Inspections and audits

The five lines the 2010 ISM Code amendments left in the internal audit interval and the risk assessment wording (MSC.273(85))

An ISM Code amendment resolution does not reprint the new text in full. It writes instructions such as replace the existing paragraph 12.1 with the following, or delete these words from paragraph 10.3. Read the resolution alone and the amended sentence is not visible; read the consolidated Code alone and which resolution changed what, and when, is not visible.

This article covers resolution MSC.273(85). The amendments were deemed accepted on 1 January 2010 and entered into force on 1 July 2010. The annex holds twelve instructions, and the ones that reach shipboard work directly are the internal audit interval, risk assessment, the master’s periodic review, prevention of recurrence in corrective action, and the wording of the critical equipment paragraph. Each section quotes the instruction and then reads the paragraph as amended.

The internal audit interval cannot exceed twelve months and gains three more only in exceptional circumstances

12.1 The Company should carry out internal safety audits on board and ashore at intervals not exceeding twelve months to verify whether safety and pollution-prevention activities comply with the safety management system. In exceptional circumstances, this interval may be exceeded by not more than three months.

Paragraph 12.1 sets the interval at not exceeding twelve months and names both places, on board and ashore. What the internal audit verifies is whether safety and pollution-prevention activities comply with the safety management system. In exceptional circumstances the interval may be exceeded, but by not more than three months. Twelve months plus three is the ceiling between two audits.

The twelve months run from audit date to audit date, not by calendar year. The exception stretches the interval; it does not skip an audit.

9 In paragraph 12.2, the words “efficiency of and, when needed, review” are replaced by the words “effectiveness of”.

In 12.2 the words efficiency of and, when needed, review became effectiveness of. The yardstick moved from efficiency to effectiveness, and the conditional wording about reviewing only when needed disappeared.

Risk assessment is now written into the objectives

.2 assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards; and

This sentence replaced the former 1.2.2.2. Assessing all identified risks and establishing appropriate safeguards became part of the company’s safety management objectives. The subjects of the assessment are ships, personnel and the environment. With this wording in place, risk assessment is no longer an optional activity but one of the objectives listed in section 1.2 of the Code.

1 In paragraph 1.1.10, the words “and includes” are replaced by the word “or”.

In the definition at 1.1.10 one connective changed. and includes became or, so a definition that needed both conditions became one satisfied by either. The resolution does not print the full paragraph, so the amended definition is read in the consolidated text.

The master’s review of the safety management system became periodic

3 The word “periodically” is added at the beginning of paragraph 5.1.5.

Paragraph 5.1.5 sits in chapter 5 on the master’s responsibility and authority. With periodically added at the front, the master’s review of the safety management system became a recurring task. The resolution sets no period. How many months apart is for the company’s safety management system to set, and the record of it becomes evidence in internal audits and external verification.

The shipboard operations and emergency preparedness paragraphs were rewritten in shorter sentences

7 SHIPBOARD OPERATIONS The Company should establish procedures, plans and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of the personnel, ship and protection of the environment. The various tasks should be defined and assigned to qualified personnel.

Chapter 7 changed from its title down. Development of plans for shipboard operations became shipboard operations, and what the company establishes is procedures, plans and instructions, with checklists where appropriate. The subject is key shipboard operations concerning the safety of personnel, the ship and the environment. The second sentence has the tasks defined and assigned to qualified personnel.

8.1 The Company should identify potential emergency shipboard situations, and establish procedures to respond to them.

Paragraph 8.1 came down to two actions: identify potential emergency shipboard situations, and establish procedures to respond to them.

Corrective action gained prevention of recurrence and the critical equipment paragraph lost its detour wording

9.2 The Company should establish procedures for the implementation of corrective action, including measures intended to prevent recurrence.

Chapter 9 deals with reports and analysis of non-conformities, accidents and hazardous occurrences. Paragraph 9.2 has corrective action procedures include measures intended to prevent recurrence. Fixing the symptom without the cause does not satisfy this paragraph. Paragraph 4.14.3 of A.1118(30) adds that failure to take adequate corrective action, including measures to prevent recurrence, may be considered a major non-conformity.

7 In paragraph 10.3, the words “establish procedures in its safety management system to” are deleted.

Paragraph 10.3 is the one on critical equipment. With establish procedures in its safety management system to deleted, the sentence moved from the company establishing procedures in its system to do something, to the company doing it directly. The resolution carries only the deletion instruction, so the full text of 10.3 as amended is read in the consolidated Code.

Chapters 13 and 14 were touched as well

Instruction 10 added 13.12, 13.13 and 13.14 to chapter 13: the validity of an SMC renewed after expiry, the five-month endorsement when the new certificate has not reached the ship, and the three-month extension to reach the port of verification. Those three paragraphs are worked through in the article on the DOC and SMC verification windows.

11 In paragraph 14.4.3, the word “internal” is inserted after the words “planned the”.

Paragraph 14.4.3 is one of the conditions verified before an Interim SMC is issued: whether the company has planned the audit of the ship within three months. With internal inserted, that audit is clearly the company’s own internal audit. The internal audit set by 12.1 has to be scheduled within three months at the interim certificate stage.

Worth confirming

This article covers only the instructions in MSC.273(85). The full sentences of 1.1.10, 10.3 and 12.2 that those instructions change are not printed in the resolution and are checked against the consolidated ISM Code. The resolution is the set that entered into force on 1 July 2010; later amendments are not covered. The date of the ship’s last internal audit, the planned date of the next, and whether the three-month exception has already been used are where the actual judgement starts.

You can consult the cited source documents

These links lead to the official publishers of the documents discussed here. Match the edition and provisions cited in the article, and check subsequent amendments and flag-state implementation before applying them.

Bellbook keeps an internal audit date on every ship and surfaces it before twelve months run out

The internal audit interval starts counting from the last audit date. Bellbook tracks the month the next audit opens on a twelve-month cycle from the vessel audit record, and keeps risk assessments per task with their approval and validity attached.

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