There is no much sense to criticize ISM, same as grumbling about bad ship’s design will not improve its manoeuvring characteristics. But whatever is a nature of the evil we have to live with, it must not, I think, defeat a reason in our acts and thoughts. It follows that when an accident happens we must thinking reasonably while working on lessons to be learned and identifying contributing factors and reasonable corrective actions, never mind what ISM says. My thesis that compliance with ISM often brings about utterly unreasonable conclusions.
One can ask, how it is possible that corrective actions perfectly within standards provided by modern safety management code at the same time practically senseless? The answer is that flaw of ISM as a system of rules, is that it designed to provide foolproof solution for any and every question. And while it always gets a sort of result, sometimes meaningless as a matter of fact but nicely wrapped, it often fails to get a proper result, such result which can be applied on practice. ISM requires us to have procedures at hands applicable to any situation, virtually rejecting existence and influence of such forces as perils of the sea, which was defined as some condition of sea or weather or accident of navigation producing a result which but for these conditions would not have occurred; or acts of god, another expression in the law descriptive of events such as direct, violent, sudden and irresistible acts of nature as the carrier could not by any amount of ability foresee, or which, if they can be foreseen, cannot be guarded against.
These exceptions, perils of the sea and acts of god known in shipping industry for many centuries and protect the owners and their masters from liability for damages or losses which were caused by force majeure. Then why ISM tries to invent bicycle instead of adoption of old, well settled rule which is in wide use in shipping, maritime and insurance law? Why ship’s command and office team shall deny simple logic of supreme force when it really takes place and look for some flaws in procedures and actions to finalise it in senseless lesson to be learned or fleet circulars impossible to apply?
ISM made not by seamen and not for seamen, it cares mainly to cover new accident or incident with new procedure, collect an evidence for insurance company and file it all in proper folder. For anyone it is evident that not safety but recordkeeping is a keystone of ISM – one can do whatever he likes so far as all paperwork done, checklist completed and filed. Therefore any accident triggers same cycle of paper movement, beginning from investigation, then new or amended procedure to be made and finally circulars/instructions to follow. There is no place for reasoning. There is even no effort made to realise that creativity in checklist production makes no sense because it is impossible to have checklist for every step and with too many checklist in use one must have a checklist on how to use all theses checklist.
Thanks to all time increasing sophistication of ship’s design, complexity of its machinery and deck systems every day brings new and new incidents and accidents. But unfortunately for us, seamen, ISM never fails to come into play with new instruction, checklist and procedure. Senseless? Unreasonable? Who cares?
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