Section 15.2 Risk Assessment and Management for Bulk Carrier Operations

At the heart of the International Safety Management (ISM) Code and any effective Safety Management System (SMS) lies the principle of proactive risk management. Rather than simply reacting to accidents after they occur, the ISM Code mandates a systematic approach to identifying potential hazards, assessing the associated risks, and implementing control measures to eliminate or reduce these risks to an acceptable level. For bulk carrier operations, which involve handling large, heavy vessels, diverse and sometimes hazardous cargoes, and working in a dynamic and often challenging maritime environment, robust risk assessment and management are not just regulatory requirements; they are fundamental to preventing incidents, protecting lives, safeguarding the vessel and its cargo, and preserving the marine environment. The Master plays a pivotal role in leading and embedding this risk-based approach into the daily operational culture of the ship.

1. Understanding Key Terminology:

Hazard: A source or situation with the potential to cause harm in terms of human injury or ill-health, damage to property, damage to the environment, or a combination of these. (e.g., an open hatch, a slippery deck, a self-heating cargo, heavy weather).

Risk: The likelihood (or probability) that a specific hazard will actually cause harm, combined with the severity of that harm. Risk = Likelihood x Severity. (e.g., the risk of someone falling into an open hatch in a poorly lit area during rough seas is high).

Risk Assessment: The overall process of hazard identification, risk analysis (estimating likelihood and severity), and risk evaluation (deciding if the risk is tolerable or requires further control).

Risk Management: The systematic application of management policies, procedures, and practices to the tasks of identifying, analyzing, evaluating, controlling, and monitoring risk. It’s an ongoing, cyclical process.

ALARP (As Low As Reasonably Practicable): A principle often used in risk management, meaning that risks should be reduced to a level that is as low as reasonably practicable, considering the cost and effort of further reduction against the level of risk. If the cost of further reduction is grossly disproportionate to the benefit gained, the risk might be considered ALARP.

2. The Risk Assessment Process (A Cyclical Approach):

The ISM Code (Section 1.2.2.2) requires the SMS to “assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards.” This typically involves a five-step process:

Step 1: Hazard Identification:

Objective: To identify all potential hazards associated with a particular operation, task, piece of equipment, or area of the ship.

Methods:

Brainstorming: Involving experienced crew members from different departments.

Checklists: Using pre-defined checklists for common operations or areas.

Review of Past Incidents: Analyzing accident reports, near-miss reports, audit findings, and industry alerts.

Job Safety Analysis (JSA) / Task Risk Assessment (TRA): Breaking down a specific job into steps and identifying hazards at each step.

Walk-through Inspections: Systematically inspecting work areas.

Consulting Manuals and Regulations: Reviewing equipment manuals, IMSBC Code, SOLAS, MARPOL, etc., for known hazards.

Common Hazard Categories on Bulk Carriers:

Navigational: Collision, grounding, heavy weather damage, contact damage during berthing.

Cargo-Related: Liquefaction, self-heating, methane/toxic gas emission, dust explosion, cargo shifting, contamination, structural stress from improper loading.

Machinery: Engine failure, fire in engine room, electrical hazards, pump failures.

Occupational/Personnel: Slips/trips/falls, working at height, enclosed space entry, manual handling injuries, exposure to noise/vibration/chemicals, fatigue.

Mooring/Anchoring: Parting lines, snap-back, windlass/winch failures.

Environmental: Oil spills, garbage pollution, ballast water non-compliance, air pollution.

Security: Piracy, stowaways, unauthorized access.

Step 2: Risk Analysis (Who might be harmed and how? What is the likelihood and severity?):

Objective: To understand the nature of the risk associated with each identified hazard by estimating its likelihood and potential severity.

Likelihood (Probability): How frequently is the hazardous event expected to occur? This can be qualitative (e.g., frequent, probable, occasional, remote, improbable) or, in some cases, quantitative (based on historical data).

Severity (Consequences): What would be the impact if the hazardous event occurs? This is assessed in terms of:

People: Fatality, serious injury, minor injury.

Environment: Major pollution, moderate pollution, minor pollution.

Asset/Property: Total loss of vessel, major damage, moderate damage, minor damage.

Operations/Reputation: Significant disruption, loss of reputation, minor delays.

Risk Matrix: Companies typically use a risk matrix (e.g., a 3×3, 4×4, or 5×5 grid) that combines likelihood and severity scales to assign a risk level or score (e.g., Low, Medium, High, Intolerable; or numerical scores). This helps prioritize risks.

Example of a simple 3×3 Risk Matrix: | Likelihood | Severity: Minor | Severity: Moderate | Severity: Major | | :————- | :————– | :—————– | :————– | | Frequent | Medium | High | High | | Occasional | Low | Medium | High | | Remote | Low | Low | Medium |

Step 3: Risk Evaluation (Is the risk acceptable or does it need further control?):

Objective: To decide whether the assessed level of risk is tolerable or if further control measures are necessary to reduce it.

Tolerability Criteria: The company’s SMS should define what levels of risk are acceptable (e.g., risks assessed as “Low” might be acceptable with existing controls; “High” risks are unacceptable and require immediate action). The ALARP principle is often applied here.

Existing Controls: Consider the effectiveness of any control measures already in place.

Step 4: Risk Control (Implementing Safeguards / Control Measures):

Objective: To eliminate the hazard or reduce the risk to an acceptable level by implementing appropriate control measures.

Hierarchy of Controls (most effective to least effective):

Elimination: Physically remove the hazard (e.g., remove a hazardous substance from use). Often the most effective but not always possible.

Substitution: Replace the hazard with a less hazardous alternative (e.g., use a less toxic cleaning chemical).

Engineering Controls: Modify equipment or the work environment to reduce exposure to the hazard (e.g., install guards on machinery, improve ventilation systems, install a BWMS, design safer access).

Administrative Controls (Procedural Controls): Change the way people work (e.g., develop safe work procedures, provide training, implement checklists, use Permit to Work systems, install warning signs, limit exposure time).

Personal Protective Equipment (PPE): Provide and ensure use of PPE (e.g., hard hats, safety glasses, respirators, gloves, safety harnesses). This is considered the last line of defense, as it only protects the individual if the hazard is encountered, rather than preventing the hazard itself.

Selection of Controls: Choose controls that are effective, practical, and sustainable. A combination of controls is often necessary.

Implementation: Ensure the chosen control measures are properly implemented, and that personnel are trained in their use.

Step 5: Monitoring and Review:

Objective: To ensure that the implemented control measures are effective and that the risk assessment remains valid.

Monitoring: Regularly check that control measures are being used correctly and are working as intended.

Review: Risk assessments should be reviewed periodically (e.g., annually, or as defined in the SMS) and also specifically when:

There is a change in operations, equipment, procedures, or personnel.

New information about a hazard becomes available.

An accident or near-miss occurs (to see if the RA was adequate or if controls failed).

Audit findings recommend a review.

Continuous Improvement: The risk management process should feed back into the SMS to drive continuous improvement in safety performance.

3. Practical Application on Bulk Carriers:

Risk assessment is not just a theoretical exercise; it must be applied practically to all aspects of bulk carrier operations.

A. Generic Risk Assessments:

The company’s SMS will typically contain generic risk assessments for routine and critical shipboard operations, such as:

Navigation in open sea, coastal waters, and confined waters.

Anchoring and mooring operations.

Cargo loading and discharging (general principles, plus specific RAs for hazardous cargoes like Group A or B).

Ballast water operations.

Bunkering operations.

Enclosed space entry.

Hot work.

Working aloft or over the side.

Maintenance tasks on specific machinery.

These generic RAs identify common hazards and standard control measures. They should be reviewed by the ship’s crew for applicability to their specific vessel and current conditions.

B. Specific or Dynamic Risk Assessments (Often using JSA/TRA format):

For non-routine tasks, or when conditions differ significantly from those assumed in a generic RA, a specific risk assessment must be conducted before starting the work.

Toolbox Talks (TBT): A common way to conduct a quick, dynamic risk assessment at the worksite just before a job starts. The team involved discusses the task, identifies hazards, and agrees on control measures. This is often documented on a simple TBT form.

Job Safety Analysis (JSA) / Task Risk Assessment (TRA): A more formal process of breaking down a job into steps, identifying hazards and existing controls for each step, assessing the risk, and implementing further controls if needed. Often documented on a specific JSA/TRA form.

C. Integrating Risk Assessment into Daily Culture:

The aim is for risk assessment to become a natural part of how all crew members think about their work – “Stop, Think, Identify Hazards, Control Risks, Proceed Safely.”

Encourage reporting of hazards and near misses, as this provides valuable input for risk assessments.

4. The Master’s Role in Leading Risk Management Onboard:

The Master is the key figure in ensuring that risk assessment and management are effectively implemented on the vessel.

Championing the Process: Lead by example and demonstrate a strong personal commitment to risk management.

Ensuring Understanding and Competence: Verify that officers and crew understand the principles of risk assessment and are competent in applying them to their work. Provide or arrange for training as needed.

Facilitating and Reviewing Risk Assessments:

Ensure that risk assessments are conducted for all relevant operations and tasks.

Review significant risk assessments (e.g., for critical cargo operations, non-routine hazardous tasks) to ensure they are thorough and that proposed control measures are adequate.

Ensure that generic RAs in the SMS are reviewed periodically by the ship’s safety committee or relevant personnel and that feedback is provided to the company.

Resource Allocation: Ensure that necessary resources (time, personnel, equipment, PPE) are available to implement risk control measures.

Decision Making Based on Risk: Use the results of risk assessments to make informed operational decisions. For example:

Deciding whether to proceed with an operation in adverse weather or with marginal equipment.

Determining the level of supervision required for a particular task.

Prioritizing maintenance tasks based on risk.

Monitoring Effectiveness: Oversee the monitoring of control measures and ensure that the risk management process is leading to tangible improvements in safety.

Fostering a Reporting Culture: Encourage open reporting of hazards, near misses, and incidents without fear of blame, as this is essential for learning and improving risk assessments.

Final Authority on Risk Acceptability: The Master has the ultimate authority to decide whether a risk is acceptable or whether an operation should be stopped or modified if safety is compromised.

5. Challenges to Effective Risk Management:

Complacency: Treating risk assessment as a “tick-box” or paperwork exercise rather than a genuine safety tool.

“Normalization of Deviance”: Becoming accustomed to minor deviations from procedures, which can erode safety margins.

Time Pressure: Perceived or actual pressure to complete tasks quickly can lead to shortcuts in risk assessment or implementation of controls.

Lack of Resources or Training: Insufficient training for crew, or lack of necessary equipment/PPE.

Poor Hazard Identification: Overlooking less obvious hazards.

Subjectivity in Assessment: Different individuals may assess likelihood or severity differently. Using a standardized risk matrix and team discussions can help mitigate this.

Failure to Implement or Maintain Controls: Identifying controls is not enough; they must be put in place and kept effective.

Lack of Follow-up: Not reviewing risk assessments after incidents or changes.

Effective risk assessment and management are not optional extras; they are fundamental to the ISM Code’s goal of creating a safer maritime industry. For the Master of a bulk carrier, fostering a robust risk-aware culture and ensuring that this systematic process is diligently applied to all operations is a critical leadership responsibility, directly contributing to the prevention of accidents and the protection of life, property, and the environment.