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Assessing The Effectiveness Of The International Safety Management (ISM) Code In Developing A Safety Culture

By: George Zeitler, MSc

Email: Mr. Zeitler
Telephone: 954-804-8919


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Abstract

The adoption of the International Safety Management Code by the International Maritime Organization as a means to promote a change in maritime industry’s attitude towards safe operating practices has been well documented. The code placed a strong level of responsibility on the ship owner or operator to conduct a self-assessment of their policies and practices in order to develop and implement a safety management system that was auditable by internal personnel and the company’s chosen regulatory bodies – Flag Administration and Classification Society. IMO’s regulatory efforts had previously be prescriptive and dealt with the design, outfitting and operation of a ship. The code extended this regulatory oversight to the shoreside management. After over two decades of use, few studies have been conducted to examine the impact and effectiveness of the ISM Code in modifying and improving the safety culture within the maritime industry. As IMO has yet to set a specific end state they wish to achieve through the implementation and enforcement of the ISM Code this paper utilizes trend analysis to review data from four different sources – port state control inspections, accident investigation reports, environmental crimes cases, and a specially developed questionnaire sent to a representative cross section of the maritime industry. The collected data has been displayed graphically and examined to identify trends. For most data collected, the presence of a downward trend (i.e. a reduction in the quantity) is considered a positive safety trend. Based upon these trends, and utilizing studies on culture and behavior changes, an assessment of the impact and effectiveness was concluded. The results can form the basis for moving the discussion on the presence of a safety culture in the maritime industry forward and for highlighting gaps where the ISM Code may need future revision.

Research Objectives

The adoption of the International Safety Management Code by the International Maritime Organization as a means to promote a change in maritime industry’s attitude towards safe operating practices has been well documented. The code placed a strong level of responsibility on the ship owner or operator to conduct a self-assessment of their policies and practices in order to develop and implement a safety management system that was auditable by internal personnel and the company’s chosen regulatory bodies – Flag Administration and Classification Society. IMO’s regulatory efforts had previously be prescriptive and dealt with the design, outfitting and operation of a ship. The code extended this regulatory oversight to the shoreside management. After over two decades of use, few studies have been conducted to examine the impact and effectiveness of the ISM Code in modifying and improving the safety culture within the maritime industry. As IMO has yet to set a specific end state they wish to achieve through the implementation and enforcement of the ISM Code this paper utilizes trend analysis to review data from four different sources – port state control inspections, accident investigation reports, environmental crimes cases, and a specially developed questionnaire sent to a representative cross section of the maritime industry. The collected data has been displayed graphically and examined to identify trends. For most data collected, the presence of a downward trend (i.e. a reduction in the quantity) is considered a positive safety trend. Based upon these trends, and utilizing studies on culture and behavior changes, an assessment of the impact and effectiveness was concluded. The results can form the basis for moving the discussion on the presence of a safety culture in the maritime industry forward and for highlighting gaps where the ISM Code may need future revision.

This paper presents the finding of research into the effectiveness of the ISM Code in altering the safety and environmental cultures within the maritime industry. While the ISM Code is considered to principally focus on safety, an additional objective of the Code was for the maritime industry to avoid damaging the marine environment [IMO, 1993]. The primary question to be answered was that twenty years after coming into force, has the ISM Code been effective at altering the safety/environmental culture in the shipping industry? If not, how can its effectiveness be improved? The main aim of the study was to determine whether the ISM Code has had the anticipated effect of improving the safety and environmental cultures of the marine industry and if not, why.

In order to accomplish this, the following analysis was carried out: evaluation and comparison of port state control inspection and detention data, evaluation of accident investigations prior to the implementation of the ISM Code and those occurring in the last three years to identify any trends in root cause or causal factors, particularly regarding any contribution that shore side management has had in accidents during the last three years, assess the presence of an environmental awareness culture by reviewing environmental crimes cases to identify trends and any contribution from shoreside management, and evaluate the responses to a questionnaire sent to individuals representing shipboard crew, shore side management, and flag administrations.

For the purposes of this study, the term ‘safety culture’ wherever used includes both safety and environmental awareness.

Literature Review

The ISM Code is a departure from the regulatory schemes used to ensure the safety of vessels, crew and passengers, and the marine environment for almost 80 years. Starting with the sinking of the Titanic in 1914, various international conventions were adopted with the sole purpose of prescribing key design, structural, outfitting, or operational requirements that must be complied with in order for a vessel to be certified to carry cargo between signatory nations. The incidents previously discussed shone a spotlight on the fact that safety did not solely rely on the actions (or inaction) of the crew. It also included the actions or inactions of the shoreside management team and highlighted a general lack of a safety culture amongst all parties involved. A new regulatory effort to ensure shoreside management provided the organizational support needed to promote the safety and well-being of the vessel, crew, and environment needed to be developed. Following on the heels of the tragic accident involving the Herald of Free Enterprise, and coinciding with an increased focus on quality management in commercial businesses through the development of the ISO 9001 standard, IMO passed a resolution that provided guidelines on the safe operation and management of ships. When the rate and severity of shipping accidents did not appreciably change, these guidelines were incorporated into the Safety of Life at Sea convention; enabling the requirements to be enforced by both the vessel’s Flag administration as well as the various port states the vessel called on during the course of its voyage.

As with any quality management philosophy, once a change is envisioned, the organizational leaders should go through a four-step process – plan, do, check, and act. The drafting of the guidelines and adoption of the ISM Code into SOLAS can be seen as the planning and doing phases of quality management. The question arises whether the third phase – checking – has been adequately accomplished; especially considering that the Code has been amended on five separate occasions. In attempting to assess the impact or effectiveness of the ISM Code in improving the safety culture within the maritime industry, a review of existing research was conducted. The goal was to identify whether a substantive analysis of the impact of the ISM Code had been carried out since the final phase of implementation in order to build on its foundation. Research typically fell into one of three areas of emphasis. The first was analysis of the effectiveness of the ISM Code in developing a safety culture within the shipping industry. There were few studies in this area. A second, more prevalent area of research dealt with safety culture at the company level. In these studies, the impact of the ISM Code was typically viewed as an ancillary factor, with the studies typically focusing on the safety culture within the organization. Scant attention was paid to how the Code was interpreted and implemented by the company. Since the organization was required to comply with the regulatory scheme there was little attention focused on whether the regulations had any impact. The most prevalent area of research dealt, not with the ISM Code, but safety cultures, in general. Research in this area was found to be beneficial in assessing whether a safety culture exists within the shipping industry. It also provided a peak into strengths and weaknesses within the ISM Code.

Changing Safety Cultures

“Safety culture is a series of beliefs, norms, attitudes, roles and social and technical practices which are established to minimize the exposure of employees, managers, customers and third parties to hazard” [Dyrhaug, A. and Holden, 1996, pp.7]. When discussing the culture of an organization, Schein’s work is generally noted as the baseline. In his studies, three key elements were highlighted as being necessary to discuss the culture of an organization. These consisted of artefacts, values, and basic assumptions [Schein, 1985]. While these can be easily identified within a single organization such as a company, these elements are much harder to clearly identify when you look at an industry. Due to the extreme diversity amongst ship owners and industry segments regarding organization, management style, customer needs, ship design and construction, and vessel operating procedures, using Schein’s analysis to evaluate the culture of the shipping industry is not appropriate. However, the statement that “organizational culture is a pattern of basic assumptions – invented, discovered, or developed by a given group as it learns to cope with its problems of external adaption and internal integration – that has worked well enough to be considered vital and, therefore, to be taught to new members as the correct way to perceive, think and feel in relation to those problems” [Schein, 1985: pg 9] can be seen at the heart of the changes the ISM Code hoped to bring about.

If the implementation and adherence to the constructs of the ISM Code was to lead to the development of a safety culture in the maritime industry, an evaluation of safety behaviors prior to the introduction of the Code is required. The safety discussions typically found in the general workplace can be considered as a comparison to similar specific discussions about the shipping industry; the difference is the scale of the accidents being discussed. One can substitute a discussion of causes for collisions, groundings, sinkings, etc. for discussions regarding personnel injuries, slips, trips, and falls; one discussion focuses on the micro level and one on the macro level. DeJoy [2005] looked at divergent approaches to managing workplace safety. Specifically, DeJoy identified two methods for managing workplace safety: a behavior-based approach focused on identifying and altering critical safety behaviors by extolling how they impact personnel injuries and losses and an emphasis on the importance of the organization’s safety culture and how it influences the actions of company personnel.

The behavior change theory utilizes rewards and punishments to encourage work groups to correct their actions in order to conform with an acceptable practice – that being safe work practices in this case. Organizations that utilize this behavior change theory use three steps to drive the change. First, they identify and clearly define the behavior to be changed. They set goals to focus the behaviors and to track performance and finally they gather feedback in order to encourage continuous improvement. In order to encourage the changes, some means of external reinforcement is required (could be as simple as a bonus for good performance or loss of employment for poor performance). In utilizing this approach, as long as the external reinforcement is present, the changed behavior should continue. Once the reinforcement is removed, the behavior will tend to return to the previous norm. DeJoy highlighted that in some of the recent studies, the periodic re-application of the reinforcement could result in more lasting results. This could lead to more of a cultural change if done long enough.

Behavioral change is employee focused. It requires the workers to buy in – usually encouraged by the reinforcer. This does not necessarily address the issues that tend to negatively impact the safety culture in shipping – pressures from shoreside management to meet financially driven objectives. One potential drawback to the behavior approach is it assumes that faults for accidents lie with the crew. Following an accident, behavior systems tend to look at the specific actions that preceded the incident to determine what changes to procedures need to occur. It does not carry out a full root cause analysis. As borne out during analysis of ship accidents and detentions, it would appear that many organizations in shipping fit this theory. This is exactly why the ISM Code was developed.

DeJoy’s second method, culture change, was derived from the expectation that the values of the organization regarding safety will drive the success of any plans or initiatives to manage safety. These efforts will mold the beliefs of employees regarding the organization’s safe work practices. Under the ISM Code, the company’s Safety Management System (SMS) is supposed to accomplish this culture change, especially since the Code mandates the SMS undergo periodic review by the users (ship’s crew). For this method to be successful, management must truly believe in the importance of safety and must incorporate the employee into the management of safety within the organization by seeking input into policies and procedures. However, if management only pays superficial heed to the management system, the culture change doesn’t occur. The company’s Safety Management System cannot only exist on the shelf. The organization must have the total commitment of senior management to the SMS. In order for the Code to be successful in changing the safety culture, it relies on the organization to place the value of safety above everything, with the threat of a ship being detained the only reinforcement. For companies with large fleets that operate in spot market or tramp services, they may be willing to take a calculated risk that one ship being detained for a short period of time will not significantly impact their bottom line thereby resulting in a less noticeable change in culture (companies in liner service or highly competitive markets do not have this luxury and tend to be more risk averse). Consequently, relying on management’s total commitment may be a fundamental flaw in the ISM Code that warrants further study beyond the scope of this project.

A potential weakness in the culture-based approach exists. Under this approach, the culture is continually assessed and methods to continually improve are sought. However, the assessment of the change is subjective and can result in the organization becoming complacent. This can most often show up in the organization’s implementation phase. The Code requires the company to internally assess and document its procedures and current culture. Then, through periodic internal audits and management reviews, revise the initial assessment and documentation to address gaps, trends, or changes. Consequently, the assessments are subjective and are only as effective as the effort put in. These assessments consist of the annual internal audits and periodic external audits required under the Code. The organization must have high quality audits to identify gaps or shortcomings and seek out he required improvement. Following the behavior versus culture change theories, it would appear that IMO is attempting to use behavior change theory masquerading as culture change to raise the level of safety in the industry. The effectiveness of the ISM Code still appears to rely on the threat of a ship being detained (or banned from a region) or a poor performing company to be targeted for increased frequency of inspection in order to compel compliance.

Does a safety culture exist within the maritime industry? Havold [2000] attempted to identify the presence of a safety culture within the maritime industry by analyzing existing research. At the time, there were two terms being utilized, often interchangeably – organizational culture and organizational climate. Havold distinguished between the two terms by using Schein’s previously mentioned definition of organizational culture and Campbell, et al’s [1970, pp. 390] definition of organizational climate: “a set of attributes specific for an organization which can be observed by the way the organization is dealing with its members and its environment. For each member of the organization the climate will appear as a set of attitudes and expectations that describe the organization both in static characteristics (like the degree of autonomy) and links between actions and result, and one result related to another.” However, Arslan et al [2016, pp. 3895] had a more succinct definition of safety culture: “how an organization behaves when no one is watching.” Havold’s analysis indicated that to be considered a culture, the behaviors had to be part of the subconscious while to be considered a climate the behaviors were part of the conscious. If one considers safety to be a culture that exists in the subconscious, then a safety climate would also exist within the organization as a part of that culture. But the converse would not be true.

The stated objective of the ISM Code was to create a cultural change within the maritime industry regarding safety. But in order to change the culture, one must imbue a safety awareness into the subconsciousness of thousands of shipboard crew members from different cultural backgrounds as well as the shoreside personnel tasked with supporting them. In order for that to occur, the ship owner must buy in to the process by critically assessing the organization and then developing and implementing the policies necessary to bring about the desired changes. There is a strong likelihood these changes will impact the bottom line, at least in the short term, which causes organizations with little margin to identify ways to minimize the changes or circumvent the requirements. As soon as the top-level management stops supporting the process, the cultural change ceases and the ISM Code loses its effectiveness.

Safety Culture at the Company Level

The difference between a culture and a climate were clearly indicated during Zohar’s study of 20 industrial organizations in Israel regarding the employees’ perception of the importance safety plays within their company. The study indicated that outside safety inspectors observed a strong correlation between employee perception and the effectiveness of the company program [1980]. Additionally, companies with strong safety culture and low accident rates had direct involvement from top-level management. This is correlates to DeJoy’s observations regarding culture and behavior theories.

Zohar identified eight factors that differentiated the safety cultures between organizations. These factors included the perceived importance of: safety training programs, management attitude towards safety, effects of safe conduct on promotions, level or risk, effect of work pace, status of safety officer, effect of safe conduct on social status, and the status of the safety committee [1980, pp. 98]. To these, Havold added a ninth factor: the degree to which accidents and incidents are investigated to determine causal factors and modify procedures to reduce the likelihood of future incidents [2000, pp. 81].

Both Havold and Zohar observed that management commitment and employee involvement are critical to development of a safety culture; an observation that mirrored DeJoy’s belief that organizations with a true safety culture have a strong commitment from the top down and the employees are actively involved in the management of safety. Havold summed it up succinctly by opining that “good safety performance is, therefore, a matter of much more than the preparation of well-structured company safety procedures [2000, pp. 82].”

The key to achieving that performance, noted by Akyuz and Celik [2014], was implementation and enforcement. Periodic assessments (the ISM Code required annual internal audits) was necessary to increase the effectiveness of the company’s safety management system. Enforcement was a reinforcer for getting the work force to develop appropriate habits.

In his study, Zohar noted that a consistent feature of high performing companies was a strong emphasis placed on safety training. Almost as important was the open communication between management and workers. Under the ISM Code, that function can be seen with the role of the Designated Person Ashore (DPA) who is tasked with providing a direct link, outside the normal chain of command, between the lower levels of the organization and the top managers.

High performing companies have clear and distinctive ways of promoting safety within the organization, including guidance and counseling instead of simple enforcement and punishment. The urgency in accomplishing this can be found in ICS’ observation that “the indirect financial costs of accidents for a company are generally about three times those of insurance claims involving personnel, cargo damage, or pollution [ICS: pp. 5].” Under IMO’s various regulatory schemes particularly under the ISM Code, safety is primarily promoted via negative reinforcement – companies are punished (e.g. - detentions, blacklisting, banned) and it is left to commercial market forces to positively reinforce. Under DeJoy’s theories, this is a further example of behavior change theory and not culture change, as IMO intends. Some port state control (PSC) regimes have tried to alter the paradigm through the use of quality performance incentives for PSC exams, typically by reducing the frequency of a ship’s PSC inspections for companies that meet a specific threshold of performance over a period of time.

So how do these companies act? Aslan et al [2016] conducted a safety climate assessment within a single company in an attempt to develop an assessment and implementation framework necessary to identify weaknesses in the company’s safety culture and develop strategies to close any gaps or to raise performance. The study utilized questionnaires designed for specifically for shipboard and shoreside personnel with follow up interviews for a percentage of the respondents. The results were broken down into ten factors (dimensions) and the scores between the shoreside personnel and shipboard crew were compared in order to develop the overall safety score of the company. Some key findings included the observation that shoreside personnel had a better attitude towards safety than the crew, especially when the questions delved into issues of employer-employee trust. This phenomenon will be discussed further in the following section. Another keen observation was that the factor of promotion of safety within the company was the second lowest score for both groups. This flies in the face of DeJoy’s assertions that in order for an organization to follow a path of culture change, there must be total buy in from senior management and is another indicator that the ISM Code may not be able to provide the wholesale cultural change that IMO envisions.

As part of the prelude to the one hundredth anniversary of the adoption of the first SOLAS convention, the International Chamber of Shipping published a document to assist shipping companies in implementing an effective safety culture [ICS, 2013]. The paper noted, as with the Allianz study and others, that following the initial implementation of the ISM Code there was a noteworthy decrease in the number of accidents, spills, and lives lost. But by the start of the second decade of the millennium, there were a number of highprofile incidents (Deepwater Horizon and Cost Concordia to name two) that highlighted that the industry still faced an overall lack of a safety culture. One of the key aspects to fully developing a safety culture was for companies to maximize the potential of the SMS to create and manage barriers to accidents. Barrier management is the key to reducing or eliminating accidents. A properly implemented SMS enacts physical and procedural barriers that reduce the likelihood that all the causal factors necessary for an accident to occur will align themselves.

The ISM Code, through the company’s SMS, encourages the self-regulation of safety. The critical link to accomplishing effective self-regulation is by setting safety goals and targets. This is the basis of DeJoy’s cultural change theory. In order for the company to set SMART safety goals, one must acknowledge that incidents are preventable, all company personnel must be continuously vigilant, and key performance indicators for tracking safety improvement must be identified. These points broadly support the findings of Havold’s and Zohar’s studies.

Effectiveness of the ISM Code

Few direct analyses of the effectiveness of the International Maritime Organization’s (IMO) regulatory scheme for driving cultural change were carried out. At the direction of IMO an assessment was conducted by a selected panel of industry experts. The study commenced shortly after the final phase of implementation was completed and had the directed purpose of determining whether the ISM Code had the expected impact on the safety culture within the shipping industry. The stated goal was to determine if the ISM Code had improved the safety culture and quality of shipping [IMO,2005] and the study consisted of both primary and secondary data analysis.

The first phase of the study analyzed secondary data consisting of the number of deficiencies issued during port state control inspections. The results were inconclusive. Due to the number of variables regarding the identification and reporting of deficiencies, no identifiable trends between the number of inspections, deficiencies and the implementation of the Code were found. The panel determined that, while objective evidence of a decrease in deficiencies was noted, the impact of other regulatory work involving national, regional and international organizations could not easily be isolated from the impact of the ISM Code. Therefore, the decrease in deficiencies could not be solely attributed to the ISM Code.

The second phase of the study involved developing and distributing questionnaires through various thirdparty organizations to flag administrations, ship owners and seafarers. The IMO panel found the data tended to indicate a positive impact from the implementation of the Code. However, that information differed from the experiences of the panel members. The low percentage of responses within each industry segment to the questionnaires did not allow for definitive opinions to be developed.

A total of 162 questionnaires were sent to Flag administrations of which less than twenty percent responded. Those that responded covered a wide size range – from registries with less than 50 ships to those with more than 1000. Noteworthy was that half of the respondents saw a decrease in detentions, thirty percent saw no change in the number of detentions and ten percent saw an increase. The trends regarding accidents was similar following the final phase of implementation [IMO, 2005]. This would indicate that the initial impact of the Code was a positive trend towards increasing safety in shipping.

The study received a total of 39 responses to the shipping company questionnaire. The companies represented a broad swath of the shipping industry with fleet sizes from small to large. Statistically, the response showed that almost one-quarter of the companies felt that they had found no major measurable benefit to the implementation of the Code [IMO,2005]. The study also highlighted the significant costs associated with obtaining and maintaining compliance. Those costs included monetary amounts for implementing and maintaining compliance, as well as personnel, where companies had to increase the number of shoreside employees to manage the SMS and compliance systems. This makes compliance one area easily targeted for financial savings for companies with little profit margins.

Harking back to DeJoy’s theory on cultural change, top level management must be all in on the safety culture in order for the changes to take hold. For companies that are seeing little return on the investment, financially committing to sustained compliance may become difficult. Effectively, the IMO assessment indicates that over time, as the return on investment diminishes, twenty-five pert of the industry will see safety improvements level off or begin to trend negatively. For those companies, DeJoy’s culture change has not occurred; only behavioral changes encouraged by a reinforcer have taken place. If monetary support is reduced, the reinforcer is removed and a regression in safety can easily occur. Regardless, one significant positive change did occur, communications between the shipboard crew and shoreside improved. If that continues to hold true in the future, the momentum for cultural change in these companies can be recaptured.

The response from seafarers was particularly lacking, less than 3,000 (less than one percent of the estimated crew world-wide) responded. Those that responded almost universally felt that the ISM Code had a positive impact on their work and their safety. While this would appear to be a strong endorsement of the ISM Code, the study group had to discount the results due to the sample size of respondents not adequately reflecting the industry as a whole. It appeared that only those with favorable attitudes towards the ISM Code took the time to respond, those with neutral or negative impacts where not represented in the responses.

In the end, the study team determined, typically, only those organizations or individuals that had a positive experience with the implementation of the ISM Code tended to respond. This meant the input from a large segment of neutral or negatively impacted organizations and individuals was missing. In the end, IMO’s committee stated “the success of its implementation depends to a great extent on the continued commitment, competence, attitudes, and motivation of individuals, at all levels, in the company and onboard ships to which the ISM Code applies” [IMO, 2005 pg 2]. The panel concluded the implementation had been successful and had generally resulted in positive changes to the safety culture.

Bhattaraya [2011, pp.528] observed that through his research that studies showed that roughly twenty percent of ship owners fully adopted the ISM Code and integrated it into their management philosophies. The remaining eighty percent saw the Code, to one degree or another, as a paperwork exercise that must be completed in order to continue operating. This contradicted the observations from the IMO study.

Members also concluded that reducing the administrative burden to achieve compliance through the following methods would result in increased compliance: streamlining paperwork required to be completed by the crew, make effective use of technology, encourage the crew to take ownership of the company Safety Management System (SMS) by refining the procedures it contains, and finally by increasing training for all users. As highlighted in Sanguri’s [2016] article, the typical seafarer still believes the administrative burden of completing all the reports, logs, and checklists required under the SMS, as well as the inadequate training regarding what is required have negatively impacted them.

As a final action, the panel recommended that IMO carry out a follow up study in the future to obtain a better understanding of the Code’s impact by reviewing Flag State safety records and port state control deficiencies for ISM compliance data. This study does not appear to have been carried out. However, some of the data collected for this research can provide some insight into the potential results from such a study.

If one presumes that an effective safety culture has been developed through the effective implementation of the ISM Code, then over time, the accident rate onboard ships should decrease. Similarly, the number of detention due to non-compliance, or the quantity of detainable deficiencies found on any given inspection should likewise decrease. Papanikolaou, et.al [2015] conducted a statistical analysis of ship accidents for the world’s shipping fleet over a 22-year period starting in 1990. The study built upon data from a previous Det Norske Veritas (DNV) study. The goal was to identify the relative safety level of each ship type to determine if any one type had a greater likelihood for accidents to occur. The results indicated that during the time period between 2002 and 2012, the frequencies of incidents generally increased. Since this is the time frame immediately after the implementation of the ISM Code, it could be argued that, if the Code was effective, these frequencies should have decreased.

Similarly, in a study of port state control data from the Tokyo Memorandum of Understanding for the AsiaPacific region, Chen, et al [2019] observed that the number of detainable deficiencies found on vessels had increased during the period from 2015 to 2018. The study highlighted the factor that played the largest role in a ship being detained within the Tokyo MOU between 2008 and 2017 was a failure to comply with the ISM Code. This would seem to contradict the Allianz study’s conclusion and the desire of IMO for the Code to promote a safety culture within the shipping industry.

An examination of the ISM Code’s impact and effectiveness from a qualitative perspective in an attempt to correlate research on “whether employment and social conditions identified as necessary to support effective implementation of self-regulating workplace health and safety procedures by shoreside management of are present in the maritime industry” [Bhattacharya, pp. 528]. Part of the reasoning behind the project was a 2008 International Union of Marine Insurance study that showed the total number of ship losses (sinking, etc.) had decreased over the first 10 years the ISM Code had been in place while the number of other types of incidents had actually increased. The data for the Bhattacharya’s study was developed during a three-year case study involving two tanker operators with a good business reputation and with a port state control detention ratio that was better than the industry average. Data was collected from the shoreside offices as well as from two vessels for each organization. The vessels selected had average or better safety records.

One hurdle acknowledged as making an effective analysis of the impact of regulatory schemes in the maritime sector difficult is that shipping companies differ greatly in their organization, structure and function. For that reason, Bhattacharya felt that regulatory schemes designed to deal with operational management consequently must be broad frameworks that provide the guidance to companies on how to develop their own policies and procedures into risk management, maintenance, emergency preparedness, and incident reporting.

Bhattacharya’s study concluded that mariners have a reduced level of participation in workplace safety management which has the effect of limiting the impact of a self-regulating management process. Often management is convinced that robust policies and procedures are the lynchpin to safety. For the case study, it resulted in shoreside micromanaging the ships to ensure compliance. This opinion was furthered by management’s theory that there should be one common procedure throughout the fleet – they did not take into account the differences between vessels or agree to allow the ships to develop their own shipspecific procedures. Considering the crew felt it was their knowledge and experience that was responsible for safety onboard and the company’s Safety Management System (required under the ISM Code) only needed to provide guidance for new crew onboard or for those procedures not done routinely, this led to distrust between the groups. This led to a critical failure under the ISM Code – the crew on one ship developing and maintaining their own special manual that consisted of a compilation of specific engine room maintenance jobs.

Both companies had adversarial relationships between ship and shore which resulted in an atmosphere of blame (shoreside) and fear (crew). As highlighted in this study, when the effectiveness of the ISM Code is analyzed from the bottom up (crew perspective) as previously discussed by DeJoy, it appears to have fallen short of the expectations of IMO. The bureaucracy that the code has created mandates that crew do what is necessary to pass the audits in order to keep their jobs. Consequently, no real effective change to the safety culture within the industry has occurred.

Research Design and Methodology

In planning the research for this project, a single phased mixed method approach was utilized for the purpose of carrying out exploratory research. A single phase of data collection was adopted due to the limited time frame for collecting the data. Since a significant portion of the data is from secondary sources, the only need for an additional data collection phase was to follow up on the responses to the questionnaire from as many participants as possible.

Due to the relatively short time frame allotted to this project, it was not possible to interview a broad selection of industry personnel. Therefore, a questionnaire was developed and sent to various individuals within the maritime industry. The questionnaire asked the individual to respond to both quantitative questions using a rating scale and to qualitative questions where they could expand upon their answers. The quantitative data assessed the presence of safety and environmental awareness cultures within the maritime industry. While the qualitative data looked at methods to improve the effectiveness of the ISM Code.

The secondary source data was obtained via annual Port State Control reports submitted to IMO and published on the websites of the Port State Control MOU’s, from accident investigation reports published by national investigative bodies from countries active within the maritime industry, and published plea agreements for environmental crimes cases. For the data collected from the accident reports, the root causes and causal factors, as determined by the investigative body, were accepted at face value; the facts in the case were not re-evaluated and independent conclusions were not drawn. A similar process was taken for the environmental crime cases...

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George Zeitler, MSc, has over 30 years of experience in the Marine Industry in various regulatory, management, and consulting roles. He is an Accredited Marine Surveyor (Y&SC) by the Society of Accredited Marine Surveyors and a Member of the International Institute of Marine Surveying. He uses his vast experience verifying Compliance with Applicable Maritime Laws / Regulations through on site surveys and audits of client's vessels. His years of operational and regulatory enforcement help provide clients with a unique perspective that is key in identifying vulnerabilities onboard vessels as well as gaps in policies and procedures. He functions as a Court Appointed Monitor in situations where vessel operators are negotiating a plea agreement for a DOJ-approved Environmental Compliance Programs.

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