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April 2012 www.sname.org/sname/mt by a company to schedule these annual audits is another example of a major nonconformity. Previous to this companys annual audit with the class society, evidence collated by the ag state indicated that the ship operated by the company had been issued more than 200 deciency notices from various sources includ- ing port state control and ag state inspections. e ag state decided to witness the annual audit. During the audit, four major nonconformities associated with failure to implement elements of the ISM Code were identied: documentation, maintenance, internal audits, and cor- rective action. According to the class societys procedures, the auditor recommended revocation of the companys Document of Compliance and the ag state representa- tive in attendance immediately agreed. e consequence of losing? the Document of Compliance meant that the Safety Management Certificate issued to this compa- nys ship was also invalidated. e ship was immediately ordered to port and not allowed to trade until such time as the company re-established its Document of Compliance, which is no simple, quick x. e ship was idle for approxi- mately 30 days while the company addressed these issues to the satisfaction of the ag state. Following is a brief look at these four elements of the ISM Code and how they were assessed as major nonconfor- mities with this company. Under documentation, the ISM Code requires that the company have procedures to con- trol all documents relevant to the management system. All documents are to be reviewed and approved by authorized personnel for initial distribution and subsequent changes. The audit identified that these procedures were loaded onto each oce persons computer in a format that could be changed by anyone and evidence showed that this had taken place. ere was no formal control. Under maintenance, the company is required to maintain its ships in accordance with applicable rules and regulations (for example, class society and ag state regu- lations). e audit identied that the 200-plus deciencies associated with the ship were the result of the company not providing the necessary resources to keep the ship main- tained. Under corrective action, the ship had been involved in a minor collision. e ag state investigated the incident and suggested several corrective actions. e company decided not to conduct a separate investigation and to accept the ag states report and recommendations (this action is acceptable). What was not acceptable is the fact that the company did nothing to implement the ag states recommendations. Under internal auditing, the company is required to conduct annual audits on the ship to determine if the management system is implemented on board. e company had not conducted any internal audits. Under scrutiny e ISM Code is a result of the IMO and ag states address- ing the many incidents and disasters that had taken place and preventing them in the future in a more holistic man- ner. Unscrupulous ship owners are now under the scrutiny of the regulators to take care of their ships and the person- nel that man them and are held accountable on a level playing eld with responsible owners. Complaints are often heard regarding too much paperwork and too many procedures; however, diligent companies address and resolve these issues through continual improvement of their own management systems. MTKim Parker is quality manager at Housto n-based Hercules Oshore. e ship was immediately ordered to port and not allowed to trade until such time as the company re-established its Document of Compliance, which is no simple, quick x.