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Thursday, September 20, 2018


At an IACS Press Conference in Piraeus on the 7 of June, it was announced that it is IACS intention to propose to IMO and the EU annual audits for ships Safety Management Certificates (SMC).

At the 3rd Meeting of the Flag State Implementation committee at IMO in February 1995, the issue of how frequently the SMC should be externally audited was given wide and vigorous discussion.  INTERTANKO was a very active participant in this debate, and the outcome was between the second and third anniversary date of the issue of the SMC.  Within the Guidelines (Section 3.2.3), it was added that “In certain cases, particularly during the initial period of operation under the SMS, (Safety Management System), the Administration may find it necessary to increase the frequency of the intermediate verification.  Additionally, the nature of non-conformities may also provide a basis for increasing the frequency of the intermediate verifications.”  Thus the mechanisms for increasing the frequencies of audits are already in place for the Flag State to initiate should they so consider it necessary.  The classification societies in their announcement are conferring upon themselves the status of the Flag State.  The ISM Code is contained in Chapter IX of SOLAS and as it is an IMO convention IACS has no authority to demand requirements contrary to the SOLAS Convention.

Increasing SMC audits will penalise those companies which already have put in place an SMS and follow up the undertakings and responsibilities of their SMC.  The already burdensome audit requirements of tanker crews will be further worsened. This is another example of the current classification societies’ problems, namely the shipping industry does not require more regulations or inspections but rather better ones in the first place.

The problems of ships crews’ competence will not be solved by additional audits on the ships, but rather by better audit of the office under the Document of Compliance (DOC), which already has an annual audit requirement.  Here a competent auditor with good marine experience will be able to determine if the arrangements for sending competent crews to ships are effectively carried out according to realistic procedures.  It is too late when the crew is on the ship.  The problem is not the audits of the ship.

Thus INTERTANKO will be immediately reconvening its ISM Code Working Group, part of the Safety, Technical and Environmental Committee, to tackle this latest additional burden which high quality tanker operators are threatened with but do not need.  For further information, please contact