Procedural Compliance

Achieving compliance with the increasing number of procedures is a major problem for many seafarers and equally so for the ship operators who produce them and are required to monitor and enforce their application.

The traditional seafarer typically used acquired skills and experience based on the standards and practices of their peers and workgroup. He had little else to guide him. His modern equivalent, whilst still basically adopting this approach, is however much more driven by formalised procedures and checklists.

Over the last 20 years, legislation including ISM has resulted in a proliferation of formalised procedures throughout all areas of seafaring. Experience has shown, however, that the formalisation of procedures and the introduction of numerous checklists for all aspects of marine operations have not been the universal panacea in terms of reducing incidents and near misses.

Indeed the use of checklists often brings with it tunnel vision which can inhibit the seafarer’s traditional talent for “thinking outside the box”. The proliferation of (often highly detailed) procedures and the accompanying paperwork places tremendous demands on the modern seafarer, in terms of both understanding (i.e. learning) and application.

In some cases, individual procedures may appear perfectly sound and workable, however when all these individual procedures are put together, they may conflict or there may simply not be enough hours in the day to implement them all; this is particularly the case where procedures have been produced in a reactive way (e.g. in response to incidents) or are over-detailed. The problem of conflict is compounded where company procedures overlap but do not exactly duplicate industry standard guidelines, such as the Bridge Procedures Guide or ISGOTT.

The seafarer can be placed in a position where he has to work excessive hours, resulting in fatigue and/or has to prioritise which procedures to implement – or to put it more bluntly – chose which procedures he has to ignore.

Developing commitment to procedural compliance

It is generally true that people will follow procedures which they value – i.e. those which they consider necessary or desirable: Away from the scrutiny of a superior or an auditor, they will frequently ignore (or pay only ‘lip-service’ to) those which they do not value or for which they can see no clear rationale. Supporting paperwork is no guarantee that a task has actually been done. Gaining procedural compliance therefore requires commitment to developing usable and relevant procedures and raising awareness of the importance and value of procedures as a primary safety defence.

Logically, this cannot be done if the procedures are not seen as reflecting the demands of real operating conditions and are not perceived as demonstrably of value – both to personnel engaged in the task and to the overall process. Major prerequisites to obtaining procedural compliance are therefore to ensure that all procedures have been developed with the collaboration and involvement of those with the appropriate operating knowledge and experience and that all procedures actually have demonstrable value.

When reviewing procedures, factors which determine whether procedures are perceived as valuable include:
· How much safer does this make the task?
· How much easier does this make the task?
· How much quicker does this make the task?

Factors which determine whether procedures are likely to be complied with include:
· The perceived value of the procedure (as above)
· The time available
· The availability of proper or necessary resources (e.g. tools, manpower, etc)
· The likelihood of detection of non-compliance and consequent punishment
· The ease with which non-compliance can be concealed (e.g. how easy it is to fabricate false records, etc)

In fact latent conditions for procedural compliance are all set at management level in the production of quality systems and procedures, and the commitment to safety, as demonstrated by expenditure on training, equipment, recruitment of quality personnel, etc

The ‘body language’ of management personnel is also highly important. This includes, (publicised) support for difficult decisions where safety has been put first and the resolve to take effective disciplinary action where safety has been wilfully or recklessly compromised.

Understanding these elements is a major factor in reviewing and successfully identifying improvements to shipboard procedures. Our on-board assessments are carried out by Consultants who are familiar with these concepts and from a standpoint which is both knowledgeable about and sympathetic to the problems of both management and the seafarer. Much of our Consultant’s time is therefore spent in education of sea staff on the reasons for and the value of procedures – from a position of experience.

By adopting a holistic approach to safety we believe we have a much better chance of making a real difference – and one which is more likely to be followed and handed on, long after we have left the vessel.