Maritime Questions › Ism Isps Management
During a busy port call lasting 22 hours you notice the bosun has been working continuously for 19 hours with only a 2-hour break. He is about to go back on deck for the next cargo operation. What are your obligations?
A. MLC 2006 / STCW hours of rest violation: STCW A-VIII/1 and MLC Standard A2.3 minimum rest requirements: (1) MINIMUM REST: not less than 10 hours rest in any 24-hour period; not less than 77 hours rest in any 7-day period; (2) MAXIMUM WORK: consequently maximum 14 hours work in any 24-hour period and 72 hours in any 7-day period; (3) EXCEPTION: STCW allows minimum rest to be divided into no more than two periods, one of which must be not less than 6 hours; (4) IN THIS CASE: bosun has worked 19 hours with only 2 hours rest in a 24-hour period = 19 hours work, only 2 hours rest. This is a SERIOUS VIOLATION — he has had only 2 hours rest vs the required minimum 10 hours; (5) IMMEDIATE ACTION: STOP the bosun from returning to work. He is unfit for duty through fatigue — this is a safety-critical judgement. Document the hours worked. Notify the master — decision on how to continue cargo operations must involve the master; (6) CARGO OPERATIONS: may need to be delayed, reduced, or alternative crew rostered; port authority may need to be informed if the delay affects berth arrangements; (7) RECORD: enter in the hours of work and rest record (must be kept aboard under MLC Reg 2.3) and log; (8) NON-CONFORMITY: raise an ISM CAR — hours of rest violation is a major NC with immediate human safety implications.
B. STCW hours of rest apply to watchkeeping officers only. Deck crew such as a bosun are covered by collective bargaining agreements and their hours are the master's decision alone.
C. During cargo operations, exemptions under STCW apply. Port operations allow up to 24 hours continuous work. The bosun can continue until cargo is complete.
D. Hours of rest requirements only apply at sea. In port, work hours are governed solely by the employment contract — STCW does not apply.
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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.
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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.
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