The SMS Blueprint | Essential Content Every Safety Management System Must Mandatorily Include, As Per Transport Canada
A well-structured Safety Management System (SMS) is what defines ideal and safe vessel operations and promotes environmental stewardship. So, for all vessel operators in Canada, here is a list of the minimum or least amount of content a law-abiding SMS must incorporate, as per the Marine Safety Management System Regulations (MSMSR) by Transport Canada (TC):
1. Safety and Environmental Protection Policy
For starters, your marine safety management system must voice your organization’s commitment to safety and environmental protection.
Scope: The policy should mandatorily mention ship personnel at all levels, including shore-based staff, shipboard personnel, and subcontractors. The SMS must also delineate their responsibilities within the work environment.
Commitments: Specific actions like the following should also be highlighted, on how you plan to:
Protect the environment,
Provide a safe working culture
Prevent human injury, loss of life, and property damage
Manage risks effectively, and
Pursue continuous improvement in operations.
2. Designated Person Ashore (DPA)
For Class 1 and 2 vessels, a documented SMS must include:
DPA Role and Qualifications:
Contact information for the DPA
Relevant qualifications, such as ISM Lead Auditor certification or management experience in safety systems.
"When appointing a DPA for domestic vessel, consider one of the following qualifications, training, and experience:
3.2.4.1 Completed a recognized ISM Lead Auditor course;
3.2.4.2 Qualified in evaluating the effectiveness of an SMS;
3.2.4.3 Management experience relevant to the SMS;
3.2.4.4 Participation in an initial verification or renewal verification as part of an SMS verification team;
3.2.4.5 Participation in ISM audits or marine SMS verification; or,
3.2.4.6 Participation in verification of compliance with other management standards (ISO 9001:2018; ISO 14001; ISO 19011)."
Responsibilities: The DPA must
Serve as a link between shore-based and on-board operations
Monitor safety and pollution prevention
Ensure adequate resources and support for vessel operations
Guidelines for Appointment: You are required to follow MSC-MEPC.7/Circ.8 "Revised Guidelines for the operational implementation of the International Safety Management (ISM) Code by companies"
3. Resources and Personnel
Your ship's SMS must ensure that both shore-based and shipboard personnel are qualified and prepared. Here's how:
Understanding Rules: Ensure personnel are acquainted with the regulations and safety protocols, codes, and varied guidelines set.
Medical Fitness and Qualifications: Verify personnel’s suitability for assigned duties.
"It should include procedures to ensure that on-board personnel are properly qualified and medically fit."
Essential Instructions: Incorporate important instructions around making the on-board personnel well aware of their responsibilities and duties, as well as their relationships and authority with respect to others in the SMS.
Familiarization: Include procedures for onboarding new or transferred personnel. To understand the complete system of familiarization, check out 3.3 subpart of the MSMSR.
Effective Communication: Establish clear communication procedures for all operational roles.
4. Levels of Authority and Lines of Communication
As the title explains, all SMSes are necessitated to immaculately define roles, responsibilities, and reporting lines. This is how TC suggests you go about it:
Organizational Structure: Develop diagrams to illustrate communication pathways between and among shore-based and on-board personnel for clearer understanding.
Master’s Authority: Highlight the master’s role in implementing safety policies and ensuring compliance, specifying that the the master has "overriding authority and responsibility to make decisions about safety and pollution prevention". A well documented SMS must delineate all duties and responsibilities of the master in an articulate manner.
Operational Clarity: Specify all operational responsibilities for both routine and emergency scenarios for all personnel.
5. Operational Procedures
Furthermore, your SMS must include detailed instructions for key vessel operations:
Safety Operations: Include checklists for loading/unloading, stability assessments, and safe navigation.
Environmental Protection: Address waste management, pollution prevention, and compliance with environmental regulations via mandatory regulations for your vessel type.
Emergency Readiness: Provide steps for preparing the vessel for severe weather or extended lay-up.
P.S. All operations must "ensure the safety of the vessel and crew, protect the environment, and prevent pollution". These cover ensuring seaworthiness and stability through proper loading, unloading, and stability assessments (intact and damaged). Voyage planning and navigation procedures address departures, arrivals, weather considerations, towing, anchoring, and radio communications, along with fuel transfers and preparations for adverse weather. Safety measures focus on conducting safety meetings, drills, managing fatigue, ensuring safe entry into confined spaces, and properly disposing of sewage, garbage, and waste oil to protect the marine environment.
6. Reporting, Addressing Marine Occurrences & Non-Conformities
A well-rounded SMS must engulf robust processes for incident reporting and corrective measures. As per TC, a non-conformity is defined as a "situation where there is objective evidence that a requirement of the regulation has not been fulfilled" whereas a major non-conformity as a "deviation that poses a serious threat to the safety of personnel or the vessel, or a serious risk to the environment, requiring immediate corrective action".
Marine Occurrences: Include protocols for reporting to authorities such as Transport Canada or the Transportation Safety Board of Canada.
Non-Conformity Reports: These forms, as part of your SMS manual, must include type of non-conformity, date, time, and reference of the incident, its description, root causes, corrective actions, and verification steps.
7. Emergency Preparedness
Every SMS is necessitated to incorporate procedures for the personnel to handle emergencies effectively:
Emergency Scenarios: Cover medical incidents (injury, accident or death), equipment failure, pollution, and abandon-ship protocols. Plans should include pollution response (fuel, sewage, cargo) and adherence to ERAP guidelines.
Communication in Emergencies: Provide detailed reporting procedures to authorities. Timely reporting to authorities like the Canadian Coast Guard, CANUTEC, and TCMSS is essential.
8. Maintenance and Review of the SMS
Regular updates and reviews are essential for an effective SMS. In order to maintain the same, a ship owner must
Continuous Feedback: Include a system for collecting and acting on feedback from personnel.
Internal Reviews: Conduct evaluations annually, led by personnel not directly involved in the area being assessed. The results of these internal reviews should be shared with all vessel personnel in the evaluated area.
Corrective Measures: Address identified issues with clear action plans to prevent recurrence.
9. Document Control
A proper documentation system ensures the SMS is accessible at all locations and are up to date:
Version Control: Regularly review and approve changes to documents.
Retention Period: Retain documents, in the most effective form, for at least five years. Out-of-date documents are required to be removed promptly.
How We Come Into the Picture
Now you know everything about what an SMS must essentially comprise. But if this is something you'd like assistance with, you're in the right place! For Oceanaut, the flagship product by Albatross Marine and a comprehensive vessel management system, can streamline the creation and management of your SMS.
Digital solutions like Oceanaut simplify SMS documentation, updates, and audits, keeping your operations safe and compliant. Get in touch to learn more!
Article reference links:
https://laws.justice.gc.ca/eng/regulations/SOR-2024-133/page-1.html
For more on Oceanaut, visit www.albatrossmarine.ca or contact us: [email protected] , +1-902-800-8055 or +1 (778) 987-4766.
