Pilot Project Testing SMS and Authorization

Final Status Report

PDF Format

Table of Contents

• Background
• Background (cont'd)
• Overview of Companies
• Pilot Project Transformation
• SMS Challenges, Lessons Learned, and Results
  • Challenges with SMS
  • Outcomes
• Authorization Challenges, Lessons Learned, and Results
  • Challenges with Authorization
  • Outcomes
  • Conclusion and Summary of Outcomes
• Thank you!
• Questions?

Background

• In 2008, Marine Safety was approached by the Council of Marine Carriers to develop and test a program that would extend authorization beyond classification societies to other organizations
  
• In March of 2009, a Pilot Project was initiated to test the Canadian Alternate Compliance Program (CACP)
  
• The CACP was developed to take advantage of certain flexibilities under the Canada Shipping Act, 2001 (CSA 2001) – section 12
  
• Specifically, the CACP was meant to extend authorization beyond classification societies to other organizations
  
• The Pilot Project was designed to test the authorization of vessel-owning organizations
  
• The pilot project was a two-year collaboration between Marine Safety Headquarters, Pacific Region, and Industry
  
• It resulted in a number of new initiatives and projects to help modernize Marine Safety’s regulatory and inspection regimes

Background (cont'd)

• One of the criteria for being authorized under the CACP was to have a functional safety management system in place
  
  • Form of quality assurance to increase safety
    
  • Aligned with Transport Canada’s strategic direction for SMS
    
• The second criteria was to assess the companies under a risk assessment framework to determine their ability to undertake inspection functions
  
• After being assessed, two companies were authorized to perform certain statutory functions on behalf of Transport Canada

Overview of Companies

• Broad range of companies – small to large companies and vessels, inspected for the purpose of receiving certificates or not, varying degree of SMS knowledge
  
  • Catherwood Towing
    
  • Harken Towing
    
  • Inlet Navigation
    
  • North Arm Transportation
    
  • Seaspan Marine Corporation

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Pilot Project Transformation

• As discussed, the CACP and SMS initiatives were originally designed to work in tandem – if a company wanted to be authorized, it would be required to have a functional SMS
  
• In June of 2009, a policy shift was made to better align the SMS initiative with Transport Canada’s strategic direction

SMS would become a mandatory requirement for all Canadian non-pleasure vessels

• Thus, SMS would not be a voluntary initiative that would be used as a criterion for authorization
• The Pilot Project was refocused to test two initiatives:
  1. SMS
  2. Authorization

SMS Challenges, Lessons Learned, and Results

Challenges with SMS

• Understanding of SMS Objectives and Principles
  
• Document Control
  
• Buy-in from Senior Management
  
• Role of the Designated Person
  

It is important to note that, as with any new project, there will be a learning period in the early stages of implementation of SMS across the Canadian marine industry and, as with any endeavour, there will always be challenges.

Outcomes

• As a result of the policy shift, Marine Safety focused on making SMS mandatory
  
• Marine Safety is in the process of developing safety management regulatory requirements for all Canadian non-pleasure vessels
  
• Consultation on the proposed regulatory requirements began in Fall 2010 and will continue through Winter 2012
  
• In Fall 2012, drafting instructions for regulations and other mandatory instruments will be developed

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Authorization Challenges, Lessons Learned, and Results

Challenges with Authorization

• Maintaining Rules and Standards
  
• Complex Regulatory Regime
  
• The Importance of an Objective Third Party

Due to the challenges that have surfaced regarding authorization beyond classification societies, the CACP was not rolled out nationally but a new way forward led by the Small Vessel Compliance Program was developed.

Outcomes

• Amend the Vessel Certificates Regulations to create the Vessel Certificates and Inspection Regulations and clarify inspection and certification requirements
  
• Developing the renewed Small Vessel Compliance Program to help vessel owners meet their responsibilities under the Canada Shipping Act, 2001
  
• Develop interim guidelines for the construction, certification and inspection of tugs up to 24 metres and barges

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Conclusion and Summary of Outcomes

SMS

• Safety Management Manual template was developed
• Each principle under the ISM Code must be incorporated into the safety management regulatory requirements
  
• Drafting instructions for safety management regulatory requirements in 2012

Regulatory Regime

• Clarify regulatory requirements pertaining to vessel inspection and certification
  
• Modern and consolidated construction, inspection and certification requirements for tugs and barges

Inspection Regime

• Small Vessel Compliance Program
  
• Development of a strategy for vessels 24 metres +

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Thank You!

Marine Safety would like to extend its sincerest thanks and gratitude to the Council of Marine Carriers and the five companies that participated in the pilot project:

• Catherwood Towing
• Harken Towing
• Inlet Navigation
• North Arm Transportation
• Seaspan Marine Corporation

Thank you for your help and dedication.

Questions?

Contact:

Caitlin O’Boyle
Policy Officer
Marine Safety
caitlin.oboyle@tc.gc.ca

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