You are Chief Officer and a crew member needs to enter the cargo hold bilge well to clear a blocked strum box. Describe the risk assessment and permit to work procedure.

A. CONFINED SPACE ENTRY — Permit to Work procedure: (1) CLASSIFY: a cargo hold bilge well is a CONFINED SPACE (COSWP Chapter 17) — limited entry/exit, not designed for continuous occupancy, potential for accumulation of hazardous atmosphere; (2) RISK ASSESSMENT: hazards include: (a) oxygen deficiency (O2 may be displaced by CO2, methane, or inert gas from cargo residue); (b) toxic gas (H2S from organic cargo residue; fumigant residue); (c) engulfment by flooding bilge water; (d) drowning; (e) trauma from fall; (3) ATMOSPHERIC TESTING: test using calibrated gas detector for: O2 (safe: 20.8%; acceptable range 20.5-21%; do not enter below 19.5%); flammable gas (LEL — do not enter above 1% LEL); toxic gases (CO, H2S, fumigants per COSHH/COSWP limits). Test BEFORE entry and continuously during; (4) PERMIT TO WORK: complete, signed by Chief Officer (permit issuer) and master (authorising officer); identify: the job, entry person, standby person (MUST be present at all times), rescue equipment; (5) STANDBY PERSON: must be positioned at the entrance — does not enter under any circumstances without additional permit; (6) RESCUE PLAN: self-contained breathing apparatus (SCBA) ready at entrance; rescue line; (7) COMMUNICATION: radio or visual contact maintained with standby person throughout.

B. Bilge wells are not confined spaces — they are not tanks. No permit to work is required for bilge maintenance. Crew may enter individually once the bilge pump is isolated.

C. Test the atmosphere once at the top of the well. If the reading is within range at entry level, crew may proceed without a standby person, provided they carry a personal gas detector.

D. The Master must be physically present in the cargo hold for any confined space entry. The Chief Officer cannot authorise a permit to work — only the master can sign.

A. CLASSIFICATION: This is a NON-CONFORMITY (NC), potentially a MAJOR NON-CONFORMITY (MNC) depending on assessment. ISM Code definitions: Non-Conformity = an observed situation where objective evidence indicates the non-fulfilment of a specified requirement. Major Non-Conformity = an identifiable deviation that poses a serious threat to the safety of personnel or the ship, or a serious risk to the environment, that requires immediate corrective action. The broken winch preventing a weekly lifeboat drill is a failure to comply with SMS procedures (and SOLAS III/19.3 drill requirements — weekly emergency drills). If drills have not occurred for 6 weeks: a MAJOR NC is justifiable — it represents a systemic failure in emergency preparedness. ACTIONS: (1) Immediate: raise a Corrective Action Request (CAR); notify master; record in ship's log; (2) Short-term corrective action: conduct drill with an alternative muster/lowering exercise that does not require the winch (manual muster drill, familiarisation); (3) Corrective action on root cause: repair the winch — raise a maintenance defect; set target date; (4) Preventive action: review SMS for alternative drill procedures when equipment is unserviceable; (5) Report to company DPA; record in non-conformity log; (6) If Major NC: immediate notification to flag state may be required; (7) Close the CAR only when both corrective and preventive actions are verified.

B. The broken winch is a maintenance finding, not an SMS non-conformity. Log the defect in the planned maintenance system and repair it on the next port call.

C. Six missed drills constitutes a non-conformity but not a major non-conformity because no accident occurred. Complete the CAR and close it without notifying the DPA.

D. Lifeboat drills are the master's responsibility under ISM. As Chief Officer, raise it verbally with the master and take no further action unless he directs otherwise.

A. Required SMS documents aboard (ISM Code Ch 11): (1) The Safety Management Manual (SMS) — the set of documents describing the company's safety and environmental protection policy, objectives, and procedures. Covers: emergency preparedness, reporting requirements, maintenance of ship and equipment, documentation, company verification/review; (2) Ship-specific procedures and instructions; (3) RECORDS — ISM Chapter 11 specifically requires records to be kept to demonstrate that the SMS is being complied with: drill records (musters, lifeboats, fire), maintenance records (PMS records, defects, rectifications), non-conformity and CAR records, accident and hazardous occurrence reports, internal audit records, certification and survey records. Chief Officer's specific records: cargo plans (mates receipts, damage reports), cargo securing manual compliance, stability calculations, chart correction log, crew certificates and documentation (STCW compliance), fire and lifeboat equipment inspection logs. Responsibility: as Chief Officer you are responsible for maintaining all records within your department and ensuring they accurately reflect what was done — falsification of records is a serious offence under the ISM Code and potentially criminal under UK law (Merchant Shipping Act).

B. The DPA ashore holds all SMS documentation. The vessel only needs to carry the Safety Management Certificate and keep a copy of the DOC. Day-to-day records are optional.

C. ISM documentation only applies to the master and company. The Chief Officer's responsibility is operational only — drills and maintenance, not paperwork.

D. The only mandatory SMS records on board are the ship's log and the Oil Record Book. All other ISM documentation is voluntary under best practice guidelines.