The Sindhuratna Accident: A System Failure in the Indian Ministry of Defense

Resignation of the CNS (Chief of Naval Staff) of the Indian Navy (IN) a System Failure:

In the August 30, 2013 blog I wrote about the explosion on board the INS Sindhurakshak, a Russian built Kilo class submarine as a part of the Indian Navy submarine arm and the tragic death of 18 of its crew. My assessment of this being a system failure is now quite substantiated by the ill-fated accident on the INS Sindhuratna, another Russian built Kilo class submarine, which took the lives of two officers, and consequent resignation of Admiral DK Joshi as the CNS. I knew DK personally; we were students in the ASW specialization training in Cochin. A very fine upright officer let down by a failed system. Dr. Deming said: “a bad system will let down a good man every time”.

The ill-fated Sindhuratna was commissioned into the Indian Navy on November 19, 1988. The Russians operated the boat for about a year on trials and weapons testing before handing it over to India. On the date of  the accident the sub had effectively been in service for 26 years. These boats  are usually sent for a half-life (10 to 12 years) refit to Russia or done by the Indians in Vishakhapatnam, depending on the capacity of the dockyard. The major refit virtually rebuilds the submarine from its casing to the pressure hull. All hull valves are serviced and/or replaced and where advances have taken place new weaponry and sensors are replaced. The sub after such a refit is good for another 10 years. The pattern is similar to ships in the mercantile marine where the full term certificate is issued for 5 years (Clause 13.7 of ISM Code) and the ships maintained accordingly. Today most good ship registries as the Liberian ship registry will not register a vessel older than 20 years. However the Indian Navy squeezed out another two years of service from this boat. And finally the active life of this submarine ended in December 2013. Yet the submarine was operating…

The Achilles heel in a conventional submarine is its set of batteries. A Kilo class submarine is driven by 240 batteries, each weighing 800 kilograms. The batteries provide a service life of 200 fully charged to fully discharged cycles or exactly 4 years whichever comes first, and then they are due for change. The older batteries do not provide the juice necessary for running under water, require frequent charging, and emit excessive hydrogen and pollute the atmoshers inside quickly. The chlorine vapors and leaking electrolyte are hardly congenial to creating the safe work environment for performance as a warship (ISO 9001:2008 clause6.4).

 The Sindhuratna's batteries in use had completed their life cycle in December 2012. Lack of planning, and incorrect implementation of a system approach to managing such a vital arm of the Navy is adversely affected by a non-committed incompetent top management (TM) both at the ministerial level and at the administrative level. Even if the IN is projecting these requirements the TM still rests in the ministry where the defense minister may not even understand the nuances of the requirements. Further, interference in the safety levels occurs when the national operational requirements remain unchanged in spite of the navy’s underwater arm being  hugely depleted. This result in the IN pressurized to stretch the service life of these aged submarines with batteries which are a ticking bomb. In this particular case, it is reported that the  Sindhuratna underwent a minor refit over the last four months and it was on its first sea trial or Task 2 sea examination before it could be re-inducted into active service. It was however at sea with these batteries whose service life had expired! Batteries which should have been junked 15 months ago. Has not the IN had accidents or near misses before related to old batteries? 

So the question is why are the submarines being sailed in this state? Why were the batteries not replaced timely? Surely the CNS would have asked for these from the Ministry of Defense (MoD). The Defense Minister (DM) needs to understand the part that batteries play, even if he is just a political head, he needs the administrative organization to explain this to him and meet the Naby’s requirements. The ship didn’t get new batteries because the procurement process of the MoD failed. It perhaps did not take the CNS’s inputs correctly. When repeated accidents occur, the CNS is aware more accidents will follow because the system in the MoD has failed. He however has no recourse or face to show his men as to why he is sending them out in unsafe vessels. Thus his resignation.

A system which is failing needs to recognize the root cause of the failure. Who is responsible for this sad state of affairs? Clearly the MoD. Battery projections for the submarines are not made at the last minute. Naval Headquarters (NHQ) processes these requests timely and at least 3 to 4 years in advance. In any case battery requirements are periodic and well known to a country which has been operating submarines since 1967. The fleet is required to have a set of batteries as a reserve. It is therefore a system failure at the national level. Authorities higher than the CNS need to take responsibility and then the new incumbent should look at the system failure. There is no room for politics in such matters of national importance. If the nation’s defense forces lose faith in the system, then the loss of morale cannot be far away. “Morale is to physical as two is to one” - Napoleon. 

There is an urgent case for studying the system that runs the navy. The resignation of the CNS is a good example but not the solution.

Training: A Luxury or Strategic Necessity?

Well-developed management systems are developed and implemented to drive efficiency in organizations.  These systems when implemented ensure that  the organization does not become vulnerable or lose its integrity when key personnel change as also during any mergers and splits in organizations. Just as technology is constantly upgraded, so must human potential. In any organization, large or small, training which needs the least investment can play a very important role given the critical contribution by human resources in ensuring efficiency. The necessity of training in building human potential and productivity to ensure optimization of human resources can hardly be emphasized.  

Top Management often go in for implementation of management systems without answering the employee’s question of “what is in it for me?” Training and exposing 10 to 15% of the manpower to management system related standards for efficiency (ISO 9001), risk management (ISO 33000), the environment management (ISO 14001) and security of the global supply chain (ISO 28000) quite prepares them for the system implementation. Some  organizations might choose to implement an integrated management system encompassing all or a combination of two or more of the above standards.

Organizations view training as a luxury and often not as a strategic necessity. A well trained manpower is a great asset in getting the “job done” . When budgets are cut training is often given a low priority. In difficult financial situations when all else costs the organizations so much more, a little investment in well trained manpower results in rich dividends and ensures human capital continues operating at their peak efficiency as a motivated work force even through bleak periods thus ensuring a continually efficient system. As a system is developed and put into place a trained workforce helps to better implement the system and results in a ‘buy in’ of the entire team. A team that appreciates the important role that a well implemented system plays in increasing the efficiency of a system while reducing non-conformities (NC).

As NCs are embraced to drive continual improvement the number of problems affecting the system reduce and the work force has its answer to "what is in it for me". This gives the organization strength in depth and provides more time to innovate and thus continually strive for new heights of excellence.

The benefits of training are intangible but below are listed a few: 

• Better output

• Higher Retention 

• Team Spirit 

• Improved corporate Image 

• Higher morale 

• Improved Profitability 

• Fewer Accidents

A small investment in training will ensure an oriented manpower, familiarized and ready to implement and meet the management’s system objectives and align them with the organizations aim of doing much more with much less.

Comments on CEO Transocean admitting to mistakes related to the tragedy of Deepwater Horizon

In a recent article in the Maritime Explorer, "Transocean Ltd. CEO Steven Newman said the company’s crew on the Deepwater Horizon “should have done more” to prevent the rig’s 2010 explosion in the Gulf of Mexico". http://www.maritime-executive.com/article/Transocean-Should-Have-Done-More-Before-Blowout-CEO-Testifies-2013-03-20/

This is indeed a pleasant change and in a way a pioneering effort for which Transocean's CEO needs to be congratulated. The maritime industry, in general, avoids taking blame. There are reasons for that wherein for example P&I clubs do not really pay unless someone is blamed. A bad system will defeat a good person every time” – W. Edwards Deming.  This reminds me of a quote from the Cain Mutiny, which in essence says, “Navy is a master plan devised by the genius for execution by idiots”.  This master plan is the system, which should be so created that there is no need to blame the individual.  Every time the system fails, the management reviews and acts to work on the procedures that comprise the system.  Improve the system enabling better protection of the individual. It is ironic that individuals who are assigned the designing and then implementing of the system often consider it a burden – little realizing that the system approach takes management away from asking, “Who” to asking, “How and Why”.  This results in further development of the system rather than blaming the individual who was simply working within the system.

In this article, however,the CEO talks of both good people and a good system. I agree with the good people bit. In any case if analysis reveals that the employees lacked competence or were negligent it would again point to the system, meaning the weak HR (Human Resources) procedures which hired incompetent personnel. So it is always the system which lets down the organization. So my objection and suggestion to Transocean (for that matter any maritime organization) is not to say that their system too was “wonderful” but to re-look at the system and analyze how the system let down the personnel they selected. I have a quote which I use when I work with organizations as I develop their systems as a consultant and that is “the only bad NC (Non Conformity) is the one you do not know about”. The system therefore should be created with the environment matched to encourage NCs to be reported. After all corrective action and correction are NC driven. And as the NCs collected contribute to the data base increase, they will provide the information which can be analyzed and trends obtained to predict potential NCs. The company becomes a mature organization when it can predict potential NCs before they occur. Potential NCs are data driven. Therefore Transocean needs to work towards that end. So, yes the CEO has indeed taken a very positive step by accepting the deficiencies and will no doubt now look ahead to going back to the Plan stage of the P-D-C-A cycle (Plan Do Check and ACT) and review the system.

Stop Work Authority and the ISM Code

A QMII alumni recently sought my opinion in interpreting the ISM Code with an interesting question.  I am sharing my reply in generic terms for the benefit of my blog readers:

Does the ISM Code refer to a policy to Time Out For Safety (TOFS) or Stop Work Authority (SWA)? A reference of the same to the ISM code being implied by the the United States Department of Justice

A stop work policy basically requires any crew member on board to self-assess and if he/she feels an operation is unsafe the crew member can stop it until further investigated and cleared by the safety officer/TM. Although there is no specific mention of a stop work policy in the ISM Code, it has its genesis in Clause 1.2.2.1 and Clause 2.1 of the Code. In interpreting the ISM code implementation from the company point of view the objectives & functional requirements are squarely the company responsibility. If a company has any doubts about the implementation of any policy likely to result in a lapse, it is imperative that it make policies which clear this doubt.  

Clause 2.1 in the tail end carries the sting asking “…how the objectives given in paragraph 1.2 will be achieved”.  It is thus, in my opinion, incumbent upon the company to provide a policy on and encourage the  stop work policy requirement to ensure the safety of operations and a safe work environment. 

I may add that, in general the ISM Code in itself is brief, flexible and open to interpretation by the company and Flag State. IMO itself in Resolution A.1022(26) provides the guidelines on interpreting the Code. These must be read in conjunction with the code. In the introduction to the Resolution paragraph 3 requires the Administration to ensure companies amplify on clause 1.2. The next paragraph requires the “development of a safety culture…” implying amplifying instructions, as for example TOFS, should be provided by the company.

As companies mature to the development of the safety culture by welcoming NCs (Non-Conformities) as the driving factor for Correction and Corrective Action (based on RCA- Root CauseAnalysis), the interpretation of the clause 9.2 of the ISM Code requiring “measures intended to prevent recurrence” would necessitate the culture which again encourages the stop work policy.

Security and Training – Intrinsically connected

A Process-Based approach to security based on training

One could conclude that the process-based approach where implemented correctly should ensure efficiency and lead to ‘cash in the bank’*. The ‘people>processes>system approach’ *  based on the international standard ISO 9001has been well tried, as the global economy has come closer necessitating standardization of procedures to ensure systems don’t conflict and adversely affect efficiency. Economy today is globally dependent and the process approach brings a system approach to it. Using the approach, one would think organizations would ensure continual improvement, innovate and grow the organization. The process approach as envisaged in the ISO 9001 however leaves out the risk aspects, pollution and the by-products of a process! To stay in business therefore the organizations implement the global standard ISO 14001 encompassing the Environmental Management System (EMS) requirements in addition to the Quality Management System requirements (QMS).

Consequent to the tragedy of 9/11, the post 2001 scenario underwent a negative sea change. Lack of security could wipe away the business totally! It is not that security was not a concern pre-2001; however, the vulnerability of the very symbols of American economic power changed the international equations, which adversely affected the business continuity. If the only superpower on earth was vulnerable and unable to protect its economic center from terrorists then it required a drastic change in the priorities of the business if they were to remain viable. It changed the priorities of the government’s worldwide. For a business to remain sustainable, ensure continuity it was not just essential to be process based and ensure pollution control, environmental protection, be risk based and catering to the by-products, but also of the utmost importance to ensure security of the business. Security became a prime concern. All investment in business can be lost in a moment if a security breach takes place.

The maritime industry is intrinsically involved with the world economy, in that more than 90% of world trade is by vessels trading the globe. The maritime world had its process approach to safety and pollution prevention covered by the SOLAS convention published and implemented as the mandatory ISM Code. Pollution aspects of vessels are specifically addressed by the MARPOL convention. The security uncertainty post 9/11, quickly lead to the implementation of the mandatory ISPSCode for all internationally trading vessels and for the ports where these vessels came in. With the implementation of the ISPS Code, the maritime assets are protected.

The global supply chain is however, not limited to the maritime assets! The concept of maritime asset protection needed to be broadened, as the assets were vulnerable to breach both ‘up-stream’ and ‘down-stream’ of the ISPS Code. Breach of security anywhere in the global supply chain could have catastrophic consequences on the global economy. The introduction of the global standard ISO 28000 filled this vacuum and provided the requirements for implementing procedures to create a system to protect the global supply chain.

Ninety percent of the US homeland imports come in by sea. Inspecting such a large quantity has colossal challenges. Only about 3 to 5% of the containers coming, for example are inspected! It is a daunting task for the USCG and CBP. The CBP initiative in terms of C-TPAT relies on partnership with the industry and encourages those trading with the US to make their security systems compliant with these requirements. It is essentially a process-based approach to security aligned and based on the ISO 28000.

Just the planning and implementation of the security requirements is not sufficient. Individual responsibility is integral to security and when combined with the system approach can pay dividends. All the standards be it ISO 9001, ISO 14001 or ISO 28000 or as applicable in the maritime world: ISM Code, ISPS Code or the MARPOL convention, each requires a system approach. It is vital to the success of this approach that the top managements (TM) are conscious of their responsibilities. Other stakeholders, be they owners, operators, auditors, statutory or regulatory bodies, flag State Administrations do their bit, but TM remains totally responsible for security.

This alignment of TM responsibility being paramount has another variance in the security scenario. I think this vital difference needs recognition by all parties involved in the security of the global supply chain. The major difference is epitomized (particularly for the maritime industry) in Clause A/ 19.1.3 of the ISPS Code. The clause is often considered just advisory in the verification process. However, the sting in the clause is applicable to the entire body of security. The clause virtually requires the Flag State to 'guarantee' full proof security following verification by the Administration! No other international or maritime standard requires this assurance from a regulator. All security related industries, not just the maritime industry (who in any case have no choice!) must take cue from this clause as it leads to a fresh interpretation of security responsibilities for all stakeholders in the global (particularly maritime) supply chain. The auditors, inspectors, the involved organization, regulators et al take due responsibility for the security.  To broaden the implications of the thought behind the clause each entity looking at the security aspect must be fully satisfied and guarantee 100% security. No deficiencies/ NCs (Non-Conformities) are acceptable. Howsoever minor the NC it must be addressed promptly. The strength of the global supply chain is defined by the weakest link in it, and as such, the deficiencies need to be completed before any verification certificate is given.

The challenge and requirements are then clear. The question is how is this to be ensured? Perhaps by getting the best available equipment? Hiring top-notch security personnel? Will just the participation of competent professional manpower and best of surveillance equipment do the magic? Alternatively, perhaps the putting in place of the correct procedures to complete the system is the guarantee of an impregnable security system.

                   

What it requires, I think, firstly is the total TM commitment, to ensure and motivate their teams by care and coordination to ensure the security system works. The security policy published by the TM should be totally in keeping with the actual security requirements of the organization and based on an in-depth study of the threat perceptions. The policy if well thought over and reflecting the actual of the organizations security threats will then lead to measurable objectives and goals for the security team. The team then can have the organization and procedures aligned and resourced to meet these objectives. Once the procedures are ready and introduced the vital phase of training and training alone will determine the outcome of the desired results. Both prevention in terms of preparing for a security eventuality and the response in consequence to a security tragedy will require the systematic P-D-C-A (Plan-Do-Check-ACT cycle)* approach. A good security plan based on a through security assessment (SA) as it moves to the working phase/ Implementation stage (Do) requires aware leaders leading their team through constant training.

Drills to practice and work the security procedures and build the required confidence level will require regular, well-planned training. Drills must exercise each security element of the global supply chain. The success in drills will then need to be bridged by training to ensure each element in the global supply chain (for that matter the domestic supply chain too) is exercised. The more innovative and realistic these drills and exercises the greater will be the confidence level of the management and employees (as also all stakeholders) in their ability to both prepare and be able to react to a breech in security of the supply chain or any of its elements.

SA is essential and integral to a security plan (SP). However, emphasis on carrying out a detailed and thorough threat perception as a must ‘pre-cursor’ to SA before a SP is made should be part of the system ensuring security. Each security drill and exercise should encompass the elements of ‘lessons learnt’ at each level, finally leading to the TM review. TM must remain involved and committed to the security ensuring continual improvement is taking place and innovation encouraged. It must be remembered that the terrorist organizations recruit and train a very motivated work force on their well-tried methods! These terrorists are often two steps ahead of the security measures the industry takes and are ever ready to circumvent security. The security of the global supply chain can only be ensured by the training system being innovative, proactive and capable of recognizing potential threats to the security. Following up on NC by correction and corrective action is essential, but an indicator of the organization being a step behind the ‘bad elements’. Following up on NCs against the security system at its best can be defined as reactive. The security team will be effective; the security system will function as planned when the indicators point to the capability of the system to predict potential security breaches (NCs) by analyzing security threats and trends from available security warnings, threat perceptions. The occurrence of a NC always costs the organization, however small or catastrophically. However, there is a cost associated.  With good training, the team with its involvement and commitment can recognize the potential NCs and add value to the system protecting the global supply chain and each element in it. The security system must therefore drill and exercise the team members to ensure competence and provide them the ability and confidence level to understand the security system so well that analysis of indicators is carried out with professionalism and correct TM decisions taken to secure the global economy from unscrupulous elements.

DP and a Maritime Company are fined by MCA (Maritime and Coast Guard Agency) in UK- Comment

I received this input from one of the Managers (DP) who attended a QMII DP (Designated Person) class I taught:

“The UK Maritime and Coastguard Agency (MCA) issued a press notice stating that a foreign shipping company and its designated person ashore (DPA) have been ordered to pay £13,152.50 in fines and costs after pleading guilty to breaches of the International Safety Management (ISM) Code. On 19 June 2012, a port state control (PSC) inspector issued a Prohibition Notice requiring entries into ballast tanks be made in accordance with the Code of Safe Working Practices. The PSC inspector returned on 20 August 2012 and noted that improper ballast tank entries were still being made and that the DPA had been present during those entries. (3/13/13).” 

I totally agree that a harsh view should be taken whenever there are clear indications of a system failure. Clause 1.1.10 of the ISM Code clearly defines a MNC (Major Non Conformity), and has a sting at the tail end of the clause mentioning the systematic implementation in the implementation of the ISM Code. The PSC (Port State Control) holding the company responsible and taking a serious view of this lapse is understandable. Entry into enclosed space should be per procedures and any check list the company has incorporated in the SMS. This is sad, that knowing the number people who lose lives due to lack of procedures or not following procedures when entering contaminated spaces and enclosed spaces, companies still compromise and take short cuts. The purpose of the check list under clause 7 of the ISM Code would be lost if it was not to be followed.  It makes it worse when the procedures are not followed even with the DP present. The link emphasized in the clause 4 of the ISM Code is in itself weak! It is not an individual failing but a system failure. What about the Master’s responsibility and commitment? Whenever there is a system failure it amounts to a MNC. And so no surprise that PSC came down hard on the company. I would not have blamed the DP (Designated Person) though. Blame culture leads to weakness in the system. After all if the company has a irresponsible DP, it is indicative of the company culture and the environment they have created which encourages individuals to not follow the system. It may perhaps point to the failure of the hiring system where they perhaps picked a DP with no understanding of the system approach. In each case it is a system failure. The PSC should have penalized the company, and in its objective evidence indicated the presence of the DP as the reason for the seriousness of the lapse.  I will not be surprised if additionally the vessel was also detained. Clause 1.2.2 in its entirety is applicable. When companies do not follow and implement their own objectives they not only contravene the ISM Code but also show a lack of social responsibility.

Why mariners and shipping companies should welcome audits not hate them?

INTRODUCTION

In my experience, Mariners have never been fond of audits! Worst the companies that run the ships have often victimized honest Master’s if during their tenure too many Non Conformities (NC) are reported, even if they relate to resources!  The only bad NC is the one the organization does not know about, and yet the organizations do not want to know!

A NC, comes from an audit and therefore the audit is an unwanted intrusion into the working of the vessel and the company, and now with the VIMSAS (Voluntary IMO Member State Audit Scheme) audits the Flag States have started disliking audits or at the best accepting them as a necessary evil!  NC drives Correction and Corrective Action (CA) and the Preventive Action (PA) is data driven. Wisdom says therefore audits should be welcome, and yet audits are feared.

Even the camaraderie on board a vessel is affected adversely as by the term “audit”- because the truth could be an utterance which gets their colleagues in trouble, or an audit may discover or uncover they are doing something “wrong”. The blame culture in the merchant ships is a reality. Something goes wrong- you blame someone! Why, the P & I clubs may not pay, if blame is not attributable to an individual.  The entire system encourages the blame culture. In this article I want to initiate a discussion wherein the maritime industry shies away from the blame culture and meets the objectives of the ISM and ISPS Codes in operating vessels safely, securely and meeting the environmental requirements. Companies should be lead by Flag States to not ask “who” when things go wrong, but instead lead their inquiries to “why” and “how” of the system failures. Individual failures are a consequence of the system failing to select correct individuals for a job!

TOP MANAGEMENT COMMITMENT

Quality is the responsibility of each individual. Having said that, we should ideally never pass responsibility down the chain of the management to ships and the crews who man them. We may pass authority bundled with resources. Top Management at each level must take responsibility for the system performance. Continual improvement has to be the underlining current. Starting with the IMO to Flag State to the Company and the ship each must be a stakeholder in the system working. Lack of care and coordination by the Top Management (TM) is roughly 90% responsible for establishing an environment of fear for audits.  By using the system and being participants in it at each level the system operators will use and improve their system, ensuring everyone understands that identifying opportunities for improvement (recognizing problems/ NC) will never be met with harshness or punishment; on the contrary, they will be valued.  Through this development of the system, a confidence emerges that the system will allow its people to produce outcomes, which meet requirements. The system will enable sailing ships of all kinds with the numerous cargoes across the globe fulfilling the demands of the economy in a safe, secure, socially responsible manner ensuring and protecting the environment.

It is the mature participatory involved confidence of the TM in itself and those who lead the various maritime procedures and processes, which will alleviate much of the fear and apprehension, associated with audits.  TM have to commit themselves and lead by accepting that audits are a vital input  to be valued for what it is: an independent look at the system to confirm how well it allows its users to meet requirements.  TM as improvement opportunities identified during day-to-day work should then welcome any findings.

The other 10% of the solution resides with the Auditor/Audit Team.  A well-trained auditor understands that their role (as mentioned above) is to look for evidence of system conformity.  Not of NC! Many a maritime auditor is not qualified and or has not imbibed the doctrine by correct training wherein the auditor should seek conformity and not go on board with the aim of somehow finding a NC. Where the system does not appear to meet requirements, the auditor must serve the audit client by providing detailed, objective evidence explaining why not.  Maintaining this integrity gives the Auditees no reason to feel defensive or that they have any reason to fear this valuable interaction. TMs must demand qualified auditors to perform audits.

SOME REASONS FOR TM’s LACK OF COMMITMENT

As, to an extent, mentioned above, the poor quality of maritime auditors is one of the reasons for a lack of TM commitment. A large force of the maritime industries auditors comes from mariners. They merely, because they are mariners and understand the environment and the industry become auditors. Like any profession, auditing has its own concepts and training. It is a science mixed with an art. It requires ethics and maturity wherein the audits are performed to meet the objective not an ulterior objective. This can be a challenge considering the global nature of the industry. Maritime Quality experts have not created the opportunities to assist their leaders in appreciating how the bottom line is positively affected by addressing NCs and better still predicting potential NCs and changing processes before a NC occurs. A process based system, as required by both the ISM and ISPS Code (as also the ISO 28000 standard), basically based on the ISO 9001, will ensure the system does not even wait for audits to recognize NCs. Too many of the TM would rather delegate their responsibility for ensuring quality instead of the authority to make it work. The TM commitment cannot be championed by anyone except the TM. It is the TM who have to walk the talk and lead the employees in developing and using the system. When have we had a company or a Flag State actually declare the state of the safety and security implementation to the employees, customers and other stakeholders and how they plan to improve it?

It is only when the maritime professionals commit themselves and use the process based management system to implement policy and the (measurable) objectives in the organization by ensuring the interactions as required by the ISM Code will the cross functional teams use the resources to best advantage.

Management systems are instinctively understood and respected by organizational leaders when they show how the core process converts the needs of customers into cash in the bank, while the support processes sustain the core process. Leaders can then explain the obligations and benefits of their system to the employees.

SELECTION, INVOLVEMENT AND RETENTION OF MARITIME MANPOWER

Another issue that the maritime industry has is the shifting and uncertain man-power situation. Companies are never able to retain those who serve at sea, these results in often, non-committed mariners, who come on board to do their tenure and not use the system. They are individuals only committed to themselves! So the companies are committed to themselves! The plot thickens when auditors are brought in. Teamwork using a process based system requires total commitment from each link in chain starting with the seaman to the Captain and on to the TM at company and Flag State level. Further, it requires the commitment from charterers, customers, P&I Clubs, PSC (Port State Control), supplier and so on. There is an element of social responsibility too involved. This combined commitment can only come with stable man-power. The industry therefore, may as a RCA (Root Cause Analysis) of many of its problems, find that retaining stable work force at sea may be one remedy to bring in commitment. Then and only then can each member of the team be held responsible including the TM, for delivering the desired results, meeting the objectives and improving efficiency.

Auditing should not substitute self and supervisor monitoring. When auditors are the only eyes for the management it is an inefficient state and indicative of the system failure. The Master at sea, the managers in the shipping companies office- particularly the DP, CSO, Superintendent and so on and those responsible for these duties at the Flag State level should all be supervising and be the first set of eyes. Monitoring should involve  the people who do the work and supervise the work and it is they who should be  observing how well their processes are fulfilling their objectives. The first set of NCs coming from internal sources will remove the fear of audits. Monitoring is therefore essential for quickly correcting processes that deviate beyond their normal range. Process monitoring should result in fast improvements so the system helps employees even more to determine and meet the process requirements. It is organizations which lack the culture of the system approach who blame individuals for all their flaws and faults and then rely on the occasional visit by their auditor. Is it any surprise that this visit is feared!

INVOLVING THE TEAM: AT SEA AND ASHORE

Clause 12.1 of the ISM Code 2010 now necessitates at least an annual internal audit. It had to be rubbed in, why? The audit would not be the only means, if the spirit of clause 12.2 of the code had been implemented with enthusiasm,  to evaluate the effectiveness of the system. Further if the results (clause 12.5) of the audits are required to be brought to the notice of all, it would invove every member of the team. In all this the company is trying to meet the objectives as required by clause 1.2.1. The feedback of facts and problems must flow and the system must use it as an input to improve the system continually.

The company must involve the employees by ensuring the system encourages self monitoring and employee suggestions, the management reviews are an integral part of the system and the results/ outcomes shared widely. Further customer feedback, as also feedback from other stakeholders must be an input to the management review. Nonconforming products and audit reports should be considered as an input to improve the system

FEAR OF AUDITS INDICATES A DYSFUNCTIONAL SYSTEM

The very first indication to management of a dysfunctional chain is the undercurrent fear of audits in the system chain of management!  Further systems that need and totally rely on auditors to be effective are dysfunctional. The system is the responsibility of TM. They need to know how well the system is helping them and their employees to determine and fulfill objectives and other requirements. By demanding that auditors supplement the flow of information from their system they are short-circuiting, this vital process and consequently weakening their systems. Dependence on auditors to improve the system is a major flaw in the mercantile marine, which because of the main asset, the ship, often operating far from their physical location becomes the only means of assessment. This it should not be. The Master and his crew should be encouraged to be the main eyes and supervisors of the management. How to bring them on board should really be the commitment of the TM. Suggestions and dependency on auditors is the starting point of the fear culture and a false measure of efficiency.

Auditors add value by examining evidence of how well the system is helping its users to predict potential NC y analyzing data and getting useful information from it. This information should provide the trends and analysis to make decisions on resources and measures to improve efficiency and cut loss before it occurs. Auditors add value by reporting NCs objectively, based on actual requirements and supported by the evidence observed. That should be the only expectation from a good auditor: a well defined objective NC.

EXPECTATIONS FROM & THE ROLE OF FLAG STATES

Flag State Administrations and Registered Organizations (RO) as also Registered Security Organizations (RSO) should support the auditing system by not getting into conflicts of interest. When for example an RO represents the Flag State for certifications, and chooses to be the consultant and trainer, a compromise on fruitfulness and objectivity of the audit comes in. Independence of the auditing institution must be a commitment of every stakeholder in the maritime industry. It will prevent ENRON like situations

CONCLUSION

Audits to any of the codes are carried out by mature auditors to confirm the system is working as desired. The objective is not to somehow find a NC! Once a NC is discovered, it should be respected as the starting point to initiate the CA process and therefore should be welcomed. Independence of the auditors is as essential as the total commitment of the TM to the process based management approach to implementation of the ISM, ISPS Codes and other relevant standards as ISO 28000 for the mercantile marine to remain viable prevent loss and prevention.

Classification Societies and their changing role in a difficult maritime environment.

Classification Societies are non-governmental organizations very often referred to by mariners as the “CLASS”. Ever since their role developed the classification societies (CS) have rendered yeoman service to mariners by not only prescribing but ensuring implementation of the  standards for the construction and classification of ships and offshore structures.

The Flag States have the responsibility to ensure vessels under their flags are designed, constructed and operated to the standards laid down by the Administration. In effect his is actually ensured by the CSs on behalf of the flag states. Class takes no responsibility for the safety, fitness for purpose, or seaworthiness of the ship, this responsibility lies with the Administration. Which is one reason the Flag States may at their discretion not recognize some CSs.

The challenge before the societies, being the SME (Subject Matter Expert) for setting technical rules, confirming  designs and calculations, surveying vessels and structures during the process of construction and commissioning to periodic survey of vessels to ensure continued compliance to meet the rules rests with the Class. The scope of their work is vast and covers all of the maritime spectrum from oil platforms, offshore structures, and submarines to survey of diesel engines, important shipboard pumps and other vital machinery.

The ship, its components and machinery are built and maintained to the standards required by their class, Flag States withdraw certificates if a ship does not maintain its class. This indeed has been their developing role since 1760, when the Register Society was formed. This was the first classification society and become Lloyd’s Register in 1834. Bureau Veritas (BV) was founded in Antwerp in 1828, and moved to Paris in 1832. The rest is history.

With the march of time, the maritime world has become exceedingly dependent on the CSs. This then appeared to the business stake holders of the society as a business opportunity. Not just that, it also met further requirements and filled the gaps in the expertise that Flag States had. Building SME in every field can be expensive. Duplicating talent is expensive. So with time the Flag States have off loaded some of the work to Recognized Organizations (RO) and Recognized Security Organizations (RSO). These could or should have been other entities which would take on this responsibility and so ensure there were no conflicts of interest. However, the Flag States have found it convenient to, in general, delegate their Flag State responsibility of RO and RSO too to CSs. Sure it is a case of wearing two hats. After all the RO representing the Flag State is charged in principle to ensure the CS performs to the satisfaction of the Flag State. In this case, by and large though the RO and CS are one!

The plot further thickens, when the CS’ take on the consulting responsibilities too. Is it any surprise that clients prefer a registrar as training providers and consultants they implement a system.  The thought process behind ISPS Clause A/9.2.1 is implicit in the philosophy that an assessment and an approval must be with two different entities. Now imagine where the same CS has consulted, met the training requirements and put together the management system coming to audit and certify the organization! And by the way it is also the class for the vessel. The conflict of interest argument has in this way been thrown overboard. A management system developed by an experienced third party, other than the CS, will not only enable their organization to run more efficiently and gain them the certifications they need to conduct business with certain customers, but will also provide both parties the independence and enable due diligence.

In my view the three in one responsibility that the CSs have taken over the years have diluted their ability to maintain independence and continue to be an unbiased SME. Thinking in another direction, it is also a case of monopolization, if this trend continues, soon one or the other or several of the CS could become the Micro Soft for the maritime industry. When large organizations as Enron work hand in hand with Arthur Anderson as their auditors, the conflict of interest will come in and will be to the determent of the maritime industry and to the values of the CSs.