Question 1

Your vessel is detained at a remote anchorage by armed persons claiming to be coast guard officials but showing no credentials. As Chief Officer (SSO), what is the SSAS and when do you activate it?

Accepted Answer

SHIP SECURITY ALERT SYSTEM (SSAS): mandated by SOLAS XI-2/6 and ISPS Code. Purpose: to transmit a covert alert to the flag state's competent authority (and optionally one other authority) indicating that the ship is being threatened or its security is compromised. The alert is SILENT — it does NOT trigger any alarm on board, does not alert the persons threatening the vessel, and transmits only the ship's identity (MMSI), position (Lat/Long), and a time-stamped alert signal to shore. Activation criteria: the SSAS should be activated when the ship is at SECURITY LEVEL 3 or when "a security incident is occurring or imminent." Armed persons boarding the vessel without verified authority, detaining the crew, is a security incident that justifies immediate SSAS activation. Procedure: (1) Activate SSAS covertly — without alerting the armed persons; (2) Do NOT issue a MAYDAY — SSAS is separate from distress; (3) Maintain normal appearance on the bridge if possible; (4) Note time, position, and details of the incident; (5) Do not resist armed boarding — crew safety is paramount; (6) Wait for naval/coast guard response coordinated by the flag state authority who received the SSAS alert. SOLAS XI-2/6 mandates SSAS on all SOLAS vessels. The fundamental design principle of SSAS is COVERTNESS — it must be activatable without alerting the attacking parties. If the alarm sounded on board (like a panic button), it would endanger the crew. The SSAS sends a signal via satellite (typically the same satellite communications system as the ship's main comms, but operating on a separate channel) to the flag state's competent authority. The flag state then coordinates a response (naval vessels, coast guard, or diplomatic intervention). SSAS activation authority: in most company SMS procedures, the master authorises activation. However, if the master is incapacitated, detained, or otherwise unable to authorise, the SSO (usually Chief Officer) has authority to activate — this is expressly stated in many SSP documents and in IMO MSC guidance. SSAS vs MAYDAY: MAYDAY is a DISTRESS signal for threat to life — it is transmitted openly and will be heard by the boarding party. SSAS is a SECURITY alert transmitted covertly. In a piracy/armed boarding situation, MAYDAY first is likely to inflame the situation; SSAS is the correct covert initial action. MCA guidance (BMP — Best Management Practice) recommends SSAS as the first action in a piracy attack, along with mustering crew in the citadel if practicable.

Question 2

During an internal SMS audit you discover that the weekly lifeboat drill has not been conducted for the past 6 weeks because the port winch was broken. No near-miss or incident resulted. As Chief Officer, how do you classify this finding and what immediate actions follow?

Accepted Answer

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. ISM Code Chapter 9 deals with reports and analysis of non-conformities, accidents, and hazardous occurrences. Chapter 9.1: the SMS must include procedures ensuring that non-conformities, accidents, and hazardous situations are reported to the company, investigated, and analysed with the objective of improving safety and pollution prevention. SOLAS III/19.3: abandon ship drills — each crew member must participate in at least one abandon ship drill and one fire drill every month. On voyages of less than 24 hours, these drills may be postponed. Six weeks without a drill is a clear SOLAS breach. The Major Non-Conformity threshold: the ISM Code and ISM Guidelines (MSC-MEPC.7/Circ.8) define a major NC as one that requires immediate corrective action AND represents a serious threat. Six weeks of no abandon-ship drill readiness could directly lead to loss of life if the vessel had to abandon ship during that period — it meets the major NC threshold. DPA (Designated Person Ashore) role: the ISM Code requires the company to designate a person (or persons) ashore with direct access to the highest level of management, responsible for monitoring safety and environmental aspects. Major NCs must be brought to the DPA without delay.

Question 3

You join a vessel as Chief Officer. What ISM/SMS documents and records would you expect to find aboard, and what is your responsibility for maintaining them?

Accepted Answer

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). ISM Code Ch 11 (Documentation) is a specific chapter dedicated to document control: "The company should establish and maintain procedures to control all documents and data which are relevant to the SMS." Documents required on board include: the SMS manual itself, emergency procedures, drill records, maintenance records, and all corrective action/NC records. Certificate requirement: the ISM Code gives rise to two certificates: the Document of Compliance (DOC) held by the COMPANY, and the Safety Management Certificate (SMC) held by the SHIP. Both must be valid for the vessel to operate legally. PSC inspectors and auditors will ask to see SMS records as part of any ISM audit — incomplete or falsified records are themselves a major non-conformity. At Chief Mate level, the examiner focuses on: (a) knowing what records are required; (b) understanding the "paper trail" from incident → report → CAR → corrective action → close-out; (c) knowledge of the DPA's role and when to escalate. The consequence of poor record keeping: a PSC detention for "inadequate SMS implementation" based on missing records is real — a clean SMS manual with poor records is itself a non-conformity.