ABS Guidance On ISM Code Clause 1 2 2 2

Subject: Guidance on the Revised ISM Code Clause 1.2.2.
2
At MSC 85, IMO adopted a number of amendments to the ISM Code that will enter into force on
1 July 2010. Among these changes was a revision of clause 1.2.2.2 which introduces for the first time
a formal requirement for companies to assess the risks to ships, personnel and the environment
arising from their shipboard operations.
This revision has prompted the following questions:
1. How should companies respond and what should they do to demonstrate compliance?
2. How should auditors interpret the new requirement and what evidence should they look for to
satisfy themselves that companies have addressed it adequately?
General
1. The amendment makes explicit what was already implicit in the Code, since it is not possible
to comply with many of the Codes provisions without carrying out some form of risk
assessment despite the fact that prior to the introduction of the amendment there was no
specific requirement to do so. The documented procedures that underpin a management
system are essentially sets of controls to be applied to the risks inherent in the companys
operations and activities. The company cannot establish what those controls should be without
first identifying the hazards associated with each operation and then evaluating the
corresponding risks. To that extent very little has changed.
2. The amendment considerably strengthens the Code by establishing a proper basis for a
companys procedures and by providing an opportunity to encourage companies to adopt
more informed and more responsible approaches to operational risk assessment.
3. The specific requirement to carry out risk assessments should not be interpreted as meaning
that companies must employ a single, formal risk assessment methodology. They may adopt
many different approaches ranging from the most detailed quantitative evaluations to much
less formal qualitative assessments based on table-top exercises or direct observation of the
activities concerned depending on the nature and complexity of their operations. In the case of
a simple, straightforward activity an assessment made on site by a supervisor with appropriate
levels of authority and experience may be sufficient provided that evidence is available to
show how and when it was carried out.
4. The extent to which individuals on board and ashore are involved in and have responsibility for
the conduct of risk assessments will depend on the way in which responsibilities, authorities
and competences are distributed within their organizations. Even companies that are engaged
in similar operations and have similar organizational structures may decide to use different risk
assessment methods.
5. Regardless of how they choose to conduct their risk assessments, companies must ensure
that they can demonstrate that they have carried out a systematic examination of their
operations, that they have identified where things may go wrong and that they have developed
and implemented adequate controls. Where appropriate a company may decide to rely on
generic industry guidance.
6. Companies should ensure that their policies concerning risk assessment are documented; that
the associated responsibilities and authorities are clearly defined; that adequate training and
guidance have been provided to individual members of staff according to the extent and level
of their involvement in the risk assessment process; that procedures and instructions are in
place for the assessment methods chosen; and that records of the risk assessments carried
out are maintained.
7. Records may take many forms including minutes of meetings, observation notes, hazard
registers, risk matrices and so on.
Guidance for auditors
8. Auditors should not insist that companies have detailed procedures for the application of
specific formal risk assessment methodologies in all circumstances and on all occasions. To
force them into adopting particular approaches that they feel are inappropriate or for which
they believe there are better alternatives will almost certainly create a resentful compliance
mentality and reduce risk assessment to a mechanical, bureaucratic, box-ticking exercise that
will do nothing to improve safety and pollution prevention.
9. Auditors should consider the revised clause 1.2.2.2 as a general background requirement
similar to those in the remainder of clause 1.2.2 and in clause 1.2.3. In other words, it should
be treated not as a discrete activity to be audited in isolation but as a provision that underlies
and supports the entire Code.
10. As when auditing other operational requirements, auditors should not set out with preconceived ideas about how companies should comply with this provision. They should adopt a
reasonable and practical approach to determining whether the company has addressed the
management of risk in a professional and conscientious manner.
Specific guidance relating to the period immediately following 1 July 2010
In many cases auditors visiting ships and offices immediately after 1 July 2010 are unlikely to find
evidence of detailed and comprehensive risk assessments carried out in support of long-standing
operational procedures. It is recommended that auditors respond in accordance with the following
general guidelines.
It is not necessary to examine in great detail all assessments relating to existing procedures
and instructions that are evidently comprehensive, thorough and effectively implemented. Lack
of documentary evidence for such assessments should not cause undue concern during
audits conducted in the first six months after 1 July.
Where an operational procedure is identified as being inadequate and there is insufficient
evidence of risk assessment to support it but the problem is not serious or extensive enough
to warrant a major non-conformity, an ordinary non-conformity should be raised in the usual
way quoting the new requirement.
Companies must have established documented policies and procedures for operational risk
assessment by 1 July 2010. However it may not be possible for them to undertake
retrospective risk assessments for all of their existing operations and activities by that date. In
such cases, where the number of missing or incomplete assessments is significant, a nonconformity should be raised and a note included in the report to the effect that if a similar
situation is encountered during subsequent audits it will result in a major non-conformity. The
note should also state that, if the company fails to address the present non-conformity, it may
be upgraded to a major non-conformity.
Where, after 1 July 2010, a company cannot provide any evidence that it has even begun to
address the requirement (no policy, no defined responsibilities and authorities, no procedures
or guidance, no training, no evidence of any risk assessments, no plan for implementation)
then a major non-conformity should be raised. The major non-conformity may be downgraded
on receipt of a plan of action to address the deficiency and should be followed up in the usual
way in accordance with the provisions of IACS PR9.
Page 2 of 2

ABS Guidance On ISM Code Clause 1 2 2 2

Uploaded by

Copyright:

Available Formats

ABS Guidance On ISM Code Clause 1 2 2 2

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

ABS Guidance On ISM Code Clause 1 2 2 2

Uploaded by

Copyright:

Available Formats

Subject: Guidance on the Revised ISM Code Clause 1.2.2.

You might also like

Pfad - The Proxy pFad of © 2024 Garber Painting. All rights reserved.