Original English
10.3 The Company should establish procedures in its SMS to identify equipment and technical systems the sudden operational failure of which may result in hazardous situations. The SMS should provide for specific measures aimed at promoting the reliability of such equipment or systems. These measures should include the regular testing of stand-by arrangements and equipment or technical systems that are not in continuous use. 10.4 The inspections mentioned in 10.2 as well as the measures referred to in 10.3 should be integrated into the ship's operational maintenance routine. Traduction officielle en français 10.3 La compagnie devrait établir dans le cadre du système de gestion de la sécurité des procédures permettant d'identifier le matériel et les systèmes techniques dont la panne soudaine pourrait entraîner des situations dangereuses. Le système de gestion de la sécurité devrait prévoir des mesures spécifiques pour renforcer la fiabilité de ce matériel et de ces systèmes. Ces mesures devraient inclure la mise à l'essai à intervalles réguliers des dispositifs et du matériel de secours ainsi que des systèmes techniques qui ne sont pas utilisés en permanence. 10.4 Les inspections mentionnées au paragraphe 10.2 ci-dessus ainsi que les mesures visées au paragraphe 10.3 devraient être intégrées dans le programme d'entretien courant |
On one hand,
" sudden operational failure " means " sudden breakdown " of course, but also " unforeseen unavailability (or failure) of exploitation (or operation) "! " hazardous situations " relates to situations of danger or risk or hazard concerning the persons on board, the ship itself and the environment! So, they are not only equipments or systems in service which suddenly break down but a group of equipments which, if they were not available at the precise moment, when needed, can put the men, the material and the environment in danger: The elements to be identified are already clearer! In addition, We must envisage specific measures to reinforce the reliability of these equipments or systems. Here no problem, it is necessary for us within the framework of a specific prevention, to ensure that this equipment or systems are able to work normally or at the desired moment. Lastly, In order that we do not forget anything, the drafting group of the ISM code insists by specifying that, certain tests or tests of the devices in stand-by (apparatus in redundancy or replacement procedures) are carried out regularly ; as well as for the technical materials or systems which are not in continuous use. There is here, in my opinion, a mistranslation: indeed “equipment and technical systems " are linked in the first part of the §, therefore they must logically remain also at the end of the § and we must thus read as above and not as in the French translation where equipment is related to " arrangements ". When we are an “habitué” of the code that does not have much importance, but I wish to point out that because these "stand-by systems" will take greater importance in the future in the prevention of accidents at sea which is the main objective of the code. In conclusion, these stand-by equipments and these materials or technical systems which are not in continuous use are …critical systems that the code encourages us not to forget. * (see NB 1) |
Capt B. APPERRY AFEXMAR President, MIIMS, AFCAN, IFSMA |
* NB 1: Draft amendment of the § 10.3 of code ISM (proposition)
10.3 – The Company should establish procedures in its SMS to identify the technical material & systems or stand-by arrangements the sudden operational failure or impossible operation or poor condition of which may result in hazardous situations for the crew, the ship or the environment. The SMS should provide specific measures of redundancy, maintenance and periodic tests as well as replacement procedures for equipment which can operate in a degraded mode in order to reinforce their reliability and to ensure their operation according to the need. ** NB 2: Anomalies A traceability of only one link of a cold chain or a quality certification applied to only one element of a chain does not have a sense; a SAFETY and ENVIRONMENTAL PROTECTION certification for only one element of maritime transport (the company and its ship) does not have more . What is the point if the ship is ISM certified if the pilot gets you aground, if the tug boat makes a hole in the hull, if the mooring gang releases a steel-wire spring in the propeller, if the port officer imposes you a dangerous berth, if the MRCC takes your damage “lightly”, if the charterer - in whom you have confidence (sic) - mixes anything in your container, if the Classification Society delivers you a certificate of convenience, etc...! The "attempt at reduction of the risks related to human activities" should logically be imposed soon to the other participants of the maritime transport, don't you think ? | Attempt at the Critical equipments or systems operational flow chart |