American Bureau of Shipping
-From J. Riva, Vice President and Chief Surveyor: ABS Surveyors (includes both Surveyors and Auditors) have been formally educated to at least a bachelor’s degree level and/or hold a professional license. This prerequisite knowledge together with the training and certification ABS administers to its Surveyors provides for the capable and sound rendering of classification and statutory certification and services within their level of work responsibility. ABS only uses exclusive Surveyors or exclusive contracted surveyors to conduct classification and statutory surveys. This is in accordance with the IACS (International Association of Classification Societies) procedural requirements.
Training programs assigned to all Surveyors are determined by corporate departments (e.g., Health, Safety and Quality & Environmental, Human Resources, Corporate Classification, Compliance, etc.). All new hire surveyors must attend instructor led training program during first year of hire. Subsequently each 3 years all Surveyors must complete a refresher five day training program that consists of instructor led training and web based courses. This training program was recently updated and the new version was implemented in April 2018. ABS has mandatory training that all Surveyors must complete based on training type and hire date. ABS also uses required training that are prerequisite for specific process certifications. For career development ABS also has other training programs. Furthermore ABS requires all Surveyors to complete an annual web based training course, on statutory regulation and ABS Rule changes The ABS training meets or exceeds the following IACS Procedural Requirements:
1) PR 7, “Procedure for the Training and Qualification of Survey and Plan Approval Staff”. This Procedural Requirement defines the common training and qualification requirements for survey and plan approval staff in accordance with the requirements of IMO Resolutions A.739(18) and A.789(19), ISO 9001:2008 and ISO/IEC 17020:2004, as amended.
2) PR10. “Procedure for the Selection, Training, Qualification and Authorization of Marine Management Systems Auditors”
The ABS Quality and Environmental Management Manual (QEMS) meets applicable regulatory requirements, in accordance with the requirements of the ISO 9001:2015, ISO 14001:2015, and EN ISO/IEC 17020:2012 and International Maritime Organization Resolution MSC.349(92) Code for Recognized Organizations (RO Code), in addition to the IACS QSCS and IACS Resolutions.
The ABS Quality System incorporates survey procedures and work instructions which ensure that the necessary steps associated with the survey and certification requirements of the relevant rules and international conventions are carried out in a controlled, verifiable manner. ABS qualification system for Surveyors contains over 190 certifications. Each Surveyor, before providing services under these procedures, must first be trained; and upon satisfactorily completing the process is, subsequently, certified to the process in question. As a minimum, proficiency in a given process instruction is established by performing the applicable task at least once, in accordance with the controlling procedure, as on-the-job training under the supervision of a person who has satisfied the requirements of the particular task in question IMO “Revised Guidelines on the Implementation of the International Safety (ISM) Code By Administration”, Res. A. 1071 (28) specifies the following requirements for the ISM Code auditors. These IMO guidelines were considered and adopted in IACS Procedural Requirements No 10 and have been implemented in the ABS ISM Code auditor training and certification procedures.
There are at least two areas where ABS requirements for auditor selection, training, and certification exceeded both IMO Res A. 1071 (28) and IACS PR 10 requirements at the time of El Faro incident. For example:
1) IMO Res A. 1071 (28) requires that ISM auditors must have participated in at least 3 initial or renewal verifications. ABS requires that ISM Code auditors must participate in 4 audits out of which 3 audits must be initial or renewal. Additionally, ISM Code auditors are required to participate in at least one company audit and one shipboard audit towards their qualification requirements. ABS does not have a separate (lower tier) qualifications for annual, intermediate and interim audits as allowed by the IMO Guidelines, but requires that the all ISM auditors be qualified for initial and renewal verifications regardless of types of verifications carried out.
2) ABS complies fully with IACS PR 10 requirements. Additionally, ABS requires that all ISM auditor candidates have minimum of two years of marine operations/shipboard experience. This ABS additional requirement is waived only on a case-by-case basis based on the prior experience of the auditor candidate and availability of auditor resources.
Based on the NTSB recommendation, ABS has required that all Surveyors attending repairs of main propulsion boilers, must be also certified for boiler surveys effective 1 February 2018.
In addition, ABS has required all Surveyors and Auditors to complete a PR17 refresher training course. Furthermore, ABS is preparing a new USCG ACP training course that will be required for Surveyors and Auditors, upon the U. S. Coast Guard releasing the new ACP NVIC 2-95 Change 3. This training course will be further updated upon implementation of the single U. S. Supplement focused on critical systems. ABS has confirmed to the USCG, that we will have Surveyors available to attend training at Yorktown, including the Steam Plant Inspection course (USCG Safety Recommendation 25) and Advance Journeyman Inspection Course (USCG Safety Recommendation 26). To date, ABS has not been invited to attend these courses. To verify the performance of Surveyors and auditors, ABS conducts monitoring once every two years and evaluates surveyor/auditor qualifications annually. ABS Policy Changes implemented on 1 February 2018:
1) Commencing at special survey of hull associated with 25 years of age, a Principal Surveyor/Surveyor- in-Charge must attend during the special survey for all self propelled vessels.
2) For U. S. Flagged vessels enrolled in ACP, MSP, or MSP Select, ABS requires two qualified Surveyors to attend commencing at 10 years of age and then each subsequent annual survey and special survey.
3) ABS requires each port office to hold a monthly survey meeting to discuss survey issues.
4) ABS is in the process of verifying the accuracy of the data contained in each vessel survey status (estimated completion date is March 2019).
In regards to the ABS Steel Vessel Rules, ABS made the following Rule changes to improve the safety of ABS classed vessels:
Jan 2015: 3-3-1/7 Damage Control Information: ABS Rules required all new ships to have plan showing clearly for each deck and hold and boundaries of the watertight compartments, the openings therein with the means of closure and position of any controls thereof, and the arrangements for the correction of any list due to flooding, is to be permanently exhibited or readily available on the navigation bridge for the guidance of the officer in charge of the vessel. Feb 2018: 7-3-2/5.1.7(a): ABS Rules require that all vessel undergoing Special Survey commencing at 15 years of age, the structural ventilation ducts and down flooding ducts are to be internally examined.
Feb 2018: 7-3-2/1.1.17: ABS Rules require cargo space fire dampers to be examined during annual surveys.
Feb 2018: 7-3-2/5.1.18: ABS Rules require all cargo space fire dampers to be examined and operational tested during each special survey (every 5 years).
Feb 2018: 7-3-2/5.1.1: ABS Rules require a survey planning document to be developed for all vessels other than barges, prior to the commencement of each Special Survey of Hull.
Based upon the above, ABS confirms that we have further enhanced the training of our Surveyors to ensure that they are properly qualified and supported to perform effective, accurate, and transparent vessel surveys, meeting all statutory and regulatory requirements.
If you have any questions or require clarifications please contact the undersigned.