(Mt) – JND 517 University of Tasmania Safety Management System Paper

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Notes on JND517 Harbour Operations and Services Module 6: Ports – Risk Assessment and Safety Management Systems Pic. Source: The Australian Port Marine Safety Management Guidelines – 2019 Module 6 Ports – Risk Assessment and Safety Management Systems Risk Assessment ‘Risk’ is the chance of something happening that can have an impact on your objectives. A risk is often specified in terms of an event or circumstance and the consequences that may flow from it. Risk is measured in terms of a combination of the consequences of an event and their likelihood. Please note the emphasis on:  impact on objectives  occurrence of event or circumstance  consequences that flow from the event of circumstance  likelihood of event or circumstances of happening To understand the level of risk that exist within a port, an overall assessment needs to be undertaken of all aspects of the business, covering some or all of the following elements: Technology – Failure of electronic systems, power and data supply, infrastructure technology and communications. People – accidents and injury, unacceptable behaviour, loss of corporate knowledge, skills and training. Financial – legislative compliance, fraud and corruption, business disruption and ability to fund development. Environment – cargo operations, sea level rise, marine pollution and dredging. Working environment – work related risks (working at heights, enclosed spaces), manual handling and traffic management. Cargo Operations – Equipment, dangerous cargo and security. Navigational safety – towage, pilotage, grounding, collision, mooring. There are basically two category of risks that a port company needs to consider: 1. Strategic risks – the risks associated with future business plans and strategies. This includes risks to the viability and sustainability of the company arising from changes to the business environment with respect to the economy, law and regulation, markets and customers, environment, technology and the political and social landscape such as: PAGE 1 – Structural changes in markets and global trends impacting on business plans and strategies. – Insufficient development of organisational capability and effectiveness. – Ineffective strategic management of an asset portfolio. – Inadequately developed brand strategy. – Government policy impacting on sustainability. – Inability to access financial resources to implement business plans and strategies. – Inability to develop integrated transport infrastructure 2. Operational risk – a risk arising from the conduct of business activities. This includes potential loss arising from inadequate or failed internal processes, business systems or human error, and from external events, such as: – Loss of revenue base. – Shipping, cargo handling and security incidents (e.g. collisions, groundings, security breaches, etc.). – Non-compliance with governance obligations including internal obligations (financial management and governance practices) and external obligations (legislative, regulatory and contractual). – Major injury or death of persons, or significant liability or loss arising from use or failure of assets or attributable to operations. – Environmental damage attributable to assets/activities. Once all such risks have been identified, they need to be rated to determine the level of attention required to minimise their possible impact. The following table provides a practical exle of identifying the risks, categorising them and assigning their control ratings. Risk # Risk Category Potential Risk Description Control Rating L A Governance Failure to maintain a high-performance culture B Governance C Governance D Business Development Government policy impacting on commercial focus. Non-compliance with legislation, regulation or contractual obligations Inadequate monitoring of changes in trading conditions / external environment Residual Risk Ranking M L L E Business Development Unable to properly position itself in relation to major projects M F Port Operations Shipping incidents such as collisions, groundings, environmental spills, etc. H PAGE 2 Risk # Risk Category Potential Risk Description G Port Operations Port security breaches and poor emergency response H Infrastructure I Infrastructure J Infrastructure Ineffective strategic management of infrastructure assets Liability or loss arising from use or failure of asset Failure to resume normal operations in the event of failure or loss of critical business assets/operations K Human Resources Inability to replace lost workforce skills L Human Resources Major injury or death to persons arising from use of assets or attributable to operations Environmental damage attributable to assets/activities Control Rating M L M M L S M Environment N Information Failure of information technology Marketing Poor customer relationship management and service delivery L Finance Inadequate financial management practices L O P S – Severe H – High M – Moderate Residual Risk Ranking M L L – Low Risk Assessment Table – Port Operations A numerical rating can further be applied to the risk level, if more details are required to support the Low/Medium/High/ Severe rating. Identified risks can be mitigated to some extent with the implementation of suitable control measures. These control measures need to be taken into consideration as they will assist with risk reduction and be used to identify the residual risk rating that exists for each category. The following is an exle of some control measures that could be associated with shipping operations. – Pilot Code of Conduct in existence – Pilot accreditation is updated every 5 years – Pilots and masters are accredited for competency – Periodic medical check-ups for pilots – Implementation of OH#038;S policies and procedures – Pilot training schedule prepared PAGE 3 – Weather stations established along key locations. Advanced electronic navigation systems in use Routine maintenance of navigational aids Port operating parameters established Tug parameters established Pilotage risk analysis undertaken Criteria for port closure due to weather condition established 24 hours surveillance of port areas Emergency plans established and tested on an annual basis Formal passage planning process in existence Pollution response plans established and exercised VTS in operation Once the control measures are identified, a residual Risk Rating can be determined. This is the final level of risk, taking into consideration all the control or mitigating measures that have been implemented. It is the residual Risk Rating that will need to be considered carefully to determine what additional measures may be required to reduce a particular risk rating to an acceptable level. References: The Australian Port Marine Safety Management Guidelines: https://uploadsssl.webflow.com/5b503e0a8411dabd7a173eb7/5cf74059eb10023f18f657d3_The%20Australian%20Port%20Mari ne%20Safety%20Management%20Guidelines.pdf Guidelines for Port and Harbour Risk Assessment and Safety Management Systems in New Zealand https://www.maritimenz.govt.nz/commercial/ports-and-harbours/documents/Port-harbour-risk-assessment.pdf Australian Standard ISO 31000:2018. (For New Zealand, Standard ISO 31000:2009 is still valid) https://www.iso.org/standard/65694.html https://shop.standards.govt.nz/catalog/31000:2009(AS%7CNZS%20ISO)/scope? https://www.complispace.com.au/blog/governance/new-risk-management-standard-iso-31000-changes-needknow/ Safety Management Systems (SMS) Having identified all the known risks, a safety management system (SMS) can be established that ensures all the policies, procedures, work instructions and processes are in place and being followed. The overarching SMS will cover all the operations such as maintenance, asset management, security, cargo operations, marine operations, etc., with individual sub-systems supporting the main structure. PAGE 4 The following is an exle of a Marine Safety Management System. The main elements of this particular system are:  Deed of Agreement or Government Licence  Pilotage SMS  Pilotage Code  Port Procedures Manual  Navigation and Dredging Plan  Incident Management System (IMS)  Risk assessments  Vessel Traffic Services (VTS) Manual  Compliance Deed of Agreement – describes the arrangement between the port authority and government and outlines how marine safety will be maintained. It covers pilotage, VTS, emergency management, navigation aids and the enforcement of navigation regulations. This type of document is used in Australia by state government agencies to assign certain safety aspects of port operations to port companies to ensure an appropriate level of safety is maintained. Pilotage SMS – Provides a range of policies and procedures that are required to be followed to ensure pilotage is conducted in a safe and effective manner. It may consist of the following elements: ➢ Administration o Manuals o Procedures o Work Instructions o Forms o Reference Documents ➢ Accidents/Incidents o Reporting o Register o Recommendations from investigations ➢ Non-Conformances Register ➢ Pilots o Personal details o License details o Training PAGE 5 o Medical reports ➢ Fatigue Management System o Policy o Procedures o Work instructions ➢ Pilot Equipment o Portable piloting units o Communications Equipment o Safety Equipment ➢ Risk o Pilotage Risk Assessments o Vessel Risk Assessments o General Risk Assessments ➢ Port Information o Passage Plans o Non-Navigable Areas o General Information on port areas ➢ Floating Plant o Tugs o Pilot Vessels o Lines boats Pilotage Code – This document describes in detail the pilot licensing arrangements, pilotage exemption requirements and what is required for pilots to retain their licenses in terms of frequency of pilotages, operational and medical checks. Port Procedures Manual – Describes the operating parameters for a port such as tug requirements, shipping parameters, pilotage planning and execution of emergency procedures. VTS Manual – Provides details about the operation of a vessel traffic management system and contains a full set of procedures and work instructions on how the VTS should operate. Compliance checks – As with any system, there is a need to ensure that those who are subject to the requirements of a safety management system are actually complying with its contents. This would typically need to be demonstrated during the periodic external independent audits conducted by a third party or government agency. PAGE 6 Navigation and Dredging Plan – This is a document that describes the frequency of hydrographic surveys and how they will be conducted, how berth, channel and swing basin depths will be maintained and what marine infrastructure may be required for the future port development. Incident Management System (IMS) – All incidents happening within the port should be recorded in an IMS so that an appropriate incident analysis can take place and necessary steps taken to improve safety outcomes and minimise the likelihood of a similar occurrence in future. Risk assessments – A full range of risk assessments for all aspects of marine operations will be undertaken and documented. A major component of this section is pilotage risk assessments that lay the foundations for the pilotage safety management system. As previously described, a risk assessment can take many forms however the outcome, although presented differently, should be the same in each case. A more recently adopted method for pilotage risk assessments is the ‘Due Diligence Safety Review Process which looks at each element of pilotage within a port and determines whether sufficient measures are in place for selected critical operations. The below exle describes a due diligence process. —————————————————————————————————————————–Due Diligence Safety Review of Pilotage Service CONTENTS 1.0 Objective 2.0 Background 3.0 Method 3.1 Port Inspection 3.2 Generative Interviews 3.3 Stakeholder Workshop 3.4 Threat Barrier Modelling 4.0 Pilotage Time Sequence Model 5.0 Threat Barrier Modelling 5.1 6.0 Grounding and Allision with Wharf Structure Findings and Recommendations PAGE 7 1.0 Objective The objective of this project is to complete a due diligence safety review for the provision of pilotage services. The outcomes of the review will feed into the Pilotage Safety Management System. 2.0 Background The marine facility consists of a jetty with one bulk loading unit capable of delivering cargo at 1,500 tonnes per hour. It is located in deep water and exposed to easterly weather that can cause the facility to be closed to shipping. Vessels approach the berth from an east or west direction, depending on wind direction, and moor alongside with a minimum of 6 lines ships lines at each end. The facility can accommodate vessels up to 250m in length. 3.0 Method The method adopted for this review is based on the due diligent common law safety case approach developed for the review of pilotage services. This process includes the application of the hierarchy of controls consistent with OH#038;S legislation (elimination, substitution, isolation, engineering/design, training and administration) based on the balance of the significance of the risk versus the effort required to reduce it. 3.1 Port Inspection An inspection of the general port area and facilities was completed in May 2019 3.2 Generative Interview A number of generative interviews were completed with marine pilots to determine a first cut assessment of the key issues associated with the provision of pilotage services. The issues identified were further tested with a broader stakeholder group at a workshop that included regulators, port authority and facility operator representatives. 3.3 Stakeholder Workshop As a way of testing for completeness of the assessment the workshop group reviewed a typical pilotage both functionally and on a geographic basis. That is, a functional review was completed by considering the tasks undertaken by a pilot during a typical pilotage: passage planning, boarding the vessel, pilotage etc. A geographic assessment of the area was completed to test for location specific issues. The issues raised and the nature of the existing and possible further precautions were documented. PAGE 8 3.4 Threat Barrier Modelling For issue/s identified as credible and critical a threat barrier diagram was developed. Threat barrier diagrams describe the threat and hazard scenarios (initiating events) that can lead to undesired outcomes. Existing barriers to threats were then identified and positioned appropriately. Further possible barriers were then considered. This type of modelling is particularly useful in showing barriers that have an effect on multiple threats. It can be compared to James Reason’s ‘Swiss Cheese’ model but has a more useful due diligence focus. 4.0 Pilotage Time Sequence Model The following time sequence model was developed for the provision of pilotage services. It identifies where the existing and possible further precautions would / could act. MPE – Master/ Pilot Exchange (of information) Note: There are three policy decision points with regard to the provision of pilotage services. 1. The first is a port specific vessel arrival policy which specifies the parameters of a vessel which can enter the port, and if so, under what conditions (tide, weather, day/night, etc) the pilotage can occur. 2. For each vessel that satisfies condition 1, the acceptability of the actual pilotage conditions at the time of entry needs to be assessed and a go/wait decision made. 3. For each vessel that satisfies condition 2, once on the water, the actual conditions are determined whether the pilot should attempt or abort the navigation to the berth. PAGE 9 5.0 Threat Barrier Modelling The key issue with the provision of a pilotage service at this port is allision with the wharf and a threat barrier model was developed to represent the credible threat scenarios, existing barriers and possible future barriers that could be considered. Allision with the wharf could occur if is vessel is approaching the berth too fast or not at the correct angle. This would generally occur as a result of adverse environmental conditions such as tide and wind, or loss of tug assistance. Of particular concern was the ability to accurately assess wind speed and direction prior to undertaking a berthing operation. A local weather station established at the wharf would provide accurate and timely information. 5.1 Allision with Wharf Threat Barrier Modelling 6.0 Findings and Recommendations A list of issues identified during the assessment process will be provided along with a number of recommendations that will help to reduce the risk profile of the operation. PAGE 10 Emergency Preparedness and Response An important element of a safety management system is the preparation of emergency management plans. This needs to be exercised regularly and personnel trained in all aspects relating to the preparedness and response. It is equally important that relationships are established with external emergency agencies to ensure that they have a working knowledge about the port and its operations. This will particularly apply to vessels calling the port as the local fire departments may not be familiar with the vessel layout and complexities associated with fighting shipboard fires. There are typically three main types of emergency plans made as part of port operations: 1. The Emergency Management Plan will cover all types of emergencies within the port area. It could be sub-divided into marine and shore-based responses if considered necessary. 2. The Marine Pollution Contingency Plan (or response plan) will apply to all waters within the port limits or that are assigned to the port by agreement. This type of plan(s) will cover oil spills, chemical spills or any other type of pollution that has the potential to damage the marine environment. 3. The Business Continuity Plans are port specific plans that will provide information on how to keep the port functioning following a major incident that has a significant effect on the port infrastructure. 1. Emergency Management Plans (EMP) The nature of operations conducted at a port will expose the organisation, its employees, contractors and the visitors to a number of risks. A detailed assessment should be conducted, in conjunction with emergency management professionals, to identify the major risks and to determine the actions required in order to ensure an effective response that can be initiated should an emergency event occur. It should be noted that port emergency plans should recognise the existence of a local municipal and/or broader government plans and ensure that they are compatible and able to cope with a potentially escalating problem. In general, these plans aim to cover all the hazards and provide information and business rules for creating responses to a range of emergencies that may affect the port, its employees, operations, port assets and infrastructure and other port users or stakeholders. In general, the objectives of an EMP should be to: – Provide a framework for emergency management. Ensure due process is applied to emergency planning, namely: prevention, preparedness, response, communication, and recovery strategies – Define roles and responsibilities of key personnel and – Provide current contact details for key stakeholders. PAGE 11 The following is an exle of the general contents of an EMP: ➢ Plan Administration o Review o Distribution ➢ Terms o Glossary o Acronyms #038; Abbreviations ➢ Introduction o Authority o Aim #038; Objectives o Scope ➢ Legislative requirements o Work health and Safety Regulations o Navigation Regulations o Incident Regulations o Building Requirements ➢ Risk Assessment ➢ Roles #038; Responsibilities o All Staff o Port Control (VTS) o Emergency Management Team o Incident Controller o Emergency Management Core Team o Other human resources o Emergency Management Committee o Media and Ministerial Liaison o Safety and Hazardous Materials o Security o Management Authorities o Supporting Agencies ➢ Prevention Strategies o Port Planning o Buildings and Structures o Vessels o Public Events o Emergency Operations centres o Evacuation Assembly Areas o Resources o Drills o Exercises o Training o Storm Warning ➢ Response Strategies o Immediate Response o Response Briefing PAGE 12 o Communications ➢ Recovery Strategies o Business Continuity o Debriefs o Personal Injury resulting from emergencies o Counselling ➢ Reference Documents Probably the most important factor for maintaining the effectiveness of emergency management plan is by ensuring that all port staff and other stakeholders are aware of its content and what is expected of them when an emergency occurs. This can best be achieved through conduct of regular exercises using the plan, which includes interaction with the local emergency agencies. References: Port of Sunderland – Port Emergency Plan. https://www.portofsunderland.org.uk/sites/default/files/201802/REDACTED%20VERSION%20Port%20of%20Sunderland%20Emergency%20Plan%20New%20issue %20%28original%29%2001.03.2013.pdf 2. Marine Pollution Contingency Plan (MPCP) In Australia there are two categories of pollution plans: 1. Oil spill contingency plans 2. Chemical spill contingency plans The local oil spill contingency plan is always port specific and describes the preparations in place to respond to an oil spill within the port area. It generally consists of the following main elements: ➢ Introduction o Authority o Aim o Objectives o Scope o Legal Responsibilities o Relevant Legislation o Delineation of Spill Response o Oil Properties and Behaviour o Risk Assessment o Spill Scenarios o Vessel Oil Capacities o Associated Documents o Reference Documents ➢ Roles and Responsibilities o State Marine Pollution Committee o Emergency Management Committee PAGE 13 o o o o o o o o o o o o o o o o o Harbour Master Authorised Officers Support Agencies Incident Management Team Incident Controller Security Centre and Port Control Safety Officer Media Liaison and Public Relations Planning Section Operations Section Logistics Section Finance and Administration All Staff Oil Spill Reporting Response Participation National Response Team Protection and Indemnity (P#038;I) Clubs ➢ Prevention Strategies o International Standards o Policy o Procedures ➢ Preparedness Strategies o Equipment o Tier 1 Equipment o Tier 2 Equipment o Other Resources o Oil Spill Resource Atlas (OSRA) o Incident Control Centre Packs o Training o Exercises o Safe Work Procedures ➢ Response Strategies o Activation Process o Immediate Response Actions • Conduct Initial Assessment • Appoint Incident Controller • Report the Incident • Select an Incident Management Team • Establish an Incident Control Centre • Develop Response Strategies • Consider Safety o Implement Response Strategies • Establish Advanced Operations Centres and Staging Areas PAGE 14 o • Applying Dispersants • Boom Deployment • Clean Up • Allowing Natural Recovery Other Response Considerations • Ongoing Monitoring and Sling • Briefings • Oil Spill Trajectory Modelling • Media Liaison • Communications • Administration • Sourcing Additional Equipment • Sourcing Additional Personnel • Waste Management ➢ Recovery Strategies o Stand down o Debriefs o Incident Reports o Cleaning Equipment o Investigation o Business Continuity o Environment Regeneration o Cost Recovery ➢ Plan Administration o Review o Audit and Compliance o Distribution This type of document is very comprehensive and provides considerable detail to those responding to a pollution incident. The port plan is structured to dovetail with the state plan which in turn “fits” with the Australian Maritime Safety Authority’s National Plan for Maritime Environmental Emergencies. Port plans are designed to handle relatively small oil spills within the port areas and essentially describe a first strike capability. State plans come into play when an oil spill is of medium size or if it happens outside a port area, but within the three-mile state territorial limits. For larger spills and any spill outside the 3-mile limit, the AMSA National Plan will be activated. References: An exle of State Plan: Tasmanian Marine Oil Spill Contingency Plan https://epa.tas.gov.au/Pages/Document.aspx?docid=558 National Plan – Australia National Plan for Maritime Environmental Emergencies https://www.amsa.gov.au/marine-environment/national-plan-maritime-environmental-emergencies PAGE 15 Chemical Spill response plans are very similar to the oil pollution plans however the essential difference is, in Australia, the fire service takes control of the response and the port authority will only provide assistance on request and only if it has resources that may be useful to the responding agency. State and national chemical spill response plans are the main documents in existence. As you would expect, responding to a chemical spill in the marine environment is a very hazardous activity that requires a specialised response. 3. Business Continuity Plan (BCP) Organisations typically work to avert business disruption risks through preventative treatments and mitigation strategies. Despite all these precautions, the likelihood of disruptive risks occurring is ever-present. For this reason, it is in an organisation’s best interest to effectively prepare for the possibility of disruptive risks occurring. This can best be achieved with the implementation of restoration and recovery processes that will return the company to normal operations as quickly as possible. Ports occupy a critical position within the supply-chain of a large number of local, national and international organisations. Any disruption to the operations would cause pile-on effects which are virtually impossible to quantify. While ports take appropriate precautions to ensure the continuity of operations and delivery of the mandate to facilitate trade, even the best-prepared organisation can at times suffer significant disruption or a critical incident. Business continuity plans are developed by ports to ensure that they are well placed to tackle any such challenges, quickly and effectively, in the event of a significant disruption or other type of critical incident, affecting the normal operations. The key to a successful response, continuity and recovery program is to be aware of the threats that can impact on the organisation and to have an effective management framework in place that is capable of rapidly activating and implementing strategies and procedures to protect the business from the consequences of a significant disruption. Skills in communicating with employees, the media and other stakeholders during a crisis, together with the ability to establish clear recovery strategies, can determine the short-term profitability of the business and even its long-term survival prospects. Business Continuity Plans (BCPs) have been developed by ports to assist in containing disruptions that may have an impact on the operations. While the term ‘BCP’ has been used, in some cases these ‘plans’ may simply identify key information, data and specialist personnel to assist in managing a disruption more effectively. The term BCP is therefore used as a collective term to describe all such strategies, plans and information sources that have been collated to manage particular disruption scenarios. PAGE 16 The following are issues that may require a specific business continuity plan as an essential part of the overall BCP structure: • Port blockage • Loss of a main administration office • Shutdown / loss of the IT system • Loss of specialist staff such as marine pilots • Loss of specific critical infrastructure • Loss of a critical mass of staff. It can be readily seen that the above events could have a significant effect on the operation of a port and have the potential, under some circumstances, to cause a cessation of operations. The BCP seeks to activate a Critical Incident Management Team (CIMT) to oversee any such events and to ensure that port is able to keep functioning or any forced shut-down is kept to a limited period of time. It should be noted that the CIMT should only be involved with the principles of overall business continuity and should not get directly involved with any on-ground emergency response. References: A Guide to Business Continuity Planning- Office of Critical Infrastructure Protection and Emergency Preparedness, Canada https://www.gov.mb.ca/emo/pdfs/bcont_e.pdf PAGE 17

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