News Article 26/06/2006

How big will TMSA be? Digital Ship, June/July 2006, p.3-12

 

The biggest obstacles cited by the conference speakers in the ability of companies to succeed with TMSA were:
o Investigation and analysis of the real situation on board and in the office compared to the one management declares (Captain Julian Brown, managing director, JCP Marine in Singapore)

  • Culture and cultural change management (Patrick Slesinger, chief information officer, Wallem Shipmanagement)
  • Uniform application or risk assessment (Capt Amarjit S Kauchhur, marine manager / marine safety quality and security, ITM)
  • Change management practice as described within TMSA (Mr. K. K. Kumar, deputy general manager, NYK Shipmanagement)
  • Culture change and avoidance of a bureaucratic exercise (Capt R. Janardhanan, QHSE manager, Anglo Eastern Singapore)
  • The human element and motivating seafarers (Capt Anuj Sahai, marine business manager, Lloyd''s Register Asia)
  • Buy in and reward (Farzin Karma, managing director, conference sponsors Ulysses Systems Singapore).


Industry view
"When we first read TMSA, we thought, this is crazy," said John West, operations manager of Unicom Shipmanagement in Cyprus. "But by the third day we realised, this is quite a good document"
Like Unicom, much of the shipping industry gave TMSA, the oil companies Tanker Management Self Assessment guide, an initially cool welcome.
They are also gradually understanding the dynamism of TMSA, almost a market conversation and framework for improvement across the whole business, rather than a one-off list of rules to be complied with.
But many are starting to see how it can help tanker operators get rewarded for their competence and compete on their competence, something that has arguably not been happening in the past
To quote conference chairman Dimitris Lyras, "Nothing more substantial can help the industry than an industry which competes on its own competence. We want to give our clients a differentiation and give our clients an idea that we are diligent about what we are doing."
Shipowners will have much more incentive to genuinely improve their operations, which will lead to better management of risks and personnel, and to the industry becoming a more desirable place to work in.
TMSA is pushing a complete culture change in shipping companies, from a reactive one to a proactive one.
Captain Julian Brown, managing director of JCP Marine, a worldwide marine consultancy headquartered in Singapore that specializes in providing technical services to marine insurers and oil and chemical majors, acknowledged ExxonMobil as the source of many of the TMSA elements. "Those of you familiar with the Exxon way of business will recognise some of those concepts and philosophies expressed in TMSA edition 1," he said.
It is gradually becoming clear in many sectors of the shipping industry just how big a modernisation force TMSA might be in the shipping industry.
Remember how over hyped ISPS was, with so many industry conferences, talk about how the shipping industry would have its vessels detained, so many vendors and security consultants getting excited, and when the deadline passed, it was a complete non event as all the shipping companies had their pieces of paper - and afterwards forgot all about it? TMSA is the opposite. There is absolutely no hype at all - indeed many tanker operators are saying that since they aren''t forced to do it, they won''t do it - yet major shipowners, such as ITM and BW Shipping, are re-organising their entire company structures around It.
The influence is spreading beyond the relationship between tanker operators and oil majors.
Some P&l clubs including The Swedish Club and Skuld are already carrying out management audits of their members. Other International P&l Group Clubs, are looking at using TMSA as a framework to help shipowners improve their management systems as a means of reducing claims according to Captain Brown.
"Lack of proper tank cleaning and sampling procedures in the chemical sector can result in costly contamination claims," he said. "It''s a big issue for, the Clubs. They are looking at TMSA as a potential tool to encourage members to come up a level, and so reduce claims".
Some ship operators (including Anglo Eastern), which operate both tankers and dry bulk vessels, are also using the system for their dry bulk vessels, rather than have different management systems for different ships in their fleet.
Similarly, many vetting inspectors who inspect both tankers and dry bulk vessels are also seeing it as a useful framework to audit dry bulk vessels against.

Information technology
TMSA is not specifically about information technology - indeed information technology is only mentioned once in the document but there is a very strong IT angle.
Shipping companies will have an incentive to spend money on improved build management systems, better ship-shore communication, computer based training tools and simulators, electronic charts and crew communications facilities. As shipping companies get more proactive in trying to improve the quality of the operations, the information communications budgets technology will start to open up.
No more "we''re only spending money on this if we have to".
There''s more – one of the trickiest systems in TMSA is the one on change management, where tanker operators are asked to have systems in place to make it easier to change.
Information technology, as Wallem''s CIO Patrick slesinger said, is a tools for change management.
As part of their change management systems, shipowners will be encouraged to realize that because they didn’t need it when they were at sea, doesn''t mean it shouldn''t be implemented now.

How far to go
Oil companies are likely to look for a minimum compliance with Stage 1 and perhaps to Stage 3, for long term time charters or COA (cash on affreightment) contracts, according to Captain Julian Brown, managing director of JCP Marine.
This does not mean that everybody has to be level 3. Oil majors will take whatever they can legally charter rather than not move the cargo. "Recently I had heard one oil major who had conducted a few audits he has rarely come across any company which has crossed stage 1 in most elements," said Capt R. Janardhanan, QHSE manager, Anglo Eastern Singapore.
"Charterers seeking a level 4 ship are likely to have to pay a high premium for it," said Mr.K.K.Kumar from NYK Shipmanagement. "Only a small proportion of the fleet will reach level 4. To reach this is very difficult and it will take a long time. When you reach it - Charterers will be very happy to charter your vessel".
Mr Kumar''s recommendations was that companies should certainly comply with level 1, and then subsequently gradually build themselves up the levels like buildinging blocks. Aim for level 4 in the due course of time," he said.

However the idea of TMSA level 1 being equivalent with ISM level is a myth, said Captain Brown, or if it is true there are plenty of vessels out there which are not ISM compliant.
To provide an indication of the general level of shipping companies he has reviewed, Captain Brown talked about TMSA and management audits that he has carried out over the
past 2-3 years with various Asian shipping companies including Thailand (2 companies), Indonesia (2), Japan (4), Malaysia (2), Philippines (2), Korea (3) and India (5).
The companies each operated between1 and 25 vessels, totalling 32 oil product tankers, 30 bulk carriers, 20 general cargo ships, 34 chemical/oil tankers, 19 crude oil tankers, 2 offshore support vessels, 1 deck cargo ships and 2 passenger ships.
Whilst TMSA does not strictly speaking provide any calculation method for developing an exact score, Captain Brown tabulated the results and levels of compliance. The results overall indicated the majority of operators (60 per cent) failed to fully comply with Stage 1: 40 per cent scored between 0 to 0.4, 20 per cent 0.5 to 0.9 and 40 per cent 1 to 1.4, he said.
The highest scoring elements were chapter 2, recruitment management of shore based personnel (average 1.3), chapter 11, emergency preparedness and contingency planning (1.0) and chapter 5, navigation safety (0.9). The lowest scoring elements were chapters 7, management of change, chapter 8 - incident investigation and analysis, chapter 9 safety management and chapter 10, environment management. The lowest four scoring elements scored about 0.6. i.e. only 60% of Stage 1 elements were complied with.

How much to spend
How much to spend on TMSA is something of a million dollar question, when it isn''t obvious what the return will be.
The potential is that charterers will choose a higher scoring vessel over a lower one if they have a choice, so higher scoring vessels will be busier, a distinct commercial advantage.
There is also a likelihood that certain oil companies will aim to get tankers at a specific level if they can, particularly for time charters.
But none of this is entirely clear at this stage and tanker operators are likely to want to have concrete evidence of returns before committing large amounts of money.
Many shipowners are still waiting to see how the dust settles before making any investments.
The pragmatic approach is to use TMSA as a business tool within your own company, adopt the elements of it, which make sense to your business, and see your scores rise as a by-product of that. "Shipowners can select the parts which are useful and reject the parts which are not," said Commander Nicholas Iliopoulos, captain of the manning and training department with Centrofin management.
TMSA requires management commitment, including rewriting procedures, resources, people, IT, time and substantial additional training.
Both ITM and Teekay said that TMSA would have very little additional costs in their companies, since they were doing most of it anyway.
"We''ve really had most of these best practises in our system in the past. It''s not really costing the owner much," said ITM''s Mr Kauchur. "The owners have not seen any increase in their budgets. You need to have your reporting incorporated in your existing systems. We always did have a planned maintenance system."
"The only cost we would emphasis is some amount of training," said AESM''s Captain Janardhanan. "Owners are well aware of it."
NYK, by contrast, is expecting to spend around $20,000 per vessel, which is mostly spent on training, including onboard training (CBT, videos and roving trainers), plus shore training (seminars, simulators, courses). There are also some additional manpower requirements, and documentation.
The company also developed its own training programs, and has some incentive programs for staff based around risk assessment and management.
"There has to be a cost," said NYK''s Mr K K Kumar. "You cannot get something free. You have to spend; you have to invest. Funds have to come from future expansion. We need some funds.
Mr. Kumar said he did not think shipmanagers would be able to cover the costs of the necessary investment out of their management fees. "There''s no way a management fee can pay for this. "You have to find it yourself, or from the owners."
Mr Kumar said that NYK Shipmanagement is in a special position, as an in house manager rather than a third party manager, it manages the ships owned by its parent company NYK. "We have other funds," he said.
Unicorn Ship management of Cyprus said they were planning to spend $40,000 per vessel on TMSA. "We will implement TMSA and take standards of recruitment and employment forward," he said.
Managing director of JCP Marine, Captain Brown stressed that TMSA covers all elements of a shipping operation, and as such it cannot be viewed as a project. "I''ve seen several companies where a superintendent has been given a copy of TMSA and told," go away, come back in 3 months time... and make sure we are at level 3," he said.
Captain Brown said he had noted that shipowners do a lot better at TMSA if the pressure to do it comes from within the company, not outside. "In particular it needs management commitment from the highest level," he said.
No-one is expecting the TMSA document to stay static. "I''m sure TMSA will be revised in the not too distant future," said International Tanker Management''s marine manager Capt Amarjit S. Kauchhur.
"OCIMF does welcome suggestions for improvements," said JCP Marine managing director Captain Julian Brown. "You can submit feedback to the appropriate OCIMF committees."
It will be a while before the industry knows exactly what the reward will be for reaching the upper levels, but the industry should be thinking about it, otherwise it is just another compliance system, said conference chairman Dimitris Lyras.

A thorough check
TMSA does hold up a lot of hope for being able to provide oil majors (and indeed, ship operators) with a more realistic view of what happens onboard ship than with the current ISM plus inspection systems.
"I audited a ship to see if they are recording a realistic expectation of what happens on the ship," said JCP Marine managing director Captain Julian Brown. "We want to move beyond simple vetting of the ship. "Now we have a third angle - TMSA," he said.
Captain Brown was not entirely confident in TMSA, and whether it was impossible for a corrupt tanker operator to pull the wool over a vetting inspector''s eyes.
"It depends on the operator," he said. "Someone who was just lying will continue to do so."
"Are we saying an irresponsible operator will do the same with TMSA?" he was asked. "I would suggest it is a possibility," he replied.
There was sceptism expressed in the conference about whether TMSA would actually lead to reduced inspections. "They say TMSA will lead to reduced inspections. How far it will be true, we have to see," said Anglo Eastern''s Captain Janardhanan.

ISM plus vetting
You know about the gap in truth that generally occurs between what actually goes on onboard ships, and what gets reported, or uncovered in vetting inspections.
Shipowners often lie in their safety management systems, and in return are subjected to an endless series of oil companies inspections rushed through during port calls.
The inspections are often too superficial to give the oil companies are clear idea about the competence of a company''s management, how well maintained the ship is or how well trained the crew are; but if the vetting inspector does find something he doesn''t like, it can lead to significant damage on the trading ability of the ship, hitting the shipowner hard and somewhat unfairly.
No-one is happy with the vetting inspection, and oil companies want to have their own inspections rather than trust those made by another oil company. The regulators are not happy with the system either and so want to make their own inspections. We end up with an escalating number of inspections by different bodies, none of which find out anything useful.
Captain Julian Brown, with Singapore Marine Consultancy firm JCP Marine, says that whilst the systems work quite effectively, there is a ''sense of frustration amongst operators'' with two of the most well known initiatives - SIRE and CDI - that multiple inspections remain a feature of commercial life. "Recent developments within CDI whereby the CDI Marine department now appoints the inspector rather than the owner has been broadly welcomed by both charterers and operators," he said.
"Vetting is like ''catch me if you can''," said Anglo Eastern''s Captain Janardhanan. "Self assessment is a leading indicator. We believe that the convention al vetting was a snapshot, which did not accurately reflect the systems. There is no adequate focus on operators," he said.
"Oil majors had their own unique ways of carrying out their judgement regarding tanker operators - some even invited operators to their offices for a presentation and some visited the operators offices to check out their systems," he said.
The ISM system was meant to make sure all vessels were safely operated, but, in the word of NYK Shipmanagement''s deputy general manager K. K. Kumar, "left a lot of loopholes which were exploited".
"ISM was not meant to be a paper tiger, which it is today," said AESM''s Captain Janardhanan. "Everything got diluted." The paperwork rarely reflects the true situation.
"An ISM audit is a collection of paperwork basically," he said. "ISM wasn''t meant to be a paper chase, it ended up being that.
However there is a clear advantage of TMSA over ISM in that ISM is mandatory. "ISM - is compliance, pass or fail," said Anglo Eastern''s Captain Janardhanan. "You have contracted auditors, certificated processes. "TMSA is not a compliance document. It is structured to measure continuous improvement."
"With TMSA the oil majors are saying what they would like us to do," said Unicom''s John West. "It''s a best practice guide, not a prescription. "It only gets prescriptive if you sign up to time charter.
Taking the ISM criticism onboard, there are open questions about how to avoid TMSA having similar problems. "TMSA could be a bigger paper chase," said conference chairman Dimitris Lyras. "How do we control that?"
"ISM is the foundation - with TMSA we are building on it," said AESM''s Captain Janardhanan.

Tricky aspects
The trickiest aspects of TMSA, most speakers agreed, was the change management, risk assessment and incident reporting.
"We''re finding management of change one of the most difficult elements - we''re struggling to get our heads around it," said Unicom''s John West. "Oil majors are still trying to get their heads around it."
"Management of change is one element which stands out from the rest of TMSA," said BW Shipping''s Captain Vibhas Carg."You have to ensure changes don''t lead to unnecessary risks."
"Management of change is difficult," said AESM''s Captain Janardhanan.
By ''change management'', what TMSA actually means to do, it emerges, is kill off the attitude prevalent in shipping companies ''we didn''t do that when I was at sea''. People who take this attitude are not very good at change management.
ITM has implemented change management procedures. For example, if it is moving into a new trade, it will take on people with experience in that trade. "We all need a common understanding of the management of change," said ITM''s Capt Kauchhur.
"We believe management of change will be the toughest one," echoed Mr Kumar from NYK.
"Implementation of risk assessment should be done in a structured way so as to have consistency of application across the fleet," said Capt Kauchhur from ITM. "We are working on how we are going to make this happen effectively."
There were suggestions that tanker companies should get seafarers more involved in risk assessment and root cause analysis, rather than seeing it as something for the shore office to do.
Captain Brown from JCP Marine said he thought one of the elements of TMSA which he would like to see substantially improved was incident investigation and analysis. Exxon''s maritime transportation division IMT has given some very impressive presentations to owners on change management, he said.

Equal across a fleet
For management purposes it is probably easier to maintain all your fleet at the same level, rather than have a ''star vessel'' which gets a higher score but run at a standard you can''t keep up with, on your other ships, said Wallem''s Patrick Slesinger.
"We''re operating mixed fleets - TMSA applies across the whole fleet - you can''t have 2 separate standards," said Unicom''s John West. "Best practises have got to be fleet wide."
"If you look at our group - the Singapore office manages tankers and gas carriers. But the decision of the top management is that it has to be implemented across the fleet," said AESM''s Captain Janardhanan.

Seafarers
Capt Kauchur said that in his view, the continuous improvement would make it easier to attract and improve management of seafarers.
This view was echoed by John West, operations manager of Unicom Shipmanagement in Cyprus. "I think TMSA is a driving force in better personnel management than has existed in the past.
Captain Vibhas Garg of BW Shipping said "I think that seafarers would like to work for a quality operator."
It is not clear at this stage how much TMSA will help improve manning levels on ships or ensure that seafarers are taking adequate rest.
It does encourage shipowners to make a much greater check that seafarers are making adequate rest, and it does include a large amount of work, which will need extra people to do.
However shipmanagers are still being given vessels to look after on the basis that they can make things work at the minimum manning levels.
George Hoyt from Newslink Services raised the issue that the money being spent on TMSA, even at $40,000 per ship per year, is still small compared to the amount the industry pays due to its poor public relations, which lead politicians to feel that they can get away with criminalizing seafarers without due process. If TMSA can lead to an improvement in industry PR that would be money well spent.
Dimitris Lyras noted that the poor industry image led to legislation requiring single hull tankers to be retired earlier than they otherwise would have been, cutting 15 to 25 per cent off the value of a vessel.
"TMSA will improve the image of shipping," said Mr NYK''s Mr Kumar.

Legal issues
Oil companies do not accept any additional legal responsibility for tanker operators which have implemented all of the best practise guides.
Many sceptical tanker operators see TMSA as a way for oil companies to pass the liability for accidents onto them, as in; we chartered you because you said you were doing certain things.
If an oil major ever charters a ship which has a major accident, the oil company is likely to be more worried about its loss of public image than any legal action, and the general public is unlikely to treat an oil company nicely because of how it chartered its ships.
However most tanker companies would like to be judged on the diligence of their operations after a tanker accident, rather than the fact that the accident happened, because they acknowledge that even good companies have accidents.
Due diligence means doing everything reasonable to reduce the risk of accidents, and doing everything reasonable afterwards, such as making sure it does not happen again.
TMSA does provide an excellent framework for due diligence, and being able to demonstrate to authorities that you did due diligence.
"The management has to provide proof that they have investigated and can provide preventative action," said Mustaffa Bakri from Eagle Shipmanagement.
Capt Janardhanan from AESM echoed these views. "It does not say anywhere [In TMSA] that you are not supposed to have an incident," he said. "The point is, if you have an incident you have to follow up and show due diligence. A manager has to show that he used all his resources to mitigate the situation."

300 defects
Conference chairman Dimitris Lyras raised the issue of how honest shipping companies should be about their defects, bringing up a story mentioned at Tanker Operator''s Athens conference in February about an old vessel just brought into management, where the company had found 300 items it wanted to fix (essentially a 300 defect list), but none of the defects were serious enough to warrant taking the ship out of service.
"Would you have that list available to an inspector - would it put you in a good light or a poor light?" he asked.
"I think that the simple answer - is - is it better to be frank and honest rather than have third parties finding out," said Wallem''s Patrick Slesinger. "If I find something you haven''t detected I will believe you are trying to hide it. If you say these are known issues and what we''re doing about it - I think that''s a far better stance." Mr Lyras said that approach might work in the UK and us. "But does it work elsewhere - e.g. a country not very sophisticated - will they say, ''we have a shipyard, that can take care of some of these things?"
"If you tell oil companies you have 300 item deficiency list, they will say very good, give us a call when it''s fixed," said Captain Julian Brown from JCP Marine. "Don''t be too surprised if they ask to inspect your ship again," he added.
"If you take a ship into management with 300 defects the price would have to be very attractive - or you should look into it on your risk assessment," said Unicom''s John West.
Patrick Slesinger raised the issue of who could competently say whether or not any of the defects made the risk too high, particularly when you look at compounded problems which could occur due to two different defects.

Non-believers
So far, industry reaction to TMSA has been divided up into believers and non-believers / wait and see attitude. The TMSA disbelievers think that since they are not forced to do TMSA, they won''t necessarily do anything. They want to see how the dust settles before making any move.
They have learned to play the shipping system, just doing the minimum to pass the rules, and know that any system, which shines a spotlight on tanker, companies which do a lot more than that will not do them any favours.
The TMSA disbelievers think this is just a way for oil companies to pass liability onto tanker operators, so, after an accident, they can say, ''we chartered you because you said you could do x y z''.
The TMSA disbelievers are cynical about industry initiatives to date, ISM, ISPS and ISO, seeing them as a bunch of forms to be filled in, or hoops to jump through, rather than having any positive benefit to anyone, and think TMSA is just another one.
The TMSA disbelievers cite the tanker industry''s excellent improvement in its accident record over the past few years as evidence that whatever is happening in the tanker industry to reduce risk is working, and no further initiatives are necessary.

BW Shipping
Captain Vibhas Garg, senior marine manager of BW Shipping (the company formed from the merger between Bergesen and World Wide Shipping) explained how BW Shipping is trying to get its whole company together under the TMSA framework. "It has a major influence on the way the company operates," he said.
"At BW Shipping we have taken all the KPIs in TMSA and built them into our procedures. The 12 elements are used as a basis for management review. We are defining the management review in line with TMSA.
"We believe TMSA is helping us have a total quality management (TQM) system," he said. "We feel it provides us with a means of achieving the holy grail of continual improvement."
BW Shipping is using TMSA as a ramework for TQM. They have included a further 2 sections of their own - section 13 on accounting, and section 14 on ballast water management.
"We had a target of 18 months to do it-it took 2 years," he said.
"You need to decide how far you go in implementing new quality procedures," he said. "How far do you go? It depends on your relationship with the oil majors."
"Quality management has been down to different systems in the past, notably SIRE systems," he said. "A single report can have a big impact on the trading ability of a ship."
"We believe TMSA is a more pragmatic approach - looking at how problems are managed."
"ISM was a significant milestone for shipping - failing a certification would result in withdrawal of ability to trade. However,failing a TMSA can also lead to commercial implications."
At BW Shipping, all areas of the shore support team are involved in the process, he said.
"We had office secondments from the fleet to look at revised procedures. The guidelines offer a way to show the industry how we are faring against each other," he said.
One particular area of concern was element 3 (have seminars for all officers). "We realized we could have 100 people over four or five seminars in a year," he said. "It''s not possible to have a training seminar for such a large group of people."
BW Shipping has found the ''best practice guides'' written as part of the TMSA guide "not always suitable," he said. An example is the section, which says you should have a liquid cargo handling simulator course. "We didn''t find a course anywhere that meets the level of requirements specified in the best practice guide".
"The best practice guides don''t always help you," he said. "You have to interpret them."

ITM
Capt Amarjit S. Κauchur, marine manager / marine safety quality and security, ITM, says his company sees TMSA as a good sort of best practise.
"People want more transparency," he said. "There''s no such thing as kicking the dust under the carpet anymore."
However ITM believes the document could be clearer in certain aspects. "There are times when we don''t understand a few things," he said.
ITM continually assesses how well each vessel complies with the different elements, and has already done three or four TMSA reviews.
"Every time we change a few of no to yes, and maybe a few yes to no. We jump from yes to no any time if we find it not fully implemented," he said.
"If we try to reach a stage very fast we might drop a lot of things between the tables which we don''t want to do," he said.
There are 12 items out of all TMSA elements 1-4 which the company does not fully comply with, he says, of which 3 are at level 3, so currently the company considers itself at level 2.
"The biggest problem we feel is implementation," he said. "We feel that people at sea and ashore should also be equipped with management skills, not just technical or operational skills.
The company is involving many of its ship staff when amending procedures.
"We get people soon to be promoted to master / chief engineer offshore for 3 months, bring them into the office, get them involved. We have ship staff coming in to assist us in projects," he said.
We teach them what a superintendent does, what operation people do. When they get back onboard they perform a lot better."
"If we place a person in a bigger position than his actual responsibility, he will appreciate this responsibility more," he said.

K. K. Kumar, NYK
Mr.K.K.Kumar, deputy general manager, NYK Ship management, said that "TMSA is a challenge and an opportunity for us to develop continuous improvement. We are committed to continuous improvement in systems as a tanker operator."
"TMSA has given us a structure which we have to follow as far as possible," he said. "If you have implemented TMSA you will have a good business."
"There are benefits of self assessment and continuous improvement - you have to go through your TMSA every now and again," he said.
"We have done our evaluation and saw where we stand in TMSA. We are still processing and checking where we stand. We spent a lot of time implementing this," he said.
"We started communication with all departments. For TMSA, many meetings have to be held."
"TMSA is a challenge, not a compulsion," be said. "But if you want to be in the tanker business you have to play this game."
"Management commitment is very important," he said. "You need a lot of resources.
Small companies may find it difficult to have these resources."
Benchmarking proved particularly complex, he said. "It''s very difficult to get figures from other companies - whatever you get will be perfect figures."

Capt Janardhanan, Anglo Eastern
"Anglo Eastern is fully supportive of TMSA and we are committed to the success of the implementation," said Capt R. Janardhanan, QHSE manager, Anglo Eastern Singapore
AESM has 700 shore staff and operates over 190 vessels, including 33 gas, chemical and oil tankers operated out of Singapore.
It has had two TMSA reviews from oil majors so far. "We did fairly well," he says. "There was no benchmarking and they did not tell us where we are, they just said, ''you''re compliant''."
"TMSA is a tool for operators to measure and report their own management systems," he said. "They can do critical self evaluation."
Capt R. Janardhanan cited a few elements of TMSA, which may need some extra looking into.
"Element 3 - need a competent crew capable of working as an effective team."
"Element 10 - efforts to improve safety and protection of the environment"
"Element 7 - management of change – a coherent system to manage temporary and permanent change - you need to define level of activity required for approval of change, you need a risk assessment to evaluate the impact of any change. A change management process is in place throughout the office and fleet to reduce operational risk. When you have a new type coming in to management - you have to do a change management," he said.
"People say - when you change the master - there could be a requirement of a management of change," he said. You need a risk assessment to evaluate the impact of any change, e.g. new people. It''s a grey area we are all looking into.
"Element 8 - incident investigation you have to have comprehensive procedures for incident management - the ''no blame'' report. You have to get into the root cause of the incident and take measures so it never occurs again. "
"Element 9 - identify each risk or hazard that might lead to a preventable accident.
You have to identify this hazard and try to minimise operational risk."
"Environment management. You have to have a plan for systematic identification and assessment of all sources of pollution, and actions that are being implemented."
Capt. Janardhanan said that in his view, some of the guidelines are not precisely enough defined.
"E.g. element 3B - procedures to ensure working hours are in line with STCW guidelines and accurately recorded.
A possible interpretation would be: develop procedures to ensure hours of rest hours are as required by STCW, recorded by ship staff, verified during ship visits by the superintendent and monitored by the office to confirm compliance," he said.
What if - for the first part, the master just sends reports saying ''STCW hours compliant for January 2006''? Don''t we still need to believe it?"
AESM has developed a pocket risk assessment guide (see picture, bottom of previous page), which is given to all seafarers, with instructions such as "Is there a risk of being struck by or against an object?"
"We have what is known as the 10 commandments - a pocket size page - given to every seafarer. They can stick their wife''s photo on the back. They are questions to ask to see if he has to consult a supervisor before doing a job," he says.
"If he answers any of the 10 questions positive he should consult a supervisor."

Capt Anuj Sahai
Capt. Anuj Sahai, marine business. manager, Lloyd''s Register Asia, noted that there is a growing need for ship operators to be able to demonstrate an ongoing process of risk management in shipboard operations in conformity with best practice.
"TMSA is a proactive vehicle that encourages transparency and provides ship operators a roadmap for the future," he said, "this is driven predominantly by industry guidelines and the imperative to meet safety and business objectives.
One problem is the lack of precision, he said. Lloyd''s Register found that many ship operators were either being too tough on themselves or too easy in deciding which level they were at.
Particularly sticky areas, in his view, were in element 1 requiring companies to define vision, mission, goals, targets and objectives. While most ship managers have had little problem with these, it remains a confusing riddle for some, especially when their core values and beliefs are not correctly articulated and aligned to their mission and vision statements, he said.
"Element 2, 3 dealing with ship-shore recruitment and training may be an area of concern for some," he said. "The paradigm shift in shipping from compliance based culture to proactive risk based culture has already resulted in companies'' making provisions for training and development of ''management systems'' in their annual budgets. However, this is definitely not enough. Training needs must be carefully analyzed, examined and aligned with the training program for it to produce tangible results."
"Element 3, 4, 6, 7 and 9 risk assessments: The underlying requirement of these elements is risk assessment. The fact that ship management, along with its regulators and enforcers, are moving towards a risk based approach in the operational phase is a given.
"The TMSA guidelines require shipping companies to formalize risk assessment processes and make it an ingrained part of company culture," he said.
"Some companies have understood the implications and consider an early compliance may well be a significant quality differentiator and are quickly building up risk management competence, many operators still see risk assessments as no more then a paper exercise.
"Element 7 - Management of Change. TMSA requirements of routine and non-routine operations must be clearly explained to those at the sharp end of the business, i.e. the seafarers onboard responsible for implementing management of change.
"Element 11 - incident investigations. Companies need to develop a culture whereby all incidents and near misses are investigated and concerted efforts made to identify weak or missing controls.
"If this is not done, any action taken to prevent recurrence will not only fail to provide a long term cure but may also create a scenario for a potential disaster in the future. Adequate resource allocation and commitment from the top are the problem areas that need to be addressed on priority.
"These are early days for TMSA and the risk management culture in shipping industry is still evolving," he said. "Tanker operators are still warming up to the fact that their major customers require new standards to be implemented as a top priority."
While this paradigm shift from compliance-based culture to risk based culture has thrown new challenges to many ship operators, it has created tremendous opportunities for those at the forefront of technology, the ship managers. "Our service will help you demonstrate that you are managing your operational risks," he said.

Farzin Karma, Ulysses Systems
Farzin Karma, managing director of maritime software company Ulysses Systems, which was also sponsoring the conference, talked about the importance of information technology in helping companies manage their business processes.
Software that allows easy input, storage and retrieval of mission critical information can significantly help to reduce the risks posed by poor information sharing, he said.
As an example, he mentioned the issue of seafarers leaving the vessel in a rush to go on leave, not taking the time to advise their replacement about any safety issues of the ship they should know about.
Well designed software can help companies comply with the higher standards of TMSA as a by-product of normal software usage, he said, and help minimise resource engagement and effort duplication.
"Measure and compare the efficiency of your software periodically using internal and external benchmarking and use results to ensure continuous improvement," he suggested.
Mr. Karma said he thought the biggest concerns- for shipowners about TMSA were addressing the issues of motivation, both explaining to individuals why they should contribute and finding the business benefits of aiming to achieve higher scores. There is also the difficulty with benchmarking and comparing performance with other companies, he said.
Mr. Karma suggested that shipowners could use software to improve their internal transparency, which will help manage their risks. Good software can do a lot to help shipowners store evidence of the processes they have carried out, he said.
This is also helpful in a court case if the company has to prove the measures it took to reduce risk, "Lack of clear evidence of due diligence, evidence of uncoordinated action, conflicting reports and opaque audit trails associated with incidents are more likely to cause the most serious and long-lasting damage to the credibility and image of the management involved," he said.