Discuss the following with respect to the International Safety Management (ISM) Code.

Section 8 of the ISM Code requires the Company to establish procedures to identify, develop and plan responses to all foreseeable emergency situations on board (fire, collision, grounding, flooding, cargo shifting, fatigue, power failure, pollution, man-overboard, abandoning ship, piracy etc.). It must establish programmes of drills and exercises to prepare personnel to respond to these emergencies, and should test the plans and identify weaknesses. The SMS should:

• Identify possible emergency scenarios and allocate duties (through the muster list, emergency response procedures).
• Provide that crew are trained and drilled so they can operate emergency equipment (lifeboats, firefighting, CO2, life rafts, emergency generator, radio/DSC), as required by SOLAS and STCW.
• Carry out regular drills (monthly fire and abandon-ship drills, and in port within 24 hours as appropriate).
• Exercise the emergency procedures including alarm signals and making the ship ready, and document the drills and their results. Training and drills must be integrated with familiarisation and must be evaluated and improve continuously.

Section 9 of the ISM Code: the Company should establish and maintain procedures to report, investigate, and evaluate the risks of non-conformities, accidents and hazardous occurrences. Procedures should include:

• A clear process for reporting any near miss, non-conformity, accident, incident or hazardous occurrence, without fear of blame (a "just culture"/non-punitive reporting).
• Each such event is to be investigated to establish the root/contributory causes.
• Corrective and preventive action is taken and its effectiveness is verified.
• Findings are communicated and the SMS is improved; the database of these reports is maintained so trends (recurring issues) can be identified.
• Major non-conformities may require reporting to the flag Administration and the company on shore.
• The reports and records (near miss register, incident reports, corrective action records) are audited by the company's internal audits and by external/statutory auditors (SMC audit).

Section 7 of the ISM Code introduces a risk assessment-based approach: the Company should establish procedures to identify hazards, assess risks, and implement appropriate controls. This includes:

• Identifying the ship's critical equipment and systems - those whose sudden loss could endanger the ship, crew or environment (e.g. steering gear, main engine, generators, emergency generator, ballast/OWS, cargo control, fireflighting).
• For each such critical item, the SMS must specify the tests and checks to be carried out at stated intervals (e.g. steering gear testing prior to departure, emergency generator/OWS tests) and maintain a maintenance schedule.
• Determining the minimum spares and stores required to operate, and ensuring a minimum list of spares is carried to maintain the critical equipment; where spares are not carried, the company is to ensure they are supplied in adequate time.
• The risk assessment must consider operational and organisational factors and is documented; the prevention of pollution risk is also evaluated. Tests, planned maintenance and the spares inventory are recorded and verified at the ISM audits.