HSEMS WORKING INSTRUCTION

Transcription

1 HSEMS WORKING INSTRUCTION WIN-ORG-07 References: OP-ORG-08; OP-ORG-09; OP-ORG-10; OP-ORG SCOPE To provide Company vessel commands and office personnel with the proper instructions on how to manage non conformities and deficiencies raised during the internal or external Audits and inspections providing the relevant corrective actions on board/shore. Non-conformities issued to the Company office and ships are to be intended as a suitable instrument for pursuing the continuous improvement Company task. 2. RESPONSIBILITY Master To inform the HSE department and eventually involved departments of any Non Conformity (Observation) or Deficiency received; To submit to the HSE Dept. a proposal of CARs, with the involvment/cooperation of involved Departments; To illustrate and explain to crew (Safety or dedicated meetings) any Non Conformity (Observation) or Deficiency issued to the vessel; To monitor and manage, upon acceptance, CARs until their completion/closure, requiring for any additional resource as deemed necessary; To monitor and manage deficiencies until their completion/closure, requiring any additional resource as deemed necessary to complete in due time; To duly collect collect and archive documentation relative to follow up and completion (including evidences of closure) of Non Conformity (Observation) or Deficiency received; To provide copy of any relevant document to HSE Department. Office Departments Manager/Responsible To submit to the HSE Dept. a proposal of CARs for any Non Conformity (Observation) or Deficiency received in office; To illustrate and explain to personnel (dedicated meetings) any Non Conformity (Observation) or Deficiency received; To monitor and manage, upon acceptance, CARs until their completion/closure, requiring for any additional resource as deemed necessary; To provide copy of any relevant document relative to the management/completion of CAR to the HSE Department. HSE Department To divulge Non Conformity (Observation) and/or Deficiency received during Internal & External Audits and/or different occurrencies into Office ashore; To coordinate the follow up activities required to complete/close CAR and/or deficiencies of Vessels and involved Departments; To verify adequacy of proposed CARs relatively to the Non Conformity/Deficiency issued, including their compliance with International & National Codes and Regulations; To duly collect collect and archive documentation relative to follow up and completion (including evidences of closure) of Non Conformity (Observation) or Deficiency received, including the verification of appropriateness of closing actions. DPA/HSE Management Representative To ensure that available resurce for the follow up/completion of CAR are adequate and to provide any additional resource if required; To ensure that relevant Non Conformity are analyzed and taken in due consideration during Board Management Review. Prepared by: Reviewed by: Approved by: HSE Dept. HSE Manager General Manager Distribution: to all managed vessels

2 2 Company Auditors & Surveyors To verify during visits on board that vessel is complying with the present procedure; To verify during visits on board that all action required by CAR are correctly implemented and effective; To provide confirmation of closure for Non Conformity (Observation) and/or Deficiency by official message upon verification that all required action are satisfactory completed; To complete during visits on board all documentation relative to Non Conformity (Observation) and/or Deficiency as required, closing them officialy (closure and verification of internal documents). 3. GENERAL Master is the only responsible for the result of any audit and inspection on board, as well as the Department Manager is responsible for the Office internal and external audits outcome. The vessel Master and Department Manager are then responsible for the non-conformities, observations, deficiencies, remarks and outstanding reported. For better understanding the different terms that can be used in respect of this subject and that can be subject to different interpretations, Company defines that "Non conformities" are those issued on account of audits only or determined by the upgrade to Non Conformity of particularly serious remarks issued during PSC, vetting or safety inspections (see dedicated WINs for details relative to the upgrade); while deficiencies" are those arising from inspections or claims. Note: All the non-conformities and deficiencies shall be discussed during the first Safety Meeting on board or, in any case, during dedicated meetings to be held (on board or at office) as soon as possible. 4.1 ACTION 4.1 Internal and external audits: Non Conformities and Observations The non-conformity is an observed situation where an evidence, or several similar evidences (accordingly with the importance of same) of non compliance with Company's system or a non compliance with any national and/or international code (ISM, ISO, etc.) has been assessed. A non-conformity is always arising from audits or from any observed Company HSE system non compliance with the ISM code. The only exception is when a non conformity is issued as an upgrade of a remark (issued during PSC, vetting inspections, safety inspection, etc.) that is deemed particularly serious. Any issued non-conformity needs following basic actions to be carried out: Treatment of Non Conformity: an immediate action - if required- to eliminate as soon as practicable the evident deficiency; Root cause analysis: a deep and detailed analysis of the chain of events that led to non conformity in order to find out the point of failure within Company Management System; Corrective action: an action finalized to the avoidance of reoccurrence of the Non Conformity. Corrective action (CAR) shall be proposed by those who are receiving the non conformity and accepted by whom that found and issued the Non Conformity. The observation is a sort of minor non conformity that can raise from a deficiency that is observed very seldom or by a deviation from the system that is too light to represent a non conformity. The observation shall be formally treated as a non-conformity (i.e their treatment to follow the above path/actions) Non Conformities received on board during Audits (from internal or external parties) Either in case of external or internal audits on board, the person in charge the management process is the Master who, with some slight differences between internal or external, will need to follow and comply with the following guidelines proceeding with listed actions: Upon closure of audit any eventual Non Conformity/Observation must be undersigned by Master for understanding and acceptance (in case of external audits in conjunction with the Company representative, if present); He shall inform the HSE Dept./DPA about the result of the audit and transmit the copy of Audit report and of all related Non Conformity/Observation as soon as possible; To act as soon as possible to rectify/eliminate/treat properly the deficiency itself that caused the Non Conformity/Observation ;

3 3 To illustrate and explain to crew (during a Safety or dedicated meetings) any Non Conformity (Observation) or Deficiency issued to the vessel; To formulate a proposal of CAR (corrective action) including Treatment, Root Cause Analysis and proposed completion date as required, with the coordination and support of involved department, to be submitted to the auditor for acceptance within the required time limits (15 days); To send the CAR proposed to HSE Dept./DPA that will submit it to the auditor for the acceptance. HSE Dept./DPA are in charge of coordinating all activities between parties (Recognized Organizations, External or Internal Auditors and Master); Upon confirmation received by HSE Dept./DPA of acceptance of the CAR proposed, the Master shall complete the original issued form and send a copy of the same to HSE Dept./DPA. To manage the CAR, requiring when necessary support to the involved Company Department, within the defined time frame, providing to HSE department copies of any document essential to give evidence of follow up and completion of all actions required; To provide to HSE Dept. confirmation of completion of the CAR. The HSE Dept. will verify the completeness and effectiveness of actions carried out and will confirm the completion by an official message. Above correspondence shall be archived together with Audit documentation; During the following of the same type the Master shall make sure that, the auditor in charge verifies and/or formally closes the previous Non Conformity/Observation as required. Copies of closed/verified forms are to be sent to HSE Dept. The Company Office is required to properly support the vessel command during the whole management process of CARs. In particular office Departments directly involved in the specific Non Conformity/Observation issued by actions they have taken and/or by the root cause analysis and HSE Dept. should during the whole process, carry out the following tasks: Monitoring of the whole process, coordinating Vessel s and Company Departments actions; Managing and taking care of any necessary information exchange between Recognized Organizations, External or Internal Auditors and Master, including the process of verification and acceptance of proposed CARs; Monitoring of the progress of corrective action in order to grant the completion of the process within the established time frame given, including the effectiveness of the same; To verify and archive the full set of documentation essential to provide evidence of correct follow up and completion of the CAR. The DPA and HSE Management Representative are required to verify that adequate resources are provided to for the management of CARs and shall report result of audit during the Board Management review, putting in evidence most relevant Non Conformity/Observation received by the Company vessels or office Non Conformities received in office during Audits (from internal or external parties) Similarly to the management on board of Non Conformity/Observation issued during audits (either external or internal), the designated persons in charge for their relevant management are the Departments Manager. They are required to manage and provide the relevant follow up according with following Company Guidelines: Upon closure of the audit any eventual Non Conformity/Observation must be undersigned by the Dept. Manager involved for understanding and acceptance in case of internal audit and by Company Representative in case of an external audit; Department Managers involved shall act as soon as possible to rectify/eliminate/treat the deficiency itself that caused the Non Conformity/Observation ; To illustrate and explain to Office personnel (dedicated meetings) any Non Conformity (Observation) or Deficiency issued to the office department; To formulate a proposal of CAR (corrective action) including Treatment, Root Cause Analysis and proposed completion date as required to be submitted to the auditor for acceptance within the required time limits (15 days); To send the CAR proposed to HSE Dept./DPA that will submit it to the auditor for the acceptance. HSE Dept./DPA are in charge for coordinating all activities between parties (Recognized Organizations and External or Internal Auditors); To manage the CAR, within the defined time frame, providing to HSE department copies of any document essential to provide evidence of follow up and completion of all actions required;

4 4 To provide to HSE Dept. confirmation of completion of the CAR. The HSE Dept. will verify the completeness and effectiveness of the actions carried out and will confirm the completion by an official message. The above correspondence shall be archived together with the Audit documentation. Company HSE Dept./DPA are required to support involved Department during the whole management process of CAR as follows: Monitoring the whole process, coordinating Company Departments actions; Managing and taking care of any necessary information exchange between the Recognized Organizations, External or Internal Auditors and involved Departments, including the process of verification and acceptance of proposed CAR; Monitoring the progress of corrective actions in order to grant the completion of the process within the time frame given, including the effectiveness of the same; To verify and archive the full set of documentation essential to provide evidence of correct follow up and completion of CAR. The DPA and the HSE Management Representative are required to verify that adequate resources are provided to for the management of CARs and shall report result of audit during the Board Management review, putting in evidence most relevant Non Conformity/Observation received Other Non Conformities received in office or on board Apart from those received during Internal or External Audits, there are some other concurrencies that can determine the issue of a Non Conformity. A Non Conformity can be generated by the upgrade of a remarks issued during different kind of inspection: Port State Controls, Vetting, Technical Inspections, Safety Inspections, etc. Usually the upgrade is required by the particular relevance or seriousness of the remarks, which is deemed requesting a full CAR process including the determination of its root cause analysis and of strong action to remove it. Issue and management of this kind of Non Conformities are described in details in the dedicated WINs dealing with specific types of inspections. Further, a Non Conformity can be generated by the observation of a situation that shows several or substantial breach of the Company HSEMS system procedures. They are defined in detail by a dedicated OP (operating procedure) and can be issued both on the vessels and to the office, according to the circumstance that caused the same or the occurrences observed. In case of issue of this kind of Non Conformity, the same should be managed according to the following guidelines: Everyone observing a relevant deviation of Company Management System can report it. Than the Master (on board) or the involved Department Manager (ashore) are the designated persons in charge for the evaluation of the same and the relevant issuing of the Non Conformity as deemed necessary. In case they will issue a nonconformity, they are the designated persons in charge for its management; The responsible shall issue the non-conformity to the persons/dept responsible for the deviation and to all subject involved into the identified deviation (interaction can be classified as follows: Ship to Shore, Shore to Ship, Shore to Shore, Ship to Ship); The person responsible for the deviation must undersign the Non Conformity for understanding and acceptance and shall rectify/eliminate as soon as possible the deficiency; He shall formulate a proposal of CAR (corrective action) including Treatment, Root Cause Analysis and proposed completion date as required within the time limits (15 days), to be submitted to issuing responsible and HSE Dept. that will cooperate to grant acceptance; To manage the CAR, within the defined time frame, providing to HSE department copy of any document essential to give evidence of follow up and completion of all actions required; To provide to the HSE Dept. the confirmation of completion of the CAR. The HSE Dept. will verify the completeness and effectiveness of the actions carried out and will confirm the completion. Issuing responsible shall then complete the official closure of Non Conformity, by verifying implementation and undersigning the issued form. The Company HSE Dept./DPA are required to support the involved Department during the whole management process of CAR and to collect and maintain relative documentation. 4.2 Deficiencies generated by internal and external inspections

5 5 The vessels and Office are continuously subject to internal and external inspections. All inspections are aimed at checking and reporting a picture of the vessel or of the office organization as accurate as possible at the specific moment, recording any deficiency or outstanding in comparison with the national and international rules, specific requirements or guidelines. Most commonly, deficiencies can arise from the following inspections: technical, commercial and safety inspection (internal), PSC, vetting, terminal inspections (external). In addition deficiencies notes can be received either in office or on board from clients, claiming for defect of service. All deficiencies are to be rectified as soon as possible, however always within their due time frame where, imposed by the issuing surveyor/authority. For any deficiency received, it is not required to produce the same deep analysis of Non Conformities, but it is sufficient to rectify the deviation and to produce evidence of such action. The responsibility of collecting and archiving all required documentation remain in charge of involved department personnel/managers. Specific instructions for the management of deficiencies are provided by dedicated WINs. References WIN-ORG-05 WIN-ORG-06 WIN-ORG-13 WIN-SAF-16 WIN-TEC-31 Audits External and Internal - Preparation and Managements Preparation and Management Of External and Internal Inspections Ship's Audits And Inspections - Extension Request Management Port State Control Inspection Management Management of Vetting Process Forms O-006A O-006B O-006C O-006D Non Compliance Report 4 O-006E O-006F Non Compliance Report 5 O-006G Internal Inspections O-007 Corrective/Improvement Actions To Be Done