Professional Documents
Culture Documents
2016.08.03 TMSA Submission
2016.08.03 TMSA Submission
1.2.2 All company personnel can describe what safety and environmental excellence Yes
means in practice.
Ship and shore management teams actively promote through leadership and sound management
practices the concept of safety and environmental excellence. Procedures are in place for
measurement of staff understanding and commitment through ship visits, meetings, audits,
appraisals, seminars, etc. Senior Management provides direction through strong, effective and
visible leadership and clearly defines responsibilities and accountabilities. Continuous
improvement considerations form a part of everyday business. The workforce is actively
participating in achieving the Company’s objectives and targets.
1.2.3 Management strives to improve performance in the areas of safety and Yes
environmental performance at all levels throughout the company.
Effective communication procedures between shore management and the fleet are fully
implemented and used to capture and share best practices, lessons learnt and trends. This includes
communication of the SMS to all areas within the Company. Necessary resources are allocated by
the Management in order to resolve problems, to realign trends, etc. Management strives to
improve performance in the areas of safety and environmental performance at all levels
throughout the Company
1.3.2 The steps required to achieve safety and environmental excellence are clearly Yes
defined by management.
Procedures for monitoring of targets and KPIs, as well as actions for achieving each KPI, are fully
implemented. Following the Management Review meetings, an action plan is drawn up including
the time frame for completion. A clear time frame and targets for each stage are established and
their progress is discussed during the Management Review Meetings. Targets are defined for each
department head.
1.3.3 Vessel and shore-based management teams promote safety and environmental No
excellence.
Stage 4
1.4.1 Safety and environmental targets and objectives are discussed, at least No
quarterly, at management meetings on board and ashore.
1.4.2 Safety and environmental performance targets are monitored against KPIs. No
1.4.3 All vessel and shore personnel demonstrate their commitment to safety and No
environmental excellence.
1A.1.2 Policies are reviewed through processes described in formal procedures and Yes
instructions.
The Company’s policies and the SMS are dynamic and cover the scope of all Company’s activities.
Procedures exist to encourage and evaluate suggestions for improvements from all levels within
the organization. The Company regularly reviews all its policies through shipboard safety meetings,
Masters’ reviews, Management reviews and other meetings.
1A.1.3 Procedures and instructions are available at all work locations. Yes
The SMS procedures and instructions are in alignment with the stated policies and each Company’s
Policy is materialized through established procedures. All employees and contractors have access
to all SMS important documents. Sufficient electronic SMS is easily accessible to all personnel.
Manning Agents are included in the distribution list of relevant SMS manuals. The SMS is
established, communicated, and supported at every level in the organization and is available on
board all vessels and at the Office.
1A.1.4 A formal document-control system is in place to ensure that the current Yes
management system documentation is available for use at all work locations.
All Managers are responsible for the evaluation and implementation of all revisions relevant to
their department. The level of authority for the final approval of the SMS documentation changes
is defined. Procedures define the distribution and use of current controlled documents. All
employees and contractors have access to all current SMS important documents. Instructions and
procedures are available wherever work is carried out. The document control system ensures that
only the documentation in force is in use.
1A.2.2 Periodic meetings that review or amend current procedures or propose new Yes
ones take place on a regular and timely basis, and are formally recorded.
Formal records include but are not limited to the items defined in the Best-Practice Guidance and
are properly maintained. Meetings that review or amend current procedures, usually coincides
with the Management Review Meetings.
Stage 3
1A.3.1 The safety-management system encourages proactive feedback. No
1A.3.2 Instructions and procedures covering shore and vessel operations are No
developed in consultation with those who will have to implement them.
1A.3.3 Managers are clearly held accountable for achieving the objectives established Yes
for them.
Roles and individual responsibilities and accountabilities are clearly established, assigned,
understood and documented for all employees and Managers. Management is accountable for
ensuring that the SMS is dynamic and is maintained to implement policy and deliver safety and
environmental excellence. Managers are clearly held accountable for achieving the objectives
established for them. The Management Review monitors relevant improvements and statistics. The
SMS contains hand over process for key positions which ensure the effective transfer of
responsibilities and critical knowledge.
Stage 4
1A.4.1 Benchmarking is used to identify further improvements to the safety No
management system.
1A.4.3 Senior managers have a mechanism in place to verify the effectiveness of key No
areas of the safety management system.
2.1.2 The recruitment process includes verification that the qualifications of new Yes
recruits are genuine.
The recruitment procedure ensures that information supplied by recruits indicates that they have
the appropriate skills to fill the position and includes checks that applicants have the appropriate
qualifications and experience. During the recruitment process, each candidate’s credentials are
verified in order to ensure that the qualifications of new recruits are genuine and to verify their
experience.
2.1.3 There is a formal familiarisation process in place for newly recruited shore- Yes
based staff.
Each employee receives job specific familiarization to undertake his responsibilities and
accountabilities as per Company’s procedures. A formal familiarization process is in place for newly
recruited shore staff which covers all policies, including safety, security, health, environment,
quality, business ethics, cultural awareness, etc. Moreover, it is the Company’s procedure to
provide initial, ongoing, and periodic refresher training for its employees to meet job and legal
requirements and to ensure understanding of the proper protective measures to mitigate potential
HSQE hazards. Each employee receives job specific familiarization to undertake his responsibilities
and accountabilities as per Company’s procedures.
2.2.2 The recruitment process identifies any training needed to ensure that personnel Yes
have the required skills and capabilities.
The SMS contains provisions for selection, placement and ongoing assessment of the qualifications
and abilities of employees and selected contractors, to meet specified job requirements. Training
needs of Company employees to ensure that personnel have the required skills and capabilities are
formally identified and properly addressed in the recruitment / new employee orientation process.
Training needs are also identified during internal and external audits, inspections, drills, etc. A
current job description is available for each critical position which includes details of the licenses
and level of experience/knowledge required, together with details of the job responsibilities. The
responsibility for verifying competency and credentials is defined.
2.2.3 The company maintains up-to-date records of qualifications, experience and Yes
training courses attended for all key shore-based staff.
Up-to-date records of shore personnel are kept in each employee’s personal file. Furthermore, the
Company follows the established Training Plan in accordance with the shore based personnel
management procedure. In house and external training seminars take place for all employees.
Course information is kept detailing the various types/topics of training. Records of qualification
and appraisals kept in employee personal file. Furthermore, the Company follows the established
Training Plan in accordance with shore personnel management procedure.
2.2.4 The average job retention rate for key staff (such as superintendents) is greater No
than 70% over a two year period, other than planned attrition.
Stage 3
2.3.1 Key staff retain core technical skills through new training, refresher training and No
participation in industry forums, seminars and conferences.
2.3.2 The company provides adequate resources to implement the safety Yes
management system effectively.
The number, experience and skills of personnel are sufficient to maintain operational integrity
under different operational conditions. The Company’s Top Management is committed to provide
adequate resources and sufficient people to implement efficiently the SMS and to provide full
supervision of all vessels in the fleet. Office resource levels are reviewed during Management
Review Meetings in order to be always maintained at adequate levels.
3.1.2 A process is in place to screen new crew members for job competence. Yes
Minimum crew qualification and experience requirements have been established by the Company.
Procedures have been also established to ensure that during crew screening process (application,
interview, etc.) these requirements are monitored. A rank-specific-interview procedure is described
in SMS and is materialized by using a dedicated form. The whole process for selection of new
crewmembers in order to screen their job competence is documented. Where Manning Agents are
employed for selection and engagement of crewmembers, an annual review on the selection and
recruitment process is conducted, to ensure the compliance of the Manning Agent with SMS
policies and procedures. Moreover, where Manning Agencies are used, the final approval is always
given by the Company.
3.1.3 Medical checks are conducted as a part of the selection and recruitment Yes
process.
All seagoing personnel meet the medical standards required by the Flag Administration and
Company’s requirements. Medical checks are conducted as a part of the selection and recruitment
process by Company’s selected doctors or contracted Medical Centres. D&A abuse and blood
accumulations are also checked prior employment. The frequency of medical checks is over and
above the Flag requirements and is defined in the Company’s SMS. Programs to identify and assess
potential safety and health hazards in the workplace that include provisions for notification and
monitoring of affected personnel, timely and proper correction of the deficiencies, and compliance
with applicable rules and regulations, are also described in the SMS procedures.
3.1.4 A formal drug and alcohol policy is implemented and a system is in place to Yes
monitor it on a regular basis.
The Company places maximum emphasis on strict compliance with established policies and
procedures which comply with Flag State legislation and OCIMF guidelines. Thus, a D & A policy is
implemented and a system is in place to monitor it on a regular basis. Procedures for random
unannounced D & A tests by external contractors and Alcohol tests by the Master and the
Company are in place and clearly described in the Company’s SMS.
Stage 2
3.2.2 The vessel operator verifies that the manning agents ensure that crew quality Yes
requirements are consistently met.
The Manning Agents are responsible to check the qualification levels of recruited seafarers and
forward to the Crew Department for further checks. Manning Agents are included in the
distribution list for all relevant controlled documents. The Crew Department is always looking for
ways to further improve both the quality of crews serving onboard and the working conditions
under which they serve. Manning Agents are audited annually by the Company, as per the
established procedures. It is the Company’s intention to employ only ISO and MLC certified
Manning Agents.
3.2.3 The company has an extended recruitment and interview process for senior Yes
officers.
The Company strives to fill Senior Officers’ positions from within the Company. Specific procedures
and checklists are established for the recruitment and interview of Masters and Senior Officers.
Interviews are conducted to ensure that the applicants have the required skills and capabilities, to
assess the candidate's personality and to determine his possible behaviour under certain
circumstances. Approval authorities for Masters and Senior Officers are clearly defined in the SMS.
Familiarisation and training periods in the Office have also been established. All Company
personnel involved in the briefing process work closely together to exchange observations and to
continuously improve the recruitment / interview process thereby ensuring expanded coverage of
all topics relevant to Company goals for continuous improvement.
3.2.4 Selection, recruitment and promotion procedures ensure appropriate staff Yes
placement with documented appointment records.
Company’s procedures for recruitment, selection and promotion are clearly defined in the SMS and
include requirements on previous experience, age limits, ability to communicate in a common
language, medical certification, etc. The relevant responsibilities are also clearly defined along with
the placement criteria which are needed to ensure that the necessary levels of individual and
collective knowledge and experience are maintained. Promotion procedures make optimal use of
all information gleaned from appropriate forms and parallel appraisals by Company’s Managers,
Superintendents and auditors
3.2.5 The company promotes hygiene awareness within the safety management Yes
system.
The Company actively promotes high standard of housekeeping and hygiene, particularly in food
storage and preparation. Health and hygiene programs are in place to assess potential safety and
health hazards in the workplace. Moreover, Company’s personnel visiting the vessels, regularly
inspect on board the food storage and food preparation areas. Their findings are reviewed as part
of our continuing effort to further improve hygiene awareness on board.
3.3.3 Manning agencies used by the company are audited annually to ensure their No
practices meet the vessel operator’s selection and recruitment procedures.
3.3.4 Vessel operators conduct an annual review of the crew selection and No
recruitment process to ensure that it complies with their policies and
procedures.
3.4.2 The company has a documented planning process to ensure that future No
manning needs can be met.
3.4.3 The management’s written policy is to operate vessels with senior officers who No
have appropriate experience and training on the particular type and size of
vessel.
3.4.4 The company undertakes vessel health-risk assessments on a rolling basis. Yes
Appropriate Company guidelines and associated procedures for conducting and documenting
health risk assessments have been developed. Criteria and procedures are in place for conducting
and documenting safety, health and environmental RA at specific project stages to ensure that
Operations Integrity objectives are met. Information on the potential hazards of materials involved
in operations should always be kept current. Responsibility has been assigned for identifying
hazardous materials and helping to ensure that the corresponding MSDS are maintained, reviewed
and distributed to employees, contractors, etc. as needed. MSDS availability should be confirmed
prior to use of new materials on-site. Exposure limits set by authorities and vendors of hazardous
materials are documented. The Risk Assessment library includes Health elements and is utilized on
board.
3.4.5 Appraisal and competence development processes for vessel personnel are No
linked to future training and promotion requirements.
3A.1.2 There are procedures to ensure that the working and rest hours of all personnel Yes
are in line with STCW or relevant authority guidelines for the vessel trade and
are being accurately recorded.
Rest hours are monitored. Fatigue awareness and preventive measures onboard is not
underestimated. Vessels are manned adequately for their type and trade. Manning always exceeds
the minimum required safe manning.
3A.1.3 There are procedures in place to ensure that, where crew training is required, it Yes
is undertaken within a specific time.
The Company carefully monitors training needs and requirements and training is undertaken within
a specific time frame. Scheduling of crew replacements is planned with the most efficient
satisfaction of these training requirements.
3A.2.2 Management monitors and records training results and its effectiveness. Yes
Crew members’ appraisal forms yield valuable information regarding effectiveness of crew training.
Training records are kept for all employees and continuously updated. Evaluation reports for
measurement of effectiveness of training have been developed. Training records and statistics are
consistently maintained.
3A.2.3 The company has procedures to identify additional training requirements. Yes
The crew members’ appraisal form has been designed to specifically identify additional individual
training needs. Improvements realized from additional individual training are recorded on
subsequent appraisals and/or personal training records.
3A.2.4 Crew training includes the use of audiovisual training aids and/or computer Yes
based training.
The Company will continue to provide the latest audio visual training materials both in its shore
side training programs and on board all vessels.
Stage 3
3A.3.1 Company policy provides career development for junior officers and aims to No
promote senior officers from within the company, where possible.
3A.3.2 The company achieves an 80% retention rate for senior officers over a two-year No
period.
3A.3.3 The company organises senior officer seminars to promote, emphasise and No
enhance the company’s safety management system.
3A.3.4 Training for seafarers exceeds the minimum requirements of the STCW or of the No
relevant authority for vessel trade.
Stage 4
3A.4.1 Company policy provides career opportunities for officers by providing shore- No
based assignments.
3A.4.2 Management achieves an officer retention rate greater than 80% over a two- No
year period.
3A.4.3 All officers attend company-run seminars at least once every two years. No
4.1.2 Company management regularly reviews the vessel and fleet maintenance Yes
activity system.
The Management is committed to provide any assistance required, providing timely support and
ensuring the availability of approved and/or fit for purpose spares, materials and resources
necessary to carry out maintenance procedures. The status of maintenance standards is frequently
reported to the Company for review. Shore management regularly monitors the maintenance
system and vessel status and provides any assistance/resources required.
4.1.3 The company ensures that condition-of-class (CoC), or equivalent, items are Yes
monitored and closed out as soon as possible.
All outstanding CoC items or equivalent are followed up in detail and Company makes every effort
in order that all such items are closed out before the due date as issued by class.
4.2.2 Cargo, void and ballast spaces are regularly inspected to ensure their integrity is Yes
maintained. Records are tank-specific and made on a standardised format that
may include photographs as evidence of the tank’s condition.
Company’s procedures satisfy this KPI. Cargo and ballast spaces are inspectedat regular intervals.
Records are tank specific and based on a Company supplied format.Guidance through industry and
class publications has been provided to all vessels.
4.2.5 The maintenance and defect reporting system alerts the staff responsible for Yes
fleet maintenance on board and ashore when it becomes due.
The PMS implemented onboard and ashore provides for alerting the responsible personnel when
any maintenance activity becomes due.
Stage 3
4.3.1 A common, computer-based maintenance system on board each vessel records No
all planned maintenance.
4.3.2 There is a formal shipyard repair list maintained on board and/or ashore. No
4.3.3 The company policy is to maintain an optimum spare parts inventory or system No
redundancy for all vessels.
4.4.2 The vessel’s maintenance and defect reporting system tracks all outstanding No
repair items, including dry-dock work lists.
4.4.3 There is a company system that tracks ALL fleet-wide outstanding maintenance No
and defect items.
4A.1.2 Critical equipment and systems are identified in the vessel’s planned Yes
maintenance system.
All Vessel Critical Equipment systems, devices, controls and alarms are recorded in the PMS of each
vessel. Throughout this system all listed Critical Equipment are available in an easy to understand
format.
Stage 2
4A.2.1 There are clear reporting requirements when critical systems, alarms or Yes
equipment become defective, or require planned or unplanned maintenance.
Reporting requirements when critical equipment brakes down or requires planned or unplanned
maintenance are fully implemented. Ship specific lists with critical equipment and reporting
requirements when critical systems, alarms or equipment become defective, or require planned or
unplanned maintenance have been established and documented. Appropriate personnel are
trained concerning the operation, testing, and calibration of critical systems.
4A.3.3 The vessel operator gives special attention to recording test and performance No
data for all critical equipment and systems.
4A.3.4 The vessel operator identifies and documents competency standards with No
regard to critical equipment and systems.
Stage 4
4A.4.1 No incidents or out-of-service times are attributable to a failure in managing the No
maintenance of critical equipment or systems and associated alarms.
4A.4.2 Critical equipment and systems should be treated as priority items in the fleet’s No
planned maintenance systems.
Stage 2
4B.2.1 The number of outstanding planned maintenance tasks of non-critical Yes
equipment for individual vessels and the fleet as a whole is expressed as a
percentage of the total number of monthly planned maintenance tasks.
Data are recorded monthly with a running year-to-date figure also recorded and reviewed in the
Management Review Meetings.
Stage 3
4B.3.1 The number of outstanding planned maintenance tasks of non-critical No
equipment for individual vessels and the fleet as a whole is expressed as a
percentage of the total number of monthly planned maintenance tasks.
Stage 4
4B.4.1 The number of outstanding planned maintenance tasks of non-critical No
equipment for individual vessels and the fleet as a whole is expressed as a
percentage of the total number of monthly planned maintenance tasks.
5.1.2 The vessel operator has procedures which achieve effective bridge resource Yes
management.
Navigational procedures aim to support effective bridge resource management and include the use
of checklists covering all relevant activities. Contingency plans addressing navigational and
machinery failures are available.
5.1.3 The vessel operator has identified shore-based staff that are responsible for Yes
maintaining navigational standards on board vessels.
As per SMS procedures the Operations Manager is responsible for maintaining nautical standards
on board Company’s vessels. He has direct access to Senior Management and the authority to
implement suitable controls. He is also responsible to track and analyse shipboard navigational
audits and to address the findings in the Management Review Meetings. The Management Review
regularly review navigation practices/procedures and performance results to ensure navigation
standards are maintained by adopting improved navigation practices, equipment, training and
procedures.
5.1.4 All navigational equipment, including lights, compass, communications and Yes
signaling equipment, is maintained fully operational. The company documents
all defects and corrective actions.
The performance of bridge equipment is monitored consistently, and defect and reliability
reporting measures are in place. The Company has available under contract suitably trained staff
and a Qualified Company capable of maintaining navigational equipment. Certain navigation
equipment, which is considered critical, is included in the critical equipment list, therefore
notification when it fails is always done. All defects and corrective actions are properly
documented. Navigational procedures ensure proper notification when critical equipment fails.
Relevant checks are conducted on a daily basis.
5.1.5 Navigational procedures include a requirement for the master to conduct Yes
audits, which are formally recorded, to ensure that all officers are complying
with applicable navigational regulations and company procedures.
Masters are required to conduct every four months navigational audits/reviews to ensure all
members of the Bridge Team are complying with established procedures for safe navigation. Each
serving Bridge Officer is audited at least once during his service period on board.
Stage 3
5.3.1 Chart supply is automated under a contract with a recognised chart agent. Yes
The Company has successfully implemented a Chartroom Management Services Contract with a
recognised contractor. This contract covers the automatic supply of charts, chart corrections, new
editions and publications.
5.3.2 The vessel operator has a formal programme to ensure that senior officers No
receive appropriate shiphandling training before promotion to master.
5.3.3 Vessel operators provide bridge resource management training courses for all Yes
deck officers. These courses follow a set format.
All Deck Officers attend Bridge Resource Management courses at shore qualified training centre.
Refresher training is provided and all training records are maintained as it is stated in the relevant
procedures.
Stage 4
5.4.1 Electronic charts are in use aboard company vessels. Yes
The Company has successfully implemented a ChartroomManagement Services Contract with a
recognised contractor.
5.4.2 Audit reports from the fleet are analysed and actions taken to improve No
procedures.
5.4.3 The vessel operator arranges independent, random navigational reviews across No
the fleet to check general navigational competence.
6.1.2 A suitably qualified person (designated officer/PIC) is responsible for ensuring Yes
compliance with implementation of the cargo and ballast procedures.
Codified job assignments are delegated by the Master to his Chief Officer and to the 2nd Officers.
All forms, work sheets, check lists, etc., are countersigned by the Master and his Officers.
6.1.3 There is a documented system in place to ensure that the company monitors Yes
cargo and ballast plans.
The SMS includes procedures to ensure that the Company monitors cargo and ballast plans.
Visiting superintendents monitor cargo and ballast operations and review relevant plans. All
relevant reports are maintained onboard. Cargo and ballast plans are also monitored / reviewed
during internal audits, inspections and shore visits. Selected records are maintained ashore
6.2.2 Loading computers, where fitted, are regularly tested against class-approved Yes
test data to ensure operational accuracy and records are maintained.
Ship loading calculators and computer programs are tested at regular intervals and test results are
recorded
6.2.3 Procedures ensure independent monitoring of tank levels in addition to the Yes
primary gauging system.
Independent high-and high-high-level alarms are provided on all vessels. All vessels are also
equipped with MMC measurement tapes for monitoring of tank levels. Comparison of
measurement results between metric tapes and vessel’s fixed gauging system is conducted
according to the relevant procedures described in SMS.
6.2.4 Company ensures that tank level measuring/custody transfer systems are Yes
verified for accuracy and operability.
Tests performed before every operation in independent high level alarms and high-high level
alarms are properly recorded. Comparison of measurements between UTI and tank radar system is
conducted before every operation.
Stage 3
6.3.1 There is a documented system in place to ensure that junior officers/relevant No
vessel staff are actively involved in planning, cargo-line setting, and execution of
the cargo and ballast operations.
Stage 4
6.4.1 The company is actively involved with equipment manufacturers in the No
development of innovative technology.
6.4.2 Officers attend shore-based courses that provide interactive computer modules No
to ensure familiarity with operational and emergency procedures.
6A.1.3 The vessel operator has a documented procedure to ensure that the Yes
maintenance and routine condition monitoring of mooring equipment are
included within the planned maintenance system (PMS).
The PMS system contains procedures for regular inspection and maintenance of all mooring
equipment. The system includes the description and method for each maintenance task, the spares
inventory and the replenishment of used parts.
6A.1.4 The vessel operator has a documented procedure to ensure that records are Yes
maintained of the inspection and replacement dates of wires, ropes and, where
fitted, tails.
The Company retains photocopies of all certificates for ropes/wires/tails and has a system in place
to follow-up inspection/replacement dates for all supplied mooring gear.
Stage 2
6A.2.1 The vessel operator has a documented procedure to ensure that unpredicted Yes
changes in environmental conditions and traffic movements are monitored to
prevent the vessel breaking-out from its berth.
Mooring procedures address requirement for regular monitoring of weather conditions and
passing traffic to ensure the timely securing of the vessel in changing conditions and avoid the
vessel breaking out from its berth.
6A.2.2 The vessel operator has a documented procedure covering deployment and Yes
monitoring of moorings throughout port operations.
Current practice is in compliance with indicated best-practice guidance. Matters such as crew
familiarity, Master’s responsibility to assess competency, suitable supervision and sufficient
members in mooring teams are emphasized to increase awareness of the Officers and crew.
Stage 4
6A.4.1 The company has a documented process to ensure that power supplies for No
mooring equipment, including steam, hydraulic or electric types, are sufficient
and adequately protected.
7.1.2 The management of change process clearly defines the level of authority Yes
required for the approval of a change.
Clear responsibilities included in SMS. Levels of authority for review and approval of changes are
also defined. Risk Assessment is carried out for any change and any measures are authorized by the
Managing Director.
Stage 2
7.2.1 The company uses techniques such as risk assessment to evaluate the impact of Yes
proposed changes.
The Company is using Risk Assessment to evaluate the impact of any proposed change as well as
on all routine and non-routine tasks.
7.2.2 The system ensures that training needs arising from changes to equipment or Yes
procedures are identified and documented.
When the change directly affects the vessel, steps are taken to familiarise theSuperintendent and
the crew as required. Equipment specific training and familiarisation isperformed and checklists of
key steps to be taken are prepared.
7.2.3 Management of change records are kept for verification purposes. Yes
Permanent changes to the company’s SMS are fully documented and linked with company’s
document control system. Records are available in the Company’s digital SMS
7.2.4 The vessel operator has documented staff handover procedures for both shore- Yes
based personnel and vessel crews.
Company implements documented handover procedures for both shore-based staff and crews.
Rank specific shore and ships personnel familiarization and handover form are properly
maintained.
7.2.5 The vessel operator has a documented familiarisation process for both shore- Yes
based staff and vessel crews.
Familiarization and handover procedures for both shore-based staff and ships’ crews have been
established and documented. The scope and depth of information provided are relevant to the
responsibilities of the personnel involved.
7.3.2 Procedures include provisions for the familiarisation of superintendents and Yes
crew with newly acquired vessels entering into the fleet
ownership/management.
rocedures are in place to ensure adequate time for crew and Superintendents to become familiar
with a newly acquired vessel.
Stage 4
7.4.1 There is a documented annual review of the impact of all changes to ensure No
objectives have been met.
7.4.2 For major changes to the shore organisation, the management of change No
procedure should require a detailed review of the impact on the organisation
and on the management system.
Stage 2
7A.2.1 The system ensures that the documentation supporting a change includes the Yes
reason for the change, a clear understanding of the safety and environmental
implications, and the appropriate level of approval.
Levels for review and authority of any type of change are defined within the relevant procedure. It
is also stated therein that changes are not approved by the person directly involved in the change.
Stage 3
7A.3.1 The management of change process ensures that any changes made are Yes
communicated to personnel affected by the change.
Procedures are in place to ensure that personnel affected by the change are always identified. The
DPA, department heads and ship’s Master are responsible to ensure that those identified are made
aware of the details surrounding the impact of the change.
7A.3.2 The system ensures that the potential consequences of a change are identified, No
together with any required risk-reduction measures.
Stage 4
7A.4.1 The management of change system also ensures that temporary changes do not No
exceed the initial authorisation for scope or time without review and re-
approval by the appropriate level of management.
7A.4.2 The system ensures that changes not carried out within the proposed time scale No
are reviewed and revalidated.
8.1.2 The vessel operator has procedures that ensure the fleet is rapidly notified of Yes
urgent safety-related information.
The established procedures supported by specific forms ensure rapid notification,
consistentreporting, effective investigation analysis, documentation of incidents, accidents and
near misses andfollow up methods to learn and avoid recurrence.
8.1.3 The reporting procedure ensures any breaches of regulations are identified. Yes
Investigation report includes reference to possible breaches of Company’s and legislative
requirements when determining route cause. The Managing Director assesses all reports to
determine which authorities should be notified.
8.2.2 The person appointed to lead the investigation is not connected with the Yes
incident.
According to the Company’s procedures, the trained person appointed to lead the investigation
shall not be connected with the incident. Resources and personnel that can assist in investigation
include independent contractors. Furthermore, Office key personnel and at least two Officers
onboard each vessel, have received Incident investigation training.
8.2.3 The vessel operator uses the conclusions from the investigation to reduce the Yes
risk of any recurrence or related incidents.
The conclusions of the investigations are distributed within the Company’s departments and fleet
to reduce the risk of any re-occurrence of related incidents. Findings are retained, periodically
analyzed to determine where improvements to practices, standards, procedures, or management
systems are warranted and used as a basis for improvement. A process also exists to ensure lessons
learnt from external incidents are evaluated and applied as needed. The conclusion of the
investigation is distributed within Company’s fleet to reduce the risk of any re-occurrence of
related incidents.
Stage 3
8.3.1 The incident-investigation process ensures that the root causes and factors No
contributing to an incident or accident are clearly identified.
8.3.2 The incident analysis process ensures that the lessons learnt from an incident or No
near miss are shared across the fleet.
Stage 4
8.4.1 The vessel operator has procedures to share lessons with industry groups, No
where appropriate.
8.4.2 The vessel operator has procedures to share lessons with oil-major vetting No
departments, where appropriate.
Stage 2
8A.2.1 External training in incident investigation techniques, including root-cause Yes
analysis, is given to at least one of the shore-based management teams.
The Company provides arrangements for managerial personnel to attend in qualified training
centers training courses on how to conduct an incident investigation and root cause analysis.
Moreover, the in house seminars include incident-investigation training. Senior Officers onboard
each vessel are also certified. Class Societies and other contracting companies are utilized to
provide relevant courses. This information is then handed over to other relevant shore and ship
personnel.
Stage 3
8A.3.1 There is a documented procedure to ensure that, where possible, practical No
experience in incident investigation is obtained.
8A.3.2 When new senior staff are recruited, they receive appropriate incident No
investigation training.
Stage 4
8A.4.1 Procedures require that incident investigation refresher training takes place No
after an appropriate period.
9.1.2 Following vessel visits, recommendations for improvement are made to senior Yes
management.
All Company’s Superintendents and Managers fully understand that the promotion of a strong
safety culture across the fleet is one of their most important duties. For this purpose, Seminars,
meetings and lectures are held by visiting shore personnel. Following ships’ inspections/visits any
findings are brought to the attention of the Master and Senior Staff.
9.1.3 Formal safety meetings are conducted with officers and crew during shore- Yes
management visits to vessels.
Formal Safety Meetings are held with Officers and crew during shore management visits and are
being properly recorded. Any feedback obtained from these meetings is reported and used to
improve the SMS procedures.
9.1.4 The vessel operator has a documented permit to work system. Yes
Work permit system complies with current ISGOTT requirements and incorporates checks and
authorizations that are consistent with mechanical and operational risks. Daily work plan considers
permit requirements for each task.
9.2.2 Records of all valid/current risk assessments are maintained at relevant Yes
locations.
All records of risk assessments are being reviewed by the Company’s qualified personnel during
Management Review meetings and are properly maintained both ashore and on board.
9.2.3 The risk assessment process also includes provision for assessing new or non- Yes
routine tasks.
The Company’s procedures require Risk Assessments for new routine or non-routine tasks. The RAs
are conducted for ongoing operations and for new projects in order to identify and address
potential hazards to personnel, facilities, the public and the environment.
9.2.4 Preventive measures and alternative methods of work to ensure safe Yes
completion of work are identified and documented in the risk-assessment
process.
All recognized potential hazards or otherwise undesirable operations in the risk-assessment
program are documented and used to improve SMS procedures and create a safe working
environment on board all vessels. Furthermore, the Risk Assessment program includes provisions
in order all preventive measures and alternative methods of work to be identified and
documented.
9.2.5 Achievable targets are set for close out of the preventive measures identified in Yes
the risk assessment.
The follow-up action plan includes priority, responsibility and planned timing to help ensuring risk
management decisions are implemented and monitored to close out. Every effort is made to
introduce identified preventive measures as soon as possible. All risk mitigation measures are
identified and implemented prior to commencement of work. All actions identified in the RA are
closed out as soon as possible and defined corrective and preventive measures are immediately
introduced.
9.3.2 The risk-assessment processes should include response elements to limit the Yes
impact of any unplanned occurrences.
The Risk Assessment process includes response and mitigation elements to limit the impact of any
unplanned occurrences and provide for formulation of contingency plans to facilitate safe
management and recovery of the situation. The Company’s Top Management approves continued
operation of vessels in higher risk scenarios. No new procedure or equipment that could pose
significant threat to safety, health or the environment is introduced until full consideration of the
potential risks has taken place.
9.3.4 Appropriate company representatives make extended visits to all vessels within No
the fleet to confirm safety standards and ensure that safety training
programmes are effectively implemented.
Stage 4
9.4.1 Company management reviews and collates all on-board risk assessments to No
check that standards are consistent.
9A.1.2 Significant safety deficiencies that cannot be rectified by vessel staff are Yes
immediately reported to company management.
According to established procedures significant safety deficiencies that cannot be rectified onboard
are immediately reported to management. Full assessment of situation is undertaken before
operation continues.
9A.1.3 On-board safety meetings are held at least monthly and as soon as possible Yes
after any serious incident or accident within the company.
Safety Meetings are carried out at least monthly and as soon as possible after any serious incident
or accident within the Company. Records are maintained on board and in the head office.
9A.1.4 There is a formalised system on board to identify hazards (hazard identification) Yes
during work planning.
The Risk Assessment procedure is used to identify hazards during work planning. The Company’s
guidelines and relevant industry publications provide all the necessary information. Hazards and
risks are systematically identified and assessed to ensure that risk exposure is effectively managed
and considered at appropriate levels of management. The Company has defined levels for the use
of PPE appropriate to the work being undertaken and the cargoes being carried by the vessels.
9A.2.2 Drills and safety exercises are used to determine and record the training needs Yes
of individual employees and records are maintained on board and/or ashore.
On board safety training and drills are fully documented and this process is designed to fully
address any identified training needs. Procedures are in place to provide periodic assessments of
the qualifications and abilities of employees to meet their specified job requirements. Training
needs are identified during drills, internal and external audits, etc., and addressed as soon as
possible. Furthermore, the Company provides personalised training in addition to the
familiarisation required by the STCW, etc.
9A.2.3 The vessel operator has a formal documented risk-assessment process on Yes
board, and relevant crew members have been trained in hazard identification
and risk assessment.
RA training as well as hazard identification and reporting are included in the Company’s Training
Plan. The Company has established ways to identify and limit hazards to a manageable level by
using the RA process. Periodic RAs are performed by trained personnel in hazard identification and
RA, including expertise from outside the immediate unit as appropriate. The RA program is
regularly reviewed and higher risk areas reassessed. The crew receives advice on assessing unsafe
acts and conditions, reporting findings and near misses and taking appropriate corrective action.
Stage 3
9A.3.1 The vessel’s management team promotes a strong, proactive safety culture on No
board, and all crew members are encouraged to be involved in proactive safety
campaigns and work methods.
9A.3.2 Company safety policy ensures that senior officers and managers always lead by Yes
example in safety-related issues.
The Company has consistently emphasized and promotes a strong safety, health and hygiene
culture through all its activities. All Managers and the responsible Officers on board appreciate this
policy and actively promote a strong proactive safety culture.
9A.3.3 The company sends officers and crew on safety training courses in excess of No
statutory requirements.
9A.3.4 Safety best practice identified on individual vessels is transferred across the No
fleet.
9A.4.2 The company actively seeks modern safety-training material and courses that No
can be used for on-board and shore-based training.
10.1.2 The company has processes in place aimed at ensuring all effluent discharges Yes
are within permitted levels or are prohibited.
All effluents are discharged within permitted limits in accordance with MARPOL, European, US and
other local requirements. Records are kept on board Company’s ships and in office and are audited
during inspections and Internal Audits.
10.1.3 All sources of marine and atmospheric pollution attributable to company Yes
activities have been systematically identified.
The Company has established and maintains procedures to identify all aspects and limit the impact
of its operations on the environment. These include provisions for the systematic identification and
assessment of all sources of marine and atmospheric pollution, i.e. NOx, SOx emissions, etc.;
minimising adverse environmental impacts and waste generation; ensuring the safe and
responsible disposal of residual wastes, etc.
10.1.4 The company has systems to identify emerging requirements for environmental Yes
protection.
Various sources to provide information in order to identify emerging requirements for
environmental protection have been identified and are systematically monitored. Environmental
Aspects have been properly addressed and controlled consistent with Company’s policy, regulatory
requirements, and Company’s business plans. All legal and other requirements to which the
Company subscribes are taken into account in establishing, implementing and maintaining its SMS.
10.2.2 The vessel operator has a system to identify the actions needed to comply with Yes
new regulations.
The Company maintains relevant procedures to identify and have access to legal and other
requirements to which we subscribe, and determines how these requirements apply to its
environmental aspects. Actions needed to comply with new regulations are a standard agenda
item in the Management Reviews and the ship Safety Committee meetings. The Company ensures
that applicable legal and other requirements are taken into account in establishing, implementing
and maintaining its EMS.
10.2.3 The company has clearly assigned management responsibility for each Yes
environmental issue.
Management responsibility is clearly assigned for each environmental issue. The responsibility for
environmental performance is assigned to all Department Heads. The Environmental Management
Representative (EMR) has defined duties and authorities for ensuring that environmental
procedures of the SMS are established, implemented and maintained.
Stage 3
10.3.1 The vessel operator has a system for auditing and reporting progress on effluent No
reduction.
10.3.2 Pollutant reduction targets are set in the company business plan. No
Stage 4
10.4.1 The company has an environmental action plan. No
10.4.2 The company has developed and maintains a long-term (a five-year minimum) No
environmental operations and business plan.
10.4.3 Environmental performance is benchmarked across the fleet and against the No
oil/marine industry as a whole.
10A.1.2 The company has identified areas of performance that will improve Yes
environmental care and has developed appropriate action plans.
Company has identified areas of performance that improve environmental care and has developed
appropriate action plans. Formal records on board show proposals and measures to be taken to
improve performance.
10A.1.3 The vessel operator has fleet-wide systems to monitor and ensure compliance Yes
with existing company policy.
Environmental performance is audited during internal audits on board vessels. Any non-
¬conformities are discussed in the Management Review Meetings
Stage 2
10A.2.1 The company has management systems to ensure environmentally critical Yes
equipment is reliable and that adequate levels of spares are carried.
The SMS ensures environmentally critical equipment is reliable and that adequate levels of spares
are carried on board. Environmental critical equipment have been identified and minimum spares
are controlled.
10A.2.2 Where applicable, each vessel has a ballast-water management system and is Yes
taking steps to reduce the transfer of unwanted marine organisms.
A Water Ballast Management Plan is provided to all of Company's vessels approved by the
Classification Society.
10A.2.3 The vessel operator has a policy to ensure purchase and supply activities Yes
continue to be more environmentally protective.
It is Company’s policy to ensure purchase and supply activities are environmentally protective.
Waste reduction methods are already implemented. Procedures are in place to ensure purchasing
in bulk.
10A.3.2 The company can demonstrate that it is taking measures to comply with known No
future regulations and legislation.
10A.3.3 Waste reduction management is undertaken throughout the fleet and on all Yes
voyages.
Waste reduction management is undertaken throughout the fleet and on all voyages. An active and
formally recorded program of waste reduction management is implemented which includes
recycling, grey water management, etc. Garbage Record Book, Garbage Management Manual,
environmental forms, etc. are part of the vessel’s internal audit checklist.
Stage 4
10A.4.1 Improvements that enhance environmental performance are included into new-
build design and vessel operating practices.
11.1.3 Vessel and shore-based contingency plans have clearly defined roles, Yes
responsibilities and record-keeping procedures.
Company’s SMS describes the shore-based and shipboard emergency teams, defines the roles and
duties of the team members as well as their contact details. Communications and logistics
personnel are included in the Emergency Response Team. Record keeping procedures are also
incorporated.
Stage 2
11.2.1 The company provides adequate emergency response facilities. Yes
A suitable dedicated incident room and other facilities i.e. dedicated fax and phoneconnections,
computer network points, a flip chart, TV and video facilities, emergencycabinet with
plans/manuals, Third party emergency contacts, etc., are available inCompany’s premises.
11.2.2 Individuals are trained in their designated emergency response roles. Yes
External and internal media response training is provided to key management staff and vessels’
Masters. Other individuals both ashore and aboard receive training for emergency situations, as
required.
11.2.3 Lessons learnt from exercises and actual incidents are incorporated into the Yes
emergency response plans when they are updated.
“Lessons learnt” are always taken into account when updating emergency response plans. The Drill
program includes critiques to identify and correct deficiencies. Improvement suggestions are
documented and formally discussed.
11.3.2 Alternative members are included in the planned exercises and drills. No
Stage 4
11.4.1 The company has in place necessary arrangements to use external resources in No
an emergency.
11.4.2 External or additional resources are used to provide more realistic drills and No
exercises.
Stage 2
11A.2.1 The scope of an exercise is consistent with the size and composition of the fleet Yes
and its trading patterns.
Masters in planning the monthly drills and enables the easy review of the drills’ execution status by
the Company. Additional plan is maintained by the Company for the annual major ship-shore
exercise exercises, fulfilling the requirements of this KPI.
11A.2.2 The frequency of drills and exercises should be determined by the number of Yes
vessels within the fleet.
The Company implements regular, realistic emergency drills and exercises that test and improve
the capacity of crews and shore-based staff to deal with a real incident. The drills schedule is over
and above the statutory and industry requirements. The scope of exercises is consistent with the
size of the fleet and its trading patterns. (Ref. Emergency Manual)
11A.2.3 Results of exercises and drills are documented and analysed to identify lessons Yes
learnt.
After office hour’s communications are regularly tested and results recorded during office and
vessel emergency drills. The ERP provides for carrying out the drills outside normal working hours
to actually test the effectiveness of the communication system and benchmark mobilization times.
A comprehensive test of all communication and mobilisation systems is also provided
Stage 3
11A.3.1 Exercises provide a comprehensive test of all communication and mobilisation Yes
systems.
The contact details of the various parties involved (damage stability contractor, oil spill response
contractor, etc.) are available. Relevant procedures have been established where Officers on leave
shall play the role of vessel’s Master during the Emergency Response exercises.
Stage 4
11A.4.1 Drills and exercises test the effectiveness of arrangements to call on external No
consultants and resources.
12.1.2 The company has an inspection plan that covers all vessels in the fleet, with at Yes
least two inspections per annum of each vessel.
The vessels are inspected in accordance with an annual inspection plan prepared by the Technical
Manager on a continuous running basis. According to this plan each Company vessel is
visited/inspected as a minimum bi-annually. The inspection plan is designed to provide a review of
the entire fleet on a regular and specified basis.
Stage 2
12.2.1 The format is of a standard that is at least equivalent to the vessel inspection Yes
reports issued by industry bodies such as OCIMF, CDI or EBIS.
The checklist format is of a standard equivalent to the vessel inspection reports issued by relevant
industry bodies.
12.2.2 The standard format measures the level of compliance with company and Yes
regulatory requirements.
The established check lists provide for recording of the level of compliance with Company and
regulatory requirements, as well as inspectors’ / auditors’ comments.
Stage 3
12.3.1 The company analyses its inspection results and compares them with data from No
third-party inspections (such as the SIRE, CDI or EBIS systems) and makes
comparisons between vessels within the fleet, particularly with any vessels built
to a similar design an
12.3.2 The company has a system that clearly demonstrates the status of the recorded No
deficiencies through to close out.
Stage 4
12.4.1 Information from the analyses of these inspections is fed into a continuous- No
improvement process.
12.4.2 The results of vessel inspections are analysed to identify trends and common No
problems.
12A.1.3 The company has an audit plan that covers shore and vessel locations. Yes
The annual audit plan, which is always kept up to date, covers all Company’s departments/activities
and all managed vessels. The audit system provides a review of the entire organization and the
fleet on a regular and specified basis.
Stage 2
12A.2.1 Audit results are reported as soon as is reasonably practicable. Yes
A performance standard for the time taken from completing the audit to distributing thereport has
been set. Spot checks are conducted to ensure that this standard is being met.Where it is not being
met, Managers intervene to improve performance.
12A.2.2 Audits are performed in line with the audit plan. Yes
Management reviews number of audits performed against number of audits planned during the
Management Review meetings. Where significant slippage has occurred, Management assign
resources to bring performance back into line with the plan.
Stage 3
12A.3.1 The company maintains records to demonstrate that all actionable items have Yes
been closed out as soon as is reasonably practicable.
The Company’s procedures, records and checks ensure resolutions of findings and that all
actionable items have been closed out as soon as is reasonably practicable. The relevant reports
are sent to the DPA as soon as possible and an action plan on how findings will be resolved is
prepared. Actions not resolved after three months are passed to Top Management for resolution.
Records are maintained to demonstrate the status of the recorded deficiencies through to close
out and that all actionable items have been closed out as soon as is reasonably practicable.
Quarterly checks are made on the status of open actions and a summary is provided during
Management Reviews. The results of audits are recorded as non-conformances and tracked
through to completion to demonstrate close out of required corrective actions.
12A.4.2 The company identifies trends by performing a formal analysis of audit results No
at least annually.