HƯỚNG DẪN QUY ĐỊNH VÀ CÁCH THỨC THỰC HIỆN CÔNG VIỆC TRÊN TÀU

TABLE OF CONTENTS SECTION 1 SCOPE AND FIELD OF APPLICATION 1.01 Definitions SECTION 2 COMPANY POLICIES 2.01 Mission and Vision Statement 2.02 Business Policy Financial / Ethics 2.03

QHSE Manual

Uncontrolled – if in hard copy

TABLE OF CONTENTS

SECTION 1 SCOPE AND FIELD OF APPLICATION

1.01 Definitions

SECTION 2 COMPANY POLICIES

2.01 Mission and Vision Statement

2.02 Business Policy (Financial / Ethics)

2.03 Shipboard & Shore-side Occupational Health, Safety and Environmental Policy

2.05 Shipboard Drug & Alcohol Policy

2.06 Speaking Up Policy

SECTION 3 QHSE MANAGEMENT SYSTEM

3.01 QHSE System Processes

3.02 Interaction and Application of the Processes

4.06 Legal and Other Requirements

4.07 Customer Focus and Customer related process

4.07.01 General 4.07.02 Determination and review of the Requirements Related to Management of

Ships

SECTION 5 RESPONSIBILITY, AUTHORITY AND COMMUNICATION

5.01 Designated Person(s) Ashore/Quality Management Representative/ Environmental

Management Representative(s)/OH&S Management Representative 5.02 Master’s Responsibility and Authority

5.03 Organizational Control

5.04 BSM Group – Shore Organization Chart

SECTION 6 RESOUCES, PERSONNEL, MAINTENANCE AND EMERGENCY

MANGEMENT

6.01 Resource Management

6.01.01 Infrastructure 6.01.02 Personnel

6.01.02.01.01 Selection, recruitment and promotion

6.01.02.02.01 Selection, recruitment & promotion 6.01.02.02.02 Ship Masters

6.01.02.02.03 Crew Welfare 6.02 Competence, Training and Awareness

6.02.01 General

6.02.03.01 Appraisals and Continual Professional Development

6.02.03.01.01 Ship Staff 6.02.03.01.02 Shore staff 6.02.04 Safety and Familiarization Training 6.03 Communication

6.07 Preservation of Product (Service)

6.08 Identification and Traceability

6.09 Maintenance of the Ship and Equipment

6.09.02 Critical Equipment & Technical Systems 6.09.03 Drydocking and afloat repairs

6.10 Emergency Preparedness and Response

6.10.01 General

6.11 Control of Monitoring and Measuring Devices (MMDs)

6.11.01 Control of Monitoring and Measuring for Shipmanagement Services

SECTION 7 MONITORING AND MEASUREMENT

7.01.02 Monitoring and Measurement of Service Characteristics

7.02 Nonconformity, Corrective Action and Preventive Action

7.02.01 Non-conformance / Control of Non-conforming Product /Service 7.02.02 Accident and Incident Reporting & Investigation (Root Cause Analysis)

7.02.02.01 Reporting of Incidents & Accidents 7.02.02.02 Investigating Incidents & Accidents 7.02.02.03 Training of Investigators

7.02.02.04 Sharing lessons learned 7.03 Analysis of Measurements and Improvement

7.03.02 Analysis of Vessel Inspection Results 7.04 Internal Audit

SECTION 8 MANAGEMENT REVIEW

8.01 General

8.02 Monthly Review Meetings

8.03 Quarterly Review Meetings

8.04 Yearly Review Meetings

1 Scope and Field of Application

“Bernhard Schulte Shipmanagement” a member of Bernhard Schulte Group consists of a Team of highly skilled and experienced managers, technicians, engineers and ship’s officers as well as specialists in the fields of Safety Management systems, Commercial Management, Ship Finance, Personnel Management and Insurance

This QHSE Manual covers all the activities of all our Offices involved in Shipmanagement, as well as the operations onboard such managed vessels, excluding those vessels under crew management contracts The Management systems of the Company are based on the requirements of:

• Mandatory Regulations (National, International, Flag State & Port State)

• Applicable Codes, Guidelines, Industry Standards to which the Company subscribes such as:

− The ISM Code

i) ISO9001:2008, Clause 7.3 Design and Development

Bernhard Schulte Shipmanagement does not currently perform true design activities as it is service oriented as such, considers that the Design and Development clauses of ISO 9001:2008 do not apply

ii) ISO 9001:2008, Clause 7.5.2 validation of processes for production & service provision

There are no special processes where the resulting output cannot be verified by subsequent monitoring and thus considers this clause not applicable

b OHSAS 18001 – Compliance to this code is part and is under active consideration for future full implementation and certification

1

ISO 9001:2008 4.2.2.a

1.01 Definitions

The definitions listed below taken, or adapted from the ISM Code, ISO 9001:2008, ISO 14001:2004 and OHSAS 18001:2007 are used in the system Manuals of the Company

Accident – An incident with unexpected or undesirable consequences The consequences may be

related to personnel injury or fatality, property loss, environmental impact, business loss, etc., or a combination of these

Administration – means the Government of the State whose flag the ship is entitled to fly

Company – For the purposes of this Manual the Company is the Bernhard Schulte Shipmanagement

(Service Delivery Centre) who has assumed the responsibility for operation of the ship from the ship owner and who, on assuming such responsibility, has agreed to take over all duties and responsibilities imposed by the ISM Code {Company = Organization (ISO 9001:2008)}

Continual improvement – recurring process of enhancing the management system in order to

achieve improvements in overall performance consistent with the Company’s stated policies for safety, quality and pollution prevention, as applicable

Corrective Action – action to eliminate the cause of detected nonconformity

CSC – Crew Service Centre - refers to Bernhard Schulte Group Company which provides Ship

manning Services

Customer – organization or person that receives a product or service

Customer satisfaction – perception of the degree to which the Customer’s requirements have been

fulfilled

DOC – Document of Compliance certificate issued to the Shore Office towards compliance with the

relevant provisions of the ISM Code

Environment – surroundings in which the Company and its ships operate, including air, water, land,

natural resources, flora, fauna, humans, and their interrelation

Environmental aspect – element of a Company’s or organization’s activities or products or services

that can interact with the environment

Environmental impact – any change to the environment, whether adverse or beneficial, wholly or

partially resulting from the Company’s environmental aspects

Environmental objective – overall environmental goal, consistent with the environmental policy, that

the Company sets itself to achieve, and which is quantifiable where practicable

Environmental management system – part of the Company’s management system used to develop

and implement its environmental policy and manage its environmental aspects

Environmental performance – measurable results of the Company’s management of its

environmental aspects

Environmental Target – detailed performance requirement, quantified where practicable, applicable

to the Company or its ships, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives

GMD – Group Managing Directors for specific type of ships

Hazard – source or situation with a potential for harm, in term of injury or ill-health, damage to

property, damage to workplace environment or a combination of these

Hazardous Occurrence: An incident with no consequences, but could have reasonably resulted in consequences under different conditions (Hazardous Occurrences are sometimes referred to as Near Misses.)

Incident - An unplanned sequence of events and/or conditions that results, or could have reasonably

resulted, in a loss event

Infrastructure – system of facilities, equipment and services needed for the operation of the

Company

Internal audit – systematic, independent and documented process for obtaining audit evidence and

evaluating it objectively to determine the extent to which the management system audit criteria set by the Company are fulfilled

Interested Parties – person or group concerned with or affected by the performance of the Company

International Safety Management (ISM) Code – means the International Management Code for the

Safe Operation of Ships and for Pollution Prevention

Major non-conformity – means the identifiable deviation that poses a serious threat to the safety of

personnel or the ship or a serious risk to the environment that requires immediate corrective action and includes the lack of effective and systematic implementation of the requirement of the Code

Near Miss: (Same as Hazardous Occurrence)

Non-conformity – means an observed situation where objective evidence indicates the non-fulfillment

of a specified requirement

Objective evidence – means quantitative or qualitative information, records or statements of fact

pertaining to safety or to the existence and implementation of a safety management system element, which is based on observation, measurement or testing that can be verified

Observation – means a statement of fact made during a management audit and substantiated by

objective evidence

Occupational health and safety (OH & S) – conditions and factors that affect the well-being of

employees, temporary workers, contractor personnel, visitors and any other person in the workplace

Policy – overall intentions and direction of an organization related to its performance as formally

expressed by the top management

Preventive action – action to eliminate the cause of a potential non-conformity

Prevention of pollution – use of processes, practices, techniques, materials, products, services or

energy to avoid, reduce or control (separately or in combination) the creation, emission or discharge of any type of pollutant or waste in order to reduce adverse environmental impacts

Procedure – specified way to carry out an activity or process

Quality – Degree to which a set of inherent characteristics fulfils the requirements.

Unless specifically stated otherwise within the application in this manual, includes the requirements for all matters concerning health, safety and protection of the environment

Quality Objective – Something sought, or aimed for, relating to quality

Record – document stating results achieved or providing evidence of activities performed

Requirement – a need or expectation generally stated, generally implied or obligatory

Risk - It is the chance of something going wrong It consists of two elements:

A) The likelihood that a hazard may occur

B) The consequence (Including severity) of the hazardous event

Risk assessment – overall process of estimating the magnitude of risk and deciding whether or not

the risk is tolerable

Safety aspect – element of a Company’s or organization’s activities or services that represents an

actual or potential risk to safety or personnel, or the ship

SDC – Service Delivery Centre - Refers to a Bernhard Schulte Group Company which is directly

involved in the provision of Shipmanagement services

Severity – In the context of Risk Assessment, this means the possible degree of harm associated

with the hazard

SMC – 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

Supplier – organization or person that supplies a product or service

System – set of interrelated or interacting elements required to direct and control a Company

Top management – person(s) who directs or controls the Company

Work environment – set of conditions under which the work is performed

2 Company Policies

The top management of the Company has adopted a Policy of operating its “Ship Management Service” business under the provision of a comprehensive Quality, Health, Safety and Environmental Management System, implemented and operated to the requirements of ISO 9001:2008, ISO14001:2004, OHSAS 18001:2007* and the ISM Code It is company policy to continuously operate

to these requirements, as would apply to it and where required (both as mandatory and value addition) have the systems certified by Accredited Certification bodies

The Top Management has ensured that it’s Policies:

• are appropriate to the purpose, nature and scale of its business

• covers all activities undertaken by the Company

• includes commitments to comply with applicable requirements

• has provisions to continually improve the effectiveness of its Management Systems

• provides for a framework for setting and reviewing its objectives

The management ensures that all its policies are communicated, understood, implemented and maintained at all levels of the shore-based and shipboard organization, and to all persons working for

or on behalf of the Company1, and that they are reviewed at Management Review meetings for their continued suitability.2

Each of the company’s policies is implemented in practice through the application of formal procedures and instructions3 and reviewed through processes described therein

The policies are duly signed by top management

2.01 Mission and Vision Statement1

Safety: our first priority is the safe operation of the vessels we manage, with no

injuries, loss of life, and damage to property or the environment

Human resources: to be the employer of choice for competent seafarers and office staff

Customer satisfaction: to meet and exceed the expectations of our customers

Service coverage: to provide excellent value added services globally for all our customers’

our people, by respecting the individual, treating them fairly and providing opportunities for continuous

learning and development

our business partners and adhere to the highest ethical standards

our independence as a family owned company with long term focus and commitment to third party

shipmanagement

the good reputation of Bernhard Schulte

an entrepreneurial approach coupled with rigorous risk management

service orientation and reliability through focusing on excellent service to our customers

1

TMSA 1.1 a

Our Principles

We:

• systematically manage risks

• continuously define, monitor and improve performance

• reward results

• are cost conscious

• meet our commitments

• encourage initiative and innovation

• promote team work and streamlined business processes

• take pride in cultural diversity and benefit from our global structure

• provide a modern and stable working environment so that all employees can contribute to the best of their abilities

• are socially responsible

2.02 Business Policy (Financial / Ethics)

The Company recognises and acknowledges that the purpose of a contract for full and/or crew management of a ship, is to provide a beneficial and profitable relationship for the Company and the Client

The Company shall not tender for, or secure any contract, if the resources of the Company are known,

or expected to be insufficient to comply with the requirements of the contract, or to meet existing and expected regulatory requirements

The Company shall not knowingly participate in any illegal activities of the client, his agents and/or his representatives Neither shall the Company enter into agreements or contracts that would involve the Company, its agents and/or representatives, in unsafe acts or practices

The Company will always adhere to sound and proper accounting principles in the management of cash or funds made available by the client as a result of, or in addition to, the terms and conditions of the contract

2.03 Shipboard & Shore-side Occupational Health, Safety and Environmental Policy1

The Company recognises that occupational health, safety and environmental (OHSE) management is essential in order to achieve the Company’s operating objectives We are committed to prevention of injury and ill health and continual improvement in OHSE performance.2

Our Occupational Health, Safety and Environmental Policy provides the framework for setting and reviewing OHSE objectives and targets.3 It is based on the requirements of:

• The ISM Code

• ISO14001:2004

• OHSAS18001:2007

Our objectives are:

• To achieve zero spills, zero accidents and zero incidents4

• To establish safeguards against all identified risks5

• To continuously improve safety management skills of personnel ashore and aboard ships, including preparing for emergencies related both to safety and environmental protection.6

• To develop a sense of personal responsibility in all personnel towards health, safety

and environmental protection

Implementation:7

The prime responsibility for implementing this Policy lies with line management (supervisory positions)

To achieve this, the commitment and involvement of all Company personnel is required Onboard ship, Senior Officers and visiting shore management must lead by example and comply with all safety practices and procedures including at all times wearing the correct PPE.8

The Company will comply with all relevant national and international OHSE legislation, and regulations, and take into account all industry guides and codes of practice9

When considering new business or work methods, full account will be taken of all relevant health, safety and environmental aspects to ensure that the standards required by this Policy are maintained All work will be properly supervised with safety and environment protection forming an integral part of all planning and procedures Necessary information, instruction and training will be given as necessary

to ensure the health and safety at work of all employees

The Company is committed to improving health and safety performance and will respond positively to recommendations, from both shore and sea staff, that identifies changes in policy, practices or equipment necessary to improve standards

All incidents of a serious or potentially serious nature will be investigated and recommendations communicated through line management where appropriate

Management will strive to ensure that purchase and supply activities are continuously improved with respect to environmental protection This includes waste reduction methods such as: 10

• Bulk purchasing to reduce packaging

• Recycling initiatives

• Using non-disposable equipment

Management will use its best endeavours to ensure that contractors working on their behalf apply standards compatible with this Policy

This Policy will be communicated to all employees and contractors11, in order to ensure they are aware

(signature)R Bajpaee

Chief Operating Officer

Bernhard Schulte Shipmanagement

Bernhard Schulte Shipmanagement will:

• adopt procedures and disciplines to ensure that the system is effectively implemented and in line with our organisational goals and expectations;

• undertake relevant skills training and conduct appropriate quality awareness training;5

• establish responsibilities for quality and communicate these responsibilities clearly to all employees;

• check the effectiveness and ongoing relevance of the policies and procedures by initiating regular reviews 6 and;

• regularly review the needs and expectations of our customers and initiate continuous improvement activities to meet these expectations

(signature)

R Bajpaee

Chief Operating Officer

Bernhard Schulte Shipmanagement

2.05 Shipboard Drug & Alcohol Policy

The Company’s Shipboard Drug and Alcohol Policy comply with the recommendations contained in OCIMF’s ‘Guidelines for the Control of Drugs and Alcohol On Board Ship’.1

With regard to Alcohol, this Policy is based on the following:

• Consumption of alcohol limited to beer, wine and similar alcoholic beverages with an alcohol content of less than 17%

• 1 hour of abstinence for each unit of alcohol consumed

• Total abstinence from alcohol for 4 hours prior to a period of scheduled responsibility, i.e watchkeeping duties, port arrival/departure etc

• Flag, Port or Coastal State requirements, or Policies of Owners, Charterers, or other interested parties which exceed the requirements of this Policy shall be adhered to as if included in this Policy

• It is accepted that many of the company’s vessels will in fact be ‘dry’, with respect to alcohol consumption, due to policies of owners or charterers

In addition, the Company maintains a system based on breathalysers and random testing to monitor the effectiveness of this Policy

Any form of drug, with the exception of over-the-counter medicines and prescribed drugs, are totally banned from Company managed vessels Personnel on prescribed drugs must declare this fact to the Master upon joining the vessel, or upon prescription if prescribed during the period of service onboard The Master if on prescribed drugs must declare this fact to the company prior joining the vessel, or upon prescription if prescribed during the period of service onboard

This Policy is monitored on board all vessels by the Master In addition, Officers and Ratings undergo screening carried out during routine medical examinations

Officers and Ratings are subject to unannounced random tests conducted by qualified personnel to Port State and Owners’ requirements

(signature)R Bajpaee

Chief Operating Officer

Bernhard Schulte Shipmanagement

The Board recognises that effective and honest communication is essential to maintain our business values and

to ensure that instances of business malpractice are detected and dealt with

• A person not complying with any legal obligation

• The use of deception to obtain an unjust or illegal financial advantage for the business unit or personally

• A miscarriage of justice

• Danger to the health and safety of an individual

• Damage to the environment

• A fundamental breach of internal control

• Intentional misrepresentation directly or indirectly affecting financial statements

• Serious non-professional or non-ethical behaviour including harassment and bullying,

• Deliberate concealment of information relating to any of the above

This policy is separate from the grievance procedure as detailed in the documented management system

Investigation

Once an allegation of business malpractice is made the Group LPSQ Director will agree an appropriate investigation plan with the SDC Head and respective GMD, and will endeavour to respond to you within 10 working days setting out what further investigation, if any, is planned

Once the investigation is complete it will be reviewed by the Group LPSQ Director and the COO and you will be advised of the results of the investigation as well as any corrective actions which are being taken

The Group is committed to running its operations without misconduct and expects its employees and other stakeholders to share this objective However the group also recognises that speaking up can be a potentially sensitive issue If you believe that you are being penalised in any way for speaking up, or if you do not have a satisfactory response to your disclosure you should write to the Group LPSQ Director setting out the facts

3 QHSE Management System

Bernhard Schulte Shipmanagement has established documented, implemented and maintains a Quality, Health Safety and Environmental Management (QHSE) System and continually improves its effectiveness in accordance with the requirements of:

• The ISM Code1

• ISO9001:20082

• ISO14001:2004

• OHSAS18001: 2007 (partly complying as mentioned in Sect 1 & 2 of this Manual)

Bernhard Schulte Shipmanagement has identified the processes required for the QHSE Management System and determined how they apply throughout the organization The sequence and interaction of the processes are shown in this QHSE Manual.3

Refer Sec 3.02

The Company has determined the methods and criteria required to make sure that the operation and control of these processes are effective (refer QHSE Procedures), and ensure that the resources and information needed to operate and monitor them are available.4

The Company monitors, measures and analyses these processes as appropriate and takes actions needed to achieve the planned results and continually improve.5

Refer Sec 7.1

The processes are managed by Bernhard Schulte Shipmanagement in accordance with the requirements of the relevant Standards, Codes, IMO, National, Flag State and International Regulations Where the company may choose to outsource any processes that can affect the conformity of the service requirements, it ensures that such processes are controlled Any such processes and their controls are identified in the QHSE management system.6

All documentation pertaining to the management system, including policies are written in the English language, being the common language understood by all shore and shipboard personnel.7 nstructions and procedures are clear and simple to use Actions are arranged in sequential order and in a way that makes it easy to identify each step. 8

3.01 QHSE System Processes

The top level processes identified by Bernhard Schulte Shipmanagement as being necessary for the QHSE management system are:

1 Running and Maintaining the Ship (A.1)

2 Managing Personnel (A.2)

3 Arranging Insurances (A.3)

4 Purchasing activities (A.4)

5 Monitoring and managing costs (A.5)

6 Monitoring, Analysis and Review (of processes and service delivery) (A.6)

Ref Sect 3.02

These processes satisfy the ISO9001:2008 requirement for process in that they include management activities, provision of resources, product realization and measurement.9

3.02 Interaction and Application of the Processes

The Company has mapped out the interaction and application of the processes using the “Integration Definition for Function Modelling” (IDEFO) language This describes the main activity of Running and Maintenance of the Ship of Ship Management Services with Inputs, Outputs, Controls Mechanism, Costs connected to it flowing in or out as appropriate This permits the construction of models comprising system functions (activities, actions, processes, operations), functional relationships, and data (information and objects)

The top level processes of the management system can be depicted using this technique:

Each of above sub-processes (A.2, A.3, A.4, A.5, A.6 are further explained in the QHSE Shore Procedures by use of RACI Charts Further sub-sub-processes as applicable /appropriate are also detailed therein

9

ISO9001:2008 sect 4.1

3.03 Management System Documentation

The management system documentation:

• defines the responsibility, authority and interrelation of all personnel who manage, perform and verify work relating to and affecting safe operation, prevention of pollution and quality, as appropriate10

• includes documents, including records, determined by the company to be necessary to ensure the effective planning, operation and control all its processes

• is maintained on a web based portal (called QMAN), with CD copies supplied to vessels, and all paper versions being considered uncontrolled This is the form that the Company considers most effective.11

Instructions and procedures covering shore-based and ship-based operations are developed in consultation with those who will have to implement them.12

The following three levels of documentation have been established, implemented and maintained to the Company’s requirements towards Compliance with provisions of ISO9001:2008 13’, ISO14001:2004, OHSAS 18001:2007 and the ISM Code:14 This arrangement provides for to continually improve the effectiveness of its Management systems

Operations and Other Manuals, Forms, Records, Work Instructions etc.

QHSE Procedures (Shore based & Shipboard)

System Manual structure overview is as below:

Level 1:

Quality Policy – a statement of the Company’s commitment to Quality and an enunciation of its

Quality objectives.15 This is issued by the COO and is reviewed annually In addition to the Quality Policy, following Policies has also issued by the Senior Management (COO), Shipboard & Shore-side Occupational Health, Safety and Environmental Policy, and a Shipboard Drug and Alcohol Policy Unless specified otherwise, the Quality Policy is understood to embrace all aspects of these other Policies

Cargo Operations Manual

EMS Manual Risk Assessment &

Management of Change

Tanker Safety (General)

Tanker (Specific)

Bulk Carriers Container

Contingency Manual

Technical Operation Manual

SHE Manual Filing Forms &

Documentation Manual

Other Cargo (Ship Type)

Ship Shore

The QHSE Manual contains references to various procedurescalled QHSE Procedures established for the QHSE management system.17

Level 2:

QHSE Procedures18 – describes how we will satisfy each element of the various codes and standards and how we control other critical processes in order to meet the commitments outlined in the Policies The complexity of the work and the skill level of personnel involved in performing the work and the work environment governs the degree of control provided within themanagement system procedures

Level 3:

Operations & Other Manuals: Contain instructions and procedures for Cargo Operations (ship type

specific), Safety Health Environment, Technical, Environment Management System (EMS), Risk Assessment, Management of Change (MOC), Personnel etc, to ensure Safe operation of ships and protection of the environment all in compliance with relevant International and flag state legislation,19(as applicable)

Contingency Response Plan Manual – This manual covers in detail Company’s set up and plans to

deal with Contingencies on board

Forms, Filing & Documentation Manual20 – Forms used to complement QHSE Procedures and/or

Work Instructions Once completed they constitute records Also covers Company’s Document Control Procedures and Filing Instructions

Records21 – Records are established and maintained by the company to provide evidence of conformity to requirements and of the effective operation of the Quality Management System

Work Instructions – Supplements the company’s procedures by giving detailed instructions on how to

carry out the specified activities, controls, inspections or tests, or how to process documents.22 They are used where the absence of such instructions would adversely affect service quality These are normally more specific to each SDC and mostly deal with Local level information

3.03.01 Control of Documents23

The Company has established and maintains procedures to ensure that:

• All documents are identified, distributed and controlled, including data that relate to the requirements of the Management System24 This includes where practical, documents of external origin determined to be necessary for the planning and operation of the Management System25 This covers all documents and data in any format, including hardcopy and electronic media

• New and revised documents and data are reviewed for and approved, or updated and approved for adequacy, as well as for co-ordination and correlation with existing documentation

re-by Senior Management prior to issue.26

• A formal document-control system ensures that current Management System documentation (and only that) is available for use onboard all vessels at all work locations27 - any invalid or obsolete documents retained for any purposes are suitably identified and prevented from unintended use.28

• Drawings, procedures and other technical documents for vessels are updated following any change or modification if carried out From the time of initial construction, or acquisition, of a vessel, a historical record is maintained that includes all structural or technical changes made, the status of equipment, and how that status has evolved from the original design Document-control systems are used to initiate and control the flow of such information 29

• Valid documents can be located and are available at all points of use, and that all staff and contractors have access to important documents.30

• Documentation remains legible and readily identifiable, maintained in an orderly manner and indicates the date of revision

• Documentation is retained for specified periods

Refer: Filing, Forms & Documentation Manual, Chapter 3 “Documentation”

3.03.02 Control of Records31

The Company has established, implemented and maintains procedures for the identification, storage, protection, retrieval and disposal of management system records These records include, training records, records of internal and external audits, records of reviews, Inspections and other pertinent records necessary to demonstrate conformity to the requirements of:

a) the Management System

b) the ISM Code,

c) should have retention times established and documented

Records also include e.g placement of a copy of the Document of Compliance (DOC) onboard the vessel in order that the Master, if so asked, may produce it for verification of the Administration or organizations recognized by the Administration

A copy of the Safety Management Certificate (SMC) issued to the vessel is similarly retained ashore Other key records apart from those described at the beginning of this section 3.03.02 would include the Ship owner’s report to the Flag Administration identifying the full name and details of the Company managing the vessel(s) on their behalf.32

32

ISM 3.1

4 Planning 1

The Company has planned and develops the processes needed for service realization to improve the effectiveness of activities required in deliverance of its services Planning of service realization is consistent with the requirements of the other processes of the management system

In delivering the service the Company:

a) ensures adherence to the requirements and objectives of the service;

b) identifies the need to establish or amend processes or procedures and provide resources required by the service;

c) identifies the verification, validation, monitoring, inspection and test activities specific to the services and the criteria for service acceptance; and

d) identifies the records required to demonstrate compliance

The scope of Planning takes into account Process Identification, Sequence & Interaction, Controls, Availability of Resources and Information as support, Process Analysis, Corrective Action and Preventive Action etc Typical Plans would include Plans for key Shipboard and Shore based Operations, Plans for critical operations, Planned Maintenance System, Planning for Emergency Preparedness / Contingency Response, Planning for Media response in an emergency etc

When changes to the system are planned and implemented it is ensured that the integrity of Quality Management System is maintained

The company also has a documented planning process to ensure that future manning needs can be met.2 Staff succession and recruitment planning is conducted, including profiling of competence, experience and retirements Assessments are made for future shore-based assignments

4.01 Business Plan

The Company develops and maintains a long term Business plan which is updated on a regular basis with a formal review at least once each year.3

Ref: QHSE Procedures - Review Meeting

The Business Plan includes apart from other issues, environmental operations which includes quantified improvement targets covering marine and atmospheric sources of pollution attributable to the company’s activities.4

4.02 Quality, Health, Safety and Environmental Objectives and Targets 1

The Company has established, implemented and maintains documented QHSE objectives and targets

at each relevant function and level within the shore-based and shipboard organization

The main forum for this are the local SDC Level Management Review Meetings where objectives which are to be set (apart from those in the Policies) , are discussed and agreed, although there may

be instances (due to business need) where QHSE objectives are set by management outside the Management Review process Targets are also set in these meetings to achieve the desired objectives within defined time frames

The objectives and targets are measurable where practicable, and consistent with the Health, Safety and Environmental policy, taking into account the Company’s commitment to safe operation and prevention of pollution in compliance with applicable legal requirements along with other requirements

to which the Company subscribes Continual improvement is kept in focus

Line Managers are responsible for converting the overall objectives into functional, or individual objectives, where they apply in the scope of their control

Top management recognizes its responsibility to ensure that QHSE objectives are achieved.2 It is the functional responsibility of each Head of Department, however, to ensure that the QHSE objectives within his scope of control are regularly reviewed, that progress is documented, that the objectives continue to reflect the business need, that they are suitably amended if necessary, and that any additional resources necessary for their achievement are provided

Responsibility for achieving these objectives and targets has also been identified and documented

Ref Group Level Review & SDC level Management Review Meeting Minutes

When establishing and reviewing its management system objectives, the Company:

1 ensures compliance with mandatory rules and regulations3

2 ensures that applicable codes, guidelines and standards recommended by the IMO, Flag Administrations, classification societies, and maritime industry organizations are taken into account

3 considers the significant environmental aspects of its operations

4 considers the views of interested parties

5 considers technological options

6 considers its financial, operational and business requirements and

7 considers its legal and other requirements

8 Ensures the integrity of the management system is maintained when changes are planned and implemented

Refer: section Management Reviews in QHSE procedures

b) establishing the vision, mission statements, the QHSE policies & procedures;

c) ensuring that QHSE objectives are established;

d) by conducting management reviews, reviewing non conformance summaries and assessing progress towards the audit plan The company keeps records that indicate the extent of management involvement in these activities1

e) ensuring availability of resources

f) Establishing and supporting proactive safety campaigns.2

Managers and supervisors give clear directions and, by their behaviour, demonstrate commitment to safety and environmental excellence

Strong, effective and visible leadership is demonstrated at every level in order to establish and sustain long-term improvements towards safety and environmental excellence.3

In addition to any shore-based safety initiatives, the ship's senior management team is actively involved and committed in promoting a strong safety, health and hygiene culture on the vessel Senior Management lead by example and encourage near-miss/hazardous occurrences reporting, hazard identification, risk assessment and use of appropriate personal protective equipment (PPE)4

4.04 Environmental Aspects 1

The Company has established, implement and maintains procedures to identify the environmental aspects of its ship and shore-based operations defined within the scope of the environmental management system that it can control and those it can influence, taking into account planned or new developments or new or modified activities and services

The Company determines which environmental aspects have or can have a significant impact on the environment The Company documents this information and keeps it up-to-date

The Company ensures that the significant environmental aspects are taken into account in establishing, implementing and maintaining its environmental management system

All sources of marine and atmospheric pollution attributable to the company activities have been systematically identified These sources include funnel emissions (NOx, SOx), garbage, volatile organic compounds (VOC), oil emissions, ballast water, sewage and antifouling paints.2

Ref: EMS Manual – Appendix 1 – Analysis of various activities

The company has an active and formally recorded programme of waste reduction management which

is undertaken throughout the fleet and on all voyages It includes, as appropriate: recycling, compacting, and grey water management3

Ref: EMS Manual – Appendix 5 – Resource Conservation

The Company has processes in place aimed at ensuring all effluent discharges are within permitted levels or are prohibited, in accordance with MARPOL Annex I, II, IV, VI, etc., and under national/regional limitations, such as European Union (EU) and US limits.4

Responsibility for environmental performance is assigned to an appropriate person within shore management.5

4.04.01 Resource Conservation

The Company makes its best endeavours to manage vessels and its shore establishments efficiently,

in order to minimise the waste of resources

The Company considers resource conservation when communicating with Owners, regarding repairs and maintenance In this respect, where relevant, resource-efficient solutions will be proposed to Owners

Notwithstanding the Company commitment to resource conservation, the aspect of financial consideration and constraints imposed by Owners needs are also borne in mind

4.04.02 Pollution by liquid substances

The Company recognises the need to minimise the risk of pollution by liquid substances

Polluting liquid substances are identified as follows:

• OIL, OILY MIXTURES AND WASTES

• BULK LIQUID CHEMICALS

• BULK LIQUID GASES

• NOXIOUS LIQUID SUBSTANCES

The goal is for ZERO spills to the sea.6

Ref Company’s SHE Manual Chapter 4

4.04.03 Sewage

The Company recognises the need to comply with MARPOL 73/78 Annex IV Vessels equipped to comply with this standard shall operate and maintain the onboard equipment and systems as per the manufacturer’s instructions, and in compliance with the intent of MARPOL 73/78 Annex IV (Current version/Update)

Ref: SHE Manual Sec 4.2

4.04.04 Carriage of dangerous goods in bulk or packaged form

In recognising the potential dangers associated with the carriage of Dangerous Cargoes, either in bulk

or packaged form, the Company requires that the Master and Officers exercise due diligence in the preparation for, and the carriage and discharge of such goods

The requirements of the following regulatory documents, as applicable to the particular cargo, are to

be complied with:

• SOLAS & MARPOL CONVENTIONS

• INTERNATIONAL MARITIME DANGEROUS GOODS CODE (IMDG)

• IMO CODE OF PRACTICE FOR SOLID BULK CARGOES

6

TMSA 1.1.a

Vessels are required to work in compliance with the onboard Garbage Management Plan In addition, the effects on the environment must be carefully considered, before disposing of cargo residues and other materials that are not covered by MARPOL

Incinerators, and other waste/garbage disposal and/or treatment equipment, must be maintained in full operational condition, and operated in accordance with the manufacturer’s instructions, and in compliance with applicable National and International regulations

Appropriate records are maintained

Ref: SHE Manual – Section 4.1.9 & Garbage Management Plan

4.04.06 Ballast water (including transfer of micro-organisms)

The Company recognises that the carriage and disposal of ballast water can significantly contribute to the transfer of species of aquatic organisms and water-borne pathogens, from their natural habitat

Vessels are to comply with the requirements of all mandatory schemes concerning the handling of ballast water, in accordance with the procedures detailed in the Ballast Water Management Plan

Care is taken to ensure specific local/regional requirements are additionally complied with

Ref: Marine Operations Manual – section 9.02 – Ballast Water Management Plan

4.04.07 Emissions to atmosphere

Recognising that emissions of exhaust gases and vapours may damage the environment, the Company uses its best endeavours to control such emissions in accordance with MARPOL Annex VI and all applicable regulations, and by promulgation of such information to employees and clients

The company maintains detailed procedures in this regard

Ref: SHE Manual – section 4.1.10

4.04.07.01 Cargo Vapours

The company endeavour to control by correct planning of all operations to minimise emissions of cargo vapours and/or inert gases These include those requirements covered by MARPOL Annexe VI

4.04.07.02 Engine Exhaust Emissions

The Company liaises with Owners to ensure their awareness of the need to supply fuel oils of the correct specification, including low sulphur content fuel, for the respective equipment, with a view towards minimising potentially harmful elements in the exhaust emissions and applicable regulations

Ref: SHE Manual, section 4.1.10

The Company uses its best endeavours to comply with regulations concerning noise level limits, in the operations both on board and ashore

4.04.08 Anti-fouling paint

Recognising the public concern over possible harmful effects of TBT (Tri-Butyl-Tin) on the marine environment, the Company will work with Owners of managed vessels toward eliminating the use of TBT coatings

This will be done by initially recommending to Owners the use of non-TBT coatings for underwater hull areas

All latest conventions/requirements are followed

4.05 Hazard Identification, Risk Assessment and Risk Control 1

The Company has established and maintains documented procedures for the identification of hazards, the assessment of risks, and the implementation of necessary control measures These procedures take into account; (But not limited to)

a) routine and non- routine activities2

b) Health & Hygiene risk where appropriate

c) Anticipated mooring arrangement and equipment to ensure Safety of personnel3

d) activities of all personnel having access to workplace (including contractors and visitors)

e) human behaviour, capabilities and other factors,

f) identified hazards originating outside vessel, capable of affecting the health and safety of persons onboard as well as onboard work activities which may create hazards in the vicinity of the vessel.(these may include environmental aspects)

g) facilities at the workplace, whether provided by the company or others

h) All other operational hazards covering safety, environmental, security impacts

The Company’s methodology for hazard identification and risk assessment:

a) is by its scope, nature and timing proactive rather than reactive;

b) provides for monitoring of physical hazards, inventorying hazardous materials and assessing human factors.4

c) Requires records of all valid/current assessments to be maintained onboard

Ref: Risk Assessment and Measurement of Change Manual

- Chapter 1 – section 1.4.6- Risk Assessment Process

f) provides input into the determination of facility requirements, identification of training needs and/or development of operational controls, and improving the operating procedures in the QHSE Management System.6

g) includes provision for assessing new or non-routine tasks

Ref: Risk Assessment and Management of Change Manual – Chapter 1 – Section 1.4.6 – Risk Assessment Process

The Company ensures that the results of these assessments and the effects of these controls ashore are considered when setting its OH&S objectives Records of all risk assessments and meetings are reviewed ashore and kept on file.7

Where required these are modified Relevant documents are reissued in part, or as a whole, if required, after each review.8

The Risk-assessment processes include response elements to limit the impact of any unplanned occurrences Contingency plans have been developed to facilitate Safe Management and recovery of such situations as described in company’s Contingency Manual.9

The company identifies best practices for common areas of risk assessment and ensures that these are shared across the fleet10

The company maintains a database of all ship-generated and shore-generated risk assessments

The Company has prescribed levels for the use of PPE appropriate to the work being undertaken and the

cargoes being carried by their vessels in support of Risk control measures.11

Ref: SHE Manual – App IX – PPE Matrix

The system includes permits for the control of any hot work on board the vessel, including requirements for office-management approval of hot work in identified hazardous areas Other permits, such as enclosed space entry, are also used – refer to ISGOTT.12

Ref: RAC & MOC Manual

The management of change process:

a) ensures that potential consequences of a change are identified, together with any required deduction measures14

Risk-b) clearly defines the level of authority required for the approval of a change

c) ensures changes are reviewed at the defined level of authority and, where new risks are identified, the adequacy of the risk-reduction measures, is authorised by a higher authority The appropriate level of approval required for different categories of change is based on the level of risk involved.15

d) ensures that changes if not carried out within the proposed time scale are reviewed and revalidated, and that temporary changes do not exceed the initial authorisation for scope or time without review and re-approval by the appropriate level of management.16

e) ensures that the documentation supporting a change includes the reason for the change, a clear understanding of the safety and environmental implications, and the appropriate level of approval Any change is approved by senior ships' management/responsible person and not by the person directly involved in the change The document includes reference to appropriate safety and environmental issues 17

f) identifies all personnel that may be affected by the change and ensures that those identified understand the extent and likely impact of any planned change.18

g) ensures that training needs arising from changes to equipment or procedures are identified and documented All appropriate personnel receive the required training within a specific period.19

h) links with, and ties into the document-control system, so that important controlled documentation remains

up to date.20

Ref: RA & MOC Manual – Chapter 2 - Section 2.4.5 MOC Process & Flow

Company Form No MOC 01

When organisational changes (changes in reporting relationships, elimination of positions, restructuring, etc), take place, the personnel responsible for supervising or managing the function(s) undergoing change are made responsible for clear and explicit reassignment of responsibilities to appropriate personnel. 21

Refer: RACI Office Organisation Responsibilities & Job Description, Competencies

There are documented staff handover procedures for both shore-based personnel and ships' crews The scope and depth of the handover process is relevant to the responsibilities of the personnel involved 22

Ref: QHSE Procedures – Personnel – Shore based – Familiarisation & Personnel, Selection & Recruitment Manual – Section 2.2 – Relief & Handovers

4.06 Legal and Other Requirements 1

The Company has established, implemented and maintains a documented procedure:

a) to identify and comply with mandatory rules and regulations applicable to both ship and shore- based operations;

Ref: SHE Manual Section 1.1

b) to identify and comply with applicable codes, guidelines and standards recommended by the IMO, Administrations, classification societies and maritime industry organizations; 2

Ref: SHE Manual Sections 1.1.3 & 1.1

c) for periodically evaluating compliance with applicable legal requirements and other requirements to which the Company subscribes Records of the results of the periodic evaluations are maintained

Ref: Form SHE Form 43

d) to determine how applicable legal requirements and other requirements to which the Company subscribes apply to its environmental aspects

Ref: EMS Manual Section 4.3.2

e) to ensure that applicable legal requirements and other requirements to which the Company subscribes are taken into account in establishing, implementing and maintaining its QHSE management system. 3

Ref: SHE Manual Section 1.1.3

f) that ensures all personnel involved in the Company’s QHSE Management System have an adequate understanding of relevant rules, regulations, codes and guidelines. 4

Ref: SHE Manual Section 1.1.3

g) For obtaining, reviewing5 and distribution of updates for relevant rules, regulations, codes and

guidelines

Ref: Policy Notes, Fleet Advisory, GSN , Circulars etc./ SHE Manual Section 1.5

The Company is aware of flag-state medical requirements and ensures these are complied with In the case of ship’s staff serving on chemical vessels, blood accumulations are checked The frequency of medical checks is clearly defined and complied with across the company to meet local legislation.6

Ref: Chemical Tanker Manual – Section 3.5