Tanker Management and self assessment- its effect on the operation of Tanker Fleet

By Capt. Mohan Naik, Extra Master, FNI, FICS, LLB ( Mumbai Univ.) General Manager/ Representative- Dynacom Tankers Management Ltd. Mumbai Tanker Management and self assessment (TMSA) is the latest initiative of The Oil Companies International Marine Forum (OCIMF) to affect the tanker operators. The first edition of the guidelines of TMSA were published in 2004. Changes to the same are on the anvil which will inter alia incorporate the requirements of ISPS in the near future. The need for TMSAWith the ISM code and the SIRE inspections already in place in most tanker companies, one would have thought that there were enough checks and balances to gauge the charterworthiness of the tank ship. However OCIMF felt the need to bring in more safe-guards on all tank ships that they vetted and eventually chartered, over and above the aforementioned statutory and commercial reports. Firstly, the ISM code, despite criticism and/ or praise from various quarters was not being evenly followed by all operators. Indeed it was felt that it had gone the same way as the STCW convention where every country managed to be on the white list. This was not to take the credit away from conscientious tanker operators, but only to highlight that every one was managing to come under the same umbrella. Secondly the SIRE inspections, which were a step in the right direction, suffered from the fact that they could tend to become very subjective and being in the nature of an audit, could overlook important flaws in the system, as any one who has been on these inspections with different inspectors could vouch for this fact about them. TMSA is aimed to be the alleged solution to the ills of the system, which has managed to circumvent the so-called spirit of ISM and the uncertainty of data presented by a SIRE audit of finite and limited nature. How is this proposed to be achieved. The guidelines propose to achieve this by providing clear-cut criteria to tanker operators, which are to be self-assessed by the operators and by presenting their findings to OCIMF for its inspection and scrutiny. Help is provided to the operators through Key Elements, the Aims of such key elements, the guidance notes, the Key Performance Indicators (KPIs), and BestGuidance Practices. All of these Key Elements are worked through increasingly onerous stages (at present numbering 4 stages). Every tanker operator is to report to OCIMF his socalled progress report card on the stage reached by him on a progressive basis. The reports are to be continuous, to be updated whenever the operator achieves a higher stage level. The report thus generated is to be an indicator of where the tanker operator stands with respect to the OCIMF guidelines on TMSA. OCIMF admits that these guidelines are to be reviewed and updated by it on an on-going basis

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How difficult are these criteria to be achieved by a Tanker operator. The fact that OCIMF found it necessary to supplement the ISM code and its own SIRE inspection guidelines through TMSA is indicative that it is not going to be easy for the companies which have only given lip service to ISM. However, operators who have implemented ISM, to use a clich again, in its true spirit, will find at least the first 2 stages routine. Stages 3 and 4 of some key elements require a certain degree of planning, restructuring and/ or remodeling of the SMS of the company. As said earlier the 4 th stage is not the ultimate as TMSA provides for continuous improvement of levels as need dictates in the future. The 12 TMSA Key elements. 1. Management, leadership and accountability 2. Recruitment and management of shore-based personal 3. Recruitment and management of ships personnel 4. Reliability and maintenance standards 5. Navigational safety 6. Cargo, ballast and mooring operations 7. Management of change 8. Incident investigation and analysis 9. Safety management 10. Environmental management 11. Emergency preparedness and contingency planning 12. Measurement, analysis and improvement If one looks at the above dispassionately, it more or less reflects the objectives of the ISM code. However there is one big difference between TMSA and ISM, TMSA not only provides the objectives to be achieved but also gives detailed guidelines to achieve them. These guidelines are not vague but are quite unambiguous and certain, leaving hardly any room for mulling over possibilities of circumventing them. The Aims of the Key elements 1A-AIM: Through strong leadership, management promotes the concepts of safety and environmental excellence at all levels in an organization. 1B-AIM: Management accepts responsibility for developing and maintaining a dynamic safety management system to implement policy and deliver safety and environmental excellence. 2A- AIM: Ensure that the Fleet is supported by key staff that is competent to carry out the full range of responsibilities and tasks. 3A- AIM: Ensure that all ships in the fleet have competent crew who fully understand their roles and responsibilities and who are capable of working as at team. 3B- AIM: Through strong leadership, management promotes the concepts of safety and environmental excellence at all levels in an organization. 4A- AIM: Each vessel has a formal maintenance and defect reporting system, and an optimum spare parts inventory. 4B AIM : Testing and planned maintenance of critical systems and equipment are always carried out as per the plan.

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4C AIM : Management tracks the number of outstanding maintenance tasks to ensure that these are resolved quickly and efficiently. 5A AIM : Establish and consistently apply navigational practices, bridge procedures and deck-officer training in line with regulatory framework and company policies. 6A AIM : Ship operators should establish, monitor and maintain all planning and operational procedures for cargo and ballasting operations and equipment, and ensure that these procedures are effectively implemented. 6B AIM : Ship operators should establish, monitor and maintain all planning and operational procedures to ensure that mooring equipment and operations are effectively managed. 7A AIM : A change management process is in place throughout the office and operates effectively to reduce operational risks. 7B AIM : A change management process is in place throughout the fleet to assist staff in identifying hazards and to reduce operational risks. 8A AIM : Comprehensive procedures are prepared and maintained for incident management. 8B AIM : Ship operators provide training for both ship based and shore based management teams in incident investigation techniques. 9A AIM : The ship operator has a comprehensive and proactive approach to the identification of potential hazards and the shore based management of operational risks. 9B AIM : The company has a comprehensive and proactive approach to the identification of potential hazards and the management of shipboard risks. 10A AIM : The company implements a plan for the systematic identification and assessment of all sources of marine and atmospheric pollution. 10B AIM : Comprehensive environmental initiatives and actions are being implemented onboard the ships. 11A AIM : To improve and test the ship operators ability to respond to and manage an incident. 11B AIM : To improve and test the ability of ship operators to respond to an incident by holding regular and realistic emergency drills and exercises. 12A AIM : Shore-based management has a structured process for conducting vessel inspections to monitor the condition of vessels in the fleet. Detailed reports and closeout plans are maintained ashore. The process includes identification of trends and provisions for promptly closing out any deficiencies that are identified. 12B AIM : The company has a structured process that allows shore-based management to conduct planned and systematic audits of all shore and shipboard locations.

The procedure of Interpretation and implementation Every tank ship operator has to study the guidelines corresponding to the key elements and sub-elements and compare them with what already has been achieved by them through their own SMS. Work up gradually through the 4 stages given for the 12 different key elements. Each Key element has Key Performance Indicators (KPIs) for different stages, which give corresponding Best Practice guidance. The idea is to compare these Best-Practice Guidance notes with the practice prevailing in the Company. If the prevailing practices are in line with these Best-Practice notes then nothing more needs to be done. If not then the system needs to

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be upgraded to these best practices and documentary evidence of the same to be provided. Thus a re-visiting of the ISM procedures and policies will need to be done by every operator as he works up through these stages. Appendix 1 gives a diagrammatic view of the way these stages may be achieved. A Practical Guide for tanker operators The best way to prepare a company to meet the requirements of TMSA is to run a GAP analysis. This will indicate the GAPs between what the present practices of the company are with respect to the TMSA best practice guidance for a KPI of a key element or sub-element. Certain Key elements may be absolutely new for many operators, e.g. Management of change, or such practices might be presently followed but documentary evidence of the same may be missing. The new training requirements for Shore-personnel in team building, presentational skills, diversity, brainstorming and negotiating skills is such an example. This is a best-practice guidance in stage 4 of the key element 2 on recruitment and management of shore-personnel. See Appendix 2 for an extract of a typical GAP analysis report for one of the key elements. The Impact on seafarers One can almost feel the palpable and collective groan of the already overburdened seafarer with the vision of impending increasing paperwork with TMSA. However the objective of TMSA is just the opposite, i.e. to reduce this burden of paperwork and repetitive reporting. To quote from the guidelines, A uniform approach to gathering information will eliminate duplication of effort by operators. Of course initially to adopt some of the new practices will take time ( read paperwork) but as it seems now through various interactions with audit teams who have come to vet the offices of tanker operators to ascertain the degree of TMSA stages achieved, there is no need to hurry through these stages. Indeed the more realistic is the achievement standard of a Company the more it will stand up to the scrutiny which the oil-majors will demand through documentary evidence. To quote from the guidance notes, Overstating the status of a companys management system could result in incorrect or meaningless information being introduced to improvement efforts .. The level of attainment achieved in meeting KPIs must be as accurate and substantive as possible. Thus seafarers need not get unduly worried about any further increase of paperwork but if realistically followed, TMSA will lead to a gradual decrease of the dreaded paperwork on board. The burden however, in the opinion of the author, will shift to the shore-personnel, especially the ones in-charge of incident investigation, recruitment and training, where the TMSA requirements are more onerous than those presently followed by most tanker operators. Conclusion OCIMF has obviously thoroughly researched the prevailing statutory and non- statutory requirements regarding tanker operations prior to coming out with the TMSA guidelines. The objectives of TMSA are indeed lofty such as, Incident-free operations, Improved management systems, Best practices transferred across the fleet, Feedback and easy access to the charterer on performance of operator, No-Blame culture and Continuous improvement in standards, to list a few. However in practice they are still in the nascent stage, only time will

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tell how well they stand up to the promise. Given the track record of Oil-Major vetting inspections as followed by OCIMF, one can confidently say that regarding their implementation by the oil-majors, no stone will be left un-turned. Tanker Operators need to sit up and take notice that this piece of document though in the same mould as that of ISM, is different, living and evolving. It has the idea of a revolution behind it and may well at least be the panacea to enhance the image of tanker operators. Bibliography & References 1. Tanker Management and Self Assessment A best practice guide for ship operators OCIMF 1st edition 2004. 2. The ISM CODE 3. The STCW Convention 4. OCIMF Publications e.g. ISGOTT, Mooring Equipment guidelines etc.

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