Reporting and Analyzing
Any employee that is involved in or witnesses an accident, near miss, hazardous occurrence
or non-conformity shall at least verbally report this to his head of department (e.g. Chief Officer, Chief Engineer or Master) or the company.
The relevant head of department or Master shall use all available information to complete an
incident report and take whatever action is necessary or possible to correct the situation immediately, at least as a short-term measure. The case will be analyzed by the responsible person in the office together with the Master or Head of Department. Corrective actions shall be
agreed if applicable and forwarded to the DPA for review.
The handling time for any case reported shall not exceed more than 1 month without any
action.
A copy of the reporting form shall be retained on board. In case of injured persons, the relevant accident report shall be attached to the incident report as per Flag State requirements.
After analyzing the report, the company shall determine which department is required to discuss and implement appropriate corrective actions if applicable.
Corrective & Preventive Action
The Designated Person/Substitute Ashore and/or the appropriate department heads (e.g.
Master/ DPA) will investigate all non-conformities, hazardous occurrences, near misses, accidents or suggestions found in the Company’s office and onboard the Company’s vessels, in
order to determine the nature of the cause. The DPA maintains and reviews records of all
incidents for the analysis of trends or repetition. The results of the analysis may be used to:
Port State Control (PSC)
All PSC Reports must be sent to the responsible inspection team and ISM Department. For
analyzing purposes each deficiency raised in a Port State Control (PSC) will be inserted in the
company’s database. In addition to this the Master must fill in a Corrective Action Plan for all deficiencies, even though they are rectified during the inspection with detailed
information about the root cause (why the deficiency occurred) and corrective actions implemented on board. Documented evidence, like pictures, delivery notes, requisitions etc., confirming that the deficiencies are rectified shall be send to the office (ism dept. + inspection)
with PSC Report and CPA-Plan. The Company will verify this report and considers long term
preventive measures which will in turn be implemented, if necessary, in due course.
By issuing the we consider this enough to comply with Element 9 of the ISM Code and no
further Non-Conformity Note is required. The report needs to be sent as soon as possible to the
office (ISM Dept. and Inspection Team) for review. Picture and/or other documented evidence
shall be available and may be requested by the Office.
This report may be used as evidence for third parties. Any PSC Report will be forwarded to the
respective administration as per their reporting requirements. Should a vessel have been
detained by a PSC Officer the applicable administration has to be informed immediately by
the company – latest 24 hours after the detention occur.
It is the obligation and responsibility of the Company to deal with PSC reports in relation to
third parties and to send the report to the administration.
The above will not relieve the Master from his responsibility to report to the relevant PSCO if
so requested (like for code 17 deficiencies).
Class survey
Findings during surveys and Inspections shall be closed within the required timeframe. For
example, a non-closed condition may lead into loss of class, thus the vessel cannot sail. It is
the obligation of all involved parties (Master, Office) to ensure timely correction and closing
of such findings.
In case of identified ISM deficiencies during surveys the vessel and Inspection group shall be
informed about the root cause and actions taken by the company within a reasonable
timeframe.
ISM failure report by Class
When deficiencies possibly affecting the implementation of the ISM Code on board are
identified by the surveyor during a Class Survey or occasional Class Survey, Statutory Surveys, additional surveys relevant to Port State Control, Flag State Inspections or any other
occasion, a Report may be completed by the attending surveyor. The report shall be handed
over to the Master on board.
The report must be sent to the office immediately after receipt.
A report may lead into additional ISM Audits and surveys. The reports will also
be filed in the Office and reviewed during the Management review and annual office Audit
In cases a report was issued on board a special form is to be completed and sent to the office.
Flag state Inspections
Findings during FSI shall be rectified within the required time frame. It is the obligation of all
involved parties (Master, Office) to ensure timely correction and closing of such findings.
An additional report is not required. The master must confirm in written with signature on the
form itself that mentioned items are rectified.
The company does not require any NC note, form or other reporting. In any way the
DPA´s will review the report and, if necessary, initiate further action and request for additional
documentation.
Near Miss reporting and guidance
Purpose: Most safety activities are reactive and not proactive. Near misses are to be considered as a tool to help improving the entire safety on board the vessels as very often near miss
incidents show improvement which can be achieved easily but were largely ignored because
nothing happened (no injury, damage or loss). Therefore, many opportunities to prevent accidents or dangerous situations are lost. Recognizing and reporting near miss incidents can
make a major difference to your safety and daily operation.
The company ensures that nobody is going to be blamed when reporting a near miss.
IN REPORTING NEAR MISSES, YOU SHOULD USE COMMON SENSE AND THE MAIN QUESTION
SHOULD ALWAYS BE:
What can we do to avoid that this event; will it cause an accident or a worse situation in the
future? Is this information useful for the whole fleet? Can we implement measures or equipment?
Further guidance can be obtained in the ISM-Code or in the IMO Circular: MSC-MEPC.7/Circ.7
Company’s definition of near miss
A near miss is an event that might cause or caused already a hazardous situation that might
have been avoided by additional measures which are not yet in place.
Not all circumstances can be covered by procedures and instructions and require knowledge,
experience and common sense.
The company divides two different near miss situations:
I) A minor incident on board where a safety meeting or briefing is considered as fair
enough by the Master (Category I)
II) A moderate or higher value incident which is worth to inform the fleet or sister ships
in order to avoid worse scenarios in the future and additional action from above is
required
Reporting of damaged or broken-down equipment
Defects and defaults on equipment that is affecting any statutory certificate and which
cannot be solved right away and need spare parts, service or assistance from the Inspection Department, have to be reported via the Failure Report F-10a.
In advance please find a list below of the equipment of which the company needs to be informed:
In all cases the responsible Superintendent shall contact the respective administration for
further advice / action (LONO, Exemption Letter, Dispensation Letter).
No reporting of above is a non-fulfillment of SOLAS Chapter I, regulation 11c and may lead to
detention during Port state control.
Reporting of other damages
Damages to the vessel need to be reported to the company as well.
Material damage which may require Class attendance; any stranding, collision, fire, explosion
or major breakdown incl. Blackout; any incident causing harm to any person or the environment; any safety or security related incident which could possibly hazard the ship or endanger
personnel or create a risk to the environment.
Examples:
Collision with locks, piers, buoys or similar
Black outs during pilotage or in narrow waters
Fire during welding, cutting or similar - even small ones.
A root cause will be carried out afterwards taking into account the level of damage and nature of incident.
Reporting to Class
Class related H&M damages need to be reported to the recognized organization as soon as
possible in order to obtain a condition for the defect. It is the obligation of the vessels superintendent to inform all relevant parties in due time and arrange for necessary action.
If a TP, dispensation letter or other exemption was already granted by the administration Class
need to be informed only if required by those.
Risk Assessment
The Master, Officers and Engineers of the ship are responsible for periodically conducting a
review* of the risk assessments. Identified hazards or if the situation requires implementing
the defined risk control measures the Company must be informed about same and about the
implementation status on board. The company will amend the general risk assessments accordingly which must be available on board.
The Company provides general Risk Assessments in a folder and will review and update the
same annually if necessary.
The Risk Assessment process must be performed in a systematic manner and may follow a
step by step approach. The Risk Assessment shall be initialized before implementing new processes or non-routine tasks and while reviewing existing processes.
Person in charge of the Risk Assessment must ensure that the Risk Assessment and controls
are effective and up to date. However, the Master bears the overall responsibility.
Since a Risk Assessment is intended to reduce the occurrence of hazardous events, such occurrences might indicate weakness in the way risks have been assessed or in the way controls
have been designed, implemented or monitored.
Review:
Any risk assessment should be reviewed before implementation. Further, the Risk Assessment is a continuous process. Hence, written Risk Assessments should be subject to periodic
reviews to confirm the validity of the assessment and whether the risk controls are still effective and adequate or if significant changes to working practices, environment or equipment
are applicable. Changes in the “normal” Conditions require a review.