Recommendation Date
Recipient Name
Nippon Kaiji Kyokai
Text
undertake random audits of vessels which have a safety management certificate issued by your company in order to check that the requirements of the International Safety Management code, with respect to on-board communication, are being complied with in practice.
Reply Text
I would like to make the following observations concerning the adoption of SR 010-00. The need to further ascertain proper compliance of the SMS with ISM Code requirements during the effective period of the DOC has already been recognized, and the efforts are currently underway at both IACS and the IMO to address this issue on a broader spectrum. IACS has been preparing a draft proposal for submission to the IMO setting forth, amongst other things, circumstances under which additional verification audits can be carried out of a company and its ships. This includes development of a new requirement for implementation of annual audits of all ships detained by PSC for ISM Code related deficiencies for a period of at least three years. ClassNK fully supports these efforts. It might also be pointed out that such audits could also serve as a means of targeting problematic ships better than the random audits suggested in SR 010-00. When conducting such annual audits, special care can also be given to the steps taken by the company to ensure adequate communication onboard ship.
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