HEALTH, SAFETY AND ENVIRONMENT MANAGEMENT SYSTEM

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1 HEALTH, SAFETY AND ENVIRONMENT MANAGEMENT SYSTEM CHAPTER 1 of 5.0 SCOPE The Company has established an internal and external audits and internal inspections program to ascertain both the general condition of the ship and the correct performance of the duties assigned to the ship personnel, as well as compliance with the procedures established in this Manual. This Chapter describes the measures established by the Company for planning and implementing internal audits, to verify the correct implementation of the HSE Management System and its effectiveness in achieving the objectives established by the Company and internal technical, safety and operations inspections and procedures established to periodically verify whether persons and entities undertaking delegated ISM-related tasks are acting in conformity with the established Company ISM responsibilities..1 AUDIT PLANNING AND SCHEDULING The HSE Management Representative defines an annual audits schedule covering all the areas affected by the HSE Management System, including the Company vessels. The audit program shall be planned, established, implemented and maintained, taking into consideration: the areas and the vessels to be audited; the audits schedule; the assigned auditor(s); the results of previous audits; importance of the operations concerned; results of risk assessments of Company s activities The shore-based Dept s and the managed vessels shall be audited at intervals not exceeding months. The audits schedule shall be approved by the General Manager. Changes could be affected on the program subject to operational issues on a case by case basis..2 AUDIT PROGRAM IMPLEMENTATION.2.1 Internal audit ashore Internal audits are assigned to Company personnel duly trained and qualified for auditing, with thorough knowledge of the HSE Management System, independent of those having direct responsibility for the activity being audited or to external appointed auditors: they report directly to the HSE Management Representative. The auditor is responsible for: carrying out the audit; issuing an audit report pointing out the findings; issuing, if needed, corrective action requests; following up their implementation. Audits are carried out using appropriate check lists and/or the applicable operating procedures. Audit recording and reporting of results shall be brought to the attention of department mgr. s, who in turn, will conduct an investigation in a timely manner in order to address the root cause analysis, the corrective and preventive action(s) to avoid recurrence. The report of the audit is sent to the General Mgr. for information.

2 2 of 5 Audit reports are filed by the HSE Coordinator for any further review..2.2 Onboard audits The auditor shall be a person duly trained and qualified for auditing, with thorough knowledge of the HSE Management System, i.e. the internal auditors not involved in the management of the audited vessel or external appointed auditors. Audit reports and possible corrective actions, are agreed with and handed to the Master for action; the report of the audit is sent to the General Mgr. for information if deemed necessary. Audit reports are filed by the HSE Coordinator and by the Master for any further review. See details in the dedicated Operating Procedure..2.3 Other audits In addition to those scheduled, other internal audits can be carried out when: the analysis of non-conformities, accidents, incidents, failures and hazardous situations shows systematic deficiencies in specific areas; important claims are made by a Client; important changes occurred in the Company organization or operation; it is necessary to investigate specific aspects of the management service. These audits are carried out and documented following the same criteria as above, with the use of the check lists oriented to the specific aspects to be audited. Furthermore, Suppliers of products and services, Vendors as well as Recruiting Agencies are also audited in case of serious inadequacy of the service they provide..3 COMPANY INSPECTIONS.3.1 General The Company is responsible for ensuring that its vessels are maintained in compliance with the provisions of mandatory rules, regulations, HSE Management System and recognizes the importance of regular inspections by shore-based personnel to verify the actual condition of the ship and its equipments. Inspection intervals are established by the Company. To ensure the effectiveness of the inspections, the following should be considered before they commence: identification of critical equipments to be periodically inspected, calibrated and/or tested. planning of routine technical and safety inspections and tests to be carried out by Company s and/or shipboard personnel; provision of instructions and technical support and assistance to the shipboard personnel to remove non conformities discovered during the inspections; assessment that the above instructions are being followed correctly; analysis and evaluation of bunker, lube oil, waters, etc. characteristics. In performing the above activities, the following criteria are also taken into consideration: the introduction of new rules, suggestions from technical bodies; reports of accidents, failures, non-conformities and near misses..3.2 Responsibility The Fleet Director, Technical Dept. Mgr., Operations Mgr. and Crew Policy Manager are responsible for inspections being carried out in accordance with their schedule. Inspections are carried out by personnel having an adequate qualification and experience. Inspectors shall also examine the records of inspections and tests performed by onboard personnel (including inspections/tests not performed, beyond the capability of the ship's crew).

3 3 of Technical Inspection of the vessel and equipment These are carried out at least every six months based on Company forms to evaluate: the general condition of the ship; the planned (PMS) and general maintenance system update, status and records; periodic inspections: controls, tests and records..3.4 Safety inspections of the vessels and equipment These are carried out at least once a year to verify that: certificates and documents are still valid; lifesaving and firefighting arrangements and appliances, navigational aids, communication and steering gear equipment are in satisfactory conditions and that the periodic inspections, controls, tests and drills are regularly carried out by the shipboard personnel; the general condition of the cargo gear, pollution prevention arrangements, galley, stores, accommodation, infirmary and pharmacy is compliant with the required standards and regulations. the crew is familiar with the ship and trained to perform the duties assigned to them..3.5 Commercial/Operations inspections of the vessels These are carried out once a year (at least one vessel each year) or, in case of a long term T/C, once in the hired period to verify that: Master/crew understood the Operations procedures; Charter parties (the specific ones for T/C or the most used ones) are understood; the standard of public relationship requested by Company is applied; means supplied by the Company are sufficient and well maintained for the requested commercial services..3.6 Reporting and Filing Any defects, malfunction or breakdown of machinery, systems or the vessel s structure, which may affect the safety of the personnel, the ship or the environment, as well as the commercial operation, discovered during the Company s inspections shall be promptly communicated to and discussed with the Master and Chief Engineer. A report shall be issued and countersigned by the Master. Master and Chief Engineer shall assure that requirements and recommendations raised from the inspection are followed in a diligent manner and shall inform the Company when they have been dealt with. The Master and Chief Engineer shall keep in the dedicated file a copy of the inspection reports and list of requirements and/or the recommendations and communication to the Company when they have been complied with. If the recommendations imply responsibilities of the Head Office, the list of recommendations is to be sent also to the department mgr. s or Management Representative. The inspection reports and the communication from the ships are kept in the HSE Cabinet ashore..4 MANAGEMENT REVIEW The General Manager organizes, and the Managing Director chairs, a management meeting at least twice a year, to review the performance, adequacy and the effectiveness of the HSE Management System in achieving the Company s safety, pollution prevention, environmental protection and quality targets. All the Department Managers participate in the review to support the General Manager in the evaluation of the various aspects and results of the HSE Management System. The elements to be evaluated during the review may be anticipated with an agenda issued by the HSE Management Representative. The results of the review are documented, including the decisions, corrective and/or improvement actions, recommendations, etc. and the assignment of the relevant responsibility.

4 4 of 5.5 COMPANY VERIFICATION OF ISM RELATED ACTIVITIES Additionally to audit and inspection the Company periodically verify any entity undertaking ISM related tasks when on acting behalf or in conformity with Company responsibilities under ISM Code. Verification applies both to Company staff and sub-contractors and can be carried out through check of certifications, surveys, safety meetings or documented interviews or investigations..6 INSPECTION ACTIVITIES MONITORING The effectiveness of inspection and test activities are assessed by the department mgrs. through: monitoring of the Superintendents and Company s representatives inspection activities; monitoring and evaluation of the audits carried out by third parties (such as National Bodies, Port State Authorities, Major Oil Companies, Charterers, etc.); verification of reports and follow up actions..6.1 Notification to Flag State and to Port Authorities Master is obliged to notify any defects, malfunction or breakdown of machinery which may affect the safety of life, the ship or the environment to the Flag State Authorities and to Port Authorities. Master should inform the Port Authorities if any defects exist prior arrival, or at once if any defects happen in harbor area. All reports are to be kept in dedicated files. Master should always inform the Company DPA with the most practicable means of communication followed by written reports..7 OTHER INSPECTIONS AND SURVEYS.7.1 Class and statutory surveys Surveys requested by Class and statutory regulations are to be carried out in due time so that the relevant certificates remain valid. Recommendations are to be dealt with within the time established by the Society classifying the ship. The list of pending recommendation for each ship shall be made available to the certifying authority auditor and kept in dedicated files..7.2 Port State Control (PSC) Surveys Surveys by the Port State Authority may be performed when the ship is in any port according to the SOLAS Convention or the "Memorandum of Understanding on Port State Control". Detailed instructions are provided by dedicated Procedure/Working Instruction..7.3 Insurance Company/Charterer s assessments Surveys are carried out when requested by insurance companies or charterers and they are always carried out by their inspector, often accompanied by a superintendent from the Company. Recommendations found during the assessments shall be communicated to the concerned dept. s mgr. s, to the DPA, to Fleet Director and to the HSE Representative and corrected, if possible, using the shipboard personnel. Correction of recommendations shall be communicated to the above dept s. Reports of Survey and related documentation are to be kept in the dedicated file.

5 5 of 5 References OP-ORG-08 OP-ORG-09 OP-ORG-10 OP-ORG-11 OP-ORG- OP-ORG-14 OP-TEC-04 OP-TEC-09 Audits: External and Internal Inspections: External and Internal Non Conformities, Observations and Deficiencies Corrective and Preventive Actions Safety and Environmental Minimum Standards, Objectives, Targets and KPIs Management of Change Maintenance and Inspection on board Management of External Services Requisitions and Orders