As Chief Officer you discover a major non-conformity in your SMS audit. The master tells you to deal with it internally without notifying the DPA because "it makes us look bad." What is your position?

A. The DPA (Designated Person Ashore) has a mandatory role under the ISM Code and CANNOT lawfully be bypassed: ISM Code Ch 4 — the Company shall designate a person or persons ashore with direct access to the highest level of management. Duties of the DPA (Ch 4): to monitor the safety and pollution prevention aspects of the operation of each ship, and to ensure that adequate resources and shore-based support are applied. ISM Code Ch 9 — the Company must establish procedures to ensure that non-conformities, accidents, and hazardous situations are reported to, investigated, and analysed by, the company. A Major Non-Conformity (MNC) MUST be reported to the DPA — it is the DPA's role to receive it and escalate to highest management level. The master's instruction not to notify the DPA is UNLAWFUL under the ISM Code and potentially exposes the company to liability. Your position as Chief Officer: report the MNC to the DPA directly — you have the right and obligation to contact the DPA under the ISM Code. If the master obstructs this, that obstruction is itself an ISM non-conformity to report. Document your attempt to report and the master's refusal in writing.

B. The master is the highest authority aboard. His instruction overrides the DPA notification requirement. Follow his direction and resolve the non-conformity internally.

C. The DPA notification only applies when a survey or PSC inspection is pending. Routine internal audit NCs can always be handled at vessel level without DPA involvement.

D. Contact the DPA after the corrective action has been completed — there is no requirement to report the non-conformity while it is being resolved. DPAs only handle closed issues.

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.