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Tanker Management and Self Assessment 2

A BEST-PRACTICE GUIDE FOR SHIP OPERATORS

Report name YSHJ-8785-2032-0205


Date published 03 Aug 2016
Operator account 20639
Operator name Borealis Denizcilik AS
DOC number
IMO number 5925485
Address Sahrayicedid Mah. Halk Sok. No:52/8, Siddiklar Is
Merkezi, istanbul,
County/State kadikoy
Post code 34734
Country Turkey

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1 Management, leadership and accountability
Stage 1
1.1.1 Management commitment is clearly defined in documentation that includes Yes
mission and vision statements, policies and procedures.
Company Policies and SMS define the Company’s philosophy aiming to continuous upgrading the
standards of vessels’ operations. Policy statements are signed by the Managing Director,
acknowledged by all shore and shipboard staff and posted in all vessels and in the office. Policies
define core responsibilities which aim to ensure that the Company’s principles are followed in all
aspects of its business. Management commitment and personal accountability for continuous
improvement is clearly defined in the SMS and demonstrated through active and visible
participation.

1.1.2 Senior management demonstrates a clear commitment to implementing the Yes


safety management system.
The SMS requires management leadership and commitment visible to the organization and
accountability at all levels. The Top Management establishes and continuously reviews policies,
provides perspective, sets expectations and provides the resources for successful operations. The
Company by implementing the SMS aims to accomplish the stated policies and objectives for
maintaining and upgrading the operational integrity of the fleet. Managers are responsible for
continuous improvement activities; they visibly participate in relevant activities and lead by
example.

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Stage 2
1.2.1 Safety and environmental excellence are fully understood and supported by Yes
vessel and shore-based management teams.
Through communications links, ship visits, meetings, training seminars, familiarization process, etc.
the Company promotes the concept of Safety and Environmental excellence and sharing of
information at all levels within the organisation. Lessons learnt and best practices are captured,
recorded and shared across the organization. Improvement plans are prioritised, developed and
monitored at these meetings. Managers track the recommendations to ensure that they are closed
out and that all necessary changes have been made.

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

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Stage 3
1.3.1 Shore management sets company standards and performs assessments to Yes
verify their implementation.
Management sets standards, objectives consistent with SMS expectations and KPIs and actively
participates in internal and external assessments to monitor their effectiveness. A comprehensive
KPI measurement and assessment system is being implemented. Performance is evaluated, the
degree to which expectations are met is assessed and the results are stewarded to management.
Measurable KPIs are reviewed during the Management Review meetings.

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.

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1A Management, leadership and accountability
Stage 1
1A.1.1 Management ensures that policies cover all the activities undertaken by the Yes
company.
The Company has established HSQE Policies and believes that their implementation is both
necessary and beneficial to the wellbeing of business, employees and the environment. Policies
governing the SMS cover all Company’s activities and are based on the concept of safety and
environmental excellence and continuous improvement. Top Management is involved in the
process of revision, approval and following up the implementation of all policies. Company’s
policies are signed by the Top Management, accepted by all employees and posted on all managed
vessels and in the Head Office.

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.

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Stage 2
1A.2.1 Instructions and procedures are written in plain language and contain sufficient Yes
detail to ensure that tasks can be completed correctly and consistently.
Instructions and procedures are presented in a clear format. A friendly reading language is used in
order to be clearly understood by the responsible crewmember. Person(s) involved in the drafting
of procedures are fully aware, qualified and experienced in their specific topic.

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.4.2 Measurements are carried out regularly according to a comprehensive No


verification plan.

1A.4.3 Senior managers have a mechanism in place to verify the effectiveness of key No
areas of the safety management system.

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2 Recruitment and management of shore-based personnel
Stage 1
2.1.1 The pre-recruitment process should include checks that applicants have the Yes
appropriate qualifications and experience.
The Company has defined in its SMS the minimum experience and qualifications requirements for
each key shore position. Procedures are in place to ensure that these requirements are met prior
to employment. Records of checks are kept in Employee’s personal file. The responsibility for
verifying competency is clearly defined in the SMS. Records of checks are kept in Employee
personal file. The responsibility for verifying competency is defined in the SMS.

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.

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Stage 2
2.2.1 A formal staff appraisal system ensures that key staff members undergo a Yes
performance assessment at least annually.
There is a formal staff appraisal system which includes annual reviews of staff abilities and
identifies any development requirements, including additional training needs. Updated methods of
staff appraisal are researched and implemented. For all issues highlighted in the appraisals, review
is performed with a view to prioritise them for resolution. The appraisal reports are being kept for
the Management to effectively review and track individual progress.

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.

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Stage 4
2.4.1 The company encourages and supports personnel taking higher education No
courses to improve their value to the company and their possibilities for
promotion within the organisation.

2.4.2 Senior on-board personnel are rotated through office assignments. No

2.4.3 The company promotes appropriate interpersonal skills training. No

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3 Recruitment and management of vessel personnel
Stage 1
3.1.1 Management has a defined system of selection, recruitment and promotion Yes
procedures.
The candidates’ credentials are verified to ensure that the qualifications of new recruits are
genuine through checking certificates with the issuing authorities and contacting former employers
to verify experience. Issue dates for certificates and endorsements correlate to previous experience
and vessel type. As described in the SMS, minimum requirements for seagoing personnel have
been established and implemented. The established selection, recruitment and promotion
procedure ensures that information supplied by recruits indicates that they have the appropriate
skills to fill the position.

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

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3.2.1 An appraisal process is in place for all vessel staff. Yes
All seafarers are appraised by the end of their contract or annually (whichever is the minimum) and
during the Master’s hand-over of command. The Company has direct involvement in the appraisal
process. Seafarers are allowed to review the appraisal reports and have their comments recorded.
Completed appraisals are filed so that shore management can effectively track an individual’s
progress. Appraisal reports are reviewed and outstanding appraisals are followed up.

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.

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Stage 3
3.3.1 The company operates an enhanced appraisal process for senior officers Yes
The performance of Masters, Chief Engineers, Chief Officers and Second Engineers is monitored
during their service period and a formal evaluation is carried out by the Company upon
disembarkation. Senior Officers are also appraised by the Company’s Managers and
Superintendents during ship visits and these appraisals are taken into account for their final
Company’s evaluations. The aim is to record positive achievements but also areas for
improvement. Any identified training needs are satisfied before next employment.

3.3.2 The company has a documented disciplinary process. No

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.

3.3.5 The company implements health awareness campaigns. No

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Stage 4
3.4.1 The company conducts pre-employment assessment for job competence and No
training for officers and ratings.

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.

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3A Recruitment and management of vessel personnel
Stage 1
3A.1.1 Shore management provides adequate resources to ensure the well-being of Yes
crews.
All vessels are provided with recreation rooms for Officers and ratings, TV sets, DVD players, radio
receivers, table games and library with various books. Through inspections by vessel personnel,
internal audits and ships’ visits, the Company ensures that adequate resources are available to care
for the welfare of the ships’ crew and to ensure their wellbeing. Well-being covers diverse aspects
of the crew’s quality of life including quality of food, accommodation, rest and recreation facilities,
hygiene, air conditioning, access to ship and shore medical facilities, eligibility for compassionate
leave, etc.

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.

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Stage 2
3A.2.1 The company provides initial and refresher training for all ranks. Yes
Policies and procedures as currently implemented satisfy this KPI objective. The Companymakes
every effort to provide the best available initial and refresher training for all ranks.

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

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4 Reliability and maintenance standards
Stage 1
4.1.1 Each vessel in the fleet is covered by a planned maintenance and defect Yes
reporting system.
The on board maintenance plan and defect reporting system covers all on board equipment on the
bridge, deck, engine room and all electronic equipment. All equipment defects are promptly
reported to the Company. This maintenance plan is based on adopted PMS.

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.

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Stage 2
4.2.1 There is a verification process in place to monitor the accuracy of all vessel Yes
certificates, in addition to the monitoring system on board the vessel.
The Company maintains a fully developed back-up system ashore to monitor all vessels certificates.
Copies of all endorsements to existing certificates on board are promptly transmitted to the
Company for filing.

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.

4.2.3 Superintendents/responsible managers follow up on all required maintenance. Yes


On board maintenance records are checked carefully in the course of shipboard visits, inspections
and audits. The Company, whenever necessary, increases the frequency of these audits and other
visits by Superintendents. All required maintenance follow up is conducted by the responsible
Superintendents/Managers, who ensure that work described in the PMS has been carried out as
appropriate. The Company provides timely support and ensures the availability of approved and/or
fit-for-purpose spares, materials and other resources necessary to carry out required maintenance.

4.2.4 Superintendents/responsible managers visit vessels to audit maintenance and Yes


defect correction plans.
Company’s superintendents visit and make short sails on vessels, in order to audit maintenance
and defect plans and to confirm that established standards are being maintained as per the PMS.

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.

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Stage 4
4.4.1 The maintenance and defect reporting system also monitors the vessel’s spares No
inventory and highlights any shortages.

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.

4.4.4 The maintenance plan includes proactive measures. No

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4A Reliability and maintenance standards (critical equipment)
Stage 1
4A.1.1 Critical equipment and systems are defined and identified within the safety Yes
management system.
Critical equipment is clearly identified in Company’s SMS based on risk assessment methods.
Before equipment’s shut down Master and Chief Engineer provide the Company with a Risk
Assessment for approval.

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.

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Stage 3
4A.3.1 Maintenance on critical equipment should follow defined procedures that Yes
include a risk assessment which requires approvals at the appropriate levels of
management before the equipment is shut down.
The Company has established a defined procedure for handling the maintenance of critical
equipment. A defect reporting and close-out system that can be monitored both on board and
ashore is followed. The SMS specifies a process for notifying Management when critical equipment
is taken out of service, and includes methods for recording Management’s approval of any
mitigating steps introduced while it is out of service. Specific forms are submitted by the vessel in
all those instances where critical equipment is to be “deactivated”. For maintenance of critical
equipment, ship’s staff provides Management with a RA that requires approval before the
equipment is shut down.

4A.3.2 If the agreed shutdown period for critical equipment or systems is to be No


exceeded, any extension or alternative actions will require review by shore
management.

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.

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4B Reliability and maintenance standards (close-out performance)
Stage 1
4B.1.1 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 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.

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5 Navigational safety
Stage 1
5.1.1 The safety management system includes navigational procedures. Yes
All listed procedures are thoroughly covered and documented in the Company’s SMS. As areas for
continued improvement are identified, existing procedures will be reviewed and expanded upon as
appropriate.

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.

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Stage 2
5.2.1 The company has a documented process to conduct on board navigational Yes
audits by shore personnel.
Navigational audits are conducted by qualified shore staff at least annually. Specific check list has
been generated for this purpose. Results of audits are analysed in order to identify trends.

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.

5.4.4 Deck officers undertake periodic bridge resource management simulator No


training at a recognised shore establishment.

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6 Cargo, ballast and mooring operations
Stage 1
6.1.1 There is a documented procedure for planning cargo and ballast operations. Yes
Where applicable this will include procedures for heavy weather ballast, and
the process for the master’s approval of each cargo and ballast operation.
Cargo operations are planned/executed in a safe way. Duties/responsibilities are clearly defined.
Checklists are used to control and ensure safe operations.

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

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Stage 2
6.2.1 Procedures for ballast operations include comprehensive and detailed plans Yes
relating to the heavy-weather ballasting within designated cargo tanks of
segregated ballast tankers.
Heavy Ballast operations are always carried out in accordance with written plan prepared by Chief
Officer and approved by Master. This plan is discussed and should be clearly understood by all
officers participating in the operation.

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.

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6A Mooring operations
Stage 1
6A.1.1 The vessel operator has a documented procedure to ensure mooring Yes
equipment and practices comply with statutory regulations, OCIMF guidelines
and/or industry best practices.
Documented mooring/unmooring procedures and check lists fully comply with OCIMF guidelines
and statutory regulations. These procedures ensure protection of personnel and safe operation of
equipment and include concise mooring instructions, emphasizing on the safety of crew and the
vessel during mooring operations. Reference to “Mooring Equipment Guidelines” for detailed
information is included.

6A.1.2 There is a documented procedure to ensure that maintenance of mooring Yes


equipment is completed, including the annual testing of winch brakes.
Annually full test of mooring equipment is conducted with ship specific test kits as per OCIMF
guidelines. The procedure for regular inspection of the mooring equipment is included in the PMS
system.

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.

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Stage 3
6A.3.1 There is a record of routine risk assessment to ensure that mooring Yes
arrangements and equipment are operated to ensure the safety of vessel
personnel.
Various Risk Assessment cases have been carried out for mooring, unmooring, etc. Risk
assessments will continue to cover as many potential scenarios as possible. The PMS procedure for
Deck equipment inspection includes items referring to the condition of protective arrangements, in
order to ensure that operators are not exposed to unreasonable risks.

6A.3.2 There are documented procedures regarding anchoring operations. Yes


The Company’s shipboard procedures satisfy this KPI objective. Procedures and relevant check lists
regarding safe anchoring and anchor watch are fully documented in Company’s SMS.

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.

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7 Management of change
Stage 1
7.1.1 The vessel operator has a documented procedure for management of change. Yes
A structured Management of Change process has been established, through which, the Company
ensures that proposed/forthcoming changes are fully evaluated and managed to ensure that
arising safety, quality, health, security and environmental risks are identified and addressed in
order to remain at an acceptable level. Procedures for acceptance and implementation of changes
have also been established.

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.

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Stage 3
7.3.1 The system ensures that drawings, procedures and other technical documents No
are updated following any change or modification.

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.

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7A Management of change
Stage 1
7A.1.1 The vessel operator has a management of change process that ensures all Yes
temporary and permanent changes to procedures or equipment on board the
vessel are subject to risk assessment.
The SMS manuals contain a section dedicated to the change management process.

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.

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8 Incident investigation and analysis
Stage 1
8.1.1 The fleet operator has procedures that ensure prompt reporting and Yes
investigation of all incidents, accidents and near misses.
The established procedures and forms, regarding prompt reporting and investigation of all
incidents, accidents and near misses, are included in the SMS. Investigation reports include
timeframe for close out of corrective actions. Management reviews the deadline till issues are
resolved. This is verified during Management review meetings.

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.

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Stage 2
8.2.1 The vessel operator has a procedure that defines responsibilities for reporting Yes
an incident, conducting the investigation and taking subsequent actions.
The Accident Reporting and Investigation Procedures cover the initial reporting up to identification
of root causes, including scope of investigation and its process. Should an authority require to be
notified, this is carried out by the DPA. Procedures for statutory reporting are included in the
Emergency Manuals (SOPEP/SMPEP/VRP, etc.). Furthermore, the procedure addresses timing of
investigations, root cause analysis and investigation team composition.

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.

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8A Incident investigation and analysis - training
Stage 1
8A.1.1 The appointed investigation leader/team has been trained in incident Yes
investigation.
The Company provides arrangements for managerial personnel and all vessels’ Senior Officers 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.
Trained and experienced independent contractors may also participate in incident investigation

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.

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9 Safety management
Stage 1
9.1.1 Shore-based managers arrange regular on-board visits to monitor the safety Yes
standards and training across the fleet. A formal record of these visits is kept
within the office.
It is the Company’s procedure to visit the vessels at frequent intervals in order to monitor their
condition and maintenance. Depending on the vessels’ trade the vessels are visited routinely at
least twice per year. These scheduled visits are supplemented by additional visits by the Company’s
Managers. Subject visit/inspections are properly recorded. During these visits, every opportunity is
taken to promote Company’s Policies and a strong safety culture across the fleet.

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.

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Stage 2
9.2.1 The vessel operator’s procedures include a documented risk-assessment Yes
process to systematically identify potential hazards and manage operational
risks fleet-wide.
The SMS aims to develop a proactive approach to safety management, both on board and ashore,
that includes identification of hazards and the implementation of preventive and mitigation
measures. The Company’s Risk Assessment program systematically identifies potential hazards and
manages operational risks fleet-wide. The relevant procedures also describe the additional
measures that should be taken to promote an effective safety culture and motivate staff to ensure
that they understand and embrace the requirements of the SMS. Finally, the Company has
established and maintains procedures to engage in a Risk Assessment program designed to identify
potential hazards and exposures, and manage operational risks, including those relating to health
and hygiene.

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.

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Stage 3
9.3.1 Shore-based management regularly reviews the validity of risk assessments and Yes
ensures that any common risk assessments are applied across the fleet.
The intervals for reviewing/amending RA program are defined in the SMS. All Risk Assessment
cases are discussed and reviewed during the Management Review Meetings. Relevant documents
are reissued in part, or as a whole, if required, after each review. The Officers and crew are
encouraged to give their views regarding the level of success in mitigation of risk through
improvements to existing procedures.

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.

9.3.3 Senior management establishes and supports proactive safety campaigns. No

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.

9.4.2 The company issues periodic (at least quarterly) safety-related No


bulletins/publication(s).

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9A Safety management - fleet monitoring
Stage 1
9A.1.1 The responsible officer conducts safety inspections at scheduled intervals and Yes
the results are recorded.
A relevant safety inspection program is in place which meets Company and regulatory
requirements. The Safety Officers conduct safety inspections at scheduled intervals and the results
are recorded and properly reviewed.

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.

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Stage 2
9A.2.1 At monthly safety meetings, the agenda includes safety monitoring and Yes
confirmation that all vessel-based safety procedures are being complied with.
The monthly safety meeting agenda includes safety monitoring and confirmation that all ship-
based safety procedures are being complied with. Various methods are used in order to ensure
that the ship’s crew are complying with SMS procedures.

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.

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Stage 4
9A.4.1 There is a system in place for vessel staff to communicate ideas for improving No
safety to shore management.

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.

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10 Environmental management
Stage 1
10.1.1 An environmental policy has been developed, signed by senior management Yes
and distributed/made available to all within the company.
The Company has identified the legal requirements that are applicable to its environmental
aspects. The environmental policy includes a zero-spill statement and is posted on board and in the
Office. All Policies are signed and accepted by Company’s and ships personnel. The Company
maintains a proactive approach to environmental management that includes identification of
sources of marine and atmospheric pollution and measures for the reduction of potential impacts,
both onboard and ashore. Procedures ensure that all applicable legal and other requirements to
which the Company subscribes are taken into account in establishing, implementing and
maintaining its SMS.

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.

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Stage 2
10.2.1 Plans to minimise or further reduce marine and atmospheric pollution Yes
attributable to company activities are under development with defined
priorities and a timescale for action.
The Company maintains procedures to identify and have access to legal and other requirements to
which we subscribe, which are taken into account in establishing, implementing and maintaining
the EMS. Actions needed to comply with new regulations are a standard agenda item in the
Management Reviews and the ship Safety Committee meetings. Environmental Aspects are
properly addressed, consistent with Company’s policy, regulatory requirements, and Company’s
business plans.

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.

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10A Environmental management
Stage 1
10A.1.1 The vessel operator has a system to monitor and reduce waste on board all Yes
vessels in the fleet.
The Company’s Management understands the importance of waste reduction on board as part of
an overall policy of environmental care. A system to monitor (through vessels reports and internal
audits/inspections) and reduce waste (through Environmental Programs) has been developed. The
Company declares specific policies and routing procedures to monitor and reduce waste onboard
all ships by promoting the use of equipment and practices that minimize waste generation.
Suggestions for improvement include improved packaging of stores and other material supplied to
the vessels, use of recyclable materials for packaging, arrangements for safe disposal of
environmentally hazardous materials like batteries, paint pots, defective wire ropes, rust, etc.

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.

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Stage 3
10A.3.1 An energy-conservation programme is in place and effectively monitored No
throughout the fleet.

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.

10A.4.2 The company employs/adheres to environmentally sound ship recycling


practices.

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11 Emergency preparedness and contingency planning
Stage 1
11.1.1 The company has detailed shore and vessel contingency plans that cover all Yes
credible emergency scenarios.
The SMS provides for review of the emergency response procedures based on feedback from drills
results and actual incidents. Masters’ reviews incorporate the results of SMS, SOPEP, etc., review.
The DPA regularly reviews SOPEP and other emergency plans in consultation with the ships’ crews.

11.1.2 Emergency procedures include effective notification procedures and Yes


communication links for rapidly alerting the emergency response team.
Contact details are contained in the ERP. The emergency response team can be contacted 24h per
day. ERP ensures that there is 24-hour cover that takes account of holidays and work-related travel
arrangements.

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.

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Stage 3
11.3.1 Alternative members for key positions in the emergency response teams have Yes
been identified and trained.
A list identifying qualified stand-ins for key positions in the Emergency Response Team hasbeen
drafted and is maintained in the Emergency Response Plan. Training has beenprovided for all
nominated stand-ins.

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.

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11A Emergency preparedness and contingency planning
Stage 1
11A.1.1 Incident scenarios for exercises fully test the contingency plans. Yes
The drill scenarios described in the ERP fully test the contingency plans and have
adequatecomplexity to enable realistic and varied plot. Varied content and duration of scenarios
hasbeen implemented.

11A.1.2 A major exercise is carried out at least annually. Yes


Major exercises, with the participation of shore team and vessel(s) are scheduled at least on an
annual basis.

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.

11A.3.2 Exercises allow the participation of a significant number of individuals. No

Stage 4
11A.4.1 Drills and exercises test the effectiveness of arrangements to call on external No
consultants and resources.

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12 Measurement, analysis and improvement
Stage 1
12.1.1 A company-specific format is used for conducting and recording vessel Yes
inspections.
A standard checklist for performing and recording vessels’ inspections is included in the SMS. It
contains all necessary items related to hull, tanks, bridge, deck-engine machinery and automation,
etc.

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.

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12A Measurement, analysis and improvement
Stage 1
12A.1.1 The company has established a consistent audit format and process. Yes
A standard checklist for performing and recording vessels’ audits is included in the SMS a
controlled document. It contains all necessary items related to hull, tanks, Bridge, Deck-Engine
machinery and automation, etc.

12A.1.2 All auditors are appropriately trained and certificated. Yes


Assessments/Audits are conducted by properly trained individuals with recognizedcredibility,
experience and expertise relevant to the operations being assessed includingexpertise from
outside the immediate unit.

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.

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Stage 4
12A.4.1 Audit results drive continuous improvement of the management system. No

12A.4.2 The company identifies trends by performing a formal analysis of audit results No
at least annually.

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