Revisions and Annual Reviews – A legal requirement!

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Both revisions and your Annual Review are important things to ensure your SMS remains compliant with Marine Order 504 and covers off the legal aspect in the event of an incident.

Above: Sample of Shorlink’s Revision and Review Log page

Note that you can have a separate form for Revisions and Annual Reviews, but we put them together to make reviewing and auditing your SMS as simple as possible.

One of the first things that will be looked by the authorities following an incident is your SMS and in particular the Annual Review and to a lesser degree revisions. This is to ensure the manual has been reviewed and verified as required by MO504.

If your Annual Reviews are not up to date then technically your SMS is not compliant so be sure to take note of the contents of this newsletter and as always, if in doubt contact Shorlink for assistance.

So…lets look at each one individually.

Revisions

Revisions may be undertaken at any time during the year and must be undertaken when…

  • Any changes to or additional operations have been included
  • There are any changes to a procedure
  • A better way of undertaking a procedure has been identified
  • Any changes to the vessel or machinery are undertaken
  • Any changes to owner’s or emergency contact details
  • Any changes to the DP have occurred
  • Anything else in relation to the vessel, its operations

It’s a requirement that when a revision has been undertaken it must be recorded in an appropriate manner.

Don’t simply change a procedure or any other information and fail to record it because a failure to record it leaves your SMS non-compliant. It also puts you in a dangerous position should an incident occur.

When interviewed you’ll explain what you did and that may not align with the procedure that’s in your SMS that’s where the trouble starts.

So…make sure that if you undertake a revision of any part of your SMS you record it!

Annual Reviews

As the name implies, these are undertaken every year on the anniversary date of your SMS. Failure to undertake your Annual Review may leave you exposed if inspected by AMSA or any of their delegates in an incident.

Completing your Annual Reviews helps if your involved in an incident as it shows that you continually monitor your SMS and the operations onboard your vessel.

We have a set procedure for undertaking Annual Reviews that we recommend be followed to ensure you stay on top of your legal requirements.

I’ve developed this process over many years of dealing with quality systems in my factories and onboard vessels. It’s structured around the international requirements for conducting audits and if followed covers all the aspects required.


Shorlink’s Recommendation

We recommend 2 key steps to ensure you remain compliant at all times:

  1. Whenever you make any changes to your SMS including contact names and details or procedures ensure you print out the pages with the changes, replace the old pages with the new ones and record the details in the review form.
  2. The same thing goes for your Annual Review, ensure you update the pages where changes have been made and record the details in the Annual Review form.

Tip

One very simple tip and that is to record the next due date of the Annual Review in your diary so as to ensure it gets done on time.

If you don’t already a form in place then I recommend you develop a specific form for this purpose to ensure all the required information is recorded.


Log Books

While not technically a log book our Revision & Review Log page is a critical part of your documentation and must be kept up to date. Like a free copy of our Revision & Review Log page then simply email us at sms@shorlink.com and we’ll email you your free Revision & Review Log page!