Reacting to my column last Saturday on the subject of safety management system, friends in the maritime sector asked what is it we should expect Government’s next step to ensure that the safety management system (SMS) works.
We all know that whenever a maritime casualty takes place, government response involves contemplating possible suspension of the company’s Certificate of Public Convenience (CPC), or launching a marine casualty investigation, or both. We gathered from news that a special investigating committee was formed by the Philippine Coast Guard (PCG); and possibly MARINA motu proprio is doing its own determination of the cause(s) of the accidents. Whatever the result of these investigations may be will lead to imposition of sanctions as are allowed by existing regulations.
What government does in the meantime while marine casualty investigations are being conducted should be an immediate concern. Should an audit of the SMS to determine if measures to address foreseeable risks pertinent to the circumstances surrounding the accident be integral to the system? And if not, would absence of these be considered as non-conformity that requires inclusion of such measures in the SMS? In a country expecting at least a dozen or more typhoons annually, identifying sanctuaries for ships during inclement weather should at the very least find its way into the SMS.
It is a complex set of actions, as the company audit will mean subjecting the Document of Compliance (DOC) to more meticulous scrutiny to determine its correctness as an attestation that ships managed by the company, of the same type as that which figured in the mishap, comply with Memorandum Circular No. 2015-11. This requires corresponding shipboard audits on covered ships listed in the DOC.
Has MARINA initiated audits on the companies that figured in the recent mishaps? And if there are non-conformities found, how soon are these to be closed out? These questions find relevance in the non-operation of ships while the audit is being conducted, short of any CPC suspension. This also denotes the immediate restoration of shipping services thus avoid continuous disruption in the movement of passengers and cargoes. It is a process that the administration has taken before; there should be no exception now.
Improving the SMS should not wait until casualty investigations are completed as ensuring maritime safety should not be put on hold. A company audit and shipboard audit should take place immediately in order to restore the confidence of passengers and shippers as corrective actions are instituted.
There are reasons to believe the ISM Code implementation in domestic shipping has contributed considerably to improving domestic ferry safety.