1. Key Clauses Required for Obtaining an Interim DOC

An Interim Document of Compliance (DOC) is issued under Clause 14.1 of the International Safety Management (ISM) Code. It is granted to facilitate the initial implementation of the ISM Code when:

• a shipping company is newly established, or
• a company holding a DOC adds a new ship type to its existing DOC.

For obtaining an Interim DOC, the company is not required to prove a long history of full onboard implementation of the Safety Management System (SMS). However, it must demonstrate that:

• its SMS meets the core objectives of the ISM Code, and
• it has a concrete plan to fully implement the system within 12 months.

The important clauses that must be complied with are as follows:

Clause 1 – General (Objectives and Functional Requirements)

Clause 1.2 – Objectives

The company must clearly establish safety management objectives to ensure:

• safety at sea,
• prevention of human injury or loss of life, and
• avoidance of damage to the marine environment.

Clause 1.4 – Functional Requirements

The company must show that its drafted SMS includes the essential elements of the ISM Code, such as:

• a safety and environmental protection policy,
• instructions and procedures for safe operation of ships,
• defined lines of communication between ship and shore personnel,
• procedures for reporting accidents and non-conformities, and
• procedures for emergency preparedness and response.

Clause 2 – Safety and Environmental Protection Policy

The company must have a formally documented safety and environmental protection policy, approved by senior management.

This policy should clearly state how the company will achieve its safety and environmental goals and must show that safety and pollution prevention take priority over commercial pressure.

Clause 3 – Company Responsibilities and Authority

The company must clearly define and document the responsibilities and authority of all persons involved in safety management.

This includes:

• identifying who is responsible for what,
• defining the responsibility, authority and interrelationship of all personnel who manage, perform and verify work related to safety and pollution prevention.

If the company operating the ship is not the owner, the shipowner must report the full details of the operator to the Flag Administration.

Clause 4 – Designated Person Ashore (DPA)

To maintain a proper link between ship and shore, the company must appoint a Designated Person Ashore (DPA).

For an Interim DOC, the company must demonstrate that the DPA is:

• properly appointed,
• qualified and competent,
• given direct access to the highest level of management, and
• provided with adequate authority and resources to monitor the safety and pollution-prevention aspects of each ship.

Clause 5 – Master’s Responsibility and Authority

The SMS documentation must clearly define the Master’s role, responsibility and authority.

Most importantly, it must state that the Master has:

• overriding authority to make decisions concerning safety and pollution prevention, and
• the authority to request the company’s assistance whenever necessary.

2. Responsibility of the Second Engineer for Satisfactory Implementation of SMS on Board

The Second Engineer is a management-level officer and the executive head of the engine department under the Chief Engineer. He plays a very important role in the effective implementation of the Safety Management System (SMS) on board, especially in the engine department.

His responsibilities include the following:

A. Familiarization, Manning and Training (Clause 6)

The Second Engineer must ensure that all engine room personnel, including junior engineers, motormen, oilers, wipers and ratings, are properly familiarized with:

• their duties under the SMS,
• the engine room layout,
• safe working procedures, and
• emergency procedures.

He must ensure that:

• newly joined personnel are properly familiarized before being assigned important duties,
• junior engineers and ratings understand SMS instructions, safety precautions and machinery operating procedures, and
• all required training sessions and drills are carried out.

B. Safe Engine Room Operations and Safety Leadership (Clause 7)

The Second Engineer is responsible for supervising the day-to-day operation of the engine room and ensuring that all work is carried out in accordance with the SMS procedures, checklists and permit-to-work system.

This includes ensuring compliance during jobs such as:

• fuel oil transfer,
• hot work,
• enclosed space entry, and
• working aloft.

He must also:

• conduct pre-work safety briefings/toolbox meetings,
• ensure all engine room personnel understand the job hazards, permit requirements and precautions, and
• conduct and document risk assessments for routine and non-routine tasks before work begins.

C. Emergency Preparedness (Clause 8)

The Second Engineer plays an active role in preparing the engine department for emergencies.

His duties include:

• organizing and participating in engine room emergency drills, such as:
  • engine room flooding,
  • fire in the scavenge space or purifier room,
  • steering gear failure,
  • blackout, etc.

  He must ensure that engine room staff are familiar with:

  • their duties during emergencies,
  • emergency escape routes,
  • operation of quick-closing valves,
  • remote trips, and
  • emergency procedures laid down in the SMS.

  He must also ensure proper readiness and testing of emergency systems such as:

  • emergency generator,
  • emergency fire pump, and
  • other emergency equipment related to the engine department.

  D. Reporting of Non-Conformities, Accidents and Hazardous Occurrences (Clause 9)

  The Second Engineer must identify and report:

  • non-conformities,
  • accidents,
  • near misses, and
  • hazardous occurrences.

  These should be reported to the Chief Engineer for entry into the ship’s SMS reporting system and communication to the company/DPA where required.

  He should also:

  • take immediate corrective action to control unsafe conditions, and
  • assist in investigating the root cause of incidents so that recurrence can be prevented.

  E. Maintenance of Ship and Equipment / Planned Maintenance System (Clause 10)

  The Second Engineer is one of the key officers responsible for implementation of the Planned Maintenance System (PMS) in the engine department.

  He must manage and monitor maintenance of:

  • main engine,
  • auxiliary engines/generators,
  • boilers,
  • steering gear, and
  • other critical machinery and equipment.

  He must ensure that:

  • maintenance is carried out at the scheduled intervals,
  • all maintenance is done according to SMS procedures,
  • defects affecting safety are identified, prioritized and rectified without delay, and
  • technical non-conformities are avoided.

  He is also responsible for inspection and testing of important emergency and safety-related equipment in engine spaces, such as:

  • fire-fighting appliances (FFA),
  • life-saving appliances (LSA) related to the engine department,
  • emergency generator, and
  • emergency fire pump.

  F. Environmental Protection and MARPOL Compliance

  The Second Engineer has an important role in ensuring pollution prevention and environmental compliance in the engine room. In many ships, he may also function as the Environmental Officer.

  He must ensure compliance with:

  • MARPOL regulations, and
  • Shipboard Oil Pollution Emergency Plan (SOPEP) requirements.

  His duties include supervising:

  • operation of the Oily Water Separator (OWS),
  • bilge and sludge transfer operations, and
  • pollution-prevention practices in machinery spaces.

  He must also ensure that relevant records are accurately maintained, especially:

  • Oil Record Book (ORB / ORB Part I),
  • engine room logbooks, and
  • work and rest hour records.

  These records provide objective evidence during internal and external audits.