ISM Code and Risk Management

December 2012 – Grounding of MODU KULLUK in Alaska (courtesy of nytimes.com)

On December 31, 2012, the Noble Drilling-operated Mobile Offshore Drilling Unit (MODU) KULLUK went aground on the eastern coast of Sitkalidak Island, Alaska. Amid winds as high as 50 miles per hour and seas as high as 18 feet, 18-member crew had to be rescued by the U.S. Coast Guard (USCG). The USCG and the National Transportation Safety Board (NTSB) investigated the casualty. The USCG determined the most significant factor being the inadequate assessment and management of risks associated with a complex vessel movement during the winter in the unique and challenging operating environment of Alaska. The NTSB concurred with the USCG that the inadequate assessment of the risk for the planned tow resulted in implementation of a tow plan insufficient to mitigate that risk.

August 2016 – Grounding of TRANSOCEAN WINNER in western Scotland
(courtesy of bbc.com)

Almost four years later, we saw similar images of Coast Guard helicopter flying over the TRANSOCEAN WINNER, which was grounded in western Scotland. The casualty released approximately 12,000 gallons of diesel oil into the ocean. The UK Marine Accident Investigation Branch (MAIB) investigation into the grounding highlighted the lack of a contingency plan.

Both vessel operators are required to comply with the International Safety Management (ISM) Code. Section 1.2.2.2 requires a company to assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards. Inadequate assessment and management of risks would be considered a Major Non-conformity under the Code. Per Section 13.5, this may result in the issuing government’s withdrawal of the company’s Document of Compliance, i.e., its ISM-compliant vessels can no longer operate until the identified discrepancies are corrected.

Meridian.us has certified and experienced ISM Code Lead Auditors, who can assist your company with their internal audits and management review. For additional information, please contact Captain Hung Nguyen at (808) 282-4981 or hnguyen@meridian.us.

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