News Article 06/12/2005 C

Methodology in TMSA compliance discussed (Tanker Operator November/ December 2005, p.26-31)

Chaired once again by Ulysses Systems'' Dimitris Lyras, delegates heard from a number of representatives of leading shipping companies concerning the shear number of vessel inspections, convergence of image, actual costs involved in complying with TMSA , training, planned maintenance systems, relevant software, other topics connected with zero tolerance and risk management and how companies coped with these while complying with the scheme.

The keynote speech was given by Captain Panos Hatzikyriakos safety and security manager with OSG Shipmanagement. He is quality manager of the entire group looking after a fleet of around 95 vessels, plus 14 newbuildings, which include three LNG carriers plus three options.

Captain Hatzikyriakos said he saw TMSA as an amalgam of the ISM Code, ISO 9001, ISO 14001, risk management, plus other new tools such as management of change, benchmarking and others. Perhaps one of the most important elements within the TMSA is that the concept of risk management takes on a new meaning and becomes an integral part of the shipboard and shoreside management style. A change of culture is certainly needed among both sets of staff to a more proactive way of thinking, encompassing continuous improvement, rather than just regulatory compliance.

His speech then turned to the risk management concept. He said risk assessment is part of OSG''s in-house training regime, which is held in Manila.

Outlining the risk management process, he said this can be broken down into five key elements :

1) Awareness - training of key personnel.

2) Hazard identification- group systems and sub-systems and identify hazards.

3) Assessment and evaluation of risk.

4) Improvement - risk control options and cost benefit analysis.

5) Monitoring and reporting of results.

Within the risk problematic area, Hatzikyriakos mentioned the ALARP (As Low As Reasonably Practical) concept and he described the word "risk" as being - probability x consequence.

He then outlined a risk management programme as the evaluation of existing systems and sub-systems and the identification of operational hazards outside acceptable levels based on the company''s documented management system. An ongoing risk assessment process/ procedure should also be established both in the office and at sea.

In assessing risk, it was easier to use the qualitative approach as it requires less resources and expertise. However, it provides the least degree of insight. The quantitative approach is more demanding on resources and expertise, but it will eventually provide the best understanding and evaluation of risk, Hatzikyriakos explained.

When considering risk assessment five simple questions should be asked.

1) What can go wrong? (Hazard identification)
2) How bad? (Consequence modelling)
3) How often? (Frequency estimation)
4) So what? (Risk assessment)
5) What do I do? (Risk management)

Captain Hatzikyriakos then gave his steps for compliance as for risk assessment saying a CBT CD should be sent to seagoing staff for familiarisation and in-house training seminars should be held both for shore and seagoing staff. An introduction should be held for the new management system, as well as training on board ship. Then an on board audit should be held against the revised management system.

NYK Shipmanagement''s managing director Aswin Atre told delegates how his company handled the problem of TMSA compliance. Atre looks after 758 vessels of all types and sizes. He explained that it is a global operation, which brings its own problems in that all the different nationalities need to be coherent. NYK conducted an organisational assessment of the various nationalities to ensure that they were all in tune with one another.

He explained that during the compliance process, the "Kaizen" culture was aggressively promoted. Basically, this philosophy is - plan, do check and act. He said that NYK aimed for zero error and zero pollution.

NYK worked out an organisational assessment of what was needed. This included the awareness of a vision and direction and the question was asked is the information used to plan for the future? NYK''s staff also needed assessing, developing and harnessing and the methods used were examined to see if they determined and met customer’s needs. The question was also asked whether efforts were made to eliminate waste and error. Performances were also compared between NYK and other companies.

The benefits of such an assessment plan were that the company could give a commitment to change if needed, identify the "vital few" areas of improvement and prepare a plan to take in any improvements necessary. Education was next on the agenda and then implementation.

Atre gave the delegates the benefit of NYK''s experience in complying with the self-assessment programme. First, the company created a task force with the specific mandate to check all of the procedures as per the scheme. A gap analysis was carried out on all the elements and brainstorming sessions were encouraged to come up with the most practical solutions. Senior management attended these sessions. It was found that there was a need for formal training in incident investigation and risk analysis. This was duly arranged.

Overall, the self-assessment task took around nine months to complete undertaken by two senior managers, Atre said. All the NYK vessels involved have now been appraised of TMSA and the sea staff have been encouraged to impart ideas for continuous improvement.

He said the main points to bear in mind was that although TMSA was meant for the tanker sector, a company with a diverse fleet may find that some of the other vessel types might benefit from certain elements of the scheme.

Risk analysis is sometimes taken to extremes and should be tempered, Atre warned. Until transparency is achieved within a company, it will be difficult to gauge a key performance indicator (KPI). The concept of management change must be preached and senior management should have hands on involvement.

He ended up by saying it would be difficult to earn extra few dollars for all the effort put into compliance.

Captain Michael Reppas, HSE director of Seaworld Management and Trading told the audience that a good OCIMF SIRE report does not clear a vessel. Elements need to be linked to objectives. The age and type of ship also needs to be taken into consideration when analysing a fleet.

He pleaded with all the OCIMF members to take the same approach, unlike the SIRE programme, which has many extra/side requirements.

Captain Reppas likened TMSA to a business excellence approach, which is all about results and improvements and builds easily on management systems, such as the ISO standards.

He listed the six disciplines for excellence as defined by Gary Harpst, which was Seaworld’s mantra for complying with TMSA. These were:

1) Decide what''s important.
2) Set goals that lead.
3) Align systems.
4) Work the plan.
5) Innovate with determination.
6) Step back

Seaworld''s aim had been to create an environment of zero accidents involving both people and assets, eliminate spills and to achieve the timely transport of oil coupled with an excellent ship turnaround time.

"A lot of operators have decorated their walls with certificates," he told delegates. "One has to decide between decorations and the use of a management system that allows companies to operate efficiently and profitably. Ignoring TMSA is done at our commercial peril."

Objectives should be listed for those working at every level of the company. Staff should be given specific aims and targets and above all else, management should be willing to listen and learn.

KPIs should be established, which could take in the numbers of pollution incidents, accidents, audit findings resolved, near miss reports, inspection results, customer complaints, the time taken from completion of an audit until its issuance and distribution and the number of audits performed against audits planned.

"We decided to be modest and clear comparing systems and TMSA guidelines," Captain Reppas. "Be honest and modest when you submit your TMSA." A management team will know where they will be taking the company. It builds up team consensus, exposes the company to best practice and builds trust. This means that the company is put on the first choice list by charterers and other business associates. "At the end of the day, the money will come", he stressed.

Kostas Polydakis, technical manager, Athenian Sea Carriers then gave an in depth appraisal of preventive maintenance system according to the TMSA.

"Tanker shipping is all about compliance. We must comply with the requirements of zillions of regulations, rules, standards, codes and directives. Then there’s hundreds more of voluntary guidelines, guides, best practices and preferred items, which again we try to comply with, as they''re not so voluntary after all, unless that is you voluntarily chose to be uncompetitive," Polydakis stressed.

"Along comes TMSA. And suddenly tanker shipping won''t be a compliance industry. We won''t be regulation driven. We will be proactive, continuously improving, self-regulating, self-assessing and self-assessed.

So why is then everybody running like mad to meet an imaginary deadline? Why is everybody creating TMSA training courses, offering TMSA consultancy services, selling TMSA software and organising TMSA conferences?

Why? We''re trying to comply again! What we are trying to do defies the very point of the introduction of such a guide.

The shipping industry is infected with the compliance virus and any best-practice guide is automatically perceived as a new set of rules and regulations. Our brains automatically translate the words "best practice guidance" to "this is what you must copy in your procedures; this is what you must COMPLY with".

Curing shipping of the compliance virus won''t be so easy. We need to ask ourselves:
How should I act as a prudent manager?
How can I get my company to embrace the continuous improvement culture?
How can I avoid the compliance trap?

There is only one reply:- Just be honest!

This is not as easy as it sounds. Being honest about ourselves is difficult. It goes without saying that when we are doing a self-assessment we have to be honest. Not being completely honest in our self-assessment can prove disastrous.

Let''s put this honesty theory to the test by having a closer look at just a few of the hundreds of key performance indicators (KPIs) included in the TMSA guidelines."

As an engineer, Polydakis said he would stick with Element 4 - reliability and maintenance standards.

"Right on the very top of Element 4a, in the not-so-humble stage 1 key performance indicators we have all read the words: "Each vessel in the fleet has a formal maintenance plan and a maintenance and defect reporting system." In the "Best Practice Guidance" column, just to the right of this, we read:
"The system, which may be computer based, covers all on board equipment on the bridge, the deck and in the engine room and all electronic equipment."

I''m sure that there are quite a few senior managers who read the above phrases and just nodded to themselves with self confidence, without second thought: "Yes, we have a PMS. We''re sorted. Let''s move on to the next bit."
But just ask yourself do I really have a proper preventive maintenance system, which fits the above description? Maybe a closer look is needed just to be sure we are being honest, before we hurry to award ourselves with a positive reply.

"Each vessel in the fleet…" This means that the PMS system is vessel-specific. It has been created by carefully studying the plans, drawings and system diagrams of the shipyard, the operations and maintenance manuals of the equipment manufacturers, all service letters issued by the equipment manufacturers after the vessel was built, or to be more specific, after each equipment was first introduced in the market, since the vessel may be new but the equipment design may be old.

Vessel-specific also means that in most cases sister vessels may not have an identical PMS. Even small differences such as the installation of a slightly improved oil mist detector version in the third vessel of a series, must be reflected in the system.

As for the formal plan, the maintenance system (MS) must be formal. It must be documented, either on paper or on hard disk. Each maintenance activity must have a clear interval, clear work instructions and a clear methodology of record keeping of the maintenance outcome.

The MS should include every planned event, whether it is a requirement of the maker, the class society, the company, the flag or any industry body. Any planned task must be recorded, or else we will not have a representative and complete maintenance history.

Proper document control, as we know it from our ISM experience, must be exercised. Revision history must be recorded and details of each revision must be recorded. A real formal working PMS is a prime example of continuous improvement and there will be literally hundreds of revisions in the lifetime of the system. After every service letter sent by equipment makers, every flag circular, every Intertanko bulletin, every class society newsletter, after every job completion report for a specific maintenance task, there is a potential need for a revision of the PMS system. This is never-ending and forms the continuous improvement.

All maintenance work carried out on board, whether planned or unplanned, condition based or cosmetic, must be reported. The maintenance report must be made available to the superintendent for checking and review as soon as possible after the maintenance task has been completed. The superintendent should acknowledge that the maintenance report has been read and checked and the vessel''s Master and Chief Engineer should be aware that their reports have been read. You soon lose interest in writing detailed reports once you start having doubts whether anyone bothers to read them.
There must be also a formal system for reporting defects, with all the associated requirements of the well-known cycle of locating the cause of the defect, planning corrective action, carrying out the repairs and closing-out the defect. Again the defect reports must be available to the shore management as soon as possible and there must be a way for acknowledging the defect reports and advising the vessel of the actions taken, or to be taken to rectify the problem. There must be a way of prioritising and drawing attention to defects with serious safety or environmental implications, or defects on critical equipment.

All company vessels must be covered by a thorough vessel-specific PMS as described above. If we have developed such systems for all our new deliveries but some older ladies in the fleet, covered by a more basic system, which are not meeting all the above requirements, then we’re on the wrong track. As the maintenance system is supposed to consist of a "formal maintenance plan", all the above should ideally form part, and be reflected in the company''s Safety Management System, and thus should apply to all company vessels.

And what about the "Best Practice Guidance" column:

"The system, which may be computer based…". I believe they should have just written,"the system, which must be computer based".

All on board equipment should be adhered to. For example, on the bridge if you read navigation and communications manuals very carefully you might be surprised to find small comments hidden here and there such as "radar scanner mechanism to be oiled every six months" or "Inmarsat B VDU internal memory back-up battery to be replaced every five years" or even "apply a small amount of grease to the shaft and the bearings of the link mechanism of the repeat back unit of the auto pilot every six months". So bridge equipment has planned maintenance. A surprising amount of planned maintenance, albeit mostly of the failure-finding type. And it should all be included in our formal maintenance system.

On deck, the PMS must cover all deck fittings, mooring equipment and lifting appliances. It should be vessel specific according to the maker’s intervals and recommendations and not a general template to be followed by all vessels.

The system should cover the engine room. Not just the main engine, diesel generators, steering gear, boilers, purifiers, compressors and pumps of PMS systems of the days of yore, but all the engine room. And finally what about the accommodation? Even deep fat fryers have planned maintenance tasks, not to mention elevators, or ventilation and air-conditioning systems.

So if we cover all the above, we are being honest in saying: "Yes. We have a PMS. Let''s move on to the next bits." And then moving on to the next bits we will realise that we meet many more performance indicators: "A common computer-based system on board each vessel records all planned maintenance" of stage 2. Or – "The maintenance and defect reporting system automatically alerts the staff responsible for shipboard maintenance and ashore when it becomes due", again stage 2.

And moving further up to stage three and stage four KPI''s, having such a solid, sound and strong foundation as the PMS system which we just described, it is easy to improve and fine-tune the system and cover more ground. Improve our system and thus meet these KPI''s.

Again, having such a complete maintenance database makes it easy to create a software tool to measure the number of outstanding planned maintenance tasks across the fleet as a percentage of the total number of monthly tasks, each month and record the figures. And that''s element 4C.

If we seek continuous improvement we will develop our own additional performance indicators, which will track the maintenance of critical equipment. We will develop performance indicators, which will track the downtime of important equipment such as the main engine, diesel generators, boilers and cargo plant equipment.

Finally, and most important of all, in a good PMS, if we are being honest we will never be tempted to give postponements or extensions to maintenance due dates, just to maintain a good picture in our performance indicator.

Investing in a good software package is just the start. There are many software options in the market for PMS, ranging from simplistic freeware options to highly advanced (and highly costly) reliability centred maintenance – FMEA analysis tools.

Buying one of these programs (in case we don’t already have one) is not the end to our problems. A PMS software application may have amazing capabilities, but it''s just an empty database. And the full value of a PMS database is not in the software. The value of a PMS database is in the data population, which only we, the users can do.

And this development is expensive. Much more than the cost of purchasing the software and paying for the annual maintenance fees over a number of years. We need to invest in time and in money. If we want to develop an in-depth PMS, a system which will allow us to meet the majority of Element 4 KPIs, and with continuous improvement some day meet all of them, we must do it ourselves. And we must allow ourselves plenty of time for the development of that system.

We must also train the users. Training is the most neglected part and inadequate training the major reason for failure of PMS in shipping companies. If people on board do not utilise the program to its full potential, all our investments have gone down the drain.

Developing a PMS is a full time job. If we don''t underestimate this, we will soon see our investment pay back. We will soon see the cost savings and the reliability gains. We may realise that we meet all Element 4 KPI''s, up to and including stage 4, and have very solid supporting evidence for anyone wishing to audit us. ",he concluded.

Andriaki Shipping''s Antonios Vrondissis also promoted the Japanese "Kaizen" system of continuous improvement and admitted that the company had underestimated its system and thus recorded a low score.

"Trying to get to level four in one go will get you into trouble," he said. Vrondissis also stressed it was important to get together more to discuss problems and new methods of working, rather than hold meetings in secret.

"We need to set up a plan and do it in stages. Also try to work on two or three top priorities as working on more than that can diffuse the effort, energy and resources" he warned.

He said he wanted to create a positive environment for improvement by celebrating, acknowledging and rewarding accomplishments."In that way you can achieve employee participation," he said.

Always look for breakthrough improvements even some small ones can turn out to be major improvements. Be aware that a breakthrough exists and look for them. Be hungry for new ideas.

Another helpful tool in striving for continuous improvement is to look at other industries, such as the airlines on safety issues. Also talk with your customers it can be surprising how much feedback can be gleaned. Competitors can also sometimes show you a better way of accomplishing goals.

Data is vital but it needs analysing and diluting. He gave an instance of the chief engineer receiving five different bunker check lists. "Take your time in choosing a system and ensure you talk with the companies that have installed it. Configure it to map the way that your company works," Vrondissis advised.

Stephan Polomsky, Transocean Shipmanagement''s managing director, stressed that if the shipping industry looses its self control, it would be a disaster. Although applauding the LAN initiative on common rules, he hoped that real common rules would be introduced by IACS by way of some sort of harmonisation. He also said it would have been helpful if the rule makers had listened to some industry players.

For the three ''Rs'' – rules, requirements and regulations – the industry needs easy rules, good shipyards with good vessel specifications, he stressed. There should be no competition among the class societies, although they should retain their independence and provide the maximum expertise.

He complained that his company''s vessels are sometimes subject to up to eight vettings per year and that some charterers will use the vetting system for commercial reasons to refuse a vessel.
Polomsky advised delegates to use the people coming on board to inspect their ships to better their work practices, instead of dismissing them.

Vice Admiral Kechris, deputy managing director of KC Lyrintzis Group, a diverse consultancy also involved in continuous training services primarily to the Greek market said his students were questioning the amount of paperwork involved with the TMSA process, which he likened to an ISM Code No 2.

"Would safety be improved, or more paperwork just be added?" he asked. "Can shipboard personnel handle the extra and requirements that come with it?"
He posed other questions, such as "How objective can self-assessment be? How can the new requirements be practically implemented?"

Vice Admiral Kechris then showed delegates a human performance and acts model together with a risk analysis of human error.

Maritime solutions adviser Apostolos Belokas, managing director of International Business Solutions posed many questions, such as "A need or a luxury? Are we managing change properly?"

He also stressed that all the stakeholders were concerned with their image, as in many cases the brand name is the most important asset. He also pointed out that continuous improvement systems have been in place since the early 1990s and as such were not new. They had a good track record, have been used widely and were based on third party certification.

In theory the future lies in self-assessment, but Belokas said that pure self-assessment had not been realised thus far. He said that one of the problems with TMSA was that there was no official implementation framework or deadline. The oil majors started to add implementation issues, but the deadline is the end of this year. "The environment (for compliance) is not mature yet", he said.

There is a danger that companies will focus on TMSA compliance rather than the philosophy of continuous improvement, or focus on minimising expenses rather than investing in cultural change. There was also a lack of communication, resources and proper change management in the OCIMF camp to properly introduce TMSA.

Its introduction was premature due to a lack of ''implementation and certification'' guidelines. He also echoed other industry players when saying that nobody was consulted during TMSA’s design stage.

However, overall Belokas was in general agreement that TMSA will move the industry forward, despite his reservations.

Drewry Technical Services managing director Kamar Zaman explained a little bit about the tanker industry today as he saw it.

He pointed out that both charterers and shipowners had been considerably reduced in numbers down the years through consolidation. For example, taking the oil major charterers, these had fallen in number from 14 to just seven – Shell, ExxonMobil, BP Amoco, TotalFinaElf, ChevronTexaco, Repsol and PhillipsConoco.

Only three of these oil majors figure in the top 10 VLCC charterers with Shell being at the top, followed by the Indian government concern IOC. ExxonMobil was in third place followed by ChevronTexaco. Then came Ssangyong, Vela, Reliance, CPC, CSSA and SKS.

Zaman thought that the oil companies continued to secure safe modern tonnage by dealing with large trusted owners, which has greatly influenced the consolidation within the shipowning fraternity.

Another method often used is seeking tonnage through pooling systems, which gives the owner a stronger market force, although its individual brand name might suffer.

This drive towards consolidation has provided the larger owners with better leverage to control operating costs by using economies of scale. However, consolidation creates fiercer competition. Entering the tanker operating sector of the shipping industry can only be justified by improving quality and building relationships with charterers.

Frequent disruptions in the oil markets and increasing threats from alternative energy sources are by and large beyond a shipowner''s control.

During the past seven years the tasks on board ship connected with the new requirements have shot up by 23%, estimates Panteleimon Pantelis, director of services Ulysses Systems. Form types have gone up by an estimated 35% and manuals by a horrific 65%. "What will happen in the next 10 years?" asked Pantelis.

One thing is for sure that the roles on board ship will not increase at all and maybe even decrease. Hence people will become more reliant on software. The TMSA scheme will bring more features into the software and get more people using it, he thought. The software will become ‘mission critical’ with base management strategies included in the software.

"Buying software now will decide the success of the company, but what to buy is of great importance and people will have to learn this skill," he said.

As for the software lifecycle costs, there is a certain amount of misunderstanding surrounding these costs. For example, the utilisation cost is the highest and is mostly underestimated by the shipping industry. The initial purchase cost is only a minor fraction of the software lifecycle cost, but this is grossly overrated, Pantelis thought.

The return on investment can be dramatically increased by well designed software that prioritises the reduction of major recurring costs, such as utilisation costs, maintenance and re-training costs. A well designed software suit facilitates the reduction of these costs as a natural by product of software usage.

Conference chairman Dimitris Lyras posed the question "Are we converging with self-regulation?" which he thought was of vital importance to the industry. Also will there be less number of inspections as suggested by TMSA, he asked. The general answer from the speakers and delegates was NO to the question of convergence.

Stephan Polomsky said: "We have to make it work by dialogue. Customers are turning on clients. We need to support the scheme, but need to control the three ''Rs''."


Aswin Atre warned about cynical regulators. "Shipowners do not have political powers," he explained. Even if an oil spill is accidental, you are still liable in the US. "There is no defence. Period," he said.

Captain Reppas agreed saying: "You cannot discuss things with a customer at the IMO, or EU. You can converge with your customers, but not with the regulators."

Kostas Polydakis thought that some of the regulators had no perception about shipping and just create pressure for more regulations. "We don’t have positive coverage. A negative image leads to more regulations. "Classification societies should have been more strict years ago", he thought.

Captain Hatzikyriakos thought we hadn''t done enough on board ship. He also said: "We shouldn''t allow bureaucrats in Washington to dictate our business."
Apostolos Belokas said: "In an $80 bill oil trading industry, we need more input from Intertanko."

There were other comments from the floor, including a call for more transparency and to move the liability question over to the shipowners themselves.