I attended a seminar in March where the fleet manager for a large brokerage house warned the captains and managers in the room that the International Safety Management Code (ISM) rules were coming down to yachts as small as 300 tons, that surveyors were following ISM guidelines in doing their inspections, and that more and more of the industry will be tasked with following some sort of ISM on their vessels, no matter if they are private or charter, large or small.
Still, a majority of the world’s yachts are smaller than 500 tons (even smaller than 300 tons) and in private use, making them exempt from these regulations under most flags. I wondered how common safety management plans are on yachts today, so we surveyed yacht captains to find out.
More than 60 captains responded, about half of whom are on vessels less than 300 tons. About 30 percent are on vessels 300-500 tons, and 23 percent are on vessels larger than 500 tons. Also, 60 percent are on vessels that are strictly private, with a quarter that are predominantly private but available for charter. Just one respondent was on a strictly charter vessel with no owner use; that vessel is 300-500 tons.
We began simply by asking Have you implemented an ISM or mini-ISM program on your yacht?
Slightly more than half — 53 percent — have not. Among the rest, 27 percent have the mini-ISM and 20 percent have full ISM. A majority of those who have some sort of safety management program onboard are on vessels over 300 tons (38 percent on vessels 300-500 tons; 38 percent on vessels over 500 tons).
Still, about a quarter of our respondents who said they have some sort of ISM plan onboard run vessels less than 300 tons.
We’ll begin with the majority. We asked those captains who do not have a safety management plan in place on their yachts, Do you have procedures for things like departure, arrival, anchoring/mooring and bunkering?
About three-quarters do. More than 40 percent said their procedures are informal and not written down; basically the procedures they use to train their crew. Slightly more than a third have more formal, written types of procedures that crew are trained to.
About a quarter have no procedures.
We also asked those without a safety management plan onboard Do you expect that your vessel will adopt an ISM plan eventually? More than three-quarters said no.
“Not unless we have to,” said the captain of a strictly private yacht under 300 tons. “Too small a boat for all this stuff. Then again, with government departments getting bigger and bigger, who knows.”
“I feel that my in-house procedures are adequate,” said a captain in yachting more than 20 years who runs a strictly private yacht less than 300 tons.
Yet a handful of our respondents noted that while they do not yet operate a safety management program, they expect to implement one soon.
“It’s coming,” said the captain of a strictly private yacht 300-500 tons. “More importantly, though, the safety culture of ISM is good and beneficial to all on yachts, from owners to crew.”
“Only to stay ahead of the game,” said the captain of a strictly private yacht less than 300 tons.
“ISM can be a burden to follow, which is why it must be kept simple,” said the captain of a strictly charter yacht 300-500 tons who expects to implement it eventually. “But if followed and policies and procedures are in place, it will make a more efficient and safe operation. When ISM is first implemented on a vessel, it is difficult to get the crew to follow the policies and procedures. Changing a safety culture on a vessel that never implemented much on safety finds the ISM extremely difficult to adapt. But once it is, the operation runs much better. The downfall is paperwork, which is why the ISM must be kept simple.”
Among those captains who did run yachts with a safety management program — 47 percent of our respondents — we turned our next questions to those with mini-ISM, 27 percent of respondents. Since on many yachts it is not required (neither by law, nor by flag), we wondered How do you follow it?
The largest group — 47 percent — follow it fully, noting that it was useful to implement and reviewed regularly.
The next largest group — 35 percent — follow it partially, noting that it was good to implement, but it hasn’t been used much since.
About 12 percent note that they follow it more than required, including completing checklists and reports even though they aren’t required.
Just one respondent said the program isn’t followed at all.
We wondered, too, if it made a difference, so we asked How does it work for you?
The largest group, almost half, said having a mini-ISM is basically what they were doing anyway, just making it more official.
“We follow the mini-ISM guidelines, but not to a T,” said the captain of a strictly private yacht less than 300 tons. “We don’t write the reports, but we basically follow the structure and implement and record everything that we do, defects log, futures repairs/shipyard lists, safety inspections monthly, etc.
“I feel we are doing a good job of keeping up on the systems and practices of the yacht with the crew complement that we have, along with our normal daily maintenance and duties,” this captain said.
“The yacht is 299 GRT; flag state required us to have mini ISM in place and operational,” said a captain who runs a yacht less than 300 tons with a mix of charter and owner use. “It was a lot of work to get it set up and running without shore-based help. We passed Cayman Island survey the first time and only had to modify the system slightly. It was well received by crew and I believe it was beneficial to all, but it’s hard to keep up and running with such a small crew (seven) on a very busy boat.”
About 30 percent said mini-ISM was too nit-picky for their tastes.
“We need one person to spend hours a day filling out forms for stupid things like anchoring and passage plans that are supposed to make us safe,” said the captain of a yacht 300-500 tons that is a mix of private and charter use. “This adds so many work hours to a work week, and then the MLC comes along and now we have to spend another day each week filling in more forms that make sure we don’t work too many hours?
“Yachting is too much like government work now,” this captain said. “It used to be about crew members traveling and seeing things while making money along the way. I feel like the safety stuff is too much most of the time. Of course, I didn’t wear a seatbelt or a bike helmet when I was growing up either. In fact, we rode in the back of the pickup truck — standing up — most of the time.”
“Safety and drills are good practice and we generally agree with them, but the one-size-fits-all approach to the regs, especially with regard to rescue boat drills, is unrealistic on yachts of our size,” said the captain of a yacht 300-500 tons that is predominantly private. “As with most government regulation, the move toward even more rules and procedures will overrun our ability to remain in compliance. I believe that yachts of less than nine or 10 crew, where everyone plays multiple roles in operations as well as hospitality, will find it impossible to do it all.”
A quarter of these respondents with mini-ISM plans said theirs was useful, practical and appropriately serious.
We asked this group of captains, too, Do you have checklists for things like departure, arrival, anchoring/mooring and bunkering? These answers broke down exactly as those from captain who do not have an ISM program onboard. Basically, three-quarters have these procedures in some form or another. Half said they were the official, printed out checklists ISM requires.
About 30 percent said “sort of”, that their procedures are available for crew to view when needed but they weren’t checklists that need to be filled out.
“Our checklists are laminated and used as a guide,” said the captain of predominantly private yacht 300-500 tons. “We do not fill out a separate one each time.”
About 20 percent said “not really,” that their official procedures are part of the plan but they aren’t looked at much.
Just one respondent said they don’t have these checklists.
A big part of full ISM is the paperwork, so we wondered if mini-ISM yachts had a similar issue, so we asked How does having the plan impact your crew?
Almost all respondents said the plan has some impact, noting that it took time to create and implement, but once in place, it has become routine.
One respondent said there was not much impact. None of our respondents chose “a lot”.
And finally, we asked Have you found mini-ISM difficult to follow, time consuming or unreasonable in its requirements?
Slightly more than half said no.
“The paperwork is onerous and difficult to achieve high standards on a busy yacht,” said the captain of a strictly private yacht 300-500 tons that is working on an ISM plan. “However, all of us can see the advantages so we make our best effort to comply with it in its entirety.”
Among those captains who run vessels with full ISM, we asked How do you handle the additional workload?
Two-thirds said they manage it fine, that either they aren’t that busy or the yacht operates with rotations to get it all done while still complying with hours of work and rest.
“If you are organized and you plan your filing system, you can do this no problem,” said the captain of a strictly private yacht over 500 tons. “Since reaching this size, I have always had ISM or mini-ISM and never had an issue. It’s just a fact of life at sea.”
“We are busy and most crew don’t have a rotation but we have learned how to handle the bureaucracy,” said the captain of a strictly private yacht larger than 500 tons.
“The first officer, along with assistance from the second officer, looks after the ISM/ISPS,” said the captain of a predominantly charter yacht over 500 tons.
A quarter of respondents said full ISM is a struggle juggling crew and duties, and noted that some things get missed. Just one of our respondents on a full-ISM yacht said the crew cannot keep up with the workload completely.
We asked them, too, Have you found full ISM difficult to follow, time consuming or unreasonable in its requirements?
Exactly half said yes, half said no.
“I am fortunate to have enough crew to allow me a dedicated first officer who pretty much does nothing but ISM,” said the captain of a predominantly private yacht larger than 500 tons who answered yes. “Everything gets accomplished and we are constantly on top of changes and all parameters of completion. I pity the smaller vessels that do not have enough crew to dedicate one person to this job. It is unbelievable the amount of time it takes; how a captain is supposed to accomplish this on his own and run his vessel is beyond me.”
We asked all captains on boats with safety management programs Has anyone ever asked to see it or check that it’s being followed?
The most common authority to ask about the plan were flag state inspectors, with whom two-thirds of our respondents interacted.
The next most common authority to ask (by 45 percent of our respondents) were surveyors, followed closed (by 38 percent of respondents) by port state control officers.
“Every large vessel should keep up with all the bureaucracies so as to maintain a record of compliance for if and when the vessel sells,” said the captain of a strictly private yacht over 500 tons running full ISM.
A quarter of our respondents said no one had ever asked to see their plan.
But about 14 percent of respondents said the owner checked up on it, and one captain said a lawyer did.
“Smaller yacht captains need to get on-the- ball about how they approach this issue,” said a captain in yachting more than 30 years. “If the owner or other authority is not checking what they do then, most often, nothing will be done.”
We neglected to offer yacht managers or designated person ashore as options in the list, which 15 percent of respondents mentioned.
We were curious to know Who decided the yacht should have a safety management program?
The largest group — 48 percent — said the law requires ISM or mini-ISM on their vessel because of flag and tonnage.
The next largest group — 28 percent — said the captains themselves decided it.
Fourteen percent said it was the manager; and 7 percent said it was some combination of all the above. Just one owner requires it on their vessel.
We asked all our respondents — those who have a safety management plan as well as those who do not — if they believed ISM and mini-ISM brings a change of culture onboard, that everyone becomes more safety conscious.
Almost two-thirds thought it did.
“Yes,” said a captain in yachting more than 20 years. “Every effort to make crew aware of safety and how to respond in emergency or critical situations is positive and useful, way beyond the initial difficulties to accept the implementation and the paperwork that goes with it. Once crew understand that it’s just a tool beneficial for their own good and that make them more professional, in my experience they do stick to it.”
“It also forces everyone to take (at least) minimal steps to actually be more safe,” said a captain in yachting more than 20 years who runs a yacht with full ISM.
“I have had crew leave an ISM culture and join a smaller boat without, let standards slip because of lack of safety culture, and end up in serious accidents,” said a captain in yachting more than 25 years who runs a yacht with full ISM. “One guy ended up in a coma after a fall from washing overboard without a harness.”
“It tends to make crew more aware of the practices and operations of the yacht,” said a captain in yachting more than 10 years who runs a vessel less than 300 tons with mini-ISM. “More crew have become safety conscious and appreciate the efforts put forth into making it that way as well as being a part of the process. It breeds accountability and not finger pointing if something is not working or properly maintained.”
About a quarter didn’t agree.
“Safety is something that you live by because you recognize its importance,” said a captain in yachting more than 25 years with no safety management program onboard. “ISM is a set of rules that you must follow at time of inspection. If you don’t live by those principles every day, inspection or not, you will eventually pay for it. The requirements of ISM may be valid issues but the idea that just because it is a rule people will always follow it is not true.”
“We were already safety conscious and have procedures for everything,” said the captain of a yacht over 500 tons who said his vessel does not run a safety management program.
“I think it’s mostly a waste of time, but the younger crew members seem to take to it very easily because they have grown up in an environment that is always fearful,” said a captain in yachting more than 20 years who runs a yacht with mini-ISM. “If we don’t hold safety meetings, they get a little worried.”
“Safety is already drilled on our vessel,” said a captain in yachting more than 30 years who runs a private yacht less than 300 tons without an ISM program. “A piece of paper saying we’re safe isn’t going to make it so.”
And there were a handful of respondents who said “it depends”.
“Only if there was a lack of safety awareness beforehand,” said a captain in yachting more than 10 years. “ISM and other safety requirements are all derived from accidents that have happened and are responses to them. If you have a lax safety attitude on board, ISM was written for you.”
Lucy Chabot Reed is editor of The Triton. Comments on this survey are welcome at firstname.lastname@example.org. We conduct our monthly surveys online. All captains and crew members are welcome to participate. If you haven’t been invited to take our surveys and would like to be, e-mail email@example.com to be added.