Compliance…. and it’s importance!

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Compliance is a topic that most operators and Master’s don’t want to deal with in many cases but…

…it can be a major issue in the event of an incident or even an inspection by AMSA!

Remaining compliant is vital to your operations and more so for your business! All too often when undertaking safety reviews or onboard training we identify non-compliance in most cases.

The non-compliance issues we uncover vary from minor (but still a potential problem) to serious which can cause serious issues in many ways.

Here’s 10 of the more common non-compliance items:

  1. Failure to complete your vessels Log Book on a daily basis;
  2. Lack of required details in your vessels Log Book;
  3. Failure to record new crew inductions;
  4. Failure to update crew details;
  5. Failure to record crew training (drills); or
  6. A failure to undertake regular drills;
  7. Failure to update procedures where changes have been made;
  8. Failure to update your Risk Register when changes in risk levels have been identified;
  9. Failure to complete the Follow-up document after an incident;
  10. Failure to record Revisions and/or Annual Reviews; or
  11. Failure to undertake Annual Reviews.

Log Book: Section 11 Documentation in MO 504 specifies what details are required in your log book. There is also a requirement for the Master to sign off each day.

Crew Inductions: Section 6 in MO 504 states that all new crew members must be inducted prior to going to work. Inductions must be recorded either in your log book or preferably in a specific form that identifies what areas new crew have been inducted in. This should be signed by the new crew member and counter signed by the person providing the induction.

Crew Details: Section 11 Documentation in MO 504 specifies that all crew members details must be documented and kept up to date.

Crew Training (Drills): Section 6 Resources and Personnel in MO 504 specifies the requirements for training which must be followed. Note that apart from “initial” training there is now no specified period for drills to be undertaken. Previously it was monthly but it’s now up to the owner or Master to ensure regular drills are undertaken. Be careful not to let your period between drills draw out otherwise you may end up with a problem in the event of an incident.

Recording Crew Training (Drills): whilst undertaking regular drills recording them is equally important because if you fail to record them legally they didn’t happen! Take note that each person taking part in the drills must sign the form and the Master must counter sign as well.

Procedures: Section 7 Procedures for onboard operations and Section 8 Emergency Preparedness in MO 504 require procedures to be developed and documented. If any changes are made to existing procedures they must be updated accordingly.

Risk Registers: Section 2 Risk Assessment in MO 504 allows you to have a Risk Register rather than completing individual Risk Assessments. No matter if you use a Risk Register or Risk Assessments they must be updated if there is a change in the level of risk involved with a particular task. Where a new task has been added this must also be assessed and recorded appropriately.

Follow-up forms: Section 9 Follow-up on hazardous occurrences and non-conformities in MO 504 states that you are required to document all incidents including each hazardous occurrence and non-conformance. You also need to record each investigation into all incidents and any corrective action taken to prevent it happening again.

Revisions and Annual Reviews: Section 12 Verification, review and evaluation in Section 12 in MO 504 specifies that both revisions and reviews be recorded in an appropriate form. A review of the SMS is required to be undertaken annually. Revisions and reviews to be recorded and include:

  • A reference number;
  • A reference to the part of the document or record changed;
  • The date of the change;
  • The signature or initials of the person making the record of the change.

Recommendations

Our most important recommendation is to ensure all your documentation is completed and up to date at all times. A failure to keep it up to date can cause serious issues and potential financial losses if involved in an incident.

Tip

The best tip for you if you’re an owner is to check all documentation has been completed correctly and is up to date. If you’re a Master ensure you keep all relevant documentation up to date at all times.

To ensure your log book is up to date fill it out as things happen or as soon as possible thereafter, not the next day, week or month.

The same goes for incident reports, do then as soon as is reasonably practicable after the event.

Happy New Year! A quick look at maritime housekeeping!

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Welcome to 2023, a year filled with great potential following on from the pandemic!

 

Start the New Year on the right foot.

Housekeeping is required!

 

To help, we’ve included a few items to ensure you stay on top of things that often get overlooked.

 

1. Safety Management Systems (SMS)

To ensure you remain complaint your SMS needs to be up to date with the latest MO504 requirements including being reviewed every year.

As the maritime industry becomes more busy, AMSA can and will increase inspections.  Don’t be one of the many who are complacent about ensuring it is up-to-date AND reviewed every year.

2. Training

Is a vital part of not only being compliant but protecting both your crew and vessels.

Just thinking about it is not enough, you must undertake regular training (drills) to ensure your crew can deal with onboard emergencies safely and efficiently.

Properly recording all drills is a vital part of demonstrating compliance.

In 2022, Shorlink saw over 200% increase in our training course bookings.  We have ensured all of our training sessions meet every clients needs and budget.  Also, we believe we are only of the very few, that understand ‘onboard the actual vessel’ training is vital.

Our training courses can be Found Here!

3. Log Books

Are a vital part in the compliance chain to ensure all required information is recorded properly.

If you haven’t heard yet, (where have you been?) Shorlink provides a range of log books that our clients absolutely love in their business’.  That’s because our Log Books were designed and used by maritime members.

Combined with this, Wayne’s vast knowledge means our log books ONLY include what is needed and required.  You won’t find any useless pages in our books.

We can even customise a log book to suit your specific requirements.

To view our range of log books Click Here (with free postage)

4. Master (Skippers)

So, last year, we created a quick check list designed primarily for recreational boaters but is also a handy guide for commercial operators that we sent out to our database!

What incredible feedback we received! The checklist just ensures that all the boxes are ticked, literally, and provides peace of mind for your time on the water.

Want a free copy? Just drop us a quick email at sms@shorlink.com

 

At Shorlink, we wish you all the very best for the upcoming year and remember…

…we’re here for your safety so don’t hesitate to contact our office by:

p: 07 4242 1412    e: sms@shorlink.com    w: www.shorlink.com

Shorlink Recommendations

Number one recommendation for 2023 is to ensure you are compliant with all regulatory requirements and at all times stay compliant!

Note that both AMSA and WHS have become and will continue to be more active in vessel/workplace inspections and particularly incident investigations.

Tip

Top tip is if you are unsure about any of the items in this newsletter, please don’t panic – just contact our office!

Maintenance and Maintenance Records. Do you know your requirements?

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Whilst it is worth initially noting that whilst every vessel is different and built with different materials, maintenance is an extremely important part of the running of your vessel.

While a critical safety factor, maintenance related issues do not always receive the attention they deserve. Maintenance issues are often difficult to detect and not generally linked to safety and therefore are not recorded.

The Importance of Maintenance

Maintenance ensures that a vessel, engine, etc. continues to perform its intended function as per its design in relation to the level of safety and reliability.

Examples of issues that could lead to technical failure include:

  • unsuitable modification to parts
  • omission of maintenance checks
  • incomplete installations
  • a fault not being isolated
  • missing equipment.

While many maintenance-related errors seem inconsequential, they have the potential to remain dormant and can affect the safe operation of a vessel over time.

How often do I need to complete maintenance checks?

Programmed maintenance of vessel and its equipment should be undertaken in accordance with the schedules specified in your SMS Manual. To ensure the safety and efficiency, inspections should be carried out prior to departure and at monthly and annually intervals at a minimum.

Where lapses have occurred in undertaking repairs and/or maintenance these are to be recorded in either the SMS or the Maintenance Log. The owner or Master is responsible for corrective actions to be undertaken within the timeframe specified in the vessels SMS.

Consideration may be given to the severity, nature and potential impact of any repairs or defects in relation to the corrective action required. Where there is no potential impact on the safety of the vessel, persons onboard, other vessels and the environment – the time required may be extended accordingly. Any extension in times should be recorded in the vessels Log Book.

The Master is responsible for ensuring all machinery, equipment and other technical and electronic equipment is maintained and serviced in accordance with the manufacturer’s instructions at all times.

The maintaining of all inspection records is the either the Master or the Engineer if caried.

When and Where do I need to inspect?

Pre-departure

These checks are to be in accordance with the vessels pre-departure check list.

Monthly

 The following areas/items should be inspected at a minimum every month:

  • Hull, Deck & Superstructure
  • Machiney, Fuel and Steering Systems
  • Fire & Safety Equipment
  • Miscellaneous – such as anchors, chain, line, winch and signage etc

Annually

 The following areas/items should be inspected at least once a year:

  • Hull, Deck & Superstructure – External
  • Hull, Deck & Superstructure – Internal
  • General Arrangements including Internal structures, stairs and air dampeners
  • Anchors, Chain and Equipment
  • Machinery, Steering and Fuel Systems
  • Electrical Systems
  • Navigation Equipment
  • Safety Equipment
  • Fire systems and Equipment

Identifying, addressing and managing maintenance-related risks is an important part of your Safety Management System (SMS). The SMS must include a planned maintenance schedule as well as a pre-departure checklist. Planned maintenance should include regular checks, servicing, visual inspections and operational tests.

Recording maintenance

Equipment failures and vessel breakdowns can cause accidents, putting everyone on board in danger.

It is important to keep proper records of what maintenance has been done. This allows you to track when you are due for maintenance and helps prove you are proactive about the safety of your operation.

Another common question we’re getting is do I have to record all my maintenance? The answer is YES you need to record all your maintenance, both scheduled and non-scheduled.

Scheduled maintenance includes everything from oil changes to annual refits and everything in between.

Unscheduled maintenance is things like when you have to repair engines, gearboxes, refrigeration or anything else due to a breakdown or hull repairs to an incident, etc.

All of these things must be recorded in an appropriate manner. You can use a Maintenance Log Book like ours below or maintenance record forms in your SMS, in an electronic maintenance program or even in an Excel spreadsheet but…it must be recorded.

We have a number of clients using specially designed maintenance software programs while others are using either our Maintenance Log Books or ones they’ve developed.

The other question is do we have to keep the records onboard? Simple answer, NO. Again, a number of our clients use our Maintenance Log Book and keep it ashore as they have shore-based maintenance personnel.

Many of our smaller clients use the maintenance form we have in our SMS Manuals and store them in their SMS.

Others use our maintenance form and store them in the cloud enabling maintenance to be recorded and having it accessible to onboard crew and shore-based staff and/or owners.

No matter which method you choose it’s no use unless you ensure all maintenance is recorded when it’s done not a month later.

My crews would often say I was too annal in recording maintenance as I insisted in everything being recorded down to changing light globes which may sound a bit extreme.

The benefit of that was upon return from a trip they had changed light globes in one cabin 6 times during that trip. This indicated an electrical fault which had the potential to cause a fire!

You don’t have to go to that extreme but must always ensure maintenance relevant to the operation and safety of the vessel are recorded. This demonstrates to AMSA that you run a professional operation!

Shorlink’s Recommendation

First recommendation is to ensure you have a method of recording maintenance that suits your requirements, and all maintenance is recorded.

Second is to ensure your SMS has a maintenance schedule or program that outlines what you inspect and/or service and at what intervals, e.g., monthly, annually, etc.

For most of our clients we develop monthly and annual schedules while a few have monthly and biannual programmes in place. The bottom line is the schedule must suit your operations.

In our Maintenance Log Books and forms we include a column for the person undertaking the maintenance to sign of on it.

Tip

Our best tip is to record all maintenance, no matter how big or small it is. We recommend recording everything from the replacement of fuses and light globes to major component items such as engines, gearboxes, etc.

This provides a chronological account of all maintenance which gives you a detailed look at how the vessel is running and identifies any areas that may require special attention.

Click Here to view the Maintenance Log Book.  If you wish, you can order with free postage.

Fire! How safe is your workplace?

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This is a very important question because over the last 12 months we’ve undertaken several Safety Audits both on vessels and in workplaces ashore and conducted multiple onboard training sessions where fire safety was compromised.

How does your fire safety stack up?

Here’s a short list of things we’ve discovered during our Safety Audits and training sessions:

  • Empty fire extinguishers
  • Fire extinguishers not serviced
  • In one case the engine room fire suppression system bottle was empty
  • Air shut offs not functioning. Often these had been painted over during refit
  • Air shut offs with damaged dampeners
  • In another case an air shut off that had a bolt from a fitting located in the vent pipe which prevented the dampener from closing
  • Inoperable fuel shut offs
  • In one case a fuel shut off that had to be accessed through a hole in the deck with a fitting that could not be removed
  • Fire hydrants and/or hoses in disrepair
  • A lack of knowledge on how to deal with a fire, even a minor one!

All of the above put the vessels at risk in the event of a fire onboard, especially in the engine room.

While the above list is based on vessels, many of the items are also relevant to workplaces such as factories, offices, etc.

Fire extinguishers that have been discharged or otherwise become inoperable should never be onboard or in the workplace, they must be serviced when due.

Check the gauge on a regular basis and if it is in the RECHARGE section, get it recharged immediately!

Do you have Dry Chemical extinguishers on your vessel in your workplace?

If yes, ensure you know what class they are as there are two classes for Dry Chemical extinguishers, these are:

ABE Type :

  • Class A Fires – paper, cardboard, wood, fabrics, people etc.
  • Class B Fires – flammable liquid fires, petrol, diesel, oil etc
  • Class E Fires – electrical fires, computers, photocopiers, switchboards etc

 BE Type:

  • Class B Fires – flammable liquid fires, petrol, diesel, oil etc
  • Class E Fires – electrical fires, computers, photocopiers, switchboards etc

Air shut offs that do not fully operate put your vessel at risk. You need to check them for full operation regularly, especially after a refit where painting has been undertaken.

The picture below was supplied by AMSA as an example of a damaged air dampener.

Fuel Shut offs: The location and operation of your fuel shut offs is also critical for your safety in the event of an engine room fire. These should also be checked regularly for effective operation.

The picture below is an example of a cable operated fuel shut off.

Fire hydrants and fire hoses are fitted on many vessels, but we’ve found ‘lay flats” hoses that were in disrepair, one that even feel apart when pulled out!

Shorlink’s Recommendation

For your safety and the safety of your crew, workers and/or clients and vessel or premises ensure you have a procedure in place and that you undertake regular drills.

Secondly, make sure all crew and workers can identify the classes of extinguishers and their specific uses.

Also, it’s critical to your safety that you undertake regular checks of ALL your fire fighting apparatus and equipment to ensure it works when required.

Tip

Best tip for Dry Chemical extinguishers is to turn them upside down and give them a little shake on a regular basis.

The reason for this is that the powder compacts on the bottom of the extinguisher and may not work efficiently or work at all.

Every Passenger Counts! Are YOU up to date!

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It’s interesting to note that some operators either did not know or failed to take the appropriate actions including updating their Safety Management System (SMS) in relation to AMSA changes.

AMSA announced an amendment to Marine Order 504 in relation to vessels carrying passengers that commenced in May 2020.

The changes!

For Class 1 and Class 2 vessels that are permitted to carry passengers you will be required to have an effective and verifiable means of passenger monitoring to ensure the master is able to find out the number of passengers onboard at any time.

Every Passenger Counts! Are YOU up to date!

You will be required to undertake a passenger count at the time of embarkation and disembarking for vessels that are:

  • a Class 2 vessel permitted to carry passengers or a Class 1 vessel that is permitted to carry no more than 75 passengers; and
  • is on a voyage of at least 30 minutes and no more than 12 hours scheduled duration and the vessel is not scheduled to stop for embarkation or disembarkation in the first 30 minutes; and
  • is operating in B, C or D waters at any time or E waters outside of daylight hours.

For operators who transport passengers to a water-based activity the passenger count:

  • must include an additional count before the vessel departs from the site; and
  • is not required to be conducted when a vessel is stopped for a water-based activity and a passenger enters or leaves:
  1. the water; or
  2. another vessel used in conjunction with the activity

This means if you’re operating a ferry service or water taxi which has voyages of less than 30 minutes this amendment does not apply.

For most operators who carry passengers on voyages of 30 minutes or more and less than 12 hours you will need to update your Safety Management System (SMS) to incorporate the changes.

The flowchart below will assist in determining what vessel is required to do in relation to passenger monitoring and counts:

Shorlink Every Passenger Counts!

Remember: Every passenger counts!

Shorlink safety system

Current regulation is in place to improve passenger safety on domestic commercial vessels. These measures were made in response to fatal and serious non-fatal incidents involving passengers falling overboard.

There are severe penalties that align with the irresponsibility to always ensure the safety of your passengers.

It is equally important that the crew are made aware of their responsibilities, actions, procedures, and consequences.  If in doubt, arrange an immediate training session with your crew and make sure these are ‘real’ sessions, out on the water, with every member of the crew.

Shorlink’s Recommendation

If you operate a passenger carrying vessel as identified above and you haven’t implemented these procedures or updated your SMS to incorporate them we strongly recommend you take action now.

A failure to implement these procedures and/or update your SMS accordingly may attract a severe penalty and in the event of an incident you can end up facing serious legal actions.

Don’t wait! As we have seen with our clients, AMSA have been and will be extremely active this year with vessel and SMS inspections.  Ensure you stay up-to-date of the requirements. This will demonstrate that you are generating a culture of compliance within your business!

As mentioned above, training is key! We have seen so may times crew and other passengers alike, panic, when someone falls overboard. Training with your crew with alleviate the unnecessary panic reaction and replace with a calm and educated response. This will save lives and provide confidence for your crew and passengers.

Tip

If you’re having trouble working out what’s required or how to incorporate the changes into your SMS then give us a call and we’ll help get you compliant with the changes.

Shorlink offer ‘Onboard’ Safety training courses for both commercial and reactional operators that include ‘real’ person overboard demonstrations, as well as learning and understanding of your vessel, its equipment and emergency response scenarios including fire, person overboard, collision and more! Click Here for more details!

Deck Log Books. Do you know what’s required?

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When we’re doing either onboard training or vessel safety audits and look at the vessels deck log the information recorded does not meet the requirements of Marine Order 504 (MO504).

There are specific requirements relating to the information that must be recorded in your log book. In the event of an incident failure to fill in your log book has the potential to cause serious issues for you or your crew!

In addition to the requirements of MO 504 there’s other information that we highly recommend you record.

Looking at deck or vessel log books for commercial fishing vessels it’s common to see the start/finish times or position of shots and little more.

In charter vessels we regularly see start and finish times and in some cases refuelling again with little more.

It’s critical for your protection to ensure you or your Master keeps the log up to date at all times. A failure to do so leaves you exposed in the event of an incident or legal claim by a crew member or passenger!

MO504 specifies that the following details MUST be recorded in your log book:

  1. Any illness or injury of persons onboard. This means crew members, passengers or any other person onboard. Injury means injuries that are serious enough to need more than just a band aid. Any injury that requires first aid or has the potential to cause infection or may need further medical attention in the future must be recorded.
  2. Any marine incident, other incident or accident involving the vessel or its equipment.
  3. Any assistance rendered to another vessel.
  4. Any unusual occurrence or incident. This means anything that has the potential to impact on the safety of a person or persons onboard or the safe operation of the vessel.
  5. All communications and/or messages sent or received for an emergency. This is critical in the event of an investigation.
  6. All passenger counts conducted for the vessel. This only applies to vessels carrying passengers
  7. Any operation of the vessel for recreational purposes

Quite often Masters tell me that ”I’m busy running the vessel and don’t have time to record all of this.”

My answer is always “do you have weeks or months available to defend yourself in court if the vessel, crew member or a passenger is involved in an incident?”

When an incident or accident occurs AMSA will undertake an investigation and apart from the incident report they will look at your SMS and log book.

So, the two questions asked are:

  1. Does your SMS comply with MO504 and is the relevant procedure or procedures appropriate?; and
  2. Is the incident detailed in the vessels log book?

If your SMS does not meet the requirements then you may have a serious problem and a failure to record the incident or accident exposes you even further.

No matter what type of vessel you operate I hope you can now see the value in keeping your vessels log book up to date with all the relevant information.

As a commercial mariner I know it can sometimes be difficult to keep your log book up to date, but you should always ensure you enter the relevant details as soon as reasonably practicable after the event. This way the event is clear in your mind, and you don’t have to think back to what actually happened.

A key point many Masters forget and I’ve been guilty of it myself, is to ensure you sign the log book page at the end of every day. Doesn’t sound like much but it can potentially leave you exposed yet again so make sure you sign every day’s log page.

Shorlink’s Recommendation

We strongly recommend recording the following information:

  • Date and time of departure and arrival
  • Navigational track and/or position at relevant times
  • Summary of weather conditions, especially any sudden changes in weather
  • All inductions and training.

By including this information, you are so much better protected in the event of an incident or accident.

Tip

Our best tip to ensure you meet AMSA’s requirements and give yourself the best protection possible is to check the previous days log book entries to ensure all requirements are recorded appropriately and that you have signed the page.

Annual Reviews How important are they?

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We often get asked “how important are Annual Reviews?”

The simple answer is they are not only import, they are critical!

All Safety Management Systems including those developed for Domestic Commercial Vessels (DCV) under Marine Order 504 and the ones developed for workplaces under Work Health and Safety are required to undergo an Annual Review or Audit.

Failure to complete your Annual Review or Audit leaves you non-compliant and exposed to legal action in the event of an incident or accident.

Shorlink’s Recommendation

My recommendation is to put the past 2 years behind you, look forward to 2022 and get going! While things are getting back to the new normal I further recommend taking a close look at your business or operations to see where and how you can better adapt to the ongoing business climate.

While there’s been a lot of heartache for many there is a lot of opportunities for those who are prepared to adapt so…go forward and prosper!

Tip

My top tip is to ensure your safety management systems comply with the relevant standards and are up to date to ensure you’re protected as both AMSA and WorkSafe are going to be very active in the new year.

Medical Log Books! Do you need one?

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What most operators don’t realise is that there is a requirement to have a Medical Log Book onboard your vessel to record medical information including the dispensing of drugs.

The NSCV Part C7A H8 specifies that all vessels shall carry and record the use of all medicines, first aid and medical incidents in a Medical Log Book and record the stock movements for Controlled Drugs in a Controlled Drug Register.

To date AMSA have not been pushing Medical Log Books other than on larger vessels but I’m guessing that this is another area that is going to surface in the near future, especially on passenger and charter vessels!

If you operate passenger or charter vessels you should consider getting a Medical Log Book in place sooner rather than later.

Other vessels that should be getting one together are commercial fishing vessels and vessels engaged in construction or towage and in particular those that undertake long voyages.

Medical Supplies: Things to consider

When considering your requirements for medical supplies you need to take into account the tables specified in C7A. Now there are more flexible rules for first aid supplies on DCV’s.

The owner/master of a domestic commercial vessel (DCV) operating in operational area C, C Restricted, D or E may undertake a risk assessment of their vessel and operation and determine the appropriate type and quantity of First Aid supplies that are to be carried on board the vessel for that operation.

Please note that the first aid kit must also comply with the Work Health and Safety Code of Practice. If necessary, assistance may be sought from an appropriately experienced pharmaceutical provider or First Aid provider/supplier in order to do so.

Based on your risk assessment you may apply for and Equivalent Solution. A few questions that you need to take into account when conducting your risk assessment…

  • Is your operation considered high risk in the WHS code of practice?
  • Do you have crew with current First Aid qualifications onboard ALL the time?
  • Are you operating more than two hours from medical assistance?
  • Based on your operations are persons on board likely to encounter specific hazards e.g., burns, stings, cuts and abrasions, etc.?

These are just a few of the things you need to take into account when undertaking your risk assessment. If you need help with completing a risk assessment for your First Aid requirements don’t hesitate to contact Shorlink or request First Aid Risk Assessment sheet.

What’s required in a Medical Log Book

There are specific requirements for a Medical Log Book which include:

  • Date
  • Time
  • Patient
  • Condition
  • Treatment

If you carry Controlled Drugs your Controlled Drugs Register should include:

  • Supply
  • Use
  • Disposal
  • Loss
  • Theft

While all of this may seem a bit daunting it’s really not too bad if you have the right layout in your log book and register.

First Aid Kits and Medical Cabinets

There are also a number of other considerations in relation to First Aid Kits and Medical Cabinets which includes…

  • Location
  • Construction and provisions
  • Labelling and identification
  • Construction and illumination for Medical Cabinets
  • Maintenance for Medical Cabinets

Shorlink’s Recommendation

The one thing that we see so often is OUT OF DATE First Aid certificates which means that person may not be up to date with the latest First Aid knowledge and skills. We strongly recommend that you ensure your First Aid is current.

 

 

For vessels with more than two crew we recommend at least one other crew member has current First Aid training. This takes the pressure off the Master in the event of an incident where injuries are sustained.

 

Tip

If you think you can have a case for an Equivalent Solution then do a risk assessment on your operations or if you need assistance in doing one then contact our office. We can assess your situation and develop a risk assessment for you.

Need a Medical Log book then look no further as Shorlink has them available and they meet all the legal requirements.Medical Stores Log Book

 

Dealing with onboard inspections. The do’s and dont’s!

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As a commercial operator we’ve all had to deal with vessel inspections by marine agencies including AMSA, Fisheries and the Water Police.

While on most occasions you get through them without too much hassle there are times when we wonder what the hell some of these officers are talking about.

I think most of us have gotten disturbed at times and even downright angry at some of the things we get thrown at us.

I can say that in most cases the officers are not displaying any form of prejudice against you as a person. Unfortunately, I have to admit to being witness to an officer going out of his way to make life hard for an operator they believed should not be on the water!

Ordinary situations can be hard enough but when you have to deal with that sort of behaviour, its hard to keep your calm.

What’s important to remember is that the person undertaking the inspection is only doing their job and they are only human after all!

One of the biggest issues to deal with is consistency. What we’ve seen happen is an inspection being undertaken in one port and being given the “all good” then going to another port only to be told all these things are wrong.

The worst one is with SMS manuals, where officers out their twist on what they think should be in your SMS.

AMSA have an SMS Assessment check list that lays out what they need to ensure is in your SMS. That’s what they should be sticking too!

So… how do we deal with onboard inspections?   

Dealing with onboard inspections at any time can cause stress, especially when you feel things are not going so well, so below I’ve listed how I recommend ALL Owners, Masters and Crew Members to respond.

During an onboard inspection I always recommend all persons involved to remain calm and respect the officers conducting the inspection, even if you disagree with their decisions.

Actions and reactions

  • Keep calm at all times
  • Don’t blow your stack no matter what
  • If you disagree with something ask them for an explanation
  • If something is found to be non-compliant or unsafe ask to be shown what it is and have them explain to you if you’re uncertain
  • If you feel the officer has been unjust or wrong in some way don’t argue about it. Let them know your concerns and ask for clarification
  • If you’re issued with a Report of Inspection with defects listed, make sure you have anything you don’t understand explained to you
  • Being issued with an order to return to port or tying up the vessel up for any reason accept it, don’t argue with the officer and follow the direction then deal with whatever was the cause
  • If you feel any decision is wrong, first follow the instructions then you can report it to AMSA but ensure you are clear about the issue have all the facts together to support your case. Be clear and concise!
  • In relation to SMS Manuals be aware that officers are viewing them to ensure they have all the required information relevant to your vessel and its operations. They are not meant to go through procedures and issue instructions about them. They may make suggestions but remember for DCV’s there is no actual approval system in place.

If you follow the above your onboard inspections will go much easier, no matter what the outcome is!

Shorlink’s Recommendation

My number one recommendation is to follow the guideline above but if you feel there is a problem with any notices given during an inspection the I strongly recommend you contact our office for advice immediately.

We have the experience and knowledge in dealing with these matters and can make life easier for you. If you have an inspection scheduled and would like assistance in dealing with it then you can arrange for us to be onboard during the inspection (based upon availability).

Tip

Safety Management Systems (SMS) are one of the biggest issues with vessel owners and operators at present due to AMSA’s increase monitoring of them.

For those who aren’t clients, my tip is to have us undertake a FREE assessment of your SMS so we can point you in the right direction. Feel free to send us a copy to sms@shorlink.com and we would be happy to assess and advise!

If you’ve received a MO504 SMS Assessment and there are items listed as “not met” then our tip is to send them to us if you’re unsure about what’s required ASAP.

Occupational Health and Safety Management Systems – Who needs one?

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Work health and safety (WHS) and now internationally referred to as Occupational Health and Safety (OH&S)  involves the management of risks to the health and safety of everyone in your workplace.

This includes the health and safety of anyone who does work for you as well as your clients, visitors and suppliers.

It may initially cost money and time to implement safe practices and install safety equipment but is critical to the success of your business. Not taking action could also result in prosecution, fines and loss of your skilled staff.

Who is required to have a WHSMS or OHSMS?

Any person conducting a business or undertaking is required to put health and safety practices in place as soon as you start your business.

Under Australian WHS laws your business must ensure the health and safety of your workers and not put the health and safety of others at risk. To do this you must:

  • provide a safe work environment
  • provide and maintain safe machinery and structures
  • provide safe ways of working
  • ensure safe use, handling and storage of machinery, structures and substances
  • provide and maintain adequate facilities
  • provide any information, training, instruction or supervision needed for safety
  • monitor the health of workers and conditions at the workplace.

To achieve the above you are required to have a documented Occupational Health and Safety Management Systems (OHSMS) otherwise known as Work Health and Safety Management Systems (WHSMS) in place.

Meaning of a person conducting a business or undertaking

In short according to the Work Health and Safety Act a person conducts a business or undertaking:

  1. Whether a person conducts the business or undertaking alone or with others; and
  2. Whether or not the business or undertaking is for profit or gain

Note that there are other factors relating the meaning which are in Subdivision 2 of the Act.

WHS requirements in your State or Territory

Each state has its own WHS laws and a regulator to enforce them. The WHS framework for each state includes the:

  • Act – outlines your broad responsibilities.
  • Regulations – set out specific requirements for particular hazards and risks, such as noise, machinery, and manual handling.
  • Codes of practice – provide practical information on how you can meet the requirements in the Act and Regulations.
  • Regulating agency (regulator) – administers WHS laws, inspects workplaces, provides advice and enforces the laws.

In simple terms, if you operate a business in Australia you are required to have a documented WHSMS or OHSMS system in place.

The standard that has been in use for WHSMS was AS/NZS 4801 but that may not be recognised in Australia in the future but can still be used unless certification is a requirement. Most small businesses won’t require certification unless it’s a client’s requirement.

AS/NZS 4801 is being replaced globally with ISO 45001 which is a much easier system and the one we’re implementing for our new clients.

Here at Shorlink we’re currently updating our own WHSMS (now OHSMS) from AS/NZS 4801 to the new ISO 45001 system.

The good thing about ISO 45001 is we’ve developed technology to assist in putting a simple system in place much cheaper than previously to meet your business requirements.

Shorlink’s Recommendation

If you already have a documented WHSMS or OHSMS in place look at it carefully to ensure it meets all of your operational requirements.

Don’t have a system in place then consider your risks in the event of a workplace incident. A simple incident can cost you anywhere from a few thousand dollars to a million or more!

Tip

Need help in developing a safety management system for your maritime based business then contact Shorlink to see how we can help by:

Phone: 07 4242 1412    Email: sms@shorlink.com    Website: www.shorlink.com

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Occupational Health and Safety Management System