MASS UK Industry Conduct Principles and Code of Practice 2022 (V6)

6.8 ISM CODE CERTIFICATION
6.8.1 The International Safety Management Code (ISM Code), under Regulation 3 and 4, may have a requirement for
MASS to have a level of certification for safety. These may include:
6.10.2 The Operator should pay due adherence to the many and varied statutes, legislations, rules, regulations and
Codes of practice that apply to seafaring. Although the autonomous nature of the MASS operation may seem to
negate some requirements, it is the crewless aspect that should demand increased awareness. Any procedures
produced should pay particular attention to this detail, especially those systems and equipment procedures that
are required to avoid collision.
n Document of Compliance;
n Safety Management Certificate.
6.8.2 The provisions of this Code (Chapter 13) and the development and use of an SMS will assist the Operator in
showing compliance to the ISM Code certification requirements when appropriate.
6.10.3 The Operator should formulate and document procedures to ensure that safe working practices are carried out
in the operation of the MASS. These may be in the form of checklists, which can be followed by all personnel
irrespective of their location.
6.10.4 Simple procedures should be developed for the operation of the MASS. These should include, but not be limited to:
6.9 RISK ASSESSMENT
6.9.1 Hazard identification and risk assessment are key tools in identifying those potential hazards that the operation
and maintenance of the MASS may impart and the associated realisation of those hazards occurring.
6.9.2 The process for the risk assessment should be based on the techniques available in the following documents:
n Testing of equipment, including propulsion and steering gear, prior to commencing a passage;
n Navigation and handling of the MASS;
n Maintenance routines;
n Bunkering operations;
n Watertight/weathertight integrity;
n Stability of the MASS;
n Conduct of passengers and crew if utilised on board.
n ISO/IEC 31010. Risk Management – Risk Assessment techniques
n ISO/IEC 27005. Information Technology – Security techniques. Information security risk management.
6.10.5 Due to the autonomous nature of MASS operation the following areas should be considered on top of traditional
vessel operating procedures:
6.9.3 Therefore, a key duty of the Operator is to develop an effective Risk Assessment system. This will, through a logical
approach, systematically identify risks to personnel and the environment that the MASS could potentially influence.
6.9.4 Risk assessment system outputs will assist in the production of the MASS safe systems of work and operational
procedures.
6.9.5 Any Risk Assessment system should be simple to understand and implement such that Operators can carry out
effective risk assessments, taking into account any deviations from the perceived ‘normal’ operating envelope.
n Anti-Collision, crewless MASS and the ability to detect and avoid collision;
n Cyber Security, anti-hacking and vessel hijacking for remote operated MASS;
n Anti-Piracy, close protection, remote control etc;
n SOLAS Reg 14, Considerations pertaining to evidence of minimum manning level requirements;
n SOLAS Reg 33, Distress situations and how the Operator meets its obligations and responsibilities to other
mariners in distress.
6.11 CREWING REQUIREMENTS FOR LARGER SHIPS WHEN PILOTAGE IS REQUIRED
6.9.6 Further guidance can be sought in Chapter 1 of the Code of Safe Working Practices for Merchant Seafarers.
6.9.7 Where a MASS uses, transfers or holds bulk quantities of substances, materials or liquids that, in the event of a
spillage could constitute an environmental impact then the Operator is recommended to develop and implement
a MASS Oil Pollution Emergency Plan (MASSOPEP).
6.10 PROCEDURES TO ENSURE SAFE OPERATION OF MASS
6.10.1 The regulations and rules, not addressed by this Code, which apply to all MASS include, but are not limited to:
n The IMO Instruments;
n Local navigation rules;
n National health and safety regulations;
n The Code of Safe Working Practices for Merchant Seamen;
n All relevant national shipping or guidance notices.
6.11.1 For some MASS, it might be
appropriate to have permanently
exhibited information for pilots and
port authorities, e.g. at the RCC for
navigational items in the event of
platform manning and the need to
take local control. An example of the
ICS Vessel Pilot Card is at Figure 5-1.
6.11.2 Alternatively, in a smaller MASS, the
record could take any suitable form.
These could include a diary, as
distinct from a specially printed
logbook, or a shore/remote pick up
data-logger.
Figure 6-1 - Pilot Card
6.11.3 Whatever form the record takes, such entries should be accepted as evidence of compliance with the
Shore-Side, On Board, Remote Procedural requirements.
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