Inland Waters Small Passenger Boat Code
GUIDANCE ON SAFETY MANAGEMENT SYSTEM
(Based on MGN 158 (M) - Safety Management Code For Domestic Passenger Ships of Classes III – VI (A))
1. The purpose of this Annex is to provide guidance on how to develop and implement an effective safety management system such as the Safety Management Code for Domestic Passenger Ships.
2. The Code for Inland Waters Small Passenger Vessels covers a wide variety of operational locations and conditions. This guidance is therefore kept brief and simple, so that it can be applied to a wide variety of ships, and developed by each operator to meet the needs of that operation.
3. As part of a safety management system, each operator should create a safe working environment, which should include the following:
4. A health and safety protection policy.
This must address the issues of health, safety and the environment as they affect the operator and his staff, both ashore and afloat. Such a policy might read along the following lines:
“The policy of (name of Operator) is to conduct its activities taking full account of the health and safety of its employees and of all persons using or connected with the Operator. In implementing this policy, (name of operator) will ensure that the [ship] is, at all times, properly maintained and operated by qualified personnel in full compliance with relevant legislation. In particular the [operator] will carry out an assessment of the risks to the health and safety of workers and others affected by [the undertaking], and will take the necessary measures to minimise the risks identified.”
5. Under the Merchant Shipping (Prevention of Pollution by Garbage) Regulations 1998 (S.I. 1998/1377) Each operator of a ship of 12 metres or more in overall length should display placards to notify the crew and passengers of the ship’s disposal requirements. MSN 1720(M+F) is relevant and should be consulted.
6. It is an offence under section 131 of the Merchant Shipping Act 1995 for a ship in U.K. national waters, navigable by sea-going ships, to discharge any oil or oily mixture into those waters. The operator of such a ship is recommended to develop and implement an oil management plan to the same standard as the garbage management plan and to integrate it with the Health and Safety Protection Policy.
Procedures to ensure safe operation of ships in compliance with the regulations and rules.
7. The regulations and rules which apply to the domestic passenger ships include but are not limited to:
• Categorisation of Waters;
• The Merchant Shipping Distress Signals and Prevention of Collisions Regulations;
• Local Navigation Rules;
• The Merchant Shipping and Fishing Vessels (Health and Safety at Work)
• Merchant Shipping Notices and Marine Guidance Notes.
8. The operator should draw up simple procedures to ensure that safe working practices are carried out in the operation of the ship. These may be in the form of checklists that can be followed by all personnel.
9. For some ships, it might be appropriate to have permanently exhibited checklists, e.g. in the wheelhouse for navigational items. Alternatively, in a smaller ship, the record could take any suitable form such as a diary as distinct from a specially printed logbook. Whatever form the record takes, such entries should be accepted as evidence of compliance with the ONBOARD PROCEDURES requirements.
10. Lines of communication between personnel, ashore and afloat.
Responsibility and authority of each employee should be clear. This may be best illustrated in a simple diagram, showing who reports to whom.
11. Procedures for reporting accidents.
The requirement for reporting accidents should be well understood by all personnel and in so doing improve the safety culture practised on board.
12. Procedures for responding to emergency situations.
There should be clearly stated procedures for responding to emergency situations. These may include but not be limited to: fire; collision; grounding; violent act; main propulsion or steering failure; and man overboard. Checklists may be useful in this regard.
HEALTH AND SAFETY PROTECTION POLICY
13. The Merchant Shipping and Fishing Vessel (Health and Safety at Work) Regulations, specifically require the appointment of one or more competent persons to take responsibility for health and safety. That person/persons should be identified. It is the responsibility of the owner/operator to ensure that the policy is complied with, and
14. that the responsibilities are understood.
15. The operator should develop a policy on prevention of alcohol and drug abuse, in the light of the very strong comments made in the THAMES SAFETY INQUIRY Report by Lord Justice Clarke. Where alcohol is served on board, the policy should also stipulate that no alcohol will be served to persons under 18 years of age.
16. Under the Health and Safety Policy, all personnel both ashore and afloat have a duty to take care of themselves and other persons who may be affected by their acts or omissions.
17. It is essential that, in the event of an emergency, there is the ability to communicate with the emergency services via a shore base. The shore base may be the operator office ashore, the local Coastguard, Police or Fire Station, or another office as may be agreed between the ship and the shore base.
18. The Skipper must have authority at all times, to make decisions with regard to the safety of the ship and the persons on board. To ensure that there is no ambiguity regarding the authority of the Skipper, there should be a simple written statement to this effect.
PERSONNEL AND TRAINING
19. All personnel should receive training appropriate to the tasks they undertake. It is the responsibility of the operator to ensure that this training is given, and that the personnel have an understanding of the relevant regulations and rules.
20. As a minimum, this means:
1) for the Skipper, the relevant qualifications;
2) for the crew, training appropriate to their designated duties.
21. Prior to the first occasion of working on the ship, each employee must receive appropriate familiarisation training and proper instruction in onboard procedures. This could include but not necessarily be limited to:
• mooring and unmooring;
• launching and recovery of survival craft;
• evacuation from all areas of the ship;
• donning of lifejackets (where carried); and
• use and handling of fire fighting equipment.
22. Where the ship uses locks or sluice gates, on the job training in this process is essential. Relevant training should also be provided to casual staff – ie not regular “crew” – who may be needed to assist in controlling/guiding passengers in the event of evacuation.
23. Simple procedures should be developed for the operation of the ship. These should include, but not be limited to:
• testing of equipment, including steering
gear, prior to commencing a passage;
• navigation and handling of the ship;
• maintenance routines;
• bunkering operations;
• watertight integrity;
• stability of the ship; and conduct of passengers and crew while on board.
PREPARATION FOR EMERGENCIES
24. The potential emergencies likely to be encountered by the ship should be considered. Exercises should then be carried out in the handling of these emergencies and evacuation from the ship.
25. Where possible, all personnel should be involved in these exercises, both ashore and afloat. (Refer to MSN 1761, paragraph 6). The roles and responsibilities of all personnel in an emergency situation should be developed in accordance with the principles of the Code.
26. The exercises should be recorded. The names of those who participated should also be recorded.
REPORTING OF ACCIDENTS
27. It is a legal requirement under the Merchant Shipping Act to report all accidents. The Merchant Shipping (Accident Reporting and Investigation) Regulations 1994 refer.
28. The regulations apply to all ships. The operator must therefore have a procedure in place to report any accident to the Marine Accident Investigation Branch (MAIB) and/or to an office of the MCA. Additionally, all accidents and near accidents should be recorded and reported to the operator, who should implement corrective action, with the aim of improving safety.
MAINTENANCE OF THE SHIP AND EQUIPMENT
29. Maintenance of the ship and equipment is an essential ingredient of safety management. The equipment should be checked and tested daily when in use; in addition to the tests referred to in the ONBOARD PROCEDURES section of this guidance.
30. There should be procedures for a more detailed inspection and maintenance programme of the ship and equipment. The frequency of the inspections should be determined by the operator, but every event should be recorded.
31. A checklist could be employed as an aide memoir for the inspection of equipment.