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ISM, ISPS & MLC 2006 Compliance

Anyone who has boarded one of today’s superyachts will understand the crucial role safety and the prevention of pollution play in its smooth operation. Camper & Nicholsons knowledge and understanding of the ISM, ISPS & MLC 2006 Convention and its application are the very important part of our service.

ISM - International Safety Management

In 2001, the ISM Code became mandatory for commercial yachts over 500 GT. This Code requires the management company to be responsible for its implementation and maintenance. The clear objective being to ensure safety at sea, prevention of human injury or loss of life, and avoidance of damage to the environment and property.

To enable Camper & Nicholsons to fulfil its obligations under the Code, we have developed and maintained a Safety Management System (SMS). This working tool, contains all the required sections of the Code, for instance, correct manning, master’s standing orders, reporting accidents and non-conformities, responding to emergencies, frequency of emergency drills, lines of communication between the yacht and the managers, reporting on technical maintenance, conducting risk assessments for shipboard operations, schedule of internal audits etc.

Our SMS is approved by the relevant Flag States under which the yachts operate, which then issue a Document of Compliance (DOC) authorising Camper & Nicholsons to operate the ISM system. A key individual required by the ISM Code is the Designated Person Ashore (DPA). It is the responsibility of Camper & Nicholsons to appoint a DPA whose purpose is to provide a direct link between the yacht and the highest level of management within the company. In addition, to monitor the safety and pollution prevention aspects of the yachts and to make sure that adequate resources and shore-based support are provided.  

In addition to the DPA, we appoint a fleet manager or technical superintendent to each yacht under our management. These personnel deal with the daily ISM related work which includes: reviewing safety meetings, monthly maintence reports, dealing with defect reports and providing solutions, assisting with manning issues, assuring crew records and qualifications are in order, responding to emergencies etc.

A requirement of the ISM Code is that the yacht and the company are audited for compliance. To facilitate this, Camper & Nicholsons conducts an annual internal audit on board which is conducted by the fleet manager to assess the level of compliance with the SMS. The Flag State also carries out an external annual audit. TheFlag State audit Camper & Nicholsons to assess our compliance to the ISM, this is required to maintain our DOC. Audits are a beneficial exercise for both parties, providing an opportunity to raise the level of awareness and interest in safety management for all concerned.

ISPS - International Ship & Port Security

ISPS became mandatory for Commercial yachts over 500 GT in 2004. The objective of the Code is to detect security threats and to implement measures to prevent incidents affecting yachts or port facilities.
To comply, Camper & Nicholsons has to appoint a company security officer and the yacht appoints a ship security officer, a member of the crew. Both appointments require the individual to receive appropriate training approved by the Flag State. A Ship Security Plan is also required. The yacht is assessed and the Plan prepared by the company is submitted to the Flag State for approval. This assessment follows guidance within the Code, but in general, considers the physical and structural security of the yacht, personnel protection systems, procedural polices, communications and areas on board that if compromised pose a risk to personnel on board, the yacht or operations.

On a practical point, the ISPS process includes the control of persons having access to the yacht, understanding what is being embarked on board in way of goods and materials. Awareness of port surroundings, controlling access to restricted areas on board, reacting and adjusting to security levels set by the Flag State or Port Authority. Record keeping of who has been on board, schedule of training drills, testing of shipboard alert systems, records of guest baggage checked, a search for a stowaway or a desk top exercise for a suspected bomb.

As a company, we also appoint a Recognised Security Organisation as a first point of contact in the event the SSAS (Ship Security Alert System) is activated, to assist with drills, assess a serious threat, or indeed assist and support an actual incident. This organisation carries out quarterly checks on the SSAS aboard each yacht in conjunction with Camper & Nicholsons.
The ISPS is subject to audit for the level of compliance on board, these audits are carried out at the same time as the ISM.

MLC 2006 (Marine labour Convention 2006)

This convention implemented in 2011 has effectively consolidated nearly 70 other conventions relating to the employment of seafarers and their conditions of employment.
The objective of the MLC 2006, which is complementary to the ISM and other international conventions, is to provide minimum requirements for the working and living conditions for seafarers. It is safe to state that a well found and operated superyacht will exceed most of these requirements. The main parts of the convention are the minimum requirements for seafarers to work on a ship, conditions of employment, accommodation, recreational facilities, food and catering, health protection, medical care, welfare and social security protection, compliance and enforcement. 
Camper & Nicholsons ensure that all crew are provided with SEA (Seafarers Employment Agreements) issued by the employer. The SEA is a comprehensive document, including the name and details of the employer and ship owner, all details of the crew, confirm payment of wages, job title and principle duties, entitlement to food and accommodation, duration and terms of termination, minimum hours of rest, entitlement to leave, repatriation, medical care on board, medical insurance, sick leave, disciplinary rules and procedures, complaints procedure, drug and alcohol policy, employer’s confidentiality policy, training policies and jurisdiction etc.
In addition to the SEA, Camper & Nicholsons makes a declaration in the form of a DMLC II (Declaration Maritime Labour Convention) to the Flag State of the yacht. This, in conjunction with the Maritime Labour Certificate, are statutory certificates in place to demonstrate compliance with the MLC 2006 Convention. The MLC 2006 is also incorporated in the auditing process along with the ISM and ISPS
The above comments are a brief synopsis of the ISM/ISPS & MLC 2006 codes all of which are comprehensive. If more detailed information relating to these codes is required, please contact the yacht management department at Camper & Nicholsons who can provide expert guidance and advice.
Apart from mandatory application; these codes should not be seen as an add-on to the day-to-day life of the yacht, but as a culture of safe and sound professional operation, safe guarding life, environment and property.
Camper & Nicholsons are fully committed to upholding these Codes of Practice. 

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