Copying an SMS Manual

Do YOU know the dangers?

While copying another vessel’s Safety Management Systems may seem like a good idea the fact is it could very easily cause you major headaches, a danger or even being tied up!

The fact is very few, if any boats, are identical in both structure and operations. While they may be similar, in most cases, there are differences. The differences may seem minor, but nevertheless, they ARE differences that can impact on your SMS.

While your SMS needs to align with Marine Order 504 (MO504), Work Health and Safety legislations and the NSCV it is also very important to note, it needs to deliver a high level of legal protection in the event of a marine incident.

Legal and regulatory risks

In Australia each domestic commercial vessel (DCV) must have an SMS that is specific to that vessel and reflects its unique risks, operations and crew structure. Copying another SMS may violate MO504!

Operational risks

1. Mismatch of vessel specifications
   
   SMS Manuals include vessel-specific details like size, propulsion, crew qualifications, and operational areas. Using another vessel’s SMS could result in procedures that are inappropriate or unsafe for your own vessel.
   
   
2. Inaccurate risk assessments
   
   Risk assessments must be based on the actual hazards and associated risks faced by your vessel and crew. Copying another vessel’s risk register or emergency procedures may leave your crew unprepared for real threats.
   
   
3. Crew confusion and poor training
   
   Policies, procedures and responsibilities outlined in the SMS must match your crew’s roles and training. A copied SMS may lead to miscommunication or unsafe practices.

Hopefully, you can see from the above, that copying another vessels SMS, even if you undertake the same or similar operations is more than a bad idea, it’s a recipe for disaster especially in the event of an incident!

Having an SMS specific to your vessel and its operations not only complies with MO504 it delivers major benefits to you in the legal process provided…

• Proper policies are in place;
• Crew members are all inducted properly;
• Ongoing training (drills) are conducted regularly;
• All inductions, training (drills) are recorded properly;
• The procedures are accurate, detailed enough without being restrictive and are vessel specific; and
• The crew follow the procedures.

IF all of these components are followed, then an SMS will deliver high levels of protection in the event of an incident. By copying another vessel’s SMS the procedures may be similar but there are usually some differences.

Another example is where the safety and fire appliances and equipment are stored. In just about all cases there are differences in where they are located onboard. This leads to confusion among crew members when in an emergency situation.

Here are a few examples…

1. Prawn Trawlers: while most prawn trawlers have a number of similar procedures there are differences between vessels. Winch operations differ between hydraulic and mechanical winches, lazy lining may be by a separate lazy line winch or one that is part of the main winch, try nets and winch operations vary, sorting varies between vessels with automation and those with out and many other variations that impact on your SMS.
   
   
2. Charter vessels: copying an SMS between charter vessels is one of the most dangerous as there are so many possible variations such as how you embark and disembark passengers, different operations including fishing, whale watching, party boat, etc., food and drink service, number of decks and so many other items that can cause major issues if you were to copy another vessels SMS then be involved in an incident.
   
   
3. Vehicle/passenger barges and ferries: these are similar to charter vessels but you also have to take into account loading and unloading vehicles as well as passengers, is there a bow and stern ramp or only a bow ramp, single or multiple decks and much more to take into account

In all of these cases, we’re only talking about procedures and vessel details – BUT there is also the Risk Register to take into account. This is where big problems surface!

Every vessel’s Risk Register must be vessel specific and apply to a recognised Australian standard such as AS/NZS 4360. If it’s not vessel specific or comply with a recognised standard, then you’re in trouble from the start.

So…from these examples I hope you can see that trying to copy other vessels SMS’s is not going to get you across the line and is also extremely dangerous!

While it may seem like a cheap way out and even if you’re not even involved in a marine incident, it may not get you passed the ‘tick the box requirement’ during an inspection – it certainly won’t deliver if under investigation.

In fact if you’re involved in an incident, an SMS that has been copied from another vessel may actually be your worst enemy!

The entire SMS must be vessel specific to align with the MO504, WHS and NSCV and deliver the protection you require. This includes daily and emergency procedures and the Risk Register. These three items are primary to your SMS.

The Risk Register is one of the giveaway items when undertaking an investigation. We can quickly assess if your Risk Register has been copied from another vessel so can a good investigator!

We fully understand that there is a cost factor to engaging someone to develop your SMS but the cost involved in copying one and then being involved in a marine incident is far greater. Just the development of your Risk Register is well worth the investment.

Here at Shorlink, the most common feedback we receive is our SMS’s and subsequent services are the cheapest insurance around – and we agree!

Shorlink’s Recommendation

Our number one recommendation is DO NOT COPY AN SMS FROM ANOTHER VESSEL, even if you think it fits your vessel because it simply will not!

We understand there is an expense involved in engaging professionals to develop your SMS’s, but compare the cost of being tied up or having to deal with a major incident. With legal representation costing $1,000 or more per hour – or heavier costs of losing the business or life and we think it’s an easy decision!

Tip

If you have an SMS and not sure if its compliant, taking into account the recent changes to MO504, which affects all SMS’s – simply get in touch with our office for a FREE no obligation assessment.

One of our SMS specialists will closely assess your current SMS and give you a brief outline, if necessary, of any non-compliance issues at no cost or obligation to you whatsoever.

We offer this free service as safety and education will also be our paramount priority for all in our marine industry.