TRANSFORMING
MARITIME SAFETY CULTURE
Assessment of the impacts of the ISM Code
on maritime safety culture in Finland

ABSTRACT
The purpose of the METKU Project (Development of Maritime Safety Culture) is to
study how the ISM Code has influenced the safety culture in the maritime industry. This
literature review is written as a part of the Work Package 2 which is conducted by the
University of Turku, Centre for Maritime Studies.
The maritime traffic is rapidly growing in the Baltic Sea which leads to a growing risk
of maritime accidents. Particularly in the Gulf of Finland, the high volume of traffic
causes a high risk of maritime accidents. The growing risks give us good reasons for
implementing the research project concerning maritime safety and the effectiveness of
the safety measures, such as the safety management systems. In order to reduce
maritime safety risks, the safety management systems should be further developed. The
METKU Project has been launched to examine the improvements which can be done to
the safety management systems.
Human errors are considered as the most important reason for maritime accidents. The
international safety management code (the ISM Code) has been established to cut down
the occurrence of human errors by creating a safety-oriented organizational culture for
the maritime industry. The ISM Code requires that a company should provide safe
practices in ship operation and a safe working environment and establish safeguards
against all identified risk. The fundamental idea of the ISM Code is that companies
should continuously improve safety. The commitment of the top management is
essential for implementing a safety-oriented culture in a company.
The ISM Code has brought a significant contribution to the progress of maritime safety
in recent years. Shipping companies and ships’ crews are more environmentally friendly
and more safety-oriented than 12 years ago. This has been showed by several studies
which have been analysed for this literature research. Nevertheless, the direct effect and
influence of the ISM Code on maritime safety could not be isolated very well. No
quantitative measurement (statistics/hard data) could be found in order to present the
impacts of the ISM Code on maritime safety.
In this study it has been discovered that safety culture has emerged and it is developing
in the maritime industry. Even though the roots of the safety culture have been
established there are still serious barriers to the breakthrough of the safety management.
These barriers could be envisaged as cultural factors preventing the safety process. Even
though the ISM Code has been effective over a decade, the old-established behaviour
which is based on the old day’s maritime culture still occurs. In the next phase of this
research project, these cultural factors shall be analysed in regard to the present safety
culture of the maritime industry in Finland.
Keywords: Maritime Safety, Safety Management, Safety Culture, ISM Code
TIIVISTELMÄ
”METKU –projektissa” (Merenkulun turvallisuuskulttuurin kehittäminen) tutkitaan
kansainvälisen turvallisuusjohtamiskoodin (ISM-koodin) vaikutuksia merenkulun
turvallisuuteen ja etsitään kehittämiskohteita merenkulun turvallisuusjohtamisen
parantamiseksi. Tämä kirjallisuusraportti on laadittu METKU –projektin työpaketissa
kaksi vuoden 2008 syksyllä.
Meriliikenteen jatkuva voimakas kasvu lisää mahdollisen merionnettomuuden riskiä
Itämerellä ja erityisesti Suomenlahdella. Yksi tärkeimmistä merenkulun riskien
hallinnan keinoista on ISM-koodin mukaiset turvallisuusjohtamisjärjestelmät
varustamoissa ja aluksilla.
Inhimillisen virheen katsotaan olevan suurin yksittäinen onnettomuuksiin johtava tekijä.
ISM-koodin mukaisella turvallisuusjohtamisella tähdätään inhimillisten virheiden
vähentämisen. ISM-Koodin mukaan varustamon täytyy varmistaa aluksen turvalliset
toiminnot, luoda turvallinen työympäristö sekä varautua kaikkiin tunnistettuihin
vaaratekijöihin. Turvallisuusjohtamisen tulee perustua jatkuvaan parantamiseen sekä
johdon sitoutumiseen.
Tässä kirjallisuustutkimuksen kuvataan, kuinka merenkulun turvallisuus on parantunut
ISM-koodin vaikutuksesta. Kansainväliset tutkimukset ovat osoittaneet, että varustamot
ja alukset sekä näiden miehistöt suhtautuvat turvallisuuteen sekä ympäristöön
myönteisemmin kuin reilut 10 vuotta sitten, kun ISM-koodin mukaiset
turvallisuusjohtamisjärjestelmät tulivat pakollisiksi merenkulussa. Samanaikaisesti
myös monet muut tekijät ovat vaikuttaneet merenkulun turvallisuuden paranemiseen.
Tästä syystä on vaikeaa osoittaa, mikä on ISM-koodin suora vaikutus turvallisuuteen.
Myös sopivat tilastolliset aineistot ISM-koodin vaikutusten arvioimiseksi puuttuvat.
ISM-koodin myötä merenkulkuun on syntynyt turvallisuuskulttuuri, joka myös edelleen
kehittyy. Kuitenkin turvallisuusjohtamisessa esiintyy puutteita, joita voidaan pitää
kulttuurisina. Tämän kirjallisuustutkimuksen pohjalta käynnistetään projektin
empiirinen osa, minkä aikana merenkuun turvallisuuskulttuuria analysoidaan
haastattelemalla erityisesti alusten miehistöjä.
Avainsanat: Merenkulun turvallisuus, turvallisuusjohtaminen, turvallisuuskulttuuri,
ISM-koodi
TABLE OF CONTENTS
1 Introduction ……………………………………………………………………………………………….. 9
1.1 Background of the study……………………………………………………………………….. 9
1.2 METKU Research Project…………………………………………………………………… 10
1.2.1 Project plan and organization ……………………………………………………….. 10
1.3 The content of the report …………………………………………………………………….. 12
2 Maritime traffic in Finland …………………………………………………………………………. 14
2.1 Shipping business trends in Finland in the early 21st century …………………… 15
2.2 Safety and risks in the Baltic Sea …………………………………………………………. 16
2.2.1 Traffic volumes and occurrence of accidents………………………………….. 16
2.2.2 Special risk areas ………………………………………………………………………… 17
2.2.3 Navigation circumstances…………………………………………………………….. 17
2.2.4 Environmental issues…………………………………………………………………… 19
2.3 The ISM Code and Maritime Safety Regulation…………………………………….. 19
2.3.1 The evolution of Maritime Safety Regulation…………………………………. 19
2.3.2 The ISM Code ……………………………………………………………………………. 20
2.3.3 The enforcement of the ISM Code ………………………………………………… 21
3 Management systems and Safety culture………………………………………………………. 23
3.1 Organizational culture ………………………………………………………………………… 23
3.2 Management systems and organizational culture……………………………………. 24
3.3 Safety culture…………………………………………………………………………………….. 24
3.4 How to change the safety culture …………………………………………………………. 25
3.5 Maritime safety culture……………………………………………………………………….. 26
3.6 IMO’s safety philosophy …………………………………………………………………….. 27
3.7 TQM provides the basis for the ISM Code…………………………………………….. 28
3.8 TQM-based management standards ……………………………………………………… 30
3.9 Substances of the ISM Code………………………………………………………………… 31
3.9.1 General objectives of the ISM Code………………………………………………. 31
3.9.2 Responsibility of the Company …………………………………………………….. 31
3.9.3 Legislative conformity…………………………………………………………………. 32
3.9.4 Functional requirements of the safety management system………………. 32
3.10 Comparing the ISM Code with the quality and safety standards ………………. 33
4 Former analyses of the ISM Code ……………………………………………………………….. 35
4.1 Implementation of the safety management system………………………………….. 35
4.2 Maintenance of the safety management system ……………………………………… 38
4.3 Improvement of maritime safety ………………………………………………………….. 38
4.4 Developing safety performance indicators…………………………………………….. 40
4.5 Evolution of the ISM Code………………………………………………………………….. 43
5 Summary and conclusions………………………………………………………………………….. 45
5.1 Arguments for the Project …………………………………………………………………… 45
5.2 Establishment of the ISM Code……………………………………………………………. 45
5.3 How to evaluate the maritime safety culture? ………………………………………… 46
5.4 Findings of the literature review…………………………………………………………… 47
6 Further Research……………………………………………………………………………………….. 49
Terminology ……………………………………………………………………………………………………. 50
References ………………………………………………………………………………………………………. 51
Jouni Lappalainen 9
1 INTRODUCTION
The ISM Code has been set up by the UN’s agency for maritime affairs, the
International Maritime Organization (IMO). The ISM Code provides the shipping
companies and mariners a standard for safety management. The ISM Code has been in
use since 1996. Thus, experiences and practices have accumulated now even more than
within a ten-year period. (Anderson, 2003).
The purpose of this study is to research how the ISM Code has influenced the safety
culture in the maritime industry in Finland.
1.1 Background of the study
The ro-ro Ship Estonia capsized and sunk in heavy weather in September 1994. The
primary reason for the accident was a failure and loosing of the bow visor of the ship.
The public significance of the disastrous accident of the Estonia was enormous
especially in the Nordic countries. The accident was thoroughly investigated. Despite of
the fact that the official accident investigation reported about the technical failure wild
rumours about conspiracy theory spread in public, especially in mass media.
Hannu Hänninen analysed the report of the investigation board thoroughly in his
doctoral thesis concerning the Estonia accident (Hänninen 2007), Hänninen stated that
the cause of the Estonia accident was not only a technical failure of the bow visor.
Hänninen widened the scope of the study from the accident itself to the surrounding
social and institutional system of the maritime industry. Hänninen shows that there are
major defects in the safety culture of the maritime industry.
Even before the Estonia accident occurred, deficiencies in the maritime safety culture
were considered as the reason for the accident of the Herald of Free Enterprise (FMA
2006). Among the other fatal accidents that occurred in the late 1980s, the accident of
the Herald of Free Enterprise was triggering concern about the maritime safety culture
among international maritime authorities. This concern leads the International Maritime
Organisation (IMO) to start to develop a new approach for managing safety in the
maritime industry. As a result, the IMO provided an international safety management
code (ISM) in 1993.
Many saw the ISM Code as a promising solution to the required change towards a better
safety culture in the maritime industry (Anderson, 2003; IMO, 2005; Mejia 2001).
Nevertheless, strong criticism towards the ISM Code has appeared throughout its
application. There have been both positive arguments and negative arguments for the
benefits of the ISM Code in Finland as well. Also Hänninen mentioned in his doctoral
thesis that the application of the ISM Code could lead the maritime industry into a safer
route. In that view, we could see the ISM Code as a remedy for the poor safety culture
of the maritime industry. Therefore, this is the right time to study what is the
significance of the ISM Code for the maritime safety in Finland.
10 Transforming Maritime Safety Culture
1.2 METKU Research Project
The METKU research project evaluates the impacts of the ISM Code on the maritime
safety culture in Finland (METKU – Developing Maritime Safety Culture). The
program started at Kotka Maritime Research Centre in the first quarter of the year 2008.
The project lasts for 2,5 years. The METKU project is funded by the European Union
and other financing comes from the European Regional Development Fund of Southern
Finland, Regional Council of Päijät-Häme, City of Kotka and private companies.
The purpose of the project is to study how the ISM Code has influenced the safety
culture in the maritime industry. The project attempts to find the best practices for the
shipping companies while improving their operations by implementing and developing
their safety management systems.
1.2.1 Project plan and organization
The METKU project consists of the following work packages and responsible research
partners:
• WP1: Statistical measurements of maritime safety, Helsinki University of
Technology, Ship Laboratory
• WP2: Assessment of the performance of Safety Management Systems in Finnish
shipping companies, University of Turku, Centre for Maritime Studies
• WP3: Comparing ISM –OHSAS practices in shipping companies and port
operations (ISM – OHSAS), Kymenlaakso University of Applied Sciences,
Maritime Studies
• WP4: Exploring the Best Practises in shipping companies, Turku University of
Applied Sciences, Ship Laboratory
• WP5: Safety management practices in Finnish maritime and port authorities,
Kymenlaakso University of Applied Sciences
• WP0, Project management and communications, Kotka Maritime Research
Centre
Kotka Maritime Research Centre is a rapidly growing research centre located in Kotka,
in Southeast Finland by the Baltic Sea and the Gulf of Finland. The research centre
consists of professors, researchers, project managers and administrative staff, currently
of over 20 persons altogether. The research staff belongs administratively to the
Helsinki University of Technology, the Kymenlaakso University of Applied Sciences,
the University of Helsinki and the University of Turku.
Jouni Lappalainen 11
Kotka Maritime Research Centre conducts research related to the maritime industry,
maritime safety and marine environment especially in the Gulf of Finland and the Baltic
Sea. Maritime transport and environmental safety threads have substantially increased
in the Gulf of Finland and the Baltic Sea. Kotka Maritime Research Centre aims at
reducing these threats through research and education. Maritime transport and port
operations and their economic impacts are also important areas of research at the
Centre.
This literature review is written as a part of the Work Package 2 which is conducted by
the University of Turku, Centre for Maritime Studies. The Centre for Maritime Studies
(CMS) was founded in 1980 and was converted into a special unit of the University of
Turku in 1984. The CMS has developed into one of the leading providers of education,
research and expert services in the maritime field and in other related fields in Finland.
The CMS has developed into a strong provider of research and expert services related to
seafaring and logistics. The services it offers include logistics and industry business
consulting, research and development projects for the maritime sector and international
co-operation projects. Most of the reports of the research and development projects are
published in the CMS’s own series. These publications are available, for example, at the
special maritime library located at the Centre for Maritime Studies in Turku. In addition
to its national activities, the CMS has taken part in international projects, especially
those concerning the Baltic Sea. For example, CMS has led several EU-funded projects,
taken part in other EU projects and participated in the research and development work
of other types of projects.
A group of Finnish shipping companies and major Finnish ports participate in the
project. The project partners are listed below:
• Finnlines Oyj
• Kristina Cruises Oy
• Meriaura Oy
• VG-Shipping Oy
• Port of Helsinki
• Port of Kotka
• Port of Hamina
These business partners support the project through financing and by providing
information on their safety management systems.
12 Transforming Maritime Safety Culture
1.3 The content of the report
The target of the Work Package Two is to study the development of the Finnish
Maritime Safety Culture considering the effects of the ISM Code from the middle of the
1990s to the present. The Work Package Two is divided into three main parts. Literature
review forms part one. The second part consists of empirical research examining the
impacts of the ISM Code on the Finnish shipping companies. The third part includes
Assessments of safety performance according to European Quality Award Criteria.
Figure 1.1: An overview of the Work Package Two
The purpose of the literature review is to attempt to formulate a theoretical framework
for the forthcoming research project. This literature review provides a starting point for
a more comprehensive study including profound interviews of maritime personnel and
evaluating the performance of the safety management systems of Finnish shipping
companies.
In order to evaluate the effects of the ISM Code on maritime safety culture we have to
specify the concept of safety culture and recognize the means which could cause
changes to the safety culture. The safety culture is a part of a wider concept of an
organizational culture. Typically, the means for changing the organizational culture
utilized by companies is called a management system. Different management systems Phase 2 Phase 2 Phase 1
Literature
review
Interviews
Quality
assessment
Participation
in Audits
Create the theoretical framework of the study
• how to develop safety culture
• characteristics of the management systems
Collect subject evidence of the impacts of ISM code
• Interviews of the collaborative Finnish shipping companies
Verifying the results of the interviews
• participation in internal audits
Analysing the role of Administration
• participation in external audits
Measuring the performance of the shipping companies SMS
• utilising the European Quality Award Criteria
Conclusion
Presenting the results of the research
• Suggestions for the shipping companies and administration
• The need for further research
Jouni Lappalainen 13
have been established for different purposes, for example quality management,
environmental management and safety management. The ISM Code provides
specifications for a safety management system in a shipping company. With the
intention of discovering the success factors of a well performing organization we have
to build a link between the management systems and the organizational culture.
Section two presents an overview of the economic and environmental conditions of
Finnish maritime traffic in order to understand the demands and challenges confronted
by the shipping companies nowadays. The demanding environmental and navigational
circumstances which the Finnish maritime traffic has to face are described in this
section. In addition, the Finnish maritime regime is described with a meaning to
discover the position of the ISM Code as a part of the Finnish maritime law.
The purpose of section three is to build a bridge between the organizational culture and
the management systems. The third section provides a description of the safety culture
and an overview of popular management systems. In addition, the most common
management principles of the management systems are characterized. Major similarities
and differences between the management standards are also evaluated.
Section four concentrates on the earlier studies in regard to the impacts of the ISM
Code. The earlier literature about the experiences of the implementation and
maintenance of the safety management system are considered. Particularly the studies
concerning the measurement of safety improvement and safety performance are
reviewed.
Section five provides a conclusion of the literature review. The next phase of the project
is presented in the last section.
14 Transforming Maritime Safety Culture
2 MARITIME TRAFFIC IN FINLAND
Maritime traffic is crucial for the Finnish economy and the welfare of the Finnish
citizens. As much as 90 % of the Finnish export and over 70 % of the Finnish import are
transported by sea. Finland is totally dependent on seaborne traffic (Karvonen et al.
2008).
Finnish maritime transportations have grown during the first decade of the 21st century,
except in 2005, as a result of labour unrest in the Finnish forest markets (Karvonen et al.
2008). Seaborne transports between Finland and foreign countries achieved the
milestone of 100 million tons in 2007 (FMA 2008). The seaborne transportation is
mostly operated by vessels which are reflagged under foreign flags. The percentage of
vessels which fly the Finnish flag has decreased dramatically during the last few years.
In 2007, the percentage of the vessels flying the Finnish flag was as low as 29 % (FMA
2008). The amount of port calls at Finnish ports was almost 40 000 in 2007. The Ports
of Kilpilahti, Helsinki and Kotka are the busiest ports in Finland (FMA 2008).
Passenger traffic between Finland and foreign countries is an important part of the
Finnish maritime traffic. Passenger traffic abroad grew constantly in the 1990sexcept
during a short period after the accident of the ro-ro ship Estonia. In the current decade,
the passenger volumes have remained on a steady level. The volume of the passenger
traffic has totalled about 16 million passengers per year. The most important destination
for passenger ship traffic is Sweden and the second most important is Estonia. The
amount of passengers between Finland and Sweden was 9,3 million in 2007 and
between Finland and Estonia 5,8 million passengers in 2007. The passenger traffic
between Finland and Germany was 0,25 million passengers in 2007. The traffic
volumes of passenger ships in the Gulf of Finland and in the northern part of the Baltic
Sea are still considerable. The Port of Helsinki is the busiest and the Port of Turku the
second busiest passenger port in Finland (FMA 2008).
Domestic passenger traffic is mainly provided by local charter boats in coastal cities and
in cities in the Lake District. These charter boats are typically managed by small
companies and they offer sightseeing cruises near by the home port. The shipping
company Kristina Cruises is the only company providing long-distance cruises between
the Finnish coastal cities and the cities in the Lake District onboard one passenger ship,
M/S Kristina Brahe.
Also the international maritime traffic has grown strongly in the neighbouring sea areas
of Finland. Maritime traffic in the Baltic Sea Region is growing rapidly due to the
economic growth of Russia. The most rapidly growing transportation, however, is the
oil transportation between Russia and international markets.
Jouni Lappalainen 15
2.1 Shipping business trends in Finland in the early 21st century
In the current (2000) decade, the Finnish shipping business has internationalized
significantly (Karvonen et al. 2008). The internationalization has developed in various
ways. Firstly, Finnish-owned vessels have been transferred to fly a foreign flag.
Reasons for flying a foreign flag are, for example, more favourable manning costs and
tax policies in the foreign country compared to Finland. At present, nearly half of the
Finnish-owned fleet is reflagged abroad.
Secondly, some Finnish shipping companies have expanded into foreign countries via
acquisitions. For example, Rettig Oy Bore purchased a Dutch shipping company in
2001 and, also, Finnlines purchased the German Team Lines and Swedish Nordö-Link
shipping companies in the early 2000s. (Karvonen et al. 2008)
Thirdly, the Finnish shipping business has become international by merging parts of it
into foreign shipping companies by foreign buyers. The major Finnish forest companies
have sold their earlier ownerships of the shipping companies such as Finnlines,
Transfennica and Silja Line. Likewise, some (private) owners who have been engaged
in the shipping business for a long time have sold their ownerships abroad (Karvonen et
al. 2008).
Also, some shipping companies have merged with domestic shipping companies in the
current decade. ESL Shipping and Bore have grown significantly through acquisitions
of domestic shipping companies (Karvonen et al. 2008).
The internationalization and concentration of the shipping business have brought about
some effects on the safety management systems of the shipping companies. The merged
companies have to consolidate their safety management systems by a standardization of
the company’s safety policy, safety documentation, manuals etc. Also there have been
notable differences between the safety cultures of the merging companies which might
produce some friction between the personnel coming from different organizations. For
example, the way in which the concept of non-conformity has been specified in
shipping companies has varied.
Changing of the flag is a symptom of uncompetitiveness of the Finnish vessels in the
international shipping market (Karvonen et al. 2008). The uncompetitiveness and a poor
economic situation of a shipping company could defeat the company’s safety
progression when the ability to invest is weak.
The Finnish maritime traffic concentrates mainly on short sea shipping business. The
main part of the Finnish-owned fleet cruises in the Baltic Sea and the North Sea region
(Karvonen et al. 2008). The maritime traffic in the Baltic Sea is characterised by short
high see legs and frequent and short calls to port. This type of “feeder traffic” could
pose a threat to maritime safety. The personnel onboard could suffer from fatigue due to
insufficient sleep, particularly when the ship is manned only with a master and one
mate. (Accident Investigation Board Finland, 2008).
16 Transforming Maritime Safety Culture
As a whole, the outlook of the shipping business seems positive in Finland. According
to Karvonen et al., the demand situation in the Finnish shipping market is believed to
strengthen in the future. The Finnish shipping companies believe that the turnover of the
business is going to grow and companies are going to hire new employees in the near
future (Karvonen et al. 2008). The positive outlook could also cause investments in new
technology and this might benefit the safety process.
Nevertheless, the Finnish shipping companies are anxious about the supply of
professional labour. Particularly a shortage of competent engineers and senior officers
has been seen as a threat to the maritime safety.
2.2 Safety and risks in the Baltic Sea
2.2.1 Traffic volumes and occurrence of accidents
The most important risk factor effecting maritime safety is the huge traffic volume in
the Baltic Sea and especially in the Gulf of Finland (Karvonen et al. 2006 and Arola et
al. 2007). The density of the maritime traffic has been heavy in recent years and it is
growing rapidly all the time. The volume of the maritime traffic is expected to double
until 2015 (Karvonen et al. 2008).
Although the volume of the maritime traffic has grown in recent years, the occurrence
of accidents has decreased by 50 % during the last 15 years.
Figure 2.1: Occurrence of accidents in years 1991 – 2006 (Jalonen et al. 2007)
Jouni Lappalainen 17
The fast growing traffic in the Gulf of Finland keeps the risks on a high level in any
case (Jalonen et al. 2007).
2.2.2 Special risk areas
Oil transports equal 57 % of the total cargo in the Gulf of Finland. Particularly, the
amount of oil tankers is abundant due to oil transportation from the Russian ports of
Primorsk and Vysotsk. Russia is currently building a new oil terminal in Ust Luga. Also
Russia is expanding its oil pipeline capacity from oil fields to the ports in the eastern
part of the Gulf of Finland. The volumes of the oil transportation are forecast to grow up
to 200 million tons until 2010 (Kommersant, 29. October 2007).
Another significant risk factor is heavy gross traffic through the Gulf of Finland from
Helsinki to Tallinn. This traffic concerns mostly passenger traffic between Finland and
Estonia. The ultimate accident scenario is a collision of an oil tanker with a full
passenger ship. In that case, thousands of people will be in jeopardy. Also, the marine
nature of the Gulf of Finland will be endangered (Arola et al. 2007).
The dimensions of the oil tankers are growing in the Baltic Sea. At the moment, the oil
tankers vary in size from 80 000 to 100 000 tons. The dimensions of the new oil tankers
are designed for 200 000 tons with a 15,4 meters draught. These are the limits for a safe
navigation through the Danish strait (Markku Mylly, General Director of FMA, at a
presentation in a seminar held on 20 Nov 2007). The length and the width of the
planned tankers will be more extensive than of the oil tankers which are currently
navigating in the Baltic Sea. The navigation of these new vessels will be more difficult
due to the narrow fairways of the Baltic Sea. Also their Helpance by ice breakers will
be more difficult in winter conditions. The risk of a larger oil spill is higher for these
giant tankers.
2.2.3 Navigation circumstances
Because of the environmental circumstances, navigation in the Finnish sea region is
very challenging. The Finnish sea areas are shallow and rocky. Also the fairways in the
Finnish sea areas are very narrow.
The Finnish Sea region is covered with ice nearly half of the year. In normal winters,
the Bay of Bothnia, the Gulf of Finland and the northern part of the Baltic Sea are icecovered. In a harsh winter, almost the entire Baltic Sea is covered with ice. The winter
conditions set special requirements for the technology and equipment of the vessels as
well as the competence and skills of the maritime personnel. The obstacles caused by
the winter conditions are packed ice, ice banks, jammed ice fields and damages of
navigation signs caused by drifting ice floes (Arola et al. 2007).
18 Transforming Maritime Safety Culture
The seafarers confront an additional challenge due to the fact that a significant part of
the marine work is done during the dark hours in difficult weather conditions and in
winter conditions (AIB, 2008).
The maritime personnel of the vessels in the Baltic Sea represent many different
nationalities. The rules of navigation are the same to all but the competence of the
maritime personnel on different vessels may differ greatly. Particularly, the personnel
might not have the required competence for winter navigation. Nevertheless, no
international requirements for the competence of winter navigation are available
(Sergey Aysinov, Project Manager, the Admiral Makarov State Maritime University,
presentation in 20. November 2007). The lack of competence and experience could pose
a risk in the Baltic Sea especially in the winter time.
Jouni Lappalainen 19
2.2.4 Environmental issues
The Baltic Sea has been recognised as a particularly sensitive sea area PSSA. PSSA
refers to an area that needs special protection through actions by the IMO because of its
significance for recognized ecological or sociological or scientific reasons which may
be vulnerable to damage by international maritime activities (IMO, 2008c). The PSSA
status enables that specific measures can be used to control the maritime traffic in the
Baltic Sea. The measures which are used in the Baltic Sea are, for example, routeing
measures and Vessel Traffic Services (VTS). The Baltic Sea has been designated as a
PSSA in 2005.
2.3 The ISM Code and Maritime Safety Regulation
Maritime safety legislation is mainly international. The most important actor is the
International Maritime Organization (IMO). The IMO is a specialized agency of the
United Nations. The primary purpose of the IMO is to provide conventions and
resolutions for safety at sea. The IMO’s convention became mandatory when the
majority of the member states had ratified the convention. The IMO focuses on the
safety and health of people, on vessel safety and, during the recent decades, much more
on environmental aspects (Kristiansen, 2005; Mitroussi, 2003 and 2004).
2.3.1 The evolution of Maritime Safety Regulation
The evolution of the Maritime Safety Regulation has gone through three stages. The
first stage was the era of culture of punishment. The culture of punishment means that if
you are found responsible for an accident you will get a punishment like a fine or even
imprisonment. A good example of the culture of punishment in connection with the
Maritime Safety Regulation from the present day is the Oil Pollution Act from 1990
(OPA90) in the United States. The Oil Pollution Act gives ship owners full economic
liability for oil spills in the US coastal waters (Kristiansen, 2005).
The second stage was called culture of compliance where the focus is to comply with
numerous prescriptive rules concerning the construction of the ship, the competence of
the crew, the required safety equipment etc. Typically, the rules are scrupulous and
strictly mandatory. Examples of the culture of compliance are The SOLAS rules
(International Convention for the Safety of Life at Sea) and the STCW rules
(International Convention on Standards of Training, Certification and Watchkeeping for
Seafarers) (Kristiansen, 2005).
Thirdly, culture of self-regulation is based on a standard established by the industry
itself. The ISO 9001 quality standard is a good example of self-regulation. Likewise, we
could see the ISM Code as a leap forward towards the culture of self-regulation
although the application of the ISM Code is mandatory for all shipping companies by
virtue of international and domestic law (Kristiansen, 2005).
20 Transforming Maritime Safety Culture
Major accidents have been activating the renewal of the international maritime safety
regulation. The International Convention for the Safety of Life at Sea (SOLAS) was
established in response to the Titanic disaster which occurred in 1912. The SOLAS
convention is generally regarded as the most important of all international treaties
concerning the safety of merchant ships (IMO, 2008). The first version of the SOLAS
convention was adopted in 1914. The SOLAS convention has been revised couple of
times during the 20th century: the second version was established in 1929, the third in
1948 and the fourth in 1960. The latest convention of the SOLAS was adopted in 1974.
This version includes the amendments agreed until the date of the agreement. The
SOLAS convention 1974 includes a new approach to the renewal of the convention
which is called tacit acceptance procedure. The tacit acceptance procedure means that,
instead of requiring that an amendment shall enter into force after being accepted by, for
example, two thirds of the Parties, the tacit acceptance procedure provides that an
amendment shall enter into force on a specified date unless, before that date, objections
to the amendment are received from an agreed number of Parties. The tacit acceptance
procedure was designed to ensure that changes could be made within a specified (and
acceptably short) period of time. As a result, the 1974 Convention has been updated and
amended on numerous occasions. The Convention in force today is sometimes referred
to as SOLAS, 1974, as amended. The ISM Code was included in the SOLAS
convention by International Maritime Organization in 1994. (IMO, 2008).
2.3.2 The ISM Code
The foundation of the ISM Code was laid in the late 1980s. In the late 1980s numerous
fatal accidents had occurred and the amount of maritime insurance claims exploded
dramatically. Particularly the capsizing of the Herald of the Free Enterprise in 1987
awoke broad concern in the maritime community about maritime safety. Through a
thorough analysis of the accidents, the shipping community came to a resolution that the
main reason for these accidents was human error. As the main reason for the accident of
the Herald of Free Enterprise was seen a lack of a comprehensive management system
in regard to organizational safety. The roles and responsibilities of the crew were poorly
described and this led to a situation where the bow door was left open without anyone
noticing the hostile situation. Consequently, the roots of the numerous human errors
were seen to stem from a lack of a comprehensive management system in relation to
safety management in shipping (Anderson, 2003).
The ISM Code was established in three phases. In the European Union, the application
of the ISM Code became mandatory for ro-ro passenger ferries which were operating
between different ports in the EU on the first of July 1996. Clearly, the accident of the
Estonia hasted the process. The next phase began when the ISM Code came into
operation in worldwide shipping on first of July 1998. On that day, the ISM Code
became mandatory for all passenger ships, high speed craft, tankers and bulk carriers.
Finally, all the other ships and mobile offshore drilling units fell under the effect of the
ISM Code on the first of July 2002. The ISM Code may be applied to all ships from 500
gross tonnages upwards (Anderson, 2003).
Jouni Lappalainen 21
The ISM Code was included in the SOLAS convention by International Maritime
Organization in 1994. Chapter IX of the SOLAS convention makes the application of
the ISM Code mandatory for a shipowner. Chapter IX requires a safety management
system to be established by the shipowner or any person who has assumed
responsibility for the ship (the “Company”) (IMO, 2004). According to Chapter IX of
the SOLAS convention the safety management system shall be in compliance with the
ISM Code (International Management Code for the Safe Operation of Ships and for
Pollution Prevention).
By ratifying the SOLAS Convention, Finland has incorporated the ISM Code into the
Finnish maritime law in 1995 (The Finnish Maritime Law, Laki merilain muuttamisesta
369/1995). According to the Finnish maritime law, the shipowner should establish and
maintain a safety management system which is compliant with the ISM Code. Detailed
specifications of the required safety management system are enacted in the statute of the
shipowner’s safety management systems (Statute/Asetus 66/1996).
2.3.3 The enforcement of the ISM Code
According to the ISM Code, national maritime administrations are responsible for the
enforcement of the ISM Code in each member state of the IMO (IMO, 2008a). The
Administration is responsible for issuing a Document of Compliance (DOC) to a
Company which operate a ship. The document of compliance should be issued to any
Company which has implemented a safety management system in compliance with the
requirements of the ISM Code. The safety management system covers any ships
operated by the Company. The Safety Management Certificate (SMC) should be issued
to any ships which are compliant with the ISM Code. External audits are performed by
administration prior to the issuance of the document of compliances and the safety
management certificates. These audits are carried out in a Company and onboard ships
in order to control the conformity of the safety management system. (IMO, 2008a)
The Administration could authorize an external organisation to perform the safety
management audits and issue the document of compliances and the safety management
certificates (IMO, 2008a). These organisations are called Recognized Organisations
(RO). Typically, the recognized organisations are Classification Societies.
In Finland, Finnish Maritime Administration is responsible for the enforcement of the
ISM Code. The role and the responsibilities of the Finnish Maritime Administration are
defined in the Finnish Act of Supervision of the Vessel Safety (Laki alusturvallisuuden
valvonnasta). Typically, the Finnish Maritime Administration has delegated the
issuance and auditing to the recognized organizations in case of cargo ships. Passenger
ships flying the Finnish flag are audited by the Administration.
Regional Port State Controls have an essential role in the enforcement of the ISM Code.
In Europe, the regional Port State Control was initiated in 1982 when fourteen European
countries agreed to co-ordinate their port State inspection effort under a voluntary
agreement known as the Paris Memorandum of Understanding on Port State Control
22 Transforming Maritime Safety Culture
(Paris MoU). Current membership includes 27 countries. The purpose of the Port State
Control is described as follows:
Port State Control is a check on visiting foreign ships to see that they comply
with international rules on safety, pollution prevention and seafarers living and
working conditions. It is a means of enforcing compliance where the owner and
flag State have failed in their responsibility to implement or ensure compliance.
The port State can require defects to be rectified and if necessary detain the ship
for this purpose. It is therefore also a port State’s defence against visiting
substandard shipping.
Finland is a member of the Paris MoU. The Paris MoU ranked Finland as the safest flag
State in 2005 and as the third safest flag State in 2007. The Paris MoU has accepted 38
countries to the “white list” which means that the maritime safety risk is low on the
ships flying the flag of these countries. (Paris MoU, 2008a).
The Paris MoU has organised three concentrated inspection campaigns (CICs), which
have been targeted to inspect the ISM compliance of visiting vessels in the European
ports. The latest CIC was launched in September 2007 with co-operation with the
Tokyo MoU, the Mediterranean MoU and the Indian Ocean MoU (Paris MoU, 2008).
In addition to the concentrated inspection campaigns, the Port State Control pays
attention to the ISM-related issues during the ordinary inspections. The nonconformities and deficiencies found in the inspections are reported to the ship’s flag
State administration. Due to a major non-conformity or a hazardous deficiency
concerning the ISM Code the Port State Control has the authority to detain the vessel
until the deficiency is repaired.
Jouni Lappalainen 23
3 MANAGEMENT SYSTEMS AND SAFETY CULTURE
The purpose of this section is to offer context to the study by giving an overview of
different theories about organizational culture. The framework of the organizational
culture sets the limits and restrictions for the Assessments of this study when assessing
the possible changes in the maritime safety culture as a result of the application of the
ISM Code.
Various management systems for different purposes are described. Management
systems provide the methods which are applied to improve the performance of the
organization.
3.1 Organizational culture
The concept of culture is adhered to the organizational context in this study. According
to Schein (2001), a unique organizational culture could be established whenever and
wherever a group of people join together for a reasonable period of time. Even a small
group could forma culture of their own.
The concept of organizational culture is described in various ways in different literary
works. According to Wiegmann et al. (2002), two main perspectives of the
organizational culture are available.

– the socio-anthropological perspective
– the organizational psychology perspective
The organizational culture could be seen as an aggregation of symbols, heroes, rituals
and values which are materialized as visible objects or practices. According to the
socio-anthropological theory of the organizational culture, there is a deeper structure of
culture inside the structure of symbols, heroes, ritual and values. This structure could be
invisible for outside observers and it can be difficult even for the member of the
organization to literally phrase the characteristics of the prevailing culture. Due to these
unconscious and deep-rooted characteristics, Schein (2001) is convinced that the
manipulation of the organizational culture is not an easy task.
As well as the socio-anthropological theory, the organizational psychology perspective
of the organizational culture focuses on shared values and beliefs manifested through
symbols etc. On the other hand, according to Wiegmann et al. (2002) organizational
psychology perspective postulates that organizational culture consists of functional
factors which could be manipulated. The organizational psychology theory believes that
in the long run attitudes, beliefs and values can be changed through the methods of
endurance management.
In order to rapidly improve the performance and effectiveness of the organization, one
has to be deeply conscious of the factors of the prevailing organizational culture
24 Transforming Maritime Safety Culture
(Schein, 2001). The chosen measures for the improvement should coincide with the
current organizational culture.
3.2 Management systems and organizational culture
The popular management systems which are applied to quality, safety and
environmental management have their origin on the organizational psychology. In
general, the functions of the management systems are:
• to set a company policy,
• set goals
• and provide a systematic approach for operations

According to Deming (1986), the corporate culture supports the total commitment of a
company to quality and high productivity. In the 1970s, Deming called in question the
prevailing organization culture and the approach to quality in the American industry.
Deming attempted to demonstrate that there has to be revolutionary cultural changes in
the management of the American companies in order for them to survive the increasing
international competition. According to Deming, the utmost requirement for the
American management is a firm commitment to the quality approach including
willingness for constant learning and continuous improvement. Later on, Deming’s
philosophy was named as Total Quality Management (TQM).
3.3 Safety culture
Safety culture has been examined as a part of the organizational culture. Wiegmann et
al. (2002) have performed a comprehensive literature analysis concerning the safety
culture. They have explored numerous definitions of safety culture in different
industries for example within the energy industry, aviation and manufacturing. One of
the most uncomplicated definitions of the safety culture is:
“Safety culture reflects the attitudes, beliefs, perception and values that
employees share in relation to safety”.
Wiegmann et al. establish their analysis of the safety culture on the organizational
psychology theory. For the purpose of measuring organization’s safety culture they
represent indicators for an accomplished safety culture. These indicators are:
– organizational commitment,
– management involvement,
– employee empowerment,
– reporting system and
– rewarding system.
Jouni Lappalainen 25
These indicators are also common for popular quality and environmental management
systems which will be described in detail below.
Krause et al. stated that the safety management system reflects the safety culture of the
organization (Kristiansen 2005). The success of the safety management system is very
depended on the prevailing safety culture.
Pun et al. (2002) performed a comprehensive analysis of the problems and difficulties in
regard to the implementation of the safety management system based on the ISM Code
in Asian shipping companies. They came to the conclusion that one of the main reasons
for the problems with the implementation was a mismatch in the current safety culture
of the company. They showed that the companies which have faced difficulties with the
implementation process did not sufficiently take the prevailing corporate safety culture
into consideration (Pun et al. 2002).
3.4 How to change the safety culture
According to Schein (2001), the organizational culture is difficult to change. Schein
described that changing the organizational culture might begin when something is
threatening the survival of the organization. The purpose of the culture for an
organization is to maintain the stability and predictability of the future. In order to
change the current organizational culture there has to be something disturbing the
ongoing stability. According to Schein, the organization culture affects the actualized
operations through a cognitive framework of the people which are involved in the
organization. The transformation of the organizational culture presumes an adaptation
of a new cognitive framework of the personnel of the organization (Schein, 2001).
Schein itemized two different ways to establish a new cognitive framework:
• imitation of and identifying with the role model provided by a management
system (learning)
• trial and error until the behaviour remains successful (experiences)
According to the organizational psychology theory, the organizational culture could be
developed by the systematic tools of management. Krause et al. represent the causation
from the safety culture to the appearance of the incidents (near misses, hazardous
situations, accidents etc.) (Kristiansen, 2005). The prevailing culture determines the
phenomenon of the safety management system and its mediation into actualized
operations. These causal relationships could be seen as bidirectional. In the long run, the
actualized operations affect the safety culture through learning and the experiences of
the personnel in the organization (Lanne, 2007).
26 Transforming Maritime Safety Culture
The interactions between safety culture, safety management and active operations are
shown in Figure 3.1.
Figure 3.1: Interactions between safety culture and safety management and operations
3.5 Maritime safety culture
According to Hänninen (2007), the accident of the ro-ro ship Estonia was caused by
poor maritime safety culture. Hänninen showed that the characteristics of the maritime
culture had prohibited the precautions a long time before the accident happened.
Hänninen saw that there is a lack of risk handling measures and that the risk
management systems are underdeveloped in the maritime industry. Due to these
deficiencies in the risk management systems, the safety culture of the maritime industry
includes poor procedures for handling incidents and safety warnings. The fact is that
there had occurred other bow visor failures even before the Estonia accident. Hänninen
supposed that there might have been opportunities to avoid the bow visor failure of the
Estonia if an industrial-level system for handling incidents as bow visor failures had
existed. There was no cumulative information about the other bow visor incidents in the
industrial level so the other shipping companies could not learn from the other
companies’ mistakes. Even national maritime administrations were reported inadequate
by the shipping companies.
Hänninen (2007) shows that there are major defects in the safety culture of the maritime
industry:
• there is a higher tolerance to accept incidents and near misses in the maritime
community
• shipping companies are more profit-oriented and neglect safety issues
• there is no systematic procedure for incident management
• mariners are not proactive for safety issues
• information about nonconformities does not cumulate in the maritime industry
and reporting of nonconformities is not reported accurately to the maritime
authorities
Safety Culture
Safety
Management System
Operations
Jouni Lappalainen 27
Hänninen urged that in order to avoid similar accidents in the future and in order to get
improvements in the maritime safety operations there has to be a revolutionary change
in the safety culture of the maritime industry.
When adapting Schein’s (2001) theories about the transformation of the organizational
culture to the transformation of the maritime safety culture, the change from the oldestablished maritime safety culture to the new safety culture requires that the current
cognitive framework is thrown overboard and a new cognitive framework is adopted
onboard instead. The ISM Code could be considered as the new cognitive framework.
3.6 IMO’s safety philosophy
Due to the accumulation of disastrous maritime accidents in the 1980s and in the early
1990s, the maritime community took the attempt to create an accomplished safety
culture for the maritime industry seriously. The IMO adopted the concept of safety
culture profoundly at that time (Anderson, 2003; Mitroussi, 2003 and 2004; Karvonen
et al. 2006). The IMO’s statement about the safety culture is composed as follows
(IMO, 2008)
An organization with a “safety culture” is one that gives appropriate
priority to safety and realises that safety has to be managed like other
areas of the business.
The IMO provides the ways in which the safety-oriented culture can be achieved in the
shipping business. The IMO’s current means for achieving the safety culture are listed
below:
• recognising that accidents are preventable through following correct
procedures and established best practices;
• constantly thinking about safety;
• and seeking continuous improvement.
In practice, these prerequisites are established in the clauses of the ISM Code.
When establishing the ISM Code in the IMO in the early1990s there was a prevailing
assurance that poor maritime safety culture could be improved (Anderson, 2003;
Mitroussi, 2003 and 2004; Karvonen et al. 2006).
According to Anderson, the IMO’s primary aim with the ISM Code is that there is a
chance to create new safety-oriented culture in the maritime community in the course of
time. There is great confidence in the safety-oriented culture that it can reduce
accidents, damages, personal injuries and lost-time incidents in shipping operations. The
safety culture provided by the ISM Code advances safer ships and cleaner seas.
Anderson sees also that due to proper safety management the business of the shipping
company will be more competent (Anderson, 2003).
28 Transforming Maritime Safety Culture
The organizational psychology theory examines the safety culture on the basis of the
establishment of the ISM Code. The IMO expressed its firm confidence in the success
of the ISM Code as follows:
“The application of the ISM Code should support and encourage the development
of a safety culture in shipping. Success factors for the development of a safety
culture are, inter alia, commitment, values and beliefs (IMO, 1995).”
Hänninen showed that the prevailing culture, including the adopted values and
preconceived beliefs, was the major barrier towards safety behaviour of the maritime
personnel (Hänninen, 2007). Therefore, the major challenge when implementing the
ISM Code is to elicit the transformation in the values and beliefs of the maritime
personnel.
3.7 TQM provides the basis for the ISM Code
Safety can be seen as the key factor in expressing organizational quality in shipping. In
other words, “safety and quality could be seen as synonymous in shipping”
(Kristiansen, 2005; Mitroussi, 2004). Hence it looks natural and obvious to adopt a
similar approach to quality management as the basis of the development of the safety
management standard in the early 1990’s.
The concept of Total Quality Management was established in the 1980s. Total Quality
Management is based on the perception of organizational psychology. Deming has been
seen as a prominent co-founder of the school of the Total Quality Management. Deming
has stated that the corporate culture supports a company’s commitment to produce
quality and high productivity for the organization (Deming, 1986).
The other co-founder of the Total Quality Management was Joseph M. Juran (1904 –
2008). Juran analyzed the well-performing American companies in the 1980s and
1990s. Juran saw that good performance by these companies was due to an ideal
organizational culture. Juran emphasized that the success factors of an ideal
organizational culture are a designed process for making improvements, which is
applied to all business processes as well as to manufacturing processes, empowered
working force to participate in making improvements, and established measures to
evaluate, review and reward the progress against the improvement goals. (Juran and
Godfrey, 1998.)
The foundation of the ISM Code is largely based on the philosophy of Total Quality
Management (TQM). In regard to the safety management, the key fundamentals
adopted from the Total Quality Management include:
• Management commitment
• Personnel empowerment
Jouni Lappalainen 29
• Continuous improvement
According to Deming (1986):
“top management is responsible for 94% of the problems because they
control the assignment of resources, establish and implement the methods
of work, develop the politics, and so forth.”
The role of the top management is essential when improving the quality or safety of a
company. Firstly, the management should set a company policy which describes where
and how the management will lead the company in terms of quality, safety and
environmental issues. Secondly, the management should provide adequate resources
and tools for the personnel in order to ensure that the company policy could become
materialized. The management should define the roles and responsibilities of the
personnel related to quality and safety unambiguously. Finally, the management is
responsible for setting realistic and achievable targets for demanded quality and safety
performance. The performance should be reviewed on a regular basis and the quality
and safety targets should be updated on the grounds of actual performance (Deming,
1986; SFS, 2001).
The involvement of the personnel is a prerequisite for a successful quality management
system. Employees should have a feel of ownership in regard to the management
system. The feel of ownership is established by providing an opportunity to participate
in establishing, implementing and operating the management system on all
organizational levels.
According to the literature on common quality management, TQM is based on the
concept of continuous improvement. The concept of continuous improvement requires
that a company improves its quality of products, services, capabilities and competence
in a continuous basis on all organizational levels. A common tool for continuous
improvement is called Deming’s cycle of continues improvement or as the PDCA cycle
(plan – do – check – act). See the picture below (Deming, 1998; Kristiansen, 2005;
Roughton and Mercurio, 2002)
30 Transforming Maritime Safety Culture
Figure 3.2: Cycle of continuos improvement (Kristiansen, 2005)
The PDCA cycle is a useful tool for improving, for example, the manufacturing
processes or business processes. In the first phase of the PDCA cycle, one should make
an action plan of the changes intended for the process. In second phase, one should
carry out or test the changes intended for the process. In the checking phase, one should
measure or analyze the results of the changes. In the action phase, the intended changes
are implemented into actual operations. (Kristiansen, 2005; Roughton and Mercurio,
2002.)
3.8 TQM-based management standards
The most commonly utilized standard for quality management based on the TQM
philosophy is the ISO 9001 quality standard provided by International Standardization
Organization (ISO). The ISO 9001 quality standard has evolved considerably. The first
version of the ISO 9001 quality standard was published by the ISO in 1987. The second
version was published in 1994 and the current version of the ISO 9001 was published in
2000. Updating of the current version is under way and the new version may be
published in 2009 (SFS, 1995; SFS, 2001).
Each new version published by the ISO is based on the concerns and criticisms
expressed by the broad users of the quality standard. The first version focused on the
manufacturing of new products. The second version (1994) focused on quality
assurance by preventive actions towards identified risks. The present version (2000)
concentrates on process improvement (process approach) (SFS 2001). The forthcoming
version emphasizes more management commitment and customer orientation.
The evolution of the quality standard has affected the utilization of the standard. The
application of the ISO 9001 quality standard started mostly in manufacturing companies
in the late 1980s. Later on, the application of the ISO 9001 has been expanded into
service business and public administration mainly in the middle of the 1990s. Also
some shipping companies have adopted the ISO 9001 quality standard as a basis for the
companies’ quality management system.
Plan
Check
Act
Do
Jouni Lappalainen 31
The first international version of the environmental management standard was
published in 1996 (ISO 14001 Environmental Management Standard). The first version
stressed the importance of the statutory and regulatory requirements and strict
documentation (SFS, 1997). As the present ISO 9001 quality standard, the current
version of the ISO 14001 (2004) environmental standard has adopted the concept of
process approach (SFS, 2004).
OHSAS 18001 provides a specification for occupational health and safety management
in any organization. The OHSAS 18001 is widely used internationally. The origin of the
OHSAS 18001 lays in the British standard on occupational health and safety (BS8800).
The OHSAS 18001 went through a thorough revision in 2007. The OHSAS 18001 was
harmonized with the ISO 9001 and ISO 14001 standards. The harmonization helps
organizations to integrate the quality, environmental and safety management systems
easier into to one common management system. The new version of the OHSAS 18001
provides a more result-oriented approach to the health and safety management. The new
version of the OHSAS considers accurately accident prevention, risk reduction and the
well-being of employees.
3.9 Substances of the ISM Code
3.9.1 General objectives of the ISM Code
The ISM Code itself has been written in broad terms; and the descriptions of the rules of
the ISM Code are very general. Thus the Code is suitable for any kind of shipping
companies and any type of fleet or ships. Section 1.2.1 describes the general objectives
of the Code, in other words the ultimate purpose of the Code (IMO, 1993).

The ISM Code section 1.2.1:
The Objectives of the Code are to ensure safety at sea, prevention of human injury
or loss of life, and avoidance of damage to the environment, in particular to the
marine environment and property
3.9.2 Responsibility of the Company
The ISM Code requires the company to set in place a safety management system
(SMS). The objectives of the safety management system of the company are described
in section 1.2.2 of the Code.
The ISM Code section 1.2.2
1. The company should provide for safe practices in ship operation and a safe
working environment;
2. Establish safeguard against all indentified risks; and
32 Transforming Maritime Safety Culture
3. Continuously improve safety management UK dissertation writing Helpance skills of personnel ashore and on
board ships, including preparing for emergencies related both to safety and
environmental protection
These targets reflect the philosophy of the Total Quality Management correspondingly.
Herein, the company is comparable with the concept of management commitment. Also
the requirement for continuous improvement is given literally. In addition, the company
has to be prepared for possible hazardous situations beforehand. This principle of
preparedness is common in quality management as well.
3.9.3 Legislative conformity
The ISM Code requires a Company to document its safety management system in
accordance with legislative requirements and with standards and guidelines set by e.g.
classification societies. The SOLAS requirements are the most important requirements
to be considered. According to the ISM Code, the safety management system should be
able to ensure (IMO, 1993):
The ISM Code section 1.2.3
1. Compliance with mandatory rules and regulations; and
2. that applicable Codes, guidelines, and standards recommended by the
Organization, Administrations, classification societies and maritime industry
organizations are taken into account
Both the ISO 9001 quality standard and ISO 14001 environmental standard require that
a company has to obey the law in its operations. This requirement is included in the
ISM Code in a very similar manner.
3.9.4 Functional requirements of the safety management system
According to the ISM Code, the safety management system should include the
following functional requirements (IMO, 1993):
The ISM Code section 1.4
1. a safety and environmental protection policy
2. instructions and procedures to ensure safe operation on ships and protection of
the environment in compliance with relevant international and flag state
legislation
3. defined levels of authority and lines of communication between, and amongst,
shore and shipboard personnel
4. procedures for reporting accidents and non-conformities with the provisions of
this Code
5. procedures to prepare for and respond to emergency situations and
6. procedures for internal audits and reviews
Jouni Lappalainen 33
These six paragraphs are quite well corresponding with the requirements of the ISO
9001 quality standard and the ISO 14001 environmental standard. The company is
responsible for setting the safety and the environmental protection policy in a similar
manner than the quality and environmental standards require the quality policy and
environmental policy to be, described by the top management.
The company is responsible for defining the operative processes onboard and providing
necessary guidance and instructions for the personnel which are involved in these
processes. Safety and environmental issues should be recognized and included in the
safety management manuals.
3.10 Comparing the ISM Code with the quality and safety standards
When comparing the ISO 9001 quality standard with the ISO 14001 environmental
management standard and the OHSAS 18001 occupational health and safety standard
point by point, they look literally very similar. The clauses of the ISM Code make a
remarkable difference. The ISM Code is seemingly written in much broader terms than
the ISO 9001, ISO 14001 and OHSAS 18001 standards. Also, the actual text is much
shorter and not so detailed than the ISO 9001, ISO 14001 or OHSAS 18001.
Nevertheless, the ISM Code and the ISO 9001 quality standards and the ISO 14001
standards share common management principles and features which are described in the
table below (IMO, 1993; SFS, 2001; SFS, 2004 and BSI, 2007):
Table 3.1: Comparison of the ISM Code, ISO9001 and ISO14001
ISM ISO 9001 ISO 14001
Purpose To provide safety
operation of ships and
prevent the pollution of
the environment
To ensure the high quality of
production, services and
business processes
To prevent the pollution of
the environment;
consideration of
environmental aspects
Target group ship operating companies
of all types and sizes
organizations of all types
and sizes
organizations of all types
and sizes
Fundamentals management
commitment, continuous
improvement, personnel
empowerment,
management commitment,
continuous improvement,
personnel empowerment,
+ strong customer
orientation
management commitment,
continuous improvement,
personnel empowerment,
Driver mandatory voluntary voluntary
Primary object Compliance with the
Code
Fulfil customer requirements Compliance with the
standard
Common
management
principles
Documentation of operation and processes, Document control, Incident reporting,
Audits, Management Reviews, Roles and responsibilities, Corrective and
preventive action , Training
Performance
Measurement
N/A Statistical technique N/A
34 Transforming Maritime Safety Culture
The ISO 14001 and OHSAS 18001 standards are similarly structured and therefore the
OHSAS 18001 is not included in the table above.
Pun et al. (2002) compared the ISM Code with the quality, safety and environmental
management standards. They perceived that the ISO 9001, ISO 14001, OHSAS 18001
and the ISM Code work in a similar way. These standards differ in terms of their
focuses to some extend. The ISM Code focuses on operations and practices of safety
management in the shipping business. The ISO 9001 focuses on compliance with the
customer requirements. The ISO 14001, on the other hand, focuses on compliance with
the environmental legislation and consideration of environmental aspects. And the
OHSAS 18001 focuses on compliance with the occupational health and safety
regulation and company performance in the occupational health and safety.
The quality, environmental and safety standards share common management practises
and requirements as well. These practises include, for example, regular management
meetings to review the progress and performance of the system and defining the
objectives and targets of the system, systematic document control, systematic recording
of non-conformities and procedures for periodic audits (IMO, 1993; SFS, 2001; SFS,
2004 and BSI, 2007).
Although the primary purpose and objects of the ISM Code and the ISO standards are
different, there are so many common features that there are good possibilities to merge
the safety management systems, quality management systems and environmental
management systems into one integrated management system in a shipping company.
For example, the Bureau Veritas ship classification society and the International
Shipping Management Association (ISMA) perceive that it is beneficial for the shipping
company to consolidate the quality, environmental and safety management systems
(Pun et al. 2002; Bureau Veritas, 1995).
Jouni Lappalainen 35
4 FORMER ANALYSES OF THE ISM CODE
4.1 Implementation of the safety management system
A lot of guidance and handbooks on how to use the ISM code have been published
during the years of application of the Code. These guides provide practical advice for
shipping companies when they are implementing and employing a safety management
system for operations ashore and operations onboard (IMO, 2008b).
Pun et al. have discovered the problems and difficulties which have appeared when the
shipping companies were implementing their safety management systems according to
the ISM Code (Pun et al. 2002). They listed the major obstacles which occurred in the
implementation process of the SMS. According to Pun et al. the most difficult problems
are:
• Resistance to change
• Lack of human resources
• Insufficient knowledge of procedures
• Lack of inter-departmental communication
• Low level of education
• Frequent staff turnover
• Time pressure to obtain registration of the SMS
From the cultural point of view the resistance to change seems to be an obvious obstacle
to the implementation of the ISM Code. According to Schein (2001), the transformation
of the organizational culture collides frequently with the resistance to change. Because
the maritime personnel were heavily bounded to the current organizational culture, they
were resistant to absorb the new procedures and instructions. Also Pun et al. mentioned
that there is a mismatch between the prevailing organizational culture and the
requirements of the ISM Code (Pun et al. 2002). Good communication between the
personnel and management, between persons onboard and onshore and between the
different departments of the company has been recognized as the key success factor in
terms of a safety-oriented culture (Anderson, 2003; Kristiansen, 2006; Lanne, 2007).
The commitment of the top management is referred to as one of the main demands for a
successful implementation of the cultural transformation (Schein, 2001; Deming, 1986
and Wiegmann et al. 2002). A lack of human resources could be regarded as poor
commitment on the top management’s part. According to the ISM Code, the
responsibility of the Company (top management) is to provide adequate resources and
support for the organization especially for the Designated Person to carry out their
functions (IMO, 2008a).
Pun et al. (2002) found cases were the personnel onboard and onshore were subject to
face the new requirements of the ISM code without proper training or they were
pressured to complete the safety management system in a short period of time. These
36 Transforming Maritime Safety Culture
problems could be understood as indications of the poor management commitment as
well.
The low level of education of the ship crew and frequent turnover of the ship crew are
considered as big problems in international shipping (Karvonen et al. 2008). In order to
economize their personnel costs, the shipping companies recruit members of the crew
from the developing countries (Pun et al. 2002). The crew might be unqualified due to
poorer educational possibilities in their home nations and the crew members and the
officers might have communication problems because they have no common language.
Heterogeneous and continually changing personnel makes it difficult to cultivate the
company’s safety values to the crew. The diverse personnel and staff turnover make it
expensive and challenging to properly familiarize the new personnel with their duties as
the ISM Code requires.
Also Anderson (2003) listed the problems and difficulties with the implementation of
the safety management system. Anderson identified certain common factors which
describe the unsatisfactorily implemented safety management systems. Anderson found
out that there was too much paperwork due to voluminous documentation; a typical
situation when a company has bought an off-the-shelf safety management system. Many
irrelevant procedures and irrelevant checklists are involved in these systems. In these
cases, safety management was usually realized through paperwork exercises and the
personnel could not develop any feeling of involvement in the system. The company did
not provide support for the personnel. The vessels have suffered from a lack of
resources and insufficient training for the new requirements of the ISM Code. So the
motivation for safety management of the personnel is low. Also, Anderson paid
attention to the turnover of the personnel. Anderson emphasized that establishing a
safety culture is not easy when the turnover of the crew is high. The new employee has
been familiarized too poorly too often (Anderson, 2003).
On the other hand, Anderson identified the success factors of a very well functioning
safety management system which entail for example:
• Leadership and commitment from the top management i.e. from the ship owner
• The personnel have a sense of ownership of the safety management system and
are empowered to safety
• Good communication between ships and office
• Paperwork has been reduced to manageable levels
Hahne et al. analyzed the prevailing safety culture in the late 1990s. In a study by Hahne
et al. the safety attitudes of the shipping companies and maritime personnel towards the
ISM Code were examined. The results of the study were published in 2000 (Hahne et al.
2000). The purpose of the study was to find out the problematic areas encountered with
the implementation of the ISM Code. Researchers came to the conclusion that the main
obstacle to the successful implementation of the ISM Code was the widespread
resistance by the seafarers to the obligatory establishment of the safety culture.
According to Hahne et al., the maritime industry was not ready for the ISM Code at that
time (Hahne et al. 2000).
Jouni Lappalainen 37
In order to uncover the benefits of the ISM Code to the Malaysian shipping companies,
Othman carried out an Assessment of the effectiveness of the safety management system
in the Malaysian shipping companies in 2003. Othman compared the compliance of the
shipping companies’ safety management systems with particular elements of the ISM
Code. He detected that almost 80 per cent of the companies had effectively
implemented the requirements of the ISM Code into their safety management systems
(Othman, 2003). Othman observed that the major gap found between the implemented
safety management system and the requirements of the ISM Code was related to system
documentation. Over 40 % of the cases indicated that the documentation process was
non-compliant with the ISM Code.
The Paris and the Tokyo MoU have conducted three Concentrated Inspections
Campaigns (CIC) concerning the compliance of the implemented safety management
systems with the ISM Code after the year of 1998 (Paris MoU, 2008). The previous
campaigns in 1998 and 2002 focused on verifying that the safety management systems
were created on board in compliance with the ISM Code. The last campaign in the
autumn of 2007 focused on verifying that the safety management system is working
effectively in practise and, moreover, the duty of the Port State Officers was to confirm
that the safety management system was not mainly a paper exercise. The inspection
officers paid special attention to the fact that the master was fully conversant with the
SMS and that the crew was able to communicate effectively when executing their duties
related to the SMS.
The results of the latest CIC of the Paris MoU were published in January 2008. The
Paris MoU reported that 20 per cent of the inspections indicated non-conformities
onboard of the inspected vessels. The study entailed inspections of 5 427 vessels (Paris
MoU 2008). There were 1 031 ships where ISM deficiencies were found. 176 ships
were detained due to major non-conformities with the ISM Code. The Paris MoU
detected that the safety management systems were implemented poorly in the detained
ships. The safety management systems were treated as dead letters although the
documentation consisted of a mountain of paper. The Paris MoU reported that the most
common non-conformities dealt with the following issues:
• effective maintenance of the ship and equipment
• emergency preparedness
• reports of nonconformities and accident occurrences
All three issues are considered as key areas in regard to the safety of the ship and its
crew. Notwithstanding that the Paris MoU came to the conclusion that the safety
management systems are gradually starting to work on ships. The Paris MoU realized
that most of the shipping companies and the crews of their vessels understand the safety
requirements and implement them. (Paris MoU, 2008a; Paris MoU, press release
January 2008; Paris MoU, 2008b)
The Tokyo MoU published the results of the CIC in the beginning of 2009 as well
(Tokyo MoU press release February 2008). The Tokyo MoU sets two major targets to
the inspection campaign: firstly, it is studied whether the safety management system is
38 Transforming Maritime Safety Culture
implemented effectively and secondly, whether the safety management system is
actively maintained. The results of the Tokyo MoU were a little more optimistic than
the results of the Paris MoU. The results indicated that for most ships and ISM
operators the safety management system was functioning and properly understood
onboard.
British Maritime and Coastguard Agency (MCA) carried out an assessment of the
British fleet in the winter of 2007 – 2008. The primary goal was to study the influence
of the ISM Code on the development of a safety culture in the commercial shipping
industry (ReportISM, May 2008). The MCA found out that the there are great barriers
to the development of the safety culture in maritime industry. One of the most
significant factors is the transient nature of the work force hired onboard. Especially the
turnover of the crew hired from a labour hiring company is high, which might cause
difficulties when establishing the safety culture. The second factor recognised by the
MCA was the distance of the asset owner from their ships. The MCA found out that the
germ of a safety culture was growing where there was strong leadership. (ReportISM,
May 2008.)
4.2 Maintenance of the safety management system
The safety management systems compliant with the ISM Code became compulsory for
the most shipping companies in 1998. The rest of the shipping companies should have
registered their safety management systems before the first of July 2002. The ISM Code
requires that the management system itself should be continuously improved (IMO,
2008a).
According to Gray (2005), some shipping companies have not kept their safety
management systems updated since the registration in 1998 or 2002. Typically, these
companies have purchased an off-the-shelf set of safety management manuals by a
consultant (Anderson, 2003). According to Anderson, the off-the-shelf documentation
could cause problems in maintaining the safety management system, due to a massive
amount of documents and unfitting procedures for the applying company. The IMO’s
Group of Expert, which studied the impacts of the implementation of the ISM, draw a
conclusion that in order to update and maintain the safety management system more
accurately, the shipping companies should involve more people, especially seafarers, in
the compilation of the safety management system (IMO, 2005).
4.3 Improvement of maritime safety
The primary purpose of the ISM Code is to establish a maritime safety culture and
continuously improve the safety performance of shipping companies and vessels (IMO,
2005). Therefore, the question is in what way the ISM Code has improved the maritime
safety culture and how the improved maritime safety culture has enhanced the safety
performance of the shipping companies.
Jouni Lappalainen 39
Some international studies have been carried out to explore what the significance of the
ISM code is to the safety culture in the maritime industry (IMO 2008b).
Doctor Phil Anderson investigated the impacts of the ISM Code in a wide international
survey in 2002. The results of the survey were published in his doctoral thesis. The
name of the published book was “Cracking the Code – The relevance of the ISM and its
impacts on shipping practises” (Anderson, 2003). Anderson found out that it is quite
difficult to get objective evidence of the impacts of the ISM Code on maritime safety.
According to Anderson, there is no relevant “hard data” on which the impact analysis
could be based.
The second study was organized by the IMO. An Independent Experts Group has been
established by the IMO Secretariat to study the impact of the ISM Code (IMO, 2005).
The Group of Expert (IMO, 2005) attempted to get objective evidence (hard facts) of
the ISM impacts on maritime safety. However, the Group found that difficult and so the
Group could not draw comprehensive conclusions when determining the impact of the
code. The Group tried to collect data based on Port State Controls and from IACS
(International Association of Classification Societies) and P&I Clubs (Protection and
indemnity, mutual insurance associations).
Both Anderson and the Group found it impossible to claim quantitative benefits gained
by implementing the safety management system. Appropriate statistics and measures of
safety performance of the shipping companies are unfortunately not available
(Anderson, 2003; IMO, 2005).
Stuart Withington has considered the means of measuring the progress of the
improvement of the safety management system (Withington, 2006). According to
Withington, accurate reporting of incidents and defects could provide the fundamental
basis for evaluating the effectiveness of the ISM Code. Unfortunately, he has
recognized that in practice severe insufficiencies in the reporting of the shipping
companies can be found, regardless of the requirements of the ISM Code that
necessitate establishing a proper reporting system for incidents and defects. The level of
the reporting varies significantly between companies, flag States and port States. He has
noticed that neglected reporting is due to the fear of blame and criticism (Withington,
2006). Withington is seeking possibilities to a global measurement of the safety
progress by utilising data provided by the ISM compliant safety management system.
With the intention of evaluating the tangible impacts of the ISM Code on maritime
safety, the IMO Group of Experts suggested that further studies should be carried out in
the future (IMO, 2005). The studies should take into consideration the causal links
between the implementation of the ISM Code and a flag State safety record. Likewise,
the relationship between PSC and ISM compliance should be thoroughly investigated in
order to link improvements in detention and accident rates directly to the
implementation of the ISM Code. According to the IMO Group of Experts, the links
between the ISM Code and the Port State Control regime were complex and further
work was required to fully understand them.
40 Transforming Maritime Safety Culture
MCA’s study was one of the latest Assessments of the impact and effectiveness of the
ISM Code. The results of the research project were published during the meeting of the
IMO Maritime Safety Committee in May 2008. The objectives of the study were as
follows:
• How effectively the ISM Code has improved safety and safety culture while the
ISM Code has reigned?
• To compare the effects of the ISM implementation between the UK Fleet and
the other “white-listed” member states of the Paris MoU.
• To find out what other safety or quality approaches, such as the ISO 9001 or
TMSA (Tanker Management and Self Assessment), are utilised in maritime
industry in order to identify what improvements should be integrated into the
ISM Code in future revisions.
• British Maritime and Coastguard Agency attempted to understand how the
implementation of the ISM Code has enhanced maritime safety and the
protection of the marine environment.
The basic result of the MCA research was that the shipping industry is a safer and a
more environmentally friendly industry than it was 12 years ago when the ISM Code
became mandatory. The study indicated that there is a common consensus about the
positive contribution of the ISM Code to the maritime safety although the direct effects
and influences of the ISM Code could not be isolated very well from the other factors
such as those established by STCW and MARPOL etc. Also these factors have made a
contribution and brought improvements to maritime safety at the same time as the ISM
Code has been prevailing (ReportISM, May 2008). The MCA attempted to provide an
analysis based on the Port Sate Control statistics concerning ISM-related nonconformities and statistics of Port State Control detentions due to incompliance with the
requirements of the ISM Code. The MCA found out that no meaningful results could be
provided due to a lack of data from pre-ISM phase before 1998. Furthermore, the MCA
discovered that only few detentions of the UK flag ships have occurred during the
researched time period.
The MCA concluded that a self-assessment toolkit for assessing the safety culture on
non-tanker vessels should be developed – similar to TMSA.
4.4 Developing safety performance indicators
When improving organizational quality or safety performance, one should be aware of
the real performance of the present management system (Juran and Godfrey, 1998).
This means that an organization should measure the performance in an accurate manner.
The ISM code does not require any prescribed techniques for performance measurement
as the ISO 9001 quality standard does. The ISO 9001 quality standard requires the use
of statistical techniques for the measurement of the quality performance.
Although the ISM Code literally demands the implementation of the process of
continuous improvement and a regular review of the performance of the improvement,
Jouni Lappalainen 41
there is lack of numerical measures to confirm that the performance of safety
management has truly improved. The real progress of the continuous improvement may
fail and the management may not realize the business benefits of the safety
management.
As early as in 2001, Max Mejia from World Maritime University proposed generic
performance criteria for the Assessment of the ISM Code. Mejia carried out a literature
review concerning the development of the performance criteria for evaluating the
effectiveness of the ISM code (Mejia, 2001). Moreover, Mejia studied the different
theories considering the performance measurement of various safety approaches such as
OHSA.
Mejia could not find any studies which could indicate that the safety management
system has direct influence on the safety performance. Mejia suggested that qualitative
systems such as the safety management system should be qualitatively evaluated. Mejia
started his analysis by specifying the concept of “effectiveness”. Mejia described that
the effectiveness means:
“the issue of whether desired results are actually achieved”.
Hs studied the documented history of the establishment phase of the ISM Code. He
attempted to describe what the desired results set by the co-founders of the ISM Code in
the IMO were (Mejia, 2001). Mejia has adopted the concepts of output and outcome
into his performance criteria approach from a policy analysis discipline. The outputs are
referred to as policies, such as the ISM Code. The outcomes are referred to as goals,
such as the positive effects of maritime safety. According to the IMO, the desired
results of the ISM Code were as follows (IMO, 1995):
• provide safe practices in ship operation and safe working environment
• to establish safeguard against all identified risks
• continually improve the safety management skills of the personnel ashore and
aboard, including preparations for emergencies related both to safety and
environmental protection
• development of a safety culture
Mejia’s next task was to identify performance criteria within the concepts of output and
outcome. Output could be considered as a set of policies which attempt to ensure that
the safety management systems of the shipping companies and vessels are compliant
with the requirements of the ISM Code. Mejia suggested the performance criteria within
the output category are as follows:
• Port state control detention due to non-conformities and deficiencies in regard to
the requirements of the ISM Code
• ISM-related spot inspections carried out by the Flag State
• Re-inspections due to major non-conformities observed in connection with
external audits performed by the administration
• ISM deficiencies and non-compliance reported by the ships’ personnel
42 Transforming Maritime Safety Culture
• Non-conformities detected by the auditors during annual and interim audits
Mejia was seeking a statistical indication that the quantity of the detention should
decrease in the long run due to improvements in the safety performance of the ships.
Various studies have attempted to analyse the data from the Port State Control statistics.
Beforehand, the Port State Control statistics have been recognized as an important
source of information with the intention to study the impacts of the ISM Code.
Unfortunately, the Port State Control did not present any meaningful results. For
instance, any downward trends could not be drawn of the ISM-related detentions.
(Anderson, 2003; IMO, 2005; MCA, 2008).
An analysis of the Port State Control statistics shows that the detention rates have
declined in the earlier years of the current decade. Unfortunately, the trend of the
detention rate has been reversed and the detention rate has risen in the past two years.
(Paris MoU, 2008b). Likewise, the quantity of the ISM-related deficiencies has
increased slightly since 2005. The Paris MoU (2008b) reported the ISM-related
deficiencies as follows:
2005 2006 2007
ISM-related deficiencies 2940 3087 4657
% of all deficiencies 4,7% 4,7% 6,2%
Further analysis is needed in order to evaluate the feasibility of the Port State Control
statistics as an indicator of safety performance.
In the literature, reporting of non-compliance and deficiencies by the ships’ personnel
has been seen as a significant indicator of a properly functioning safety culture
(Anderson, 2003; IMO, 2005; Mejia 2001). According to Mejia, willingness to report is
an indication of whether the ISM Code is functioning as it should. The main focus of
the study by Anderson was to investigate how the incidents, near-misses and other
hazardous occurrences were reported. In addition, Anderson emphasized the further
analysis of and willingness to learn from the incidents, near-misses and other hazardous
occurrences in his study. According to Anderson, a properly working reporting process
indicates the cycle of continuous improvement in an outstanding manner.
Notwithstanding, the Paris MoU (2008a) reported that one of the most common ISMrelated deficiencies was the lack of reporting nonconformities, accidents and hazardous
occurrences. Also Anderson (2003) discovered that the reporting of incidents was quite
insufficient within the seafarers. Especially the minor incidents were not regularly
reported. Particularly, Anderson was surprised that most of the seafarers were more or
less reluctant to report the incidents. In this case, the no-blame culture did not prevail.
In order to utilise the statistics of incident reporting as an indicator of the safety culture,
these barriers should be overcome first.
Mejia suggested that the time series of the non-conformities found in connection with
the audits and re-inspections due to ISM-related non-conformities should be utilized as
Jouni Lappalainen 43
safety performance indicators. The statistics of the non-conformities and the reinspections should be provided by the administrations.
Mejia (2001) described that the performance criteria under the outcome/goal category
should indicate whether the safety management system is producing the intended
results, for example, a reduced death toll, less injuries and damages. To the outcome
category Mejia suggested the following performance criteria:
• Accident rate and injury frequency
• Mortality rate
• Lost time injuries
• Vessel off-hire/delay
• Crew repatriated or sent ashore for retraining
• Insurance premiums and claims level
• Active commitment of management to safety
• Safety culture
Accident rate and injury frequency, mortality rate and lost time injuries are notable
because these performance indicators are comparable with the other industries. These
indicators are commonly utilised in safety science but not utilized in any Assessment of
the ISM Code (Mejia, 2001).
Vessel off-hire or delay in voyages due to material damages could cause the loss of
income and even the loss of long-standing customers. Vessel off-hire time could be
caused by the Port State Control detention, on-going accident investigation, reparations
of the vessel etc. The recurrence of the off-hire and delay could be an indicator of poor
safety performance level of the vessel or the shipping company. (Mejia, 2001).
Mejia does not provide any direct method to evaluate the safety culture or management
commitment. The performance criteria presented above describes safety performance
merely consequentially. How do these criteria authenticate the likelihood of the vessel
to be a subject of an accident?
Also Deming saw that the absolute quality was challenging to measure (Deming, 1986).
Deming supposed that a more sensible way to measure the progress of the quality is to
measure the performance of the management system. In that view, the presented
performance criteria should be carefully dissected. Particularly the performance criteria
which are targeted to measure the safety culture need further development.
4.5 Evolution of the ISM Code
When comparing the ISM Code with the ISO 9001 and ISO 14001 standards the ISM
Code is written in a much more straightforward way. Also, the ISM Code is considered
to be very flexible. The ISM Code includes 16 short and generic sections. The
flexibility of the ISM Code enables that it is applicable to all kinds of shipping
companies and on ships of all kind (IMO, 1993, Anderson, 2003).
44 Transforming Maritime Safety Culture
Unfortunately, the generic nature of the Code could bring about difficulties when
assessing the compliance of the safety management system objectively. The auditors of
the administrations or classification societies could interpret the Code and the IMO
guideline diversely and even an individual auditor could have his/her own benchmark of
what is acceptable compliance (Anderson, 2003). Also the MCA found it problematic
that there is a lack of standardization in the interpretation of the requirements of the
ISM Code in practise (ReportISM, 2008). The MCA found that depending on the
external auditor the interpretations about the requirements of the ISM Code differ.
These differentiations could cause problems to the shipping companies when preparing
for an audit or a port state control. The respondents of the MCA study were asking for
clearer guidance and uniform instructions for the practice of the ISM Code.
The ISO 9001 and the ISO 14001 have been under development through their lifetime.
The fourth version of the ISO 9001 quality standard is going to be published at the end
of this year. Also, the current version of the ISO 14001 environmental management
standard is comparatively new. The contents of the ISO 9001 and ISO 14001 standards
have advanced substantially.
No new version of the ISM Code has been published after the first version in 1993. The
need for renewing the ISM Code has been recognized. The Group of Experts which
studied the impacts of the implementation of the ISM code came up with some
suggestions for updating the Code (IMO, 2005). The Group recommended that further
studies should be conducted on whether textual changes in the requirements of the Code
could make compliance easier and lead to an improved safety culture.
Jouni Lappalainen 45
5 SUMMARY AND CONCLUSIONS
5.1 Arguments for the Project
The maritime traffic is rapidly growing in the Baltic Sea which leads to a growing risk
of maritime accidents. Particularly in the Gulf of Finland, the high volume of traffic
causes a high risk of maritime accidents. In addition, the hard navigation conditions of
the Baltic Sea present extra challenge for the maritime traffic.
Economic trends in the maritime industry challenge the maritime safety as well. The
various ways of internationalizing the ownership of the shipping companies keep on
developing (Karvonen et al. 2008). The vessels of a shipping company fly various flags
and the personnel are more and more multinational. There is a strong possibility that the
members of the crew are coming from such nations where the educational facilities are
poor and thus the risk of having no common language for communication between the
crew members increases (Pun et al. 2002). The Finnish shipping companies suffer from
a lack of labour force. The shipping companies are captive to hire foreign personnel,
and they consider it also as a safety problem (Karvonen et al. 2008).
The growing risks give us good reasons for implementing the research project
concerning maritime safety and the effectiveness of the safety measures, such as the
safety management systems. In order to eliminate or reduce maritime safety risks, the
safety management systems should be further developed. The METKU Project has been
launched to examine the improvements which can be done to the safety management
systems.
5.2 Establishment of the ISM Code
Human errors are considered as the most important reason for maritime accidents.
According to Hänninen (2007), the fundamental reason for the accident of the ro-ro ship
Estonia was the prevailing bad safety culture. Hänninen saw that the prevailing safety
culture hindered the maritime industry from preventing the occurrence of erroneous
behaviour. Hänninen urged that the maritime safety culture should be transformed in a
revolutionary way in order to decrease human errors.
Even before the accident of Estonia, other fatal accidents have awakened the
international maritime community to consider the reasons for such accidents. Thorough
accident investigations showed that the reasons for the occurrence of accidents were
more often human than technological. The results of the investigations showed that
problems were arisen due to a lack of a management system in regard to safety issues,
poor specifications of responsibilities onboard and ashore, poor communication and
unwillingness to report and to learn about incidents and near-misses (Anderson, 2003).
All these problems could be seen as elements of the organizational culture (Anderson,
2003; Hänninen, 2007).
46 Transforming Maritime Safety Culture
The international safety management code (the ISM Code) has been established to cut
down the occurrence of human errors by creating a safety-oriented organizational
culture for the maritime industry. The ISM Code came into operation in worldwide
shipping in 1998. The ISM Code provides the requirements of the safety management
system needed in a shipping company. The ISM Code requires that a company should
provide safe practices in ship operation and a safe working environment and establish
safeguards against all identified risk. The fundamental idea of the ISM Code is that
companies should continuously improve safety. The continuous improvement could be
obtained by training and regularly practising the personnel onboard and ashore. The
commitment of the top management is essential for implementing a safety-oriented
culture in a company. (Anderson, 2003; IMO, 2008a).
5.3 How to evaluate the maritime safety culture?
The purpose of this study is to recognize whether the safety culture has been initiated
due to the ISM Code and evaluate the impacts of the ISM Code on maritime safety.
According to Schein (2001), transformation of the organizational culture is very
complicated. Schein considered that changing the organizational culture presumes the
adaptation of a new cognitive framework. Undoubtedly, the shipping companies which
have successfully implemented their safety management systems have adopted the new
cognitive framework provided by the ISM Code. The role of the top management is
essential when adapting the new cognitive framework. The top management is required
to act as a role model in terms of admirable safety attitudes. This way the top
management is able to manifest its commitment to safety. The top management
encourages and supports the personnel to eagerly report incidents and near-misses and
the top management gives positive feedback on safety initiatives made by the personnel.
The personnel on all levels of the organization are willing to learn from incidents, nearmisses and accidents (Schein, 2003; Anderson, 2003; IMO, 2005).
Schein (2001) proposed that one solution for the assessment of the organizational
culture is to analyze the contradictions or inconsistencies between the manifested values
and policies and actual operations.
Mejia (2001) proposed that the Assessment of the effectiveness of the ISM Code should
be based on whether the desired objectives of the ISM Code have been achieved.
According to Anderson (2003), the main objective of the ISM Code is to establish a
safety culture for the maritime industry. In order to recognize that the safety culture
exists we are required to specify the indicators used in the Assessment. Various lists of
indicators have been presented in literary works dealing with quality and safety
management (Deming, 1986; Juran and Godfrey, 1998; Mejia, 2001; Wiegmann et al.
2002; Anderson 2003).
For the purpose of evaluating the maritime safety culture we should base the Assessment
on the intention set by the maritime community itself. The ISM Code provides the
indicators for recognizing whether the safety culture exists in the maritime industry.
Jouni Lappalainen 47
These indicators are going to be utilized as the criteria for the forthcoming Assessment.
The chosen indicators are listed below.
1. established and actively working process for continuous improvement
2. commitment from the top management of the company
3. motivated and encouraged personnel onboard to actively initiate safety
improvements (personnel empowerment)
5.4 Findings of the literature review
The ISM Code has brought a significant contribution to the progress of maritime safety
in recent years. Shipping companies and ships’ crews are more environmentally friendly
and more safety-oriented than 12 years ago. This has been showed by several studies
which have been analysed for this literature research (Othman, 2003; Anderson, 2003;
IMO, 2005; Paris MoU, 2008; ReportISM, May 2008).
Othman (2003) states that most of the (80 %) Malaysian shipping companies have
implemented their safety management systems effectively according to the requirements
of the ISM Code. The member states of the Paris MoU conducted a Concentrated
Inspection Campaign (CIC) which focused on the effectiveness of the ISM Code. The
Paris MoU discovered that most of the shipping companies and the crews of the vessels
understand safety and implement it (Paris MoU, 2008). The Tokyo MoU conducted a
CIC simultaneously with the Paris MoU. The result of the CIC showed that the safety
management systems operate and function effectively onboard most of the ships and the
ISM operators (Tokyo MoU, 2008).
Nevertheless, the direct effect and influence of the ISM Code on maritime safety could
not be isolated very well. No quantitative measurement (statistics/hard data) could be
found in order to present the impacts of the ISM Code on maritime safety (Mejia, 2001;
Anderson, 2003, IMO 2005, ReportISM, May 2008).
In the light of the performance criteria set in the previous chapter, there are major
shortcomings concerning effective safety management in the maritime industry.
Continuous improvement
The referenced studies show that near-misses are not perfectly reported. Some
mariners are still reluctant to express their mistakes (Withington, 2002; Anderson,
2003). The Paris MoU (2008) reported that one of the most common deficiencies
in the safety management systems concern the reporting of the nonconformities
and occurrences of accidents. Hence, there is still room for improvement in the
reporting of the deficiencies and non-conformities in the maritime industry. The
proper reporting of the deficiencies and non-conformities establishes a basis for
continuous improvement.
Furthermore, Anderson (2003) uncovered that in certain cases further analysis and
corrective actions of the reported incidents were not properly carried out. Under
48 Transforming Maritime Safety Culture
these circumstances, the successful cycle of continuous improvement could not
function.
Management commitment
Some shipping companies prefer short-term profits at the expense of maritime
safety (Anderson, 2003). The Paris MoU reported as a result of the CIC that 176
ships were detained due to serious deficiencies against the requirements of the
ISM Code. The reasons for the detentions were that the maintenance of the ship
and its safety equipment were badly neglected. The status of the emergency
preparedness was poor as well. (Paris MoU, 2008; ReportISM, May 2008).
Evidently the top management of the badly performing shipping companies are
not committed at all to the safety issues.
Personnel empowerment and motivation
Pun et al. stated that the high turnover of the labour force could prevent the
establishment of the safety culture in the maritime industry (Pun et al, 2002). Also
Anderson emphasized that establishing a safety culture is not easy when the
turnover of the crew is high (Anderson, 2003). British Maritime and Coastguard
Agency expressed the same concern in their study in 2008. The transient nature of
the workforce with a relatively long distance between the ship owner and the
vessel complicate the progress of safety management (ReportISM, May 2008).
In this study I have discovered that safety culture has emerged and it is developing in
the maritime industry. Even though the roots of the safety culture have been established
there are still serious barriers to the breakthrough of the safety management. These
barriers could be envisaged as cultural factors preventing the safety process. Even
though the ISM Code has been effective over a decade, the old-established behaviour
which is based on the old day’s maritime culture still occurs. In the next phase of this
research project, I will concentrate on analysing these cultural factors in regard to the
present safety culture of the maritime industry in Finland. The analysis will be based on
the criteria presented above.
Jouni Lappalainen 49
6 FURTHER RESEARCH
The aim of this research project was to study if the goals of the ISM Code have been
achieved during the last 10 – 12 years. The major goal of the ISM Code was to establish
a safety culture in the shipping industry (Anderson 2003). The safety culture can be
seen established if the criteria presented in Chapter 5.3 are fulfilled.
In the next phase of this project, empiric Assessments concerning the impacts of the ISM
Code on Finnish shipping companies and Finnish-owned vessels will be performed.
During the study, the experiences and impressions of the ISM Code will be collected by
interviewing the personnel of the Finnish shipping companies. Particularly the crew and
the officers of the vessels will be interviewed.
As a part of the empiric study, the researcher will participate in several internal and
external ISM audits carried out by a company or an administration. The purpose of
participating in the audits is to find out implications of any contradictions or
inconsistencies between the opinions expressed during the interviews and the reality
observed during the audits.
The results of the interviews will be compared with the performance criteria of the
maritime safety culture. The results of the interviews will be utilized by authenticating
whether a maritime safety culture has transformed. The main questions are:
• Can we see continuous improvement onboard and in the shipping companies as
a result of willingness to report and learn from near misses or are the marine
personnel still reluctant to admit that they have made a mistake?
• Is the top management sincerely committed to the company’s manifested safety
and environmental policy by providing accurate resources for safe operation?
• How deeply are the personnel of the vessels engaged in the safety management?
Interviews will be carried out by in-depth interviews. A structured questionnaire is
provided in order to examine the research area comprehensively. The purpose of the
questionnaire is to Help the interviewer and function as a reminder. The interviewees
will be buoyed up to express themselves freely and in their own words.
As the previous international studies referred to in this literature review have showed
some shipping companies perform their duties better than others. Hence, the empiric
study attempts to clarify what kinds of obstacles and difficulties have occurred during
the development, implementation and operation of a safety management system in a
shipping company. And vice versa, it is important to collect successful experiences
from the better performing companies.
50 Transforming Maritime Safety Culture
TERMINOLOGY
International Safety Management (ISM) Code
– the International Management Code for the Safe Operation of Ships
and for Pollution Prevention
Company
– The owner of the ship or any other organization or person such as
the manager, or the bareboat charterer, who has assumed the
responsibility of operating the ship from the ship owner and who,
by assuming such responsibility, has agreed to take over all duties
and responsibilities imposed by the ISM Code.
Designated Person Ashore (DPA)
– To ensure the safe operation of each ship and to provide a link
between the Company and those on board, every Company, as
appropriate, should designate a person or persons ashore having
direct access to the highest level of management. The responsibility
and authority of the designated person or persons should include
monitoring the safety and pollution-prevention aspects of the
operation of each ship and ensuring that adequate resources and
shore-based support are applied, as required.
Administration
– The Government of the State whose flag the ship is entitled to fly.
Safety management system
– a structured and documented system enabling the Company
personnel to effectively implement the Company’s safety and
environmental protection policy.
Document of Compliance
– a document issued to a Company which complies with the
requirements of the ISM Code.
Safety Management Certificate
– a document issued to a ship which signifies that the Company and
its shipboard management operate in accordance with the approved
safety management system.
Source: IMO, 2008
Jouni Lappalainen 51
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University of Turku
CENTRE FOR MARITIME STUDIES
Veistämönaukio 1–3
FI–20100 TURKU, Finland
http://mkk.utu.fi

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