and retention time of records onboard is found in
the Procedure 01A-“Vessel’s Reports, Records and Log Books”, of this Manual.
2.5 DOCUMENTATION AND RECORDS

All IMS documentation must be identified in the respective Manual Procedures.
The IMS Forms must fully support the relevant Procedures.
Records must be kept in hard copy and/or electronically.
2.6 CONFIDENTIALITY
At all times, the Company records are considered as confidential.
They may be made available to Owners, Charterers and other designated persons only when
authorized by the Chief Operating Officer (COO) or Deputy COO or his authorized representative
(i.e the DPA).
3 RECORDS
None
Page 4 of 4
(002) ACQUISITION OF NEW VESSELS & Revision: 07
NEW-BUILDING POLICY Eff. Date: 29/02/2020
Contents
1. PURPOSE ..................................................................................................................................3
2. PROCEDURE ............................................................................................................................3
2.1 Pre-Acquisition Procedures ....................................................................................................3
2.1.1 Initial Notification ....................................................................................................................................... 3
2.1.2 Pre-purchase Investigation and Review ...................................................................................................... 3
2.1.3 Final Decision ............................................................................................................................................. 3
2.2 Acquisition Procedures ...........................................................................................................4
2.2.1 Memorandum of Agreement is signed (MOA) ........................................................................................... 4
2.2.2 Delivery Date/ Port ..................................................................................................................................... 4
2.2.3 Application & Registration Process by the Legal Department .................................................................... 5
2.2.4 Management of Change/ Monitoring of the Vessel Acquisition Process .................................................... 5
2.2.5 Management Agreement ............................................................................................................................. 7
2.3 Change Of Vessel’s Name Or Flag .........................................................................................7
2.4 Acquisition of New Vessel (S&Q Department Responsibilities) ...........................................8
2.4.1 New Vessel Acquisition Checklist .............................................................................................................. 8
2.4.2 Items prepared or arranged for by the S&Q Department ............................................................................ 8
2.4.3 Updating the Management of Change Report ............................................................................................. 9
2.4.4 Vessel Leaving Management ...................................................................................................................... 9
2.5 Acquisition of New Vessel (Legal & Insurance Department Responsibilities) .....................9
2.5.1 Initial Notification ....................................................................................................................................... 9
2.5.2 The Agreements .......................................................................................................................................... 9
2.5.3 Insurance ..................................................................................................................................................... 9
2.5.4 Registration ............................................................................................................................................... 10
2.5.5 Closing ...................................................................................................................................................... 10
2.6 Acquisition of New Vessel (Technical Department Responsibilities) ................................. 11
2.6.1 Introduction of Newly Acquired Vessel .................................................................................................... 11
2.6.2 Familiarization with New Ship’s Equipment ............................................................................................ 14
2.6.2.1 ENGINE ROOM ....................................................................................................................................... 14
2.6.2.1.1 E/R Piping System/Tanks........................................................................................................................... 14
2.6.2.1.2 Main Engine ............................................................................................................................................... 14
2.6.2.1.3 Generators .................................................................................................................................................. 15
2.6.2.1.4 Oil –Fired Boilers ....................................................................................................................................... 15
2.6.2.1.5 Exhaust Gas Boilers ................................................................................................................................... 15
2.6.2.1.6 Fresh Water Generator ............................................................................................................................... 16
2.6.2.1.7 Engine Room Bilges .................................................................................................................................. 16
2.6.2.1.8 Bilge Water Separator ................................................................................................................................ 16
2.6.2.1.9 Sewage Unit/ Holding Tank ....................................................................................................................... 16
2.6.2.1.10 Purifiers .................................................................................................................................................... 16
2.6.2.1.11 Auxiliary Machinery ................................................................................................................................ 16
2.6.2.1.12 Tail-shaft .................................................................................................................................................. 16
2.6.2.1.13 Steering Gear............................................................................................................................................ 16
2.6.2.1.14 Spare Parts................................................................................................................................................ 16
2.6.2.2 DECK ....................................................................................................................................................... 17
2.6.2.2.1 Cargo Piping (on deck/ in tanks/ heating coils).......................................................................................... 17
2.6.2.2.2 Cargo Discharge ......................................................................................................................................... 17
2.6.2.2.3 Cranes and Winches for Loading /Unloaded Operations ........................................................................... 17
2.6.2.2.4 Anchor Windlass and Mooring Winches ................................................................................................... 17
2.6.2.2.5 Inert Gas System ........................................................................................................................................ 17
2.6.2.3 PUMPROOM ........................................................................................................................................... 17
2.6.2.3.1 Cargo / Ballast Pumps and Stripping Pumps .............................................................................................. 17
2.6.2.4 HULL CONDITION ................................................................................................................................ 17
2.6.2.5 SAFETY................................................................................................................................................... 18
2.6.2.6 BRIDGE APPARATI AND RADIO ....................................................................................................... 18
Page 1 of 20
2.7 New-Building Policy .........................................................................................................18

3. RECORD ..................................................................................................................................20
Page 2 of 20
1. PURPOSE
This procedure describes the steps which must be followed by Office Department for the acquisition
of a new Vessel.
The purpose of this procedure is to provide instructions related to the introduction of a newly
acquired Vessel into the company fleet, in order to ensure that all appropriate preparatory activities
are properly carried out so that all the potential risks are identified and timely addressed.
Also this procedure applies to the case of a Vessel leaving the Company’s Management, as well as
to the case of a Vessel which changes name and/or flag.
2. PROCEDURE
2.1 PRE-ACQUISITION PROCEDURES
2.1.1 Initial Notification

The Chief Operating Officer (COO) or Deputy COO notifies the Fleet Technical Manager of any
interest in new Vessel(s).
2.1.2 Pre-purchase Investigation and Review

As soon as the interest for purchasing a specific Vessel is made known to the Fleet Technical
Manager, he is responsible to initiate an "Investigation and review process" which includes the
following steps:
 Review of the Vessel’s PSC and USCG Inspection History by utilizing the Internet:
o "EQUASIS" website (PSC)
o "P-SIX" website (USCG)
 Arrangements for the review of Class Records.
 Arrangements for the physical inspection of Vessel.
Depending on the location of the Vessel, availability of Office Superintendents, etc. the
physical inspection of the Vessel may be conducted by:
o Fleet Technical Manager
o In-house Superintendent
o Outside contractor (known inspection company)
 Communication of all results/findings to the Chief Operating Officer (COO) or Deputy
COO.
2.1.3 Final Decision

It is the responsibility of the COO or Deputy COO to take the final decision regarding the purchase
of the Vessel, in consultation with the Finance Department.
Page 3 of 20
The Final Decision-making Process is as follows:

 Results/findings must be studied, and a decision must be made as to move forward or not.
 If the decision is to move forward with the acquisition, then the Financial Negotiations must
continue.
Financial factors are, but not limited to, the following:
o Finance predictions
o Mortgage options
o Loan options
o Future Charter-Party possibilities
2.2 ACQUISITION PROCEDURES
2.2.1 Memorandum of Agreement is signed (MOA)

A Memorandum of Agreement is issued and signed by the two parties involved in the sale and
purchase of a new Vessel being added to the Company Fleet.
The MOA is handled by the Company’s Legal Department. In general, a MOA includes the
following subjects:
o Definitions
o Purchase Price
o Payment Terms
o Inspections
o Notices, time and place of delivery
o Dry-Dock works / Divers Inspection
o Spares / Bunkers etc.
o Documentation
o Encumbrances and Taxes
o Conditions of Delivery
o Buyers Default
o Sellers Default
o Buyers Representatives
o Arbitration
2.2.2 Delivery Date/ Port

An approximate date of delivery and port must be agreed upon between the buyers and the sellers.
The Fleet Technical Manager and the Legal Department must be notified and given all relevant
details, including but not limited to the following:
o Port & date of delivery
o Vessel’s new name (if applicable)
o Flag Administration
o Class
Page 4 of 20
2.2.3 Application & Registration Process by the Legal Department

The Legal Department is responsible for monitoring all the necessary actions for the application,
registration and insurance of the new acquisition.
These actions include:

 Application to the Flag Administration for:
 Vessel’s Registration
 Radio License
 Minimum Safe Manning
 Registration for Insurance
 Protection & Indemnity (P&I)
 Hull and Machinery
 Application for applicable Oil Pollution Certificates (Financial Responsibility)
 USCG COFR
 California COFR
 Flag Administration CLC
During the "Closing", the Legal Department must liaise with the Chief Finance Officer when he is
at the Mortgage Bank.
A Member of Legal Department will attend the "Closing meeting" held at the premises of the Flag
Administration.
All required documents issued by the Flag Administration must be immediately faxed to the
attending Superintendent onboard the Vessel. Hard Copy ORIGINALS must follow by courier
service.
2.2.4 Management of Change/ Monitoring of the Vessel Acquisition Process

The Technical Manager is responsible to monitor the activities of all Departments for the
acquisition of the new Vessel.
The steps taken by the Technical Manager include, but not limited to:
 The Technical Manager must determine the Vessel-responsible persons for the take-over of the
new Vessel.
 The updated "Vessel-Responsible Personnel" list must be distributed to the Vessels and in-
office.
 The Technical Manager must notify the relevant Office Departments of the expected delivery
date, and must initiate a Management of Change Process (on form - Management of Change for
Acquisition of new Vessels).
All Departments must review the “New Vessel Acquisition Checklist” - thereby setting in motion
the actions of all responsible Departments and their deadline (based on the delivery date).
All actions completed, must be recorded, under the Sub file “Management of Change”, for the
specific Acquisition.
The Technical Manager, in cooperation with the Crew Manager, must determine the Crewing Level
of the new Vessel.
In deciding on the crew complement, factors such as Vessel’s trade, trading area and maintenance
needs must be considered.
Page 5 of 20
Additionally, the Technical Manager in cooperation with the Crew Manager will decide on the
number and rank of Officers and other crew, who will join the Vessel, before the take-over, as well
as the time they will be onboard with the current crew and Management in order to get fully
familiarized.
The Technical Manager must contact Class for:
 Advance notification of pending take-over as Managers
 Arrange attendance for the following (as applicable):
o Change of Owners.
o Change of Managers.
o Change of Class.
o Change of Flag.
o Change of Name.
The Technical Manager must arrange for Underwater Inspection by a Class-Approved Diving
Company (this inspection to take place prior to Closing).
He must arrange for (in cooperation with the Crew Department) the designated attending
Superintendent and the Crew to be available 2 to 3 days prior to the schedules date of delivery.
In cooperation with the S&Q Department, applications are made to the relevant outside consultants
for required Oil Pollution Plans:
o SMPEP.
o Panama Canal SMPEP.
o VRP.
o California Contingency Plan.
Once the actual CLOSING has been completed, the Technical Manager must make the following
notifications for immediate enrollment purposes:
o Local Office for the Vessel’s Class Society.
o The "QI" for Oil Pollution Incidents in U.S. territories.
o The Contractor for Bunker and Lubes Sampling.
The Technical Manager must facilitate, coordinate and monitor all Departments' actions with
regards to their duties according to the "New Vessel Acquisition Checklist", including but not
limited to:
o Marine/Vetting Department to arrange for Flag and P&I Inspections, ISPS Assessment
and Oil Majors Vetting in due course.
o As per the MOA, the Crew Department must arrange for two (2) crewmembers to be
placed onboard PRIOR to take-over, for Vessel familiarization. In addition, the eventual
full crew complement to be arranged for, with emphasis on crew already having served
on Prime Marine managed Vessels.
o The Purchasing Department must arrange the ship’s initial supplies.
o The Operations Department must arrange for the Agent, lay-by berth, anchorage, future
employment, etc.
o The S&Q Department is responsible for:
- Ensuring that the entire IMS and other related items are on hand / produced as
necessary.
Page 6 of 20
- The general organization and packing of all items to be sent to the Vessel for take-
over (includes items handed over from other departments).
- Contacting the Recognized Organization in order to schedule the Interim Audits – to
take place during Vessel take-over.
2.2.5 Management Agreement

Following the "Closing Meeting" for the acquisition of the new Vessel, a Management Agreement
must be issued.
The Management Agreement is a contractual document which defines the business relationship
between the Owning Company and the Managing Company, which inter alia:
o Appoints the Company as Manager and Agent.
o Outlines the services to be provided by the Company.
o Deals with the arrangements for budgeting, payments and Management Funds.
o Details the insurance coverage.
o Details the respective obligations of both parties.
The Management Agreement must be signed by the authorized representatives of the Owning
Company and Managing Company, on all pages.
The contents of the Management Agreement defines the Company’s "PRODUCT" which is
supplied to the Owners.
Before the final signature, it must be reviewed by the Owners and Company’s Representatives, and
records of such a review must be kept.
2.3 CHANGE OF VESSEL’S NAME OR FLAG

In the event of a Vessel’s name changing, the new name must be first approved by the
administration and all Certificates, documents and manuals must be appropriately endorsed by the
Vessel’s Class Society or Flag Administration.
It must be also considered the possible need of re-issuance of certain statutory certificates, in
accordance to the applicable requirements of the Administration.
In the event of a Vessel’s Flag change, all Statutory Certificates (including Certificate of Registry
and Radio License) shall be issued by the new Flag Administration.
It must be ensured that any specific requirements of the new Flag are satisfied that might be related,
among others, to:
 Availability and specification of shipboard equipment.
 Management of Change (MOC).
 Training and drills planning.
 Shipboard inspections, surveyors and certification.
 Crew documentation.
Department Managers must co-operate for ensuring conformance to these requirements, including
possible needs for purchase / modification / certification of equipment, co-ordination with external
partners (e.g. manning agents) and instructions to the Master towards implementing revised training
/ drills schemes etc.
Relevant Certificates and documents must be appropriately endorsed by Flag Administration or by a
Class Society authorised by the Flag Administration to act on its behalf.
Page 7 of 20
2.4 ACQUISITION OF NEW VESSEL (S&Q DEPARTMENT RESPONSIBILITIES)

This section describes the steps taken to prepare for the acquisition of a new Vessel – within the
parameters of the S&Q Department.
2.4.1 New Vessel Acquisition Checklist

The "New Vessel Acquisition Checklist" (OFF/SAQ/412) is the main tool used when preparing for
a new Vessel. Under each Department is a list of tasks to be done, or items to be obtained or
produced, in order to take delivery of the new Vessel.
A. As the checklist is a controlled form, all changes to the form are made only by the S&Q
Department.
B. Although the outline/basic set-up of the form is controlled, the contents of the form is dynamic
and is updated/changed whenever necessary.
 Many times changes are made based on experience – that is, following a Vessel take-over
the checklist is evaluated for usefulness. Were the items on the checklist sufficient? Was
something or some action needed that was not on the checklist? Must an existing task be
re-assigned to a more appropriate department? Etc.
 Department Heads can at any time advise the S&Q Department if they find that
changes/additions are needed in their section of the checklist.
 Changes may also be made due to new class or flag regulations, etc.
The checklist is organized by department (i.e. Management, S&Q etc.)
(The Technical Department has its own OFF/TEC/109-“New Vessel Acquisition Checklist”)
 Under each Department is a list of tasks to be done, or items to be obtained or produced, in
order to take delivery of the new Vessel.
2.4.2 Items prepared or arranged for by the S&Q Department

Prior Vessel’s departure from delivery port the S&Q department shall notify the certifying
Authority to proceed in the issuance of an interim SMC, MLC and ISSC. According to the "New
Vessel Acquisition Checklist", the S&Q Department will prepare for the new Vessel, beginning
with:
 Arrange for the ISM Interim Audit, notifying Class with all relevant details (port, agent,
expected delivery date, type of Vessel, etc.)
 Procure/produce all IMS to be sent onboard:
o D.O.C.
o Company Policies.
o IMS Manuals – hard copies and electronically (CD).
o IMS Shipboard Forms, Posters, Uncontrolled Forms and International Requirements (in
electronic form only (CD).
o Circulars.
o Oil pollution plans – as applicable.
o Standard Vessel Filing System.
NOTE:
The specific items shown above are standard each time a new Vessel is acquired.
Page 8 of 20
However, only a portion of what is actually needed for every new Vessel is listed above.
The current “New Vessel Acquisition Checklist” is the document followed for ensuring that all
steps have been taken.
2.4.3 Updating the Management of Change Report

For each new Acquisition, a Management of Change is initiated in the “Archive Data Base”.
The dedicated form “Management of Change for Acquisition of new Vessel” has sections per
Department. Each Department is responsible to fill-in, all the items until completion of all the tasks
under their Responsibility.
2.4.4 Vessel Leaving Management

When a ship leaves Company’s management, the Master shall ensure that all controlled IMS
documentation and records onboard are destroyed (i.e in the Vessel’s incinerator or returned to the
S&Q department. The Office must provide clear instructions on this topic.
The certifying Authority must be immediately informed.
2.5 ACQUISITION OF NEW VESSEL (LEGAL & INSURANCE DEPARTMENT RESPONSIBILITIES)

This section describes the actions taken by the Legal & Insurance Department when the Company
acquires a new Vessel.
2.5.1 Initial Notification

The COO or Deputy COO notifies the Legal/Insurance Department that the Company is to acquire a
new Vessel, and actions are taken as shown in the following Paragraphs.
2.5.2 The Agreements

 Advice from COO or Deputy COO regarding the details of the agreement (recap).
 Review of and comments are given to Chief Operating Officer (COO) or Deputy COO on
the MOA.
 Negotiation of Terms with Sellers.
 Receive final approval on MOA from Chief Operating Officer (COO) or Deputy COO.
 Execution of MOA.
 Preparation of Memorandum of Agreement and execution of at time of delivery.
 Request Sellers to provide relevant trading certificates, as per the MOA.
2.5.3 Insurance
A. Request quotations from insurance placement for:
 Protection and Indemnity (P&I)
 Hull & Machinery
 Loss of Hire
 FD&D
 War Risks
Page 9 of 20
B. Negotiations / Agreements for insurance placement and preparation of applications for such
insurance, as listed above.
C. Prepare applications for COFR and CLC, as applicable.
D. Request P&I Club to issued "Blue Card", as applicable (tankers/ OBOs)
E. Upon execution of MOA, placing FD&D cover
F. On day of delivery, the covers for all are placed, and the Mortgagee Bank is notified of such
accordingly.
2.5.4 Registration
A. Preparation of applications (and submission to the Vessel's Flag Administration RO) of the
following:
 Vessel Registration
 Declaration of Company
 Declaration of DPA
 Declaration of Company Security
 Radio License (in cooperation with the Marine Department)
B. Agreement and payment of Registration fees to RO
C. Also sent to the RO:
 "Blue Card" (needed for issuance of CLC)
 Evidence of P&I cover
 Copies of mortgage documents for review and approval
D. Upon execution of the MOA, the RO is notified.
E. Class certificates (obtained from the Sellers) are presented to the RO.
2.5.5 Closing
A. Review of draft documentation of the closing:
 Bill of Sale
 Minutes of Meeting
 Power of Attorney
 Good Standing
 Ownership & encumbrances
 Release Letter of Deposit
 Commercial Invoice
 Other letters required by the MOA
B. Arrange date and place of closing
C. Liaise with external lawyers (Sellers / Buyers) for all closing matters.
D. Arrange for Class Maintenance Certificate to be provided by Class.
E. Attend the closing or registration of Vessel / mortgage and obtain the Original Registry
Certificate.
F. All required documents issued by Flag RO are immediately faxed to the Vessel, with original
hard copies to follow a.s.a.p. by courier mail service.
G. Copies of all required documentation filed accordingly in the Legal & Insurance Department's
Filing System.
Page 10 of 20
2.6 ACQUISITION OF NEW VESSEL (TECHNICAL DEPARTMENT RESPONSIBILITIES)
2.6.1 Introduction of Newly Acquired Vessel

Prior to considering acceptance of a Vessel into the Company’s Management, it must be ensured
that the Vessel meets potentially the Company’s standards. In this respect, the Vessel must be
boarded in advance by a Company’s representative (a superintendent or a competent independent
contractor), for a thorough inspection and reporting to the Company. For the reporting, Company’s
form “Pre-purchase Condition Survey Report” must be used, in case the inspection is performed by
Company representative.
The period between the Vessel’s delivery and entering service is referred to as “downtime”.
On the basis of this report the perspective of new acquisition shall be assessed and also the
necessity of rectification activities during and following the acquaintance period shall be
considered.
As per above a period of downtime between delivery and entering service may be effected.
Prior to undertaking the management of a new type of Vessel, associated tasks must be assessed and
new/amended procedures, if required, must be developed and incorporated in the IMS.
More specific, when a new type of Vessel enters Company’s management, the Company shall
ensure that:
 The type of Vessel is included in the DOC issued for the Company.
 The IMS has been distributed to shipboard personnel.
 Adequate time for familiarization of Officers and Superintendents has been provided, in order to
become familiar with the Vessel and the IMS.
 Proper familiarization with the Vessel and the IMS has been ensured for the ratings, prior to the
Vessel’s commencement of operation.
 A Risk Assessment / Management of Change has been carried out for the new tonnage brought
in the fleet and especially, when applicable, for new type of managed Vessel.
 All required Company’s manuals, drawings, plans etc. are available on board.
 Instructions essential to be provided prior to sailing, have been given to the crew.
 Navigational charts and publications have been updated, as appropriate.
 Minimum number of spare parts have been delivered onboard as per Company’s requirements.
 All necessary data is available for activating and following-up the planned maintenance system
of the Vessel.
 Vessel’s certificates have been checked and found in order.
 Officers and ratings fulfill the Company’s crewing requirements.
 Any high-risk maintenance issues have been rectified before the Vessel enters into service.
Prior to undertaking the management of an LPG Vessel following additional requirements are
placed:
 Cargo tank tables and Cargo system certificates proving compliance with requirements of
Japanese customs must be available for review.
 Certificates of last overhauling of Cargo tank /Deck tank / Cargo system relief valves to be
provided for review and comparison with the Certificate of Fitness.
Page 11 of 20
 In case of an LPG carrier with an already issued “Subcharter O Endorsement” (SOE) from
USCG, the Certificate of fitness and drawings/ documents which have been submitted to
USCG during that time must be provided to company for review.
In case there is a change in any of below documents, then after Vessel’s acquisition the company
must submit documents to USCG for a revision to the SOE at least two (2) weeks prior a call in US.
 IMO Certificate of Fitness for Carriage of Liquefied Gases in Bulk and all Addendums
 Vessel particulars).
 General arrangement plan of the Vessel.
 Cargo containment system specifications.
 Mid-ship section plan of the Vessel.
 Fire-fighting and Safety Plans.
 Liquid and vapour cargo piping.
 Classification Society certification for ethylene oxide carriage.
 Classification Society certification for steel and cargo temperature control (per 154.170).
 SOLAS Safety Construction and Safety Equipment Certificates.
When the Company takes over the management of a 2nd hand Vessel and the Vessel’s complement
is to be entirely replaced by the Company new Officers and ratings, they must have received
adequate training on the IMS as per. Table No.1 before the Vessel sails.
Otherwise, in case the existing crew is to be retained onboard, adequate time for their
familiarization with the Company’s IMS must be ensured prior to Vessel’s commencement of
operation.
This familiarization is estimated to last for (two) 2 days prior to sailing, and is carried out by
the Company’s representative(s) on-site.
All onboard documents related to the previous Management System shall be discarded.
The following steps shall be taken in order to complete a successful new Vessel familiarization
process. Record to document these steps must be retained.
Page 12 of 20
Table No.1: New Acquisition Requirements Guide
2nd hand Vessel

STEP
Y N Remarks
Company’s superintendent or Ship Senior X 2 weeks prior delivery, when feasible

Officer to sail with the Vessel.
Familiarisation of Officers. X At least two (2 ) days prior sailing
Familiarization of ratings. X 1 day prior operation
Prior sailing drills X Abandon, Fire, Oil Pollution
Other Drills: X These drills must be carried out at first

Emergency steering, M/E failure, Loss of opportunity but no later than three
electrical power, Man overboard, Rescue from Three (3) months after delivery.
dangerous space. Afterwards, to be repeated as per
schedule.
From the initial acquisition of a Vessel, a historical record must be maintained which indicates any
structural or technical changes made, the current status of equipment and how that status evolved
from the original design.
For any new acquisition, prior and during tanking-over, form “New Vessel Acquisition Checklist”
must be completed.
Also prior to newly acquired Vessel’s departure from the acquisition port or the building yard, it
must be ensured that all safety equipment, critical equipment and alarms and emergency equipment
are in proper operational condition, minimum spares are available and complete updated charts
folio.
Furthermore, the crew has to familiarize with safety/critical/emergency equipment during the 2 days
familiarization period foreseen above.
With respect to establishing maintenance routines and given that an electronic PMS is used across
the fleet, the PMS databases for the new Vessels are anticipated to require a reasonable time for
population and updating.
Implementation of databases to be completed within four (4) months the from Vessel’s
acquisition date.
In case, this is not completed by that time, approval for extension from the DPA and Chief COO or
Deputy COO must be granted.
Until this process is completed to the Technical Manager satisfaction, a new Vessel Planned
Maintenance System will be temporarily operated by specific Work Orders identified by Technical
& Marine Superintendents into the electronic Superintendents Orders module, and will be based on
the ship specific maintenance requirements upon delivery and the Company’s established PMS
routines.
Page 13 of 20
2.6.2 Familiarization with New Ship’s Equipment

Before or during delivery, the Company’s attending superintendent(s) and the new crew must
familiarize themselves with the ship’s equipment, operation and current condition, including
possible defects.
Attending Superintendents will be familiarized for a minimum of two (2) days.

New Acquisition Familiarization form to be filled and sent to the Office.
In this context, all information that can be provided via the co-operation of the previous crew is
valuable and must be shared with the Technical Department accordingly.
The following topics are of importance regarding the proper familiarization of the superintendent(s)
and the crew and special effort must be placed for ensuring availability of as much information as it
is possible prior to the Vessel’s departure from the port of delivery.
2.6.2.1 ENGINE ROOM

 General condition of the engine room, including cleanliness:
If necessary, arrangements for cleaning, painting or for additional Wiper / Cleaner may be
made.
 Suitability of equipment ranging:
 Attention must be paid to bilges, condition around Main Engine, D/G, Boilers, etc.
2.6.2.1.1 E/R Piping System/Tanks

Familiarization with the following piping systems:
a. Ballast g. Lubricating Oil
b. Steam h. Sea Water
c. Fire i. Jacket Cooling
d. Bilge j. Cargo
f. Fuel Oil k. Feed Water
l. Air System
Compilation of failed pipes, valves or pumps, which must be immediately notified to the Office,
incl. dimensions and quantities.
Examination and commenting as appropriate on the condition of fuel oil, diesel oil, cylinder oil
and fresh water tanks.
2.6.2.1.2 Main Engine

a) Satisfactory operation of the Main Engine (noise level, vibration and soot leakage, type of
FO being burned.
b) Fuel oil consumption at the corresponding revolutions per minute and speed, in both loaded
and ballast conditions.
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c) Fuel handle position / Fuel Pump Mark indication, RPM, Jacket, Piston water, Scavenging
Air and Exhaust Gas temperatures, L.O. Scavenging air pressures, incl. any deficiencies
detected.
d) Running hours Reports since last inspection of cylinders, fuel pumps and turbochargers.
e) Date and results of last analysis for engine lubricating oil, and, in particular, check for
leakage of water into the lubricating oil. Lubricating oil samples to be sent to the office, for
further analysis.
f) Condition of automation systems, including operation of alarms, trips and other safety
devices, and instruments.
g) Condition of jacket cooling water and use of chemicals.
h) Consumption of system and cylinder oil.
i) Exterior oil leakages (especially from stuffing boxes), if any.
j) Availability onboard of copies of M/E, D/G and Auxiliaries overhauling reports and last
wear measurements.
k) Main Engine special arrangements and documentation if any to operate on low Sulphur
MGO.
2.6.2.1.3 Generators
a) Operational conditions (noise level, vibration, leaking soot, high exhaust temperatures) and
type of fuel being burned.
b) Working hours of each diesel generator and its turbocharger since last inspection.
c) Operations of alarms, trips and other safety devices, including instruments.
d) Number of generators during sailing and discharging and corresponding electric load.
e) Lubricating oil system and lubricating oil consumption.
f) Control board – Parallelism.
g) Generators special arrangements and documentation if any to operate on low Sulphur MGO.
2.6.2.1.4 Oil –Fired Boilers

a) General condition.
b) Feed water condition and chemicals use.
c) Whether the boiler operates automatically or manually.
d) Operations of alarms, trips and other safety devices, including instruments.
e) Soot-blower operation and whether it is mechanical / electrical / remote.
f) Fuel oil consumption in the basic modes of operation, i.e. sailing and port operation.
g) Any electrical problems with boiler’s automation and main switch board.
h) Boilers special arrangements and documentation if any to operate on low Sulphur MGO.
2.6.2.1.5 Exhaust Gas Boilers

a) General conditional assessment, incl. adequacy of the steam production for the ship’s needs
and reasons for using the fired boiler.
b) Minimum M/E RPM where the exhaust gas boiler is used, the corresponding fuel oil
consumption and speed of Vessel.
c) Number of plugged tubes and whether soot-blowing is available.
d) Drainage of the exhaust gas boiler shell.
Page 15 of 20
2.6.2.1.6 Fresh Water Generator

a) General condition, number of units and type of operation (i.e. steam).
b) Actual fresh water nominal production compared to the manufacturer’s standards and its
adequacy for the ship’s needs.
2.6.2.1.7 Engine Room Bilges
a) General condition of bilges and cleanliness.
b) Operational condition of the bilge pump.
2.6.2.1.8 Bilge Water Separator

a) Type of separator and operational condition.
b) PPM efficiency (15 ppm).
c) Condition of the oil discharge system, incl. the piping connection on main deck for oil
discharge to port facilities and operation of the monitor device.
2.6.2.1.9 Sewage Unit/ Holding Tank

a) General condition.
b) Applied methodology; biological or chemical.
c) Availability of a U.S.C.G. Certificate.
2.6.2.1.10 Purifiers
Reporting on number, condition and type of purifiers available and checking whether they may
be operated as purifier / clarifier.
2.6.2.1.11 Auxiliary Machinery

Description the general condition of the auxiliary machinery, including electric motors.
2.6.2.1.12 Tail-shaft
a) Oil consumption, if any, to be reported and type of lubrication oil being used (in case of
suspected leakage).
b) Oil sample to be drawn and dispatched for analysis.
2.6.2.1.13 Steering Gear

a) Operational condition to be checked (incl. whether rudder is operated with one or two
motors) and the condition of the deck floor (i.e. traces of leaking oil).
b) Rudder trunk and horn to be inspected.
2.6.2.1.14 Spare Parts

a) Inventory of spare parts for the Critical and Essential Equipment according to Company
procedures.
b) Proper ranging of spare parts and their condition (in particular pistons, jackets, bearings etc.,
whether they are used/usable or new).
Page 16 of 20
2.6.2.2 DECK
2.6.2.2.1 Cargo Piping (on deck/ in tanks/ heating coils)

Condition of the cargo piping on deck, Pump Room as applicable, in tanks when gas-free and
safe for entry, as well as heating coils with photos, if possible.
2.6.2.2.2 Cargo Discharge

a) Number of main cargo pumps in operation, number of revolutions, any malfunction and
whether a stripping pump is operated at the end of discharge.
b) Operational condition of ODME.
c) Cargo valves, reach rods condition.
d) Leakages through cargo pipes, dressers in pumproom and cargo tanks.
e) Leakages in E/R, P/R steam pipes and tanks heating coils.
2.6.2.2.3 Cranes and Winches for Loading /Unloaded Operations

a) General condition of each loading/unloading device, operational efficiency and possible
repairs needed to improve its performance.
b) Oil leakages.
2.6.2.2.4 Anchor Windlass and Mooring Winches

a) General condition of the anchor windlass and mooring winches. In particular, condition of
the windlass wildcat and its wear out at the contact areas with the anchor chain.
b) Condition of anchor chains, loose studs and evident diminution.
c) Wear-out of the lining brakes.
2.6.2.2.5 Inert Gas System

a) Operational condition of the control panel, on-line instruments and alarms.
b) Condition of I.G. line up to the deck isolating valve, both I.G. blowers and scrubber,
pressure regulating valve and deck seal unit.
2.6.2.3 PUMPROOM
2.6.2.3.1 Cargo / Ballast Pumps and Stripping Pumps
a) General condition, with particular attention paid to instrumentation of cargo pumps and the
existence of functional bilge high level alarm.
b) Cargo ballast and stripping pumps, the piping systems and compliance of the system with
the designation of the Vessel.
c) General condition and functionality of all cargo valves.
2.6.2.4 HULL CONDITION

Condition of deck plate and scantlings, shell plate bulkheads, detection of leakages, bottom
plates, internals, ballast tanks, hatch covers.
Page 17 of 20
2.6.2.5 SAFETY
a) Availability check of the following, as applicable:
 Dead-Man Alarm from Bridge to Engine Control Room.
 Pumproom light with ventilator interconnection.
 Cargo pumps manifold trips.
 Pumproom Cargo Pumps local trips.
 General Alarm (visual and acoustic) in Pumproom.
 General alarm button in Pumproom.
 Thermocouples on Cargo pump casings.
 Cargo Pump bearing thermocouple indicators.
 Oxygen Gas Detector in Pumproom.
 High / high-high level alarms fitted in bunker tanks.
b) Lifeboats condition, incl. Hull condition (any doublers), their engine operation and lowering
without problems.
c) Working condition of air vents / closing appliances.
d) Emergency fire pump, Emergency Generator.
e) Fire-fighting and lifesaving equipment in accordance with Vessel’s Fire & Safety Plan.
2.6.2.6 BRIDGE APPARATI AND RADIO

a) Bridge Navigational Watch Alarm System maker / type.
b) Gyro and magnetic compass maker/type.
c) Autopilot maker/type.
d) Echo sounder maker/type.
e) Course recorder maker/type.
f) EPIRB maker / type, as well as transmitting frequencies.
g) NAVTEX receiver maker/type.
h) Auto Exchange telephone maker/type.
i) GPS SATNAV maker/type.
j) GMDSS equipment maker/type.
k) AIS maker/type.
l) VDR/SVDR maker/type.
m) LRIT maker/type.
n) RADAR/ARPA maker/type.
o) ECDIS maker/type.
p) Speed log maker/type.
2.7 NEW-BUILDING POLICY

No specification will be accepted without the thorough checking by the Company.
The following departments must check shipyard specifications:
 Projects Department
 Technical Department
 Vetting Department
 Operations Department
Page 18 of 20
Third party consultants may also be used if deemed necessary by the Owners.
The new Vessels must be fit for purpose and fully meet the latest industry requirements in terms of
robustness in design, onboard equipment, user friendliness and ease of maintenance.
The criteria used in the development of Specification Approval Process are:
 The Owners standards and operational requirements.
 Company’s experience and IMS procedures.
 Best Industry practices, as outlined by Class Societies and Industry bodies.
 Shipbuilding and Ship Operating market condition.
 Charterers’ specific requirements (if applicable).
 Practices for the protection of Crew health, safety and well-being and Marine Life such as :
o Noise and Vibration Levels (Including Underwater Noise).
o Hazardous Materials.
o Exposure to Cargo Vapours.
o Extreme (high-low) temperatures and humidity.
o Incorrect Illumination.
o Poor Ergonomics.
o Stressful conditions.
o Mooring layout.
The Specification must include a detailed description of the Vessel, its equipment and systems and
must incorporate all National and International and Class rules and regulations, as well as good
Shipbuilding and Technical/Operational practices affecting the construction and operation of the
Vessel.
Latest Industry Environmental Standards/Notations must be adopted.
Provision must be made for known but not yet enforced future regulations, as well as to establishing
new-building designs intended to enhance environmental performance in conjunction with the
applicable operational practices.
During the development of the Newbuilding’s Specification, various practices, design strategies
and/or devices are evaluated, in order to be included in the project in order to achieve higher energy
efficiency and performance improvement.
During this process, the following are taken into consideration:
 The Company’s experience ,
 Industry latest developments
 Pioneer technologies ,
 The expected operational profile of the Vessel.
Cargo tanks Coating:

 All new-building Vessels will have fully coated Heavy weather ballast Cargo tanks of
Tanker Vessels
 Cargo tanks of Tanker Vessels size up to and including Aframax (LR2) to be fully coated.
An indicative list of various measures/practices, components etc., is found here below:
 Fuel management and treatment technologies.
 Use of clean fuel in accordance with the latest ISO specifications.
Page 19 of 20
 Implementation of energy saving devices such as: LED lights, Dimmer switches, Variable
frequency drives on large power consumers etc.
 Use of exhaust gas recirculation and by-pass systems to improve fuel consumption and
steam production.
 Selection of waste reduction equipment such as compactors, trimmers, shredders etc.
 Hull form optimization.
 Use of trim optimization technology for fuel reduction.
 Installation of top performance Anti-fouling schemes for hull.
 Installation of performance management systems such as PYTHIA, KYMA, PMI Cocos
 Installation of fuel saving devices such as MEWIS duct, Schneekluth duct, PBCF, Rudder
Fins etc.
 Installation of electric fuel and LO heaters for use during long anchorage stays.
 VOC reduction methods.
 Installation of Electronic main engine.
Security parameters are also taken into consideration during new-building design.
Various enhancements and controls are examined to be included in the specification, indicatively
listed as follows:
 Installation of CCTV system for monitoring Vessel’s exposed areas.
 Installation of quick deployment hardening material.
 Use of protective anti-bullet films on wheel house windows.
 Use of strengthened doors on Wheel house wings entrance.
 Use of High power sound generator system for external accommodation when Vessel’s
security is breached.
The measures which are selected, depend upon the Vessel’s expected Trading Area/Type and
size/manning level.
It is at this stage that the List of Makers of equipment is discussed and evaluated.
The final list will reflect the shipyards’ preferred Makers, Company’s experience, new products
development, the need of uniformity throughout the fleet, the after sales service organization,
availability and cost of spare parts, the maintenance requirements, etc.
Any deviations of the specifications from the Company’s requirements as outlined above will be
compiled in a List of Extra Items, which may or may not carry extra cost. Once extra cost
adjustment has been agreed between the Yard and the Owners, the list becomes a List of Extras,
which becomes binding for the Yard and a part of the Specification and the Shipbuilding Contract.
For more details, reference is made to Office Manual, “Technical Department Operating
Procedures”.
3. RECORD
 Acquisition of New Vessel Checklist-S&Q PRO/PRO 4/ OFF/SAQ/412
 New Acquisition Familiarization PRO/PRO 4/ OFF/TEC/105
 Pre-purchase Condition Survey Report PRO/PRO 4/ OFF/TEC/108
 New Vessel Acquisition Checklist-TEC PRO/PRO 4/ OFF/TEC/109
 Management of Change- Acquisition New Vessel PRO/PRO 4/ OFF/GEN/008A
Page 20 of 20
(002) CERTIFICATION, VERIFICATION AND Revision: 08
CONTROL Eff. Date: 30/04/2022
Contents
1. PURPOSE ..................................................................................................................................2
2. PROCEDURE ............................................................................................................................2
2.1 ISM Certification ....................................................................................................................2
2.1.1 Document of Compliance (DOC)................................................................................................................ 2
2.1.2 Safety Management Certificate (SMC) ....................................................................................................... 2
2.1.3 Monitoring of ISM Certificates ................................................................................................................... 3
2.1.4 Distribution of ISM Certificates .................................................................................................................. 3
2.1.5 ISM External Audits.................................................................................................................................... 4
2.2 International Ship Security Certificate (ISSC) ......................................................................5
2.3 MLC Certificate - Ref MLC 2006- Regulation 5.1.3 .............................................................5
2.3.1 General ........................................................................................................................................................ 5
2.3.2 MLC External Audits .................................................................................................................................. 7
2.4 ISM/ISO External Audits – Office .........................................................................................7
2.4.1 Arranging the External Audits with the Recognized Organization / Certification Body ............................ 7
2.4.2 Preparation for External Office Audits........................................................................................................ 8
2.4.3 Processing the External Audit Report ......................................................................................................... 8
2.4.4 Closing the Non Conformities from External Office Audits ....................................................................... 9
2.4.5 Analysis and Distribution of Experiences throughout the Company ........................................................ 10
2.5 ISM/MLC/ISPS/ISO External Audits –Vessels....................................................................10
2.5.1 Vessel Preparation for External Audits ..................................................................................................... 11
2.5.2 Arranging the External Audits with the Recognized Organization ........................................................... 11
2.5.3 Processing the External Audit Report ....................................................................................................... 12
2.5.4 Closing the Non Conformities resulting from External Audits ................................................................. 12
2.5.5 Analysis and Distribution of Experiences throughout the Company ........................................................ 13
2.6 Monitoring of ISM/ISPS/MLC/ISO Certificates ..................................................................14
2.7 Vessel’s preparation for External audits ............................................................................... 14
2.8 External Navigational Audits ................................................................................................16
2.9 Ship’s Certificates .................................................................................................................16
2.9.1 General ..................................................................................................................................................... 16
2.9.2 Electronic Certificates .............................................................................................................................. 17
2.9.3 Monitoring of Certificates and Surveys ................................................................................................... 18
2.9.4 Taking Ship’s Certificates Ashore ........................................................................................................... 19
3. RECORDS ............................................................................................................................... 19
Page 1 of 19
1. PURPOSE
This procedure describes the steps which are followed for IMS Certification, Verification and Control
by a Recognized Organization.
2. PROCEDURE
2.1 ISM CERTIFICATION
2.1.1 Document of Compliance (DOC)

The DOC indicates that the Company’s Safety Management System complies with the requirements
of the ISM Code.
The DOC is issued by the Organization recognized by the Flag Administration to audit and certify
on their behalf.
A Company may have a number of DOCs if it operates a Multi- Flag Fleet.
The DOC is only valid for the types of ship(s) stated on the document.
The DOC is valid for a period of five (5) years from the date of the verification audit, subject to an
Annual Verification by the RO.
New DOCs must be issued in the following cases:
 When a Company is established.
 When the Company changes its name.
 When the Company changes its address.
 When new types of ships are added in the Fleet and must be added to the existing DOC,
or when new types of Vessels are removed from the Fleet.
2.1.2 Safety Management Certificate (SMC)

A. General
The SMC indicates that the SHIP is in compliance with the requirements of the ISM Code.
This also includes the verification that the DOC of the Company responsible for the operation of the
ship is applicable to that particular type of ship.
The SMC is issued by the Organization recognized by the Flag Administration to audit and certify on
their behalf.
The SMC is generally valid for a period of five (5) years from the date of issue.
The new ISM Code has provisions for various cases regarding the extension of a SMC, the validity
etc.
The validity of the SMC is subject to at least one (1) Intermediate verification, confirming the
effective functioning of the SMS.
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B. Issuance of new SMC

A new SMC must be issued in the following cases:
 When a new Vessel is added to the Fleet.
 When the Vessel changes its name.
 When the Vessel changes Flag.
 When the Managing Company changes its name.
 When the Company changes its address.
2.1.3 Monitoring of ISM Certificates

The S&Q Department is responsible to arrange for the issuance, intermediate verification and renewal
of DOC and SMC Certificates.
As a general rule:
 Interim DOCs are issued for a period not exceeding twelve (12) months.
 Interim SMCs are issued for a period not exceeding six (6) months.
The procedure which is followed by the S&Q Department to ensure that valid DOC and SMC
certificates are always available as required by the ISM Code is described in §2.6 “Monitoring of
ISM/MLC/ISO/ISPS Certificates” of this Manual.
2.1.4 Distribution of ISM Certificates

The S&Q Department is responsible for distributing the ISM Certificates, through a strict Document
Control procedure.
 DOC
The original DOCs of the Company are held by the S&Q Department in the S&Q File "Valid DOC
and SMC". Electronic copies are also found in the Company’s "Archive" database and/or ERP IMS
Module.
Copies of the valid DOC are always available onboard.
A copy of the DOC must always be found filed in the Vessel’s Filing System, in Master’s File
TEC 01-“Vessel’s Primary Certificates”.
Their distribution is made according to the Document Control procedures.
The S&Q is responsible to ensure that updated copies, as well as copies of the annual DOC
endorsement, are sent onboard, following the ISM Annual Verification Audit by the RO.
 SMC
The original SMC is always sent onboard. The original SMC must be filed onboard, in Master’s File
TEC 01-“Vessel’s Primary Certificates”.
The S&Q keeps Certified Copies of all the SMCs in the S&Q File "Valid DOC and SMC".
Copies are also found in the company "Archive" database and/or ERP IMS Module.
Following each onboard Intermediate Verification Audit, the S&Q is responsible to ensure that it
receives and files copies of the SMC endorsement to the SMC Certificate.
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2.1.5 ISM External Audits

ISM External Audits are divided in:
 Office External Audits
 Vessel External Audits
DOC
The Company is subject to the following External Audits, according to the requirements of the IMS
Code:
Interim Audit When the Company is established or when it adds new types of
Vessels in its Fleet.
Initial Audit In a period not exceeding twelve 12 months from the date of issue of
the Interim DOC.
Annual Verification Audit Within three (3) months before or after the anniversary date of the
DOC.
Renewal Audit: In a period not exceeding five (5) years from the date of expiry of the
existing DOC.
SMC
The Vessels are subject to ISM External Audits, according to the requirements of the ISM Code:
Interim Audit On acquisition of a new Vessel in the Fleet.
Initial Audit Before the expiration date of the Interim SMC –within six (6) months
from the date of the Interim Audit.
Annual Verification Audit Between the second and third anniversary year of the issue of the
SMC.
During this Audit, the SMC Certificate will be endorsed, following
satisfactory intermediate inspection.
Renewal Audit: Before the expiration of the Long Term SMC in a period not
exceeding five years from the date of issue of the SMC. Renewal
verification may be carried out from six (6) months before the
expiration date of the SMC.
Arrangement of ISM External Audits

The arrangement of the ISM External Audits is the responsibility of the S&Q Department in close
cooperation with the DPA.
The External Audits are planned at the beginning of each January, using relevant forms and are
approved by the DPA.
When the RO confirms attendance on the requested date, the S&Q must notify the Office and/or the
Vessel, in writing.
S&Q is also responsible to monitor the preparation activities for an ISM External Audit.
Processing the ISM External Audit reports & Non-conformities
The S&Q Department is responsible for the processing and recording of the results of ISM External
Audits.
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The follow-up of all Non-conformities and the corrective action for their close-out are monitored by
the S&Q in close cooperation with the DPA and are discussed during weekly Operational Meetings
and Quarterly Management Review Meetings.
Analysis and Distribution of Experiences throughout the Company
Quarterly, the results of all the ISM External Audits are collected and grouped in categories per nature
of deficiency.
The analysis of the ISM External Audit results are included in the Agenda of the Management Review
Meeting, which is distributed onboard and ashore.
2.2 INTERNATIONAL SHIP SECURITY CERTIFICATE (ISSC)

The Vessels are subject to ISPS External Audits, according to the requirements of the ISPS Code:

Initial Audit Before the expiration date of the Interim ISSC –within six (6) months
ISSC. During this Audit, the ISSC Certificate will be endorsed,
following satisfactory intermediate inspection.
Renewal Audit: Before the expiration of the Long Term ISSC in a period not
exceeding five years from the date of issue of the ISSC. Renewal
expiration date of the ISSC.
ISPS External Audits

In close cooperation with the S&Q Manager, the Company Security Officer is responsible for the
planning, monitoring and follow-up of the ISPS External Audits, following the same procedures
applicable to ISM Audits.
The ISM and ISPS External Audits of the Vessels are arranged simultaneously.
2.3 MLC CERTIFICATE - REF MLC 2006- REGULATION 5.1.3
2.3.1 General
The Vessels are subject to MLC 2006 External Audits, according to the requirements of the MLC
2006 Convention which came into force on August 20, 2013:
Initial Audit Before the expiration date of the Interim MLC –within six (6) months
MLC. During this Audit, the MLC Certificate will be endorsed,
following satisfactory intermediate inspection.
Renewal Audit: Before the expiration of the Long Term MLC in a period not
exceeding five years from the date of issue of the MLC. Renewal
expiration date of the ISSC.
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The Declaration of the Maritime Labour Compliance must be attached to the Maritime Labour
Certificate.
It consists of two (2) Parts:
 Part I -this is drawn by the Competent Authority which identifies :
o the list of matters to be inspected;
o the national requirements embodying the provisions of the MLC 2006 Convention;
o Ship-type specific requirements;
o Any substantially equivalent provisions;
o Any exemptions granted by the Competent Authority.
Note:
A DMLC Part I is not required when there is a change of Management only.
It is required when there is:
 A change of name , Change in IMO or GT ,
 In case any addition and/or change in the Substantial Equivalence and Exemptions sections
 If the Original DMLC hard copy is lost.
 A DMLC Part I issued before 24/02/2020 should be maintained in original hard copy form
onboard the vessel – if it cannot be found – a new electronic copy of DMLC Part I must be
issued ( 24/02/2020 is the date after which all DMLC Part I are issued electronically)
(MI Marine Safety Advisory No. 07-20)
 Part II- this is drawn by the Shipowner and identifies:

o The measures adopted to ensure ongoing compliance with national requirements between
inspections;
o The measures proposed to ensure that there is continuous improvement.
The Competent Authority or Recognised Organization duly authorized for this purpose, certifies
PART II and issues the “Declaration of Maritime Labour Convention”.
A current valid Maritime Labour Certificate and the Declaration of Maritime Labour Compliance,
must be carried on the ship and a copy must be posted in a conspicuous place onboard where it is
available to the seafarers.
A copy must be made available, upon request, to Seafarers, Flag State inspectors, authorized officers
in port States, and Shipowners’ and Seafarers’ representatives.
A Maritime Labour Certificate may be issued on an Interim basis:
 When a new Vessel is added to the Fleet.
 When the Vessel changes its name.
 When the Vessel changes Flag.
 When a Shipowner assumes responsibility for the operation of a ship which is new to that
Shipowner.
The MLC will cease to be valid in any of the following cases:
 If the relevant inspections are not completed within the periods specified,
 If the certificate is not endorsed in accordance with MLC requirements,
 When a ship changes Flag Administration,
 When a Shipowner ceases to assume the responsibility for the operation of a ship,
 When substantial changes have been made to the structure or equipment.
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A new MLC must only be issued when the Competent Authority or Recognized Organization issuing
the new Certificate is fully satisfied that the ship is in compliance with the requirements of the MLC
2006 Convention.
2.3.2 MLC External Audits

The MLC External Audits will preferably be arranged simultaneously with ISM & ISPS External
Audits, therefore the same procedures followed for the ISM & ISPS External Audits apply to the
MLC External Audits.
2.4 ISM/ISO EXTERNAL AUDITS – OFFICE

This section details the arrangements made for the External Audits of the Office Departments to be
conducted by a Recognized Organization (RO) / Certification Body.
For brief reference, the External Audits against ISM Code, ISO 9001, ISO 14001, ISO 27001, ISO
45001, ISO 50001 will be referred to as “IMS External Audits” in this section.
Within the first half of the month of January of each year, the S&Q Department must submit the
Audits Schedules, for both Internal and External Audits, to the DPA and all Management
Representatives for approval.
All the Office Departments are subject to Annual Verification / External Audit, conducted by the RO
(Recognized Organization) / Certification Body.
The External DOC Office Audit must be conducted as required by the ISM Code, §.13 – 13.4
“The validity of the DOC must be subject to annual verification by the
Administration or the Recognized Organization, within three (3) months before or after the
Anniversary date”.
2.4.1 Arranging the External Audits with the Recognized Organization / Certification Body
The arrangement of External Audits is the responsibility of the S&Q Department in close cooperation
with the DPA and the responsible Management Representatives.
As soon as the Office Internal Audit Schedule is approved, a suitable date must be selected for the
Office External Audit.
Quite before the selected Audit date, (at least one month) the S&Q Department must notify the
Office of the RO/Certification Body, requesting the arrangement of the External Office Audits on the
selected date.
This procedure is carried out by filling-in a Format which is provided by the RO/Certification Body.
When the RO/Certification Body confirms attendance on the proposed date, all the Office
Departments are notified in writing.
All the Department Managers are responsible to fully prepare their Departments for the forthcoming
Audits.
The Company Security Officer (CSO ) is responsible for the ISO 27001 External Audits, according
to IMSM Manual (001) –Appendix C-Shore Based Personnel Responsibilities and Authorities- §
12.1- Responsibilities.
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2.4.2 Preparation for External Office Audits

 Before the External Office Audit, the following must be completed:
o The S&Q Department must conduct the Internal Audits of all the Office Departments, and the
findings must be documented as per Company procedures and made known to the Auditees,
the DPA, the responsible Management Representative and to Top Management.
Findings of previous Internal and External Audits must be reviewed, to ensure close-out. The
close-out of the Non Conformities must be based on supporting evidence.
o The S&Q Department must complete all the analyses and statistics of Accidents, Near
Misses, and of the results of Audits and Inspections, and distribute them in a well-
documented way (by official Circular), throughout the Company.
o All Departments must prepare their statistical tables, KPIs, Objectives and Targets met or
failed, problems etc, to be presented during the Management Review Meeting.
o All Department Managers and staff must make an overall review of the implementation of
Manual procedures, Circulars, Filing System, pending cases and refresh their awareness of
the IMS related to their responsibilities.
A review of the results of the current Internal Audits and the previous External Audits must
be made in order to ensure that corrective action has been taken for their close-out and that
the corrective action is still well implemented.
o The Management Review Meeting must be readily available.
If the Quarterly Management Review Meeting is due, it must be held, chaired by the Chief
Operating Officer (COO) or Deputy COO and the DPA, with the participation of all
Management Representatives and Department Managers and selected staff.
The Agenda, as per the relevant Company Procedures, must be followed.
o Minutes of the Management Review Meeting must be produced with the signatures of all
attendees.
2.4.3 Processing the External Audit Report

Immediately after the External Office Audit is completed, the S&Q Department performs the
following activities:
 Briefs the DPA and the responsible Management Representatives on the Audit results.
 Advises the Fleet Vessels of the Audit results.
 Updates the S&Q Electronic Files with the Audit results and the due dates for corrective actions.
 Updates the “Archive” database with new DOC Certificate data (in the case of DOC Renewal) or
the endorsement page (in case of Annual Verification) and or the ERP ISM Module.
 In the case of a new DOC, sends the newly issued DOC Certificate to the Flag Administration
(by e-mail attachment).
 In case of DOC Annual verification, sends the second page of the DOC (with the endorsement)
to all the Fleet Vessels and to the Flag Administration.
 Issues “Summary Tables” of the External Audit results, and files them together with the complete
Audit report in S&Q File - ISM External Audits-Office.
 Reviews the Audit Results, and in cooperation with the DPA and / or the responsible Management
Representative, decides on the corrective action to be taken and the Persons responsible to
implement them.
 Coordinates the corrective actions necessary for the close out of the Non Conformities.
Page 8 of 19
 If the Non Conformities raised are related to mistakes and inadequacies of the Company IMS, the
S&Q department initiates an Amendment Process in order to incorporate the necessary
corrections to the IMS before the due date of the Non Conformities.
 Keeps the Hard Copy and Electronic Files updated with the progress of corrective actions taken
by Office staff and Vessel staff (if required) for the close-out of the Non Conformities.
2.4.4 Closing the Non Conformities from External Office Audits
The DPA makes periodic checks to ensure that the Deficiencies raised are closed within the time limit,
as set by the RO.
The same applies for the Management Representatives regarding the findings raised by the
Certification Body during the External ISO Audits.
Upon completion of the Corrective Actions, the S&Q Department must collect all supporting
evidence from the Office Departments and from any other party involved in the close-out process.
A set must be prepared to be submitted to the RO/Certification Body, which must include the
following:
 An official letter addressed to the RO/Certification Body, to accompany the set, outlining the
contents of the enclosed set, and requesting for close-out of the Non Conformities.
 All the Non Conformity Notes, duly completed with a brief description of the corrective action
taken.
The Non Conformity Notes must be signed by the DPA, or by the S&Q Manager, or by the
responsible Management Representative in case of ISO 9001, ISO 14001, ISO 27001, ISO 45001
and ISO 50001.
 Each separate Non Conformity Note must have attached a page with a detailed description of the
corrective action taken, as well as any supporting evidence available.
This official set is produced in two (2) copies and is distributed as follows:
 One copy is sent to the RO/Certification Body
 One copy is kept by the S&Q Department
The RO/Certification Body must make a review of the set with the supporting documentation, and if
it is to their satisfaction, they must sign and stamp the Non Conformity notes at the left down part, as
“Corrective Action Accepted”.
Copies of the Non Conformity Notes must be filed in S&Q File 003, upon receipt from
RO/Certification Body.
If the Non Conformity Notes, which have been submitted to RO/Certification Body, are not returned
signed and stamped as “Corrective Action Accepted”, then during the next External Audit of the
Office, the RO/Certification Body auditor must review the Non Conformity notes, and if the
verification is considered satisfactory, must sign them at the right down part, in the space “Close-
out”.
When the above procedure is complete, the External Office Audit is considered as finally closed.
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2.4.5 Analysis and Distribution of Experiences throughout the Company

On a Quarterly Basis and at the end of each year, the results of all the External Audits of the
Office must be collected and grouped in categories per nature of deficiency.
The purpose is to identify any common Non Conformities, which may be an indication of weakness
of the IMS.
The Audit results must be included in the Agenda of the Management Review Meetings, copies of
which are distributed to all Office Departments for review and corrective action.
The Audit results must serve as a basis for identifying further training needs of the Office Personnel.
Evaluation of the External Audit Findings may result in:
 Amendments of existing IMS Procedures and Forms.
 Development of new IMS Procedures.
 Issuance of guiding Circulars on specific IMS elements.
 Identification of training needs.
2.5 ISM/MLC/ISPS/ISO EXTERNAL AUDITS –VESSELS

This section details the arrangements made for the onboard External Audits to be conducted by a
Recognized Organization (RO) / Certification Body.
Audits Schedules, for both Internal and External Audits, to the Vessels’ Master upon DPA and all
Management Representatives approval.
The Schedule of ISM/ISPS/MLC External Audits is drawn, based on their due date according to the
requirements of the ISM Code, ISPS Code and MLC, respectively, and the anniversary dates / validity
of the corresponding certificates.
Initial Audit Before the expiration date of the Interim SMC, ISSC & MLC 2006
Certificates within six (6) months from the Interim Audit
Annual Verification Audit Between the second and the third anniversary year of the issue of the
SMC, ISSC and MLC 2006 Certificates.
Renewal Verification A. Before the expiration of the Long Term SMC, ISSC and MLC
Audit: 2006 certificates (five (5) years).
(Details on the Renewal Verification of the SMC are provided in
§ 13- of the ISM Code).
B. The Master must ensure that the Audit Schedule prepared by the S&Q Department complies with
aforementioned requirements.
Failure to schedule and conduct the annual, intermediate and renewal audits are considered as a
violation of SOLAS–Chapter IX, ISPS Code and MLC and the relevant certificate may be suspended
or revoked.
Page 10 of 19
The Schedule of ISO External Audits is drawn, based on the sample that the RO/Certification Body
will request to verify as part of the company’s certification and the anniversary dates / validity of the
corresponding certificates.
ISM/ISPS/MLC 2006 External Audits due to Change of Flag only

The RO is authorized to issue a Short Term Certificates to a Vessel changing Flag, without an initial
verification audit, if the following conditions exist:
 The Company chooses not to undergo a full initial verification audit leading to a new Full Term
five (5) year Certificate.
 The Vessel is changing Flag within a company managed fleet.
 The Company remains the same and holds a valid Full Term DOC for the ship type.
 The Vessel has a valid Certificate with no major nonconformities open or outstanding.
 The RO remains the same for the Vessel.
 The crew is predominantly the same or at the very least, is familiar with the Certificate.
 A periodical external audit onboard the Vessel has been satisfactorily completed by the RO within
the last six (6) months or an annual shipboard internal audit has been reviewed with satisfaction
by the RO at the most recent annual Company DOC Audit made within the same period.
If any of the conditions mentioned above have changed or does not apply with the change of flag,
then the Vessel must be treated as a new Vessel entering the new Registry and be issued an Interim
Certificate.
2.5.1 Vessel Preparation for External Audits

When the Audit Schedules are finalized in early January of each year, each Vessel must be notified
in writing of the forthcoming audit.
The S&Q Department must take all the necessary steps in order to ensure the Vessel’s preparation.
This includes:
 Thorough review of all the Vessel’s reporting, certificates, audit results etc.
 Arrangement for the Annual Internal Audit, before the External Audit date ( if possible).
The S&Q Department is responsible for the arrangement and preparation of the External Audits.
The Company Security Officer is responsible for the arrangement and preparation of the ISPS Audits.
The S&Q Manager is responsible for the overall coordination.
2.5.2 Arranging the External Audits with the Recognized Organization

The final arrangement of External Audit is the responsibility of the S&Q Department.
The Audit must be arranged in close cooperation with the Operations Department, in order to ensure
that there is adequate time for the Audit to be conducted at the specific port.
The proposed Audit date and Port must be approved by the DPA.
Quite before the proposed Audit date, the S&Q must notify the RO, requesting the arrangement of
the External Audit on the selected date and port.
This procedure is processed by filling-in a Format which is provided by the RO Office.
As soon as the RO Office confirms attendance, the Vessel and the Vessel’s Agent are notified in
writing.
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For a Company Fleet with Vessels individually classed by one or more recognized Classification
Societies, a single RO may, if requested by the Company, act as a sole assessor in performing the
verification audit and certification of SMS for the Company and all of its Vessels.
The RO does not have to be the Classification Society of any of the Vessels in the fleet.
ROs may establish their own service requirements, provided they do not negatively affect the
compliance with the ISM Code.
2.5.3 Processing the External Audit Report

Immediately after the External Audit is completed, it must immediately be forwarded to the Office
(even the same day), to the attention of the S&Q Department, by e-mail attachment.
Upon receipt of the External Audit report, the S&Q Department performs the following activities:
 Briefs the DPA and the responsible Management Representatives, if applicable, on the Audit
results
 Communicates the Audit results to all the Vessels.
 Updates the S&Q Electronic Files with the Audit results and the due dates for corrective actions.
 Updates the “Archive” database with the new Certificates data (Certificate Number, Issue date,
Expiration date, and endorsement).
 Sends the newly issued statutory certificates to the Flag Administration of the Vessel.
 Issues “Summary Tables” of the ISM External Audit results, and files them together with the
complete Audit report in S&Q File - “ISM External Vessel Audits”.
 Sends these “Summary Tables” to the Vessel by e-mail attachment to serve as quick and easy
reference and follow-up.
 Reviews the Audit Results, and in cooperation with the DPA and the responsible Management
Representatives, as applicable, decides on the corrective action to be taken and the persons
responsible to implement them.
 Coordinates the corrective actions necessary for the close out of the Non Conformities.
 If the Non Conformities raised, are related to mistakes and inadequacies of the Company IMS,
the S&Q initiates an amendment process in order to incorporate the necessary corrections to the
IMS, before the due date of the Non Conformities.
 Keeps the Hard Copy and Electronic Files updated with the progress of corrective actions taken
by the Shipboard and Office staff for the close-out of the Non Conformities.
The same procedure, as stated above must be followed by the Company Security Officer
for the processing of the ISPS External Audit reports and Certificates.
2.5.4 Closing the Non Conformities resulting from External Audits

Upon completion of the Corrective Actions, the S&Q must collect all supporting evidence from the
Vessel, from the Office Departments and from any other party involved in the close-out procedure.
A set must be prepared to be submitted to the RO, which must include the following:
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A. An official letter addressed to the RO, accompanying the enclosed set, and requesting for the
close-out of the Non Conformities and their deletion from the Vessel’s Class Survey Reports.
B. All the Conformity Notes, duly completed with a brief description of the corrective action taken.
The Non Conformity Notes must be signed by the DPA or the SAQ Manager.
C. Each separate Non Conformity Note must have attached a page with a detailed description of the
corrective action taken, as well as any supporting evidence available.
The official set is produced in three (3) copies and is distributed as follows:
 One copy is sent to the RO/Certification Body.
 One copy is sent to the Vessel.
 One copy is kept by S&Q.
The RO must review the set with the supporting documentation, and if it is to their satisfaction, they
must sign and stamp the Non Conformity notes at the left down part, as “Corrective Action Accepted”,
and return them to the S&Q Department.
Copies of the Non Conformity Notes must be filed in S&Q File 004.
The originally signed Non Conformity notes must be forwarded to the Vessel, accompanied by an
official letter.
The Master must file them in his Master’s File SAQ 01 “ISM External Audits” and must confirm
receipt to the S&Q Department.
During the next External Audit of the Vessel, the External auditor must review the Non Conformity
notes, and if the onboard verification is considered satisfactory, he must sign them in the right lower
section, “Close-out” for final close-out.
Copies of the “double-closed” Non Conformity notes must be sent by the Vessel to the Office, to the
attention of the S&Q Department.
When the above procedure is complete, the External Audits are considered as finally closed-out.
The same procedure, as stated above must be followed by the Company Security Officer for the
closing of the Non Conformities of the ISPS & MLC 2006 External Audit reports.

Quarterly and at the end of each year, the results of all the Vessel ISM/ISPS External Audits must be
collected and grouped in categories per nature of deficiency.
The purpose is to identify any common Non Conformities which may be an indication of weakness
of the SMS.
A relevant ISM Circular must be issued, analysing the Audit results, and must be distributed through-
out the Company.
The Audit results must also be included in the Agenda of the Management Review Meetings.
Evaluation of the ISM/ISPS External Vessel Audit Findings may result in:
A. Amendments of existing IMS Procedures and Forms.
B. Development of new IMS Procedures.
C. Issuance of guiding Circulars on specific IMS elements.
D. Identification of training needs.
Page 13 of 19
2.6 MONITORING OF ISM/ISPS/MLC/ISO CERTIFICATES

This section describes the arrangements necessary for the issuance and monitoring of the Certificates.
The S&Q Department is responsible for monitoring the ISM, ISO, ISPS and MLC Certificates.
The S&Q Department is also responsible for notifying the Flag Administration of newly
issued/renewed statutory SMC, ISSC and MLC 2006 Certificates.
The S&Q is responsible for the distribution of the Certificates as follows:

 Vessels
o Original SMCs, ISSPs, MLCs
o Copies of the valid DOC of the relevant Flag Administration upon DOC renewal/
endorsement following every Annual Verification audit
o Copies of the ISO 9001, ISO 14001, ISO 27001, ISO 45001 and ISO 50001 Certificates
 Flag Administrations
o Copies of the statutory certificates and their relevant endorsements, sent by e-mail
attachment.
The S&Q is responsible to check and ensure that all Certificates issued by the RO/Certification Body
are correct.
The distribution of the Certificates is made following the Document Control Procedures.
Copies of the valid Certificates must be filed electronically in the Company “Archive” database. The
S&Q Department is responsible to update the “Archive” database with the newly issued or renewed
Certificates.
In case of ISO Certification, the S&Q Department is responsible for arranging for the “Annual
Routine Surveillance” or the “Certificate Renewal” Audits, as previously described and upon
satisfactory completion of the audits it must made available for use in Company documents the
corresponding “ISO Approval Mark”.
The same procedure, as stated above must be followed by the Company Security Officer for the
monitoring of the ISPS Certificates.
2.7 VESSEL’S PREPARATION FOR EXTERNAL AUDITS

When the Master receives the final External Audit notification from the S&Q Department, the Vessel
and crew must be fully prepared.
The following must be checked:

 An overall review of the vessel’s Reporting and PMS Status must be carried out.
Any PMS Pending issues must be addressed, and if time does not permit, a relevant extension
should be granted by the Office Department responsible.
Any Non-Conformity and Observation raised during Internal Audits & 3rd Party Inspections
must already be closed. If this is not possible, evidence of follow-up must be available.
If for example some equipment are required or equipment need repairs, the Master must make
sure that a Defect report in the PMS has been issued and a relevant requisition has been sent
to the Office.
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He must also be aware of the status of the requisition, especially if it is relevant to critical
equipment.
(Note: for Defects of Critical Equipment, a relevant Risk Assessment must also be available).
 ISM/ISPS/MLC Internal Audits

The Internal Audit must have been conducted before the External Audit, on their due date and
if possible, all the Non Conformities and Observations raised must be closed or evidence must
exist that they are in progress.
The Internal Audit files must be reviewed in detail to ensure that all documentation is present
as per the Vessel’s Standard Filing System.
 Vessel’s Physical Condition and cleanliness.

All the Vessel’s spaces must be re-inspected one last time, by Master, the Chief Officer and
the Chief Engineer to ensure that all are in order.
 Audit “Priority Items”

These are the following:
a. Availability, knowledge & implementation of Rules, Regulations and Flag
Requirements.
b. Implementation of Risk Management controls.
c. Ship/Shore communication and follow-up including communication with the DPA.
d. Status on Ship’s Statutory and Class certification, outstanding memos and conditions.
e. Shipboard Familiarization and training for Officers and Crew.
f. Status on Contingency Plans and Drills including evaluation and reporting
g. Status on the Ships (Planned) Maintenance for Deck and Engine-room including FFA,
LSA & Critical Equipment.
h. Language and communication onboard.
i. Specific Shipboard operation for this type of ship addressed.
j. Master and Officers familiarity with the IMS.
k. Chart corrections, NTMs and Nautical Publications
l. Masters over-ridding authority.
m. Master’s reviews of the IMS.
n. Review of Internal and External Audits as applicable, including findings and associated
corrective action.
o. Sample STCW 95 requirement (licenses, COCs , CRA , Medical Fitness, Watch Schedules
etc)
p. MLC 2006 requirements (MLC Convention)
The Master and his Officers must ensure that all above are in order, that the Files are complete
and the records are correct.
All crew must be aware of the Company’s Policy regarding the Master’s Ultimate Authority
and the Name and Role of the DPA and CSO (and their Alternates).
 IMS Awareness
All Officers and crew must be well aware of the IMS procedures related to their work.
Page 15 of 19
 IMS Documentation and Vessel’s Standard Filing Plan

All Hard Copy IMS Documentation must be inventoried and must be placed by numbering
sequence in the Master’s Office or Ship’s Office.
All Officers must review their files and ensure that they are in good condition.
The following Manuals must be checked to ensure that their Ship Specific Sections are
updated:
o SOLAS Manuals.
o Fire Training Manuals.
o Plans and Procedures for Recovery of Persons from the Water.
 Findings from previous ISM/ISPS /MLC External Audits

The Master and his Officers must review the previous ISM/ISPS/MLC External Audits and
ensure that all corrective actions taken to close any Non-Conformities raised, are still in force
and well implemented.
Repetitive findings during External Audits may result in the issuance of Major Non
Conformities.
 Pre-audit Safety Meeting

A Safety Meeting must always be held before the External Audit.
All crew must be reminded to go through their IMS Documentation, Responsibilities, Files,
in order to be fully prepared.
Their working place must be checked to ensure that it is tidy and clean.
The procedure “Third Party Inspections” of the IMS Procedures Manual, must be reviewed
and followed.
2.8 EXTERNAL NAVIGATIONAL AUDITS

As per the TMSA Requirement- Element 5A- the Company must arrange independent, random
Navigational Audits across the fleet to check general navigational competence.
The Deficiencies raised during these Audits, must be reviewed and treated as ISM External Audit
results and must be closed out.
Records of the External Navigational Audits are maintained in Bridge File “Navigational Audits”.
The follow up of the External Navigational Audits and the Summary Table listing all the External
Navigational Audits must be found filed in Bridge File.
The Third Party Navigational Audits are monitored by the Marine/Vetting Department.
2.9 SHIP’S CERTIFICATES
2.9.1 General
The Master must ensure that all Flag Administration and Classification Society Surveys are timely
carried out and that the Vessel’s Certificates are maintained valid at all times.
Any new Certificate received onboard should be carefully checked by the Vessel’s Master for any
errors before filing.
Page 16 of 19
In case of any noted error or if there is any doubt as to the validity or authenticity of the certificate, the
Company must be advised immediately.
The Master must maintain Files of all the original Ship’s Statutory Certificates and any other
Certificates that may be required during an Inspection.
Original Certificates are maintained in the Master’s Standard Filing System as follows:
 File TEC 01- Primary Certificates,
 File TEC 02A - Secondary Certificates and
 File TEC 02B- Safety Equipment Certificates
Obsolete Certificates must be kept in separate files (File TEC 03A & TEC 03B).
2.9.2 Electronic Certificates
Definitions
Electronic Certificate A Certificate which is issued in an electronic format.
Electronic Signature Data in electronic form which is attached to or logically associated
with other electronic data to serve as a method of authentication of the
issuer and contents of the electronic data.
Printed version of A paper print-out produced from the Electronic Certificate.
Electronic Certificate
Unique Tracking A string of numbers, letters or symbols used as an identifier to
Number distinguish an Electronic Certificate issued by an Administration or its
representative from any other Electronic Certificate issued by the same
Administration or representative.
Verifying A reliable, secure and continuously available process to confirm the
authenticity and validity of an Electronic Certificate using the unique
tracking number and other data contained on or embedded in an
Electronic Certificate.
Issuance of Electronic Certificates

Electronic Certificates can be issued by:
 The Flag Administration,
 Recognized Organizations (Classification Societies, Training Centers etc), if the same are
approved by the Flag Administration.
As per IMO Requirements (FAL.5/Circ.39 as amended), where the Electronic Certificates are issued
by the Flag Administration of Recognized Organization, these should have the following features:
 Validity and consistency with the format and content required by the relevant International
Convention or instrument, as applicable.
 Protected from edits, modifications or revisions, other than those authorized by the issuer.
 A unique Tracking Number used for verification.
 A printable and visible symbol that confirms the source of the issuance.
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Processing of Electronic Certificates

Upon receipt of an Electronic Certificate onboard, the Master should:
 Ensure that the Certificate issuing Authority instructions/procedure is available for online
access to Electronic Certificate for verification including confirmation of periodic
endorsements, when necessary.
In case of unavailability of same, the Company must be promptly notified.
 Verify authenticity and validity of an Electronic Certificate using the unique tracking
number and other data contained on or embedded in the Electronic Certificate in accordance
with instructions /procedure of the issuing Authority.
 Print the Electronic Certificate by high quality printing and file the printed version and
electronic version accordingly.
The Ship’s Master should ensure that the validity of Electronic Certificates is checked with the
required frequency and out-of-date Certificates are promptly removed.
Verification Instructions/ Procedures

Instructions/ Procedures for verifying the information contained in any Electronic Certificate,
including confirmation of periodic endorsements, when necessary, should be readily available on
board the ship.
The Master and Officers must be able to demonstrate online access to electronic certificates for
verification on demand of the Authorities of any State Party, while a certified vessel is within the
jurisdiction of such State.
2.9.3 Monitoring of Certificates and Surveys

The Certificate Status Report (SF/TEC/112A-B-C) is sent to the Office on a MONTHLY basis, thus
providing a back-up system ashore for the monitoring of the Vessel’s Certificates.
This report must be filed in the corresponding Files (TEC 01-02A-02B) as mentioned above.
For Certificates expiring within one (1) month, the Master must always ensure that the renewed
Certificate is onboard.
If not, the Office must be alerted by e-mail.
As soon as a renewed Certificate is received in Office, it must immediately be forwarded to the
Vessel, by e-mail attachment, and must be mailed the soonest possible, following a strict Document
Control Procedure.
The Chief Engineer must maintain any records required for Classification Society Surveys.
The Master must advise the Company Office, if Survey Arrangements have not been agreed within
two (2) weeks from the due date of the Survey.
The Master may use as guidance the Flag Administration form “Report of Safety Inspection” for
preparing the Crew and the Vessel for the Annual Safety Inspection.
When a Survey is due, the Master and Chief Engineer must ensure that all preparations for the Survey
are completed before the Surveyor attends the Vessel.
When the Master receives a Certificate directly from the Flag Administration or Classification
Society, a copy must be forwarded to the Company and the Certificate must also be uploaded in the
ERP.
Page 18 of 19
2.9.4 Taking Ship’s Certificates Ashore

During the Vessel’s stay in Port, it is usual practice for the Agent to take the Vessel’s Certificates
ashore for inspection by Port Authorities.
This may cause a problem, if the Vessel has a Third Party inspection in that Port and the Inspector
requests to review the Vessel’s Certificates.
If it is necessary for the Agent to take the Vessel’s Certificates ashore, the following procedure must
be applied:
A. The Agent must hand a Letter of Receipt for the listed Certificates.
B. If there is a scheduled Inspection for Vetting/ Flag/USCG-PSC , the Agent must be informed to
return the Certificates, preferably before the Inspection or at least while the Inspector is still
onboard.
C. Before handing over the original Vessel’s Certificates to the Agent, photocopies of the
Certificates must be made and placed in the respective Files.
The copies must be removed after the Original Certificates are returned.
However, it must be stressed that the Inspectors insist in checking Original Certificates.
3. RECORDS
None
Page 19 of 19
(002) Revision: 07
INFRASTRUCTURE Eff. Date: 30/09/2022
Contents
1. PURPOSE ..................................................................................................................................2
2. PROCEDURE ............................................................................................................................2
2.1 Office Infrastructure - Responsibilities ...................................................................................2
2.1.1 Company Buildings/Spaces......................................................................................................................... 2
2.1.2 Office Furnishing & Utilities ...................................................................................................................... 2
2.1.3 Monitoring of Building-Related Maintenance and Repairs......................................................................... 2
3. RECORDS .................................................................................................................................2
Page 1 of 2
(002) Revision: 07
INFRASTRUCTURE Eff. Date: 30/09/2022
1. PURPOSE
This procedure describes the arrangements which are made in order to provide the suitable
infrastructure which is necessary for the smooth operation of the Company.
In addition, it describes the functions and working instructions of the IT Administrator.
2. PROCEDURE
2.1 OFFICE INFRASTRUCTURE - RESPONSIBILITIES

Infrastructure includes the buildings, workspace, associated utilities, process equipment and other
supporting services. The Office Administrator is responsible for the Office Infrastructure.
2.1.1 Company Buildings/Spaces

The Office Administrator has been authorized by the Chief Operating Officer (COO) or Deputy
COO to identify suitable office locations for renting or purchasing, when required.
The Office Administrator is responsible to make market research through advertisements or Real
Estate Agencies, to collect all relevant information and advise the COO or Deputy COO
accordingly.
The required space may be for Office Premises, Storage Spaces and/or Parking spaces.
Following the consent of the COO or Deputy COO, the Office Administrator is authorized by the
Company, to sign Contracts/ Leases etc, on behalf of the Company.
The Office Administrator is responsible to keep all the Contracts/ leases, in relevant files and to
effect the payments regarding Company Buildings as per contract /lease agreements.
2.1.2 Office Furnishing & Utilities

The Office Administrator is responsible to ensure that adequate Office furnishing and other utilities
are available for the smooth operation of the Company.
An evaluation of Office needs on a continuous basis must be carried out, in order to ensure that at
all times, all Employees are provided with the necessary Office furniture, telephone extensions and
mobile phones, as required by the position of each.
Additionally, the Office Administrator, in cooperation with the IT Administrator, must ensure at all
times that the Office has adequate supporting utilities such as, photocopy machines, fax machines,
scanners and Personal Computers.
2.1.3 Monitoring of Building-Related Maintenance and Repairs

The Office Administrator is responsible to monitor all building related items:
 Office Cleaning Services.
 Fumigation, if required.
 Maintenance (painting / general upkeep).
 Maintenance and Repair of Air-conditioning / Heating units (every four months).
 Electric and plumbing installations.
3. RECORDS
None
Page 2 of 2
(002) Revision: 09
COMMUNICATION Eff. Date: 30/09/2022
Contents
1. PURPOSE ..................................................................................................................................2
2. PROCEDURES ..........................................................................................................................2
2.1 Internal Communication .........................................................................................................2
2.1.1 Office communication equipment ............................................................................................................... 3
2.1.1.1 Office Telephone Switch-board ...................................................................................................................... 3
2.1.1.2 E-mail/Fax/Telex............................................................................................................................................. 3
2.1.1.3 Mobile Telephones .......................................................................................................................................... 3
2.1.2 Office communication processes................................................................................................................. 4
2.1.2.1 Reviewing incoming and outgoing messages.................................................................................................. 4
2.1.2.2 Holding Departmental Meetings ..................................................................................................................... 4
2.1.2.3 Holding Inter-Departmental Meetings ............................................................................................................ 4
2.1.2.4 Management Review Meetings ....................................................................................................................... 4
2.1.2.5 Inter-Office Memos ......................................................................................................................................... 5
2.1.2.6 Company Circulars.......................................................................................................................................... 5
2.1.2.7 Sending Vessel Mail ....................................................................................................................................... 5
2.1.2.8 Webinar ........................................................................................................................................................... 5
2.1.2.9 Office-Vessel Conference Calls ...................................................................................................................... 5
2.1.2.10 Alerts, Bulletins and Newsletters .................................................................................................................. 5
2.1.2.11 Archive Database .......................................................................................................................................... 6
2.1.3 Vessel Communication Equipment ............................................................................................................. 6
2.1.3.1 E-mail, Fax, GMDSS ...................................................................................................................................... 6
2.1.3.2 Internal Telephone System .............................................................................................................................. 6
2.1.3.3 Public Address and Alarm Signals .................................................................................................................. 6
2.1.3.4 VHF and Walkie-Talkies ................................................................................................................................ 7
2.1.4 Vessel Communication Processes .............................................................................................................. 7
2.1.4.1 Telephone ........................................................................................................................................................ 7
2.1.4.2 Sending Messages to the Company and Third Parties .................................................................................... 7
2.1.4.3 Vessel’s Mail................................................................................................................................................... 7
2.1.4.4 Safety Meetings ............................................................................................................................................... 7
2.1.4.5 Departmental Meetings before carrying out work ........................................................................................... 7
2.1.5 Vessel Communication Processes for Feedback to Office ......................................................................... 7
2.1.5.1 Standard Reporting to the Office..................................................................................................................... 7
2.1.5.2 Feedback for Safety-related Issues .................................................................................................................. 8
2.2 Communication with External Parties ....................................................................................8
3. RECORDS ............................................................................................................................... 10
Page 1 of 10
(002) Revision: 09
1. PURPOSE
This procedure describes the way with which effective communication channels are established
throughout the Company, through the availability of suitable equipment and efficient communication
procedures.
The Company strongly encourages an “Open Reporting Environment”, where employees feel
comfortable and willing to raise any and all integrity concerns, which helps to highlight a problem
before it grows bigger and prevents the Company from potential losses, legal actions, injuries or
reduced performance.
Office or Shipboard employees, wishing to report a matter of concern, must make their
disclosure, by sending an e-mail to the e-mail address: openreporting@prime-marine.net.
2. PROCEDURES
2.1 INTERNAL COMMUNICATION

Top Management has established procedures for effective communication channels throughout the
Company.
These procedures apply to interoffice communications, as well as communication with Vessels,
Charterers and Third Parties, such as Suppliers, Flag Administrations, and Classification Societies
etc.
The Official Language of the Company (in Office and Onboard) is ENGLISH.
As a general principle, all communications, written or verbal, must be carried out in English and
must be clear, concise and unambiguous.
The method of transmission must be made by the most appropriate method, taking into account the
nature of communication (i.e. in an emergency the most appropriate method will be by telephone or
fax).
The Company recognizes that the effective communication at all levels of its business is of a
paramount importance and may enhance the overall performance.
The Company has established lines and methods of communication and continues to improve these
with computerized systems of the latest technology.
Particular importance is placed on communications between the Office Personnel and the Vessels
on a 24 hours basis, Interoffice-communication, and communication with Third Parties.
Communication exchanges are effected by means of e-mail, fax or letter, circulars etc.
Communication to Ships, in addition to instructions contained in the Company’s Manuals are given
by telephone, e-mail, fax, and mobile telephones.
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(002) Revision: 09
The communications system has a control mechanism which reports received or failed messages. The
relevant original messages are resent in case of failure notification.
Important issues are sent through circular messages and official Circular Letters.
The Department Managers are responsible for establishing an effective communication flow within
their Departments.
They are also responsible for ensuring that information received by their department, which is
pertinent to other Departments, is efficiently communicated.
The Department Managers are responsible to review all the incoming messages related to their
department, to respond, and to keep records of the communication exchanged.
2.1.1 Office communication equipment
2.1.1.1 Office Telephone Switch-board

o The Company has established a Telephone Switchboard with multiple lines.
o In addition, each extension of the Switchboard can be called directly in emergency
situations, when the switchboard operator is not in Office.
2.1.1.2 E-mail/Fax/Telex
The Company has a general e-mail address, and general Fax and Telex Numbers.
They all operate under the communication software, and all Office Employees have access to the
incoming messages.
All outside parties, including Fleet Vessels, can send e-mail messages to the general
address/numbers.
As a back-up in case of temporary failure in the communication software, the Office is equipped
with a manual fax machine that will automatically receive any fax messages sent to the general
fax number, and can also be used to send-out faxes .
Each Office Department has its own e-mail address for quick review and processing of
Department –specific matters.
2.1.1.3 Mobile Telephones

All the members of the Emergency Response Team, and other Office employees are provided
with Company Mobile phones enabling the Vessels to call on a 24-hours basis and communicate
at any time, outside the office hours –or in case of a temporary failure of the telephone landlines
in the Office.
The relevant “Mobile Phone Use Policy”, as found in the Integrated Management System
Manual (IMSM 001) – Appendix Z-1, n the Office Manual (OFF 008)–Appendix B, and in the
Office Employee Handbook, must be strictly followed.
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(002) Revision: 09
2.1.2 Office communication processes
2.1.2.1 Reviewing incoming and outgoing messages

The communication of information in Office is achieved as per “Computer, E-mail and Internet
Policy”, of the Integrated Management System Manual (IMSM 001)-Appendix Y.
2.1.2.2 Holding Departmental Meetings

The Department Manager may hold meetings, weekly or even daily (if required), in order to
discuss planned action, problems, corrective actions, improvement etc.
2.1.2.3 Holding Inter-Departmental Meetings

The Chief Operating Officer (COO) or Deputy COO or the DPA may hold Interdepartmental
meetings when deemed necessary and when assistance and cooperation between Office
Departments is necessary i.e to discuss various problems, future plans and strategies and other
IMS matters, to make Risk Assessments of projects/work to be carried out etc.
Such Interdepartmental Meetings include:
 Fleet Coordination Meetings.
These meeting will be held weekly, and will include the following topics:
o Operational Schedule, including any specific operational requirements.
o Inspections (Planned or potential PSC).
o Technical Status focusing only on Defects/Cases that can affect the vessel’s operation or
inspections.
o Crew Matters that may affect the vessel’s operation.
The participants will be as follows:
o COO/DCOO.
o Operations Managers.
o Marine/Vetting Managers.
o Technical Manager/Deputy Technical Manager.
o Crew Manager.
 Safety Meetings
These meetings will be held MONTHLY, and will include topics related to Safety.
 Maintenance Review Meetings

These meetings will be held MONTHLY.
 Management Meetings
These meetings will be held MONTHLY.
2.1.2.4 Management Review Meetings

These are the official Management Review Meetings, which are held in the presence of the Chief
Operating Officer (COO) or Deputy COO, the DPA, all Management Representatives, the
Managers of all Departments and selected staff from each department.
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(002) Revision: 09
The Management Review meeting has a defined agenda, which covers the functions of all
Departments. A relevant procedure for Management Review Meeting is found in this Manual.
2.1.2.5 Inter-Office Memos

A department may issue Inter-Office memos (distributed in hard copy or electronically through
the communication software) in order to announce an important procedure, change in the
Company’s IMS, or introduce a new International Regulation, to analyze any identified problem
etc.
2.1.2.6 Company Circulars

Company Circulars are issued in order to introduce new practices and procedures.
Additionally, Circulars are sent to the Vessels for rapid notification of urgent safety-related
issues within the fleet.
All Company Circulars must be numbered, processed and distributed through the S&Q
Department. The Circulars are uploaded in the ERP, and for easy retrieval are also
electronically saved in the "Archive" database.
All Company Circulars are forwarded to the Vessels electronically through the ERP Module.
2.1.2.7 Sending Vessel Mail

The Company may communicate information to the Vessels, through the Vessel’s Mail
Procedure.
As a general Office rule for sending Vessel Mail, all the mail must be placed in the Vessel’s mail
cube, in an envelope clearly marked with its contents. All mail to the Vessel must be forwarded
in identified and labeled bags accompanied by a "List of Contents".
The dispatch and follow-up of Ship’s Mail is the responsibility of the Office Secretary.
2.1.2.8 Webinar
Interactive Seminars or other presentations are organized, which take place on the Internet and
allow participants in different locations to see and hear the presenter, ask questions, express
opinions. Such Webinar Seminars and presentations are carried out by the HR Department and
the Training Department.
2.1.2.9 Office-Vessel Conference Calls

Office –Vessel Conference Calls (or connection with the Bridge and Engine Control Room may
be carried out, during Incidents, Accidents and during difficult Vessel Operations i.e Tank
Cleaning, difficult STS Operations, Ice Navigation, preparation for Hurricane encounter, Piracy
Attack, Information Security Incident etc
2.1.2.10 Alerts, Bulletins and Newsletters

The Company issues various Safety and Technical Alert Messages and Bulletins in order to share
Industry best practices, draw attention to specific issues etc.
Health Bulletins are issued on a Monthly basis.
Company Newsletters are issued Quarterly.
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(002) Revision: 09
2.1.2.11 Archive Database

The Company has established the "Archive Database", where various information is recorded and
updated.
The Archive Database includes the following information:
o Company Circulars.
o Vessel Position Lists.
o Management of Change ( MOC)
o Management Review Meeting Minutes.
o Office Audit Results by Oil Majors.
o DOC & SMC Certificate status.
o DOC & SMC updated certificates.
o ISM/ISPS/ MLC/ISO Audit Schedules.
o Vetting Status.
o Office Departments’ Filing Records.
o Voyage Files / Results.
o Ship’s Certificates.
o Results and status of inspections: PSC, USCG, Flag, P&I, Vetting Inspections.
o Fleet Lists.
o Ship Visit reports.
o Ship Visits by Superintendents.
o Codes of Company Mobile Phones.
o TMSA .
o Other.
All Office Employees have access to the "Archive" Database.
2.1.3 Vessel Communication Equipment
2.1.3.1 E-mail, Fax, GMDSS

All the Vessels are equipped with e-mail, fax and telephones.
All the Vessels have a telephone via Inmarsat.
The communications between Office and Vessels are established by the use of e-mail, fax and by
telephone and mobile telephones.
All the Vessels have been provided with Company mobile phones.
2.1.3.2 Internal Telephone System

All the Vessels are equipped with an Internal Telephone System enabling the various
departments – Bridge, Engine Control Room, Master’s Office, etc. to communicate.
2.1.3.3 Public Address and Alarm Signals

The Vessel’s Public Address system is used in order to communicate a general order or an
emergency onboard, as well as the Alarm system, depending on the emergency.
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(002) Revision: 09
2.1.3.4 VHF and Walkie-Talkies

The communication between Shipboard Departments during Vessel operations, is done by the use
of VHF and Walkie-Talkies.
Shipboard Procedures and checklists are available to ensure the regular testing and maintenance
of Communication Equipment.
2.1.4 Vessel Communication Processes
2.1.4.1 Telephone
The Vessel may communicate with the Office and all other Third Parties by using the telephone.
In any event, any telephone conversation which is important, must be backed –up by a written
message, confirming the contents of the discussion.
2.1.4.2 Sending Messages to the Company and Third Parties

The Vessel communicates through messages, sent by e-mail and fax.
Records of all communication exchanged, must be kept in the appropriate files of the Vessel’s
Standard Filing System (and/or electronically).
If the contents of messages with Third Parties are important, such messages must also be made
"cc" to the Company.
2.1.4.3 Vessel’s Mail

Information and reporting is sent from the Vessel to the Company, by mail.
Mail is usually sent by the Vessel on a monthly basis, through the Agent.
2.1.4.4 Safety Meetings

Safety Meetings are held at least once a month, with the participation of all shipboard personnel
except those who are on duty. During the Safety Meetings, which have a defined agenda, various
subjects are discussed as well as any correspondence received from the Office i.e. new circulars,
new or amended procedures, new requirements, risk assessments etc.
2.1.4.5 Departmental Meetings before carrying out work

Effective communication must be ensured in the various Shipboard Departments, before carrying
out work which requires a plan, involves risk and needs a Risk Assessment and Work Permit to
be issued. (i.e Daily Work Plans – refer to Shipboard Safety Manual (003)-Section 02).
2.1.5 Vessel Communication Processes for Feedback to Office

The Vessel provides feedback on various Operational and Safety/ Security Issues to the Office
through:
2.1.5.1 Standard Reporting to the Office

The Vessels reporting is carried out through the ERP Software, by e-mails and by phone
Page 7 of 10
(002) Revision: 09
2.1.5.2 Feedback for Safety-related Issues

Feedback related to Safety issues is communicated to the Office through:
 Reporting of Accidents/Incidents.
 Near Misses.
 Behavioural Safety Issues.
 Stop Work Authority Issues.
 Contractor’s Evaluation.
 Terminal Satisfaction reports.
 Open Reporting System, where any employee may send a request or comment directly to
openreporting@prime-marine.net or during Shore Personnel Visits onboard.
 Best Practices and Best Safety Ideas, reporting in the context of Safety Campaigns and
Competitions.
2.2 COMMUNICATION WITH EXTERNAL PARTIES

External Communication related to Environmental, Energy Efficiency, and Health and Welfare
Matters are recorded and logged.
Regarding the Environment this procedure provides instructions and assigns responsibilities
for external communication regarding environmental aspects and issues such as:
 Policies, procedures and instructions;
 Significant aspects, objectives, targets, and management programs;
 Feedback on environmental performance status and results;
 Suggestions and feedback from personnel and crew.
Regarding the Occupational Health and Safety this procedure provides instructions and assigns
responsibilities for external communication regarding:
 Internal communication among the various levels and functions of the Company,
 Communication with contractors and other visitors to the workplace,
 Receiving, documenting and responding to relevant communications from external interested
parties.
All comments resulting from the implementation of the Occupational Health and Safety matters shall
be also communicated utilizing this procedure.
The responsibility for communicating with contractors and other visitors, ashore or onboard, rests
with the responsible person for communicating the safety requirements.
Communication from interested parties, whether written or verbal, is forwarded to the DPA and /or
the responsible Management Representative.
Letters, faxes, e-mail, memos, conversations, minutes of meeting, etc., are recorded and maintained
by the corresponding Representative.
The DPA, Quality, Environmental, Energy Efficiency, and Occupational Health Management
Representative review the incoming communication and determine which other shore-based
Managers must be informed or involved, what response must be given to the originator (if any), and
whether any internal actions must be considered to address issues raised in the communication.
These decisions and determinations are recorded by them.
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(002) Revision: 09
The COO or Deputy COO is involved when the communication pertains to policy matters or has
potential legal consequences, or when his decision is required.
External Communication of the Company’s Policies includes the availability of the Company’s policy
statements to the public.
The Company’s management during the initial management review of the Integrated Management
System shall consider whether information on significant environmental aspects must, or must not,
be communicated externally.
The decision is recorded in the relevant management review minutes of meeting and can be
additionally reviewed at any subsequent review.
Same applies for externally communicate the information on energy efficiency matters.
It is the responsibility of the DPA and the Management Representatives to issue an Environmental,
Energy Efficiency and Occupational Health and Safety Report annually and present it to the
Management Review Meeting participants.
The report shall contain all aspects regarding the Environmental, Energy Efficiency, Occupational
Health and Safety Performance of the Company.
Communication with external parties regarding services rendered includes, but is not limited to:
 Communication of Company’s requirements;
 Comments resulting from the implementation of the occupational health and safety items to
involved third parties, contractors and suppliers, as applicable.
With regards to Information Security related activities, the ICT Manager is responsible for managing
relationships with National Authorities and Regulatory Bodies.
Personal data breaches must be reported to the national authority in accordance with the GDPR
requirements and applicable legislation.
More specifically, the following requirements have been identified and apply for Information Security
Incident reporting:
 National Response Center (NRC): In accordance with CG-5P Policy Letter 08-16: “Reporting
Suspicious Activity and Breaches of Security” certain types of information security events
constitute suspicious activity and breaches of security (“BoS”) must be reported to the National
Response Center (NRC).
 National Computer Emergency Response Team (NCERT-GR): Company may report information
security incidents to NCERT-GR, which is responsible for the collection of information security
incident data. NCERT-GR maintains an emailed-based reporting platform to log incidents under:
http://www.nis.gr/portal/page/portal/NIS/NCERT.
 Company complies with the Facilitation and Maritime Safety Committees that have initiated
consideration of information security matters and will work on this matter in consultation with
other United Nations bodies and relevant international organizations such as the International
Telecommunication Union (ITU). MSC 96 (May 2016) approved interim IMO guidelines on
maritime cyber risk management, aimed at enabling stakeholders to take the necessary steps to
safeguard shipping from current and emerging threats and vulnerabilities related to digitization,
integration and automation of processes and systems in shipping.
The interim guidelines are expected to be updated when the Facilitation Committee has completed
its work on facilitation aspects of risk management.
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In addition, to improve knowledge about information security best practices and stay up to date with
relevant security information, the ICT Development Head is a member of:
 The Information Systems Audit and Control Association (ISACA), an international professional
association focused on IT governance;
 The Information Security Forum (ISF), an independent, non- profit organization;
 The Center of Internet Security (CIS), an independent, non-profit organization.
3. RECORDS
 Minutes of Operational Meetings
 Management Review Meeting Minutes
 E-mails
 Interoffice Memos
 Bulletins
 Alerts
 Newsletters
 Circulars
 Vessels’ Reports
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PURCHASING Eff. Date: 30/09/2022
Contents
1. PURPOSE ..................................................................................................................................2
2. PROCEDURE ............................................................................................................................2
2.1 Purchase requisitions ..............................................................................................................2
2.1.1 Details to be included in all Purchase Requisitions ..................................................................................... 2
2.1.2 Spares requiring Class Certificates.............................................................................................................. 3
2.1.3 Orders arranged locally by the Master ........................................................................................................ 4
2.1.4 Orders for Victualing .................................................................................................................................. 4
2.1.5 Delivery time of Requisitions ..................................................................................................................... 4
2.2 Process of Requisitions ...........................................................................................................4
2.2.1 Issuing Requisitions .................................................................................................................................... 4
2.2.2 Numbering Requisitions .............................................................................................................................. 5
2.2.3 Processing Requisitions for SPARES ......................................................................................................... 5
2.2.4 Processing Requisitions for STORES ......................................................................................................... 5
2.2.5 Clarifications ............................................................................................................................................... 5
2.3 Request for Quotation, Evaluation and Purchase Orders........................................................6
2.3.1 Request for Quotation ................................................................................................................................. 6
2.3.2 Evaluations and Approval ........................................................................................................................... 7
2.3.3 Purchase Orders .......................................................................................................................................... 7
2.3.4 Exceptions to Usual Purchase Order Procedures ........................................................................................ 8
2.4 Forwarding Goods to the Vessels ...........................................................................................8
2.4.1 Direct Orders / Forwarding Enquiries ......................................................................................................... 9
2.4.2 Forwarding Procedures ............................................................................................................................... 9
2.4.3 Forwarding Goods to the Vessels for IHM compliance requirements ........................................................ 9
2.5 Verification of Supplied Goods ............................................................................................ 10
2.5.1 Delivery Onboard ...................................................................................................................................... 10
2.5.2 Confirmation of orders received................................................................................................................ 11
2.5.3 Reporting Quality of Goods Received ...................................................................................................... 11
2.5.4 Discrepancies in Delivered Goods ............................................................................................................ 11
2.6 Checking / Approval of Invoices .......................................................................................... 12
2.6.1 Registering Invoices .................................................................................................................................. 12
2.6.2 Checking / Approving Invoices ................................................................................................................. 12
2.6.3 Discrepancies ............................................................................................................................................ 12
2.7 Landed Goods ....................................................................................................................... 12
2.7.1 Landing of Goods ...................................................................................................................................... 12
2.7.2 Dispatch Report for Landed Goods ........................................................................................................... 12
2.8 Spares Management Onboard and Inventories ..................................................................... 13
2.8.1 Maintenance of Spares .............................................................................................................................. 13
3 RECORDS ................................................................................................................................... 13
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1. PURPOSE
This procedure describes the steps to be followed by the Purchasing Department in order to ensure
appropriate and effective purchasing procedure from approved suppliers and subcontractors.
In addition, this procedure describes the Company’s practices for managing spares, supplies and
purchase requisitions and includes:
 Ordering and delivery onboard of ship’s spares and stores.
 Landing equipment on exchange basis, or as sample for fabrication of new parts.
 General instructions regarding spares and specific guidance for spares and stores needing Class
Certificates.
 Managing of inventories of spares and stores.
For services or products that the purchasing procedure does not involve the Purchasing department
utilizing requisitions, such as services provided by Manning Agents, Port Agents etc, reference is
made to other parts of the integrated management system.
These procedures are governed by the responsible Department.
2. PROCEDURE
2.1 PURCHASE REQUISITIONS

The Company’s Purchase Requisition System (for spares and stores) must be used when requesting
spares, stores or services for the ship.
Purchasing Requisitions are processed through the appropriate Purchasing Software and must
include all the necessary details, in order to ensure correct ordering.
However, the Requisitions forms – “Spares Requisition List” and “Stores Requisition List” have been
retained in the IMS, to be emailed to the Office occasionally, in any case of software failure or
malfunctioning.
2.1.1 Details to be included in all Purchase Requisitions

All Purchase Requisitions must contain:
A. A Purchase Requisition Number.
B. Sufficient Specification Details to describe accurately the item required, including manufacturer,
Part number, ROB quantities, reason for requesting.
C. Whenever necessary, accompanying sketches, machinery details such as serial number, rating etc
or drawings of the item required must be attached to the requisition.
D. For stores the CATALOGUE CODE and ROB quantities must always be mentioned for quick
and correct ordering.
E. Especially, when completing requisitions for spare gear, the following details are required, as
appropriate:
 Full description of the item and the reason for ordering.
 Manufacturer.
 Part Number.
 Serial Number.
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 Rating.
 Drawing Number.
 Quantity required.
 Material of construction, where applicable.
 Special inspections, if necessary.
 Class certificate required.
 Priority.
 ROB Quantity.
The CATALOGUE Codes of the items to be ordered, must be strictly for ASBESTOS Free Items.
( MLC 2006)
The Vessel must be advised of the supplier, orders and forwarders prior to arrival at the port.
The purchase system must be followed for all orders, except as permitted below for urgent orders,
arranged locally.
All Purchase Requisitions must be approved by the Master.
If the Office, for any reason cancels the Purchase Requisitions, then the Vessel must be notified
accordingly.
2.1.2 Spares requiring Class Certificates

When the spares to be ordered require a Class Certificate, this must be clearly stated on the requisition
form.
The following Spares in brand-new condition, must be accompanied by Class Certificates, while the
Stores mentioned below must be accompanied by Makers’ Certificates:
A. Main Engine
 Piston Crown and Skirt.
 Cylinder Cover and Insert (if applicable).
 Cylinder Liner.
B. Generator Engine
 Piston.
 Cylinder Liner.
 Crankshaft.
 Cylinder Cover.
C. Auxiliary Machinery
 New Pumps/Compressors/Purifiers complete.
D. Anchoring equipment
 Anchor chains.
 Anchor.
E. Stores
 Mooring Ropes
 Mooring Wires.
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2.1.3 Orders arranged locally by the Master

When unforeseen circumstances and Emergencies require the purchase of stores and/or spares, an
order may be placed without processing a Purchase Requisition through the Office.
This especially applies to cases when it appears not feasible for supplying stores locally via the normal
channels of the providers under contract, the Master having the clear authority to purchase necessary
stores or spares locally, prior to sailing.
Attending Company’s Representatives may also process a Purchase Requisition, in case of
emergency.
Further to the Master’s approval for all orders placed locally, permission from the Company must be
requested (oral or written).
In this case, the Vessel is obliged to send a message to the Office, noting all requested / received
items, and a copy of the Supplier’s Invoice and Delivery Note to enable the Purchasing Department
to update their records.
This message, together with the Supplier’s Quotation and the Delivery Ticket, must be attached to
the MGA Account.
A Purchase Requisition must be issued in any case following the completion of above procedure.
2.1.4 Orders for Victualing

For ordering Food supplies, the Master must fill-in the Victualing Report and forward it to:
1) Catering Provider (where applicable) which has been appointed by the Purchasing
Department.
2) Purchasing Department – where applicable.
2.1.5 Delivery time of Requisitions

The requisitions must be marked in terms of required urgency to proceed, by marking the “Priority”
check box in the applicable requisition templates, as follows:
A. Normal For normal delivery within three (3) months.

B. Urgent For urgent matters.
C. Top Urgent For matters related to safety and environmental issues.
2.2 PROCESS OF REQUISITIONS

This section describes the steps for issuing and processing requisitions.
2.2.1 Issuing Requisitions

For more details, reference is made to previous paragraph. Requisitions are usually issued by the
Vessels. However, if a need is identified, the requisition may be issued in the Office.
The usual Requisition format used may be either:
 Form-" Spares Vessel Requisition".
 Form-" Stores Vessel Requisition".
 Created using specific Purchasing Software.
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In Emergency cases, the Master, Chief Engineer or attending Company Representative may verbally
issue a requisition without using the usual form.
The verbal request will be followed by a message from the Vessel (e-mail or fax), which will
thereafter serve as the Vessel's requisition.
Typically, Vessels do not issue requisitions for PROVISIONS.
The Catering Provider requests Chief Cook or Master to revert with Provisions Requisition.
Purchasing Operators are authorized to issue requisitions based on Victualling Reports which are sent
to the office from the Vessels at the end of each month, where applicable
Depending on the convenience of the port, a Vessel may be instructed to purchase the items locally
– this usually refers to cases for fresh provisions.
2.2.2 Numbering Requisitions

All requisitions issued by the Vessels are approved by the Master and given a unique reference using
the formula XX-XXX/XX-SPA or –STO where:
 SPA – requisition concerning spares.
 STO – requisition concerning stores.
The numbering is as per automatic sequence given by the software.
2.2.3 Processing Requisitions for SPARES

Requisitions for SPARES are typically processed subject to the following conditions:
 ROB (Remaining On Board) quantities of the items requested.
 Reason for the Request.
 Priority is clearly specified.
 Authority / Approval is granted through a pre-defined workflow though the ERP by the
responsible Superintendent.
The Purchasing Spares Manager approves last.
No requisitions of spares can be processed without these approvals.
2.2.4 Processing Requisitions for STORES

Requisitions for STORES are typically processed subject to the following conditions:
 ROB (Remaining On Board) quantities.
 Duration of supplies requested is stated.
 Priority is clearly specified.
(Approval is not required).
2.2.5 Clarifications
If there are any unclear points or omissions in requisitions received at the office, then any of the
following office personnel may inquire with the Vessel for clarification, depending on the nature of
the clarification needed:
 Purchaser.
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 Ship Manager.
 Marine Superintendent.
 Operator.
2.3 REQUEST FOR QUOTATION, EVALUATION AND PURCHASE ORDERS

This section describes the procedure which is followed by the Purchasing Department for sending out
quotations, evaluating them and placing purchase orders.
It is the responsibility of the Purchasing Department to forward company’s requirements regarding
the occupational health and safety matters, and relevant requirements regarding the energy efficiency
matters to subcontractors and suppliers, by informing them that procurement is partly evaluated on
the basis of energy performance, if applicable.
2.3.1 Request for Quotation
A. SPARES
Once written authority has been given by the responsible Manager and by the Purchasing
Manager to proceed with the requisitioned items:
 The Purchaser must send out "Requests for Quotation"–obtaining at least two (2) written
offers (for each requisition) from approved suppliers.
It is understood that exceptions for obtaining two quotations may be granted in cases, such as
request from makers, emergency requisitions, non-availability, no reply etc.
 Requests for Quotation for Spares may also be sent to new / non-approved suppliers,
especially when the equipment cannot be supplied by an approved supplier.
 If it is agreed to place a Spares order with a new or non-approved supplier, then the Purchaser
must obtain approval from the Purchasing Manager.
B. STORES and PROVISIONS

 The Purchaser must send out "Requests for Quotation"–obtaining at least two (2) written
offers (for each requisition) from approved suppliers. It is understood that exceptions for
obtaining two quotations may be granted in cases, such as request from makers, emergency
requisitions, non-availability, no reply etc.
 Requests for Quotation for STORES and PROVISIONS may be sent to non-approved
suppliers, if no other supplier is available in the area, and because they are arranged through
local chandlers depending on Vessel's schedule.
C. Purchasing Operators are authorized to initiate Requests for Quotation, without first receiving
requisitions from the Vessel for:
 Provisions, where applicable.
 Lubricants.
 Chemicals.
 Gases.
This is done after evaluating amounts remaining onboard (ROB), maintenance schedule, etc., and
always in close cooperation with the Ship's Manager / Master / Chief Engineer.
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2.3.2 Evaluations and Approval

Based on Suppliers' offers, the EVALUATION is then prepared by using the specific Purchasing
Software, stating the following:
 Price of each item requested.
 Delivery time.
 Payment terms.
 Place of Delivery.
 Forwarding costs (if known).
 Total amount spent of the yearly budget for the category of evaluated items (i.e. spares, deck,
stores, engine stores, etc.)
The Evaluation is processed by the predefined workflow through the ERP and submitted to the
responsible Manager of each department for approval.
At this time, he may alter the quantities, or cancel or postpone the requisition.
The Authorization levels will be as follows:
Spares
 All evaluations regardless amount are approved first by Purchasing Spares Manager.
 Evaluations less than 5,000 USD must be approved by Fleet Manager.
 Evaluations equal to and above 5,000 USD to be submitted to the Technical Manager for
approval.
 Evaluations equal to and above 10,000 USD to be submitted to the Deputy COO for
approval
 Evaluations equal to and above 24,000 USD to be submitted to the Contracts manager for
approval – excluding evaluations of lubricants.
All of the above approvals are automatic and predefined in the Company’s ERP.
Stores
 If the actual amount spent (including the evaluations under approval process) is less than the
quarterly budgeted figure then Fleet Manager/Ship Manager can approve the order.
Otherwise, the case must be submitted to the Technical Manager for final approval.
 Evaluations equal to and above 10,000 USD to be submitted to the Deputy COO for
approval.
 Evaluations equal to and above 24,000 USD to be submitted to the Contracts Manager for
approval.
All of the above approvals are automatic and predefined in company’s ERP.
Upon approval by the responsible manager above, the Purchasing Operator can procced in order
placement.
2.3.3 Purchase Orders

Once it has been decided which offer to accept and the terms have been agreed upon between the
Company and the selected supplier, then a purchase order is placed.
 At times, Purchasing Operators may place direct orders based on recent evaluation in similar
cases, in order to save time, subject to Purchasing Manager approval.
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 Where there is an agreement or contract (i.e. lubricants, chemicals, paints, etc.), the Purchaser
may place a direct order based on the price list available. However, this does not prevent
circulating "Request for Quotations" to other suppliers – especially in remote or costly ports.
 In emergency cases, the responsible Manager of each department, may authorize the
following:
o To place the order by using the first available offer from an approved or non-approved
supplier.
o To place direct order based on previous offers or past experience.
Purchase orders clearly describe all items ordered and may also provide forwarding instructions.
Purchase Orders are placed using either the specific Purchasing Software.
The Purchase order is sent to the selected supplier and copies are kept electronically.
Once an order is placed, the case is monitored for readiness. When the Purchaser or the responsible
Manager determines that the Vessel will call on a convenient port, the Purchaser may initiate the
forwarding process, supplying the Vessel with single or multiple orders.
It is Company Policy to use Bulk Ordering, reduced Packaging Volume as far as practicable.
2.3.4 Exceptions to Usual Purchase Order Procedures

In cases of great urgency, the Master, Chief Engineer or Company Representative onboard can also
initiate an order.
 An order can be placed by the Purchaser based on a requisition from the Master, Chief
Engineer or responsible Officer.
 An order can be placed by the Purchaser without a requisition from the Vessel. In such cases
the supplier will be instructed to hand a copy of Purchaser's order to the Master, or Vessel will
be notified of the order by e-mail by the Purchaser.
 An order can be placed by the Master or Chief Engineer, who can purchase needed goods
locally, following approval from authorized personnel.
 An order can be placed by attending shore personnel, who are authorized to order any urgently
required goods.
The Purchaser will be notified of any such orders.
o In this case, the Vessel is obliged to send a requisition to the office noting all
requested/received items and supplier to revert with prices, thereby allowing the
Purchaser to update his records accordingly.
2.4 FORWARDING GOODS TO THE VESSELS

This section describes the procedure for forwarding ordered goods to the Vessels.
A consolidated forwarding policy for stores and spares in order to minimize the total cost and
environmental impact has been adapted by the Purchasing Department.
The forwarding procedure is usually initiated based on the following factors:
 Vessel's need for specific order;
 Convenience in port;
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Suppliers are requested to ensure that all ordered goods are packed as reduced as possible and
packaging material is from environmental friendly, recycles or re-used materials (if/when applicable).
Moreover, an Approved Supplier List is being monitored and updated with all available ISO Standard
Certifications such as ISO 14001, ISO 9001, ISO 45001, ISO 50001 etc.
2.4.1 Direct Orders / Forwarding Enquiries

A. When the need to send one or more orders to a port is recognized, the Purchaser informs the Fleet
and the Forwarding Department of all available orders, their location and packing.
B. The Company may exclusively use the services of specific forwarders at various ports.
However, in cases where a heavy item is involved, it is advisable (but not compulsory) to seek
offers from other forwarders – by circulating "Forwarding Enquiries".
C. Forwarding Enquiries and/or Direct Orders are given a unique case number utilizing the formula
XX-YYY/ZZ, where:
 XX = Two digits representing the Vessel's initials
 YYY = Three digits representing the sequential number starting from 999 each
New Year, and continued in a descending order until the end of the year
 ZZ = Two digits representing the current calendar year
2.4.2 Forwarding Procedures

A. Prior to the Vessel's arrival in port, the Purchaser must inform the Master/Chief Engineer by
analytical message, about supplies arrangement to be affected.
B. Orders are sent to the Forwarders and/or Vessel's Agents or to the local representative of the
forwarders, who will then coordinate delivery onboard.
The Forwarding Coordinator must liaise with agents and forwarders and investigate cost of inland
transportation/launch service. The same applies for delivery of any goods purchased locally.
C. The Forwarding Coordinator authorizes the forwarder or the agents to arrange delivery onboard.
The forwarder sends a confirmation message to the Purchaser or the Forwarding Coordinator,
confirming all in order and giving relevant shipping details.
2.4.3 Forwarding Goods to the Vessels for IHM compliance requirements

In order to maintain Vessels’ Inventory of Hazardous Materials (IHM) certification, company follows
specific procedures to restrict hazards being brought on board ships after the initial compilation of
the IHM.
If any items recorded in the IHM are added to, removed or replaced, or the hull coating is renewed,
the IHM is updated using information obtained from Material Declarations (MD) and Supplier
Declarations of Conformity (SDoC) forms.
These MD and SDoC are collected for every item brought on board the ship using the supporting
documentation for details of templates provided by Class. (Included in the Appendix of IHM
Manual).
Company’s policy covers the hazards listed in both Appendix I and II of Hong Kong Convention and
Annex I and II of EU Regulation on Ship Recycling.
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Suppliers are requested to ensure that any items supplied to the ship are accompanied by a completed
MD and SDoC as per the guidance of up to date IMO Resolution MEPC.269(68) which replaced
MEPC.197(62) in order to cover Hong Kong Convention, the EMSA best practice guidance &
Regulation (EU) no 1257/2013 on Ship Recycling.
Reference is made to ship-specific Inventory of Hazardous Materials, EMS / SECTION10/ 2.3.4
Excluding materials and 2.4 Hazardous materials which cannot be purchased or brought onto the ship.
2.5 VERIFICATION OF SUPPLIED GOODS

This section describes the steps taken for verifying goods supplied onboard.
2.5.1 Delivery Onboard

When ordered spares or stores are delivered onboard, the consignments must be checked against the
Purchase Requisition (the requisitions must be modified according to the order finally placed, as
advised from the Office).
A. When the goods are delivered onboard, the responsible Officer must check to ensure that delivered
goods are of good quality, correct quantity, meet the specified requirements and match the
delivery note issued by the supplier.
B. The Delivery receipt must be signed by the officer in charge, stamped and signed by the Master.
C. Confirmation of satisfactory receipt of goods is reported to the office by using the “Master's Port
Report", which must be sent by e-mail to the office not later that two days from delivery date of
goods onboard. Master's Port Reports are filed in ERP.
D. Captains, upon receipt of goods on-board the Vessel, are instructed to provide their feedback to
the Company, relevant to the quality of suppliers’ environmental packaging of goods (please refer
to Supplier Evaluation Check List SF/PUR/603) and issue deliveries in the ERP.
When several deliveries arrive at the same time, the following priorities must apply:
A. Deliveries from Local Suppliers must be counted and checked for breakage or damages first, in
order to return incorrect or broken goods before the ship sails.
B. All other parcels must be checked for damage. Parcels with visible damage must be opened and
checked for quantity, specification and damage.
C. Missing, incorrect or damaged items must be reported to the Office the soonest possible.
D. The Office must contact the supplier and re-order replacement.
E. In case the delivery is totally unacceptable, this must be formally reported to the Office, in order
the Supplier to be re-evaluated.
F. The remaining supplies must be checked for quantity, specification and damage. Missing,
incorrect or damaged items must be reported to the Office. The Office must contact the supplier
and re-order a replacement.
The Company ensures that equipment, installations and materials are safe for use by workers.
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Upon delivery and installation and prior to confirmation of acceptance, the Master and the responsible
officer onboard must verify that:
A. Equipment is delivered according to specification and is tested to ensure it works as intended;
B. Installations are commissioned to ensure they function as designed;
C. Materials are delivered according to their specifications;
D. Any usage requirements, precautions or other protective measures are communicated and made
available.
2.5.2 Confirmation of orders received

The Master must confirm in writing the safe and complete delivery of the items ordered, in the
Master’s Port Report, which must be sent my e-mail, latest within two (2) days after the Vessel has
left the port.
If items are supplied, which include Asbestos, then they must be immediately returned (not
accepted onboard) and the Office must be notified immediately.
When an order has been placed for local supplies and paid Cash by the Master, a relevant message,
together with Supplier’s Invoice and Delivery Note must be sent to the Office.
2.5.3 Reporting Quality of Goods Received

Following each individual supply, the Master must carefully check and report the quality of goods
received.
This is done through a “Suppliers Evaluation Checklist”, which is incorporated in the Master’s Port
Report, and which includes the following items to be considered for every supply:
A. Prompt Delivery.
B. Packaging (Good protection of supplies).
C. Environmental Friendly Packaging.
D. Quality of General Items Supplied.
E. Quality of the Technical Items Supplied.
F. Quality of Provisions Supplied.
G. Honesty.
H. Diligence.
I. Quick Response to additional “Last Minute” Requisitions.
J. Expiration Date of dry provisions. ( at least four (4) months from the date of supply)
2.5.4 Discrepancies in Delivered Goods

In the event of any shortages, omissions, poor quality, damages, late deliveries or any unsatisfactory
receipt of goods, the Vessel must immediately advise the responsible Purchaser.
This will enable the Purchaser to take necessary action by arranging for the return of the unsuitable
goods and their replacement.
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2.6 CHECKING / APPROVAL OF INVOICES

This section describes how invoices are checked / approved.
2.6.1 Registering Invoices

A. Invoices from all suppliers are first given to the Accounting Department for registering into their
Accounting Program.
B. The invoices are then handed over the Purchasing Department for checking / approval.
2.6.2 Checking / Approving Invoices

A. The Invoice Controller will check the invoice against the Purchase Order, any delivery messages,
and the Master's Port Report.
B. If the invoice is in accordance with above-mentioned, then invoice is then processed and finalized.
The invoice is entered into the specific Purchasing Software.
C. The invoice is approved and submitted electronically through the ERP to the Accounting
Department for payment.
2.6.3 Discrepancies
If any discrepancies/mistakes are identified, the designated person from the purchasing department
works to resolves the matter with the supplier.
2.7 LANDED GOODS

This section describes the process for Vessel's landed goods, keeping track of, and returning the goods
to the Vessel.
2.7.1 Landing of Goods

The Vessel may be instructed by the Company to land various items for the following reasons, which
are relevant to the Purchasing Department.
 To be returned in case goods on exchange basis are purchased, including Gas Cylinders.
 For repairs.
 As samples
 In case of wrong supply, where return to the Supplier is required.
 Landed in case of a vessel’s sale, and have to be returned to the Office, or distributed to other
Fleet Vessels.
The Vessel must fill-in the relevant form and send it to the Office immediately upon landing, to enable
the Purchaser to follow-up the return of items landed and to coordinate the involved parties for their
final destination.
2.7.2 Dispatch Report for Landed Goods

When items are landed in any of the above circumstances, then the “Landed Goods” Report must be
issued by the Vessel and kept temporarily in the files of the Chief Engineer or Chief Officer
(depending on the case) for follow-up.
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A copy must be sent to the Office to the attention of the Purchasing Department for further follow-
up. The central filing of all these reports is in the Master’s File.
This procedure and reporting is very important since it eliminates the danger of forgetting goods in
various warehouses or workshops all over the world, and it also helps in organizing the re-delivery.
2.8 SPARES MANAGEMENT ONBOARD AND INVENTORIES
2.8.1 Maintenance of Spares

Spares must always be maintained in first class condition, ready for use at very short notice.
Where machined or special surfaces are coated with a preservative or similar protective coating, these
must be inspected regularly for deterioration and the coatings made good as necessary.
Paint must not be used as preservative on spare gear.
Spares to be kept on deck/engine store rooms or in other designated positions.
Boxes containing spares for major equipment to be properly tagged/marked for easy identification
purposes and must be in line with the identification on spare parts inventory book.
Boxes containing spares and spares out of the boxes must be properly secured against movement.
The Chief Engineer or the appointed Second Engineer are the ones who authorize the
use/consumption of onboard spares.
The quantities of spares available onboard are monitored via the electronic PMS.
The relevant stocks are updated automatically for the new spares received onboard by the Chief
Engineer or Office, as applicable.
For spares consumed for shipboard maintenance activities, stocks are updated by the Chief Engineer.
Spares consumed must be declared in relevant PMS jobs in order inventory to be automatically
updated.
Necessary spares for the planned maintenance of Vessel’s equipment must be promptly requested
form Vessel (utilizing the respective module of e-PMS), allowing timely delivery before respective
job becomes overdue.
3 RECORDS
 Spares Requisition List PRO/PRO 8/ OFF/PUR/601
 Stores Requisition List PRO/PRO 8/ OFF/PUR/601A
 Request for Quotation PRO/PRO 8/ OFF/PUR/602
 Purchase Order PRO/PRO 8/ OFF/PUR/603
 Evaluation Form PRO/PRO 8/ OFF/PUR/607
 Stores Evaluation Form PRO/PRO 8/ OFF/PUR/613
 Victualling Report PRO/PRO 8/ OFF/PUR/614
 Spares Requisition List PRO/PRO 8/ SF/PUR/601
 Stores Requisition List PRO/PRO 8/ SF/PUR/601A
 Protocol of Condemned Provision PRO/PRO 8/ SF/PUR/602
 Master's Port Report PRO/PRO 8/ SF/PUR/603
 Spares and Stores needing Class Certificates POSTER 21
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(002) Revision: 09
SUPPLIERS AND SUBCONTRACTORS Eff. Date: 30/09/2022
Contents
1. PURPOSE ..................................................................................................................................2
2. PROCEDURE ............................................................................................................................3
2.1 Responsibilities ....................................................................................................................3
2.2 Contractual Requirements .......................................................................................................3
2.3 Evaluation Criteria ..................................................................................................................4
2.4 Registering / Categorizing. .....................................................................................................5
2.5 Approval of Suppliers / Subcontractors ................................................................................5
2.6 Upgrading Suppliers / Subcontractors ....................................................................................6
2.7 Downgrading Suppliers / Subcontractors ...............................................................................6
2.8 Expelling Suppliers / Subcontractors ......................................................................................6
2.9 Suppliers’ and Contractors’ ISO Certificates .........................................................................6
2.10 Suppliers’ / Subcontractors’ File .........................................................................................6
2.11 Monitoring of Suppliers and Subcontractors .......................................................................7
2.12 Company Audits of Contractors / Subcontractors. ..............................................................8
3. RECORDS .................................................................................................................................8
Page 1 of 9
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1. PURPOSE
This procedure describes the process followed by the Company’s Office Departments to:
 Register.
 Categorize.
 Monitor.
 Evaluate.
the Suppliers and Subcontractors, in order to ensure that they meet the required Quality criteria to
accomplish the Company’s Objectives and Targets.
The term “SERVICES” includes:
 Subcontracted Labor,
 Agents,
 Surveyors or other Professionals,
engaged for their Specialized Services e.g. Technical, Financial and Human resources etc.
For Suppliers and Subcontractors involved in Services such as those provided by Manning Agents,
Port Agents etc, this procedure will be implemented in conjunction with other parts of the Integrated
Management System (IMS), which are governed by the responsible Departments assigned there-in.
The assignment of activities to Contractors does not eliminate the Company's responsibility for the
full implementation of the procedures of the IMS i.e
 Quality Management System,
 Environmental Management System,
 Energy Management System,
 Occupational Health and Safety Management System and
 Information Security Management System.
For this reason, the Company achieves coordination of its Services External Providers' activities
through the use of Contracts that clearly define the Responsibilities of the Parties involved.
Focusing on aspects related to the IMS, the Company takes the following actions:
 Identifies and reports hazards affecting both / either Company's Employees and Services
External Providers.
 Controls Workers’ access to Hazardous or Restricted / Sensitive areas.
 Provides familiarization, as well as training, which address the above documented operations’
aspects.
 Implements relevant procedures of the Integrated Management System.
 Adheres to the Legal and Regulatory framework, applicable per case.
 Checks, evaluates and verifies the capability of the Services External Providers to perform the
assigned task(s), by reviewing:
o Qualifications,
o Competency records,
o Relevant previous experience
and carries out preparatory Work Planning and Tool Box meetings, before the
commencement of the agreed tasks/work.
 Agrees on the Contingency Plan and the Emergency Procedures to be followed by the Parties
involved, in case of any accident / incident / emergency.
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(002) Revision: 09
2. PROCEDURE
All Company Employees, arranging and receiving goods as well as 3rd Parties are responsible to
report deficiencies with respect to the Terms, Conditions and Specifications of the agreed Project
Scope / Service Agreement e.g. defective products, delays in delivery, bad and / or inadequate
services etc.
The assigned Office Departments’ responsible Employees should evaluate these reports and
propose remedial actions, as applicable per case, in order to ensure that the agreed Services /
Product / Project Scope are implemented.
Based on the final outcome of the overall review of such reports, and the necessary remedial
actions, the assigned Office Departments’ responsible employees must evaluate and categorize the
Suppliers and Subcontractors with whom the Company is cooperating.
2.1 RESPONSIBILITIES
The responsibilities for the review of the Suppliers and Sub-Contractors are as follows:
The DPA : is responsible to ensure that a Review of the Suppliers and

Contractors, relevant to Quality issues is carried out.
S&Q Manager : is responsible to carry-out the review of Occupational Safety &

Health issues.
Environmental/Energy : is responsible to carry-out the review for issues related to
Performance Manager Environmental & Energy Efficiency issues.
The ICT Development Head : is responsible to define the information security requirements
that will be agreed with all Suppliers and Subcontractors, to
carry out the Annual Review of the ICT Contractors & Suppliers
and advice all other Department Managers regarding their own
Departmental Contractors’ Information Security compliance.
In the case of personal data being involved, the privacy and data
protection requirements set out by GPDR and applicable
national laws, rules and regulations must be also taken into
account.
All other Department : are responsible to carry-out a review of the Suppliers /
Managers Subcontractors under their responsibility.
2.2 CONTRACTUAL REQUIREMENTS

Before any Supplier, Service Provider or Subcontractor is employed, the relevant Company-Specific
Form OFF/ICT/010-“Non-Disclosure and Confidentiality Agreement (““NDA””)" should be
counter-signed in order to ascertain Data Protection and Information Security responsibilities of both
Parties involved, including but not limited to the protection of Personal and Sensitive Personal data.
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The Counterparties responsible to sign the ““NDA”” Form are:

o The Company Legal Representative and
o The Provider’s Responsible counterpart (nominated in writing).
When the ““NDA”” is signed by the Parties involved (as stated above), it should be forwarded to
the ICT Development Head (who is the “NDA” Template Owner), as evidence of compliance and
verification during Internal & External Audits.
After the mutual agreement on the Services has been finalized ( i.e having reached agreement on the
supply of Product and the Project Scope and having signed the “NDA” Agreement) a Contract must
be signed between the involved Parties, detailing the Scope and the Parameters of the Service, Product
or Project to be provided.
This contract should be reviewed by the ICT Development Head to ensure compliance with the ISO
27001:2013 requirements, as per Procedure ISMS-PROC 05F of the ISMS Manual Information
Security Management System Manual) and must be signed by the authorized counter-parts i.e
o the Company Legal Representative and
o the Provider’s Responsible counterpart (nominated in writing).
2.3 EVALUATION CRITERIA

The Evaluation criteria used to categorize the Suppliers and Subcontractors are as follows:
 Ability to consistently supply Products and Services of the specifications and standards required
by the Company, in compliance with ISO 9001 quality requirements.
 Dependability in meeting agreed Delivery times, of the agreed Services, Products & Projects.
 Dependability in adequately forwarding / delivering the Products and Services, in compliance
with the agreed Contractual Terms and Company instructions.
 Ability to consistently supply Environmental-Friendly and Energy- Efficient Products and
Services, in compliance with ISO14001 & ISO 50001 Standards.
 Ability to consistently supply services compliant with Occupational, Health and Safety Standards
as per ISO 45001 and Company Requirements
 Compliance with Company Information Security Standards documented in the Company’s ISO-
27001:2013 Policies, Processes & Procedures and adhering to the relevant Scope, Objectives &
Targets.
 Ability to efficiently facilitate the project deliverable and services as well as address associated
problems which they are invited to solve.
The Company coordinates the service / project planning and procurement procedure with its
Providers, in order to identify underlying hazards and to assess and control associated Occupational
Health, Safety, Quality, Environmental, Energy Efficiency & Information Security risks arising from
the Contractors’ activities and operations that impact:
 The Company;
 The Contractors' Workers;
 Other interested parties in the workplace.
In all cases above, hazards’ identification, impact and remedial actions should always take into
consideration the following factors for and from all parties involved:
 People.
 Assets being both standard physical as well as Information / Data.
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 Environment – Energy Efficiency.

 Company’s Reputation.
2.4 REGISTERING / CATEGORIZING.

All Suppliers and Subcontractors (including Service sub-contractors) must be registered in an
“Approved Suppliers’ / Subcontractors’ List”, under different categories, depending on their
performance record.
Categories are as follows:

A. Category "A" includes:
 Suppliers / Subcontractors with long-standing cooperation with the Company.
 Equipment Manufacturers and their Representative Offices are automatically entered in
Category “A”– unless specific reasons arise, such as unprofessionalism, delays etc.
B. Category "B" includes:

 Suppliers / Subcontractors who enter our list as "first-time" cooperation and will be under
observation for a period of six (6) months, or until three (3) orders are placed. This period
can be prolonged to one (1) year, if necessary.
C. Category "C" includes:

 Suppliers / Subcontractors previously listed in Categories “A” or “B”, but due to repeatedly
poor service or cooperation are now "demoted" to Category “C”.
 Suppliers / Subcontractors in Category “C” may be used if the case / need is very urgent.
Category "F" (NON-APPROVED) includes:

 Suppliers / Subcontractors who repeatedly provide poor service, resulting in damage / loss to
the Company (i.e. delaying Vessel's schedule, etc.).
 Such Suppliers are expelled from the Approved Suppliers / Subcontractors List and are
downgraded to Category “F” – meaning that they are NON-APPROVED and are barred from
future cooperation with the Company.
 Supporting evidence / reasons for downgrading a Supplier to Category “F” are appropriately
filed in the Filing System of the relevant Department.
 If “Non-Approved” Suppliers have to be used, in urgent cases, when there is no other option,
then a relevant Risk Assessment must be carried out prior to any appointment.
2.5 APPROVAL OF SUPPLIERS / SUBCONTRACTORS

Once a Supplier / Subcontractor is proposed, the relevant Department Manager / Deputy Manager
must give his approval. Records of such approval will be kept in the relevant files of each Department.
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2.6 UPGRADING SUPPLIERS / SUBCONTRACTORS

Following satisfactory service, a Supplier / Subcontractor might be upgraded.
The upgrade will be effected upon approval from the relevant Department Manager / Deputy
Manager. All relevant documentation duly signed by the Department Manager / Deputy Manager,
will be filed in the Department’s Filing System.
2.7 DOWNGRADING SUPPLIERS / SUBCONTRACTORS

In case of repeated poor service, the Supplier / Subcontractor might be downgraded, after the
approval of the Department Manager / Deputy Manager. The relevant documentation and / or notes,
duly signed by the relevant Department’s Manager / Deputy Manager, will be filed in the
Department’s Filing System.
In case of any malfunction occurring soon after a service has been conducted a re-evaluation of this
supplier must be made and in case it is revealed that the malfunction has occurred due to Service
Provider negligence or lack of expertise, then a downgrading must be considered.
2.8 EXPELLING SUPPLIERS / SUBCONTRACTORS

In the case of repeated poor service, resulting in damage / loss to the Company, the Supplier /
Subcontractor may be expelled from the Approved Suppliers / Subcontractors List and downgraded
to "Category F" - meaning NON-APPROVED - and will be barred from future cooperation with the
Company. Supporting evidence / reasons for downgrading a Supplier/Subcontractor to Category “F”
are filed in the relevant Department’s Files.
2.9 SUPPLIERS’ AND CONTRACTORS’ ISO CERTIFICATES

The Company has established a procedure to request and collect the ISO Certificates of its Suppliers
/ Subcontractors. Copies are kept in the relevant Departments’ Files. The Company’s preference is to
appoint Suppliers/ Subcontractors who are ISO Certified.
The following indicative ISO Certificates will be considered as Suppliers’ / Contractors’ Evaluation
add-on assets:
 ISO 9001:2015
 ISO 14001:2015
 ISO 27001:2013
 ISO 50001:2018
 ISO 45001:2018
2.10 SUPPLIERS’ / SUBCONTRACTORS’ FILE

The above-mentioned list of Suppliers and related information can be found in the relevant
Department’s Filing System. The file includes the following:
 Categorized List of Suppliers / Subcontractors.
 ISO Certificates.
 Approval of New Suppliers / Subcontractors.
 Upgraded Suppliers / Subcontractors.
 Downgraded Suppliers / Subcontractors.
 Non-Approved Suppliers / Subcontractors.
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2.11 MONITORING OF SUPPLIERS AND SUBCONTRACTORS

The following Suppliers’ / Subcontractors Monitoring scheme applies per case:
1. Consumables, Navigation and Deck Equipment / Services / Supplies.
Following the receipt of services / goods on board a Vessel, the Purchase Order / Report will be
returned to the Company's Office by the Supplier, with the invoice, for payment. When received,
the responsible staff will carry out the examination. Any deficiency / complaint noted will be
recorded.
2. Machinery, Engine Room and Deck Auxiliary Services / Supplies.

When the delivery of Services / Goods is completed, the relevant Order / Confirmation Form /
Report is returned from the Vessel to the Office. The person checking for reconciliation will note
any deficiencies / complaints.
3. Information Security Service & Systems Providers.

Roles & Responsibilities as well as processes applicable are documented in detail in the relevant
Information Security Management System (ISMS – 015) Manual Procedures about New System
Acquisition, Hardware Acquisition and Software Upgrade:
 ISMS-PROC 05F-ICT Systems Lifecycle (Acquisition - Termination).
 ISMS- PROC 05G-Hardware Life Cycle Management Procedure.
 ISMS-PROC 05E-Software Management Procedure.
4. Onboard Contractors e.g. Riding Squads / Service Technicians / Repair Teams.

When they complete the work, the Master and / or Chief Engineer will submit to the Office a
Report in which the effectiveness of the job and the non-conformances (if any) will be noted.
Deficiencies / complaints will be recorded.
During the onboard Contractors’ monitoring and evaluation process, the status of the following
aspects of their professional conduct should be documented as per the Relevant Company form
SF/CRW/506C – “Contractor’s Safety Familiarization Record”:
 Occupational Health & Safety.
 Quality Management.
 Environmental & Energy Efficiency.
 Information Security Standards’ Compliance.
This form is divided into three (3) Sections:

o Familiarization on Occupation Health, Safety, Environmental, Energy Efficiency, Security
and Information Security issues.
o Contractor’s Evaluation Report on Vessel and Crew.
o Master’s Evaluation of Contractor’s Personnel.
The Form SF/CRW/506C – “Contractor’s Safety Familiarization Record” is used for:

 Ridings Teams,
 Repair Teams and
 Shore Service Technicians.
It is not used for Agents, Surveyors, Vetting Inspectors, Auditors, PSC / USCG Inspectors etc.
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5. Manning Agents are controlled as follows.

Crewing Manager will evaluate the efficiency reports of crewmembers as well as relevant reports
from the Masters and any non-conformance will be recorded. The Manning Agents must be
audited on an Annual basis using the relevant Forms OFF/CRW/510-“Company Audit and
Review of Manning Agents”.
6. Port Agents are controlled as follows.
The Master of each Vessel will inform the Operations Department about the performance of every
Port Agent.
7. Other Services are controlled as follows:
The responsible Department Manager will evaluate the efficiency and effectiveness of the offered
service and any non-conformance will be recorded.
2.12 COMPANY AUDITS OF CONTRACTORS / SUBCONTRACTORS.

The Company should conduct Audits of the Contractors and Subcontractors with which it cooperates.
The Audits should be carried out by properly qualified personnel of the Company Departments, who
are responsible for the appointment and monitoring of the Contractors / Subcontractors as per
Paragraph 2.1 above, using dedicated Audit Forms which have been developed for this purpose.
As a minimum, the Audit Periodicity is three (3) years.

Audits may be carried out sooner, if deemed necessary.
The criteria for selecting the Contractors and Subcontractors who will be audited are, but not
limited to, the following:
 Incidents / Accidents with one of the Root Causes being their products / services.
 Not timely delivery of critical products or services.
 Continuous delivery of products / services of low quality or other than ordered.
 Criticality of Services / Products.
The schedule of the Audits of Contractors, must be presented during the Management Review
Meetings, also stating the reason for the selection of the Contractors who will be audited. The results
of the Contractors’ Audits must also be presented during the Management Review Meetings.
3. RECORDS
 Suppliers / Subcontractors Evaluation PRO/PRO 9/ OFF/PUR/605
 Stores Supplier Evaluation Form PRO/PRO 9/ OFF/PUR/612
 Services / Spares / Stores Supplier / Subcontractor Approval PRO/PRO 9/ OFF/PUR/616
 Contractors Safety Familiarization PRO/PRO 23/ SF/CRW/506C
 Company Audit and Review of Manning Agents PRO/PRO 22/ SF/CRW/510
 Suppliers Evaluation PRO/PRO 9/ OFF/OPS/304
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Contractors’ Audit Checklists

 Audit Checklist for D&A Screening Companies PRO/PRO 9/ OFF/SAQ/428
 Periodic Audit Checklist –Port Agents PRO/PRO 9/ OFF/OPS/308
 Shipyard Evaluation PRO/PRO 9/ OFF/TEC/107
 Audit Checklist –Mooring Equip. Suppliers PRO/PRO 9/ OFF/PUR/617A
 Audit Checklist –Vessels’ Catering Provider PRO/PRO 9/ OFF/PUR/617B
 Audit Checklist –Spares Suppliers PRO/PRO 9/ OFF/PUR/617C
 Training Providers’ Audit Checklist PRO/PRO 9/ OFF/TRN/701
 Screening of Private Maritime Security Companies PRO/PRO 9/ OFF/SEC/904
 Information Security Contractors’ Audit Checklist PRO/PRO 9/ OFF/ICT/009
Page 9 of 9
PROCEDURE 10
Manual
(002) Revision: 08
INTERNAL AUDITS Eff. Date: 30/04/2022
Contents
1. PURPOSE .................................................................................................................................. 2
2. PROCEDURE ............................................................................................................................ 2
2.1 Audit Schedules ...................................................................................................................... 2
2.1.1 Timing of Audits .........................................................................................................................................2
2.1.2 Records of Audit Schedules ........................................................................................................................4
2.1.3 Updating the Audit Schedules .....................................................................................................................5
2.1.4 Changes in the Audit Schedules ..................................................................................................................5
2.1.5 Review of the Audit Schedules by Management .........................................................................................5
2.2 Internal Audits – General ....................................................................................................... 5
2.2.1 Internal Audit Announcements....................................................................................................................5
2.2.2 Unannounced Internal Audits ......................................................................................................................6
2.2.3 Appointment of Internal Auditors ...............................................................................................................6
2.2.4 Competency standards for Internal Auditors ...............................................................................................7
2.2.5 Internal Audit Purpose and Scope ...............................................................................................................7
2.2.6 Preparation of Internal Audits .....................................................................................................................7
2.2.7 Internal Audit Set ........................................................................................................................................7
2.2.8 Internal Audit Reference Numbers ..............................................................................................................8
2.2.9 Classification of Audit Results ....................................................................................................................8
2.2.10 Non Conformity Notes ................................................................................................................................8
2.2.11 Deficiencies List –Internal Audit ................................................................................................................9
2.2.12 Distribution of Internal Audit Reports.........................................................................................................9
2.2.13 Records of the Internal Audit Reports .......................................................................................................10
2.2.14 Processing of the Internal Audit Reports by S&Q.....................................................................................10
2.2.15 Analysis and Distribution of Experiences throughout the Company.........................................................10
2.2.16 Discussion of the Results of Internal & External Audits during the Management Review Meetings .......11
2.3 Internal Audits – Office ........................................................................................................ 11
2.3.1 Internal Audit Sets for Office Departments ...............................................................................................11
2.3.2 Scope of the ISM/ISO Internal Office Audit .............................................................................................12
2.3.3 Conducting the Internal Office Audits ......................................................................................................12
2.3.4 Processing of the Internal Office Audits Reports by S&Q ........................................................................12
2.3.5 Closing the Non Conformities and Observations ......................................................................................13
2.4 Internal Audits – Vessels ...................................................................................................... 13
2.4.1 Internal Audit Checklists ...........................................................................................................................14
2.4.2 Scope of the Partial Vessel Audit ..............................................................................................................14
2.4.3 Conducting the Internal Vessel Audits ......................................................................................................14
2.4.4 Processing of the Internal Vessel Audit Reports by S&Q .........................................................................15
2.4.5 Closing the Non Conformities and Observations ......................................................................................15
2.5 Master’s Navigational Audits ............................................................................................... 16
2.6 Navigational, Mooring and Cargo Audits by Marine Superintendents................................ 16
3. RECORDS ............................................................................................................................... 17
Page 1 of 17
PROCEDURE 10
Manual
(002) Revision: 08
1. PURPOSE
This procedure defines, the general steps necessary to conduct management system Internal Audits.
2. PROCEDURE
2.1 AUDIT SCHEDULES

This section details the arrangements made in order to draw the schedules for the Internal and
External Audits for the current year.
The Schedule of the Audits is the responsibility of the S&Q Department.
Audit Schedules to the DPA for approval.
However, for External or Internal Audits which are due for the First Quarter of the new year, a
planning quite ahead, must be made and be submitted separately.
The Audits include two (2) categories:

A. Internal Audits, subdivided into:
 Office Audits
 Vessel Audits
B. External Audits, subdivided into:
 Office Audits
 Vessel Audits
The Audit Schedules must cover all the above Audit categories.
2.1.1 Timing of Audits

The Schedule of Internal and External Audits must be drawn, based on their due date.
 Internal Office Audits
The Internal Office Audits must be conducted, as a minimum, every twelve (12) months from
the date of the previous Audit and definitely before the Annual Verification Audit, which is
conducted by the RO (Recognized Organization).
The Audit of the Manning Agent(s) is included in this schedule.
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PROCEDURE 10
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 Internal Vessel Audits
As per the ISM Code, all Company Vessels must be audited at intervals not exceeding twelve (12)
months to verify whether the safety and pollution prevention activities comply with the IMS.
In exceptional circumstances, the intervals may be exceeded by not more than three (3) months.
The acceptability of any exceptional circumstances will be considered by the Administrator on a
case-by-case basis prior to the postponement of an Internal Audit.
All requests for an extension of the 12-months interval must be presented to the Administrator, well
in advance, accompanied by documentation explaining the reasons for which the Internal Audit
cannot be conducted within the required timeframe.
This documentation and the Administrator’s authorization for postponement must be presented to the
RO for verification at the annual Company audit and relevant Shipboard audit.
In all cases, there shall not be less than five (5) internal audits of the Company or any ship during the
five (5) year validity of certification.
The Company provides ISM /ISPS/MLC 2006 Auditor’s Training to its Senior Masters.
This enables the Masters to carry out an Internal Audit, onboard the Vessel they are to join,
before assuming command.
Such Audits may be planned, in exceptional circumstances.
(The Training of Masters as IMS Auditors is optional, not mandatory)
When a Vessel is newly acquired, the ISM/ISPS/MLC Internal Audits must be scheduled after a
period of three (3) full months under Company Management.
During the Internal Audit, documentation for at least three (3) Months must be available, enabling
the Auditor to make a full and accurate assessment of the IMS implementation onboard.
The same applies for the Internal Vessel Audits referring to other parts of the IMS Management
System i.e. ISO etc, which must be also conducted, as a minimum every twelve (12) months from
the date of the previous Audit.
If, within a specific year, the Vessel is subject to an External Audit (Initial, Intermediate Verification,
Renewal), then the Internal Audit must preferably be conducted before the External Audit, if
possible.
 External Office Audits
All the Office Departments are subject to an Annual Verification Audit, conducted by the RO
(Recognized Organization).
The date of the External Office Audit, must be arranged, within three (3) months before or after
the anniversary date and definitely before the expiration date of the DOC(s).
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PROCEDURE 10
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 External Vessel Audits

All the Vessels are subject to External Audits according to the requirements of the ISM, ISPS
Codes and MLC 2006 as follows:
o Interim Audit: On Acquisition of a new Vessel.
o Initial Audit: Before the expiration date of the Interim SMC, ISSC & MLC 2006– usually
within six (6) months from the Interim Audit date.
o Intermediate Verification Audit: Between the second and the third anniversary year, from
the issue date of the SMC, ISSC and MLC 2006, during which the relevant Certificates are
endorsed following satisfactory inspection.
o Renewal Audit: Before the expiration of the Long Term SMC , ISSC and MLC 2006
five (5) years.
The Audit Planning must include all the Internal Office and Vessel Audits which are to be
conducted within the current year.
If External Audits must be conducted during the current year, these must also be included in the
Audit Schedule.
Only the Audits for the possible acquisition of new Vessels cannot be included, since specific
information is not available.
When such information is made known, the Audit Schedule must be updated, re-issued and re-
circulated.
A copy of the revised Audit Schedule, including the Audit plan of the newly acquired Vessel must
be presented to the RO Auditor, during the Interim Audit, on acquisition.
Failure to schedule and conduct the annual or intermediate verification is considered as a violation
of SOLAS –Chapter IX requirements and the DOC and/or SMC and MLC 2006 Certificates may be
suspended or revoked.
At times, the Company may wish to Audit specific elements of the IMS independently, in which
case, the purpose and the scope of the Audit must be clearly defined (i.e. Internal Navigational
Audit only). Such Audits are exceptional and do not replace the full scale Audits.
2.1.2 Records of Audit Schedules

The Audit Schedules are submitted, using two (2) Forms:
 OFF/SAQ/413-Audits Schedule – Office.
 OFF/SAQ/414-Audits Schedule – Vessels.
The two above Audit Schedules must be submitted by the S&Q Manager to the DPA for approval.
When they are approved, both the Office and the Shipboard Personnel are notified in writing (by e-
mail) with copies of the Audit schedules attached.
Both Audit Schedules (Vessel and Office) are readily available for review by all Office Personnel,
as they are electronically filed in the Office Data-Base “Archive”.
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PROCEDURE 10
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2.1.3 Updating the Audit Schedules

During the year, and as Audits are being conducted, the S&Q Department must update the
electronic records of the Audit Schedules found in “Archive”.
2.1.4 Changes in the Audit Schedules

Due to various reasons, the Audit Schedules may be required to change. Any change must be
discussed and agreed between the S&Q Manager and the DPA.
The Office Departments and the Vessels must be immediately notified of the changes. The
Company may also conduct Internal Audits which are unscheduled and unannounced.
2.1.5 Review of the Audit Schedules by Management

The DPA makes ‘spot checks” (by checking in the Archive Data-base) to ensure that the Audits are
conducted in line with the Audit Schedule.
Where significant delays occur, the issue is discussed during the Weekly Operational Meetings and
during the quarterly Management Review Meeting.
If required, appropriate resources are assigned to bring the Audits back into line with the Audit
Schedule.
2.2 INTERNAL AUDITS – GENERAL

This section defines, the general steps necessary to conduct IMS Management System Internal
Audits.
For brief reference, the above Audits covering all applicable Standards and Codes will be referred
to as “Internal Audit” throughout this Procedure.
For all Audits, (full scale or partial), the following Audit principles must apply:
A. The Internal Audit is a tool to assess the IMS and not a kind of Office or Shipboard inspection
designed to allocate blame if something is identified as being wrong.
B. The results of the Audits are fed back into the IMS for Corrective/Preventive action and the
experience is distributed throughout the Company.
C. The Audits are conducted by Personnel who, at the time of the Audit, are independent of the
area being audited.
2.2.1 Internal Audit Announcements

Internal Audit Announcements of the expected Audit date must be made to all Office Departments
and Vessels. They must always be in writing.
The first announcement must be made within the month of January of each year, after the approval
of the Audit Schedules.
Pre-announcements may be made periodically, advising the exact month in which the Internal Audit
is expected.
The expected Audit date must be agreed, taking into consideration the operational needs in order to
prevent any possible disruptions to business processes.
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The Final Office Audit Announcement, advising the exact date and the name of the Auditor must be
sent at least one (1) week before the Audit date.
The Final Vessel Internal Audit Announcement, specifying the exact date, and the port (for
Vessels), at least one (1) week before the Audit date.
Any change must be advised as early as possible.

Copies of all Internal Audit Announcements must be filed together with the complete Internal Audit
reports, by the S&Q Department and the Vessels.
2.2.2 Unannounced Internal Audits

The S&Q Department recognizes that there are many occasions when it is necessary to deviate from
the approved Internal Audit Schedule and initiate unscheduled audits.
These may arise from a number of reasons, including occasions when serious failures in the IMS
are identified.
Unannounced Internal Audits may be conducted, following DPA approval.
2.2.3 Appointment of Internal Auditors

Internal Audits must be carried by Company Employees or other persons appointed by the
Company, who are qualified and certified Auditors.
The appointment of the Internal Auditor is the responsibility of the DPA, in cooperation with the
S&Q Department.
As a principle, the Auditor must NOT be directly involved in the Auditee activities at the time of
the Audit.
For example, the Master, as principle authority onboard the ship, must not carry out an Internal
Audit while he is in command.
However, he may carry out an Internal Audit on his appointment to the Ship before he assumes
command. (refer to Page 3 of this procedure)
If at the time of the scheduled Audit, the Vessel is trading in inconvenient/unsafe ports and the
Office Internal Auditor cannot travel, the Internal Audit may be conducted by the Master and/or by
Senior Shipboard Personnel, as long as the auditor does not audit an area in which he is directly
involved i.e. Deck Officers may audit IMS procedures of Engine Room and Engineering Officers
may carry Internal Audits of the IMS procedures of Bridge and Deck.
However, it must be stressed that an Official Internal Audit must be carried by a certified Office
Auditor, at the next convenient port.
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2.2.4 Competency standards for Internal Auditors

The Competency Standards for Internal Auditors must be:
A. Internal Auditor’s Certificate (applicable to specific Standard / Code), issued by a Recognized
Organization;
B. Knowledge of the ISM Code;
C. Knowledge of MLC 2006;
D. Knowledge of ISPS Code (for Vessel Audits);
E. Knowledge of the ISO Standards 9001, ISO 14001, ISO 27001, ISO 45001 and ISO 50001 (for
Office and Vessel Audits);
F. Knowledge of the Company IMS;
G. Knowledge of the Company ISMS;
H. Audit and Training Experience;
I. Practical Experience in marine operations (preferably).
2.2.5 Internal Audit Purpose and Scope

The S&Q Department must advise the appointed Internal Auditor of the following:
A. The Purpose of the Audit e.g. whether the audit is scheduled, unscheduled, follow-up etc.
B. The Scope/extent of the Audit e.g. specific elements of the IMS to be audited.
For ICT/ISO 27001 Audits, the audit scope and extent should always consider the operational
continuity of the involved systems, allowing checks to be performed in a non-invasive manner.
C. The duration of the Audit (e.g. for Vessels - Audit during a Port call, traveling on the Vessel
for a few days etc.)
2.2.6 Preparation of Internal Audits

The S&Q department recognizes that good preparation is the foundation for a successful audit.
For this purpose the appointed Internal Auditor must become familiarized as to IMS procedures
which need special attention for the specific Vessel, as well as the results of the previous Audits.
2.2.7 Internal Audit Set

The Internal Audits are conducted using appropriate Checklists for Office Departments and Vessels,
in order to ensure that the audits are conducted in a consistent and systematic way.
The Checklists are periodically reviewed by the responsible Departments (S&Q, CSO and ICT) to
ensure that they include the latest requirements of the ISM Code, MLC, ISPS Code, ISO 9001, ISO
14001, ISO 27001, ISO 45001 and ISO 50001 Standards, the Company IMS, and IMO Regulations.
The Audit Checklists are guiding but not limiting.
The Internal Auditor may expand the Checklist by adding more elements to be audited, if necessary.
A complete Internal Audit Set includes:
 Internal Audit Announcements.
 Any Preparation documents (reviewed in Office).
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 Internal Audit Checklist (for guidance and reference).

The Internal Audit Checklist- Form OFF/SAQ/409 may be used.
The VIQ Questionnaire is also acceptable.
 Deficiencies List .
 Non Conformity Notes.
2.2.8 Internal Audit Reference Numbers

 Each Internal Office Audit is assigned a unique number, according to the Formula:
OFF/CODE OR STANDARD/MMYY/XXX
MM= Month
YY= Year
XXX: Initials of Auditee Department (three (3) letters: TEC, MRS, SAQ, CREW, etc.)
All the IMS Forms, which comprise the Internal Office Audit set, must have this reference
number.
 Each Vessel Internal Audit is assigned a unique number, according to the following Formula:
VV/INSP/MMYY/CODE OR STANDARD (i.e. ISM or SEC)
VV= Vessel’s Initials (2 letters)
MM= Month
YY= Year
All the IMS Forms which comprise the Internal Audit set, must have this reference number.
2.2.9 Classification of Audit Results

The Audit results are classified as follows:
A. Non Conformity (NCR)
B. Observation (OBS)
C. Agreed Action (AA): This is somewhat relevant to the SFI (Suggestion for improvement) which
is used by certain classification societies.
The contents of Agreed Actions are self-explanatory (training, best practice etc)
The Audit Results must always be agreed by both the Auditor and the Auditee.
The relevant Internal Audit checklists must always be signed by both parties.
2.2.10 Non Conformity Notes

The following “Non Conformity Notes” have been developed for the Non Conformities raised
during Internal Audits:
A. For management system Internal Audits of Vessels
B. For ISPS Internal Audits of Vessels
C. For Internal Audits of Office Departments
The above forms must be issued for Non-Conformities only.
Non Conformity Notes must not be issued for Observations.
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The Non Conformity Note must include the following information, without fail:
 Area of Non Conformity;
 Reference to the Code / Standard or Company IMS or other IMO Requirement;
 Description of the Non Conformity;
 Agreed Corrective Action;
 Person responsible to take the corrective action;
 Due date of corrective actions (definite – not abstract).
All the Non Conformity Notes must be signed by both the Auditor and Auditee.
2.2.11 Deficiencies List –Internal Audit

The Non Conformities and Observations of the Audit are listed in the “Deficiencies Lists”, specific
for each type of Audit as follows:
A. For management system Internal Audits of Vessels.
B. For ISPS Internal Audits of Vessels.
C. For ISM/ISO Internal Audits of Office Departments.
These Reports serve as a quick and easy reference of the Audit results, their category, their due date
and their status, having reference to supporting evidence.
Every time there is a change, in the status, these reports are updated by the S&Q Department.
The originally issued Deficiencies List must be signed by both the Auditor and the Auditee.
2.2.12 Distribution of Internal Audit Reports

The Internal Audit Set must be produced in two (2) computer typed copies with original signatures
of the Auditor and the Auditees.
 One set must be handed over to the Auditee (Vessel or Office Department) and
 One copy must be kept by the S&Q Department.
The Audit reports must be produced and handed over to the S&Q Department
in a period of SEVEN (7) Working Days
after the completion of the Audit.
This consists a S&Q Department KPI
In case of a Vessel Internal Audit, this period is granted because some Auditors travel from Vessel
to Vessel and delay to return to the Office.
However, a copy of the Audit Deficiencies List (even in handwriting), is sent by e-mail attachment
from the audited Vessel, thus enabling the Company to be notified of the Audit results and to start
taking corrective action.
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The DPA conducts “spot-checks” to ensure that this performance standard is being met.
If the Audit report is not produced in the set time limit, the DPA will intervene.
In case the Forms of the Audit Set are filled-in by hand (due to lack of time), the original is kept by
the Auditor and a copy is given to the Auditee.
In such cases, it is recommended to produce a typed set with the original signatures of the Auditor,
to be signed by the Auditees at a later date.
2.2.13 Records of the Internal Audit Reports

Full records of the Internal Audit Reports must be kept as follows:
 S&Q: All Internal Audits (Office and Vessels).
 Vessels: All Vessels Internal Audits.
 Office Departments: All Internal Office Audits of the specific Department.
 Vessel Records in Master’s File in case of Vessel Internal Audit.
 CSO Records in S&Q File-“ISPS Internal Audits- Vessels”.
Internal Audit reports are also uploaded in the ERP.
2.2.14 Processing of the Internal Audit Reports by S&Q

The S&Q Department is responsible to process the Internal Audits Reports, as described in the
following paragraphs.
All closed Non Conformities raised during an Internal Audit,

may be subject to a further on-the-spot verification during later Audits.
The due time for the close-out of the Non Conformities and Observations raised during an Audit
must not exceed the period of three (3) months.
Under certain justifiable circumstances (not convenient ports for supply of spares etc), extension
may be granted.
Items which are not closed within the period of three (3) months are passed to Senior
Management (during the weekly Operational Meetings and the Management Review Meeting) for
resolution.

The results of the Audits, when they are significant, are immediately distributed to the Fleet
Vessels, via an e-mail.
When deemed necessary, all the Vessels are requested to report the status on their own Vessel,
related to the Audit findings.
Quarterly and at the end of each year, the results of all the Internal and External Audits must be
collected and grouped in categories per nature of deficiency.
The purpose is to identify any common Non Conformities which may be an indication of a
weakness of the IMS.
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The Audit results must also be included in the Agenda of the Management Review Meetings and
must be evaluated.
The Management Review Meetings are distributed to Shore and Shipboard Personnel.
Evaluation and Analysis of the Internal Audit Findings may result in:
 Amendments of existing IMS Procedures and Forms.
 Development of new IMS Procedures. ( incorporation of new regulations etc)
 Issuance of guiding Circulars on specific IMS elements.
 Identification of trends and areas of improvement
2.2.16 Discussion of the Results of Internal & External Audits during the Management
Review Meetings
The Management Review Meeting Agenda includes discussions related to Audits as follows:
 If the Audits were conducted as per the Audit Plan.
 If the Audit Results were reported within the set time frame.
 Audit Findings Status.
 If the Deficiencies raised during the Audits were closed within the set time frame of three (3)
months.
 The reason for which any extensions as to close-out date were granted.
 Efficiency of Company Auditors (additional Auditors, Refresher Training etc).
 Corrective Actions taken which can be adopted as standard Best Practice for all Fleet Vessels.
 Any IMS improvement that originated from Audit Results.
 If the Annual KPIs were achieved.
2.3 INTERNAL AUDITS – OFFICE

This section describes the specific arrangements made in order to conduct IMS Management
System Internal Audits of the Office Departments.
The Internal Office Audit, must follow the basic Audit principles, as presented in above
subparagraph.
2.3.1 Internal Audit Sets for Office Departments

The Internal Office Audits are conducted by using Audit Checklists, which are “Department
Specific” issued by the S&Q Dpt.
The Internal Audit Sets for Office Departments, include the following reports:
 Office Departments-Specific Audit Checklists Form ( for guidance and reference).
 Deficiencies List/ISM/ISO Internal Audit-Office.
 Non Conformity Note –Office.
 ISM/ISO Internal Audit Report – Office.
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The Office Department Audit Checklists, have been developed for guiding purposes only.
They are “Adjustable” Forms, meaning that they can be modified by the Internal Auditor, depending
on the purpose and scope of the Audit.
2.3.2 Scope of the ISM/ISO Internal Office Audit

The Internal Office Audit Checklists have been developed to cover the requirements of a full-scale
Audit.
However, partial audits of selected sections of the Internal Audit checklist may be conducted when
serious failures in the IMS are identified.
These partial Audits are usually unannounced.
Partial Audits in no way replace the Annual full-scale Internal Audits.
2.3.3 Conducting the Internal Office Audits

Before starting the Audit, the appointed Internal Auditor must hold an Opening Meeting with the
Department Manager and staff, in order to explain the purpose and the scope of the Audit and to
decide on the actual Auditing Schedule which has to be followed in order not to impede daily work.
The Audits must be conducted by observing and by interviewing.
When all the Sections of the Audit checklist are complete, a Closing Meeting must be held with the
Department Manager. During the Closing Meeting, the Audit results must be presented, analyzed,
classified (NCR, OBS and Agreed Actions) and agreed by both parties.
When the classification of Audit results has been finalized and agreed, the Corrective Action
Requests and Deficiencies List must be filled in.
All the Non Conformity Notes must be signed by both the Auditor and the Department Manager.
2.3.4 Processing of the Internal Office Audits Reports by S&Q

When the S&Q receives the Audit sets, the procedure, which must be followed for each case, is:
A. Filing of the Audit set in the S&Q File (Office Internal Audits).
B. Updating the S&Q electronic Files with the Audit documents.
C. Briefing the DPA and responsible Management Representative on Audit Results.
D. Notifying all Office Departments responsible for areas involved, of the audit results.
E. Coordinating necessary corrective actions and keeping a close follow-up.
F. In case of serious Non Conformities, notifying all the Office Departments and Fleet Vessels,
and if necessary, issuing guiding Circulars /Alerts on specific items/ problems.
G. Reviewing the supporting documentation and ensuring that corrective actions are sufficient and
are completed on due date.
H. Continuously updating the Deficiencies List with the latest status.
I. Closing the Non Conformity Notes by signing them and submitting them to the DPA and or the
responsible Management Representative for final approval and close-out.
J. Providing “Closed Sets” to the Office Departments.
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2.3.5 Closing the Non Conformities and Observations
The due time for the close-out of the Non Conformities and Observations raised during an
ISM/ISO/ISPS/MLC 2006 Audit must not exceed the period of three (3) months.
Under certain justifiable circumstances, extension may be granted.
Management (during the weekly Operational Meetings and the Management Review Meeting)
for resolution.
 Non-Conformities
When a Non Conformity has closed, the Department Manager must submit to the S&Q
Department, the original Non Conformity Form signed and stamped and having filled-in in the
space “Corrective Action Taken”, and the date of close-out.
Any Supporting Evidence, serving as proof that the Non Conformity has closed, must be
attached to the relevant Non Conformity Note.
Upon receipt, the S&Q Department must check the supporting evidence.
If the result of this checking is satisfactory, then the S&Q Department must sign the Non
Conformity Note for the final close-out of the Non Conformity.
The S&Q Electronic files must be updated with the Close-out.
 Observations
When an Observation has closed, the Department Manager must notify the S&Q Department in
writing, giving details of the corrective actions taken.
Where applicable, supporting evidence must be provided.
All the closed Non Conformities raised during an Internal Office Audit may be subject to new
verification during later Audits.
2.4 INTERNAL AUDITS – VESSELS

This section describes the specific arrangements made in order to conduct Internal Audits of
Vessels.
The Internal Vessel Audit must follow the basic Audit principles, as presented in previous
subparagraph.
It must be stressed that visiting Auditor must always set a good example to the ship crews by
wearing the correct PPE and complying with all safety and security procedures and practices.
They must also observe that the Senior Shipboard Officers also set a good example by doing the
same.
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2.4.1 Internal Audit Checklists

The ISM/ISO Internal Audit Set for Vessels, includes the following reports:
 SF/SAQ/409- Audit Checklist ( Optional for guidance and reference)
 SF/SAQ/410- Ship’s Deficiencies List
 SF/SAQ/411- Non Conformity Note
The Internal Audit Checklist-Vessel (SF/SAQ/409) includes the following sections:

 Section 1: Master
 Section 2: Bridge
 Section 3: Chief Officer
 Section 4: Chief Engineer
 Section 5: Safety Officer
 Section 6: Crew Interviews
 Section 7: Walking around the Deck
 Section8: Visiting Engine Room
The above sections, also include ISO & MLC 2006 related items as well.
During a full-scale management system Internal Vessel Audit, all the above sections must be
checked.
The ISPS Internal Audit Set for Vessels, includes the following reports:
 Form OFF/SEC/901 Security -Internal Audit Checklist
 Form OFF/SEC/902 Security -Deficiencies List
 Form OFF/SEC/903 Security- Non Conformity Note
2.4.2 Scope of the Partial Vessel Audit

The Audit Checklist, has been developed to cover the requirements of a full-scale Audit.
However, partial audits of selected sections of the Audit checklist, may be conducted.
Partial Audits may be considered for two reasons:

 Shortage of time at a specific Port
The option for a partial Internal Audit (due to short stay at port, or numerous inspections at Port
i.e. Vetting, PSC etc.), may be accepted, provided that at the next convenient port, the remaining
aspects of the Vessel’s operations will be audited, and provided that the partial audit is
conducted in a period not more that twelve (12) months since the previous partial audit.
 Identification of serious failures in the IMS, on specific Shipboard procedures.
Such Partial Audits are in addition, and not in the place of the Annual Internal Audit.
2.4.3 Conducting the Internal Vessel Audits

Before starting the Audit, the appointed Internal Auditor must hold an Opening Meeting with the
Master and Officers in order to explain the purpose and the scope of the Audit and to decide on the
actual Auditing Schedule which has to be followed in order not to impede the Vessel activities.
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The Audit must be conducted by observing and by interviewing.

When the Audit of each separate section of the Audit Checklist is completed, the last page of the
section must be signed by both the Auditor and the Auditee, conforming agreement of the Audit
results.
When all the Sections of the Audit checklist are complete, a Closing Meeting must be held with the
Master and all the Officers who have been audited. During the Closing Meeting, the Audit results
must be presented, analyzed, classified (NCR, OBS and Agreed Actions (AA)) and agreed by both
parties.
When the classification of Audit results has been finalized and agreed, the Non Conformity Notes
and Deficiencies List must be filled in.
All the Non Conformity Notes must be signed by both the Auditor and Master.
2.4.4 Processing of the Internal Vessel Audit Reports by S&Q

The Internal Vessel Audits are processed by the S&Q Department.
The ISO 27001 Audits are processed by the Company Security Officer.
When the S&Q receives the Audit set, the procedure which must be followed, is:
A. Filing of the Audit set in the S&Q File 202 (Vessel Internal Audits) or electronically.
B. Updating the S&Q electronic Files with the Audit documents.
C. Briefing the DPA and or responsible Management Representative on Audit Results.
D. Notifying all Office Departments responsible for areas involved, of the audit results.
E. Coordinating necessary corrective/preventive actions and keeping a close follow-up.
F. In case of Non-Conformities, notifying all the Office Departments and Fleet Vessels, and if
necessary, issuing guiding Circulars /Alerts on specific items/ problems.
G. Reviewing the supporting documentation and ensuring that corrective actions are sufficient and
are completed on due date.
H. Continuously updating the Deficiencies List with the latest status.
I. Closing the Non Conformity Notes by signing them and submitting them to the DPA and or
responsible Management Representative for final approval and close-out.
J. Providing “Closed Sets” to the Vessels.
2.4.5 Closing the Non Conformities and Observations
The due time for the close-out of the Non Conformities and Observations raised during an
ISM/ISO/ISPS Audit must not exceed the period of three (3) months.
Under certain justifiable circumstances (not convenient ports etc), extension may be granted.
Management ( during the Weekly Operational Meetings and the Management Review
Meetings) for resolution.
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 Non Conformities
When a Non Conformity has closed, the Master must submit to the S&Q Department, the
original Non Conformity Note, signed and stamped and having filled-in in the space “Corrective
Action Taken”, and the date of close –out.
Any Supporting Evidence, serving as proof that the Non Conformity has closed, must be
attached to the relevant Non Conformity Note.
Upon receipt, the S&Q Department must check the supporting evidence, and if applicable,
perform cross- checks with other Vessel reports.
If the result of this checking is satisfactory, then the S&Q Department must submit the Non
Conformity Notes to the DPA, for the final close-out of the Non Conformity.
 Observations & Agreed Actions
When an Observation or Agreed Action has closed, the Master must notify the S&Q
Department in writing (e-mail attachment), giving details of the corrective actions taken. Where
applicable, supporting evidence must be provided.
 Audit close- out
When all the Items of the Deficiencies List have been reported by the Master as “Closed” and
the Closed and signed Non Conformity Notes have been submitted to the S&Q, with
satisfactory supporting documentation, the Internal Vessel Audit may be considered as
“Closed”.
The Deficiencies List must be updated with the latest status, and must be signed and stamped by
the S&Q Manager.
A “Closed Set” must be sent onboard, which must include the Final Deficiencies List as well as
all the Original Non Conformity Note, signed and stamped by the DPA.
All the closed Non Conformities raised during an Internal Audit, may be subject to an onboard
verification during later Audits.
2.5 MASTER’S NAVIGATIONAL AUDITS

As per TMSA Requirement 5A-KPI 2.3, the Master is required to perform Navigational Audits.
A dedicated Navigational Audit has been added in the IMS for this purpose i.e
SF/MRS/200-“Internal Navigational Audit-Master”.
For more details refer to the Manual “Navigational and Mooring Manual”- NAVM 006- Section10-
paragraph 2.1.2- Master’s Navigational Audit”
Navigational Audits are monitored and reviewed by the Marine/Vetting Department.
2.6 NAVIGATIONAL, MOORING AND CARGO AUDITS BY MARINE SUPERINTENDENTS

During their attendance onboard Marine /Vetting Superintendents carry out Internal Navigational,
Cargo and Mooring Audits, depending on the time available.
Dedicated Internal Audit Checklists:
 OFF/MRS/201- Internal Navigational Audit
 OFF/MRS/202- Internal Cargo Audit
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 OFF/MRS/202G- Internal Cargo Audit- LPG

 OFF/MRS/203- Internal Mooring Audit
Although the frequency of the above Internal Audits has not been established as an Official KPI,
every effort is made in order to carry out at least one (1) Audit of each category per year (also
taking into consideration relevant Audits carried by 3rd Parties).
3. RECORDS
 Vessel Pre-Audit Checklist PRO/PRO 10/ OFF/SAQ/408
 Internal Audit Checklist- Vessel PRO/PRO 10/ OFF/SAQ/409
 Ship’s Deficiencies List/Internal Audit - Vessel PRO/PRO 10/ OFF/SAQ/410
 Non Conformity Note/Internal Audit- Vessel PRO/PRO 10/ OFF/SAQ/411
 Audits Schedule - Office PRO/PRO 10/ OFF/SAQ/413
 Audits Schedule - Vessels PRO/PRO 10/ OFF/SAQ/414
 Office Departmental Internal Audit Checklists PRO/PRO 10/ OFF/SAQ/416
o General Office PRO/PRO 10/ OFF/SAQ/416A
o S&Q Department PRO/PRO 10/ OFF/SAQ/416B
o Vetting Department PRO/PRO 10/ OFF/SAQ/416C
o Technical Department PRO/PRO 10/ OFF/SAQ/416D
o Crew Department PRO/PRO 10/ OFF/SAQ/416E
o Operations Department PRO/PRO 10/ OFF/SAQ/416F
o Purchasing Department PRO/PRO 10/ OFF/SAQ/416G
o Legal & Insurance Department PRO/PRO 10/ OFF/SAQ/416H
o Office Administration PRO/PRO 10/ OFF/SAQ/416I
o Training Department PRO/PRO 10/ OFF/SAQ/416J
 Deficiencies List - Office PRO/PRO 10/ OFF/SAQ/417
 Corrective Action Request - Office PRO/PRO 10/ OFF/SAQ/418
 Internal Audit Report - Office PRO/PRO 10/ OFF/SAQ/419
 Internal Navigational Audit Checklist PRO/PRO 10/ OFF/MRS/201
 Internal Navigational Audit-Master PRO/PRO 10/ SF/MRS/200
 Ship Security Internal Audit-Checklist PRO/PRO 10/ OFF/SEC/901
 Ship Security Internal Audit-Deficiencies List PRO/PRO 10/ OFF/SEC/902
 Ship Security Internal Audit-Corrective Action Request PRO/PRO 10/ OFF/SEC/903
 Internal Navigational Audit Checklist PRO/PRO 10/ OFF/MRS/201
 Internal Cargo Audit Checklist PRO/PRO 10/ OFF/MRS/202
 Internal Cargo Audit Checklist –LPG/G PRO/PRO 10/ OFF/MRS/202G
 Internal Mooring Audit Checklist PRO/PRO 10/ OFF/MRS/203
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CORRECTIVE AND PREVENTIVE ACTIONS Eff. Date: 30/11/2021
Contents
1. PURPOSE 2
2. PROCEDURE 2
2.1 Purpose of the Management Review Meeting 2
2.2 Non-Conformities 2
2.3 General Procedure for the Monitoring Non Conformities 3
2.4 Corrective and Preventive Actions 4
2.5 Closing – Out Non-Conformities 6
3. RECORDS 6
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1. PURPOSE
This procedure defines the procedures followed for the reporting, investigating and analyzing of Non-
conformities. It also includes provision for Corrective and Preventive actions.
2. PROCEDURE
2.1 PURPOSE OF THE MANAGEMENT REVIEW MEETING
2.2 NON-CONFORMITIES
According to the definition of Non-Conformity, the following may be considered as such:
 An incident, such as an accident causing personal injury, a hazardous occurrence, pollution and a
defect or deficiency of ship critical equipment, system and/or personnel, which has been identified
from analysis as failure to provide the service required by contract with a customer or as required
by a third party or affects the safety and the performance of the Vessel.
 A Deficiency in the Integrated Management System (Safety-Health-Quality-Environmental-
Energy- Information Security Management), which has been identified from the day-to-day
operation, during Third Party and Internal Inspections, from the analysis of a Report, or has
been found or reported during Internal and External audits.
 Non-fulfillment of International and / or National regulations including the ISM Code, ISO
9001, ISO 14001, ISO 27001, ISO 45001 and ISO 50001.
 Material breakdowns due to fair wear and tear SHALL NOT be considered as Non-
conformities.
 Damage, defects, malfunctioning, deficiencies of the Vessel’s equipment and systems which
cannot be easily solved out (as decided by the Master and the Chief Engineer) and/or involve
critical equipment, shall be considered as Non-conformities.
 Nevertheless, whatever defect is a threat for the environment / safety / crew / personnel shall be
considered as Non-Conformity.
A deviation from requirements specified in Integrated Management System, or an error or defect, or

an identified lack of plan or instructions for a key shipboard operation which could endanger or has
compromised the safety of people, the environment, the ship or cargo may result to a Non-
Conformity.
Also Non-conformities may be raised during “Day to Day” operations, External/Internal Audits or
any other Statutory, Class, Flag State or Port State Surveys, Management Review Meetings, Customer
Complaints or Feedback, Non-conforming Services, Hazardous Situations, Accidents and Casualties.
The company identifies Non Conformities through the following processes:

 Day –to – Day operation ashore and onboard,
 Vessel’s Reporting of Defects, by issuing Defect Reports & Dry Dock Repair Requests through
the Deficiencies identified during Superintendent’s Visits,
 Internal Audits ashore and onboard,
 Vessel Visit Report,
 External Audits,
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 Third Party Inspections (USCG, PSC, Flag, P&I Club),

 Vetting/CDI Inspections,
 Legal breaches,
 Periodical and Special Surveys,
 Customer complaints (Owners/Charterers),
 Loading/Discharging Documents,
 Letters of Protest,
 Claims from Third parties,
 Customer Satisfaction reports,
 Suppliers Evaluation reports,
Every member of the Office personnel/Vessel crew shall be responsible to identify and report any
Non-Conformity or Defect to Integrated Management System, applicable Rules, Regulations and
other requirements, identified during every-day work, Vessel Surveys or Inspections, Audits, etc.
Non-Conformity Note must be properly completed by the Initiator.
Records of the nature of the Non-conformities raised and the relevant Corrective Actions taken are
maintained.
For findings raised during Internal Audits, reference is made to the Specific IMS Procedure
which must be read in conjunction with this procedure.
The person raising the initial Non-Conformity shall bring to the attention of the relevant Department
Manager the existence of the Non-Conformity.
A Non-Conformity Report will be issued, indicating the nature and extent of the Non-Conformity and
any Corrective Action taken, and forward it to the DPA.
The relevant Department Manager shall take immediate Corrective Action to control the situation in
the Short term. Onboard, Non-conformities must be reported by the Master.
All Non-conformities must be forwarded to the S&Q with cc to the DPA
The responsible Management Representatives, must be informed, in case that the Non-Conformity
also refers to other ISO Standards besides ISM, ISPS, MLC (i.e ISO 9001, 14001, 27001, 45001
and 50001).
2.3 GENERAL PROCEDURE FOR THE MONITORING NON CONFORMITIES

The procedures for the follow-up of Non-Conformities involve the following steps:
 The Non Conformity, if identified and raised by Company employees (Office or Shipboard) must
be documented and reported on an official IMS Form i.e.
o Defect Report (Through e-PMS ),
o Dry Dock Repair Request (Through e-PMS ),
o Non Conformity Note-Internal Audit – Vessel,
o Non Conformity Note– Internal Audit – Office,
o Superintendent’s Visit Report,
o Company Audit & Review of Manning Agents.
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 Comments, if raised by other Organizations (Class, Oil Majors, Flag, USCG/PSC, Owners or
Charterers), will be reported on their own Documents (Inspection Reports), however, copies
must be forwarded immediately to the Office. The comments raised by Third Parties as
mentioned above, must be treated in the Office as Non Conformities.
 For Non-Conformities which are identified and raised by Company employees (Office or
Shipboard), “Summary Lists” are maintained on official IMS Forms i.e.
o Ship’s Deficiencies List – Internal Audit – Vessel ;
o Deficiencies List – Internal Audit – Office;
o Ship’s Deficiencies List- ISPS Internal Audits;
o Recommendations for Ship Staff Maintenance ( through the e-PMS );
 For Non-Conformities which are identified and raised by other Organizations, “Summary Lists”
are maintained, on controlled or uncontrolled forms.
 Records are also available electronically, by using computer software i.e. ERP
 All documentation related to the identification, reporting, follow-up, close out and verification of
Non-Conformities, must be filed in specific files as per the Filing System of Office Departments
and Vessels ( in hard copy or electronically).
 Depending on the nature of the Non-Conformity, responsibilities must be assigned, for the follow-
up, corrective and preventive actions taken, close-out, and reporting to Authorities if necessary.
The DPA and / or the responsible Management Representative are responsible to monitor these
activities.
 Non-Conformities must be grouped, categorized, analyzed, and the Root Cause must be
identified.
Trends must be identified. If necessary, changes to procedures, processes, forms must be made.
 Appropriate corrective / preventive actions must be taken.
 Appropriate corrective/preventive actions may be, but are not limited to:
o The amendment to existing IMS Procedures and instructions or forms.
o The development of new IMS Procedure and instructions or forms.
o The removal of a Supplier/Subcontractor from the Approved Supplier / Subcontractor List.
o Training of Company Employees to increase awareness of the IMS and its implementation,
or changes.
o Employment of specialized consultants for a specific project.
 Periodically, corrective / preventive actions must be evaluated for their effectiveness.
 Experience must be distributed throughout the Company, for lessons learned in order to avoid re-
occurrence.
 If deemed necessary and depending on the seriousness of the Non Conformity a re-inspection /
re-audit of the Non Conformity to verify satisfactory close-out may be conducted.
2.4 CORRECTIVE AND PREVENTIVE ACTIONS

Once a Non-Conformity has been identified, the nature and the extent of the Non-Conformity shall
be agreed between the person identifying the Non-Conformity and the Head of the relevant
Department. In case that non-conformities and deficiencies are noticed, office personnel and Vessel’s
crew shall simultaneously respond and initiate appropriate corrective and preventive action.
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Appropriate Corrective Action must involve solutions, which may reduce or prevent re-occurrence
of this type of Non-Conformity.
A Non-Conformity report may be raised, when further investigation is required in order to prevent
re-occurrence.
Upon identification of Non-Conformity and submission of the relevant report, the Department
Manager and any other person(s) related to the Non-Conformity ashore and the Master together with
the Chief Officer and / or Chief Engineer onboard, shall hold an informal meeting in order to:
 Analyze and investigate the Non-Conformity with the objective to identify root cause and the risk
involvement.
 Decide on the action to be taken for eliminating the cause of the Non-Conformity.
 Decide on the action to be taken in order to avoid similar future occurrences.
 Decide for the responsible person and the target date for the implementation of corrective and
preventive action.
Upon receipt of the completed Non-Conformity Report, the DPA shall, in conjunction with the
relevant Management Representative and department manager, decide if further corrective or
Preventive Action is required.
Any Corrective Action decided shall be recorded on the Non-Conformity Report subsequent to the
Corrective Action.
Immediate Corrective Action may be taken, if the identified non-conformance directly endangers the
safety of the ship and the crew or the marine environment.
Such an action may be taken by either DPA or the Master and shall be considered as temporary until
corrective action procedure has been completed.
In any case, DPA shall be advised immediate. Same procedure applies when a Major Non-Conformity
exist in order to down-grade it into minor Non-Conformity.
When Non-conformities concern the Integrated Management System’s functional aspects, then
appropriate Corrective Action may be taken, but not limited to any or a combination of the following:
 amendments to existing procedures and instructions,
 development of new procedures and instructions,
 further training or education,
 take action to eliminate the detected nonconformity,
 authorizing its use, release or acceptance under concession by a relevant authority and, where
applicable, by the customer,
 take action to preclude its intended use or application.
All Non-Conformity Reports shall be investigated.

The investigation shall be headed by the DPA or the responsible Management Representative,
assisted by the relevant Department Managers and other personnel as appropriate.
The purpose of the investigations shall be to determine the underlying cause, and to decide upon
appropriate Corrective and Preventive Action, to prevent a recurrence.
Any Corrective and Preventive Action shall be implemented within a defined timescale, which shall
be realistic and achievable.
The appropriate timescale for implementation shall be recorded on the original report form, and
monitored by the S&Q Department, as appropriate.
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2.5 CLOSING – OUT NON-CONFORMITIES

On a regular basis (e.g. monthly) but as a minimum on due date, the Master must send a message to
S&Q Department reporting progress or close-out of the Non Conformities.
In case a Non Conformity is still pending on due date, the Master must request for a reasonable
extension, stating the reasons for the delay. When satisfied as to the full completion of all the
Corrective Actions, the Master must complete all the Non Conformity Notes, sign them and send
them to the Office, to the attention of the S&Q Department. Similar procedure shall be implemented
in case of non-conformities issued to office departments in which cases the responsible manager of
the involved department must complete all the Non-conformities Notes, sign them and forward them
to the responsible Management Representative.
When the NCRs and any supporting documentation are received in Office, they are reviewed as
follows:
 For ISM/ISO 45001: by the DPA and S&Q Department Manager,
 For MLC: by the S&Q Department Manager and the Crew Manager,
 For ISO 9001: By the S&Q Department Manager and the Quality Management Representative,
 For ISO 14001: by the DPA and the Environmental Management Representative,
 For ISO 27001: by the ICT Support Manager,
 For ISO 50001: by the Energy Efficiency Management Representative,
 For ISPS : by the Company Security Officer (CSO).
The DPA (or Alternate DPA) and / or the responsible Management Representative must
originally sign as closed out the NCRs issued.
Similarly, the CSO or Alternate CSO (or S&Q Manager) must originally sign as closed the NCRs
issued during the ISPS Internal Audits. All NCRs must be returned to the Vessel for final filing.
In case of Internal Audits, the relevant file includes the following documentation for all closed
management system Internal Audits:
 Summary Table which lists all the management system Audits conducted since the acquisition of
the Vessel under Company Management.
 Final Deficiencies List.
 All Non-Conformity Notes signed as closed by the responsible person as presented above.
 All supporting evidence available to prove close-out of the Non Conformities and Observations.
 Original Deficiencies List (as left onboard by the Internal Auditor).
 Management system Internal Audit Checklist.
 Internal Audit announcement messages (e-mails sent by the S&Q Department).
These files must always be in order.
All Corrective Actions may be the subject of re-audits.
3. RECORDS
 Non Conformity Report PRO/PRO 11/ OFF/SAQ/427
 Non Conformity Note- Internal Audit- Vessel PRO/PRO 10 / OFF/SAQ/411
 Non Conformity Note-Internal Audit-Office PRO/ PRO 10 / OFF/SAQ/418
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MANAGEMENT REVIEW MEETINGS Eff. Date: 30/09/2022
Contents
1. PURPOSE ..................................................................................................................................2
2. PROCEDURE ............................................................................................................................2
2.1 Purpose of the Management Review Meeting ........................................................................2
2.2 Frequency of Management Review Meeting ..........................................................................2
2.3 Coordination of Management Review Meetings ....................................................................2
2.4 Attendees.................................................................................................................................3
2.5 Notification of Management Review Meeting .......................................................................3
2.6 Management Review Meeting – Input / Output .....................................................................3
2.7 Assignment of Responsibilities...............................................................................................5
2.8 Records of Management Review Meetings ............................................................................7
3. RECORDS .................................................................................................................................7
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1. PURPOSE
This procedure describes the steps to be followed when conducting Management reviews.
2. PROCEDURE
2.1 PURPOSE OF THE MANAGEMENT REVIEW MEETING

The purpose of the Management Review Meeting is to:
 Assess the effectiveness and the degree of the implementation of the Company Integrated
Management System.
 Discuss the SWOT Analysis (i.e the Company’s Strengths, Weakness, Opportunities and
Threats).
 Analyze the Root Cause of the Identified Deficiencies.
 Decide on the Corrective /Preventive actions which are required.
 Plan for further development.
2.2 FREQUENCY OF MANAGEMENT REVIEW MEETING

The Management Review Meeting must be held on a Quarterly Basis, 30-45 days after the end of
each Quarter (with a reasonable deviation of up to 15 days, which will be approved by the COO/D-
COO).
1st Quarter Results ( January –March) End April to Mid-May.

2nd Quarter and 1st Semester Results End July to Mid-August, with a deviation until
( January to June ) first week of September due to the Summer
Vacation Period.
3rd Quarter and 9-Months Results End October to Mid-November.
(January to September)
4th Quarter and Annual Results End January to End February
(January to December ) (Due to additional work required for the Annual
Presentation of the Results).
2.3 COORDINATION OF MANAGEMENT REVIEW MEETINGS

The COO and the S&Q Manager are responsible for the coordination of the Management Review
Meeting.
They are responsible for the following activities:
A. Scheduling of the Management Review Meeting.
B. Deciding on the Agenda to be followed.
C. Notifying the Office Departments.
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2.4 ATTENDEES
The attendees of the Management Review Meetings must be as a minimum:
A. The Chief Operating Officer (COO) or Deputy COO.
B. The Designated Person Ashore (DPA).
C. All Office Department Managers (Technical, Operations, Marine/Vetting, HR, Crew, Training,
S&Q, Purchasing, IT, ICT, Legal).
D. Other Department Managers at their discretion (Chartering , Finance , Accounting)
E. The Company Security Officer (CSO) and/or Alternate CSO.
F. Attendees from each Office Department.
G. Ship Managers.
H. Vessel Operators.
I. Marine Superintendents.
J. Other Office Employees (The Management Review meeting is an “open” meeting and all may
participate)
K. The Assistant to the S&Q Manager (Record Keeper)
L. Any Shipboard Officer(s) who may be in Office Premises on that day.
M. Company’s Medical Contractor.
2.5 NOTIFICATION OF MANAGEMENT REVIEW MEETING

The S&Q Department must notify all attendees of the forthcoming Management Review Meeting,
providing the Date and exact Time, as well as the Agenda to be followed.
This must always be done in writing.
The notification must be given as early as possible to allow for Attendees to schedule their work,
and to prepare their Presentations.
Any change of the Date and Time must be advised as early as possible.
2.6 MANAGEMENT REVIEW MEETING – INPUT / OUTPUT

A. The Agenda of the Management Review Meeting must include, but not be limited to:
 Review of Company Targets & Objectives and progress towards Safety and Environmental
Excellence,
 Acquisition /Sale of Vessels,
 Review of Company Policies,
 Review/Status of the IMS (Amendment Processes etc) and recommendation for
improvements,
 Review and verification of the Company’s significant Environmental Aspects,
Changing circumstances, including developments in legal and other requirements related to
the Company’s Environmental Aspects,
 Company Circulars, Alerts, Bulletins,
 Masters’ Reviews,
 Status of Corrective and Preventive actions,
 Office External and Internal Audits,
 Vessels External and Internal Audits,
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 Analysis of Results from all Audits (Internal and External Audits etc) and overall
effectiveness of Company IMS,
 Customer Feedback,
 Communication from External Interested parties, including Complaints,
 Process Performance and Service Conformity,
 External & Internal Audit Schedules,
 Analysis of Accidents, Incidents and Near Misses, Behavioral Safety, LTIF/ TRCF and
Benchmarking ( e.g Intertanko, ITOSF ),
 Technical Incidents,
 Marine Incidents,
 Non Conformance data,
 Company Security Activities and new Requirements/ Regulations,
 Security Incidents,
 Information Security Issues, Requirements and Regulations,
 Information Security Incidents,
 Crewing, and Level of Manning onboard,
 Flag Inspection Results,
 Port State / USCG Inspection Results,
 Marine /Vetting Inspection Results,
Aiming at identifying trends and common problems and evaluating performance, internal
Superintendents inspection observations are compared against SIRE Inspection
Observations and Internal Navigational Audits observations are compared against external
Navigational Audit observations,
 Technical Performance (reporting and follow-up of PMS/Defects/Recommendations
outstanding, Class Conditions etc),
 Identification of weaknesses across the Fleet,
 Review of the Company’s overall Environmental Performance ( i.e the extent to which the
Objectives and Targets have been met),
 Operations Department Results / Customer feedback,
 Training Department Activities and Results,
 New Regulations,
 Risk Assessment Review, taking into consideration emerging requirements and new
regulations,
 Management of Change reports and impacts of Management of Change,
Considerations for updating the system due to fleet changes, new trade and market
strategies, new regulations or changes in social and environmental attitudes,
 Office Resources (Current, future needs, new Employments, Promotions, dismissals,
resignations , internal transfers),
 Office Staff Training,
 Office-Vessel Drills & Table Top Exercises,
 Office Safety Drills,
 Health & Safety Campaigns,
 Health Bulletins and Newsletters,
 Best Practices,
 Any awards by Flag, other Organizations (i.e Safety4Sea) and other important events etc;
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 Follow-up actions from previous Management Review Meetings,

 Company SWOT Analysis ( Strengths – Weaknesses-Opportunities –Risks ),
 Action Plans, with clear time-frames for Short-Term targets and objective for each step of
the plan to achieve the long term goals.
The results must be tabulated to facilitate analysis and to identify trends and common problems.
Suggested improvements- if accepted during the Management Review Meeting- must be fed-back
into the Company’s continuous-improvement process.
Any progress which is identified to be less than planned, must result in a re-assessment of
Objectives, Targets and Plans.
B. Review output
 New Targets and KPIs
(Where performance exceeds expectations, management must consider re-assessing and
revising targets, objectives and KPIs).
 Improvement of the effectiveness of the IMS and its process
 New or amended Environmental Programs for the improvement of the Company’s
Environmental Performance.
 Improvement of the service related to customer requirements
 Resource needs (office and shipboard personnel levels)
 Future Training Needs
 Corrective Actions to realign performance with the set Targets, Objectives and KPIs.
 Relevant Action Plans, with clear time-frames for Short-Term Targets and Objective for
each step of the plan to achieve the long term Goals.
2.7 ASSIGNMENT OF RESPONSIBILITIES

The findings, conclusions and recommendations must be documented.
Action Plans must also be documented having clear time frames for short –term targets and
objectives, and clearly defining the Persons or Departments responsible.
Responsibilities must be allocated to Office personnel for any follow-up actions, to items which
were raised and agreed during the Management Review Meeting.
The COO is responsible to allocate the responsibilities to the Office Departments.
The Department Managers are responsible to allocate the responsibilities to specific employees in
their Department.
The DPA is overall responsible to periodically ensure that the agreed follow-up actions have been
implemented by all Office Departments within the set time scale.
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The COO and the S&Q Manager prepare a report with the input for the Agenda of the Management
Review which includes:
 Review of previous meeting regarding Occupational Health and Safety matters;
 Suitability of the Policy related to Occupational Health and Safety;
 Occupational Health and Safety Objectives and Targets as well as their associated Programs and
the extent to which these have been met;
 Communication(s) from External Interested Parties (including Complaints);
 Safe and correct working conditions in the Office and onboard including verification of
implementation of the Occupational Health and Safety Program and Action Plan on an Annual
basis;
 Health factors which could impact on Safety and Health of Personnel, on an Annual basis;
 Results of Health & Safety Awareness Campaigns implemented during the previous year.
Decision upon and initiation of new Campaigns for the next year, on an Annual basis;
 Occupational Health and Safety Performance including comments on relevant Programs,
Objectives, Policy Statement, Risk Assessment results, Legal Compliance and Feedback from
Interested Parties.
The Environmental & Performance Manager prepares a report with his input for the agenda of the
management review which includes:
 Review of previous meeting regarding Environmental matters,
 Significant Environmental Aspects,
 Suitability of Policy related to Environment,
 Environmental Objectives and Targets as well as their associated programs and the extent to
which these have been met,
 Changing circumstances, including developments in legal and other requirements related to the
Environmental Aspects,
 Training related to Environment,
 Measurement and Monitoring of key environmental performance indicators,
 Environmental performance of the organization indicating continual improvement,
 Communication(s) from external interested parties (including complaints).
 Review of previous meeting regarding Energy Efficiency matters,
 Significant Energy Use Aspects,
 Suitability of Policy related to Energy Efficiency,
 Energy Efficiency Objectives and Targets as well as their associated programs and the extent to
which these have been met,
 Changing circumstances, including developments and compliance in legal and other
requirements related to the Energy Efficiency,
 Training related to Energy Efficiency,
 Measurement and Monitoring of key energy efficiency performance indicators (reference is
made to SEEMP),
 Energy Efficiency performance of the organization indicating continual improvement,
 Communication(s) from external interested parties (including complaints),
 Verification of implementation of Energy Efficiency program and action plan on an annual
basis,
 Future energy performance matters,
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 Results of energy efficiency awareness campaigns implemented during the previous year.
Decision upon and initiation of new campaigns for the next year, on an annual basis.
All Office Department Managers have the responsibility to prepare reports, which summarize the
work in their respective areas with regard to the performance of the Integrated Management
System.
2.8 RECORDS OF MANAGEMENT REVIEW MEETINGS

The S&Q Department is responsible for keeping Minutes of the Management Review Meetings.
The cover page must be signed by all attendees.
The Management Review Meetings Minutes are found in the electronic “Archive Data Base” and
are accessible to all.
The MRM Minutes are forwarded to all Fleet Vessels, for their review and discussion.
3. RECORDS
Departmental Presentations saved in Archive (Electronic file, organized per YEAR /QUARTER)
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MASTER’S REVIEW REPORTS Eff. Date: 30/09/2022
Contents
1. PURPOSE ..................................................................................................................................2
2. PROCEDURE ............................................................................................................................2
2.1 Subjects for Master’s Reviews................................................................................................2
2.2 Master’s Reviews Reports ......................................................................................................3
2.2.1 Master’s Brief Review Report (Form SF/SAQ/403) ................................................................................... 3
2.2.2 Master’s Overall IMS Review Report (Form SF/SAQ/402) ....................................................................... 3
2.2.3 Focused Review Processes .......................................................................................................................... 4
2.3 Office Procedure for the processing of Master’s Review Reports .........................................4
2.4 Established Time-Frame for Office Response to Master’s Review Reports ..........................5
3. RECORDS .................................................................................................................................5
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1. PURPOSE
This procedure describes the steps to be followed when carrying out the Master’s Review Process
of the Integrated Management System.
2. PROCEDURE
The Master is required to periodically review the Company Policies, Manuals and Forms and other
IMS Documents (i.e Circulars, Risk Assessments), report any identified deficiencies and make
recommendations for the correction/improvement of the IMS, with the aim to improve its
robustness and effectiveness.
All Shipboard Personnel (NOT only Masters and Officers) are encouraged to make
suggestions for correction /improvement of the IMS.
In particular, Senior Officers (besides the Master ) i.e Chief Officers, Chief Engineers, Second
Engineers and other Junior Officers and Cadets must be actively involved in the review of the IMS
and must contribute to its correction and/or improvement.
(TMSA Requirement- Element 1A KPI 3.2: “Instructions and procedures covering shore and vessel
operations are developed in consultation with those who will have to implement them”.
Shipboard Personnel must submit their suggestions to the Master.
The Master, in turn, must submit them to the S&Q Department for processing.
In such a case, the Master’s Review Report must include the names of both the proposing
Officer/Crew Member and the Master.
2.1 SUBJECTS FOR MASTER’S REVIEWS

The Master's Review Process includes the following
Annual Review On Office Request

001 - (IMSM) Integrated Management System & Policies. 12- (STM) SOLAS Training Manual.
002 - (PRO) IMS Procedures Manual. 13- (FTM) Fire Training Manual.
14- (PIW) Plans & Procedures for Recovery of
002A- (ISMS) Information Security Management Manual.
Persons from the water
003 - (SAF) Shipboard Safety Manual.
004 - (EMP) Emergency Procedures Manual. STS Manual.
005 - (MTN) Maintenance Manual. VOC Manual.
006 - (NAVM) Navigational & Mooring Manual. Emergency Towing Manual.
009 - (EMS) Environmental Manual. SEEMP Manual.
010 - (COM) Cargo Operations Manual – OT / CT & LPG Risk Assessment
IMS Forms & Circulars Mooring System & Line Management Plan
Oil Pollution Plans (SOPEP/SMPEP/VRP/CCP/ PCSOPEP )
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Other Issues for review may include:

 Crew Matters, Familiarization Procedures and other Onboard Training.
 Risk Assessments, Work Permit Procedures.
 Safety, Security and Information Security Issues.
 Supply of Provisions, Spares and Stores (Quantities, Delivery Time, Quality)
Complaints from Customers (i.e. Charterers, Receivers etc.), Terminals
 MLC 2006 issues, including Mental Health.
 Issues related to other Quality Standards adopted by the Company (i.e ISO 14001, ISO 50001
etc).
 Any other proposals and Suggestions.
2.2 MASTER’S REVIEWS REPORTS

For this reporting, two (2) ISM Forms are available:
2.2.1 Master’s Brief Review Report (Form SF/SAQ/403)

On joining the Vessel, the Master and his Officers must review, in a very short period, some
Procedures/Manuals/Forms in order to be able to meet everyday requirements and reporting.
It is understood that due to other responsibilities, the review will be performed in stages.
During these Periodical Reviews, the Master and Officers may identify deficiencies of the IMS
(even minor) and propose corrective action or they may submit suggestions for improvement.
In such cases, Form SF/MRS/403-“Master’s Brief Review Report must be completed.
This report refers to specific Procedures, Forms, Circulars etc, and not to the entire IMS System.
The use of this report is optional and unlimited (The Masters, Officers and Crew may as many
such reports as they wish.
However, every effort must be made to submit at least one (1) such Report, either identifying
deficiencies in the IMS, or making suggestions for improvement, in order to avoid negative
observations during SIRE 2.0 inspections.
2.2.2 Master’s Overall IMS Review Report (Form SF/SAQ/402)
Each Master must submit Form SF/SAQ/402-“Master’s Overall IMS Review Report”, at least
once during his service, and this must be a review of the entire IMS system.
This report is Mandatory and must be completed and submitted to the S&Q Department, before
the Master signs-off.
If the Master has not submitted any Master’s Brief Review with suggestions for improvement or
correction of the IMS during this service, he must include such proposals in the Master’s Overall
IMS Review Report, in order to avoid negative observations during SIRE 2.0 inspections.
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2.2.3 Focused Review Processes
In order to organize the IMS Review Process onboard, the S&Q Department issues a “Focused
Review Plan”, clearly defining the subject of each Focused Review.
Such a Focused Review Plan must ensure that within a period of twelve (12) Months all the IMS
Manuals and/or other related IMS Documents i.e Forms, Risk Assessments, Circulars, are
reviewed by the Masters and Officers onboard.
Oil Pollution Plans are also included in the “Focused Review Plan” as required by TMSA.
The Focused Review Processes, must have a defined duration i.e one-two months.
An extension period may be granted, per case.
The S&Q Department is responsible to collect the proposals submitted by the Masters and Officers
in the context of each Focused Review Process and record them in Summary Tables.
On the due date of each Focused Review process, these Summary Tables are submitted to the
relevant Department(s) for review, and comments.
The results of the Focused Review Processes are circulated to the Vessels and Office.
The accepted proposals for corrections and improvement are inserted in the IMS during the next
IMS Amendment Processes.
2.3 OFFICE PROCEDURE FOR THE PROCESSING OF MASTER’S REVIEW REPORTS
The review of Master’s Review Reports is the responsibility of ALL Office Departments
concerned.
The S&Q has the role of the coordinator, processor and record-keeper.
A. The Master’s Review Reports are processed through the ERP-Document Control Module, which
is continuously monitored by the S&Q Department, for any new incoming Reports.
B. The S&Q Department maintains “REPORT CONTROL TABLES”, per Master /Vessel, where
the Master’s Review Reports are recorded.
These Report Control Table are continuously updated, whenever there is a change (i.e when a
new Master’s Review Report is received).
They provide a quick summary of all Master’s Review Reports submitted by each Master on the
specific Vessel and the relevant Office Response.
C. The S&Q Department reviews the Master’s Review Reports, and takes action depending on the
cases below:
a. If the proposals in the Master’s Review Reports are related to typing mistakes or minor
inconsistencies of IMS Documentation and do not involve important changes in
Procedures and Forms, the S&Q Department may immediately respond to the Master
through an Official e-mail.
b. If the Master’s Review Reports are related to ISM Documents (Procedures, Forms, Risk
Assessments and Circulars) of the S&Q Department, the S&Q Manager may decide to
Page 4 of 5
(002) Revision: 07
accept or reject, after consultation with the other members of the S&Q Department and
COO/DCOO, the DPA and any other relevant Department and respond accordingly.
c. If the contents of the Master’s Review Reports are related to IMS Documents of other
Office Departments, they are distributed by e-mail to the relevant Departments for
review with CC to the proposing Master/Vessel.
In this case, the S&Q Department, sends an Initial Office Response/acknowledgement
of receipt by e-mail to the Master, having attached, the Report Control Table as well as
any e-mails submitted to the relevant Departments.
d. If the proposed changes are relevant to serious mistake or omissions to Safety related
Procedures and /or Checklists, then they are processed immediately and all Fleet Vessels
are notified.
D. The Office Response e-mail, is uploaded in the ERP, attached to the relevant Masters’ Review
Report (also including the Report Control Table, the e-mails sent to the relevant Departments
and any feedback received from them at the time of the Office Response).
E. All the “Report Control Tables” per Year/per Vessel /per Master are available in the ERP as
well as in the electronic Filing system of the S&Q Department.
For each Master’s Review Report which has been processed by the S&Q Department, the following
documents must be found attached in the ERP –Document Control Module:
o Report Control Table listing all Master’s Review Reports per Master/Vessel.
o The Office Response e-mail(s) sent by the S&Q Department.
o The e-mails which have been sent to the relevant Departments having attached the Master’s
Review Reports (if applicable).
o Any feedback received from other Departments, on the Master’s Review Reports (if
applicable).
2.4 ESTABLISHED TIME-FRAME FOR OFFICE RESPONSE TO MASTER’S REVIEW REPORTS
The established Time-Frame for the Response to the Master’s Review Reports
is fifteen (15) calendar days.
3. RECORDS
 Master’s Overall IMS Review Report PRO/PRO 13/ SF/SAQ/402

 Master’s Brief Review Report PRO/PRO 13/ SF/SAQ/403
 Report Control Table PRO/PRO 13/ OFF/SAQ/407
Page 5 of 5
Prime Tanker Management Inc. PROCEDURE 14
IMS Procedures
(002) ACCIDENTS, INCIDENTS, NEAR MISSES, Revision: 14
FIRST AID CASES, BEHAVIOURAL SAFETY Eff. Date: 30/09/2022
Contents
1. PURPOSE .................................................................................................................................. 3
1.1 Definitions of Accidents & Incidents .....................................................................................3
2. SHIPBOARD PROCEDURES .................................................................................................. 4
2.1 Accident /Incident Reporting to the Company .......................................................................4
2.2 Master’s Initial Verbal Notification to the DPA .....................................................................4
2.3 Master’s Initial Written Notification ......................................................................................4
2.4 Master’s Notification to the Flag Administration ...................................................................5
2.4.1 Marshall Islands ..................................................................................................................5
2.4.2 MPA-Singapore ..................................................................................................................7
2.5 Notification to Third Parties ...................................................................................................8
2.6 Initial Investigation Onboard ..................................................................................................8
2.7 Onboard Periodic Training in Incident Investigation .............................................................9
2.8 Safety Meeting following an Accident or Incident .................................................................9
2.9 Record Keeping Onboard ..................................................................................................... 10
3. OFFICE PROCEDURES ......................................................................................................... 10
3.1 Company Notifications to Third Parties ............................................................................... 10
3.2 Prompt Notification to all Fleet ............................................................................................ 11
3.3 Incident Investigation Committee .........................................................................................12
3.4 On Scene Investigation .........................................................................................................12
3.5 In Office Investigation Process ............................................................................................. 13
3.6 Incident Methodology ........................................................................................................... 15
3.6.1 Root Cause Analysis ..........................................................................................................15
3.6.2 “5 WHYs”.......................................................................................................................... 17
3.6.3 Causal Factors / Root Causes ............................................................................................ 18
3.6.3.1 Unsafe Conditions ..............................................................................................................18
3.6.3.2 Unsafe Acts ........................................................................................................................ 18
3.6.3.3 Job Factors.......................................................................................................................... 19
3.6.3.4 Personal Factors ............................................................................................................... 19
3.6.3.5 Factors beyond Company Control......................................................................................20
3.7 Incident Investigation –Review Meeting and Incident Report ............................................. 21
3.8 Corrective and Preventive Action .........................................................................................21
3.9 Time Frame for Completion of the Investigation and Corrective and Preventive Action ....22
3.10 Accident /Incident Investigation Training and Refresher Training of the “Investigation
Committee” ....................................................................................................................................22
3.11 Lessons Learnt Shared across the Fleet ............................................................................. 23
3.12 Re-training after a Serious Accident /incident ..................................................................24
3.13 Lessons Learnt /Shared with Industry Groups and Oil Majors Vetting Departments .......24
3.14 Accident / Incident Case Studies ......................................................................................25
3.15 Record Keeping .................................................................................................................25
4. OCIMF MARINE INJURY REPORTING FORMAT ............................................................ 26
4.1 Lost Time Injury Frequency (LTIF) ..................................................................................... 26
4.1.1 Total Recordable Case Frequency (TRCF) ...................................................................... 26
4.1.2 OCIMF Definitions...........................................................................................................26
5. NEAR MISSES ........................................................................................................................ 27
5.1 Definition ..............................................................................................................................27
5.2 “Just Culture” Approach ....................................................................................................27
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IMS Procedures
5.3 The Near Miss Investigation Process ....................................................................................28

5.3.1 Shipboard Procedure.........................................................................................................28
5.3.2.1 Serious Near Misses .......................................................................................................28
5.3.3 Office Procedure ................................................................................................................ 29
5.3.3.1 Routine Near Misses ...................................................................................................... 29
5.3.3.2 Serious Near Misses .......................................................................................................29
6. FIRST AID CASES REPORTS ............................................................................................... 30
7. BEHAVIOURAL SAFETY REPORTS .................................................................................. 31
8. SEAFARERS’ NOTEBOOKS ................................................................................................. 32
9. INJURY- FREE DAYS ............................................................................................................ 33
10. S&Q DEPARTMENT PROCESSING .................................................................................... 33
11. DRUG & ALCOHOL TESTS FOLLOWING A SERIOUS MARINE INCIDENT............... 34
12. MARSHALL ISLAND REQUIREMENTS ............................................................................ 34
12.1 Retention of Voyage Records ............................................................................................ 34
13. INFORMATION SECURITY INCIDENTS ........................................................................... 35
13.1 Definition ...........................................................................................................................35
13.2 Incident Management ........................................................................................................ 35
13.3 Employees Actions ............................................................................................................37
14. RECORDS ............................................................................................................................... 38
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IMS Procedures
1. PURPOSE
This procedure describes the process which must be followed by Office and Shipboard personnel for
the analysis of Accidents, Incidents and Serious Near Misses which take place onboard.
As per requirements of ISM Code - §9: “All the Accidents and Near Misses (hazardous occurrences)
must be reported, analyzed, corrective action must be taken and the experience must be distributed
throughout the Company”.
1.1 DEFINITIONS OF ACCIDENTS & INCIDENTS
Accident : An uncontrolled or unplanned event, or sequence of events, that results in a fatality or

(Injury) injury to a seafarer(s) or 3RD Party onboard or whilst ashore on company business
(Terminal, Pilot Station, STS Location etc).
Incident : An occurrence when there is damage to property, machinery, pollution or spillage of

cargo or bunkers, environment or property An event, or sequence of events, which has
occurred directly in connection with the operation of a ship that endanger, or if not
corrected, could endanger the safety of a ship, its crew or any other persons or the
environment and / or property.
 Fire  Mooring Incident
 Explosion  Hazardous Material release/involved
 Collision  Loss of Primary Containment**
 Allision  Oil Spill in water
 Grounding  Oil Spill onboard
 Flooding  Cargo Transfer
 Steering Failure  Ballast Transfer
 Machinery Failure  Heavy Weather Damage
 Lost or reduced power  Ice Damage
 Lost or reduced propulsion  Fire-Fighting Equipment Failure
 Electric Power Failure/ Black-out  Jetty Contact
 Structural Failure  Security Incident
 Damage to Navigation Aids  Information Security Incident
 Any other
Any accidents, damage or suspected damage to other Vessels or property which have been caused by the
Vessel or its personnel. (I.e Contact with Bridges, Jetty contact, damage to Buoys etc).
** Loss of Primary Containment is defined as an unplanned or uncontrolled release of material from

primary containment, including non-toxic and non-flammable materials (e.g., steam, hot condensate,
nitrogen, compressed CO2 or compressed air).
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IMS Procedures
2. SHIPBOARD PROCEDURES
2.1 ACCIDENT /INCIDENT REPORTING TO THE COMPANY

All Accidents, Incidents and Serious Near Misses which occur onboard must be reported to the
Company.
These events include:
 All Accidents (Injuries / Fatalities), as per “OCIMF Marine Injury Reporting” Categories.
 Incidents causing damage to Assets i.e the Ship, Equipment & fittings or Third Party property.
 Incidents causing Environmental impact i.e Cargo or Bunker spillage, Leakage or
Contamination and any other incident which results in Pollution.
 Incidents having an impact on Company reputation.
 Serious Near Misses (Hazardous occurrences).
Occupational Diseases are also subject to reporting and investigation. (MLC 2006-Regulation 4.3)
ALL Accidents (Injuries), Incidents and Serious Near Misses must be reported
to the Company as soon as possible, after the event.
( see analytical Matrix Table in PRO 14-Annex 2 of this Manual )
The Company requires from the Fleet Vessels’ Masters rapid notification of all the events detailed
above,
or any other urgent safety-related issues which occur onboard.
The Master is the person responsible to notify the Office on these occasions.
All Accidents, Incidents and Serious Near Misses must be the subject of an in-depth investigation
2.2 MASTER’S INITIAL VERBAL NOTIFICATION TO THE DPA

The Master must notify the Company by phone, as soon as possible, and later in writing, following
the Emergency Procedures, as found in Emergency Manual (004-Section 03-“Shipboard Emergency
Procedures”).
Incidents and Accidents must be reported DIRECTLY TO THE DPA who is the Office Emergency
Response Team (ERT) Coordinator and is responsible for the "call-out" of the Emergency Response
Team.
(refer to EMP Manual (004) –Section 02-Office Emergency procedures) and PRO 14-Annex 2 –
“Guide for Incident Notification & Reporting” of this Manual).
2.3 MASTER’S INITIAL WRITTEN NOTIFICATION

Following the initial Verbal notification, the Master must send an initial Written Report filling-in the
form “Emergency Reporting” (SF/SOS/001).
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IMS Procedures
Accident / Incident Report, following an Initial Investigation onboard.

The Accidents and Incidents must be reported to the Company in writing, using the following forms:
 Form SF/SAQ/405A-“Accident Report”
This form must be used for occurrences involving injuries or fatalities.
The reporting of Marine Injuries must always follow the OCIMF Marine Injury Reporting
categories (these categories are included in the guiding Accident and Incidents Forms).
 Form SF/SAQ/405B-“Incident Report”
This form must be used for occurrences:
o Involving damage to Assets i.e the Ship, Equipment & fittings or Third Party property.
o Having Environmental impact i.e Cargo or Bunker spillage, Leakage or Contamination
and any other incident which results in Pollution.
o Having an impact on Company reputation.
The two above Forms, have two (2) sections i.e:

 Section A - (To be filled in for Simple Accidents / Incidents – as per PRO 14- Annex 2)
 Section B - (To be filled in for Medium and High Risk Accidents /Incidents as per PRO
14- Annex 2 )
The Company must advise the Master of the nature of the investigation to be carried out i.e.
depending on the seriousness of the event.
(as per PRO 14-Annex 2- Guide for Incident Notification & Reporting).
In such a case, “Section B” of the above mentioned forms, must be filled in.
If there are witnesses, it would be helpful for the investigation to fill-in the form
SF/SAQ/406-“Voluntary Statement” with any additional information available.
Both forms include guiding questions for a complete investigation.
However, the forms, in no way restrict the Master from adding additional information as deemed
necessary.
The Forms include a list of the Documents, Photos and other Reports (i.e. Medical Reports,
Work/Rest Hours schedules, Onboard Alcohol Tests, First Aid provided etc.) which must be attached.
Additionally, the Forms include guiding tables, listing all possible Root Causes/Causal factors, in
order to facilitate the Investigation process.
2.4 MASTER’S NOTIFICATION TO THE FLAG ADMINISTRATION
2.4.1 MARSHALL ISLANDS

The Administration of Marshall Islands requires reporting within 24 hours after the event.
Promptly after submitting the Initial Notification to the Office Emergency Response Team (ERT), by
the Master (or the highest available Officer or Ship’s Representative) shall be forwarded to the Office
ERT the following Marshall Islands forms (per case) in order to report to the Administration of the
Republic of Marshall Islands (RMI).
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IMS Procedures
These forms are available on the CD and/or- under the electronic File “Marshall Islands”.
 MI-109- Report of Vessel Casualty or Accident form
 MI-109-1 - Report of Personal Injury or Loss of Life Form
 MI-109-2- Report of Piracy and Armed Robbery
 MI-109-3- Report on Stowaways
 MI-109-4- Report on Migrant Smuggling by Sea
 MI-105MR – Injury and Illness Medical Report
The DPA and the Department Managers (who are responsible for the Incident Investigations) must
review the above mentioned MI Reports, as sent by the Master, and then must forward them to the
Flag Administration at the e-mail below.
For Injuries ONLY, the MI Report will be forwarded to the Flag Administration by the S&Q
Department.
For all other Incidents, the MI Reports will be forwarded to the Flag Administration by the
Marine/Vetting Department.
A follow-up report to the Flag Administration must be filed whenever there is:
o Damage to property.
o Material damage affecting the seaworthiness of a Vessel.
o Collision, allision, stranding, grounding, abandonment or loss of Vessel.
o Severe damage to the environment.
o Fire or Explosion.
o Loss of Life.
o Injury causing any person to remain incapacitated for a period in excess of 72 hours,
including occupational accidents and occupational injuries and diseases, which may not
be limited to accidents or incidents involving the Vessel.
o Acts or attempted acts to Armed Robbery, Piracy, Hijacking or terrorism.
Reference is made to Maritime Regulations – Marine Investigations- Chapter 6.
The Initial Notification must be received by the Administration

within 24 hours following the casualty.
The report must be sent to the following e-mail address:
Emergencies : dutyofficer@register-iri.com
& investigations@register-iri.com
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IMS Procedures
2.4.2 MPA-SINGAPORE
The Administration of Singapore (MPA) requires reporting within TWO (2) hours after the event.
The Marine Accident or Marine Incident must be reported on form IVD-MSI– “Report of a Marine
Casualty or Marine Incident” (found as annex to Circular sc_no_8_of_2021)
When to use this Report
This Report must be submitted when a Ship:
 has sustained or caused an accident occasioning loss of life or serious injury to a person;
 has sustained an accident or received damage, or otherwise sustained a defect.
or deficiency in the ship or its equipment which has been discovered, and the accident,
damage, defect or deficiency has affected, or is likely to affect the seaworthiness of the ship,
or the efficiency or completeness of the life-saving appliances or other safety equipment of
the ship.
 has been in a position of great peril, either from the action of some other ship or
 from danger of wreck or collision, or
 has been stranded or wrecked.
Where to send the Report (include Crew List)
The Initial Notification must be received by the Administration

Within TWO (2) hours following the casualty.
The report must be sent to the following e-mail address:
Director of Marine
Maritime and Port Authority of Singapore
Shipping Division
460 Alexandra Road, #21 PSA Building
Singapore 119963
Emails where the Notification should be forwarded:
shipping@mpa.gov.sg
marine@mpa.gov.sg
ivd@mpa.gov.sg
mmo@mpa.gov.sg;
MPA Singapore requires the Initial Report to be submitted within 2 hours in the following format:
1. Type of incident (collision, grounding, fire, hull breach, death of a person, work accident, injury,
diseases, etc)
2. Pollution to environment (if any) (pollutant-type & amount spilled)
3. Date and time (in local time and time zone)
4. Location of incident (Lat, Long, etc.)
5. Injuries (number and severity) and/or damage (location & severity) and/or pollution (pollutant type &
amount spilled)
6. Current status of incident (e.g. under control/mitigation ongoing)
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IMS Procedures
2.5 NOTIFICATION TO THIRD PARTIES

The Notification of Third Parties is clearly defined in the Emergency Manual (004) - Emergency
Organization Chart ( Section 03) and in PRO 14- Annex 2- “Guide for Incident Notification and
Reporting”- of this Manual.
The Master must ensure that all Notifications as per SOPEP / SMPEP / VRP / NTVRP/PCSOPEP are
made.
For major Oil Pollution Incidents, special reporting requirements are also found in the Emergency
Manual (Section 03- Paragraph 2.4.4- “Reporting of Incidents involving Pollution”).
The Master must liaise with the DPA, the Technical Department, the S&Q Department, the
Operations Department, the Marine/Vetting Department and Legal Department (as necessary) in
order to notify all Third Parties concerned.
2.6 INITIAL INVESTIGATION ONBOARD
Following the initial notification to the Office, and the first actions taken to recover control,
the Master must initiate an investigation process.
The Initial Investigation must be conducted by the Master assisted by his Senior Officers.
However, the Investigation, when carried by Shipboard Personnel, must be conducted
by Officers who are independent of the specific Ship Department i.e
 The Master and Chief Officer must investigate an Engine Incident or
 The Chief Engineer must investigate a Deck Incident.
This initial investigation process must not be confused with the Official Investigation Process which
is initiated in the Office, by the Incident Investigation Committee.
This Initial Investigation which is carried onboard by Shipboard Personnel does not replace the
Investigation which must be carried in Office.
The Investigation process onboard is carried out in order to compile an Incident Report as accurate
as possible.
The Master must collect as much information as possible, through the Voluntary Statements of
witnesses.
Any possible breaches of Company or legislative requirements, if determined, must be reported.
Identification of the “Root Cause(s)” is very important.
Any other supporting evidence (Documents, Photos, Oil Samples etc) must be collected
immediately.
The Accident or Incident Report and any other supporting documentation must be forwarded to the
Company by e-mail attachments, as soon as possible, and as per PRO 14- Annex 2- “Guide for
Incident Notification and Reporting” of this Manual.
Later, they should be uploaded in the Company ERP.
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IMS Procedures
2.7 ONBOARD PERIODIC TRAINING IN INCIDENT INVESTIGATION

The Master, the Chief Officer/ Safety Officer, the Chief Engineer and the Second Engineer must be
able to effectively conduct an Investigation.
For this purpose these Officers receive relevant Training in Certified Training Centers and are
Holders of the relevant Certificate.
Moreover, Incident Investigation Training based on the Company’s Investigation Methodology
(i.e “Root Cause Analysis” and “5 WHYs”) is provided.
Additionally, the Company has provided the training CD IMO D311E- “Marine Accident and
Incident Investigation” to be viewed onboard.
In order to refresh Accident/Incident Investigation skills, all Senior Officers must periodically view
this CD. This is monitored by the Training Department, through the online Training Platform.
2.8 SAFETY MEETING FOLLOWING AN ACCIDENT OR INCIDENT

A Safety Meeting must be conducted after any serious incident or accident on board the vessel where
the Accident /Incident occurred and on all other Fleet Vessels.
(The Safety Meeting can be the Routine Monthly Safety Meeting or a Dedicated Safety Meeting,
provided that it is carried out within one week (7 days) after the Fleet Notification).
The Agenda items to be discussed at Shipboard Safety Meeting after an Incident or Accident must
be minimum:
 Description of the incident.
 Analysis of the incident.
 Root cause(s) leading to the incident.
 Corrective actions.
 Preventive actions.
 Proposed Training avoiding a recurrence.
 Review of the equipment, procedures, implementation etc which led to the incident, and
evaluation of the relevant status onboard their own Vessel.
These Safety Meeting Reports must be uploaded in the Company ERP
If the Accident /Incident is included in the Monthly Safety Meeting (Form SF/SAQ/401) this will be
reviewed by the S&Q Department who will respond to the Master, and notify the Office Departments
concerned, if it includes any suggestions for corrective /preventive actions or training.
If a Dedicated Safety Meeting is held (Form SF/SAQ/401A), then the relevant Department is
responsible to review it and comment on the validity of information provided as detailed below.
Marine/Vetting Department Marine Incidents
Technical Department Technical Incidents
S&Q Department Crew Injury or Work-related

Fatality.
(A reference is also found in the Safety Manual (003) –Section 03- Safety Meetings).
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IMS Procedures
2.9 RECORD KEEPING ONBOARD

All Documentation related to the Accident or Incident, must be filed in Master’s File -“Accidents
/Near Misses”, under a separator, for the specific event (i.e. the Accident /Incident report, Voluntary
Statements, Medical reports (in case of injuries), Alcohol Tests onboard, Photos, Work/Rest hour
reports, Work Permits, Copies of Deck Log Books, VDR Data, Reporting to the Flag
Administration etc- details lists of Data Required are found in forms SF/SAQ405A- & B).
The final Investigation Report, and the Report Control Table which are sent by the Office must also
be filed there-in.
During the IMS Internal Audits, this file is audited, in order to ensure that a complete Accident or
Incident “set” is readily available for review by any Internal or Third Party inspector.
Records of Accidents /Incidents must also be available in the ERP.
3. OFFICE PROCEDURES
3.1 COMPANY NOTIFICATIONS TO THIRD PARTIES

When an emergency occurs onboard, the Vessel’s Master must immediately notify the DPA, by phone
(followed later by a written report on the Company Emergency Format SF/SOS/001).
The DPA, who is the Head of the Office Emergency Response Team, is responsible for the
“Call-out” of the Emergency Response Team. The Members of the Emergency Response Team, will
assume their responsibilities in order to meet the Emergency.
The Members of the Emergency Response Team must liaise with the Master and notify all
Third Parties concerned (as per Emergency Manual- Section 02) i.e.:
Flag Administration Initially notified by the Vetting /Marine Department as per the Flag
Administration regulations.
The Master must submit the reports required, within 24 hours after the event, to
the Office for review, and then they will be forwarded to the Flag Administration
i.e
 S&Q Department will forward the MI Reports, in case of Injury.
 Marine/Vetting Department will forward the MI Reports for all other
Incidents.
Port Authorities, Oil
Notified by the Master.
Response Teams, QI
Charterers and Cargo
Initially notified by the Operations Department.
Owners
Oil Majors
Initially notified by the Vetting/Marine Department as per their requirements.
Classification Society
Notified by Technical Department.
Manning Agent
Notified by the Crew Department.
P&I, H&M
Notified by the Legal Department.
Fleet Vessels
Alerted by the Technical , or Marine/Vetting or S&Q Department
(Depending on the nature of the Incident).
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IMS Procedures
OCIMF Marine Incident Notified by the Marine/Vetting Department.

Database
3.2 PROMPT NOTIFICATION TO ALL FLEET

When an Accident/ Incident Report is received in Office (Verbal or Written), it is immediately
reviewed by the relevant Departments.
Depending on the nature of the Accident/Incident, the case is initially reviewed by Technical,
Marine/Vetting, Operations and S&Q Department.
If the Accident or Incident is very serious, the Emergency Response Team is summoned
immediately in order to meet the Emergency.
It is Company practice to promptly notify all the Fleet Vessels for these events,
(As per PRO 14-Annex 2- “Guide for Incident Notification & Reporting” of this Manual).
After the first actions have been taken to assist the Vessel’s Master and Officers in recovering
control, the Office must promptly make an Initial Notification to all Fleet Vessels
(OFF/GEN/020A), by e-mail, including a brief description of the event and a first evaluation of the
occurrence.
If required, the Master must be requested to provide additional information, photos, and other data.
When the additional data are received, a follow-up e-mail alert, must be forwarded to the Vessels at
a later time, by use of OFF/GEN/020B- “Incident Interim Update”.
The Fleet Notification Time frame is the following (as per as per PRO 14-Annex 2-“Guide for
Incident Notification & Reporting” of this Manual).
Incident RA Report Notification

Consequence Time frame
Low Risk Incidents “V” Incident Investigation Report or Within 30 days
Lessons Learnt Bulletin form –
within 30 days
Low Risk Incidents “IV” Incident Investigation Report or Within 30 days
Lessons Learnt Bulletin form –
within 30 days
Medium Risk “III” Immediate Incident Notification Within 72 hours
Incidents (OFF/GEN/020A)
High Risk “II” Immediate Incident Notification Within 72 hours
(OFF/GEN/020A)
High Risk “I” Immediate Incident Notification Within 24 hours
(OFF/GEN/020A)
Incident Interim Report
( OFF/GEN/020B)
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IMS Procedures
When the Accident/Incident Investigation is finalized, the Investigation report must be forwarded to
all Fleet Vessels for discussion during a Dedicated Safety Meeting, within a minimum of one week
(7 days). If the Routine Monthly Meeting is due within one week, then the discussion may be carried
out during the Routine Monthly Meeting (SIRE 2.0)
(Refer to below § 3. 11 “Lessons learnt, shared across the Fleet Vessels”).
3.3 INCIDENT INVESTIGATION COMMITTEE

Following any Emergency onboard, and after the initial actions have been taken by the Emergency
Response Team to assist the Shipboard Personnel in recovering control, the event must be fully
investigated and analyzed by an Office Investigation Committee.
3.4 ON SCENE INVESTIGATION
The Initial Investigation is conducted by the Master assisted by his Senior Officers in order to
compile an Accident or Incident report, as accurate as possible.
For a more detailed Investigation on scene, the DPA is responsible to appoint the Investigator.
The person appointed to conduct an in-depth investigation (Leader of Investigation) must not be
connected with the incident.
Only experienced persons having received training in Incident Investigation Techniques and having
the necessary expertized knowledge are allowed to lead an investigation.
These person may be the Department Managers, Fleet or Ship Managers, Marine/Vetting
Superintendents, Vessel Personnel or a Person completely independent of the Ship with the
proper qualifications.
The DPA, in cooperation with the Incident Investigation Committee may assign the Investigation to
a specialized Third Party Investigator as per PROC 14 – Annex 2.
(Depending on the severity and the impact of the incident, on safety of Crew, Vessel, Environment
and the Company Reputation).
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IMS Procedures
3.5 IN OFFICE INVESTIGATION PROCESS
For simple events, the Investigations are conducted as follows :

S&Q Department Investigates Injuries to Personnel.
Crew Department Investigates Natural Death Cases and Illnesses.
Marine /Vetting Department Investigates Marine Incidents
(Navigational, Mooring, Oil Pollution).
Technical Department Investigates Technical Incidents / Breakdown /Failure of
Machinery.
Operations Department Investigates Incidents related to Cargo and Ballast transfer.
CSO/ A-CSO Security Incidents and participation in Information Security
Incidents (as required).
ICT Department Investigates Information Security Incidents
Members from other Departments may also participate in all above investigation processes, as
required. Records are maintained by each Department, depending on the nature of the Incident.
For serious events, the “Incident Investigation Committee” is summoned.

This committee is formed by (depending on the nature and severity of the event):
 The DPA and/or Alternate DPA.
 The Technical Manager and the Technical Superintendent(s).
 The Vetting/Marine Manager, and Marine Superintendent(s).
 The Operations Manager and Vessel Operator(s).
 The S&Q Manager & an ISM Auditor(s).
 The Crew Manager and Crew Operator(s).
 The Company Security Officer and the Alternate Security Officer (for Security Incidents).
If required, additional members may be invited to participate i.e
 Shipboard Personnel.
 3rd Party Contractor Staff.
Particularly for serious Information Security Incidents the “Incident Investigation Committee” is
formed by (depending on the nature and severity of the event):
 The ICT Manager.
 Members of the ICT Department.
 Ad-hoc third party consultants and experts at the discretion of the ICT Manager.
Other Members of the aforementioned Departments may also participate, assisting in the
Investigation process.
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The Training Department shall ensure that all times at least four (4) members of the Incident
Investigation committee must have received Investigation Training in recognized Training Centers.
One of the Members of the Accident / Incident Investigation Committee must be assigned the role
of the “Leader of the Investigation”.
The Leader of the Office “Accident /Incident Investigation Committee” must be trained and
experienced.
He must either be a Manager or a person which has participated effectively in Incident
Investigations (at least three (3) within a 2-years period) and must have been well appraised for
his/her performance in this activity.
(This item is included in the Office Staff Appraisal Report.
(Form OFF/GEN/002- “Appraisal Report for Office Staff”).
Third Party Investigators who are appointed to carry out an Incident Investigations should
have the following qualifications:
 For Marine Incidents: Shipping Academy Graduate, Master Mariner with at least 7 years of
sea experience in total on Tankers or Gas Carriers and with at least five (5) years of
experience the Incident Investigation process.
 For Technical Incidents: Chief Engineer on Tankers or Gas Carriers with at least 7 years of
sea service or Engineering University Degree and with at least five (5) years of experience
the Incident Investigation process.
 For Information Security Incidents: Information Security Certifications (e.g. CISSP, CEH,
CCI, GIAC Certified Forensic Analyst) and with proven experience on the Information
Security Incident Investigation process.
It must be stressed that the Company, adopting the principles of the ISM Code has developed a Just
Culture.
The reason of an investigation is not to identify and then apportion the blame, but to identify the Root
Cause(s) and take corrective actions to prevent re-occurrence and to establish new safety processes
and controls.
Guiding Publications are available onboard and in Office to be referred to for guidance in the
Accident/Incident Investigation process i.e
 OCIMF Marine Injury Reporting Guidelines
 Resolution MSC.255 /84 / Casualty Investigation Code
 Resolution MSC A.1075( 28) Casualty Investigation Code
 The Mariner’s Role in collecting evidence (in light of ISM) – “The Nautical Institute”.
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3.6 INCIDENT METHODOLOGY
All Investigations must be conducted in a structured and systematic manner.

The methodology of the Investigation Process is
“ROOT CAUSE ANALYSIS” supported by “5 WHYs” TECHNIQUE.
3.6.1 ROOT CAUSE ANALYSIS

Root Cause Analysis is a “tool” used for identifying the underlying Root Cause(s) which resulted in
an Incident, Accident or Near Miss or other event.
Root Cause Analysis refers to the causes which are beneath the surface of an event and not only
the one main cause which is immediately obvious.
Focusing on a single cause can limit the solutions set, resulting in missing better solutions.
The Root Cause (s) might be much deeper than outward symptoms identified, and several layers may
have to be pushed aside to reach the true ROOT" cause.
Having identified the Root Cause(s), the Company must take appropriate actions, on all levels to
eliminate or reduce re-occurrence.
In order to make an effective Root Cause Analysis, it is important to know the difference between a
Root Cause and a Causal Factor.
Root Cause: Is a factor, which if removed, will prevent the event/problem from re-occurring.
Causal Is a factor that affects the outcome of an event /problem, which if removed will
Factor: not prevent its re-occurrence with certainty.
The Company has adopted the “Comprehensive List of Causes”, which is found in Annex 1 of
this procedure and is a useful tool for Root Cause Analysis.
The Root Cause Analysis includes the following basic questions:
 What's the problem?
 Why did it happen?
 How did it happen?
 What is the Root Cause?
 What must be done to correct the problem?
 What must be done to prevent re-occurrence?
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The steps to be followed in the Root Cause Analysis are:
Identification of the Document the type/ severity of the problem.

Problem
“What is the problem?”
Collection of Data Start collecting any evidence which is required.
“How did it happen?” The “5 WHYs” Technique is very useful at this stage, since it covers
the questions: WHO/ WHAT/WHERE/ WHEN/WHY/HOW.
Analysis Phase Identify the critical factors.

Use the “Comprehensive List of Causes” of Annex 1 of this procedure
“Why did it happen?” to identify :
 unsafe actions
 unsafe conditions
 Direct causes
 Underlying causes
 Personal Factors
 Job Factors
 Factors beyond Company Control
Continue with the “5 WHYs” focusing on “WHY” causes.
Stop the “5 WHYs”, when the answer is something which the Company
cannot control or influence.
Root Cause Determine which factors are Root Causes and not just causal factors/
Identification symptoms.
“What is the ROOT If any cause accounts for more than 70 % of causal factors,
Cause(s)? (As a result of the “5 WHYs”) it can be considered as a Root
Cause.
Keep in mind that the Root Causes may be multiple – not just
one.
Corrective Actions Identify the corrective actions which are necessary in order to solve
“What must be done to the specific problem.
correct the problem?”
Preventive Actions Identify preventive actions / solutions that will help the problem from
“What must be done to re-occurring and causing more problems.
prevent re-occurrence?”
Implementation and Implement the corrective and preventive actions and follow-up until
Follow up completion. Evaluate their efficiency.
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Below is a list of tools that may be used to conduct a root cause analysis.
Ideally, a combination of tools below should be used i.e
• Brainstorming.
• Checklists.
• Logic/Event Trees.
• Timelines.
• Sequence Diagrams.
• Causal Factor Determination.
3.6.2 “5 WHYS”
The “5 WHYs” is a repetitive interrogative technique used to explore the cause and effect
relationship underlying a particular problem.
The primary goal of this technique is to determine the Root Cause

by repeating the question “WHY” five (5) times, or more, if necessary.
Each answer forms the basis for the next question.

The questioning could be taken further to a sixth, seventh or higher level, but five (5) “WHY”
repetitions has been determined as a satisfactory “Rule of Thumb”, in order to reach a Root Cause.
The investigator must avoid making assumptions and falling into logic “traps”.
He must trace the chain of causes, which may originally seem irrelevant by still have some connection
to the original problem.
The most important aspects in the Root Cause Analysis and the 5 WHY” approach is that the real
Root Cause must point toward a Process that is not working well or does not exist.
The key phrase to keep in mind in any investigation is “People do NOT fail – Processes DO”
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3.6.3 CAUSAL FACTORS / ROOT CAUSES
3.6.3.1 UNSAFE CONDITIONS

Inadequate guards or barriers Inadequate ventilation
Inadequate or defective PPE Hazardous environmental conditions
Inadequate number of equipment/tolls etc Material failure
Defective equipment ,machinery /tools Bunkers and /or lub oils
Hull or structural operation Port and berthing facilities
Inadequate warning system Cargo
Adverse weather condition Other substantial conditions
Adverse sea condition High or low temperature
Poor housekeeping Electrostatic hazards
Congestion or restricted action Piracy activities
Inadequate or excess illumination Design fault
Fire and explosion hazards Out dated charts, publications and other documents
Noise or temperature exposure Radiation exposure
Inadequate number of spares
3.6.3.2 UNSAFE ACTS

Failure to follow rules and regulations Inappropriate behaviour /Horseplay
Failure to use PPE properly Under the influence of alcohol/drug
Operating equipment without equipment Sabotage, wilful damage
Incorrect use of equipment or machinery Suicide / Homicide
Using defective equipment or machinery Other substantial acts
Failure to follow repair /maintenance instruction Inadequate communication
Incorrect navigation or ship handling Inadequate familiarization
Failure to warn Record keeping
Failure to secure Failure to follow procedures
Making safety devices inoperative Improper inspection
Improper position for task
Improper lifting, handling or storage.
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3.6.3.3 JOB FACTORS

Unclear or conflict assign of response Communication needs
Improper or insufficient delegation Inadequate evaluation of changes
Giving inadequate policy/procedure/practice Inadequate standards or specifications
Inadequate work planning/program Inadequate adjustment /repair/maintenance
Inadequate or improper controls Inventory & evaluation of exposure & needs
Inadequate performance measure and evaluation Procedures/practices/rules
Inadequate instruction, orient &/or train Training
Inadequate consideration of human factors Inadequate standards of maintenance
Improper handling of materials Monitoring use of procedure/practices /rules
Inadequate standards, specs &/or design criteria Inadequate monitoring of compliance
Inadequate assess of operation readiness Inadequate planning of use
Inadequate monitoring or initial operation Inadequate inspection &/or monitoring
Inadequate specifications on requisitions Inadequate maintenance
Inadequate receiving inspection & acceptance Use by unqualified or untrained people
Improper storage of materials Inadequate tools or equipment
Inadequate identification of hazardous materials Inadequate work standards
Inadequate preventive maintenance Inadequate or absent procedure
Scheduling work Excessive wear & tear
Inadequate assessment of needs & risks Inadequate engineering
Inadequate Leadership/supervision Lack of Supervision
Lack of proper Attention Lack of supervisory/management / job know
3.6.3.4 PERSONAL FACTORS

Restricted range of body movement Poor judgment
Vision deficiency Poor coordination
Hearing deficiency Slow reaction time
Other sensory deficiency Low learning aptitude
Respiratory incapacity Memory failure
Fears and phobias Injury or illness
Fatigue/stress due to task load Mental illness
Fatigue due to lack of rest Lack of experience
Exposure to health hazards Inadequate initial training
Exposure to temperature extremes Inadequate update training
Oxygen deficiency Misunderstood directions
Atmospheric pressure variation Inadequate initial instruction
Drugs and/or alcohol Inadequate practice
Emotional overload Infrequent performance
Inappropriate aggression Lack of coaching
Improper attempt to save time/effort Inadequate review instruction
Improper attempt to gain attention Lack of knowledge/training
Inadequate discipline Improper Motivation
Improper supervisory example Negligence
Inadequate performance feed back Lack of motivation
Improper production incentives Lack of attention
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3.6.3.5 FACTORS BEYOND COMPANY CONTROL
Actions of 3RD Parties i.e Cargo Masters , Pilots, Port Personnel, etc
For a more detailed Root Cause Analysis, refer to PRO 14-ANNEX 1 of this Manual.
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3.7 INCIDENT INVESTIGATION –REVIEW MEETING AND INCIDENT REPORT

The appointed Accident / Incident Investigation Committee must hold a "Review Meeting"
as soon as all the information is made available and initiate an Investigation process based on the
Masters’ Initial Investigation Report, Voluntary Statements and any other information available
(VDR, Deck Log Book entries etc).
The "Review Meeting" may be part of the Weekly “Fleet Coordination Meeting”, which has been
scheduled immediately after the incident or may be a dedicated Review Meeting, carried as soon as
possible, for very urgent cases.
The "Review Meeting" by the "Accident/Incident Committee" must determine:
 The Loss (extent and impact).
 The Root Cause of the Accident / Incident or Serious Near Miss and any other contributory
factors.
 Any breaches of Regulations or Legislative requirements.
 Environmental Impacts.
 The necessary corrective actions and preventive actions which must be taken to avoid future re-
occurrence.
 The persons responsible for the Corrective and Preventive Actions.
 The time scale for closing the Corrective and Preventive Actions.
 The Third Parties which must be notified.
 Any additional Training, Safety Campaigns, Additional Internal Audits required etc
 Any Amendments to the IMS, if required.
The Accident/Incident Investigation Report (OFF/GEN/020 or OFF/TEC/106) must include
sufficient detail to accurately establish the root cause(s) of the incident.
It must be issued, and signed by the Members of the Accident/Incident Committee and by the DPA.
For Accident/Incidents which are High Risk Cases (Risk Assessment consequences III, II, I), the
Chief Operating Officer (COO) or Deputy COO must review and approve the Final Accident
/Incident Report.
Particularly for Information Security Incidents the Accident/Incident Investigation Report is issued
and signed by the Members of the Accident/Incident Committee, reviewed and approved by the ICT
Manager. For High Risk Cases it is reviewed and approved by the ICT Manager and the COO.
The Accident/Incident Investigation Report must be forwarded to all Fleet Vessels by e-mail and
should be discussed during the next Routine Monthly Safety Meeting, for “Lessons Learnt”.
Any corrective /preventive actions which must be taken fleet wide, must be monitored and verified
for each Vessel.
3.8 CORRECTIVE AND PREVENTIVE ACTION

The Accident/Incident Investigation Committee must identify any Corrective and Preventive Actions
which are required to avoid re-occurrence and to include them in the Report.
These actions may be specific for the Vessel, on which the accident or incident has occurred, but in
the majority of cases, actions are taken fleet-wide, as a preventive measure.
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The Office Department who is responsible to carry out the Investigation (as per § 3.5–“In Office
Investigation Process”) is responsible to monitor the corrective/preventive actions, and ensure their
close-out within set time –frame, on each Vessel (see below § 3.9)
3.9 TIME FRAME FOR COMPLETION OF THE INVESTIGATION AND CORRECTIVE AND PREVENTIVE
ACTION
Time Frame for the completion of the Incident Investigation Report One (1) Month
If for various reasons, a full Incident Investigation Report cannot be finalized, then within the time
frame of one (1) month, a “Preliminary Incident Investigation Report” must initially be issued, and
the Final Incident Investigation Report, must be issued later, at a determined date.
Time Frame for the completion of all Corrective Actions following an Three (3) Months
Incident
If the target date cannot be met, the DPA must be notified of the justified
reasons for not meeting the target date, and a new target date must be
established.
3.10 ACCIDENT /INCIDENT INVESTIGATION TRAINING AND REFRESHER TRAINING OF THE

“INVESTIGATION COMMITTEE”
All members of the Accident/Incident “Committee” must have received Incident Investigation
training, in recognized Training Centres.
However, it is the Company’s Policy to train all Office Department Managers, Department
Operators, Fleet Managers, Marine and Technical Superintendents etc in Accident/Incident
Investigation, based on the Company’s Investigation Methodology (i.e “Root Cause Analysis “ and
“5 WHYs”).
(Refer to Form OFF/GEN/009B- “Position Minimum Training Requirements”).
In addition to the Training Sessions carried out in the Company’s Training Center, Seagull CBT
Training must also be carried out i.e
 CBT 306- Cause and Effect
 CBT 307- Incident Investigation Techniques
This knowledge must be passed on to other relevant Shore-based and Ship-based Management
Teams. When new Senior Staff are recruited (Department Managers, Ship Managers, Vessel
Operators) they receive appropriate Accident/Incident Investigation In-house Training, by already
trained Shore staff.
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Accident/ Incident Investigation Training must be supported by practical experience.

Personnel who have received training are required to participate in Investigation Processes in order to
practice and acquire the relevant skills before being expected to lead an investigation.
The Leader of the Investigation Committee must :
 Be a Holder of an Incident Investigation Certificate.
 Have participated in an adequate number of Incident Investigations- at least three (3) within a
2-years period in order to have experience in the Investigation process and has been well
appraised for his/her performance/effectiveness in this activity.
Refresher Training on Accident /Incident Investigation must be carried out

Every five (5) years.
This is monitored by the Training Department.
3.11 LESSONS LEARNT SHARED ACROSS THE FLEET

The lessons learnt from Accident, Incidents and Serious Near Misses are shared across the Fleet as
follows:
 Initially, an “Alert e-mail” must be sent out to all the Fleet Vessels (and distributed
electronically to all Office Staff) for prompt notification. (Form OFF/GEN/020A)
The Vessels’ Masters are instructed to discuss this “Alert e-mail” during a Routine Monthly
Safety Meeting or a Dedicated Safety Meeting as long as it is carried out within one week
(7 days).
Depending on the seriousness of an occurrence, a dedicated Safety Meeting (Form
SF/SAQ/401A), for the particular event, may be requested by the Office, to be carried out
immediately after the notification.
Depending on the case, before the incident investigation is finalized Interim Updates may be
sent to the Fleet Vessels (Form OFF/GEN/020B), by e-mail to be discussed.
 When the Incident Investigation Report is finalized, it is circulated to all Fleet Vessels for
discussion during the next Routine Monthly Safety Meeting (Form OFF/GEN/020C).
 If fleet-wide corrective and preventive actions are necessary, these are monitored, until their
close-out, on each Vessel.
 Incident Trends must be identified and communicated to the Fleet Vessels ( Form
OFF/GEN/020D)
 All Accident / Incident Investigation Reports must be circulated to the Fleet Vessels, through
Circulars, Alerts and Bulletins, and must also be uploaded in the ERP, in the relevant Module
“Accidents List”.
 Lessons learnt from Accidents and Incidents are discussed during the Officers/Ratings
Conferences, which are organized annually as a minimum.
 Lessons learnt from Accidents/Incidents and Exercises are incorporated in the Contingency Plans
and Emergency Manuals.
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 Lessons learnt from Accidents/Incidents are fed back into the system in order to improve and
update the related Risk Assessments. The Risk Assessment process aims to reduce the risk of any
re-occurrence or related incident.
 Actual Marine Incidents which occur on Fleet Vessels are incorporated in the Training Center’s
Bridge Simulator, as Case Studies, for training purposes.
 Where appropriate, lessons learnt from accident/ incidents may be shared with the Marine
Industry (i.e ITOSF). (Refer to paragraph 3.13 below).
All the Accidents, Incidents and Serious Near Miss are discussed and further analyzed during the
Quarterly Management Review Meetings.
During these Management Review Meetings, similarities between incidents and trends must be
discussed.
The corrective and preventive actions taken after each incident must be evaluated for their
effectiveness and Actions Plans must be established to improve the Company’s IMS, Emergency
Procedures and Checklists.
3.12 RE-TRAINING AFTER A SERIOUS ACCIDENT /INCIDENT

Senior Officers who are involved in a serious Accident/Incident should be invited to Head Officer for
de-briefing and re-training.
The invitation, as well as the nature and duration of the training shall be decided by the Training
Manager, based on the conclusions of the Accident/Incident Investigation Report.
All relevant means of the Company’s Maritime Assessment and Training Center, will be used during
this training session i.e. Bridge, Cargo, ECDIS and Engine Simulators, Computer Assisted Training,
Crew Evaluation Test, Psychometric Tests, Training Units and equipment, as well as Interviews,
Seminars and Lectures.
3.13 LESSONS LEARNT /SHARED WITH INDUSTRY GROUPS AND OIL MAJORS VETTING
DEPARTMENTS
Industry Groups
The Company is an active member of the ITOSF “Informal Tankers Operators Safety Forum”.
A Company Representative participates in the Quarterly Meetings and shares lessons learnt and
Accident /Incident statistics with the other Companies which participate in this Forum.
Oil Majors Vetting Departments
As per the Emergency Procedures Manual (004)–Section 02-Office Emergency Procedures,
paragraph 2.1.2-“Emergency Responsibilities per Department”, the Marine /Vetting Manager must
notify the Oil Majors, when an incident occurs.
This is also clearly stated in the Procedures Manual (002)–Procedure 14-Annex 2-“Guide for
Incident Notification and Reporting”, which requires:
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High Risk Incidents All Oil Majors must be notified within 24 hours after the
occurrence.
The Incident Investigation Report must be sent within 30 days
after the occurrence.
Other Significant Incidents Oil Majors will be notified, as per their reporting requirements.
( not necessarily High Risk)
3.14 ACCIDENT / INCIDENT CASE STUDIES

Besides the analysis of Accidents/ Incidents which occur on Company Vessels, the Company
circulates analysis of Accidents/Incidents which occur worldwide and are found in the Internet sites
and Safety Bulletins of P&I Clubs, Classification Societies and Flag Administrations.
This procedure enables the Company (onboard and in-office) to provide rapid notification of safety
and security related issues within the Fleet and to share lessons with Industry groups.
The Vessel’s Safety Meeting Agenda has a specific item, in order to record discussions on
Accident/Incident cases.
3.15 RECORD KEEPING

Records of Incidents and Accidents are maintained in the Office as follows:
S&Q Department Keeps full records of all the Accidents involving Crew
injuries.
The Marine/Vetting Department Keeps records of all the Marine Incidents.
The Technical Department Keep full records of all Engine Room/ Machinery Failures,
Breakdowns etc.
The ICT Department Keeps records of all Information Security Incidents.
The Crew Department Keeps records of all Natural Deaths and Illnesses.
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4. OCIMF MARINE INJURY REPORTING FORMAT

The Company has adopted the OCIMF Marine Injury Reporting Guidelines, in order to have a
consistent method of collecting, classifying and reporting data on all injuries occurring onboard and
for “benchmarking”.
Safety Measurement Performance is calculated using the following formulas:
4.1 LOST TIME INJURY FREQUENCY (LTIF)

This is the number of Lost Time Injuries per unit of exposure hours **
**exposure hours include Shipboard personnel as well as supernumeraries and contractors
travelling onboard (i.e Armed Guards, specialized maintenance teams, and additional paint squads).
The most common unit in respect to LTIF is one (1) million man hours.
LTIF: LTIs X 1,000,000

Exposure Hours
4.1.1 TOTAL RECORDABLE CASE FREQUENCY (TRCF)

TRCF= (LTIs +RWCs+ MTCs) X 1,000,000
Exposure Hours
4.1.2 OCIMF DEFINITIONS

LWC: Lost Workday Case
RWC: Restricted Work Case
MTC: Medical Treatment Case
LTI: Lost Time Injury
FAC: First Aid Case
TRC: Total Recordable Cases
PTD: Permanent Total Disability
PPD: Permanent Partial Disability
For more detailed information on the above Marine Injury Categories, one may refer to the relevant
OCIMF Marine Injury Reporting Guidelines, attached to the Accident and Incident Report Forms.
The calculation of the LTIF and TRCF Formulas and the Industry Benchmarking is the responsibility
of the S&Q Department.
However, since these indexes are audited by Oil Majors during Vetting Inspections, Shipboard
personnel must be well familiar with them.
The LTIF & TRCF Indexes are calculated by the S&Q Department on a Quarterly basis
( through Official Circulars) and are included in the Quarterly Management Review Meeting Minutes
and the S&Q Department Presentation which are sent to all Vessels.
The OCIMF Indexes of the Company are “benchmarked” against the relevant OCIMF Indexes of
other Organizations (i.e ITOSF) on a Quarterly Basis and are presented during the Management
Review Meeting.
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5. NEAR MISSES
5.1 DEFINITION
Near Miss: The IMO Definition (MSC-MEPC.7 / Circ .7) of a Near Miss states:
“A Near Miss is a sequence of events and/or conditions that could have resulted in loss.
This loss was prevented only by an accidental break in the chain of events, and/or conditions.
The potential loss could be human injury, environmental damage or negative business impact (e.g.
repair or replacement costs, scheduling delays, contract violations, loss of reputation)”.
The Company encourages all Officers and Crew onboard, Company Superintendents & Internal
Auditors or other Company Representatives, as well as Third Party Contractors and Visitors, to
report Near Misses.
5.2 “JUST CULTURE” APPROACH

All Near Miss investigations must be based on “Just Culture” which also applies to the Accident
and Incident investigation.
The “Just Culture” features an atmosphere of Responsible Behavior and trust, whereby people are
encouraged to provide essential safety-related information without fear of retribution (vengeance/
punishment).
However, a distinction is maintained for acceptable and unacceptable behavior.
Unacceptable behavior will not necessarily receive a guarantee that a person will not face
consequences.
The Company guarantees :

 A “Just Culture” in Near Miss reporting.
 Confidentiality for reporting Near Misses, meaning that after the completion of the investigation,
personal information is removed and remains confidential.
 Thorough Near Miss investigations.
 Processing the results of the Near Miss Investigation, in order to determine training needs, or IMS
improvement requirements.
Near Misses may be reported through the Near Miss reporting system i.e they must be reported to
the Officer of the Watch, or the Safety Officer or the Master, who will report it through the ERP
Module.
However, encouraging an Open Reporting Culture, Near Misses may initially be reported directly
to the Company, by e-mail to : openreporting@prime-marine.net
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5.3 THE NEAR MISS INVESTIGATION PROCESS
5.3.1 SHIPBOARD PROCEDURE

As a minimum, the following information must be collected for a Near Miss Investigation:
 Who and what was involved?
 What happened, where, when, and in what sequence?
 What was the Root Cause (s)?
 What were the potential losses and their potential severity?
 What was the likelihood of a loss being realized?
 What is the likelihood of a recurrence of the chain of events and/or conditions that led to the
Near Miss?
The answer to these questions will determine the depth of the investigation.
Once the decision for a full investigation has been taken the following steps must be followed:
 Gathering Near Miss information.
 Analyzing the information.
 Identifying the Causal Factors.
 Developing and implementing recommendations.
5.3.2.1 Serious Near Misses

A Serious Near Miss is defined as a sequence of events and/or conditions that under other
circumstances, could have resulted in an Accident or Incident of the High Risk Categories.
(Refer to Procedure 14- Annex 2- Incident Notification Matrix –Risk Categories “I”& “II”)
Upon completion of the investigation process, the Master and Officers should determine whether
the Near Miss is simple or serious.
If the Near Miss is Simple, it must be uploaded in the ERP, the latest at the end of the Month.
Serious Near Miss reports which could have resulted in very severe loss
(High Potential: Loss of Life/Lives), loss of Vessel, extreme harm to the environment,
must be sent to the Office by e-mail, immediately after the initial investigation at
emergency@prime-marine.net , and should not be processed as simple Near Misses.
An Initial onboard Investigation must be carried out by the Master and Officers for the Serious
Near Misses. Full details and supporting evidence should be provided to the Company, who will
proceed with a rapid notification of the Fleet (as per Table in § 3.2 –“Prompt Notification to all
Fleet” of this Procedure).
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5.3.3 OFFICE PROCEDURE

The S&Q Department is responsible to review all the Near Miss reports through the ERP
“Accidents List” Module, and process this information in a way which supports long term Trend
Analysis fleet-wide.
When a Near Miss is received in Office, it is originally reviewed by the S&Q Department to determine
the nature (routine, serious, very serious etc).
5.3.3.1 Routine Near Misses

All the Near Misses are reviewed and commented by a member of the S&Q Department.
If the Near Miss reports are routine cases, they are processed within one (1) month and the
response is uploaded in the ERP Module.
The Vessels are requested to discuss the Company feedback on Near Misses during the next
Routine Monthly Safety Meeting.
5.3.3.2 Serious Near Misses

A Serious Near Miss is defined as a sequence of events and/or conditions, that under other
circumstances, could have resulted in an Accident or Incident of the High Risk Categories
II and I (of the RA Consequence Matrix–Refer to PROC 14-Annex 2).
If a serious Near Miss occurs onboard, it must be immediately sent to the Office by urgent e-mail.
Serious Near Misses which could have resulted in severe loss, are treated as Accidents,
following the same procedures:
 A prompt initial notification Alert must be sent to all Fleet Vessels (as per Table in § 3.2 –
“Prompt Notification to all Fleet” of this Procedure).
 The serious Near Miss must be discussed by all Fleet Vessels, in the Routine Monthly Safety
Meeting or a Dedicated Safety Meeting, provided that it is carried out within one week (7
days) after the receipt of the notification.
 The case is investigated by the responsible Office Department (as per Table of § 3.5) or by
the “Accident Investigation Committee” (in case of extremely serious Near Misses), in order
to further analyze the information and identify the causal factors.
 If required, Extra Training on safety or other issues may be carried out.
 Any corrective or preventive actions recommended by the Master and Officers of the vessel
as well as by the Office staff must be reviewed, and evaluated in order to decide whether these
will be implemented fleet-wide or on the specific Vessel on which the Serious Near Miss
occurred.
 The corrective and preventive actions must be monitored until final close out.
 The Root Causes must be further analysed in order to decide if the IMS must be amended, as
required.
 The related Risk Assessments must also be reviewed in order to include any additional
hazards and controls, as required.
 Very serious Near Misses must be presented during the Conferences held for Shipboard
Personnel.
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Near Misses statistics, Trends, and any Corrective /Preventive Actions (e.g Campaigns and other
Safety Initiatives) are discussed during the Quarterly Management Review Meetings.
6. FIRST AID CASES REPORTS
Additionally, First Aid Cases (FAC) must be reported on a Monthly basis
The OCIMF Definition of “First Aid Case” is the following:

 One-time treatment cases and subsequent observation or minor injuries such as bruises, scratches,
cuts, burns, splinters etc
First Aid Cases include:

 Follow-up visits to physician or nurse.
 Negative X-ray results.
 Cleaning abrasions/wounds with antiseptic and applying dressing.
 Irrigation of eye & removal of non-embedded foreign objects using a cotton swab.
 One-time administration of oxygen after exposure to toxic atmosphere and resumption to normal (but
not restricted work) the following day.
 Hot or cold compresses and use of elastic bandage on sprains and strains immediately after injury.
 Applying on-off cold compress or limited soaking of a bruise.
 Use of non-prescriptive medicines.
 Use of elastic bandages.
 Treatment of First Degree burns.
The OCIMF First Aid Cases- Form SF/SAQ/405C, must be sent Monthly
as well as the extract for the Medical Log Book (SF/SAQ/428) for the specific month.
When the above mentioned reports are received by the S&Q Department, the following action is taken:
 The Medical Report is reviewed, checking all the medication received by Ship’s staff and the
reason for the administration of the medication.
 If the medication received is simple illness (cold, head-ache, dry skin etc) no further action is
taken.
 If the medication received is relevant to wound disinfection, eye drops for removal of foreign
body, bandages etc, then a cross check is made with the “First Aid Case – Monitoring Table” to
ensure that there is a relevant entry .
 In case the Master has not provided any information on the conditions under which the wound
eye irritation etc occurred the S&Q Department requests clarifications.
 If the result of this investigation indicates that the First Aid Case is related to small injury
during work or even leisure time, as a result of not following safety rules, then this is
communicated to the Vessels’ Personnel in the Quarterly ISM Circulars issued by the S&Q
Department on the Accidents (Crew Injuries, Near Misses and First Aid cases).
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7. BEHAVIOURAL SAFETY REPORTS

Behavioural Safety aims to involve all crew members in:
 Identifying Unsafe Acts / Unsafe Conditions ** ( see definitions in the Table below)
 Taking action to tackle such behaviors.
 Reporting findings, as required.
Unsafe Act A violation of an accepted safety procedure or practice which could permit
the occurrence of an accident/incident, damage to property or Company
reputation
Unsafe Condition A hazardous physical condition or circumstance which could directly

permit the occurrence of an accident/incident, damage to property or
Company reputation
In order to accomplish the above tasks, crew must use the following “tools”:
 Tool 1- Planned Observations – to identify Unsafe Acts/ Unsafe conditions
 Tool 2- Feedback Sessions – to tackle unsafe behavior.
All crew must be involved in the role of guard of the Safety Behaviour onboard.
Every crew member is a potential observer, but also, may himself be observed by his colleagues
with regard to safe behavior when at work, or when involved in any activity onboard.
Everybody onboard must feel responsible, not only for his own safe behavior but also for the
behavior of his colleagues.
If during the Observation , a hazard is identified as imminent,

the Behavioural Safety Observation Team ( BSOT) has the right to intervene immediately and
STOP WORK
The relevant Form SF/SAQ/436- “Behavioural Safety Report” must be issued.
BEHAVIOURAL SAFETY PROGRAM

The Behavioural Safety Program is carried out by two (2) Behavioural Safety Observer Teams
(BSOT).
Each Team must consist of three (3) persons, one of each may be an Officer, e.g
 One Engine Room crewmember and two Deck Crewmembers ( for Engine Room Works )
 One Deck Crew member and two Engine Room Crewmembers ( for Deck Works )
Such a BSOT composition, will provide an “independent eye” and a cross-checking of Deck and
Engine Works.
The Behavioural Safety Report is a MONTHLY report.
Every month, two (2) Behavioural Safety Reports must be submitted as a minimum.
(One from each of the above mentioned Behavioural Safety Observer Teams (BSOT).
Behavioural Safety Reports may be negative or positive.
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However, this does not stop any individual person to carry out a Behavioural Safety Reporting and
exercise his STOP WORK AUTHORITY/OBLIGATION, if he identifies unsafe conditions and
acts, which could endanger the Crew, the Vessel and the Environment.
The Company fully supports and encourages all crew to exercise STOP WORK AUTHORITY,
and ensures non-retaliation of the crew member who does so.
8. SEAFARERS’ NOTEBOOKS
In order to improve the Safety Culture onboard, and encourage OPEN REPORTING, the Company
has introduced a “Seafarer’s Notebook”.
These are pocket-size Notebooks, which are distributed to all Crew members, when they join the
Vessel.
The first pages include:
 Guidance on Safety Procedures,
 Guidance on Stop Work Authority,
 Guidance on Basic Safety Rules ( i.e STOP and Think, Look for Hazards, Assess the Risk,
place controls etc)
 Photo examples of Good/Bad practices
 Examples of Good Practices and Bad Practices,
 Encouragement of OPEN REPORTING,
 Environmental Sensitivity messages.
The Seafarer’s Notebook includes some blank pages for free text, and formatted Yellow Pages for
the reporting of:
 Safe Acts/Best Practices Reports
 Unsafe Acts/ Unsafe Conditions Reports
Each Crew member of any rank, is strongly encouraged to report any safe or unsafe act and condition
he observes onboard, during work or during rest hours.
The above reports (especially the Unsafe Acts/Unsafe conditions reports) may be anonymous.
Ballot Boxes must be placed in the Smoking Room(s), where such reports will be dropped-in.
The Content of the Ballot Boxes must be collected by the Safety Officer or his Deputy just before the
Monthly Safety Meeting, and must be brought for discussion.
Such discussions must be logged in the Safety Meeting Minutes (Form SF/SAQ/401)–under Item 4-
sub section E-“Safety Ballot Issues”.
This reporting does not substitute the mandatory Behavioural Safety Reporting (Form SF/SAQ/436)
nor does it change the minimum Behavioural Safety cases which must be reported monthly as per
the relevant KPI of the respective.
The Safety Officer must maintain an Inventory of the Seafarers’ Notebooks and ensure that at any
time, at least fifteen (15) pieces are available.
The S&Q Department receives the Seafarers’ Notebook pages, reviews them and evaluates them.
In case any breach of Safety Rules and Procedures is reported, this is investigated.
If Safety Suggestions are submitted, then these are collected, reviewed and evaluated for fleet-wide
implementation.
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9. INJURY- FREE DAYS

On a monthly basis, each Vessel reports its Injury-Free days, in the Safety Meeting (Form
SF/SAQ/401) – under Item 4-“Accidents, Incidents, Near Misses, Behavioural Safety, LTIF /TRCF.
The calculation of the Injury Free days, commenced from the date of the Vessels’ delivery to the
Company. If any injury occurs, the calculation must restart from the date of the last injury.
First Aid cases are not taken into consideration.
The S&Q Department, collects this information from the Fleet Vessels, verifies their accuracy and
maintains statistical tables Per Vessel/ Per Fleet and carries out benchmarking between Fleets in
order to identify trends and evaluate the level of Safety Culture across the Fleet and also to identify
areas of improvement.
10. S&Q DEPARTMENT PROCESSING

This section describes the processing of Accident and Near Miss Reports by the S&Q Department.
When the Accident and Near Miss reports and First Aid Cases are received by S&Q through the ERP,
the following must be checked and ensured:
 That the form or ERP Module has been filled in correctly, providing all the data which are
required.
 That Accidents, or First Aid Cases have not been reported on the Near Miss Form
(i.e that there is no incorrect classification of occurrence).
 That Serious Near Misses have not been reported as Simple Near Misses or vice versa.
(Simple Near Misses can be upgraded to Serious or Serious Near Misses may be downgraded to
Simple Near misses, following the review in Office).
 That all Accidents & Near Misses have been discussed in the Safety Meeting which was held after
the occurrence (cross checking with Safety Meeting Agenda).
 That for all the Medical Reports, which involved crew injury during shipboard activities, a
relevant Accident report has been issued.
 That for all medication administered for slight injuries, eye infections etc, and a relevant First Aid
Case entry has been made (cross checking with the Medical Log Book).
If the Accident reports are not satisfactory, guiding messages must be sent to the Master.
When the Accident Investigation Report is finalized ( within one month ), the S&Q Department issues
as relevant ISM Circular, which is circulated to all Fleet Vessels through the ERP.
The Vessels are notified by e-mail to discuss the Final Accident Investigation Report during the next
Routine Monthly Safety Meeting.
Near Misses (Statistics, Trends, correlation of Serious Near Misses with Accidents, Safety
Initiatives etc) are included in the Quarterly Management Review Meetings which are also
circulated to the Vessels, as ISM Circulars.
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In addition, Circulars /Alert E-mails may be issued and sent to the Vessels’ Master for rapid
notification of urgent safety-related issues within the fleet.
Safety Campaigns are initiated, based on the results of the Accidents, First Aid Cases, and Near
Misses.
11. DRUG & ALCOHOL TESTS FOLLOWING A SERIOUS MARINE INCIDENT

The Company procedures concerning drug & alcohol testing are described in PROC 14 - Annex 2.
USCG requires that all personnel involved in a Serious Marine Incident (SMI) are tested as follows:
 For Alcohol: within two (2) hours after the occurrence of the incident.
 For Drugs: within thirty two (32) hours after the occurrence of the incident.
In the event that safety concerns related to the SMI do not permit the testing for alcohol within two
hours, the testing must be conducted as soon as possible, but not later than eight (8) hours following
the incident.
12. MARSHALL ISLAND REQUIREMENTS
12.1 RETENTION OF VOYAGE RECORDS

In case of an Accident or Incident, the following must be retained for at least two (2) years:
 Accident/Incident Reports.
 Complete Voyage Records.
 Voyage Data Recorder (VDR) information.
 Other automatically recorded data and other material, which might be of assistance in
investigating and determining the cause and scope of the Marine Casualty or Marine Incident.
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13. INFORMATION SECURITY INCIDENTS
13.1 DEFINITION
An Information Security Incident is a single incident or a series of unwanted or unexpected
Information Security events that have a significant probability of compromising business operations
and threaten Information Security.
Examples of Information Security Incidents are:
1. Computer System intrusion.
2. Unauthorized, inappropriate or unintentional disclosure of Company’s Data.
3. Suspected or actual breaches, compromises or other unauthorized access to ICT Systems,
information or data, applications or accounts.
4. Unauthorized or unintentional changes to Computers or Software.
5. Loss or theft of Company’s Computer Equipment or other Data Storage devices and media
(e.g. laptop, USB Drive) used to store Company’s information or Data confidential
information.
6. Denial of service attack or an attack that prevents or impairs the authorized use of networks,
systems or applications.
7. Interference with the intended use or inappropriate or improper usage of Information
Technology Resources.
13.2 INCIDENT MANAGEMENT

 Incident Detection
Information Security Incidents and Breaches, whether actual or suspected, are identified and
reported upon detection, in accordance with paragraph 13.3 – “Employee Actions” of this
procedure.
 Initial Information
When the ICT Support Manager receives the incident report, he will determine and
document the following information (if available at the time).
o Name and contact details of the person reporting the incident.
o Nature of the incident.
o Time and Date.
o What Information System or resource was targeted.
o How did the incident occur and/or how was the incident identified.
o Any actions that have already been taken.
o The impact on the Organization.
o Whether the incident is still occurring.
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 Incident Confirmation
The ICT Support Manager is responsible to confirm whether the reported event constitutes
an Information Security Incident or not.
Upon confirmation of the incident, the ICT Support Manager will document the necessary
information on form OFF/ICT/006-“Information Security Incident Reporting Form”.
The following information must be established as soon as possible.

o When did the incident occur?
o When was the incident discovered?
o Contact details of the person reporting the incident.
o Whether it is a Near Miss or an actual Incident.
o What Data or Media were involved?
o How did the incident occur? (e.g malicious e-mail, virus transmitted through infected
USB Stick, Internet Browsing etc.).
o Whether the incident is still occurring.
o Any actions that have already been taken.
 Incident Containment
Following the confirmation stage, the incident must be contained.
Decisions with regards to containment are handled by the ICT Support Manager with advice
from suitably skilled Security Resources and in cooperation with the Business Owner.
This includes a review of the access rights, active sessions etc.
 Incident Reporting
Incident registration and reporting aims to confirm that affected Stakeholders and applicable
Authorities are informed, as required.
This step usually takes place after or in parallel with Incident Containment.
However, it highly depends on the criticality of the incident and whether Legal, Regulatory
or Contractual obligations apply.
All incident are reported to the ICT Support Manager who is responsible to handle the
incidents.
He reports to the ICT Manager, who also provides guidance and informs other parties
(Management, Legal Department etc).
In case of breaches of Personal Data, the ICT Manager is responsible to inform the Legal
Representative of the Company and other Data Protection Authorities, as applicable.
 Eradication
This involves removal of the security problem to support business as usual.
A review of all changes to return to normal service operations is carried out.
Suitable testing of services is conducted to provide an appreciable level of assurance that the
security incident has been completely removed.
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 Recovery
This step aims to ensure that systems are returned to normal service and that a re-occurrence
of the Security Incident is less likely.
Systems are tested to ensure that the Information Security Incident has been completely
removed.
System monitoring is performed to ensure that there is no abnormal behaviour and that
systems are operating as expected.
 Incident Registration
Information Security Incidents are registered in a central Information Security Incident
Register form.
Upon Incident Registration, the incident is assigned a Registration Number and the ICT
Support Manager documents the incident information on form OFF/ICT/006-“Information
Security Incident Reporting Form”.
 Follow-up/ Lessons Learnt

This step ensures that the Company learns from Information Security Incidents and
weaknesses and improves the overall Response System.
Tracking and monitoring of agreed actions resulting from Information Security Incidents are
performed by the ICT Support Manager and are reported during the Management Review
Meeting on a Quarterly Basis.
Incident Investigation process in compliance with current procedure will be performed using
the functionalities of the relevant Company ERP Module.
13.3 EMPLOYEES ACTIONS

Where a breach or suspected breach is identified by a Company employee, it must be reported as soon
as possible to the ICT Support Manager.
Failure to report Information Security Incidents could leave the Company exposed to repeated or
more serious attacks/breaches.
On discovering a breach or suspected breach, the employee must act in accordance to the following
guidelines:
 The loss of theft of a device, must be reported to the ICT Support Manager as soon as
possible.
When raising a call with the ICT Support Manager, it should be made clear whether a laptop
or mobile device was lost/stolen, as each requires a different treatment.
In general, corporate laptops are encrypted so there is no significant concern of data being
stolen, unless still logged-in when the incident occurred.
 For all other Information Security Incidents, such as Malware, the ICT Support Manager
should be informed immediately via e-mail with the following information:
o Date.
o Incident description.
o Affected device.
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IMS Procedures
14. RECORDS
 Accident Report PRO/PRO 14/ SF/SAQ/405A
 Incident Report PRO/PRO 14/ SF/SAQ/405B
 Voluntary Statement PRO/PRO 14/ SF/SAQ/406
 Near Miss Report (back-up form) PRO/PRO 14/ SF/SAQ/407
 Accident/ Incident-Fleet Monitoring Table PRO/PRO 14/ OFF/GEN /019
 Accident/ Incident Investigation Report PRO/PRO 14/ OFF/GEN /020
 Immediate Accident-Incident Notification PRO/PRO 14/ OFF/GEN/020A
 Immediate Accident-Incident Notification & Interim Update PRO/PRO 14/ OFF/GEN/020B
 Information Security Incident Report PRO/PRO 14/ OFF/ICT/006
 Information Security Incident Register PRO/PRO 14/ OFF/ICT/011
 Lessons Learnt from Accident & Incident Investigation PRO/PRO 14/ OFF/GEN/020C
 Lessons Learnt from the Review of Incidents Trends PRO/PRO 14/ OFF/GEN/020D
 Behavioural Safety Report PRO/PRO 14/ SF/SAQ/436
 Technical Incident Investigation Report PRO/PRO 14/ OFF/TEC/106
 OCIMF Reporting-First Aid Cases Monitoring PRO/PRO 14/ SF/SAQ/405C
 Root Cause Analysis TEMP 16
 PROC 14-Annex 1- Root Cause Analysis Table
 PROC 14-Annex 2-Guide for Incident Investigation & Reporting
Page 38 of 38
Comprehensive List of Causes
TOOL FOR ROOT CAUSE ANA YSIS
DESCRIPTION OF IMPLEMENTATION & RESEARCH ANALYSIS PHASE:
INCIDENT EVIDENCE GATHERING IDENTIFICATION OF CRITICAL
• Gather relevant • Organise all evidence
• Document the type/severity of • Implementation phase = direct evidence (scene and • Map evidence
• Cover the who / what / when / where / how as known at the • Research phase = indirect evidence (written • Identify critical factors
• Consider People / Parts / Position / • USE CLC to identify all immediate and root
POSSIBLE SYSTEM CAUSES

ACTIONS CONDITIONS
1. Following Procedures 2. Use of Tools or Equipment 3. Use of Protective Methods 4. Inattention / Lack of Awareness 5. Protective Systems 6. Tools, Equipment and Vehicles 7. Work Exposures to 8. Workplace Environment / Layout
1-1 Violation by individual 2-1 Improper use of equipment 3-1 Lack of knowledge of hazards present 4-1 Improper decision making or lack of 5-1 Inadequate guards or protective devices 6-1 Defective equipment 7-1 Fire or explosion 8-1 Congestion or restricted motion
1-2 Violation by group 2-2 Improper use of tools 3-2 Personal protective equipment not used judgement 5-2 Defective guards or proactive devices 6-2 Inadequate equipment 7-2 Noise 8-2 Inadequate or excessive illumination
1-3 Violation by supervisor 2-3 Use of defective equipment (aware) 3-3 Improper use of proper personal protective 4-2 Distracted by other concerns 5-3 Inadequate personal protective equipment 6-3 Improperly prepared equipment 7-3 Energised electrical systems 8-3 Inadequate ventilation
1-4 Operation of equipment without authority 2-4 Use of defective tools (aware) equipment 4-3 Inattention to footing and surroundings 5-4 Defective personal protective equipment 6-4 Defective tools 7-4 Energised systems, other than electrical 8-4 Unprotected height
1-5 Improper position or posture for the task 2-5 Improper placement of tools, equipment or 3-4 Servicing of energised equipment 4-4 Horseplay 5-5 Inadequate warning systems 6-5 Inadequate tools 7-5 Radiation 8-5 Inadequate workplace layout
1-6 Overexertion of physical capability materials 3-5 Equipment of materials not secured 4-5 Acts of violence 5-6 Defective warning systems 6-6 Improperly prepared tools 7-6 Temperature extremes controls less than adequate
1-7 Work or motion at improper speed 2-6 Operation of equipment at improper speed 3-6 Disabled guards, warning systems or safety 4-6 Failure to warn 5-7 Inadequate isolation of process or equipment 6-7 Defective vehicle 7-7 Hazardous chemicals • displays less than adequate
1-8 Improper lifting 2-7 Servicing of equipment in operation devices 4-7 Use of drugs or alcohol 5-8 Inadequate safety devices 6-8 Inadequate vehicle for the purpose 7-8 Mechanical hazards • labels less than adequate
1-9 Improper loading 2-8 Other 3-7 Removal of guards, warning systems or safety 4-8 Routine activity without thought 5-9 Defective safety devices 6-9 Improperly prepared vehicle 7-9 Clutter or debris • locations out of reach or sight
1-10 Shortcuts devices 4-9 Other 5-10 Other 6-10 Other 7-10 Storms or acts of nature • conflicting information is presented
1-11 Other 3-8 Personal protective equipment not available 7-11 Slippery floors or walkways 8-6 Other
3-9 Other 7-12 Other
POSSIBLE SYSTEM CAUSES

PERSONAL FACTORS JOB FACTORS
1. Physical 2. Physical 3. Mental State 4. Mental Stress 5. Behaviour 6. Skill Level 7. Training / Knowledge 8. Management / Supervision 9. Contractor Selection 10. Engineering / Design 11. Work Planning 12. Purchasing, Material 13. Tools and Equipment 14. Work Rules / Policies / 15. Communication
Capability Condition Transfer Employee Leadership and Oversight Handling and Material Control Standards / Procedures (PSP)
1-1 Vision deficiency 2-1 Previous injury or 3-1 Poor judgement 4-1 Preoccupation with 5-1 Improper performance is 6-1 Inadequate assessment 7-1 Inadequate knowledge 8-1 Conflicting roles / 9-1 Lack of contractor pre- 10-1 Inadequate technical 11-1 Inadequate work 12-1 Incorrect item received 13-1 Inadequate assessment 14-1 Lack of PSP for the task Inadequate horizontal
1-2 Hearing deficiency illness 3-2 Memory failure problems rewarded of required skills transfer responsibilities qualifications design planning • inadequate of needs and risks • lack of defined communication between
1-3 Other sensory Fatigue 3-3 Poor co-ordination or 4-2 Frustration • saves time or effort 6-2 Inadequate practice of • inability to • unclear reporting 9-2 Inadequate contractor • design input obsolete 11-2 Inadequate preventative specifications to vendor 13-2 Inadequate human responsibility for PSP peers
deficiency • due to workload reaction time 4-3 Confusing • avoids discomfort skill comprehend relationships pre-qualifications • design input not maintenance • inadequate factors / ergonomics • lack of job safety Inadequate vertical
1-4 Reduced respiratory • due to lack of rest 3-4 Emotional disturbance directions/demands • gains attention 6-3 Infrequent performance • inadequate instruction • conflicting reporting 9-3 Inadequate contractor correct • assessment of needs specifications on considerations analysis communication between
capacity • due to sensory 3-5 Fears or phobias 4-4 Conflicting 5-2 Improper supervisory of skill qualifications relationships selection • design input not • lubrication / servicing requisition 13-3 Inadequate standards or • inadequate job safety supervisor and person
1-5 Other permanent overload 3-6 Low mechanical directions/demands example 6-4 Lack of coaching on • inadequate training • unclear assignment of 9-4 Use of non-approved available • adjustment / assembly • inadequate control on specifications analysis Inadequate
physical disabilities 2-2 Diminished performance aptitude 4-5 Meaningless or 5-3 Inadequate identification skill equipment responsibility contractor • design output • clearing / resurfacing changes to orders 13-4 Inadequate availability 14-2 Inadequate development communication between
1-6 Temporary disabilities • due to temperature 3-7 Low learning aptitude degrading activities of critical safe 6-5 Insufficient review of • misunderstood • conflicting assignment 9-5 Lack of job oversight inadequate 11-3 Inadequate repair • unauthorised 13-5 Inadequate adjustment / of PSP different organisations
1-7 Inability to sustain body extremes 3-8 Influenced by 4-6 Emotional overload behaviours instruction to establish instructions of responsibility 9-6 Inadequate oversight • design input feasible • communication of substitution repair / maintenance • inadequate co- Inadequate
positions • due to oxygen medication 4-7 Extreme judgement 5-4 Inadequate skill 7-2 Inadequate recall of • improper or 9-7 Other • design output unclear needed repair • inadequate product 13-6 Inadequate salvage and ordination with process communication between
1-8 Restricted range of body deficiency 3-9 Other decisions/demands reinforcement of critical 6-6 Other training material insufficient delegation Not applicable • design output not • scheduling of work acceptance reclamation / equipment design work groups
movement • due to atmospheric Not applicable 4-8 Extreme concentration/ safe behaviours Not applicable • training not reinforced 8-2 of authority correct • examination of parts requirements 13-7 Inadequate removal / • inadequate employee Inadequate
1-9 Substance sensitivities pressure variation perception demands • proper performance is on the job Inadequate leadership • design output • parts substitution • no acceptance replacement of involvement n the communication between
or allergies 2-3 Blood sugar 4-9 Extreme boredom criticised • inadequate refresher • standards of inconsistent 11-4 Excessive wear and tear verification performed unsuitable items development shifts
1-10 Inadequate size or insufficiency 4-10 Other •Inappropriate peer training frequency performance missing or • no independent design • inadequate planning 12-2 Inadequate research on 13-8 No equipment record • inadequate definition Inadequate
strength 2-4 Impainment due to drug Not applicable pressure 7-3 Inadequate training not enforced review for use materials / equipment history of correction actions communication methods
1-11 Diminished capacity due or alcohol use • inadequate effort • inadequate 10-2 Inadequate standards, • extension of service 12-3 Inadequate mode or 13-9 Inadequate equipment • inadequate format for No communication
to medication Other performance feedback • inadequate training accountability specifications, and/or life route of shipment record history easy use method available
1-12 Other Not applicable • inadequate disciplinary program design • inadequate or incorrect design criteria • improper loading 12-4 Improper handling of 13-10 Other 14-3 Inadequate Incorrect instructions
Not applicable process • inadequate training performance feedback 10-3 Inadequate assessment • use by untrained materials Not applicable implementation of PSP, Inadequate
5-5 Inappropriate goals / objectives • inadequate work site of potential failure people 12-5 Improper storage of due to deficiencies communication due to
aggression • inadequate new walk-through 10-4 Inadequate ergonomic • use for wrong purpose materials or spare parts • contradictory job turnover
5-6 Improper use or employee orientation • inadequate safety design 11-5 Inadequate reference 12-6 Inadequate material requirements Inadequate
production incentives • inadequate initial 8-3 promotion 10-5 Inadequate monitoring materials or publications packaging • confusing format communication of safety
5-7 Supervisor implied training Inadequate correction of of construction 11-6 Inadequate audit / 12-7 Material shelf life • more than one action and health data,
haste • inadequate means to 8-4 prior hazard / incident 10.6 Inadequate assessment inspection / monitoring exceeded per step regulations or
5.8 Employee perceived determine if qualified for Inadequate identification of operational readiness • no documentation 12-8 Improper identification • no check-off spaces guidelines
haste job 8-5 of worksite / job hazards 10-7 Inadequate monitoring • no correction of hazardous materials provided Standard terminology
5.9 Other 7-4 No training provided Inadequate management of initial operation responsibility assigned 12-9 Improper salvage and/or • inaccurate sequence of not used
Not applicable • need for training not 8-6 of change system 10-8 Inadequate evaluation • no accountability for waste disposal steps 15-12 Verification / repeat back
identified Inadequate incident and/or documentation of corrective action 12-10 Inadequate use of safety • confusing instructions techniques not used
• training records reporting / investigation change 11-7 Inadequate job and health data • technical error / 15-13 Messages too long
incorrect or out of date 8-7 system 10-9 Other placement 12-11 Other missing steps 15-14 Speech interference
• new work methods Inadequate or lack of Not applicable • appropriate personnel Not applicable • excessive references 15-15 Other
introduced without 8-8 safety meetings not identified • potential situations not Not applicable
training Inadequate performance • appropriate personnel covered
• decision made not to measurement and not available 14-4 Inadequate enforcement
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CORRECTIVE PHASE: PROPOSALS FOR CORRECTIVE ACTION

• Align with AMEC Performance Standards elements
ELEMENTS OF PERFORMANCE STANDARDS
Management leadership,
Employee competency Impact upon the community
commitment & accountability Risk Assessment and Management Design & Construction Operations & Maintenance Occupational health Third party management Incident investigation and analysis Measurement, audit & review
& involvement & emergency planning
PROC 14‐Annex 2
PROC 14‐ Annex 2 Revision: 03
Guide for Incident 30/09/22
Investigation and Reporting
INVESTIGATION
Consequence REPORTING LINES FOR VESSEL / OFFICE NOTIFICATIONS
INCIDENT CATEGORY
Responsible Person
Industry Organisations
QI (If in US waters)
Damage to
Health & Safety Environmental
Administration
Property / Reputation and other
Independent
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Authorities
(People) Impact
Oil Majors
Charterers
Company
Manning
Assets
Vessels
Master
Agent
Follow Up
Fleet
Flag
Actions Timeframe
Notification
C1 C2 C3 C4
Initial verbal notification

DPA/Alternate DPA
( for C2,C3,C4 ) .
1 For C1- verbal notification to Crew Immediately Within 6 hrs
dept and to Ship MEDCARE
**(Illness cases should also be
reported)
R A CONSEQUENCE: "V"
LOW RISK INCIDENTS
◦Failure to operate to As soon as possible if not immediately

◦Oil spill contained documented company after verbal notification.
◦No disruption to Initial Written notification through
FAC onboard < 0,5 litres standard 2
operation by e-mail ( C2, C3, C4) Maximum within 2 hours
*Illness cases not ◦Release onboard ◦Local public
◦Costs/Liability less
work related affecting shipboard awareness but no
than 10,000 US$
environment discernible concern
◦No media coverage
For First Aid Report and Medical Within 30 days maximum of no urgent
3
Log Book sent to S&Q Dept action is required
Root Cause Analysis along with

Corrective & Preventive Actions.
4 Within 30 days 
Lessons Learned Bulletin Form to be
completed as required
PROC 14‐Annex 2
INVESTIGATION
INCIDENT CATEGORY
Responsible Person
Damage to
Administration
Independent
Investigators
Investigators
Authorities
(People) Impact
Oil Majors
Charterers
Company
Manning
Assets
Vessels
Master
Agent
Follow Up
Fleet
Flag
Actions Timeframe
Notification
C1 C2 C3 C4
Initial verbal notification to

DPA/Alternate DPA for ( C2, C3,
C4)
1 Immediately Within 6 hrs
For C1- initial verbal notification to
Crew Dpt and Ship Medcare
◦LWC
R A CONSEQUENCE: "IV"
◦RWC Initial Written notification using the

LOW RISK INCIDENTS
◦MTC ◦Oil spill contained As soon as possible if not immediately

◦Failure to operate to Accident or Incident report forms
◦Work Related onboard 0.5 litres - ◦Brief disruption to after verbal notification.
terminal/ country 2 SF/SAQ/405A or 405B
Illness Case 1.0m3 operation Maximum within 2 hours
requirements **(Illness cases should also be
◦Illness cases not ◦Single breach of ◦Costs / Liability reported )
◦Complaints from the
work related statutory or other between 10,000 and
local public
where more than prescribed limits 100,000 US$
◦Local media / political
2 crew members ◦ Public complaint up ◦Site restriction
attention
have same to 10 individuals
symptoms within 3 Onboard Alcohol Test by Master Within 2 hours
a week period
4 Initiation of Investigation Within 72 hrs  
Issuance of Final Investigation 

5 Within 30 days   
(if required)
Report.
PROC 14‐Annex 2
INVESTIGATION
INCIDENT CATEGORY
Responsible Person
Damage to
Administration
Independent
Investigators
Investigators
Authorities
(People) Impact
Oil Majors
Charterers
Company
Manning
Assets
Vessels
Master
Agent
Follow Up
Fleet
Flag
Actions Timeframe
Notification
C1 C2 C3 C4
Initial verbal notification to DPA /

Deputy DPA (for C2,C3,C4 )
For C1- notification to Crew
1 Department, Ship MEDCARE, S&Q Immediately Within 4 hrs
Department
ERT CALL OUT (for C2, C3 &
C4).
Initial written notification using

standard Accident Report
◦Oil spill isolated ( SF/SAQ/405A ) or Incident
As soon as possible if not immediately
onboard great than Report
after verbal notification.
MEDIUM RISK INCIDENTS
R A CONSEQUENCE: "III"
1.0 m3 ( SF/SAQ/405B) and Statutory

2 Maximum within 2 hours
◦Hydrocarbon Gas ◦Partial disruption report to Authorities including
◦Regional public
release less than 500 to operation Flag Administration ( MI 109, and
◦PPD concern
kg ◦ Instant loss of or MI-109-1 and as per SOPEP,
◦LTI ◦Extensive local media
◦Hydrocarbon gas power VRP etc.
◦Long term / attention
weeping / seeping for ◦Costs / Liability
occupational ◦Enforced remedial
a period >24 hrs between 100,000
illnesses action or reportable to Initial Onboard Alcohol Test by
◦Repeated breach of and 1 million US$ 3 Within 2 hours
authorities Master
statutory or ◦Site restriction
prescribed limits
◦Complaints from Drug and Alcohol Test ashore
Local Authorities For C1 ( INJURY ) – at Shore
4 Within 8 hours max.
Hospital /Clinic

5 Initiation of Investigation Within 72 hrs   
(C1)
  
Issuance of Final Investigation

6 Report and release to the fleet and Within 30 days    
all interested parties.
PROC 14‐Annex 2
INVESTIGATION
INCIDENT CATEGORY
Responsible Person
Damage to
Administration
Independent
Investigators
Investigators
Authorities
(People) Impact
Oil Majors
Charterers
Company
Manning
Assets
Vessels
Master
Agent
Follow Up
Fleet
Flag
Actions Timeframe
Notification
C1 C2 C3 C4
Initial verbal notification to DPA/

/Deputy DPA
1 ERT CALL OUT Immediately Within 4 hrs 
ForSecurity Incidents notify CSO /
A-CSO

standard formats for Accident (
SF/SAQ/405A ) , for Incident
◦Up to a 2-week ( SF/SAQ/405B ) and Statutory As soon as possible if not immediately
R A CONSEQUENCE: "II"
after verbal notification.

HIGH RISK INCIDENTS
◦Oil Spill overboard disruption report to Authorities including Flag

2
◦Hydrocarbon Gas ◦Costs/Liability ◦National public Administration Maximum within 2 hours
release >500 kg between 1 million concern (MI109 or MI-109-1 ) and as per
◦Single fatality
◦Complaints from and 10 million US$ ◦Negative national SOPEP, VRP etc.
◦PTD
National Authorities / ◦Severe damage to media attention ForSecurity Incident SSP
◦Shooting / Fire
Flag State critical systems and ◦Vessel detained by reporting provisions apply
Arms Incident
◦Extended breach of vessel integrity authorities / operations
statutory or Prolonged Loss of restricted Alcohol within 2 hours – maximum
prescribed limits power Drug and Alcohol Test by Shore within 8 hours
3
Allision Screening Company Drugs within 32 hours max
4 Superintendent on scene Immediately to travel on scene

5 Initiation of Investigation Within 24 hrs  
(72 hrs)
    
Issuance of Final Investigation 

6 Report and release to the fleet and Within 30 days  (C2, C3, C4)    
PROC 14‐Annex 2
INVESTIGATION
INCIDENT CATEGORY
Responsible Person
Damage to
Administration
Independent
Investigators
Investigators
Authorities
(People) Impact
Oil Majors
Charterers
Company
Manning
Assets
Vessels
Master
Agent
Follow Up
Fleet
Flag
Actions Timeframe
Notification
C1 C2 C3 C4
Initial verbal notification to DPA/

Alternate DPA
1 ERT CALL OUT Immediately Within 4 hrs 
For Security Incident notify CSO / A-
CSO

standard formats for Accident (
SF/SAQ/405A ) , for Incident
( SF/SAQ/405B ) and Statutory As soon as possible if not immediately
report to Authorities including Flag after verbal notification.
2 Administration
Maximum within 2 hours
(MI109 or MI-109-1 ) and as per
◦Costs/Liability
SOPEP, VRP etc.
greater than 10
For Security Incidents SSP reporting
million US$ provisions apply
R A CONSEQUENCE: "I"
HIGH RISK INCIDENTS
◦Catastrophic
◦Oil Spill overboard damage to critical ◦International public Alcohol within 2 hours – maximum
◦Multiple ◦Severe nuisance systems & vessel attention within 8 hours
fatalities over a large area integrity ◦Negative international 3 Drug and Alcohol Test by Shore Drugs within 32 hours max
◦Terrorist ◦Consistent breach of ◦Loss of propulsion media attention
Attack statutory or or steering in ◦Compliance failure
prescribed limits restricted waters resulting in prosecution
◦Piracy incident / Superintendent on scene
Grounding/ 4 Immediately to travel on scene
Collision
Explosion
Master and Officers involved to be

As soon as possible in coordination
5 released – as well as any other
with Manning Agent
crew who cannot handle this crisis
6 Initiation of Investigation Within 24 hrs        
Issuance of Final Investigation

7 Report and release to the fleet and Within 30 days         
(002) Revision: 04
CUSTOMER FEEDBACK Eff. Date: 29/02/2020
Contents
1. PURPOSE 2
2. PROCEDURE 2
2.1 Customer Complaints Log 2
2.2 Categories of Customer Complaints 2
2.3 Processing of Customer Complaints related to Commercial Issues 2
2.4 Customer Satisfaction Report 3
3. RECORDS 3
Page 1 of 3
(002) Revision: 04
1. PURPOSE
This procedure provides the steps to be followed in order to receive and process customer feedback
and complaints.
2. PROCEDURE
2.1 CUSTOMER COMPLAINTS LOG

All customer communication, feedback and complaints related to ships’ Commercial Operation,
whether written or verbal is forwarded to the Operations Department.
Any verbal communication by phone must be documented in a memo established during or
immediately following the conversation with the customer.
All customer feedback and complaints must be recorded in the Customer Complaints Log.
The Log must include the following information:
 Date;
 Identification of customer;
 Reference to the service (Charter Party, Voyage No., Port,);
 Brief Description of the feedback or complaint;
 Corrective Action required, already taken or status of Claim;
The Fleet Operations Manager and/or Deputy Operations Manager must respond to Charterer’s
complaints.
2.2 CATEGORIES OF CUSTOMER COMPLAINTS

Customer complaints are categorized as follows, but not limited to:
 Vessel’s Performance;
 Vessel’s damages;
 Non -conforming or otherwise Unsatisfactory Services;
 Inadequate records;
 Delays;
 Lapsing Quality Management System (long outstanding corrective actions);
 Complaints regarding the Vessel, the Crew, the Equipment, the use of materials and cost;
 Problems with communication and responsiveness;
 Incorrect Invoicing;
 Complaints regarding business practices, publicity etc;
2.3 PROCESSING OF CUSTOMER COMPLAINTS RELATED TO COMMERCIAL ISSUES

The Fleet Operations Manager and/or Deputy Operations Manager must evaluate the Complaints
and must determine the Corrective Actions required to solve the reported problems.
The Fleet Operations Manager and/or Deputy Operations Manager must identify the Operations,
Subcontractors or other External Organizations who contributed to the Complaint and contact them
in order to come to an agreement on the Corrective and Preventive Actions which must be taken in
order to avoid re-occurrence.
Page 2 of 3
(002) Revision: 04
2.4 CUSTOMER SATISFACTION REPORT

On completion of a Charter Party or of a Management Agreement, the Post Fixing and Claims
Operator must send to all the customers a "Customer Satisfaction Report".
(for Voyage Charter Form OFF/OPS/302A and for Time Charger Form OFF/OPS/302B).
This questionnaire (and any attachment added to it by the Customer i.e. Letters of Protest etc) must
be used to determine if the Company has fulfilled its contractual obligations and commitment to the
satisfaction of the customer.
When the "Customer Satisfaction Reports" are received by the Operations, they must be reviewed
by the Fleet Operations Manager and/or Deputy Operations Manager and/or Fleet Operator in
cooperation with the Chartering Manager or any other Manager involved. If complaints reported are
relevant to the activities of other Office Departments and the Vessel, they must be communicated to
all parties involved.
Information collected must be used as a guideline for making improvements of the IMS.
Improvements of the IMS may involve, but are not limited to:
 Procedures and processes;
 Training of Office & Shipboard Personnel;
 Re-evaluation of Suppliers, Sub-contractors, Agents ;
 Renewal of Fleet etc/
The Fleet Operations Manager and/or Deputy Operations Manager must present the Customer
Feedback and complaints, as well as the corrective and preventive action required or taken, during
the annual Management Review Meeting.
3. RECORDS
 Customer Complaints Log PRO/PRO 15/ OFF/OPS/301
 Customer Satisfaction Report –Voyage Charter PRO/PRO 15/ OFF/OPS/302A
 Customer Satisfaction Report – Time Charter PRO/PRO 15/ OFF/OPS/302B
Page 3 of 3
(002) Revision: 07
THIRD PARTY INSPECTIONS Eff. Date: 30/04/2022
Contents
1. PURPOSE .................................................................................................................................... 2
2. PROCEDURE .............................................................................................................................. 2
2.1 Monitoring of Third Party Inspections ...................................................................................2
2.1.1 Preparation of the Vessel............................................................................................................................. 2
2.1.2 Arrangement of Inspections ........................................................................................................................ 2
2.1.3 Inspection Reports ...................................................................................................................................... 2
2.1.4 Records of Third Party Inspections ............................................................................................................. 3
2.1.5 Amending/ Improving the IMS ................................................................................................................... 3
2.2 Monitoring of Vetting & CDI Inspections ..............................................................................3
2.2.1 Planning ...................................................................................................................................................... 3
2.2.2 Invitation ..................................................................................................................................................... 3
2.2.3 Inspection and Corrective Action ................................................................................................................ 4
2.2.4 Follow-up of Observations .......................................................................................................................... 4
2.2.5 Updating the Archive .................................................................................................................................. 4
2.2.6 Distribution of Inspection Results to all Vessels ......................................................................................... 4
2.3 Third Party Visits Onboard .....................................................................................................5
2.3.1 Company Guidance for Inspections ............................................................................................................ 5
2.3.2 Preparation of the Vessel............................................................................................................................. 5
2.3.3 Meeting the Inspectors ................................................................................................................................ 6
2.3.4 Planning and Carrying-out the Inspection ................................................................................................... 8
2.4 Marshall Islands Flag Requirements .......................................................................................9
2.4.1 Initial Inspection (MI Maritime Regulations) ............................................................................................. 9
2.4.2 Responsibilities of Owners and Operators .................................................................................................. 9
2.4.3 Alternate Safety Inspection Program ........................................................................................................ 10
2.5 Port State Control Procedures & New Inspection Regime (NIR).........................................10
2.5.1 Ship Risk Profile ....................................................................................................................................... 10
2.5.2 Reporting Obligations ............................................................................................................................... 11
2.5.3 Refusal of Access ..................................................................................................................................... 12
2.5.4 Inspection Types ....................................................................................................................................... 12
2.5.5 Vessel Categories subject to expanded PSC Inspections .......................................................................... 12
2.5.6 Clear Grounds for an Expanded Inspection............................................................................................... 13
2.5.7 Detainable Deficiencies............................................................................................................................. 13
3. RECORDS ................................................................................................................................. 14
Page 1 of 14
(002) Revision: 07
1. PURPOSE
This procedure describes the procedures followed by the office (Vetting Department) and shipboard
personnel to arrange, carry out and monitor Third Party Inspections.
“Third Party Inspections” include:
 PSC - Port State Control
 USCG - United States Coast Guard
 P&I Club - Protection and Indemnity
 Flag Administration Inspections
 Vetting & CDI Inspections
2. PROCEDURE
2.1 MONITORING OF THIRD PARTY INSPECTIONS
2.1.1 Preparation of the Vessel

It is the responsibility of the Vetting Department to prepare the Vessel for Third Party Inspections.
The Master must be notified quite in advance of the forthcoming Inspection, in order to start the
necessary preparations.
Depending on the type of the inspection, the Vetting Department must send messages to the
Vessels, reminding them to go through the relevant Checklists (e.g VIQ, CDI etc) and Company
procedures.
The Findings and Deficiencies raised during similar inspections on other Company Vessels must be
provided to the Master, in order to check the status on his own Vessel.
For Flag Inspections by the Administration of Marshall Islands, the Master may refer to the
following MI Checklists:
 MSD 252-Report of Operational Safety;
 MSD 252 Supplement- Operational Safety Inspection Supplement;
 MSD 252 for LGC-Operational Safety Inspection for Liquefied Gas Carriers;
 MSD 340- Critical Equipment Checklist.
 MSD 340- A-C – Critical Equipment Checklist for Australia and China.
2.1.2 Arrangement of Inspections

The Vetting Department is responsible to arrange for all Third Party Inspections and Vetting
Inspections.
When the expanded PSC inspection becomes due, it is the Master’s responsibility to notify the PSC,
through the Agent, by submitting the form TEMP 01A- “Request for expanded PSC”.
2.1.3 Inspection Reports

Following the Inspection, the Inspection report must be immediately sent to the Office by e-mail
attachment or fax.
It must be reviewed by all Departments concerned.
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(002) Revision: 07
The DPA is responsible to allocate responsibilities to the relevant Departments according to the
deficiencies raised, to monitor all corrective actions and to ensure rectification.
The Vetting Department is responsible to ensure that all Deficiencies have closed and to notify the
relevant parties of their close-out, providing supporting evidence, if necessary.
2.1.4 Records of Third Party Inspections

Records of Third Party Inspections are kept by the Marine/Vetting Department.
The Marine/Vetting Department creates "Summary Control Tables" of all Inspections, per case,
listing the Deficiencies raised, and describing the corrective actions taken, and the date of final
close-out. These "Summary Control Tables" are also filed electronically, in the "Archive Database",
per Inspection Category and per Vessel.
2.1.5 Amending/ Improving the IMS

In case the observations raised are related to shortcomings of the IMS, then it is the responsibility of
the Vetting Superintendent, to advise the S&Q Department of the exact Corrections / improvements
which have to be done.
2.2 MONITORING OF VETTING & CDI INSPECTIONS

This section describes the procedures followed by the Vetting Department to arrange and monitor
Vetting and Chemical Distribution Institute (CDI) Inspections.
2.2.1 Planning
When a Vessel is chartered, the Vetting Department must review the Charter Party, in order to
identify how many Vetting Approvals must be secured for that particular Vessel.
A plan must be drawn, in order to decide the dates and ports where Vetting Inspectors must be
invited to inspect the Vessel.
The Master must be notified quite in advance, in order to make any necessary arrangements.
Guidance must be given to the Master, and a reminder to go through the Vetting Inspection
Checklist which are available in the IMS System.
2.2.2 Invitation
The Invitation for a Vetting Inspection must always be done in writing (usually, be e-mail), as per
the requirements of each Oil Major. Depending on the Oil Major, a preliminary "Questionnaire"
may have to be prepared by the Vetting Assistant.
For CDI Inspections, the invitation is done through the CDI Internet system.
The attending 3rd Party Inspectors must be advised of the Company COVID-19 Boarding
Requirements as per form SF/COV/009, i.e:
All Visitors boarding the Vessel must present:
 Vaccination Certificate (carried out at least 15 days before boarding the Vessel)
Or
 COVID-19 Illness Certificate (if available).
Page 3 of 14
(002) Revision: 07
Or
 A Negative COVID-19 PCR Test at least 48 hours before boarding.
Or
 A Negative COVID-19 Rapid Antigen Test at least 24 hours before boarding.
2.2.3 Inspection and Corrective Action

Usually, the Vetting Superintendent joins the Vessel before the Inspection in order to make a final
pre-inspection.
During the Vetting/CDI Inspection, the Vetting Superintendent, (if present onboard), must escort
the Vetting Inspector around the Vessel for his inspection.
If the Observations can be rectified immediately, every effort must be made to rectify them before
the Inspector leaves the Vessel.
All other findings, which may be dealt with immediately (by ordering spares and services at the
particular port) must be taken care of as urgent matters.
The Vetting Inspection report must be forwarded immediately by fax to the Company.
All Departments must review the Vetting findings and take corrective action for the Observations of
their responsibility. However, it is the Vetting Superintendent’s responsibility to ensure that all
Departments are aware of the Observations, and must monitor and ensure that corrective action has
been taken.
2.2.4 Follow-up of Observations

Some Observations raised during Vetting Inspections cannot be rectified immediately e.g. they can
be done during Dry Dock only. In such cases, the Vetting Superintendent is responsible to keep a
strict follow-up of the Observations to ensure that they have been satisfactory closed.
He is also responsible to report close-out to the Oil Majors, in writing.
The Company Official response to OCIMF /SIRE must be sent within the time frame of fourteen
days after the date of receipt of the Official OCIMF report in Office.
2.2.5 Updating the Archive

The Vetting Status of all Vessels is found in the "Archive Database" – in the relevant File
"Vetting".
The Vetting Assistant is responsible to update the Archive with the results of the Inspections.
2.2.6 Distribution of Inspection Results to all Vessels

When the Vetting /CDI report is received in Office and as soon as the observations are analyzed and
the root cause identified, it is the responsibility of the Vetting Coordinator to communicate the
observations identified with specific instructions for compliance the other Vessels.
This practice will enable the other Vessels to check their own Vessel, and make sure that the
observations raised to that particular Vessel will not be raised to their own.
Page 4 of 14
(002) Revision: 07
2.3 THIRD PARTY VISITS ONBOARD

This section describes the preparation which has to be made as well as the procedure to be followed
when Third Party Inspectors (Port State Control, USCG, Vetting Inspectors, Class Surveyors, and
ISM/ISPS External Auditors etc) visit the Vessel.
During visits by Third Parties (Port State, USCG, Vetting Inspectors, Surveyors, Auditors) it is
essential that the contact of the Master and crew be professional.
The rules included in the following paragraphs will assist in making a good impression and getting
the best results.
2.3.1 Company Guidance for Inspections

The following rules will assist in making a good impression and in getting the best results:
 Cleanliness of all spaces.
 Good illumination of all spaces.
 Safe access (safety net, good lighting, life-buoy with self -activating light).
 High standards of dress (Master in uniform, clean overalls for Crew, no long-hair, horse tails,
ear-rings etc).
 High standards of Safety (Safety Helmets, shoes, gloves etc).
 Escort Team having a good knowledge of English.
 Hospitality.
 Good Planning of the Inspection (Master must introduce his Officers, the Inspector to be
escorted by an Officer equipped with VHF).
 A closing meeting must be held to discuss the results.
 End of the Inspection (The Master may offer a small gift e.g Company hat etc).
 The Inspector must be escorted by an Officer to the accommodation ladder.
2.3.2 Preparation of the Vessel

A. All the Vessel’s spaces must be thoroughly cleaned
 Deck spaces must be very clean, free of any oil leakages and from any objects /tools
scattered around.
 All Engine Rooms spaces, including workshop and storage spaces.
 All accommodation spaces must be cleaned (Offices, Bridge, Messrooms, Corridors, Galley,
refrigerated chambers).
 All crew cabins must be clean and tidy.
 The Master’s Office and the Bridge, Ship’s Office and Chief Engineer’s and Chief Officer’s
Office must be very clean and tidy. All worn out files must be replaced. The Master’s
Library to be well organized, all the Files and Manuals must be in place.
 The Hospital Room must be sparkling clean.
 All surgical equipment must be clean and in order and the Medical Chest must be complete
and with no expiring medicines.
B. All the Vessel’s spaces must be well illuminated

 All light covers must be cleaned with detergent to be clear and provide adequate lighting.
 All broken electric outlets must be repaired.
Page 5 of 14
(002) Revision: 07
C. All Officers and Crew must be well prepared

 Each Officer must review his area of responsibility and ensure that his documentation is in
order and updated (Charts, Log Books, IMS reports, Maintenance records etc).
 Each crew member must inspect his area of responsibility and ensure that all are clean and
in order.
 For all broken or malfunctioning items, a Requisition form must be prepared and be ready
for inspection.
 Inspectors are always lenient when problems have already been detected by Vessel’s staff
and some action has been taken. (Risk Assessment, Defect Report and relevant requisition,
if required).
 All crew must keep personal contradictions and dissatisfaction between themselves, away
from the Inspectors, and act as a team with the common goal to pass the Inspection
successfully.
 All Officers and crew must have clean overalls, Safety Helmets and jockey hats to wear
during the visit.
 A Safety meeting must be held and the Company Policies, DPA, Crew Responsibilities, last
drills performed etc must be refreshed.
D. Preparing for the Visiting Inspectors

 Clean Overalls and Safety Helmets must also be available for the Inspectors.
 All unused cabins must also be cleaned and made ready in case a visitor would like to use a
cabin.
 Crockery (plates and glasses), table cloths etc, in good condition, must be available for
serving.
2.3.3 Meeting the Inspectors

A. Vessel’s Access
 Ensure safe access to the Vessel, according to International Requirements – and as per IMS.
 Gangway with Safety Net
 Adequate Lighting
 A lifebuoy with a self-activating light and a lifebuoy with a buoyant heaving line must be
provided and be ready for use at the point of access to the ship.
 The area around the means of access must be kept free from obstruction and clean of any
substances likely to cause a person to slip .Where this is not possible, warning notices to be
posted.
 The name and Identity of the Visitor must be requested and a relevant entry must be made in
the Visitor’s Log Book. Depending on the Security Level, a Baggage Search may be
required. The Visitor’s Log Book procedure has to be strictly followed for ALL, including
all the Third Party Inspectors.
 The Inspectors must be requested to sign in the Visitor’s Log Book.
 A Visitor’s Card to be handed to the Third Party Inspectors.
 A copy of the Form SF/CRW/506V- “Visitor’s Safety Familiarization” to be handed to all
the Third Party Inspectors.
 The Master must be notified for the arrival of the visitors, through VHF – in English.
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(002) Revision: 07
 Do not hesitate to strictly implement the Company’s Gangway Watch Security procedure
i.e. request for identification card, conduct a search etc.
 Remember! You are only doing your job implementing Company procedures!
 When the Third Party Inspectors board the Vessel, the Master must immediately notify the
relevant Office Departments, (i.e depending on the nature of the Inspection), by phone
and/or by e-mail.
B. Escort of the Third Party Inspectors

An Officer must meet the Visitor(s) at the embarkation ladder and lead him/them to the
Master’s Office. The escort Officer must have a good knowledge of the English Language.
C. Fatigue of 3rd Party Inspectors

The Master must ensure that the 3RD Party Inspectors who board the Vessel, can safely carry
out their inspection.
Any signs of fatigue of 3rd Party Personnel must be taken into consideration and resting time
and resting facilities must be provided, as required.
D. Standards of Dress
 The standards of dress must be high.
 All must wear clean overalls, safety shoes and, safety helmets and inside the
accommodation spaces jockey hats with the Company’s name.
 All courtesies, “Good Morning”, “Good Afternoon”, “How are you, sir?” etc must be
addressed in good English.
E. Master’s Presentation and Hospitality

 The Master shall present himself in Uniform.
 His office must be clean and tidy – ensuring a suitable business- like atmosphere. (all
ashtrays must be of the safety type, safety matches must be available, room atmosphere must
be refreshed ahead of time etc)
 The Master must have a list with the names of his Key Officers who will participate in the
Inspection.
 A Company Information Booklet must be distributed to the Inspectors (if available
onboard)
 The Master must be polite and hospitable, but must never relinquish his role as Master. (The
Master does not serve coffee himself or goes to get a soft drink etc and does not leave his
Office during the visit).
 A mess-boy, dressed suitably (in dark trousers and white shirt), must be present to serve.
 Coffee or soft drinks must be served. (Coffee machines must be available in Master’s Office
and in the Ship’s Office – if possible, and a catering staff member must be assigned the duty
to have coffee ready, throughout the visit).
 The Master may ask the visitors, depending on the hour, if they would like breakfast, lunch,
sandwiches etc.
 The menu must be decided ahead of time by the Master and must include two (2) starting
dishes and two (2) main dishes as well as salad and dessert.
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F. Serving of alcohol drinks is not permitted, even if the Inspector requests.

The Company Policy for Alcohol must be strictly implemented.
The duration of the visit must be agreed, as well as the time for the meal to be served.
Instructions must be given to the Cook to have the meal ready at the agreed time.
2.3.4 Planning and Carrying-out the Inspection

A. Planning the Inspection
The Master must properly introduce his key officers and ask the same courtesy in return. All key
staff must be present, unless duty requires otherwise, in which case this must be explained.
The Master must require the Inspectors to state their Inspection Procedure.
The Master must identify the ship’s officers who will assist in the key elements of the inspection
and request the Inspectors to identify their counter-part.
B. Carrying out the Inspection

The Inspector(s), escorted by the assigned Vessel’s Officers will start their inspection.
It is preferable to have two Officers escort the Inspectors, one equipped with a VHF.
In this way any deficiencies identified can be communicated immediately to the Master, who may
arrange for the “on the spot” rectification before the Inspector’s closing meeting.
Officers must reply to all questions addressed to them. Answers must be short and exact to the
point, strictly on what is being asked. Long explanative answers may trigger more invasive
questions.
Officers must never intentionally misrepresent a condition to the Inspectors.
Officers must carefully listen to what the Master or Senior Officers say and must never contradict
them or express a different opinion during the inspection.
Officers must have a note book and write down the Inspectors comments, and from time to time
deliver them to the Master, who may meanwhile prepare for the answer or corrective action.
If during the Inspection (Class Survey, Flag Inspection, PSC/USCG, Vetting, and External Audit)
issues occur, the Master must immediately notify the relevant Office Department(s) by phone or e-
mail, for guidance and assistance.
C. Completion of the Inspection

The Master must insist in a Closing Meeting.
The Master must carefully listen to the comments of the Senior Inspector and then carefully review
what the Inspector writes in his report.
Sometimes, a simple comment expressed in words may turn out to be a very serious comment
when put down in writing.
Before the Inspectors’ disembarkation (Class Surveyor, External Auditors, Vetting Inspectors,
USCG/PSC Control Inspectors), the Master must send the Reports to the relevant Office
Department for review in order to avoid any incorrect wording or inaccurate comments.
All efforts must be made to avoid comments involving Class.
The Inspectors must be escorted back to the embarkation ladder with all respect and politeness.
The Gangway watch must politely request the Visitor’s Card which had been handed to the
Inspector(s), during their embarkation onboard.
The relevant entry to the Visitors Log book must be completed with the exact time of
disembarkation.
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D. Root Cause Analysis

Following all Third Party Inspections, the Master must notify the Company and send the Inspection
Report and any other documentation left onboard, by fax or e-mail attachment, with no changes and
alterations by the Vessel personnel.
If Deficiencies are raised, the Master must submit a “Root Cause Analysis”, using the Form TEMP
16-“Root Cause Analysis”.
2.4 MARSHALL ISLANDS FLAG REQUIREMENTS

(Marshall Islands – Maritime Regulations – Chapter 5 – & Marine Notice -5 -34)
All Marshall Islands Vessels are required to undergo an annual Safety Inspection.
The Maritime Administrator, or an official who is authorized to act for and on behalf of the
Maritime Administrator, may appoint Nautical Inspectors to board and examine or inspect the
Vessels registered under the Maritime Act.
Nautical Inspectors shall render a report with respect to each boarding to the Deputy Commissioner
in charge of Marine Safety Department of Marshall Islands Flag.
2.4.1 Initial Inspection (MI Maritime Regulations)

All Marshall Islands Vessels are required to undergo an initial Safety Inspection within thirty (30)
days of:
 Registration.
 Re-registration whereupon a change of ownership and management has taken place.
 Prior to resuming service at the end of a lay - up period in excess of six (6) months.
 After a substantial structural alteration.
 The Maritime Administration can, in addition to the above inspections, require a Vessel to
undergo a special or unscheduled Safety Inspection at any time.
2.4.2 Responsibilities of Owners and Operators

(Marshall Islands Maritime Regulations (MI-108) Chapter 5- §5.34.12)
It is the responsibility of Owners and Operators of all Vessels subject to inspection or compliance
verification and registered under the RMI, to present each such Vessel for boarding when required,
and to cooperate fully with the Maritime Administrator, or an official who is authorized to act for
and on behalf of the Maritime Administrator, particular in enabling them to board and examine ,
inspect or audit the condition of each such Vessel, including any documents and equipment and the
use thereof during:
 its operation in the Flag and
 prior to change of Ownership.
Failure to present such a Vessel for inspection prior to due date , failure to cooperate as above or
allowing the existence of a condition onboard in violation of established requirements may subject
the Vessel in question to immediate detention and suspension of registration, in addition to any
penalty prescribed by Law or Regulation.
Such detention and suspension shall be cancelled upon satisfactory completion of the Inspection,
Examination or Audit and any required Corrective Action.
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Actions or measures taken to rectify Deficiencies and Non Conformities noted during Surveys and
Annual Safety Inspections must be logged in the Ship’s Deck Log Book and notification must be
given to the Administration of the corrective actions taken.
2.4.3 Alternate Safety Inspection Program

(Marshall Islands Maritime Regulations (MI-108) Chapter 5- §5.34.7)
The Maritime Administrator, or an Official who is authorized to act for and on behalf of the
Maritime Administrator, may establish an alternative program for an annual Safety Inspection, of
Vessels operating in remote or hard to reach areas, to which a Nautical Inspector cannot travel or is
not available.
2.5 PORT STATE CONTROL PROCEDURES & NEW INSPECTION REGIME (NIR)
This section describes the procedure, which is followed by the PSC Inspectors of the Paris
Memorandum of Understanding (MOU) and the New Inspection Regime (NIR).
Definitions:
 The Members of the Paris MOU are: Belgium, Canada, Croatia, Cyprus, Denmark, Finland,
France, Germany, Greece, Iceland, Ireland, Italy, Netherlands, Norway, Poland, Portugal,
Russian Federation, Slovenia, Spain, Sweden, United Kingdom and Northern Ireland.
 M.E.I: Mandatory Expanded Inspection
 NIR: New Inspection Regime
 THETIS: New Database for Port State Control Inspections.
The inspections to be carried out must consist of a visit onboard a ship, in order to check the
certificates and documents. Furthermore, the PSC Inspector must ensure that the crew and the
overall condition of the ship, including the Engine Room, Accommodation and hygienic conditions
meet generally accepted international rules and standards.
In the absence of valid certificates or documents, or if there are clear grounds for believing that the
condition of a ship, its equipment, or its crew do not substantially meet the requirements, a more
detailed inspection (Expanded) will be carried out.
2.5.1 Ship Risk Profile

A. General
The Ship Risk Profile classifies the ships in the following categories:
Low Risk Ships Ships which meet all the criteria of the low risk parameters.
High Risk Ships The ships with five (5) or more points.
Standard Risk Ships Ships which are neither Low Risk Ships or High Risk Ships
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The Ship Risk Profile (SRP) is based on the following factors, using details of the ships’ inspections
in the PARIS MOU area in the last 36 months (3 years).
Generic Factors
 Type and age of ship
 Performance of the Ship’s Flag
 IMO Member State Audit Scheme (VIMSAS)
 Performance of the Recognized Organization (RO)
 Performance of the Company Responsible for the ISM Management (Holder of the DOC)
Historical Factors
 Number of Deficiencies
 Number of Detentions
B. Inspection Categories
The New Inspection Regime includes two Inspection Categories:
 Periodic Inspection: These are determined by the Time Window.
 Additional Inspection: These are determined by overriding or unexpected factors depending on
the severity of the occurrence.
2.5.2 Reporting Obligations

The relevant Port State Control Officer must be notified as follows:
72 Hours Notification before ETA
 If the ship is due for Expanded PSC inspection
 If the ship has a High Risk Profile
 If the ship is older than 12 years of age.
The Operator, Agent or Master of a ship which is subject to an Expanded Inspection must notify its
arrival at least 72 hours before the expected time of arrival (ETA) in the Port or anchorage or before
leaving the previous port, if the voyage is expected to take less than 72 hours.
The arrival notification can be sent by fax or e-mail via the agent.
Regardless of who sends the arrival notification, the Master of the ship remains responsible for
complying with the reporting obligations.
Failure to report to the Port State that your Ship is eligible for a mandatory expanded inspection is
an offence and may risk delay, due to the involved nature of the inspection. The ship also risks that
a penalty (fine) is imposed when not fulfilling the reporting obligation.
A. 24 Hours Notification before ETA

The Operator, Agent or Master of the ship must notify the pre-arrival information to the Port
Authority. The Notification must be done at least 24 hours in advance or at the latest when the ship
leaves the previous port if the voyage is less than 24 hours.
B. ATA and ATD within reasonable time

A new reporting requirement which has been introduced by the NIR (New Inspection Regime) is
the Actual Time of Arrival (ATA) and the Actual Time of Departure (ATD) of all ships.
The notifications must be made to the Port State in accordance with their national arrangements.
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2.5.3 Refusal of Access

With the New Inspection Regime (NIR), the Paris MOU has widened the banning for multiple
detentions from certain ship types to ALL Ship Types and has extended the flag from the Flag from
Black-listed to also include the Grey-listed.
The Banning criteria for the first and second ban have been amended as follows:
 If the ship flies a Black-listed Flag it will be banned after more than 2 detentions in the last 36
months.
 If the ship flies a Grey Listed flag it will be banned after more than 2 detentions in the last 24
months.
Any subsequent detention after the 2nd banning will lead to a ban, regardless of the Flag.
A time period until the banning can be lifted will be introduced, which is as follows:
 1st ban – after 3 months
 2nd ban- after 12 months
 3rd ban-after 24 months
Note: to life the 3rd ban more stringent conditions are applied which have to be fulfilled before
the 24 months has elapsed.
 4th ban- permanent ban
Ships will also be banned when:
 Any ship jumps detention
 Any ship fails to call to the agreed repair yard.
2.5.4 Inspection Types

The Inspection Types are:
 Initial Inspection
 More Detailed Inspection
 Expanded Inspection
2.5.5 Vessel Categories subject to expanded PSC Inspections

The categories of ships subject to Expanded Inspections are:
 Oil Tankers with a gross tonnage of more than 3000 and older than 15 years of age.
 Bulk Carriers older than 12 years of age.
 Gas and Chemical Tankers older than 10 years of age.
A ship in one of the above categories will have to pass an Expanded Inspection after a period of
twelve (12) months since the last expanded inspection carried out in a port within the region of the
Paris MOU.
The Vessel must submit via the Agent, a request to the PSC Authorities for an Expanded PSC
Inspection, in good time. (i.e information must be provided about 3 days (72 hours) before the
expected time of arrival or before leaving the previous port if the voyage is expected to take less
than three (3) days).
The Company has put this request format on an Uncontrolled form – TEMP 01A- “Request for
Expanded PSC”.
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If for operational reasons, an Authority is unable to carry out an inspection or an Expanded

inspection, the Authority must inform the PSC Data Base system “THETIS” that such inspection
did not take place.
The Authorities must seek to avoid inspecting ships, which have been inspected by any of the other
Authorities within the previous six (6) months unless there are clear grounds for an inspection.
If the ship to be inspected does not belong to the categories, which are subject to expanded
inspections, then a period of at least one (1) month must have elapsed since the last inspection
carried out in the region of the Paris MOU and the Vessel must have a target factor over 50 in the
“Thetis” System.
2.5.6 Clear Grounds for an Expanded Inspection

Clear grounds, which warrant a more detailed inspection include the following:
A. During the examination of certificates and documents, inaccuracies have been revealed or the
documents have not been found properly kept or updated.
B. Indication that the relevant crew members are unable to communicate properly with each other,
or with other persons onboard, or that the ship is unable to communicate with the shore-based
authorities either in common language or in the language of the authorities.
C. Evidence of cargo and other operations not being conducted safely or in accordance with IMO
Guidelines.
D. Failure of the Master of an Oil Tanker to produce the record of the Oil Discharge Monitoring
and control system for the last ballast voyage.
E. Absence of an up-to-date Muster List, or crew members not aware of their duties in the event of
fire or an order to abandon the ship.
F. The emission of false distress alerts not followed by proper cancellation procedures.
G. Evidence of the PSC officer’s general impressions and observations that serious hull or
structural deterioration or deficiencies exist that may place at risk the structural, watertight or
weather tight integrity of the ship.
H. Excessive unsanitary conditions on board the ship.
I. Information or evidence that the Master or crew is not familiar with essential shipboard
operations relating to the safety of the ship or the prevention of pollution, or that such
operations have not been carried out.
J. The absence of a table of shipboard working arrangements or records of hours or work or rest of
seafarers.
2.5.7 Detainable Deficiencies

The detainable deficiencies are grouped under the following relevant conventions.
 SOLAS  Annex I – Marpol

 IBC Code  Annex II – Marpol
 IGS Code  Annex V – Marpol
 Loadlines 66  ILO Conventions
 STCW
In the case of a detention, the PSC must immediately notify the Flag State Administration in
writing, which must include the report of the inspection.
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Likewise, the recognized organization, which has issued the Class Certificates, will be notified.
Both must also be notified in writing of the release of the detention.
Where the ground for a detention is the result of accidental damage suffered on the ship’s voyage to
a port, or during cargo operations, no detention must be issued, provided that:
Due account has been given to the requirements contained in Regulation I/II (c) of SOLAS 74,
regarding notification to the Flag State, the nominated surveyor of the recognized organization
responsible for issuing the relevant certificate.
Before entering a port or immediately after a damage has occurred, the Master of ship-owner has
submitted to the PSC authority details on the circumstances of the accident and the damage suffered
and information about the required notification of the Flag State Administration (Importance of
Defect reports).
Appropriate remedial action, to the satisfaction of the Authority, is being taken by the ship.
The Authority has ensured, having been notified of the completion of remedial action, that the
deficiencies, which were clearly hazardous to safety, health or the environment, have been rectified.
3. RECORDS
Non Conformity Note for Third Party Inspection Findings PRO/PRO 16/ OFF/MRS/204
Company COVID-19 Boarding Requirements Covid-19 Plan SF/COV/009
Page 14 of 14
(002) COMPANY’S REPRESENTATIVES Revision: 09
VISITS ONBOARD Eff. Date: 30/09/2022
Contents
1. PURPOSE ..................................................................................................................................2
2. PROCEDURE ............................................................................................................................2
2.1 Frequency of Visits .................................................................................................................2
2.2 Indicative items for review .....................................................................................................3
2.3 Superintendents Visits Planning .............................................................................................4
2.3.1 Attendance Plan .................................................................................................................................................. 4
2.3.2 Other Inspections ................................................................................................................................................ 4
2.3.3 Medical examinations of Traveling Office Personnel ......................................................................................... 4
2.3.4 Fatigue of Company Representatives onboard .................................................................................................... 4
2.4 Ship Visit Preparation .............................................................................................................4
2.4.1 Focus of the Inspections ...................................................................................................................................... 5
2.5 Safety Meetings held by Visiting Superintendents .................................................................5
2.6 Vessel’s logging of Superintendent’s Visits ...........................................................................6
2.7 Documentation and Reporting ................................................................................................6
2.7.1 Vessel Visit Report ............................................................................................................................................. 6
2.7.2 Appraisals of Master and Senior Officers ........................................................................................................... 7
2.7.3 Written Warnings ................................................................................................................................................ 7
2.8 Superintendent’s Job Orders ...................................................................................................8
2.8.1 Job Order Lists .................................................................................................................................................... 8
2.8.2 Processing and follow-up of the “Recommendations for Ship Staff Maintenance ” ........................................... 8
2.9 Superintendents’ Short Visit Inspection .................................................................................8
2.10 Ship Visits by Senior Shore-Based Managers .....................................................................9
3. RECORDS .......................................................................................................................................9
Page 1 of 9
1. PURPOSE
This procedure provides guidance for visits to the Company Vessels by Ship Marine and Technical
Superintendents acting as representatives of Shore Management.
It also refers to the reporting, recording and follow-up process of the deficiencies which are
identified during a Ship’s Visit.
Office Personnel who are to travel and attend Company Vessels must review
the Company Travel Policy (found in IMSM (001)–Appendix U-and refer to
the Form TEMP 24-“Travel Guidance Checklist”.
2. PROCEDURE
2.1 FREQUENCY OF VISITS

The Vessel’s Superintendents or other Office Representatives must make frequent visits to the
Company Vessels. Each ship must be inspected on a regular basis.
The timing of the inspection is flexible and must depend on the Vessel’s trading pattern, reported
condition and office workload.
Intervals between visits must be every six (6) months and must not exceed under normal
circumstances a period of seven (7) months, and always at safe ports.
If a port is not considered safe for the travelling Superintendents, the visit must be postponed
(as per Company Travel Policy).
Each Vessel must be visited, once by a Technical Superintendent

(Fleet Manager, Ship Manager, Assistant Superintendent, Technical Manager) and once by a
Marine & Vetting Superintendent.
Additionally, at least once per year, one Technical Superintendent and one Marine Superintendent
must sail with the Vessel.
During the Sailing Visit, the Technical Superintendent will additionally conduct a “Real-Time”
Engineering Audit and submit a Report, using form OFF/TEC/111.
(A Ship Attendance is considered a “Sailing Visit” when it has a duration of at least seventy two
(72) hours).
The Ship Visits are a good opportunity to establish and maintain communication between Ship and
Shore and every effort shall be taken to promote a strong Safety Culture across the Fleet.
They must also observe and advise the Company about the maintenance standards, as well as about
any required safety improvements and corrective actions.
A “Ship Inspection Report (OFF/TEC/101) must be filled-in as a minimum two (2) times per
year. The Ship Inspection must be carried out based on the OCIMF (VIQ) Questionnaire.
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2.2 INDICATIVE ITEMS FOR REVIEW

The Ship Inspection must establish the condition of both the structure and machinery of the Vessel,
the unacceptability of any part of the Vessel or her operation.
The Ship Inspection must also verify that all Deficiencies raised during the previous Visit, which
have been reported by the Master as "Closed" are actually closed, to the satisfaction of the
Superintendent.
During a Ship Visit, the following basic list of indicative items subject to be reviewed:
 Vessel’s general appearance.
 Engine Room conditions and problems.
 Deck condition and problems.
 Bridge issues and any problems with Navigational and Electronic equipment.
 Class Status.
 Outstanding Defect Reports.
 Outstanding Purchase Orders.
 Outstanding Port State Inspections, USCG Inspections, Vetting Inspections etc.
 Outstanding findings from previous Internal and External audits.
 Items for Dry Dock Reports.
 Status of PMS, including cross-examination of PMS records against the observed actual
shipboard maintenance status.
 Operational adequacy of Critical Equipment (incl. attending relevant tests, when applicable).
 Work Plans for future survey and maintenance requirements.
 Manning Levels.
 Budgets.
 Ship’s Overall Performance.
 Onboard verification of items from previous Recommendations for Ship Staff Maintenance,
which have been reported as “Closed”.
 Implementation of IMS, Filing Plans, Safety & Security etc.
 Marine Labour Convention Items (i.e. Accommodation items: Heating/Lighting/Air-
conditioning/Noise/Vibration, Work/ Rest Hours, Training and Drills, Crew Certificates).
 If complaints have been raised regarding high levels of noise and vibration, visiting
Superintendents who carry with them Noise and Vibration Measuring Equipment, must perform
relevant measurements at various spaces onboard.
These measurements must be recorded on the Form OFF/TEC/101-“ Ship Inspection Report”
where the form “Noise and Vibration Levels’ Measurements” has been attached as Appendix on
the separate Form-TEMP 09 - “Noise and Vibration Measurement records”, and maintained in
Master’s file - Health and Hygiene Matters.
 Safety Culture onboard and correct implementation of Safety Procedures (Use of PPE, Stop
Work Authority, Risk Assessments, Work Permit System, Near Miss reporting, Behavioural
Safety reporting, Safety Drills, Security and Information Security Issues etc).
 CBT Training Status.
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2.3 SUPERINTENDENTS VISITS PLANNING
2.3.1 Attendance Plan
On a continuous running basis, the Fleet Managers are responsible to draw a draft plan of the Vessel
Visits for the year.
The Fleet Managers are responsible for ensuring that the Vessels inspections are carried out in the
agreed frequency, according to Company procedures.
The routine Vessel visit may be combined with other attendances i.e. Vetting Inspections, IMS
Internal or External Audits, attendance during Dry Docking, etc.
Records are being maintained and updated in the Office Filing System.
2.3.2 Other Inspections

Inspections-other than routine inspections-may be conducted by members of the Technical
Department (e.g. Pre-Sale or Damage Inspection).
In these cases, the same Ship Inspection Report (OFF/TEC/101) may be used or any other
alternative report, (with more details) as per Fleet Technical Manager’s instructions.
2.3.3 Medical examinations of Traveling Office Personnel

All Office Personnel, who travel in order to attend Vessels, must undergo Medical Examinations
Annually.
2.3.4 Fatigue of Company Representatives onboard

The Master must ensure that the Company Representative who board the Vessel, can safely carry
out their inspection.
Any signs of fatigue of Company Representatives (Superintendent, Auditors etc) must be taken into
consideration and resting time and resting facilities must be provided, as required.
2.4 SHIP VISIT PREPARATION

When the Fleet/Ship Manager, Technical Superintendent, Assistant Superintendent and / or Safety /
Marine Superintendent is scheduled to visit a Vessel, he must prepare for the Vessel visit.
The Vessel Visit preparations must include, but not limited to:
A. Reviewing the latest Class Survey Status, including any Conditions of Class and/or Memoranda.
B. Reviewing the latest Ship Inspection Report (found in Archive).
C. Reviewing the latest updated Recommendations for Ship Staff Maintenance List (found in
electronic PMS).
D. Reviewing the latest status of the Vessel’s Defect Reports (found in electronic PMS)
E. Reviewing recent PMS reported activities, as well as current PMS Outstandings of importance.
F. Reviewing any outstanding Deficiencies resulting from USCG, PSC or Flag which are related to
Technical/ Marine issues.
G. Being briefed by the Purchasing Department of any pending Requisitions for Critical Spares,
any problems in their delivery onboard etc.
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H. Informing all Office Departments of the forthcoming Vessel Visit and requesting them to state
any important problems which need clarifications with the Master etc.
I. Ensuring that he has the latest version of the relevant Form OFF/TEC/101-“Ship Inspection
Report”, which he must fill-in after the Vessel visit.
J. Getting informed of the latest Management Circular regarding traveling expenses (the latest
version must be found under "Archive Database" in electronic File "Superintendents Traveling
Allowance").
K. Advising the Office Secretary of his forthcoming Vessel Visit, in order to prepare a mail
package, with important or urgent correspondence, if necessary.
L. Advising the Technical Secretary, for the arrangement of air-tickets, arrangement with the
agent, letter "to whom it may concern" etc.
M. Arranging with the Accounting Department, quite ahead of time, for the cash advance for the
traveling expenses.
The Shipboard Management Personnel must be advised of the Ship Inspection and of any special
requirements (e.g .venting of tanks to be inspected etc.) which may need advance planning,
preparation and organization.
2.4.1 Focus of the Inspections

During the Vessel Visit, the focus of the inspection will depend on the specific responsibilities of
the Department, the member of which will carry out the Ship Inspection, for example:
A. The Fleet/Ship Managers, Technical Superintendents, Assistant Superintendents must focus on
the condition of E/R & Deck machinery & systems, overall condition of E/R & Deck, Safety
Systems, etc.: however a general review of the Vessel’s Condition must always be made.
B. Vetting / Marine Superintendents must focus on Bridge and Deck inspections; however they
must also be able to report on the Vessel’s general and Engine Room condition.
C. IMS Auditors must focus on ISM/ISPS/MCL 2006 and ISO Matters and conduct IMS /Internal
Audits, but must also make a tour of the Vessel’s spaces and ensure compliance with Safety
Rules.
However, all Office Staff visiting the Vessel must also briefly inspect and report on the general
condition of the Vessel, safety culture /precautions, general maintenance, cleanliness, and effective
security measures, Electronic and Hard Copy Filing System, as well as MLC 2006 related issues
(victualing, accommodation, heating, air-conditioning, lighting, vibration & noise monitoring and
the quality of onboard life in general).
2.5 SAFETY MEETINGS HELD BY VISITING SUPERINTENDENTS

When Superintendents visit the Vessel, they must hold a Safety Meeting, with the participation of
ALL Crew, except for those who are on duty.
Depending on the prevailing circumstances, Safety Meetings may be combined / supplemented by
Seminars, Drills and other Training activities organized by the attending superintendent
(i.e Shell Training (Resilience, Reflective Learning, LET)- or other Training).
Page 5 of 9
Additional items to be discussed may include, but not limited to:

A. Dry Dock repair works.
B. Work plans for future Surveys and maintenance.
C. Any Accidents / Incidents which occurred since the last visit.
D. Manning Problems (if any).
E. Budget status.
F. Overall Vessel performance.
G. Any Near Miss observed and raised by the Superintendent during his attendance.
H. Safety Culture onboard & Stop Work Authority.
I. Security and Information Security Issues.
J. Company Policies etc
The minutes of this meeting must be recorded in the Form OFF/TEC/101A–Superintendent’s Safety
Meeting , which is a supplement to the Ship inspection Report (OFF/TEC/101).
Any feedback obtained from these Safety Meetings must be used to improve the Company’s Safety,
Security and Environmental procedures.
It must be stressed that visiting Shore-Management Representatives must always set a good
example to the Ship crews by wearing/using the correct PPE and complying with all Safety
and Security procedures and practices.
They must also observe that the Senior Shipboard Officers also set a good example, by doing
the same.
2.6 VESSEL’S LOGGING OF SUPERINTENDENT’S VISITS

The Superintendent’s visit must be always recorded in the Form SF/SEC/911-“Visitor’s Log Book”
and in the Deck Log Book.
If the Superintendent is to travel with the Ship for a period of time (i.e Sailing Visit), the Crew List
and Muster List must be updated accordingly.
2.7 DOCUMENTATION AND REPORTING
2.7.1 Vessel Visit Report

Following the termination of a Ship Visit, it is the duty of the attending Superintendent, upon return
to Office, to fill in the "Ship Inspection Report", as per the form OFF/TEC/101, in typed format.
The Vessel Visit Reports must be produced

in a period of FIFTEEN (15) Calendar Days
after the completion of the Vessel Visit.
The Superintendent must evaluate the condition of each specified area of the ship.
If the evaluation is "unsatisfactory", "Poor", or “not in compliance with Class, Statutory and
Industry requirement”, then specific details must be given.
Additional space is provided in the Form, for any extra comments.
Each Ship Visit Report must be a follow-up on previous Reports and its contents must be concise
and factual, and must accurately reflect the Superintendent’s Appraisal of the subject Vessel.
Page 6 of 9
In this context, where necessary, the Report must refer back to earlier reports or memos, in which
ongoing problems, reasons for high expenditures, or inefficiency of shipboard personnel had been
mentioned.
The original Report must be signed by the attending Superintendent, corresponding Fleet/Ship
Managers and Technical Manager, and filed in the Technical Department.
The Report must be saved electronically, in the "Archive Data base", in Electronic File
"Superintendent’s Visits Report", under the sub-file of the specific Vessel.
The Ship Inspection report must be submitted to the Technical Manager for review, and circulated
to all other Department Heads, to the Vessel and the Chief Operating Officer.
For quick and easy review, all Departments may refer to the "Archive" database.
2.7.2 Appraisals of Master and Senior Officers

On return to the Office, the attending Superintendent must fill in the Appraisal reports of the four
(4) Senior Officers (i.e the Master, Chief Engineer, Chief Officer and Second Engineer
(Forms OFF/CRW/508A-1, OFF/CRW/508A-2, OFF/CRW/508B, OFF/CRW/508C).
This Appraisal procedure is mandatory for all Superintendents (except for Assistant
Superintendents), in addition to the Brief Appraisal which is included in a separate section of the
Ship Visit Report and established in order to have official documents of Superintendents comments
concerning higher rank Officers.
Masters’ Senior Officers’ Appraisal reports must be submitted

after both Long and Short Vessel Visits.
Assistant Superintendents must not fill-in Appraisal Reports for Masters and Chief Engineers
However, on return to the Office they must communicate their comments, verbally to their
Manager.
The Appraisal results are recorded in the Crew Data Base, and are taken into consideration for
future employment. The Appraisal reports are filed in the Crew Personal Files.
2.7.3 Written Warnings

The Superintendent has the authority to issue Written Warnings to Shipboard Personnel, if any
unsafe act (Behavioural Safety), violation of Company procedures or poor performance is
identified.
In this case, form SF/CRW/525 - “Written Warning” must be issued and handed over to the
addressee (also refer to PRO (002) Manual- Procedure 21-“Shipboard Personnel”).
The issuer (Superintendent) and the addressee must sign the Written Warning form and the Master
must countersign it and made a relevant Deck Log Book entry.
The Master must forward a copy of this Written Warning to the Crew Department, who will file this
document in the Personal File of the Crew Member.
Page 7 of 9
2.8 SUPERINTENDENT’S JOB ORDERS
2.8.1 Job Order Lists

Superintendent Orders can result from Superintendents ship inspections or directly from office
(without attendance) in order to follow-up an unscheduled/unplanned maintenance job.
During the Ship Inspection, the Superintendent must:
o Inspect and verify the status of all the Deficiencies raised during the previous inspection.
o Identify any new Deficiencies.
o Discuss the inspection results and the findings with the Master, Chief Engineer and Chief
Officer, who must agree on the contents of the new “Recommendations for Ship Staff
Maintenance” List.
Following the visit, the Superintendent must process Recommendations for Ship Staff Maintenance
through the electronic “Recommendations” module of the electronic PMS system, including only
deficiencies, which can be repaired by Ship’s staff.
The “Recommendations for Ship Staff Maintenance” require the entry of:
(a) A title,
(b) A description,
(c) The office department issuing the Order (Technical or Marine), and
(d) A due date.
All deficiencies must have definite due dates, based on an initial estimate of the time required to
process an unplanned maintenance job and must be mutually agreed by both sides; due dates can be
rescheduled provided there is a written justification.
The deficiencies must be specific and not ambiguous (e.g. "paint the supports under the walkway"
and NOT "deck to be maintained").
2.8.2 Processing and follow-up of the “Recommendations for Ship Staff Maintenance ”
The Vessel must review & process the updated “Recommendations for Ship Staff Maintenance”,
through the module of the electronic PMS system, accordingly.
When a “Recommendation” is closed from the Vessel, then the Fleet/Ship Manager must review the
actions taken and any other supporting evidence ( photos etc ) and confirm through ERP, if found
satisfactory.
2.9 SUPERINTENDENTS’ SHORT VISIT INSPECTION

If a Vessel is visited more frequently than the requirements as specified in § 2.1“Frequency of
Visits” of this procedure, then Form OFF/TEC/101B-“Superintendents’ Short Visit Inspection
Report” may be issued, instead of the extended OFF/TEC/101- Ship Inspection Report”.
Masters’ and Senior Officers’ Appraisal reports must also be submitted after Short Vessel Visits
and Long Vessel Visits.
Page 8 of 9
2.10 SHIP VISITS BY SENIOR SHORE-BASED MANAGERS

The Company fully promotes Ship Visits by Senior Shore-based Managers, since to a large extent,
the effective operation of a Vessel is determined by the quality of the relationships between shore
personnel and sea staff.
During their Visit onboard, Senior Managers, must follow the Safety and Security Rules, and wear
the appropriate PPE, thus delivering the message that for Safety and Security, all are equal onboard,
and LEADING BY EXAMPLE.
Senior Shore –based Managers must have Informal Meetings & discussions with available
Shipboard personnel, of all ranks on issues of their concern, including Work, Health & Welfare
issues with special emphasis on the Safety Culture onboard and Company Policies.
Such Visits enhance the bonds between Shore-Based Management and Shipboard Personnel and set
the basis for an effective “Open Reporting System” since the shipboard staff will feel that they are
supported by their employer and the information which they will provide will be useful and will be
used for further improvement.
A relevant KPI for such Senior Management Ship Visits has been established and is monitored on a
Quarterly basis. The results of such visits, are discussed during the Weekly Operational Meetings,
following the Visit as well as during the Quarterly Management Review Meetings.
During their Visits, Top Management Personnel must fill-in the form OFF/GEN/026-“Top
Management Vessel Visit Report”.
3. RECORDS
 Ship Inspection Report PRO/PRO 17/ OFF/TEC/101
 Superintendent’s Safety Meeting PRO/PRO 17/ OFF/TEC/101A
 Superintendent’s Short Visit Inspection Report PRO/PRO 17/ OFF/TEC/101B
 Real Time Engineering Audit PRO/PRO 17/ OFF/TEC/111
 Recommendations for Ship Staff Maintenance PRO/PRO 17/ OFF/TEC/102
 Top Management Vessel Visit Report PRO/PRO 17/ OFF/GEN/026
 Appraisal Report for Masters–by Technical Supts PRO/PRO 21/OFF/CRW/508A-1
 Appraisal Report for Masters- by Marine Supts PRO/PRO 21/OFF/CRW/508A-2
 Appraisal Report for Chief Officer PRO/PRO 21/OFF/CRW/508B
 Appraisal Report for Senior Engineer Officers PRO/PRO 21/OFF/CRW/508C
 Operations Department-Ship Operator’s
Short Visit Inspection Report PRO/PRO 17/OFF/OPS/306
 Noise and Vibration Measurement Records TEMP 09
Page 9 of 9
(002) CONTROL OF MONITORING AND MEASURING Revision: 06
EQUIPMENT Eff. Date: 31/08/2020
Contents
1. PURPOSE .................................................................................................................................... 2
2. PROCEDURE .............................................................................................................................. 2
2.1 Categories of Equipment & Instruments needing Calibration .................................................. 2
2.2 Monitoring of Calibration ......................................................................................................... 3
2.3 Gas Measuring Instruments-Testing & Checks ........................................................................ 3
3. RECORDS ................................................................................................................................... 4
Page 1 of 4
1. PURPOSE
This procedure defines the activities and controls which must be done in order to ensure that measuring
and testing equipment which are used to verify conformance standards, specifications, codes and
procedures related to Safety and Quality of service are regularly calibrated maintained and
documented.
All the critical equipment and the inspection, measuring and testing instruments which are used
onboard, must always be in good operational condition and must be giving accurate measurements.
For this reason it is very important to calibrate them, in regular intervals as per Manufacturer’s
instructions and/or Company procedures.
All Vessels must have records of equipment and measuring instruments which need calibration, as well
as their calibration instructions.
Their identification is necessary in order to be able to determine their calibration status. These
measuring equipment and instruments must be safeguarded from adjustments that would invalidate the
readings.
They must be protected from damage and deterioration during handling, maintenance and storage. For
this reason, it is important to have the Manufacturer’s instructions readily available and in an organized
file.
2. PROCEDURE
2.1 CATEGORIES OF EQUIPMENT & INSTRUMENTS NEEDING CALIBRATION

The equipment and instruments which are considered as critical and are subject to regular calibration,
are those upon which decisions are made, which may affect the safety of the crew, the safety and
efficient performance of the Vessel and the environment.
The following list is indicative, but not limited:
 Vessel’s electronic Navigational and Positioning Equipment.
 Bridge Control critical instruments (propulsion, engine and propeller indicators, Rudder indicators,
GMDSS, Magnetic Steering Compass, and Steering Gear).
 Tank sound equipment and tapes.
 Smoke/Fire detection and Alarm Systems.
 Machinery indicating devices.
 Machinery Alarms and shut down devices.
 Portable precision instruments (Micrometers and various similar tools).
 Oxygen Analyzers.
 Portable monitoring /testing equipment (Toxic Gas detectors, Explosimeters).
 Calibration Equipment.
 Cargo Handling Equipment.
 Measuring Instruments of Gas Carriers.
 Any other instruments and equipment available onboard each Vessel, as reported by the Chief
Engineer and the Chief Officer.
 Alcometers (if the appliance or the sensor is not replaced annually, it must be calibrated).
Page 2 of 4
2.2 MONITORING OF CALIBRATION

Each equipment must be calibrated according to Manufacturer’s instructions at the specified intervals.
Calibration may be made onboard by Crew, or by specialized Shore technicians.
For onboard calibration by crew, special calibration kits must be provided which in turn must be
maintained and calibrated as per their Manufacturer’s instructions.
Changing of Manufacturer’s Alarms and Parameters is not allowed.
The calibration must be done against measurement standards, traceable to International or National
Measurement Standards.
Where no such standards exist, the basis used for calibration and verification must be recorded.
The equipment which need calibration are listed in the following reports:
 For E/R Thermometers/Manometers: SF/TEC/127-“Calibration of Measuring & Testing
Equipment Calibration / Test Details.
 For Gas Measuring Equipment , the series of Forms SF/MRS/231-“ Portable Equipment –
Inventory and Test Details” have been issued as follows :
o SF/MRS/231-1– For LPG Carriers
o SF/MRS/231R- For OT/CT equipped with Riken Keiki Instruments
o SF/MRS/231M-For OT/CT equipped with MSA Instruments
 Their Calibration status is recorded on the Form SF/MRS/231B-“Maintenance & Calibration Log”
All critical equipment and instrumentation, needing calibration must be entered in the PMS, in order
to ensure timely calibration.
Calibration /Service records as well as the relevant Certificates must be kept in official files of the
Vessel’s Standard Filing System.
Separate Files must be held by the Chief Officer and Chief Engineer including:
 A list of all equipment and instrumentation needing calibration, Manufacturer’s calibration
frequency requirements.
 A section which must have the calibration records per equipment instruments.
 A section which must have any leaflets with Manufacturer’s specific requirements.
 A section which must have Calibration Certificates.
These records must be checked during the Annual Internal Audit.
2.3 GAS MEASURING INSTRUMENTS-TESTING & CHECKS

This section details the procedure for the testing and checking of Gas Measuring Instruments for testing
flammable vapours in O2 deficient atmospheres, oxygen analysers and toxic gas detectors.
A detailed procedure is found in the Maintenance Manual for:

 Oil and Chemical Tankers
 Gas Carriers
Page 3 of 4
A. Gas Measuring Equipment onboard Company Vessels

The Company has decided on a Standard Functionality Set of Gas Measuring Equipment, which must
be available onboard all Company Vessels.
The functionality standardization of Gas Measuring Equipment onboard all company Vessels ensures
that all users, regardless on which Fleet Vessel they are serving are familiar with their use, testing and
maintenance. The IMS requires a 4-months refresher training on the use of Gas Measuring Equipment.
B. Operational Testing and Inspection

Gas Measuring Equipment must be tested at regular intervals in accordance with the manufacturer’s
instructions before the commencement of operations requiring their use. Such tests are designed only
to ensure that the instruments are working properly. Operational Tests must not be confused with
calibration.
C. Calibration
The Standard Gas Measuring Equipment which are provided onboard, must not be sent ashore for
calibration but must be calibrated onboard, using the Calibration set and gases, following
Manufacturer’s instructions as found in the Instructions Manuals.
Person(s) who calibrate the instruments must have received appropriate and documented training for
this task.
Equipment must be sent ashore for repairs and service & (if required) during the Vessel’s dry docking.
On a Monthly basis the following reports must be sent to the attention of the Vetting / Marine
Dpt. by e-mail:
 For Oil Tankers/Chemical Tankers
SF/MRS/231R-“Portable Equipment – Inventory & Test Details for Vessels equipped with
Riken Keiki Instruments”.
SF/MRS/231M --“Portable Equipment – Inventory & Test Details for Vessels equipped
with Riken MSA”.
 For LPG Carriers :
o SF/MRS/231-1-“Portable Equipment – Inventory & Test Details for LPG Vessels”
3. RECORDS
 Calibration of Measuring & Testing Equipment-

Calibration / Test Details PRO/PRO 18/ SF/TEC/127
 Portable Equipment – Inventory and Test Details
-LPG Carriers PRO/PRO 18/ SF/MRS/231-1
- OT/CT equipped with Riken Keiki Instruments PRO/PRO 18/ SF/MRS/231R
- OT/CT equipped with MSA Instruments PRO/PRO 18/ SF/MRS/231M
 Gas Measuring Equipment- Use of Instrument Log PRO/PRO 18/ SF/MRS/231A
 Gas Measuring Equipment-Maintenance & Calibration record PRO/PRO 18/ SF/MRS/231B
 Gas Measuring Equipment-Training Record PRO/PRO 18/ SF/MRS/231C
Page 4 of 4
(002) Revision: 05
CONTRACT REVIEW Eff. Date: 30/11/2021
Contents
1. PURPOSE .................................................................................................................................... 2
2. PROCEDURE .............................................................................................................................. 2
2.1 Legal Statutory and Other requirements ................................................................................... 2
2.2 Review of Management Agreements ........................................................................................ 2
2.3 Review of Charter Parties ......................................................................................................... 2
3. RECORDS ................................................................................................................................... 3
Page 1 of 3
(002) Revision: 05
1. PURPOSE
This procedure describes the steps to be followed by the Company to review the requirements related
to the offered services.
The Company enters into two kinds of contract agreements related to the Company "product", which
is Ship Management Services:
A. Management Agreements with the Owners of the Vessels.
B. Charter Party Agreements with the Charterers.
2. PROCEDURE
2.1 LEGAL STATUTORY AND OTHER REQUIREMENTS

The Company maintains a current database of applicable Statutory, Class, and International Bodies,
Associations legal and other requirements and updates related or affecting the Operation, Safety-
Health-Quality-Environmental-Energy Efficiency–Information Security performance of the
Company.
(i.e Lloyds Register Rule-Finder, Company Electronic and Hardcopy Library, enrollment in various
Industry Publications etc).
The Company has arranged to gain access to all applicable Laws, Resolutions, Regulations, Policies
and Guidelines.
The Legal Department supports on their interpretation.
The impact of ongoing Regulatory changes is considered in maintaining Compliance, and in
maintaining the database of Environmental, Energy Efficiency and Health, as well as Information
Security aspects and impacts.
2.2 REVIEW OF MANAGEMENT AGREEMENTS

Following a "Closing Meeting", for the acquisition of a new Vessel, a Management Agreement must
be issued.
The Management Agreement must be signed by authorized Representatives of the Owning Company
and the Managing Company, on all pages.
Before the final signature, it must be reviewed by the Owners’ and the Company’s Representatives,
and Records of such review must be maintained.
A special form has been issued for the Management Agreement Review.
2.3 REVIEW OF CHARTER PARTIES

The Charter Party Agreement is a contractual document which defines the business relationship
between the Owning Company and the Managing Company, which, inter alia:
 Appoints the Company as Manager and Agent.
 Outlines the services to be provided by the Company.
 Deals with the arrangements of budgeting, payments and Management Funds.
 Details the insurance coverage.
Page 2 of 3
(002) Revision: 05
 Details the respective obligations of both parties.

Before the final signature and acceptance of the Charter Party Agreement, a review must be made
and records of such review must be maintained.
A detailed procedure for “Pre-Fixture Activities” is available and a special form has been issued for
the Charter Party Review.
The Operations Manager, in cooperation with other Departments is responsible for the review of the
Charter Party Agreement and for signing and approving it.
3. RECORDS
 Pre-Fixture - Charter Party Review PRO/PRO 19/ OFF/OPS/303

 Management Agreement Review PRO/PRO 19/ OFF/GEN/006
Page 3 of 3
PROCEDURE 20A
Manual Revision: 04
(002)
SHORE PERSONNEL
RECRUITMENT & SELECTION Eff. Date: 30/09/2022
PROCESSES AND PROCEDURES
Contents
1. PURPOSE 2
2. POLICY 2
3. SCOPE 2
4. RECRUITMENT PROCESS AND PROCEDURES 2
4.1 Personnel Requisitions 2
4.2 Internal Transfers and Promotions 3
4.3 Job Postings 3
4.4 Internal Applications (Including Crew members) 4
4.5 Former Employees 4
4.6 Employee Referrals 4
5. SELECTION PROCESS AND PROCEDURES 4
5.1 Screening 4
5.2 Interviews 4
5.3 Assessment and Evaluation 5
5.4 Selection and Offer 5
6. RECORDS 5
Page 1 of 5
PROCEDURE 20A
Manual Revision: 04
(002)
SHORE PERSONNEL
1. PURPOSE
The purpose of this policy is to:
o Set out a systematic framework to promote objective, fair and transparent recruitment and
selection practices in the Company for shore-based positions.
o Continuously improve the consistency and effectiveness of the recruitment and selection
processes and procedures.
2. POLICY
The Company’s Policy is to provide equal employment opportunity to all applicants and Employees
and to apply fair and effective recruitment and selection procedures, in order to ensure that the best
person in terms of knowledge, skills, experience and attitude is chosen for each position.
3. SCOPE
This policy, processes and procedures apply to the recruitment and selection of all shore staff of the
Company.
The Processes and Procedures for recruitment and selection are managed by the Human Resources
Manager.
The HR Department applies the current policy and ensuing procedures and provides advice to Chief
Officers and Department Managers on good practice in recruitment and selection methods.
Authorization from the HR Department is required to initiate any action for an open or new position,
including position creation, internal transfer, promotion, recruitment, advertising, interviewing and
offer of employment.
As “Hiring Manager” is defined the Chief Officer or the Department Manager that initiates a
Personnel requisition:
o Chief Officers are authorized to initiate and forward directly to the HR Department.
Personnel requisitions for their subordinate Department Manager positions.
o Department Managers are authorized to initiate and forward directly to the HR Department
Personnel requisitions for their Department subordinate positions.
4. RECRUITMENT PROCESS AND PROCEDURES
4.1 PERSONNEL REQUISITIONS

A Personnel Requisition Form (OFF/HRD/001) must be completed by the Hiring Manager and
submitted to the HR Department with the relevant documentation whenever there is a need to:
1. Create and fill a new position.
2. Refill an existing position when there is a termination of employment or a proposal for
internal transfer or promotion.
3. Hire a temporary Employee.
The HR Department will review the request and the submitted documentation.
Page 2 of 5
PROCEDURE 20A
Manual Revision: 04
(002)
SHORE PERSONNEL
An intake meeting with the Hiring Manager will be conducted to learn more about the requisition,
the position qualifications and requirements as well as the profile of the ideal candidate.
For a new position, this information will serve to create the position’s Job description which is a very
important part of the recruitment and selection processes.
The HR Department will determine the necessity to create, fill or refill the position and will propose
to the CFO a salary range for the position.
Upon final approval of the requisition, the HR department will decide the recruitment strategy that
will be followed and will notify the Hiring Manager for the open requisition and posting.
If it is necessary, a vacant position may be temporarily filled by an existing qualified employee
providing the Hiring Manager requested so at the Personnel Requisition Form.
4.2 INTERNAL TRANSFERS AND PROMOTIONS

The Company believes in providing opportunities for its Employees to develop knowledge and to
advance within the organization.
Transfer or promotion opportunities to positions of different or higher responsibilities depends on
several factors such as, but not limited to, position availability, Company’s staffing plans, the
individual’s qualifications, experience, education, performance and capabilities.
The Hiring Manager shall indicate at the Personnel Requisition Form the Employees that according
to his opinion fulfil the qualifications and requirements of an open position and are eligible to be
transferred or promoted.
4.3 JOB POSTINGS

The HR Department will create job postings that describe the job opening and communicate the
Company’s brand.
Job postings will include some or all of the following:
o Company website.
o Internal (including vessels) posting.
o Online job boards.
o Social media sites (Facebook, LinkedIn etc.).
o Newspaper advertising.
Jobs will remain posted until the position is filled.
The HR Department will track all applicants and retain applications and resumes as required by GDPR
rules.
Page 3 of 5
PROCEDURE 20A
Manual Revision: 04
(002)
SHORE PERSONNEL
4.4 INTERNAL APPLICATIONS (Including Crew members)

Current Employees and Crew Members may apply for internal job openings.
However, to be considered for an open position they must:
 Have worked for the Company and have been in his/her current position for at least 24
months or 3 contracts for crew members.
 Have received a rating no lower than “3” meaning “Meets normal job role requirements” on
any skill on the most recent performance appraisal and not currently be on a performance
improvement plan.
 Meet the minimum requirements for the job.
All applicants for a posted vacancy will be considered based on their qualifications and ability to
perform the job successfully.
Internal candidates who are not selected will be notified by the HR Department.
4.5 FORMER EMPLOYEES

Former Employees who left the company in good standing may be considered for reemployment.
Former Employees who resigned without a written notice of at least two weeks or who were dismissed
may not be considered for reemployment.
4.6 EMPLOYEE REFERRALS

When there is a job vacancy, any office employee may recommend a candidate for the position. The
candidate is requested to submit his Curriculum Vitae and any other documents of his/ her academic
and professional qualification and experience.
5. SELECTION PROCESS AND PROCEDURES
5.1 SCREENING
The HR Department will screen the pool of candidates by reviewing the submitted resumes in order
to:
o Identify applicants who fit the minimum selection criteria.
o Provide information for reference checks.
o Provide a source of questions for subsequent interviews.
o Ensure that only qualified candidates will be interviewed.
5.2 INTERVIEWS
The HR Manager and the Hiring Manager will review resumes of the qualified candidates to identify
the most appropriate candidates for interviewing in person or distantly (i.e VDC. in case of Crew
Members).
Depending on the position, the HR Manager and the Hiring Manager will conduct more than one
interviews ranging from short, pre-screening interviews to long, in depth interviews.
Page 4 of 5
PROCEDURE 20A
Manual Revision: 04
(002)
SHORE PERSONNEL
The purpose of the Interviews is to determine how well the candidate meets the needs of the position
and the organization. To this end, the style of the interviews may vary and it would be advised by the
HR Manager (structured, unstructured, behavioural etc.).
Candidate Interview and evaluation forms will be completed after each interview and retained with
the application by the HR Department

5.3 ASSESSMENT AND EVALUATION
By the HR Department, the finalist candidates shall undergo Personality Assessment tests. Depending
on the position they might also be tested on Maritime English and undergo other departmental
professional knowledge tests.
Background investigations and reference checks must be conducted by the HR Department on
claimed qualifications of candidates before offering a job.
Moreover, for “Key Staff” positions Security Background Check must be conducted requesting the
candidate to make available to the Company’s HR Department his/her criminal record.
Candidate’s fitness for duty is also to be confirmed.
The candidate should make available to the Company’s Medical Practitioner information of his/her
medical record, as well as his /her undergoing medical tests on the Company’s account.
5.4 SELECTION AND OFFER

When all the previous steps of the selection process for all the finalist candidates have been
completed, the HR Department identifies and ranks the finalists acceptable candidates.
The Hiring Manager advises the HR Manager which candidate selects from the ranked list.
The HR Manager makes a Contingent job offer to the selected by the Hiring Manger candidate.
The offer is contingent on the candidate being approved by the COO or the respective Chief Officer
(for positions subordinate to Department Managers) or by the CEO, CoCEO (for Department
Manager positions). To this end, a meeting is arranged with the COO or the respective Chief Officer
or the CEO, CoCEO. If the candidate is approved, then the HR Department confirms the offer to the
candidate and proceeds to the final hiring details and records collection as per PRO 20B.
All unsuccessful candidates who attended interview are informed by the HR Department via
telephone within a reasonable time after the selection decision has been made and all their interview
records are destroyed due to GDPR reasons.
6. RECORDS
Personnel Requisition PRO/SECTION 20AOFF/HRD/001
Interview Guiding Questions PRO/SECTION 20A OFF/HRD/002
Consent & Authorization-
Medical & Criminal Report PRO/SECTION 20A OFF/HRD/003
New Employee Approval PRO/SECTION 20A OFF/HRD/004
Recruitment & On-boarding Checklist PRO/SECTION 20A OFF/HRD/006A
Page 5 of 5
IMS Procedures PROCEDURE 20B
(002) Revision: 07
SHORE-BASED PERSONNEL Eff. Date: 30/09/2022
Contents
1. PURPOSE 2
2. PROCEDURE 2
2.1 Record Keeping of Employee Qualifications, Experience, Training Skills and Abilities
Development 2
2.2 Office Manning 2
2.2.1 Key Office Personnel 2
2.3 Employee On Boarding 3
2.4 Familiarization / Handover process of Office Employees 4
2.4.1 Familiarization by Department Staff 5
2.4.2 Review of IMS Documentation 5
2.4.3 Handover Process 7
2.5 Employee Training, Skills and Abilities Development 7
2.6 Performance Appraisal of Office Employees 8
2.6.1 Performance Appraisal Procedure 9
2.6.2 Performance Appraisal Records 10
2.7 Vacation Requests 10
2.7.1 Basic Principles 10
2.7.2 Vacation Request 10
2.7.3 Distribution of "Vacation request" Forms 11
2.7.4 Amendment of "Vacation Requests" 11
2.8 Benefits and Incentives, bonuses 11
2.9 Disciplinary Process 12
2.9.1 Purpose 12
2.9.2 Responsibilities of Employees 12
2.9.3 Responsibilities of Managers and Chief Officers 12
2.9.4 Progressive Discipline Process 12
2.10 Termination of Employment 13
2.11 Retention Rate of Shore Based Personnel 14
2.12 Career Opportunities – Promotion – Fleet Officers rotation 14
3. RECORDS 14
Page 1 of 15
(002) Revision: 07
1. PURPOSE
This procedure describes the steps to be followed for managing Shore-based Personnel.
2. PROCEDURE
2.1 RECORD KEEPING OF EMPLOYEE QUALIFICATIONS, EXPERIENCE, TRAINING SKILLS AND

ABILITIES DEVELOPMENT
The Human Resources Department keeps all the records of all Office Employees: i.e. Qualifications
(CVs, Copies of Diplomas, reference letters etc.), experience, training, skills and abilities
development that has been conducted before or during employment with the Company etc.
2.2 OFFICE MANNING

The Company’s Management ensures the availability of resources (human resources with specialized
knowledge, skills, and abilities, organizational infrastructure and technology and financial resources)
essential to implement and improve the IMS.
The needs for shore based personnel are continuously foreseen to effectively meet the anticipated
workload and/or Employee shortages due to age profiling, promotions, increased fleet size, new ship
types, new building programs and technological/regulatory changes.
This process includes unplanned loss of personnel, profiling of competence, qualifications,
experience and retirements. The Company aims to retain low vessel to shore personnel ratios.
Especially the vessel to technical superintendent and vessel to marine/vetting superintendent ratios
should not be greater than 4:1 and 8:1 respectively.
Workforce planning, staffing, recruiting and selection, Employee engagement, training, skills,
abilities and competences development, performance management and succession planning are
continuous Human Resources processes, that are also triggered by the Management Review Meeting
results in order to ensure that the Company IMS can be implemented effectively and efficiently.
2.2.1 Key Office Personnel
TECHNICAL DEPARTMENT VETTING DEPARTMENT

Technical Manager Marine & Vetting Manager
Fleet Manager Marine & Vetting Superintendent
Technical Superintendent
OPERATIONS DEPARTMENT S&Q DEPARTMENT
Tanker Operations Manager S&Q Manager
Gas Operations Manager Deputy S&Q Manager
Tanker & Gas Operator Company Security Officer
Page 2 of 15
(002) Revision: 07
CREW DEPARTMENT PURCHASING DEPARTMENT

Crew Manager Purchasing Spares Manager
Purchasing Stores Manager
ICT DEPARTMENT PROJECTS DEPARTMENT
ICT Manager Projects Manager
IT Support Manager
ICT Development Head
HR DEPARTMENT TRAINING DEPARTMENT
HR Manager Training Manager
2.3 EMPLOYEE ON BOARDING
A. A Hiring is considered as completed when the following conditions are met:

 New Employee Personal Data (OFF/HRD/005) form is filled.
 A Contract Agreement is signed between the Company and the Employee and should be
kept by the Accounting Department.
 An Employee Confidentiality Agreement (OFF/ICT/008A) form is signed by the
Employee.
B. Collecting Records of Training received in previous employments

If a Candidate is approved for employment, he/she is requested to provide the Company with
copies of all training certificates which he has received during his/her previous employments.
These Records are maintained by the Human Resources Department, in order to identify further
training, development needs or Refresher Courses.
C. Identifying Training Needs

During the recruitment process, training needs are identified as follows:
 By reviewing the candidate’s CV.
 During the Interview Process
In form “New Employee Approval”, there is a special section for each Interviewer to note any
additional training which is required for the candidate to be efficient in the specific position.
Page 3 of 15
(002) Revision: 07
D. Probation Period
All newly employed Office Staff should be thoroughly informed by the HR department of the
conditions related to the position, the salary and any other terms and sign their Job Description kept
in their records.
Following the employment, the Employee should be on a six (6) months’ probation period, during
which the Employee should be closely monitored.
At the end of the probation period (six months from employment) the employees’ performance shall
be appraised by his/her Department Manager or the respective Chief Officer, depending on his/her
position.
In case the “end of probation performance appraisal” is conducted during the months of November
or December, there is no need for annual appraisal at the end of the current year.
E. Pre-employment Medical Examination of Office Personnel

An Office Personnel pre-employment Medical Examination should be made, which should
entail the following :
 Complete Medical History / Physical examination ( Company physician)
 Laboratory Investigations
o Complete Blood Count,
o Blood Sugar Fasting, BUN, SGOT, SGPT, creatinine, Cholesterol, HDL, LDL,
HbsAg,
o Erythrocyte, Sedimentation Rate ( ESR )
o Urine Routine & Microscopy
o Chest X-Ray
o ECG
2.4 FAMILIARIZATION / HANDOVER PROCESS OF OFFICE EMPLOYEES

This section describes the familiarization process which should be followed for all newly employed
Office Personnel. As a standard procedure, all newly employed Office Personnel should become fully
familiarized with the Company’s Integrated Management System and the responsibilities and
procedures related to their position.
This familiarization should be completed following the employment within:

 two (2) months for the Managers
 one (1) month for all other Employees,
This procedure is mandatory for all Office Employees.
The Familiarization procedure is as follows:

 The Department Staff familiarize the new Employee.
 The Employee familiarizes himself by reviewing the IMS Documentation related to his position
 The S&Q Department may familiarize/clarify sections in the IMS, as required.
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2.4.1 Familiarization by Department Staff

For every new Employee, the respective Department Manager should appoint a member (mentor) of
the Department to familiarize him/her.
The initial induction should include:
A. General Office Policies, Procedures, terms and conditions (Business Ethics, Cultural Awareness,
Working hours, absences, etc.)
B. Company Organogram, general responsibilities of the Department and the Job Description of the
position.
C. Interrelations with other Departments.
D. Computer Files used by the Department.
E. Company communication systems (Microsoft Outlook program, fax, telex etc.) and procedures
(Circulars, sending mail to the vessels etc.).
F. IMS Manuals and forms directly related to the Department and the position.
G. Familiarization with the Department’s Filing System.
H. Familiarization with the Company’s "Archive" Data Base.
Special Familiarization Checklists are available per Department i.e.

 OFF/ HRD/008- Familiarization Technical Department
 OFF/ HRD/009-Familiarization-Vetting –Marine Department
 OFF/ HRD/010-Familiarization–Operations Department
 OFF/ HRD/011-Familiarization-S&Q Department
 OFF/ HRD/011A-Familiarization-Security Department
 OFF/ HRD/012-Familiarization-Crew Department
 OFF/ HRD/012A-Familiarization- Training Department
 OFF/ HRD/013-Familiarization-Purchasing Department
 OFF/ HRD/014- Familiarization-Legal Department
 OFF/ HRD/015-Familiarization- HR Department
 OFF/HRD/015A-Familiarization-ICT Department
Reference is also made to “Training” procedure.
2.4.2 Review of IMS Documentation

Depending on the Department and the position, each Employee should review the IMS documentation
which is related to his/her responsibilities.
A. IMS Documentation to be reviewed by all Office Employees

All Office personnel should become familiarized with the following:
 Company Policies.
 Integrated Management System Manual.
 Integrated Management System Procedures Manual.
 Emergency Manual.
 Office IMS Forms.
 Shipboard Operations Procedures (as applicable).
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 Shipboard IMS Forms (as applicable).

 Posters and Uncontrolled Forms (as applicable).
 Company Circulars (as applicable).
As a minimum, Secretarial Staff should review:

 Office Manual.
 Office Administration Procedures and the relevant Office forms.
 Office Employee Handbook.
B. IMS Documentation to be reviewed by Specific Departments

In addition to the IMS Documentation stated above, the Technical, Operations, Vetting/ Marine, and
S&Q departments should review the IMS Shipboard related Manuals including SOPEP/
SMPEP/VRP/ California Contingency Plan/ Panama Canal SOPEP.
C. IMS Documentation to be reviewed by Internal Auditors and Vetting Superintendents

It is very important that the Company Internal Auditors have a thorough knowledge of the
Company’s Integrated Management System.
Therefore, they should review and be fully versed with all the Company Manuals.
D. IMS Documentation made available to Office Employees

As a principle, the full Company IMS is available on the ERP ISM Module
Additionally, the ISM is available to Office Personnel in the “ARCHIVE” Data Base (for access
from home).
E. Monitoring of the Familiarization Process

The Human Resources monitors the Familiarization Process of all newly employed Office Staff. The
Training Manager should briefly familiarize/clarify the Employee with:
 The Company Policies.
 The IMS Manuals, the Forms, their structure etc.
 Procedure for issuing Circulars.
 How to locate various procedures through the Systems Index.
 How to make proposals for amendments.
 Procedure for Document Control of documents sent on board.
The Human Resources should hand over to the Employee a copy of Form "Office Personnel
Familiarization".
In the period of one (1) month or two (2) months for Managers following the employment, the
Employee should hand-over to the Human Resources Manager the "Office Personnel
Familiarization" duly filled-in and signed.
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Records of this Familiarization process are kept by the Human Resources Department in the relevant
File "Office Personnel Familiarization Process".
G. After the completion of both the familiarization checklist and the IMS review form the new
Employee, the respective Department Manager shall notify the Human Resources the new Employee
is ready to assume his position duties.
This period should not exceed forty five (45) days, or (65) for Managers, from employment.
(This also applies in case of internal movement of an Employee to another Position/ Department).
2.4.3 Handover Process

When an Employee is replaced in the post by another one, a Handover Form has to be completed.
Depending on the nature of the position, the proper form (Series OFF/HRD/016A-H) is selected i.e.
OFF / HRD/016A-Purchasing Department
OFF / HRD/016B-Marine /Vetting Department
OFF/ HRD /016C-Technical Department
OFF/ HRD /016D-S&Q Department
OFF/ HRD /016E-Security Department
OFF/ HRD /016F-Operations Department
OFF/ HRD /016G-Crew Department
OFF/ HRD /016H-HR Department
OFF/ HRD /016I-ICT Department
OFF/ HRD /016J-Training Department
OFF/HRD/016K- DPA
Department Managers are in charge of the handover process.

The handover should be given by the employee to be replaced or by any other department member,
in case that the position holder is already relieved from his duties.
As soon as the handover process is completed, the related form must be signed by all parties involved
and should be maintained in the Department’s files.
In case an Employee has to be relieved temporarily from his duties (for a period less than 15 day),
then the Temporary Handover form is completed, while emphasis should be given on the items
which are outstanding, pending and in progress under the responsibility of the replaced Employee.
2.5 EMPLOYEE TRAINING, SKILLS AND ABILITIES DEVELOPMENT

For Employee training, reference is made to IMS Procedures Manual, “Training Procedure” that
describes all the activities of providing the knowledge specific to a particular office position.
Skills (including interpersonal and intrapersonal), abilities and generally competences development,
have a long-term focus on preparing for future responsibilities while increasing the capacities of
Employees to perform their current jobs.
They are an important pillar of the Career development process which in turn, is an important factor
in building and sustaining Employee engagement.
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The Human Resources department develops and implements skills, abilities and competences
development programs for the shore Employees, as part of the Career management process.
A relevant yearly plan is developed within the first quarter each year
(Form OFF/HRD/020“Position Skills, Abilities and Competences Development Plan”).
Indicatively such programs may include:
 Team building,
 Brainstorming,
 Managerial, Leadership,
 Presentation and negotiation skills,
 Cultural diversity etc.
2.6 PERFORMANCE APPRAISAL OF OFFICE EMPLOYEES

This section describes the procedures for appraising the performance of Office Employees.
The performance Appraisal reports serve as a means of:
A. Measuring Employee performance, skills, initiative, attitude, cooperation.
B. Discussing with Employee the identified strong points or weaknesses, as well as eventual points
for improvement.
C. Highlighting the potential that each individual has to develop within his/her current position or
into another.
D. Identifying training needs & further development requirements.
E. Proposing a promotion.
F. Identifying grievances or any other issues.
G. Ensuring that Employee’s annual check-up has been conducted:
 The Company provides every Employee medical care through a private insurance program
including medical examinations.
 Making use of this incentive, all Company’s Employees should conduct medical check-up
once per year at a date of their own convenience.
Every year, the Appraiser shall ask the Appraisee during the appraisal session whether he/she has
undergone annual Medical checkup (past year) and tick the appraisal form accordingly.
If still pending, the Employee shall be asked to proceed with medical checkup the soonest possible.
Failure to conduct annual checkup until the next appraisal session will be brought to the attention of
Human Resources Manager.
All Office personnel are appraised annually on their performance of the previous year.
All new Employees, are appraised at the end of the probation period i.e (six (6) months from
employment).
In case the “end of probation performance appraisal” is during the months of November or December,
there is no need for Annual performance appraisal at the end of the current year.
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The annual performance appraisal procedure should be concluded within the month of January each
year.
An extension may be granted but not later than April.
A special form "Appraisal Report for Office Staff" should be filled in separately for each employee
and should be signed by the appraiser.
While appraisals are a formal method of evaluating and giving feedback, Managers or Chief Officers
respectively, must also give feedback informally on the results of more casual observation.
Evaluations of performance should be communicated continuously, not just conducted as an annual
appraisal.
Managers or Chief Officers should regularly monitor Employees’ progress and either reward good
performance, or coach Employees in areas for improvement, thus ensuring effectiveness until the next
formal annual appraisal.
2.6.1 Performance Appraisal Procedure

Office Employees are appraised as follows:
A. Department Employees: appraised by their Department Manager.
B. Department Managers: appraised by the respective Chief Officer.
Handling Appraisal Form OFF/HRD/017-“Appraisal Report for Office Staff”
The Appraisee completes Part A of the Appraisal form consisting the SELF APPRAISAL.
In this part, the Appraisee shall state how he/she understands his main duties and responsibilities,
elements of his/her job that are interesting or difficult, achievement or not of set goals and reasons,
suggestions for improvement, career aspirations, things he/she likes and dislikes in the Organization
and relevant proposals to improve areas of dislike.
He/she then delivers the form to Appraiser who will complete Part B.
The Appraisal to include comments on Part A if needed, agreed goals of the Appraise for next year
and grading of professional skills and generic skills.
There should be a direct relationship between the Employee’s position Job Description
(Competences, Responsibilities etc) and the set goals. The goals should be clearly defined,
measurable with specific results.
The Appraisers shall discuss the appraisal results with the Employee, in order to assist in the
improvement of the performance, attitude, and training, to give guidance regarding shortcomings,
give praise for accomplishments and have him/her sign the appraisal.
Similar meetings, should be conducted periodically in order to discuss the performance of the
Employee, as stated above. Records of such meetings are kept at the discretion of the Appraiser.
The Appraisee may comment in writing on the appraisal report.
The Appraisals of all Employees are reviewed by the Human Resources Manager and appropriate
actions for the issues of paragraphs 2.6 A-H should be taken.
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2.6.2 Performance Appraisal Records

Records of "Office Employee Appraisal Report" should be kept by the Human Resources, in a special
file.
This information is considered strictly confidential.
2.7 VACATION REQUESTS

This section describes the procedures to be followed when office Employees request days off for
vacation or for other reasons.
2.7.1 Basic Principles

The Manager of each Office Department is responsible to plan the Vacation Schedule for the members
of his/her Department and the Chief Officers for their direct report Department Managers.
The general principles are:
A. At least 50 % of the Department Staff should be in Office.
B. At least 50 % of the Secretarial Staff should be in Office.
C. In case one Department/Section is comprised by one person only, then the person who is trained
for his replacement should not be absent at the same time.
D. The DPA and Alternate DPA should not be absent at the same time.
E. If serious circumstances require such absence, then in no case should the Chef Operating Officer,
the Head of the Vetting /Marine Department and the S&Q Manager be absent as well.
F. The CSO and Alternate CSO should not be absent at the same time.
G. Not all Department Managers may be absent during the same period. (e.g. In no way, at a given
period of time, only lower rank Employees are in Office. If the Crew Manager is absent, the
Operations Manager should to be in Office etc.)
H. No vacation leave is approved, during Internal Audits of the Department or the External Audit of
the Office.
I. Before leaving on vacation, each Office Employee should fill in the form “Office Personnel Leave
Handover” – and leave it to the person who will replace him/her during his/her leave. In this form,
the pending items /actions which should be followed and monitored should be mentioned.
J. Absence requests for serious cases (serious family problems, health problems etc.) should be
considered and given priority. In such cases, vacation requests of other Department staff may be
withdrawn.
2.7.2 Vacation Request

When Office Employees wish to be absent for a time period, for vacation or other reasons, they should
fill in the appropriate Form "Vacation request".
Department Managers approve the Vacation Requests of their employees and Chief Officers approve
the Vacation Requests of their Department Managers. The Vacation requests should not conflict with
Audit schedules, serious and urgent departmental work or other department Employee absences.
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2.7.3 Distribution of "Vacation request" Forms

Following approval, the "Vacation Request" should be distributed as follows:
A. The original should be handed over to the Office Administrator for acknowledgement.
B. The Office Administrator is responsible to hand it over to the Accounting Department.
C. A copy is handed over to the Office Secretary who is responsible to keep the Office Attendance
records.
A copy may be kept by the Employee.
2.7.4 Amendment of "Vacation Requests"

If the actual vacation period taken is different than what was noted on the original Vacation Request,
then the original "Vacation Request" must be amended.
It is the responsibility of the Employee upon return to the Office to obtain the original copy from the
Accounting Department, and to amend the report, in order to reflect the actual amount of days finally
taken.
The appropriate space of the form should be filled in and signed.
The original should be returned to the Accounting Department and a copy should be handed over to
the Office Secretary. The Office Secretary should amend her records accordingly.
2.8 BENEFITS AND INCENTIVES, BONUSES

The Company provides annual bonuses and a variety of benefits and incentives aiming to support
Employees’ wellbeing, to make a pleasant working environment and to motivate further professional
development and increased productivity.
Those bonuses, benefits and incentives may change from year to year depending on the general and
personal needs of the Employees and the Company’s economic results.
In general, so far the Company provides:
 Annual bonuses
 Private insurance (all Employees)
 Annual medical checkup (all Employees)
 Free meals and Beverages in Company’s restaurant (all Employees)
 Company Contracted Medical Service in Office Premises (Ship Medcare)
 7/24 Free coffee (all Employees)
 Funding higher education of those Employees who have interest and in combination with
performance and succession plans.
 Possibility of flexible working hours for those who may have personal reasons (case by
case)
 Paid long leave for serious medical problems in family (case by case).
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2.9 DISCIPLINARY PROCESS
2.9.1 Purpose
The purpose of this policy is to clarify guidelines for employee conduct and to outline appropriate
disciplinary steps.
Employment with the Company is subject to termination by either the Company or the employee at
any time, for any reason. Nothing in this policy provides any contractual rights regarding employee
discipline or counselling, nor should anything in this policy be read or construed as modifying or
altering the employment contract between the Company and its employees.
2.9.2 Responsibilities of Employees

It is the duty and the responsibility of every Company employee to be aware of and to abide by
existing policies, procedures, circulars, guidelines and instructions.
It is also the responsibility of employees to perform their duties to the best of their ability and to the
standards set forth in their job descriptions or as otherwise established.
Employees are encouraged to take advantage of all learning and development opportunities available
and to request additional instruction when needed.
2.9.3 Responsibilities of Managers and Chief Officers

The Department Manager or Chief Officer should approach corrective measures in an objective
manner.
If the employee's performance of assigned tasks is the issue, Department Manager or Chief Officer
should confirm that proper instructions, appropriate orientation and adequate training have been given
and that the employee is aware of job expectations.
Both single incidents and patterns of poor performance should be of concern.
If misconduct of any kind is the issue, the Department Manager or Chief Officer in consultation with
Human Resources (HR) should take steps to ensure that the employee is aware of the Company's
policies, procedures, circulars, guidelines and instructions regarding employee conduct.
If, in either case, appropriate instruction or information was not communicated, the Department
Manager or Chief Officer in consultation with Human resources (HR) should immediately develop a
plan for delivering such instruction or information and should review the content with the employee.
2.9.4 Progressive Discipline Process

The Company supports the use of progressive discipline to address issues such as poor work
performance or misconduct to encourage employees to become more productive workers and to adapt
their behaviour to Company standards and expectations.
Generally, a Department Manager or Chief Officer gives a warning to an employee to explain
behaviour or performance that the Department Manager or Chief Officer has found unacceptable.
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There are two types of warnings:

 Verbal and
 Written.
A verbal warning occurs when a Department Manager or Chief Officer verbally counsels an
employee about an issue of concern.
A written record of the discussion, noting the date, event and recommended action, is placed in the
employee's personnel file at the Human Recourses (HR) for future reference.
A written warning is used for behaviour or performance that a Department Manager or Chief Officer
considers serious or when a verbal warning has not helped change unacceptable behaviour or
performance.
The Department Manager or Chief Officer, in consultation with Human Resources (HR), may place
the employee on a performance improvement plan (PIP).
Within this time period, the employee must demonstrate a willingness and ability to meet and
maintain the conduct and work requirements specified by the Department Manager or Chief Officer
and the organization.
The Department Manager or Chief Officer and employee should meet regularly to assess the progress
of the PIP. If the employee has met the goals and expectations described in the PIP, the Department
Manager or Chief Officer will document that he or she has successfully completed the PIP.
All these should be appropriately placed in the employee's personnel file at the Human Recourses
(HR) for future reference. If established goals are not met, dismissal may occur.
The last and most serious step in the progressive discipline process is a recommendation to terminate
employment.
Generally, the Company will try to exercise the progressive nature of this policy by first providing
warnings, issuing a final written warning before proceeding to a recommendation to terminate
employment.
However, the Company reserves the right to combine and skip steps depending on the circumstances
of each situation and the nature of the offense.
Furthermore, employees may be terminated without prior notice or disciplinary action.
The Company reserves the right to administer appropriate disciplinary action for all forms of
disruptive or inappropriate behaviour. Each situation will be dealt with on an individual basis.
2.10 TERMINATION OF EMPLOYMENT

Employment with the Company is voluntary and subject to termination by the Employee or the
Company at will, with or without cause and with or without notice at any time.
Management's recommendation to terminate employment must be approved by Human Resources
(HR). Final approval may be required from the COO, CoCEO, and CEO.
In case of termination of Employment, the HR Manager schedules an exit interview with the
Employee before the last day of work and the Form OFF/HRD/019 “Termination of Employment” is
completed.
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2.11 RETENTION RATE OF SHORE BASED PERSONNEL

The Company’ objective is to retain an Average Job Retention rate for Key Office Staff, greater than
70 % over a two-year period. Relevant calculation shall be conducted according to the formula of
INTERTANKO.
The HR Manager compares and analyzes the retention rate against the set targets and where
required/applicable, takes actions to address concerns.
Lessons learnt from exit interviews (Termination of Employment form) should be taken into
consideration.
2.12 CAREER OPPORTUNITIES – PROMOTION – FLEET OFFICERS ROTATION

The Company seeks to fill vacant positions including key staff positions giving priority to its own
staff.
Consequently, the Company provides to all Employees equal opportunities for professional
development.
Acting proactively, the Company offers a wide variety of tools and options to support its career
development efforts. Such options include training, higher or continuing education programs, skills
and abilities development, job rotation, enlargement and enrichment, projects, committees and team
participation, mentoring/coaching, membership to professional bodies etc.
In addition to above, the Company seeks also to fill key shore staff positions from within the ship
born personnel i.e. senior Officers of the fleet.
This effort may involve targeted invitations to the Office of senior Officers of the fleet for rotation
(secondment) for at least 3-4 weeks.
During this period Officers will be given appropriate familiarization regarding Office duties and
routine job and will be required to work side by side with Office staff or they might be given
assignments like vessel attendances on behalf of the Company.
The Department Manager(s) involved shall evaluate their capabilities and overall performance in
order to propose them or not to be future candidates for Office position.
Above evaluation must be combined with feedback from Superintendents and Candidates’ Appraisal
Reviews.
3. RECORDS
 New Employee Personal Data-Greek PRO/PRO 20A OFF/HRD/005
 New Employee Personal Data- English PRO/PRO 20A OFF/HRD/005A
 Employee Confidentiality Agreement PRO/PRO 20B OFF/ICT/008A
 Office Newcomer Checklist PRO/PRO 20A OFF/HRD/006
 Office Personnel Familiarization PRO/PRO 20B/ OFF/HRD/007
 Familiarization Forms per Department PRO/PRO 20B/ OFF/HRD/008-015A
 Office Personnel Short/Temporary Leave Handover PRO/PRO 20B/ OFF/HRD/016
 Purchasing Department Handover PRO/PRO 20B/ OFF/HRD/016A
 Marine/Vetting Department Handover PRO/PRO 20B/ OFF/HRD/016B
 Technical Department Handover PRO/PRO 20B/ OFF/HRD/016C
 S&Q Department Handover PRO/PRO 20B/ OFF/HRD/016D
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 Security Department Handover PRO/PRO 20B/ OFF/HRD/016E

 Operations Department Handover PRO/PRO 20B/ OFF/HRD/016F
 Crew Department Handover PRO/PRO 20B/ OFF/HRD/016G
 HR Department handover PRO/PRO 20B/ OFF/HRD/016H
 ICT Department Handover PRO/PRO 20B/ OFF/HRD/016I
 Training Department Handover PRO/PRO 20B/ OFF/HRD/016J
 DPA Handover PRO/PRO 20B/ OFF/HRD/016K
 Appraisal Report for Office Staff PRO/PRO 20B/ OFF/HRD/017
 Vacation Request Form PRO/PRO 20B/ OFF/HRD/018
 Termination of Employment PRO/PRO 20B/ OFF/HRD/019
 Position Skills, Abilities and Competences
Development Plan PRO/PRO 20B/ OFF/HRD/020
 Employee Development Program Evaluation PRO/PRO 20B/ OFF/HRD/022
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IMS Procedures PROCEDURE 20C
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PROMOTIONS AND POSITION CHANGES Eff. Date: 30/11/2021
Contents
1. PURPOSE 2
2. DEFINITIONS 2
3. ELIGIBILITY 2
4. PROCEDURE 2
5. RECORDS 3
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1. PURPOSE
The Company believes in providing opportunities for its Employees to advance within the
Organization.
This procedure provides guidance and defines the steps that shall be followed for a position change
or a promotion of a Company Shore Employee.
2. DEFINITIONS
Promotion is the movement of an employee to a position of higher Rank and Responsibilities either
within the same Department or to another Department.
Position change of an Employee is a role change to a position with different but not higher
responsibilities that helps employees develop and grow.
3. ELIGIBILITY
Depending on the Company’s workforce plans and staffing needs, an employee might be eligible for
promotion consideration or position change, provided that the following criteria are met:
 There is an open position.
 The Employee possess the minimum qualifications for the position.
 The Employee’s performance level is:
o above 85% (for promotions) and
o above 65% (for position changes)
during the last two (2) annual appraisal cycles.
 That suitability for promotion has been indicated by his/her Department Manager or Chief
Officer (in case the employee is a Department Manager).
 The Employee has been in current position for at least two (2) annual appraisal cycles.
 Personal motivation and willingness for a change in responsibilities.
4. PROCEDURE
The Process and Procedure for Promotions and Position changes is managed by the Human Resources
Manager.
Department Managers and Chief Officers shall indicate at the Annual Appraisal Report if the
employee is suitable for promotion or not.
In case of a new vacant position, the Hiring Manager shall indicate at the Personnel Requisition Form
the Employees that according to his/her opinion and as per this policy, fulfill the qualifications and
requirements of the position and are eligible to be transferred or promoted.
The Human Resources Manager in consultation with the respective Chief Officer decides the
promotions or position changes of Employees up to the level of Department Manager.
The Chief Executive Officer (CEO) decides the promotions of the Chief Officers.
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5. RECORDS
Personnel Requisition Form PRO/SECTION 20A OFF/HRD/001
Management of Change-Change of Employee Position PRO/PROC 27 OFF/GEN/008D
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SHIPBOARD PERSONNEL Eff. Date: 30/09/2022
Table of Contents
1. PURPOSE ......................................................................................................................................................... 4
2. PROCEDURE................................................................................................................................................... 4
2.1 Recruitment of Seafarers .......................................................................................................................................... 4
2.1.1 Rank‐Specific Interviews .............................................................................................................................................. 6
2.1.2 Rank Specific Psychometric Assessments & English language skills ............................................................................ 7
2.1.3 TESTs Description ......................................................................................................................................................... 9
2.1.4 Acceptance /Rejection of a Seafarer ............................................................................................................................ 9
2.1.5 Training/Familiarization of Officers ........................................................................................................................... 10
2.1.6 Training/Familiarization of Ratings ............................................................................................................................ 10
2.2 SEAFARERs APPROVAL ........................................................................................................................................... 12
2.3 Senior Officers Briefing .......................................................................................................................................... 13
2.3.1 Senior Officers Newly Recruited or Promoted ........................................................................................................... 13
2.3.1.1 Briefing Agenda ....................................................................................................................................................... 13
2.3.1.2 Briefing Participants ................................................................................................................................................ 14
2.3.2 Senior Officers previously served on Company’s Vessels .......................................................................................... 14
2.4 Preparation for Joining Crew .................................................................................................................................. 14
2.4.1 Certificates of Competency ........................................................................................................................................ 15
2.4.2 Flag Administration Certificates ................................................................................................................................. 15
2.4.3 National Seaman’s book, Seafarer’ Identification and Record Book (SIRB) ............................................................... 15
2.4.4 Security Certificate for Criminal Liability .................................................................................................................... 15
2.4.5 Pre‐Employment Medical Examinations .................................................................................................................... 16
2.4.6 Vaccination................................................................................................................................................................. 16
2.4.7 Visas ........................................................................................................................................................................... 16
2.4.8 Manning Agents’ Pre‐Departure Briefing ................................................................................................................... 16
2.4.9 Traveling Arrangements ............................................................................................................................................. 17
2.4.10 Crewmember Documentation Required by Crew Department ............................................................................... 17
2.4.11 Submission of the Crewmembers’ Documentation ................................................................................................. 17
2.4.12 Verification of Qualifications and Certificates ......................................................................................................... 18
2.4.13 Official Declaration of Personal Medication ............................................................................................................ 19
2.4.13.1 COVID‐19 Precautions** ....................................................................................................................................... 19
2.5 Crew Changes OFFSIGNING CREW .......................................................................................................................... 20
2.5.1 Extension of Contract ................................................................................................................................................. 20
2.5.2 Notification for Signing‐Off ........................................................................................................................................ 20
2.5.3 Repatriation of Crewmember .................................................................................................................................... 21
2.6 Crew Changes ONSIGNING CREW ........................................................................................................................... 22
2.6.1 Articles of Agreement ................................................................................................................................................ 22
2.6.2 Official Declaration of Personal Medication .............................................................................................................. 22
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2.6.3 Crew Certificates & Documents ................................................................................................................................. 22
2.6.4 Crew Lists ................................................................................................................................................................... 30
2.7 Crew Familiarization .............................................................................................................................................. 31
2.7.1 Safety & Security Familiarization ............................................................................................................................... 31
2.7.1.1 Stages in Safety Familiarization .............................................................................................................................. 31
2.7.1.2 Security Familiarization ........................................................................................................................................... 31
2.7.2 Job Familiarization ..................................................................................................................................................... 31
2.7.3 IMS Training ............................................................................................................................................................... 32
2.7.4 Assessment of Qualifications and Skills ..................................................................................................................... 32
2.8 Crew Handovers ..................................................................................................................................................... 33
2.8.1 "OVERLAPPING" ......................................................................................................................................................... 33
2.8.2 Senior Officers, officers and Senior Ratings Hand over ............................................................................................. 34
2.8.3 Senior Officers Handovers after Promotions ............................................................................................................. 34
2.8.4 Master’s Handover ..................................................................................................................................................... 34
2.8.5 Chief Officer’s Handover ............................................................................................................................................ 35
2.8.6 Chief Engineer Handover ........................................................................................................................................... 36
2.8.7 Second Engineer Handover ........................................................................................................................................ 36
2.9 Probation Period .................................................................................................................................................... 37
2.10 Crew appraisals .................................................................................................................................................... 37
2.10.1 Officers and Ratings Performance Appraisals onboard ........................................................................................... 37
2.10.1.1 Appraisals Responsibilities .................................................................................................................................... 38
2.10.1.2 Appraisals Reporting ............................................................................................................................................. 39
2.10.1.3 Officers and Ratings Performance Appraisals by Office Staff ............................................................................... 39
2.10.2 Training Needs identified during the Appraisal Process .......................................................................................... 40
2.10.3 Ship Staff Safety and Performance Award ‐ Recognition of excellent performance ............................................... 40
2.11 Senior Officers De‐Briefing ................................................................................................................................... 40
2.11.1 De‐Briefing Agenda .................................................................................................................................................. 41
2.11.2 De‐Briefing Participants ........................................................................................................................................... 41
2.11.3 Office Assignments .................................................................................................................................................. 42
2.11.4 Refresher Familiarization & Assessment Programs ................................................................................................. 42
2.12 Crew Re‐employment Procedure & Crew .............................................................................................................. 42
2.12.1 Application for Re‐employment ............................................................................................................................... 42
2.12.2 Bonuses .................................................................................................................................................................... 43
2.13 Promotions .......................................................................................................................................................... 43
2.13.1 Conditions & Exemptions ......................................................................................................................................... 44
2.13.2 Rank Specific Psychometric Assessments & English Language Skills for Promotion ................................................ 48
2.13.3 Acceptance /Rejection of Promotions ..................................................................................................................... 49
2.14 Disciplinary Process .............................................................................................................................................. 50
2.14.1 Master’s Responsibility and Level of Authority onboard ......................................................................................... 50
2.14.2 The Levels of Offence/Violation ............................................................................................................................... 51
2.14.3 Discipline Guidelines ................................................................................................................................................ 52
2.14.4 Discipline Procedures ............................................................................................................................................... 52
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2.14.5 Progressive Disciplinary Levels ................................................................................................................................. 53
2.14.5.1 Warnings ............................................................................................................................................................... 53
2.14.5.2 Sever Sanctions (Dismissals) ................................................................................................................................. 54
2.14.5.3 Disciplinary Process for Third Party Contractors’ Personnel................................................................................. 56
2.15 Manning in Port & Shore Leave ............................................................................................................................ 56
2.15.1 Manning Rules while in Port .................................................................................................................................... 57
2.15.2 Crew Shore Leave ............................................................................................................................................ 57
2.16 Vessel’s Supernumeraries ..................................................................................................................................... 59
2.16.1 Visits while the Ship is in Port .................................................................................................................................. 59
2.16.2 Permission to Travel on the Ship ............................................................................................................................. 59
2.16.3 Inclusion of Supernumeraries in the Crew List ........................................................................................................ 60
2.16.4 Terms and Conditions for Supernumeraries‐ Indemnity Form ................................................................................ 60
2.17 Master’s General Account (MGA) ......................................................................................................................... 60
2.17.1 Processing the MGA ................................................................................................................................................. 60
2.18 Personal Crew Files .............................................................................................................................................. 61
2.18.1 Personal Crew Records ............................................................................................................................................ 61
2.18.2 Processing Personal Crew Files ................................................................................................................................ 62
2.19 Records of Airline Tickets ..................................................................................................................................... 63
2.20 Crew Emergency .................................................................................................................................................. 63
3. RECORDS .................................................................................................................................................... 63
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1. Purpose
This procedure describes the required processes for management of the Shipboard personnel.
2. Procedure
2.1 RECRUITMENT OF SEAFARERS
Seafarer shall be presented to the Company as soon as possible.

This is reported by the Manning Agent through their CV forms "Record of Personal Information
and Last Experience" which is sent for review and includes:
• Seafarer's Personal Details & Educational History
• Licenses and Certificates available
• Previous Sea Service
• Other profiling information
The Manning Agents have qualified, experienced and dedicated personnel, who select, and shortlist
candidates following a rank specific process in co-ordination with Crew Department to address specific
vessel’s needs or special competencies and in compliance with the procedures described in:
PROC 22 2.2.1 Criteria for Setting the Vessel’s Crewing Level
PROC 22 2.3.1 Standard Minimum Experience Requirement per Rank
PROC 22 2.3.4 Minimum Age Limit
PROC 22 2.3.5 Maximum Age Limit
PROC 22 2.3.6 English Language and Computer Skills
The candidates are requested to documentation such as:
 Past Experience  Interview reports  Certificates/Qualifications

(all seafaring career)
 Compatibility with  Physical Appearance  Sociability
Prime’s philosophy
 Communication Skills  Soft Skills  Professional Knowledge
 Attitude  English Language  Salary , Service period
Table
 Age  Training  Appraisals (previous employer if
Requirements applicable/required)
 CES STCW test
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The following table depicts information/reports the Manning agent should provide as a minimum.
Table 1
Tests/Reports to be provided by the Manning Agent
Rank Recruitment CES Test Minimum Required

Documentation
 CES STCW Deck Management  Candidates full CV
Master
Oil or LPG *  CES wrong answer
summary
Chief Officer  CES STCW Deck Management  Candidates full CV
summary
Deck Officers  CES STCW Deck Operational Oil or  Candidates full CV
LPG *  CES wrong answer
summary
Chief Engineer  CES STCW Engine Management  Candidates full CV
2nd Engineer Slow speed  CES wrong answer
summary
Engineer  CES STCW Engine Operational  Candidates full CV
Officer Medium speed  CES wrong answer
summary
Electrician  CES Electrical/Electronic/Control  Candidates full CV
(ETO) Engineering (Operational Level)  CES wrong answer
summary
 Interview Report
Pump-Man  CES Cargo Handling & Stowage  Candidates full CV
Gas Eng Oil or LPG (support Level) *  CES wrong answer
 CES Maritime English Deck (Support summary
Level)  Interview report
 English Language table
Deck Ratings  CES STCW Deck Support  Candidates full CV
 CES Maritime English Deck (Support summary
Level)  Interview report
Engine Ratings  CES STCW Engine Support  Candidates full CV
 CES Maritime English Engine  CES wrong answer
(Support Level) summary
 Interview report
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Rank Recruitment CES Test Minimum Required

Documentation
Cook  CES Catering Operational  Candidates full CV
 CES wrong answer
summary
Catering  CES Catering support  Candidates full CV
Ratings  CES wrong answer
summary
* As applicable to ship type the candidate is applying for Tanker or LPG
Conditions and exemptions

1. Passing CES Test Score is :
 OFFICERS: Overall 70% no less than 60% in each Chapter
 RATINGS: Overall 60%
2. In case a candidate does not achieve the required Score in the 1st attempt, he can repeat the
test up to a maximum of three (3) times.
3. Time limit is set at 160 seconds per question for all tests.
4. Passing Maritime English at Support level score for ratings is 55%
5. Earlier CES tests may be accepted provided that they are recent (No major revision within the
SEAGULL testing system)
2.1.1 Rank-Specific Interviews
The submitted documentation is reviewed by the Crew Department and if acceptable interviews shall be
conducted as outlined below.
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Table 2
Recruitment Interviews
RECRUITMENT
RANK
1. Crew Department and/or Crew Manager
Master
2. Vetting Department and/or Vetting Manager or Operations manager
Chief Officer 1. Crew Department and/or Crew Manager
2. Vetting Department and/or Vetting Manager or Operations manager
Deck Officers 1. Crew Department
2. Vetting Manager and/or Navigation Officer
Chief / 2nd 1. Crew Department and/or Crew Manager
Engineer 2. Technical Fleet-manager
Engineer Officer 1. Crew Department
2. Technical Instructor
Elect. (ETO) 1. Technical Instructor (if required) *
Pump-Man 1. Crew Department (if required) *
Gas Eng
Deck Ratings 1. Crew Department (if required) *
Engine Ratings 1. Crew Department (if required) *
Catering 1. Interview by Crew Department (if required) *
* Interviews are established after reviewing manning agent’s submitted records

(CV, Sea services, qualifications experience, assessment and English language table)
2.1.2 Rank Specific Psychometric Assessments & English language skills
After a successful interview, psychometric and English assessment are conducted according to rank as
per the below table.
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Table 3
Psychometric Assessments & English Language Skills
RECRUITMENT
RANK
 Psychometric Assessment
Master
 Language MARLINS Deck Management Level Assessment **
Chief Officer  Psychometric Assessment
Deck Officers  Psychometric Assessment
 Language MARLINS Deck Operational Level Assessment **
Chief & 2nd  Psychometric Assessment
Engineer  Language MARLINS Engine Management Level Assessment **
Engineer  Psychometric Assessment
Officer  Language MARLINS Engine Operational Level Assessment **
Electrician  Psychometric Assessment
(ETO)  Language MARLINS Engine Operational Level Assessment **
**English test may be omitted if candidate demonstrates the required fluency during the
interview
Passing MARLINS test is:

 Master & Chief Officer 85%
 Junior Deck Officers 75%
 Chief Engineer officers 75%
 2nd Engineer officers 65%
 Junior Engineer officers 65%
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2.1.3 TESTs Description
 CES, (Crew Evaluation System) is designed to evaluate the background knowledge of

seafarers. It consists of a question database with over 6,500 multiple choice questions, specific
to the knowledge areas defined in STCW.
 Psychometric Questionnaire: Is a holistic test that assesses the important qualities of seafarers,
covering personality, behavior, leadership, resilience, soft skills and psychosocial risks and
measures 77 factors.
 MARLINS Language tests: The Marlins use contemporary English testing methodology that
enables assessment on Seafarers understanding of English quickly and accurately and
providing an overall language profile of the seafarer.
 IMS tests: The IMS system manuals of the company are made available to the Candidates.
In turn they are required to pass this test in order to familiarize themselves with its structure
content, policies, and how to seek information and guidance within it.
A Seafarer may be requested to repeat the above or others (competency specific) available in the
SEAGULL CES system or designed by the Company for reasons such as:
• To test the effectiveness of Training Courses attended
• To verify reliability of previous Tests
• To facilitate focused screening
• To facilitate focused screening on interview raised issues/concerns
• To examine specific competencies
The test reports are reviewed by the Training and Crew Manager.
Psychometric Tests Provider maybe asked to review for their input, should clarifications are needed.
2.1.4 Acceptance /Rejection of a Seafarer

The Crew Department shall review the, i n t e r v i e w s a n d t e s t r e p o r t s as soon as possible and
revert to the manning agent i n writing with either confirmation of acceptance or rejection.
At this point, candidates are accepted for employment.
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2.1.5 Training/Familiarization of Officers

The procedure describes the process of, Training / familiarization of the Officers after successful test and
interviews.
The Duration of the training/familiarization is minimum 1 week and can extend to as long as deem
necessary to satisfy company’s requirements and vessel specifics needs if known at this stage.
Officers who are new to the Company / or newly promoted officers are invited to company facilities
for training, familiarization and assessment as required.
Online software solutions and virtual classrooms led by the Training Manager or Training Department
instructors can be also used instead.
This process is organized by the Training Department (PROC 23).
The PMA/TC, POTF and PRRF are responsible to train and familiarize them as per para. 2.2.2.1 of
Procedure 23 and other trainings as defined by the Training Department or prescribed in the interviews.
During this period, the officers receive training/certification and attend online or class based training,
courses, simulation exercises as well as familiarization with company Integrated Management
System, the latter aims to train seafarers on how to find answers in the IMS regarding certain topics
related to their rank.
The manning agents make available the manuals to the seafarers for studying and use, at the end a test is
undertaken to verify their engagement.
RANK RECRUITMENT
 IMS test for senior deck officers *
Master & Chief
Officer
Deck Officers  IMS test for junior deck officers *
Chief & 2nd  IMS test for Chief Engineer and 2nd Engineer *
Engineer
Engineer  IMS test for Junior Engineer officers *
Officer & ETO
* The Passing score is set at 75%.
2.1.6 Training/Familiarization of Ratings

Ratings receive training/certification and attend online or class based training, courses, if required
consistent with as per § 2.2.2.1 of Procedure 23-“Training”.
The manning agents shall make available the IMS manuals to the seafarers for studying and use, at the
end a test is undertaken to verify their engagement.
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RANK RECRUITMENT IMS TEST

Pump-Man  IMS test for Deck Ratings *
Gas Eng
Deck Ratings  IMS test for Deck Ratings *
Engine IMS test for Engine Ratings *
Ratings
Cook  IMS test for Catering Ratings *
Catering  IMS test for Catering Ratings *
Ratings
* The Passing score is set to 65%.
At this point should immediate vacancies are open, Seafarers are assigned ships and approved
consistent with Table No. 1 “Approval Authority for Seagoing Personnel’s Selection”.
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2.2 SEAFARERS APPROVAL

The approval authority for vessel assignment/employment of seagoing personnel (Officers) whether
promoted, recruited or from the pool for vessel assignments is in accordance with the below Table.
Table No. 4 : Approval Authority for Seagoing Personnel’s Selection
Departments
Crew Training Technical Operation Marine/ Vetting DCOO
Ranks or COO
Master & Chief Approval Approval Approval Approval -
Officer (existing) Manager Manager - Manager Manager
Master Approval Approval - Approval Approval Approval
(new & promoted) Manager Manager Manager Manager (Final)
Chief Officer Approval Approval Approval Approval
(new & promoted) Manager Manager - Fleet Operator Fleet Marine -
Superintendent
Deck Junior Officers Approval Approval - Approval Approval -
(existing) Manager Manager Fleet Operator Fleet Marine
Superintendent
Deck Junior Officers Approval Approval - Approval Approval -
(new & promoted) Manager Manager Fleet Operator Fleet Marine
Superintendent
Deck Junior Trainee Approval Approval - Approval Approval -
Officers Manager Manager Fleet Operator Fleet Marine
(new & promoted) Superintendent
Chief Engineers Approval Approval Approval - -

(existing) Manager Manager Tech. Manager/ -
Fleet Manager
Chief Engineers Approval Approval Approval - - Approval

(new & promoted) Manager Manager Tech. Manager/ (Final)
Fleet Manager
2nd Engineers Approval Approval -
(existing, new & Manager Approval Technical - -
promoted) Manager Superintendent/
Junior Engineer Approval Approval Approval - - -
Officers (existing) Manager Manager Technical
Superintendent
Junior Engineer Approval Approval Approval - -
Officers Manager Manager Technical -
(new & promoted) Superintendent
Other Crew Operator - - - - -
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The "Seafarer Approval" report shall be signed electronically by the Crew Manager and shall also take into
account the Appraisals of previous services (i.e. the seafarers must have been appraised as “Suitable for re-
employment”).
2.3 SENIOR OFFICERS BRIEFING
2.3.1 Senior Officers Newly Recruited or Promoted

Masters and Senior Officers Newly recruited or promoted, may be invited if necessary to POTF or
PRRF or to Head Office for a one (1) day briefing, or remotely via teleconference in order to discuss
issues of the previous contract or provide personal guidance, or when the next contract is a special case
e.g. new charterer, different type of Main Engine etc.
The pre-employment Briefing may also be conducted through ZOOM using the forms:
• OFF/CRW/516A- “Briefing of Masters and Chief Officers”.
• OFF/CRW/516B -“Briefing of Chief Engineers and Second Engineers”.
2.3.1.1 Briefing Agenda

Briefings, sessions shall include subjects such as:
• Company’s Structure, Policies, Mission, Vision, Objectives, KPIs, Long Term Goals, etc.
• Roles and Responsibilities.
• Standards to be maintained onboard with regards to IMS.
• Any recent IMS Amendments, Circulars issued etc.
• Technical & Operational Standards and Procedures to be maintained onboard.
• Emergency Response Plans.
• Vessel’s current specific issues such as maintenance plan, defects, outstanding from SIRE
inspections, PSCs and Flag.
• Familiarization of vessel through specific presentation.
• Safety issues.
This process is organized by the Crew Department however, Departmental Managers shall control the
briefing, de-briefing, interview and interdepartmental delegation of the process.
The Briefing shall be ship-specific to the extent possible and shall be carried out as follows:
Shipboard Officers Office Staff Briefers

Masters and Chief Officers All Departments
Chief Engineers and 2nd Engineers All Departments –except for CSO
The Briefing shall be performed on:

 Tuesdays,
 Wednesdays,
 Thursdays of every week.
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2.3.1.2 Briefing Participants

Officers should be briefed by appropriate Departments, as per below Matrix:
Rank / Dept. Marine / SAQ / Security / Technical / Stores DCOO/DPA

Operations Crew/ Training
Master X X X
Chief Officer X X X **
Chief Engineer X X X
2nd Engineer X X
The Briefing shall be performed by the relevant Superintendent of the respective vessel while the
departmental Manager may participate on a sampling basis ad-hoc.
In the event that the Superintendent will not be able to perform due to other commitments he should be
substituted by the Departmental Superintendents.
**The DCOO/DPA, briefs for Management Level Officers on a sampling basis ad-hoc and retains
the right to be fully engaged in the process especially on significant incidents or where it is deemed
appropriate while following up on special cases.
Any other Office Staff may also be involved in the Briefing process, if there are issues to be discussed.
The items of discussion will be recorded electronically in the ERP system forms or alternatively in
Briefing Forms (mentioned above) which shall be signed and delivered to the Crew Department.
2.3.2 Senior Officers previously served on Company’s Vessels

Briefing of Senior Officers that previously served on company vessels shall follow the same process as
it i described in §2.3.1.
2.4 PREPARATION FOR JOINING CREW

Once a seafarer is approved and assigned to a ship, the Manning Agent is notified in writing by the
Crew Department, in order to proceed with the necessary arrangements and prepare the seafarer for
joining the Vessel in time.
The following shall be ensured:
• Certificates of Competency.
• Flag Administration Certificates of Competency.
• National seamen’s’ book and Seafarer’ Identification and Record Book.
• Security Certificate for Criminal Liability for all newcomers.
• Pre-employment Medical Examinations.
• Vaccinations.
• Visas.
• Pre-departure Briefing.
• Traveling Arrangements.
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Each of the aforementioned is analyzed below.
2.4.1 Certificates of Competency

All required Certificates of Competency must be authentic and valid for the entire period of the Seafarer's
service contract.
2.4.2 Flag Administration Certificates

No Crewmember may perform duties onboard a registered Vessel, unless he is holder of a Certificate
issued by the Flag Administration.
In case the Crewmember is not a holder of such Certificates, or they have expired, the Manning Agent
is responsible to make the necessary applications to Flag Administration for their issuance.
2.4.3 National Seaman’s book, Seafarer’ Identification and Record Book (SIRB)
Seaman’s book issued by the national authority.
SIRBs are issued by the flag administration. In case the Crewmember is not a holder of the SIRB, the
Manning Agent is responsible to make the necessary applications to the Flag for its issuance.
The Seafarers SIRB contains Certificates of Special Qualifications issued to the Holder and the sea
service is recorded and endorsed by the Master.
Seafarers may be given a Document containing a Record of their Employment onboard the Ship upon
request.
For seafarers not required to possess a SIRB, a Certificate of Service is issued by the Master as per Form
SF/CRW/510-"Employment Confirmation”.
These Documents must contain sufficient information, with a translation in English, to facilitate the
acquisition of further work or to satisfy the sea-service requirements for upgrading or promotion and
shall NOT contain a statement as to the quality of the Seafarer's work or wages.
2.4.4 Security Certificate for Criminal Liability

This document can be called in different ways:
Police Clearance Certificate, No Criminal records Certificate, Certificate of Good Conduct, Criminal
history clearance, Certificate of no criminal conviction, Police Certificate, Criminal History Record
Information, Background screening certificate, Certificate of clean criminal record.
The document is produced by the request of the individual after approval and indicates the information
of previous convictions or criminal cases according to the Police database.
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2.4.5 Pre-Employment Medical Examinations

As per Procedure 22-“MLC Requirements”
In addition, before embarkation new applicants undergo the Mental and Alcohol Test developed by the
Company and the contracted Medical Advisor (Ship MedCare) for the evaluation of Alcohol abuse
tendencies and likely Mental Health issue.
The results of those are evaluated by Ship MedCare, who advises the Seafarer and the Company.
2.4.6 Vaccination
The Company shall advise the Manning Agent of any vaccination requirements, in addition to Cholera
(if/where required) and Yellow Fever.
All required vaccinations must be valid throughout the Seafarer's contract period.
2.4.7 Visas
If a visa is required, the Manning Agent, in cooperation with the Crew Department, shall arrange for its
issuance.
2.4.8 Manning Agents’ Pre-Departure Briefing

The Manning Agent shall brief the joining Crewmember before his departure. The Pre-departure Briefing
shall include the following:
• SEA review and acceptance of Terms and Conditions of Employment
• Company's Policies- Company’s Notices.
The Manning Agent shall check the SEAGULL record of the joining crewmember and have him
attend the Company’s Notices pending review. In case the seafarer is to join the Vessel with such
items pending, the Manning Agent shall inform the Training Department that will take further action.
• Disciplinary Process
• Hygiene awareness
• Traveling Arrangements
• COVID precautions
• Emergency Contact Numbers of Port Agent and Crew Manager
• Hotel/Accommodation Terms; the Company does not cover Mini-bar, drinks & private phone calls
• A copy of the Company’s Travelling Policy which shall be handed over to the joining Crewmember
for review.
This shall be stated in the Manning Agents form MAN/AGENT/004 - “Crew Personal Data –
Transmittal Sheet”.
Additionally, the form MAN/AGENT/006 - “Travel Guidance Checklist” shall be handed over to the
joining Crewmember.
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2.4.9 Traveling Arrangements

The Crew Department shall make all the necessary traveling arrangements from the Port/Town of
engagement to Vessel and vice versa.
In some cases, the traveling arrangements may be arranged by the Manning Agent, after agreement with
the Crew Department.
The Company shall inform the Manning Agent of the flight details, split ticket arrangements, overnight
accommodation and Port Agents and Crew Manager's contact details.
The Manning Agent shall, in turn, pass on to Crewmember this information and traveling schedule. In
addition, he shall ensure that the Crewmember is in possession of International Passport with validity not
less than 16 months, while for the Seaman’s Book the required validity is not less than 10 months.
The Company and Vessel’s Master shall ensure that seafarers joining Company Vessels will be well-
rested prior to embarkation and taking-over their duties.
2.4.10 Crewmember Documentation Required by Crew Department

The approved seafarer is referred to as "Crewmember" and all his documentation shall be made available
to Crew Department through the CrewWeb portal.
These records shall include, but are not limited to:
• Personal Details (Address, Next of Kin, Date of Birth, Dependents, Bank Account).
• Seafarer's Qualifications and copies of all the Certificates and Seaman's Book (stating the Type,
Number, Date of issue, issuing Authority, Date of Validity).
• Medical Details (Medical Certificate as per MLC), Vaccination record, Health Certificate,
significant Medical History and Epidemic Certificates (especially required for Catering Personnel)
• Service Record (Performance Reports, additional reports, as applicable).
• Record of Previous Employment, References etc.
• Seafarer's Employment Agreement (SEA) signed by the crewmember and Company’s
representative.
• Training Records/Certificates.
2.4.11 Submission of the Crewmembers’ Documentation

The Crewmember’s documentation shall be transmitted to Company accompanied by the MAN 004-
“Transmittal Sheet”, signed by the dedicated employee of the Manning Agent and confirming that:
• Crewmember's Certificates were checked and found authentic.
• Crewmember's past experience was verified and found satisfactory.
• Crewmember has been familiarized with the Company’s “Traveling Policy-Guide”.
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2.4.12 Verification of Qualifications and Certificates

The recruitment process includes verification that the qualifications of the new recruit are genuine,
through checking Certificates with the issuing Authorities and contacting former Employers to verify
experience (if referred to by the candidate).
A. Responsibility of Manning Agents
Ensure that all Crew who are to join the Vessel have valid, authentic and original certificates suitable
for their Rank and consistent with table in §2.4.4 “Crew Certificates & Documents”.
The Manning Agent shall fully check the authenticity of the Certificates of any candidate before
employment. Verification of the authenticity is carried out in the following occasions:
 Whenever Seafarers which are new to the Company are recruited.
 Whenever Seafarers present new Certificates, not previously screened.
 Whenever there is a suspicion of fraud.
All Crew Documentation must be valid for the duration of the anticipated Contract period
Manning Agent's must also check the Seafarer’s security background, for new Employees.
B. Responsibility of the Crew Department
Ensures that all Crew who are accepted to join a Vessel are certified as per STCW and MLC
requirements, and are holders of any additional valid Training Certificates according to their Rank, as
required by the Company.
In addition to the authenticity checking by the Manning Agent, the Crew Department performs an
additional random checking through the website (where this is available/possible) of the Organization
which has issued the Crew Certificates, to verify authenticity.
In case of Ukrainian Crew, the site “Inspection, Training and Certification of seafarers” is visited
(https://verification.itcs.net.ua/en).
The Crew Department shall check at least one (1) Crew mandatory Certificate/per Vessel/per
Month, by random selection.
The relevant records are filed in the file kept by the Crew Department–“Authenticity of Crew
Certificates”.
In this file, which is sorted per Vessel, the monthly checking documentation is found as follows:
 A copy of Crew List – valid at the date of checking – with the names of the Crewmembers for whom
the checking was done highlighted.
 Attached to Crew List are the “printouts” from the website of the Organization which has issued the
Crew Certificates.
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C. Non Authentic Crew Certificates

In case Crew Certificates are found fraudulent, this shall be considered as a Breach of the Agency
Agreement.
In addition, the Crewmember who has presented them shall not be employed/re-employed.
When fraudulent Crew Certificates are identified, the Flag Administration shall be notified, as per their
reporting requirements.
2.4.13 Official Declaration of Personal Medication

During the Seafarers’ Pre-employment Medical Checks, the Approved Medical Centers shall issue an
Official Declaration, listing the regular prescribed Medication which the Seafarer is receiving (Manning
Agent Form MAN/AGENT/005- “Declaration of Personal Medication on prescription”.
2.4.13.1 COVID-19 Precautions**
During the COVID-19 epidemic, the procedure below must be followed by Crew travelling to join a
vessel:
 No Crewmember should join a ship if they are feeling ill or suffering from flu-like symptoms.
 All travelling Crew must pass a PCR test, at least 48 hours prior to departure.
 Until the embarkation on the airplane, they must remain isolated in separate rooms/spaces
without any contact between them.
 Hygiene PPE (masks, gloves, antiseptic gel) must be available and used at all times.
 They must travelling by separate cars.
 In case one of the Crewmembers is found to be “positive” and have been in contact with other
on signing Crew at any point during the preparation process, then the departure of all the group
of on-signers will be cancelled. Social distancing procedures should be in place during the hand
over between the on and off signing seafarer. The off-signing seafarer must report to the
Company if during the 14 days following leaving the ship they feel ill or exhibit flu-like
symptoms.
 Similarly, if there is a suspected outbreak on board, the company must inform all off-signers of
the situation within 14 days of their departure from the ship.
On signing, Crew luggage should be handled with gloves and cleaned thoroughly before it is brought
inside the accommodation
** See COVID-19 Management Plan (Found in ERP as Circular, under the Category COVID-19)
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2.5 CREW CHANGES OFFSIGNING CREW

This procedure describes the process of Crew changes for the off signing crew.
As a general rule the following shall be taken into consideration by the Crew Department:
• The Master and Chief Officer must not sign-off simultaneously
• The Chief Engineer and the 2nd Engineer must not sign-off simultaneously
• Preferably, the Master and Chief Engineer shall not sign-off simultaneously, however this is
reviewed on a case-by-case basis.
• Changes of other Officers/Ratings must not exceed 50%.
• The "Combined Experience" of the Senior Officers.
• Preferably, Seafarers of our “Pool” to serve in the same Company’s Vessels.
• Due to pandemic restrictions world-wide and difficulties encountered the above procedure may be
deviated, provided that a thorough Risk Assessment is in place.
2.5.1 Extension of Contract

If a Crewmember wishes to extend his Contract, he shall declare this to the Master in writing.
The Master shall notify the Crew Department in order to obtain approval. The Crew Department shall in
turn notify the Manning Agent.
A new SEA shall be sent onboard by e-mail (scanned) bearing the signature of the Manning Agent's
authorized person.
The new SEA shall be signed by the Crewmember and sent back to Manning Agent and to Crew
Department. The Crewmember shall also be handed a signed copy of his SEA.
2.5.2 Notification for Signing-Off

When a Crewmember's Contract is to expire and he wishes to sign-off, he shall submit a written notice
to Master 45 days prior to the expiration date of his Contract.
The Master, in turn, shall immediately submit this notification to Crew Department.
Crew changes may also occur for reasons other than Contract expiration i.e. Crew may request to sign-
off due to serious family problems or due to sickness.
They may also be required to sign off:
• following an accident onboard, during which they were injured, or
• when they are under a post-traumatic stress due to the accident, or
• as a result of disciplinary action taken by the Company.
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2.5.3 Repatriation of Crewmember

When the Crew Department receives a notification for Crew replacement, it takes the following actions:
• Checks the Contracts of the Crewmembers who wish to sign-off, to ensure that their Contracts are
actually expiring
• Approves the Crew changes, taking into account the Company P olicy for Crew Changes and the
"Combined Experience" of Senior Officers
• Contacts with the Manning Agent in writing and requests substitutes of the same Rank
• Advises the Master of the Crewmember to be replaced, and the Port, Date etc. of replacement
• Approves the proposed Candidates.
• Advises the Manning Agent of the approved Candidates.
• Appoints the Port Agent, in order to arrange for the Crew changes, requesting any information on
special Visas, Vaccinations etc.
• Informs the Manning Agent of the time and Port of Crew change, and provides any information
available for Visas, special Vaccination etc. provided by the Port Agent.
• Contacts the Travelling Agent, requesting information for flights to the Port of destination
• Advises the Manning Agent, the Master and the Port Agent when the flights for both joining and
sign-off Crew are confirmed.
• Arranges Cash to Master for the pay-off of the signing off Crew.
• Requests from the Master a confirmation Message of safe embarkation/disembarkation
• Requests from the Master an updated Crew List, after each Crew change.
• In case the Crew change is more than 25%, advises the S&Q Department, in order to monitor
Abandon, Fire Drills and Security Drills, as per SOLAS & ISPS Code requirements.
• Updates the Crew Department Database with the on-signers Personal Data.
• Updates the Box Files – “On-Duty Crew” (with the Personal Folders of the on-signers) and transfers
the Personal Crew Folders of the off-signers in the Box Files – “Off-Duty Crew”.
• Updates ERP (e.g. BENEFIT) Crew Module accordingly.
• Ensures that all the Personal Data and Documentation of the new on-signers (Certificates, Medical
Reports, etc.) are sent in good time by the Manning Agent.
Shipboard personnel who are to be repatriated shall review the Company’s Travelling Policy found
in IMSM (001) – Appendix U and refer to Form TEMP 24-“Travel Guidance Checklist”.
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2.6 CREW CHANGES ONSIGNING CREW
The procedures describes for the on-signing crew.
2.6.1 Articles of Agreement

Every Seafarer joining a Vessel shall sign the Shipping Articles (as per the Form provided by the Flag
Administration) prior to Vessel's departure from the Port at which the Seafarer joined the Vessel.
The Master shall officiate at the signing-on of each Seafarer, and sign his name to the Shipping Article.
The signing-off of the Shipping Articles by a seaman at the time of his discharge from employment
onboard does not constitute a waiver on his part of any claims he may have against the Vessel or the
Master at that time.
The Form of the Shipping Articles shall be annexed to the Crew List.
2.6.2 Official Declaration of Personal Medication

On joining, the crewmember shall hand a copy of this Official Declaration to Master who will maintain
it to the Crew Personal Files.
This will be recorded in Form SF/CRW/511-“CrewQualifications Checklist”.
2.6.3 Crew Certificates & Documents

Except the responsibilities for checking the Crew Certificates my Manning agent and Crew Department
The Master shall check all the Certificates of the on-signing personnel before they officially undertake
their duties and releasing the out-going personnel.
During the checking of incoming Crewmembers’ Certificates, the Master shall ensure that:
 The Ship's Manning Level complies with the Ship's Minimum Safe Manning Certificate.
 The Seafarer is NOT under the age of 18.
 All the Certificates are Original.
 The Crewmembers have received the necessary Vaccination (e.g. Yellow Fever).
 The Crewmember's knowledge of the English Language is sufficient to enable him to perform his
duties as per his Rank.
 The Crewmember is Holder of all Certificates as per the Crew Qualifications Checklist for his rank
(refer to below Table which is in consistency with Form SF/CRW/511 –“Crew Qualifications
Checklist”).
(Refer to Crew Qualifications Table, on next page and to relevant Color / Symbol Code).
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Table No. 5 “Crew Qualifications”.
COLOUR / SYMBOL CODE OF CREWQUALIFICATIONS/CERTIFICATION PER RANK

On pages 19-
Applicable to ICE classed vessels

Applicable to chemical vessels.
Applicable to Liquefied Gas Tankers.
Applicable to fast rescue boat equipped ships
Applicable to Vessels with Electronic Engines. Certification is required for 1 of the 2 senior engineers
Applicable to AFRAMAX & SUEZMAX vessels
1 Cooks shall have completed a training course approved by the Flag State or instituted approved by the administration covering
practical cookery, food and personal hygiene, food storage, stock control, environmental protection and catering health and safety.
2
Required for 2nd Officer designated to provide medical care on-board.
3
Ship-handling required for Masters & Chief Officers & Second Officers
4
Can be supplementing or replacing ECDIS specific/generic which is approved in-house certification
* Has a biannual validity - Color Vision certificate is included or provided in separate certificate that has a validity of 6 years
** Refresher every 5 Years
Crew or other members missing/not having A-VI/6-1 (All Officers and Ratings not holders of SSO, or Security Designated Duties,
members of Technicians, Riding Teams sailing with the vessel
NOTE They have to be provided onboard by Master on form SF/SEC/905A), These individuals should in addition take the SEAGULL CBT
No: 115 “Security awareness”
For the Non-Statutory courses other equivalency options (e.g e-learnings) are considered valid.
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Crew Qualifications Table (as per Form SF/CRW/511)

DECK ENGINE CATERING
OFFICERS RATINGS OFFICERS RATINGS RATINGS

OPER
MANAGEME
MANAGEMENT ATIO - SUPPORT OPERATIONAL - SUPPORT SUPPORT
NT
NAL
Master Chief. 2/Off- Deck Bosun AB OS Chief. 2nd 3/Eng ETO GAS Engine Pump- Oiler/ Wiper ETR Cook1 Mess
Off. 3/Off Cadet Eng. Eng 4/Eng Eng Cadet -Man Motor man
J TDO man Fitter
FLAG AND NATIONAL CERTIFICATES / DOCUMENTS / ENDORSEMENTS / GENERAL REQUIREMENTS

Seaman’s book
(as per Flag X X X X X X X X X X X X X X X X X X X
requirements)
Medical Certificate
(SEA)*
X X X X X X X X X X X X X X X X X X X
D&A pre-joining
examination
Valid Passport X X X X X X X X X X X X X X X X X X X
Visa (as applicable) X X X X X X X X X X X X X X X X X X X
Yellow fever /
Vaccination book X X X X X X X X X X X X X X X X X X X
(as applicable)
National license (COC)
(Certificate of X X X X X X X X X X X X X X X X
Competency.)
Flag Endorsement
(if applicable)
X X X X X X X X X X X X X X X X
Official Declaration
Form MAN 005
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OPER
MANAGEME
NT
NAL
J TDO man Fitter
NAVIGATION WATCH OFFICERS & RATINGS

Navigat. Watchkeeping
A-II/1**
X
Navigat. Watchkeeping
A-II/2**
X X
GMDSS operators
A-IV/2**
X X X
Polar Code (Basic)
A-V/4-1**
X
Polar Code (Advanced)
A-V/4-2**
X X
Part of Navig. Watch
A-II/4
X
Able Seafarer Deck
A-II/5
X X
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OPER
MANAGEME
NT
NAL
JTDO man Fitter
ENGINEERING WATCH OFFCERS & RATINGS

E/R watchkeeping
A-III/1**
X
E/R watchkeeping
A-III/2**
X X
Electro-Technical
X
Officer A-III/6**
Electro-Technical
X
Rating -A-III/7
Ratings part of watch
X
in E/R A-III/4 -
Ratings able seafarer

X
in E/R A-III/5
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OPER
MANAGEMEN MANAGEME
ATIO - SUPPORT OPERATIONAL - SUPPORT SUPPORT
T NT
NAL
JTDO man Fitter
OIL TANKERS / CHEMICAL / GAS ENDORSEMENTS

Basic Training for Oil
and Chem. Tankers A- X X X X X X X X X X X
V/1-1-1 **
Advanced Training for
Oil Tankers A-V/1-1-2 X X X X X X X
**
Chemical Tankers X X X X X X X
A-V/1-1-3 **
Basic Training for
Liquefied Gas Tanker X X X X X X X X X X
A-V/1-2 -1 **
Liquefied Gas Tanker X X X X X X X X
A-V/1-2 -2) **
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OPER
MANAGEMEN MANAGEME
T NT
NAL
JTDO man Fitter
EMERGENCY, SECURITY, OCCUPATIONAL SAFETY, MEDICAL CARE AND SURVIVAL FUNCTIONS

Basic training A-VI/1-1~
1-4** (Can be 4 X X X X X X X X X X X X X X X X X X X
separate certificates)
Proficiency in survival
craft & rescue boats A- X X X X X X X X X X X X X
VI/2-1 **
Proficiency in Fast rescue
boats A-VI/2-2 **
X X X X
Advanced fire fight. A-
VI/3-1 **
X X X X X X X
Medical First Aid A-
VI/4-1**
X X X X
Medical care A-VI/4-2** X X X2
Ship Security Officer
(SSO) X X
A-VI/5**
Security training with
Designated Security X X X X X X X X X X X X X X X
Duties A-VI/6-2
Security Awareness
A-VI/6-1 -see NOTE
X X
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OPER
MANAGEMEN MANAGEME
T NT
NAL
JTDO man Fitter
ADDITIONAL (NON-STATUTORY) TRAINING

STCW BRM/BTM/SH
X3 X3 X3
IMO 1.22 **
STCW Operational use of
X4 X4 X4
ECDIS IMO 1.27 **
ECDIS Specific ** X4 X4 X4
STCW ERM IMO 2.07 ** X X X
Risk Assessment Incident
X X X X X
Investigation **
ISM & S/O ** X X X X X
Diesel ME- C Standard
X X
Operations
STCW LICOS TANKER
X X X X
GAS IMO 2.06 / 1.35 **
Train the Trainer X X X X
Crane Simulator** X
Mooring System and related
X X X X
Procedures **
Vessel’s Sanitary Program
X X
(MLC) **
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The pre-joining Medical Certificates shall be issued by a Medical Practitioner/ Institute licensed in the
place of examination. Lists of Approved Medical Practitioners/Clinics are found in File
TEC 02-“Vessel’s Secondary Certificates” under D.22.
The Medical Certificate is valid for Therefore, it must not be issued at a date of more than 2
(two) 2 years years before the date of signing the Articles of Agreement
The Certificate for Colour Vision is Therefore, it must not be issued at a date of more than 6
valid for six (6 )years years before the date of signing the Articles of Agreement
In urgent cases, the Competent Authority may permit a Seafarer to work without a Valid Medical
Certificate until the next port of call, where the Seafarer can obtain a Medical Certificate from a qualified
Medical Practitioner, provided that:
 A period of such permission does not exceed three (3 )months
 The Seafarer is in possession of an expired Medical Certificate for a period not greater than
6 months.
Must a Medical Certificate expire in the course of a voyage, it shall be in force until the next port of call,
where the Seafarer can obtain a Medical Certificate from a qualified Medical practitioner, provided that
the period shall not exceed three (3) months (Marshall Islands Regulation MI-108 7.47.4.d).
On a bi-annual basis, a periodic verification of Crew Recruitment, Training and Appraisal reports
must be carried out in order to verify the compliance with Company’s procedures
2.6.4 Crew Lists

After every Crew change, a new Crew List shall be issued immediately and not when the Vessel is ready
to leave the port.
Updated Crew Lists shall always be processed through the ERP BENEFIT module.
All Supernumeraries who are travelling with the Vessel (Ship Managers, Internal Auditors, Technicians,
Crew relatives) shall be mentioned in the Crew List. Contracted Armed Security Personnel shall also be
included in the Crew List as Supernumeraries or Security Guards.
Before accepting any Visitor/Supernumerary onboard, the Master shall ensure that the Vessel's Lifeboat
capacity is not exceeded, by checking the Cargo Ship Safety Equipment Certificate – Form E.
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2.7 CREW FAMILIARIZATION

The procedure describes the process for Crew Familiarization.
2.7.1 Safety & Security Familiarization

The Master shall ensure the Crewmember's familiarization (on Job, Safety and Security issues) with the
Ship and arrange the IMS and STCW familiarization.
On joining the Ship and before being assigned their duties, seafarers shall be made familiar with all
Safety Procedures and Equipment.
2.7.1.1 Stages in Safety Familiarization

The Safety Familiarisation procedure is carried out in 2 basic stages:
 The assigned Officer shall familiarize the newly joined Crew with all the Safety Equipment and
Procedures and shall complete the Safety Familiarisation Checklist.
After having received training, the new Crewmember shall complete the Safety Familiarisation
Checklist by himself assuming full responsibility that he has understood and is fully familiar with
all Safety Procedures and Equipment.
2.7.1.2 Security Familiarization

On joining the Vessel, each Crewmember shall receive Security familiarization (ISPS Code PART A-
§13, 13.5 & PART B- § 9.7) which includes, but is not limited to:
 Familiarization with Security Duties per rank and per Security Level and the relevant measures
for each Security Level
 Restricted Areas
 Access control
 Monitoring of deck and Ship surrounding areas and Security Patrols
 SSAS Tests (for Master and SSO)
 Citadel Area–Citadel Muster lists etc.
This Safety and Security Familiarization Checklist shall be completed in stages:
 Within the first 6 hours.
 Within the first 24 hours.
 Within 7 days.
2.7.2 Job Familiarization

All crewmembers joining the Ship shall be given the required familiarisation/training, so as to become
familiar with their duties and responsibilities on-board. This includes, but not limited to, the following:
 Visiting the spaces in which their primary duties will be performed
 Acquainting themselves with the location, controls and display features of equipment they will
be operating or using
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 When possible, activating the equipment and performing functions using the controls on the
equipment
 Being familiarized with Ship-specific watch-keeping, safety, environmental protection,
emergency procedures and all arrangements required to perform their assigned duties properly
 The Garbage Management Plan as related to their duties, etc.
The Master shall ensure that seafarers are given a reasonable period of time for their familiarisation
& training and are given the opportunity of observing and asking someone who is already familiar
with the equipment, procedures and other arrangements.
The newly joining seafarers shall be trained and familiarized with any ship-specific equipment not
commonly found on other Vessels (if any).
The Job Familiarisation Form shall be completed for all Ranks. In addition, depending on the Shipboard
Department, specific Job Familiarization checklists shall be filled in by the Crewmember:
 For Bridge Officers:
 SF/CRW/505A-1-“Bridge Equipment Familiarization”
 SF/CRW/505A-2-“ECDIS Familiarization”
 SF/CRW/505A-3-“ECDIS Certificate”
 For Deck Officers - SF/CRW/505B-“Cargo Equipment Familiarization”
 For Engine Room Officers -SF/CRW/505C-“Engine Room Familiarization”
 For Crane Operators -SF/CRW/505D- “Crane Operators Familiarization”.
2.7.3 IMS Training

Training is carried out to ensure that all shipboard personnel are familiar with the Company’s IMS:
 All seafarers joining a Ship for the 1st time shall be given training to introduce them to IMS and
shall review all IMS documentation (Manuals, Forms, Circulars, Posters, etc.).
 All seafarers who join the Ship following a period of leave, shall familiarise themselves with any
changes made during their absence.
 The Master and Officers shall become familiarized with ALL the IMS Manuals.
2.7.4 Assessment of Qualifications and Skills

 The Master must immediately report to Company any seafarer who does not have the appropriate
Certificates, Technical Skills or Qualifications to serve his Rank satisfactorily.
 In case the Crewmember is an Officer and his knowledge of English Language is not sufficient
for the performance of his duties, this shall be reported to the Company immediately.
 The Master shall also report any Officer when there is evidence or even suspicion that a
Certificate of Competency or special qualification was obtained by fraudulent means.
The Company shall then notify the Flag Administration, as per their requirements.
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2.8 CREW HANDOVERS

This procedure describes the process for the change of Crew on board, so that their relief is fully
informed about the Ship status related to their job function.
2.8.1 "OVERLAPPING"
When there is a change of Master, Chief Engineer, Chief Officer, Second Engineer, and Junior Deck
Officers (2nd and 3rd Officers), the "overlapping period" in order to allow their relief to become
familiarized with the Vessel and its operations shall be as follows:
Days onboard Cargo
Operations
MASTER
Experienced as a Master on this type of Vessel with the Company.
Min. 2 and/or 1
Joining the Company for the first time or newly promoted in this type of
Vessel as Master. Min. 7 and 1
CHIEF ENGINEER
Experienced as a C/E on this type of Vessel with the Company. Min. 2 and/or 1
Joining the Company for the first time or newly promoted in this type of E/R
as C/E. Min. 5 and 1
CHIEF OFFICER
Experienced as a C/O on this type of Vessel with the
Company. Min. 2 and/or 1
Joining the Company for the first time/ or newly promoted in this type of
Vessel as C/O. Min. 5 and 1
2nd ENGINEER
Experienced as a 2nd Engineer on this type of Vessel with the
Company. Min. 2 and/or 1
Joining the Company for the first time
or newly promoted to this type of E/R as 2nd Eng. Min. 5 and/or 1
JUNIOR DECK OFFICERS 24 hours (if circumstances do not allow a 24 hour period,
nd rd
( 2 & 3 Officers ) Bridge Watch Type must be set to Type “B”)
The Crew Manager shall ensure that the Handover periods comply with the indicated duration. When
extreme circumstances do not allow this overlapping period, then the handover is undertaken by an
experienced Officer and a Management of Change and Risk Assessment shall be carried out.
• Due to pandemic restrictions world-wide and difficulties encountered the OVERLAP procedure
may be deviated, provided that a thorough Risk Assessment is in place.
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2.8.2 Senior Officers, officers and Senior Ratings Hand over

When any of the following seafarers is to be relieved, he shall complete a Hand-over note with his relief:
 All Deck and Engineer Officers
 Senior ratings - Deck and Engine Room i.e
Electrician/Pumpman/Fitter (Form SF/CRW/504-“Handover Note for Other Officers/Electro-
technical Officer/Bosun/Fitter/ Pumpman”).
2.8.3 Senior Officers Handovers after Promotions

Senior Officers due for promotions join the vessels as “Trainees”. During the overlap period as per Table
2.8.1 OVERLAPING , the Master in command at the time will verify their suitability to carry-out
the new duties, along with verifying the required competencies / tasks prior taking over their roles and
handover is completed.
The Master shall confirm to the Crew Manager the completion of the familiarization procedure and
Candidate’s readiness to take-over his new duties and responsibilities submitting along the Training
Familiarization of the respective Trainee Officer form SF/CRW/509A through 509D, i.e:
• Training /Familiarization of Trainee Master SF/CRW/509A
• Training /Familiarization of Trainee Chief Officer SF/CRW/509B
• Training /Familiarization of Trainee Chief Engineer SF/CRW/509C
• Training/Familiarization of Trainee Second Engineer SF/CRW/509D
In turn, the Crew Manager will advise the Master the date that the promotion will be effected.
The Wage Scale of the new rank will start from the day that the Crewmember fully undertakes the duties
of his new Rank.
2.8.4 Master’s Handover

 When a Master is relieved, he shall familiarize the incoming Master on all the items as listed in
the Form SF/CRW/501- "Hand-over Checklist - Master".
 If during the Handover some items are considered as "Non-Satisfactory" by the incoming Master,
or he wishes to note down some comments, these shall be recorded on his Handover Checklist.
 All information and documentation shall be passed on to the relieving Master.
 The Master's Handover Checklist shall be completed and signed by both Masters.
 The Handover of Command to the incoming Master will be officially effected only following
written confirmation by the Operations Department.
 A copy of the Master's Handover Report shall be forwarded to Crew Department.
 The Master’s Hand-over report to be sent by the Crew Department to the respective Office
Departments for review through via Work Flow through the ERP.
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The new Master shall enter the following statement in the Vessel's Deck Log Book:
"I, (Name) a citizen of … (Country), holder of the Republic of … (Flag Administration) Certificate of
Competence, No. … (number of certificate), in the grade of Master, assumed command of the Vessel
on … (Date on which officially took over the command), at the port of … (Port where change was
effected)".
Only after completion of this procedure, shall the new Master assume the full responsibility and
authority of a permanent Master for the period of his employment.
Immediately after taking over the command, the on-signing Master shall report the place/date and names
of off-signing and on-signing Crew by e-mail to Company and, if applicable, to Charterer(s).
2.8.5 Chief Officer’s Handover

When a Chief Officer is relieved, he shall familiarize the in-coming Chief Officer on all the items listed
in relevant Handover Checklist.
There are two Chief Officer's Handover Checklists:
• SF/CRW/502 for Chief Officers on Oil & Chemical Tankers.
• SF/CRW/502A for Chief Officers on Gas Carriers.
In addition, all working copies of Ship's Deck Procedures, Operations Manuals, Deck Plans and Cargo-
related Documentation, shall be passed on to the relieving Chief Officer.
 If during the Handover some items are considered as "Non Satisfactory" by the incoming C/O,
or he wishes to note down some comments, these shall be recorded on his Handover Checklist.
 The Chief Officer's Handover Checklist shall be completed and signed by both Chief Officers.
 The original shall be given to Master for retention and 1 copy shall be sent to Crew Department.
 The Chief Officer’s Hand-over report to be sent by the Crew Department to the respective Office
Departments for review through via Work Flow through the ERP.
A relevant Deck Log Book entry shall be made as follows:

"I … (Name), a citizen of … (Country), holder of the Republic of … (Flag Administration) Certificate
of Competence, No. … (number of certificate), in the grade of Chief Officer, assumed full duties
and responsibilities of the position of Chief Officer, Safety Officer and Ship Security Officer of
the Vessel on … (Date of official Handover), at the port of … (Port where change was effected)”.
Only after completion of this procedure must the new Chief Officer assume the full authority and
responsibility of a permanent Chief Officer for the period of his employment.
Poster 30-"Ship's Security Officer" shall be filled in with the name of the on-signing Chief Officer /SSO
and posted in conspicuous places.
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2.8.6 Chief Engineer Handover

 When a Chief Engineer is relieved, he shall familiarize the in-coming Chief Engineer on all the
items of form SF/CRW/503-"Handover Checklist-Chief Engineer". In addition, all Engineering
Documents, Procedures and Manuals shall be passed on to the relieving Chief Engineer.
 If during the Handover some items are considered as "Non Satisfactory" by the incoming Chief
Engineer, or he wishes to note down some comments, these shall be recorded on his Handover
Checklist.
 Any over
 The Handover Checklist shall be completed and signed by both Chief Engineers.
 The original shall be given to Master for retention in his filing system and a copy shall be sent
by e-mail to the attention of Crew and Technical Departments.
 A relevant entry may also be made in the Engine Log Book.
 The Chief Engineer’s Hand-over report to be sent by the Crew Department to the respective
Office Departments for review through via Work Flow through the ERP.
The new Chief Engineer shall enter the following statement in the Vessel's Engine Log Book:
"I, (Name), a citizen of … (Country), holder of the Republic of … (Flag Administration) Certificate
of Competence, No. …… (number of certificate), in the grade of Chief Engineer, assumed full duties
and responsibilities of the position of Chief Engineer , Environmental and Energy Efficiency Officer
of the Vessel on ... (Date of official Handover), at the port of … (Port where change was effected).”
Only after completion of this procedure must the new Chief Engineer assume the full authority and
responsibility of a permanent Chief Engineer for the period of his employment.
2.8.7 Second Engineer Handover

 When a Second Engineer is relieved, he shall familiarize the in-coming Second Engineer on all
the items of form SF/CRW/503A-"Handover Checklist -Second Engineer".
 In addition, all Engineering Documents, Procedures and Manuals (as included in the Handover
Checklist) shall be passed on to the relieving Second Engineer.
 If during the Handover some items are considered as "Non Satisfactory" by the incoming Second
Engineer or he wishes to note down some comments, these shall be recorded on his Handover
Checklist.
 The Handover Checklist shall be completed and signed by both Second Engineers. The original
shall be given to Master for retention and a copy shall be sent by e-mail to the attention of the
Crew and Technical Departments.
 A relevant entry may also be made in the Engine Log Book.
 The Second Engineer’s Hand-over report to be sent by the Crew Department to the respective
Office Departments for review through via Work Flow through the ERP.
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The new Second Engineer shall enter the following statement in the Vessel's Engine Log Book:
"I, .…(Name), a citizen of … (Country), holder of the Republic of … (Flag Administration)
Certificate of Competence, No. … (number of certificate), in the grade of Second Engineer,
assumed full duties and responsibilities of the position of Second Engineer of the Vessel on ……
(Date of official Handover), at the port of … (Port where change was effected)”.
Only after completion of this procedure must the new Second Engineer assume the full authority and
responsibility of a permanent Second Engineer for the period of his employment.
2.9 PROBATION PERIOD

After a newly hired or newly promoted Senior Officer assume duties onboard, they are placed under
probation for a period of one (1) month.
During this period, they will be closely monitored and mentored by the Office (i.e. Fleet Manager, Ship
Operator, Ship Superintendent, etc.).
Upon completion of this period the assigned Office Personnel will submit mentoring forms to the Crew
Department.
• Master’s / Chief Officer’s Mentoring Report CRW/518A
nd
• Chief Engineer’s 2 Engineers’ Mentoring Report CRW/518B
Within two (2) months from the date taken over duties, visiting Marine and/or Technical Superintendent
will assess the suitability and operational effectiveness of the newly hired Master, Chief Officer, Chief
Engineer, Second Engineer.
(In case on-board visit is not possible, then can be assessed remotely by interviews and screening of
operational records, performance)
2.10 CREW APPRAISALS

The Company’s goal is to achieve zero incidents through continuous improvement. Conducting
operations safely and without incidents relies on human competency, which comprises both technical
and soft skills. Personnel behavior and attitude are key elements of a positive safety culture that promote
a safe work environment and helps reduce incidents.
The Company, having recognized the above, has established several tools for the assessment of
Crewmembers’ competency. The aim is to develop and improve officers’ technical and soft skills for the
benefit of each individual, onboard teams and the Company. The assessment of soft skills must be seen
as an opportunity to improve everyone’s behavior. The associated assessment of Seafarers’ job
competence is part of a continuous improvement process, with purpose to identify the existing
competency gaps and address them.
2.10.1 Officers and Ratings Performance Appraisals onboard

During the appraisal process, assessment of seafarers’ technical and soft skills is made by the Master or
Company’s Representatives. This assessment is based on the job observations, record books, results of
Inspections, familiarity with IMS, operational performance, attitude and conduct, Vessel’s condition, etc
including the following:
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 “Company’s Navigational Audit (Forms SF/MRS/200 & OFF/MRS/201).

 “Company’s Cargo Audit” (Form OFF/MRS/202).
 “Company’s Mooring Audit” (Form OFF/MRS/203).
 “Company’s Engineer Audit” (Form OFF/TEC/111).
During the above mentioned audits, apart from assessing the implementation of Company’s
procedures, particular assessment of Seafarers’ behavioral competency is made. Relevant audits
checklist includes specific sections for the evaluation of competency domains: “Teamwork”,
“Communication and Influencing”, “Situational Awareness”, “Decision Making”, “Results Focus” and
“Leadership and Management Skills”, while examples of behaviors are provided for helping the
assessors.
The results of all the assessments are communicated to the Crew Department for the creation of Seafarers’
profiles. When specific areas for improvement are identified, which can be technical skills, soft skills or
both, specific target dates are set and followed up accordingly by the Crew and Training
Departments. Where competency gaps are identified in entire teams or in multiple individuals,
company training programs may be revised to focus on this specific competency domains, such as
leadership development or communication and influencing
2.10.1.1 Appraisals Responsibilities

The Master is responsible for appraising the Chief Engineer and the Chief Officer.
The Master, with the co-operation of the Chief Officer, is responsible for appraising:
 All the Deck Officers.
 The Bosun.
 The Pumpman & Sandblasters (in cooperation with Chief Engineer).
 All the Deck Ratings & Cadets.
 The Cook and Mess-Men.
The Master, with the co-operation of the Chief Engineer, is responsible for appraising:
 All the Engineer Officers.
 The Electrical Officer.
 The Gas Engineer (for Gas Carriers).
 The Pumpman & Sandblasters (in cooperation with Chief Officer).
 The Fitters.
 All the Engine Room Ratings & Cadets.
Visiting Superintendents may conduct appraisals at will or at Crew Department request for
 Senior Officers
 Junior officers
 Ratings on higher rank process
 Ratings if they deem necessary (i.e exceptional or poor performance )
The visiting Technical/Marine Superintendents/ Fleet Managers/ Port Captains are obliged to fill-in
the relevant Appraisal form and submit it to Crew Manager.
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2.10.1.2 Appraisals Reporting

The Crew Appraisal System consists of regular reporting via a formal Appraisal report, follow-up of
the report, recording and analysis. The Appraisals are also used for identifying Training needs and
giving promotions.
The Appraisals shall be signed by the appraisee, following a discussion with the Master and other Senior
Officers (i.e. Chief Engineer and/or Chief Officer) who participate in the Appraisal.
If the seafarer wishes, he may comment on his Appraisal report, in writing.
The Appraisals shall be submitted as follows:
 When a person signs-off the Vessel (if he has been with the current Master for at least 1 month).
 When the Master signs-off.
 On request from the Company or at the discretion of the Master or the Chief Engineer.
Specifically for Officers newly promoted or new to the Company,

an Appraisal Report must be submitted within one (1) month after assuming duties onboard,
in case of low performance /problematic behavior /training requirements.
 The results of the Appraisal shall be discussed with the Appraisee to identify areas where
improvement can be made, any training needs, etc.
 The Appraisals shall be sent electronically to Crew Department, who shall review and follow-up
them, as required. The Appraisals are filed in each Crewmember’s Personal File.
 The Master's electronic signature is acceptable.
 No copies shall be retained onboard and no hardcopies shall be sent to Office or to Manning
Agent. The Crew Department shall forward the Appraisals to Manning Agent (electronically).
 In case of request, the Crewmember can receive a hard copy of his Appraisal.
 On the Vessels, the Appraisals shall be maintained in electronic files and protected with a
"password" which shall be passed on to incoming Master. Form SF/CRW/501-“Master’s Hand-
over note” includes a relevant item.
 The visiting Technical/Marine Superintendents/ Fleet Managers/ Port Captains are obliged to fill-
in the relevant Appraisal form and submit it to Crew Manager.
2.10.1.3 Officers and Ratings Performance Appraisals by Office Staff

The appraisal of Senior Officers is carried out as follows, after their discharge:
 The Master is appraised by the Office Department Heads.
 The Chief Officers are appraised by the Marine/Vetting Department.
 The Chief Engineers and the Second Engineers are appraised by the Fleet Managers.
For the above appraisals, the results of Vessel's Internal and External Audits/Inspections, familiarity with
the IMS, the operational performance, the condition of the Vessel, etc. are taken into account.
For the Appraisal of Officers and Ratings the following forms are used:
 Form OFF/CRW/508A-“Appraisal Report for Master”.
 Form OFF/CRW/508B-“Appraisal Report for Chief Officers”.
 Form OFF/CRW/508C-“Appraisal Report for Senior Engineer Officers”.
 Form OFF/CRW/508D-“Appraisal Report for Other Crew/Ratings”
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If Senior Officers are invited to POTF-PRRF or the Head Office, or remotely via teleconference for the
De-briefing a discussion on the appraisal results shall be made, either for the Senior Officers themselves,
or for their Officers and Crew during the last service onboard, e.g.:
 Results of Master's or Senior Officers Appraisals by visiting Superintendents.
 Results of Master's and Chief Engineers Appraisals of their Crew onboard.
This serves to identify any additional training needs, or any other problems (e.g. discipline, attitudes
etc.).
2.10.2 Training Needs identified during the Appraisal Process

In case an Appraisal report includes training needs, the Crew Department shall notify the Training
Department. The process is described in PROC 23 para 2.3 “Training Needs Identification and Follow-
up”.
2.10.3 Ship Staff Safety and Performance Award - Recognition of excellent performance
The Company gives Performance Awards to Shipboard personnel due to outstanding performance on the
basis of:
 Successful rescue operation during which Prime’s Vessel had a central role.
 Exceptional act by Crewmember(s) resulting in saving human lives.
 Excellent maintenance of the Vessel.
 Vetting Results.
 Major equipment repair by Crew.
 Excellent Safety Results.
 Superior Environmental Performance.
 Innovative Best Practice proposals and/or Best Safety Ideas.
Appointment of Vessel and Crew to be awarded as well as the nature of award will be decided during
MRM after proposal of the Manager concerned.
2.11 SENIOR OFFICERS DE-BRIEFING

Masters and Senior Officers may be invited if necessary to POTF or PRRF or to Head Office for a
one (1) day de-briefing, or remotely via teleconference in order to discuss issues of the previous
contract or provide personal guidance, or when the next contract is a special case e.g. new charterer,
different type of Main Engine etc.
The De- Briefing may also be conducted through ZOOM using the forms:
• OFF/CRW/517A-“Debriefing of Masters and Chief Officers”.
• OFF/CRW/517B-“Debriefing of Chief Engineers and Second Engineers”.
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2.11.1 De-Briefing Agenda

Briefings, sessions shall include subjects such as:
• Vessels Operational/ Commercial performance.
• Vessel’s specific issues such as maintenance plan, defects, outstanding and performance with SIRE
inspections, PSCs and Flag and audits.
• Training, Drills, Performance appraisals, Complaints.
• Safety, Security, Environmental issues accomplishments and performance.
• Technical issues and performance.
This process is organized by the Crew Department however, Departmental Managers shall control the
briefing, de-briefing, interview and interdepartmental delegation of the process.
The De-Briefing shall be ship-specific to the extent possible and shall be carried out as follows:
Shipboard Officers Office Staff Briefers

Masters and Chief Officers All Departments
Chief Engineers and 2nd Engineers All Departments – except for CSO
As Briefings the De-briefing shall be performed on Tuesdays, Wednesdays and Thursdays of every
week.
2.11.2 De-Briefing Participants

Officers should be DE- briefed by appropriate Departments, as per below matrix:
Rank / Dept. Marine / SAQ / Security / Technical / Stores DCOO/DPA

Operations Crew/ Training
Master X X X
Chief Officer X X X **
Chief Engineer X X X
2nd Engineer X X
The Briefing shall be performed by the relevant Superintendent of the respective vessel while the
departmental Manager may participate on a sampling basis ad-hoc.
In the event that the Superintendent will not be able to perform due to other commitments he should be
substituted by the Departmental Superintendents.
** The DCOO/DPA, briefs for Management Level Officers on a sampling basis ad-hoc and retains the
right to be fully engaged in the process especially on significant incidents or where it is deemed
appropriate while following up on special cases.
Any other Office Staff may also be involved in the Briefing process, if there are issues to be discussed.
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The items of discussion will be recorded electronically in the ERP system forms or alternatively in
Briefing Forms (mentioned above) which shall be signed and delivered to the Crew Department.
2.11.3 Office Assignments

Company seeks to fill key shore positions from within the fleet.
This involves targeted invitations to Office of Senior Officers (secondment) for at least 3-4 weeks.
During this period, the Senior Officers will be given appropriate familiarization regarding Office duties
and will work side-by-side with Office Staff or they might be given specific assignments i.e. Vessel
attendances on behalf of the Company.
Relevant records are kept by the Training Department.
The Department Managers shall evaluate their capabilities and their overall performance in order to
propose them or not as future Candidates for Office positions.
Their evaluations must be combined with feedback from Superintendents and Appraisal reviews of the
Candidates.
2.11.4 Refresher Familiarization & Assessment Programs

Masters, Senior Officers and Junior Deck Officers (watchkeeping) shall attend a
Refresher Familiarization Program at PMA & TC or POTF /PRRF Premises or online software
solutions and virtual classrooms led by the Training Manager or Training Department instructors,
every five (5) years in order to assess and verify that they retain the competencies required for their
rank and responsibilities.
The Training Department will organize SKYPE interviews or WEBINARS with the Company’s Office
Departments, in order to assist in the assessment and training.
2.12 CREW RE-EMPLOYMENT PROCEDURE & CREW

This paragraph describes the terms and conditions for Crew re-employment on Company’s Vessels.
It is well understood that a long-term co-operation between the Company and the Crewmember is to
the benefit of both parties.
For this reason the Company always welcomes the good Seamen who have worked on Company’s
Vessels in the past.
2.12.1 Application for Re-employment

All Crewmembers who fulfill the above requirements and wish to re-join a Vessel shall fill-in Form
SF/CRW/515- "Application for Re-employment" and hand it over to the Master, who will in turn send it
to Crew Department.
When a Seaman is ready to be re-employed, he shall contact the Manning Agent or the Company,
however, all re-employment procedures shall be processed through the Manning Agent.
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2.12.2 Bonuses
In order to provide an additional incentive to its Seamen to rejoin the Company Vessels, the Company
has adopted the policy of "Re-joining Bonus" and "Seniority" Bonus.
2.13 PROMOTIONS
The Company encourages Career and Skill Development and Employment Opportunities for
Seafarers, in order to provide its fleet with a stable and competent workforce.
It is the Company’s Policy to encourage promotions of its own Crew, this providing Career
Development for Junior Officers, and to recruit Senior Officers from within the Company.
 The Crew Manager, in cooperation with the other Managers, is responsible for the
implementation of the Promotion procedure.
 All Officers and ratings are encouraged to obtain Licenses and Certificates for higher grades, and
study the duties of the next higher grade, so as to be prepared for promotion.
 The Company encourages and supports personnel taking Higher Education courses to improve
their value to the Company and their possibilities for promotion.
 When a vacancy to a higher position becomes available, the Master and Chief Engineer may
propose in writing (Form SF/CRW/517-“Proposal for Promotion”) a Candidate for this position.
Before proposing, the Master shall ensure that the Candidate meets the requirements of the new
Rank (License, Certificates, Knowledge and Experience).
 On receipt of the "Proposal for Promotion", the Crew Manager shall evaluate the Candidate by
counter-checking his Personal File and fill-in Part B of the form "Proposal for Promotion". The
subject form shall be filed in the Seafarer's Personal Crew File in the Crew Department
 A copy shall be sent onboard to be also filed in the Seafarer's Personal File.
If all relevant requirements are met, the Crew Manager may approve the promotion in coordination with
other Managers, as per Table No. 4 “Approval Authority for seagoing Personnel’s selection”
The candidate for promotion must have at least two (2) positives Appraisals from two (2) different
Senior Officers.
For promotions of Senior Officers, there must be proposals by Masters and at least 1 Technical/
Marine Superintendent’s positive Appraisal.
Newly promoted Officers without previous service in our Company, will be accepted only after
serving for a certain period on his previous rank.
Not more than one (1) promotion within the same Shipboard Department
may be carried out simultaneously
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No promotion will be considered as valid without the final approval of the Crew Manager
The Crew Manager or any other Manager can also recommend for promotion any Officer, after
having reviewed the Master's relevant Appraisal and all other evaluations conducted by the visiting
Superintendents.
The Promotion Procedure shall always ensure appropriate staff placement with documented and
updated pre-employment and appointment records.
Promotion shall be by merit, although the length of service with the Company and the length of service
in a particular Rank are taken into account.
The following criteria shall be met prior to promotion of an Officer to a Higher Rank and his assignment
onboard to perform the duties of this rank:
 The candidate holds the required appraisals, proposals for promotions as required by table
TABLE 6 - “Requirements for Promotion”. Appraisals and any other available information
regarding the Candidate's professional ability have been carefully considered
 The Candidate possesses the License and all applicable Certificates for the proposed Rank
 The candidate has completed the training of Officers in Higher Rank duties (Forms
SF/CRW/519A-I).
 The candidate has passed the required tests/assessments as per table 7 assessment tests for
Promotion”.
 The candidate has passed the required interviews as per table 8 “interviews for promotion”.
 The Candidate has attended training courses/familiarization required by the IMS for the proposed
Rank as required (PROC 23 para 2.2.2.1 “Training / Familiarization”).
 Previous sea service has been considered in relation with the type/size/BHP/etc. of the Vessels
the Candidate had served, in order to be compatible with the proposed Vessels.
2.13.1 Conditions & Exemptions

 Senior Officers are not directly promoted on-board, unless appraised on-board by Technical or
Marine Superintendents.
 The Crew Manager may override the established overlap period under exceptional circumstances.
In such a case, a Management of Change and a Risk Assessment shall be issued.
 The Hand-over of the newly promoted Senior Officer shall be verified by the Master and Chief
Engineer (as applicable).
 After completion of the program, the promoted Senior Officers will join the Vessel as trainee.
 The approval authority for vessel assignment/employment of seagoing personnel (Officers) is in
accordance with the Table No. 4 “Approval Authority for Seagoing Personnel’s Selection”.
 During the overlap period, the Master on board will verify their suitability to carry-out the
new duties, before the handover is completed and the promotion is effected as per para 2.9
Crew Handovers.
 In Emergencies, the Master may temporarily "promote" Officers or Ratings, following written
notification to the Office and after receiving written approval from the Crew Manager.
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TABLE 6 - “Requirements for Promotion”

(See next page)
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Requirements for Master Chief Engineer Chief Officer Second Engineer Second Officer/
promotion Third Engineer
STCW Compliant Yes Yes Yes Yes Yes
Seatime 24 months sea service as 18 months sea service as 24 months sea service as 20 months sea service as 8 months sea service as
Chief Officer Second Engineer Deck Watch-keeping Eng. Watch-keeping Officer Third Officer/Fourth
(two contracts complete (two contracts complete Officer with minimum 12 with minimum 8 months as Engineer
with the Company) with the Company) months as Second Officer Third Engineer
(two contracts complete Engineer (two contracts
with the Company) complete with the Company
Seagoing experience * Minimum 8 months sea Minimum 8 months sea Minimum 8 months sea Minimum 8 months sea Minimum 4 months sea
service in previous 36 service in previous 36 service in previous 36 service in previous 36 service in previous 24
months on similar Ship type months with similar months on similar Ship months with similar engine months on Ship/engine
engine type type type type
Training for the Higher Completed on at least two Completed on at least two Completed on at least Completed on at least two Completed on at least
rank Vessels Vessels two Vessels Vessels two Vessels
Appraisals At least 2 Appraisal At least 2 Appraisal At least 2 Appraisal At least 2 Appraisal At least 2 Appraisal
recommending promotion recommending promotion recommending promotion recommending promotion recommending
from Vessel and 1positive from Vessel and 1 positive from Vessel and 1 from Vessel and 1 positive promotion from Vessel
Marine Superintendent's Tech. Superintendent's positive Marine Tech. Superintendent's and/or positive
appraisal appraisal Superintendent's appraisal positive appraisal Superintendent's appraisal
Promotion Interview Yes Yes Yes Yes Yes / No

(office)*
Responsibility Crew Manager Crew Manager Crew Manager Crew Manager Crew Manager
Stakeholders COO or Deputy COO, COO or Deputy COO, Marine Manager, Fleet Technical Manager, Fleet Technical Manager,
Operations Manager, Technical Manager, Training Manager Training Manager Marine Manager,
Training Manager, Marine Training Manager, Training Manager
Manager & Technical Operations Manager,
Manager Marine Manager
* The Crew Manager may override the established requirements under exceptional circumstances, after conducting MoC/Risk Assessment.
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Table 7
Assessment tests for Promotion
PROMOTION
RANK
 CES STCW Deck Management Oil or LPG *
Master
Chief Officer  CES STCW Deck Management Oil or LPG *
Deck Officers  CES STCW Deck Operational Oil or LPG *
Chief & 2nd  CES STCW Engine Management Slow speed
Engineer
Engineer Officer  CES STCW Engine Operational Medium speed
Electrician
(ETO) No promotions are granted
Pump-Man  CES Cargo Handling & Stowage Oil or LPG (support Level) *
Gas Eng  CES Maritime English Deck (Support Level)
Deck Ratings  CES STCW Deck Support Oil or LPG Tanker *
 CES Maritime English Deck (Support Level)
Engine Ratings  CES STCW Engine Support
 CES Maritime English Engine (Support Level)
Cook  CES Catering Operational
Catering Ratings  CES Catering support
*As applicable to ship type the candidate is applying for Tanker or LPG
Conditions
1. Passing CES Test Score is
OFFICERS: Overall 70% no less than 60% in each Chapter
RATINGS: Overall 60%
2. In case a candidate does not achieve the required Score in the 1st attempt, he can repeat the
test up to a maximum of three (3) times.
3. Time limit is set at 160 seconds per question for all tests.
4. Passing Maritime English at Support level score for ratings is 55%
5. Earlier CES tests may be accepted provided that :

For OFFICERS
 they are recent (No major revision within the SEAGULL testing system) and
 The candidate performs well during an interview
For RATINGS
They are recent (No major revision within the SEAGULL testing system)
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Table 8
Interviews for Promotion
PROMOTION
RANK
Master 1. Crew Department and/or Crew Manager
2. Vetting Department and/or Vetting Manager and Operations
Manager
Chief Officer 1. Crew Department and/or Crew Manager
2. Vetting and/or Vetting /Operations Manager
Deck Officers 1. Crew Department
2. Vetting manager and/or Navigation Officer
Chief / 2nd 1. Crew Department and/or Crew Manager
Engineer
2. Technical Department Fleet Manager
Engineer Officer 1. Crew Department
2. Technical Instructor
Elect. (ETO) No promotions are granted
Pump-Man 1. Crew Department (if required) *
Gas Engineer
Deck Ratings 1. Crew Department (if required) *
Engine Ratings 1. Crew Department (if required) *
Catering 1. Interview by Crew Department (if required) *
* Interviews established if required after reviewing promotion proposals, appraisals, Sea services,
qualifications, certification, experience and training records
2.13.2 Rank Specific Psychometric Assessments & English Language Skills for Promotion
After a successful interview, psychometric assessments and English adequacy of each seafarer for
promotion is conducted if required according to their rank as per the below table.
The table below outlines the flow;
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Table 9
Psychometric Assessments & English Language Skills
RANK RECRUITMENT
 Psychometric Assessment
Master
Chief Officer  Psychometric Assessment
Deck Officers  Psychometric Assessment
 Language MARLINS Deck Operational Level Assessment **
Chief & 2nd  Psychometric Assessment
Engineer  Language MARLINS Engine Management Level Assessment **
Engineer  Psychometric Assessment
Officer  Language MARLINS Engine Operational Level Assessment **
** English test may be omitted if candidate demonstrates the required fluency during the
interview
Passing MARLINS test is:
 Master & Chief Officer 85%
 Junior Deck Officers 75%
 Chief Engineer officers 75%
 2nd Engineer officers 65%
 Junior Engineer officers 65%
2.13.3 Acceptance /Rejection of Promotions

The Crew Department shall review the, i n t e r v i e w s a n d t e s t r e p o r t s as soon as possible and
revert to the manning agent/seafarer in writing with either confirmation of acceptance or rejection of
the promotion.
At this point, candidates are admitted to the Training/Familiarization program
As per §2.1.6 and §2.17 “Training/Familiarization of Officers and Ratings”,

Training & Familiarization requirements are denoted on the interview forms.
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2.14 DISCIPLINARY PROCESS

Any inability on the part of the Shore Staff or Seagoing Personnel to perform on board as per the
Company’s requirements is dealt with according to the particular circumstances.
This covers breaches of the IMS requirements, poor performance, etc. Where disciplinary action is
This covers breaches of the IMS requirements, on any Company’s Policies or Procedures, poor
performance, etc. Where disciplinary action is considered to be appropriate, this will be carried out
in accordance with this procedure.
2.14.1 Master’s Responsibility and Level of Authority onboard

The Master has the overriding authority over all persons on board the Vessel.
He must require that his orders are carried out, and any neglect or refusal to do so, must be met with
the appropriate Disciplinary Action, which must be properly administered and documented.
The Master may rely on the Company for support in the proper execution of his duties and the
maintenance of Discipline.
The Master has the authority to dismiss any seafarer, including shore staff and contractors, who
violate the Company’s rules and regulations from the Vessel.
This power must be used judiciously and only for a proper cause and must be preceded by at least
one, preferably more, formal warnings.
The Company expects from its Seagoing Personnel the implementation of the following:
Punctuality It is important that for the efficient operation of the ship and to avoid putting
extra work on shipmates that punctuality be maintained by all personnel at all
times. This applies to joining the Vessel at the time of appointment, returning
from shore leave, reporting for watch keeping duties and all other work.
Drug & Strict compliance with the Company’s Drug and Alcohol Policy for the
Alcohol Policy particular Vessel, to which the seafarer is assigned, is an absolute requirement.
Unauthorized The ships rules and/or port authority rules on bringing unauthorized persons,
Persons & equipment software, reading material etc. on board must be strictly observed.
Equipment
Offensive These are not allowed to be brought or carried on board e.g. guns, knives etc.
Weapons
Smoking Smoking is not permitted in prohibited areas on board ships, particularly on
tankers and Vessels carrying explosive or inflammable materials. Vessels rules
to control smoking and the use of naked lights or unapproved electric torches
must be scrupulously obeyed. All Vessels carrying dangerous/ flammable
cargoes are to have designated smoking areas. These are to be marked and
explained to the staff.
Duties Every Crewmember must carry out his duties efficiently exercising due
diligence to the best of his ability. Every Crewmember must be informed clearly
about his duties and to whom he is responsible for carrying them out. Within the
scope of his duties, responsible commands and instructions must be obeyed.
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Property Whilst on board the Seafarer is responsible for the maintenance and upkeep of
all gear and facilities in the accommodation provided by the Company/
Principal. The seafarer is expected to take due care of and make proper use of
tools provided on board and used within the scope of his duties.
Relationships The seafarer is expected to be aware of the needs of his colleagues, especially
the fact that some people need to sleep whilst others are awake, thus causing
excessive noise is not permitted in alleyways and common areas. Any anti-social
behaviour, such as the use of abusive language, aggressive attitudes and
offensive personal habits is not permitted.
2.14.2 The Levels of Offence/Violation
The list of minor offences includes but not limited to:

 Any offence from the "List of serious offences" which does not justify dismissal in that particular
case.
 Minor act of negligence, neglect of duty, or disobedience.
 Unsatisfactory work performance.
 Poor time keeping / Stopping of work prior to the authorized time.
 Failure to report for work without a satisfactory reason.
 Offensive and/or disorderly behaviour.
 Unsatisfactory Housekeeping.
The list of serious offences includes but not limited to:
The following offences are those upon which the Company is entitled to terminate the Agreement
with the Employee, either immediately, at the end of voyage, or whenever this deemed necessary
according to the circumstances of the case.
This is apart from any legal action, which may be called for under the regulations of the port or flag
state.
 Wilful / flagrant violation of the law.
 Any serious breach of the Terms and Conditions of Employment.
 Acceptance of gifts or services, in contravention of the Company's Antibribery Policy.
 Misappropriation of the Company's funds or materials.
 Fraud and deliberate falsification of records.
 Theft or wilful damage to the Company's property.
 Being on-duty under the influence of Alcohol or Drugs.
 Possession of Alcohol in private quarters.
 Possession or use of Illegal Drugs.
 Possession of drugs not prescribed by a physician or issued by the Ship’s Medic while aboard a
Vessel or enroute to or from the Ship.
 Serious breaches of health, safety and environment regulations.
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 Deliberate or negligent acts which cause or might cause unacceptable loss, damage or injury.
 Leaving the work place without permission.
 Serious bullying, harassment or acts of violence towards any person.
 Serious insubordination.
 Any breach of the Code of Ethics and Discipline.
 Misuse of the Company’s property or name.
 Bringing the Company into serious disrepute.
 Misuse of Company electronic mail and internet facilities, etc.
Failure to comply with the D&A Policy will lead to instant dismissal from the Vessel and exclusion
from a future employment.
2.14.3 Discipline Guidelines

In situations, where job performance or personal conduct falls below minimum acceptable standards
or when work rules are disobeyed, Progressive Discipline will be applied.
The concept of Progressive Discipline may also be applied to those situations when behavioral issues
have been identified during an Incident Investigation.
Any of the steps outlined below, may be omitted depending on the seriousness of the misconduct.
Progressive discipline will be applied uniformly and impartially, as appropriate for the circumstances,
to ensure fairness and consistency in the treatment of all crewmembers.
With every disciplinary action the crewmember will be notified that a subsequent or similar act of
misconduct will result in a more severe disciplinary action.
Disciplinary actions, including re-education, are likewise to be entered in the Appraisal report and
the offender shall be notified in writing of the action taken against him.
Documentation relevant to offender disciplinary action, includes the following:
 Date, time, place, possible Witnesses and facts related to misconduct (avoid use of wording
that is highly subjective or beyond facts, such as malicious, deliberate, etc.).
 A clear statement of the Rule or Practice which the seafarer violates.
 A proper reference to any previous verbal warnings, including dates, times and other facts of
such prior warnings (avoid general statements - such as on several occasions or in the past).
A Crewmember will not normally be dismissed because of a failure to perform to the required
standards, unless an appropriate warning and an opportunity to improve has been already given.
The categorization of disciplinary actions ranges progressively from warning to summary dismissal.
All circumstances must be promptly and impartially investigated.
The crewmember must be given an opportunity to express his position.
2.14.4 Discipline Procedures

 Disciplinary procedures will be based upon a “Just Culture”.
 Disciplinary action of Seafarers will be governed by the Labor Convention agreements that
apply to them.
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 The Seafarer may have a Union representative present at discussions held to investigate any
misconduct.
The following categorization of disciplinary actions ranges progressively from the least to the most
severe.
2.14.5 Progressive Disciplinary Levels
The causes for dismissal can vary from violation of regulations to consistently substandard
performance. Wilful or repeated violation of Company’s requirements or refusal to observe Safe
Working Practices may also subject to disciplinary action.
The Progressive Disciplinary levels are presented below:
2.14.5.1 Warnings
 Verbal Warning is a reminder offense of a less serious nature, for example, tardiness, minor
rule infractions or performance lapses.
A verbal warning must be witnessed by a Senior Officer who will also co-sign the Log entry
of the verbal warning.
 Written Warning
A Written Warning documents a serious first offense, recurring offenses, multiple offenses or
continued poor performance.
This is a serious expression of disapproval followed by a thorough discussion. The Master
and Senior Officers (or Superintendent in the case of Master’s discipline) will document the
discussion with the Crewmember by completing the form SF/CRW/525 “Written Warning”
and sending it to Crew Manager in order to be placed in the Crewmember’s Personnel File
and retained indefinitely.
The Master shall be the leader of the disciplinary hearing.
The Crew shall be offered a duplicate copy. The discussion will specifically address:
• The reason and a Summary of the discussion
• Action taken, including what needs to be done e.g. re-education, training, etc.
• The way improvements or changes will be tracked
• The time period within which these improvements or changes must be completed
• Notification that further disciplinary action will occur if there is no sustained improvement
or change
• A statement that if the Seafarer fails again to correct the offense, further Disciplinary
Action, including Termination of Employment, may be deemed necessary.
An official entry shall be also made in the Official Deck Log Book.
The accused crewmember will be given a copy of the Deck Log Book Entry and an additional
relevant entry will be made in the Log that this has been done.
If the accused person refuses to sign the Written Warning (SF/CRW/525) this must also be
logged on the Form and in the Deck Log Book.
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2.14.5.2 Sever Sanctions (Dismissals)
A. Ship Dismissal
Where there is a failure to improve or change behavior as outlined in the Written Warning or Deck
Log Book Entry, or where the infringement is sufficiently serious for Summary Dismissal, the
Crewmember will be dismissed from the Ship.
The Dismissal is entered in the Deck Log Book and the form SF/CRW/527 “Dismissal Notice”.
The Master must follow the same instructions for the Official Log Entry as above, and must document
the reason for the dismissal.
Ship dismissal will lead to a review by Office Managers and may result in additional disciplinary
action, up to and including Termination of Employment from the Company.
Depending on the urgency of the situation, dismissal from service must be preceded by at least
one (1), preferably more, formal warnings.
Dismissal may be effected by the Master without furnishing the Seafarer with a Notice of Dismissal,
if there is a clear danger to the safety of the Crew or the Vessel. The Master shall send a report to
Crew Manager, substantiated by witnesses, testimonies, etc.
No Seafarer shall be permanently dismissed without prior notification of the Company.
Appeals against dismissal must be referred to Crew Manager, who will confirm the dismissal or set
it aside, as the circumstances dictate, and shall notify the Manning Agents, as appropriate.
B. Summary Dismissal
Summary Dismissal is a dismissal without notice and is applicable when any serious offence
occurred. Reference is made on §2.7.3.2.
An incident investigation must be conducted when a severe breach of discipline occurred, according
the procedure described in Company’s IMS.
Participants in the Dismissal Review, depending upon the rank of the Crewmember dismissed, are as
follows:
The Crew Manager: He will ensure consideration of all factors and prior
dismissals. Following the review, he will make a recommendation
Officers, Ratings and
regarding the appropriateness of additional disciplinary actions. He will
Cadets
inform the Master/Senior Officers and the relevant Manning office
regarding the final outcome.
• The Crew Manager

• The DPA and
• Department Managers.
Master and Senior
Officers The Crew Manager will recommend to the COO or Deputy COO as to
whether additional disciplinary action is warranted. He will also inform
the Master/Senior Officers and the relevant Manning office regarding the
final outcome.
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C. Progressive Discipline - Associated with an Incident Investigation

The root cause investigation process is designed to focus on the systemic causes that result in Human
Error.
However, there are times when Personal accountability in an incident could justify disciplinary action.
Discipline shall NOT be part of the corrective action in the Incident Investigation process; it shall
be based on the facts of the investigation, but shall be totally separated from the Incident
Investigation process.
Discipline is inappropriate in the following cases:

 When a behavior is widespread and accepted by Management/Supervision.
 When hazards are not within the Person’s Control.
Discipline is appropriate when the following are true:

 This behavior was NOT common (the Rule was usually followed).
 The workforce clearly understands the Rule.
 The Rule is within the Crewmember’s ability to follow.
D. Discharge Reporting
When an unscheduled discharge of a crewmember takes place, the Master shall inform the Crew
Manager as follows:
 The Name and Rank of the crewmember
 The date of the discharge (the same date shall be recorded in the SIRB or on the Certificate of
Service)
 The reason for the discharge
 Recommendation to fill the position by promotion from the Vessel’s complement, if practical
 The Rank needed to complete the Crew Complement.
E. Resignation/Discharge for Cause

A Crewmember who resigns without proper notice or is discharged for cause from Company’s service
is responsible for all expenses incurred. To ensure complete recovery of these expenses, the Master
shall:
 Obtain from the Company’s Traveling Agents the cost of an economy airfare.
 Request the Local Ship Agent to obtain an exit Visa, arrange for lodging and meals (if required),
offer any other assistance (as required for the seafarer’s disembarkation / repatriation) and arrange
for transportation to Airport.
 Request the Local Ship Agent to bill the Company for these expenses separately, and identify
these billings with the departing seafarer’s name.
 Request the Ship Agent to provide the Manning Agent with the total repatriation expenses of the
seafarer. Any salary balance due to the seafarers must be settled after all incurred expenses have
been recovered.
Shore staff and contractors found to be in violation of the Company’s rules and regulations are to be
also instructed, as appropriate.
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All additional Flag and/or contractual requirements must be properly followed, if any.
2.14.5.3 Disciplinary Process for Third Party Contractors’ Personnel

Disciplinary actions may be extended to the personnel of Third Party Contractors, for unacceptable
behavior or actions which include, but are not limited to:
 Any serious breach of the Terms and Conditions of Employment.
 Misappropriation of the Company’s property and materials.
 Theft or willful damage to the Company's property.
 Misuse of the Company’s Name.
 Bringing the Company into serious disrepute.
 Being on-duty under the influence of alcohol or drugs.
 Possession of alcohol and illegal drugs in private quarters.
 Serious breaches of Health, Safety and Environment Regulations.
 Deliberate or negligent acts which cause or might cause unacceptable loss, damage or injury.
 Serious bullying, harassment or act of violence towards any person.
 Serious disobedience to Vessel’s Senior Officers.
 Any breach of the Code of Ethics and Discipline.
 Misuse of Company electronic mail and internet facilities.
 Gross Negligence.
The Contractor’s representative onboard or their company will be notified by the Master and/or the
Company, in order to participate in the disciplinary review.
2.15 MANNING IN PORT & SHORE LEAVE

This paragraph describes the procedure for maintaining sufficient Crew onboard in port to respond
to any emergency.
On any Ship moored or safely anchored under normal circumstances in port, the Master shall arrange
for an appropriate and effective watch to be maintained for the purpose of Safety.
Special requirements may be necessary for special types of Ship’s propulsion systems or ancillary
equipment and for Ships carrying hazardous, dangerous, toxic or highly flammable materials or other
special types of cargo.
Arrangements for keeping a watch when the Ship is in port shall at all times be adequate to:
 Ensure the safety of life of the Ship, the port, the environment and the safe operation of all
Machinery related to Cargo operations and Engine Room.
 Observe International, National and local rules.
 Maintain order and normal routine of the Ship.
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2.15.1 Manning Rules while in Port
The Master shall decide the composition and duration of the deck watch, depending on the conditions
of mooring, type of Ship, type of cargo and character of duties.
The possibility for any emergency situations shall also be taken into consideration.
If the Master considers it necessary, a qualified Officer shall be placed in charge of the Deck Watch.
The necessary equipment shall be so arranged as to provide for efficient Watchkeeping.
Officers in charge of the Deck or Engineering watch shall not hand over the watch to their relieving
Officer, if they have any reason to believe that the latter is obviously not capable of carrying out
watch-keeping duties effectively.
In such a case the Master or Chief Engineer shall be notified accordingly.
Relieving Officers of the Deck or Engineering Watch shall ensure that all members of their watch are
apparently fully capable of performing their duties effectively.
In order to prevent any incidents or problems resulting from inadequate manning levels, the following
rules apply to all Vessels while in Port, and the Master shall strictly implement them.
A. While in Port, at least 2/3 of Vessel’s Personnel shall be onboard at all times.
The Master shall make necessary arrangements to ensure that all Crewmembers go ashore in shifts
and that 2/3 of the Officers and Crew remain onboard.
B. Either the Master or Chief Officer shall be onboard at all times.
C. Either the Chief Engineer or the Second Engineer shall be onboard at all times.
2.15.2 Crew Shore Leave

All Shipboard Personnel are entitled to shore leave, when the Vessel’s schedule and circumstances
(Port regulations, etc.) permit. All crewmembers must obtain the permission of the Master and/or
Head of their Department before going ashore (see section “Responsibilities” of this Manual).
The Master may restrict or deny shore leave where he considers there may be a threat to personal
safety, risk of desertion or for any other reasonable cause (epidemic risk etc.).
A notice shall be clearly displayed at the Ship’s gangway, stating the time and date of sailing
( if known), and the time and date that the shore leave ceases.
The Visitors Logbook shall be updated with the time-out/time-in of crewmembers on shore leave
When leaving on shore leave, and while in the Terminal Area, all Crew must strictly adhere to the
Terminal’s Safety Regulations regarding, but not limited to:
 Smoking (including e-cigarettes).
 Lighters.
 Mobile Phones.
 Cameras.
 Other non-intrinsically safe devices.
 Use of Personal Protective Equipment (as required by the Terminal).
 Transportation within the Terminal Area.
All Crew must keep in mind that the shore leave commences and ends at the Terminal Gate.
All are expected to have a highly professional conduct within the Terminal area.
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The following additional measures shall be followed by all Vessels while calling at any Port
worldwide:
 Terminal Regulations shall be communicated to all Crew and posted on the Ship’s Notice
Board.
 Crew shall declare their familiarity with the Terminal Regulations by signing the form
SF/SEC/920-“CrewShore Leave” just before their shore leave and not during their
familiarization on the Terminal Regulations
 The Master shall forward a copy of Terminal Regulations to CSO and the Operations
Department
 The Officer of the Watch shall closely monitor the Crew Shore Leave and their return onboard.
 The Duty Bridge/Deck Officer and Duty Engineer Officer shall at all times be fully aware of
the personnel from their departments who are ashore, and shall keep a record with their names
 Shore leave shall be allowed only if the Immigration Department grants the permission and
delivers Shore Passes to Vessel. Some ports need a personal photo for every Crewmember to
be placed on the Shore Pass. In other cases, a Crew List shall be provided to Terminal Gate,
for the smooth and formal Shore Leave of the Ship’s Crew
 No one is allowed to walk within the confines of the Terminal
 The transportation of the Seafarer to the Terminal Gate to be carried out only by Security
Shore bus (if Terminal Regulations require it)
When ashore, all crewmembers are expected to conduct in a respectable and orderly manner. All
crewmembers are reminded that the Local Laws and Customs shall be respected and adhered to. The
Company, Owners and P&I Club are not responsible for defending Crewmembers for criminal acts
committed by them.
On returning to Vessel, the seafarer is bound by the Company’s Drug and Alcohol Policy, therefore,
the alcohol levels shall be within the limits stated in this Policy,
i.e. the maximum permitted alcohol level is 40 mgs to 100 ml of blood (0.04 % BAC).
A BAC of more than 0.04% is considered Intoxication.
Officers and Crew are not allowed to bring with them any Alcohol or Drugs onboard the Vessel,
when returning from Shore Leave. The Master shall issue a Standing Order to the gangway watch to
perform searches when Crew return from shore in order to ensure that no alcohol is brought onboard
Note: Standard “Master’s Standing Orders to Gangway Watch” are included in the front page of the
Visitors Book.
The Master shall sign them every time a new Visitors Book is initiated.
Managers and Superintendents shall monitor the enforcement of the above rules during their visits to
the Vessels.
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2.16 VESSEL’S SUPERNUMERARIES

At times, persons in addition to Vessel's Crew may travel with the Ship.
Usually, these persons are Company’s Superintendents or Auditors. In some cases, Technicians may
be also traveling, in order to repair machinery and equipment.
2.16.1 Visits while the Ship is in Port

Subject to any applicable national or international laws or regulations, and whenever possible and
reasonable, seafarers are expeditiously granted permission to have their partners, relatives or friends
as visitors onboard their Ship when in port.
Such measures must meet any concerns for security clearances.
2.16.2 Permission to Travel on the Ship

Under special circumstances the Company may permit Senior Officers to carry their wives/ partners
on occasional voyages for a defined period of time, where practicable and reasonable.
The time period during which seafarer family members may stay onboard
shall not exceed one (1) month.
Women in the state of pregnancy and Children are NOT ALLOWED at any time.
Such partners must carry adequate Insurance Cover against accident and illness.
In case of Senior Officers wives, a written application shall be sent by the Master to Crew Department.
Only the Crew Manager can grant permission for Senior Officers wives.
The Crew Manager shall be informed whenever a family member joins or leaves the Vessel.
No family member is allowed to join a Vessel when it is scheduled to transit a High Risk
Piracy Area.
Before accepting any Visitor/Supernumerary onboard, the Master shall ensure that the Vessel's
Lifeboat Capacity is not exceeded, by checking the Vessel's Safety Equipment Record.
The Master shall ensure that the family member is fully conversant with the Vessel's Safety
Instructions.
The relevant Officer is held personally responsible for ensuring that his family member complies with
the Safety procedures, including participation in the Safety and Security Drills.
No extra burden shall be placed on Catering Staff. Meals shall be taken in the Officer's room.
No room service is permitted.
The Family members are NOT permitted to prepare food in the galley for Safety reasons,
as they are not familiar with the Galley Equipment and the dangers in the Galley.
The Officer's own accommodation room must be kept clean by the Officer's family member during
his/her stay onboard.
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All relevant documentation (Visas, Letter of application for Family Accompaniment/ Indemnity,
Indemnity form, Medical Certificates, Personal Insurance) shall be forwarded to Crew Department
before the family member joins the Vessel.
The expenses for Visas and other traveling formalities are for the Officer's account.
2.16.3 Inclusion of Supernumeraries in the Crew List

As a general rule, all Supernumeraries shall be listed in the Crew List. The updated Crew List shall
be immediately sent to the Office.
2.16.4 Terms and Conditions for Supernumeraries- Indemnity Form

Any Person who travels on the Ship without being a Crewmember shall sign the form SF/CRW/514-
“Indemnity Form”.
This applies to Technicians, Crew Relatives, and Armed Guards and to any other non-Crewpersons.
All Terms and Conditions included in this Form must be accepted and strictly followed.
Company personnel (Internal Auditors, Superintendents, Managers)

are not required to sign the Indemnity Form.
2.17 MASTER’S GENERAL ACCOUNT (MGA)
The Master's General Account is due on a monthly basis and includes six (6) Forms:
• Wages Account.
• Cash Account.
• Provisions Account.
• Bonded Stores.
• Crew Home Allotments - Personal Details.
• Crew Home Allotments - Summary Table.
2.17.1 Processing the MGA
The MGA must be submitted on a Monthly basis.

The MGA is entirely and exclusively processed through the Benefit MGA Application.
When the MGA is received by the Crew Department, the following checks must be made:
• The Crew names listed are the correct ones and reflect the Crew compliment for the period
covered by the MGA.
• The service period is the correct one.
• The wages listed are the correct ones, as per the Seafarers’ Employment Agreements.
• Officers requesting re-joining bonus are entitled to it.
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• The balance carried over from the previous month is correct.

• The charges of Column 7 of Wages Results (e.g. traveling expenses, Vessel’s laundry, bread-
making etc.) have been itemized by the Crew Department.
• All the calculations are correct, and as per Crew Department’s approval.
• The Cash remaining onboard is correct and documented.
• Banking details of Crew Home Allotments are correct and according to the instructions provided.
After all the checks as stated above are complete, the MGA and all supporting documentation is
handed over to the Accounting for further processing and remittance process
Electronic Copies of the MGA forms are maintained by the Crew Department in relevant Crew Files.
The MGA Forms:

 SF/ACC/701-“Wages Account”
 SF/ACC/702- “Cash Account”
 SF/SAQ/703-“ Provisions Account”
 SF/SAQ/704-“Bonded Stores/ Shore Chest Account”
 SF/SAQ/705-“ Crew Allotments Bank Details
 SF/SAQ/705A-“Home Allotments Summary
are maintained in the IMS, only for urgent cases ( i.e malfunctioning of Benefit, Internet
Connection etc) , without negating the mandatory use and creation of the MGA through the Benefit
Application when its smooth operation is restored.
2.18 PERSONAL CREW FILES

This paragraph describes the Filing System of the Crew Department related to Crew personal data.
The most important records held are the Personal Crew Files which shall always be updated, well
organized and easy to access and review. These are thru ERP?
Additionally, the Filing System shall be set in such a way so that, at all times, the Personal Crew Files
of Crewmembers onboard a specific Vessel are filed all together for quick reference during
emergencies.
In addition, the personal files of all off-duty Crew shall be filed in such a way so as to be easy to
retrieve, depending on the Rank.
2.18.1 Personal Crew Records
The Crew Department keeps Personal Crew Records as described below:

• Personal Crew Files are divided into two large groups:
 Box Files: On-Duty Crew Records  kept per VESSEL
 Box Files: Off-Duty Crew Records  kept per RANK
 Each Crewmember has a Personal Crew File in a soft-cover folder with his Name and Rank
on the cover.
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 Following each Crew change, the Personal Crew File of all the Crewmembers of the particular
Vessel is filed in the respective Box Files.
 Each Personal Crew File shall initially include the following documentation:
o Seafarer Approval, depending on the Crewmember’s Rank (as cover page).
o Record of Personal Information and Last Experience Sheet. (This record is on a Form issued
by the Manning Agent, and provides all Personal Data, Addresses, Next of Kin and all other
information on education, certification and sea service).
o "Certificate of Receipt of Application" from the Flag Administration, in case the Crewmember
does not have such certificates or they have expired.
o Contract of SEA signed by the Manning Agent's authorized representative and the
Crewmember.
o ITF Seaman's Employment Contract (Collective Bargaining Agreement) signed by the
Manning Agent's authorized representative and the Crewmember.
o Photocopies of all the Certificates required for the Crewmember's rank and the type of Vessel
he is to serve (electronic Filing of Certificates is acceptable).
o Crew Qualifications Checklist - as a final check by the Manning Agent that the Company
Qualification requirements have been met.
o English Assessment Table (Manning Agent form), as indication of the assessment of the
English level of the particular Crewmember.
o Physical Examination Record by a recognized Medical Institute, issued maximum 1 month
before his employment.
o Drug & Alcohol examination issued 1-3 months before employment.
 During the Crewmember's service onboard, more documents are added to his Files i.e.:
o Crew Qualification Checklist - filled by the Master when the Crewmember joins the Vessel
o Appraisal Reports.
o Medical Reports, if any.
o Copies of any accident report in which the Crewmember was involved (injured, etc.).
o Copies of any Appraisals issued by visiting Superintendents.
o Written Warnings (disciplinary, if any).
o Crew Complaint form, if any.
2.18.2 Processing Personal Crew Files

Initially, on Vessel acquisition, Box Files (usually 2-3) are established for the Vessel.
Inside the Box Files, the Personal Crew Files, in soft cover folders, are arranged per Rank as per the
order in the Crew List. Every time there is a Crew change, the off-signer’s Personal Crew File is
removed from the Vessel’s Box File, and is replaced by the Personal Crew File of the joining
Crewmember.
The Personal Crew File of the off-signer is transferred to Box Files – “Off-duty Crew”, at the
specific Box File per Rank (Masters, Chief Officers, Chief Engineers, Second Engineers, and Bosun
etc.).
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2.19 RECORDS OF AIRLINE TICKETS
The Crew Department keeps records of all Airline Tickets for traveling Crew, through:
• OFF/CRW/513-“General Booking Plan” (for each flight arrangement) with attached
documentation.
• OFF/CRW/514-“Issued Airline Tickets-Summary Table” per Month.
2.20 CREW EMERGENCY

In case of Crew Emergency, refer to Emergency Procedures Manual (004).
3. RECORDS
• In-Office Familiarization – Schedule PRO/PRO 21/ OFF/CRW/501
• Interview / Familiarization Checklist - Technical Dept. PRO/PRO 21/ OFF/CRW/502
• Interview / Familiarization Checklist - Marine / Vetting Dept. PRO/PRO 21/ OFF/CRW/503
• Interview / Familiarization Checklist - Operations Dept. PRO/PRO 21/ OFF/CRW/504
• Interview / Familiarization Checklist - S&Q Dept. PRO/PRO 21/ OFF/CRW/505
• Interview / Familiarization Checklist - Security Dept. PRO/PRO 21/ OFF/CRW/505A
• Interview / Familiarization Checklist – Crew Dept. PRO/PRO 21/ OFF/CRW/506
• Interview / Familiarization Checklist - Training Dept. PRO/PRO 21 OFF/CRW/506A
• Interview / Familiarization Checklist - Purchasing Dept. PRO/PRO 21/ OFF/CRW/507
• Appraisal Report for Master PRO/PRO 21/ OFF/CRW/508A
• Appraisal Report for Senior Deck Officers PRO/PRO 21/ OFF/CRW/508B
• Appraisal Report for Senior Engineer Officers PRO/PRO 21/ OFF/CRW/508C
• Skype Interview – Masters PRO/PRO 21/ OFF/CRW/509A
• Skype Interview - Chief Officers PRO/PRO 21/ OFF/CRW/509B
• Skype Interview – Second Officers PRO/PRO 21/ OFF/CRW/509C
• Skype Interview - Third Officers PRO/PRO 21/ OFF/CRW/509D
• Skype Interview – Chief Engineers PRO/PRO 21/ OFF/CRW/509E
• Skype Interview - Second Engineers PRO/PRO 21/ OFF/CRW/509F
• General Booking Plan PRO/PRO 21/ OFF/CRW/513
• Airline Tickets Issued PRO/PRO 21/ OFF/CRW/514
• Hand-over Notes PRO/PRO 21/ OFF/CRW/515
• Briefing of Masters and Chief Officers PRO/PRO 21/ OFF/CRW/516A
• Briefing of Chief Engineer & Second Engineer PRO/PRO 21/ OFF/CRW/516B
• Debriefing of Master PRO/PRO 21/ OFF/CRW/517A
• Debriefing of Chief Engineer PRO/PRO 21/ OFFC/RW/517B
• Master’s Mentoring Report PRO/PRO 21/ OFF/CRW/518A
• Chief Engineer’s Mentoring Report PRO/PRO 21/ OFF/CRW/518B
• Hand-over Checklist – Master PRO/PRO 21/ SF/CRW/501
• Hand-over Checklist - Chief Officer for OT/CT PRO/PRO 21/ SF/CRW/502
• Hand-over Checklist - Chief Officer for LPG PRO/PRO 21/ SF/CRW/502A
• Hand-over Checklist - Chief Engineer PRO/PRO 21/ SF/CRW/503
• Hand-over Checklist – Other PRO/PRO 21/ SF/CRW/504
• Job Familiarization - General Training Record PRO/PRO 21/ SF/CRW/505
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• Bridge Equipment Familiarization Checklist PRO/PRO 21/ SF/CRW/505A-1

• ECDIS Familiarization Checklist PRO/PRO 21/ SF/CRW/505A-2
• ECDIS Certificate PRO/PRO 21/ SF/CRW/505A-3
• Cargo Equipment Familiarization PRO/PRO 21/ SF/CRW/505B
• Engine Room Familiarization PRO/PRO 21/ SF/CRW/505C
• Crane Operator Familiarization –Training Record PRO/PRO 21/ SF/CRW/505D
• Safety and Security Familiarization -Training PRO/PRO 21/ SF/CRW/506
• Appraisal Report for Deck Officers PRO/PRO 21/ SF/CRW/508A
• Appraisal Report for Engine Officers PRO/PRO 21/ SF/CRW/508B
• Appraisal Report for Rating PRO/PRO 21/ SF/CRW/508C
• Training /Familiarization of Trainee Master PRO/PRO 21/ SF/CRW/509A
• Training /Familiarization of Trainee Chief Officer PRO/PRO 21/ SF/CRW/509B
• Training /Familiarization of Trainee Chief Engineer PRO/PRO 21/ SF/CRW/509C
• Training/Familiarization of Trainee Second Engineer PRO/PRO 21/ SF/CRW/509D
• Crew Qualifications Checklist PRO/PRO 21/ SF/CRW/511
• Crew List PRO/PRO 21/ SF/CRW/513
• Indemnity Form PRO/PRO 21/ SF/CRW/514
• Application for re-employment PRO/PRO 21/ SF/CRW/515
• Proposal for Promotion PRO/PRO 21/ SF/CRW/517
Written Warning PRO/PRO 21/ SF/CRW/525

• Statement of Environmental Compliance PRO/PRO 21/ SF/CRW/526
• Dismissal Notice PRO/PRO 21/ SF/CRW/527
• Crew Shore Leave Checklist PRO/PRO 21/ SF/SEC/920
• Cash Account PRO/PRO 21/ SF/ACC/702
• Provisions Account PRO/PRO 21/ SF/ACC/703
• Bonded Stores / Shore Chest Account PRO/PRO 21/ SF/ACC/704
• Travel Guidance Checklist PRO/PRO 21/ TEMP 24
Manning Agent's Forms (provided by the Company)
• English Assessment Table PRO/PRO 21/ MAN/AGENT/001
• Crew Qualifications Checklist PRO/PRO 21/ MAN/AGENT/002
• Transmittal Sheet PRO/PRO 21/ MAN/AGENT/004
• Travel Guidance Checklist PRO/PRO 21/ MAN/AGENT 006
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MLC REQUIREMENTS Eff.Date: 30/09/2022
Contents
1. PURPOSE .................................................................................................................................... 3
2. PROCEDURE .............................................................................................................................. 3
2.1 Maritime Labour Convention - MLC 2006 .............................................................................. 3
2.1.1 The Sixteen (16) Areas of the MLC 2006 Inspections ..................................................................................3
2.1.2 Inspections and MLC Certificates ..................................................................................................................4
2.2 Company Manning Procedure .................................................................................................. 7
2.2.1 Criteria for Setting the Vessel’s Crewing Level.............................................................................................8
2.2.2 Master’s Request for Additional Crew ..............................................................................................................9
2.2.3 Crew Dispensation.............................................................................................................................................9
2.3 Minimum Requirements for Employment of Shipboard Personnel ....................................... 10
2.3.1 Standard Minimum Experience Requirement per Rank ..................................................................................10
2.3.2 Combined Experience of Senior Officers per Ship Department ......................................................................11
2.3.3 Standard Minimum Qualification Requirements per Rank ..........................................................................11
2.3.4 Minimum Age Limit........................................................................................................................................11
2.3.5 Maximum Age Limit....................................................................................................................................12
2.3.6 English Language and Computer Skills .......................................................................................................13
2.4 Seafarers Employment Agreements (SEA, CBA), Wages and Payments ............................. 14
2.4.1 The Seafarer’s Employment Agreement (SEA) ...........................................................................................14
2.4.2 Responsibilities ............................................................................................................................................17
2.4.3 The Wages....................................................................................................................................................17
2.4.4 Cash to Master, Home Allotments and other Crew Payments......................................................................19
2.5 Medical Certification of Seafarers .......................................................................................... 21
2.5.1 Responsibilities of the Crew Department and the Manning Agent ..............................................................21
2.5.2 Contents of the Medical Certificate..............................................................................................................22
2.5.3 Validity of the Medical Certificates .............................................................................................................23
2.5.4 Failure to pass Pre-Employment Medical Examinations .............................................................................23
2.5.5 Signing off due to Serious Illness or Injury..................................................................................................24
2.5.6 Confidentiality of Medical Reports ..............................................................................................................24
2.5.7 Declaration of Personal Medication .............................................................................................................24
2.6 Hours of Work and Rest ......................................................................................................... 24
2.6.1 General .........................................................................................................................................................24
2.6.2 Work during Emergencies or Overriding Operational Conditions ...............................................................26
2.6.3 Watch Schedules ..........................................................................................................................................26
2.6.4 Monitoring of Work/Rest Hours ..................................................................................................................28
2.6.5 Records of Work/Rest Hours .......................................................................................................................28
2.6.6 Work After Dry-dock ...................................................................................................................................28
2.7 Entitlement to Leave ............................................................................................................... 29
2.7.1 Calculation of Entitlement ...........................................................................................................................29
2.7.2 Taking on Annual Leave ..............................................................................................................................29
2.8 Repatriation ............................................................................................................................. 30
2.8.1 Entitlement to Repatriation ..........................................................................................................................31
2.8.2 Seafarers put Ashore at Foreign Ports ..............................................................................................................32
2.8.3 Loss of Right of Repatriation .......................................................................................................................32
2.9 Seafarer Compensation for the Ship’s Loss or Foundering & Lay-up ................................... 33
2.9.1 Loss or Foundering of Vessel.......................................................................................................................33
2.9.2 Lay-up ..........................................................................................................................................................33
2.10 Shipowner’s Liability .......................................................................................................... 33
2.11 Social Security ..................................................................................................................... 34
2.12 Financial Security Certificates............................................................................................. 34
2.13 Accommodation................................................................................................................... 35
2.13.1 Company Procedure for Inspection and Maintenance of Accommodation Spaces and Equipment .............36
2.14 Food and Catering ............................................................................................................... 37
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2.14.1 Food Supplies ...............................................................................................................................................38

2.14.2 Ship’s Menu .................................................................................................................................................38
2.14.3 Ship’s Cook ..................................................................................................................................................38
2.14.4 Catering Staff ...............................................................................................................................................38
2.14.5 Master’s Health and Hygiene Inspection .....................................................................................................38
2.15 Crew Welfare and Recreational Facilities ........................................................................... 39
2.15.1 Personal Protective Equipment ....................................................................................................................39
2.15.2 Press .............................................................................................................................................................39
2.15.3 Mail ..............................................................................................................................................................39
2.15.4 Welfare Items ...............................................................................................................................................39
2.15.5 Free Internet .................................................................................................................................................40
2.15.6 Gambling ......................................................................................................................................................40
2.16 Onboard Complaint Procedure ............................................................................................ 40
2.16.1 Contact Details Available to the Seafarer ....................................................................................................41
2.16.2 Crew Complaints Procedure.........................................................................................................................41
2.16.3 External Authorities .....................................................................................................................................42
2.16.4 Unresolved Disputes & Arbitration ..............................................................................................................43
2.16.5 Record Keeping............................................................................................................................................43
2.16.6 Reporting to the Company ...........................................................................................................................43
2.16.7 Non Victimization of Crew who File Complaints ........................................................................................43
2.17 Measures against Harassment and Bullying onboard ......................................................... 44
2.18 Safety Protection and Accident Prevention ......................................................................... 44
2.18.1 Safety Protection ..........................................................................................................................................44
2.19 Selection of Manning Agent and Responsibilities............................................................... 45
2.19.1 Criteria for Selecting the Manning Agent ....................................................................................................45
2.19.2 Manning Agencies’ Compliance with MLC 2006 .......................................................................................46
2.19.3 The Agency Agreement ....................................................................................................................................48
2.19.4 Content of the Agency Agreement ...............................................................................................................48
2.19.5 Declarations of MLC (DMLC PARTS I & II) .............................................................................................49
2.20 Audits of the Contracted Manning Agent(s) ....................................................................... 49
3. RECORDS ................................................................................................................................. 50
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1. PURPOSE
This procedure describes the actions to be taken in order to ensure full compliance with the MLC
2006 requirements.
2. PROCEDURE
2.1 MARITIME LABOUR CONVENTION - MLC 2006

The aim of the MLC 2006 Convention is to safeguard the Seafarers' wellbeing and their health &
safety in all aspects of their living and working onboard.
The Flag Administration has established an Inspection and Certification Program to implement
the MLC 2006, which governs the Maritime Labour conditions and sets minimum standards for the
working and living conditions of seafarers onboard ships.
The MLC 2006 applies to all ships of: ( Regulation 5.1.3 )

 500 gross tonnage or over, engaged in International Voyages;**
 500 gross tonnage or over, flying the Flag of a Member and operating from a port, or between
ports of another country.
** International Voyage means a voyage from a country to a port outside such a country
All ships to which is the MLC 2006 applies of 500 gross tons or over, engaged in International
Voyages or operating from a port or between ports in another country, must be certified for
compliance with the sixteen (16) areas of the MLC 2006 which are subject for mandatory
inspection.
A copy of the MLC 2006 must be maintained onboard and made available to all seafarers.
2.1.1 The Sixteen (16) Areas of the MLC 2006 Inspections

A MLC Certificate will be issued or renewed after completion of a satisfactory inspection of the
National Requirements for the sixteen (16) areas listed below for implementing the MLC 2006:
(MLC 2006 Convention – Appendix A5-1).
No. Regulation Requirements

1. Regulation 1.1 Minimum Age
2. Regulation 1.2 Medical Certification
3. Regulation 1.3 Qualifications of Seafarers
4. Regulation 2.1 Seafarers' employment agreements ( SEA )
Use of any licensed or certified or regulated private recruitment &
5. Regulation 1.4 placement service
6. Regulation 2.3 Hours of Work or Rest
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No. Regulation Requirements

7. Regulation 2.7 Manning Levels for the Ship
8. Regulation 3.1 Accommodation
9. Regulation 3.1 On-board Recreational Facilities
10. Regulation 3.2 Food and Catering
11. Regulation 4.3 Health and Safety and Accident Prevention
12. Regulation 4.1 On-board Medical Care
13. Regulation 5.1.5 On-board Complaint Procedures
14. Regulation 2.2 Payment of Wages
15. Regulation 2.5 Financial Security for Repatriation
16. Regulation 4.2 Financial Security relating to Shipowners’ Liability
2.1.2 Inspections and MLC Certificates

A. Interim Inspection and Interim MLC Certificate
An Interim MLC Certificate may be issued to: (Standard A5.1.3 (5))

• New Ships on delivery
• When a Ship changes Flag
• When a Shipowner assumes responsibility for the operation of a ship which is new to that
Shipowner.
An Interim IMLC may only be issued following verification that: (Standard A5.1.3 (7)
 The ship has been inspected, as far as reasonable and practicable, for the sixteen (16) areas listed
in § 2.1.1 of this procedure (MLC 2006 Appendix A5-1).
 The Shipowner has demonstrated to the Competent Authority or the Recognized Organization
(RO) that the ship has adequate procedures to comply with the MLC 2006 Convention.
 The Master is familiar with the requirements of MLC 2006 and the responsibilities for
implementation.
 Relevant information has been submitted to the RO to produce a DMLC.
An Interim MLC Certificate may be issued for a period not exceeding Six (6) Months
(Standard A5.1.3 (6)).
No further Interim Certificate may be issued following the initial six (6) months.
(Standard A5.1.3 (8)).
A full Inspection must be carried out before the expiration of the Interim MLC Certificate, to enable
the issuance of the full-term MLC Certificate ( 5 year )
A DMLC need not be issued for the period of validity of the Interim MLC Certificate
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B. Initial Inspection and Long Term MLC Certificate

A full inspection must be carried out before the expiration of the Interim MLC Certificate in
order to enable the issuance of a full-term MLC Certificate.
The MLC Certificate shall be issued to a ship by the Flag Administration , or by a Recognized
Organization ( e.g Lloyds Register, DNV-GL, ABS etc ) duly authorized for this purpose.
A list of matters ( 16 areas ) that must be inspected and found to meet National Laws and
Regulations is found in § 2.1.1 of this Procedure (based on Appendix A5-I of the MLC 2006).
The Validity of the Long Term MLC Certificate shall not exceed five (5) years.
C. Initial Inspection and Long Term MLC Certificate

The validity of the MLC Certificate will be subject to an Intermediate Inspection by the
competent authority, or by a Recognized Organization, to ensure continuing compliance with the
National Requirements implementing this Convention.
This Intermediate Inspection it will take place between the Second (2nd) and Third (3rd)
Anniversary date of the certificate.
“Anniversary date” means the day and month of each year which will correspond to the date of
expiry of the MLC Certificate.
The MLC Certificate shall be endorsed, following satisfactory intermediate inspection.
A Full Term MLC Certificate endorsed by the RO, must have attached to it
the DMLC (Declaration of Maritime Labour Compliance).
( Standard A5.1.3 (10))
D. Renewal Inspection and issuance of a new MLC Certificate

A Renewal Inspection must be carried out, before the expiration of the Full Term MLC
Certificate.
When the Renewal Inspection has been completed within three (3) months before the expiry of
the existing MLC Certificate, the new MLC Certificate shall be valid from the date of completion
of the renewal inspection for a period not exceeding five (5) years from the date of expiry of
the existing certificate.
When the Renewal Inspection is completed more than three (3) months before the expiry date of
the existing MLC Certificate, the new MLC certificate shall be valid for a period not exceeding
five (5) years starting from the date of completion of the renewal inspection.
Where after a Renewal Inspection completed prior to the expiry of the MLC Certificate, the ship
is found to continue to meet National Laws and Regulations or other measures implementing the
requirements of this Convention, but a new MLC Certificate cannot immediately be issued to
and made available on board that ship, the Competent Authority, or the Recognized Organization
duly authorized for this purpose, may extend the validity of the Certificate for a further
period not exceeding five (5) months from the expiry date of the existing certificate, and
endorse the certificate accordingly.
The new certificate shall be valid for a period not exceeding five years, depending on the date of
the Renewal Inspection as detailed in this paragraph. (As per MLC 2006 Amendments 2016).
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A copy of the MLC Certificate of Compliance must be posted in a conspicuous place onboard the
ship, or otherwise “publicly available” (MLC 2006- Regulation 5.1.3 (6) & Standard A5.1.3 (12)).
A Copy must be made available in accordance with National Laws and Regulations, upon request,
to seafarers, Flag State Inspectors, Authorized Officers in Port States, and Shipowners’ and
Seafarers’ Representatives.
E. Declaration of Maritime Labour Convention (DMLC)

This document outlines the National Laws or provisions that give effect to the 16 Areas of the MLC
2006 that are subject to inspection for certification and the measures put in place by the Shipowner
/operator to ensure compliance with these inspection items.
The DMLC consists of two (2) parts:
 DMLC -Part I
This is drawn-up by the Competent Authority (Flag Administration) and:
 Identifies the list of matters to be inspected ( 16 areas as per § 2.1.1 of this procedure
based on Appendix A5-I of MLC )
 Identifies the National Requirements embodying the provision of MLC 2006
 Refers to Ship-type specific requirements under National Legislation
 Records and substantially equivalent provisions
 Clearly indicates any exemptions granted by the Flag Administration.
 DMCL Part II:

The statement is drawn-up by the Ship-owner / Operator and identifies:
 The measures adopted to ensure ongoing compliance with the National requirements between
inspections
 The measures proposed to ensure that there is continuous improvement
Such measures must in particular:
• Indicate the occasions on which ongoing compliance with National Requirements shall be
verified.
• The Persons responsible for verification.
• The Records to be taken.
• The Procedures to be followed when Non Compliance is identified.
To ensure ongoing compliance, the DMLC Part II must also include general international
requirements concerning advances in technology and scientific finding concerning workplace design.
The DMLC Part II shall be certified compliant by the relevant RO before the issuance of the
MLC Certificate to the Shipowner /Operator.
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The MLC Certificate shall cease to be valid in any of the following cases: (Standard A5.1.3 (14))
a) If the relevant inspections are not completed within the periods specified under Standard
A5.1.3.2 i.e an intermediate inspection must be carried out between the second and third
anniversary date of the certificate.
b) If the certificate is not endorsed in accordance item a) above
c) When a ship changes Flag;
d) When a Company ceases to assume the responsibility for the operation of a ship; and
e) When substantial changes have been made to the structure or equipment.
A new MLC Certificate shall only be issued when the Competent Authority (Flag Administration) or
Recognized Organization, issuing the new MLC Certificate is fully satisfied that the Ship is in
compliance with the requirements of the MLC 2006 Convention.
A MLC Certificate shall be withdrawn by the Competent Authority (Flag Administration) or the
Recognized Organization if there is evidence that the ship concerned does not comply with the
requirements of the MLC 2006 Convention, and any required corrective action has not been taken.
When considering whether a Maritime Labour Certificate must be withdrawn (as per Standard
A5.1.3 (14)), the Competent Authority or the Recognized Organization shall take into account the
seriousness or the frequency of the deficiencies.
Compliance with the MLC 2006 requirements is part of the internal audit process onboard and ashore
and shall be verified concurrently with other Company systems audited. The results of the audits
shall be documented as per the Internal Audit procedure and any non-conformities issued shall be
addressed in line with the Company's relevant system.
2.2 COMPANY MANNING PROCEDURE

In order to comply with the standards of the Maritime Labour Convention ( MLC 2006), every
Company Vessel must be manned by a Crew that is adequate in terms of size and qualifications, to
ensure the safety and security of the ship and its personnel, under all operating conditions in
accordance with the Minimum Safe Manning Certificate or an equivalent issued by the
Competent Authority (Flag Administration)
Complying with the MLC 2006 requirements the Company ensures at all times that:
 The Vessels are manned in accordance with the Safe Manning as set by the Administration.
 The Seafarers' licenses and special qualifications are valid.
 The Seafarers are sufficiently rested to limit fatigue.
The Company procedure to ensure the Safe Manning of the Vessel is the following:
 When an acquisition of a Vessel is to be made, and as soon as this is made known, the Crew
Manager must check the Safe Manning requirements, as per the Vessel's Safety Manning
Certificate.
 Before the acquisition, since the Safe Manning Certificate is not issued, the Crew Manager and
Top Management will decide on the Manning Level of the Vessel, based on previous experience
on the specific type of Vessel.
 It is Company Policy to man its Vessels high above the requirements of the Administration, in
order to maintain high and efficient operational standards onboard.
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2.2.1 Criteria for Setting the Vessel’s Crewing Level

The Crewing level of each Vessel (or sister Vessels) is subject to Management decision.
This decision must be based on the following criteria:
• Compliance with the Safe Manning Certificate.
• The safe and efficient Operation of the ship, under all conditions.
• The maintenance work to be done onboard, which may require additional Crew e.g. more fitters
etc.
• The Vessel's trading schedule (if it includes consecutive short voyages and high workload
that might necessitate increase of Bridge /Mooring/Engineering Manning levels).
• The Vessel's trade (nature and conditions of voyage, nature of cargo i.e. dangerous cargo etc).
• The Vessel's trading area and security conditions (in case it is trading in unsafe areas, where
terrorist activities and piracy are possible, it is likely that more Crew is required to cover the
requirements of the ISPS Code).
• A Manning Level which will ensure sufficient rest and limit seafarer fatigue.
• The Vessel’s engagement in continuous /repetitive STS Operations would entail the provision of
an additional Deck Officer, in order to cope with Watch-Keeping /Rest Hours requirements.
• Especially VLCCs, SUEZMAXs and AFRAMAXs ( if any) , must be manned with three (3)
Deck Officers in addition to the Chief Officer and Master, when lightering in the US Gulf.
(For details, please refer to Cargo Operations Manual (001) –Section 23 §2.2.2 and §2.2.3.)
• Before a Vessel’s Dry-dock, the Crew complement to be sufficient, supplemented as required, in

order to cope with the increased work load, during the dry-dock preparation state and while the
Vessel is in the Shipyard.
The Vessel’s Master and Technical Department must determine ranks of the additional Crew
requirements i.e fitters, painters, Deck or Engine Officers.
Sometimes, due to sister Vessels in the Fleet, Management may decide on a “Standard Crewing
Level” per Ship Type.
The decision is taken by the DPA in close cooperation with the Crew Manager, the Technical
Manager and the Fleet Managers.
The final decision as to the Crewing level must be documented in writing, signed by the DPA.
(See on next page Minimum Manning Levels established by the Company)
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The Table below presents the Minimum Manning Levels established by the Company for safe Fleet
Operation.
Company Manning Standard Tanker Gas Vessels

Vessels
Master 1 1
Chief Officer 1 1
Officers in charge of a Navigation Watch 1 1
Chief Engineer 1 1
Second Engineer 1 1
Officers in charge of Engineering Watch (*UMS) 2 2
Electrician 1 1
Bosun 1 1
Gas Engineer (when required) - 1
Pumpman (when required) 1 -
Ratings forming part of a navigation watch / Able Seamen 4 4
Ordinary Seamen or deck cadets 1 1
Ratings part of an engineering watch/Motormen or Oiler (**UMS) 3 3
Cook 1 1
Messman 1 1
**For UMS Vessels Officer in charge of Engineering Watch is not required.

**For UMS Vessels one motormen/or Oiler to be excluded.
The onboard Manning Levels are reviewed on a Quarterly basis during Management Review Meetings.
2.2.2 Master’s Request for Additional Crew

When the Vessel changes its operations activities, the Master may request additional Crew, if the
activities cannot be effectively performed by the existing Crew onboard.
Complaints or disputes concerning the Manning Level of the ships may be addressed by the
Shipboard Personnel to the Competent Authority for investigation and settlement, therefore the
Company has assigned one person (member of the Crew Department or other Department as
assigned) to monitor all such complaints and to be in contact with the Competent Authority.
2.2.3 Crew Dispensation

A Crew Dispensation must be requested from the Flag Administration, if for any reasons the
Minimum Ship's Manning Certificate is affected.
If for example the Master is incapacitated and the Chief Officer must temporarily (e.g. until reaching
port) assume the Master's duties without being the holder of a Master's Certificate, then a Crew
Dispensation is required.
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2.3 MINIMUM REQUIREMENTS FOR EMPLOYMENT OF SHIPBOARD PERSONNEL

As per MLC 2006- Regulation 1.3, Seafarers must not work on a Vessel unless they are trained and
certified as competent or otherwise qualified to perform their duties.
This is ensured by the Manning Agent and the Company by reviewing their Certificates of
Competency and all other Training Certificates required by STCW.
(These are analyzed in detail in this procedure and are itemized in form "Crew Qualifications
Checklist").
Each Seafarer must be in possession of valid Licenses and Certificates, issued by a Recognized
Authority in accordance with the Vessel's Type or Cargo and Navigational/ Technical outfit.
The Crew Manager is responsible to ensure that Company's minimum experience requirements and
the level of Senior Officers aggregate service onboard each Vessel, comply with those defined
in this procedure.
In exceptional cases, where these requirements are not satisfied, a Management of Change and Risk
Assessment must be conducted in order to define measures to mitigate the risks involved.
2.3.1 Standard Minimum Experience Requirement per Rank

The minimum experience requirements set by the Company for the employment of seagoing
personnel NOT from Company's Pool are as follows:
Years in Level of
Rank Sea service (years)
Rank English
Master 1 7 (2 years in similar Vessel type) Good
Senior Officers
Ch. Officer 0.5 4 (1 year in similar Vessel type) Good

Chief Engineer 4 (2 year in similar technical outfit) Good
1
2nd Engineer 0.5 3 (1 year in similar technical outfit) Good
2nd Officer Good

Officers
- 1
Junior
Deck
3nd Officer Good

- -
3nd Engineer
- 1
Officers
Engine
Junior
4th Engineer
- -
Electrician 1 (ships of similar technical outfit) Good
-
Bosun/Pumpman - 1 Basic
A/B, Oilers - 1 Basic
Ranks
Other
O/S Wipers, Ass

- 0.5 Basic
Stewards, Ass. Cooks
Ch. Stewards & Cooks - 1 Basic
App. Officer & Eng. - - Basic
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2.3.2 Combined Experience of Senior Officers per Ship Department

Complying with the Oil Major Companies requirement, the following must always be taken into
account for the manning of Tankers:
The two Senior Officers of each Department (Master- Chief Officer & Chief Engineer -Second
Engineer), must:
A. Not join the Vessel at the same time.
B. Satisfy the experience requirements described in the following table:
YEARS IN RANK ENGAGEMENT

Experience Sea service Years with Minimum Months
Rank Operator of Sailing with the
Company
Years on ALL 2*
Years in Rank 1
types of tankers 1*
A) SENIOR OFFICERS
Master + Chief Officer Six (6) Three (3 ) Two (2) 9
Chief Engineer + 2nd Engineer Six (6) Three (3 ) Two (2) 9
B) JUNIOR OFFICERS ( The following criteria are strongly preferred but not compulsory)
Junior Officers (Deck/Engine) One (1) One (1) One (1)
1* Time served on board - Sea time

2* Calendar Years or at least 6 months sea service
2.3.3 Standard Minimum Qualification Requirements per Rank

The Standard Minimum Qualification Requirements per Rank are the following:
(Detailed in PROCEDURE 21- of this Manual, § 2.4.6- Master’s Checks of Crew Certificates and in
the relevant Checklist SF/CRW/511- "Crew Qualification Checklist").
2.3.4 Minimum Age Limit

Fully complying with the requirements of the MLC 2006-Regulation 1.1, the Company has strictly
set the Minimum Age to 18.
No person under the age of 18 shall be engaged or work onboard the ship in ANY rank, including
the rank of Ship's Cook.
The age verification of each seafarer must be strictly carried out prior employment, by both the
Manning Agent and the Crew Department.
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2.3.5 Maximum Age Limit

The Company has set the following Age Limits in order to avoid aged Crew and increased Crew
exposure to danger, due to possible health risks (hard physical labor, stress, shift work, climate,
fatigue and limited qualified medical attendance at all times).
RANK AGE LIMIT AGE LIMIT

FOR NEWCOMERS
Deck Crew
Masters 65 60
Chief Officers 62 50
Second Officers 50 35
Third Officers 40 30
Bosuns 65 60
Fitters 60 55
Able Seamen 60 55
Ordinary Seamen 50 45
Engine Crew
Chief Engineers 65 55
Second Engineers 62 50
Electrical Engineers 62 55
Third Engineers 50 35
Fourth Engineers 40 30
Gas Engineer 60 55
Pumpmen 60 55
Oilers 60 55
Wipers 50 45
Catering Staff
Cooks 60 55
Second Cooks 55 50
Messboys 50 45
However, it must be stressed that these Maximum Age Limits

are only “indicative” and not binding.
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2.3.6 English Language and Computer Skills
A. English Language
The official language of the Vessel is English. All IMS documentation is in English. All
communication between the Office and the Vessels (and vice versa) is carried out in English. The
Master, Navigation Officers and Engineer Officers are required to meet, as a minimum, the English
Proficiency standard as required by STCW.
The ability of Shipboard Personnel to communicate effectively in English during normal duties
and emergencies must be strictly assessed at the time of recruitment.
The Manning Agent is therefore instructed to commence all recruiting procedures by starting
with the assessment of the seafarer's ability to communicate in English.
The Manning Agent must interview the seafarer in English in order to assess his knowledge. In case
the seafarer's English is poor for the needs of his rank, this candidate must not be proposed for
recruitment on any Company Vessel. Insufficient knowledge of the English language for the needs of
a seaman's rank may lead to the breach of his contract.
For this purpose, the "English Assessment Table" has been issued by the Company and has been
provided to the Manning Agent to be filled-in for each seafarer who is proposed for employment.
This form must be present in each Personal Crew File.
The Assessment of the English Language by the Manning Agent is conducted by qualified English
Language Assessors (i.e Teachers of the English Language).
Objective evidence must be based on an Internationally Recognized Test System i.e
 Marlin’s English Language Test
 Seagull CES Test “Maritime English”
Rank-Specific “Passing-Scores” are as follows:
 Masters and Chief Officers 85%.
 Chief Engineers 75%.
 Deck Officers 60 %.
 Engine Officers 60%.
 Ratings 55%.
The education and experience of the English Language Assessors is audited by the Company
during the Annual Manning Agent's Audit.
The Master must also assess communication effectiveness on an ongoing basis, during Crew
performance appraisals.
Company Superintendents must continuously assess the English level of Senior Officers during their
visits onboard.
B. Computer Skills
All Officers must have basic Computer skills in order to create computerized reports. Basic
knowledge of Excel, Word, copying from CDs is a requirement.
All Officers must be tested in the Manning Agent's Office, for both the English language and
Computer skills, before final employment.
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2.4 SEAFARERS EMPLOYMENT AGREEMENTS (SEA, CBA), WAGES AND PAYMENTS

This procedure describes the way in which the terms and conditions of employment are defined and
agreed, the way wages are set, the way that Home allotments are settled and any other payments due
to Shipboard Personnel, in order to ensure that seafarers have a fair employment agreement.
2.4.1 The Seafarer’s Employment Agreement (SEA)

Before the commencement of work, every seafarer must have a Seafarer's Employment Agreement
(SEA), issued by the Manning Agent under the instructions of the Company. The SEA is a
legally enforceable document and must be consistent with the standards set out in the MLC 2006. It
must clearly define the terms and conditions under which the Crewmember is to be employed and
must include any applicable Collective Bargaining Agreements (CBA).
A. MLC 2006 Requirements regarding the Sea
• The SEA must be signed by both the Seafarer and the Company or a representative of the
Company.
• Seafarers signing a Seafarers' Employment Agreement must be given the opportunity to
examine and seek advice on the agreement before signing it, as well as such other facilities as are
necessary to ensure that they have freely entered into an Agreement with a sufficient
understanding of their rights and responsibilities.
• The Company and the Seafarer concerned must each have a signed original of the
Seafarer's Employment Agreement.
• Measures must be taken to ensure that clear information as to the conditions of their
employment can be easily obtained onboard by seafarers, including the Ship's Master and that
such information, including a copy of the seafarer's employment agreement is also accessible for
review by Officers of a competent authority, including those in ports to be visited.
B. Minimum Requirements to be included in the Employment Agreement
As per MLC 2006 the following information must be included in the Employment Agreements
and/or the Collective Bargaining Agreement:
• The seafarer's full name, date of birth of age and birthplace.
• The Company's name and address.
• The place where and the date when the Seafarer's Employment Agreement is entered into.
• The capacity in which the seafarer is to be employed.
• The amount of the seafarer's wages or, where applicable, the formula used for calculating them.
• The amount of paid annual leave, or where applicable, the formula used for calculating it.
• The termination of the agreement and the conditions thereof, including:
 If the agreement has been made for an indefinite period, the conditions entitling either
party to terminate it, as well as the required notice period, which shall not be less for the
ship-owner than for the seafarer.
 If the agreement has been made for a definite period, the date fixed for its expiry.
 If the agreement has been made for a voyage the part of destination and the time which has
to expire after arrival before the seafarer must be discharged.
• Provision for health and social security protection benefits to be provided to the seafarer by the
ship-owner.
• The seafarer's entitlement to repatriation.
• Reference to the Collective Bargaining Agreement, if applicable.
• Any other particulars which national law may require.
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C. Regulation 2.1- Standard A.2.1- Seafarers’ Employment Agreements

(in force since 26/12/2020)
Each Member shall require that a seafarer’s employment agreement shall continue to have effect
while a seafarer is held captive on or off the ship as a result of acts of piracy or armed robbery
against ships, regardless of whether the date fixed for its expiry has passed or either party has
given notice to suspend or terminate it.
For the purpose of this paragraph, the term:
(a) Piracy shall have the same meaning as in the United Nations Convention on the Law of the
Sea, 1982;
(b) Armed robbery against ships means any illegal act of violence or detention or any act of
depredation, or threat thereof, other than an act of piracy, committed for private ends and
directed against a ship or against persons or property on board such a ship, within a State’s
internal waters, archipelagic waters and territorial sea, or any act of inciting or of intentionally
facilitating an act described above.
D. Minimum Notice Period (7 Days)

The Employment Agreement must contain provisions for the minimum notice period to be given by
the seafarer and the Company for the early termination of a seafarer's employment agreement.
The duration of this minimum notice period shall be according to National Laws and
Regulations of the Vessel's Flag State but must not be shorter than seven (7) days.
E. Notice Period Shorter than 7 Days

A notice period shorter than the minimum (i.e. seven (7) days) may be given in circumstances which
are recognized under National Law or Regulations or applicable collective bargaining agreements as
justifying termination of employment agreement at shorter notice or without notice.
In determining those circumstances the need of the seafarer to terminate without penalty the
employment agreement on shorter notice or without notice for compassionate or other urgent reasons
must be taken into account.
F. Record of Employment
Reference is made to procedure PRO 21-“Shipboard Personnel” of this Manual.
G. Collective Bargaining Agreement

Where a Collective Bargaining Agreement forms all or part of a Seafarer's Employment Agreement,
a copy of that agreement must be available onboard.
Where the language of the Seafarer's Employment Agreement and any applicable
Collective Bargaining Agreement is not in English the following must also be available in English.
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H. A copy of the Standard form of the Agreement

• The portions of the Collective Bargaining Agreement that are subject to a Port State Control
Inspection.
The Company must retain all Seafarer's Employment Agreements for at least five (5) years
for legal reasons in the Head Office.
I. Seafarer’s MLC Declaration regarding the “SEA”

The SEA used by the Company has incorporated an "MLC Declaration" (Form
MAN/AGENT/007A) which is signed by the Seafarer as part of the SEA and indicates that:
• All items contained in the SEA have been explained to the seafarer and he is aware of them.
• All the Certificates / Documents that the seafarer has furnished are genuine.
• A full sample agreement incorporating all terms and conditions to apply (including the CBA)
have been provided to the seafarer prior to entering the agreement.
• The Seafarer was given adequate time to review the contract and seek advice on the terms and
conditions in the agreement.
• The seafarer freely entered into the Agreement with a sufficient understanding of his rights
and responsibilities.
• He was given an original set of his SEA, which he must carry with him onboard.
(A copy can also be carried onboard).
• No fees or other charges for his recruitment or placement or for providing employment to him
have incurred directly or indirectly in whole or in part.
• No joining advances or any other exploitation incurred with regard to the employment.
• The Company's Complaint procedure has been explained to him and he is fully aware of the
process to be followed and the records to be used.
• The terms and conditions of employment and any particular conditions applicable to the job for
which he is engaged have been explained to him.
J. Attached Documents to the Seafarers’ Employment Agreement

The following Declarations and Official Office Forms should be attached to the Seafarer’s
Employment Agreement.
 Form OFF/ICT/008B –“Seafarer Confidentiality Agreement.
 Declarations:
o Form MAN/AGENT/007A-Seafarer’s MLC 2006 Declaration ( Detailed in §I above)
o Form MAN/AGENT/007B-Seafarer’s Drug and Alcohol Declaration
o Form MAN/AGENT/007C-Criminal Record Declaration
o Form MAN/AGENT/007D-Company Social Media Policy Statement
o Form MAN/AGENT/007E-Crew Member Acknowledgment of Environmental Policy
Statement
o Form MAN/AGENT/007F-Consent and Authorization to receive and release my
Medical Record
o Form MAN/AGENT/007G-Informed consent to participate and receive remote Tele-
consulting Services (“RMTCS”)
Signing and accepting the terms and conditions of the above Form and Declarations is mandatory and
without these, the SEA is not considered valid.
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The Crew Department should maintain full records of the signed Seafarer’s Employment Agreement
and the attachments i.e
 Form OFF/ICT/008B Seafarer Confidentiality Agreement,
 The set of Declarations (Forms MAN/AGENT/007A-G) for each Seafarer, and have them
readily for any 3rd Party Audit/Inspection.
2.4.2 Responsibilities
Although the Manning Agent signs the Seafarer's Employment Agreement on behalf of the
Company as "Agent Only" (based on a "Power of Attorney" document), he is not responsible for any
legal conflicts that may arise from the Employment Contract between the Company and the seafarer.
However, the Manning Agent is responsible in assuring that the correct Seafarer's Employment
Agreement format is used and the correct wages are applied.
In an individual contract, various conditions can be negotiable, such as wages and the duration of the
contract period.
Any deviation from the standard contract or the applicable wage scale must be confirmed by the
Company, before the contract is signed.
Union contracts, also known as Collective Bargaining Agreements and their wages are not
negotiable.
If an ITF CBA is implemented, the respective "Seaman's Employment Contract" form must be used
referring to the type of the CBA (TCC-PNO etc).
If a non-ITF Union Agreement is applied, an "Employment Contract" form may be used but
any reference to ITF must be crossed out.
2.4.3 The Wages

A. General
All Seafarers are paid for their work regularly and in full and in no greater than monthly intervals and
in accordance with their Employment Contract or any applicable Collective Bargaining Agreement.
Calculation and payment:
• for the purpose of calculating wages, the normal hours of work at sea and in port must not
exceed eight (8) hours per day;
• for the purpose of calculating overtime, the number of normal hours per week covered by the
basic pay or wages must be prescribed by national laws or regulations, if not determined by
collective agreements, but must not exceed 48 hours per week; collective agreements may
provide for a different but not less favorable treatment;
• the rate or rates of compensation for overtime, which must be not less than one and one-
quarter times the basic pay or wages per hour, must be prescribed by national laws or regulations
or by collective agreements, if applicable; and
• records of all overtime worked must be maintained by the master, or a person assigned by the
master, and endorsed by the seafarer at no greater than monthly intervals.
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B. Regulation 2.2- Standard A2.2- Wages

( in force since 26/12/2020)
Where a seafarer is held captive on or off the ship as a result of acts of piracy or armed robbery
against ships, wages and other entitlements under the seafarers’ employment agreement, relevant
collective bargaining agreement or applicable national laws, including the remittance of any
allotments as provided in paragraph 4 of this Standard, shall continue to be paid during the entire
period of captivity and until the seafarer is released and duly repatriated in accordance with
Standard A2.5.1 or, where the seafarer dies while in captivity, until the date of death as
determined in accordance with applicable national laws or regulations. The terms piracy and
armed robbery against ships shall have the same meaning as in Standard A2.1, paragraph.
(and § 2.4.1 C- of this procedure).
C. Seafarer’s Employment Agreement used by the Company

1. Calculation and Payment of Wages
The SEA adopted by the Company, states the following:
• Wages are calculated for one (1) month.
• If wages are paid for single days they always have to be calculated on the basis of a
30- day’s month.
• The wage (consolidated wage) of each Crewmember consists of the following:
o Basic Salary
o Fixed overtime
o Paid annual leave.
• The wages are paid in US Dollars, through Bank Remittances at monthly intervals.
• Overtime hours, i.e hours worked outside of normal working hours, will be paid at a rate
per hour as prescribed by the applicable Collective Bargaining Agreement.
• Applicable monthly wages are paid to the Crew, starting from the day of signing-on until
the day of signing-off.
• The Basic wage applies for the travelling time i.e from the day of departure from
homeport until the day of embarkation, and from the day of disembarkation until his safe
return to homeland.
• Seafarers are entitled to receive on request, in local currency, from the Master one half
(½) of the balance of base wages actually earned and payable at every intermediate port
where the Vessel shall load or discharge cargo before the end of the voyage, but not more
than once in a ten (10) day period.
2. Overtime
Work performed in excess of eight (8) hours per day and all works performed on Sundays
and
Holidays will be compensated monthly at the overtime rates specified in the SEA.
However, work performed in excess of the normal working hours shall not be compensated
at overtime rates when such work is necessary for the safety of the Vessel, its passengers,
officers, Crew, cargo or for the saving of other Vessels, lives or cargo, or for the performance
of fire, lifeboat or other emergency drills.
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3. Holidays
The SEA adopted by the Company, under Article -9, states that the following days are
considered as Holidays:
• New Year's Day - January 1st,
• Christmas Day- December 25th & 26th,
• Labour Day -May 1st,
• Easter Monday,
• Good Friday,
• National Days may be considered as days-off.
2.4.4 Cash to Master, Home Allotments and other Crew Payments
A. Cash to Master
On a monthly basis, the Master must submit to the Office the Master's General Account (MGA).
The balance due to Crewmembers must be sent onboard at first opportunity, in ports where the U.S.
currency delivery is possible.
In ports, where "Cash to Master" in U.S currency is not allowed from the local Bank Regulations or
the Bank commission is extremely high, the Master may request, well in advance, any amount
required for Crew advances in local currency.
B. Home Allotments
Home Allotments are the payments made to Crew Bank Accounts, as has been requested by Crew
on their employment.
Company procedures to ensure that the seafarers are able to transmit their earnings to their families
include:
• A system enabling seafarers, at the time of their entering employment or during it, to
allot, if they so desire, a proportion of their wages for remittance at regular intervals to their
families by bank transfers or similar means
• A requirement that allotments must be remitted in due time and directly to the person or
persons nominated by the Crewmembers.
At the end of each Month, the Crewmembers must declare to the Master the Home Allotments which
they wish to be made. The Master, in turn, must advise the Crew Department in writing about the
Home Allotments, within the first five (5) days of each month.
The Forms used for this purpose are the following:

• SF/ACC/705-Crew Home Allotments - Personal Details
• SF/ACC/705A-Allotments - Summary Table
After receiving the requirements from all the Vessels, the Company must proceed with the
remittance.
Any charge for the Home allotments must be of a reasonable amount and the rate of currency
exchange, unless otherwise provided must be at the prevailing market rate or the official published
rate and not unfavourable to the seafarer.
The Seafarers are given a monthly account of the payments due and the amounts paid, including
wages, additional payments and the rate of exchange used, where payment has been made in a
currency or at a rate different from the one agreed to.
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When the Bank Remittances of the monthly Home Allotments are complete, each Crewmember
receives onboard a copy of the relevant Bank Slip.
In addition, the Master must provide each seafarer, a copy of the form, in which the
seafarer's name and manual payment is stated.
C. Re-joining Bonus
The Company wishes to keep good Crew who has previously served on Company Vessels.
For this purpose, when rejoining a Company Vessel, every Officer is entitled to a re-joining
bonus which is equal to one Basic monthly salary on last service. The re-joining bonus must be paid
together with the first payment onboard the new Vessel.
D. Seniority Bonus
A seniority bonus is granted to the following ranks:
• Master,
• Chief Officer,
• Chief Engineer,
• Second Engineer,
• Electrician,
• Pumpman.
The seniority bonus depends on the Rank and the years of service on Company Vessels. The amount
of the Seniority Bonus per rank is decided by Chief Operating Officer (COO) or Deputy COO in
cooperation with the DPA/Fleet Technical Manager and the Crew Manager. Rates are reviewed
on an annual basis.
E. Crew Personal Effects

When the crewmember suffers total or partial loss of, or damages to his personal effects due to
a cause, while serving onboard the Vessel, he is entitled to recover from the Vessel’s Managers a
compensation up to a maximum five hundred (500) USD.
The crewmember must certify that any information provided with regards to lost property is true to
the best of his knowledge.
F. Other Crew Payments/ Awards

At times, the Company may decide to issue extra benefits to the Officers and Crew being connected
with the performance of the Vessel (e.g during PSC/USCG Inspections, Vetting Inspections, Holds
Preparation, Dry Docking etc., or overtime work due to response in an emergency).
However, this is at the discretion of the Company and must not be considered as a standard practice,
commitment or obligation. (Also see PRO 21-“Recognition of excellent performance).
G. Periodical Review of Wages

Periodically, the Company must negotiate wage increases, reflecting the current labor market. This
will enable the Manning Agent to supply seafarers as per Company's Standards. The Wage scales
are discussed in a Meeting with the participation of the Chief Operating Officer (COO) or Deputy
COOs, the Crew Manager and the DPA.
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The wages of each rank must be specified in a Wage Scale Table, valid for one (1) year.
The Manning Agent has the responsibility to explain to all seafarers the Contract terms and
conditions so that they fully understand the way their wages are calculated.
2.5 MEDICAL CERTIFICATION OF SEAFARERS

This procedure details the steps, which must be followed for the Medical Certification of
Seafarers as per MLC 2006 requirements.
Seafarers must not work on a ship unless they are certified as medically fit to perform their duties.
Exceptions can only be permitted as prescribed in the Code.
Pre-employment Medical examinations must be carried out by Doctors or Medical Clinics,

which are recognized or licensed by the Government or the responsible Maritime Authority or the
Flag Administration.
The Doctors and Medical Clinics must be fully aware of Flag State Maritime Requirements and must
follow the ILO/WHO Guidelines for Conducting Pre-sea and Periodical Medical Fitness.
Examinations for Seafarers, including subsequent versions and any other applicable International
Guidelines published by the International Labour Organization (ILO), the International Maritime
Organization (IMO), the World Health Organization (WHO) and MLC 2006.
The Medical Certificate must be issued by a duly qualified Medical Practitioner or, in the case of a
certificate solely concerning eyesight, by a person recognized by the Competent Authority to issue
such a Certificate. The Doctors and Medical Clinics that conduct the Medical checks must also be
approved by the Company.
The Medical Certificates for seafarers working on ships ordinarily engaged on International Voyages
must - as a minimum - be provided in English.
2.5.1 Responsibilities of the Crew Department and the Manning Agent

The Crew Department and the Manning Agent are responsible for:
• Assessing and monitoring changes to the Flag State Regulations and Guidelines
prescribing the Medical Examinations and certificates and verifying compliance. The
Crew Manager and Manning Agent are responsible for ensuring that the Medical
Certificates are issued in the prescribed format (i.e. for Marshall Islands on form MI-
105A) and are valid for the period of the Seafarer's Service onboard.
• Identifying and maintaining a List of Qualified Medical practitioners or Medical clinics
recognized by the Flag Administration for providing vision services.
Note: the Administration of Marshall Island does not approve or recognize any medical
practitioners, and for this reason, Medical Clinics approved and recognized by the
relevant Government Authorities in the Country in which the Manning Agent operates are
accepted.
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• Reviewing the Medical Examination Certificates for any limitations in respect to Medical
Fitness.
2.5.2 Contents of the Medical Certificate

The medical information required to be recorded on the Medical Certificate is as referred to in the
Convention as per the model Medical Examination form of the Flag Administration, e.g for Marshall
Islands form MI-105M) or other equivalent, which covers the minimum requirements of the IMO
Circular STCW.7/Circ.19/Rev.1- Appendix G.
The pre-employment Medical Tests required by the Company must include:

• Blood Analysis
• Urine Analysis
• V.D.R.L.
• Chest X-Ray
• Weight/Height
• Blood Pressure
• Pulse
• Respiration / lungs
• Liver Test
• Test by Oto-rhino-laryngologist
• Test by Dermatologist
• Test by Dentist
• Test by Neuro-pathologist
• Test by Medical Psychologist
• General Appearance
• Test by Ophthalmologist
Besides the regular checks (Heart, Blood pressure), the pre-employment Medical Examination
must also include:
 Drug & Alcohol Testing **
 HIV Testing.
 For Catering staff , Stool examinations for Food handlers (for Hepatitis)
 If the Company manages Chemical Carriers, (which actually carry chemical cargoes), blood
accumulations must also be checked.
(In case the Chemical Tankers do not carry chemical cargoes, then Benzene tests are carried out
annually on 10% of Crew. If there is a positive result, all Crew is tested).
** Pre-joining Drug and Alcohol Tests

The pre-joining Drug and Alcohol Tests must include the following eleven (11) Drugs and Ethyl
Alcohol, as required by Exxon:
A. Amphetamines B. Barbiturics
C. Cocaine D. Benzodiazepines
E. Cannabis F. Methaqualone
G. Opiates H. Methadone
I. PCP ( Phencyclicidine ) J. Propoxyphene
K. Ethyl Alcohol L. Ecstasy Pills ( MDMA)
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A Medical Certificate solely concerning eyesight must be issued by a recognized Authority as

qualified to issue such a Certificate.
The practitioners must enjoy full professional independence in exercising their medical judgment
in undertaking medical examination procedures.
Each Medical Certificate must state in particular that:
• The hearing and sight of the seafarer concerned and the colour vision, in the case of a seafarer
to be employed in capacities where fitness for the work to be performed is liable to be affected
by defective colour vision, are all satisfactory.
• The seafarer concerned is not suffering from any medical condition likely to be aggravated by
service at sea or to render the seafarer unfit for such service or to endanger the health of other
persons onboard.
2.5.3 Validity of the Medical Certificates

 The pre-joining Medical Certificates are valid for two (2) years.
(Except for the Drug and Alcohol Certificate. Drug and Alcohol Tests must be carried out
before each employment).
 The Certificate for Colour vision is valid for a maximum period of six (6) years.
 The Medical Certificates must be valid for the entire period of the Seafarer's employment.
In urgent cases , the Competent Authority may permit a seafarer to work without a valid medical
certificate until the next port of call, where the seafarer can obtain a Medical Certificate from a
Qualified Medical Practitioner, provided that:
• The period of such permission does not exceed three (3) months.
• The seafarer concerned is in possession of an expired Medical Certificate** of recent date,
** “Expired Certificate if recent date” is defined as a Medical Certificate which has expired for a
period of not greater than six (6) months (MI Guideline 7-47-1).
If the period of validity of a certificate expires in the course of a voyage, the Medical Certificate will
continue to be in force until the next port of call, where the Seafarer can obtain a Medical Certificate
from a qualified Medical Practitioner, provided that the period shall not exceed three (3) months.
If no qualified Medical Practitioner is available in the specific port, then the Master must request
from the Port Agent an Official letter, signed and stamped by the Agent confirming this.
2.5.4 Failure to pass Pre-Employment Medical Examinations

A seafarer who fails the Medical Examination cannot be accepted for employment on any
Company Vessel.
As a standard practice, the Company does not interfere in the procedure which must be
followed in case a seafarer fails to pass a pre-employment Medical Examination. In such a case, the
seafarer must follow the process as described in the MLC 2006 (Appeal, re-examination by medical
referee etc).
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2.5.5 Signing off due to Serious Illness or Injury

For any seafarer who signs-off due to serious illness or injury, the Company requires a new Pre-
employment Medical Examination, before his re-embarkation, even if the Medical Certificate, issued
before the illness or injury is still valid.
2.5.6 Confidentiality of Medical Reports

The Medical Certificates and reports are considered as highly confidential. All persons who
come in contact with Medical examination forms, laboratory results and other medical information
must ensure the right of privacy of the examinee.
Medical records must only be used for determining the fitness of the seafarer for work and enhancing
health care.
The seafarer shall have the right of access to and receipt of a copy of his/her personal Medical Data.
Medical examination reports and records (whether electronic or hard copy), including a copy of the
medical certificate and all medical data collected from the examinee must be clearly marked as
"confidential" used only to facilitate the treatment of the seafarer and must be made available only
to persons authorized with the informed consent of the examinee.
Any questions that may arise concerning the validity of Medical certificates or the fitness of seafarers
must be communicated to the Crew Department.
2.5.7 Declaration of Personal Medication

This information is necessary for the following cases:
• To ensure Medical Treatment compliance/compatibility, in case of Medical Emergency.
• To take the medication and its timing into consideration, for drawing the Watchkeeping
schedules (the medication may have a sedative substance).
• To take this medication into consideration, during Drug Tests (the medication may have a
sedative substance).
On joining, the Seafarer must hand a copy of this Official Declaration to the Master and this will
be recorded in Form - Crew Qualifications Checklist. This Declaration will be maintained by the
Master, in the Crew Personal Files.
2.6 HOURS OF WORK AND REST

2.6.1 General
This paragraph describes the procedure for ensuring that all persons onboard are provided with
sufficient rest in order to maintain fitness for duty and prevent the onset of fatigue.
These provisions do not replace or reduce any conditions a Crew member may have in his contract of
employment or other agreement, but ensure that excessive or unreasonable overall working hours are
not undertaken.
This procedure applies to all Crew members on board.
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The Seaman's working hours per day must be performed as directed by the Master or the
Department Senior Officer and as required by the:
• STCW ("Manila Amendments to the STCW Convention and Code"),
• MLC 2006 Regulation 2.3
• Flag Administration
All seafarers must be provided with rest period of not less than:
• A minimum of 10 hours in any 24-hour period,
• 77 hours in any 7-day period.
The hours of rest may be divided into no more than two (2) periods, one of which must be at least six
(6) hours in length, and the intervals between consecutive periods of rest must not exceed fourteen
(14) hours.
The requirements for rest periods need not be maintained in the case of an emergency or other
overriding operational condition (i.e. essential shipboard work, which cannot be delayed for safety or
environmental reasons, which could not have been reasonably anticipated at the commencement of
the voyage).
In case of any deviations of the rest periods, then any overriding operational condition or any other
unavoidable reasons, should be clearly commented against these deviations (i.e in the ISF
Watchkeeper Crew Records).
Musters, fire-fighting and lifeboat drills and drills prescribed by national laws and regulations and
by International Instruments shall be conducted in a manner that minimizes the disturbance of rest
periods and does not induce fatigue.
Seafarers who are on call during a normal rest period, for example, when responding to an engine-
room alarm during a period when the Engine Room is unmanned, must have an adequate
compensatory rest period.
 Wherever practical, it is recommended that compensatory rest is provided as required to duty
personnel when they have responded to calls that have interrupted their rest period.
 The compensatory rest period must be added to the rest period to achieve the minimum rest
hours required before the seafarer returns to work.
 Duty personnel must record the time spent undertaking rounds or responding to alarms,
recognising that a non-conformance as a result of such response may be unavoidable.
If the minimum rest periods cannot be achieved, the Master must consider bringing the ship to a
secure anchorage or berth to ensure that the proper rest periods are achieved.
In such circumstances the Operations department must be advised immediately.
The Master and Chief Engineer must always maintain a record of the hours worked.
For Vessels operating in USA Waters to which OPA 90 requirements apply a seafarer may
not be permitted to work:
• More than 15 hours in any 24-hour period or
• More than 36 hours in any 72 hour period, except in an emergency or drill.
Therefore, adherence to the 77 hours rest in any 7 day period may not ensure compliance with this
unique 72 hour period limit. Accordingly, it is advised to take measures to ensure that the strictest
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requirements for all periods (24-hour, 72-hour and 7 day periods) are met while operating
under OPA 90 Regulations.
The Master must ensure that all Officers and Crew receive adequate rest periods between duty shifts
to avoid possible errors of judgment resulting from fatigue.
In determining the composition of the watches the Master and C/E must take into account all relevant
factors such as statutory requirements, Vessel characteristics, Crew competence, expected
navigational conditions etc. During dry docking period, Crew work / rest hours must also comply
with the applicable requirements and must be documented in accordance with Company's established
procedures.
2.6.2 Work during Emergencies or Overriding Operational Conditions

Nothing in this section shall be deemed to impair the right of the Master of a ship to require a
seafarer to perform any hours of work necessary for:
 The immediate safety of the ship, persons on board or cargo, or
 For the purpose of providing assistance to other ships or persons in distress at sea.
In this respect, the Master may suspend the schedule of hours of work or hours of rest and
require a seafarer to perform any hours of work necessary until the normal situation has been
restored.
As soon as practicable after the normal situation has been restored, the Master shall ensure that any
seafarers who have performed work in a scheduled rest period are provided with an adequate period
of rest.
Additionally, it is Company Policy to not accept any planned deviations from the Work/Rest Hours
Regulations.
However, at sea and in port, there might be circumstances leading to such deviations.
The Master must inform the Company accordingly and provide full explanation and relevant
Records.
An entry to made in both the Bridge Log Book and the ISF Watchkeeper software stating the reasons
for deviation next to the affected individuals daily rest hours data.
If deviation of Work/Rest Hours occur repeatedly and for the same reason, the DPA, the
Marine/Vetting Manager and the Operations Manager must be advised, in order to take action to
avoid re-occurrence.
It is Company policy to provide additional manning, particularly where voyages are short or where
workloads are high.
This policy shall be verified by means of checking the manning arrangements of some Vessels which
has short voyages with high workloads.
2.6.3 Watch Schedules

In order to monitor the Work/Rest Hours the Company Vessels use the latest version of ISF Watch-
keeper Software.
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Watch Schedules must include all watch-keeping personnel, including Officers, Ratings and UMS
Duty Engineers.
Watch schedules (Form –“Table of Shipboard Working Arrangements” or Watchkeeper printouts of
the latest available version) must be:
• Drawn-up on a 24 hours basis;
• Signed by the Chief Officer and Chief Engineer (according to the Shipboard Department) and
approved by the Master;
• Posted in conspicuous places (Bridge, Engine Control Room, and Ship’s Office).
The Work /Rest Hours Tables must be in a standardized Format (Form -Table of Shipboard Working
Arrangements or Watchkeeper printouts of the latest available version) and available in the Official
Language of the Vessel (English).
The schedule must contain the following information (as per the latest version of Watchkeeper
Format)
• Vessel Name & IMO Number,
• Name/rank of person,
• Scheduled watch period(s) at sea and in port,
• Hours of Work in a 24 hours period,
• Hours of rest in a 24 hour period,
• Hours of rest in any 7 day period.
UMS (Unmanned Machinery Spaces) schedules must indicate the day or date of duty. If the schedule
changes, depending on when at sea or in port, two schedules must be posted.
This software allows individual work hour records to be maintained to demonstrate compliance with
International Rules. Individual record forms must be printed off, pre-completed with calculated totals
following the official IMO/ILO Format.
The latest version of ISF Watchkeeper Software is provided with a Non Conformity Time Sheet, a
new multi-Crew planning tool, a Vessel scheduler and an intelligent Non-Conformity hours'
identification function.
Through this software both the Vessel and the office can clearly see non -conforming hours on a
separate "Seafarers' Record of Hours" sheet, marking each non-conforming half hour with the
letter “N”. It also allows multiple seafarer schedule planning, either by department, individual
selection or rank. It is ideal for planning for future Vessel activities to ensure compliance.
The use of this module is a MUST and must be utilized whenever intensified operations are
anticipated so that the work/rest hours are properly planned.
In case it is identified, (by utilizing the planning module), that rest hours requirements cannot be
met for the forthcoming operations, then watch schedules must be re-arranged.
 If minimum rest hours' requirements cannot be met despite the re-arrangement of watches,
then the Office/DPA and Marine / Vetting Manager must be consulted so that additional
measures are taken in order to ensure that the Crew receives adequate rest and safety is not
jeopardized.
 In such a case the Office must be officially advised of the anticipated non-compliance
through an email which will be also escorted by "planning" print-outs.
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In addition to the above, utilizing the Non conformity Time Sheet Module provided, the Master must
advise the Office at the end of each month if any of the Crew members worked while in non-
conformance. This will also serve as an additional measure for the monitoring of Crew rest hours.
The Chief Officer and Chief Engineer are responsible to record the Work/ Rest hours of Deck and
Engine personnel respectively, on a daily basis. The seafarers must receive a copy of the records
pertaining to them, which shall be endorsed by the Master, or a person authorised by the Master, and
by the seafarers themselves.
It must be borne in mind, however, that due to the nature of service at sea, some deviation from the
schedule is to be expected, and such deviations do not necessarily indicate non-compliance with the
minimum rest periods required.
Such "non-compliances" will be further evaluated by the Office and actions will be taken as found
necessary.
Familiarization of lower rank Crew in Watch/ Rest Hours Requirements, planning and records is
carried out during the initial Safety Familiarization when joining.
2.6.4 Monitoring of Work/Rest Hours

The Company's personnel must check the work / rest hours' records during their visits onboard in
order to ensure compliance with established procedures.
Records evidenced must be cross checked with other documents and logs (i.e. Oil record book, port
logs, etc).
Distant assessments must also be carried out to confirm compliance. (This is carried out in Office
since the Work/Rest Hour table is included in the Monthly reporting to the office).
2.6.5 Records of Work/Rest Hours

As per Company Filing Plan procedures, the records must be maintained onboard for the full
duration of the sea service of each Crewmember.
Each seafarer must receive a copy of the Watch/Rest Records pertaining to him / her via the ISF
watch keeper software.
Copies of the Watch/Rest hours must be sent to the Office, on a monthly basis, by e-mail attachment
at the beginning of each month.
Any deviation from Working hours must be reported to the Crew Department on a monthly basis.
The absence of a table of Shipboard Working arrangements or Records of Hours of work and rest of
Crew will give clear grounds for an Expanded Port State Control Inspection.
2.6.6 Work After Dry-dock

After the completion of the Dry Dock works, and before the Vessel returns to her normal operations,
the Master must ensure that all the Officers and Crew have received adequate rest (in accordance
with the International and Company's established procedures) and they are in all means ready and
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fully capable of assuming their duties. During the Dry Docking period, Crew Work / Rest hours
must comply with the applicable requirements and must be documented in accordance with
Company's procedures.
2.7 ENTITLEMENT TO LEAVE

This section describes the procedures ensuring that seafarers have adequate leave.
Subject to any CBA or laws or regulations providing for an appropriate method of calculation that
takes account of the special needs of seafarers in this respect, the annual leave with pay entitlement
shall be calculated on the basis of a minimum of 2.5 calendar days per month of employment. The
manner in which the length of service is calculated shall be determined by the competent authority.
Justified absences from work shall not be considered as annual leave.
Any agreement to forgo the minimum annual leave with pay prescribed above, except in cases
provided for by the competent authority, is prohibited.
2.7.1 Calculation of Entitlement

Under conditions as determined by the competent authority or through the appropriate machinery in
each country, service off-articles are counted as part of the period of service.
Under conditions as determined by the competent authority or in an applicable CBA, absence from
work to attend an approved maritime vocational training course or for such reasons as illness or
injury or for maternity are counted as part of the period of service.
The level of pay during annual leave is at the seafarer's normal level of remuneration provided for
by national laws or regulations or in the applicable SEA.
For seafarers employed for periods shorter than one year or in the event of termination of the
employment relationship, entitlement to leave is calculated on a pro-rata basis.
The following are not counted as part of annual leave with pay:
• Public and customary holidays recognized as such in the Flag State, whether or not they fall
during the annual leave with pay.
• Periods of incapacity for work resulting from illness or injury or from maternity, under
conditions as determined by the competent authority.
• Temporary shore leave granted to a seafarer while under an employment agreement.
• Compensatory leave of any kind, under conditions as determined by the competent
authority.
2.7.2 Taking on Annual Leave

• The time at which annual leave is to be taken is, unless it is fixed by regulation, CBA,
arbitration award or other means consistent with national practice, determined by the Company
after consultation and, as far as possible, in agreement with the seafarers concerned or their
representatives.
• Seafarers must in principle have the right to take annual leave in the place with which they
have a substantial connection, which would normally be the same as the place to which they are
entitled to be repatriated. Seafarers are not required without their consent to take annual leave
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due to them in another place except under the provisions of a SEA or of national laws or
regulations.
• If seafarers are required to take their annual leave from a place other than that permitted above,
they are entitled to free transportation to the place where they were engaged or recruited,
whichever is nearer their home; subsistence and other costs directly involved are for the
account of the Company; the travel time involved is not deducted from the annual leave with pay
due to the seafarer.
• A seafarer taking annual leave is recalled only in cases of extreme emergency and with the
seafarer's consent.
2.8 REPATRIATION
This section describes the procedures followed by the Company to ensure that the Seafarers are
safely repatriated to their homeland or elsewhere as stated in their Seafarer’s Employment
Agreement.
Seafarers have a right to be repatriated at no cost to themselves in the circumstances and under the
conditions specified in MLC 2006.
The Company provides financial security to ensure that seafarers are duly repatriated in accordance
with the MLC 2006. The P&I Certificate of Entry must always be available onboard to satisfy this
requirement.
The seafarers are entitled to be repatriated in the following circumstances:
• If the seafarer's employment agreement expires while they are onboard.
• When the seafarer's employment agreement is terminated :
o By the Company
o By the seafarer for justified reasons
• When the seafarers are no longer able to carry out their duties under their employment
agreement or cannot be expected to carry them out in the specific circumstances.
The Collective Bargaining Agreement prescribes:
• The circumstances in which seafarers are entitled to repatriation.
• The maximum duration of service periods onboard, following which a seafarer is entitled to
repatriation.
• The precise entitlements to be accorded by the Company for repatriation, including those relating
to the destinations of repatriation, the mode of transport, the items of expense to be covered and
other arrangements to be made by the Company.
The Company does not require that seafarers make an advance payment for the cost of
repatriation at the beginning of their employment and also, does not recover the cost of repatriation
from the seafarers wages or other entitlements except where the seafarer has been found to be in
serious default of his employment obligations, always in accordance with national laws or regulations
or applicable Collective Bargaining Agreements.
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2.8.1 Entitlement to Repatriation

The Seafarer's Employment Contract specifies the conditions under which the seafarer is entitled to
repatriation as follows (see Article 3 of the Contract Agreement).
The seafarer is entitled to repatriation:
• In the event of illness or injury or other medical condition which requires their
repatriation when found medically fit to travel.
• In the event of a ship wreck.
• In the event of the Company not being able to continue to fulfil its legal or contractual
obligations as an employer of the seafarers by reason of insolvency, sale of ship, change of
ship's registration.
• In the event of a ship being bound for a war zone, as defined by national laws or
regulations or seafarer's employment agreements, to which the seafarer does not consent to.
• In the event of termination or interruption of employment in accordance with the
collective bargaining agreement.
• When the Employment Contract Agreement is terminated or is expiring.
The maximum period of service period onboard must be in accordance with the Collective
Bargaining Agreement.
The entitlement to repatriation entails appropriate and expeditious means i.e. by air or any other
expeditious mean to the point of hire. The normal mode of transportation must be by air. The
seafarer must follow the scheduled travel arrangement made by the Head Office and has no other
rights than those arising under the present agreement.
The costs to be borne by the Company for repatriation must at least include:
• Passage to the destination selected for repatriation
• Accommodation and food from the moment the seafarers leave the ship until they reach the
repatriation destination.
• Pay and allowances from the moment the seafarers leave the ship until they reach the
repatriation destination (if provided for by national laws or regulations or Collective Bargaining
Agreements).
• Transportation of 30 kg of the seafarer's personal luggage to the repatriation destination.
• Medical treatment when necessary, until the seafarers are medically fit to travel to the repatriation
destination.
Time spent awaiting repatriation and repatriation travel time must not be deducted from paid
leave accrued to the seafarer. The Company is required to continue to cover the costs of repatriation
until the seafarers are landed at the destination prescribed in the Contract of Employment.
The destinations include the countries with which the seafarers may have a substantial connection
including:
• The place at which the seafarer agreed to enter into the engagement.
• The place stipulated by the collective agreement.
• The seafarer's country of residence.
• Any other place as may be mutually agreed at the time of engagement.
The seafarers must have the right to choose from among the prescribed destinations the place to
which they are to be repatriated.
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Regulation 2.5- Guideline B2.5.1- Entitlement

(In force since 26/12/2020)
The entitlement to repatriation may lapse if the seafarers concerned do not claim it within a
reasonable period of time to be defined by national laws or regulations or collective agreements,
except where they are held captive on or off the ship as a result of acts of piracy or armed robbery
against ships. The terms piracy and armed robbery against ships shall have the same meaning as in
Standard A2.1, paragraph 7 of the MLC 2006 Convention (and § 2.4.1 C of this procedure).
2.8.2 Seafarers put Ashore at Foreign Ports

If a seafarer who is put ashore at a port other than the one where he signed the Shipping Articles for
reasons for which he is not responsible, the company has the responsibility to return him,
without any expense to him:
• To the port at which the seafarer concerned was engaged, or
• To a port in the seafarer's State of Nationality or State of Residence
• To another port agreed upon between the seafarer and the Master or Company, with the approval
of the Competent Authority or under other appropriate safeguards.
If a seafarer is put ashore in a foreign port in consequence of sickness or injury incurred in the
service of the ship and not due to his/her own willful misconduct, the Company is responsible to
ensure his/her medical care and maintenance.
The entitlement to repatriation may lapse if the seafarers concerned do not claim it within a reasonable period
of time to be defined by national law, or regulations or collective agreements.
Regulation 2.5- Guideline B2.5.1- Entitlement
(In force since 26/12/2020)
The entitlement to repatriation may lapse if the seafarers concerned do not claim it within a
reasonable period of time to be defined by national laws or regulations or collective agreements,
except where they are held captive on or off the ship as a result of acts of piracy or armed robbery
against ships.
The terms piracy and armed robbery against ships shall have the same meaning as in Standard A2.1,
paragraph 7 of the MLC 2006 Convention (and § 2.4.1 C of this procedure).
2.8.3 Loss of Right of Repatriation

A seafarer shall forfeit his right of repatriation in case of:
• Desertion,
• Entering into a new agreement with the same owner after his discharge,
• Entering into a new agreement with another owner within one week after his discharge,
• Criminal offences under Sections 847, ( barratry, drunkenness , neglect of duty (849 (incitement
of seafarer to revolt or mutiny) and 850 ( revolt or mutiny of the seafarer)),
• Unjustifiable repudiation of the Shipping Articles,
• Failure of the seafarer to request repatriation within one week from the time that he is in
condition to be repatriated.
The ship must carry and make available to all seafarers aboard the ship a copy of the applicable
provisions of the Maritime Act regarding repatriation.
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2.9 SEAFARER COMPENSATION FOR THE SHIP’S LOSS OR FOUNDERING & LAY-UP
This procedure describes the seafarer's entitlement to compensation for the ship's loss, foundering or
lay-up.
2.9.1 Loss or Foundering of Vessel

Seafarers are entitled to adequate compensation in the case of injury, loss or unemployment arising
from the ship's loss or foundering.
The indemnity against unemployment resulting from a ship's foundering or loss must be paid for
the days during which the seafarer remains in face unemployed at the same rate as the wages payable
under the employment agreement, but the total indemnity payable to any one seafarer may be limited
to two (2) months wages.
Seafarers have the same legal remedies for recovering such indemnities as they have for recovering
arrears of wages earned during the service.
2.9.2 Lay-up
In case the Vessel is laid up the Crew managers are entitled to reduce the number of the Crew and
keep a skeleton Crew. The payment for the Crew must be adjusted proportionally and repatriation
expenses of Crew leaving the Vessel will be for the Crew Managers Account.
The same will apply in case the ship is sold for demolition.
Every Crew member will be entitled to receive one (1) month basic wage as indemnity against
unemployment, after three (3) months staying onboard, or proportionally.
2.10 SHIPOWNER’S LIABILITY

This section describes the procedures and actions taken by the Company to ensure that the seafarers
are protected from the financial consequences of sickness, injury or death occurring in connection
with their employment.
In the event of disabling sickness or injury while a seaman is on board a Vessel under signed
shipping articles, or off the Vessel pursuant to an actual mission assigned to him by, or by the
authority of the Master, the seaman is entitled to:
• Full wages, as long as he is sick or injured and remains on board the Vessel,
• Medical and surgical treatment and supply of proper and sufficient medicines and
therapeutical appliances, until medically declared to have reached a maximum cure or to be
incurable, but in no event more than thirty (30) weeks from the day of the injury or
commencement of the sickness,
• An amount equal to board and lodging up to a maximum period of thirty (30) weeks, and one-
third (1/3) of his base wages during any portion of such period subsequent to his landing
from the Vessel but not to exceed a maximum period of sixteen (16) weeks commencing
from the day of injury or commencement of the sickness, and
• Repatriation including, in addition, all charges for his transportation, accommodation and food
during the journey and his maintenance up to the time fixed for his departure.
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The seaman is not entitled to any of the above benefits:

• if such sickness or injury resulted from his willful act, default or misconduct,
• if such sickness or injury developed from a condition which was intentionally concealed from
the employer at or prior to his engagement under the articles,
• if he refuses medical treatment for such sickness or injury or is denied such treatment
because of misconduct or default, or
• if at the time of his engagement he refused to be medically examined.
The seaman shall have a maritime lien against the Vessel for any wages due to him under this
regulation.
2.11 SOCIAL SECURITY

This section describes the procedures and actions taken by the Company to ensure that measures to
provide seafarers with access to social security protection.
The Company meets all its responsibilities concerning social security protection, including
making the required contributions to social security schemes.
The Company ensures that all seafarers serving onboard Company's Vessels are provided with
social security protection that at least includes the branches of:
• Medical care,
• Sickness benefit and
• Employment injury benefit.
The SEA must identify the means by which the various branches of social security protection will be
provided to the seafarer by the Company as well as any other relevant information at the disposal of
the Company, such as statutory deductions from the seafarers' wages and Company' contributions
which may be made in accordance with the requirements of identified authorized bodies pursuant to
relevant national social security schemes.
2.12 FINANCIAL SECURITY CERTIFICATES

As per MLC 2006 Regulations, the Company has issued Third Party Liability Certificates for every
Fleet Vessel. The following Certificates, issued by the P&I Club, are available onboard each Vessel:
MLC Financial Security Certificate for the compensation
in the event of abandonment (repatriation)
Regulation
2.5 “Abandonment” means when the Shipowner :
-Fails to cover to costs of the seafarer’s repatriation
- Has left the seafarer without the necessary maintenance and support
-has otherwise unilaterally severed their ties with the seafarer including failure to
pay contractual obligations for a period of at least two (2) months.
MLC Financial Security Certificate for the compensation in the event of contractual
claim, involving death or long term disability
Regulation 4.2
“Contractual claim” means any claim which relates to death or long term
disability of a seafarer due to an occupational injury, illness or hazard as set out in
national law, the SEA or Collective Bargaining Agreement (CBA).
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The Company must furnish the Certificates to the MI Flag Administration at the e-mail address:
vesdoc@register-iri.com
A copy of each if the above Certificates must be posted in a conspicuous place onboard the Vessel.
The Company is required to notify the seafarers if Financial Security is to be cancelled or terminated.
The Financial Coverage must be maintained in full force and effect for a Vessel to maintain its
registration under the Flag Administration.
The Provider of the Financial Security (i.e the P&I Club) must notify the Flag Administration as
follows:
 30 days prior written notice – for cancellation or alteration of the Financial Coverage.
 10 days prior written notice –for non-payment of premium.
The issuance of the above Financial Security Certificates, and their distribution to the Fleet Vessels is
the responsibility of the Legal Department.
The Legal Department is also responsible to notify the P&I Club, quite ahead of time for any
cancellation or alteration of the Financial Coverage, in order to enable the Financial Security
Provider to notify the Flag Administration within their set time limits.
The Master is responsible to maintain the Certificates in file and have them readily available for
Inspection, and ensure that they are posted.
2.13 ACCOMMODATION
This procedure describes the actions taken by the Company to ensure that the seafarers have decent
accommodation facilities.
The Company is responsible to ensure that the Fleet Ships provide and maintain decent
accommodation facilities to the seafarers working and/or living or both, consistent with promoting
the seafarer's health and well-being.
The MLC 2006 requirements which relate to the construction and equipment, apply only to ships
constructed on or after the date when this convention comes into force for the Flag Administration
concerned.
Requirement for new ship1: Accommodation and recreational facilities - Construction and
equipment (see Reg .3.1 MLC 2006).
2
Existing ships shall comply with the requirements relating to construction and equipment, as set out
in ILO Convention No. 92 (ILO 92) and/or ILO Convention No.133 (ILO 133).
1
New Ship: A ship constructed on or after the date that MLC, 2006 enters into force. A ship shall be deemed to have
been constructed on the date when its keel is laid or when it is at a similar stage of construction.
2
Existing Ship: A ship constructed before the date that MLC, 2006 enters into force.
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The Administration may consider, where appropriate, exemptions for existing ships that do not fully
comply with the requirements relating to construction and equipment as set out in ILO 92 and ILO
133.Due to the fact that the Marshall Islands could not become a member of the International Labour
Organization (ILO) until 2007, it was not possible to become party to Conventions No. 92 and No.
133. The Administration however has always strongly recommended that Companies voluntarily
seek certification through their Classification Societies which have been authorized to
accommodate such requests.
Flag Inspections will be carried out based on MLC 2006 Regulations:
• 3.1- Accommodation and Recreational Facilities.
• 3.2-Food and Catering.
• 4.3 Health, Safety and Accident Prevention.
Flag Inspections relating to design, construction and equipment shall be carried out in accordance
with the requirements of the Convention, when:
a) A new ship under construction is registered;
b) At registration or re-registration for a new ship; or
c) The seafarer accommodation on a ship has been substantially altered.
The Company places particular attention to ensuring implementation of the requirements of the
MLC 2006 Convention relating to:
a) Accommodation spaces,
b) Heating and ventilation,
c) Noise and vibration,
d) Sanitary facilities,
e) Lighting,
f) Hospital accommodation,
g) Food, water and catering.
2.13.1 Company Procedure for Inspection and Maintenance of Accommodation Spaces and
Equipment
In order to ensure good maintenance of Accommodation spaces and equipment, the Company has
established a procedure according to which the Master conducts weekly Health & Hygiene
Inspections of all Accommodation Spaces and Equipment. The Areas to be inspected include:
• All Accommodation Areas,
• Gym Room,
• Hospital Room,
• Stairways and Passage ways,
• Toilets, showers and Bathrooms,
• Galley, Pantry and Food preparation Areas,
• Laundry Spaces,
• Refrigerator Rooms and Freezers,
• Dry Store Rooms,
• Vegetable Rooms,
• Fresh Water Tanks and Arrangements,
• Store Rooms (Paints, Chemicals, Oxygen, Acetylene, Battery Rooms),
• Working Areas (Deck Areas, Engine Room Areas),
• Air condition system,
• Air Coolers,
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• Fresh Water Tanks,

• Medical Chest and Surgical Equipment.
A special Checklist has been developed for this purpose - Form "Master's Monthly Health
and Hygiene Inspection". During his weekly inspections, the Master must cover some of the
items of the checklist, in such a way, so that at the end of the month he has covered the inspection of
all the items of the Checklist.
Ventilation, heating and air conditioning systems are regularly maintained and cleaned.
High noise areas are distinctively marked and seafarers are made aware of these areas during the
familiarization process.
Provisions for natural and adequate artificial lighting in the accommodations, including the sleeping
rooms are made.
As applicable, ships calling into mosquito-infested ports are provided with equipment to
minimize the encroachment of mosquitoes.
2.14 FOOD AND CATERING

This procedure describes the actions taken by the Company to ensure that the all seafarers have
access to good quality food and drinking water provided under regulated Hygienic conditions.
Seafarers on board a ship are provided with food and water free of charge during the period of their
employment. On the majority of Vessels, only bottled water is used onboard as drinking water.
On some Vessels, a Water Filtering System has been installed, and the drinking water is further
enriched with the end product being water of good quality and taste.
The Master is responsible for ensuring that the Vessel has sufficient stores and provisions on
board to make the contemplated voyage safely, taking into account the number of seafarers onboard,
their religious requirements and cultural practices as they pertain to food.
The Purchasing Department is responsible to provide / supply well in advance all Vessels with the
necessary material, supplies, equipment, and services at the specified quality and within the time
limits imposed from their itinerary and cargo operation commitments.
Different cultural and religious peculiarities are always taken into consideration during the
supplying of food on board.
The "Complaints Procedure" enables Shipboard Personnel to bring any unresolved issues arising
from cultural or religious requirements to the attention of the Company.
Clean mess utensils are supplied to all seafarers for use on board during service on the ship. Plates,
cups and other mess utensils are of approved good quality material which can be easily cleaned.
SEA Article 16 states:

The Company shall provide the following for the use of each seafarer while he is serving
onboard:
• Victualling of no less than eight (8) USD daily.
In addition, the Company shall provide the galley with all items of equipment normally required for
cooking purposes. All items of equipment mentioned above must be of good quality.
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2.14.1 Food Supplies

Food Supplies are checked on a Monthly basis and the "Victualling Report" is sent to the Purchasing
Department, with the ROB Quantities. The Purchasing Department reviews the Victualling Report
and the ROB Quantities and replenishes as required.
2.14.2 Ship’s Menu

The Ship's Cook draws the Weekly or Monthly Menu, which is approved by the Master.
The Menu must be drawn in such a way as to provide variety of nutritional dishes, prepared and
served in a hygienic conditions always taking into account cultural and religious requirements.
Periodically (Quarterly) the Ship's Menus are sent to the Crew Department, who review them and
ensure that the menus include healthy nutritious food of adequate variety.
2.14.3 Ship’s Cook

Seafarers are considered qualified as ships' cooks only if they satisfy the following:
• Age and Sea-time:
Applicants must be not less than 18 years of age with a minimum of 12 months seagoing service
which may be varied to take into account existing relevant qualifications or experience.
• Medical:
Applicants must meet the physical examination requirements for a certificated Deck/Navigational
Officer.
• Training:
Applicants must have successfully completed a legitimate training course or program covering
practical cookery and food preparation, food and personal hygiene, galley sanitation, nutrition,
food storage, stock control, environmental protection and catering health and safety.
2.14.4 Catering Staff

Catering staff must attend the Vessel Sanitary Program.
2.14.5 Master’s Health and Hygiene Inspection

It is a strict Company requirement that the Master, accompanied by at least one Senior Officer,
inspects the ship's galley (including any other food preparation or serving areas), provision
stores and refrigerated rooms on a weekly basis.
Water testing kit is provided onboard and testing of fresh water must be carried out as per PMS.
The Company has established a Standard Vessels’ Cleanliness and Sanitation Schedule
(Refer to Safety Manual (SAF (003) –Section 25- “Master’s Health and Hygiene Inspection of
Accommodation, Galley and Store Rooms” and Poster 64-“Vessel’s Cleanliness and Sanitation
Schedule”).
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2.15 CREW WELFARE AND RECREATIONAL FACILITIES

This procedure describes the actions taken by the Company to improve Crew Welfare by
maintaining decent recreational facilities onboard.
The Company takes all efforts to provide and maintain decent accommodations and recreational
facilities for seafarers, working and living on board, or both, consistent with promoting the seafarer's
health and well-being.
Particular attention is placed on:
• Rooms and other accommodation spaces ( as applicable to each Vessel ),
• Heating, ventilation and insulation,
• Noise, vibration and other ambient factors,
• Sanitary Facilities,
• Lighting,
• Hospital Accommodation.
2.15.1 Personal Protective Equipment

The Company provides all its Shipboard Staff with Safety Clothes, Safety Helmets, Safety Shoes and
all other Personal Protective Equipment, which are required to protect the Crewmembers, when
working onboard in adequate quantities.
2.15.2 Press
The Company o provides the Vessels with electronic newspaper (Newslink services).
2.15.3 Mail
Seafarers' Mail must be forwarded in a reliable and expeditious way, and seafarers must not be
requested to pay additional postage, when mail has to be re-addressed owing to circumstances
beyond their control.
2.15.4 Welfare Items

In order to ensure that the seafarers have decent accommodation, the Company provides recreational
facilities onboard.
Recreational facilities and services must be reviewed frequently to ensure that they are appropriate.
Recreational facilities must be located as far as practicable from excessive noise and vibration. This
must be checked by visiting Company superintendents and by visiting Crew Department Staff.
As per MLC 2006 Recreational facilities onboard must include:
• A Smoke room.
• Television viewing and radio broadcasting.
• Showing of films, the stock of which must be adequate for the duration of the voyage and,
where necessary, changed at reasonable intervals.
• Sports equipment includes exercise equipment, table games and deck games.
• Where possible, swimming facilities.
• Facilities for recreational handicrafts.
• Electronic equipment such as radio, television, DVD/CD players etc.
• Reasonable access to ship-to-shore telephone communications and e-mail, with any
charges for the use of these services being reasonable in amount.
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The Company has decided on a list of welfare items, which must be onboard at all times. All Fleet
Vessels are provided with television sets, CD players, Video and DVD players. Games exist on all
Vessels, such as ping-pong tables etc. The Vessels gymnasiums are organized to enable
Crewmembers to exercise and maintain their physical fitness.
The welfare items, which must be present onboard, are listed in Form - "Recreational & Fitness
Equipment". This is an inventory list, which is due every six (6) months, in order to ensure
that all welfare items exist onboard and are in good operational condition.
2.15.5 Free Internet

Each crew member is granted some hours of free internet access, as specified by the Company.
However, in order to prevent Crew Fatigue caused by the over-use of Internet, Crew Internet is
restricted to a few hours /day.
2.15.6 Gambling
The Company does not forbid gambling onboard, as this is an activity which is relaxing, recreational,
helps overcome boredom, and improves social interaction on board.
However, the following rules must be followed:
 Gambling must not result in fighting or in any incident that can upset the crew relationships
onboard.
 It must be carried out for fun and social interaction only and the bets must be very low, not
resulting in any negative consequences for the seafarer in terms of time and money lost.
 The gambling must be strictly restricted to rest hours and in no way should it be extended to
working hours.
 The seafarers should gamble occasionally, knowing how/when to end the game in a controlled
way.
 The seafarers must accept the fact that there is a possibility to lose money and they must not
continue gambling to recover their losses.
 Seafarers should not spend all their rest hours for gambling and deprive themselves of rest and
sleep, which will then lead to fatigue, and possibly to an accident/injury etc.
 The area for the gambling must be clearly defined (i.e Only in Messrooms or Smoking Rooms as
decided by the Master).
 No Gambling is allowed in Crew Cabins.
 Gambling with persons other than Crew Members should be avoided (e.g Armed Guards).
 Officers should periodically check in order to ensure that no tension and fights occur, and that the
gambling is not extended too many hours, that will cause gambling crew to present signs of
fatigue during their working hours, due to lack of sleep.
2.16 ONBOARD COMPLAINT PROCEDURE

This section describes the Onboard Complaint Procedure, which must be implemented onboard and
must be monitored by the Office.
Every seafarer onboard a Company Vessel has the right to lodge a complaint and to have the
complaint investigated, provided it is of a specific nature and it constitutes a breach of the seafarer's
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rights under the Maritime Labour Convention 2006 or the Law and Regulations of the Flag
Administration.
The Complaint Procedure fully covers complaints on sexual harassment and bullying (as per § 2.17
of this procedure).
Each seafarer must be provided with a copy of his employment agreement and must be made aware
of the Onboard Complaints procedure.
The highest level in the Company, for resolving Crew Complaints is the DPA or his designee
(a nominated member of the Crew Department).
2.16.1 Contact Details Available to the Seafarer

The following Contact Details must be available to all Crewmembers onboard:
• Contact information for the Company DPA and Alternate DPA (DPA Poster).
• Contact information for the Office of the Maritime Administrator.
• Contact information for the Competent Authority of the Seafarer's Country of
residence.
• The Name of the person(s) onboard who can, on a confidential basis, provide seafarers with
impartial (objective) advice on their complaint and assist them in following the complaint
procedures. Such assistance may include attending meetings or hearings, if requested by the
complainant seafarer.
The relevant Form/ Poster SF/CRW/521-"Crew Complaints Contact Points" must be posted in
conspicuous places.
2.16.2 Crew Complaints Procedure

In case a Crew member wishes to lodge a complaint, he must fill-in the Crew Complaint Report -
( SF/CRW/520)-"Section A"- Description of the Complaint.
He must sign the Complaint report- at the appropriate space of "Section A" - "Complainant
Signature".
The Officers and /or Crew Members must, within five (5) days of the alleged occurrence of the
complaint, bring the matter to their immediate Supervisor.
The Immediate Supervisor will in turn sign for acknowledgment and note down the date of the
receipt of the complaint. The Immediate Supervisor will have a further five (5) days to find a
solution to the matter, provided that this time limit is appropriate to the seriousness of the matter.
Every effort must be taken to resolve the complaints at the lowest level possible.
Therefore , if the immediate supervisor is in a position to take an action that will resolve the
complaint, then this must be noted down on the appropriate space of "Section A"- of the Crew
Complaint report. If the matter cannot be resolved at this level, then the Crew Complaint Report
must be handed over to the Head of the Shipboard Department , who will sign for acknowledgment
and note down the date of receipt of the complaint.
The Head of the Department will have a further five (5) days to find a solution to the matter,
provided that this time limit is appropriate to the seriousness of the matter. The Head of the
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Department will try to resolve the Crew Complaint, Any action taken must be noted down in the
appropriate space of "Section B" of the Crew Complaint Report.
If the matter cannot be resolved even at this level, then the complaint must be brought to the attention
of the Master. The Master must sign at the appropriate space in "Section C" - and note down the
date of receipt of the complaint.
When a complaint reaches the level of the Master, the Master must:
• Conduct an investigation or inquiry, as appropriate,
• Reference the Terms and conditions of employment,
• Seek the advice of the Company DPA or his designee, where necessary,
• Any action taken by the Master must be note down in "Section C".
If the Master cannot reconcile the complaint, the matter must be formally referred within
ten (10) days to the Company DPA or his designee, by forwarding via e-mail the Crew Complaint
Report and any documentation, necessary for the investigation of the case.
The DPA or his designee must initiate an investigation and decide on the final action to be taken
to conciliate the matter in accordance with the Terms and Conditions of Employment. The results of
the Investigation, and the Final Action to be taken, must be noted down in the space "Section D" of
the Crew Complaint Report.
A copy of this fully completed Crew Complaint Report must be forwarded back to the Vessel.
It must be stressed that all Crewmembers have the right to complain directly to the Master, and
where considered necessary, to the Company DPA or his designee for Crew Complaints for
reconciliation.
Until the decision of the DPA or his designee is received, the Master's decision must be binding
for all parties
If the matter is to the prejudice of the Master, then the Seafarer must present his /her case directly
to the Company DPA or his designee.
A copy of the Crew Complaints Report filled in with the results of the Investigation and the Final
Action Taken, as decided by the DPA or his designee, must be handed to the complainant.
2.16.3 External Authorities

Seafarers have the right to file a complaint directly to an appropriate External Authority such as, but
not limited to:
• A Flag Administration Nautical Inspector,
• A Flag Administration Recognized Organization Inspector,
• A Port State Control Official,
• A Local Seafarer Labour Organization representative, or
• Other Seafarer Welfare Assistance Service.
If a complaint reaches the level of an External Authority, that Authority must be provided with the
contact information for the Office of the Maritime Administrator and must be requested to
communicate the complaint to the Office of the Maritime Administrator.
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The Office of the Administrator must communicate the complaints to the Company DPA who must
then be expected to resolve the matter in accordance with the Terms and Conditions of
employment to the satisfaction of both parties.
No seafarer shall go ashore in any foreign port except by permission of the Master.
However, the Master shall not refuse the reasonable request of any seafarer for shore leave in order to
present a complaint against the Vessel or Master to a Consul of the Republic of the Marshall Islands,
other officials of the Republic of the Marshall Islands, or any other proper authority, in case of
Marshall Flag Vessel.
2.16.4 Unresolved Disputes & Arbitration

If after twenty (20) days, a conciliation, acceptable to both parties, cannot be reached, either party
must have a further twenty (20) days to call upon the Office of the Maritime Administrator or an
agent appointed by the Office of the Administrator, to act as mediator to try to find a solution to the
matter, satisfactory to both parties.
If the dispute cannot be resolved by conciliation or mediation, either Party may submit the matter
to an independent arbitrator or arbitrators for a final determination in accordance with the
Arbitration Rules and Proceedings provided in the Maritime Regulation 7.53.
2.16.5 Record Keeping

All Crew Complaints must be recorded on the Crew Complaints Report and must be filed in Master's
Crew File-"Crew Complaints Reports". A Crew Complaints Register and Follow-up Log must be
maintained at the beginning of the File.
The Crew Complaint Reports and any correspondence from the Seafarer to the Company DPA or
his designee must be signed by the Master, where seen.
2.16.6 Reporting to the Company

All the Crew Complaints Reports must be forwarded to the Company, to the attention of the
Designee of the DPA (Member of the Crew Department), as soon as they are issued.
At the end of each Month the Crew Complaints Register and Follow-up Log must be forwarded by
e-mail, updated with the status of each Crew Complaint.
2.16.7 Non Victimization of Crew who File Complaints

The Company will not take any adverse action (victimize) any Crew member who lodges a
complaint, as long as it is not maliciously made or manifestly vexatious.
On the contrary, all reasonable Complaints will be reviewed with attention and understanding and the
best possible solution will be sought.
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2.17 MEASURES AGAINST HARASSMENT AND BULLYING ONBOARD

The Company is committed to maintain a working environment in which there is respect for the
dignity and well-being of all seafarers.
No seafarers must be sexually harassed and bullied onboard Company Vessels.
All seafarers have a responsibility for ensuring that their ship is free of sexual harassment and
bullying.
As per MLC 2006 (Amendments 2016), the Company has issued two Policies which detail the types
of behaviour and acts which are considered Sexual Harassment and Bullying i.e:
 Anti-bullying Policy ( IMSM Manual (001) – Appendix Q
 Sexual Harassment Policy ( IMSM Manual (001) – Appendix R
The Company strongly encourages those who witness sexual harassment and bullying to report such
incidents either onboard to the Master or to Shore (as per the Onboard Complaint Procedure of the
paragraph 2.16- and as per Form SF/CRW/521- “Crew Complaints Contact Points”.
Any reports of this type will be treated seriously, investigated promptly and impartially.
The Company will protect any Employee who reports bullying conduct from retaliation or
vengeance.
2.18 SAFETY PROTECTION AND ACCIDENT PREVENTION

This section describes the procedures and actions taken by the Company to ensure that the
seafarer's work environment onboard promotes Occupational Safety and Health.
The Company is responsible to provide the seafarers on its fleet Vessels with occupational health
protection and the conditions to live work and be trained onboard in a safe and hygienic environment.
2.18.1 Safety Protection

The Company has taken the following measures in order to establish and maintain high Safety
Standards onboard:
• Has set procedures for the Safety Familiarization of joining Crew (Safety Familiarization
Checklist).
• Has set procedures for the Job Familiarization, depending on the seafarer's rank and
shipboard department (Job Familiarization Checklists).
• Has issued the SOLAS Training Manual.
• Has issued the Fire Training Manual.
• Has issued the Risk Management Procedure, which includes generic Risk Assessments,
which are reviewed bi-annually, taking into consideration Shipboard generated Risk Assessments
which are included in the Safety Meetings or are sent independently from the Vessels.
• The Company has issued separate Manuals for the various Shipboard Activities, which
include Safety guidelines and procedures.
• The Company has issued various Official Circulars including safety procedures and
guidelines.
• Has issued Safety Cards related to various Shipboard Operations (POSTERS 15-15A-15B).
• Has issues requirements for the use of PPE for specific operations PPE Matrix).
• Has provided the Publication MCA "Code of Safe Working Practices for Merchant Seamen", to
be referred to by Shipboard Personnel when issuing Risk Assessments.
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• Operates a Work Permit system which is based on Job Hazard Analyses and Risk Assessments.
• Has issued the Emergency Manual.
• Has issued Emergency Forms related to various accident/incident scenarios.
• Has set procedures for weekly familiarization in Life-Saving and Fire Fighting Equipment.
• Has procedures for Emergency Drills, each drill having a dedicated form, with the actions
which must be taken according the drill scenario.
• Has set procedures for Extra Training in the cases where additional training needs are
identified.
• Has procedures for four months training in critical issues (ODME- OWS - VDR etc).
• Has set procedures for Daily Work Plans and Toolbox Meetings for the works which are to be
done onboard.
• Has initiated the Behavioural Safety Program, in which all Crew participate in teams and
helps improve the skills in Hazard Identification and appropriate Safety Precautions to be taken.
• Has Procedures for carrying out Safety Meetings during which Accidents, Near Accidents,
potential unsafe situations and deviations from Safety Procedures are discussed.
• Has procedures for the immediate report of Accidents and Near Accidents and their
discussion during the Safety Meetings.
• Has procedures for the issuance of Job Hazard Analysis and Risk Assessments,
which are also discussed during the Safety Meetings, and improved through a brainstorming
process, where all Crew participate.
• Has procedures for the regular review and analysis of the Accidents and Incidents which
occurred in the Fleet, and for the issuance of relevant Circulars which are distributed to all Fleet
Vessels for "lessons learnt".
• Has procedures for the Table Top Exercises, with the participation of Fleet Vessels, Office
departments, the QI, Manning Agent, Classification Society etc.
• Has procedures for the maintenance of a Safety Officer's Log Book for the prompt
identification of Safety Hazards.
• Has procedures for the supply of Publications relevant to Safety onboard.
2.19 SELECTION OF MANNING AGENT AND RESPONSIBILITIES

This section describes the process of selecting qualified and certified Manning Agent(s).
2.19.1 Criteria for Selecting the Manning Agent

The selection of the Manning Agent is the combined responsibility of the Chief Operating Officer
(COO) or Deputy COO, the DPA and the Crew Manager.
In order to reach the final decision for selecting the appropriate Manning Agent, various criteria
must be considered, such as:
• Manning Agent's Organizational Structure. (The Manning Agent(s) must be ISO 9001 Certified
and must be assessed on an Annual Basis by a RO).
• Quality of Manning Services provided.
• Recruitment Standards.
• Response to Emergency needs.
• Manning Fees.
• Compliance with the MLC 2006 Requirements and Certification.
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2.19.2 Manning Agencies’ Compliance with MLC 2006

The MLC 2006 Convention (A.1.4.2 & A.1.4.9) requires the Manning Agency to:
• Maintain an up-to-date Register of all seafarers recruited or placed through them, to be readily
available for inspection by the Competent Authority or by the Company.
• Ensure that the seafarers are informed of their rights and duties under their Employment
Agreement prior to or in the process of engagement and that proper arrangements are made
for seafarers to examine their Employment Agreements before and after they are signed and that
the seafarers receive an originally signed copy of the agreements.
• Verify that seafarers recruited or placed by them are qualified and hold the documents
necessary for the job concerned and that the Seafarers' Employment Agreements are in
accordance with applicable laws and regulations and any Collective Bargaining Agreement that
forms part of the employment agreement.
• Make sure, as far as practicable, that the Company has the means to protect seafarers from
being stranded in a foreign port.
• Operate a Complaint Procedure in accordance with the Flag Administration requirements and
the MLC 2006 requirements.
• Examine and respond to any complaint concerning their activities and advise the
Competent Authority of any unresolved complaint.
• Establish a system of protection, by way of insurance or an equivalent appropriate measure
to compensate seafarers for monetary loss that they may incur as a result of the failure of a
recruitment and placement service or the relevant Company under the Seafarer's Employment
Agreement to meet its obligation for them.
• Ensure that any licenses or certificates or similar authorizations for the operation of the
Manning Agency are renewed after verification by the Competent Authority or other
authorized authority that the Manning Agency meets the requirements of the National laws
and regulations and the MLC 2006 Requirements.
• Ensure that adequate personnel and facilities exist for the recruitment services and the for the
investigation/processing of complaints of seafarer recruitment and placement services, involving
as appropriate, representative of Shipowners and seafarers.
The Manning Agent used must develop and maintain verifiable operational practices.
These practices must address the following matters:
• Medical Examinations, Seafarer's Identity documents and such other items as may be required
for the seafarer to gain employment.
• Maintaining, with due regard to the right to privacy and the need to protect
confidentiality, full and complete records of the seafarers covered by their recruitment and
placement system , which must include but not limited to:
o The seafarer's qualifications.
o Record of employment.
o Personal data relevant to the employment.
o Medical data relevant to the employment.
• Maintaining up-to-date lists of the ships for which the seafarer recruitment and
placement services provide seafarers and ensuring that there is a means by which the services
can be contacted in an emergency at all hours.
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• Procedures to ensure that seafarers are not subject to exploitation by the seafarer
recruitment and placement services or their personnel with regard to the offer of engagement on
particular ships or by particular companies.
• Procedures to prevent the opportunities for exploitation of seafarers arising from the issue of
joining advances or any financial transaction between the ship-owner and the seafarers which are
handled by the seafarer recruitment and placement services.
• Clearly publicizing costs, if any, which the seafarer will be expected to bear in the
recruitment process.
• Ensuring that seafarers are advised of any particular condition applicable to the job for which
they are to be engaged and of any particular Shipowner's policies relating to their employment.
• Procedures which are in accordance with the principles of natural justice for dealing with cases
of incompetence or indiscipline consistent with national laws and practice, and where applicable,
with Collective Bargaining Agreements.
• Procedures to ensure, as far as practicable, that all mandatory certificates and documents
submitted for employment are up-to-date and have not been fraudulently obtained and that
employment references are verified.
• Procedures to ensure that requests for information or advice by families of seafarers while
the seafarers are at sea are dealt with promptly and sympathetically and at no cost.
• Verifying that labour conditions on ships where seafarers are placed, are in conformity with
applicable Collective Bargaining Agreements concluded between a Shipowner and a
representative Seafarer's Organization and, as a matter of policy, supplying seafarers only to
Shipowners that offer terms and conditions of employment to seafarers which comply with the
applicable laws or regulations or Collective Bargaining Agreements.
• Has a clear policy and ensures that no fees or other charges for seafarer recruitment or
placement or for providing employment to seafarers are borne directly or indirectly , in whole or
in part , by the seafarer, other than the cost of the seafarer obtaining:
o A National Statutory Certificate,
o The National Seafarer's Book, and
o A passport or other similar Personal Traveling Document.
The cost of any visas required is borne by the Company.
Manning Agent operating in a country that has ratified MLC 2006

When the Manning Agent operates in a country that has ratified the MLC 2006, documentary
evidence is required onboard that the Manning Agent concerned is operating in accordance with the
National Laws and Regulations or other measures implementing the MLC 2006
requirements.
Therefore, the Manning Agent must be licensed or Certified or regulated in accordance with the
National Laws and Regulations relevant to MLC 2006 requirements.
The Manning Agency's MLC 2006 Certificate of Compliance must be available in the Office of the
Company.
The Company must provide all the Vessels with a copy of the Manning Agent's MLC 2006
Certificate of Compliance. (Master's File)
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Manning Agent operating in a country that has NOT ratified MLC 2006
When the Manning Agent operates in a country that has not ratified the MLC 2006, documentary
evidence is required onboard, showing that the Company has verified through a proper system that
the manning agent is operating consistently with the MLC 2006. This system may be for example an
Audit /certificate by a Recognized Organization.
The Third Party (Recognized RO) Audit Documentation of the Manning Agency and the relevant
Certificate must be available in the Office.
The above evidence and /or certificate must be placed onboard all ships as evidence of compliance of
the Manning Agent with the MLC 2006.
The Company must provide all the Vessels with a copy of the Third Party (RO) Audit
documentation of the Manning Agency and the relevant Certificate issued. (Master's File)
2.19.3 The Agency Agreement

 When the decision for the Manning Agent has been taken, an Agency Agreement must be issued.
 The Agency Agreements must be signed by duly Authorized Representatives of the Owning
Company of the Vessel and of the Manning Agent.
 This Agency Agreement must be renewed on an Annual Basis, one (1) month before the
expiration date.
 An Audit of the Manning Agent must be carried out, if possible, before the renewal of the
Agency Agreement.
 During this Audit, the recruitment policies and objectives, the training needs as well as any
other related elements must be discussed and analyzed.
 In case Non Conformities or weaknesses in certain areas of the Manning procedures are
identified, it is the responsibility of both parties involved to decide on the corrective actions to be
taken within an agreed time frame.
 Agency Agreements are issued for each Fleet Vessel separately, and are valid for twelve (12)
calendar months.
 The Agency Agreement is produced in two original sets:
o One copy is kept by the Manning Agent.
o One copy is kept by the Crew Department.
2.19.4 Content of the Agency Agreement

The Agency Agreement must clearly define the responsibility of the Manning Agent to:
• Propose to the Company candidates who are suitably qualified, trained and medically fit and
appropriately experienced for the rank and type of Vessel that they are to be appointed
to, and who are fully certified in compliance with International, Flag State regulations and
MLC 2006 recommendations requirements.
• Ensure that the proposed seafarers’ certificates are authentic, valid and that they will remain
valid for the entire period of their service onboard Company Vessels.
• Maintain and provide immediately on request, all required data for seafarers supplied
through their Manning Agency.
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• Screen and ensure that all proposed Senior Officers have a good command of the English
Language.
• Arrange formalities for Crew leaving their country of origin (visas, renewal of passports etc.).
• Provide Office Facilities for the familiarization of Crewmembers in the Company IMS.
• Prepare applications for Flag Administrations for the issuance of Flag Certificates.
Additionally, the Manning Agent is responsible for:

• Conducting pre-departure briefing in his Office premises.
• Organizing and monitoring training seminars (In-house or in recognized Maritime
• Institutes).
• Assisting the Company in Crew disciplinary matters.
• Providing assistance during Crew repatriation, especially in case of illness or injury.
• Keeping an updated copy of the Company IMS in its premises.
• Assisting the Company to organize various parties, children summer camps etc. for Crew
welfare.
The Agency Agreement must clearly define the responsibility of the Company to:
• Provide a Healthy and Safe environment to all Crew working on Company Vessels.
• Undertake the responsibility of their Safety and Health.
• Follow all the Rules and Conditions of the Collective Bargaining Agreement and fulfill the
obligations required.
• Notify the Manning Agent quite ahead of the planned date of Crewmember to join a
Vessel.
• Cover all expenses of Crew traveling.
• Remit the Agency Fees as stated in the Agency Agreement.
• Advise the Manning Agent of visas required, flight details etc.
2.19.5 Declarations of MLC (DMLC PARTS I & II)

The Company must provide the Manning Agency with copies of the DMLC -Part I & Part II, as
evidence of Company's compliance to the MLC 2006 Requirements.
2.20 AUDITS OF THE CONTRACTED MANNING AGENT(S)

This procedure describes the process of auditing the Manning Agents.
The Manning Agent(s) must be the holder of the following Certificates:
• ISO 9001 Certificate
• MLC 2006 Certificate of Compliance.
The Manning Agent must be assessed by the Company on an Annual Basis.
It is the Company's Policy to continuously assess the services provided by the Manning Agent. At
regular intervals, but as a minimum once a year, the Manning Agent is visited by the Crew Manager,
and at times by members of other Office Departments.
The relevant form "Company Audit & Review of Manning Agent" must be filled-in.
Any Non-Conformities must be agreed between both parties and must be in writing.
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The due date for corrective action must be clearly defined and agreed by both parties.
Regular follow-up must be made until the final close-out.
The Crew Department must keep full Audit records as well as supporting evidence proving full close-
out of Non-Conformities or Observations raised.
If time and circumstances permit, the Medical and Training Subcontractors used by the Manning
Agent must be visited by the Company Auditor. A Manning Agent's representative must escort the
Company Auditor in these visits.
3. RECORDS
• Company Audit & Review of Manning Agent PRO/PRO 22/ OFF/CRW/510
• Recreational Equipment Inventory PRO/PRO 22/ SF/CRW/516
• Master's Health & Hygiene Inspection PRO/PRO 22/ SF/CRW/518
• Crew Complaint Report PRO/PRO 22/ SF/CRW/520
• Crew Complaints Contact Points PRO/PRO 22/ SF/CRW/521
• Crew Complaints Register and Follow-up Log PRO/PRO 22/ SF/CRW/522
• Ship's Menu PRO/PRO 22/ SF/CRW/523
• Personnel Overtime Records PRO/PRO 22/ SF/CRW/524
• Seafarer Confidentiality Agreement PRO/PRO 22/ OFF/ICT 008B
• Wages Account PRO/PRO 21/ SF/ACC/701

• Crew Home Allotments - Personal Bank Details PRO/PRO 21/ SF/ACC/705
• Crew Home Allotments - Summary Table PRO/PRO 21/ SF/ACC/705A
• Vessels’ Cleanliness and Sanitation Schedule SAF/SECTION 25/ POSTER 64
• Table of Shipboard Working Arrangements TEMP 10

• Record of Seafarers' Hours of Rest TEMP 24
(to be used as back-up in case of software's malfunction)
• ISF Watch-keeper Printouts (latest version)
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TRAINING Eff. Date: 30/09/2022
Contents
1. PURPOSE .................................................................................................................................... 2
2. PROCEDURE .............................................................................................................................. 2
2.1 Office Employee Training ........................................................................................................ 2
2.1.1 Identification of Training Needs ....................................................................................................................2
2.1.2 Training methods ...........................................................................................................................................3
2.1.3 Annual Training Schedule ..............................................................................................................................4
2.1.4 Office Assignments to Shipborne Employees ................................................................................................5
2.2 Shipboard Personnel Training................................................................................................... 5
2.2.1 Company Training / Familiarization / Assessment Facilities .........................................................................5
2.2.1.1 Company Head Office Training / Familiarization / Assessment Facilities ........................................................5
2.2.1.2 Prime Odessa Training Facility (POTF) ............................................................................................................6
2.2.1.3 Prime Riga Recruitment Facility (PRRF) ..........................................................................................................6
2.2.2 Concept – Aim of Crew Training ...................................................................................................................6
2.2.2.1 Training / Familiarization...................................................................................................................................7
2.2.3 Crew Training ashore .....................................................................................................................................9
2.2.4 Crew Training Onboard .................................................................................................................................9
2.2.5 Onboard Higher Rank Officers Training & Trainee Senior Officers ...........................................................11
2.2.6 Cadet Training ..............................................................................................................................................11
2.2.7 Training by Visiting Superintendents...........................................................................................................11
2.2.8 Re-training after a Serious Accident/Incident ..............................................................................................11
2.2.9 Company Seminars ......................................................................................................................................12
2.2.10 Crew Training in recognized Maritime Training Centers ............................................................................12
2.3 Training Needs Identification and Follow-up ......................................................................... 13
2.4 Evaluation of Training ............................................................................................................ 16
3. RECORDS ................................................................................................................................. 16
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1. PURPOSE
This procedure aims to ensure that training needs of Shipboard and Shore-based Personnel are
continuously identified and met, training results are recorded and records are maintained.
2. PROCEDURE
2.1 OFFICE EMPLOYEE TRAINING

Continuous training is a key element in the Company’s strategy to meeting changing requirements and
plan for future success.
All Office personnel shall obtain all necessary training in order to be able to successfully undertake
their tasks.
2.1.1 Identification of Training Needs

Training needs are identified from:
A. Office Employee Recruitment Process

During the recruitment of new Office personnel, training needs may be identified and these shall be
met in order to ensure that the new employee will be fully qualified for the intended job.
During the Interview process, training needs identified are recorded on the “Interview Set” Forms
(“New Employee Approval” and “Interview Guide Questionnaire”).
The Company has identified the minimum training requirements of various Office positions.
Therefore, based on the position taken, every new employee receives the minimum required training
and within the time frame specified in form OFF/GEN/009B.
In case the training needs recorded in the “Interview Set” forms are different from those provided in
OFF/GEN/009B, the interviewer must state the timeframe within which the need shall be met.
The Manager or Supervisor decides if such a need is directly associated to employee’s ability and
required certification to perform certain tasks and until the need is closed out such tasks are not
assigned.
However, assignment of some tasks with a training need still open may occur after a risk assessment
is conducted and required measures are taken.
B. Familiarization process of Office employees

Department Managers may identify training needs of a new employee regarding his/her job/duties
during the familiarization period (see Procedure 20B §2.4-“Familiarization/Handover Process of
Office Employees”).
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Office Employee Appraisal Reports

During the Office Employee Appraisal, training needs may be identified which will improve the
employee’s performance or may make him qualified for a promotion.
The identification of such training may originate from the employee and/or from Department
Manager(s), DPA, COO, Deputy COO, Management Representatives, etc.
The form “Appraisal Report for Office Staff” has a special place for recording training needs.
Such training needs shall be closed out as soon as possible.

The appraiser must define the specific time frame to close out such stated training needs,
however this cannot be later than twelve (12) months from the date of the appraisal.
C. Field development (new regulations, advances in technology etc.)

As the Marine Industry is dynamic with many changes in regulations, technology etc., it is necessary
to keep-up with all the new information.
In addition, training needs may be required due to the widening of the scope of activities of the
Company.
Therefore the Company’s Management shall always be alert to such changes and the training required
to meet them. Key staff shall retain core technical skills through new or refresher training, and
participation in Industry Forums, Seminars, Conferences, etc.
In addition, the Annual Training schedule is compiled for all employees, taking into account any
identified training needs.
2.1.2 Training methods

Training needs are fulfilled through the following ways:
A. Training Courses/Seminars at Recognized Training Institutes or Class Societies & Conferences
The Company continuously receives information regarding seminars and conferences from Industry
organizations, Training Institutes, Class Societies, etc.
The Training Manager, in collaboration with Department Managers, decides on the training courses
and attendees.
Specifically for the Information Security training, the ICT Development Head provides the training
requirements (PROC 23-ANNEX 4-“Information Security Users Training Requirements”) and
evaluates the available courses.
Minimum training requirements are defined at the Position Minimum Training Requirements of shore
or shipboard personnel.
B. On-the-job training
Office Personnel may be trained on-the-job, under the supervision and coaching/mentoring of another
Department member, until they receive the knowledge and skills necessary to perform their duties.
This practice is usually followed when new office staff is employed or when old staff is transferred to
new positions. Records (Form OFF/GEN/010) are maintained by each Department.
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C. In-House Training
The Training Department organizes in-house training sessions on various topics which are conducted
either by a Third Party or by the Training Department or other Office Employees.
When appropriate, a relevant Certificate per participant will be issued, and will be forwarded to the
HR Department for further process (i.e filing, record keeping etc).
D. Higher Education & Self -tuition

The Company encourages and supports/sponsors Office personnel taking higher education courses to
improve their value to the company and their possibilities for promotion.
2.1.3 Annual Training Schedule

It is the responsibility of all Department Managers to identify the employees’ training needs, to review
the training methods available, depending on the individual concerned, and to make a proposal to the
Training Manager.
Training conducted is discussed during the Management Reviews Meetings.
During the 1st Quarter of each year and depending on the identified training needs and the “Position
Minimum Training Requirements”, the Training Manager shall issue the form “Annual Training
Schedule” (Annex I of the annual Training Plan).
The Annual Training schedule maybe revised during the year, taking into account any new identified
training needs.
Company’s Managers are responsible for identifying any training requirements and liaising with the
Training Manager.
For the preparation of the Annual Training Schedule, the following shall be taken into account:
 Incidents occurred and their root causes.
 Disciplinary cases.
 Changes in procedures.
 Changes in Operations, including new buildings or new type of Vessels in the Fleet.
 New rules / regulations and Industry best practices.
 Results of training effectiveness measurements.
 Results from Appraisals.
 Training Needs identified.
 Overall review of onboard training.
 Non-statutory Training and Refresher periods.
 Audit/Survey results.
 Recruitment of new employees or promotion of employees etc.
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2.1.4 Office Assignments to Shipborne Employees

This practice improves understanding of the wider aspects within the shipping business and also
improves understanding of marine operations for non-mariner shore personnel.
These assignments are usually relevant to:
 The IMS (assistance in developing/amending IMS procedures and forms).
 Participation in Table Top Exercises (have an office staff role).
 Participation in Management Review Meetings.
 Participation in Office-Vessel Drills and Table Top exercises (directly active or as observers).
Such assignments may also be given for specific projects or in order to assess suitability for promotion
and career development, as well as for future selection for permanent office position.
Records are maintained by the Training Department.
2.2 SHIPBOARD PERSONNEL TRAINING

Reference is made to relevant provisions of Procedure 21-“ Shipboard Personnel” of this Manual,
that define the stages of recruitment, their duration, the responsible persons and ranks of attendees in
the various locations where training /familiarization /assessment is conducted.
Shipboard Personnel are trained and tested by:
A. E- Training onboard and ashore (CBTs – Online sessions – self-study).
B. Group Training by the use of facilitator(s) /experienced crew member on the subject.
C. Classroom courses ashore (Instructors – Simulators).
D. On the job training, Familiarization/Demonstration by Experienced crew, Officers and
Superintendents).
E. WEBINAR sessions.
The training may be delivered at:
A. The Company’s Training Center and Training / Recruiting Facilities
B. The Manning Agents’ premises.
C. The recognized Shore Training Centers.
D. On board.
E. The Mariner’s place provided he has internet access.
2.2.1 Company Training / Familiarization / Assessment Facilities
2.2.1.1 Company Head Office Training / Familiarization / Assessment Facilities

PMA & TC is located at the Company’s building in Athens and is a recognized Maritime Training
Centre by ABS.
It is equipped with all kinds of Simulators including:
 One (1) Full Mission Bridge.
 Two (2) Bridges class B.
 ECDIS Simulator two Bridges Class C.
 Cargo Simulators.
 Engine Full Mission Simulator connected with the full mission Bridge.
 Engine Simulator Virtual Reality.
 Fire Fighting Simulator.
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 Life Boat (conventional) and Davits hardware Simulator.

 Portable Gas Meters of various types and makes.
 PPE ABA and filling compressor.
 Loadicator Software E-Training and on line testing systems
 Five (5) PMS stations.
 Three (3) Loading computers.
 E- Training and on-line testing systems.
 Models in all Simulators designed to correspond to the Company’s fleet.
2.2.1.2 Prime Odessa Training Facility (POTF)

The Company has established POTF, aiming to enhance the system of selection, familiarization and
training of Tanker Officers who have access to Company’s assets not far from their homes.
The POTF is equipped with:
 Simulators Bridge/ECDIS – Two (2) Stations.
 ECDIS Desktop –One (1) Station.
 ABA and Filling Compressor.
 PMS – Five (5) Stations.
 Portable Gas Meters of various types and makes.
 Engine Simulators – Two (2) Stations.
 An Oily Water Separator 15ppm alarm monitor (OMD 2005) & Ancillary simulation
equipment.
2.2.1.3 Prime Riga Recruitment Facility (PRRF)

A CAT ECDIS Simulator for type specific training in FURUNO FMD and a desktop ECDIS - one (1)
station.
2.2.2 Concept – Aim of Crew Training

The aim of training in the Company is to address the Crews’ identified training needs and weaknesses,
improve the safety culture, steer existing mentality towards the direction of high professionalism and
elevate the performance of each individual.
The Training Department conducts the overall planning and is overseeing and evaluating the training
of seaborne personnel.
Psychometric tests and CES tests are reviewed by the Training and Crew Managers in order to provide
focused training.
The Training Department organizes Class or remote (WEBINAR) sessions and reviews the results of
the exercises/assessments. It also ensures programs are complemented, by office staff if required, or
allocate trainings to recognized Training Centers.
Additionally, the Training Department audits the contracted Training Centers, as required.
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2.2.2.1 Training / Familiarization

The Training Department shall ensure that Training/Familiarization is provided to newcomers and
newly promoted Officers (as per the below Tables):
FAMILIARIZATION
MANDATORY (M) OPTIONAL (O)
1. Technical Matters Senior Deck & All Engine
Officers
2. Environmental Matters All Deck and Engine Officers
3. Vetting Marine Issues Masters, Deck Officers,
Chief Engineers & 2nd Engineers
4. Operation - Commercial Matters Masters & Chief Officers
5. S&Q Matters All Deck and Engine Officers
6. Security Matters Masters, Deck Officers ,
Chief Engineers & 2nd Engineers.
7. Crew Matters Masters, Deck Officers ,
Chief Engineers & 2nd
Engineers.
8. Training Dept. courses Senior Deck & All Engine
Officers
9. Purchasing – (Spares-Stores Senior Deck and all Engine
Officers
10. Navigation & Mooring Manual Master & Deck Officers
11. Information Security Matters All Crew members
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TRAINING
MANDATORY (M) OPTIONAL (O)
1. BRM, BTM, Ship Handling Masters & Deck Officers If holders of relevant
(Newcomers & newly trainings/certificates over
promoted, when serving on statutory requirements
different vessel size). from recognized
institutions*.
2. ERM Simulator Chief Engineers & If holders of relevant
2nd Engineers trainings/certificates over
statutory requirements
from recognized
institutions*.
3. Train the Trainer Masters, Chief Officers,
Chief Engineers & 2nd
Engineers
4. ECDIS Masters & Deck Officers If holders of relevant
trainings/certificates over
statutory requirements
from recognized
institutions*.
5. Marine Risk Assessment & Incident Masters, Deck Officers,
Investigation Chief Engineers & 2nd
Engineers
6. ISM Code & Safety Officer Masters, Deck Officers,
Chief Engineers &
2nd Engineers
7. Cargo Handling Simulator/ Cargo Masters & Deck Officers If holders of relevant
Handling Emergencies training certificates from
recognized institutions*.
If holders of relevant
Chief Engineers &
8. Diesel ME- C Standard Operations training certificates from
2nd Engineers
If holders of relevant
9. Crane Simulator Bosuns training certificates from
Mooring System and related Deck Cadets, Oilers,
10.
Procedures Wipers, Fitters, Messmen
11. Vessel’s Sanitary Program Cooks, Messmen
* Recognized Institutions: Training Center authorized by the Administration of the Country they
operate and Holders of ISO Standard 9001 or other equivalent Certificate.
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2.2.3 Crew Training ashore
A. Computer Based Training (CBT)

Crewmembers ready to join a Vessel can view the CBTs provided in the CBT Matrix pertinent to
their rank.
The Manning Agent and /or the Training Department informs all Mariners ashore of the need to
complete their e-training matrices before they are selected for the next contract.
The Manning Agent and /or the Training Department check the joining Crewmember’s CBT
matrices at an early staffing stage.
In case of pending CBTs, the mariner is requested to complete the e-trainings required by the
matrix to the best extent possible.
Above must be achieved either from home since all CBTs are on-line, or at the Manning Agent’s
premises.
Completing CBT Matrix ashore is encouraged since it relieves part of the on-board obligations.
The Company has provided access and encourages all seafarers to conduct CBT training from
home during their vacations, as well as to stay updated on Company’s IMS amendments,
Company’s Circulars / Notices and other important information.
B. Familiarization with Company’s IMS

New recruited seafarers will be given ample time to be familiarized with the IMS during STAGE 2 of
recruitment, and prior to joining onboard.
2.2.4 Crew Training Onboard

The Onboard Training Program includes the following:
A. CBTs by the dedicated Training Platform
All Ships have been supplied with a Computer Based Online CBT Training that synchronizes its data
with the platform ashore on a frequent basis.
The CBT matrices are reviewed as necessary, based on identified needs.

Seafarers shall view specific CBTs, related to their rank, as provided by the CBT Training Matrix.
Seafarers shall make every effort to complete their Rank-Specific CBT Matrix, as soon as possible
and in any case, no later than due date.
Passing Scores:
 The CBT Passing Score is 70 % & 80%, depending on the course requirements.
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B. On Board Training
During this process, an Officer may train other seafarers on specific subjects/procedures/operations or
maintenance of equipment, as per Company’s Matrix.
The on onboard training can take place by consulting a variety of teaching/learning methods s outlined
in Annex 3, followed by discussion on the subject, without a passing score.
For each training session the relevant form SF/TRN/001 must be submitted and sent to the Office on a
Monthly basis, along form SF/TRN/002- Training Matrix.
The Training Matrix is continuously reviewed, developed and complemented by the Training Manager.
C. Monitoring of CBT and on board training

Both CBT and on board trainings are monitored by the Training Department through the Provider’s
web and ERP.
For this purpose, at the end of each month, all Masters shall ensure that export of the training records
to the database are performed either automatically or manually, by exporting the files.
D. Environmental Training
This Training includes:
Online solutions in the form of CBT and presentations developed in the Training Platform and the
Company delivered in the form of Briefings/Familiarization which amongst other cover subjects such
as:
 ISO 14001 Standard.
 Technical and practical information associated with Pollution Prevention.
 Pollution Prevention.
 Oil Bilge Water Management.
 Garbage Management Plan.
 Vessel General Permit (VGP).
 Operation, maintenance and repairs of Oily Water Separators.
 Operation, maintenance and repairs of the ODME.
 Operation, maintenance and repairs of Incinerator and other oil prevention equipment.
 Consequences of violation of Environmental procedures and the necessity of honesty in all dealings
with Port and Flag State Authorities and the need for factual record keeping.
 Use of anonymous reporting system.
 Procedures on change of new fuels according to the IMO Global Sulphur Cap 2020 regulation.
 Ballast Water Management.
 Inventory of Hazardous Materials.
E. Information Security Training

Online solutions in the form of CBT’s are provided to all crew members and presentations are delivered
to all Officers in the form of Briefings/Familiarization which amongst other cover subjects according
to PROC 23_TRAINING-ANNEX 4-“Information Security Users Training Requirements”.
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2.2.5 Onboard Higher Rank Officers Training & Trainee Senior Officers
The Company encourages the Crew, whether they target Career Development or not during their
service onboard, to get trained in Higher-Rank duties, during their service onboard.
Such trainings are recorded in forms SF/CRW/519 to 519I and are taken into account during the review
for promotions.
2.2.6 Cadet Training

Cadets onboard will receive “on-the-job” training by Deck and Engineer Officers (as per Higher Rank
Training of AB/Cadet in Third Officer’s Duties and as per Higher Rank Training of Oiler/ Engine
Cadet in 4th Engineer’s Duties.
Such trainings are recorded in forms SF/CRW/519H and SF/CRW/519G respectively and are taken
into account during the review for promotions.
The Master must make checks at least once per month in order to ensure progress of Cadet’s
training and that training items have been conducted.
The Master approves the records in the system for each cadet, however he shall previously verify (when
needed in consultation with the Chief Engineer) that sufficient training has been provided to the Cadet
as per described items.
The Training Manager shall inform the Crew Manager regarding the percentage achieved in the
“Training in Higher Rank Duties” by reviewing the Cadets’ records, in view of promotion.
(Refer to Annex 2-“Cadets’ Training Standards” of this Procedure).
2.2.7 Training by Visiting Superintendents

During their visits, Superintendents may conduct training to crewmembers on various issues as
required.
Particular attention is paid on specific trainings like the SHELL’s Partners for Safety material,
supporting the concept “Learning from Incidents-LFI” like the Reflective Learning, the Learning
Engagement Tool and the Resilience modules.
2.2.8 Re-training after a Serious Accident/Incident

Senior Officers who are involved in a serious Accident/Incident shall be invited for re-training
The nature and duration of the training shall be decided, based on the conclusions of the Incident
Investigation.
Company’s or 3rd Party’s Training Facilities may be used during this training i.e. Bridge, Cargo, ECDIS
, Engine Simulators, Computer Assisted Training, Crew Evaluation Test, Psychometric Tests, as well
as interviews, seminars and lectures.
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2.2.9 Company Seminars
Every effort shall be made so that ALL Officers attend Company’s Seminars
once every two (2) years.
The Company’s Seminars are conducted at Manning Agent’s base(s), Head Office or via online
facilitation software.
The Company utilizes available technology (online software platforms) to host numerous
seminars/conferences at intervals for selected subjects to allow participation across multiple disciplines
and ranks.
Venue-led seminars/conferences allow ratings to participate as well.
Among other issues, the Agenda includes:
 New International Regulations.
 Incidents and lessons learnt.
 Safe practices and procedures.
 Amendments to IMS.
 Company’s KPIs-Culture- Ethics-Values.
 Inspection findings and maintenance issues e.g. inspections of tanks, etc.
 Environmental Management.
 Safety, human element and security issues.
 Specific shipboard procedures, e.g. the role of the Safety Officer, enclosed space entry, safe
mooring and engine room waste management.
 Repeated problems, trends and non-conformities.
 Officers’ suggestions for improvement of working conditions onboard.
 Complaints (if any).
 Training needs.
 Career Development.
 Seafarers’ Mental Health & Well-being.
2.2.10 Crew Training in recognized Maritime Training Centers

It is the Company’s policy to recruit seafarers trained in excess of the statutory requirements.
The Company’s additional training courses are depicted in table ¨ADDITIONAL (NON-
STATUTORY) TRAINING¨ of Procedure 21-“Shipboard Personnel” of this Manual.
If the seafarer does not possess such Training Certificates, the Company will sponsor the respective
Training Courses, before embarkation, in-house or at approved Maritime Training Centers.
Equivalency options (e.g e-learnings) will be considered on case by case basis.
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2.3 TRAINING NEEDS IDENTIFICATION AND FOLLOW-UP

The Company continuously monitors personnel performance to identify training needs.
The recruitment process identifies any training needed to ensure that personnel have the required skills
and capabilities.
Furthermore, the IMS contains provisions for the ongoing assessment of the qualifications and abilities
of employees to meet the specified job requirements.
The need for further training may be identified by any of the following ways:
 from reviewing the personnel appraisals; any training needs identified are given priority,
 from new regulatory or industry requirements and from changes in the technological, legal and
general operating environment (see Management of Change procedure),
 from reviewing the Drill Reports,
 as an outcome from the evaluation of incidents, near-misses, non-conformities etc,
 from internal / external audits and inspections and from reviewing Vessels performance trends,
 from the Department Heads’ or employees’ direct requests,
 from transfers to new assignments, promotions etc,
 from assessment of competence in rank or in preparation for promotion.
The Master shall ensure that seafarers’ identified training needs are addressed, as appropriate.
In case the training needs cannot be tackled onboard, the Training Manager shall be informed.
2.3.1 Close-out of Identified Training Needs

The Master is responsible to tackle any identified training needs during the course of seafarers’
probation period and service on board that could adversely affect safety and vessels operations.
Crew disembarking with training needs not addressed or raised from office staff appraisals should
receive appropriate training to the extent practicable and after considering their impact on Seafarers
professional competence, critical skills and future performance needs.
Training Requirements All disciplines Location Time Frame

Safety/Environmental/Security On Board Immediately
Critical
Navigation/Bridge Watchkeeping On Board Immediately
Deck operations/Mooring/Cargo On Board Immediately
Engine Operations/Watch keeping On Board Immediately
Maintenance/Repair Onboard or Ashore Ashore or Next embarkation
Administrational Onboard or Ashore Ashore or Next embarkation
Soft / Language Skills Onboard or Ashore Within multiple employments
The Training Department may request from specific seafarers, while ashore to undertake courses or
extra training or self-study in order to either close out pending trainings or defer them for their next
assignment if needs require practical, hands on training, or demonstrations or interaction with certain
devices and ships equipment and/or officers to witness / verify close out.
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In case that seafarers miss training course(s) prior to their embarkation due to unexpected reasons
(e.g urgent embarkation, etc), the respective Manning Agency must immediately inform, prior
seafarers’ embarkation, the Crew / Training Departments and request for approval. Once request
approved, approval mail released shall be uploaded to ERP (under “Training Needs”) and missing
training course(s) shall be arranged either onboard (via existing LMS with a similar course or with an
equivalent one), or ashore immediately after seafarers’ disembarkation and in any case before the next
contract. (Refer in detail to the below table)
Missing Training Courses

All disciplines Location Time Frame
(before embarkation)
Ashore at Training Centre
STCW BRM/BTM/SH IMO 1.22. Prior next embarkation
(TC).
 Ashore at TC
 Onboard temporarily via
Prior next embarkation (even
existing in LMS e-learning if similar e-learning titles
titles, for the sake of due have been completed
STCW Operational use of ECDIS diligence only (in no case temporarily onboard during
IMO 1.27. the temporary LMS course
seafarer’s previous contract
on board solution replaces
(see comments in column “All
the STCW course, which
disciplines Location”))
must be attended ashore at
TC).
 Ashore at TC or via Safe

Bridge LMS, or;
ECDIS Specific.  Onboard via Safe Bridge Prior next embarkation
LMS (see comments on
column “Time Frame”).
STCW ERM IMO 2.07.  Ashore at TC. Prior next embarkation.
 Ashore at TC.
 Onboard temporarily via Prior next embarkation (even
existing in LMS e-learning if similar e-learning titles
titles, for the sake of due have been completed
Risk Assessment & Incident
diligence only (in no case temporarily onboard during
Investigation.
the temporary LMS course seafarer’s previous contract
on board solution replaces (see comments in column “
the course, which must be All disciplines Location”).
attended ashore at TC).
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Missing Training Courses

All disciplines Location Time Frame
(before embarkation)
 Ashore at TC Prior next embarkation (even
 Onboard temporarily via existing in if similar e-learning title has
LMS e-learning titles, for the sake been completed temporarily
ISM & S/O of due diligence only (in no case the onboard during seafarer’s
temporary LMS course on board previous contract (see
solution replaces the course, which comments in column “All
must be attended ashore at TC). disciplines Location”).
Diesel ME- C Standard
 Ashore at TC. Prior next embarkation.
Operations
STCW LICOS TANKER GAS
 Ashore at TC. Prior next embarkation.
IMO 2.06 / 1.35
 Onboard temporarily via existing in if similar e-learning title has
LMS e-learning titles, for the sake been completed temporarily
Train the Trainer of due diligence only (in no case the onboard during seafarer’s
temporary LMS course on board previous contract (see
solution replaces the course, which comments in column “All
must be attended ashore at TC). disciplines Location”).
Crane Simulator  Ashore at TC. Prior next embarkation.

 Onboard temporarily via existing in if similar e-learning titles
LMS e-learning titles, for the sake have been completed
Mooring System and related
of due diligence only (in no case the temporarily onboard during
Procedures
temporary LMS course on board seafarer’s previous contract
solution replaces the course, which (see comments in column
must be attended ashore at TC). “All disciplines Location”).
Prior next embarkation via

 Ashore via Oceanic Catering
Oceanic Catering training
training process and via LMS e-
process (even if similar e-
learning title.
learning title has been
Vessel’s Sanitary Program  Onboard temporarily only, via
completed temporarily
(MLC) existing in LMS e-learning title (this
onboard during seafarer’s
option applies only when Oceanic previous contract (see
Catering training has not been comments in column “All
completed prior embarkation).
disciplines Location”).
Extra training ashore may be conducted at Prime training center or at External Training Centers or
by the Manning Agent’s Training staff or via the online solutions.
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2.4 EVALUATION OF TRAINING

The Training Manager shall assess the value and effectiveness of all training activities, shall determine
whether the content of the training courses is consistent with the aims and current needs of the
Company and shall assess the overall effectiveness and the benefits of the training activities.
This may be done in any of the following ways:
 by interviewing / testing the Trainees in order to verify their competence,
 by requesting the Attendees to evaluate Trainers and courses, as applicable,
 by Company’s representation at Training Courses,
 by reviewing Appraisal Records,
 by reviewing the Vessels’ performance as well as the Audit and Inspection Trends,
 by correlation of Non-Conformance, Incidents and Near Misses.
In consultation with Masters, the Training Manager must also evaluate the effectiveness of training by
monitoring the performance on-board of certain individuals in areas where they have recently received
specific training.
The evaluation of the training shall be documented, filed along with the Training Plan and taken into
account when preparing future training seminars.
Taking into account the results of the training evaluation, the Training Manager may conduct audits to
the external Training Providers, as required.
The effectiveness of Training Programs is discussed during the Management Review Meetings.
3. RECORDS
 Training Provider Audit Questionnaire PRO/PRO 23/ OFF/TRN/701
 Annual Training Schedule PRO/PRO 23/ OFF/GEN/007
 Position Minimum Training Requirements PRO/PRO 23/ OFF/GEN/009B
 Office Personnel In-House Training PRO/PRO 23/ OFF/GEN/010
 Training Record PRO/PRO 23/ SF/TRN/001
 Higher Rank Training in Master’ Duties PRO/PRO 23/ SF/CRW/519A
 Higher Rank Training in Chief Officer’s Duties PRO/PRO 23/ SF/CRW/519B
 Higher Rank Training in Second Officer’s Duties PRO/PRO 23/ SF/CRW/519C
 Higher Rank Training in Chief Engineer’s Duties PRO/PRO 23/ SF/CRW/519D
 Higher Rank Training in Second Engineer’ s Duties PRO/PRO 23/ SF/CRW/519E
 Higher Rank Training in Third Engineer’s Duties PRO/PRO 23/ SF/CRW/519F
 Higher Rank Training in Fourth Engineer’s Duties PRO/PRO 23/ SF/CRW/519G
 Higher Rank Training in Third Officer’s Duties PRO/PRO 23/ SF/CRW/519H
 Higher Rank Training in AB Duties PRO/PRO 23/ SF/CRW/519I
 Training Familiarization Senior Deck PRO/ PRO 23/ OFF/CRW 506A
 Training Familiarization Junior Deck PRO/ PRO 23/ OFF/CRW 506B
 Training Familiarization Senior Engine PRO/ PRO 23/ OFF/CRW 506C
 Training Familiarization Junior Engine PRO/ PRO 23/ OFF/CRW 506D
Page 16 of 16

IMS Procedures ANNEX 1
(002)
Revision: 01
TRAINING
Eff. Date: 31/10/2020

PROC 23- ANNEX

TRAINING & ASSESSMENT PROGRAM
BLUE COLOR DECK & ENGINEERS
GREEN COLOR DECK
YELLOW ENGINEERS
MAROON BRIEFINGS
DAY 1
Introduction TRN
Tour at Company’s premises TRN
Conduct any missing CES or PSYCHOMETRIC test TRN
Conduct Mental health tests TRN- DOC
Familiarization in simulators TRN
Feedback on Psychometric Tests TRN
How we treat a vetting inspector TRN
Interview- Briefing on personal hygiene- Medical issues Doctor/ Paramedic
& First Aid techniques-
Interview- Briefing- Marine/ Operations
Interview- Briefing- Technical
DAY 2
Medical Tests (METROPOLITAN
HOSPITAL 0700-0900)
BRM/BTM/Ship-handling Simulator Exercises TRN
Engine Simulator Exercise TEC
Cargo Simulator Exercises TRN
ECDIS Theory TRN
Bridge Simulator exercise TRN
DAY 3
ECDIS Simulator Exercises TRN
Commercial Cargo Matters (MASTERS ONLY) TRN
Decision Making in Fire Emergencies/AFF Simulator TRN
Engine - Machinery Incidents TEC
Cargo Simulator Exercises TRN
Interview Briefing/ Marine/ Operations/ Technical (Fleet Managers, Operators, Superintendents

Page 1 of 2

DAY 4
Gas Meters Calibration/maintenance TRN
PMS Software BENEFIT TEC
Seamanship - Navigation Incidents TRN
Interview– Briefing / Crew
PPE TRN
ISM– Safety Officer- Behavioral Based Safety TRN
Interview– Briefing Purchasing Dep./ Spares
Interview– Briefing Purchasing Dep./ Stores
DAY 5
Environmental issues-Energy Conservation – TEC
Risk Assessment & Incident Investigation TRN
Internal Audits– Security issues- R.A. in BENFIT ERP– S&Q
MEDIA Training TRN
Train the Trainer - incl. Resilience Reflective Learning - LET TRN
Interview– Briefing with DPA

Page 2 of 2

PRIME TANKER PROC 23 PROC 23‐ Annex 1
PRIME GAS Annex 1‐ Onboard Training Matrix Revision :01
Issue Date: 30/04/2022
Shipboard Personnel Training ( Group Training by facil
Code Topics
T1 Fire Fighting Equipment/Appliances (Note 2)
T2 Lifesaving Equipment/Appliances (Note 2)
Environmental & Technical
Pollution Prevention
T3
Ballast & Sewage treatment
IGS/IGG & EDG
Cargo/Ballast Operations
Gas Measurement
T4
Cargo Handling equipment
Cargo/ Ballast Operations ‐ (Oil/Chem/Gas) As applicable
Mooring & Lifting equipment Appliances
T5 Lifting equipment & appliances
Mooring system & line Management plans, arrangement and equipment
Operational (Note 1) (Before relevant operation and every 4 Months)
T6 Mooring operation
STS Operation & Bunkering Operation
Work Permit System & IMS (Integrated Management System)
T7 BBS, Risk Assessment & tool box meeting
Permit to work system
Personal Safety, Health and hygiene
Drug & Alcohol procedures
T8
Human Element
Use of PPE
Navigation
T9 GMDSS
Navigational Equipment
T10 Master’s discretion (Topic suggested by Master)
Notes: All training sessions must be adjusted to Polar waters where available. Minimum du
for deck, engine and galley depts, as applicable.
(1) This training session must be repeated before each operation (mooring / Unmooring/STS
Demonstration/practical training at mooring stations].
(2) Individual instructions may cover different parts of the ship’s life‐saving and fire extingui
For each training sessions, relevant form (CRW‐507) must be submitted and uploaded to ER
Code Topics
Resilience Issue Date: 30/04/2022
Module 1: Change is a part of living or Module 2: Keep things in perspective
Module 3: Take decisive action or Module 4:Take care of yourself
S1
Module 5: What is resilience? Or Module 6: Dealing with crises
Module 7: Making Connections or Module 8: Maintain a hopeful outlook
Module 9: Connections to home or Module 10: Gratitude
Module 11: Positive communication
Let’s Talk
Module 1: We all have a state of mental health
S2 Module 2: Support Structures
Module 3: ALL ACT – Supporting others
Module 4: Promoting Positive Mental Health and Reducing Stigma
Reflective Learning
Personnel Transfer or Mooring
Weak Signals or Removing the Hazard
S3 Chronic Unease or Collective Normalization
I Keep My Barrier Strong or It Will Never Happen to Me
Is it Equipment That Really Fails? Or People Make Mistakes
Supporting Documents or Machinery Space Fires
LET (Learning Engagement Tool)
Hazard and Risk or Personal Safety
Seafarer Wellbeing or Human Performance
Confined Space Entry or Invisible Hazards
Cargo Transfer Operations or H2S Exposure
Machinery Space Fires or Engine Failure
S4
Personnel Transfer or Mooring Operations
Colregs or Navigation
Ship to Ship Operations or Dry Docking
Lifeboat Operation or Lifting and Hoisting
Prevention of Man Overboard or Falling into the Water
Are we in control?
Bad Weather
S5 Master’s discretion (Topic suggested by Master)
Notes (Shell Material Training Matrix )
All the training material related to the Shell matrix is available in the training platfo
Every Shell based session has to be registered in the VMLS platform with the Facilita
litator(s) / experienced crew members on the subject/ On job training/ Demonstratio
Ranks January February March April May June July
Deck Off
Eng Off
Ratings
Deck Off
Eng Off
Ratings
Deck Off Environmental & Technical
Eng Off
Ratings
Deck Off Cargo/Ballast Operations
Eng Off
Ratings
Deck Off Mooring & Lifting equipment App
Eng Off
Ratings
Deck Off Operational
Eng Off
Ratings
Deck Off Work Permit System & IMS (Integrated Mana
Eng Off
Ratings
Deck Off Personal Safety, Health and hygi
Eng Off
Ratings
Navigation
Deck Officers
ration for each training session is 30 min based on scenario every time. Relevant training material must be
S) with practice/training on site for all involved personnel [mooring training to be conducted in two equal st
ishing appliances, but all the ship’s LSA & FFE must be covered within any period of two (2) months
RP
Shell Training Matrix ( Group Training by facilitator)
Ranks January February March April May June July
Resilience
Deck Off
Eng Off
Ratings
Let’s Talk
Deck Off
Eng Off
Ratings
Reflective Learning
Deck Off
Eng Off
Ratings
LET (Learning Engagement Too
Deck Off
Eng Off
Ratings
orm (VLMS).
ator credentials.
on on site, as applicable (Proc_23)
August September October November December
liances
agement System)
iene
used and accordingly adjusted/applied
tages: a) Theory and b)
August September October November December

ol)
IMS Procedures Prime Gas Management Inc. Annex 4
Manual
TRAINING – ANNEX 4 Revision: 00
(002) INFORMATION SECURITY USERS Eff. Date: 30/11/2021
TRAINING REQUIREMENTS
PROC 23- TRAINING –ANNEX 4

INFORMATION SECURITY USERS TRAINING REQUIREMENTS
This document provides requirements for building and maintaining a comprehensive information
security awareness and training program for the end users both ashore and on-board.
Below are the main topics that are covered during the awareness and training courses:
 Phishing.
 Social Engineering.
 Malware:
o The principles and requirements of the anti-malware policy.
o Identifying and responding to ‘hoax’ virus warnings, reporting them to the
Company’s responsible, and not passing them on.
o Not opening attachments to e-mails that are unexpected or where the sender is
unknown.
o How to respond if a virus does successfully install itself on their workstation or
laptop.
o What protective steps are necessary in respect of portable memory media.
o How to respond to screen and system alerts regarding viruses, spam, and mobile code.
o Not to accept any file or folder execution requests while on the Internet.
o To deliver regular training to Company’s employees regarding the malware.
o Clear desk, screen & office.
 Portable devices:
o Raise users awareness of the additional risks resulting from working with portable
devices and the controls that should be implemented.
o Separation of private and business use of the devices protecting business
information and data.
 Password Security Guidelines.
 Report security incidents.
 Work securely outside the office.
o Laptop security while on travel – address both physical and information security
issues.
o Desktop security – discuss use of screensavers, restricting visitors’ view of
information on screen.
 Personal Devices.
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IMS Procedures
Prime Gas Management Inc. ANNEX B
Manual
(002) Revision: 03
CADET TRAINING STANDARDS Eff. Date: 30/09/2022
Contents
1. INTRODUCTION ........................................................................................................................ 2
2. TARGETED DEVELOPMENT .................................................................................................. 2
2.1 Structuring and Maintaining Maritime skills ............................................................................ 2
2.2 “Adding Value” to Seafarers’ Skills ......................................................................................... 2
2.3 Management Development ....................................................................................................... 2
2.4 Recruitment and Career Progression ........................................................................................ 2
3. BROAD PRINCIPLES FOR OFFICER CADET PROGRAM ................................................... 3
3.1 General ...................................................................................................................................... 3
3.2 Requirements for the Officer Cadet Program ........................................................................... 4
3.3 Entry Requirements .................................................................................................................. 4
3.4 Academic Requirements for Admission ................................................................................... 4
3.5 Age requirements ...................................................................................................................... 4
3.6 Security Criteria ........................................................................................................................ 5
3.7 Other Requirements .................................................................................................................. 5
4. TRAINING PLANS ..................................................................................................................... 5
5. OTHER PROGRAM ASPECTS .................................................................................................. 5
6. MAIN ROLES & RESPONSIBILITIES OF OFFICER CADET TRAINING PROGRAMS .. 10
7. LIST OF STCW SHORT COURSES ........................................................................................ 11
8. RECORDS ................................................................................................................................. 12
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1. INTRODUCTION
The purpose of this procedure is to provide the fundamentals for the development and approval of
the Officer Cadet Program (Deck & Engine) of the Company.
2. TARGETED DEVELOPMENT
2.1 STRUCTURING AND MAINTAINING MARITIME SKILLS

Based on the vision of the company this list is of relevance as a whole as; Demand for maritime
skills comes not only from the need to operate the fleet effectively but to also provide a
sustainable supply of young, well-trained and qualified officers, officers with leadership and
managerial potential.
The program supports the manning, strategic goals and recruitment efforts, with a ‘from the
cradle’ approach in developing PRIME’s future officers. The effort focuses to select candidates
at an early stage and train them from the basic level up to the ranks of junior officers and
beyond.
2.2 “ADDING VALUE” TO SEAFARERS’ SKILLS

Our crews and officers operate in a global market. The standards of education, training and
performance of officers need to be raised in response to raised expectations for the performance
industry demands. Measures that ‘add value’ in comparison to the current norms are needed to:
 safeguard the expertise of the future officers company uses and
 retain the attractiveness of a career up to the highest level to those who would otherwise
choose alternative short term employers.
2.3 MANAGEMENT DEVELOPMENT

Research suggests that it is managerial ability rather than technical skills that distinguish senior
officers who are highly effective from those who are less. Looking beyond statutory
qualifications to develop and recognise the management skills and competences of junior
officers employed at sea will contribute significant “added value”.
2.4 RECRUITMENT AND CAREER PROGRESSION

The Company can attract both the quantity and the calibre of the officers it requires for the future.
The Company has the potential to source high quality new entrants from amongst the pool of
available candidates.
Candidates who achieve higher academic qualifications and aspire for a career progression to the
highest level.
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3. BROAD PRINCIPLES FOR OFFICER CADET PROGRAM
3.1 GENERAL
The program created for the benefit of the company and must prepare its officers to meet the
demands of the industry, along with achieving a sustainable stream of officers to the quality
Company demands for its staff.
The program provides for the education and training of its future officers to a standard beyond
the STCW Officer of the Watch certification.
It encompasses:
 An educational qualification incorporating the underpinning knowledge, learning and
appropriate practice defined within STCW and IMS relevant procedures;
 The Industry-specified knowledge, understanding and behaviours as identified by the
Industry guidance , National and International Regulatory Bodies;
 Specific STCW “Short Courses” as an integral part of the program;
 Mandatory minimum sea time, effectively integrated through the course, such that
appropriate stages of learning support practice on board;
 Inclusion of in-house developed “Short Courses”, Webinars, briefings and the Cadets’
Training Record Book (Deck and Engine), to attest to relevant coverage of STCW and
Company-determined tasks/activities to be carried out whilst Cadets are on-board Company
vessels.
Qualifications for admission to the program must meet the required Academic Standard and
other criteria, as laid down in the Program.
In order to achieve STCW Certification, the Officer Cadet besides in-house Company training
criteria, must satisfy the specific requirements of the respective National Maritime Authority and
achieve the examination Pass-Marks, along with the Training Records and attestations required,
to which the current document doesn’t touch upon.
The program is to consist of phases at both the Academic Establishments and at sea, on board
Company vessels which progress logically, with completing Academy’s Deck and Engine
Training Record Book, specific trainings, STCW and in-house developed courses optimised to
ensure that learning is progressively effected.
Each phase must thus build on the previous, whilst preparing for the next.
For this purpose and to satisfy Company’s specific criteria, there must be at least a minimum of
two (2) separate and distinct sea-phases interspersed with separate college phases
supplemented by trainings/briefings and assessments during the academic terms at the Manning
Agents’ and / or Company’s available facilities.
Subject to the above, the program structure and timings (Sea-Phases) are not specifically defined
as they will be staged to cater for the academic requirements of the National Training
Establishments (Academies/Colleges).
The chosen/approved Training Establishments from which Cadets are drawn, are from long-
established Institutions, reputable and authorized to provide relevant Training and Certification
to the STCW Standards, with their content been fully transparent such that programs provided by
them can be compared to each other.
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The chosen Establishments provide programs leading to different Qualifications/Degrees within

the same discipline, with differences in Sea/Shore phasing, Academic duration ,Assessment
Methods and Admission Criteria, however to the extend the Qualification/Degree obtained at the
end of the Academic and Sea-time training as a Watch Officer (both Engine and Deck) fully
satisfy the relevant STCW standards.
Sea-time will be underpinned within the Training Record Book, the Seaman’s Book and relevant
Sea Service Certificates.
The program clearly identifies appropriate links between the stages and coverage of Academic/
College-Based learning, Work-Based learning, relevant Tasks/Activities and other requirements
within the Training Record Books, available LMS platforms onto which Cadets are required to
undertake specifically designed trainings, CBTs , Tests, Seminars, briefings etc.
3.2 REQUIREMENTS FOR THE OFFICER CADET PROGRAM

The program to the extent sea time is concerned nevertheless meet the minimum requirements
of the sea phase time for the award of either STCW II/1, or STCW III/1 (i.e. operational level for
deck and engineering disciplines), and as minimum incorporates all the requirements within the
Training Standard to ensure defined industry needs are provided for.
Academic Degrees provided by the National Training Institutions are not listed, however all
from which Cadets are to be drawn from provide the underpinning knowledge and criteria for
STCW certification.
3.3 ENTRY REQUIREMENTS

Graduates from the National Institutions and the respective faculties are awarded with STCW
“Officer on Watch” Certificates on the disciplines of Deck and Engine, which are administered by
the respective national Maritime Authority.
3.4 ACADEMIC REQUIREMENTS FOR ADMISSION

a) Candidates drawn from the Institutions are at least up to the equivalent of the 80% to the highest
grade.
b) Candidates will be considered in case they have been admitted to the Colleges or Universities on
scholarships, or perform exceptionally on interviews and/or admission Test Criteria and they
fulfil the age requirements.
c) Graduates with existing relevant experience (Sea-Time) and/or expertise even on other ship types
(completed Sea-Time and Training Books) across all Institutions, will also be considered
provided they hold a “Junior Specialist or Bachelor’s Degree” or OOW Certification, they fulfil
maximum age requirements and perform to the required criteria in tests and interviews.
3.5 AGE REQUIREMENTS

Program Participants must not be younger than 18 and older than 25 years of age.
The Company reserves the right to waive the upper limit in case of candidate(s) displaying
exceptional capabilities.
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3.6 SECURITY CRITERIA

Program Participants must be free of conviction and must produce a clean Criminal Record.
The Manning Agent will request entrants to disclose any “unspent” or “past” convictions.
If a candidate was sentenced in prison (or a corresponding Court Martial Punishment), then any
conviction cannot be regarded as “spent”.
3.7 OTHER REQUIREMENTS

 Where English is not the Applicant’s first language, the English test must be performed/passed
and Manning Agents must confirm adequacy of English language at the interview stage.
 Competency Evaluation System (CES) Tests must yield results not less than 60% per chapter
and 70% per subject.
Repetitive tests, if score is not achieved, are allowed up to a maximum of three (3) attempts.
These are:
 Survival -Basic & Fire Fighting.
 Marlins Test for Junior Officers.
 The Psychometric Assessment must also be passed and reviewed by the Crew Manager and the
Training Manager, who will inform the Manning Agent on the overall assessment made.
4. TRAINING PLANS
Before the first sea-phase is conducted, mandatory safety and other training are required to be
undertaken along with specified non-mandatory courses.
Suitable inductions are also planned to ensure that the Officer Cadet understands what is expected
in each phase at sea.
This will need to cover the induction requirements set out by the:
o Academy’s Training Work Book.
o Company’s specific requirements, applicable to the Cadets.
Subsequent shore phases must provide for learning at the appropriate level, in a progressive
arrangement, such that it supports the development of STCW knowledge, understanding and
proficiency and relates to the tasks to be undertaken throughout each sea phase, as defined within
the Training Record Book.
5. OTHER PROGRAM ASPECTS

The Training content is mapped to relevant STCW tables for each discipline and it is detailed
within the Academy’s Training Record Book.
Within the two sea-phases, Officer Cadets are expected to complete all tasks within the
respective sea-phase, as specified in the Training Record Book (Deck & Engine respectively).
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To ensure the appropriate monitoring of progress and the consistent tutoring of Trainees, the
Master/Training Officer on board and the Mentor at the Manning Agency, are to adhere to their
respective responsibilities, as detailed in the Table of paragraph 6 of this procedure..
The program provides for appropriate evaluation and assessment to ensure that the trainee
performs to the expectations and subsequently is ready to move onto each subsequent phase.
The assessment upon first term return is key as in this phase it is expected to evaluate the
completed training book tasks along with the onboard training teams’ appraisals assessments and
recommendations for the Cadets.
Based on this and after a series of CES tests, interviews and evaluations forward planning (ref
corrective actions, training, or amendments on the individual’s scheme) will further be decided.
Mandatory short courses are to be appropriately incorporated within the program at suitable
times as recommended below.
Wherever possible, specific learning for and/or the short course itself must be incorporated
within relevant program units/modules to ensure cost effectiveness and integration of learning.
STCW courses must be delivered at approved training centres.
Before setting to sea the following must be ensured/ undertaken;

1st Sea-phase Cadets Statutory Certificates
( as per Matrix of Procedure 21- “Shipboard Personnel” of this Manual , applicable to
Cadets)
1st Sea-phase Cadets CBTs

SEAGULL-VLMS
( as per Seagull and SQLearn ( VLMS) Matrices, applicable to Cadets )
1st Sea-phase Cadets Induction ( Manning Agency)

Besides the Statutory Certificates mentioned above, Company’s Specific Trainings and Pre-
Embarkation Briefings are conducted, including Ship-Specific matters, if necessary:
Cadet pre-embarkation briefing

• IMS Basic Training/familiarization
• Company Structure, Policies, Objective and targets.
• Company’s Mission, Vision, Policies, Long Term Goals and Expectations.
1st Sea-phase Cadets MANNING AGENT Familiarization – Briefing

The Pre-Departure Briefing besides the delivery of the “Cadet pre-embarkation Briefing”
(delivered through the Manning Agent), also includes specific references to:
• Seafarers’ Employment Agreement review and acceptance of Terms and conditions of
Employment;
• Disciplinary Process;
• Traveling Arrangements;
• Emergency Contact Numbers Port Agent and Crew Manager;
• Hotel Accommodation.
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• A copy of the Company’s Travelling Policy must be handed over to the joining Crew
Member, for review. This must be clearly stated in the Manning Agents Form
MAN/AGENT/004-“Crew Personal Data – Transmittal Sheet”.
• Form MAN/AGENT/006- “Travel Guidance Checklist” must be handed to him.
• Officer Cadets must never travel alone from and to a ship on both sea-phases.
1st Sea-phase Cadets Familiarization on Board:
Safety- & Security familiarization- Form SF/CRW/506. 1st Week
Job Familiarisation – Form SF/CRW/505. 1st Month

(applicable for the role codes)
Bridge/Engine Familiarisation Forms : 1st Month

SF/CRW/505A-1-Bridge Familiarization
SF/CRW/505A-2-ECDIS Familiarization
SF/CRW/505B-Cargo Familiarization
SF/CRW/505C- Engine Room Familiarization
(applicable for the roles codes).
o As per Training Record Book.

o As per communications by Training Department.
1st Sea-phase Completion

The program provides for appropriate evaluation and assessment between phases to ensure that
the trainee performs to the expectations and subsequently is ready to move onto each
subsequent phase.
The assessment upon first term return is key as this stage is crucial for the development and
progress of the Cadet into the scheme since evaluation of the completed training book tasks
along with the on-board training teams’ appraisals assessments and recommendations are taken
into consideration in conjunction to 3 assessments (CES tests) and the running year’s
college/academy grades scores.
CES tests: Must yield results not less than 60% per chapter and 70% per subject, Repetitive
tests if score not achieved are allowed up to a maximum of three.
• Fire Fighting- Advanced
• Security Awareness / Ship Security Officer
• IMS Test for Junior Deck Officers
Based on the above further training needs or scheme amendments are to be decided;
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2nd Sea-phase Cadets Mandatory /Statutory Certificates

(As per Matric of Procedure 21-“Shipboard Personnel” ( STCW Certificates) and as per
below Company’s mandatory courses, applicable to Cadets.
Mooring System and related Procedures Deck

Benefit e-learning Both
2nd Sea-phase Cadets CBTs

SEAGULL-VLMS
As per Seagull and SQLearn (VLMS) Matrices, applicable to Cadets.
2nd Sea-phase Cadets Induction (Manning Agency)

Besides the Statutory Certificates and the Company’s Courses mentioned above, Company’s Specific
trainings and Pre-embarkation Briefings are conducted, including Ship Specific Matters, if necessary:
Cadet Pre-Embarkation Briefing

• IMS structure (amendments since last induction).
• Company Structure, Policies, Objective and targets (amendments if any).
• Company’s Mission, Vision, Policies, Long Term Goals and Expectations.
• Behaviour Safety On-board.
• Vetting/Technical Dpt introductions to the Superintendents.
• DPA introduction.
2nd Sea-phase Cadets Manning Agent Familiarization – Briefing

The Pre-Departure Briefing includes (delivered through Manning Agent) specific references to:
• Seafarers’ Employment Agreement review and acceptance of Terms and conditions of
Employment;
• Disciplinary Process;
• Traveling Arrangements;
• Emergency Contact Numbers Port Agent and Crew Manager;
• Hotel Accommodation
• A copy of the Company’s Travelling Policy must be handed over to the joining Crew Member, for
review.
This must be clearly stated in the Manning Agents Form MAN/AGENT/004-“Crew Personal Data
– Transmittal Sheet”.
• Form MAN/AGENT/006- “Travel Guidance Checklist” must be handed to him.
• Officer Cadets must never travel alone from and to a ship on both sea-phases.
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2nd Sea-phase Cadets Familiarisation on Board
Safety and Security Familiarization (Form SF/CRW/506) 1st Week
Job Familiarisation – Form SF/CRW/505 1st Month

(applicable for the role codes)
Bridge/Engine Familiarisation Forms : 1st Month
SF/CRW/505A-1-Bridge Familiarization
SF/CRW/505A-2-ECDIS Familiarization
SF/CRW/505B-Cargo Familiarization
SF/CRW/505C- Engine Room Familiarization
(applicable for the roles codes).
o As per Training Record Book

o As per communications by Training Departments
2nd Sea-Phase Completion

The scheme provided it shall be rigorously followed is well structured and balanced for Cadet
officers to be successful and expect them to have acquired except the technical skills , particular
personal qualities in order to handle the demands of the OOW role at their respective disciplines.
Upon completion of the 2nd sea phase , the Cadets consistent to the certification route they follow
would still have to satisfy their academic obligations (last semester studies if not completed) and the
administration requirements for their OOW STCW certification, thence for the company (PRIME)
the process is not considered complete.
Cadets would still need to complete certain administrational processes , exams and assessments until
they receive their Certificate Of Competency thence be eligible for an OOW role onboard PRIME’s
vessels.
Partners in the Table of paragraph 6 of this procedure, shall evaluate and assess the successful
completion of the Training Record Book tasks along with the review of the onboard appraisals
assessments and recommendations which will all be taken into consideration along with final exams
grades and OOW certificate awards.
Candidates will then follow the route of Junior Officer Recruitment, as described in the relevant
Procedures Manual in :
 Procedure 21-“Shipboard Personnel”
 Procedure 22- “MLC Requirements”
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6. MAIN ROLES & RESPONSIBILITIES OF OFFICER CADET TRAINING PROGRAMS
Partner Responsibilities
1. Program design, validation, delivery and assessment
2. Student-centered Personal Development Planning ,
3. Course administration and Individual Action Plans
4. Standards for admission to the program.
Training 5. Liaison with Departments on aspects of Program Design, Delivery, Organization,
Management – including Pre-Embarkation Briefings, Training Record Book and the
Department
Shipboard Induction Booklet.
-Manning
6. Presentation of the program across Institutions.
Agencies
7. Selection of Cadets.
8. Provision and supervision/monitoring of practical training aboard ship,
9. Checking of completion of Training Record Book tasks to meet program requirements.
10. Checking compliance with arrangements for planned training at sea, in liaison with
the Manning Agent.
1. Officer Cadet Mentoring on specific Departmental aspects (if applicable).
Company
Departments 2. Liaison with Training Department on aspects of Program Design, Delivery,
Organization, Management
1. Documentation, background checks, certificates, contracts, Hiring procedures,
Medicals.
Crew 2. Implementation of Procedure 21- “Shipboard Personnel” and Procedure 22- “MLC
Department Requirements”.
3. Embarkation/Disembarkation of sponsored Cadets.
4. Monitoring/Administration of Appraisals.
1. Documentation, background checks, certificates, Contracts, Hiring procedures,
Medicals, Criminal Records.
2. Embarkation/Disembarkation of sponsored Officer.
3. Traveling arrangements and briefings consistent with:
 Procedure 21-“ Shipboard Personnel”
Manning Agent
 Procedure 22- “MLC Requirements”
4. Application/Conduct of CBT Training Modules.
5. STCW Short Courses through Approved Training Centers.
6. Check compliance with arrangements for Planned Training at Sea (i.e. satisfactory
completion of Training Record Book) upon Cadet’s return.
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Partner Responsibilities
1. Student-centered Personal Development Planning.
Master 2. Course Administration on board and Individual Action Plans.
Training
/Officer 3. Provision and supervision/monitoring of Practical Training onboard
4. Overseeing completion of Training Record Book Tasks to meet Program requirements
1. Responsibility for own learning and development.
Cadets 2. Adherence to Training plan, TRB, Training Matrix and other procedures, consistent with
Company IMS and Contractual Obligations.
7. LIST OF STCW SHORT COURSES
1. Personal Survival Techniques (A-VI/1-1)
2. Fire Fighting and Fire Prevention (A-VI/1-2)
3. Elementary First Aid (A-VI/1-3)
4. Personal Safety and Social Responsibility (A-VI/1-4)
5. Proficiency in Security Awareness (A-VI/6-1)
6. Proficiency in Survival crafts and rescue boats (A-VI/2-1)
7. Proficiency in fast rescue boats (A-VI/2-2)
8. Medical First Aid (A-VI/4-1)
9. non-STCW Entry into Enclosed Spaces Training
10. Advanced Fire Fighting (A-VI/3)
11. Automatic Radar Plotting Aids (A-II/1 Section B-I/12)
12. Electronic Chart Display and Information Systems (ECDIS) IMO Model Course 1.27
13. Global Marine Distress and Safety System (GMDSS)
Courses Criteria (General Operator’s Certificate (GOC); Model course 1.25
14. Leadership and Management (Operational and Management Levels) (A-II/1, A-III/1 and A-
III/6)
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15. Navigational Aids and Equipment Simulator Training (NAEST)

(Operational Level; Management Level)
16. Shipboard Safety Officer Training (non-STCW requirement) A-II/1, A-III/1, A-III/6
17. Basic Training for Oil Tanker Cargo Operations (A-V/1-1)
18. Advance Training for Oil Tanker Cargo Operations (A-V/1-2)
19. Mooring System and related Procedures
20. Vessel Sanitary Program
21. Risk Assessment & Marine Incident Investigation Course Model Course 3.1 IMO A.849 (20)
Code for the Investigation of Marine Casualties and Incidents.
8. RECORDS
• Interview / Familiarization Checklist - S&Q Dpt PRO/PRO 21/ OFF/CRW/505
• Interview / Familiarization Checklist - Crew Dpt PRO/PRO 21/ OFF/CRW/506
Manning Agent's Forms (provided by the Company)
• English Assessment Table PRO/PRO 21/ MAN/AGENT/001
• Crew Qualifications Checklist PRO/PRO 21/ MAN/AGENT/002
• Transmittal Sheet PRO/PRO 21/ MAN/AGENT/004
• Travel Guidance Checklist PRO/PRO 21/ MAN/AGENT 006
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PROCEDURE 24
Manual Revision: 05
(002)
ENVIRONMENTAL, ENERGY EFFICIENCY,
OCCUPATIONAL HEALTH AND SAFETY Eff. Date: 29/02/2020
MANAGEMENT PROGRAMS
Contents
1. PURPOSE .................................................................................................................................... 2
2. PROCEDURE .............................................................................................................................. 2
2.1 Development of Management Program .................................................................................... 2
2.2 Final Review and Close-out ...................................................................................................... 3
2.3 Amendment of Management Programs and the Integrated Management System .................... 3
3. RECORDS ................................................................................................................................... 4
Page 1 of 4
PROCEDURE 24
Manual Revision: 05
(002)
MANAGEMENT PROGRAMS
1. PURPOSE
The purpose of this procedure is to provide the steps to be followed and to assign responsibilities for:
 establishing Environmental, Energy Efficiency, Occupational Health and Safety Management
Programs to achieve relevant objectives and targets;
 amending management programs and the Integrated Management System;
 ensuring that the management programs apply to the existing fleet and to new developments and
new or modified activities, or services.
This procedure applies to office and vessels activities or services for which there are established
environmental, energy efficiency, occupational health and safety objectives and targets.
The DPA and the Management Representatives are responsible for initiating Environmental, Energy
Efficiency, Occupational Health and Safety Management Programs and for coordinating and
supervising their implementation.
The company’s Managers and Vessels Masters assigned with overall responsibility for specific
objectives are responsible for implementing relevant Management Programs and for reporting on
their status and progress.
Within the framework of management reviews, the top management is responsible for periodic
review of management programs, and has the authority to close out, or redefine programs that
achieved their objectives.
2. PROCEDURE
2.1 DEVELOPMENT OF MANAGEMENT PROGRAM

For each environmental, energy efficiency, occupational health and safety objective the DPA and
responsible Management Representative establishes one or more programs, which must at least
contain the following information:
 Program description
 Duration of program or time frame
 Objective and targets that are to be achieved by the program
 Continual improvement of the process(es) employed to achieve the program
 Vessels departments / shore based departments
 Methods or ways of program achievement (if applicable)
 Service / Activity / Operation
 Target
 Responsible
 Performance monitoring
 Date Issued
 Key characteristics / operational controls / comments
The Environmental, Energy Efficiency, Occupational Health and Safety Management Programs'
record, is then forwarded to Managers assigned with the responsibility to implement the program.
The responsible Managers define the main parameters of the program and document them
accordingly.
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The top management (Chief Operating Officer (COO) or Deputy COO, DPA and Management
Representatives) reviews the Environmental, Energy Efficiency, Occupational Health and Safety
Program Instructions and, if these are in agreement with the proposed program, approves it for
implementation.
For most programs, the responsible Manager for implementation maintains records of its
implementation, progress, and completion.
When necessary, the top management may extend the overall timeframe for achieving an objective or
target, or to change the actual objective. If the objective needs to be changed, this may involve
authorization by the top management.
2.2 FINAL REVIEW AND CLOSE-OUT

When an Environmental, Energy Efficiency, Occupational Health and Safety Management Program
achieves its objectives and targets, the results are reported at the Management Review.
If a review is not scheduled within the next three months, or when the matter is urgent, results of the
program may be communicated to individual members of the Management Team, or an additional
review may be called.
The process for the final review and close out or modification of objectives, targets, and associated
programs is defined the relevant procedure Management Review.
2.3 AMENDMENT OF MANAGEMENT PROGRAMS AND THE INTEGRATED MANAGEMENT SYSTEM
All projects related to new developments or to new or modified activities, vessels or services are
reported to the top management.
Examples of such projects may include:
 New Vessels of Different type – design from existing;
 Changes in ship operational processes and technology, and introduction of new activities;
 Significant expansion or reduction of fleet capacity;
 New suppliers and subcontractors;
 Office addition or relocation;
 Changes in company’s scope of activities and / or addition of new activities.
The DPA and Management Representatives review the proposed changes and determine whether the
existing programs or any of its elements needs to be amended to address the change. Amendments to
Environmental, Energy Efficiency, Occupational Health and Safety Management Program may
include:
 Identification of new environmental aspects or invalidation of current aspects;
 Addition of new significant environmental aspects;
 Setting of new environmental, energy efficiency, occupational health and safety objectives and
targets;
 Modification of environmental, energy efficiency, occupational health and safety management
programs or establishment of new programs;
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 Adjustment of programs for monitoring environmental, energy efficiency, occupational health

and safety performance and evaluation of compliance;
 Modification of emergency preparedness and response programs;
 Addition of new training programs; and
 Changes to the environmental, energy efficiency, occupational health and safety policies.
Processes for amending specific elements of the Integrated Management System are defined in
Procedures dealing with these elements. Amendments and changes to the Integrated Management
System are also considered by the management review.
3. RECORDS
 Management Program PRO/PRO24/ OFF/EMS/E003
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ENVIRONMENTAL ISSUES Eff. Date: 29/02/2020
Contents
1. PURPOSE ..................................................................................................................................2
2. PROCEDURE ............................................................................................................................2
2.1 Environmental Aspects and Impacts .......................................................................................2
2.1.1 General ........................................................................................................................................................ 2
2.1.2 Risk Assessment.......................................................................................................................................... 3
2.1.3 Company’s Environmental Aspects and associated Impacts....................................................................... 4
2.2 Legal and Other Requirements ...............................................................................................5
2.3 Environmental Objectives, Targets & Plans ...........................................................................7
2.4 Environmental Management Report .......................................................................................9
2.5 Implementation and Operation .............................................................................................11
2.5.1 Resources, roles, responsibilities and authorities ...................................................................................... 11
2.5.2 Competence, Training and Awareness ...................................................................................................... 13
2.5.3 Communication ......................................................................................................................................... 14
2.5.4 Operational control.................................................................................................................................... 16
2.5.5 Emergency Preparedness and Response.................................................................................................... 16
2.6 Checking ...............................................................................................................................17
2.7 Environmental Management Review ...................................................................................17
3. RECORDS ...............................................................................................................................18
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1. PURPOSE
The purpose of this procedure is to provide evidence for compliance with specific requirements of
ISO 14001.
The EMS is a dynamic system integrating environmental management in accordance with the ISO
14001 with Company’s operations and applies to all environmental aspects that the Company
identifies, either as those that it can control or those that it can influence.
The purpose of the EMS is to ensure that Company’s Vessels comply with all applicable marine
environmental protection requirements established under applicable International, Flag State, Port
State and Coastal State law hereinafter marine environmental protection requirements and to the
additional requirements and voluntary undertakings established by the EMS itself. Voluntary
undertakings include industry best practices that the Company may choose to adopt.
In the case of a conflict between the EMS and any of the aforementioned requirements such that the
EMS is less restrictive, then the more restrictive authority shall govern.
Furthermore, the purpose of the EMS is to:

 increase environmental training and awareness of all personnel involved with managed fleet;
 develop and implement management and engineering controls to better manage, identify and
prevent environmental violations;
 manage and control activities and processes that have a significant impact on the environment,
minimize the impact of these activities, and achieve continual improvement of the EMS and
Company’s environmental performance.
The implementation of a robust EMS and the achievement of sound environmental performance
require all activities, operations and personnel to be in the frame of environmental awareness, care
and set of objectives. Consequently, all Company’s employees are aware of this system and
understand, implement and continually support any requirements of the EMS.
2. PROCEDURE
2.1 ENVIRONMENTAL ASPECTS AND IMPACTS

This section identifies the Environmental aspects and impacts of the Company activities within the
scope of the EMS, that it can control or that it can influence.
2.1.1 General
Identifying significant environmental aspects and associated impacts is necessary in order to
determine where control or improvement is needed and to set priorities for management action.
Changes to the environment, either adverse or beneficial, that result wholly or partially from
environmental aspects are called environmental impacts.
The relationship between environmental aspects and associated impacts is one of cause and effect.
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In this respect the Company:

 identifies the environmental aspects of its activities and services, within the defined scope of the
EMS, that it can control and those that it can influence, taking into account planned or new
developments, new or modified activities, products and services; and
 determines those aspects that have or can have significant impacts on the environment.
The Company documents this information and keeps it up to date.
Furthermore, the Company ensures that the significant environmental aspects are taken into account
in establishing, implementing and maintaining its EMS, through continual review and update (when
necessary) of the running “Environmental Management Report”.
The process of establishing significant environmental aspects involves the following steps:
 Identifying, evaluating and prioritizing environmental aspects.
 Defining goals and environmental programs.
A tool that the Company uses for the identification of significant environmental aspects and impacts
is the Risk Assessment (RA). Through the RA the Company aims to systematically approach the
identification of hazards and the assessment of the associated environmental risks.
The Company reviews the progress of the environmental programs and evaluates the need to
reassess the environmental impacts of its activities.
Responsibilities related to establishing and maintaining the way that the Company controls all
matters relating to the management of the environmental aspects of its activities are as follows:
 The Deputy Environmental Management Representative is responsible for composing the
“Environmental Management Report” and the Environmental Programs.
 The Environmental Management Representative is responsible for checking the form
“Environmental Management Report”.
 The Chief Operating Officer (COO) or Deputy COO is responsible for approving the form
“Environmental Management Report” and the Environmental Programs.
The basic environmental aspects related to a Vessel’s operation and office activities are presented in
the following paragraphs.
2.1.2 Risk Assessment

In order to identify the significant environmental aspects and associated impacts, the Company uses
the Risk Assessment process (RA).
The RA process is intended to be a careful examination of what, as far as any Company’s activity is
concerned, could damage the environment.
The “Color Code” used for the Risk Assessments in the Environmental Management Report is the
following:
Low Priority: Aspect is NOT Significant
Medium Priority: Aspect is Significant
High Priority: Aspect is Significant – Major
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2.1.3 Company’s Environmental Aspects and associated Impacts

The Company has identified its basic Operational Activities and all the Environmental Aspects and
Impacts related to these activities.
The Environmental Aspects are continuously reviewed and updated when necessary.
A. Office Environmental Aspects and Impacts
E x h a u st fro m c e n tra l
h e a tin g .
D e liv e r y o f g a rb a g e
- P la stic s
- Paper
- S p e c ia l w a ste
- E E w a ste
- O th e r w a ste
Sew age C o n s u m p tio n

L a n d u se - fre sh w a te r
- e n e rg y /e le c tric ity
- c o n su m a b le s
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B. Shipboard Environmental Aspects and Impacts
Basic environmental aspects related to a Vessel’s operation
The Company continuously reviews and updates its environmental aspects and impacts and updates the
relevant form “Environmental Management Report”.
2.2 LEGAL AND OTHER REQUIREMENTS

This section identifies the legal requirements which are related to the environmental aspects of the
Company’s activities, products and services. Environmental matters can be found in all spheres
from International Codes such as MARPOL, to local Port requirements.
The Company aims to:
 identify and have access to the applicable legal and other requirements to which the Company
subscribes, related to its environmental aspects; and
 determine how these requirements apply to its environmental aspects.
The Company ensures that legal and other requirements that are applicable to its environmental
aspects are taken into account in establishing, implementing and maintaining its EMS, i.e.:
 national and international legal requirements;
 non-regulatory guidelines and voluntary principles or Codes of practice;
 voluntary environmental labelling or clients stewardship commitments; and
 requirements of trade associations.
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The DEMR, through follow up of proceedings of the International Bodies and Interested Parties
listed here below, updates the “Legal and Other Requirements List”, while informs all involved
personnel regarding new and revised regulations. Summaries of key items are also provided and
ships are alerted of important issues through Circulars, etc.
The EMR is responsible for checking the “Legal and Other Requirements List” and the Chief
Operating Officer (COO) or Deputy COO is responsible for approving it. All Managers are
responsible to follow up forthcoming regulations through the form “Legal and Other Requirements
List”.
Monitoring and Updating the Legal Requirements List

The Environmental Management Representative (EMR) is the dedicated person responsible to:
 Identify the Legal Requirements which are relevant to the Company’s activities.
 Continuously follow-up :
o Environmental laws, directives and National / International legislation.
o Requirements of Classification Societies.
o MARPOL Requirements
o Voluntary principles or Codes of Practice, requirements of trade associations etc, non-
regulatory guidelines, voluntary environmental labeling, clients stewardship commitments
etc
o Requirements of Local Authorities
 Make the above requirements available to all Company Employees by issuing relevant
Circulars.
 Update the Environmental Management Report with the new Legal Requirements, as necessary.
 Ensure that mandatory legal requirements are incorporated in the IMS, as required.
International Bodies and Interested Parties to be monitored for updating the form E002:
IMO European Union
http://www.imo.org http://europa.eu.int
BIMCO Baltic and International Maritime
INTERTANKO
Conference
http://www.intertanko.com
http://www.bimco.dk
ICF – ISF Seafarers Int’l Research Center
http://www.marisec.org http://www.sirc.cf.ac.uk
Hellenic Chamber of Shipping
http://www.nee.gr Greek Ministry of Mercantile Marine
ABS http://www.yen.gr
http://www.eagle.org
BV Lloyd’s Register
http://www.veristar.com http://www.lr.org
International Maritime Academy DNV-GL
http://www.imoima.org/ http:/www.dnvgl.com
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International Chamber of Shipping IACS

http://www.marisec.org/ http://www.iacs.org
World Maritime University (WMU) UNEP Mediterranean Action Plan (MAP)

http://www.wmu.se/ http://www.unepmap.org
ITOPF World Maritime Institute

http://www.itopf.com http://www.wmi-org.com
Mediterranean Programme for International
Infomarine on-line
Environmental Law and Negotiation (MEPIELAN)
http://www.infomarine.gr
http://www.mepielan.gr/intro-en.html
Institute of Marine Engineering, Science & European Commission Information System (CIS)
Technology (IMarEST) http://www.yen.gr/cis/yourcountry/index.htm
http://www.imarest.org
Hellenic Ministry of Environment, Energy & Hellenic Institute for Occupational Health and Safety
Climate Change (EL.IN.Y.A.E)
http://www.ypeka.gr http://www.elinyae.gr
2.3 ENVIRONMENTAL OBJECTIVES, TARGETS & PLANS

This section defines the Environmental objectives, targets and plans which have been established by
Top Management for the relevant functions and levels within the Organization.
The Company has established, implements and maintains a procedure for developing documented
environmental objectives and targets. Top Management approves the environmental objectives and
targets which reflect the significant environmental aspects and are consistent with the
Environmental Policy. Objectives and targets contain the high-level and long-term goals and
aspirations of the Company, such as zero incidents and zero pollution.
The Company aims to reach these goals through continual improvement.
The Company’s objectives and targets have been set in accordance to Specific, Measurable,
Acceptable, Realistic and Time bound approach (SMART).
The Company also considers available technological options, financial, operational and business
requirements, and the views of interested parties. The EMS establishes specific objectives and
targets for:
 Achieving and maintaining compliance with all environmental protection requirements and the
requirements of the EMS.
 Environmental performance demonstrating continuous improvement in regulated and non-
regulated areas.
 Pollution prevention that emphasizes source reduction with respect to engine room, machinery
space waste streams and effective management of cargo related wastes.
 Sharing information with external stakeholders on environmental performance against EMS
objectives and targets.
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The Company establishes, implements and maintains appropriate Environmental Programs for
achieving its objectives and targets.
These Programs include:
 designation of responsibility at relevant functions and levels of the Company; and
 the means and time-frame by which they are to be achieved. These must be documented and
updated as environmental requirements change or as modifications occur in activities and
structures within the Company, in a manner that affects environmental performance or as a
result of recommendations made by any internal or external/third party auditor.
The objectives, targets, procedures and systems are part of routine operations related to the on-
going activities of the Company. Progress towards targets and objectives is reviewed at Safety
meetings onboard and at Management meetings ashore, as well as the need to reassess the
environmental impacts of Company’s activities. Where progress is less than planned, the
Company’s management intervenes to realign performance. Environmental performance targets are
monitored against appropriate Environmental Performance Indicators (EPIs).
Environmental Programs(EP)
Environmental Programs are established after the:
 Identification of Environmental Aspects.
 Identification of Environmental Impacts.
 Risk Assessment of the identified environmental impacts.
 Establishment of the Environmental Objectives and Targets.
In order to achieve the Environmental Objectives and Targets, the Company establishes
Environmental Programs. Reference is made to the “Management Programs” procedure.
These programs include :
 Designation of responsibility for achieving the objectives and targets at relevant functions and
levels of the Company.
 The means and time-frame by which they are to be achieved.
The Environmental Programs must be updated when:

 Environmental Requirements change.
 Modifications occur in the activities and structures within the Company in a manner that affects
environmental performance.
 Recommendations are made by any Internal or Third Party Auditor.
Each Environmental Program must be well documented. The “Management Programs” Form, is
used in order to document each Environmental Program providing the following data:
 Environmental Program Code (e.g EP-01).
 Objective.
 Overall completion deadline.
 Phase, description and due date for each.
 Person Responsible.
 Comments, as needed.
 Budget.
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During each Management Review Meeting:

 The existing Environmental Programs are reviewed for their progress.
 The programs are re-evaluated and re-assessed in connection to the Environmental Aspects and
Impacts of the Company’s activities.
 Where progress is less than planned, staff intervenes to realign performance with targets and
objectives.
 Performance Targets are monitored against appropriate Environmental Performance Indicators.
2.4 ENVIRONMENTAL MANAGEMENT REPORT

This section describes the procedure for compiling of the Environmental Management Report.
The Environmental Management Report is the basic “tool” in order to monitor the environmental
matters of the IMS and to evaluate compliance.
The Environmental Management Report details the Company’s Environmental Aspects, Risk
Assessment Evaluation, Impacts, Legal Requirements, Means of Influence of the Aspects,
Environmental Objectives, Targets and Plans.
Performance Targets are monitored against appropriate Environmental Performance Indicators
(EPI).
The Environmental Management Representative is responsible to collect all the required data from
the Office and Shipboard Departments, calculate the EPIs and fill-in the last column of the
Environmental Management Report.
See on next Page , Table “ Instructions for composing the Environmental Management Report”
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Instructions for composing the Environmental Management Report (Form E001)

Column Column Title Composing
1 Activity All the frequent and non-frequent activities of the Company are stated.
All the environmental aspects related to frequent and non-frequent activities
2 Aspect
of the Company are stated.
All the environmental impacts are stated. One activity may concern several
3 Impact aspects, and an aspect may result in several impacts. Accordingly, an impact
may arise from several different aspects related to several activities.
L Likelihood of the impact assessed.
S Severity of the impact.
Every impact is evaluated through the Risk Matrix. Relevant Color Code is
4 Evaluation applied.
Risk Aspect is NOT Significant – Broadly Acceptable.
Aspect is Significant – Tolerable.
Aspect is Significant – Intolerable.
All mandatory and non-mandatory requirements related to the specific
Legal and Ref aspect or impact are stated. The mandatory ones are marked by the use of
5 Normative red font, and the non-mandatory ones by the use of green font.
References
Limit Any limits to each environmental aspect are stated.
Specific policy Overall Company’s intentions to handle the aspect.
Routine Identification of a documented procedure (incorporated in the IMS or the
Means of Procedures EMS).
6 influence on Certification/R The required records for documentation and evaluation of the specific
the aspect ecords aspects.
Emergency
Emergency Response Plan, SOPEP/VRP, etc.
Plan
Description An Environmental Objective must be established for each aspect.
Envir/ntal
7 A code name EO-00X (X: consecutive number) is granted for each
Objective Code
Environmental Objective.
Description A measurable Environmental Target is established for each Objective.
8 Envir/ntal
A code name ET-0Y (Y: consecutive number) is granted for each
Target Code
Environmental Target.
A code name EP-0Z (Z: consecutive number) is granted for each
Scheduled Code
Environmental Program in order to meet specific Targets.
9 Programs
Milestone Scheduled deadline of the Environmental Program.
Status I: First Phase, II: Second Phase, III: Third Phase, etc.
10 EPI A numerical result of a specific formula for each environmental aspect.
 Whenever a change occurs to Company’s activities, aspects, impacts, legal and other
requirements, EPIs or objectives and targets, the form “Environmental Management Report” is
revised after Chief Operating Officer’s approval. It is also reviewed during the annual
Management Review. When an Environmental Program is either concluded or abandoned, the
relevant Environmental Target must be updated. The EMR keeps data and records (e.g. form
Vessel’s Specific Environmental Performance Workbook) and benchmarks the EPI values.
In case of unexpected deviations from the scheduled, he proceeds to the necessary corrective
and preventive actions.
 Vessel’s environmental reporting is achieved through the above mentioned form “Vessel’s
Specific Environmental Performance Workbook” and with regards to Environmental
Workbook (which constitutes part of SEEMP) the following must be noted:
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 “Vessel’s Specific Environmental Performance Workbook” has to be submitted by the

Vessel to the Environmental Department at the end of each month, as a monthly report.
 The monthly “Vessel’s Specific Environmental Performance Workbook” Report will be
post-processed by office Environmental Engineers and each Vessel’s results will be evaluated
and / or corrected.
 The aforementioned corrected reports will be:
 Forwarded back to each Vessel quarterly and will be electronically filed as SSEMP Annex,
under directory Common / SEEMP.
 Used to create the Office Environmental Management Review Meeting report which will be
sent back to each Vessel quarterly and will be electronically filed as SEEMP Annex, under
directory Common / SEEMP.
 The abovementioned SEEMP Annex will be updated every three months following Office
Management Review Meetings. In MRM document, Company’s Environmental Performance
Indicators (EPIs), Vessel’s individual performance for each EPI and Company’s average values
are indicated. Relevant graphs and statistics are also included.
2.5 IMPLEMENTATION AND OPERATION

The Company provides resources, capabilities, structures and supports mechanisms necessary to:
 achieve its environmental policy, objectives and targets;
 meet the changing of legal and other applicable requirements;
 communicate on EMS matters with Interested Parties; and
 provide for the ongoing operation and continual improvement of the EMS in order to improve
Company’s environmental performance.
To effectively manage environmental matters, the EMS is designed so that it is effectively aligned
and integrated with the IMS processes. Such integration can help the Company to balance and
resolve potential conflicts between environmental and other organizational objectives and priorities.
2.5.1 Resources, roles, responsibilities and authorities

The Company’s Management ensures the availability of sufficient personnel and other resources
essential to establish, implement, maintain and improve the EMS and to meet its objectives and
targets. Resources include human resources and specialized skills, organizational infrastructure,
technology and financial resources.
The Company recognizes and provides additional recourses and oversight required of older Vessels
within its fleet or of Vessels with increased workload due to trading patterns.
Roles, responsibilities and authorities of personnel both ashore and onboard are defined,
documented and communicated in order to facilitate effective environmental management.
The IMS defines the responsibilities of all seagoing and shore side personnel involved with the
operation, maintenance and repair of the Vessels, and indicates how they are held accountable for
achieving and maintaining compliance with the requirements of the EMS and other marine
environmental protection requirements.
The Company’s Management has appointed an Environmental Management Representative (EMR)
who, irrespective of other responsibilities, has a defined role, responsibility and authority for:
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 ensuring that the EMS is established, implemented and maintained in accordance with the
requirements of the ISO 14001 ( in cooperation with Company Environmental Committee
(CEC), referenced below); and
 reporting to Management on EMS performance, including recommendations for improvement.
The specific EMS responsibilities of EMR are presented in Appendix C of the Integrated
Management System Manual.
The members of the Company’s Environmental Committee (CEC) are:

 The Chief Operating Officer (COO).
 The Deputy Chief Operating Officer (DCOO).
 The Quality Assurance Representative / DPA.
 The Environmental Management Representative ( EMR).
 The Deputy Environmental Management Representative (if applicable).
 The Energy Efficiency Management Representative (EEMR).
 All the Office Department Managers.
 Any other Office Department staff, as required.
The CEC is responsible for the Environmental Management Review Meetings as well as for the
Special Meetings. Reference is made to “Management Review” procedure of this manual and the
relevant paragraph of this procedure.
Any member of the CEC may request for a special session of the CEC (e.g. by memo, e-mail, etc.)
addressing his request to the EMR, accompanied by a brief summary of the environmental topics
proposed for discussion.
The Office Department Managers and the Ship Masters are responsible to ensure that in their area
of responsibility:
 The requirements of the environmental matters of IMS are implemented effectively.
 Specified Environmental Objectives and Targets are met.
 Non Conformities are reported.
 Corrective Actions are taken.
 Data are collected and all necessary environmental Documentation is prepared.
Each Office and Shipboard Employee is responsible to effectively implement the responsibilities
assigned to him as per the Company’s IMS, and to exercise his authority/supervision/cooperation as
per the lines of authority and interrelations.
The members of the Ship’s Safety & Environmental Committee (SEC) are:
 The Master
 The Chief Engineer
 The Chief Officer
 The Safety Officer (if other than Chief Officer)
 Any other Deck and Engine Officer, as required.
 The Bosun
 The Cook and Messeman
 Any other Deck and Engine staff, as required.
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The objectives of the ships’ Safety & Environmental Committee (SEC) meetings with regard to
environmental issues include:
 have the environment protected by avoiding damage and preventing accidents;
 promote safe and environmental friendly working practices on board Vessel;
 advise the office of any experience or measure taken which may be of value to other Vessels;
 monitor and increase the effectiveness of the EMS and Company’s Policies; and
 motivate the crew in the observation of the Environmental and other Company’s Policies.
 assist the Master in organizing Safety & Pollution response drills.
The activities, discussions and decisions of the Shipboard Environmental Committee must be
included in the Monthly Safety Meeting under item “Ship’s Environmental Matters”, as per
procedure for conducting Safety Meetings.
The Environmental Management Representative and the Company Environmental Committee must
review and evaluate the proposals/decisions of the Shipboard Environmental Committees and
inform the other fleet Vessels, as required.
Other proposals on environmental issues may be made through :

 the Master’s Review Procedure
 IMS Review and suggestions for Amendments
2.5.2 Competence, Training and Awareness

The Company provides adequate resources to implement the EMS effectively and ensures that any
person performing tasks for the Company or on its behalf, that has the potential to cause an
identified significant environmental impact, is competent on the basis of appropriate education,
training or experience and retains associated records.
The Company identifies training needs of employees associated with the EMS, provides training
and takes all appropriate actions to meet these needs.
The Company has designed a training program to ensure competence within the whole organization
and establishes, implements and maintains procedures to make people working for it or on its behalf
aware of:
 the importance of conformity with the Environmental Policy and the EMS requirements;
 the significant environmental aspects and related actual or potential impacts associated with
their work, and the environmental benefits of improved personal performance;
 the operational, monitoring and contingency procedures;
 the day to day activities and the potential environmental impacts thereof;
 their roles and responsibilities in achieving conformity with the EMS requirements;
 the potential consequences of deviation from specified procedures, etc.
Proper training leads to compliance with legal and other requirements and can reinforce the
principles, goals and commitment to the EMS. Through the effective implementation of the IMS,
the Company ensures that all personnel whose job responsibilities affect the ability to achieve its
objectives and targets, have been trained and are capable of carrying out these responsibilities.
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Training is achieved by:

 Attending Training Seminars, Forums etc. on environmental subjects.
 Issuing Environmental Circulars issued by the Company.
 Viewing Computer Based Training (CBT), with subjects relevant to environmental issues.
 Issuing environmental articles in the Company Newsletter.
Reference is made to procedure “Training” of this manual.
2.5.3 Communication
With regard to its environmental aspects and the EMS, the Company has established, implements
and maintains procedures for:
 internal communication among the various levels and functions of the Company;
 receiving, documenting and responding to relevant communication from Interested Parties.
Everyone within the organization understands the concept of environmentally safe operations which
is promoted through leadership and sound management practices.
Department Heads measure and evaluate staff understanding of this concept through activities such
as ship visits, meetings, seminars and appraisals.
Ship-to-shore communication links and procedures are used to capture and promote best practices,
aiming to improvement of Company’s environmental performance.
Internal communication
Internal communication strategies include all stages involved in the process from the introduction of
the EMS to its implementation process. Internal communication is also essential in the up-keeping
and improvement processes generated by the EMS in the long-term perspective, and thus it is also
important after EMS implementation.
The Company establishes communication links to encourage information sharing through Circulars
and Bulletins, records every significant information and delivers it to the relevant personnel.
Environmental information is also relayed through established communication channels such as
management meetings, shipboard meetings, and web pages. Other communication tools are
Handouts/Letters, Information boards, open forums and conferences, etc.
External communication
The Company has a system to receive, document and respond to relevant communication from
external interested parties.
All external controlled documents are distributed to Vessels according to their content and intended
use.
Furthermore, the Company has decided to communicate externally about its significant
environmental aspects with interested parties, according to the following Table.
Our Environmental policy is available to the public, and beyond that we always consider the best
possible process for external communication on significant environmental aspects.
The IMS describes how environmental performance and compliance information is communicated
to external parties, authorities, vendors, technicians and other non-crewmembers onboard our
Vessels.
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Reference is made to Chapter 5 of the Integrated Management System Manual and Procedure
“Communication” of this manual.
Environmental Communication Plan
Interested Party Communication Method Environmental Topic
Accident or significant
violation of MARPOL or
1 Port and Coastal Authorities
- Meetings. other applicable
- Emergency communication as defined in legislation.
the SOPEP/VRP and in the SMS.
- VHF Channel 13.
Accident or pollution
2 Fire Service
emergency.
Notification of Company’s Environmental Management of

3 Client
Policy. Environmental Aspects.
Emergency communication as defined in Accident or pollution

the SOPEP/VRP and in the SMS. emergency.
-Terminal Authorities
4
-Shore Authorities
Notification of Company’s Environmental Management of
Policy. Environmental Aspects.
Accident or pollution
5 Local Municipalities Communication with authorities.
emergency.
Competence of personnel
Notification of Company’s Environmental
6 Manning Agents to handle emergency
Policy and SMS.
situations.
- Emergency communication as defined in
the SOPEP/VRP and the SMS.
- VHF Channel 16. Accident or pollution
7 Nearby Sailing Vessels
emergency.
Information material,
- Meetings, notification of Company’s management of
-Subcontractors Environmental Policy. environmental aspects
8
-Suppliers - Notification of relevant “Subcontractors relating to particular
Commitment” initiatives. suppliers of products or
services.
Proactive information,
- Attendance of Training Seminars and management of
Environmental Protection
9 incorporation of training material to information concerning
Associations
Company’s Training Plan. legal and other
requirements.
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2.5.4 Operational control

Operational control must be in place for all significant aspects in order to maintain required
performance.
The IMS identifies and provides for the planning and management of all Company’s operations and
activities with a view to achieving its objectives and targets.
The Company identifies and monitors all operations which are associated with the significant
environmental aspects, consistent with its Environmental Policy, objectives and targets, in order to
ensure that these are carried out under specified conditions, by:
 establishing, implementing and maintaining a documented procedure for the preparation of
plans and instructions for key shipboard operations;
 stipulating the operating criteria in the procedure;
 communicating applicable procedures and requirements to suppliers and subcontractors. Where
contractors can affect the environmental performance, the Company has control techniques to
assure maintenance of such environmental performance i.e. pre-selection procedures,
establishment of controls and specific contractor competencies, contract evaluation, etc.
All the environmentally critical operations relating to Company’s activities have been identified and
assessed (see “Environmental Management Reports”).
All operational procedures affecting environmental system integrity are included in the IMS, i.e.:
Cargo operations (loading, discharging), Emergency response, Drills and Training, Engine Room
operations, Ballast Management, Garbage Management, procedures/ records to ensure that
calibrated or verified monitoring and measurement equipment is used and maintained, sewage
treatment, purchasing, etc.
Some of the procedures for ensuring that these operations are performed under specified controlled
conditions are given in the columns “Means of Influence on the Aspect” and “Routine Procedures”
of the “Environmental Management Reports”.
2.5.5 Emergency Preparedness and Response

The Company has established, implements and maintains a documented procedure to identify
potential emergency situations and incidents that can have an impact on the environment and to
define how it will respond to them to prevent or mitigate associated adverse environmental impacts.
The IMS/SOPEP/SMPEP/VRP, etc., also establishes procedures for mitigating any adverse impacts
on the environment that may be associated with incidents or emergency situations and for ensuring
that similar incidents are avoided. If an environmental violation is resulted from a weakness in the
system, then the IMS is updated to minimize the likelihood of reoccurrence.
The Company periodically reviews and, where necessary, revises its emergency response
procedures. The Emergency Procedures Manual, along with the SOPEP/SMPEP/VRP, etc., aim to
minimise the impacts of an accident to the environment.
The Company monitors the compliance of these plans and, if needed, any revisions are submitted to
ship’s Flag Administration or Class Society for approval.
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2.6 CHECKING
Checking involves measurement, monitoring and evaluation of Company’s environmental
performance.
The process of identifying nonconformity in the EMS and taking corrective or preventive action
assists the Company to operate and maintain the EMS as it intends.
Corrective action consists of identifying and correcting problems in the EMS. Preventive actions
are used to identify and prevent possible problems before they occur.
Retaining records and managing them effectively also provides to the Company a reliable source of
information on the operation and results of the EMS.
Finally, audits of the EMS assist the Company to verify that the system is designed and operating
according to plan.
Reference is made to the corresponding procedures of this manual (Corrective and Preventive
Actions, Internal Audits, Control and Monitor of Measuring Devices etc).
The S&Q Department, which has the overall control of the Internal Audit Process, notifies the
Environmental Department, when during the Vessels’ ISO 14001 Audits, Non Conformities and
Observations are raised.
These data are used by the Environmental Department for Trend identification purposes, for
distribution to the Fleet Vessels and for the initiation of Environmental Campaigns.
The Results of Internal & External Audits including findings related to Environmental issues, are
presented in Environmental Department’s Management Review Presentations.
For the definition, maintenance and repair of Critical Equipment and Systems reference is made to
the Maintenance Manual.
Following equipment have been identified as critical due to their importance to the environment:
 OWS (including content meter).
 ODME.
 Incinerator.
 Sewage System.
2.7 ENVIRONMENTAL MANAGEMENT REVIEW

The Top Management reviews the EMS at planned intervals (quarterly) to ensure its continuing
suitability, adequacy and effectiveness. Reviews include assessing opportunities for improvement
and the need for changes to the EMS, including the Environmental Policy, objectives, targets and
programs.
Inputs to Management Reviews include:
 Changing circumstances, including developments in legal and other requirements.
 Review of the Company’s Environmental Policy, Environmental Objectives and Targets.
 Review and verification of the Company’s significant Environmental Aspects.
 Results of internal / external audits and inspections and evaluations of compliance with legal
and other requirements to which the Company subscribes.
 Master’s Review Reports / important & interesting proposals on environmental issues.
 Communication(s) from external interested parties, including complaints.
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 The Company’s environmental performance and the extent to which objectives and targets have
been met.
 Considerations for updating the system due to fleet changes, new trade and market strategies,
new regulations or changes in social and environmental attitudes.
 Follow-up and monitoring of the progress of Environmental Programs and preparation,
composition and approval of new Environmental Programs, according to identified training
needs.
 Checking and approving the updated issue of Environmental Management Report, taking into
consideration new developments, such as technological options, regulatory requirements and
results from running Environmental Programs.
 Checking of the updated issue of Legal and other Requirements List.
 Non-Conformities resulting from External & Internal Audits and various other Third Party
Inspections.
 Recommendations following Flag, USCG, PSC Inspections, Class Surveys.
 Status of preventive and corrective actions.
 Analysis of Accidents, Incidents and Near Accident related to environmental issues.
 Recommendations for improvement and follow-up actions from previous Management
Reviews.
The results must be tabulated to facilitate analysis and to identify trends and common problems.
Suggested improvements- if accepted during the Management Review Meeting- must be fed-back
into the Company’s continuous-improvement process.
Any progress which is identified to be less than planned, must result in a re-assessment of
objectives, targets and plans.
Outputs to management reviews include:

 Any decisions and actions related to possible changes to Environmental Policy, Objectives,
targets and other elements of the EMS.
 Improvement of the effectiveness of the Environmental Management System.
 New or amended Environmental Programs for the improvement of the Company’s
Environmental Performance.
 Additional Resource needs (office and shipboard personnel levels), if required.
 Additional Training Needs (if required).
Reference is made to procedure “Management Review” of this manual.
3. RECORDS
 Environmental Management Report PRO/PRO 25/ OFF/EMS/E001

 Environmental Program PRO/PRO 25/ OFF/EMS/E002
 Legal and other Requirements List PRO/PRO 25/ OFF/EMS/E003
 Vessel’s Specific Environmental Performance Workbook PRO/PRO 25/ SF/TEC/139
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ENERGY EFFICIENCY ISSUES Eff. Date: 29/02/2020
Contents
1. PURPOSE ..................................................................................................................................2
2. PROCEDURE ............................................................................................................................2
2.1 General ....................................................................................................................................2
2.2 Legal requirements and other requirements ............................................................................3
2.3 Energy Audit ...........................................................................................................................4
2.4 Energy Review ........................................................................................................................4
2.5 Energy Baseline ......................................................................................................................5
2.6 Energy Performance Indicators (EnPIs) .................................................................................5
2.7 Energy objectives, energy targets and energy management action plans ...............................6
2.8 Implementation and Operation ...............................................................................................6
2.8.1 Competence, training and awareness .......................................................................................................... 6
2.8.2 Communication ........................................................................................................................................... 7
2.8.3 Documentation ............................................................................................................................................ 7
2.8.4 Operational control...................................................................................................................................... 7
2.8.5 Design ......................................................................................................................................................... 9
2.8.6 Procurement of Energy Services, Products, Equipment and Energy ......................................................... 10
2.9 Checking ............................................................................................................................... 11
2.10 Monitoring and Reporting ................................................................................................. 12
2.11 Environmental Management Review ................................................................................ 14
2.11.1 Input to Management Review .................................................................................................................. 14
2.11.2 Output to Management Review ................................................................................................................. 14
3 RECORDS ................................................................................................................................... 14
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1. PURPOSE
The purpose of this procedure is to provide the steps to be followed, and to assign responsibilities in
order to conduct and document the energy planning process.
This procedure applies to the energy efficiency aspects of the company’s activities, operations and
services.
The Chief Operating Officer (COO) or Deputy COO, DPA and responsible Management
Representatives) has the overall responsible for Energy Planning.
The Energy Efficiency Management Representative is responsible for ensuring that the planning of
energy management activities is designed to support the Company’s environmental and energy
policy, for reviewing the results of energy audits and other energy review outputs, for establishing
the energy baseline and for calculating /analyzing the Vessels’ EEOI/EEDI and other relevant
Energy Performance Indicators (EnPIs).
2. PROCEDURE
2.1 GENERAL
The purpose of this section is the identification and evaluation of energy use, the definition of areas
with significant energy consumption and the identification of the opportunities for improving
energy performance.
An energy audit or assessment comprises a detailed review of the energy performance. It is
typically based on appropriate measurement and observation of actual energy performance.
Audit outputs typically include information on current consumption and performance, and they can
be accompanied by a series of ranked recommendations for improvement in terms of energy
performance.
Energy audits are planned and conducted as part of the identification and prioritization of
opportunities to improve energy performance.
The Energy Management Representative is supported in his responsibilities as the appointed
Management Representative for the EnMS by an Energy Management Team, the aim of which is to
provide an effective mechanism to engage different parts of the Company in the planning,
implementation and monitoring of the EnMS.
The Energy Management Team has the following main members, being the focal persons in the
Company responsible for effective implementation of the EnMS activities and for delivering energy
performance improvement:
 EnMR
 Technical Manager
 Operations Manager
 DPA, as the Chairman
The appointment of the members of the Team shall be endorsed by the COO or Deputy COO.
Additional personnel may be invited on an ad-hoc basis to participate in the Team, as need be.
The Energy Management Team will meet at least on a quarterly basis, preferably prior to the
Management Review Committee and at any other time, as is deemed necessary by its Chairman.
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2.2 LEGAL REQUIREMENTS AND OTHER REQUIREMENTS

The applicable legal and other requirements to which the Company subscribes related to the
shipboard energy use, consumption and efficiency shall be identified and implemented.
The procedure for the identification of these requirements is explained in Integrated Management
System Manual and is similar to the requirements of “Environmental Issues” procedure.
The current legal and other requirements related to the energy use, consumption and efficiency
onboard ships are listed in the following table and are considered in establishing, implementing
and maintaining the EnMS.
The legal and other requirements (international, regional, national, and local requirements) shall be
reviewed during the Management Review Meetings and below table shall be updated, as need be.
Legal Requirements
IMO Resolution MEPC.203 (62) MARPOL Annex VI Amendments and in particular
Chapter 4 “Regulations on Energy Efficiency for Ships”.
Amendments in Resolution MEPC.251 (66).
IMO MEPC.1/Circ.684 “Guidelines for voluntary use of the ship energy efficiency
operational indicator (EEOI)”.
IMO Resolution MEPC.282(70) “2016 Guidelines for the Development of a Ship Energy
Efficiency Management Plan (SEEMP)”
IMO Resolution MEPC.308 (73) “2018 Guidelines on the Method of Calculation of the
Attained Energy Efficiency Design Index (EEDI) for New Ships”.
IMO Resolution MEPC.254(67) and its amendments MEPC.261(68), MEPC.309(73)
“2014 Guidelines on Survey and Certification of the Energy Efficiency Design
Index (EEDI)”
Other requirements
INTERTANKO Guide for Tanker Energy Efficiency Management Plan
OCIMF Guide for Energy Efficiency and Fuel Management

OCIMF Virtual Arrival - Optimizing Voyage Management and Reducing Vessel
Emissions - an Emissions Management Framework
ExxonMobil Marine environmental, safety and quality assurance criteria for seagoing
industry Vessels in ExxonMobil affiliate service, 2010 Ed., Rev.: 01 - Appendix
A: additional criteria for term chartered tonnage -Section U. Energy efficiency
and fuel management
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2.3 ENERGY AUDIT

The company uses the Energy audit as the main technique by which is performed a holistic and
systematic energy performance assessment of the ship as well as its energy producing and
consuming systems.
The main objective of the energy audit, which is performed on a yearly basis, is to gather required
information of ship energy performance including analysis of energy use and consumption,
evaluation and comparison of the past and present energy consumption and setting of Energy Key
Performance Indicators (EnPIs) that must be adequately adjusted for improving ship’s energy
efficiency.
An initial energy audit and assessment is carried out onboard Vessels of the Company’s fleet for
identifying all equipment and systems which consume energy, setting the energy baseline for future
comparison purposes and suggesting energy targets.
2.4 ENERGY REVIEW

Energy review is the determination of the Company’s energy performance based on data and other
information, leading to identification of opportunities for improvement.
The energy review must be carried out/updated, as need be, on an annual basis, during the
Management Review Meeting.
The update of the energy performance review might be also required in response to major changes
in the fleet or equipment, systems, or processes onboard.
The methodology and criteria used to develop the energy review is as follows.
Input to the Energy review
The input to the Energy review must be the following:
 New/revised legal and other requirements.
 Bunker consumption data (past and present) for the fleet Vessels.
 Voyage patterns and operational profile of fleet Vessels.
 Energy audits carried out onboard fleet Vessels.
 The Electric Load Analysis booklet of the fleet Vessels.
 The identification of any new energy sources for onboard use, in addition to the use of fuel oil.
 The market projections and how the expected freight rates are expected to affect the energy
consumption.
 Results of the implementation of the EnMS.
 Benchmarking data.
 Activities of service contractors that could affect energy consumption.
Analysis of the energy use and consumption
The data and other input to the energy review, as explained above, must be analyzed with the view
to identifying the areas of significant use onboard the fleet Vessels.
In particular, the following must be identified:
 Facilities, equipment, systems, operations onboard the fleet Vessels that significantly affect
energy use and consumption.
 Crew operational practices that have the potential to significantly affect energy use and
consumption.
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 Type of fleet Vessels having the highest energy consumption.

 Categories of voyages/cargoes that present the higher energy consumption.
 The current energy performance of the Vessels (bunker consumption and laden/ballast voyage
distance); and
 Estimated future energy use and consumption, taking into account market projections.
Identification of energy improvement opportunities
The final stage of the energy review is the identification, prioritization and recording of the
opportunities for improving energy performance.
The assessment criteria for the energy improvement opportunities are:
 their cost effectiveness (i.e. cost for implementation vs. energy efficiency benefit); and
 their potential for implementation to newbuilding and/or existing Vessels.
The opportunities must be categorized in the following basic areas:

 Voyage optimization.
 Propulsion resistance management.
 Machinery optimization.
 Cargo handling optimization.
 Bunker management.
 IT and other household equipment replacement.
 Minimize incinerator use.
 Crew energy efficiency awareness, training and familiarization.
2.5 ENERGY BASELINE

The Company has established and uses as an Energy Baseline the Energy Efficiency Operational
Indicator (EEOI), as defined by the IMO Circular MEPC.1/Circ.684 guidelines.
This Indicator serves as an overall indicator of the energy efficiency of the transport work carried
out by the fleet Vessels.
The EEOI is calculated on a quarterly basis and on a 12-months rolling basis for each fleet Vessel.
It is also averaged by ship type to evaluate the overall performance and carry out benchmarking.
The methodology for calculating the EEOI is set out in the IMO Circular MEPC.1/Circ.684
“Guidelines for voluntary use of the ship energy efficiency operational indicator (EEOI)”.
The Company shall evaluate the effectiveness of the set Energy Baseline and adjust it as necessary.
2.6 ENERGY PERFORMANCE INDICATORS (ENPIS)

The Company has identified EnPIs appropriate for monitoring and measuring the shipboard energy
performance.
The EnPIs have been determined with the aim of:
 providing a quantitative value to enable the monitoring of the effectiveness of the set energy
management action plans in meeting the set targets;
 allowing a comparison to be made between fleet Vessels.
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The set EnPIs (e.g. M/E Specific Fuel Oil Consumption) are set out in the:
 Company Energy Efficiency Management Plan (CEEMP) and
 Ship Energy Efficiency Management Plan (SEEMP)
Both above Plans shall be reviewed and updated during the annual Management Review Meeting
and when business activities or baselines that affect the relevance of the EnPI change.
2.7 ENERGY OBJECTIVES, ENERGY TARGETS AND ENERGY MANAGEMENT ACTION PLANS
The Company has established, implements and maintains documented energy objectives and targets
for the shipboard operations, processes and facilities.
Time frames have been established for achievement of the objectives and targets.
The set objectives and targets are consistent with the energy policy and the set targets are consistent
with the objectives.
In establishing and reviewing objectives and targets, the Company has taken into account legal and
other requirements, significant energy consumers and opportunities to improve energy performance,
as identified in the energy review.
It has also considered its financial, operational and business conditions, technological options and the
views of interested parties (such as Charterers).
The Company has established, implements and maintains action plans for achieving its objectives and
targets.
The action plans include:
 designation of responsibility;
 the means and time frame by which individual targets are to be achieved;
 a statement of the method by which an improvement in energy performance shall be verified;
 a statement of the method of verifying the results.
The set energy objectives, targets are action plans are documented in the CEEMP and the SEEMP
and shall be reviewed on an annual basis and updated as need be with the view to ensuring
continual improvement.
2.8 IMPLEMENTATION AND OPERATION

The implementation of the set action plans/energy efficiency measures is carried out in accordance
with the procedures and guidance provided in the CEEMP and the SEEMP.
2.8.1 Competence, training and awareness

Company’s personnel (ashore and onboard) must be aware of the energy management procedures and
initiatives that are in place with the aim of ensuring the proper implementation of the EnMS and
continually improving energy efficiency.
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Therefore, parallel to the procedure “Training” of this manual, the following must be implemented:
Energy efficiency awareness

A specific energy efficiency awareness Campaign must be rolled out to the fleet on an annual basis
with the view to raising awareness on shipboard energy efficiency and providing information on best
practices and the relevant initiatives implemented by the Company.
Shipboard familiarization
Officers must be familiarized on the procedures and practices contained in the SEEMP & CEEMP, as
part of their initial onboard familiarization.
Shore Training
An in-house training course on “Shipboard Energy Efficiency and Management” must be carried out
at least annually with the view to improving crewmembers awareness of onboard energy efficiency
and areas in which energy can be conserved.
The aim is to integrate energy saving management into general ship management operations and to
ensure that all relevant information is being used and understood by the crew.
Incentive Program
At least once per year, the EnMR must launch a “Energy Saving Idea” campaign inviting seagoing
personnel of all fleet Vessels to put forward proposals on improving energy efficiency onboard.
The Company, upon the collection of the “Energy Saving Ideas” submitted by the fleet Vessels, will
evaluate them and select one for implementation on a fleet level.
A special “award” will be given to the Vessel having submitted the “selected” idea.
Appropriate records shall be maintained.
2.8.2 Communication
The Company shall communicate internally with regard to its energy performance and EnMS, by
circulating to the fleet the relevant report from the Management Review Meetings.
Any shore or seagoing personnel can make comments or suggest improvements to the EnMS.
Any external communication about the Company’s energy policy, EnMS and energy performance
shall be considered on a case-by-case basis and it shall be subject Chief Operating Officer (COO) or
Deputy COO’s approval. The approval shall indicate the method for this external communication.
2.8.3 Documentation
The EnMS documentation is set out in this Integrated Management System, in the CEEMP and the
SEEMP.
2.8.4 Operational control

The operations and maintenance activities which are related to the Company’s significant energy
uses are set out in the CEEMP and the SEEMP and are consistent with its energy policy, objectives,
targets and action plans.
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The following aspects are covered:

Τrim, which has a significant effect on ship’s resistance; the optimization of the trim may result in
significant fuel savings.
For any given draught there is a trim condition that results in minimum resistance.
The company uses various tools in order to optimize Vessel’s trim taking into account the cargo
capacity & the weather conditions. Parameters such as hull, propeller pitch, and Main Engine
behaviour and water depth are combined in order to calculate the most efficient operating condition.
The ship speed and propulsion power, which are not linearly related, therefore in order to
increase the speed by 1 knot to reach 14 knots, much more power is needed than to do the same
when at 12 knots. As the speed increases, more power is needed to achieve the desired speed.
Eventually, a speed barrier is reached, often called the “wave wall”. This enormous increase in
power for further acceleration of the ship is caused by the equally enormous increase of the hull’s
wave resistance, i.e. the resistance caused by the waves produced when the ship is moving through
the water.
Speed optimization can produce significant savings. However, optimum speed means the speed
where the fuel used per tonne-mile is at a minimum level for that voyage. It does not mean
minimum speed; in fact, sailing at less than optimum speed will eventually result in burning more
fuel.
Where is practical for commercial purposes, the company’s objective is the Vessels to sail with the
economical speed in order to reach a particular port at a specific time or to maintain the Charter
Party ordered speed on the loaded voyage leg. In the case of ballast leg, the economical speed is
optimized when the Master is timely notified for the loading port and the lay-days prior to or soon
after Vessel’s departure from the last discharging port.
The influence of weather on Vessel’s consumption is undisputable. The weather that Vessel will
encounter across the intended passage has to be analysed, both ashore and onboard, and the
optimum passage with regard to passage time/FO consumption has to be selected. Various weather
inputs/reporting sources are available both on-board and ashore.
Regarding the method of ballast water exchange/treatment, the company prefers to use the
sequential method which is the most energy efficient. Its advantage on energy efficiency is that it
takes less time than the flow-through or dilution method as only pumping out and refilling of tanks
is required.
As the fouled hull & propeller increases the hull resistance that the Vessel has to confront, the
fuel consumption of the Vessel & consequently the energy efficiency & the environmental impact
significantly increase. The company tries to minimize the time interval between the underwater
cleanings & propeller polishing when it is permitted by the circumstances such as the trading
pattern of the Vessel.
Regarding the power management on-board such as the use of generators and boilers, the
company seeks to optimise their energy efficiency. Low D/G loads (below 40%) have an adverse
effect to the operation of the engine (particularly the FO system and cylinders) leading to increased
maintenance costs and accelerated wear of engine components.
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Due to these reasons it is prudent to exercise efficient load management, with the aim to minimize
the number of running generators and maximize their load factor, when possible and safety
permitting.
The total electricity demand will be the same, but less operating engines at higher load (i.e. lower
SFOC) translates to reduced fuel consumption.
A single diesel generator is normally capable to sustain the electrical load while the Vessel is sailing
without other activities in place.
The boilers’ running is optimized with minimizing unnecessary fuel consumption and monitoring
operation parameters as per maker’s instruction manual.
Depending on the operational mode & condition of the Vessels (sailing or at port) it is required that
specific number of DGs must operate under certain load as per electrical balance calculations.
It must be noted that energy performance has not been included in the planning for contingency or
emergency situations, since priority in such cases must be given to the safety of the human life at sea
and the protection of the environment.
2.8.5 Design
Energy Efficiency Design Index
All fleet Vessels for which the building contract is placed on or after 1 January 2013 or in the absence
of a building contract, the keel of which is laid or which is at a similar stage of construction on or after
1 July 2013 or the delivery of which is on or after 1 July 2015, must have an attained Energy
Efficiency Design Index (Attained EEDI) less or equal than the Required EEDI as this is defined in
Regulation 21 of MARPOL Annex VI. (Guidelines amended in 2018 by Resolution MEPC.308 (73)).
New installations or retrofits

The Company is committed to consider energy performance improvement opportunities and
operational control in the design of new, modified and retrofitted facilities, equipment, systems and
processes that can have a significant impact on its energy performance. The results of the energy
performance evaluation shall be incorporated where appropriate into the specification, design and
procurement activities of the relevant project(s).
Cooperation with Marine Industry Stakeholders

As part of the Company’s ongoing energy efficiency initiatives, the Company motivates ship-builders
and ship-designers in implementing technical measures and design changes that would enhance the
energy efficiency of our new-building projects.
These include, amongst others, the following: ships’ hull form improvement; use of additional
hydrodynamic efficiency devices; new type of energy efficient main engines, redesign of the propeller;
new-technology turbochargers; turbocharging cut off; installation of shaft generators/turbo generator;
modified designs of the accommodation blog to reduce air drag etc.
Research and Development (R&D) projects

The Company aims to cooperate with national / international Academic institutions and universities
and to participate in various Research and Development projects and other similar programs, in co-
operation with other industry partners, with the aim of developing methodologies/tools for the
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implementation of energy efficient operational measures and the retrofitting of energy efficiency
technologies onboard Vessels.
The results of the design activity shall be recorded.
2.8.6 Procurement of Energy Services, Products, Equipment and Energy

Reference is made to “Purchasing” procedure of this manual.
General
Procurement is an opportunity to improve energy performance through the use of more efficient
products and services. It is also an opportunity to work with the supply chain and influence its
energy behavior. Therefore, when procuring energy services, products and equipment that have, or
can have, an impact on significant energy use, the Company shall inform suppliers that procurement
is also evaluated on the basis of energy performance.
Purchasing of IT and household equipment

When purchasing products where an ENERGY STAR specification is applicable (i.e. computers,
monitors, copiers) the Purchasing Managers shall ensure that only equipment that meet the
ENERGY STAR specifications for energy efficiency are procured.
The above-mentioned policy of installing “energy saving” devices must be applied to the
procurement of other household devices such as refrigerators, microwave ovens, washing and
drying machines.
Fuel Oil Purchasing

All fuels are purchased against the internationally recognized standard ISO 8217:2005. In addition,
all distillates bunker supplies arranged by the Company must comply with the DMZ specification
(as per the ISO 8217:2005) with maximum sulfur content as per applicable rules and regulations.
Before ordering bunkers, each ship must calculate the expected bunker consumption and verify the
amount with the Operations Department.
As a minimum, Vessels must have enough bunkers onboard to complete the current voyage,
maintaining also a safe margin for reserve as set out in “Bunkering” procedure of the Shipboard
Operations Manual.
The decision to carry excess bunkers above the above-mentioned quantity is to be justified by
economic and operational considerations.
Factors that can influence this decision include bunker cost, quality, the absence of firm orders, and
cargo heating requirements.
Fuel Oil Analysis

Fuel samples are collected from every bunkering and are retained under the ship’s control until the
fuel oil is substantially consumed, but in any case for a period of not less than twelve months from
the time of delivery.
Furthermore, the Company is monitoring closely the quality of the bunkers by using a service
provider for the independent verification of fuel quality.
Fuel Oil analysis ensures that the certain parameters that affect the fuel oil calorific value (e.g.
density, water content, calorific value, ash) are closely monitored.
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2.9 CHECKING
The key characteristics of the shipboard operations that determine energy performance must be
monitored, measured and analyzed at set intervals.
Key characteristics shall include at a minimum:
 significant energy uses and other outputs of the energy review;
 the relevant variables related to significant energy uses;
 EnPIs;
 the effectiveness of the action plans in achieving objectives and targets;
 evaluation of actual versus expected energy consumption.
The results from monitoring and measurement of the key characteristics shall be recorded in the
Management Review minutes.
The S&Q Department, which has the overall control of the Internal Audit Process, notifies the
Environmental Department, when during the Vessels’ ISO 50001 Audits, Non Conformities and
Observations are raised.
These data are used by the Environmental Department for Trend identification purposes, for
distribution to the Fleet Vessels and for the initiation of Energy Efficiency Campaigns.
The Results of Internal & External Audits including findings related to Energy Efficiency issues, are
presented by the Environmental Department during the Management Review Meetings.
The proper implementation of the monitoring system relies on accurate and verifiable collection of
data. Since collection of quality data is normally a practical issue, it is important that all the
available data sources are identified and used.
For ship energy performance monitoring and benchmarking, the following data sources could be
used:
 Ship’s technical specification.
 Speed trial reports.
 Engine’s “NOx Technical File” that includes engines’ performance data.
 Operational data logs/noon reports.
 Data from dedicated trials.
 Engine Logbook.
 Bridge Logbook.
 Oil Record Book / Bunker Delivery Notes/Fuel oil analysis reports.
Additional data could be utilized, as appropriate.
The relevant data/records to be monitored/collected depend on each energy efficiency measure
implemented and are set out in the CEEMP and the SEEMP.
Any identified significant deviation in energy performance must be investigated and responded as
need be.
Any equipment used in monitoring and measurement of key energy characteristics must provide
accurate and repeatable data and for this reason records of calibration and other means of
establishing accuracy and repeatability shall be maintained.
Results of the above-mentioned activities shall be maintained and included in the relevant sections of
the Management Review Meeting reports.
At every Management Review Meetings, the Company shall evaluate compliance with legal and
other requirements to which it subscribes, related to its energy use and consumption.
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Records of the results of the evaluations of compliance shall be maintained.
2.10 MONITORING AND REPORTING

The company’s daily reporting & monitoring plan includes the Main Engine, the Diesel Generators,
Fresh Water Production, Boilers and Auxiliaries.
With the use of different types of software, the evaluation of the data reported from the Vessels in
Noon Reports (both sailing in laden and ballast condition and when the Vessels are at ports), is
performed in order to calculate the fuel consumption.
When the Vessel is sailing both in ballast and laden condition, the fuel oil consumption of the Main
Engine, the Auxiliary Engines, the Boiler & the IG are monitored on a daily basis.
Taking into consideration, the weather, sea state & wind direction that are reported in Noon Reports
& cross checked with online weather software, the fuel oil consumption is evaluated in comparison
with Vessel’s performance taken from the corrected with sea margin & Vessel’s condition sea trials
curves.
The company closely monitors the hull & propeller condition of the Vessels & accordingly updates
the tables that correspond to the indicative fuel oil consumption of every Vessel.
Regarding the staying at port and anchorage, the fuel oil consumption for the Main Engine,
auxiliaries, IG & Boiler is monitored on a daily basis with the Noon Reports at port.
Extended period of staying in the same port is taken into consideration in order to re-evaluate the
hull & propeller fouling.
Regarding the Auxiliaries, a report is compiled on a daily basis for all Vessels (whether anchored or
sailing) that includes the number of Diesel Generators that are in use, how many hours operating
and at which load (KW). The company tries to minimize the running of DGs by closely monitoring
the reasons of running a 2nd one.
The sequence of DGs running is decided from the office based on the elimination of the Lube oil
Consumption and on energy efficiency reasons which are affected from TBOs.
On a weekly basis, a form that reports how many hours every diesel generator was running, if the
sequence has been followed and the reasons for running a 2nd or even 3rd generator has been used
along with the reasons for not following the sequence, is being produced.
In addition, a form that reports the Lube Oil Consumption for every auxiliary engine is prepared on
a monthly basis in order to monitor the relative consumption or to proceed with the needed actions.
Based on these forms, the company proceeds to the reporting of the Lube Oil Consumption for each
one Diesel Generator of every Vessel with purpose to minimize the consumption by change of
sequence or proceed to the required corrective actions / overhauls.
Furthermore, a monthly form that reports testing at 80% load for every auxiliary is submitted in
order to evaluate the condition of each engine at the relevant load. (SF/TEC/102).
With regard to Main Engine, the company monitors on a weekly basis the performance of every
Engine on the sailing load.
Every time that for commercial reasons, the Vessel is requested to increase her speed or proceed in
slow steaming, a performance report is requested by Vessel or checked by online monitoring system
in order to reassure that the Vessel’s main engine can correspond to the relevant load & all the
parameters are within Maker’s limits.
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On a monthly basis, the last main engine performance received from the Vessels and for
Vessels equipped with online monitoring system their main engine condition in 70 to 75% of
load are reviewed for calculation of Specific Cylinder Oil Consumption (gr/kWh).
Reports are evaluated for further actions as they might be needed.
The report is compiled after evaluating data from Engine Performance reports and the online
monitoring systems, where installed. Comparison with Engine baseline criteria is made.
Based on the Main Engine Performances received from the Vessels and from online software, the
company reviews on a monthly basis the hull condition & propeller polishing and benchmarks the
Vessels’ performance.
The benchmarking is done into three categories based on the increase of the Brake Horse Power in
comparison with the Sea Trials Curves after draft, weather and age corrections.
The purpose is to closely monitor the hull & propeller condition and proceed to the required
corrective actions (Underwater Inspections and if required Underwater Cleaning & Propeller
Polishing) especially after extensive staying.
The process of Underwater Hull Cleaning is complex as it is affected by many parameters.
The trading pattern of the Vessel, the ports that calls (availability of divers & cost that arises) & the
time that the Vessel has available between operations at anchorage, affect significantly in
company’s decisions.
The decisions are taken based on the Vessels’ daily monitoring of the consumption & the monthly
categorization of the hull condition into three main categories (green, yellow & red). So, an
Underwater Inspection is arranged when the reported Vessel’s consumption is above company’s
standards for many days without bad weather & when the monthly condition of the Vessel is in red
colour. The red colour of the performance status means that the Brake Horse Power of the Main
Engine of the Vessel is 15% above the Sea Margin of the Vessel compared with the Sea Trials
Curves after draft, weather and age corrections.
The Company’s policy regarding the Propeller Inspection is to be carried out on annual basis & if
necessary to proceed with an Underwater Propeller Polishing.
The monitoring of the time interval between the last Propeller Polishing & the time that has passed
is done on a monthly basis with the preparation of relevant table.
Monthly statistics for the sludges and bilges produced relative to the days that the Vessel was
underway act as an indicator in order to closely monitor the engine room waste.
The VOC emissions / releases for the Vessels carrying Crude Oil are monitored & reported as per
the relevant Emission Calculation Spreadsheet included in the Vessels’ specific VOC Management
Plan.
The company promotes the installation of real time performance monitoring & comparative analysis
systems on the Vessels.
The system might support an engine diagnostic tool that monitors fuel consumption rate and shaft
horsepower.
The provided online data is collected and evaluated in order to proceed with corrective actions as
needed.
For Main Engines fitted with such systems by Engine Maker, auto-tuning functions are available
and must be exercised.
Regarding the European MRV Regulation that took effect from 1st January 2018 for Vessels calling
at European Ports and for IMO DCS that took effect on 1st January 2019 for Vessels calling all ports
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worldwide, the company has prepared a reporting form that includes all the required data in order to
monitor the Fuel Oil Consumption & the CO2 emissions accordingly.
This form includes data as the RPM, distance travelled in Log speed & GPS speed accordingly,
steaming time per day & since start & the Fuel Oil Consumption.
By processing this data, the company corrects if needed the reported measurements regarding the
weather conditions with online software.
The measurement of deviation between the reported data from the Vessels & the theoretical method
is done using a backup theoretical method.
The purpose is the deviation between them to be within the percentage of 5% (plus or minus).
For above actions please refer to Technical Forms.
2.11 ENVIRONMENTAL MANAGEMENT REVIEW

The Company’s Top Management shall review the EnMS to ensure its continuing suitability,
adequacy and effectiveness.
2.11.1 Input to Management Review

Inputs to the Management Review shall include:
 follow-up actions from previous Management Reviews;
 review of the energy policy;
 review of energy performance and related EnPIs;
 results of the evaluation of compliance with legal requirements and changes in legal and other
requirements to which the Company subscribes;
 the extent to which the energy objectives and targets have been met;
 EnMS audit results;
 the status of corrective actions and preventive actions;
 projected energy performance for the following period;
 recommendations for improvement.
2.11.2 Output to Management Review

Outputs from the Management Review shall include any decisions or actions related to:
 changes in the energy performance of the Company,
 changes to the energy policy,
 changes to the EnPIs,
 changes to objectives, targets or other elements of the EnMS, consistent with the Company’s
commitment to continual improvement,
 changes to allocation of resources.
Reference is made to procedure “Management Review” of this Manual.
3 RECORDS
None
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MANAGEMENT OF CHANGE Eff. Date: 30/09/2022
Contents
1. PURPOSE ..................................................................................................................................2
1.1 Identifying the need to make a Change & Sources of Information ........................................2
2. PROCEDURE ............................................................................................................................2
2.1 General ....................................................................................................................................2
2.2 Identification of Changes ........................................................................................................7
2.3 Risk Assessments ...................................................................................................................7
2.4 Approval / Action Plan / Verification of Change ...................................................................7
LEVEL OF AUTHORITY FOR THE APPROVAL OF CHANGE .........................................9
LEVEL OF AUTHORITY FOR THE APPROVAL OF CHANGE .......................................10
2.5 Implementation and Monitoring ...........................................................................................11
2.6 Review of Effectiveness of Change During Management reviews Meetings ......................12
3. RECORD ..................................................................................................................................12
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1. PURPOSE
This procedure describes the steps to be followed by the Company, both ashore and onboard, for
identifying the need for changes , evaluating and managing changes to the IMS, Ship’s Equipment
(including modifications), Materials, Office and Shipboard Personnel , and all other as, described in
this Procedure, to ensure that safety and environmental standards are not compromised.
In addition, the Company reviews and controls temporary and permanent changes that have an impact
on occupational health and safety performance.
1.1 IDENTIFYING THE NEED TO MAKE A CHANGE & SOURCES OF INFORMATION

The Company has identified sources of information for emerging requirements for change, imposed
either by Legislation or by Industry requirements and best practices.
Sources of information may include:
 Code of Safe Work Practices,
 Publications and Guidelines issued by Classification Societies,
 Flag Administration Publications,
 TMSA,
 Information and updates from Private Maritime Security Companies,
 INTERTANKO,
 IMO,
 OIL Majors Requirements,
 ITOSF,
 MARTECMA.
2. PROCEDURE
2.1 GENERAL
Management of Change is a Planning Tool

Management of Change (MOC) is a systematic approach to assess and manage the risks associated
with a change BEFORE the change is made.
Even Minor changes may affect safety if they are not properly carried out.
Management of Change must not be confused with the procedure for Master’s Reviews which mainly
include proposals for IMS Changes. The Management of Change, as applied onboard, is the process
during which the Shipboard Personnel may propose changes in the Vessel’s structure and equipment.
The primary objective of a MOC process is to manage the risk associated with a change in order to
reduce the likelihood of unsafe situations arising.
The MOC process applies to all levels of an organization and to all the activities.
Approval of any changes must be given by the appropriate level of Management, in order to ensure
that the associated risk assessed by suitable personnel and effective control measures are taken for
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safeguarding the health and safety of people, the environment and the property as well as the
Company reputation.
Any change must comply with International, National Regulations and Company procedures.
MOC is applied to both temporary and permanent changes to ensure that un-intended consequences
are foreseen and mitigating actions are included in the change.
Following a MOC process correctly will ensure that training needs arising from the change are
identified and incorporated within both the shore and onboard training programs.
Furthermore, it will ensure that changes are incorporated into the ship’s operational manuals,
procedures, guides and drawings.
Efficiency will be brought to the Company by ensuring that

changes are completed within a defined time scale and scope.
Clarity of the MOC will come from having a clear and well documented process that is available to
all levels of the organization.
Each Office Department is responsible to initiate and monitor the Management of Change of any
activities related to the responsibilities of the Department, by issuing the Management of Change
form and securing the approvals, as required.
Each Shipboard Department (Deck or Engine) is responsible to initiate and monitor the
Management of Change of any activities related to the responsibilities of the Department, by issuing
the Management of Change form and securing the approvals, as required.
The key elements of a MOC process are:

 Definition of levels of authority and approval,
 Defined process of change,
 Risk Assessment Process,
 Controls at key stages,
 Review of the change process and corrective action (if required).
Changes may be effected in:

 Organizational Structure
o New Department,
o New positions,
o Change in authorities and responsibilities,
o Elimination of positions,
o Merging or splitting of Departments.
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 Company Policies and Gained Experience

o Policy statements,
o Mission and Visions,
o Field of activities,
o Incidents, Accidents, Near Misses and Ships Equipment Failures,
o Information from the Maritime Community,
(e.g. Flag State, IACS, P&I Clubs, IMO, BIMCO, etc),
o Outputs of Management Review and Safety Meetings,
o Changes in the applicable Standards and Codes,
o Changes in the legislation related to company’s and shipboard activities.
 Integrated Management System
o New procedures,
o Revisions on existing procedures that change the actions to be followed (editorial revisions
are not included),
o Total re-issuance of IMS (change of documentation Structure etc).
 New Legislation
 New Types of Vessel in the Fleet
 Change of Name, Class, or Flag of a Vessel
 Acquisition of a new Vessel
 New Tonnage under Management
o New ship type acquisition.
o Second hand Ship acquisition.
 Merger/ Restructuring of Fleet
 Technical Changes
o Major Repairs, including Modification,
o Change of Ship’s Equipment (manufacturer / technology etc),
o New constructed Ship acquisition,
o Changes to any Bridge or E/R equipment or system,
o Changes to Cargo or Ballast Systems,
o Installation of a new equipment or system (i.e Scrubbers, Ballast Water Treatment Systems),
o New Flag regulations affecting the technical condition of the Vessel,
o New Classification regulations affecting the technical condition of the Vessel,
o New technological solution available in the market,
o By-pass arrangements for equipment normally in service,
o Temporary isolation and re-activation of alarms for maintenance purposes,
o Structural modifications of the ships, including means of access,
All drawings and Technical Manuals are indexed and controlled by the Technical Department
ashore and the Master/ CE onboard. Where amendments have been made, the Technical
Manager must ensure that previous Drawings /Technical Manuals are either removed from
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use and replaced or changed and updated with the latest information, the issue status and date
of any amendments must be clearly recorded on the Plan, Drawing or Technical Manual itself.
 Operational Changes
o Change of Trading Area (i.e. navigating in areas with special conditions (in rivers or in ice),
o Change in Market Condition,
o Change in the contractual agreements with our customers (e.g. a fundamentally different
charter party),
o Change in political environment (e.g. war),
o Change of Type of Cargo (i.e. committing to carry cargo with extra-ordinary characteristics,
planning an unusual cargo operation (e.g. discharge in barges)),
 Change and/or upgrades to Software or new installation of Computer Software / Hardware ashore
and onboard.
 Human Resources Changes

o Change in the Vessel’s Manning Level,
o Additional Crew onboard for a specific time period, to carry out maintenance work, STS
operations etc,
o Change in Crew Nationality (i.e. cultural differences, new Nationality language etc),
o Changes in Office Personnel (Internal Transfers or New Employment),
o Major shore organization changes,
o Re-assignment of responsibilities of Shore Staff,
o New Shore staff (for major shore staff changes a detailed review of the impact must be
carried out),
o Change in Shipboard Personnel (Large crew changes, New Flag or International
requirements related to crew composition or competency etc).
 Occupational Health and Safety Changes

o New products, services and processes, or changes to existing products, services and
processes, including workplace locations and surroundings, work organization, working
conditions, equipment and work force,
o Changes to legal requirements and other requirements,
o Changes in knowledge or information about hazards and occupational health and safety
risks,
o Developments in knowledge and technology.
 Change in Ship’s Materials
 Change in Suppliers (i.e. Change of Manning Agent etc)
Changes may be:

 Permanent
A change of permanent nature following a decision taken at the appropriate level of authority.
 Temporary
A change of temporary nature, following a decision taken at the appropriate level. This change
will be valid until a permanent solution is found. A time scale must be specified for temporary
changes on each Temporary Management of Change Record.
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 Emergency change
A change required to be done during an Emergency or to prevent it. Where practicable, approval
must be requested by the Office. Such a change must be reviewed and re-approved at the next
available opportunity.
The procedures for Management of Change must:
 Define the change.
 Define the reason for the change.
 Define the duration of the change (Temporary or Permanent)
 Ensure that the documentation supporting the change includes the reason for the change.
 Define the level of authority required for the approval of a change.
 Provide a clear understanding of the safety and environmental implications of a change.
 Ensure that all changes comply with the international, national, local and company regulations
and industry standards.
 Ensure that all changes comply with original equipment design specifications.
 Ensure that appropriate Drawings, Certificates, Manuals & Procedures, Checklists, PMS Issues,
Spare Parts and any other technical documents are updated following any change or modification.
 Ensure adequate manning, competency and experience of people and/or contractors.
 Identify all personnel that may be affected by the change and ensure that they understand the full
extent and the likely impact of the planned change.
 Identify and document any training needs arising from the changes to equipment and requirements
and ensure that all personnel receive the required training within a specified period.
 Ensure that there is an appropriate procedure for handover and familiarization both ashore and
onboard.
 Include health and safety issues.
 Include Security issues.
 Include Information Security issues.
 Include environmental and energy efficiency issues.
 Include provisions for issuing work permits before any work is carried out and any changes made
to equipment. Identify the safety precautions which must be taken in order to eliminate the
resulting risks or minimizing them to a level as low as practically possible.
 Identifying the risks associated with the change in order to identify any potential hazards,
including information security impacts.
 Carrying out risk assessments to all activities associated with the changes in order to identify
potential hazards.
 Ensure that all changes are developed in consultation with those who will have to implement the
changes. This will make the changes more readily acceptable.
 Monitor the change. Ensure that Temporary and Permanent changes do not exceed the initial
authorization for scope or time without review and re-approval by appropriate management level.
If the change exceeds the time frame then it must be closely monitored and extension must be
granted only following a new risk assessment.
 Ensure that the potential consequences of a change are identified, including Information Security
impacts, together with any necessary mitigation measures, verify that Information Security
requirements have been met and that the results are communicated to those affected by the change.
 Ensure feedback and review of changes made.
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Each MOC must include an Agreed Action Plan, stating the Action to be taken, the Person or
Department Responsible and the Due Date of each action.
The Due Dates must be closely monitored. If the actions cannot be met on due date, then a Revised
Action Plan must be issued for these actions, following approval by the appropriate Level of
Authority.
Actions after the change:

 Ensure that appropriate Drawings, Certificates, Manuals & Procedures, Checklists, PMS Issues,
Spare Parts and any other technical documents are updated following any change or modification.
 Communicate the results of the change to all those involved/ affected by the change.
 Evaluate the results of the change.
2.2 IDENTIFICATION OF CHANGES

Top management personnel identifying the need for any change of the above mentioned reasons will
commence the process by completing the first part of the Management of Change (MOC) Form.
Urgent shipboard changes can be initiated through e-mail dialog with Superintendent Engineer and
followed up with a Risk Assessment carried out onboard the ship.
2.3 RISK ASSESSMENTS

For all changes, a risk assessment must be made, taking into consideration all the potential hazards
(Quality, Environmental, Information Security, Occupational Health & Safety, and Energy)
All temporary and permanent changes in the procedures and equipment onboard must be subject to a
Risk Assessment taking into consideration all the potential hazards, including Information Security
impacts.
If new risks are identified during the implementation of the Management of Change, a new Risk
Assessment must be performed.
The procedure for Risk Assessment must be implemented.
2.4 APPROVAL / ACTION PLAN / VERIFICATION OF CHANGE

Once the level of the overall risk associated with the change is identified, the appropriate Manager
together with his team shall develop an Action Plan aiming to bring the risk associated with the
change to acceptable level.
The Risk Assessment may result to:
 Identification to resource needs.
 Revision of Procedures.
 Updating of Planned Maintenance System / Spares Requirements / drawings and or technical
documents.
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Each Action Plan shall have at least the following elements:

 Overall responsible for the Action Plan.
 Actions to be taken.
 Responsibility for these actions.
 Time frame for completing the actions.
When the Action Plan is completed the person with appropriate level of authority will approve the
Change.
Depending on the Initial Risk Level of the change, the Management of Change (MOC) must be
approved by the level of authority as indicated in the Table below.
TABLE 1
Risk Associated with Level of Approval required

Management of Change
High Risk Chief Operating Officer (COO) or Deputy COO,

ICT and HR Managers for ICT and HR functions only.
Medium Risk Relevant Department Manager(s), ICT and HR Managers
for ICT and HR functions only.
Low Risk Relevant Department Manager(s) / Master
As a rule, the Person directly involved in the change,

shall not be the one who grants the Final Approval.
Approval of Changes must be secured according to the “APPROVALS TABLE”, on the next page
depending on the Initial Risk Level.
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LEVEL OF AUTHORITY FOR THE APPROVAL OF CHANGE

CATEGORY TYPE OF CHANGE INITIAL REVIEW/ FINAL APPROVAL PARTIES AFFECTED
RISK EVALUATION BY BY BY CHANGE TO BE
NOTIFIED
COMMERCIAL / OPERATIONAL
Commercial Trading Area Operation Manager / COO See Table 1 on page 8 Vessel / Company
Risk vs Approval
Commercial New Subcontractor Managers / COO As Above Company / Vessel
Commercial Change of Vessel’s Name or Flag or Managers / COO As Above Company / Vessel
Class, etc.
Commercial Acquisition of new Vessel Managers / COO As Above Company / Vessel
Operational/ Commercial Changes on Types of Cargo Operation Manager/ COO As Above Company / Vessel
Operational New Vessel Type in the Fleet Managers / COO As Above Company / Vessel
TECHNICAL
Technical Drawings, Plans, Manuals Technical Manager As Above Company /Vessel
Technical Deck/Cargo Equipment or Components Managers As Above Company / Vessel
Technical E/R Equipment or Components Technical Manager As Above Company/ Vessel
Technical Safety Equipment or Components Managers / COO As Above Company/ Vessel
Technical Major Repairs – Modification Technical Manager / COO As Above Company/ Vessel
PERSONNEL
Personnel Shipboard Personnel – Manning levels Crew Manager / COO As Above Company / Vessel
Personnel Shipboard Personnel – New Nationality Crew Manager / COO As Above Company / Vessel
Personnel Shore Personnel - Position Change Managers /HR Manager As Above Company / Vessel
Personnel Company’s Organisation, Restructuring, Managers /HR Manager As Above Company / Vessel
Reporting Lines
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LEVEL OF AUTHORITY FOR THE APPROVAL OF CHANGE
CATEGORY TYPE OF CHANGE INITIAL REVIEW/ FINAL APPROVAL BY PARTIES AFFECTED

RISK EVALUATION BY BY CHANGE TO BE
NOTIFIED
SOFTWARE
Changes in ICT and OT Software (only See Table 1 on page 8
ICT Changes OT Software Integrated with ICT ICT Development Head Risk vs Approval Company / Vessel
Systems) and / or Hardware
Technical and / or Marine / See above table
Changes to OT Software and / or Vetting / ICT Development
OT Changes Company / Vessel
Hardware Head (only for OT Systems
Integrated with ICT Systems)
IMS DOCUMENTS
Documents IMS Revisions - New Procedures Managers /S&Q See above table Company / Vessel
Manager/COO
Documents Company’s Policies COO/HR and ICT Managers COO Company / Vessel
for the relevant functions.
TEMPORARY
Temporary Temporary changes of Medium or Low Managers See above table Temporary
Risk
EMERGENCY
Emergency Emergency changes of Medium Risk Master / Managers See above table Company / Vessel
Note: In case Initial Reviewer and Final Approver happen to be the same person, then the Final Approver’s immediate supervisor will provide final
approval in order to preserve independence of person involved – being part of the change and the one approving it.
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This approval must include verification that the correct process has been followed and that all
necessary procedures have been put in place to manage the change effectively.
Such verification must include:
 Content of the change.
 Scale of the change.
 Reason for the change.
 Necessity for the change.
 Risk Assessment.
 Mitigating Procedures.
 Financial approval of the change.
 Any required change to the IMS.
Revised Action Plan

The “Due Dates” of each Item of the Approved Action Plan, must be closely monitored.
If, for any reason, an Action or due date of the Approved Action Plan cannot be met, then a Revised
Action Plan must be drawn and recorded on the Management of Change report.
The Initial Risk Assessment must be re-visited and adjusted as necessary, or a new Risk Assessment
must be issued.
Re-approval of the new Action Plan with a new due date must be obtained.
All persons involved / affected by the change must be kept updated as to the status of the Actions
plans of the change, and the revised due dates.
2.5 IMPLEMENTATION AND MONITORING
The Management of Change documentation must identify the person(s) responsible for the
implementation and for monitoring of change.
The person responsible for monitoring must ensure that changes are completed within the agreed time
scale.
Where this cannot be met, approval of the Revised Action Plan must be obtained from the Approver
of the change.
The Management of Change monitoring is carried out:

 through the use of the relevant series of IMS Forms OFF/GEN/008+ or
 through the MOC ERP Module ( for more or less standard ( routine) MOCs)
The Status of the MOCs must be continuously monitored and should be included in the Hand-over
process, for both Office and Shipboard Personnel.
For Office Personnel: Forms OFF/HRD/016A to 016I.
For the 4 Senior Officers onboard: Forms SF/CRW/501-502-502A-503-503A.
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2.6 REVIEW OF EFFECTIVENESS OF CHANGE DURING MANAGEMENT REVIEWS MEETINGS

The review of the effectiveness of the changes is carried out during the Quarterly Management
Review Meetings.
The review must include:
 Was the change completed as per the Action Plan within the time scale?
 Have the objectives of the change been met?
Where objective have not been met, have appropriate action been taken?
 Was the overall impact of the change satisfactory?
 Were all risk reduction measures taken (as identified in the Risk Assessment)?
 Have all publications, manuals and drawings, Spare Parts Inventories etc been updated?
 Were there any deviations from the original plan?
 Were there any improvements to the plan?
 Are any additional changes to the process required?
 Are any additional changes needed to correct gaps?
3. RECORD
 Management of Change (Ashore) PRO/PRO 27/ OFF/GEN/008
 Management of Change –New Acquisitions PRO/PRO 27 / OFF/GEN/008A
 Management of Change-Sale of Vessel PRO/PRO 27/ OFF/GEN/008B
 Management of Change-New Employee PRO/PRO 27/ OFF/GEN/008C
 Management of Change- Change of Employee Position PRO/PRO 27/ OFF/GEN/008D
 Management of Change-IMS Amendments PRO/PRO 27/ OFF/GEN/008E
 Management of Change-Position of DPA PRO/PRO 27/ OFF/GEN/008F
 MOC ERP Module
 Record of Changes to Drawings or Equipment PRO/PRO 27/ OFF/TEC/103
 Vessel’s Management of Change PRO/PRO 27/ SF/TEC/118

(see MOC Flow Chart on next page)
Page 12 of 13
(002) Revision: 11
Page 13 of 13
(002) ISOLATED OPERATION TECHNOLOGY (OT) Revision: 03
SOFTWARE MANAGEMENT Eff. Date: 30/09/2022
Contents
1. PURPOSE ..................................................................................................................................2
2. GENERAL .................................................................................................................................2
2.1. Isolated Operational Technology (OT) Software Changes ...............................................2
2.2 Responsibilities .......................................................................................................................2
2.3 Shipboard and Shore Systems Isolated OT Inventory ............................................................3
2.3.1 Generic Inventory of Vessels Isolated OT Systems .................................................................................... 3
2.4 Software System’s Update ......................................................................................................3
2.4.1 Checking availability of Appropriate / Latest Version ................................................................................ 3
2.4.2 Updates from Software Vendors ................................................................................................................. 3
2.4.3 Identification of Crucial Vulnerability Patches ........................................................................................... 3
2.5 Software Update Deployment .................................................................................................4
2.5.1 Compatibility Checks to ensure integration with existing systems ............................................................. 4
2.5.2 Competency & Training requirements. ....................................................................................................... 4
2.5.3 Instructions for Back-up, where applicable. ................................................................................................ 4
2.5.4 Installation Process Implementation & Post Installation Tasks .................................................................. 4
2.6 Software Patch Management ..................................................................................................5
2.7 Review of Effectiveness of Change During Management reviews Meetings ........................5
2.8 Level of Authority for the Approval of Changes ....................................................................5
3. RECORD ....................................................................................................................................5
4. REFERENCES ...........................................................................................................................6
Page 1 of 6
1. PURPOSE
This procedure provides the necessary steps, as well as guidance for establishing and maintaining an
effective Software Management System, based on guidance provided by Classification Societies and
other Industry publication, for all OT Systems that are not integrated towards the ICT infrastructure
– Isolated OT systems.
The ICT Integrated OT Systems must to comply with the Information Security equivalent process.
2. GENERAL
The Management of Change (MOC) procedure requires that the impact of any change is risk assessed
and mitigation measures are identified. In order to keep the Isolated OT Software installations,
updates, upgrades, addition of new Modules etc. at a reasonable level, intended categories of software
changes must be assessed in advance, with respect to their Risk considering that:
 Risk = Likelihood x Consequence.
The current procedure applies to all Isolated OT - Operational Technology systems which includes
devices, sensors, software and associated networking that monitor and control onboard systems.
2.1. ISOLATED OPERATIONAL TECHNOLOGY (OT) SOFTWARE CHANGES

Regarding Isolated OT Software Systems there are no pre-approved changes. Vendors performing
changes must obtain approval from the relevant Office Departments who are responsible for the
Software systems in question.
The Technical or Marine / Vetting Department Manager (depending on the

equipment) are the persons responsible for the initial Risk Assessments &
Management of Change of the Isolated OT Hardware and Software related
Office Responsible upgrades onboard. They are also responsible to monitor the latest version
Departments of the OT Software available and ensure that the appropriate versions are
installed onboard. Training Manager being responsible for the Simulators
in the Training center will be performing equivalent tasks for the Office OT
assets.
The DPA is the person responsible to approve the changes Isolated OT
DPA Hardware and Software, onboard and ashore, as defined in Procedure 27 -
Table 2.7 of this Manual.
Following relevant planning and authorization by the Isolated OT Office

Responsible as per above, the Master is responsible to verify all the changes
Master in Isolated OT Hardware and Software onboard and keep the relevant
Vessel specific inventory up-to-date with all relevant upgrades made. This
inventory must be verified on a Quarterly basis as a minimum.
Page 2 of 6
2.3 SHIPBOARD AND SHORE SYSTEMS ISOLATED OT INVENTORY

Isolated Operational Technology (OT) Shipboard and Shore Systems, must be recorded.
The Technical and Marine / Vetting Departments must create and maintain this Inventory in
collaboration with the Vessels for shipboard systems while the Training Manager must do the same
for Office OT systems. Update process must monitor all SW changes, patches, updates and fixes.
All Software Changes must be recorded in a Software Change Tracking Form - OFF/CBS/001. This
will included both Major as well as Minor Changes:
 Major Changes: New asset or existing asset Major release upgrade.
 Minor Change: Bug fixing or small functionality improvement / enhancement.
2.3.1 Generic Inventory of Vessels Isolated OT Systems

A Generic Inventory of Vessel Isolated OT Systems has been issued and has been included as Annex
to this Procedure. Based on this Generic Inventory, each Vessel will issue a Vessel-Specific
Inventory, which will include all the Isolated OT Systems onboard. The latter must be included in
Company ERP and kept up-to-date.
The Master is responsible to update the Vessel Specific Isolated OT Inventory whenever any
change occurs. The List must be reviewed and verified by the Master on a Quarterly basis, as a
minimum, by issuing the Isolated OT Equipment Inventory Record – SF/CBS/001.
2.4 SOFTWARE SYSTEM’S UPDATE

2.4.1 Checking availability of Appropriate / Latest Version
The responsible personnel, who are assigned to update the List of Software Systems must regularly
check the installed Isolated OT Software, for available updates.
Such checks must be performed Quarterly, as a minimum.
All relevant information must be included in the Inventory List included as Annex in the current
procedure.
2.4.2 Updates from Software Vendors

The responsible personnel must check the possibility to receive update notifications in case of
Vendors, with whom the Company has signed Service Contracts e.g. Radio Equipment Vendors.
These must be included in the software inventory lists as per previous point.
2.4.3 Identification of Crucial Vulnerability Patches

The responsible personnel must identify crucial vulnerability patches also in compliance with
guidance documented in paragraph 2.6. Possible ways to achieve this include but are not limited to:
 Check with Certified Organizations (Once per month).
 Attend Maritime Information Security Conferences.
 Query Vendors.
 Check Publications from e.g. Classification Society and BIMCO.
 Contract a 3rd Party Threat Intelligence Provider.
Page 3 of 6
2.5 SOFTWARE UPDATE DEPLOYMENT
2.5.1 Compatibility Checks to ensure integration with existing systems

Compatibility Checks to ensure integration with existing systems must include the following steps:
 Guidelines and Documents.
2.5.2 Competency & Training requirements.

 Establish competence requirements per responsible person / position.
 Develop a Training Program for the personnel, as per the Competences required for each
Position / Responsibility.
 Establish Administrative Accounts for Software installation.
 Establish Training Program onboard and provide Training Material.
 Establish what training material will be provided by the Vendors of Software / Hardware.
2.5.3 Instructions for Back-up, where applicable.

 Establish a schedule for regular back-ups, consider automatization if not already in place.
 Confirm back-up availability before installation / change of software.
2.5.4 Installation Process Implementation & Post Installation Tasks

o Updates / upgrades will be performed by certified service engineers only.
o Vendor practice and relevant documentation must be available and checked prior the
upgrade / update process taking place.
o Action taken by the Vendor / Service Engineer must be documented e.g. within
Service Report.
o System responsible as per Paragraph 2.2 to document feedback / experience gained
upon successful Installation
o Send feedback to Vendor and / or relevant company stakeholders, in case of
unsuccessful installation.
o Tests including Performance Testing must be carried out following any Software
Updates. Target is to:
 Verify standard functionality / improvements expected.
 Evaluate potential impact to other integrated / co-operating assets.
 Identify any case of performance degradation following update process
conclusion.
o Test procedure above must be documented in form OFF/CBS/001 relevant section.
Page 4 of 6
2.6 SOFTWARE PATCH MANAGEMENT

One of the most common vulnerabilities is unpatched software. Attackers are quick to get the upper
hand when software patches are not kept up-to-date. Software patches for Isolated OT systems must
therefore be managed be a defined process, which includes the following steps:
 Regular examination for new vulnerability alert messages from the Isolated OT Party System
Suppliers.
 Assessment of the criticality of patches.
 Obtaining patches and updates.
 Backing –up the system for restoration in case something goes wrong. This is particularly
important when the Isolated OT system is required for production.
 Approval process - Isolated OT System Support Contractual Agreements for periods of time
for the approval and provision of patches and updates or alternative workarounds for
vulnerabilities.
 Handling Product Supplier Approvals of Patches.
 Handling the patching of additional software.
Ideally, patches installation must be scheduled during maintenance windows. If however, the Isolated
OT systems are redundant, then the patch updates can be made sooner.
2.7 REVIEW OF EFFECTIVENESS OF CHANGE DURING MANAGEMENT REVIEWS MEETINGS

The review of the effectiveness of the Isolated OT Software Management Process is carried out
during the Quarterly Management Review Meetings in compliance with PRO Manual, Procedure 27
– MoC – Paragraph 2.6 requirements.
2.8 LEVEL OF AUTHORITY FOR THE APPROVAL OF CHANGES
Category Initial Review / Risk evaluation by: Final Approval by:

OT - ER Equipment. Technical Manager & Deputy DPA
OT - Navigational & Electronic Marine / Vetting Manager & DPA
Equipment. Deputy
OT - Training Department Simulators. Training Manager DPA
3. RECORD
 Management of Change (Ashore) PRO/PRO 27/ OFF/GEN/008
 Vessel’s Management of Change PRO/PRO 27/ SF/TEC/118
 Software Change Tracking Record PRO/PRO27A /OFF/CBS/001
 Vessel Isolated OT Equipment Inventory Record PRO/PRO27A/SF/CBS/001
Page 5 of 6
4. REFERENCES
 DNGL-RP-0496 Cyber Security Resilience Management for Ships and Mobile Offshore Units
in operation
 DNV-OS-D203 Integrated Software Dependant System (ISDS)
 BSI –ICS Security Compendium Version 1.23 § 5.6.4 Patch Management.
Page 6 of 6
PRIME TANKER PROCEDURE 27A ‐ ANNEX A4 ‐ MARINE ISOLATED OT SOFTWARE MANAGEMENT INVENTORY TEMPLATE Marine Isolated
PRIME GAS Marine Isolated OT Management Inventory Template
Revision: 1
OT Equipment Name OT Equipment Vendor Location OT Equipment HW SW Version / Firmware Release Date Back-Up Solution Used? Back-Up Media Used / Location Scope & Purpose of Use Patching / Minor Release Level Release Date Configuration Files Used? I/O Signals.
ANEMOMETER
AUTOPILOT
BNWAS
CCTV
ECDIS
GPS
GYRO COMPASS
MF/HF
NBDP TERMINAL
NAVTEX
INMARSAT-C
RADARS
VDR
VHF / UHF UNITS
COURSE RECORDER
SPEED LOG
ECHO SOUNDER
EPIRB
SART
PRIME TANKER PROCEDURE 27A ‐ANNEX A5 ‐ TECHNICAL ISOLATED OT SOFTWARE INVENTORY TEMPLATE Technical Isolated OT
PRIME GAS Software Inventory
Template
Revision: 1
30/11/2021
OT Equipment Name OT Equipment Vendor Location OT Equipment HW SW Version / Firmware Release Date Back-Up Solution Used? BackUp Media Used / Location Scope & Purpose of Use Patching / Minor Release Level Release Date Configuration Files Used? I/O Signals.
yes / no (*Configuration files: security mechanism parameters are

particularly important. The following should be considered:
- Default configuration
i.e UNISAB - Activation/Deactivation of unsecure services
CONTROLLER (Tag - Replacing of passwords, certificates for all services
i.e i.e. (Yes ONLY if there is specific
No..) UNISAB i.e. 1.2.3. PC program i.e. YES , emergency i.e. Spare Unisab available onboarb i.e. Controlling of Boiler (patch - Required authorisations for configuration changes).
AUX. BOILER i.e AALBORG ENGINE i.e. 05/04/2017 indication in the Software , i.e. : i.e Alarm Monitoring system
CONTROLLER (Tag version. …5-4-92.. operation tag no.. Software version.. function release date) The configuration files are some parameters which must be
ROOM Software version 1.2.3 Patch 2
No..) … available and saved in order to enable proper operaiton of the
PC HP….TYPE…. equipment/system , after a possible Software upgrade. In simple
words this is the parameters of ship specific installation of the
equipment . When you meniton that confirguration files available
please indicate where these are stored.
CCTV
LOCAL WATER MIST FIRE EXTINGUISHING SYSTEM
BALLAST WATER TREATMENT SYSTEM
MAIN ENGINE ME TYPE (Electronically controlled,
without camshaft)
ALARM MONITORING SYSTEM
POWER MANAGEMENT SYSTEM
M/E REMOTE CONTROL SYSTEM
OIL DISCHARGE MONITORING SYSTEM
FIRE DETECTION SYSTEM
GAS DETECTION SYSTEM
CARGO MONITORING SYSTEM / HIGH OVERFILL ALARM /
REMOTE SOUNDING SYSTEM
FRAMO CARGO PUMPING SYSTEM
VAPOR EMISSION CONTROL SYSTEM
LOADING COMPUTER
ENGINE CONTROL ROOM CONSOLE
BOW THRUSTER CONTROL
RUDDER CONTROL
MAIN / EMERGENCY SWITCHBOARD
ENGINE / BRIDGE COMMUNICATION SYSTEMS
ENGINE AUTO SYSTEMS
DP SYSTEM (N/A)
COMPOSITE BOILER
HFO / LO PURIFIERS
ALPHA LUBRICATOR
OIL WATER SEPARATOR 15ppm
OIL MIST DETECTION SYSTEM
ICCP
SHAFT EARTHING DEVICE
AIR CONDITIONING PLANT
INERT GAS SYSTEM
INERT GAS GENERATOR
INCINERATOR
MGO CHILLER UNIT
UV STERILIZER
SEWAGE TREATMENT PLANT
SMOKE DENSITY INDICATOR
BEARING WEAR MONITORING SYSTEM
AIR COMPRESSOR
(002) Revision: 08
RISK ASSESSMENT Eff. Date: 30/09/2022
Contents
1. PURPOSE .................................................................................................................................. 2
2. PROCEDURE ............................................................................................................................ 3
2.1 General .................................................................................................................................... 3
2.2 Applicability ........................................................................................................................... 6
2.2.1 Shore-based Risk Assessment ..................................................................................................................... 6
2.2.2 Onboard Risk Assessment ........................................................................................................................... 7
2.3 Responsibilities ....................................................................................................................... 7
2.4 Company’s Risk Management Program ................................................................................. 8
2.5 Risk Assessment Process ........................................................................................................ 9
2.6 Steps of the Risk Assessment process .................................................................................. 11
2.6.1 Step 1: Classification of the work activities whose risk are to be reviewed .............................................. 11
2.6.2 Step 2: Identification of hazards and potential events ............................................................................... 11
2.6.3 Step 3: Determination of the Likelihood / Frequency and the Consequence(s) ........................................ 14
2.6.4 Step 4: Risk Determination. ...................................................................................................................... 14
2.6.5 Step 5: Consideration of Alternative Methods, if necessary and checking of Existing controls ............... 15
2.6.6 Step 6: Evaluation / establishment of additional controls and review of the Residual Risk...................... 16
2.6.7 Step 7: Follow- up ..................................................................................................................................... 17
2.7 Risk Assessment Cases ......................................................................................................... 18
2.7.1 CASE 1: A relevant Risk Assessment EXISTS in the “Risk Assessment Library” .................................. 18
2.7.2 CASE 2: Relevant Risk Assessment DOES NOT EXIST in the “Risk Assessment Library” .................. 19
2.8 Review of the Company’s Risk Management Program by the relevant Office .................... 19
Departments ................................................................................................................................... 19
2.9 Risk Assessments Included in Safety Meeting Minutes Onboard ........................................ 19
2.10 Training in Hazard Identification and Risk Assessment of Senior Shipboard Officers .... 20
2.11 Training in Hazard Identification and Risk Assessment of Office Employees ................. 20
2.12 Risk Assessment Management through Proactive Safety Campaigns .............................. 20
2.13 Health Risk Assessments ................................................................................................... 21
2.14 Information Security Risk Assessment.............................................................................. 22
2.14.1 Information Security Risk Assessment ..................................................................................................... 22
2.14.2 Identification of Information Security Threats (Hazards) and Vulnerabilities .......................................... 23
2.14.3 Risk Estimation ......................................................................................................................................... 23
2.14.4 Risk Evaluation ......................................................................................................................................... 24
2.14.5 Risk Reduction .......................................................................................................................................... 24
2.15 Critical Equipment & Systems .......................................................................................... 25
3. RECORD .................................................................................................................................. 25
Page 1 of 25
(002) Revision: 08
1. PURPOSE
This procedure describes the steps to be followed in order to make a suitable and sufficient Risk
Assessment of the work which must be carried out.
The Company targets to develop robust SMS procedures, easy to understand and in compliance
with industry standards and best practices.
In this context, the Company’s procedures are reviewed for all possible risks that entail.
The task is involving both ashore and on board personnel.
A Company’s Hazard Register has been developed and includes all Vessel potential operations
(Security – including IT security, general shipboard operations, smoking, Drugs & Alcohol,
vibration, electricity, bunkering, environmental influences, stress, noise, lightering, fatigue,
emergency, enclosed space entry, hot work, cold work, mooring operations, maintenance, engine
operations, navigation, cargo related operations, etc.).
Possible threats have been identified and top event as well as potential consequences were
specified.
Thereafter, the initial risk has been calculated and Company’s controls (either procedural or
technical) were considered and incorporated in Company’s procedures.
The adoption of controls usually leads to risk mitigation.
The target is risk to become low or medium.
The Company’s procedures are therefore continuously enriched with additional controls as the
update of the Hazard Register is dynamic (max period between updates is maximum one year in
line with RA procedures).
It is underlined that risk identification is not only based to event- frequency as happens in the
Shipping Industry but also considers the frequency of the Company’s incidents/events.
The company (ashore and onboard) utilizes ERP Software for conducting Risk Assessments.
This Software is available to all relevant personnel onboard and ashore.
Reference is made to the Manufacturer’s Guidelines.
Page 2 of 25
(002) Revision: 08
2. PROCEDURE
2.1 GENERAL
The purpose of this procedure is to ensure that potential risks are systematically identified and
controlled through-out the Company – both Ashore and Onboard
Definitions
Hazard Hazard is the condition or action in each working environment that has the
potential for an unplanned release of, or unwanted contact with an energy source
and / or situation that may result in harm or injury to people, property or the
environment
Risk Risk is the effect of uncertainty on objectives. Every step has an element of risks
that needs to be recognised and managed.
Uncertainty Uncertainty is a state or condition that involves a deficiency of information and
leads to inadequate or incomplete knowledge or understanding.
Risk Risk Identification is the process that involves finding, recognizing and describing
Identification the risks that could affect the achievement of Company’s objectives
Risk Risk evaluation is the process that is used to compare risk analysis results with
Evaluation risk criteria in order to determine whether or not a specified level of risk is
acceptable or tolerable
Event Event could be an occurrence or several occurrences or even a non-occurrence
(when something doesn’t happen that was supposed to happen). Events always
have causes and consequences.
Consequence Consequence is the outcome of an event and has the effect on Company’s
objectives.
Likelihood Likelihood is the change that something might happen.
Determined Determined Risk and its Level is the identified risk and its level always in
Risk conjunction with the frequency of and severity of the consequence.
Controls in Controls in place are measures and actions that will reduce the risk to acceptable
place level
Additional Additional controls are additional measures and actions that will further reduce
Controls the risk to the acceptable level.
Responsible Responsible person is the person who will Plan-Do-Check-Act as per Control and
Person Additional Control measures.
Timeline Timeline: the setting of time to complete the Risk Assessment Process
Residual Residual Risk is the risk left over after a risk treatment implementation.
Risk
Page 3 of 25
(002) Revision: 08
A Risk Assessment is designed to:

 Identify all hazards.
 Analyze / assess the related risks.
 Explore options and identify controls to reduce the risks to a level that is as low as reasonably
possible (ALARP).
 Identify preventive measures.
 Identify the residual level of risk after taking the mitigating measures i.e. detailed instructions,
checklists, close supervision, familiarization, specialized training, PPE etc.
 Implement mitigating measures.
 Instigate actions for monitoring and reviewing.
 Develop contingency plans.
 Establish responsibilities.
 Amend / improve the existing IMS, if necessary.
The Risk Assessment must include:
 Conformity with International, National, Local and Company Regulations and Industry Best
Practices.
 Evaluation of the effect on the environment.
 Evaluation of the effect on the Safety Management System.
 Competency of People and / or Contractors.
 Equipment specifications.
 Health and Safety issues.
 Energy Efficiency issues.
 Security implications including Information Security.
 Effects on the Company’s Organization.
For occupational health and safety matters, when determining the Hazard Identification the following
should be considered:
 Routine and non-routine activities and situations:
o Routine activities and situations create hazards through day-to day operations and normal
work activities;
o Non-routine activities and situations are occasional or planned;
o Short-term or long-term activities can create different hazards;
 Human factors:
o Relate to human capabilities, limitations and other characteristics;
o Information should be applied to tools, machines, systems, activities and environment for
safe, comfortable human use;
o Should address three aspects: the activity, the worker and the Company, and how these
interact with and impact on occupational health and safety.
 New or changed hazards:
o Can arise when work processes are deteriorated, modified, adapted or evolved as a result
of familiarity or changing circumstances;
o Understanding how work is actually performed (e.g. observing and discussing hazards
with workers) can identify if OH&S risks are increased or reduce.
Page 4 of 25
(002) Revision: 08
 Potential emergency situations:

o Unplanned or unscheduled situations that require an immediate response (e.g. a machine
catching fire in the workplace, or a natural disaster in the vicinity of the workplace or at
another location where workers are performing work-related activities);
o Include situations such as civil unrest at a location at which workers are performing work-
related activities which requires their urgent evacuation.
 People:
o Those in the vicinity of the workplace who could be affected by the activities of the
Company (e.g. passers-by, contractors or immediate neighbours);
o Workers at a location not under the direct control of the Company, such as mobile
workers or workers who travel to perform work-related activities at another location (e.g.
service personnel travelling to and working at a customer's site);
o Home-based workers, or those who work alone.
 Changes in knowledge of, and information about, hazards:
o Sources of knowledge , information and new understanding about hazards can include
published literature, research and development, feedback from workers, and review of the
Company's own operational experience;
o These sources can provide new information about the hazards and OH&S risks.
The Risk Assessment must:

 Cover the risks arising from the work activities and is not expected to cover risks which are
not reasonably foreseeable.
 Be suitable and sufficient.
The Risk Assessment Process must not be overcomplicated.
The Risk Assessment must include consideration of the existing precautions to control the risk such
as:
 Permits to work.
 Restricted Access / Working areas.
 Use of Warning Signs.
 Agreed Procedures of the Integrated Management System and from other publications such
as ISGOTT and Code of Safe Work Practices.
 Personal Protective Equipment.
 Suitable tools and equipment, well maintained.
 Use of experienced personnel.
 Involvement of Adequate Personnel.
 Adequate Training.
 Adequate Supervision.
The Work Permit system must be strictly followed on board the Vessel for tasks which, following
Risk Assessments, have been found to be hazardous.
Page 5 of 25
(002) Revision: 08
2.2 APPLICABILITY
The Risk Assessment program of the company may be applied in the following cases:
 Personnel safety.
 Health Aspects (Exposure to Hazardous materials, occupational health).
 Environmental aspects.
 Security issues (see Ship Security Assessment / Plan) including Information Security.
 Regulatory compliance.
 Damage to property.
 Company Reputation.
 Financial effects.
 New projects.
Risk assessment to measure the impact of identified aspects may be applied in the following cases:
 Management of Change.
 Non-routine repairs (following equipment breakdown or arising from the potential for
breakdown).
 Other potentially hazardous operations and projects.
 New or non-routine tasks that may be carried out in the future.
 Recognized potential hazards.
 Works which are not covered by specific procedures.
 Health and occupational tasks.
2.2.1 Shore-based Risk Assessment

Shore-based Risk Assessment may be considered in the following cases:
 For any new business bid, whether it is for the ships into management or a new venture or a
general project.
 As part of a Contract Review.
 When a Management of Change process is required.
 Changes in the applicable standards and codes of the management system.
 Changes in the legislation related to Company’s activities.
 Shore organizational top management positions’ change.
 Conversion of Vessels.
 Change of Crew nationality.
 Changes of Manning Level.
 Changes in major subcontractors, such as manning agent.
 Adding new types of Vessels in the Fleet.
 Fleet size changes.
 New Vessel trading areas.
 Flag or class society changes.
 New Cargoes.
 Major changes in current procedures.
Page 6 of 25
(002) Revision: 08
2.2.2 Onboard Risk Assessment

Onboard Risk Assessment may be considered in the following cases:
 All identified risks to the ship, personnel and the environment.
 Carry out works on Deck, in Engine room, in Galley etc involving a hazard (routine or non-
routine).
 Operational changes.
 Change of equipment, materials.
 Equipment breakdown and risk of alternative to be used.
 Change or variation of an installed system (e.g. changing of loading computer software).
 Change to the manning of a ship (e.g. more than 25% of the crew).
 Navigation in heavy weather, restricted visibility etc.
 Approaching High Risk Areas (i.e. Piracy, Ebola affected areas etc).
 Other.
The Master has the overall responsibility for the safe working practices of the Vessel. Ship’s Officers
have delegated responsibilities within the Management System but nevertheless it is important that
every crewmember is aware of his personal responsibility towards safety for himself and to others
during all onboard operations.
STOP WORK AUTHORITY must be exercised
in all cases where the Risk Level is Moderate to High.
The request for a Risk Assessment may be made by any crewmember but it is the Master who is
responsible for ensuring that a Risk Assessment is carried out and implemented.
Attending company personnel are responsible to review tasks carried out since the last company visit
in order to establish, if practicable, that measures have been put in place to establish a safe place of
work.
This is to be established by review of work permits, maintenance records and Risk Assessment
Worksheets.
The request for a Risk Assessment may be made by any shore-based personnel but it is the
responsibility of the Department’s Manager to ensure that a Risk Assessment is carried out and
implemented.
All Department Managers are responsible to assist and review those Risk Assessments forwarded by
the Vessels.
The general responsibility for the implementation of this procedure rests with the Designated Person
Ashore.
Page 7 of 25
(002) Revision: 08
In more details, the responsibilities related to the Risk Assessment process are as follows:
Chief Operating Officer

Approval of control measures and resources (if required).
(COO) or Deputy COO
Ensuring effectiveness of the RA procedure, approving control
DPA
measures, initiating RAs, reviewing & evaluating, etc.
Hazard Identification, issuance of Risk Assessments and
Masters / Officers
implementation of Control and Additional Control measures.
Initiating and improving Risk Assessments, approving the Control in
Office Department
place and Additional Control measures, verifying / evaluating if any
Heads
additional measures are required.
Issuing Risk Assessments Depending on the seriousness and the
complexity of a Risk Assessment a “RA Team” (3rd parties may also
be involved) will undertake to develop the Risk Assessment and
Risk Assessment Team advise the Management of the results, as well as of the residual Risk,
the uncontrollable hazards, etc. The “RA Team” is responsible to
review and approve any new version of an existing RA form already
existing in the RA library and any new established RA.
All Office / Shipboard
Identification of Hazards.
employees
All Office / Shipboard
employees through
Request for the initiation of a Risk Assessment process.
Department Heads /
DPA/ Master.
2.4 COMPANY’S RISK MANAGEMENT PROGRAM

The Company’s Risk Management Program includes the following documentation:
 This Risk Assessment procedure and relevant Posters for Hazard Identification and Energy
Source;
 Risk Assessments Library (ERP Software – RA Module).
 Information Security Risk Assessment Template – Annex D.
 Work Permit System.
The Company has collected the “Job Risk Assessment” (RA), submitted by the Fleet Vessels as well
as those issued by the Office and has created a common Library.
The Risk Assessments included in the RA Library, are relevant to operations involving recognised
risks and include a number of standard preventive and control measures.
These control and preventive measures must always be considered when relevant operations are
carried out on board.
It must be stressed that the “Job Risk Assessments” included in the Library serve as guiding examples,
for reference purposes and can be utilized if no any additional hazard or controlled measure is
required.
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2.5 RISK ASSESSMENT PROCESS

The steps of a Risk Assessment process are the following:
Step 1 Classify the work activities (task), whose risks are to be reviewed.
Step 2 Identify the hazards and potential events.
Refer to Annex A - Hazard Identification relevant Tables and to the Hazard Identification
Posters.
Step 3 Determine:
1. The Likelihood / Frequency i.e. the chance that something might happen and how
frequent.
2. Consequence i.e. the outcome of an event which has effect on Company’s objectives
(Refer to Annex B - Risk Assessment Matrix).
Step 4 Determine the Risk Factor.
Refer to paragraph 2.6.4 – Risk Determination.
Step 5 Consider Alternative Methods, if necessary and check existing controls.
 Identify any other alternative methods of doing the Job (depending on the risk
identified at Step 4 - i.e. if the risk is determined as “High”).
 Identify and take all preventive measures and controls required.
 Check that the existing controls are in place.
Step 6 Evaluate / establish additional controls and review the Residual Risk.
1. Evaluate, if necessary, any additional controls to reduce the risk i.e.
2. Review the Residual Risk.
3. Review the Job Risk Assessment.
Step 7 Follow-up.
 Conduct follow-up evaluations of the controls to ensure they remain in place and have
the desired effect.
 Monitor any changes which may require further Risk Assessments (a hazard may exist
in the current operation or it may result from changes to the current operation-
therefore a continuous control and assessment is necessary).
As a basic rule, for any work which presents a hazard, and a relevant Risk Assessment is available in
the Library, the Risk Assessment Process must be fully implemented.
Diagram of Risk Assessment Process on the following page.
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Identification of Task
Does the competent No

person identify any
hazard?
Yes
Level 1
Yes Is an initial Risk

Assessment available?
No
All Carry out Risk
conditions No Assessment –
and hazards Identification of Hazards
remain the
same?
Identification of
Consequences –
Calculate Risk Factor
Yes before safeguards
Define Measures /
Safeguards
Calculate Risk Factor

after safeguards
Level 2
Yes Is the calculated

Risk Factor “LOW”?
No
Send Risk Assessment to

the company for review
Modify Task Yes

/ wait until No
Can the task Cancel Task
conditions be performed?
change
Implement Perform Task

safeguards Page 10 of 25
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2.6 STEPS OF THE RISK ASSESSMENT PROCESS
2.6.1 Step 1: Classification of the work activities whose risk are to be reviewed
The first step in the Risk Assessment process is to define the activity whose risks are to be reviewed.
Some indicative questions may be:
 What is the work to be carried out?
 Is it a simple work, or is it a complicated work, with many stages, etc?
 Will it be done by one person or by a group of persons?
 Does the group consist of persons from one Shipboard Department or from more departments?
 Will shore personnel (Terminal employees, contractors) be involved?
 Must the person (s) have special skills and experience?
 Has the person(s) any previous experience of this work?
 Is it a work which needs physical strength and do the persons selected have this quality?
 What is the required level of supervision?
 Does the job to be carried out require permission from the Company?
 Must Port Authorities, Vessels in the Vicinity etc be notified of the planned work?
Before initiating a Risk Assessment, all parties involved must have a common understanding of the
goals, the methods to be used, the resources required and in what way the results of the Risk
Assessment process will be applied.
2.6.2 Step 2: Identification of hazards and potential events

The second step is to identify hazards and potential events. This is the most important step since all
that follows depends on it. It must be complete and accurate, and must be based, as far as possible,
on observation of the activity.
However hazard identification is not as easy as it may first appear.
Completeness and accuracy can be achieved only if the process is systematic.
Those charged with the task must have sufficient training and guidance to ensure that it is conducted
in a thorough and consistent manner.
The terms used must be clearly defined and the process must be fully described; for example, hazards
must not be confused with incidents, and incidents must not be confused with consequences. The
following steps / indicative questions shall be implemented in all cases.
 What can go wrong?

 Why could something go wrong? i.e.
o Due to changing weather conditions?
o Due to lack or insufficient supervision / training?
o Due to problems / insufficient handover of watch in the middle of the operation?
o Due to insufficient or damaged equipment or PPE?
o Due to insufficient resources?
o Due to insufficient data, measurements etc?
o Due to difficult access to the work location or poor layout of space?
o Due to inexperience of the persons involved or other personal factors i.e. fear of confined
spaces, fear of height etc?
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o Due to breakdown of communication?

o Due to unclear procedures, instructions or checklists?
o Due to use of new equipment / design – with which crew are not familiar?
o Due to poor lighting, high temperature, high noise?
o Due to lack or insufficient marking of working areas (Safety signs, fencing of space etc)?
o Due to Language barriers and /or cultural misunderstanding or even “taking shortcuts to
safety” ingrained in the culture of the persons involved? (Multinational crew,
Contractors, Pilots, Terminal employees etc)
o Due to failure to notify other parties (i.e Port Authorities, Vessel in Vicinity etc)
(For more causal factors, refer to Table 3 of Annex A: “Factors which may lead to Hazards &
Events”).
This process usually focuses on human action / inaction, equipment, utilities, instrumentation and
external factors which may cause an incident to occur.
The hazard may exist in the current operation or it may result from changes to the current situation.
An indicative list of hazards is provided in the Table (POSTER – List of Hazards).
LIST OF HAZARDS
1. Chemical (Toxic) A chemical that exposes a person to absorption through the skin,
inhalation, or through the bloodstream that causes illness, disease or
death. The amount of chemical exposure is critical in determining
hazardous effects. Check Material Safety Data Sheets (MSDS).
2. Chemical A chemical that, when exposed to a heat ignition source, results in
(Flammable) combustion. Typically, the lower a chemical’s flash point and boiling
point, the more flammable the chemical. Check MSDS for
flammability information.
3. Chemical A chemical that, when it comes into contact with skin, metal or other
(Corrosive) materials, damages the materials. Acids and bases are examples of
corrosives.
4. Explosion Sudden and violent release of a large amount of gas / energy due to a
(Over significant pressure difference such as rupture in a boiler or
pressurization) compressed gas cylinder.
5. Electric Contact with exposed conductors or a device that is incorrectly or
(Shock / Short inadvertently grounded, such as when a metal ladder comes into
Circuit) contact with power lines. 60HZ alternating current (common house
current) is very dangerous because it can stop the heart.
6. Electric Use of electric power that results in electrical heating or arcing to the
(Fire) point of combustion or ignition of flammables or electrical
component damages.
7. Electrical Safety – critical equipment failure as a result of loss of power.
(Loss of Power)
8. Ergonomics Damage of tissue due to over exertion (strains and sprains) or
(Strain) repetitive motion.
9. Ergonomics A system design, procedure or equipment that is error-provocative.
(Human Error) A switch goes up to turn something off.
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LIST OF HAZARDS- continuing

10. Fall Conditions that result in falls (impacts) from height or traditional
(Slip, Trip) walking surfaces such as slippery floors, poor housekeeping ,
uneven walking surfaces , exposed ledges etc.
11. Working at a height Risk of falling. A Work Permit must be issued and the
(over 1.8 meters) appropriate PPE worn (safety belt must be used).
12. Working overboard Risk of falling. A Work Permit must be issued and the
appropriate PPE worn (safety belt must be used).
13. Fire / Heating Temperatures that can cause burns to the skin or damage to other
organs. Fires require a heat source, fuel and oxygen.
14. Mechanical / Vibration Vibration that can cause damage to nerve endings, or material
(Chaffing / Fatigue) fatigue that results in a safety-critical failure. Examples are
abraded slings and ropes, weakened hoses and belts.
15. Noise Noise levels (> 85 Dba 8-hr TWA) that result in hearing damage
or inability to communicate safety-critical information.
16. Radiation Alpha, Beta, Gamma, neutral particles, and X-Rays that cause
(Ionization) injury (tissue damage) by ionization of cellular components.
17. Radiation Ultraviolet, visible light, infrared and microwaves that cause
(Non-Ionization) injury to tissue by thermal or photochemical means.
18. Struck by Accelerated mass that strikes the body causing injury or death.
(Mass Acceleration) Examples are falling objects and projectiles.
19. Struck against Injury to a body part as a result of coming into contact of a
surface in which action was initiated by the person. An example
is when a screwdriver slips.
20. Temperature Extreme Temperatures that result in heat stress, exhaustion or metabolic
(Heat / Cold) slow down such as hypothermia.
21. Visibility Lack of lighting or obstructed vision that results in an error or
other hazard.
22. Weather Phenomena Self-Explanatory
(Snow / Rain / Wind /
Ice)
23. Humidity Extremes Self-Explanatory
24. Exposure to sunlight / Self-Explanatory
UV Radiation Exposure
26. Existence of Asbestos Inhalation of Asbestos fibres which can lead to asbestos related
diseases (chest / lung cancer).
27. Extreme Dust Extreme dust may be produced during works during mechanical
processes such as sanding, grinding, sawing, etc. Appropriate
PPE must be worn per case.
28. Drowning Asphyxia due to water inhalation
29. Biological Agents Infection by biological agent (In Hospital Room by needle-stick
injury from a needle used on patient, etc. (blood borne))
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Other Posters which may be referred to for Hazard Identification are:

 Energy Sources.
 Hazard Identification.
 “Take 5”.
 BIMCO Cyber Security Awareness Poster.
 Seagull Cyber Security e-learning CBTs.
Consequence is the outcome of an event and has the effect on Company’s objectives. For every
hazard identified, the corresponding consequence must be written down, in order to be able to decide
the severity and the likelihood before any safeguards, and thus calculate the risk factor for every
hazard.
A hypothetical Risk Scenario can also be considered, describing the outcome / event (i.e. exposure
of the Vessel into unsafe condition) and the consequences (e.g. fire, vapor release, person’s injury,
environmental impact etc.). (Refer to ANNEX A of this procedure “Hazard identification or relevant
POSTER).
2.6.3 Step 3: Determination of the Likelihood / Frequency and the Consequence(s)

Having identified the Hazards associated to the Planned Work, the following must be determined:
o The Likelihood / Frequency:
 How bad and how likely can something go wrong? What are the possibilities / chances
that something wrong might happen?
Likelihood Frequency
Possibility of repeated events One or more times per month
Possibility of isolated incidents One or more times per quarter
Occurring some times One or more times per one (1)year
Not very likely to occur Less than once in five (5) years
Very remote probability Less than once in ten (10) years
o The Consequences.
If something wrong happens, what would the consequences be? i.e.
 Health and Safety.
 Damage to Vessel or property.
 Environmental Impact.
 Other (i.e. major industry reaction, black-listing of Vessel or Company, loss of hire, etc).
2.6.4 Step 4: Risk Determination.
Having identified:
 The Work to be done (Step 1).
 The associated Hazards (Step 2).
 The Likelihood and Frequency (Step 3)
the Risk must be determined.
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The risks associated with each hazard are evaluated in terms of the likelihood of harm and the
potential consequences. This, in turn, allows personnel to set priorities and to decide where its
resources may be used to get the best possible results.
The Risk Factor is the combination of the likelihood that a hazardous event or exposure may occur
and the severity of the consequences. The determination of the risk is based on the Formula:
RF = Frequency / Likelihood (L) X Consequence (C)
The Risks are classified as per below – also in compliance with the Risk Assessment process diagram
on page 8:
High / Moderate The work shall not start unless approval is obtained from Management
Ashore. Risk must be reduced through implementation and monitoring of
additional controls that must be introduced.
Low No additional controls are required. However monitoring is necessary to
ensure controls are maintained.
2.6.5 Step 5: Consideration of Alternative Methods, if necessary and checking of Existing

controls
If the Risk is classified as “Moderate” or “High”, the following must be considered:
 Can the work be postponed or cancelled?
 Is there any alternative way to do the work?
 Can matters be improved by implementing additional controls?
 What would these preventive measures and additional controls be?
 Are the additional measures and controls based on sound engineering and common sense?
 Are these measures and controls technically possible and will they have a significant effect?
 Are they in consistency with local / prevailing regulations, circumstances and conditions?
 Do the people who will implement the additional measures and controls have the necessary
scientific or technical knowledge and experience?
 If multiple control measures are necessary, which one would have the greatest impact in reducing
the risk?
 What is the effort, cost and risk involved in implementing the additional measures and controls?
 Having taken the additional measures and controls, how much better would the result be?
 Is this effort worthwhile the resulting benefit? (in terms of cost, time, difficulty, necessary
resources).
After the selection of the NEW control measures, the Risk Ranking process must be repeated in order
to evaluate if the risk is reduced to a lower Category i.e. from High to Medium. The process must be
repeated again in order to reach the lowest possible category.
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2.6.6 Step 6: Evaluation / establishment of additional controls and review of the Residual Risk
The selection of the most appropriate approach to assess the risk and define the control measures is
dependent on the level of uncertainty or risks associated with the hazards of performing the task.
After calculating the risk factor for every hazard referred to, control measures / safeguards must be
decided in order to:
 Eliminate hazard;
 Reduce the likelihood of occurrence of an adverse event;
 Reduce the severity of the consequences;
 A combination of all three above.
The aim is to reduce the Risk Factor to “As Low as Reasonably Practicable” by identifying all of
the safeguards needed to control the hazard. Existing safeguards must be also included.
The Integrated Management System already has a number of procedures for provision of a safe
system of work within the Vessel, which can be considered as providing the framework for the risk-
based approach to Safety Management.
These include:
 Procedures, forms, checklists.
 Training requirements.
 Safe Working Conditions.
 Work Permits.
 Fitness for Duty etc.
A. Establishment of Additional Controls

The result of a Risk Assessment must be a set of measures, controls and actions required in order to
establish, maintain and improve the safe operations.
Controls must be chosen, taking into account the following, in order of effectiveness:
1. If possible, eliminate hazards altogether at their source (e.g. use a safe substance instead of a
harmful one).
2. If elimination is not possible, try to reduce the risk (e.g. where there are risks of electrocution,
use a low voltage electrical appliance).
3. Consider controls and measures to reduce the likelihood of one or more events (e.g. by better
design, planning, increased supervision, additional training, additional PPE, stand-by personnel
and safety equipment etc).
4. Consider controls and measures to reduce the frequency of failures (e.g. through better design,
planning, additional training, increased supervision, stand-by personal and safety equipment etc).
5. Consider controls and measures to reduce the Severity of consequences (e.g. suitable / additional
PPE, stand-by personnel, standby safety equipment etc).
6. Consider controls and measures to reduce all (likelihood, frequency, severity).
7. Consider controls to alleviate (reduce / lessen) the circumstances in which failures may occur
(e.g. breakdown of communication, misunderstanding, equipment failure etc).
8. Where possible, adapt work to the individual e.g. take account of the individual’s mental and
physical capabilities, possible phobias etc
9. Take advantage of technical capabilities to improve controls.
10. Introduce or ensure continuation of Planned Maintenance, e.g. Machinery safeguards.
11. Ensure that Emergency arrangements are in place.
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12. Personal Protective Equipment is the last resort, after all control options have been considered.
13. In addition to Emergency plans, it may be necessary to provide specific Emergency Equipment
relevant to the specific hazards.
B. Review of the Residual Risk & the Risk Assessment Result

The Risk Assessment must be reviewed before implementation considering the following:
1. Will the revised safety measures and controls lead to tolerable risk levels?
2. What do people affected think about the need for and practicality of the revised safety and
preventive measures?
3. Have they fully understood what exactly to do, how to do it, with what sequence, what equipment
must be used, what equipment must be worn, the agreed methods of emergency communications,
agreed emergency signals? (Daily Work Plan & Tool Box Meeting)
4. Will the revised safety measures and controls be used in practice and not ignored in the face of
i.e. pressure to get the job done?
5. During the work, is the occurrence of new hazards possible?
2.6.7 Step 7: Follow- up

Upon identifying all necessary safeguards, a new Risk Factor must be calculated taking into
consideration the above additional / residual measures. Those making the assessment must decide
whether each risk result can be accepted, basing their judgment on the number and effectiveness of
safeguards available to control that risk.
The higher the perceived risk for any particular hazard, the greater must be the number and / or quality
of independent safeguards.
After the completion of the Risk Assessment, follow-up evaluations of the controls and measures
must be conducted, in order to ensure that they are in place and have the desired effect.
Continuous monitoring of changes must be made, which may occur in new hazards being
identified.
On completion of the Risk Assessment, the safeguards specified by those making the assessment must
be implemented, including any training and / or special briefing to the person performing the work.
The Master and the Chief Officer or the Chief Engineer must be satisfied that the required safeguards
are in place, and that all the risks will be adequately controlled before the permit is issued to allow
work to begin.
If new hazards are identified, these must be evaluated and adjustments to the Risk Assessment
must be made and approved. All personnel affected must be advised of the changes.
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2.7 RISK ASSESSMENT CASES
For those Risk Assessments that must be carried out by office personnel, the Risk Assessment
Cases are not applicable.
2.7.1 CASE 1: A relevant Risk Assessment EXISTS in the “Risk Assessment Library”
In case the Job Risk Assessments Library includes a relevant Risk Assessment template, then the
following procedure must be implemented:
1. The Library Risk Assessment template must be reviewed to determine if Hazards & Controls
included are enough or additional measures / adjustments are being required.
2. In no additional measures are necessary then proceed to step 4 below.
3. If additional hazards or additional controls / safety measures are required that are not included in
the standard template, then the following course of actions applies:
a. Additional hazards / control measures must be amended in the relevant RA fields.
b. The modified RA must be forwarded to Office (through the ERP Software Replication
process) for:
1. Review and Approval.
The relevant Office Department must review the amended Risk Assessment, make changes and
improvements - as required - and forward the Risk Assessment back to the Vessel through the
ERP system. Vessel must be notified to proceed with the planned work as per the final version
of the Risk Assessment forwarded from Office.
Exemption from the above rule:

Some significant Risk Assessments which are included in the Company’s Control Library,
always require approval from Office before proceeding with the Task, even if the residual risk is
Low. These have been marked in the ERP Software accordingly (i.e. A-01 Hot Work, B-13
Reduced UKC while the Vessel is alongside etc).
4. Verify Controls by:
a. Checking / defining Risk reduction impact upon relevant Hazards
b. Assigning time & person responsible.
5. Update Additional Precautions Tab stating No if no amendments have been performed or Yes
Otherwise.
6. Define Contingency Plan actions.
7. Attach any relevant hardcopy record necessary and make reference to any other ISM record
submitted electronically through the ERP Software.
8. Submit final Risk Assessment to Office.
9. In case of amended Risk Assessment, this must be taken into consideration by the Company’s
Risk Assessment Team for improving / upgrading the Risk Assessment Library. Any such
improvement must be circulated to the entire fleet through the ERP Software.
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2.7.2 CASE 2: Relevant Risk Assessment DOES NOT EXIST in the “Risk Assessment
Library”
In case that the Risk Assessment Library does not include a relevant Risk Assessment, then the
following procedure must be implemented:
1. A new Risk Assessment must be issued by the Vessel’s Personnel.
2. The new RA must be forwarded to Office (through the ERP Software Replication process) for:
Review and Approval.
The relevant Office Department must review the new Risk Assessment, make changes and
improvements - as required - and forward the Risk Assessment back to the Vessel through the ERP
system.
The Vessel must be notified to proceed with the planned work as per the final version of the Risk
Assessment forwarded from Office.
Although Officers may issue Risk Assessments, related to their duties and responsibilities, these Risk
Assessments must be reviewed and approved by the Master, before their submission to Office.
2.8 REVIEW OF THE COMPANY’S RISK MANAGEMENT PROGRAM BY THE RELEVANT OFFICE
DEPARTMENTS
The effectiveness of the Risk Assessment Management Program must be discussed Quarterly during
the Management Review Meetings.
The Company’s Risk Assessment procedure and Control Library must be reviewed by the Risk
Assessment Team, (consisting of the relevant Department Managers or designated Members and the
DPA, as required), collating all Risk Assessments with end target to improve IMS and / or existing
Risk Assessments templates.
Risk Assessments for routine tasks are used to develop safe working procedures and are entered into
the IMS.
The existing Risk Assessments which are included in the Control Library, must be reviewed on
an ANNUAL Basis, by the relevant Office Departments.
The results of the review of the Risk Assessment Control Library (New Risk Assessments and
Amended) are discussed during the Management Review Meetings, which is uploaded in the
Company ERP as a “Circular”, accessible to Shipboard Personnel for review.
2.9 RISK ASSESSMENTS INCLUDED IN SAFETY MEETING MINUTES ONBOARD

The Risk Assessment Program must be discussed on board, during regular Safety Meeting. The Safety
Meeting Agenda includes an Item, which reads:
“Safety monitoring, potential unsafe situations, deviations from safety procedures (Deck, Engine
Room, Accommodation, Other) and Risk Assessments associated with routine and non-routine
repairs or hazardous operations (Work Activity Hazards, controls in place, personnel at risk,
likelihood of harm, severity of harm, actions to be taken following the assessment)”.
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The existing Risk Assessments (as found in Control Library) or the amended and / or newly issued
ones, either by the Vessel or other Fleet Vessels, must be discussed or analysed.
By discussing Risk Assessments during Safety Meetings, the Company ensures that all crew are
involved in the Hazard Identification and Risk Assessment process and thus they are being trained in
assessing unsafe acts and conditions, on increasing their safety consciousness and on improving the
Behavioural Safety on board.
2.10 TRAINING IN HAZARD IDENTIFICATION AND RISK ASSESSMENT OF SENIOR SHIPBOARD

OFFICERS
As per Company’s Policy, Senior Shipboard Officers receive Hazard Identification and Risk
Assessment Training in recognized Training Centres, either in their own country, or when visiting
the Head Office, during the Briefing / Familiarization visit, or during the De-briefing visit.
Additionally, all Crew must view the Seagull Training “Risk Assessment and Incident
Investigation” as well as the relevant Information Security e-learning modules as per the Seagull
CBT Training Matrix.
2.11 TRAINING IN HAZARD IDENTIFICATION AND RISK ASSESSMENT OF OFFICE EMPLOYEES

As per Company’s Policy, as a minimum, Office Key personnel receive Hazard Identification and
Risk Assessment Training. Such training is mandatory for:
 All Office Department Managers
 Fleet Managers
 Ship Operations
 Ship Managers / Superintendents.
 Superintendents.
 Internal Auditors.
Focusing on Information Security, training objectives are accomplished through the Seagull e-
learning relevant modules. These are mandatory for all Office personnel apart from the Counter
Measures CBT that is mandatory only for Department Managers, Deputies, CSO & A-CSO.
2.12 RISK ASSESSMENT MANAGEMENT THROUGH PROACTIVE SAFETY CAMPAIGNS

Top level Management supports pro-active Safety Campaigns by encouraging feed-back from the
Vessels, communicated to the Company:
 In Masters’ Reviews.
 In Near Miss reporting.
 During Safety Meetings held on board, as well as in meetings held during the visits of Office
representatives.
 During Officers’ and Ratings’ Conferences.
 In Behavioural Safety Campaigns.
 In various Concentrated Safety Awareness Campaigns.
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Established Key Performance Indicators are part of Safety Campaigns.

In addition, the Company has established and supports proactive safety campaigns, by circulating to
all the Vessels Safety Bulletins from Classifications Societies, P&I Club, Marine Industry, Flag
Administration, etc.
2.13 HEALTH RISK ASSESSMENTS

The Company is responsible to develop Vessel Health Risk Assessments, based on identified hazards.
A. Hazards which have an adverse effect on health are:
Chemical effects Such as exposure to toxic gases, contact with corrosive chemicals, lack
of oxygen, exposure to airborne particles especially asbestos, etc.
Tolerable exposure limits for chemical hazards are defined in various
National / International Standards.
Biological hazards Such as microorganisms.
Physical effects Such as temperature, noise, vibration and motion, radiation, pressure,
etc.
Ergonomic effects Such as tripping, strains due to lifting, repetitive actions, etc.
Psychological effects Such as stress, effects of height, etc.
Life Style Such as eating habits etc).

Medical Issues.
When Health Hazards are identified, their severity must be assessed, in order to develop the
relevant Health Risk Assessments. Control and contingency measures must be taken in order to
reduce the probability and the frequency of the hazardous events.
Such controls may include:
 Specialized Personal Protective Equipment (i.e. Chemical Resistance suits, gloves, eye
protection (face visors), Aprons, etc.)
 Provision of Specialized Rescue arrangements.
 Emergency Medical facilities including specific antidotes, etc.
B. Material Safety Data Sheets (MSDS).

Material Safety Data Sheets (MSDS) are effective tools in identifying health hazards and
precautionary measures when using or handling hazardous substances. MSDS are usually based
upon the best available information relating to the particular hazard, and need to be kept up to
date. They may be produced by national or international bodies or by the Company and form a
"checklist" of aspects relating to the particular material, process or task.
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Although the exact form of the MSDS varies, the following data are normally included:
 Specification of the material, process or task covered by that particular Data Sheet.
 Definition of the range of materials or situations for which the data sheet is valid.
 Hazards associated with the material, process or task.
 Precautionary measures to be taken.
 Contingency measures considered to guard against the possible realization of the hazards.
 Abnormal situations which give rise to particular hazards, e.g. effect of weather, etc.
The Company has issued a series of Health Risk Assessments as follows:

 Food Handling.
 Asbestos Exposure.
 Working under Noise & Vibration.
 Working close to hot work surfaces etc.
Additionally:
 The Company conducts annual Benzene Tests of crew serving on Chemical Tankers.
 Noise and Vibration is monitored during Superintendents’ Visits on board.
 Health Campaigns are initiated on a regular basis, and Vessel feedback is being reviewed and
investigated. Where necessary, additional measures and resources are provided.
 Adverse reports for medical conditions, indicating long or short term effects related to handling
of hazardous materials, are thoroughly investigated and assessed.
 Information on the potential hazards of materials is kept current and a process for the
management of occupational health is in place.
 Based upon assessed risk to personnel, exposure is being monitored, proper protective and
preventive measures are being implemented and communicated, early detection and diagnosis
are being provided and pertinent health data are being recorded and reviewed.
Tables in attached Annex A provide guidance which may be used for the identification of hazards,
their sources and their possible effects.
This hazards’ categorization reflects the category considered likely to be most important for that
particular hazard, but does not mean or imply that other categories may not be more important in
certain applications.
Moreover, the inclusion of one hazard category does not preclude other categories also being relevant.
Hazards described in the Annex A are to be considered as applicable to the type of Vessel.
2.14 INFORMATION SECURITY RISK ASSESSMENT
2.14.1 Information Security Risk Assessment

Information Security Risk Assessment scope includes the following two (2) asset categories for both
Office & Vessel:
 IT: Information Technology.
 OT: Operational Technology.
For this purpose the list of IT & OT Hardware and Software both in Office and Onboard must be
evaluated in order to determine the Information Risk per item as per process detailed below. Updated
Page 22 of 25
(002) Revision: 08
IT and OT Systems’ List is found in Annex A of Procedure 27A –“Software Management Procedure”
of this Manual.
It must be noted that the Information Risk Analysis process must not be limited exclusively to the
two above asset categories but must also expand to include any other relevant asset involved not
supported by IT / OT such as personnel, site, location etc that may be directly involved and affect the
Information Security Threat (Hazard) manifestation.
2.14.2 Identification of Information Security Threats (Hazards) and Vulnerabilities

Information Security Threat (Hazard) Identification is the first and in many ways the most critical
step related to Information Security Risk Assessment. It serves to identify “what could go wrong”.
The key objective of “Information Security Threat (Hazard) Identification” can be summarized as
follows:
 Completeness: Full list of potential threats (both intentional and unintentional).
 Knowledge Based: Awareness based on past incidents and other work issues.
 Multi-disciplinary: Lateral Thinking based on diverse experiences.
In practice, various professional websites can be referred to in order to identify Information Security
Threats (Hazards) as per guidance above i.e.:
 European Union Computer Emergency Response Team.
 Department of Homeland Security - United States Computer Emergency Response Team.
 Carnegie Mellon University – Software Engineering Institute – Computer Emergency Readiness
Team.
 The Register.
Additionally, relevant reports and publications provide an overview of Information Security Threats
(Hazards) i.e.:
 DNV GL - DNVGL-RP-0496 – Recommended practice: Cyber security resilience management.
 ABS – Cyber Security Resources & Guidance Notes.
 BIMCO - The Guideline on Cyber Security Onboard Ships.
 USCG – Cyber Strategy.
 NIST Special Publication 800-82 – Guide to Industrial Control System (ICS) Security.
 German Information Security Agency – Industrial Control System Security – Top 10 Threats and
Countermeasures 2016.
2.14.3 Risk Estimation

Information Security Risk Estimation is performed in compliance with paragraph 2.6.4 directives. It
considers both the Information Security Threat (Hazard) effects - Severity of Consequences – as well
as the probability – Likelihood of occurrence of the Information Security Threat (Hazard).
Prime Risk Assessment Matrix included as Annex B of this procedure has been updated regarding
Consequence definitions. In particular, Severity of Consequence criteria have been modified in order
to correspond to:
 Confidentiality,
 Integrity &
 Availability.
Page 23 of 25
(002) Revision: 08
of assets, data and resources involved in Information Security as per table below. Meanwhile
Likelihood definitions have been addressed as per paragraph 2.6.3 references.
Consequence Severity Rating Scale.

# Description Criteria
Critical violations of confidentiality / integrity; critical asset / data / resource
Hazardous
1 unavailable; Critical violations of procedures / process / policies; Problem either
Effect
known or unknown but cannot be controlled.
Major violations of confidentiality / integrity; critical asset / data / resource
2 Major Effect unavailable; major violations of procedures / process / policies. Problem known
and can be controlled.
ModerateModerate violations of confidentiality / integrity; non-critical asset / data /
3
Effect resource unavailable; moderate violations of procedures / process / policies.
Minor violations of confidentiality / integrity; minor effect on availability of
4 Minor Effect asset / data / resource available; minor violations of procedures / process /
policies.
No effect; confidentiality / integrity not endangered; asset / data / resource
5 No Effect
available; minor violations of procedures / process / policies.
Furthermore, the cause of the threat is being described. This is called a “Risk Scenario” and is plotted
on the Risk Matrix (see Annex B).
2.14.4 Risk Evaluation

Risk Evaluation is performed in compliance with paragraph 2.6.6 requirements and using the Risk
Assessment Matrix included as Annex B of this procedure.
All Information Security Threat (Hazards) are being documented in the Information Security Risk
Assessment template included as Annex C of this procedure.
Annex C also documents the cause of the Information Security Threat (Hazard).
This allows for a “Risk Scenario” to be is plotted on thus facilitating the Initial Risk evaluation.
High and Medium risk scenarios must receive further evaluation and risk reduction measures –
Controls - must be applied. These must be again documented in Annex C.
Meanwhile Low risk scenarios may not be considered further or a simple reference to the risk
assessment matrix can be made to be used as evidence of the particular Information Security Threat
having being evaluated.
2.14.5 Risk Reduction

Risk reduction measures are Controls acting as improvements to the design or operation of the Cyber
Information Security asset that are applied in order to enhance the security level and mitigate the
initially evaluated Information Security Risk.
Available Risk mitigation actions include:
 Avoidance.
 Reduction.
 Acceptance & Transfer.
Page 24 of 25
(002) Revision: 08
Classification above is being based on the DNVGL guidance RP-0496-Recommended practice:

Information security resilience management - Table 3-1.
The following step-by-step process applies:
 Update the Information Security Risk Assessment Template – Annex C - including a list of
all IT & OT assets with initial Information Security related Risk as per guidance in paragraph
2.15.4.
 For systems with High & Medium initial risk assign a set of mitigating measures – Controls
– as per above DNV-GL-RP-0496 publication Appendices E, F & G in order to reduce
Residual risk to Low as per ALARP principle and document in Annex C.
 Departments being owners of the IT / OT assets above will make sure that controls defined
will be implemented.
 All above the will be documented Information Security Risk Assessment Template – Annex
C.
2.15 CRITICAL EQUIPMENT & SYSTEMS

The Company has identified the Critical Equipment and Systems, following relevant Risk
Assessments as per Annex D of this procedure.
3. RECORD
 ERP Software Module
Page 25 of 25
(002) ANNEX A: HAZARD IDENTIFICATION Revision: 03
GUIDANCE Eff. Date: 01/03/2016
TABLE 1: THE HAZARDS AND EFFECTS CHECKLIST
Safety hazards Health hazards Environmental hazards
F = Flammable B = Biological agent D = Discharge hazards
MH = Major Hazard C = Chemical agent R = Use of natural resources
Se = Security hazard E = Ergonomic agent Pr = Presence
WP = Work Practice P = Physical agent
LS = Life style agent
Psy = Psychological agent
M = Medical issue
Environ-
Safety Health Sources
Hazard description mental
1. Hydrocarbons
Oil under pressure MH C D Flowlines, pipelines, pressure vessels
and piping
Hydrocarbon gas MH C D Oil/gas separators, compressors, gas
pipelines
Oil at low pressures MH C D Oil storage tanks
Wax F C D Filter separators, well tubulars,
pipelines
Coal F P R Fuel source
LPGs (e.g. Propane) MH C D Process fractionating equipment,
storage tanks, LPG vessels
LNGs MH C D Cryogenic plants, LNG carriers
Condensate, NGL MH C D Gas wells, gas pipelines, gas
separation vessels
Page 1 of 15
TABLE 1: THE HAZARDS AND EFFECTS CHECKLIST- continuing
Environ-
Safety Health Sources
Hazard description mental
2-Refined hydrocarbons
Lube and seal oil - C D Engines and rotating equipment
Hydraulic oil - C D Hydraulic pistons, hydraulic reservoirs
and pumps
Diesel fuel F C D Engines, storage
Petroleum spirit/gasoline F C D Storage
03-Other flammable materials

Cellulosic materials F - - Packing materials, wood planks, paper
rubbish
Pyrophoric materials F C D Metal scale from vessels in sour
service, scale on filters in sour service,
iron sponge sweetening units
04-Pressure hazards
Bottled gases under pressure WP - - Welding and metal cutting operations
Water under pressure in WP - - Water disposal, water floods and
pipeworks injection operations, strength testing of
pipeworks
Non-hydrocarbon gas under MH - - Purging and leak testing of facilities
pressure in pipeworks
Air under high pressure WP - - Air guns and related piping
Oil and hydrocarbon gas WP - D Flowlines, pipelines, pressure vessels
under pressure and piping
Page 2 of 15

05-Hazards associated with differences in height
Personnel at height >2 m MH - - Work involving scaffolding,
suspended access, ladders, platforms,
towers, stacks, roofing, working
overboard, working on monkey board
Personnel at height <2 m WP - - Slippery/ uneven surfaces, climbing/

descending stairs, obstructions, loose
gratings
Overhead equipment MH - - Objects falling while being lifted/
handled or working at a height over
people, equipment or process systems,
elevated work platforms, slung loads
Personnel under water MH - - Objects falling onto divers from
operations overhead
06 -Objects under induced stress

Guy and support cables, anchor chains,
Objects under tension WP - - tow and barge tie-off ropes, slings
Spring-loaded devices, such as relief
Objects under compression WP - - valves and actuators, and hydraulically
operated devices
07 -Dynamic situation hazards
On-water transport (boating) WP - - Boat transport to and from locations
and camps, transporting materials,
supplies and products
Boat collision hazard to MH - - Shipping lane traffic, transport vessels,
other vessels and offshore supply & maintenance barges/ boats,
structures drifting boats
Equipment with moving or WP - - Engines, motors, compressors
rotating parts
Use of hazardous hand tools WP - - Workshop, construction sites,
(grinding, sawing) maintenance sites, rotating equipment
Use of knives, machetes and WP - - Galley

other sharp objects
Transfer from boat to ship WP - - Basket transfer, rope transfer
Page 3 of 15
08-Environmental hazards
Weather WP - - Winds, temperature extremes, rain,
etc.
Sea state MH - - Waves, tides or other sea states
09-Hot surfaces
Engine and turbine exhaust WP P - Power generation, refrigeration
systems compression, engine-driven
equipment i.e. forklifts
Steam piping WP P - Sulfur plants, power boilers, waste
heat recovery systems, heat tracing and
jackets
10-Hot fluids
Temperatures 100°-150°C WP P - Low quality steam systems, cooling
oils, galley
Temperatures greater than MH P - Power boilers, steam generators, waste
150°C heat recovery units, hot-oil heating
systems, regeneration gases used with
catalysts and desiccants
11-Cold surfaces
Process piping between - MH P - Cold ambient climate, propane
25°C and - 80 °C refrigeration systems
Oceans, seas and lakes less - P - Northern and Southern oceans and
than 10°C lakes
12--Open flame
Heaters with fire tube F P D Boilers, heaters
Direct-fired furnaces F P D Hot oil furnace, incinerators, boilers
Flares - P D Pressure-relief & blowdown systems
Page 4 of 15
13-Electricity
Voltage> 50 V to 440 V in MH - - Power cables, temporary electrical
cables lines
Voltage> 50 V to 440 V in WP - - Electric motors/ switchgear, power
equipment generation, welding machines,
transformer secondary
Voltage> 440 V MH - - Power lines, power generation,
transformer primary, large electrical
motors
Lightning discharge WP - - Major lightning-prone areas
Electrostatic energy WP - - Non-metallic storage vessels and
piping, product hoses, wiping rags,
unearthed equipment, aluminium/
steel, high-velocity gas discharges
14-Electromagnetic radiation
Ultraviolet radiation - P - Arc welding, sunshine
Infrared radiation - P - Flares
Microwaves - P - Galley
Lasers - P - Instrumentation, surveying
15-Asphyxiates
Insufficient oxygen - C - Confined spaces, tanks
atmospheres
Excessive CO2 - C D Areas with C02 firefighting systems
Drowning - C - Working overboard, water transport
Halon - C D Areas with halon fire-fighting systems
i.e. turbine enclosures, electrical
switchgear, battery rooms
Smoke - C D Welding/burning operations, fires
Excessive N2 - C - N2 purged vessels
Page 5 of 15

16-Toxic gas
H2S (hydrogen sulfide, sour MH C D Sour gas production, bacterial activity
gas) in stagnant water, confined spaces in
sour operations
Exhaust fumes - C D Enclosed spaces
SO2 - C D Component of H2S flare and
incinerator flue gas
Benzene - C D Component of crude oil, concentrated
in glycol vent emissions
Chlorine MH C D Water treatment facilities
Welding fumes - C - Metal fabrication/repair, welding toxic
metals (galvanized steel, cadmium-
coated steel), metal cutting, grinding
Tobacco smoke - LS - Accommodation, office buildings,
boats
CFCs - - D Air conditioning, refrigeration, aerosol
sprays
Vinyl Chloride Monomer - C D Cargo in LPG vessels
(VCM)
17-Toxic liquid
Mercury - C D Electrical switches, gas filters
PCBs - C D Transformer cooling oils
Biocide (Gluteraldehyde) - C D Water treatment systems
Methanol - Glycols - C D Gas drying and hydrate control
Sulfanol - Amines - C D Gas sweetening
Corrosion inhibitors - C D Additive to pipelines, chromates,
phosphates
Scale inhibitors - C D Cooling and injection water additive
Odorant additives - C D Custody transfer facilities for gas, LPG
(mercaptans) and LNG
Alcohol-containing WP LS -
beverages
Non-prescribed drugs WP LS -
Polycyclic aromatic - C D Used engine oils
hydrocarbons
Grey and/ or black water - D Septic systems, camps, detergents
Page 6 of 15

18-Toxic solid
Asbestos - C D Thermal insulation and construction
materials, old roofing (encountered
during removal)
Man-made mineral fibre - C D Thermal insulation and construction
material
Dusts - C D Grit blasting, sand blasting, catalyst
(dumping, screening, removal,
drumming)
Cadmium compounds and - C D Welding fumes, handling coated bolts
other heavy metals
Oil-based sludges - C D Oil storage tank cleaning
19-Corrosive substances
Sulfuric acid WP C D Wet batteries, regenerant for reverse-
osmosis water makers
20-Biological hazards
Food-borne bacteria (e.g. - B - Contaminated food
E.coli)
Water-borne bacteria (e.g. - B - Cooling systems, domestic water
Legionella) systems
Parasitic insects (pin worms, - B - Improperly cleaned food, hands,
bed bugs, lice, fleas) clothing, living sites (pin worms, bed
bugs, lice, fleas)
Human Immune Virus (HIV) - B - Contaminated blood, blood products,
body fluids
Other communicable - B - Other people
diseases
21-Ergonomic hazards
Manual materials handling - E - Pipe handling, sack handling in sack
store, manoeuvring equipment in
awkward locations
Damaging noise WP P Pr Releases from relief valves, pressure
control valves
Loud steady noise> 85 dBA - P Pr Engine rooms, compressor rooms, air
tools
Heat stress (high ambient - P - Near flare, on the monkey board under
temperatures) certain conditions, in open exposed
areas in certain regions of the world
during summer
Page 7 of 15

21-Ergonomic hazards- continuing
Cold stress (low ambient - P - Open areas in winter in cold climates,
temperatures) refrigerated storage areas
High humidity - P - Climates where sweat evaporation
rates are too low to cool the human
body, personal protective clothing
Vibration - P Pr Hand-tool vibration, maintenance
worker, boating
Workstations - E - Poorly designed office furniture and
poorly laid out workstations
Lighting - P Pr Work areas requiring intense light,
glare, lack of contrast, insufficient
light
Incompatible hand controls - E - Controls poorly positioned requiring
workers to exert excessive force, no
proper labels, hand-operated control
valves, i.e. in heavy machinery
Awkward location of - E - Machinery difficult to maintain
workplaces regularly due to their awkward
and machinery positioning, for example valves in an
usually high or low position
Mismatch of work to - E - Requiring older workers to maintain a
physical abilities high level of physical activity over the
course of an 8/12 hour day, heavy
work performed by slight individuals
Mismatch of work to - E - Requiring individuals to monitor a
cognitive abilities process without trying to reduce their
boredom by giving them a higher task
load, asking a worker to supervise
something he is not qualified to do
Long & irregular working - E - Overtime, night shifts, rollover shifts
hours/shifts
Poor organization and job - E - Ambiguity of job requirements,
design unclear reporting relationships,
over/under-supervision, poor
operator/contractor interfaces
Work planning issues - E - Work overload, unrealistic targets,
lack of clear planning, poor
communications
Indoor climate (too hot, cold, - E - Uncomfortable climate for
dry, humid, draughty) permanently manned areas
Page 8 of 15

22-Psychological hazards
Living on the job/away from - Psy - Homesickness, missing family and
family social events, unable to be involved in
community, feeling of isolation and
missing part of life. Drifting away
from spouse and family, development
of different interests and friends,
threatened by spouse's independence,
wind-down period at start of break.
Inability to support spouse in domestic
crisis. Difficult to turn off in leisure
time
Working and living on a ship - Psy - Awareness that mistakes can be
catastrophic, vulnerable to mistakes of
others, responsible for the safety of
others. Awareness of difficulty of
escape in an emergency. Awareness of
risks in work, adverse weather
Post traumatic stress - Psy - Serious incidents, injuries to self and
others
Fatigue - Psy - Physically demanding or arduous
work, long or excessive working hours
Shift work - Psy - Construction, operations involving 24
hour working, saturation diving
operations, changing rest and sleep
patterns associated with activities
Peer pressure - Psy - Pressure from others at the work
location to behave in a manner which
may affect well-being of the individual
23-Use of natural resources

Water - - R Cooling water
Air - - R Turbines, combustion engines (pump
and compressor drivers)
24-Medical
Medical unfitness - M - Medically unfit staff for the task
Motion sickness - M - Marine operations
Page 9 of 15

25-Noise
High-level noise - M - Plant areas, e.g. turbines, compressors,
generators, etc.
Intrusive noise - Psy - Intrusive noise in sleeping areas,
offices and recreational areas
26-Entrapment
Fire / explosion MH - - Blockage of routes to muster location
or contamination of muster area
Mechanical damage WP - - Objects blocking access / escape routes
Diving WP - - Snagging of lines / umbilicals
Page 10 of 15
TABLE 2: SOURCES - HAZARDS – EFFECTS
Source Routine Hazards Potential effects
FLARE CH4 Global warming/ climate change/ atmospheric ozone

increase
SOx Acid deposition, water acidification
NOx Atmospheric ozone increase/ acid deposition
N2O Global warming/ stratosphere ozone depletion/ climate
change
CO2 Global warming/ climate change
CO Health damage
Noise Nuisance/ health damage
Light Nuisance/ health effects
H2S Health damage/ odour nuisance
Odorous compounds Nuisance/ odour
Particulates Health damage/ ecological damage/ soot deposition
Radiation Health damage/ ecological
Heat Nuisance/ ecological damage
Trace toxics/ metals/ Ecological/ health damage
PAH
ENERGY- CH4 Global warming/ climate change/ atmospheric ozone
GENERATING increase
EQUIPMENT SOx Acid deposition, water acidification, global cooling
turbines NOx Atmospheric ozone increase/ acid deposition/ fertilization
boilers/heaters N2O Global warming/ stratosphere ozone depletion/ climate
change
furnaces CO2 Global warming/ climate change
transport (diesel, CO Health damage
gasoline), etc Noise Nuisance/ health damage/ wildlife damage
Light Nuisance/ health damage/ wildlife damage
Odorous compounds Nuisance/ odour
Particulates/dust Ecological damage/health damage/soot deposition
Radiation Ecological/ health damage
PAH Ecological/ health damage
H2S Nuisance, health damage, ecological damage
Heat Health damage, ecological damage
PCB Health damage, ecological damage
Trace toxics (e.g. Health damage, ecological damage
catalysts, heavy
metals, chemicals)
VENTING CH4 Global warming/ climate change/ atmospheric ozone
increase
pressure relief VOC/ CxHx Atmospheric ozone increase/ health damage/ ecological
damage
glycol venting Specific chemicals Health damage/ ecological damage
Page 11 of 15
Source Routine Hazards Potential effects
Refrigeration CFC Global warming/ climate change/ stratosphere ozone

depletion
Fire Extinguishers Halons Global warming/ climate change/ stratosphere ozone
depletion
Fugitives CH4 Global warming/ climate change/ atmospheric ozone
increase
valves, pumps, etc. VOC/ CxHxl specific Global warming/ climate change/ atmospheric ozone
chemicals increase/ health damage/ ecological damage
Water , Water-based Oil Floating layer/ unfit for drinking recreation/ tainting of fish/
Mud biological damage
Oil—based Mud
Aqueous Effluents, Soluble Tainting of fish, damage to aquatic organisms
site drains DRAINS organics/dissolved
HC/ BTEX
Water Run-off Heavy metals Accumulation in living organisms and sediments, adverse
effects on organisms
Produced Water Salts Biological damage
Cooling Water Barite (mud) Smothering/ damage to sea bed and biota
Tank Bottom Nutrients Eutrophication
Water Odour Nuisance

Chemicals/corrosion Damage to aquatic organisms
inhibitors/biocides/
fungicides
Fresh-water discharge Decreased salinity
Suspended solids Decreased transparency, damage to coral reefs, damage to
and bottom organisms, recreation, habitat
PAH Damage to aquatic organisms
Grease Damage to bottom sediments
Salts/ brine Increased salinity, damage to aquatic organisms
Acids/caustics Damage to aquatic organisms
Temperature change Change in oxygen concentration, damage to aquatic
organisms, increased growth/blooms
Detergents Eutrophication/ toxicity
Black Water and /or Pathogens Health damage
Lack of Water and /or Anoxia
Biological damage
Grey Water (Sewage (deoxygenation)
amd Wash Water ) Nutrients Eutrophication
Specific chemicals Damage to aquatic organisms
Odorous compounds Nuisance odour/ smell
Sacrificial Anodes Heavy metals Damage to aquatic organisms
Page 12 of 15
Source Routine Hazards Potential Effects
Detonators Noise/pressure waves Damage to aquatic organisms/ repellent

Chemicals Paints Biological toxic or chronic damage/ global warming
Solvents Health/ biological toxic or chronic damage/ global warming
Cleaners Biological toxic or chronic damage
Eroded Materials Soil sediments Smothering, biological damage
Solid Liquid Wastes . Hazardous wastes Water contamination
Medical Waste. Spent toxic substances
catalyst
Household, Organic and specific Water contamination damage to health
Food/Kitchen and wastes pathogens
Office Waste
Human Resources Presence of workforce Socio/ cultural effects; employment increase/decrease;
with different socio/ demands on local resources/surfaces
cultural backgrounds
during construction
and operation;
community intrusion
Need for Energy Energy take Loss of energy resources
heaters/boilers
power generation
steam generation
cooling
Water take Damage to wetlands
Draw-down of ground-water level/ damage to water-well
cooling users
process Impact on downstream users
drinking water
waste waters
recharge/pressure
Need for consumable Use of non-renewable Depletion of raw materials

raw materials
Page 13 of 15
TABLE 3- FACTORS WHICH MAY LEAD TO HAZARDS & EVENTS

SUBSTANDARD CONDITIONS
SC 01. Inadequate Guards or Barriers
SC 02. Inadequate or defective PPE
SC 03. Inadequate Number of Equipment , Machinery or Tools
SC 04. Defective Equipment ,Machinery or Tools
SC 05. Hull or Structural Condition
SC 06. Inadequate Warning System
SC 07. Adverse Weather / Sea Conditions
SC 08. Poor Housekeeping/disorder
SC 09. Inadequate or Excess Illumination
SC 10. Fire and explosion Hazards
SC 11. Noise or Temperature Exposure
SC 12. Radiation Exposure
SC 13. Inadequate Ventilation
SC 14. Hazardous Environmental Conditions
SC 15. Outdated Charts, Publications and other Documents
SC 16. Port and Berthing Facilities
SC 17. Other Substantial Condition(s)
SC 18. High or Low temperature exposure
SC 19. Electrostatic Hazard
SC 20. Piracy Activities
SC 21. Design fault / Material Failure
SC 22. Inadequate number of Spares
SUBSTANDARD PRACTICES
SP 01. Failure to follow Rules and Regulations
SP 02. Failure to use PPE properly
SP 03. Operating Equipment or Mach W/O Authority
SP 04. Incorrect Use of Equipment or Machinery
SP 05. Using Defective Equipment or Machinery
SP 06. Failure to Follow Repair/Maintenance Instruction
SP 07. Incorrect Navigation or Ship Handling
SP 08. Failure to Warn
SP 09. Failure to Secure
SP 10. Making Safety Devices Inoperative
SP 11. Improper Position for Task
SP 12. Improper Lifting, Handling or Storage
SP 13. Horseplay/Inappropriate Behavior
SP 14. Under the Influence Alcohol &/or other Drug
SP 15. Failure to follow seamanship/practice
SP 16. Wrong direction order
SP 17. Other substantial Act(s)
SP 18. Inadequate communication
SP 19. Inadequate familiarization
SP 20. Record keeping
SP 21. Failure to follow Procedures
SP 22. Improper inspection
Page 14 of 15
TABLE 3- FACTORS LEADING TO HAZARDS- continuing
JOB FACTORS
JF 01. Improper or insufficient delegation
JF 02. Inadequate work planning/program
JF 03. Providing inadequate documentation and direction
JF 04. Lack of supervisory/management / job know
JF 05. Inadequate performance measure and evaluation
JF 06. Inadequate assess of operation readiness
JF 07. Inadequate or improper controls
JF 08. Inadequate monitoring or initial operation
JF 09. Inadequate evaluation of changes
JF 10. Inadequate specifications on requisitions
JF 11. Inadequate communication of safety & health data
JF 12. Improper handling of materials
JF 13. Improper storage of materials
JF 14. Inadequate identification of hazardous materials
JF 15. Inadequate preventive maintenance
JF 16. Inadequate assessment of needs & risks
JF 17. Inadequate standards of maintenance
JF 18. Inadequate monitoring of compliance
JF 19. Inadequate planning of use
JF 20. Inadequate inspection &/or monitoring
JF 21. Inadequate maintenance
JF 22. Use by unqualified or untrained people
JF 23. Inadequate tools or equipment
JF 24. Inadequate work standards
JF 25. Inadequate purchasing
JF 26. Excessive wear & tear
JF 27. Inadequate Leadership/supervision
JF 28. Lack of proper Attention
JF 29. Lack of Supervision
Page 15 of 15
PRIME TANKER OFFICE ICT INFORMATION PROC 28‐ Annex C1
PRIME GAS SECURITY RISK ASSESSMENT Issue Date:30/09/2022
Threat Top Subsequent

ID Hazard Location
(Direct Cause) Event Event
ICT Virus Exposure;
ICT Tracker Exposure;
Human Error*;
Uncontrolled Loss of ICT Ransom Exposure;
Both Ashore ICT Criminal act
A2‐1 Exposure to
and Onborad (Virus;
control Breakdown of ICT
Internet systems;
Malware, etc);
Breakdown of
Electronic equipment;
Human Error*
ICT Virus Exposure;
(Uncontrolled
ICT Tracker Exposure;
Uncontrolled use for USB
Loss of ICT Ransom Exposure;
Use of Portable Both Ashore Sticks on board
A2‐2 and Removable and Onborad for the purpose
control Breakdown of ICT
systems;
Media of Update
Breakdown of
systems or
Electronic equipment;
private use.)
Sensitive company
Human Error*
information released
(Uncontrolled
causing commercial
use for Social
Uncontrolled Unauthoriz impact;
Both Ashore Media on board
A2‐3 Use of Social
and Onborad and / or in the
ed data Release of vessels
Media disclosure position when
office);
transiting through
Social
piracy area causing
Engineering
Piracy Hazard
Loss of
control; Sensitive company
Attacking the
Data Loss; information stolen /
Information Both Ashore Company/
A2‐4 Security Crime and Onborad Vessels ICT
Data Leak: released;
Service Company/ Vessels ICT
systems;
Unavailabil system compromised;
ity;
Sensitive Company
Unauthorized Compromising
Information stolen/
Physical Access ICT Physical
Both Ashore released; Company/
A2‐5 to
and Onborad
infrastructure Access
Vessels ICT
Infrastructure/ physical Violation;
infrastructure
Systems integrity;
compromise;
Attacking the
Unable to
Company/
Respond in
Both Ashore Vessels ICT Unable to Company/ Vessels
Information
A2‐6 Security
and systems; bring back infrastructure
Onborad Terminal in service unvailability
Onborad; Terminal in service; unvailability;
Emergency
system Data inaccessible;
situations
malfunction;
Not being able
to address daily Company/ Vessels ICT
Unable to
Both Ashore challenges; Lack of system being
Manage
A2‐7 Operational
and Attacking 3rd Administra compromised;
Onborad; parties ICT tion; Data becoming
Environment
Systems; unavailable or
corrupted;
Attacking the
Company;
Vessels ICT
systems;
Human Error;
System
Malfunction;
Software Bug;
DoS Attacks;
Attacking 3rd
parties ICT Service
Unavailability Both Ashore
Systems; Unavailabil Business Processes
A2‐8 of and
Power failure ity; not running;
data/systems Onborad;
or fluctuation;
Failure of
environmental
control
systems;
Extreme
weather
conditions (hot,
storm, snow);
Earthquake;
Attacking the
Company/
Vessels ICT Sensitive company
systems; information stolen /
Unauthorized
Both Ashore Attacking 3rd Loss of released;
Access to
A2‐9 Data/ Data
and parties ICT confidenti Company/ Vessels ICT
Onborad; Systems; ality; system controls
Breach
Human Error; violated;
Internal user's Company/ Vessels ICT
Malicious system compromised;
Intent;
Attacking 3rd
parties ICT
Innapropriate
Both Ashore Systems; Data CIA
Company's Breach of Company's
A2‐10 Data Handling
and Human Error; Compromi
sensitive data;
Onborad; Malicious se;
by 3rd Parties
intent;
Unintentional Data
Non‐ Personal/ sensitive
Both Ashore or malicious protection
Compliance data being
A2‐11 with Legal
and breach of legal s safe
compromised;
Onborad; and regulatory mechanis
Framework
framework; ms failure;
The
User may not
procedure
have access to
s for
Hardware and the requested
Both Ashore Software/ Business Processes
A2‐12 Software
and Onborad
service, Staff
Hardware not running;
Upgrade unable to work;
upgrade
Unavailability
not
of Systems;
followed;
User may not
Company may Follow
have access to
not be able to Inadequat
the requested
meet its Both Ashore e Criteria Business Processes
A2‐13 contractual and Onborad
data;
for not running;
Staff unable to
obligations to Selection
work;
Customers; of Cloud
Initial Consequence of Cyber Risk on
Conseque Availability, Integrity & Authenticity
nces Company Procedures
Consequence Likelihood Risk
001‐IMSM Appendix Y ‐ Computer
Email & Internet Policy
002A‐ISMS Procedure 02A Asset
Management
Financial 002A‐ISMS Procedure 05A Protection
loss; Against Malicious Code
Damage of III C M
002A‐ISMS‐Procedure 05F ICT
Company's
Systems Lifecycle (Acquisition ‐
Reputation;
Termination)
002A‐ISMS Procedure 07A Network
and Communications Security
002A‐ISMS Procedure 05H
Configuration Controls
002‐PRO Procedure 23 Training
002A‐ISMS Procedure 06
Cryptographic Use
Financial 002‐PRO Procedure 23 Training
loss; 002A‐ISMS Procedure 05D Portable
Damage of III C M Device Security
Company's
Reputation; 002A‐ISMS Procedure 02B Physical
Media Transfer
001‐IMSM Appendix S ‐ Social Media
Policy
Injury;
Asset 001‐IMSM Appendix Z‐1 ‐ Mobile
Damage; Phone Use Policy
Financial
III C M
loss; 001‐IMSM Appendix Y ‐Computer, E‐
Damage of mail & Internet
Company's
Reputation; 001‐IMSM Appendix W ‐General Data
Protection Policy
002A‐ISMS‐PROC 05F_ICT Systems
Lifecycle (Acquisition ‐ Termination)
002A‐ISMS Procedure 02B Physical
Media Transfer
002A‐ISMS Procedure 04A Access
Management
002A‐ISMS Procedure 04B Password
Financial Security
loss;
002A‐ISMS Procedure 05B Technical
Damage of III D M
Vulnerabilities and Patch
Company's
Management
Reputation;
002A‐ISMS Procedure 05D Portable
Device Security
002A‐ISMS Procedure 05A Protection
Against Malicious Code
002A‐ISMS Procedure 01 Physical and
Environmental Security
Infrastructr Ship Security Plan
e Damage;
Information 002A‐ISMS Procedure 02B Physical
III C M Media Trasnfer
Leak;
Damage of 002A‐ISMS Procedure 03 Secure
Company's Disposal
Reputation;
Device
001‐IMSM Appendix Z‐5 Clear Desk
and Clear Screen Policy
Service 004‐EMP ZZ‐Appendix A Business
unavailabilit Continuity Plan
y; 002‐PRO Procedure 23 Training
Financial 002‐PRO Procedure 14 Accidents ‐
loss; III C H Incidents ‐ Near Misses
Damage of
Damage of
002A‐ISMS Procedure 05C Capacity
Company's
Management
Reputation;
002A‐ISMS Procedure 05I Backup
002A‐ISMS Procedure 02A Asset
Management
Configuration Controls
002A‐ISMS Procedure 05E Software
Management
Management
Service 002A‐ISMS Procedure 05I Backup
Unavailabili
ty; 002A‐ISMS Procedure 05G Hardware
II C H
Damage of Lifeycycle Management
Company's
Reputation; 002A‐ISMS Procedure 04A Access
Management
Security
Management
002‐PRO‐Procedure 27A Operation
Technology (OT) Software
Management
002A‐ISMS Procedure 01 Physical and
Environmental Security
Management
Security
Management
Injury &
Control
Management
Systems
automation
not 002A‐ISMS Procedure 05E Software
working; III C H Management
Financial
loss;
Damage of
Company's
Reputation;
Ship Security Plan
004‐EMP ZZ‐Appendix A Business
Continuity Plan
Management
002‐PRO Procedure 14 Accidents ‐
Incidents ‐ Near Misses
001‐IMSM Appendix Z‐6 Information
Classification Policy
002A‐ISMS Procedure 08 Information
Classification and Handling
Management
Security
Commercial 002A‐ISMS Procedure 07A Network
impact/ and Communications Security
Financial
loss;
III C M 001‐IMSM Appendix Y ‐ Computer
Damage of
Email & Internet Policy
Company's
Reputation;
002A‐ISMS Procedure 02B Physical
Media Transfer
002A‐ISMS Procedure 03 Secure
Disposal
Management
Management
Device Security
Cryptographic Use
Management
Commercial
001‐IMSM Appendix Z‐6 Information
impact;
Classification Policy
Problems
with
authorities;
III D M 002A‐ISMS Procedure 08 Information
Financial
Classification and Handling
loss;
Damage of
Company's
reputation; 002‐PRO Procedure 09 Suppliers and
Subcontractors
001‐IMSM Appendix W ‐General Data
Protection Policy
001‐IMSM Appendix W ‐General Data
Protection Policy
Management
Cryptographic Use
002A‐ISMS Procedure 05J Event
Logging
Company/v
essel 002A‐ISMS Procedure 08 Information
Certificatio Classification and Handling
n issues;
Lawsuits;
001‐IMSM Appendix Z‐5 Clean Desk
Fines;
and Clear Screen Policy
Problems
III D M
with
authorities; 001‐IMSM Appendix Y Computer, E‐
Financial mail & Internet
loss;
Damage of 002A‐ISMS Procedure 02B Physical
company Media Transfer
reputation;
002A‐ISMS Procedure 03 Secure
Disposal
004‐EMP ZZ‐Appendix A Business
Continuity Plan
002A‐ISMS Procedure 05G Hardware
Lifeycycle Management;
Asset Configuration Controls;
Damage;
Financial
loss; III C M 002A‐ISMS Procedure 05E Software
Damage of Management;
Company's
Reputation;
002A‐ISMS Procedure 05I Backup;
Management
Asset 002A‐ISMS‐Procedure 05F_ICT
Damage; SYSTEMS LIFECYCLE (ACQUISITION ‐
Financial TERMINATION);
III C M
loss;
Damage of
002A‐ISMS Procedure 05I Backup;
Company's
Controls
Electronic communications, including internal and external emails, voice, text messages, Internet use,
transmitted by or stored in Company's technology systems are controlled through appropriate technical
measures.
All proprietary information assets that are managed and/or used by Company's employees and all natural
persons and legal entities using and/or accessing organization’s ICT systems, such as equipment, electronic data,
ICT systems, hardware, software and channels of communication, including voice‐ telephony, email, internet,
intranet and paper documents are protected through the appropriate technical controls.
Company's ICT Systems, Information and Data are protected through the appropriate technical and
organizational measures against all forms of malware or malicious users.
The project scope address all Information Security Risks have been identified and provide specific controls
(Information Confidentiality, Integrity & Availability, Data Classification, Personal Data Handling, Remote Access
Issues, Business Continuity, Incident Response, Emergency Response & Contingency Planning).
Define rules and processes for controlled and monitored E‐mail, Web & Systems’ access both from within Internal
Network as well as External Domain – including wireless access as well as 3rd parties’ connectivity needs.
Company's ICT assets (hardware and software) are protected, operate as intended and the security of
information processing facilities is not compromised by following Best Practices and Maker's guidelines during
th fi ti
Information Security trainings are conducted to increase the awareness of the end users.
Company's Information and data is transmitted outside a secure network/system is protected using the
appropriate encryption mechanisms.
Company's ICT systems (during the remote connection from public access points or home networks) and portable
devices are protected through technological controls and specific guidelines that have been provided to end
users.
Access to USB ports on endpoint machines is blocked through a device control policy. Device control blocks
unauthorized media and prevents malware from spreading via removable media.
Disclosure of confidential, proprietary or sensitive information about the Company, its Employees, Customers,
Vendors, Contractors, Suppliers, Competitors and others, is strictly prohibited.
Comments on Social Media on Company related legal matters, financial performance, Competitors, strategy or
rumours is strictly prohibited as well.
The use of camera or other video or audio recording‐capable devices on company premises is prohibited without
prior permission.
Internal and external electronic communications is considered business record and may be subject to discovery in
the event of litigation.
All Employees who work for or with the Company, are held responsible for ensuring that Personal & Sensitive
Data is collected, stored and handled appropriately, in a manner that aims to minimize breaches of
confidentiality and reputational damage.
Define rules and processes for controlled, monitored and on a need‐to‐know basis access to Company's Systems
for both Company's employees and external collaborators.
Business information and data processed by third‐parties are subject to additional GDPR requirements.
Company has set Technocal Controls to protect the ICT Systems with strong passwords and appropriate
Organizational measures to inform users about best practices and increase their awareness.
Processes have been defined for monitoring possible vulnerabilities, vendors’ releases of patches and fixes and
installing software updates, patches and fixes on the ICT systems.
Penetration tests are to be performed biannually to identify potential vulnerabilities of Company's ICT Systems.
users.
All servers and communications equipment have adequate power supplies. The availability of power supply and
condition of Company's critical facilities are assured by using appropriate technical and Organizational measures.
Company has also set up both technical and Organizational measures to prevent the unauthorized access on both
vessels and Headquarters.
The computer room and per floor switch rooms are restricted areas and are under key and lock protection or
with card.
The physical access to vessel's is restricted and is under key and lock protection.
Company follows appropriate procedures and processes to destroy or dispose storage media and documents
containing Confidential information.
users.
The appropriate technical measures and guidence has been provided to employees to prevent the unauhorized
access to Company's ICt Systems and information/ data.
Company's Business Continuity Plan will be set in effect and the key users will work from alternative site, until
the HQ's are available again. In case of HQ's total loss affecting the availability of Company’s Business
applications, key users will work with the minimum accepted capabilities using their email through cloud.
Specifc rules and guidelines have been set up to respond in Infromation Security Incidents both ashore and
onboard.
The Capacity requirements of the Company's ICT Systems are assessed for each information processing activity.
Best practises and guidelines have been followed for protecting the availability of Company's ICT Systems and
Applications data through backup and restore activities.
All proprietary information assets that are managed and/or used by Company's employees and all natural
persons and legal entities using and/or accessing organization’s ICT systems, such as equipment, electronic data,
ICT systems, hardware, software and channels of communication, including voice‐ telephony, email, internet,
intranet and paper documents are protected through the appropriate technical controls.
the configuration process.
The appropriate controls and processes are followed prior, during and after the upgrade of a software and is
performed only from the authorized personnel.
Regarding the OT systems that are integrated with the ICT infrastructure, the ICT Development Head evaluates
the potential impact of the upgrade and examines the feasibility of the upgrade focusing on the ICT infrastructure
The Capacity requirements of the Company's ICT Systems are assessed for each information processing activity
and is assured that are maintained within the planned upper limits.
Applications data through backup and restore activities.
The current capacity of ICT resources is evaluated and is ensured that stays within the planned upper limits.
Where there is evidence that the requirements are higher than expected, the cause is investigated and are
proposed the appropriate corrective actions.
The appropriate controls and processes are followed prior, during and after the upgrade of a software for OT
Sytems and is performed solely from the authorized personnel to ensure the smooth transition to the new
software version.
All servers and communications equipment have adequate power supplies. The availability of power supply and
condition of Company's critical facilities are assured by using appropriate technical and Organizational measures.
Company has also set up both technical and Organizational measures to prevent the unauthorized access on both
vessels and Headquarters.
The Capacity requirements of the Company's ICT Systems are assessed for each information processing activity
and is assured that are maintained within the planned upper limits.
Applications data through backup and restoration activities.
The computer room and per floor switch rooms are restricted areas and are under key and lock protection or
with card.
The physical access to vessel's is restricted and is under key and lock protection.
software version.
Specifc rules and guidelines have been set up to respond in Infromation Security Events both ashore and
onboard.
Company promotes Awareness by arranging comprehensive training and familiarization of all Personnel in Office
and Onboard as well as 3rd Parties.
All information and data Is Classified, Labelled and Handled in accordance with corporate‐assigned classification.
All 3rd parties involved in Information & Data handling with the Company must Corporate Information
Classification.
The users are responsible to protect corporate information and ICT systems and to carry out their daily activities
in a manner that ensures privacy, compliance with the relevant security procedures and work instructions.
C t t l t fid ti lit th h t d ft th i d ti ll
Company has set Technocal Controls to protect the ICT Systems with strong passwords and appropriate li
Electronic communications, including internal and external emails, voice, text messages, Internet use,
transmitted by or stored in Company's technology systems are controlled through appropriate technical
measures.
The appropriate controls and processes are followed for monitoring possible vulnerabilities, vendors’ releases of
patches and fixes and installing software updates, patches and fixes on the OT systems.
users.
from external collaborators.
Contractual agreements ensure confidentiality throughout and after the service duration, as well as compliance
Company promotes Awareness by arranging comprehensive training and familiarization of all Personnel in Office
and Onboard as well as 3rd Parties.
Classification.
in a manner that ensures privacy, compliance with the relevant security procedures and work instructions.
Specific information security requirements are defined with all Suppliers and Subcontractors.
In the case of personal data being involved, the privacy and data protection requirements set out by GPDR and
applicable national laws, rules and regulations must be also taken into account.
Annual Review of Suppliers and Subcontractor is carried out to ensure Information Security compliance.
confidentiality and reputational damage.
Rules and processes have been defined for the recording of events (e.g. access and actions of users, errors) and
generation of evidences for investigation purposes.
Classification.
in a manner that ensures privacy compliance with the relevant security procedures and work instructions
The appropriate technical measures and guidence has been provided to employees to prevent the unauhorized
access to Company's ICt Systems and information/ data.
Electronic communications, directories, files and all other content, including Internet use, transmitted by or
stored in Company's technology systems, whether onsite, offsite or in cloud are monitored for Information
Security purposes.
Internal and external e‐mail, voice mail, text messages and other electronic communications are considered
The current capacity of ICT resources is evaluated and is ensured that stays within the planned upper limits.
Where there is evidence that the requirements are higher than expected, the cause is investigated and are
proposed the appropriate corrective actions.
the configuration process
domain.
software version.
Residual Consequence of Cyber Risk on Availability, Integrity &
Authenticity
Consequence Likelihood Risk
III Ε L
III Ε L
III Ε L
III Ε L
II F L
II F L
II F L
III F L
III F L
III E L
III F L
III F L
III E L
PRIME TANKER PROCEDURE 28 ‐ ANNEX C2 VESSEL ICT INFORMATION SECURITY RISK ASSESSMENT PROC 28‐ Annex C2
PRIME GAS Issued on: 30/09/2022
Initial Consequence of Cyber Risk on Availability, Residual Consequence of Cyber Risk on

Integrity & Authenticity Availability, Integrity & Authenticity
Asset Name Function Failure Threat and Effect Root Cause Recommended Actions / Controls
Consequence Likelihood Risk Consequence Likelihood Risk
Intrusion Prevention
Examines the network traffic in order to identify Entry of External Hackers,
known threats by matching traffic patterns to Disclosure or modification of
signature database. If a threat is identified takes business records
action based on set policies
Firewall rules not appropriately
Under support/maintenance contract with 3rd party
configured or the system not full
Procedures not followed III C M provider. III E L
updated with the latest
Configuration Management.
updates/patches;
Remote Access
User may not have access to the
Secure connectivity to vessel's computers from our
requested service, Crew unable to
headquarter in order offer support and
work
troubleshooting in case needed
Clustered FW Setup;
The equipment is down due to a
The firewall is not properly
local breakdown or a local III C M III E L
secured against physical attacks; Back-Up in place;
physical attack.
Access to those equipment is restricted;

Due to unintentional or
Access authorization is delivered by the ICT
intentional human action or any
Administrator;
technical issue, the firewall III C M III E L
Cabinet key is delivered by the Ship Security
configuration is neither relevant
Officer;
or efficient anymore.
URL Filtering
Protect users from risky content by blocking malicious User may not have access to the
websites. Unavailability of filtering setup requested service, Crew unable to
Firewall Allow or restrict URLs using user, group, and schedule work
policies
Due to unintentional or
intentional human action or any System configuration is part of the monitoring
technical issue, the firewall III C M process; III E L
configuration is neither relevant
or efficient anymore.
Deploy secondary firewall with same rules ; Clustered

FW Setup;
loss of internet access; loss of
HW failure System failure III C M III E L
comunications; downtime
Back-Up in place; configure firewalls with rules as
close as possible
Operation failure
Human factor (on leave; medical

Failure in administration Single point of administration III D M Knowledge sharing between IT roles; III F L
reasons etc); accidental errors;

The area where the switch is installed to consider as

Unauthorized access to vessel's
restricted area and to be under key lock protection;
documents/records and possible Procedures not followed III D M III E L
Quarantine vlan are applied on useless interfaces;
infection from virus/ransomware
The network switch connects devices on a computer User's physical access to ethetnet
Ethernet Switch network by using packet switching to receive, process, switch;
and forward data to the destination device. Remote Attack;
Procedures for configuration were All the insecure, as well as the unecessary protocols
Activated insecure protocols III D M III E L
not followed must be disabled.
Connection of not The device's owner not aware

Crew Internet Network User may not have access to the
updated/patched devices which for the information security Physical isolation of the Crew WiFi network using
WiFi Access Point Offer Internet connectivity to Crew personal mobile requested service, Crew unable to III D M V F L
maybe are affected by risks and the status of his separate ethernet switch and controlled from HQ
devices (laptop, mobile phones and tablets) work
virus/ransomware device
Ransomware/Malware, user may Physical access to those equipment is restricted;

Unwanted Programs or Messages not have access to the requested
service II D M II F L
that Start Automatically
Monitoring and Controlling the traffic of 3rd parties
An attacker may use a integrated systems with ICT systems onboard.
vulnerability to gain privileged
Unexpected pop-ups appear on
access to the operating system; II D M The Active Directory Schema Classes (ADSC) are to II F L
the system
be protected by Access Control List (ACL)
Unpatched Vulnerabilities as
Crew unable to work
result of missing security
The account management (AM) is to be designed
Users are Unable to Connect updates
Unavailability of company's II D M with the principle of least privilege II F L
Provide shared resources (files, applications, data, to the Server
files/records
etc.) Unsafe behavior of the Crew
Using of a reputable updated antimalware and
antivirus software
Domain Controller, File Server, eMail Server, ERP The Server Crashes for No Malicious or accidentally
II D M II F L
Server, Database Server Reason Internal User Action
Data Compromised/ Exploited Do make sure that all systems and software are up-
to-date with relevant patches. Regular patching of
Attacking and compromise 3rd
An attacker gain access to the DC vulnerable software is necessary to help prevent
parties ICT Systems;
Vessel's Server by using weaknesses of the infection
authentication
Maintain backup of files/records to minimize the
Deletion of company's An attackers gains access to the potential permanent damage of a server failure,
II D M II F L
files/records DC by using a vulnerability from a virus or malware, malicious/which could corrupt or
hosted service delete files
An attackers gains access to the Setting of Users Access Controls on shares

DC by using a DC vulnerability Files/Folders
Service distruption; service

Failure in proper password Password management policy
Password Management delivery failure; users cannot use III D M Introduce strict and clear policies ; III F L
management not followed
critical Company's ICT resources;
Availability compromise;

Application not start while user Implementation of Physical Media Transfer

tried to started from the start Procedure to reduce the occurrence
II D M II F L
menu or desktop of the computer
and nothing happens Using of a reputable updated antimalware and
antivirus software
Do make sure that all systems and software are up-

to-date with relevant patches. Regular patching of
Hard Drive or Network unusually Infected removable media, vulnerable software is necessary to help prevent
high activity even when the An attacker may use a II D M II F L
opening of suspicious Email infection.
computer not using vulnerability to gain privileged
messages/files
access to the operating system;
Users information security awareness training
Unpatched Vulnerabilities as
Ransomware/Malware;
result of missing security When the user is away from the desk, should be
updates leave the computer in locked/“log in required”
User may not have access to the
protection status
Daily paperwork and email communication Unwanted Programs or Messages requested service
Attacking and compromise 3rd II D M II F L
that Start Automatically Crew unable to work
parties ICT Systems; The vessels supplied with one more computer &
printer which will be used from the 3rd parties who
comes on board and ask to prepare various
Vessel's Client
documents on vessel’s computer. This equipment
Computers
will not be connected on vessel’s network and will
not allowed to use from our crew
Unexpected pop-ups appear on
II D M Monitoring and Controlling the traffic of 3rd parties II F L
the system
integrated systems with ICT systems onboard.
Software to be updated with the latest patches

Single Application Failure/Not Lack of adequate testing from
Malfunction/Software bug III C M III E L
Response the developer Extented testing of the software before installed to
end users
PRIME TANKER PROCEDURE 28 ‐ Annex C3 PROC 28‐ Annex C3
PRIME GAS ICT INFORMATION SECURITY Issue Date: 30/09/2022
RISK ASSESSMENT CONTROLS
Table E-1 Requirements for IT system; Module 3 – IT-systems

Module 3 – IT Systems Requirement L M H
S 3.101 General server Escrow of passwords ×
S 3.101 General server Prompt installation of security-relevant patches and updates × × ×
S 3.101 General server Ensuring consistent system management × × ×
S 3.101 General server Regular integrity checking ×
S 3.101 General server Use of local packet filters × × ×
S 3.101 General server Secure operation of a server × × ×
S 3.101 General server Setting up a testing environment for servers ×
S 3.101 General server Regular security checks of the network × ×
S 3.101 General server Logging on the server × ×
S 3.102 Servers under Unix Use of logging in Unix systems × × ×
S 3.102 Servers under Unix Regular security checks of Unix systems ×
S 3.107 S/390 and zSeries mainframes Security reporting and security audits under z/OS ×
S 3.107 S/390 and zSeries mainframes Monitoring of z/OS systems × ×
S 3.107 S/390 and zSeries mainframes Maintenance of zSeries systems ×
S 3.107 S/390 and zSeries mainframes Synchronisation of z/OS passwords and RACF commands ×
S 3.107 S/390 and zSeries mainframes Secure operation of the z/OS operating system × ×
S 3.107 S/390 and zSeries mainframes Administration of data media under z/OS systems × ×
S 3.107 S/390 and zSeries mainframes Protection of z/OS utilities that are critical to security × ×
S 3.107 S/390 and zSeries mainframes Information on character set conversion in z/OS systems ×
Handling of administrative templates under Windows Server 2003 and
S 3.108 Windows Server 2003 ×
higher
S 3.108 Windows Server 2003 Regular security-relevant maintenance of a Windows Server 2003 × × ×
S 3.108 Windows Server 2003 Administration of access rights under Windows Server 2003 and higher × × ×
S 3.108 Windows Server 2003 Secure deletion under Windows operating systems ×
Handling of administrative templates under Windows Server 2003 and
higher
S 3.109 Windows Server 2008 Regular security-relevant maintenance of a Windows Server 2003 × × ×
S 3.109 Windows Server 2008 Administration of access rights under Windows Server 2003 and higher × × ×
S 3.109 Windows Server 2008 Secure deletion under Windows operating systems ×
Reactivation of Windows systems from a volume licence contract in Vista
or Server 2008 and higher versions
Monitoring of Windows Vista, Windows 7 and Windows Server 2008
S 3.109 Windows Server 2008 × ×
systems
S 3.109 Windows Server 2008 Secure use of DirectAccess under Windows ×
S 3.109 Windows Server 2008 Secure operation of biometric authentication under Windows ×
S 3.109 Windows Server 2008 Use of Windows Server Core ×
S 3.109 Windows Server 2008 Patch Management with WSUS under Windows Server 2008 and higher × ×
S 3.201 General client Log-out obligation for PC users × × ×

S 3.201 General client Screen lock × × ×
S 3.201 General client Use of virus protection programs × × ×
Correct handling of drives for removable media and external data
S 3.201 General client ×
storage
S 3.201 General client Handling of USB storage media ×
S 3.201 General client Use of local packet filters × × ×
S 3.201 General client Secure operation of clients × × ×
S 3.201 General client Setting up a reference installation for clients ×
S 3.201 General client Secure use of browsers × ×
S 3.202 General stand-alone IT systems Escrow of passwords ×

S 3.202 General stand-alone IT systems Log-out obligation for PC users × × ×
S 3.202 General stand-alone IT systems Screen lock × × ×
S 3.202 General stand-alone IT systems ×
storage
S 3.202 General stand-alone IT systems Utilisation of the security functions offered in application programs × × ×
S 3.203 Laptop Safe keeping of laptop PCs during mobile use × × ×

S 3.203 Laptop Safe keeping of laptop PCs during stationary use × × ×
S 3.203 Laptop Pooled storage of portable IT systems ×
S 3.203 Laptop Use of anti-theft devices ×
S 3.203 Laptop Use of virus protection programs × × ×
S 3.203 Laptop Laptop access protection × × ×
S 3.203 Laptop Software reinstallation in the case of change of laptop users ×
S 3.203 Laptop Ensuring power supply during mobile use × × ×
S 3.203 Laptop Comparison of stored data on laptops × ×
S 3.203 Laptop Central administration of laptops ×
S 3.203 Laptop Use of the IrDA interfaces × × ×
S 3.204 Unix client Use of logging in Unix systems × × ×
S 3.204 Unix client Regular security checks of Unix systems ×
S 3.208 Internet PCs Secure registration with Internet services × × ×
S 3.208 Internet PCs Use of virus protection programs × × ×
S 3.208 Internet PCs Secure operation of Internet PCs × ×
S 3.208 Internet PCs Protection against DNS spoofing in authentication mechanisms × × ×
S 3.208 Internet PCs Security issues relating to the use of web browsers by Internet PCs × × ×
S 3.208 Internet PCs Security issues relating to the use of e-mail clients by Internet PCs × × ×
S 3.208 Internet PCs Secure e-commerce using Internet PCs × ×

S 3.208 Internet PCs The secure use of webmail × × ×
S 3.209 Windows XP client Introduction of Windows XP SP2 × × ×
Regular checks of the Windows XP, Windows Vista and Windows 7
S 3.209 Windows XP client × ×
security policies and their implementation
S 3.209 Windows XP client Secure deletion under Windows operating systems ×
S 3.209 Windows XP client Secure operation of Windows client operating systems × × ×
S 3.209 Windows XP client Monitoring a Windows 2000/XP system × ×
S 3.209 Windows XP client Keeping Windows client systems up to date × × ×
S 3.210 Windows Vista client × ×
S 3.210 Windows Vista client Implementation of Windows Vista SP1 × × ×
S 3.210 Windows Vista client Secure deletion under Windows operating systems ×
S 3.210 Windows Vista client Secure operation of Windows client operating systems × × ×
S 3.210 Windows Vista client Keeping Windows client systems up to date × × ×
S 3.210 Windows Vista client ×
or Server 2008 and higher versions
S 3.210 Windows Vista client × ×
systems
S 3.211 Client under Mac OS X Monitoring and administration of storage systems × ×
S 3.211 Client under Mac OS X Security audits and reporting for storage systems × ×
S 3.211 Client under Mac OS X Secure operation of storage systems × × ×
S 3.212 Clients under Windows 7 or higher × ×
S 3.212 Clients under Windows 7 or higher Secure deletion under Windows operating systems ×
S 3.212 Clients under Windows 7 or higher Secure operation of Windows client operating systems × × ×
S 3.212 Clients under Windows 7 or higher Keeping Windows client systems up to date × × ×
S 3.212 Clients under Windows 7 or higher ×
or Server
S 3.212 Clients under Windows 7 or higher × ×
systems
S 3.212 Clients under Windows 7 or higher Secure use of the Maintenance Center under Windows 7 × × ×
S 3.212 Clients under Windows 7 or higher Use of BitLocker To Go in Windows 7 and higher ×
S 3.301 Security gateway (firewall) Secure operation of a firewall × × ×
S 3.301 Security gateway (firewall) Security gateways and high availability ×
S 3.301 Security gateway (firewall) Logging of security gateway activities × × ×
S 3.301 Security gateway (firewall) Security gateways and active content ×
S 3.301 Security gateway (firewall) Firewalls and encryption ×
S 3.301 Security gateway (firewall) Correct configuration of security proxies × ×
S 3.301 Security gateway (firewall) Integration of proxy servers into the security gateway × ×
S 3.301 Security gateway (firewall) Use of a logging server on a security gateway ×
S 3.301 Security gateway (firewall) Integration of virus scanners into a security gateway ×
S 3.301 Security gateway (firewall) Use of a local NTP server for time synchronisation ×
S 3.301 Security gateway (firewall) Secure use of protocols and services × × ×
S 3.301 Security gateway (firewall) Installing stand-alone-systems for Internet use × × ×
S 3.301 Security gateway (firewall) Protection against DNS spoofing in authentication mechanisms × × ×
S 3.301 Security gateway (firewall) Network address translation (NAT) × × ×

S 3.301 Security gateway (firewall) Intrusion detection and intrusion response system ×
S 3.301 Security gateway (firewall) Integration of a web server into a security gateway ×
S 3.301 Security gateway (firewall) Integration of an email server into a security gateway ×
S 3.301 Security gateway (firewall) Integration of a database server into a security gateway ×
S 3.301 Security gateway (firewall) Integration of a DNS server into a security gateway ×
Integration of a web application with web, application, and database
S 3.301 Security gateway (firewall) ×
servers into a security gateway
S 3.301 Security gateway (firewall) Handling of ICMP on the security gateway × × ×
S 3.303 Storage systems and storage networks Monitoring and administration of storage systems × ×
S 3.303 Storage systems and storage networks Security audits and reporting for storage systems × ×
S 3.303 Storage systems and storage networks Secure operation of storage systems × × ×
S 3.304 Virtualisation Monitoring the function and configuration of virtual infrastructures × ×
S 3.304 Virtualisation Minimum use of console accesses to virtual IT systems ×

S 3.304 Virtualisation Time synchronisation in virtual IT systems ×
S 3.304 Virtualisation Secure operation of virtual infrastructures × × ×
S 3.305 Terminal servers Prompt installation of security-relevant patches and updates × × ×
S 3.305 Terminal servers Use of virus protection programs × × ×
S 3.305 Terminal servers Secure use of client applications for terminal servers × ×
S 3.305 Terminal servers Regular audits of the terminal server environment × ×
S 3.305 Terminal servers Secure use of a terminal server from a remote network × ×
S 3.401 Telecommunications system Training on the secure use of PBX systems × ×
S 3.401 Telecommunications system Logging for PBX systems × ×
S 3.401 Telecommunications system Audit of the PBX configuration ×
S 3.402 Fax machine Designating authorised fax operators ×
S 3.402 Fax machine Producing copies of incoming fax messages ×
S 3.402 Fax machine Supply and monitoring of consumables ×
S 3.402 Fax machine Deactivation of fax machines after office hours ×
S 3.402 Fax machine Fax machine with automatic envelopment sealing system ×
S 3.402 Fax machine Use of a suitable fax cover sheet ×
S 3.402 Fax machine Using transmission and reception logs × × ×
S 3.402 Fax machine Announcing fax messages via telephone ×
S 3.402 Fax machine Acknowledging successful fax reception via telephone ×
S 3.402 Fax machine Acknowledging correct fax origin via telephone ×
S 3.402 Fax machine Periodic checks of destination addresses and logs ×
S 3.404 Mobile telephones Blocking of the mobile phone in the event of its loss × × ×
S 3.404 Mobile telephones Safeguarding the power supply of mobile phones × ×
S 3.404 Mobile telephones Use of the IrDA interfaces × × ×
Protection against mobile phone usage data being used to create
S 3.404 Mobile telephones ×
movement profiles
S 3.404 Mobile telephones Protection against call number identification during use of mobile phones ×
S 3.404 Mobile telephones Protection against bugging of indoor conversations using mobile phones ×
S 3.404 Mobile telephones Secure transmission of data over mobile phones × ×

S 3.405 PDA Safe keeping of laptop PCs during mobile use × × ×
S 3.405 PDA Use of virus protection programs × × ×
S 3.405 PDA Ensuring power supply during mobile use × × ×
S 3.405 PDA Using the built-in security mechanisms on PDAs × × ×
S 3.405 PDA Secure operation of PDAs ×
S 3.405 PDA Central administration of PDAs ×
S 3.405 PDA Secure use of extended memory cards ×
S 3.405 PDA Use of the IrDA interfaces × × ×
S 3.406 Printers, copiers, and all-in-one devices Supply and monitoring of consumables ×
S 3.406 Printers, copiers, and all-in-one devices Logging on printers, copiers, and all-in-one devices ×
S 3.406 Printers, copiers, and all-in-one devices Use of network-enabled document scanners ×
S 3.406 Printers, copiers, and all-in-one devices Administration of printers ×
S 3.406 Printers, copiers, and all-in-one devices Network separation when using all-in-one devices
×
Table E-2 Requirements for IT system; Module 4 – Networks
Module 4 - Networks Requirement L M H
S 4.1 Heterogeneous networks Auditing and logging of activities in a network × ×
S 4.1 Heterogeneous networks Updating/upgrading of software and hardware in network components ×
S 4.2 Network- and System management Secure operation of a network management system
× × ×
S 4.2 Network- and System management Secure operation of a system management system × × ×
S 4.3 Modem Secure administration of a modem × × ×
S 4.3 Modem Briefing personnel on modem usage × × ×
Use of a virus scanning program on exchange of data media and during
S 4.3 Modem × × ×
data transfer
S 4.3 Modem One-way connection setup ×
S 4.4 VPN Secure operation of a VPN × × ×
S 4.5 LAN connection of an IT system via ISDN Periodic checks of destination addresses and logs ×
S 4.6 WLAN Appropriate key management for WLAN × ×

S 4.6 WLAN Secure use of hotspots ×
S 4.6 WLAN Secure operation of hotspots ×
S 4.6 WLAN Use of a suitable management solution for WLAN ×

S 4.6 WLAN Secure operation of WLAN components × × ×
S 4.6 WLAN Regular audits of WLAN components × ×
S 4.6 WLAN Regular security checks of WLANs × ×
Informing all staff members about possible PBX warning notices,
S 4.7 VoIP × ×
warning symbols, and acoustic alarm signals
S 4.7 VoIP Increasing staff awareness of potential threats to the PBX × ×
S 4.7 VoIP Logging for PBX systems × ×
S 4.7 VoIP Audit of the PBX configuration ×
S 4.7 VoIP Secure configuration of VoIP middleware × × ×
S 4.7 VoIP Logging of VoIP events × × ×
S 4.8 Bluetooth Use of a central pool of Bluetooth peripheral devices ×
S 4.8 Bluetooth Secure operation of Bluetooth devices × × ×
Table E-3 Requirements for IT system; Module 5 – Applications
Module 5 - Applications Requirement L M H
S 5.2 Exchange of data media Safekeeping of data media before and after dispatch × × ×
S 5.2 Exchange of data media Adequate labelling of data media for dispatch × × ×
S 5.2 Exchange of data media Secure packaging of data media × × ×
S 5.2 Exchange of data media Briefing personnel on correct procedures of exchanging data media × ×
S 5.2 Exchange of data media × × ×
data transfer
S 5.2 Exchange of data media Pre-dispatch verification of the data to be transferred ×
S 5.3 Groupware Basic user training on how to use groupware and e-mail ×
S 5.3 Groupware Avoiding problematic file formats × ×
S 5.3 Groupware Secure operation of groupware systems × × ×
S 5.3 Groupware Logging groupware systems × ×
S 5.3 Groupware Dealing with unwanted e-mails × ×
S 5.3 Groupware Secure operation of a mail server × × ×
S 5.3 Groupware Cryptographic protection of groupware and/or e- mail ×
S 5.3 Groupware Use of an e-mail scanner on the mail server ×
S 5.4 Web servers Secure operation of a web server × × ×
S 5.4 Web servers Prompt installation of security-relevant patches and updates × × ×
S 5.4 Web servers × × ×
data transfer
S 5.4 Web servers Careful modifications of configurations × × ×
S 5.4 Web servers Assuring the integrity and authenticity of software packages × ×
S 5.4 Web servers Protection against DNS spoofing in authentication mechanisms × × ×
S 5.5 Lotus Notes/Domino Secure operation of the Lotus Notes/Domino environment × × ×
S 5.5 Lotus Notes/Domino Monitoring the Lotus Notes/Domino environment ×
S 5.5 Lotus Notes/Domino Archiving for the Lotus Notes/Domino environment ×
S 5.5 Lotus Notes/Domino Security-relevant logging and evaluating for Lotus Notes/Domino ×
S 5.5 Lotus Notes/Domino Audit of the Lotus Notes/Domino environment ×

S 5.6 Fax servers Use of a suitable fax cover sheet ×
S 5.6 Fax servers Using transmission and reception logs × × ×
S 5.6 Fax servers Announcing fax messages via telephone ×
S 5.6 Fax servers Acknowledging successful fax reception via telephone ×
S 5.6 Fax servers Acknowledging correct fax origin via telephone ×
S 5.6 Fax servers Secure operation of a fax server × × ×
S 5.6 Fax servers Maintenance of fax server address books and distribution lists × × ×
S 5.6 Fax servers Protecting against overloading the fax server ×
S 5.7 Databases Documentation of authorised users and rights profiles × × ×

S 5.7 Databases Documentation on changes made to an existing IT system × × ×
S 5.7 Databases Checking the efficiency of user separation on an IT system ×
S 5.7 Databases Inference prevention × ×
S 5.7 Databases Controlling access to a database system × × ×
S 5.7 Databases Controlling access to database information × × ×
S 5.7 Databases Ensuring the integrity of a database × × ×
S 5.7 Databases Separation of administrative tasks for database systems ×
S 5.7 Databases Checking the log files of a database system × × ×
S 5.7 Databases Log-out obligation for PC users × × ×
S 5.7 Databases Locking and deleting database accounts which are no longer required × ×
S 5.7 Databases Ensuring consistent database management × × ×

S 5.7 Databases Regular checks of database security × ×
S 5.7 Databases Monitoring a database ×
S 5.7 Databases Database encryption ×
S 5.7 Databases Integration of a database server into a security gateway ×
S 5.8 Telecommuting Training of telecommuters as regards security- related issues × × ×
S 5.9 Novell eDirectory Secure operation of Novell eDirectory × × ×
S 5.9 Novell eDirectory Monitoring of Novell eDirectory × ×
S 5.9 Novell eDirectory Protection of communications with Novell eDirectory × ×
S 5.12 Microsoft Exchange/ Outlook Regular security checks of Exchange systems × ×
S 5.12 Microsoft Exchange/ Outlook Secure operation of Exchange systems × × ×
S 5.13 SAP System Regular security checks of SAP systems × ×
S 5.13 SAP System Security aspects relating to the customisation of SAP systems ×
S 5.13 SAP System Secure software development for SAP systems ×
S 5.13 SAP System Logging of SAP events × × ×
S 5.13 SAP System Computer virus protection for SAP systems ×
S 5.13 SAP System Secure use of the SAP transport system × × ×
S 5.13 SAP System Secure use of the SAP Java Stack software deployment × × ×
S 5.14 Mobile data media Sensitising staff to secure handling of mobile data media and devices ×
S 5.14 Mobile data media ×
storage
S 5.14 Mobile data media Handling of USB storage media ×
S 5.14 Mobile data media Secure use of extended memory cards ×
S 5.15 General directory service Careful modifications of configurations × × ×
S 5.15 General directory service Secure operation of directory services × × ×
S 5.15 General directory service Monitoring directory services × ×
S 5.15 General directory service Protection of communications with directory services ×
S 5.16 Active Directory Configuration of Windows Server as a domain controller × × ×
S 5.16 Active Directory Maintenance of the operational reliability of an Active Directory × × ×
S 5.16 Active Directory Monitoring the Active Directory infrastructure × ×
S 5.17 Samba Secure operation of a Samba server × ×
S 5.18 DNS-Server Assignment of access rights × × ×
S 5.18 DNS-Server Obtaining information on security weaknesses of the system × ×
S 5.18 DNS-Server Prompt installation of security-relevant patches and updates × × ×
S 5.18 DNS-Server Careful modifications of configurations × × ×
S 5.18 DNS-Server Monitoring of a DNS server × ×
S 5.18 DNS-Server Integration of a DNS server into a security gateway ×
S 5.19 Internet use Secure registration with Internet services × × ×
S 5.19 Internet use Secure use of browsers × ×

S 5.19 Internet use Data protection aspects when using the Internet ×
S 5.19 Internet use Secure use of Twitter ×
S 5.19 Internet use Secure use of social networks ×
S 5.19 Internet use Use of web disk space ×
S 5.19 Internet use Use of short URLs and QR codes ×
S 5.20 OpenLDAP Secure updating of OpenLDAP ×
S 5.20 OpenLDAP Secure operation of OpenLDAP × ×
S 5.20 OpenLDAP Logging when using OpenLDAP × ×
S 5.20 OpenLDAP Secure communication connections when using OpenLDAP ×
S 5.21 Web applications Assignment of access rights × × ×
S 5.21 Web applications Documentation of authorised users and rights profiles × × ×
S 5.21 Web applications Documentation on changes made to an existing IT system × × ×
S 5.21 Web applications Obtaining information on security weaknesses of the system × ×
S 5.21 Web applications Checking the log files × × ×
S 5.21 Web applications Data protection guidelines for logging procedures × × ×
S 5.21 Web applications Prompt installation of security-relevant patches and updates × × ×
S 5.21 Web applications Training on security safeguards × × ×
S 5.21 Web applications Careful modifications of configurations × × ×
S 5.21 Web applications Logging security-relevant events of web applications ×
S 5.21 Web applications Performing penetration tests ×
S 5.22 Logging Assignment of access rights × × ×
S 5.22 Logging Checking the log files × × ×
S 5.22 Logging Data protection guidelines for logging procedures × × ×
S 5.22 Logging Use of a logging server on a security gateway ×
S 5.22 Logging Use of a local NTP server for time synchronisation ×
S 5.22 Logging Analysing the logged data × × ×
S 5.22 Logging Selecting and processing relevant information for logging × × ×
S 5.22 Logging Logging on the server × ×
S 5.22 Logging Secure communication with a centralised logging server × × ×
S 5.22 Logging Secure time synchronisation for centralised logging × × ×
Table E-4 Additional requirements.
Module 3, 4 & 5 – IT Systems (new in 15th
Requirement L M H
rev)
S3.302 Routers and switches Documentation of the system configuration of routers and switches × × ×
S 3.302 Routers and switches Regular checking of routers and switches × × ×

S 3.302 Routers and switches Software maintenance on routers and switches × ×
S 3.302 Routers and switches Secure administration of routers and switches ×
S 3.302 Routers and switches Logging on routers and switches ×
S 3.302 Routers and switches Protection of switch ports ×
S 3.302 Routers and switches Security aspects of routing protocols ×
S 3.303 Storage systems and storage networks Secure deletion in SAN environments × ×
S 3.303 Storage systems and storage networks Ensuring the integrity of the SAN fabric ×
Staff awareness on information security concerning mobile phones,
S 3.404 Virtualisation × × ×
smartphones, tablets and PDAs
Staff awareness on information security concerning mobile phones,
S 3.405 PDA × × ×
smartphones, tablets and PDAs
S 3.405 PDA Use of anti-virus programs for smartphones, tablets and PADs ×
Defense against infiltrated GSM codes on end devices with phone
S 3.405 PDA × × ×
function
S 3.405 PDA Use of URL shortening services and QR codes ×

Secure connection of smartphones, tablets and PDAs to the corporate
S 3.405 PDA × ×
network
S 3.407 Embedded systems Physical protection of embedded systems × × ×
S 3.407 Embedded systems Documentation of changes to an existing system × × ×
S 3.407 Embedded systems Logging security events in embedded systems × × ×
S 3.407 Embedded systems Careful implementation of configuration changes × × ×
S 3.407 Embedded systems Ensuring integrity and authenticity of software packages × ×
S 3.407 Embedded systems Built-in self test (BIST) of embedded system modules × × ×
S 3.407 Embedded systems Preventing debugging capabilities in embedded systems × × ×
S 3.407 Embedded systems Secure configuration and use of embedded web servers × ×
S 4.1 Heterogeneous networks Installation, configuration and support of local networks by third parties ×
S 4.1 Heterogeneous networks Regular audits of local networks × ×

S 4.2 Network- and System management Training of maintenance and administrative staff × × ×
S 4.2 Network- and System management Audit and logging of activities in the network × ×
S 5.19 Internet use Correct behaviour on the Internet and social networks ×
S 5.22 Logging Secure time synchronisation for centralised logging × × ×
S 5.23 Cloud Management Use of a highly-available firewall-solution ×
S 5.23 Cloud Management Controlled administration of users and permissions in cloud computing × × ×
S 5.23 Cloud Management Safe and complete deletion of user data in the cloud ×
S 5.23 Cloud Management Controlled provisioning and de-provisioning of cloud services × × ×
S 5.23 Cloud Management Reporting system and communication to cloud users × ×
S 5.23 Cloud Management Safe automation in cloud administrative processes ×
S 5.23 Cloud Management Analysis of log data × × ×
S 5.23 Cloud Management Central protection of malware in the cloud infrastructure ×
S 5.23 Cloud Management Logging and monitoring of events in the cloud infrastructure
× ×
S 5.23 Cloud Management Patch management for cloud components × × ×
S 5.23 Cloud Management Comprehensive segregation of cloud service users × × ×
S 5.23 Cloud Management Intrusion Detection and Intrusion Response systems ×
S 5.24 Web services Allocation of access rights × × ×
S 5.24 Web services Documentation of registered users and access profiles × × ×
S 5.24 Web services Documentation of changes on existing systems × × ×
S 5.24 Web services Obtaining information on security gaps in the system × ×
S 5.24 Web services Checking of log information × × ×
S 5.24 Web services Data privacy protection during log writing × × ×
S 5.24 Web services Timely application of security related patches and updates × × ×
S 5.24 Web services Education on security measures × × ×
S 5.24 Web services Careful implementation of configuration changes × × ×
S 5.24 Web services Logging of security related events of web applications and services ×
S 5.24 Web services Monitoring of web services × × ×

S 5.24 Web services Execution of penetration tests ×
S 5.25 General applications Training before using a system × × ×
S 5.25 General applications Maintaining security during operation × ×
S 5.26 Service oriented architecture Education on security measures × × ×
S 5.26 Service oriented architecture Protection of a WS-Notification-Subscription in Broker × ×
S 5.26 Service oriented architecture Protection of a WS-Notification × ×
S 5.26 Service oriented architecture Key management for SOA ×
S 5.26 Service oriented architecture Protection of regulations in a SOA × ×
S 5.26 Service oriented architecture Protection of WS-resources in a SOA-environment ×
S 5.26 Service oriented architecture Safe usage of connectionless SOAP-communication ×

S 5.26 Service oriented architecture Protection of communication with the directory service ×
S 5.26 Service oriented architecture Execution of penetration tests ×
S 5.27 Software development Timely application of security-related patches and updates × × ×
S 5.27 Software development Regular security audits of the software development environment ×
S 5.27 Software development Usage of anti-viros software during media exchange and transmission × × ×
S 5.27 Software development Careful implementation of configuration changes ×

S 5.27 Software development Regular integrity check ×
S 5.27 Software development Safe installation of the developed software ×
PRIME TANKER PROCEDURE 28 ‐ ANNEX C4‐ OFFICE OT INFORMATION SECURITY RISK ASSESSMENT PROC 28‐ Annex C4
PRIME GAS Issue Date: 30/09/2022

Intrusion Prevention
Examines the network traffic in order to identify Entry of External Hackers, The Firewall is under
known threats by matching traffic patterns to Disclosure or modification of III D M support/maintenance contract with III E L
signature database. If a threat is identified takes Firewall rules not appropriately system Kongsberg
action based on set policies configured or the system not full
Zyxel Firewall Procedures not followed
updated with the latest
Remote Access Physical isolation of the Similators
updates/patches
Secure connectivity to sinulator's computers from Konsberg/VSTEPS may not have network using separate ethernet
III D M switch and Internet connection III E L
the ventors in order offer support and access to the simulators
troubleshooting in case needed
The network switch connects devices on a computer The switch room are restricted area
Ethernet Switch User's physical access to switch Possible infection from
network by using packet switching to receive, Procedures not followed III D M and is under key and lock protection IV F L
(Unmanaged) room virus/ransomware
process, and forward data to the destination device. or with card
Simulator application not start

Kongsberg K-Sim Navigation - Ships bridge while started from the start menu Implementation of removable Media
III D M III E L
simulator or desktop of the computer and Policy to reduce the occurrence
nothing happens Infected removable media,
opening of suspicious Email
Kongsberg K-Sim Engine - Engine Room Simulator Hard Drive or Network unusually Ransomware/Malware, trainee All systems and software should be
messages/files or clicking on
high activity even when the may not have access to the III D M updated with relevant patches. This III E L
suspicious links, websites, or
Simulators Kongsberg K-Sim Cargo - Liquid Cargo Handling computer not using requested function procedure are under responsibility of
pop-ups
Computers Simulator service engineer from
Unwanted Programs or Messages Trainee unable to trained to one Kongsberg/VSTEP
Unpatched Vulnerabilities as III D M III E L
VSTEP Nautis RescueSim Advanced Fire that Start Automatically or more matters
result of missing security
Fighting Simulator All simulators rooms are restricted
updates
areas where allowed the access only
VSTEP Nautis Bridge Simulator (ECDIS) Unexpected pop-ups appear on to authorized personnel
III D M III E L
the system
PRIME TANKER PROCEDURE 28 ‐ ANNEX C5 ‐ MARINE OT INFORMATION SECURITY RISK ASSESSMENT PROC 28‐ Annex C5
Initial Consequence of Cyber Risk on Residual Consequence of Cyber Risk on

Asset Availability, Integrity & Authenticity Availability, Integrity & Authenticity
Function Failure Threat and Effect Root Cause Recommended Action / Controls
ID Name
USB Locks to be installed in all

ECDIS USB Ports - Key Under
Master's Authority. Use dedicated
Virus transfer through USB sticks only for requested data
Electronic Chart Display and
USB or Malware DVD III A H transfer and original DVDs. Install V C L
Information System (ECDIS) is a
of chart database Two (2) ECDIS Onboard. EMCY folio
geographic information system Wrong chart data in monitor Non dedicated & checked USBs, not
of paper charts. Any other USB or
1 ECDIS used for nautical navigation that Lost chart data or route data official DVDs, usage - Malfunction
complies with International DVD restricted prohibited as per
Fault in vessel's data settings on charts data or lose charts data
Maritime Organization (IMO) company's policy.
regulations
Software and information integrity
Failure software Software upgrade only from
III C M IV E L
upgrade authorised and approved, on board
service center.
Software and information integrity

The AIS has an error on internal GPS Spoofing,
Infos cross check, with vessels
data - Receiving wrong informations Diversion of sensitive IV B M IV D L
around through VHF, whenever
Automatic Identification System is for vessels data traffic, fraud
applicable
an automatic tracking system AIS receiver do not operating
2 AIS
used on ships and by vessel correctly. Wrong data in monitor. Software process and device
traffic services (VTS). identification and authentication
AIS receiver failure - AIS out of Miscarriage to software
IV C M Software upgrade only from IV D L
order upgrade
authorised and approved, on board
service center.
Gyrocompass is a type of non-

magnetic compass which is based Gyro Compass error - Wrong route -
on a fast-spinning disc and the Fault in many Electronic
Malfunction appeared Service only from authorised and
rotation of the Earth (or another Malfunction - Error. Wrong data in Navigational equipment such us
3 GYRO COMPASS after Gyro Compass III C M approved, on board service center III E L
planetary body if used elsewhere monitor. ECDIS - RADAR - AUTO PILOT etc,
in the universe) to find maintenance & usage of original spare parts, if
due to connectivity with Gyro
geographical direction needed
Compass
automatically.
Radar is an object-detection The Radar has an error on internal Service or software upgrade, only
Malfunction appeared
system that uses radio waves to RADAR receiver do not operating data - Receiving wrong informations from authorised and approved, on
4 RADAR after Radar III C M III E L
determine the range, angle, or correctly. Wrong data in monitor. for our vessel regarding vessels in board service center
velocity of objects. maintenance
range - Radar out of order & usage of original spare parts, if
needed
Autopilot is a system used to

control the route of a vessel
without constant 'hands-on'
Malfunction appeared Service only from authorised and
control by a human operator Malfunction - Error. Wrong data in
5 AUTOPILOT Autopilot error - Wrong route after Autopilot III D M approved, on board service center III E L
being required. Autopilots do not monitor.
replace human operators, but maintenance & usage of original spare parts, if
instead they assist them in needed
controlling of a vessel.
Global Positioning System (GPS), The GPS has an error on internal

is a satellite-based GPS Spoofing, Communication integrity
data - Receiving wrong informations
radionavigation system, global Diversion of sensitive IV C M Software and information integrity IV E L
for vessels - Transferring wrong info
navigation satellite system that data traffic, fraud Control system back-up
to ECDIS
provides geolocation and time GPS receiver do not operating
6 GPS
information to a GPS receiver correctly. Wrong data in monitor. Software process and device
anywhere on or near the Earth identification and authentication
GPS receiver failure - GPS out of Failure to software
where there is an unobstructed III D M Software upgrade only from III E L
line of sight to four or more GPS order upgrade
authorised and approved, on board
satellites service center.

ID Name
Bridge Navigational Watch Alarm

System, is an automatic system
Service or software upgrade, only
which sounds an alarm if the Malfunction appeared
BNWAS error / Out of order - No from authorised and approved, on
7 BNWAS watch officer on the bridge of a Malfunction - Error. after BNWAS III C M III E L
alarm in case Bridge Officer is off. board service center
ship falls asleep, becomes maintenance
otherwise incapacitated, or is & usage of original spare parts, if
absent for too long a time. needed
Navtex (Navigational Telex) is an Service or software upgrade, only

international automated medium from authorised and approved, on
frequency direct-printing service Malfunction appeared
NAVTEX receiver failure / out of board service center
for delivery of navigational and NAVTEX receiver do not operating after NAVTEX
8 NAVTEX order - Vessel fail to receive IV C M & usage of original spare parts, if IV F L
meteorological warnings and correctly. Wrong data in monitor. maintenance or
forecasts, as well as urgent NAVTEX informations/ warnings needed. Similar information can be
software update
maritime safety information to received from INM-C, or from
ships. specific software such as CharCo &
Voyager that equip all fleet vessels
Digital selective calling is a

standard for sending pre-defined
digital messages via the medium-
DSC Service or software upgrade, only
frequency (MF), high-frequency DSC, VHF / UHF, MF / HF error / Malfunction appeared
VHF / UHF from authorised and approved, on
9 (HF) and very-high-frequency Malfunction - Error. Out of order - Fail to emit distress after GMDSS III C M III E L
MF / HF board service center
(VHF) maritime radio systems. It signal maintenance
is a core part of the Global & usage of original spare parts, if
Maritime Distress Safety System needed
(GMDSS)
Inmarsat-C is a two-way, packet Inmarsat-C receiver or transmiter

data service operated by the failure / out of order - Lose of Service or software upgrade, only
Failure after
telecommunications company tracking, maritime safety from authorised and approved, on
10 Inmarsat-C Malfunction - Error. maintenance or II D M II F L
Inmarsat which operates between information (MSI), GMDSS, two- board service center
mobile earth stations (MES) and software upgrade
way messaging, data reporting, & usage of original spare parts, if
land earth stations (LES). Safety/Emergency alerting. needed
Non dedicated & checked USBs, Virus transfer through Communication integrity
Voyage data recorder, is a data
usage - Malfunction on data USB or Malware DVD III A H Software and information integrity III E L
recording system designed for all
vessels required to comply with recorded or lose data of chart database
the IMO's International
11 VDR Malfunction - Error.
Convention SOLAS VDR error, out of order - No any Software process and device
Requirements in order to collect data recorded from many Electronic identification and authentication
Failure due to software
data from various sensors on Navigational equipment such us III D M Software upgrade only from III F L
board the vessel. upgrade or maintenace
ECDIS - RADAR - AUTO PILOT etc, authorised and approved, on board
due to connectivity with VDR service center.
Echo sounder is a type of sonar
used to determine the depth of
water by transmitting sound Service only from authorised and
pulses into water. The time approved, on board service center
Malfunction appeared
interval between emission and Malfunction - Error. Wrong data in Echo sounder error - Wrong sounds & usage of original spare parts, if
12 ECHO SOUNDER after Echo sounder III D M III E L
return of a pulse is recorded, monitor/ recorder. data receiving needed. Depth information can be
which is used to determine the maintenance
also received from ECDIS charts as
depth of water along with the well as from Sailing directions (Pilot
speed of sound in water at the books), for approaches
time.

ID Name
Emergency Position Indicating
Radiobeacon station is a
COSPAS-SARSAT 406-MHz
tracking transmitters in the mobile
radiocommunication service Service only from authorised and
EPIRB transmiter failure / out of Failure after
which aid search and rescue approved, on board service center
13 EPIRB Malfunction - Error. order - No transmission of maintenance or III D M III F L
operations in the detection and & usage of original spare parts, if
location of boats, aircraft, and emergency data change battery
needed. Similar information can be
people in distress. It is distinct send from INM-C
from a Satellite emergency
position-indicating radiobeacon
station.
Search And Rescue Transponder,

is a self-contained, waterproof SART transmiter failure / out of Failure after Service only from authorised and
14 SART transponder intended for Malfunction - Error. order - No transmission to a 9 GHz maintenance or V C L approved, on board service center V F L
emergency use at sea. These X-band (3 cm wavelength) radar. change battery & usage of original spare parts, if
devices is usually a radar-SART needed
PRIME TANKER PROCEDURE 28 ‐ ANNEX C6 ‐ TECHNICAL OT INFORMATION SECURITY RISK ASSESSMENT PROC 28‐Annex C6
Residual Consequence of Cyber

Initial Consequence of Cyber Risk on Availability, Integrity
Risk on Availability, Integrity &
Asset & Authenticity
Recommended Action / Controls Authenticity
Consequence
ID NAME analysis
CATEGORIZATION
Only Makers' authorized Service Engineers to be provided access to the boiler
interconnection panel.
Off hire due to
Authorized Officer to control all service actions and verify proper operation
inoperability and
before Service Engineers disembarkation.
inability to either use
Only original PLC and controllers are procured.
CARGO OPERATIONS 1 AUX. BOILER II steam COP , produce D M II F L
IG or other vessel
Passwords to be provided for equipment access.
purposes (i.e heat
Training before use after any system upgrade.
bunkers)
Back up/recovery data to be stored/available.
Crew awareness on the consequences of cyber threat.
CCTV operating system to be priovided with access code regulated from IT

administrator.
Minor imparing of
AUXILLIARIES 2 CCTV III D M III E L
confidentiality Passwords to be provided for equipment accesss.
Crew awareness on the consequenses of cyber threat.
Only original PCB and software will be provided. Only authorized service
Engineers to be carrying out service/inspection to the system.
Inability ot extinguish Authorized officer to control all service actions and verify proper operation
fire using the system or before service engineer dissembarkation.
FIRE PROTECTION/DETECTION 3 LOCAL WATER MIST FIRE EXTINGUISHING SYSTEM III D M III F L
mischievous system
operation Passwords to be provided for equipment accesss.
Makers isntructions to be followed. In case of malfunction only maker's
appointed service engineers to attend. Authorized officer to control all service
actions and verify proper operation before service engineer dissembarkation.
In case of equipment failure alternative measures are : a) Dispose Ballast to
Incompliance with
shore facilities or barge , b) Deballasting operations to take place clear of
Regulatory framework.
the 200nm from closest shore , c) Inform port authorities and request one-off
ENVIRONMENTAL EQUIPMENT 4 BALLAST WATER TREATMENT SYSTEM II Extensive penalties D M II F L
exception.
imposed or Major Off
hire
Passwords to be provided for equipment accesss.
Only makers' authorized service enigneers to be allowed to access vessel's

electornic components. Authorized officer to control all service actions and
verify proper operation before service engineer dissembarkation.
Seawothiness and
MAIN ENGINE ME TYPE (Electronically controlled, vessel's
PROPULSION/STEERING 5 II D M Training before use after any system upgrade. II F L
without camshaft) maneuverabiltiy is
affected.
Original software to be procured and updated in accordance with Maker

Service news.

Consequence
ID NAME analysis

Service news.
Loss of integrity. In case of system failure then
AUXILLIARIES 6 ALARM MONITORING SYSTEM III False alarms occuring, D M UMS will be suspended and will conduct visual montioring of all parameters. III F L
system unreliable.

electornic components.
Extensive off hire due
to lost integrity of
Service news. Chief Engineer will control all service actions and verify system
power
POWER MANAGEMENT 7 POWER MANAGEMENT SYSTEM II E M operability prior service engineer disssemabrkation . II F L
control/management
Backout occurrence
Load sharing inability

to lost integrity of
Service news. Chief Engineer will control all service actions and verify system
remote control system
PROPULSION/STEERING 8 M/E REMOTE CONTROL SYSTEM II D M operability prior service engineer disssemabrkation . II F L
. Collision risk .
Grounding riisk.
Lossof manoeuvrability

System's intergity is verified during the annual inspections by maker's
Incorrect system authorized service engineers.
operation and disposal Disposal thorugh ODME is taking place daylight only and effluent monitored
ENVIRONMENTAL EQUIPMENT 9 OIL DISCHARGE MONITORING SYSTEM II E M II F L
non compliant with visually by deck watch.
Marpol In case system not operational , slops to be retained onboard.


System inoperability System's intergity is verified during the annual inspections by authorized
and render unable to service engineers.
defect fire.
FIRE PROTECTION/DETECTION 10 FIRE DETECTION SYSTEM III E L III F L
Michievous operation In case system out of order, partol roundsto be organized by Master.
and frequent flase fire
detection alarms. Passwords to be provided for equipment accesss.

Consequence
ID NAME analysis

System inoperability verify proper operation before service engineer dissembarkation.
and render unavaiable System's intergity is verified during the annual inspections by authorized
to defect gas leakage. service engineers.
FIRE PROTECTION/DETECTION 11 GAS DETECTION SYSTEM III Michievous operation D M In case system out of order, manual measurements to be carried out as per III F L
and frequent false gas IMS.
detection alarms.

System incorrect
process.
Risk of oil (or LPG)
System's intergity is verified during the annual inspections by authorized
spillage iwhen alevel
service engineers.
CARGO MONITORING SYSTEM / HIGH OVERFILL ALARM / and alarm system
CARGO OPERATIONS 12 II D M Availability of additional resourses (UTI)a and Loading Instrument II F L
REMOTE SOUNDING SYSTEM becomes inoperable.
calculations to enable identification of system malfucntion.
to incrrect cargo
quantities or extensive
opearation delays

Major off hire.
System's intergity is verified during the periodical inspections by authorized
Unavailability of
service engineers.
CARGO OPERATIONS 13 FRAMO CARGO PUMPING SYSTEM II system. Not able to E M II F L
Emergency operaiton of system where software/PLC is by passed.
discharge cargo when
needed.

Unavailability of electornic components. Authorized officer to control all service actions and
system. Incompliance verify proper operation before service engineer dissembarkation.
CARGO OPERATIONS 14 VAPOR EMISSION CONTROL SYSTEM III with MARPOL D M System's intergity is verified during the periodical inspections by crew. III F L
regulations. Risk of Available redundancy (tank P/V Valves) .
tank structural integrity
USB Locks to be installed in all Loadicator USB Ports - Key Under Master's
Authority. Only authorized service enigneers to be allowed to access loading
System integrity software. Authorized officer to control all service actions and verify proper
jeopardized and wrong operation before service engineer dissembarkation. Any amendment /
calculations produced. alteration to be under approval form Classisification society. Loading software
CARGO OPERATIONS 15 LOADING COMPUTER III D M III F L
Structural damages correct operation is verified on monthly basis and compared with official
due to incorrect approved loading conditions as included in Trim and stability booklet. Manual
stresses calculations. calculations to be performed. Passwords to be provided for equipment access.
Training before use after any system upgrade. Back up / recovery data to be
stored / available. Crew awareness on the consequenses of cyber threat.

Consequence
ID NAME analysis
Only authorized maker ervice engineers will eb provied access to inspect the
System integrity
system as per recommended periodicty by maker. Authorized officer to
jeopardized and render
control all service actions and verify proper operation before service engineer
unable to control
dissembarkation.
various machinery
Reducndancy is availabel using local controls and manually monitoring
AUXILLIARIES 16 ENGINE CONTROL ROOM CONSOLE III (icnluding ME). D M III F L
machinery parameters.
Operational delays and
need for external
assistance by thrid
party.
Machinery to be maintained in accordance with aker recommended periodicity

Machinery inoperability.
and instructions. Software update is only being provided by maker and in case
Commercial degrating
necessary carried out by authorized service engineer.
of vessel if system
Authorized officer to control all service actions and verify proper operation
considered inpoerative.
PROPULSION/STEERING 17 BOW THRUSTER CONTROL II E M before service engineer dissembarkation. II F L
Damages due to
system incorrect
operation during
maneuvering
Machinery inoperability.
Machinery to be maintained in accordance with aker recommended periodicity
Commercial degrating
and instructions. Software update is only being provided by maker and in case
of vessel if system
necessary carried out by authorized service engineer.
considered inpoerative.
Damages due to
PROPULSION/STEERING 18 RUDDER CONTROL II E M before service engineer dissembarkation. II F L
system incorrect
operation during
maneuvering.
Loss of maoeuvrabilitiy,
Grounding.
Main / Emergency siwtchboard breakers are serviced by auhtorized repair

workshops during renewal surveys. The patrmeters of the ESB/MSB breakers
and the connecitons in the boards are being controlled by the Chief Engineer
and vessel's electrical engineer and any alteration is subject to Class approval.
Blackout. Major off Authorized officer to control all service actions and verify proper operation
hire and Serious before service engineer dissembarkation.
POWER MANAGEMENT 19 MAIN / EMERGENCY SWITCHBOARD II damages due to E M In case failure of Main siwtchboard breakers , Emergency Generator will start II F L
inability to maneuver and power up ESB. In case ystem of DGs synchornization / load sharign is
vessel. out of order ,the DGs to be manuually controlled.

Communication systems with external parties (other vessels / shore) are
provided with redundancy.
Any software updatei s provided by GMDSS Shore based maintenance
provider and carried out by authorized service engineer during annual
inspections of GMDSS or ocassisonally as required.
Communicaiton Authorized officer to control all service actions and verify proper operation
AUXILLIARIES 20 ENGINE / BRIDGE COMMUNICATION SYSTEMS IV D L IV E L
impossible. before service engineer dissembarkation.
Vessel internal communication systems have also redundancy.
Use of vessel's Mobile phone.


Consequence
ID NAME analysis
Service engineers from reputable and approved companies are only employed
ot carry out inspecitons if considered necessary.
Resource being
unavailable. Monitoring
before service engineer dissembarkation.
process being
AUXILLIARIES 21 ENGINE AUTO SYSTEMS III D M Redundancy is in place as per Classification society regulations. III E L
jeopardized.
In case of auto systems failure the engine room will switch to manned
UMS operation is
condition.
rendered inoperative
In case of system unavialability, visual observation of critical parameters to
take place.
Only makers' authorized service enigneers to be provided access to inspect /
maintain the DP stystem components. Original software to be procured and
updated only by Maker service Enigneers.
PROPULSION/STEERING 22 DP SYSTEM (N/A) I Major off hire. Oil spill E M I F L
Only makers' authorized service enigneers to be provided access to the
composite boiler panels for programming . Only original PLC and Unisab
Unavailability of controllers are procured.
equipment and Authorized officer to control all service actions and verify proper operation
rendering unable to before service engineer dissembarkation.
AUXILLIARIES 23 COMPOSITE BOILER II D M II F L
produce steam for
vessel purposes Passwords to be provided for equipment accesss.
(bunker heating , etc) . Training before use after any system upgrade.
Only original makers PLC and control panels are installed to Purifiers and these
Unavailability of are preprogrammed from maker factory .
equipment. Possible Authorized officer to control all service actions and verify proper operation
subsequent damages before service engineer dissembarkation.
due to untreated Fuel/ Settling techniques to be used for FO/LO if purifiers are out of order.
AUXILLIARIES 24 HFO / LO PURIFIERS III D M III F L
LO being used on
vessel's machinery Passwords to be provided for equipment accesss.
(Main Engine / Diesel Training before use after any system upgrade.
Engines). Back up/recovery data to be stored/available.
Unavailability of
equipment. Minor off Only original makers PLC and control panels are installed. Only maker
hire due to vessel apporved service engineers are attendign system for periodical inspeciton /
stoppage to avoid service.
subsequent damages Authorized officer to control all service actions and verify proper operation
due to inoperable before service engineer dissembarkation.
PROPULSION/STEERING 25 ALPHA LUBRICATOR III D M III F L
cylinder lubrication.
Main Engine damage if Passwords to be provided for equipment accesss.
system alarms are Training before use after any system upgrade.
supresed while Back up/recovery data to be stored/available.
lubrication is out of Crew awareness on the consequenses of cyber threat.
order.
Annual calibration/inspeciton of equipment is taking place by Maker's
authorized service engineers only. Original software to be procured and
updated by maker's service engineer.
Incorrect system Any modification of system is to approval of Class .
operation and disposal Authorized officer to control all service actions and verify proper operation
ENVIRONMENTAL EQUIPMENT 26 OIL WATER SEPARATOR 15ppm II E M II F L
of bilges non compliant before service engineer dissembarkation.
with Marpol Retention of bilges onboard, in case of OWS malfunction,


Consequence
ID NAME analysis
Failure to detect timely

oil mist in ME
crankcase (& FRAMO
room in case of OMD
system for FRAMO).
Service news.
Posisibility of
flamable/explosive
ENVIRONMENTAL EQUIPMENT 27 OIL MIST DETECTION SYSTEM II atmposphere and E M II F L
In case system malfunctions, visual observaiton of temperatures and Crew
damage to equipment
rounds to be arranged by Chief Engineer.
with Major off Hire
involved.
Danger to crew due to
presense of explosive
atmposphere/fire
hazards.
System's parameters are monitored and reported to service company largely

Equipment integrity
agkowledged on monthly basis, to verify integrity.
jeopartized. Systenm
not producing the
AUXILLIARIES 28 ICCP V D L before service engineer dissembarkation. V E L
protective effect of
vessel's hull.
Equipment containing electonic modules will be serviced only by Maker

Equipment rendered authorized service engineers. System's parameters are monitoring on daily
inoperative. Incorrect basis by crew and verified to be within Main Enigne maker recommended
AUXILLIARIES 29 SHAFT EARTHING DEVICE III E M III F L
operation to result in range.
ME damages Authorized officer to control all service actions and verify proper operation
Equipment rendered When electronic components are replaced these are supplied only by maker or
inoperative. Internal authorized dealer and are readily progorammed.
spaces atmposphere Authorized officer to control all service actions and verify proper operation
non controlled and before service engineer dissembarkation.
AUXILLIARIES 30 AIR CONDITIONING PLANT III complains from Crew or E L If system controls fail, manual operation to be used. III F L
third party. Minor off
hire if vessel rejected Passwords to be provided for equipment accesss.
to conduct operations Training before use after any system upgrade.
due to system status Crew awareness on the consequenses of cyber threat.

System inoperability.
Non compliance with
Service news.
regulatory framework.
Periodc health check inspections by largely acredited companies are being
Vessel unable to
conducted.
conduct discharging
CARGO OPERATIONS 31 INERT GAS SYSTEM II operations. Cargo D M II F L
tank atmosphere not
If system controls fail, manual operation to be used.
being controlled and
possibilitiy of formation
of explosive gas
mixtures

Consequence
ID NAME analysis

System inoperability.
Non compliance with
Service news.
regulatory framework.
Vessel unable to
conduct discharging
Periodc health check inspections by largely acredited companies are being
CARGO OPERATIONS 32 INERT GAS GENERATOR II operations. Cargo D M II F L
conducted.
tank atmosphere not
If system controls fail, manual operation to be used.
being controlled and
possibilitiy of formation
of explosive gas
mixtures
When electronic components are replaced these are supplied only by maker or
System inoperability. authorized dealer and are readily programmed.
Non compliance with Authorized officer to control all service actions and verify proper operation
regulatory framework. before service engineer dissembarkation.
Vessel unable to burn Monitoring on daily basis vessel's retained sludge quantity and operaitonal
ENVIRONMENTAL EQUIPMENT 33 INCINERATOR III D M III E L
sludge produced and status of Incinerator provides additiona barrier if system fails, allowing time to
sludge is being enable repair or to dispose sludges to shore facilities.
accumulated/stored
onboard. Training before use after any system upgrade.

System integrity. electornic components.
Incorrect or no Authorized officer to control all service actions and verify proper operation
operation. Fuel before service engineer dissembarkation.
viscosity to the internal Original software to be procured and updated in accordance with Maker
AUXILLIARIES 34 MGO CHILLER UNIT III D M III E L
combustion machinery Service news.
not controlled and If system controls fail, manual operation to be used.
possibility of power
interruptions enhanced. Training before use after any system upgrade.
When PLC or other programmable controllers are replaced , these are procured
readily programmed from maker. If service engineers are attending they must
be maker accredited.
System integrity. Rsik before service engineer dissembarkation.
of bacteria formation If equipment fails, Bottled water to be used for food preparation , catering
AUXILLIARIES 35 UV STERILIZER IV and rendering water D L services and consumption. IV F L
dangerous to be
consumed. Prior recommisioning of the system, it should be subjected to testing to verify
bacteria elimination.

When PLC or other programmable controllers are replaced , these are procured
System inoperability. readily programmed from maker. If service engineers are attending they must
Non compliance with be maker accredited.
regulatory framework. Authorized officer to control all service actions and verify proper operation
Vessel unable to before service engineer dissembarkation.
ENVIRONMENTAL EQUIPMENT 36 SEWAGE TREATMENT PLANT III dispose treated D M Retention of sewage onboard, in case of Sewage treatment system III E L
sewage. Sewage is malfunction,
being
accumulated/stored Passwords to be provided for equipment accesss.
onboard. Training before use after any system upgrade.

Consequence
ID NAME analysis
System inoperability. Only maker produced software to be purchased and installed. In case of
Non compliance with service engineer is attending the vessel, he must be maker authiorized.
regulatory framework. Software update to be carrioed out only by maker authorized service enginer.
Excessive smoke Authorized officer to control all service actions and verify proper operation
ENVIRONMENTAL EQUIPMENT 37 SMOKE DENSITY INDICATOR III leading to thrid party D M before service engineer dissembarkation. III E L
negative observations, Visual observiton for smoke to be conducted if system bacomes inoperative.
PSC related
deficiencies/penalites Training before use after any system upgrade.
imposed. Crew awareness on the consequenses of cyber threat.
Equipment containing electonic modules will be serviced only by Maker

authorized service engineers. System's parameters are monitoring on daily
basis by crew and verified to be within Main Enigne maker recommended
range.
Equipment rendered
inoperative. Incorrect
AUXILLIARIES 38 BEARING WEAR MONITORING SYSTEM III E M Software uograde to be carried out in accordance with maker service news. III F L
operation to reasult in
Visual observation of temperatures when system is inoperative.
ME damages
Equipment rendered When electronic components are replaced these are supplied only by maker or
inoperative. authorized dealer and are readily progorammed.
Inadequate air suplpy Authorized officer to control all service actions and verify proper operation
AUXILLIARIES 39 AIR COMPRESSOR IV to control system D M before service engineer dissembarkation. IV F L
resulting to loss of
power and Training before use after any system upgrade.
maneuverability Crew awareness on the consequenses of cyber threat.
PRIME TANKER PROCEDURE 28 ‐ ANNEX C7 ‐ OT INFORMATION SECURITY PROC 28‐Annex C7
PRIME GAS RISK ASSESSMENT CONTROLS Issue Date: 30/09/2022
Table F‐1 Recommendations for timely responses to events
CIAA Timely response to events L M H
SR 6.1 Audit log accessibility × × ×
SR 6.1 RE 1 Programmatic access to audit logs ×
SR 6.2 Continuous monitoring × ×
Table F‐2 Requirements for Confidentiality in OT system
Confidentiality Data confidentiality L M H
SR 4.1 Information confidentiality × × ×
SR 4.1 RE 1 Protection of confidentiality at rest or in transit via untrusted networks × ×
SR 4.2 Information persistence × ×

SR 4.2 RE 1 Purging of shared memory resources ×
SR 4.3 Use of cryptography × × ×
Table F‐3 Requirements for Integrity in OT system
Integrity System integrity L M H
SR 3.1 Communication integrity × × ×
SR 3.2 Malicious code protection × × ×
SR 3.2 RE 1 Malicious code protection on entry and exit points × ×
SR 3.2 RE 2 Central management and reporting for malicious code protection ×
SR 3.3 Security functionality verification × × ×

SR 3.4 Software and information integrity × × ×
SR 3.5 Input validation × × ×
SR 3.6 Deterministic output × × ×
SR 3.7 Error handling × ×
SR 3.8 Session integrity × ×
SR 3.9 Protection of audit information × ×
Table F‐4 Requirements for Availability in OT system
Restricted data flow and timely response to events and
Availability L M H
resource availability
SR 5.1 Network segmentation × × ×
SR 5.1 RE 1 Physical network segmentation × × ×
SR 5.1 RE 2 Independence from non-control system networks × × ×
SR 5.1 RE 3 Logical and physical isolation of critical networks × × ×
SR 5.2 Zone boundary protection × × ×
SR 5.2 RE 1 Deny by default, allow by exception × ×
SR 5.2 RE 2 Island mode ×
SR 5.3 General purpose person-to-person communication restrictions × × ×
SR 5.3 RE 1 Prohibit all general purpose person-to-person communications × × ×
SR 5.4 Application partitioning × × ×

SR 7.1 Denial of service protection × × ×
SR 7.1 RE 1 Manage communication loads × ×
SR 7.1 RE 2 Limit DoS effects to other systems or networks ×
SR 7.2 Resource management × × ×
SR 7.3 Control system back-up × × ×
SR 7.3 RE 1 Backup verification × ×
SR 7.3 RE 2 Backup automation ×
SR 7.4 Control system recovery and reconstitution × × ×
SR 7.5 Emergency power × ×
PRIME TANKER PROCEDURE 28 ‐ ANNEX C7 ‐ OT INFORMATION SECURITY PROC 28‐Annex C7
PRIME GAS RISK ASSESSMENT CONTROLS Issue Date: 30/09/2022
SR 7.6 Network and security configuration × × ×

SR 7.6 RE 1 Machine-readable reporting of current security settings ×
SR 7.7 Least functionality × × ×
SR 7.8 Control system component inventory × ×
Table F‐5 Requirements for Authenticity in OT system
Authenticity Identification and authentication control and use control L M H
SR 1.1 Human user identification and authentication × × ×

SR 1.1 RE 1 Unique identification and authentication ×
SR 1.2 Software process and device identification and authentication × ×
SR 1.3 Account management × × ×

SR 1.4 Identifier management × × ×
SR 1.5 Authenticator management × × ×
SR 1.6 Wireless access management × × ×
SR 1.6 RE 1 Unique identification and authentication × ×
SR 1.7 Strength of password-based authentication × × ×
SR 1.7 RE 1 Password generation and lifetime restrictions for human users ×
SR 1.8 Public key infrastructure certificates × ×

SR 1.9 Strength of public key authentication × ×
SR 1.10 Authenticator feedback × × ×
SR 1.13 Access via untrusted networks × × ×
SR 1.13 RE 1 Explicit access request approval × ×
SR 2.1 Authorization enforcement × × ×
SR 2.1 RE 1 Authorization enforcement for all users × ×
SR 2.1 RE 2 Permission mapping to roles × ×
SR 2.1 RE 3 Supervisor override ×
SR 2.2 Wireless use control × × ×
SR 2.2 RE 1 Identity and report unauthorized wireless devices ×
SR 2.3 Use control for portable and mobile devices × × ×
SR 2.3 RE 1 Enforcement of security status of portable and mobile devices ×
SR 2.4 Mobile code × × ×

SR 2.4 RE 1 Mobile code integrity check ×
SR 2.6 Remote session termination × ×
SR 2.7 Concurrent session control ×
SR 2.8 Auditable events × × ×
SR 2.8 RE 1 Centrally managed, system-wide audit trail ×
SR 2.9 Audit storage capacity × × ×
SR 2.9 RE 1 Warn when audit record storage capacity threshold reached ×
SR 2.10 Response to audit processing failures × × ×
SR 2.11 Timestamp × × ×
SR 2.11 RE 1 Internal time synchronization × × ×
PRIME TANKER PROCEDURE 28 ‐ANNEX C8 ‐ PROC 28‐ C8
PRIME GAS COMMON INFRASTRUCTURE Issue Date: 30/09/2022
INFORMATION SECURITY RISK ASSESSMENT CONTROLS
Module 1 – Common Aspects.
Module 1 – Common aspects Requirement
S 1.0 Security management Maintaining information security
S 1.0 Security management Management reports on information security
S 1.0 Security management Documentation of the security process
S 1.1 Organisation Granting of site access authorisations
S 1.1 Organisation Granting of (system/network) access authorisations
S 1.1 Organisation Assignment of access rights
S 1.1 Organisation Supervising or escorting outside staff/visitors
S 1.1 Organisation Inspection rounds
S 1.1 Organisation Clean desk policy
S 1.1 Organisation Response to violations of security policies
S 1.1 Organisation Security during relocation
S 1.1 Organisation Secure remote maintenance
S 1.2 Personnel Arrangements for substitution
S 1.2 Personnel Training before actual use of a program
S 1.2 Personnel Training on security safeguards
S 1.2 Personnel Point of contact in case of personal problems
S 1.2 Personnel Avoidance of factors impairing the organisation climate
S 1.2 Personnel Training of maintenance and administration staff
S 1.3 Business continuity management Tests and emergency drills
S 1.3 Business continuity management Checking and maintaining the emergency measures
S 1.3 Business continuity management Documentation in the business continuity management process
S 1.3 Business continuity management Checking and controlling the business continuity management process
S 1.4 Data backup policy Appropriate storage of backup data media

S 1.4 Data backup policy Sporadic checks of the restorability of backups
S 1.5 Data protection Data protection guidelines for logging procedures
S 1.5 Data protection Documentation of admissibility regarding data protection
S 1.5 Data protection Maintenance of data protection during operation
S 1.5 Data protection Deletion/destruction in compliance with data protection
S 1.6 Protection against malware Documentation on changes made to an existing IT system
S 1.6 Protection against malware Reporting infections of malware,
S 1.6 Protection against malware Updating the virus protection programs and signatures
S 1.6 Protection against malware Prevention against malware
S 1.6 Protection against malware Use of virus protection programs
S 1.8 Handling security incidents Remedial action in connection with security incidents
S 1.8 Handling security incidents Notification of parties affected by security incidents
S 1.8 Handling security incidents Evaluation of security incidents
Testing the effectiveness of the management system for the handling of
S 1.8 Handling security incidents
security incidents
S 1.8 Handling security incidents Detection and documentation of security incidents
S 1.8 Handling security incidents Classifying and assessing security incidents
S 1.8 Handling security incidents Limiting the effects of security incidents
S 1.8 Handling security incidents Recovering the operating environment after security incidents
S 1.8 Handling security incidents Documentation of security incidents
S 1.9 Hardware and software management Use of anti-theft devices
S 1.9 Hardware and software management Audit of the hardware and software inventory
S 1.9 Hardware and software management Escrow of passwords
S 1.9 Hardware and software management Documentation of authorised users and rights profiles
S 1.9 Hardware and software management Documentation on changes made to an existing IT system
S 1.9 Hardware and software management Obtaining information on security weaknesses of the system
S 1.9 Hardware and software management Checking the log files
S 1.9 Hardware and software management Checking the efficiency of user separation on an IT system
S 1.9 Hardware and software management Data protection guidelines for logging procedures
S 1.9 Hardware and software management Error handling
S 1.9 Hardware and software management Continuous documentation of information processing
S 1.9 Hardware and software management Prompt installation of security-relevant patches and updates
S 1.9 Hardware and software management Resetting passwords
S 1.9 Hardware and software management Careful modifications of configurations
S 1.9 Hardware and software management Use of the vendor resources
S 1.9 Hardware and software management Software reinstallation on workstations
S 1.9 Hardware and software management Secure usage of wireless keyboards and mice
S 1.9 Hardware and software management Handling of password storage tools
S 1.9 Hardware and software management Protection against undesired outflows of information
S 1.9 Hardware and software management Performing penetration tests
S 1.10 Standard software Licence management and version control for standard software
Planning and maintenance of IT security during ongoing outsourcing
S 1.11 Outsourcing
operations
S 1.12 Archiving Appropriate storage of archiving media
S 1.12 Archiving Monitoring of the memory resources of archiving media
S 1.12 Archiving Consistent indexing of documents during archiving
S 1.12 Archiving Regular auditing of the archiving procedure
S 1.12 Archiving Regular market surveys of archive systems
S 1.12 Archiving Regular regeneration of archived data resources
S 1.12 Archiving Regular regeneration of encrypted data in archiving
S 1.12 Archiving Protection of the integrity of the archive system index database
S 1.12 Archiving Logging of the archival accesses
S 1.12 Archiving Regular function and recovery tests for archiving
S 1.13 Information security awareness and training Making staff aware of information security issues
S 1.13 Information security awareness and training Training before actual use of a program
S 1.13 Information security awareness and training Training on security safeguards
S 1.13 Information security awareness and training Training of maintenance and administration staff
S 1.13 Information security awareness and training Instructing staff members in the secure handling of IT
S 1.13 Information security awareness and training Performing simulations on information security
S 1.14 Patch and change management Continuous documentation of information processing
S 1.14 Patch and change management Integration of patch and change management into the business processes
S 1.14 Patch and change management Co-ordination of change requests

S 1.14 Patch and change management Scalability in patch and change management
S 1.14 Patch and change management Measuring the success of change requests
S 1.14 Patch and change management Careful modifications of configurations
S 1.14 Patch and change management Assuring the integrity and authenticity of software packages
S 1.14 Patch and change management Synchronisation within patch and change management
Configuration of auto-update mechanisms in patch and change

S 1.14 Patch and change management
management
Careful classification and handling of information, applications and
S 1.15 Deleting and destroying data
systems
S 1.16 Compliance management Maintaining information security
Careful classification and handling of information, applications and
S 1.16 Compliance management
systems
S 1.16 Compliance management Consideration of legal framework conditions
S 1.16 Compliance management Granting exceptions
S 1.16 Compliance management Instructing staff members in the secure handling of IT
Module 2 – Infrastructure
Module 2 - Infrastructure Requirement
S 2.1 General vessel Closed windows and doors
S 2.1 General vessel Locked doors
S 2.1 General vessel Key management
S 2.1 General vessel Fire safety inspection
S 2.1 General vessel Timely provision of information to the fire safety engineer
S 2.2 Electrical Cabling Timely provision of information to the fire safety engineer
S 2.2 Electrical Cabling Inspection of electrical equipment
S 2.3 Office/local workplace Closed windows and doors
S 2.3 Office/local workplace Locked doors
S 2.3 Office/local workplace Suitable storage of official documents and data media
S 2.3 Office/local workplace Use of anti-theft devices
S 2.3 Office/local workplace Clean desk policy
S 2.4 Server room Closed windows and doors
S 2.4 Server room Locked doors
S 2.5 Data media archives Closed windows and doors
S 2.5 Data media archives Locked doors
S 2.6 Technical infrastructure room Closed windows and doors
S 2.6 Technical infrastructure room Locked doors
S 2.7 Protective cabinets Closed windows and doors
S 2.7 Protective cabinets Locking of protective cabinets
S 2.7 Protective cabinets Correct procedure for code locks
S 2.8 Home workplace Closed windows and doors
S 2.8 Home workplace Locked doors
Module 2 - Infrastructure Requirement
S 2.8 Home workplace Clean desk policy
S 2.9 Computer centre Closed windows and doors
S 2.9 Computer centre Locked doors
S 2.9 Computer centre Function tests of the technical infrastructure
S 2.9 Computer centre Construction projects during ongoing operations
S 2.9 Computer centre Protecting a computer centre from unauthorised entry
S 2.10 Mobile workplace Closed windows and doors
S 2.10 Mobile workplace Locked doors
S 2.10 Mobile workplace Use of anti-theft devices
S 2.10 Mobile workplace Clean desk policy
S 2.10 Mobile workplace Secure use of hotspots
S 2.10 Mobile workplace Working with external IT systems
S 2.11 Meeting, event, and training rooms Closed windows and doors
S 2.11 Meeting, event, and training rooms Supervising or escorting outside staff/visitors
S 2.11 Meeting, event, and training rooms Software reinstallation on workstations
S 2.11 Meeting, event, and training rooms Secure operation of hotspots
S 2.12 IT-Cabling Prevention of transient currents on shielding
S 2.12 IT-Cabling Monitoring of existing connections
S 2.12 IT-Cabling Ongoing update and review of network documentation
PRIME TANKER PROCEDURE 28 ‐ ANNEX C ‐RISK ASSESSMENT MATRIX RISK ASSESSMENT MATRIX
PRIME GAS Revision: 0
HIGH: Work shall not start unless approval is obtained from Management Ashore.
MODERATE : Efforts should be made to reduce the risk, with heightened monitoring of the additional controls implemented
LOW : No additional controls required, monitoring requires ensuring controls maintained.
A B C D E F
I H H H H M L
II H H H M M L
III H H M M L L
IV H M M L L L
V M M L L L L
Risk Letter Likelihood Estimated Frequency of incidents

A Possibility of repeated events One or more times per month
B Possibility of isolated incidents One or more times per quarter
C Possibility of occurring sometime One or more times in 1 year
D Not likely to occur Less than once in 5 years
E Very remote probability of occurrence Less than once in 10 years
F Extremely remote probability of occurrence Less that once in 15 years
Consequence Health and Safety Damage to Vessel / Property Environmental Impact Cyber Security Impact. Other
Critical violations of confidentiality / integrity;
Total loss. Immediate lay up / Dry Docking critical asset / data / resource unavailable;
Spill / discharge in water > 100 ltr. Major Industry reaction. Fleet-wide blacklist
I Fatality, serious impact on public for major repairs. Major claims from 3rd Critical violations of procedures / processes /
by one or more Oil Majors.
parties. policies; Problem known / unknown but cannot
be controlled.
Major violations of confidentiality / integrity;

Extensive off-hire, loss of charter,
Permanent disability, Limited impact on Require lay up repairs, 3rd Party claims. critical asset / data / resource unavailable; major
II Spill / discharge in water <100 ltr blacklisting of vessel by more than one Oil
public. violations of procedures / processes / policies;
Major.
Problem known and can be controlled.
Medium violations of confidentiality / integrity;

Affecting sea worthiness, repaired with or
Serious injury or multiple minor injuries non-critical asset / data / resource unavailable; Major off-hire, blacklisting of vessel by one
III without shore assistance. Leading to COC to Spill on deck > 1 M3
requiring hospitalization / signing off. medium violations of procedures / processes / Oil Major.
be cleared by next DD.
policies.
Minor violations of confidentiality / integrity;
Not affecting sea worthiness, repair minor effect on availability of asset / data /
IV Injury requiring medical treatment ashore Spill on deck < 1 M3 Minor off-hire.
requiring external assistance. resource available; minor violations of
procedures / processes / policies.
No effect; confidentiality / integrity not
Not affecting sea worthiness, repairable by endangered; asset / data / resource available;
V Simple First Aid Accidental discharge within containment tray Operational delay.
ship staff minor violations of procedures / processes /
policies.
PRIME TANKER APPENDIX TO PRO 28- RISK ASSESSMENT CRITICAL EQUIPMENT
PRIME GAS Version:13
RISK ASSESSMENT FOR CRITICAL EQUIPMENT IDENTIFICATION Issue date :30/09/22
MINIMUM SYSTEMS CRITICALITY & RISK

OIL & LPG TANKERS RISK ASSESSMENT MSC.1/Circ.1389
Possibly Applicable?
Inventory Of Minimum Spare Parts based on TMSA 3 requirments :
Criticality of equipment
Software dependant
Consequnece of failure
LIKELIHOOD
Upgrade to
ESSENTIAL
SEVERITY
CRITICAL
Risk Based equipment categorisation
Required Available latest released
RISK
Is sudden loss of a single system Equipment. Machinery and system redundancy
Ref Systems Potential Hazardous effects System system Measures For Mitigating Risks Performance standard software that
functionality a potential hazard? Experience of the equipment and machinery
Reliability reliability solves a known
Manufacturers' recommendations
bug
Vessel's trade
Lead time for spares delivery
Parts working quantities for each equipment
1 Navigation & Communication Equipment

Yes Yes Yes Yes Yes Yes Yes - According to SOLAS ,
vessels should be equipped with an
Performance standard:
X-band Radar (9GHz) ,able to Regular checks according to PMS, CRITICAL SPARES Yes (due to
Potential collision/No possibility of Resolution MSC.192
1.1 X-band Radar & ARPA I Yes determine and display the range and Yes High High E M and spare parts inventory to be Spare Magnetron for X-Band Radar - One Set. Yes criticality
assistance in rescue operations (79) Adopted on 6
bearing of SART. The S-band retained. Carbo brushes (applicable to Furruno X band) assessment)
December 2004
radar (3GHz) does not provide
SART display
Yes Yes Yes Yes Yes Yes
Yes (due to
No- X-band radar provides Resolution MSC.192
1.1a S-band Radar Potential collision I Yes NO High High E M Regular checks according to PMS Yes criticality
adequate redundancy (79) Adopted on 6
December 2004
assessment)

Yes (if during
annual
Magnetic Compass and second Performance Standard:
overhauling
Gyro is considered sufficient Resolution A.424 (XI)
Affecting Sea Worthiness, No - Adequate redundancy with this is
1.2 Gyro Compass II Yes No High High E M redundancy. Frequent inspections Yes Adopted on 15
Operational delay Magnetic Compass. considered
as per PMS & Annual Service by November 1979
Agenda item 10 (b) necessary by
Service Engineer.
the
technician)

Potential collision with small No - Adequate redundancy with
1.3 Ship's Whistle III Yes No High High E L No
vessels/boats two units & independent fog/bell.

Regular checks as per PMS.
1.4 Navigation lights Potential Collision I Yes No - Duplication of lights No High High E M Inspection during company No
representative attendance.

Performance Standard
Regular checks as per PMS. Resolution MSC. 74 Yes (due to
Potential grounding at shallow
1.5 Echo sounder II Yes Yes - No system redundancy. Yes High High D M Nautical Charts continuously Yes (69) Adopted of new criticality
waters
updated. and amended assessment)
perforamnce standards

Potential collision with small No - Other means for warning MINIMUM SPARES
1.6 Aldis III Yes No High High E L No
vessels/boats (ship's whistle) (3) pcs spare lamps

FBB
1.7 Communication Equipment Minor off-hire. IV No No No High High D L
Yes
Yes (If found

Performance
No - Adequate redundancy with Regular checks as per PMS, necessary
Standards: A.525(13),
1.8 GMDSS No means to raise distress call. II Yes Satellite communication systems No High High E M Annual check/service by Radio Yes during the
A.694(17), A.808(19),
(Inmarsat & Fleet Broad-band) Technician. annual radio
MSC68(68),A.807(19)
survey)

GMDSS not operational during Regular checks as per PMS,
No - Adequate redundancy with
1.9 Emergency Batteries Black-out, no means to raise II Yes No High High E M inspected/checked by company No
Emergency Generator
distress call. representative during attendance.

No (due to
Deviation in system, Operational
1.10 Autopilot IV No No No High High D L Yes Resolution A.342(IX) criticality
Delay
assessment)
No (due to
1. Position fixing by alternative
Performance Standard: redundancy
means (visual observations - radar)
Resolution by
Inadequacy of electronic position 2. GPS automatic integrity check
GPS I Yes No- Adequate redundancy No High High E M Yes MSC.112(73) Adopted navigational
fxing means on ECDIS 3. GPS failure drill 4.
on 1 December 2000 equipment
RIO 5. Magnetic compass 6. Self (on or after 01.07.2003) not software
Test function
dependant )
Page 1 of 11
Performance Standard:
Resolution
MSC.333(90) Adopted
on 22 May 2012
No (due to
Insufficient detail to restore a (installed after
VDR V Yes No No High High C L Annual Performance test Yes criticality
complete record of the voyage 01.07.2014) -
Resolution MSC. 214
assessment)
(81) Adopted on 12
May 2006 (installed
before 1.07.2014)
Inadequate information provided to Resolution MSC.
No AIS provides supplementary No (due to
appropriately equipped (AIS) shore 74(69) Adopted on 12
AIS V Yes information, AIS not used for No High High C L Annual Performance Test Yes criticality
stations. Indaqueacy of situational May 1998 Resolution
collision avoidance purposes assessment)
awareness. A.694 (17) Adopted on
6 November 1991
No (due to
No speed indictaion and distance Resolution MSC. 96
Speedlog III Yes Speed can be obtained from GPS No High High E L Yes criticality
through the water (72) Adopted on 22
May 200
assessment)
Lack of determination and display
Resolution A.694 (17)
Magnetic Compass of the vessel's heading independent III Yes No No High High E L No
Adopted on 6
of any power supply
November 1991
No (due to
No- Weather information can be
Weather facsimile Lack of weather information III Yes No High High E L Yes criticality
obatined by alternative means
assessment)
Provided with a facility to to test

that the radio receiver, the display Resolution MSC.148 No (due to
Lack of navigational warnings Yes- unavailability of navigational ,
NAVTEX III Yes No High High E L device/printer and non-volatile Yes (77) Adopted on 3 June criticality
information meteorological information
message memory are functioning 2003 assessment)
correctly.
Not based on Risk Assessment due

to back-up system availability at all Performance Standard
Back-up system provided with Yes (due to
Potential grounding at shallow times. It is made Crtitical by default CRITICAL SPARES Resolution
1.11 ECDIS II Yes Yes High High E M either a back-up ECDIS or papart Yes criticality
waters due to Australian Port State One SPARE SCREEN MSC.232(82) Adopted
charts. assessment)
Authorities requirements, and due on 5 December 2006
to newly implied system.
Inability to provide prompt

notifications/announcements to all
crew (i.e. Security breach , Safety
1.12 Public addressor II YES Yes - No system redundancy. Yes High High E M PMS : Weekly check of the system
hazard idenitified, Fire on non
detected areas , Emergency
evaluation etc.)
Even though as per SOLAS

Inabilitiy of on-scene requirements each vessel (above
communication between survival 500gt) must have 3 x VHF and PMS : Inspections as per SOLAS
1.13 VHF of GMDSS II YES Yes High High E M
craft and ship and between survival spare batteries , the equipment is are included in the PMS
craft and rescue unit considered critical due to impact in
case of failure
Page 2 of 11
2 Safety equipment
Lose time in ship staff reaction in System frequent test as per
2.1 General Alarm System case of Emergency. Can result in I Yes Yes - No system redundancy. Yes High High E M company PMS & test during
fatality company representative attendance.

Losing time in case of rescue. Can
No - Adequate redundency with Frequent test onboard (PMS).
2.2 EPIRB cause fatality in case of Ship I Yes No High High E M
SART and GMDSS Distress. Annual check by Radio Technician.
Abandon

Yes - for rescue operation CRITICAL SPARES
(Lifeboats critical) Annual Service, frequent Lifeboat Engine spare Fuel Oil & Lub Oil Filters elements 2 pieces each.
Fatality in case of ship abandon. No
2.3 Life boats & Life Rafts I Yes No - for ship abandon since Full Yes High High E M inspections as per PMS & inventory
Possibility for rescue operation.
redundancy between lifeboats & of Spare Parts MINIMUM SPARES
liferafts. Lifeboat wire (1 pc)

Personnel injury in case of Black-
2.4 Emergency Lights II Yes No - Fully redundant system No High High E M Regular checks according to PMS
Out

Regular checks as per PMS &
Mustering equipment No - Adequate Redundancy with
2.5 loss of life in case of Emergency I Yes No High High E M test/inspection during Company
(walkie talkie/VHF) multiple portable radios
Representative Attendance.

No - Other means for towing are
2.6 Emergency towing Systems Off-hire III Yes No High High E L
possible

General safety equipment No - Adequate Redundancy of
(Lifejackets, TPA, etc.) Lifesaving Equipment onboard.
Yes Yes Yes Yes No No

No - Adequate Redundancy with Regular checks as per PMS &
2.8 Portable measuring instruments loss of life I Yes multiple Portable Measuring No High High E M test/inspection during Company
Instruments Representative Attendance.
Yes. Ability to charge BA cylinders

Breathing apparatus not ready for
is lost.
use. Regular checks as per PMS &
Vessel's compliance with regulatory CRITICAL SPARES
2.9 Breathing Air compressor Loss of ability to mobilize fire I Yes YES High High E M test/inspection during Company
requirements SOLAS will be One set of Air filter and Hoses/fittings
fighting team for extingushing fire. Representative Attendance.
affected.
Loss of life
Page 3 of 11
3 Fire Fighting Equipment

test/inspection during Company
No back-up in case of emergency, CRITICAL SPARES
3.1 Emergency Fire Pump I Yes Yes Yes High High E M Representative Attendance &
no control of fire. Emergency Fire Pump Spare mechanical seal. Mouth Ring & Bearings
Inventory of Spare Parts to be
retained:
In case of Fire Detection system MINIMUM SPARES
3.2 Fire detection & alarm system Delay in Fire Fighting reaction II Yes Yes Yes High High E M failure, the Engine Room is One piece of each type of smoke/heat/flame sensor.
operated under manned mode. One manual call point
Yes Yes Yes Yes No No CRITICAL SPARES

1x sesnor each type
No possibility to detect Cargo Regular checks as per PMS &
MINIMUM SPARES
3.3 Gas Detection System Leakage into Ballast Tanks or into I Yes Yes Yes High High E M inspection/check during company
3 xMEMBRANE for PUMPS of Salvico system
P/R - Pollution & Fire Hazards representative attendance.
Applicable vessels as per MOC No 30/2017
1 xMEMBRANE for each PUMP type

No possibility to extinguish an Regular checks as per PMS &
Fixed fire extinguishing system
3.4 extensive fire with the system. No I Yes Yes Yes High High E M annual service by WSS or other
(E/R)
control of Fire authorized Service Company.

Fixed fire extinguishing system No possibility to extinguish an Regular checks as per PMS &
3.5 (Deck, P/R, Cargo Compressor extensive fire with the system. No I Yes Yes Yes High High E M test/inspection during Company
Room, other) control of Fire Representative Attendance.

No - Adequate means to stop
Difficulty to extinguish fire due to Regular checks as per PMS &
Remote Shut-Down Devices supply of fuel/lub oil by quick
3.6 continuous supply of fuel/lub oil II Yes No High High E M test/inspection during Company
(ventilation & pumps) closing valves and supply of air by
and air flow. Representative Attendance.
fire dampers
Yes Yes Yes Yes Yes Yes Regular checks as per PMS,
No possibility to isolate FO & LO test/inspection during Company
Yes (Flow of fuel will continue by CRITICAL SPARES
3.7 Quick-Closing Valves Tanks in case of Fire. II Yes Yes High High D M Representative Attendance &
gravity in case of leakage) Quick Closing Valves O-Rings (One Set) for each kind of piston.
inventory of spare parts to be
retained onboard:
Ventilation Fire dampers and funnel No possibility to isolate air during CRITICAL SPARES
3.8 II Yes Yes Yes High High D M Representative Attendance &
dampers Fire Ventilation Fire Dampers actuators one (1) set of spare seals
retained onboard:
Local Fire Fighting (Water Mist) MINIMUM SPARES
3.9 Delay in Fire Fighting reaction II Yes Yes Yes High High D M Representative Attendance &
System One piece of each type of smoke/heat/flame sensor.
retained onboard:
Page 4 of 11
4 Machinery Equipment
CRITICAL SPARES
M/E is provided with self
M/E T/C spare Bearings & Labyrinth (one set).
redundancy. Defective units can be
isolated. If Alarms not working, Regular checks as per PMS &
MINIMUM SPARES
E/R will be operated under manned test/inspection during Company
M/E Spares to cover the complete O/H of one Cylinder Unit (including Piston, Cover, Cooling jackets ,
Loss of propulsion, collision in conditions. In case Maneuvering Representative Attendance. M/E
Main Engine, including Alarms & Starting air valve , Fuel valves , High pressure pipe, Fuel Pump,Exhuast valve , Bearings). M/E jacket
maneuvering,, off-hire, injury due system failure, Engine operated Maneuvering System inspection by
4.1 Emergency Shut-Downs & Oil Mist II Yes Yes High High D M cooling Compensator.
to crankcase explosion. from Emergency Stand. Service Engineer during D/D. M/E
Detector When ME is equipped with Alpha Cylinder Lubrication system , vessel to have spare two pcs of rpm pick-
Item considered Critical: T/C Spare Parts inventory to be
up sensors, (2) pcs inductive sensors & (2) pcs solenoid valves.
1. Oil Mist Detector. retained onboard:
One spare ME Aux blower Electric Motor .
2. Em. Maneuvering Stand
One piece exhaust gas temperatrure sensor
3. M/E Safety Shutdowns
One local temperature gauge
4. M/E Turbocharger
One Piston Cooling Non-Flow Sensor
MINIMUM SPARES
D/G Spares : Two (2) pistons with piston irngs and scrapper rings, one (1) cylinder cover complete , one
Regular checks as per PMS,
cylinder liner, one Fuel oil injection pump , one set of T/C bearings , one set T/C labyrinth, one T/C nozzle
Main Diesel Generators Alarms & Engine Damage, black out. No - Adequate redundancy ring, FO high pressure pipes fro two cylinders , fuel valves complete for three (3) cylinder units, inlet
4.2 III Yes No High High D M Representative Attendance &
Emergency Shut Downs onboard valves for 2 cylinder units, exhaust valves for four (4) cylinder units, Main/Crankpin/Conn rod bearing
one piece each , Connecting rod bolts for one cylinder.
retained onboard:
Automatic Voltage regulator 1pc/Vessel (9/4/2017)

MINIMUM SPARES
Boiler spares one set; Main burner & Ignition Burner nozzles.
For vessels fitted with 2 Oil fired Boilers, one set of force draft fan electric motor bearings.
For vessels fitted with 1 OIl fired boiler Boiler, one Complete Electric Motor for forced draft fan.
For vessels fitted with 1 Oil fired boiler with rotary cup burner (Spottail, Bowfin, Flagship Lotus,
Starman Avanti) one (1) set of bearings.
1x Mechanical seal for the economizer feed or circulating pump (as applicable)
Smoke density sensor 1/vessel
1x Mechanical seal (or gland packing) for auxiliary boiler feed water pump
MINIMUM SPARES (In case of AALBORG Boilers only)
1) D/P air flow transmitter (1 / vessel)

2) Unisab (1 / vessel)
No - Adequate redundancy 3) Control panel parts
boiler explosion, onboard with two Boilers. If one a) Timer for Control Panel, 1pc
II Yes No High High E M Representative Attendance &
no heating,, off hire Boiler Unit, Generators are run on b) PR Sockets, 2pcs
Diesel. c) PR Springs, 2pcs
retained onboard:
Boilers including safety devices and 4) Oil Flow Parts
4.3 trips including safety valves and a) Pick Up Sensor, 1pc
automation b) Set of bearings, 1pc
c) Set of O rings, 1pc
5) Flame Surveillance Parts
a) Photo cell for Main Burner, 2pcs
b) Photo cell for Ignition Burner, 1pc
c) Flame relay for Main burner, 1pc
6) Burner / Ignition burner Parts
a) Set of ignition electrodes for ignition burner, 1pc
b) O-rings for main nozzle, 10pcs
c) CU Washer for main nozzle, 10pcs
d) Read contact for igniter in position signal, 1pc
e) Solenoid valve, for Ignition burner, 1pc
f) Spark plug cover for ignition burner, 2pcs
7) Pneumatic control Parts
a) Filter regulator, 1pc
b) Vent valve, 1pc
c) Positional for air damper, 1pc
8)Burner main shaft ball bearings (2) pcs (Applicable only for Aalborg Mission OM35)
black out, no possibility of CRITICAL SPARES
4.4 Emergency generator II Yes Yes Yes High High D M Representative Attendance &
recovery. Emergency Diesel Generator one (1) spare set of Fuel Oil & Lub Oil Filters elements.
retained onboard:
Yes Yes Yes Yes Yes Yes MINIMUM SPARES
FO Purifier one complete set of O-rings
No - Adequate system redundancy Ball bearings (for both shafts) of one 1 HFO purifier .
Fuel oil system & Pumps, with stand-by start pumps. In case FO Purifier Friction Clutch (1) complete set
4.5 Sea worthiness, vessel's stop/delay III Yes No High High D M Representative Attendance &
including safety devices of Alarms failure, E/R operated One mechanical seal for each type (HFO/MGO) ME FO Circulating pump
under manned condition. One mechanical seal for each type (HFO/MGO) ME FO supply pump
retained onboard:
One mechanical seal for each type (HFO/MGO) AE FO Circulating pump
One mechanical seal for each type (HFO/MGO) AE FO supply pump
Page 5 of 11
Regular checks as per PMS, MINIMUM SPARES

No - Adequate system redundancy
test/inspection during Company LO Purifier one complete set of O-rings
with stand-by start pumps. In case
4.6 Lub Oil system & Pumps Sea worthiness, vessel's stop/delay III Yes No High High D M Representative Attendance & Ball bearings (for both shafts) of one 1 LO purifier.
of Alarms failure, E/R operated
inventory of spare parts to be LO Purifier Friction Clutch (1) complete set
under manned condition.
retained onboard: 3 PCS filter elements for M/E LO Auto filter & Servo oil filter (for electronic engines only)
Yes Regular checks as per PMS,

S.W. & F.W. Cooling Systems & no cooling , no propulsion and with stand-by start pumps. In case MINIMUM SPARES
Pumps black out, vessel's stop/delay. of Alarms failure, E/R operated Main Cooling S.W. Pumps Mechanical Seal and mouth ring.
retained onboard:
No - Adequate system redundancy test/inspection during Company
No propulsion, losing time to start MINIMUM SPARES
4.8 Compressed air MAIN system III Yes with multiple air compressors and No High High D M Representative Attendance &
in emergency situation. Main Air Compressors one set spare suction and discharge valves.
receivers. inventory of spare parts to be
retained onboard:
Emergency Air Compressor failure
is not a hazard as long as Receiver
Regular checks as per PMS CRITICAL SPARES
Unavailability of air to supply remains charged.
Inpsection during office 1x Electric motor for the Emcy compressor |(in case of Electric driven and provided the emrgency
4.9 Emergency Air compressor starting air to vessel's Diesel III Yes However taking into account the YES High High D M
representative attendance. compressor is not one of the main air compressors)
Generators after a black out. risk that receiver is empty due to
Critical spare parts 1 x set of fuel oil filters in case of Diesel Driven emergency air compressors
human error the equipment is
considered critical
Page 6 of 11

CRITICAL SPARES
Even though there is available Adequate redundancy built-in the
One (1) Hydraulic pump filter / Vessel.
redundancy (2 x pumps), the system. Regular checks as per
4.10 Steering gear collision II Yes YES High High E M
impact of a potential failure is high PMS.
For vessels fitted with HATLAPA Steering Gear one (1) hydraulic pump complete (Sauger, Flagship Ivy,
thus rendering equipment critical.
Flagship Violet).
MINIMUM SPARES
Spare : One set of Brake band for Windlass and
Two set of Brake band for Winches to be onboard .
No - adequate redundancy with two
4.11 Windlasses & Mooring Winches Off-hire III Yes No High High E L One spare Hydraulic motor for Windlass.
units
Two spare mooring wires ,
Two spare mooring tails.
O-ring kit for main control valve (1) set for windlass & (1) set for mooring winch
No - E/R operated under manned

Machinery failure, tanks
4.12 Alarm & Monitoring System III Yes conditions in case of Alarm No Medium High E L
overflow/pollution.
Monitoring System failure.

E/R Bilge System & Associated Pumping system fully redundant.
4.13 Potential flooding. II Yes Yes High High E M test/inspection during Company
Alarms Critical: Bilge Level Alarms
Yes Yes Yes Yes Yes Yes Yes (No redundancy to discharge
Bilge water from E/R).
test/inspection during Company CRITICAL SPARES
0il / water separator and measuring pollution if valve not closing, off- Furthermore considering the
4.14 II Yes Yes High High D M Representative Attendance & Oily Water Separator Spare one set Solenoid Coil for 3-Way Valve & Spare Filter.
system (15PPM) hire potential & legal implications Environmental impact component
inventory of spare parts to be 5 pcs Membrane Cartridge (applicable only for Sasakura SMT-5A)
categorized also as
retained onboard:
Environmentaly Critical.
CRITICAL SPARES
Yes, due to lack of redundancy. Regular checks as per PMS,
W.O. Incinerator spare one (1) set temperature controller for primary chamber, (1) set temperature
Furthermore considering the test/inspection during Company
controller for secondary chamber, Thermocouples for cobustion/flue gas (1) pc each Electrode units for
4.15 Incinerator Oil retention onboard. III Yes Environmental impact component Yes High High C M Representative Attendance &
Primary / Seconday Burners and Flame Detector (1).
categorized also as inventory of spare parts to be
2 bags of 25kg each (plibrico or fire clay)
Environmentaly Critical. retained onboard:
Flue Gas Fan V-Belt (1) (applicable only for Teamtec OG(S) 400)
Yes, due to lack of redundancy.

Furthermore considering the Regular checks as per PMS, CRITICAL SPARES (& ENVIRONMENTAL SPARES):
4.16 Sewage System Pollution if not treating properly III Yes Environmental impact component Yes High High D L test/inspection during Company Vessels equipped with one Air blower to have
categorized also as Representative Attendance 1 x Air blower (including motor) complete

personnel injury, damaged No - E/R Crane not operated if not MINIMUM SPARES
4.17 ER Crane II Yes No Medium Medium E M test/inspection during Company
equipment in good condition Crane wire (1 pc)

No - adequate redundancy of Main Main Switchboard safety devices &
no propulsion, black out,
4.18 Switch boards II Yes Switchboard for MINIMUM No High High E M redundancy. Regular checks as per
electrocution
Motors PMS.
PMS :
1)Concerning shafting the stern
tube oil is analysed on 6m basis.
2)Stern tube bearing is equipped
Yes. In case of either
with a temperature alarm.
Rudder.Shafting or Propeller loss
3) Concering rudder, testing as per
the vessel will be rendered non self
pms of steering gear system.
propelling and external assistance
4.19 Propeller, Shafting ,rudder Loss of maneuverability. II Yes YES High High E M During preiodical underwater
(i.e Tugs Escorting ) will have ot be
isnpections, rudder structural
mobilized for vessel assistance and
condition is confirmed.
reposition to safe location for
repairs.
Propeller : On yearyl basis propeller
inspection andcleaning is conducted
as per PMS.
Page 7 of 11
Yes Yes Yes Yes Yes Yes CRITICAL SPARES (& ENVIRONMENTAL SPARES) :
1. Purimar (electrolysis): Vessels equipped with Purimar Ballast water treatment system to be equipped
with 1 x TRO sensor
Vessels with Erma First BWTS using electrolytic cell, to also be equipped with the following:
- CENTRIFUGAL PUMP 84M3/H 20M 440V/ 60Hz
- T-STRAINER
- REPLACEMENT TUBING/ CUVETTE KIT NON-EX
- Flow Through Cuvette
- CHECK VALVE REPLACEMENT KIT
- T STRAINER SCREEN
- T STRAINER/ PRESSURE REGULATOR ASSEMBLY
- FLOW SWITCH DIGITAL 24V
- PRESSURE TRANSMITTER 0-10bar
- TEMPERATURE SENSOR 0-100C
Yes (No redundancy to discharge
- SOLENOID 5/2 1/4" NAMUR ALUM 24 VDC EMBEDED COIL/CONNECTOR
pollution if system is not properly Ballast with zones as defined in the
Regular checks as per PMS & - SOLENOID VALVE 2/2 NC DN6 THREADED EMBEDED COIL 24V DC
BALLAST WATER functioning. Inability or prohibition BWM Convention ) Furthermore
4.20 III Yes YES High Medium D M test/inspection during Company - SOLENOID VALVE CONNECTOR WITH LED 24V DC
TREATMENT SYSTEM to carry ot cargo operations, off- considering the Environmental
Representative Attendance. - SOLENOID 5/2 1/4" NAMUR ALUM 24 VDC EMBEDED COIL/CONNECTOR
hire potential & legal implications impact component categorized
- MECHANICAL SEAL FOR CENTIFUGAL PUMP
also as Environmentaly Critical.
- PNEUMATIC DIAPHRAGM PUMP 8LT/MIN 3,5BAR
- FUSE &- CYLINDRICAL FUSE 2A 10X38MM
2. Pureballast (UV): Vessels equipped with PureBallast Ballast water treatment system to be equipped with
MINIMUM SPARES:
1x CIP liquid (Spare part)
1x Filter maintenance kit
1x CIP pump spare part set
CRITICAL SPARES:
1x Lamp power supply
1x Quartz sleeve set
1x UV lamp set
1x UV sensor
1x Temperature switch
No likelihood of rudder loss due to

4.21 Rudder Loss of maneuverability. III Yes No High High E L
system malfunction.

Maker recommedned PMS
Ballast with zones as defined in the
Exhasut Gas Cleaning Scrubber pollution to the atmoshere with requirements to be implemented
BWM Convention ) Furthermore Critical spares will be assessed based on maker requirements and company assessemnt and will be
4.22 System (To be installed on first excess Sulphur than allowed if III Yes YES High Medium D M prior system is put in service.
considering the Environmental developed prior system is put into service.
fleet vessel by end of April-2020) system is not properly functioning. System to be inspected by attending
impact component categorized
Technical Superintendents.

No - Adequate system redundancy test/inspection during Company MINIMUM SPARES
4.23 Main Engine LO Auto Filter Sea worthiness, vessel's stop/delay III Yes with manual by pass filter. E/R No High High D M Representative Attendance & ME LO Auto Filter 3 filter elements (cartridges).
operated under manned condition. inventory of spare parts to be
retained onboard:
Page 8 of 11
5 Cargo Equipment (Oil Tankers)

No - Redundancy with multiple MINIMUM SPARES
5.1 Cargo pumps and stripping pumps Off-hire III Yes Cargo Pumps & Portable Pump for No High High E L 1 x set of Mehcanical seals for CARGO PUMP
the case of Framo. EFC governor for hydraulic powerpack diesel engine (FRAMO Vessels)
Yes Yes Yes Yes No No Although redundancy exists

Release of crude oil, oil spill, (multiple stop buttons), the
CRITICAL SPARES
5.2 Emergency Stop of Cargo Pumps pollution . II Yes potential consequence of failure to YES High High E M Frequent checks as per PMS
One cargo pump emergency stop button/ vessel
opearate of one stop buttion in case
ofemergency is considered high.
Adequate Redundancy with
Cargo Pumps Temperature Alarms
5.3 Fire hazard II Yes No - Multiple Cargo Pumps. No High High E M multiple Cargo Pumps. Frequent
& Trips
testing as per PMS.
Yes Yes Yes Yes No No High Level Alarm provided with

adequate Redundancy due to Adequate redundancy with two
Cargo Tanks High & High-High Release of crude oil, oil spill,
5.4 II Yes independent High-High Level Yes High High E M alarm units. Regular checks as per
Level Alarm System pollution.
Alarms. PMS.
Critical: High-High Level Alarm
Yes
Conceriing hazard of Hull structral

Hull Structural damage (if does not damage, there is redundancy from
CRITICAL SPARES
open at specified pressure) , PV breaker and also installed
Uncontrolled HC gases leakage if pressure sensors.
5.5.1 Cargo Tanks PV Valves II Yes Yes High High E M Frequent checks as per PMS One spare PV valve ( The same PV Valve is fitted to the vent piping of the WB Tanks when these are
damaged or open at different There is no redundancy if a P/V
inerted)
settings valve is damaged or opens at
One PV valve Tester
different (lower span) setting than
designed.
Cargo tanks Secondary No - Adequate Redundancy, Adequate redundancy with PV

Hull Structural damage MIMIMUM SPARES
5.5.2 Overpressure/Underpressure II Yes P/V Valve (being primary means of No High High E M Braker and PV valves.
One cargo tank pressure sensor,
Protection Arr't protection) Frequent checks as per PMS
No No No Yes No No

Oil Discharge Monitoring Furthermore considering the test/inspection during Company CRITICAL SPARES
Oil spill, Pollution, off-hire
5.6 Equipment (ODME) II Yes Environmental impact component Yes High Medium E M Representative Attendance & ODME spare parts inventory one (1) set printer paper, ink ribbon (1), projector (Halogen Lamp), wiper for
Cargo (oil tankers) categorized also as inventory of spare parts to be cleaner (cleaning ring) and measuring tube.
Yes
CRITICAL SPARES
IGS spare one set of ; oxygen analyzer (Complete), oxygen analyzer sensor , main burner and ignition
burner nozzles, ignition glow plug, photocell, ignition transformer, solenoid valve for each type and
diaphragm for Oil Control Valve.
CRITICAL SPARES for SMIT IGG type

Solenoid valve , One (1) piece each for
IGS components are provied with Regular checks as per PMS, a) OEM TOTAL CARE KIT 1 x set, b) Main burner fuel valve, c) Pilot burner fuel valve , d) Ignition air
Oxygen level too high, explosive redundancy. test/inspection during Company system control valve
5.7 Inert Gas System atmosphere, off-hire II Yes Items Critical: Yes High Medium E M Representative Attendance & Local control room panel PLC (1) pc (only for vessels without flue gas)
1. Oxygen Analyzer inventory of spare parts to be
2. IGS Safety Devices & Alarms retained onboard: CRITICAL SPARES FOR HAMWORTHY MOSS IGG Type
DI Sub Module X 40 , one piece
CRITICAL SPARES FOR KANGRIM IGS

Main control panel power supply (1) pc
CRITICAL SPARES for IG Fans

1 set of bearings for electric motor, bearings of IG Fan shaft as applicable and 1 set of carbon seals,
sufficient to overhaul one IG Fan onboard.
Yes
Yes: Pump rooms equipped with

two P/R Fans . In case one P/R fan Regular checks as per PMS,
Oxygen level too high, explosive
only , the system does not have test/inspection . Availability of MINIMUM SPARES
5.8 Cargo pump room atmosphere, off-hire II Yes NO High Medium E M
redundancy , but access to space sparezs in case vesel equipped with Vessels with one P/R fan to have below spares :
can be restricted only when P/R fan one P/R fan. One pump room fan impeller and One electric motor .
is normal working

Oil spill, Pollution, off-hire, cargo No: Redundancy exists, emergency test/inspection during Company
MINIMUM SPARES
5.9 Cargo Valves contamination II Yes stop of cargo pumps can be NO High High E M Representative Attendance &
Cargo valves: Seat rings, one (1) pc for each size
activated inventory of spare parts to be
Cargo Tanks suction valves: Seat rings, two (2) pcs for each size (main suction & stripping suction)
retained onboard:
Page 9 of 11

No: Redundancy exists, emergency test/inspection during Company
5.10 Cargo Lines II Yes stop of cargo pumps can be NO High High E M Representative Attendance & MINIMUM SPARES
activated inventory of spare parts to be Dresser couplings: Gaskets, three (3) sets for each size
retained onboard:
Page 10 of 11
6 Cargo Equipment (LPG Tankers)

6.1 Cargo Pumps Off-hire III Yes No High High E L
Cargo Pumps 1 x coupling (motor-pump)
Although redundancy exists

(multiple stop buttons), the
Cargo Leakage, fire/explosion CRITICAL SPARES
6.2.1 Emergency Stop of Cargo Pumps II Yes potential consequence of failure to yes High High E M Frequent checks as per PMS
hazard Onecargo pump emergency stop button/ vessel
of emergency is considered high.
Although inherent redundancy

Frequent checks as per PMS.
exists (multiple ways to activate
Emergency shut down system Damage to cargo system Verificatio nthat system is
6.2.2 I Yes system), the potential consequence yes High High E M
(ESD) components, Cargo leaks, fire operational as epr Pre-arrival
of system's complete failure in case
checklist
In case of failure of the COP trips a

pump can fail and be damaged.
However in caseof the LPGs there Adequate Redundancy with
6.3 Fire hazard II Yes is redundacny due to ther common no High High E M multiple Cargo Pumps. Frequent
& Trips
bulkhead valve which allows use of testing as per PMS.
the second pump for cargo
operation.

High Level Alarm provided with
Cargo Tanks High & High-High Cargo Leakage, fire/explosion
Level Alarm System hazard
Alarms. PMS.
Adequate redundancy with two

Damage to Cargo Tank Structure,
No - Adequate Redundancy, two relief valves per Cargo Tank. Cargo
6.5 Cargo Tanks Relief Valves Cargo Leakage, fire/explosion II Yes No High High E M
valves per cargo tank. Tanks Relief Valves calibrated
hazard
every D/D.
Difficult to keep pressure (or
cooling in case of reliquifaction
No - Adequate Redundancy with
6.6 Cargo Compressors plant) on Cargo Tanks. Cargo loss III Yes No High High E L
multiple compressors.
due to opening of Tanks relief
valves.
No - Shore supply in case system

6.7 Inert Gas System - N2 Generator Minor Off-hire IV No No Medium Medium E L
out of order.
7 VARIOUS EQUIPMENT
MINIMUM SPARES
No - In case of failure, shore means Hose handling crane wire (1 pc),
7.1 Hose handling crane Off-hire III Yes (permanent crane or floating crane) No High High E L One set of hydraulic hoses ( flexible )
can be used One manipulator (main control/operating valve block , Applicable to vessels 15Year and older which are
fitted with single HHC.
No- Adequate Redundancy (2 sets MINIMUM SPARES

7.2 Accommodation ladders Loss of life I Yes No High High E M Regular checks as per PMS
of Accommodation ladders) Accommodaiton ladder wire (1 pc)
No - In case of failure, the second

MINIMUM SPARE
7.3 Provision crane Difficult to receive stores/spares V Yes Provision crane or HHC could be No Medium Medium E L
Provision crane wire (1 pc)
used
Daily fresh water production &

No : Fresh water stock is MINIMUM SPARES
retained onboard sounding and
7.4 Fresh water generator Insuffient water onboard V Yes monitored and in case necessary No Medium Medium E L One impeller & one mechanical seal for distillate pump / vessel
calculation.
shore sypply is arranged One overhaul kit for ejector pump / vessel
Insufficient heating of
Accommodation spaces for Ice
MINIMUM SPARES:
HVAC with single Fan/Motor Class Vessel, not provided with Yes - In case Vessel is trading
7.5 IV Yes No Medium Medium C M Regular checks as per PMS Complete AHU Fan
and Steam Heater fixed electric heaters in at sub-zero temperature area
Electric motor for AHU Fan
Cabins/Public spaces of
Accommodation NO
Page 11 of 11
MINIMUM SYSTEMS CRITICALITY & RISK

OIL & LPG TANKERS RISK ASSESSMENT MSC.1/Circ.1389
Inventory Of Minimum Spare Parts based on TMSA 3 requirments :
Criticality of equipment
Software dependant
Consequnece of failure
LIKELIHOOD
Upgrade to
ESSENTIAL
SEVERITY
CRITICAL
Risk Based equipment categorisation
Required Available latest released
RISK
Is sudden loss of a single system Equipment. Machinery and system redundancy
Ref Systems Potential Hazardous effects System system Measures For Mitigating Risks Performance standard software that
functionality a potential hazard? Experience of the equipment and machinery
Reliability reliability solves a known
Manufacturers' recommendations
bug
Vessel's trade
Lead time for spares delivery
Parts working quantities for each equipment
1 Navigation & Communication Equipment

Yes Yes Yes Yes Yes Yes Yes - According to SOLAS ,
vessels should be equipped with an
X-band Radar (9GHz) ,able to Regular checks according to PMS, CRITICAL SPARES Yes (due to
Potential collision/No possibility of Resolution MSC.192
1.1 X-band Radar & ARPA I Yes determine and display the range and Yes High High E M and spare parts inventory to be Spare Magnetron for X-Band Radar - One Set. Yes criticality
assistance in rescue operations (79) Adopted on 6
bearing of SART. The S-band retained. Carbo brushes (applicable to Furruno X band) assessment)
December 2004
radar (3GHz) does not provide
SART display
Yes (due to
No- X-band radar provides Resolution MSC.192
1.1a S-band Radar Potential collision I Yes NO High High E M Regular checks according to PMS Yes criticality
adequate redundancy (79) Adopted on 6
December 2004
assessment)

Yes (if during
annual
Magnetic Compass and second Performance Standard:
overhauling
Gyro is considered sufficient Resolution A.424 (XI)
Affecting Sea Worthiness, No - Adequate redundancy with this is
1.2 Gyro Compass II Yes No High High E M redundancy. Frequent inspections Yes Adopted on 15
Operational delay Magnetic Compass. considered
as per PMS & Annual Service by November 1979
Agenda item 10 (b) necessary by
Service Engineer.
the
technician)

Potential collision with small No - Adequate redundancy with
1.3 Ship's Whistle III Yes No High High E L No
vessels/boats two units & independent fog/bell.

Regular checks as per PMS.
1.4 Navigation lights Potential Collision I Yes No - Duplication of lights No High High E M Inspection during company No
representative attendance.

Performance Standard
Regular checks as per PMS. Resolution MSC. 74 Yes (due to
Potential grounding at shallow
1.5 Echo sounder II Yes Yes - No system redundancy. Yes High High D M Nautical Charts continuously Yes (69) Adopted of new criticality
waters
updated. and amended assessment)
perforamnce standards

Potential collision with small No - Other means for warning MINIMUM SPARES
1.6 Aldis III Yes No High High E L No
vessels/boats (ship's whistle) (3) pcs spare lamps

FBB
1.7 Communication Equipment Minor off-hire. IV No No No High High D L
Yes
Yes (If found

Performance
No - Adequate redundancy with Regular checks as per PMS, necessary
Standards: A.525(13),
1.8 GMDSS No means to raise distress call. II Yes Satellite communication systems No High High E M Annual check/service by Radio Yes during the
A.694(17), A.808(19),
(Inmarsat & Fleet Broad-band) Technician. annual radio
MSC68(68),A.807(19)
survey)

GMDSS not operational during Regular checks as per PMS,
No - Adequate redundancy with
1.9 Emergency Batteries Black-out, no means to raise II Yes No High High E M inspected/checked by company No
Emergency Generator
distress call. representative during attendance.

No (due to
Deviation in system, Operational
1.10 Autopilot IV No No No High High D L Yes Resolution A.342(IX) criticality
Delay
assessment)
No (due to
1. Position fixing by alternative
Performance Standard: redundancy
means (visual observations - radar)
Resolution by
Inadequacy of electronic position 2. GPS automatic integrity check
GPS I Yes No- Adequate redundancy No High High E M Yes MSC.112(73) Adopted navigational
fxing means on ECDIS 3. GPS failure drill 4.
on 1 December 2000 equipment
RIO 5. Magnetic compass 6. Self (on or after 01.07.2003) not software
Test function
dependant )
Page 1 of 11
Resolution
MSC.333(90) Adopted
on 22 May 2012
No (due to
Insufficient detail to restore a (installed after
VDR V Yes No No High High C L Annual Performance test Yes criticality
complete record of the voyage 01.07.2014) -
Resolution MSC. 214
assessment)
(81) Adopted on 12
May 2006 (installed
before 1.07.2014)
Inadequate information provided to Resolution MSC.
No AIS provides supplementary No (due to
appropriately equipped (AIS) shore 74(69) Adopted on 12
AIS V Yes information, AIS not used for No High High C L Annual Performance Test Yes criticality
stations. Indaqueacy of situational May 1998 Resolution
collision avoidance purposes assessment)
awareness. A.694 (17) Adopted on
6 November 1991
No (due to
No speed indictaion and distance Resolution MSC. 96
Speedlog III Yes Speed can be obtained from GPS No High High E L Yes criticality
through the water (72) Adopted on 22
May 200
assessment)
Lack of determination and display
Resolution A.694 (17)
Magnetic Compass of the vessel's heading independent III Yes No No High High E L No
Adopted on 6
of any power supply
November 1991
No (due to
No- Weather information can be
Weather facsimile Lack of weather information III Yes No High High E L Yes criticality
obatined by alternative means
assessment)
Provided with a facility to to test

that the radio receiver, the display Resolution MSC.148 No (due to
Lack of navigational warnings Yes- unavailability of navigational ,
NAVTEX III Yes No High High E L device/printer and non-volatile Yes (77) Adopted on 3 June criticality
information meteorological information
message memory are functioning 2003 assessment)
correctly.
Not based on Risk Assessment due

to back-up system availability at all Performance Standard
Back-up system provided with Yes (due to
Potential grounding at shallow times. It is made Crtitical by default CRITICAL SPARES Resolution
1.11 ECDIS II Yes Yes High High E M either a back-up ECDIS or papart Yes criticality
waters due to Australian Port State One SPARE SCREEN MSC.232(82) Adopted
charts. assessment)
Authorities requirements, and due on 5 December 2006
to newly implied system.
Inability to provide prompt

notifications/announcements to all
crew (i.e. Security breach , Safety
1.12 Public addressor II YES Yes - No system redundancy. Yes High High E M PMS : Weekly check of the system
hazard idenitified, Fire on non
detected areas , Emergency
evaluation etc.)
Even though as per SOLAS

Inabilitiy of on-scene requirements each vessel (above
communication between survival 500gt) must have 3 x VHF and PMS : Inspections as per SOLAS
1.13 VHF of GMDSS II YES Yes High High E M
craft and ship and between survival spare batteries , the equipment is are included in the PMS
craft and rescue unit considered critical due to impact in
case of failure
Page 2 of 11
2 Safety equipment
Lose time in ship staff reaction in System frequent test as per
2.1 General Alarm System case of Emergency. Can result in I Yes Yes - No system redundancy. Yes High High E M company PMS & test during
fatality company representative attendance.

Losing time in case of rescue. Can
No - Adequate redundency with Frequent test onboard (PMS).
2.2 EPIRB cause fatality in case of Ship I Yes No High High E M
SART and GMDSS Distress. Annual check by Radio Technician.
Abandon

Yes - for rescue operation CRITICAL SPARES
(Lifeboats critical) Annual Service, frequent Lifeboat Engine spare Fuel Oil & Lub Oil Filters elements 2 pieces each.
Fatality in case of ship abandon. No
2.3 Life boats & Life Rafts I Yes No - for ship abandon since Full Yes High High E M inspections as per PMS & inventory
Possibility for rescue operation.
redundancy between lifeboats & of Spare Parts MINIMUM SPARES
liferafts. Lifeboat wire (1 pc)

Personnel injury in case of Black-
2.4 Emergency Lights II Yes No - Fully redundant system No High High E M Regular checks according to PMS
Out

Mustering equipment No - Adequate Redundancy with
(walkie talkie/VHF) multiple portable radios

No - Other means for towing are
2.6 Emergency towing Systems Off-hire III Yes No High High E L
possible

General safety equipment No - Adequate Redundancy of
(Lifejackets, TPA, etc.) Lifesaving Equipment onboard.

No - Adequate Redundancy with Regular checks as per PMS &
2.8 Portable measuring instruments loss of life I Yes multiple Portable Measuring No High High E M test/inspection during Company
Instruments Representative Attendance.
Yes. Ability to charge BA cylinders

Breathing apparatus not ready for
is lost.
use. Regular checks as per PMS &
Vessel's compliance with regulatory CRITICAL SPARES
2.9 Breathing Air compressor Loss of ability to mobilize fire I Yes YES High High E M test/inspection during Company
requirements SOLAS will be One set of Air filter and Hoses/fittings
fighting team for extingushing fire. Representative Attendance.
affected.
Loss of life
Page 3 of 11
3 Fire Fighting Equipment

No back-up in case of emergency, CRITICAL SPARES
3.1 Emergency Fire Pump I Yes Yes Yes High High E M Representative Attendance &
no control of fire. Emergency Fire Pump Spare mechanical seal. Mouth Ring & Bearings
Inventory of Spare Parts to be
retained:
In case of Fire Detection system MINIMUM SPARES
3.2 Fire detection & alarm system Delay in Fire Fighting reaction II Yes Yes Yes High High E M failure, the Engine Room is One piece of each type of smoke/heat/flame sensor.
operated under manned mode. One manual call point
Yes Yes Yes Yes No No CRITICAL SPARES

1x sesnor each type
No possibility to detect Cargo Regular checks as per PMS &
MINIMUM SPARES
3.3 Gas Detection System Leakage into Ballast Tanks or into I Yes Yes Yes High High E M inspection/check during company
3 xMEMBRANE for PUMPS of Salvico system
P/R - Pollution & Fire Hazards representative attendance.
Applicable vessels as per MOC No 30/2017
1 xMEMBRANE for each PUMP type

No possibility to extinguish an Regular checks as per PMS &
Fixed fire extinguishing system
3.4 extensive fire with the system. No I Yes Yes Yes High High E M annual service by WSS or other
(E/R)
control of Fire authorized Service Company.

Fixed fire extinguishing system No possibility to extinguish an Regular checks as per PMS &
3.5 (Deck, P/R, Cargo Compressor extensive fire with the system. No I Yes Yes Yes High High E M test/inspection during Company
Room, other) control of Fire Representative Attendance.

No - Adequate means to stop
Difficulty to extinguish fire due to Regular checks as per PMS &
Remote Shut-Down Devices supply of fuel/lub oil by quick
3.6 continuous supply of fuel/lub oil II Yes No High High E M test/inspection during Company
(ventilation & pumps) closing valves and supply of air by
and air flow. Representative Attendance.
fire dampers
No possibility to isolate FO & LO test/inspection during Company
Yes (Flow of fuel will continue by CRITICAL SPARES
3.7 Quick-Closing Valves Tanks in case of Fire. II Yes Yes High High D M Representative Attendance &
gravity in case of leakage) Quick Closing Valves O-Rings (One Set) for each kind of piston.
retained onboard:
Ventilation Fire dampers and funnel No possibility to isolate air during CRITICAL SPARES
3.8 II Yes Yes Yes High High D M Representative Attendance &
dampers Fire Ventilation Fire Dampers actuators one (1) set of spare seals
retained onboard:
Local Fire Fighting (Water Mist) MINIMUM SPARES
3.9 Delay in Fire Fighting reaction II Yes Yes Yes High High D M Representative Attendance &
System One piece of each type of smoke/heat/flame sensor.
retained onboard:
Page 4 of 11
4 Machinery Equipment
CRITICAL SPARES
M/E is provided with self
M/E T/C spare Bearings & Labyrinth (one set).
redundancy. Defective units can be
isolated. If Alarms not working, Regular checks as per PMS &
MINIMUM SPARES
E/R will be operated under manned test/inspection during Company
M/E Spares to cover the complete O/H of one Cylinder Unit (including Piston, Cover, Cooling jackets ,
Loss of propulsion, collision in conditions. In case Maneuvering Representative Attendance. M/E
Main Engine, including Alarms & Starting air valve , Fuel valves , High pressure pipe, Fuel Pump,Exhuast valve , Bearings). M/E jacket
maneuvering,, off-hire, injury due system failure, Engine operated Maneuvering System inspection by
4.1 Emergency Shut-Downs & Oil Mist II Yes Yes High High D M cooling Compensator.
to crankcase explosion. from Emergency Stand. Service Engineer during D/D. M/E
Detector When ME is equipped with Alpha Cylinder Lubrication system , vessel to have spare two pcs of rpm pick-
Item considered Critical: T/C Spare Parts inventory to be
up sensors, (2) pcs inductive sensors & (2) pcs solenoid valves.
1. Oil Mist Detector. retained onboard:
One spare ME Aux blower Electric Motor .
2. Em. Maneuvering Stand
One piece exhaust gas temperatrure sensor
3. M/E Safety Shutdowns
One local temperature gauge
4. M/E Turbocharger
One Piston Cooling Non-Flow Sensor
MINIMUM SPARES
D/G Spares : Two (2) pistons with piston irngs and scrapper rings, one (1) cylinder cover complete , one
cylinder liner, one Fuel oil injection pump , one set of T/C bearings , one set T/C labyrinth, one T/C nozzle
Main Diesel Generators Alarms & Engine Damage, black out. No - Adequate redundancy ring, FO high pressure pipes fro two cylinders , fuel valves complete for three (3) cylinder units, inlet
Emergency Shut Downs onboard valves for 2 cylinder units, exhaust valves for four (4) cylinder units, Main/Crankpin/Conn rod bearing
one piece each , Connecting rod bolts for one cylinder.
retained onboard:
Automatic Voltage regulator 1pc/Vessel (9/4/2017)

MINIMUM SPARES
Boiler spares one set; Main burner & Ignition Burner nozzles.
For vessels fitted with 2 Oil fired Boilers, one set of force draft fan electric motor bearings.
For vessels fitted with 1 OIl fired boiler Boiler, one Complete Electric Motor for forced draft fan.
For vessels fitted with 1 Oil fired boiler with rotary cup burner (Spottail, Bowfin, Flagship Lotus,
Starman Avanti) one (1) set of bearings.
1x Mechanical seal for the economizer feed or circulating pump (as applicable)
Smoke density sensor 1/vessel
1x Mechanical seal (or gland packing) for auxiliary boiler feed water pump
MINIMUM SPARES (In case of AALBORG Boilers only)
1) D/P air flow transmitter (1 / vessel)

2) Unisab (1 / vessel)
No - Adequate redundancy 3) Control panel parts
boiler explosion, onboard with two Boilers. If one a) Timer for Control Panel, 1pc
II Yes No High High E M Representative Attendance &
no heating,, off hire Boiler Unit, Generators are run on b) PR Sockets, 2pcs
Diesel. c) PR Springs, 2pcs
retained onboard:
Boilers including safety devices and 4) Oil Flow Parts
4.3 trips including safety valves and a) Pick Up Sensor, 1pc
automation b) Set of bearings, 1pc
c) Set of O rings, 1pc
5) Flame Surveillance Parts
a) Photo cell for Main Burner, 2pcs
b) Photo cell for Ignition Burner, 1pc
c) Flame relay for Main burner, 1pc
6) Burner / Ignition burner Parts
a) Set of ignition electrodes for ignition burner, 1pc
b) O-rings for main nozzle, 10pcs
c) CU Washer for main nozzle, 10pcs
d) Read contact for igniter in position signal, 1pc
e) Solenoid valve, for Ignition burner, 1pc
f) Spark plug cover for ignition burner, 2pcs
7) Pneumatic control Parts
a) Filter regulator, 1pc
b) Vent valve, 1pc
c) Positional for air damper, 1pc
8)Burner main shaft ball bearings (2) pcs (Applicable only for Aalborg Mission OM35)
black out, no possibility of CRITICAL SPARES
4.4 Emergency generator II Yes Yes Yes High High D M Representative Attendance &
recovery. Emergency Diesel Generator one (1) spare set of Fuel Oil & Lub Oil Filters elements.
retained onboard:
Yes Yes Yes Yes Yes Yes MINIMUM SPARES
FO Purifier one complete set of O-rings
No - Adequate system redundancy Ball bearings (for both shafts) of one 1 HFO purifier .
Fuel oil system & Pumps, with stand-by start pumps. In case FO Purifier Friction Clutch (1) complete set
4.5 Sea worthiness, vessel's stop/delay III Yes No High High D M Representative Attendance &
including safety devices of Alarms failure, E/R operated One mechanical seal for each type (HFO/MGO) ME FO Circulating pump
under manned condition. One mechanical seal for each type (HFO/MGO) ME FO supply pump
retained onboard:
One mechanical seal for each type (HFO/MGO) AE FO Circulating pump
One mechanical seal for each type (HFO/MGO) AE FO supply pump
Page 5 of 11
Regular checks as per PMS, MINIMUM SPARES

test/inspection during Company LO Purifier one complete set of O-rings
with stand-by start pumps. In case
4.6 Lub Oil system & Pumps Sea worthiness, vessel's stop/delay III Yes No High High D M Representative Attendance & Ball bearings (for both shafts) of one 1 LO purifier.
of Alarms failure, E/R operated
inventory of spare parts to be LO Purifier Friction Clutch (1) complete set
retained onboard: 3 PCS filter elements for M/E LO Auto filter & Servo oil filter (for electronic engines only)

S.W. & F.W. Cooling Systems & no cooling , no propulsion and with stand-by start pumps. In case MINIMUM SPARES
Pumps black out, vessel's stop/delay. of Alarms failure, E/R operated Main Cooling S.W. Pumps Mechanical Seal and mouth ring.
retained onboard:
No - Adequate system redundancy test/inspection during Company
No propulsion, losing time to start MINIMUM SPARES
4.8 Compressed air MAIN system III Yes with multiple air compressors and No High High D M Representative Attendance &
in emergency situation. Main Air Compressors one set spare suction and discharge valves.
receivers. inventory of spare parts to be
retained onboard:
Emergency Air Compressor failure
is not a hazard as long as Receiver
Regular checks as per PMS CRITICAL SPARES
Unavailability of air to supply remains charged.
Inpsection during office 1x Electric motor for the Emcy compressor |(in case of Electric driven and provided the emrgency
4.9 Emergency Air compressor starting air to vessel's Diesel III Yes However taking into account the YES High High D M
representative attendance. compressor is not one of the main air compressors)
Generators after a black out. risk that receiver is empty due to
Critical spare parts 1 x set of fuel oil filters in case of Diesel Driven emergency air compressors
human error the equipment is
considered critical
Page 6 of 11

CRITICAL SPARES
Even though there is available Adequate redundancy built-in the
One (1) Hydraulic pump filter / Vessel.
redundancy (2 x pumps), the system. Regular checks as per
4.10 Steering gear collision II Yes YES High High E M
impact of a potential failure is high PMS.
For vessels fitted with HATLAPA Steering Gear one (1) hydraulic pump complete (Sauger, Flagship Ivy,
thus rendering equipment critical.
Flagship Violet).
MINIMUM SPARES
Spare : One set of Brake band for Windlass and
Two set of Brake band for Winches to be onboard .
No - adequate redundancy with two
4.11 Windlasses & Mooring Winches Off-hire III Yes No High High E L One spare Hydraulic motor for Windlass.
units
Two spare mooring wires ,
Two spare mooring tails.
O-ring kit for main control valve (1) set for windlass & (1) set for mooring winch
No - E/R operated under manned

Machinery failure, tanks
4.12 Alarm & Monitoring System III Yes conditions in case of Alarm No Medium High E L
overflow/pollution.
Monitoring System failure.

E/R Bilge System & Associated Pumping system fully redundant.
4.13 Potential flooding. II Yes Yes High High E M test/inspection during Company
Alarms Critical: Bilge Level Alarms
Yes Yes Yes Yes Yes Yes Yes (No redundancy to discharge
Bilge water from E/R).
test/inspection during Company CRITICAL SPARES
0il / water separator and measuring pollution if valve not closing, off- Furthermore considering the
4.14 II Yes Yes High High D M Representative Attendance & Oily Water Separator Spare one set Solenoid Coil for 3-Way Valve & Spare Filter.
system (15PPM) hire potential & legal implications Environmental impact component
inventory of spare parts to be 5 pcs Membrane Cartridge (applicable only for Sasakura SMT-5A)
categorized also as
retained onboard:
CRITICAL SPARES
Yes, due to lack of redundancy. Regular checks as per PMS,
W.O. Incinerator spare one (1) set temperature controller for primary chamber, (1) set temperature
Furthermore considering the test/inspection during Company
controller for secondary chamber, Thermocouples for cobustion/flue gas (1) pc each Electrode units for
4.15 Incinerator Oil retention onboard. III Yes Environmental impact component Yes High High C M Representative Attendance &
Primary / Seconday Burners and Flame Detector (1).
categorized also as inventory of spare parts to be
2 bags of 25kg each (plibrico or fire clay)
Flue Gas Fan V-Belt (1) (applicable only for Teamtec OG(S) 400)
Yes, due to lack of redundancy.

Furthermore considering the Regular checks as per PMS, CRITICAL SPARES (& ENVIRONMENTAL SPARES):
4.16 Sewage System Pollution if not treating properly III Yes Environmental impact component Yes High High D L test/inspection during Company Vessels equipped with one Air blower to have
categorized also as Representative Attendance 1 x Air blower (including motor) complete

personnel injury, damaged No - E/R Crane not operated if not MINIMUM SPARES
4.17 ER Crane II Yes No Medium Medium E M test/inspection during Company
equipment in good condition Crane wire (1 pc)

No - adequate redundancy of Main Main Switchboard safety devices &
no propulsion, black out,
4.18 Switch boards II Yes Switchboard for MINIMUM No High High E M redundancy. Regular checks as per
electrocution
Motors PMS.
PMS :
1)Concerning shafting the stern
tube oil is analysed on 6m basis.
2)Stern tube bearing is equipped
Yes. In case of either
with a temperature alarm.
Rudder.Shafting or Propeller loss
3) Concering rudder, testing as per
the vessel will be rendered non self
pms of steering gear system.
propelling and external assistance
4.19 Propeller, Shafting ,rudder Loss of maneuverability. II Yes YES High High E M During preiodical underwater
(i.e Tugs Escorting ) will have ot be
isnpections, rudder structural
mobilized for vessel assistance and
condition is confirmed.
reposition to safe location for
repairs.
Propeller : On yearyl basis propeller
inspection andcleaning is conducted
as per PMS.
Page 7 of 11
Yes Yes Yes Yes Yes Yes CRITICAL SPARES (& ENVIRONMENTAL SPARES) :
1. Purimar (electrolysis): Vessels equipped with Purimar Ballast water treatment system to be equipped
with 1 x TRO sensor
Vessels with Erma First BWTS using electrolytic cell, to also be equipped with the following:
- CENTRIFUGAL PUMP 84M3/H 20M 440V/ 60Hz
- T-STRAINER
- REPLACEMENT TUBING/ CUVETTE KIT NON-EX
- Flow Through Cuvette
- CHECK VALVE REPLACEMENT KIT
- T STRAINER SCREEN
- T STRAINER/ PRESSURE REGULATOR ASSEMBLY
- FLOW SWITCH DIGITAL 24V
- PRESSURE TRANSMITTER 0-10bar
- TEMPERATURE SENSOR 0-100C
- SOLENOID 5/2 1/4" NAMUR ALUM 24 VDC EMBEDED COIL/CONNECTOR
pollution if system is not properly Ballast with zones as defined in the
Regular checks as per PMS & - SOLENOID VALVE 2/2 NC DN6 THREADED EMBEDED COIL 24V DC
BALLAST WATER functioning. Inability or prohibition BWM Convention ) Furthermore
4.20 III Yes YES High Medium D M test/inspection during Company - SOLENOID VALVE CONNECTOR WITH LED 24V DC
TREATMENT SYSTEM to carry ot cargo operations, off- considering the Environmental
Representative Attendance. - SOLENOID 5/2 1/4" NAMUR ALUM 24 VDC EMBEDED COIL/CONNECTOR
hire potential & legal implications impact component categorized
- MECHANICAL SEAL FOR CENTIFUGAL PUMP
- PNEUMATIC DIAPHRAGM PUMP 8LT/MIN 3,5BAR
- FUSE &- CYLINDRICAL FUSE 2A 10X38MM
2. Pureballast (UV): Vessels equipped with PureBallast Ballast water treatment system to be equipped with
MINIMUM SPARES:
1x CIP liquid (Spare part)
1x Filter maintenance kit
1x CIP pump spare part set
CRITICAL SPARES:
1x Lamp power supply
1x Quartz sleeve set
1x UV lamp set
1x UV sensor
1x Temperature switch
No likelihood of rudder loss due to

4.21 Rudder Loss of maneuverability. III Yes No High High E L
system malfunction.

Maker recommedned PMS
Ballast with zones as defined in the
Exhasut Gas Cleaning Scrubber pollution to the atmoshere with requirements to be implemented
BWM Convention ) Furthermore Critical spares will be assessed based on maker requirements and company assessemnt and will be
4.22 System (To be installed on first excess Sulphur than allowed if III Yes YES High Medium D M prior system is put in service.
considering the Environmental developed prior system is put into service.
fleet vessel by end of April-2020) system is not properly functioning. System to be inspected by attending
impact component categorized
Technical Superintendents.

No - Adequate system redundancy test/inspection during Company MINIMUM SPARES
4.23 Main Engine LO Auto Filter Sea worthiness, vessel's stop/delay III Yes with manual by pass filter. E/R No High High D M Representative Attendance & ME LO Auto Filter 3 filter elements (cartridges).
operated under manned condition. inventory of spare parts to be
retained onboard:
Page 8 of 11
5 Cargo Equipment (Oil Tankers)

5.1 Cargo pumps and stripping pumps Off-hire III Yes Cargo Pumps & Portable Pump for No High High E L 1 x set of Mehcanical seals for CARGO PUMP
the case of Framo. EFC governor for hydraulic powerpack diesel engine (FRAMO Vessels)
Yes Yes Yes Yes No No Although redundancy exists

Release of crude oil, oil spill, (multiple stop buttons), the
CRITICAL SPARES
5.2 Emergency Stop of Cargo Pumps pollution . II Yes potential consequence of failure to YES High High E M Frequent checks as per PMS
One cargo pump emergency stop button/ vessel
ofemergency is considered high.
Adequate Redundancy with
5.3 Fire hazard II Yes No - Multiple Cargo Pumps. No High High E M multiple Cargo Pumps. Frequent
& Trips
testing as per PMS.
Yes Yes Yes Yes No No High Level Alarm provided with

Cargo Tanks High & High-High Release of crude oil, oil spill,
Level Alarm System pollution.
Alarms. PMS.
Yes
Conceriing hazard of Hull structral

Hull Structural damage (if does not damage, there is redundancy from
CRITICAL SPARES
open at specified pressure) , PV breaker and also installed
Uncontrolled HC gases leakage if pressure sensors.
5.5.1 Cargo Tanks PV Valves II Yes Yes High High E M Frequent checks as per PMS One spare PV valve ( The same PV Valve is fitted to the vent piping of the WB Tanks when these are
damaged or open at different There is no redundancy if a P/V
inerted)
settings valve is damaged or opens at
One PV valve Tester
different (lower span) setting than
designed.
Cargo tanks Secondary No - Adequate Redundancy, Adequate redundancy with PV

Hull Structural damage MIMIMUM SPARES
5.5.2 Overpressure/Underpressure II Yes P/V Valve (being primary means of No High High E M Braker and PV valves.
One cargo tank pressure sensor,
Protection Arr't protection) Frequent checks as per PMS
No No No Yes No No

Oil Discharge Monitoring Furthermore considering the test/inspection during Company CRITICAL SPARES
5.6 Equipment (ODME) II Yes Environmental impact component Yes High Medium E M Representative Attendance & ODME spare parts inventory one (1) set printer paper, ink ribbon (1), projector (Halogen Lamp), wiper for
Cargo (oil tankers) categorized also as inventory of spare parts to be cleaner (cleaning ring) and measuring tube.
Yes
CRITICAL SPARES
IGS spare one set of ; oxygen analyzer (Complete), oxygen analyzer sensor , main burner and ignition
burner nozzles, ignition glow plug, photocell, ignition transformer, solenoid valve for each type and
diaphragm for Oil Control Valve.
CRITICAL SPARES for SMIT IGG type

Solenoid valve , One (1) piece each for
IGS components are provied with Regular checks as per PMS, a) OEM TOTAL CARE KIT 1 x set, b) Main burner fuel valve, c) Pilot burner fuel valve , d) Ignition air
Oxygen level too high, explosive redundancy. test/inspection during Company system control valve
5.7 Inert Gas System atmosphere, off-hire II Yes Items Critical: Yes High Medium E M Representative Attendance & Local control room panel PLC (1) pc (only for vessels without flue gas)
1. Oxygen Analyzer inventory of spare parts to be
2. IGS Safety Devices & Alarms retained onboard: CRITICAL SPARES FOR HAMWORTHY MOSS IGG Type
DI Sub Module X 40 , one piece
CRITICAL SPARES FOR KANGRIM IGS

Main control panel power supply (1) pc
CRITICAL SPARES for IG Fans

1 set of bearings for electric motor, bearings of IG Fan shaft as applicable and 1 set of carbon seals,
sufficient to overhaul one IG Fan onboard.
Yes
Yes: Pump rooms equipped with

two P/R Fans . In case one P/R fan Regular checks as per PMS,
Oxygen level too high, explosive
only , the system does not have test/inspection . Availability of MINIMUM SPARES
5.8 Cargo pump room atmosphere, off-hire II Yes NO High Medium E M
redundancy , but access to space sparezs in case vesel equipped with Vessels with one P/R fan to have below spares :
can be restricted only when P/R fan one P/R fan. One pump room fan impeller and One electric motor .
is normal working

Oil spill, Pollution, off-hire, cargo No: Redundancy exists, emergency test/inspection during Company
MINIMUM SPARES
5.9 Cargo Valves contamination II Yes stop of cargo pumps can be NO High High E M Representative Attendance &
Cargo valves: Seat rings, one (1) pc for each size
activated inventory of spare parts to be
Cargo Tanks suction valves: Seat rings, two (2) pcs for each size (main suction & stripping suction)
retained onboard:
Page 9 of 11

No: Redundancy exists, emergency test/inspection during Company
5.10 Cargo Lines II Yes stop of cargo pumps can be NO High High E M Representative Attendance & MINIMUM SPARES
activated inventory of spare parts to be Dresser couplings: Gaskets, three (3) sets for each size
retained onboard:
Page 10 of 11
6 Cargo Equipment (LPG Tankers)

6.1 Cargo Pumps Off-hire III Yes No High High E L
Cargo Pumps 1 x coupling (motor-pump)
Although redundancy exists

(multiple stop buttons), the
Cargo Leakage, fire/explosion CRITICAL SPARES
6.2.1 Emergency Stop of Cargo Pumps II Yes potential consequence of failure to yes High High E M Frequent checks as per PMS
hazard Onecargo pump emergency stop button/ vessel
Although inherent redundancy

Frequent checks as per PMS.
exists (multiple ways to activate
Emergency shut down system Damage to cargo system Verificatio nthat system is
6.2.2 I Yes system), the potential consequence yes High High E M
(ESD) components, Cargo leaks, fire operational as epr Pre-arrival
of system's complete failure in case
checklist
In case of failure of the COP trips a

pump can fail and be damaged.
However in caseof the LPGs there Adequate Redundancy with
6.3 Fire hazard II Yes is redundacny due to ther common no High High E M multiple Cargo Pumps. Frequent
& Trips
bulkhead valve which allows use of testing as per PMS.
the second pump for cargo
operation.

High Level Alarm provided with
Cargo Tanks High & High-High Cargo Leakage, fire/explosion
Level Alarm System hazard
Alarms. PMS.
Adequate redundancy with two

Damage to Cargo Tank Structure,
No - Adequate Redundancy, two relief valves per Cargo Tank. Cargo
6.5 Cargo Tanks Relief Valves Cargo Leakage, fire/explosion II Yes No High High E M
valves per cargo tank. Tanks Relief Valves calibrated
hazard
every D/D.
Difficult to keep pressure (or
cooling in case of reliquifaction
No - Adequate Redundancy with
6.6 Cargo Compressors plant) on Cargo Tanks. Cargo loss III Yes No High High E L
multiple compressors.
due to opening of Tanks relief
valves.
No - Shore supply in case system

6.7 Inert Gas System - N2 Generator Minor Off-hire IV No No Medium Medium E L
out of order.
7 VARIOUS EQUIPMENT
MINIMUM SPARES
No - In case of failure, shore means Hose handling crane wire (1 pc),
7.1 Hose handling crane Off-hire III Yes (permanent crane or floating crane) No High High E L One set of hydraulic hoses ( flexible )
can be used One manipulator (main control/operating valve block , Applicable to vessels 15Year and older which are
fitted with single HHC.
No- Adequate Redundancy (2 sets MINIMUM SPARES

7.2 Accommodation ladders Loss of life I Yes No High High E M Regular checks as per PMS
of Accommodation ladders) Accommodaiton ladder wire (1 pc)
No - In case of failure, the second

MINIMUM SPARE
7.3 Provision crane Difficult to receive stores/spares V Yes Provision crane or HHC could be No Medium Medium E L
Provision crane wire (1 pc)
used
Daily fresh water production &

No : Fresh water stock is MINIMUM SPARES
retained onboard sounding and
7.4 Fresh water generator Insuffient water onboard V Yes monitored and in case necessary No Medium Medium E L One impeller & one mechanical seal for distillate pump / vessel
calculation.
shore sypply is arranged One overhaul kit for ejector pump / vessel
Insufficient heating of
Accommodation spaces for Ice
MINIMUM SPARES:
HVAC with single Fan/Motor Class Vessel, not provided with Yes - In case Vessel is trading
7.5 IV Yes No Medium Medium C M Regular checks as per PMS Complete AHU Fan
and Steam Heater fixed electric heaters in at sub-zero temperature area
Electric motor for AHU Fan
Cabins/Public spaces of
Accommodation NO
Page 11 of 11
PRO 28‐ Annex D
Version:3
Issue Date :31/05/22
Rev. 08.2020 Company Hazard Register List 2020
L M H S L M H S L M H S L M H S
Potential Risk Potential Risk Technical Actual / Residual Actual / Residual
Threat Top Subsequent System Controls Reference Reg & Industry
ID Hazard Location
Consequences New Matrix Prime
(Company Procedures) in place
Controls in
Documents
Risk Risk Prime ALARP
P A E R P A E R place P A E R P A E R
Information Security
001‐IMSM Appendix Z4 ‐ Information Security Policy
001‐IMSM Appendix Y ‐ Computer Email & Internet Policy
002A‐ISMS Procedure 02A Asset Management
ICT Virus Exposure;
002A‐ISMS Procedure 05A Protection Against Malicious Code
ICT Tracker Exposure; OCIMF: The Guidelines on Cyber
Human Error*; Financial loss; ISMS‐PROC 05F_ICT Systems Lifecycle (Acquisition ‐ Termination)
Loss of control ICT Ransom Exposure; Security Onboard Ship;
A2‐1 Uncontrolled Exposure to Internet Both Ashore and Onborad IT Criminal act
Breakdown of ICT systems;
Damage of Company's B1 D2 B1 D2 E5 C4 E5 C4 002A‐ISMS Procedure 07A Network and Communications Security
ISO 27001; B1 B2 B1 B2 E5 E4 E5 E4 Yes
(Virus; Malware, etc); Reputation; 002A‐ISMS Procedure 05H Server Configuration Controls
Breakdown of Electronic ISO 27002;
004‐EMP ZZ‐Appendix A Business Continuity Plan
equipment;
ICT Virus Exposure; 001‐IMSM Appendix Z4 ‐ Information Security Policy
Human Error* 002A‐ISMS Procedure 06 Cryptographic Use
ICT Tracker Exposure; OCIMF: The Guidelines on Cyber
(Uncontrolled use for USB Financial loss; 002A‐ISMS Procedure 05D Portable Device Security
Uncontrolled Use of Portable and Loss of control ICT Ransom Exposure; Security Onboard Ship;
A2‐2 Removable Media
Both Ashore and Onborad Sticks on board for the purpose
Breakdown of ICT systems;
Damage of Company's B1 D3 B1 D1 E5 C3 E5 C5 002A‐ISMS Procedure 02B Physical Media Transfer ISO 27001; B1 B3 B1 B1 E5 E3 E5 E5 Yes
of Update systems or private Reputation;
Breakdown of Electronic ISO 27002;
use.)
equipment;
001‐IMSM Appendix Z‐4 ‐ Information Security Policy
Sensitive company information 001‐IMSM Appendix S ‐ Social Media Policy
Human Error* Injury;
released causing commercial 001‐IMSM Appendix Z‐1 ‐ Mobile Phone Use Policy OCIMF: The Guidelines on Cyber
(Uncontrolled use for Social Asset Damage;
Unauthorized data impact; Security Onboard Ship;
A2‐3 Uncontrolled Use of Social Media Both Ashore and Onborad Media on board and / or in the
disclosure Release of vessels position
Financial loss; D3 D3 B1 D3 C3 C3 E5 C3 001‐IMSM Appendix Y ‐Computer, E‐mail & Internet
001‐IMSM Appendix W ‐General Data Protection Policy ISO 27001; A3 A3 B1 A3 F3 F3 E5 F3 Yes
office); Damage of Company's
when transiting through piracy ISO 27002;
Social Engineering Reputation;
area causing Piracy Hazard
002A‐ISMS‐PROC 05F_ICT Systems Lifecycle (Acquisition ‐ Termination)
002A‐ISMS Procedure 02B Physical Media Transfer
002A‐ISMS Procedure 04 Access Management
002A‐ISMS Procedure 04B Password Security
Loss of control; Sensitive company information 002A‐ISMS Procedure 05B Technical Vulnerabilities and Patch Management OCIMF: The Guidelines on Cyber
Financial loss;
Attacking the Company/ Data Loss; stolen / released; Security Onboard Ship;
A2‐4 Information Security Crime Both Ashore and Onborad
Vessels ICT systems; Data Leak: Service Company/ Vessels ICT system
Damage of Company's B1 D3 B1 D3 E5 C3 E5 C3 002A‐ISMS Procedure 05D Portable Device Security
002A‐ISMS Procedure 07A Network and Communications Security ISO 27001; B1 B3 B1 B3 E5 E3 E5 E3 Yes
Reputation;
Unavailability; compromised; 002A‐ISMS Procedure 05A Protection Against Malicious Code ISO 27002;
002A‐ISMS Procedure 01 Physical and Environmental Security
Sensitive Company Information Ship Security Plan OCIMF: The Guidelines on Cyber
Infrastructre Damage;
Unauthorized Physical Access to Compromising ICT Physical Access stolen/ released; Company/ Security Onboard Ship;
A2‐5 Infrastructure/ Systems
Both Ashore and Onborad
infrastructure physical integrity; Violation; Vessels ICT infrastructure
Information Leak; B1 D3 B1 D3 E5 C3 E5 C3 002A‐ISMS Procedure 02B Physical Media Trasnfer
002A‐ISMS Procedure 03 Secure Disposal ISO 27001; B1 B3 B1 B3 E5 E3 E5 E3 Yes
Damage of Company's
compromise; 002A‐ISMS Procedure 05D Portable Device ISO 27002;
Reputation;
001‐IMSM Appendix Z‐5 Clear Desk and Clear Screen Policy
004‐EMP ZZ‐Appendix A Business Continuity Plan
004‐EMP Section 02 Office Emergency Procedure
Service unavailability; 002A‐ISMS Procedure 05I Backup OCIMF: The Guidelines on Cyber
Attacking the Company/ Financial loss;
Unable to Respond in Information Unable to bring back in Company/ Vessels Security Onboard Ship;
A2‐6 Security Emergency situations
Both Ashore and Onborad; Vessels ICT systems;
service; infrastructure unvailability;
Damage of Company's B1 D3 B1 D3 E5 C3 E5 C3 ISO 27001; B1 B3 B1 B3 E5 E3 E5 E3 Yes
Terminal system malfunction; Reputation;
Data inaccessible; ISO 27002;
002A‐ISMS Procedure 02A Asset Management
002A‐ISMS Procedure 05H Server Configuration Controls
002A‐ISMS Procedure 05E Software Management
002A‐ISMS‐PROC 05F_ICT Systems Lifecycle (Acquisition ‐ Termination)
Not being able to address daily
002A‐ISMS Procedure 05C Capacity Management OCIMF: The Guidelines on Cyber
challenges; Company/ Vessels ICT system Service Unavailability;
Unable to Manage Operational 002A‐ISMS Procedure 05I Backup Security Onboard Ship;
A2‐7 Environment
Both Ashore and Onborad; Attacking 3rd parties ICT Lack of Administration; being compromised; Damage of Company's B1 D2 B1 D2 E5 C4 E5 C4 002A‐ISMS Procedure 05G Hardware Lifeycycle Management ISO 27001; B1 B2 B1 B2 E5 E4 E5 E4 Yes
Systems; Data becoming unavailable or Reputation;
002A‐ISMS Procedure 04A Access Management ISO 27002;
corrupted;
002A‐ISMS Procedure 05A Protection Against Malicious Code
002A‐ISMS Procedure 05B Technical Vulnerabilities and Patch Management
002A‐ISMS Procedure 07A Network and Communications Security
002A‐ISMS Procedure 01 Physical and Environmental Security
Attacking the Company; Vessels 002A‐ISMS Procedure 04A Access Management
ICT systems; 002A‐ISMS Procedure 04B Password Security
Human Error; 002A‐ISMS Procedure 05A Protection Against Malicious Code
System Malfunction; 002A‐ISMS Procedure 05B Technical Vulnerabilities and Patch Management
Software Bug; 002A‐ISMS Procedure 05C Capacity Management
DoS Attacks; Injury & Control Systems 002A‐ISMS Procedure 05E Software Management
002A‐ISMS‐PROC 05F_ICT Systems Lifecycle (Acquisition ‐ Termination) OCIMF: The Guidelines on Cyber
Attacking 3rd parties ICT automation not working;
Service Unavailability; Security Onboard Ship;
A2‐8 Unavailability of data/systems Both Ashore and Onborad; Systems; Business Processes not running; Financial loss; B2 D3 B2 D2 E4 C3 E4 C4 002A‐ISMS Procedure 05I Backup
002A‐ISMS Procedure 07A Network and Communications Security ISO 27001; A2 B3 A2 B2 F4 E3 F4 E4 Yes
Power failure or fluctuation; Damage of Company's
Office Security Plan ISO 27002;
Failure of environmental Reputation;
control systems; Ship Security Plan
Extreme weather conditions 004‐EMP ZZ‐Appendix A Business Continuity Plan
(hot, storm, snow);
Earthquake;
1
PRO 28‐ Annex D
Version:3
Issue Date :31/05/22
Rev. 08.2020 Company Hazard Register List 2020
L M H S L M H S L M H S L M H S
Potential Risk Potential Risk Technical Actual / Residual Actual / Residual
Threat Top Subsequent System Controls Reference Reg & Industry
ID Hazard Location
Consequences New Matrix Prime
(Company Procedures) in place
Controls in
Documents
Risk Risk Prime ALARP
P A E R P A E R place P A E R P A E R
001‐IMSM Appendix Z‐6 Information Classification Policy
002A‐ISMS Procedure 08 Information Classification and Handling
002A‐ISMS Procedure 04A Access Management
002A‐ISMS Procedure 07A Network and Communications Security
Attacking the Company/ 001‐IMSM Appendix Y ‐ Computer Email & Internet Policy
Sensitive company information Commercial impact/ Financial
Vessels ICT systems; 002A‐ISMS Procedure 02B Physical Media Transfer OCIMF: The Guidelines on Cyber
stolen / released; loss;
Unauthorized Access to Data/ Attacking 3rd parties ICT 002A‐ISMS Procedure 03 Secure Disposal Security Onboard Ship;
A2‐9 Data Breach
Both Ashore and Onborad;
Systems;
Loss of confidentiality; Company/ Vessels ICT system Damage of Company's B1 D3 B1 D2 E5 C3 E5 C4 002A‐ISMS Procedure 05B Technical Vulnerabilities and Patch Management ISO 27001; B1 B3 B1 B2 E5 E3 E5 E4 Yes
controls violated; Reputation;
Human Error; 002A‐ISMS Procedure 05D Portable Device Security ISO 27002;
Company/ Vessels ICT system
Internal user's Malicious Intent; 002A‐ISMS Procedure 06 Cryptographic Use
compromised;
001‐IMSM Appendix Z‐6 Information Classification Policy
002A‐ISMS Procedure 08 Information Classification and Handling
002‐PRO Procedure 09 Suppliers and Subcontractors
OFF_ICT 010‐Non‐Disclosure and Confidentiality Agreement
OFF_ICT 009 ‐ Information Security Suppliers' Subcontractors' Audit Checklist
Attacking 3rd parties ICT Commercial impact;
Systems; Problems with authorities;
Innapropriate Company's Data Breach of Company's sensitive ISO 27001;
A2‐10 Handling by 3rd Parties
Both Ashore and Onborad; Human Error; Data CIA Compromise;
data;
Financial loss; B1 D3 B1 C4 E5 C3 E5 D2 ISO 27002; B1 B3 B1 A4 E5 E3 E5 F2 Yes
Malicious intent; Damage of Company's
reputation;
002A‐ISMS Procedure 06 Cryptographic Use
Company/vessel Certification 001‐IMSM Appendix Z‐6 Information Classification Policy
issues; 002A‐ISMS Procedure 08 Information Classification and Handling
Lawsuits; 001‐IMSM Appendix Z‐5 Clean Desk and Clear Screen Policy OCIMF: The Guidelines on Cyber
Unintentional or malicious Personal/ sensitive data being
Non‐Compliance with Legal Data protections safe Fines; 001‐IMSM Appendix Y Computer, E‐mail & Internet Security Onboard Ship;
A2‐11 Framework
Both Ashore and Onborad; breach of legal and regulatory
mechanisms failure;
compromised;
Problems with authorities; B1 D3 B1 C4 E5 C3 E5 D2 002A‐ISMS Procedure 02B Physical Media Transfer ISO 27001; B1 B3 B1 A4 E5 E3 E5 F2 Yes
framework;
Financial loss; 002A‐ISMS Procedure 03 Secure Disposal ISO 27002;
Damage of company 002A‐ISMS Procedure 07A Network and Communications Security
reputation; 004‐EMP ZZ‐Appendix A Business Continuity Plan

002 Procedures 30-09-22

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Prime Tanker Management Inc.

Prime Gas Management Inc.

Manual Code: PRO (002)

IMS PROCEDURES MANUAL

05 PROC 28-Annex B 31/05/2019 CAC S&Q Mgr

Amendment Date Position /

Amendment Date Position /

10 23-Annex I 01/03/2016 31/10/2020 CAC S&Q Mgr

28- Annex D 29/02/2020

Amendment Date Position /

NEW Annexes 30/11/2021

Amendment Date Position /

PROC 28- Annex D 29/02/2020

Procedure No. Procedure Title Issue Issue

Procedure No. Procedure Title Issue Issue

2.2 CREATING THE IMS –IMS LEVELS

The Company’s Integrated Management System consists of five (5) Levels.

2.2.1 Level 1 – IMSM Manual

 The Company Organization Charts (Lines of Authority and Responsibility)

2.2.2 Level 2 – IMS Procedures Manual

2.2.3 Level 3 – All other IMS Manuals and IMS Forms

2.2.4 Level 4 –Secondary Manuals

SECONDARY ISM MANUALS

SECONDARY ISM MANUALS

 All Company developed and/or purchased Software :

2.3 PRELIMINARY IMS DOCUMENTATION

2.4 DEVELOPMENT OF IMS MANUALS

2.5 IMS FORMAT

2.5.1 IMS Manuals’ Format

B. All have a "Record of Amendments" page, which lists:

E. Each Chapter is divided in the following parts:

F. Each Procedure / Section is divided in the following parts:

Indexing of the IMS Manuals.

2.5.2 IMS Forms and Checklists

Department Form Group Initials Group Number

Department Form Group Initials Group Number

Note: Some Forms are Vessel-Type Specific i.e.

2.5.3 Company Circulars

Oil Pollution Plans are uploaded in Danaos as Circulars i.e:

Flag Administration Forms are uploaded in Danaos as Circulars i.e

C. Company Circulars Register.

2.6 APPROVAL OF IMS

2.7 DISTRIBUTION OF IMS

MANUAL TITLE NUMBER OF COPIES

2.8 VALIDITY OF DOCUMENTS

2.8.1 Shipboard Forms

2.8.2 Office Forms

2.8.3 Controlled documents - IMS Manuals & Circulars

2.9 CHANGES AND AMENDMENTS

2.9.1 Reason for Amendments

2.9.2 Proposal for Amendments

2.9.3 Record Keeping / Filing of Proposals for Amendments

 Master’s Overall & Brief Review Reports – SF/SAQ/402 & SF/SAQ/403:

2.9.4 Frequency of IMS Amendments.

As a standard procedure, the need to perform MAJOR amendments

A Gap Analysis of the IMS, will be a carried out

2.9.5 Amendment Process

All amendments are outlined in the Management Review Meeting.

2.9.6 Identification of Amended IMS Documentation

2.9.7 Notification of Amendments

After each major IMS Amendment,

2.9.8 Records of Amended IMS Documentation

2.10 UPDATING THE IMS WITH NEW AMENDMENTS.