Tanker Management and Self Assessment 3 [PDF]

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Tanker Management and Self Assessment 3 A BEST-PRACTICE GUIDE FOR SHIP OPERATORS



Report name Date published Operator account Operator name DOC number IMO number Address County/State Post code Country



NTTA-3227-7794-6834 02 Jan 2018 11594 Knutsen OAS Shipping AS 0367129 Smedasundet 40, Haugesund, Rogaland 5529 Norway



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Management, Leadership and Accountability Stage 1 1.1.1



Management commitment is clearly defined in documentation that includes Yes mission statements, policies and procedures. Governing principles, good corporate governance is about establishing a sound platform to govern and control operations in Knutsen OAS shipping (company). Corporate governance shall contribute to improving business performance and ensuring compliance with laws and regulations. It is a prerequisite to maintain company's high reputation and trust in the market place. This is to be achieved through correct attitudes and conscious responsibility by the employees in respect to attendance to health, safety and environment and quality in the day-to-day tasks, and includes the commitment to accurate and reliable financial reporting. Company’s core values are credibility, innovation and care. These values shall reflect our performance of the work including our relation to each other, our customers, suppliers and society in general. These values and commitments shall contribute to the foundation and further development of the confidence towards the company and clients. The governing principles together with the Code of Conduct make up the foundation for governance in Company. This document (1) identifies key governing bodies within the Company and (2) specifies requirements for the business on important governing processes, documents and systems. The governing principles shall be assessed yearly through the management review and the KM Board of Directors (the Board). Management shall ensure that decisiveness, individual understanding of responsibilities, all employees maintain discipline and innovation. This shall be ensured through formalized delegation of responsibilities and authority and the establishment of adequate reporting lines. All employees shall have a basic knowledge to the general system and structure of responsibility and authority, both within the organisation at large and within their respective units. Directors and managers also have the responsibility for establishing and maintaining good management governance and control. They shall be the driving force in the creation of an overall corporate culture. Governing policies incorporate corporate policies that are determined by the Board (code of conduct, suppliers’ code of conduct, governing principles, delegation of authority, and closely related parties) and other governing Policy’s such as; HSE Policy, Quality Policy, Security Policy etc. that are determined by the President & CEO. These specify the rules and framework that Company's business shall exercise within. Company Ref; - ADM 3.1.1 Governing principles - ADM 3.1.4.1 Management requirements and responsibilities - ADM 3.3 HSE policy - HSE&QA Action plan. - Company Key point indicators



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1.1.2



Senior management demonstrates a clear commitment to implementing the Yes SMS. One of a number of managerial requirements is that directors and managers must assume managerial responsibility. This responsibility includes ensuring that the employees in the unit or department have a clear idea of the goals that have been set and have the correct and sufficient expertise to perform their duties, and that the right decisions are made so that the employees can deliver. Management shall ensure that decisiveness, individual understanding of responsibilities, all employees maintain discipline and innovation. This shall be ensured through formalized delegation of responsibilities and authority and the establishment of adequate reporting lines. All employees shall have a basic knowledge to the general system and structure of responsibility and authority, both within the organisation at large and within their respective units. All organisational units are responsible for implementing and executing any necessary action according to organisational descriptions and in accordance with requirements established in this instruction. The ultimate responsibility for quality, safety and environment in KNOT lies with the President & CEO. However, everyone in the Company, whether permanent employees or temporary personnel, on board or ashore, are responsible for the Quality, Safety and Environment of the work that is produced by KNOT. Management Review of the company's SMS is performed once a year and included review of policies, action plan, KPI's, Incident & NC data. HSE targets are reviewed on regular basis during Management meeting at least once a month – minutes of meeting are taken and filed. Company reference; ADM 3.1.4.1 Management requirements and responsibilities ADM 5.5 Management review. HSE 1.1.3 Responsibilities Management review. Management meeting MoM.



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1.1.3



HSSE excellence is fully understood and supported by vessel and shore-based Yes management teams. The success of the system depends on commitment from all level and functions of the organization, especially from top management. The Department Manager shall ensure that the required resources, including programme, personnel, material and environment, are incorporated in to the early planning stages of work. The Manager shall, furthermore, verify that these requirements are complied with and that the requirements are being reviewed at regular intervals.Ensuring that feedback from employees are registered and dealt with in an appropriate and relevant manner is also of great importance, e.g. in order to maintain occupational health and prevent ill health. The HSSE&QA Director in KNOT is responsible for the verification, distribution and document control of Company HSE&QA-Manuals as relevant, as well as for the introduction of these Manuals to Company employees, including both Maritime Personnel and Shore-Based Staff. Each Department Head within the Company is responsible for their special field and for the description of their routines in the Manuals. Best Practice Management Meeting (BPMM) program established in 2011, these very successful mini conferences have the attendance from up to 3 vessels, senior managements. During these mini conferences/gatherings at the main office, best management practice based on sharing of information and experience gained from operating similar vessels, trade, equipment, charterers, geographical position, terminals and offshore installations will be targeted . These meetings will be attended by Technical Operation, Vetting, Personnel and HSSE & QA department. in addition; Safety Bulletin, Technical Bulletin and Vetting Focus are sent onboard. Safety Flash is distributed when needed. Annual Officer's conferences and briefing sessions for newly employed top officers. Company Ref - HSE 1.1.3 Responsibilities. - HSE 6.3 HSE&QA Statistics, Safety Bulletins & Key Performance Indicators (KPI). - ADM 5.5 HSSE&QA Department organization and responsibilities. - ADM 6.9.3 Officer Conference. - ADM 12.8.4 Ship visits - Safety Bulletin - Action plan.



Stage 2



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1.2.1



All company personnel can describe what HSSE excellence means in practice. Yes One of a number of managerial requirements is that directors and managers must assume managerial responsibility. This responsibility includes ensuring that the employees in the unit or department have a clear idea of the goals that have been set and have the correct and sufficient expertise to perform their duties, and that the right decisions are made so that the employees can deliver. Management shall ensure that decisiveness, individual understanding of responsibilities, all employees maintain discipline and innovation. This shall be ensured through formalized delegation of responsibilities and authority and the establishment of adequate reporting lines. All employees shall have a basic knowledge to the general system and structure of responsibility and authority, both within the organisation at large and within their respective units. All organisational units are responsible for implementing and executing any necessary action according to organisational descriptions and in accordance with requirements established in this instruction. The ultimate responsibility for quality, safety and environment in KNOT lies with the President & CEO. However, everyone in the Company, whether permanent employees or temporary personnel, on board or ashore, are responsible for the Quality, Safety and Environment of the work that is produced by KNOT. The visions and goals are addressed at officers’ conferences and during ship visit's by management. The same is also communicated in the Company magazine Knut’en, safety bulletins and newsletters. Company Ref; ADM 3.1.4.1 Management requirements and responsibilities HSE 1.1.3 Responsibilities ADM 6.9.3 Officer Conference ADM 12.4.3 Meetings with senior officers ADM 12.8.4 Ship visits and internal audits. ADM 12.10 Assessment of master and senior officers ADM 14.10 Personnel development ADM 14.16 Performance review.



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1.2.2



Management strives to improve safety and environmental performance at all Yes levels. Based upon management review the management will conclude in an action plan for next year in quality-, occupational health, safety- and environmental objectives with priority. For every Board meeting the President & CEO shall present a report with the status of the company on concerns of significant importance, such as: - Financial status in relation to budget and previous year’s achievement as well as the liquidity situation. - Key Performance Indicators (KPIs) within the areas of e.g. health, safety, security, environment and quality assurance. - Received reports on significant deviations related to HSSE&QA and applicable laws and regulations, as well as the company’s internal procedures such as compliance issues. As soon as the vessel receives the statistics from the Company, the Master shall review the statistics in an open PEC Meeting, with all crew present. Each vessel’s individual KPI Results is monitored. Action's shall be established for individual KPI's in circumstance they deviate from the set limits. Company Ref; - HSE 6.3 HSE&QA Statistics, Safety Bulletins & Key Performance Indicators (KPI). - HSE 9.2 P&E Committee(PEC) Report - ADM 5.5 HSSE&QA Department organization and responsibilities. - ADM 3.4.1 C. Reporting routines - Management meetings MoM. - Unisea Univu.



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1.2.3



Vessel and shore-based management teams promote HSSE excellence. Yes Visible leadership is demonstrated at all levels in the organisation during ship visits by Superintendents, Management and QA/HSE personnel. This is also demonstrated at office visits from officers and at Company conferences (twice a year). - Leading by example - Company Behavior based safety program focuses on active leadership as one part. - Empowering personnel to intervene to prevent hazardous situations developing. - All crew have the right and responsibility to call for a "Time out" whenever required, this practice is encouraged by management onboard and ashore. - Safety inspections/rounds by Senior Officers. - Monthly safety inspections are carried out. - Ship visits by senior shore-based managers which include informal meetings with available vessel personnel. - Company KPI is that management should visit 50% of the fleet, monitored monthly. - Recognition and rewarding of outstanding HSSE performance. - Bonus and recognition for Vetting performance and days without LWC is given. Company Ref; - HSE&QA Action plan. - HSE 5.1.4 Risk Assessment - Time out - HSE 11.1 HSE Inspections - ADM 12 APP F. Management Ship visit report. - Active leadership program.



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Stage 3 1.3.1



Shore management establishes targets related to HSSE performance and Yes conducts measurements to assess and verify their implementation. Based upon management review the management will conclude in an action plan for next year in quality-, occupational health, safety- and environmental objectives with priority. HSE&QA Department prepares and maintains the different statistics in order to monitor the company annual KPI targets, the objective is that the Company and each vessel shall be able to measure the KPI results towards the annual KPI Targets. As soon as the vessel receives the statistics from the Company, the Master shall review the statistics in an open PEC Meeting, with all crew present, the monthly PEC Report is entered into UniSea from the ship. Company Ref; - ADM 5.5.2 Management review conclusions. - HSE 6.3 HSE&QA Statistics, Safety Bulletins & Key Performance Indicators (KPI) - HSE&QA Action plan. - HSE 9.2 P&E Committee(PEC) Report - Unisea dashboard - HSE status reports



1.3.2



The steps required to HSSE excellence at each level of the action plan are clearly Yes defined by management. Company Objectives and Targets incl. Key point indicators are set in the HSE&QA Action plan which is updated/revised on any annual basis in connection with management review, once signed the plan is distributed to all vessels. QA department follow-up and monitor time frame/dead lines for all Objectives/Targets. Company KPI's are reviewed during monthly management meeting and is a fixed topic on the agenda. Company Ref; - ADM 3.4.1 Instructions for the President & Chief Executive Officer. C. Reporting routines. - ADM 5.5.2 Management review conclusion



Stage 4



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1.4.1



HSSE targets and objectives are discussed, at least quarterly, at management Yes meetings onboard and ashore. Shore management meeting are held on a monthly basis, status and review of company KPI's (action plan) are a part of these meetings including remedial action towards under-performing KPI's. KPI status is distributed monthly to company vessels, KPI reports are discussed onboard all vessel's in the monthly protection and environment committee meetings. Safety Bulletins are in addition to the monthly KPI reports sent to all vessels quarterly, the bulletin give a more in depth analysis and status of KPI's, grouping of findings from internal reporting system (Docmap/unisea), status of campaigns, safety topics and focus areas etc... Company Ref; - ADM 3.4.1 Instructions for the President & Chief Executive Officer. C. Reporting routines. - ADM 12.3 Administrative routines - ADM 19.3 Schematic outline of HSE&QA system. - HSE 9.1 Protection & Environment Committee. - HSE 6.3 HSE&QA Statistics, Safety Bulletins & Key Performance Indicators (KPI) - KPI report.



1.4.2



HSSE performance targets are continually monitored against KPIs. Yes For every Board meeting the President & CEO shall present a report with the status of the company on concerns of significant importance, such as: - Financial status in relation to budget and previous year’s achievement as well as the liquidity situation. - Key Performance Indicators (KPIs) within the areas of e.g. health, safety, security, environment and quality assurance. - Received reports on significant deviations related to HSSE&QA and applicable laws and regulations, as well as the company’s internal procedures such as compliance issues Computer based systems are used to compile the statistics (TMv2, Docmap, Unisea, OCS and report manager) KPI reports are published in Docmap and available for all. - ADM 3.4.1 Instructions for the President & Chief Executive Officer. C. Reporting routines. - HSE 6.3 HSE&QA Statistics, Safety Bulletins & Key Performance Indicators (KPI) - KPI report



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1.4.3



All vessel and shore-based personnel demonstrate their commitment to HSSE Yes excellence. Company demonstrate its commitment to HSSE excellence through our Behavior based safety program ("We are committed to safety" & "Active leadership") Visible leadership is demonstrated at all levels in the organisation during ship visits by Superintendents, Management and QA/HSE personnel. This is also demonstrated at office visits from officers and at Company conferences (twice a year). Company's behavior-based program - Company Behavior based safety program focuses on active leadership as one part. - Empowering personnel to intervene to prevent hazardous situations developing. - All crew have the right and responsibility to call for a "Time out" whenever required, this practice is encouraged by management onboard and ashore. - Safety inspections/rounds by Senior Officers. - Monthly safety inspections are carried out. - Ship visits by senior shore-based managers which include informal meetings with available vessel personnel. - Company KPI is that management should visit 50% of the fleet, monitored monthly. - Recognition and rewarding of outstanding HSSE performance. - Bonus and recognition for Vetting performance and days without LWC is given. Company Ref; - HSE&QA Action plan. - HSE 5.1.4 Risk Assessment - Time out - HSE 11.1 HSE Inspections - ADM 12 APP F. Management Ship visit report.



1.4.4



A strategic plan ensures continual improvements in HSSE performance are Yes achieved. The strategy plan is the Board’s most important governance tool. The strategy will define KM’s goals and ambitions, as well as set guidelines for the company’s development for the next years. The strategy plan is developed for a period of five years. The President & CEO shall present to the Board a risk analysis, including market attractiveness, competitive position, and evaluation of options, for review and discussion for implementation of strategic plan for the company. The Board approves the strategy plan. Company Ref; - ADM 3.1.4.2 Governing Principles - Strategy process.



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Developing and Maintaining a SMS Stage 1 1A.1.1



Management ensures that company policy and the supporting procedures and Yes instructions cover all the activities undertaken. Governing Policy’s such as; HSE Policy, Quality Policy, Security Policy etc. that are determined by the President & CEO. These specify the rules and framework that the company business shall exercise within. Policies contain key business principles and requirements from management on selected subject areas and they shall be reflected in the business and operations. The procedures provide more detailed and practical instructions, and, together with the key controls, they describe how to implement the principles in the policies. Company policies cover; - Safety and environmental protection. - HSE Policy - Security. - Security policy statement. - Health and welfare, including D&A. - HSE Policy & D&A policy - Social responsibility. - Code of conduct. Company Ref: - ADM 3.1.5 Governance / Policy - ADM 3.7 HSE Policy - ADM 3.9 Security Policy statement - HSE 3.4 D&A Policy - Code of conduct



1A.1.2



Policy and procedures are formally reviewed at regular intervals to ensure Yes robustness and effectiveness. Company Policies are evaluated in Management Review based on input from Masters Review and Internal audits on vessels and office(s) and approved on an annual basis. Procedures may be reviewed and revised at any time based upon online comments from company SMS software, BPMM, officers conferences, regulatory updates, internal/external feedback. immediately required changes are handled through Circular letters towards all vessels until the change can be included into a formal revision. Company Ref: - VAM 1.7 Masters review. - ADM 5.5 Management review. - ADM 19.1 Document control.



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1A.1.3



Procedures and instructions are written in plain language and contain sufficient Yes detail to ensure that tasks can be completed correctly and consistently. STCW-2010 requires crew coordination, meaning that the ship’s complement (Officers & Crew) can effectively coordinate their activities in an emergency situation, and in performing functions vital to Safety or to the Prevention or Mitigation of Pollution. The requirements concerning the crewmembers ability to coordinate activities, includes the ability of crewmembers to communicate effectively with each other in a common language. The common language used: - Onboard ships with multinational crew, the working language shall be English. - Onboard ships with Norwegian crew only, the working language shall be Norwegian. However, Master and his Officers shall be able to use English both verbally and in writing, as all HSE&QA documentation will be in English. All work shall be executed in such a way that fulfilment of specified requirements is ensured, and that plans are adhered to regarding resources, budgets and schedules. The following elements shall be present at commencement of any activity; safe and acceptable working environment, clear and instructive task definition and approved controlling documents, such as plans, specifications, procedures and instructions



Company Ref: - VAM 3.1.1 Crew policy, Language. - HSE 2.3.2 Common Language. - ADM 5.1.2.3 Execution. - ADM 19.1 Document Control - VAM 4.6 Checklists. 1A.1.4



Procedures and instructions are easily accessible to personnel and available at appropriate locations. The company use Docmap for all governing documents in the Safety Management System. All employees have access to relevant documents in this system



Yes



Company Ref; - ADM 19.1.3 Document control - Electronic documents.



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1A.1.5



A formal document control system is in place to ensure that the current SMS Yes documentation is available. The originator of any document is responsible for the document. The originator is always the head of the department, and the owner of the document. A document will be sent from the originator to the checker and further to the approver. Before a revision, the document shall be sent on hearing to person in charge of the discipline in question. The respective documents shall be checked by the Quality Assurance department and approved by HSSE & QA Director before implementation in KNOT Management AS Safety Management System Docmap. The originator and the approver might be the same person, the checker and the approver shall never be the same person, nor can the checker and the originator be the same person. Company Ref; - ADM 19.1 Document control.



Stage 2 1A.2.1



Periodic meetings that review or amend current procedures, or propose new Yes ones, take place at defined intervals and are formally recorded. Revision & Maintenance of HSE&QA-Manuals: At least once per year the need for revision of Shipboard HSE&QA Manuals shall be evaluated. If Shipboard Operations or other important elements and procedures linked to Operation and Management have been changed, the actual Manuals shall be updated as quickly as practically possible. Revision and maintenance of the Manuals shall be based upon experience return and corrections received from the vessels, for instance through Reporting, commenting and Master’s Review, as well as on comments and return information received from the various Company Departments, Oil Companies, Class etc.



Company Ref; - VAM 1.1.3 Revision & Maintenance of HSE&QA-Manuals - ADM 19.1 Document control. - VAM 1.7 Masters review. - ADM 5.5 Management review.



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1A.2.2



Managers’ roles, responsibilities and accountabilities for achieving objectives Yes are defined within the SMS. All organisational units are responsible for implementing and executing any necessary action according to organisational descriptions and in accordance with requirements established in this instruction. The ultimate responsibility for quality, safety and environment in company lies with the President & CEO. However, everyone in the Company, whether permanent employees or temporary personnel, on board or ashore, are responsible for the Quality, Safety and Environment of the work that is produced by KNOT Roles, responsibility, reporting, and accountability, for all positions are described in the Company management system. Managers report their activities in monthly Management meetings. Manager are resp. that new personnel is presented all aspects of positions, whenever changes in organisation are made. Company Ref; - ADM 2 Organization. - ADM APP 12 C Handover. - ADM 14.3 Employment, Resignation & Dismissal. - ADM 20 Job descriptions



1A.2.3



Relevant reference documents are provided as a supplement to the SMS both Yes onboard and ashore. Office have web- accounts with Reg4Ships that is kept up to date with all Regulatory publications, including highlighting of forthcoming regulatory updates. Ships has an active subscription list, which ensures that latest editions of regulatory/industry guidelines are kept & sent onboard automatically . "Nautisk forlag", Office is also included in this subscription. Company Ref; - VAM 4.3.7 Shipboard library - Publications. - ADM 11.22 Vessel sea preparation.



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Stage 3 1A.3.1



Open dialogue between vessel personnel and shore-based personnel to Yes improve the SMS is encouraged. Proactive feedback is provided to the whole fleet by sending Safety Bulletins, circular letters and online sharing of reports. Instant commenting on procedures to HSSE&QA department is available to crew by comment function in Docmap (company online SMS software) Industry guidance is made available in UniSea Bulletins for easy access and archiving. Company Ref; - ADM 5.1 HSSE & QA Organization and Responsibilities. - HSE 6.3 4 Safety Bulletin and Safety Flash – issuing and distribution



1A.3.2



Instructions and procedures covering shore and vessel operations are Yes developed in consultation with those who will have to implement them. The originator of a document is responsible for the document. The originator is always the head of a department, and the owner of the document. A document will be sent from the originator to the checker and further to the approver. Before a revision, the document shall be sent on hearing to person in charge of the discipline in question. The respective documents shall be checked by the Quality Assurance department and approved by HSSE & QA Director before implementation in KNOT Management AS Safety Management System Docmap. The originator and the approver might be the same person, the checker and the approver shall never be the same person, nor can the checker and the originator be the same person. Personnel with competence in subject area will form the hearing. Company Ref; - ADM 19.1 Document control. - ADM Job description (Fleet manager, Vetting Manager)



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Stage 4 1A.4.1



Benchmarking is used to identify further improvements to the SMS. Yes Company’s performance is bench-marked with certain ship-owning companies through exchange of reports. Further through audits, inspections and vetting. In addition Norwegian Shipowner Association provides relevant statistics. Company Ref; - Management review



1A.4.2



The company is innovative in improving the content, format and delivery of the SMS.



No



1A.4.3



Senior managers have an assurance programme in place to verify the Yes effectiveness of the SMS. For every Board meeting the President & CEO shall present a report with the status of the company on concerns of significant importance, such as: Financial status in relation to budget and previous year’s achievement as well as the liquidity situation. Key Performance Indicators (KPIs) within the areas of e.g. health, safety, security, environment and quality assurance. Received reports on significant deviations related to HSSE&QA and applicable laws and regulations, as well as the company’s internal procedures such as compliance issues.



Company Ref: - ADM 3.4.1 (C. reporting) Instructions for the President & Chief Executive Officer. - ADM 5.6 Internal audit.



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Recruitment and Management of Shore-based Personnel Stage 1 2.1.1



A pre-recruitment process is in place that ensures candidates for key shorebased positions have the appropriate qualifications, experience and competence. Key information received during the interview process are randomly checked and former employers are asked about the applicants experience and qualifications.



Yes



Company Ref: - ADM 14.02. Procedure for Human Resources. - Job descriptions 2.1.2



The company has a documented recruitment process for key personnel. Yes The procedure for Human Resources (HR) is part of the companies governing documents and is anchored in the HR Policy. Company Ref - ADM 14.1 HR Policy - ADM 14.2 Procedure for Human Resources



2.1.3



A formal familiarisation process is in place for newly recruited key shore-based Yes personnel. A "Personal Handbook" is established in order to give an induction/familiarization to all new employees. In addition all head of departments are responsible for proper introduction to work requirements, duties and resp. Familiarisation checklists established. Company Ref: - ADM 14.14 Personnel handbook - ADM 14.15 Introduction program - New Employee



2.1.4



There is a documented handover procedure for shore-based personnel. Yes The Fleet Manager shall be informed in advance about absence. The back-up Superintendent will normally only take over in case of vacation or illness. In cases where the absence is expected to exceed 14 days handover checklist to be completed. Company Ref - ADM 12.3.Administrative Routines - Absence. - ADM 12 APP C. Handover.



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2.1.5



Up-to-date records of qualifications, experience and training courses attended for all key shore-based staff are maintained. HR director is responsible for establishing and maintaining records of onshore personnel competence



Yes



Company Ref: - ADM 14.1 HR Policy / Roles and responsibility / Process owner. - ADM 14.3 Onshore Personnel Administration, organization and responsibilities. - HR personnel records. Stage 2 2.2.1



A formal personnel appraisal system ensures that key personnel undergo a Yes performance assessment at least annually. An appraisal talk shall be performed once a year, for each individual employee and manager. This evaluation process of the employee’s performance shall be a continuous process where the objective is to contribute to the employee’s development and potential improvement through a dialogue based on constructive feedback. It is the responsibility of employees with leader responsibilities to arrange the mentioned employee appraisal talks.



Company Ref:' - ADM 3.1.4.4 HR process - ADM 14.1 HR Policy - ADM 14.2 Procedure for human resources - ADM 14.10 Personnel development - ADM 14.16 Performance review form 2.2.2



Retention rates for key personnel over a two-year period are calculated. Yes Retention rate for key personnel ashore is calculated and reported on a monthly basis and included in internal KPI report. Retention rate is based on 2 year rolling period.



Company Ref KPI report (internal)



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Stage 3 2.3.1



Key personnel retain core technical skills through training, refresher training Yes and participation in industry forums, seminars and conferences. Compulsory courses identified for key personnel, the course program for Superintendents lists compulsory and some preferred courses. Compulsory courses need not be taken if the Superintendent already possesses the necessary knowledge. Superintendents shall attend relevant courses, seminars etc to keep updated in Ship Management issues in general, and in their fields of expertise in particular. The HR Director shall file a copy of the course diploma. Training needs are assessed for every employee subject for performance review/appraisal talk annually. Company ref. - ADM 12.2.3 Training. - ADM 14.2 Procedure for human resources (14.2.3.6 item 3) - ADM 14.16 Performance review template



2.3.2



Sufficient shore-based personnel are provided to implement the SMS Yes effectively. Personnel resources are reviewed during the management review meeting with Line managers who are responsible for identifying personnel needs. Company Ref - Management review department input template. - ADM 14.2 Procedure for human resources (14.2.3.2 item 1)



2.3.3



Targets for retention rates are formally reviewed and documented. Yes Retention rate for key personnel ashore has a target of >90%. Retention rate is recorded and updated monthly on Company internal KPI report and reviewed by management. Company Ref KPI report (internal)



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Stage 4 2.4.1



Continual professional development of personnel is encouraged and supported. The employees are encouraged to attend courses related to their work. For longer education the employee has to put in an application to the Board for individual evaluation.



Yes



HR Policy The company acknowledges that competent personnel are key for success and that their skills are a main source of competitive advantage. the company shall encourage each individual to update their skills in order to be prepared to meet future tasks and challenges. Company Ref. - ADM 14.1 HR policy. (14.1.3 employee development) 2.4.2



The company aims to fill relevant shore-based positions from within the fleet Yes wherever possible. To achieve a proper recruitment process KNOT Management (KM) shall - Base recruitment upon KM business objectives and strategies to strengthen KM competitive position. - Attract and nurture personnel who have the ability and desire to contribute to the development of the company. - Employ qualified personnel who are competent and medically fit to ensure a good, safe and secure working environment. - Base the recruitment of staff on merit and equal opportunity regardless of race, colour, religion, gender, age, national origin, sexual orientation, marital status and disability. - Recruit new positions in the company primarily by internal promotions as far as is reasonable, in order to maintain and promote in-house personnel development potential. - Perform KM recruitment process according to the defined guidelines and procedure/checklist (i.e. include key elements such as interview and control of references) to make sure that the recruitment process is handled with maximum professionalism and that all applicants feel that they have received fair treatment



Company ref. - ADM 6.3 Procedure for crew human resources (6.3.4 Manage internal recruitment) - ADM 11.7 New-building Personnel - ADM 14.1.3 HR policy Main principles - ADM 14.17 Short term commitment for sailing personnel at the office. 2.4.3



The company promotes appropriate interpersonal skills training.



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No



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Recruitment and Management of Vessel Personnel Stage 1 3.1.1



Management has procedures for the selection, recruitment and promotion of Yes all vessel personnel. The Procedure for Crew Human Resources is part of the company's governing documents and is anchored in the Crew Policy. The HR-Maritime Personnel Department is responsible for establishing and maintaining the Company's policy including requirements and criteria with respect to shipboard personnel administrative issues. Company Ref: - ADM 6.3 Procedure for crew Human resources - ADM 6.1 Crew Policy - ADM 5.4 Audit of subcontractors, manning companies etc.. - ADM 6.7 Control of documents



3.1.2



All vessel personnel have valid medical certificates in compliance with Flag State Yes and/or relevant authority requirements. All seafarers shall be holder of a valid "Medical Health Certificate" before joining the vessel. The certificate should be valid until the end of on board period (contract) +1 month. All medical examination shall be issued by a recognized medical practitioner, approved by vessels flag-state or another maritime administration and recognized as equivalent. Company Ref: - ADM 6.7 Control of documents



3.1.3



Procedures are in place to identify and manage mandatory training, including Yes refresher training, for all vessel personnel. It is company policy to have an adequate, robust and specific familiarization and training program in place for all positions on board. The familiarization and training program will ensure that each crew-member will be given necessary and required training & familiarization within the time frames, based on the seafarer qualifications and experience. Company Ref - FAT 1.2 Familiarization & Training - policy & objectives. - FAT 7.2 Course matrix. - ADM 6.4 HR-Maritime Personnel Department Organization and Responsibilities. - OCS software for records



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3.1.4



Formal familiarisation procedures are in place for vessel personnel, including Yes contractors. It is company policy to have an adequate, robust and specific familiarization and training program in place for all positions on board. The familiarization and training program will ensure that each crew-member will be given necessary and required training & familiarization within the time frames, based on the seafarer qualifications and experience. Company ref - FAT 1.2 Familiarization & Training - policy & objectives. - FAT 1.4 Familiarization matrix Crew - FAT 8.0 Visitor safety familiarization (non-crew) - FAT 1.3.6 Documentation.



3.1.5



Documented handover procedures for key vessel personnel are in place. Yes Captain and Chief engineers shall make “Change of command” and “Relief report” respectively. A copy shall be sent to the superintendent. Particularly in case of short overlaps, it is advisable that the reliever is updated on phone a few days before signing on. The superintendent may also update the reliever with key focal issues. All Officers onboard, including Electrician and chief cook should write a handover report to their respective reliever with copy to the departments head. Company ref: - VAM 3.14 Crew changes (3.14.3 Handover reports) - VAM 1.10 - 1.16 Handover checklists.



Stage 2 3.2.1



Appraisal procedures are in place for all vessel personnel. Yes The main purpose of the evaluation report is Active Leadership in order to assess the following: - Regular general appraisal of performance, motivation and guidance for further improvements. - Whether more experience, courses or training is required for the current position. - Whether the person is a candidate for promotion. Chief Officer and Chief Engineer shall make evaluation reports for deck- and engine crews respectively. The Captain shall evaluate the head of galley department, who again shall evaluate the galley staff. It is particularly important to take part in the evaluation of new Senior Officers after their first period onboard.



Company Ref: - VAM 3.19 Evaluation reports - ADM 12.4.2 Appraisal talk/performance and evaluation report. - ADM 12.10.0 Assessment of Master & Senior Officers.



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3.2.2



Procedures are in place to provide company specific additional training for all Yes ranks. It is company policy to have an adequate, robust and specific training program in place for all positions on board. Computer based training programs have been included in a matrix presenting the total library of training courses Company Ref: - FAT 6.1 CBT Computer based training - FAT 6.2 CBT training matrix - VAM 3.19 Evaluation reports



3.2.3



The company verifies that vessel personnel quality requirements are Yes consistently met. Before joining, competence and certification requirements are checked by the manning agent, personnel department and master on board the vessel. Annual audits of manning agents and additional visits. Ref. is made to the company's Guidelines for manning comp. Company Ref; - ADM 5.4 Audit of subcontractors, manning companies etc.. - ADM 6.1 Crew policy (6.1.3 Main principles) - ADM 6.7 Control of documents - OCS records.



3.2.4



Procedures to identify additional training requirements for individual personnel are in place. The company has a procedure for evaluation/appraisal which includes training needs of the individual employee.



Yes



Company Ref; - ADM 6.3 Procedure for crew human resources. (6.3.6 Career planning) - ADM 5.5 Management review. - VAM 3.19 Evaluation reports. 3.2.5



There is an enhanced recruitment procedure for Senior Officers. Yes Recruitment checklists have been made, including interview questions. Introduction program is implemented for all masters, chief officers and chief engineers. Company Ref; - ADM 6.3 Procedure for crew human resources. (6.3.4 manage internal/external recruitment)¨ - ADM 6.5 Recruitment - VAM 3.19 Evaluation reports (3.19.2 Interval)



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3.2.6



The company monitors and records training results and effectiveness. Yes Company is receiving course evaluation reports from our external courses. All course evaluation reports received from course organizer is filed in the HR-Maritime Personnel Department. Training Manager is controlling all course evaluation reports on regular basis and discussing these reports with course organizer and with HR Director when needed, and before renewing of any agreement.



Company Ref - ADM 6.10 Course evaluation. - ADM 6.3 Procedure for crew human resources. (6.3.6.1 Career planning ) 3.2.7



There is a documented promotion procedure. Possible promotion candidates are found/based on the following; Evaluation reports & Recommendations from Master(s)



Yes



For promotion to top position, the following will be will be considered Loyalty, leadership, safety consciousness, cost consciousness, Representative, positive and diplomatic behavior, Efficiency & Commercial knowledge. It is Company guideline to rank candidates for promotion, according to number of years in position, provided requirements with regard to experience, performance and skills are met. If internal candidates do not qualify, external personnel will be employed. Process will follow the process described in crew human resources procedure. Company Ref: - VAM 3.5 Promotion. - ADM 6.3 Procedure for crew human resources ( Manage internal/external recruitment) - ADM 6.15 Checklist - promotion - FAT 1.4 Familiarization Matrix - FAT 7.2 Course matrix - FAT 7.3 Certificate matrix. Stage 3 3.3.1



There are enhanced appraisal procedures for Senior Officers. Yes Assessment of Masters and Chief Engineers will be conducted during vessels Superintendent visit onboard, or during the senior officer visit to the office. The Master assesses the Chief Officer according to company form - ADM 6.3 Procedure for crew human resources (career planing). - ADM 12.10 Assessment of master & Senior officers. - VAM 3.19 Evaluation reports (General information).



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3.3.2



The company provides career development for Junior Officers and aims to Yes promote Senior Officers from within the company, where possible. It is Company guideline to rank candidates for promotion, according to number of years in position, provided requirements with regard to experience, performance and skills are met. If internal candidates do not qualify, external personnel will be employed. Company ref; - ADM 6.3 Procedure for crew human resources (6.3.6.1 career planing Item 3). - VAM 3.5 Promotion - ADM 6.15 Checklist promotion.



3.3.3



Training for vessel personnel exceeds the minimum requirements of the Yes International Convention on STCW or of the relevant authority for vessel trade. The company has an extensive training program which exceeds minimum STCW requirements. This can be found in course matrixes both for onshore training and CBT-modules onboard. Training is reviewed annually. Company Ref: - VAM 3.18 Training - FAT 6.2 CBT training matrix - FAT 7.2 Course matrix - FAT 7.3 Certificate matrix. - ADM 6.6 Test of professional skills (CES Test) - ADM 6.3 Procedure for crew human resources (6.3.6.1 career planing Item 5)



3.3.4



Personnel selection and recruitment is reviewed annually to ensure it complies Yes with company policies and procedures. Company will carry out audits of manning companies, to verify that the companies are in compliance with KNOT HSSE&QA Requirements, audit will be carried out on an annual basis. Crew manager is responsible for ensuring remediation of the crew processes based on annual internal audit results, in addition to designing and propose changes to the policy and governing documents based on an annual review of the Crew policy. Company ref - ADM 5.4 Audits of Subcontractors, Manning Companies, Yards, Suppliers, etc. - ADM 5.6 Internal Audit Program. - ADM 6.1.4 Crew policy; roles and responsibilities.



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Stage 4 3.4.1



Procedures to assess crew members for job competency are in place. Yes Lack of competence is relevant in different settings such as in a recruitment process, promotion, and change of vessel or in the case of crew change. There are specific requirements for the different setting and four checklists have to be completed to ensure that the specific employee meets the individual requirements: -1. New recruitment. 2. Promotion. 3. Change of vessel. 4. Crew change. Depending on the checklist; different levels of authority are responsible for completing the checklist. The Training Consultant/Training Administrator is responsible for reviewing that the checklist is complete when entering the individual employee’s experience in OCS. OCS will generate qualified activities that decide what kind of work the individual employee is qualified to perform. The Personnel Coordinator will review the work conducted by the Training Consultant/Training Administrator.



Company Ref - VOM 2.12-13 verification of skills - ADM 6.3 Procedure for crew human resources (6.3.5.1 Manage external recruitment item 6) - ADM 6.3 Procedure for crew human resources (6.3.10 Risk and control matrix item 2) - ADM 6.5 Recruitment - ADM 6.6 Test of professional skills - ADM 6.8 Approval of New Employees - VAM 3.4 Selection - VAM 3.7 Recruitment sources - VAM 3.19 Evaluation reports 3.4.2



A documented planning procedure is in place to ensures future manning needs Yes can be met. Depending on the need Vice President Technical Operation, Vice President Chartering/ Business Development, Fleet Manager, the Superintendent and/or the Crewing Manager identifies the need of recruiting and/or need for operation manning on board vessel(s). this is based on some of the following factors; New Projects, New Building, New trade / operations, New vessels, New charterer, New/other field for vessel.



Company Ref: - ADM 12.1 Technical Operation Department Organization and Responsibility. - ADM 12.3 Administrative routines ( 12.3.6 HR & Tech dept. meetings) - ADM 6.3 Procedure for crew human resources (6.3.4.1 Manage external recruitment item 1a, b, c, d) 3.4.3



Cross-cultural interpersonal skills are promoted.



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No



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Wellbeing of Vessel Personnel Stage 1 3A.1.1



Procedures ensure that each vessel is appropriately manned in order to Yes maintain safe operation onboard. The company shall employ properly qualified personnel who are competent, medically fit and trained. Our objective is to achieve safe and efficient operation with the stipulated manning. The Master may, however, propose changes in the manning with the company. The safety, welfare and social environment of the crew shall be properly maintained. It is important that each individual and in particular the Ship Management Team contributes to achieve this. The company acknowledges that competent personnel are the key for successful ship operation. Each individual must complete necessary training and courses required by company to ensure safe and efficient operation. Company Ref - ADM 3.1 Governing principles (3.1.3.2.5. Vice President Technical Operations - establish manning policies and standards) - ADM 6.3 Procedure Crew HR (6.3.4.1 Item 1a) - VAM 3.1 Crew Policy.



3A.1.2



Shore management provides adequate resources to ensure the wellbeing of Yes vessel personnel. The safety, welfare and social environment of the crew shall be properly maintained. It is important that each individual and in particular the Ship Management Team contributes to achieve this. The company contributes an fixed amount every year to each vessels welfare account, vetting bonus comes in addition. Standard exercise equipment shall be maintained onboard for company account. Welfare matters is fixed on the PEC meeting agenda.



Company ref. - VAM 3.1 Crew Policy. - VAM 3.11 Accounts (3.11.4 Welfare account). - HSE 7.7 Food and Recreation. - HSE 9.1 Protection & Environment Committee. - ADM 6.3 Procedure Crew HR (6.3.8.1 Manage employee health and safety item 1).



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3A.1.3



Procedures ensure that working and rest hours of all personnel are in line with Yes the STCW, applicable Flag State requirements or any relevant authority guidelines for the vessel trade and are being accurately recorded and monitored. Common working hours shall be executed in accordance with the Flag State and CBA requirements. Normal working hours and rest hours shall be permanently displayed onboard in English, and in another working language if so required. The following situation shall generate Non-Conformity reports in company software; If a trend is noticed e.g. same person on-board is consistently breaching rest hour’s requirement. (3 or more days containing “non-conformance” by any individual on board within last 30 days) If the minimum weekly required rest hours are not meet during two consecutive weeks. If less than 6 consecutive hours of rest is recorded during a 24 hours period. ISF Watchkeeper online provides mail notifications to vessel masters/superintendent/ when crew are exceeding set limits. overview and trends are sent to fleet management level on a weekly basis. In anticipation of periods of potential high workload or change of trading pattern, additional personnel may be assigned to or requested from the vessels, this shall be based on a Risk Assessment.



Company Ref; - VAM 3.10 rest hour - Watchkeeper online software. 3A.1.4



A formal D&A policy is implemented and a system is in place to monitor it on a Yes regular basis. Company Policy on the prevention of abuse of alcohol, drugs and narcotics presents guidelines to all Company employees on how to relate to alcohol and narcotics, both when in service and during leisure-time onboard. Upon demand from the Company, Operators and the Authorities, and in order to uncover any abuse and illegal use of alcohol, drugs and narcotics, testing of Ship’s Officers and Ratings may take place. Such testing shall be carried out in accordance with Company Procedures. In order to meet the requirements of Company Drugs & Alcohol Policy, the Company will onboard each vessel, 4 times a year; carry out unannounced and random tests for alcohol abuse. Unannounced drug-and alcohol tests by external company, (Alere toxicology PLC), 3 times per two years and should not extend 12 months between two tests. The tests will be based on urine samples. Company ref; - HSE 3.4 Drugs & Alcohol Policy - HSE 3.1 Drugs & Alcohol - Policy, Objectives & Guidelines (3.1.5 Drug & Alcohol - Test intervals)



Stage 2



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3A.2.1



A defined complaints procedure is in place. Yes With reference to the ILO Maritime Labour Convention (ILO MLC), regulation 5.1.5, the following on board complaint procedure has been established for expeditious handling of seafarer complaints alleging breaches of the requirements of the ILO MLC. Company Ref; - FAT 3.1 Initial familiarization General SMS, HSE & Hazards - VAM 3.21 Complaint & Grievance Procedure. - HSE 11.3 MLC-2006 - HSE 11.4 Isle of Man & UK requirements - ADM 1.App 1A Complaint Report - ADM 1.APP 1B Complaint Log



3A.2.2



A documented disciplinary procedure is in place. Yes Grievance procedure in compliance with flag and CBA requirements is laid down in vessel administration manual and will be followed when the company is offended or dissatisfied with the seafarer's behavior or performance. Personnel involved in operational incidents are followed up by shore staff (personnel, HSSE&QA and/or technical dept.). Post incident assessment are conducted to evaluate corrective actions (training, procedures etc.) Company ref. - VAM 3.21 Complaint & Grievance Procedure. - VAM 3.9 Employee contracts (3.9.2 Disciplinary actions). - HSE 12.2 Reactions on failure to use Personal Protection Equipment (PPE). - VAM App.13 Written warning. - FAT 3.1 Initial Familiarization - General SMS, HSE & HAZARDS



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3A.2.3



Documented procedures are in place to ensure high standards of hygiene are maintained. It is a basic requirement in our QA system to maintain a clean and tidy ship.



Yes



Cleaning and hygiene in general, as far as possible, the Company vessels shall at all times be kept clean and shipshape. Accommodation with common rooms, cabins, storerooms, provision- and cooling/refrigerated spaces shall at any time be kept clean. Cleanliness and hygiene has an important role in the crew’s well-being and shall have priority as it influences occupational health and safety. Crew-members participating in preparation, serving, handling and storing of food, shall attach utmost importance to the requirements to hygiene - both in general and personal, in order for food being handled, stored, prepared and served in the safest and most hygienic manner. Company Ref. - FAT 3.1. Initial Familiarization - General SMS, HSE & HAZARDS. - HSE 7.1 Cleaning & Hygiene in general. - HSE 7.2 Catering Personnel – Personal hygiene & conduct. - HSE 7.3 Catering Department – Cleaning procedures. - HSE 7.5 Cleaning & Hygiene - Documentation. - HSE 7.6 Galley Hygienic Procedure. - HSE 11.2 Monthly HSE - Inspection checklist. - HSE APP 6(a - e) Cleaning logs. 3A.2.4



Retention rates for Senior Officers over a two-year period are calculated. Yes Retention rates for Senior Officers over a two-year period are calculated and included in monthly KPI's. Retention rate is above 90% over a two-year period Company Ref - Monthly KPI report (Quality section) - HSSE&QA Action plan (Retention target) - Management review.



Stage 3



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3A.3.1



Seminars are held for senior officers that promote, emphasise and enhance the Yes company’s SMS. Officer conferences are conducted annually for each fleet segment/Office presence (Haugesund, Manila, Madrid) BPMM- Best practice management meetings, senior management from up to three vessels will be called to office for a mini conference sharing the information and experience gained from operating similar vessels, trade, equipment, charterers, geographical position, terminals and offshore installations It is as a main rule necessary for all our officers to take part of Company Officers Conference if not every year so at least every 3rd year as minimum. All participation in Officer Conference to be registered in Company Human Resource System (OCS). Company Ref: - ADM 6.1 Crew Policy - ADM 6.9 Meetings (6.9.3 Officer conferences.) - HSSE&QA Action plan



3A.3.2



An enhanced documented disciplinary procedure is in place. Yes Company Employment practices and work environment is laid down in code of conduct as well as other governing documents. KM will not condone any type of harassment, abuse or punishment, whether corporal, mental or physical, of an employee by a director, manager or other employee or any partner, customer or supplier of KM.



Company Ref - ADM 3.2 Code of conduct (II. Implementation F. Violation of policy)/ (VIII. Employment practices and work environment. D. Disciplinary practices) - VAM 3.9.2 Employment contracts - Disciplinary actions - HSE 3.4 Drugs & Alcohol Policy - HSE 8.1.8 Disciplinary reactions (Smoking) - HSE 12.2.5 Disciplinary reactions (PPE)



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3A.3.3



Health awareness campaigns are implemented. Health awareness is a part of companies obligations towards BS-OHSAS 18001 certification.



Yes



Examples of health awareness campaign and focus; -Variety of food provides a healthy diet. Meals should provide a balance of carbohydrates, protein, fat and fiber, vitamins and minerals. Food should be prepared and cooked with minimum levels of salt, fat and sugar according to diet standards given by the National Health Authorities. - Company vessels are equipped with gym facilities with standard training equipment & introduction material. (booklet and video "Fit onboard") - Smoking onboard a vessel has been included in the aspects of “Health, Safety & Environment Protection”. In order to reduce safety-risks and health-problems, it is therefore Company objective that smoking as far as possible, should be limited or banned where appropriate. - HSE 8.1 Smoking onboard incl.Health & Safety - Fit onboard (Movie and booklet) 3A.3.4



Retention rates for all officers over a two-year period are calculated. Yes Retention rates for Officers over a two-year period are calculated and included in monthly KPI's Retention rate is above 90% over a two-year period for officers.



Company Ref - Monthly KPI report (Quality section) - HSSE&QA Action plan (Retention target) - Management review.-



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Stage 4 3A.4.1



Seminars are held for all officers to promote, emphasise and enhance the Yes company’s SMS. Officer conferences are conducted annually for each fleet segment/Office presence (Haugesund, Manila, Madrid) It is as a main rule necessary for all our officers to take part of Company Officers Conference if not every year so at least every 3rd year as minimum. All participation in Officer Conference to be registered in Company Human Resource System (OCS). Company Ref: - ADM 6.1 Crew Policy - ADM 6.9 Meetings (6.9.3 Officer conferences.)



3A.4.2



A documented procedure to conduct vessel health-risk assessments is in place. Yes Risk Assessment is a vital tool to evaluate the risk in various operations onboard, both routine and non-routine activities. Hazards to health shall be assessed on the same level as direct energy hazards. Company ref. HSE 5.1 Risk Assessment / Risk evaluation.(5.1.2 item 2 Identifying hazards) HSE 5.3 Toolbox talk - risk identification form. HSE 5.5 Risk assessment form.



3A.4.3



The company provides career development opportunities by arranging shorebased assignments for vessel personnel. Officers are given the opportunity to work at the office. This is particularly in connection with projects, but also in many other aspects where operational experience is needed.



Yes



Company Ref. - ADM 14.17 Short term Commitment for Sailing Personnel at the Office. - ADM 14.2 Procedure for Human Resources ( 14.2.3.2 Item 4). - ADM 11.7 Personnel.



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Vessel Reliability and Maintenance Stage 1 4.1.1



Each vessel in the fleet is covered by a planned maintenance system and spare Yes parts inventory which reflects the company’s maintenance strategy. The computer based maintenance system is delivered by Tero Marine, and is onboard all our ships. the structure is based on SFI Group System and includes all parts of the vessel, such as engine systems, deck, hull inspections, galley, cargo and bridge. Spare part, docking & claims and purchase are modules included in the same software package. In-house training course is given to users



Company Ref; - VOM 8.2 Planned maintenance system (PMS TM-master) - FAT 5.8 TM master / PMS Approval - FAT 7.2. Course matrix 4.1.2



A defect reporting system is in place for each vessel within the fleet. Yes It is of outmost importance that vessels reports all undesired events, in order to obtain continuous improvement of the Work Environment and Safety Level onboard, and to prevent ill health, injuries and harm to the environment, in accordance with the requirements described in ISO 9001:2008, ISO14001:2004, MLC-2006, OHSAS 18001:2007 and in the ISM Code. Reports/Observations from vessels are important initiatives to the Company, in order to obtain and document continuous improvements on all levels within the Safe Operation of the Company vessels. Simultaneously, Reports/Observations from the vessels are also very important with regards to revision, development and improvement of the Company Administrative HSE&QA Systems. The Company will always strive to give the necessary handling and follow-up all reports/observations received from the vessels. The Company shall also encourage the vessels to report Preventive Measures, represented by Near Miss, Non-Conformities and Suggestion for Improvements. Condition of Authority (CA) and Condition of Class (CC) shall always be recorded in UniSea Audit to ensure proper investigation and action, there shall be registered one finding pr. Condition issued by the class authorities, this to ensure that each case can document proper follow up by the vessel and company. Vessels superintendent is responsible for ensuring that each case is closed down within the given deadlines. - HSE 6.1 HSE&QA Reports from the vessels. - VOM 8.2.1.2 TM-Master – main principles - DOCMAP/UNISEA



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4.1.3



Company management regularly reviews the status of fleet maintenance. Yes The computerized spare part and maintenance system keeps track of maintenance due, as well as records of jobs done (history). The amount of overdue jobs shall be kept at a minimum. Deficiencies shall be repaired as soon as possible. Maintenance jobs shall be done when they fall due. The target for overdue jobs in the TM Master is 1% of all jobs. Postponement of maintenance and repairs shall be based on Risk Assessment, e.g. by regular inspections. Deficiencies that may result in a condition of class should be reported to company. Maintenance status is regularly checked by superintendents or fleet manager, PMS system is an online software ensuring that technical management ashore have access to all maintenance records performed onboard company vessels at all times. Overdue maintenance is also defined as a KPI and is thus reviewed by management monthly. Company Ref. - VOM 8.1 Maintenance & repairs in general - VOM 8.2 Planned maintenance system (PMS TM-master) - VOM 8.9 Critical equipment list. - ADM 3.4.1 (C) reporting routines. - Monthly KPI report "quality section"



4.1.4



The company monitors outstanding planned maintenance tasks. Yes The computerized spare part and maintenance system keeps track of maintenance due, as well as records of jobs done (history). The amount of overdue jobs shall be kept at a minimum and jobs on critical components shall be prioritized. PMS system is an online software ensuring that technical management ashore have access to all maintenance records. Overdue maintenance is also reviewed by management monthly as part of the companies KPI's. Overdue maintenance can be monitored on Vessel, fleet segment or company level. Company Ref - Q:\TEKNISK\Technical file\TM-Master\KPI (Valid)\KPI 2017 - Monthly KPI report. - HSE 8.2 Planned maintenance system. - ADM 3.4 3.4.1 (C) Purpose of instructions for the President & CEO



Stage 2



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4.2.1



A procedure is in place to ensure the validity and accuracy of statutory and/or Yes Classification certificates. Master is responsible for class and statutory certificates onboard while Superintendent is responsible from shore and overlooks/monitors certificates using class software and notification system. All certificates must be added in the TMv2 with their expiry date, survey window and a copy of the original certificate added as an attachment. Company Ref. - VAM 4.4.2 Class and statutory certificates - VAM 4.4.2.1 Survey intervals - ADM 12.6 Critical Equipment - ADM JD-10 Vessel superintendent.



4.2.2



Cargo, void and ballast spaces are inspected to ensure their integrity is Yes maintained. Tank inspection procedures are described in a special inspection manual and in Vessel Operation Manual. inspection intervals for tanks and spaces are defined in vessel operation manual. All tank inspections are recorded on a controlled format for inspection, the procedure includes taking representative photos. which are uploaded into vessel PMS together with the inspection report. In addition to the above, tanks adjacent to cargo tanks are checked for the ingress of cargo on a regular basis as laid down in vessel operation manual Company Ref: - Company Tank/steel Inspection manual. - VOM 9.12 Tanks, cofferdams & other enclosed spaces. - VOM 9.13 Periodic inspection of ballast- & other tanks for ingress of liquid cargo



4.2.3



Superintendents verify maintenance and defect records during ship visits. Yes Superintendents visit the ships two times a year. One of the visits should preferable be conducted while sailing with the vessel. Any visit shall normally be followed by a well documented “Ship visit Report” that describes among other, the general standard of maintenance, pictures, Annual inspection checklist etc... Fleet Safety Inspectors may perform technical visit upon request from the vessels superintendent, in these cases the fleet safety inspector shall complete and file Ship Visit Report. All ship visit reports shall be entered into Unisea Audit. items for follow up shall be generated as action points to ensure proper follow up.



Company Ref: - ADM 12.8.4 Ship visits and internal audits - ADM 12 APP A. Ship visit report. - HSE 6.1.6 Company inspections onboard the vessels - Unisea.



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4.2.4



The company has a formal system to develop dry-dock specifications, which Yes involves collaboration between the vessel and shore management. KNOT standard general clauses and docking specification formats shall be used. Once the ship has left the yard, the ship shall start preparing for the next docking. Job descriptions shall be entered into the PMS System. standard Jobs in the TM-Master may also be postponed till docking, as applicable. In this way, the ship’s specification can be sent to the Superintendent on a very short notice Docking Jobs entered into vessel PMS system are handled through the PMS software's docking module between ship and office Company Ref: - VOM 8.8.0 Docking and repairs. - ADM 12.13 Docking - Planning, Execution And Reporting.



Stage 3 4.3.1



A common computer-based maintenance system onboard each vessel records Yes all maintenance tasks and incorporates the defect reporting system. The system includes a facility to make extensive descriptions of jobs done, in addition to the job description as such. Such description will then be a part of the equipment history. Company Ref:



4.3.2



The company policy is to maintain an optimum spare parts inventory or system Yes redundancy for all vessels. As inventory of spare part represents locked-up equity (assets), it is important to minimize rather than optimize the number of spare parts. On the opposite side, lack of spare parts may result in hazardous situations or in substantial loss of revenue - if the ship goes Off Hire. For the most costeffective operation it is therefore important that Ship Management Team, as well as other Shipboard Personnel continuously review the vessel’s inventory of spare parts. As guidance, Chief Engineer shall assure himself that Spare Parts to be used for Planned Maintenance during the next 6 months, are already onboard, or have been included in Purchase Orders sent to the Company PMS system includes spare parts inventory and ordering system. Initially equipment spare parts are based on maker’s recommendation, but re-supply level may be adjusted based experience and equipment criticality. Company Ref: - VOM 8.4.2 Spare Parts – Availability - Inventory.



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4.3.3



Performance indicators have been developed to monitor fleet reliability. The performance indicators are measured for individual vessels and fleet wide. Performance indicators have been developed to monitor fleet reliability, PI are included in Company Internal KPI's



Yes



Company Ref: - KPI report (internal) 4.3.4



The frequency and extent of structural inspections of the vessel’s cargo ballast and void spaces is determined based upon risk criteria. The cargo containment system is considered as critical parts of the ship for several reasons: - Pollution - Danger for explosion - Cargo contamination - Hull strength



Yes



Ballast tanks are considered critical for the following reason - As secondary barrier or double hull - Hull strength In general, the technical life of a ship very much relies on the condition of the hull. It is therefore Company Policy to carry out continuous maintenance of not only the outer hull, but also the inside of the tanks. Exposed tank areas (e.g. bow and midships) should also be inspected shortly after a period of extreme weather. (The annual inspection of these tanks should preferably be scheduled after the winter season). Furthermore, new repairs shall be re-inspected, e.g. after 3-6 months. If possible, inspections shall be carried out in due time before dry-docking, in order to prepare for necessary repairs. Reference is made to Tank Inspection Manual and inspection forms. The TM master shall be updated with filled in SRF tank inspection forms. If a form is not attached, the condition shall be written in the “jobs done” display.



Company Ref - VOM 9.12 Tanks, cofferdams & other enclosed spaces. - Company Tank Inspection Manual



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Stage 4 4.4.1



The maintenance and defect reporting system integrates the spare parts inventory management and procurement systems. Vessel PMS integrates spare parts inventory management and procurement. (TMv2)



Yes



Company Ref: - VOM 8.4.1 Computer-based Spare Part System - TMv2 Software 4.4.2



The maintenance and defect reporting system tracks all deferred repair items Yes for inclusion in the dry-dock specification. Overdue jobs on are tracked and can be deferred to docking list. Work list for docking are kept separately. TMv2 PMS includes a separate docking/project module."



Company Ref: - VOM 8.2.1.2 TM-Master – main principles. - VOM 8.1 Maintenance policies and procedures. - ADM 12.13 Docking - Planning, Execution And Reporting. - TMv2 Softeware 4.4.3



The maintenance and defect reporting systems provide management with a real Yes time status of fleet maintenance. TMv2 is online and sync automatically between ship/shore servers for all vessels. All data is fully accessible from shore. Company Ref - VOM 8.2.1.2. TM-Master – main principles



4.4.4



The planned maintenance system includes the use of condition-based No monitoring in order to ensure optimal equipment performance. Company PMS includes the use of condition-based monitoring on Oil analysis (fuel / Lub) as well as Infrared monitoring and thermal mapping. Intervals are included in TMv2. Company ref, - VOM 06-07 Bunkering. - VOM 8.1.9 Lub. Oil Analysis – Sampling. - Technical bulletin 01/08.



4.4.5



Comprehensive engineering audits are completed by a suitably qualified and experienced company representative. The audit includes observation of engineering practices while on passage.



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Vessel Reliability and Maintenance (Critical Equipment) Stage 1 4A.1.1



Critical equipment and systems are identified and listed within the SMS and the Yes vessel’s planned maintenance system. Critical systems, equipment and alarms are those “which in case of a sudden operational failure”, may result in a hazardous situation”. Critical equipment is listed in VOM chapter 8.9 and included in the Planned Maintenance System Company Ref, - VOM 8.3 Critical equipment - VOM 8.9 Critical systems, equipment and alarms



4A.1.2



A procedure is in place to manage the planned maintenance of critical Yes equipment and systems. Maintenance of critical equipment consists of procedure, flowchart, risk assessment and permit to work. Company Ref - VOM 8.3.8 Maintenance of critical equipment. - VOM 8.11 Risk assessment of critical equipment. - HSE 4.31 Work Flow for Critical Equipment. - HSE 4.32 Work Permit for Critical Equipment.



4A.1.3



A procedure is in place which requires shore management to be informed when Yes critical equipment or systems become defective or require unplanned maintenance. Deficiencies of critical systems, equipment and alarms shall be reported as follows: Serious defects to critical equipment shall be reported as soon as possible. Other defects if the equipment is in use or about to be used - during day time. Non conformity report will normally be made. Company Ref - VOM 8.3.3 Reporting to Company



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4A.1.4



Procedures are in place to record the testing of critical equipment and systems Yes that are not in continuous use. Maintenance of Critical Equipment has the highest priority and shall not be overdue. If for any reason it is not possible to do a scheduled job on time, A Non-Conformity report shall be issued; this report shall describe why the maintenance could not be done within schedule, when it is expected to be done, what measures is taken to ensure function and effect of the equipment in the period up until the maintenance will be done. The Maintenance System shall include the following: - Function and performance tests. For equipment seldom in use, tests shall be carried out to ensure that Operators’ skills are maintained. - Maintenance history shall be properly recorded. - Only personnel/crewmembers having the required and satisfactory knowledge and skills shall be allowed to carry out maintenance of critical equipment. - After completion of work, Chief Engineer or his deputy shall inspect the equipment and supervise relevant function tests, before the equipment is put back into service. - A work permit is needed when maintenance is to be carried out on Critical Equipment



Company Ref. - VOM 8.3.8 Maintenance of critical equipment.



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Stage 2 4A.2.1



Maintenance on critical equipment and systems requiring them to be taken out Yes of service is subject to risk assessment and management approval. Maintenance on Critical Equipment shall not be performed unless all the following steps have been documented: - Risk Assessment is carried out. - If needed request for Permit to Work for Critical Equipment, shall be addressed to Ship Superintendent, with CC to backup superintendent and “Arkiv” - The request shall be sent by Master, or Chief Engineer or Chief Officer. In case of repairs on critical equipment a formal permit to work procedure has been established including risk assessment, flowchart and shore-side approval when certain criteria s are meet Company Ref: - VOM 8.3.8 Maintenance of Critical Equipment. - VOM 8.11 Risk Assessment for Critical Equipment – Instructions. - HSE 4.31 Work flow for critical equipment. - HSE 4.32 Work permit for critical equipment.



4A.2.2



Work instructions are available in the planned maintenance system for critical Yes equipment and systems. The list of critical equipment is included in Vessel Operation Manual chapter 8. The items are also included in the TMv2 (PMS) Company Ref: - TMv2 job description for critical equipment.



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Stage 3 4A.3.1



Designated personnel are responsible for the maintenance and repair of critical Yes equipment and systems. Maintenance of Critical Equipment has the highest priority and shall not be overdue. If for any reason it is not possible to do a scheduled job on time, A Non-Conformity report shall be issued; this report shall describe why the maintenance could not be done within schedule, when it is expected to be done, what measures is taken to ensure function and effect of the equipment in the period up until the maintenance will be done. The Maintenance System shall include the following: - Function and performance tests. For equipment seldom in use, tests shall be carried out to ensure that Operators’ skills are maintained. - Maintenance history shall be properly recorded. - Only personnel/crewmembers having the required and satisfactory knowledge and skills shall be allowed to carry out maintenance of critical equipment. - After completion of work, Chief Engineer or his deputy shall inspect the equipment and supervise relevant function tests, before the equipment is put back into service. - A work permit is needed when maintenance is to be carried out on Critical Equipment Company Ref. - VOM 8.3.8 Maintenance of Critical Equipment.



4A.3.2



A procedure is in place to test and record performance data for all critical Yes equipment and systems. Procedure to test and record performance data for critical equipment is documented in Vessel operation manual. Company Ref - VOM 8.3.8 Maintenance of Critical Equipment



Stage 4 4A.4.1



The reliability and performance of critical equipment or systems and associated Yes alarms is monitored and analysed. The maintenance system is a pro-active system with intervals as recommended by makers and owner experience. Special emphasis is put on critical equipment and systems. Company Ref. - VOM 8.2 Planned maintenance system - VOM 8.3 Critical equipment. - TMv2



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Navigational Safety Stage 1 5.1.1



The company designates appropriate shore-based personnel responsible for Yes navigational standards. The vetting Manager together with Senior Superintendent designated for maintaining navigational standards and procedures. Company Ref: - ADM Appendices Job description - VD 1.



5.1.2



Comprehensive procedures to ensure safe navigation are in place. Yes The Company shall ensure that the vessels can sail safely in the designated areas. Execution of safe voyages requires qualified navigators who understand and follow the Company and industry navigational procedures. The bridge and other equipment shall be in good working condition. The Master shall closely monitor that the bridge team works as expected, and he shall introduce corrective actions as required. Furthermore, the Master has the overriding authority to make any decision required to maintain a minimum safety level. Company Ref: - VOM Chapter 2 Bridge checklists - VOM chapter 4 navigation.



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5.1.3



Procedures to ensure effective bridge resource management are in place. Yes Master shall ensure that the composition of the Bridge Team at any time is maintained at a satisfactory level. Weather, traffic as well as the skills and abilities of each of the members of the bridge team shall be taken into account. The poster “Watch matrix” shall be posted on the bridge showing the bridge manning in various navigational situation. The competence and the alertness of the Duty Officer(s) are the most important qualities to avoid any dangerous situations. The main elements in Bridge Resource Management shall be reviewed and practiced by the bridge team members. This includes but is not limited to the importance of having an open and positive dialogue which allows subordinates to question instructions from and acts by their superiors. It is essential that the Duty Officer is clear about the actions that Master expects him to take while on duty. It is therefore necessary to have bridge procedures, clearly defined and in compliance with the standards included in this Manual. In addition, all Deck Officers shall be familiar with ICS Bridge procedures Guide. If Captain change of command takes place while the ship is not moored or anchored, the chief officer shall be in command on the bridge.



Company Ref - VOM Chapter 2 Checklists. - VOM Chapter 4 Procedure. - PBR 35 Watch matrix. 5.1.4



The company has procedures that ensure all navigational equipment is Yes maintained as operational. The duty officer shall always ensure that the ship’s navigation and communication equipment is in good working condition and is responsible to report any defects to the Master. The Master is responsible to monitor that this equipment is properly maintained in a timely manner. It is important that Bridge Officers are familiar with the respective Operating Manuals, for each piece of equipment, particularly with regard to: - normal operation of the equipment; - use of controls and control procedures; - procedures to be followed in the event of failures of the same equipment.



Company Ref. - VOM 4.21.1 General information on navigation equipment. - VOM 4.21.14 Service on bridge equipment. Stage 2



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5.2.1



A procedure is in place requiring the Master to conduct a navigational audit to Yes ensure compliance with navigational regulations and company procedures. The Master shall verify himself that the bridge team fully understand and complies with all bridge procedures. The check list "Master’s verification of skills” shall be filled in for all new deck officers. To be completed in connection with: 1) Evaluation report for deck officers (at least annually). 2) For navigators the Captain has never sailed with – within 14 days. If a Navigational audit is carried out in connection with above criteria’s, the report shall be filed on board. All Masters are required to perform Navigational Audit at least every three months. The basis for the Navigational Audit shall be Sire VIQ CH. 4 and 10. The inspection and findings shall be filed and followed up in Unisea Audit.



Company Ref. - VOM 4.1.3 Master’s Verification of skills & Masters Bi-annually Navigational Audit. 5.2.2



A procedure is in place for appropriate shore-based personnel to conduct Yes navigational verification assessments. Bridge procedures and navigational standards are reviewed during internal ISM audits. In addition the company has assigned marine superintendents to carry out safety audits onboard our vessels. They will sail with the vessels and as part of the audit; they will monitor the skills for each navigational officer. Purpose made checklists are used for this audit, these checklists are based on company procedures and VIQ navigational chapter. Company Ref. Fleet safety Audit report.



5.2.3



The person(s) responsible for navigational standards ensures that navigational Yes procedures are regularly reviewed and updated. Vetting Manager together with his team are responsible for maintaining and updating navigational standards and procedures. Company ref: - ADM 20.0 App VD1 Vetting manager.



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5.2.4



The company has a procedure to identify recurring defects in navigational Yes equipment across the fleet. Instructions for reporting of inoperative navigational equipment is stated in company navigational procedure. Records of breakdown can be observed in company maintenance system.



Company Ref: VOM 4.1.7 Reporting of defect navigational equipment Stage 3 5.3.1



Provision of charts, publications and electronic licenses is managed under Yes contract by a recognised chart agent. All vessels are fully equipped with minimum dual ECDIS and are in compliance with all regulations and procedures. ENC cells are supplied by NAVTOR. ENC cells are weekly updated. Company ref: - VOM 4.6 Passage planning - VOM 2.20 Passage planning checklist



5.3.2



A formal programme ensures that Senior Officers receive appropriate shipYes handling training before promotion to Master or assignment to a new vessel type. All Chief Officers shall on regular basis berth and unberth the ship and train to be in command during pilotage. To support onboard training Senior Officer also attend simulator training in ship handling/DP on a regular basis. Comapny Ref: - VOM 4.1.6.1 Watch system for Chief Officer / Training for next level. - FAT 7.2 Course matrix.



5.3.3



Comprehensive navigational audits are conducted while on passage by a Yes suitably qualified and experienced company representative. Comprehensive navigational audits are conducted while vessels are on passage, these are performed by Sailing marine superintendents on a annually. During his stay on-board he joins the different OOW while on duty for a proper evaluation of their skills. Audit questionnaire/checklist is based on Company procedure and OCIMF SIRE VIQ. Navigational audits are registered, follow up and closed out in UniSea Audit. Comapny Ref: - Safety Audit checklist - UniSea Audit.



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Stage 4 5.4.1



Comprehensive navigational audits are conducted while on passage by a Yes suitably qualified and experienced person. Comprehensive navigational audits are conducted while vessels are on passage, these are performed by Sailing marine superintendents on a annually. During his stay on-board he joins the different OOW while on duty for a proper evaluation of their skills. Audit questionnaire/checklist is based on Company procedure and OCIMF SIRE VIQ. Navigational audits are registered, follow up and closed out in UniSea Audit. Comapny Ref: - Safety Audit checklist - UniSea Audit.



5.4.2



All navigational assessment and audit reports from the fleet are analysed, trends identified and improvement plans are developed. All audit reports (SIRE, PSC, FMEA, audits by class, flag and fleet safety audits are registered, analysed and closed out in Unisea. giving the company a broad foundation of data to trend, analyse and initiate actions one.



Yes



Company ref - UniSea Audit. - Company quarterly bulletins. - Management review 5.4.3



Competency assessment programmes ensure that Masters and navigation officers maintain core and specialist skills.



No



5.4.4



Navigation officers undertake periodic refresher bridge resource management simulator training at a national or industry accredited shore establishment.



No



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Cargo, Ballast, Tank Cleaning and Bunkering Operations Stage 1 6.1.1



Procedures for cargo, ballast, tank cleaning and bunkering operations are in place for all vessel types within the fleet. Procedures for cargo, ballast, tank cleaning and bunkering operations are laid down in Vessel operation Manual Chapter 5 and 6.



Yes



Company ref - VOM Chapter 5 Cargo - VOM Chapter 6 Bunkering. - VAM job description Chief officer. 6.1.2



Procedures for pre-operational tests and checks of cargo and bunkering Yes equipment are in place for all vessel types within the fleet. Procedures for pre-operational tests and checks of cargo and bunkering equipment are covered in Vessel operation manual Company ref; - VOM Chapter 2.30-72 Operational checklists cargo and engine. - VOM Chapter 5 Cargo procedure. - VOM Chapter 6 Engine procedure. - VOM 9.2 Cargo monitoring equipment. - VOM 9.3 Cargo equipment.



6.1.3



Management ensures that cargo, ballast and bunkering operations are Yes conducted in accordance with company procedures. Cargo plans (loading and discharge) are reviewed and approved by the Master onboard. Cargo plans are checked at random by fleet safety inspectors, superintendent visits and internal audit annually. Company Ref: - VOM 5.4. Cargo Handling. - Fleet safety reports. - Unisea Audit



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6.1.4



The company has procedures that address cargo specific hazards for all vessel Yes types within the fleet. MSDS shall be provided by supplier prior to taking onboard Annex 1 cargo according to SOLAS Chapter VI Carriage of cargo regulation 5-1 MSDS, Failure by the shipper to deliver MSDS of the received cargo shall generate a letter of protest. Information about the content of H2S and/or other toxic gases shall be obtained from the Charterers/Shippers. To ensure that personnel involved in cargo handling/operations are not exposed to levels of hazardous/toxic gas above industry/company levels, all personnel involved in the operation should be equipped with personal gas detection device. Company Ref: - VOM 5.2.5 Material Safety Data Sheet. - VOM 5.2.6 Gas monitoring. - HSE 13.1 Health Hazards. - VOM 2.51 checklist Precautions when loading crude oils containing H2S.



Stage 2 6.2.1



A comprehensive procedure for planning cargo, ballast and bunkering Yes operations is in place for all types of vessel within the fleet. Comprehensive procedure for planning cargo, ballast and bunkering operations is laid down in Vessel operation manual chapter 2 checklists cargo section, 5 Cargo operations and chapter 6 Engine operations. Company Ref. - VAM 2.0 Shipboard Organization job description. - VOM 2.30-51. Cargo checklist. - VOM 2.65 Bunkering checklist. - VOM 5 Cargo operations. - VOM 6.7 Bunkering procedure. - Posters



6.2.2



Comprehensive procedures cover all aspects of cargo transfer operations for Yes each type of vessel within the fleet. Procedures covering cargo operations is documented in Vessel Operation Manual, Procedures are found in chapter 5 Cargo operations (shuttle tankers), chapter 10 Cargo Operations (product/chemical tankers) while supporting checklists are located under chapter 2.30 to 2.51. Company Ref - VOM 2.30 - 2.51 Cargo checklists. - VOM 5 Cargo operations Shuttle tankers. - KNOT posters program PCO.



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6.2.3



Comprehensive procedures cover all aspects of ballast handling operations. Yes Procedures covering normal ballast operations is documented in Vessel Operation Manual 5.7 ballast operation.



Company Ref - VOM 5.7 Ballast operations. - Ballast water management plan. - KOAS posters program PCO. 6.2.4



Comprehensive procedures cover all aspects of tank cleaning operations for each vessel type within the fleet. Procedures covering tank cleaning is documented in Vessel Operation Manual.



Yes



Company Ref - VOM 10.0 Cargo operations product/chemical tankers. - VOM 10.6 Wall-wash. - VOM 10.9 Sweeping cargo tanks - VOM 10.13 Cargo Line Cleaning. - VOM 5.33 Inerting / gassing up / cooling down and gas freeing 6.2.5



Comprehensive procedures cover all aspects of bunkering operations for each vessel type within the fleet. Company bunkering procedures is stated in vessel operation manual chapter 6.7 Bunkering



Yes



Procedure cover the following; - Ordering – quality and amounts. - Fuel quality analysis. - Off spec bunkers. - Preparations for bunkering. - Bunkering Personnel. - Mixing of fuels. - Calculation of quantities received - receipt. - Completion. - Hydraulic and Lubricating Oils. - Checklists. - Internal Transfer. Bunkering procedure is supported by relevant checklist. Company ref; - VOM 6.7 Bunkering. - VOM 2.65 Bunkering checklist. - VOM 8.1.9 Lub. oil Analysis. - TB 01/2008 sample intervals. Stage 3



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6.3.1



Standardised templates are used for planning and operational record keeping. A variety of company templates are found in each manuals appendix section.



Yes



- VOM Appendix - HSE Appendix - VAM Appendix 6.3.2



Procedures for each vessel type within the fleet ensure tank atmospheres are maintained within defined limits for each cargo type being carried throughout the voyage cycle. Procedures for tank atmospheres is stated in Vessel Operation Manual.



Yes



Pressure in the cargo tanks shall be maintained at min 20 mbar/200mmH2O and topped up when necessary during the voyage. The oxygen content in cargo tanks is verified prior arrival Port/oil field and shall not exceed 8%. During voyage, tank pressure shall be checked regularly, readings shall be recorded in Deck logbook at noon. Company Ref: - VOM 5.4.5 Production and use of Inert Gas. - VOM 5.4.6 Failure of inert gas plant. 6.3.3



The SMS includes procedures for non-routine or specialised cargo and ballast operations undertaken in the fleet. Specialized operations operations are covered in Vessel or ship specific operation manuals.



Yes



STS - VOM 7.4 Ship to ship. - VOM 2.42 - 2.48. - Ship STS manual. BLS - VOM 5.4.4 Offshore loading. - VOM 2.41 Cargo operation offshore loading. - Field offshore manual Vapour return and vapour balancing. - VOM 5.5.3.2 Vapour return. - VOM 5.5.3.3 Vapour balancing. - Ballast water management plan.



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6.3.4



The SMS requires Junior Officers/relevant personnel to be actively involved in Yes planning, line setting and execution of the cargo, ballast, tank cleaning and bunkering operations as part of their continuing personal development plan. All junior officers have their individual training program in accordance with STCW – 95 requirements, in addition junior officer have to undertake our job familiarization and training for next rank, which incl. preparation and execution of cargo & bunkers operations depending on department. Company ref: - VAM 3.19 Evaluation Reports. - VAM 2 Job description (officers)



Stage 4 6.4.1



6.4.2



Officers attend shore-based simulator courses covering routine and emergency cargo operations.



No



Comprehensive audits are completed by a suitably qualified and experienced Yes company representative. The audit includes observation of cargo, ballast, tank cleaning and bunker handling operations. Comprehensive audits are conducted while vessels is performing cargo operations, these audits are performed by Sailing marine superintendents on a annual basis. During his stay on-board he joins the different OOW while on duty for a proper evaluation of their skills. Audit questionnaire/checklist is based on Company procedure and OCIMF SIRE VIQ. The audits are registered, follow up and closed out in UniSea Audit. Comapny Ref: - Safety Audit checklist - UniSea Audit.



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Mooring and Anchoring Operations Stage 1 6A.1.1



Procedures for mooring and anchoring operations are in place for all vessel types within the fleet. Company procedures are based on OCIMF Mooring Equipment Guidelines and consist of procedures that includes risk assessment, responsibilities and checklists. Safety precautions included in a Safety Handbook located in each cabin, as well as a training module in Seagull’s “Computer based Training System”



Yes



Company Ref - VOM 4.9 Anchoring. - VOM 4.12 Mooring. - Welcome onboard booklet QA- server. - Unisea Risk. - FAT 6.2 CBT training matrix 6A.1.2



Maintenance, testing and routine inspections of mooring and anchoring equipment is included in the planned maintenance system. The PMS covers all maintenance jobs on mooring equipment components.



Yes



The following components are include, but not limited to: - Winches and windlasses. - Roller fairleads, panamas, bow chain stoppers. - Hydraulic, steam, or electrical drive systems. - Emergency towing systems. Brake testing is conducted according to industry guidelines. Company Ref - VOM 8.2.1.2 Planned maintenance system. - Main principles 1 - VOM 8.4 Spare part system - PMS system SFI 434.



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6A.1.3



The company has procedures to manage the condition of mooring ropes, wires, Yes mooring tails and joining shackles for all fleet vessels. Replacement of wires is based on the condition in addition to the wire age. The wire shall be turned when deemed necessary based on the wire condition, but with a max limit of 5 years. After 10 years the wire should be discarded. The vessel shall keep a record including wire number, certificate number, winch position, TM Number, date installed, date turned, days in use, number of mooring operations, grease interval, % of broken strand, external corrosion, diameter measurement, wire been spliced and any deformation. Tails: Mooring tails shall be closely monitored and replaced after max 18 months. Company Ref - VOM 4.12 Mooring. - VOM APP 04 Mooring inspection form. - Inspection and Removal Guidelines for Mooring Lines



6A.1.4



The company has procedures that address the use of tugs. Yes Tugboat operation are always supervised by the person in charge when securing and "let go". Responsible shall not involve himself in the operation, but maintain a supervisory role to closely monitor the operation of both tug and own crew. When letting go, there shall be no strain on the mooring line. Towline received from the tug shall be in compliance with OCIMF-MEG, and shall have an eye of minimum 180 cm. If not, the towline may not be accepted. Strong point for tug escort fitted on all vessels. Company Ref: - VOM 4.12.10 Tugboats.



Stage 2



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6A.2.1



Detailed procedures address each different type of mooring operation likely to Yes be undertaken by fleet vessels. Prior to berthing, Master shall agree with the Pilot (representing the terminal) on the mooring plan, including the number of ropes, wires and positions of mooring lines. The plan shall take into account the effect of passing ships (surge), current and weather forecast. It shall be discussed with the persons in Charge of mooring operation at the forecastle and on poopdeck. In addition to the general Risk Assessment for mooring operations, specific risk assessments shall be considered for various special mooring arrangements. The Person in Charge shall give proper instruction to deck crew in the use of winches, both to avoid ropes and wires in the propellers and/or thrusters, but also to exercise caution to prevent shore personnel being injured. Master and the persons in charge on the mooring deck shall ensure that ropes and/or wires are correctly reeled in on the drums, also to see that split drums are correctly used. Tight mooring ropes shall not be left on warping heads, but be properly secured on bollards. Master at his discretion, may demand additional mooring ropes. Master at his discretion, may prepare and maintain a booklet, presenting mooring arrangements and facilities at berths visited and moorings used. Company standard Risk assessment for mooring operations expected is available in UniSea Risk. Company Ref: - VOM 4.12.6.1 Mooring Procedures. - VOM 4.12.7 Mooring Booklet. - UniSea Risk.



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6A.2.2



Procedures address all aspects of anchoring operations likely to be undertaken by fleet vessels. Company procedures describing anchoring address all aspects of the operation.



Yes



Aspects include; - Approaching anchorage the largest scale charts available and relevant Sailing Directions shall be studied. - Weather conditions and forecasts shall be taken into consideration, together with other relevant information required for safe anchoring. - If vessel is in an open and exposed anchorage and with poor holding grounds or near water or other ships or, the main engines shall be kept ready for maneuvering on short notice. - The speed over ground shall be close to nil. - The length of cable outside the hawse pipe shall be sufficient to ensure weight and flexing, e-g- 410 times the water depth depending on ship size and weather. - The anchor, chain and chainstopper is designed with SWL according to the ship’s equipment number, sufficient to withstand forces from adverse weather. - Ensure that the chain stopper is properly closed to take the full force from the anchor chain, the brakes shall not take this force. - An arrangement should be fitted to the chain (e.g a stick with a piece of cloth) so that any movement of the chain can be seen from the bridge (where this is possible). To avoid drifting, it is important to consider when to heave the anchor. Combination of wind, sea state and current must be carefully considered as well as the location of the anchorage and nearby vessels. With a depth to draft ratio less than 2, the current and wave forces can be very significant and even more than the wind forces. When anchoring over an extended period of time, anchor should be lifted up to water surface every 10 days to limit the amount of kinks on the anchor chain Company standard Risk assessment for anchoring operations has been made and published in UniSea Risk.



Company Ref: - VOM 4.9 Anchoring. - UniSea Risk.



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6A.2.3



Procedures ensure that vessels remain safely moored at all times. Yes Prior to berthing, Master shall agree with the Pilot (representing the terminal) on the mooring plan, including the number of ropes, wires and positions of mooring lines. The plan shall take into account the effect of passing ships (surge), current and weather forecast. It shall be discussed with the Officers in Charge of mooring operation at the forecastle and on poopdeck. In addition to the general Risk Assessment for mooring operations, specific risk assessments shall be considered for various special mooring arrangements. The Person in Charge shall give proper instruction to deck crew in the use of winches, both to avoid ropes and wires in the propellers and/or thrusters, but also to exercise caution to prevent shore personnel being injured. Master and the persons in charge on the mooring deck shall ensure that ropes and/or wires are correctly reeled in on the drums, also to see that split drums are correctly used. Tight mooring ropes shall not be left on warping heads, but be properly secured on bollards. Master at his discretion, may demand additional mooring ropes. Company Ref: - VOM 4.12.6.1 Mooring procedures. - VOM 4.12.6.2 Safety precautions during severe weather in port. - VOM 5.2.3 Manning - VOM 5.14 Deck Watchman - During Cargo Operations.



6A.2.4



Procedures are in place for the inspection, maintenance and replacement of Yes wires, ropes, tails and ancillary equipment. Replacement of wires is based on the condition in addition to the wire age. The wire shall be turned when deemed necessary based on the wire condition, but with a max limit of 5 years. After 10 years the wire should be discarded. The vessel shall keep a record including wire number, certificate number, winch position, TM Number, date installed, date turned, days in use, number of mooring operations, grease interval, % of broken strand, external corrosion, diameter measurement, wire been spliced and any deformation. Tails: Mooring tails shall be closely monitored and replaced after max 18 months. Company Ref - VOM 4.12 Mooring. - VOM APP 04 Mooring inspection form. - VOM 8.4 Spare part system. - VOM 8.2 TM-Master - main principles. - TMv2 Records.



Stage 3



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6A.3.1



Procedures identify requirements for personnel involved in mooring operations. Yes Prior berthing the Master will agree with the Pilot (representing the terminal) on the mooring plan, including; number of ropes (ship/shore), wires and positioning of the lines. The plan will take into account the effect of passing ships (surge), current and weather forecast, information is then discussed with the persons in Charge of mooring operation at the forecastle and on poop-deck. Toolbox Talks are conducted before any mooring, ship to ship operation and offshore loading, in addition to the general/specific Risk Assessments for mooring operation. The Person in Charge shall give proper instruction to deck crew in the use of winches, both to avoid ropes and wires in the propellers and/or thrusters, but also to exercise caution to prevent ship/shore personnel being injured. Personnel involved in mooring operations shall be properly informed about hazards, have sufficient knowledge, experience and be fully aware of the safety requirements. Including using protective clothing and PPE such as hard-hat with straps, gloves, correct working shoes and overalls. Company Ref VOM 4.12.6.1 Mooring procedure. VOM 4.12.5 Safety. HSE 5.1.8 Toolbox talk. UniSea risk



6A.3.2



Measures are taken to optimise onboard mooring arrangements to ensure the Yes safety of vessel personnel. Mooring arrangement/layout on ships built by the company is carefully evaluated in connection with plan approvals. Each ship has carried out risk assessments of the most common mooring operations. Working areas (mooring, BLS area, manifold area etc) and walking lanes is provided with sand or grit in the paint to prevent slips and falls. Company ref. VOM 4.12.6.1 Mooring procedures. VOM 8.6.2 Deck maintenance.



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6A.3.3



Procedures address the use of all ancillary craft used in mooring and towage Yes operations. It is very important that the Pilot has good communication with the tugboat as communication between the pilot and tugs, terminal, mooring boats and other traffic, etc. may in some places be done in a local language. The Master shall however instruct the Pilot to translate the instructions to English, which is the working language on-board company vessels. Tugboat operation are always supervised by the person in charge when securing and "let go". Responsible shall not involve himself in the operation, but maintain a supervisory role to closely monitor the operation of both tug/boat crew and own personnel. When letting go, there shall be no strain on the mooring line. Towline received from the tug shall be in compliance with OCIMF-MEG, and shall have an eye of minimum 180 cm. If not, the towline may not be accepted. Mooring is a shipboard activity that shall always be risk assessed. VOM 4.12.6.1 Mooring Procedure. VOM 4.8.7 Communication/language. HSE 5.1.6 Risk Assessment in connection with Company “Permit to Work System” and established procedures.



6A.3.4



A process ensures that all mooring equipment and fittings comply with the Yes latest industry guidance. The vessel Superintendent is responsible for identifying incidents/possible claims continuously. The Superintendent notifies the Maintenance & Docking Manager. Company Ref: ADM 9.2.3.1 Flowchart Insurance claims handling. ADM 11 App F.



Stage 4 6A.4.1



The company actively seeks involvement of manufacturers, to enhance the management of mooring equipment including ropes and wires.



No



6A.4.2



All available means are used to ensure that vessels can safely moor at terminals being visited for the first time.



No



6A.4.3



Comprehensive audits are completed by a suitably qualified and experienced company representative. The audit uses observation of mooring operations.



No



6A.4.4



The company actively seeks out available or innovative technology to enhance safe mooring operations.



No



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Management of Change Stage 1 7.1.1



There is a documented procedure for management of change. Yes It is company policy to implement and monitor all major changes within the organization in order to maintain Company requirements to Occupational Health, Safety and Environment (HSE) including relevant standards and regulations. All temporary and permanent changes to organization, personnel, systems, procedures, equipment, products, or substances shall be evaluated and managed to ensure that HSE risks arising from these changes remain at an acceptable level. Likewise all changes to laws and regulations shall be evaluated and taken into account with regards to Company HSE performance. President & CEO has the overall responsibility to initiate actions to implement all changes that effect HSE issues within the Company. He will delegate this responsibility and duty as appropriate, to all Head of Departments involved in the changes. Onboard the vessels, the Master have the overall responsibility to carry out actions required to maintain the HSE in accordance with KNOT requirements. Under his discretion, he can delegate the duty and obligation to designated personnel onboard. Risk Assessment evaluation shall be conducted when deemed necessary in order to identify all risk exposed by the change. All measures and controls taken to mitigate risk shall be distributed and communicated to all personnel involved. All activities regarding Management of Change shall be documented and filed, in accordance with Company routines and practice. Management of Change evaluation are to be carried out in accordance with Company Risk Assessment Procedure.



Company Ref: - ADM 16 Management of change. - ADM 10.4 Procedure For IT Change Management. - ADM 19.1 Document control.



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7.1.2



A procedure is in place to ensure that the impact of any proposed change is Yes assessed. Changes normally represent increased risks, this risk must be controlled and reduced to acceptable levels. Changes be to systems such as: -Organisations, (key officers or major part of the crew). -Technical systems (new equipment or modifications). -Procedures, (operational and administrative systems). -In connection with takeover of new ships to the Company fleet. The procedure is to ensure that changes onshore or onboard are carried out in a controlled way and with retention of a safe and efficient operation during, and after the implementation of change. Included, but not limited to: -Identification and assessment of hazards arising as a result of the change. -Identification and assessment of the impact of the change of operations. -Control of the activity to implement the change. -Training. -Maintenance of documentation. -Information of the change to affected parties. Changes may range from small to large and may be permanent as well as temporary. Changes can be based on suggestion for improvement submitted by anyone in the organisation, Actions from reporting system or external requirement from customers or authorities. It is important that the benefit of a change is properly justified, considering the risks and efforts required changing existing systems. Although most cases are different, a general procedure should be followed in order to identify elements, which need to be controlled. In particular the consequences to Occupational Health, Safety and Environment shall be considered. For permanent or temporary changes that will affect the normal operation of equipment or governing procedures (new vessels, new administrative systems, conversions etc), a formal Management of Change request shall be issued. The request shall include description of the various tasks, responsible persons and deadlines. approval shall be according to procedure. For each task, it is very important to properly consider all consequences regarding safety for personnel and equipment, cost etc. Several Risk Assessments may therefore be required. Company Ref - ADM 16.2 Management of change procedure. - ADM 16.3 Change request form - ADM 16.4 Management of change flowchart



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7.1.3



The management of change procedure clearly defines the levels of authority Yes required for the approval of any changes. Management of Change from Vessel are sent to Vessels Superintendent for first approval. Fleet Manager of the respective fleet shall make the final approval and is responsible for filing. In the MOC form approval fields are listed as 1st, 2nd and 3rd level. e.g. 1st level: Master – 2nd level: Superintendent – 3rd level: Fleet Manager Management of change onshore shall follow the lines within KOAS organization. The department manager is responsible for filing e.g. 1st level: Initiator – 2nd level: Department Head – 3rd level: Management *3rd level approval ashore is only required if identified risks are considered as “High” Company Ref : - ADM 16.2.7 Approval



7.1.4



Procedures identify emerging requirements. Yes Company subscribes and receives regulatory updates from Class, Flag, industry forums: Intertanko, IMCA as well as online publication services (Reg4ships) HSSE&QA director is responsible for the above, Company Ref - ADM Appendices Job descriptions HQ1 HSSE&QA director.



Stage 2 7.2.1



The management of change process ensures all proposed temporary and Yes permanent changes to onboard procedures and equipment are subject to risk assessment. Although cases are different, a general procedure should be followed in order to identify elements, which need to be controlled. In particular the consequences to Occupational Health, Safety and Environment shall be considered. Permanent and temporary changes that affect the normal operation of equipment or governing procedures, a formal Management of Change request shall be issued. The request shall include description of the various tasks, responsible persons and deadlines. For each task, it is very important to properly consider all consequences regarding safety for personnel and equipment, cost etc. Several Risk Assessments may therefore be required. For a minor changes (renewal of obsolete equipment, revised procedures etc), a formal management of change is not required. A simple plan or risk assessment will be sufficient to identify the need for training, documentation, verification etc. Company Ref; - ADM 16.2.5 Management of change - General procedure.



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7.2.2



Management of change identifies all personnel that may be affected by the Yes change and ensures that they understand the extent and likely impact of any planned change. The procedure purpose is to ensure that changes onshore and onboard is carried out in a controlled way ensuring safe and efficient operation both during and after the implementation of a change. Included, but not limited to: -Identification and assessment of hazards arising as a result of the change. -Identification and assessment of the impact of the change of operations. -Control of the activity to implement the change. -Training. -Maintenance of documentation. -Information of the change to affected parties. Company Ref: - ADM 16.2.2 Purpose.



7.2.3



Management of change procedures ensure that training needs arising from any Yes proposed changes are identified and documented. Although cases are different, a general procedure should be followed in order to identify elements, which need to be controlled. In particular the consequences to Occupational Health, Safety and Environment shall be considered. Permanent and temporary changes that affect the normal operation of equipment or governing procedures, a formal Management of Change request shall be issued. The request shall include description of the various tasks, responsible persons and deadlines. - ADM 16.2.5 Management of change - General procedure.



7.2.4



Management of change identifies all documentation and records that may be Yes affected by the change. Prior to receive authorization for the change, the Company must identify the actions required to implement the change deemed necessary: - Development of a project plan to implement the change detailing the schedule, estimated cost, resources and material required. - Preparation of suitable procedures for implementing the change - Consultation with relevant authorities, affected parties and relevant specialists - Hazard analysis - Risk Assessment Evaluation - Approvals required - Training and certification - Changes to documentation and drawings Company ref: - ADM 16.2.6 Management of Change Procedure - Implementation of change. - ADM 16.3 Change Request Form.



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7.2.5



Regular reviews are conducted of management of change plans being Yes implemented.Any changes not carried out within the proposed timescale are reviewed, revalidated and approved. Management of change request shall include description of the various tasks, responsible persons and deadline´s If temporary changes do exceed the initial authorization for scope of time, or changes not carried out within the proposed time, re-approval by appropriate Management to be performed. Company ref: - ADM 16.2.5 Management of Change Procedure - General procedure. - ADM 16.4 Management of change flowchart.



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Stage 3 7.3.1



A management of change procedure is applied when the company acquires additional vessels. Management of Change shall always be completed and shall be the main document in any takeover process in addition APPENDIX D Change of management checklist.



Yes



New building is handled in house, process and procedures covering the New building process is is described in detail in chapter 11 and follow its own handover process.



Company Ref: - ADM 12.12.5 Sale of vessel or vessel taken on - General procedure. - ADM App. D Change of management checklist - ADM chapter 11 new building. 7.3.2



There is a periodic review of the outcome of all changes to ensure objectives have been met. The company arranges annual strategy and planning meetings where experience and recent developments and plans for further development are discussed, including strategies and objectives. The effectiveness of all recorded changes shall be reviewed in connection with the annual Management Review.



Yes



Company Ref. - ADM 16.2.8 Management of change procedure - Documentation. - ADM 5.5 Management review. - VAM 1.7 Master review. 7.3.3



A software management procedure covers all shipboard and shore systems. The Procedure for IT Change Management is part of company's governing documents and is anchored in the IT Policy.



Yes



The purpose of this procedure is to provide an understanding of how the activities related to IT change management are performed. The process covers the activities from need for change until the solution proposal is prepared, approved and implemented. The procedure clarifies roles and responsibilities regarding each process steps. This includes control activities to minimize risks of material misstatements in the financial reporting, fraud and corruption. Company ref. - ADM 10.4 Procedure For IT Change Management. Stage 4



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7.4.1



For major changes to the shore organisation, management of change procedures ensure that manning, competency and experience levels are maintained so that there is no deterioration in supervision and the management of key processes. All temporary and permanent changes to organization, personnel, systems, procedures, equipment, products, or substances shall be evaluated and managed to ensure that the risks arising from these changes remain at an acceptable level



Yes



Changes normally represent increased risks, which should be controlled and reduced to acceptable levels. Changes may be done to various systems such as: - Organisations, such as key officers or major part of the crew; - Technical systems, such as new equipment or modifications to existing systems; - Procedures, such as operational and administrative systems. - In connection with takeover of new ships to the Company fleet. Movement of key personnel and change of responsibilities/added resources are dealt with in the monthly Management meetings. Major changes are analysed and prepared in Annual Strategic Meetings which include detailed description of change. Company ref. ADM 16.1.1 Management of Change Policy. ADM 16.2.1 Management of Change Procedure



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7.4.2



The company actively seeks out improvements for new build design Yes specifications. The company actively works on a number of new projects, including the new ship concept PNG ®, and emission reduction system KVOC® as well as the new Ballast Water treatment System, KBAL ® for which the company has strong expectations. Knutsen has an active approach regarding implementation and development of technology for reducing emissions to water and air. Knutsen Technology has developed its own system for reducing VOC emissions (volatile oil compounds) in connection with loading of shuttle tankers offshore on the Norwegian Continental Shelf where there are strict requirements for VOC emissions. This system is now accepted for use on the Norwegian Continental Shelf. Knutsen Technology has also developed its groundbreaking Ballast Water treatment technology which has now received the Type Approval Certificate from DNV and is commercialized.



Knutsen technology actively seeks out improvements and development of new technology within the marine industry. Ship conversions + design KVOC® - reducing VOC emissions KBAL® - ballast water treatment PNG® - marine CNG transportation PCO2® - marine CO2 transportation Knutsen Subsea Solution Enhanced Oil Recovery (EOR) Well stimulation and chemicals injection Extended Well Testing Plug and abandonment.



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Incident Reporting, Investigation and Analysis Stage 1 8.1.1



Procedures ensure prompt reporting and investigation of incidents and Yes significant near misses. Docmap incident reporting software is the company tool for reporting, Accident/Incidents, Near misses, non-conformity, suggestions, ECO-care, Ill-health and illness. Events categorized as Accident/incidents and high potential Near Misses - shall be reported as soon as practical / possible following an event High potential Near Misses are described as case that has a risk potential of 16 and above consisting of hazards severity 4 (high) and 5 (major). Handling time of observations shall be kept between 1 to 3 months for time shore organization receives the observation. In addition to reporting and follow up in Docmap, it is the Company Policy that all serious incidents, which have caused death or serious injury to personnel, ill health or damage to environment, material or to third person’s property, shall be investigated by Root Cause investigation (RCI). The HSSE&QA Director or Fleet Manager is responsible for initiating a Root Cause Investigation and too inform each other when learning about matters that might require a RCI. Company Ref: - HSE 6.1.1 HSE&QA Reports from the vessels. - HSE 6.2 Root Cause Investigation of Accidents & Near Accidents.



8.1.2



The reporting and investigation procedures ensure that all mandatory Yes notifications are carried out within the required time frame. Depending on the nature of the report and of the conclusions and suggestions for improvement, the report shall be distributed: - Internally, to involved and appropriate Company staff (Management, Ship Superintendents, etc.). - To all ships in the Company fleet, for internal distribution and discussion in PEC and in general meetings, discussing suggestions for improvements that may be implemented - To Company branch offices - To Charterers/Operators - To the Maritime Authorities e.g. Norwegian Maritime Directorate - To Suppliers and Manufacturers (if relevant), in order to improve equipment, design, services, programs Reports shall be approved by Director Technical Operation or HSSE&QA Director (DPA) prior sending. The Company is obligated to report to flag according to requirements of the Flag State the actual ship is flying. The vessels superintendent is responsible for filing the required reports with the relevant Flag State within the set time limits Company Ref - HSE 6.1.1 HSE&QA Reports from the vessels. - CCP 6.6 Incident/Accident Reporting Flow Chart



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8.1.3



Procedures ensure the fleet is rapidly notified of urgent information related to Yes incidents and near misses. Company will distribute Safety Flash containing important Safety Information whenever immediate distribution is required.



Company Ref: - HSE 6.3.4 6.3 HSE&QA Statistics, Safety Bulletins & Key Performance Indicators 8.1.4



Procedures ensure that incidents are investigated and analysed.Corrective and Yes preventative actions are identified and implemented. It is the Company Policy that all serious incidents, which have caused death or serious injury to personnel, ill health or damage to environment, material or to third person’s property, shall be investigated. As a minimum, investigation shall be initiated for the following cases: - Lost time injuries (LTI) - Any considerable oil spill with extensive potential hazard to environment - Vapour release LNG (controlled or emergency) - Serious incidents at the field, e.g. production loss, pollution, off hire, DP loss, damages to properties, technical breakdown, blackout etc. - Fire and marine casualty, including fire in vent mast - Grounding - Collision - Off Hire due to technical or operational conditions. - Materiel damages and technical faults exceeding > $50.000,- Near accidents with immediate potential for serious personal injuries, pollution to environment and extensive material losses etc., as mentioned above or for the safety at sea in general. Normal procedure will be the following. - The vessels superintendents advises the fleet manager immediately when he becomes aware of incidents that might warrant a root cause investigation. - The HSSE&QA Director or Fleet Manager initiates a RCI with the vessel (vessel start onboard investigation and make first draft of the report). - The Initiator of the investigation must also give a dead-line for the completion of the RCI. - The Initiator shall appoint an Investigation Leader - Additional resources needed - Review by shore-management, - Action list (short/long term) forwarded to affected department. - Initiator and Technical director will approve of the final report. Company ref - HSE 6.2 Root Cause Investigation of Accidents & Near Accidents. - HSE 6.4 Root cause investigation form.



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8.1.5



Procedures ensure that the appointed incident investigation team are Yes appropriately trained and qualified to conduct the investigation and analysis. Depending on the background of the report, HSSE&QA Director or Fleet Managers will appoint one of the group members to be the leader the Root Cause Investigation. This person will be given the responsibility to execute the investigation in accordance with the Company requirements, and to ensure that the report is completed within the determined time limit. The investigation leader must not be connected with the incident in any way and further; potential conflicts of interest must be clarified. A shore-based Root Cause Analyses course including Investigation techniques, by DNV or MTO course held by RESQ has been held for personnel in Technical and HSSE & QA department. For senior officer our own in-house developed course is mandatory to completed. A Root Cause Analysis course is offered / given to all new senior Officers, Superintendents and HSE & QA staff. Company Ref - HSE 6.2.3. Organization and performance of Root Cause Investigation - ADM 12.11 Familiarization - Technical operations personnel - ADM APP 20 Job description HQ/VD



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8.2.1



The incident-investigation procedure ensures that the root causes and factors Yes contributing to an incident or significant near miss are accurately identified. A complete Root Cause Investigation Report shall as a minimum contain the following elements: - Information about the vessel - Summary - The Root Cause Investigation Group’s composition - Working methods - Description of uncertainties - Course of events - Conditions of emergency preparedness significance - Consequences - Direct causes - Underlying causes – Company Management - Recommendations of measures - Enclosures. Direct causes: It shall be listed up the actual conditions that have, or there are good reasons to anticipate that have contributed directly to the incident. Underlying causes – Management of the Company: On background of the actual conditions (direct causes), the investigation group shall draw conclusions with respect to causal connections. The vessel is responsible to start taking statements and securing documentation and evidence as soon as practical after incidents described in HSE 6.2.2. This must be done even if a RCI has not yet been formally initiated, see VCP 4.2 “Post incidents – Securing of evidence.” Company ref HSE 6.2.9 Content of the investigation. HSE 6.2.3 Organization and performance of Root Cause Investigation. VCP 4.2. Post incident - securing of evidence.



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8.2.2



The composition of the investigation team is established according to the Yes severity and type of the incident. Depending on the background of the report, HSSE&QA Director or Fleet Manager will appoint one of the group members to be the leader the Root Cause Investigation. This person will be given the responsibility to execute the investigation in accordance with the Company requirements, and to ensure that the report is completed within the determined time limit. The investigation leader must not be connected with the incident in any way and further; potential conflicts of interest must be clarified. Normal procedure will then be as follow: 1. The vessels superintendents shall advise the fleet manager immediately when he becomes aware of incidents that might warrant a root cause investigation. 2. The HSSE&QA Director or Fleet Manager initiates a RCI with the vessel (vessel start onboard investigation and make first draft of the report). 3. Once it has been decided that a RCI is required, it must be given an ID number that will be supplied by the QA department. The Initiator of the investigation must also give a dead-line for the completion of the RCI. 4. The Initiator shall appoint an Investigation Leader 5. Are additional resources needed? (personnel / material / organisation) 6. Review of report shore side (superintendent, fleet manager, resource personnel) 7. Action list (corrective action) forwarded to affected department. These actions shall also be entered in the DocMap report that describes the incident/accident investigated. 8. The initiator of the RCI and the Technical director will be the approvers of the final report Following a serious incident (collision, grounding, fire onboard, etc.) or an incident with serious potential, the Master and/or senior personnel onboard may be relived and called into office to be part of or support the root cause investigation group until completion of the investigation



Company Ref - HSE 6.2.3 Organization and performance of Root Cause Investigation. 8.2.3



External training in incident investigation and analysis is given to at least one Yes member of the shore-based management teams. A shore-based Root Cause Analyses course arranged by RESQ or DNV GL is held for personnel in Technical and QA department. Course requirement incorporated in Job description. Company Ref: ADM App Job description HQ/VD/TO.



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8.2.4



The safety culture encourages reporting of all near misses and incidents. Yes Master, with the active support of the Shipboard Management Team is responsible for informing about, motivating and encouraging the crew to report Accident/Incidents, Near Miss events, NonConformities and Suggestions for Improvements. All crew have an individual responsibility to report all undesired events occurred onboard, in accordance with Company requirements. All vessels shall have onboard a mailbox for postage of Company Report Form, which is to be used for reports from the crew. The mailbox is to be locked and emptied at least once a week. The Master is responsible for the mailbox system, but can delegate the handling of the mailbox to one of his Officers. Company Ref: - HSE 6.1.2 Ship Personnel responsibility to report. - HSE 6.1.3 Mailbox. - Company report form.



8.2.5



Lessons learnt from incidents are used to prevent any recurrence. Yes Any lessons learnt from incident investigation is included as an long term action in the investigation report with target date and responsible personnel of monitoring. Completed Root cause investigation reports marked for distribution are shared in full by being uploaded into Unisea Bulletins for lateral learning. Prior to being distributed internally and externally, the report shall be approved by Director Technical Operation or HSSE&QA Director. Depending on the nature of the report and of the conclusions and suggestions for improvement, the report shall be distributed: - Internally, to involved and relevant Company staff (Management, Ship Superintendents, etc.). - To all ships in the Company fleet, for internal distribution and discussion in PEC and in general meetings, discussing suggestions for improvements that may be implemented. - To Company branch offices. - To Charterers/Operators. - To the Maritime Authorities e.g. Norwegian Maritime Directorate. - To Suppliers and Manufacturers (if relevant), in order to improve equipment, design, services, programs. Company Ref: - HSE 6.2.2.1 Distribution. - HSE 6.4 Root cause investigation form - Long term actions. - UniSea Bulletins.



Stage 3



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8.3.1



Lessons learnt from incidents and near misses and safety performance statistics are promulgated across the fleet periodically. HSE&QA Department prepares and maintains the different statistics in order to monitor the Company annual KPI Targets. The KPI’s is divided in four separate groups, is revised annually. - Safety, - Health, - Environment, - Quality.



Yes



The objective of the statistics is that the Company and each vessel shall be able to measure their KPI results towards the annual KPI Targets. As soon as the vessel receives the monthly statistics from the Company, the Master shall review the statistics in an open PEC Meeting, with all crew present. Vessel’s individual KPI Results shall be monitored and reported in the monthly PEC Report, from the ship. The statistics shall be posted on vessels notice board. Company Safety Bulletin is issued every quarter and distributed to all vessels. Safety Bulletins include comments on the HSE-results achieved, The bulletins also include experience feedback to the ships, based on occurrences of mutual interest that have taken place during the last quarter, in order for the other vessels to implement preventive measures to avoid the same incident. Important Safety Information, which requires immediate distribution to the ships are distributed in safety flash. In addition to the above, lessons learnt both internal and external is shared in UniSea bulletins. (IMCA, Flag, industry peers and Oil Majors) Company Ref - HSE 6.3 HSE&QA Statistics, Safety Bulletins & Key Performance Indicators (KPI). - KPI Report. - Safety bulletin. - Unisea Bulletins. 8.3.2



Analysis of company incidents and significant near misses is conducted at Yes periodic intervals. Safety Bulletins are issued every quarterly by the Company and distributed to all vessels. Safety Bulletins include comments on the HSE-results achieved, analysis and breakdown of actual and potential consequences. Common topics, trends identified from the reports is highlighted in order for the other vessels to implement preventive measures to avoid the same incident Company Ref - HSE 6.3.4 Safety Bulletin and Safety Flash – issuing and distribution. - Safety Bulletin.



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8.3.3



Incidents and subsequent investigations are reported to oil major vetting Yes departments. Company incident flow chart identifies all incident categories requiring notification to Oil vetting departments, it is company policy to report to all oil companies that we consider as majors. Statement of facts regarding an accident is reported to oil companies in the notification, this is then followed up with an investigation report, once the report is completed and approved. Company Ref: - CCP 6.1 Notification checklist. - CCP 6.6 Incidents/accident reporting flow chart. - Duty officer Emergency booklet.



8.3.4



Procedures ensure that incident investigation and analysis refresher training Yes takes place after an appropriate period. Incident investigation and analysis training is a required Course for technical, Vetting and HSSE&QA department. Refresher training is set at 5 years. Company Ref; - ADM 12.11 Familiarization - Technical operations personnel. - ADM 20. Job description.



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Stage 4 8.4.1



Incident analysis data is shared with industry groups. Yes Distributed internally and externally shall be approved by Director Technical Operation or HSSE&QA Director. Depending on the nature of the report and of the conclusions and suggestions for improvement, the report shall be distributed: - Internally, to involved and relevant Company staff (Management, Ship Superintendents, etc.) - To all ships in the Company fleet, for internal distribution and discussion in PEC and in general meetings, discussing suggestions for improvements that may be implemented - To Company branch offices - To Charterers/Operators - To the Maritime Authorities e.g. Flag - To Suppliers and Manufacturers (if relevant), in order to improve equipment, design, services, programs Lessons learned / statistics are also shared with industry groups (or companies, class societies, manufactures) whenever appropriate. Company Ref: - HSE 6.2.2.1 Distribution



8.4.2



Procedures ensure that, where possible, all trained personnel are given the No opportunity to participate in incident investigation and analysis. Investigation is carried out by a team consisting of a leader with ample experience and training. The ship superintendents have completed basic training course. The ship’s superintendent is normally appointed member of the investigation team. Company ref; HSE06-02 Root Cause Investigation of Accidents & Near Accidents.



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Safety Management – Shore-Based Monitoring Stage 1 9.1.1



Safety standards are monitored across the fleet during shore-based Yes management visits to vessels. Each vessel shall be visited minimum 3 times a year. A formal safety meeting should be held with all crew during the visit. The latest safety campaigns shall be presented and discussed and the status of the on-going campaigns shall be reviewed. Company Ref: - ADM 12.08 Reports and documentation system - ADM 12 App A Ship visit report.



9.1.2



During vessel visits, every opportunity is taken to promote a strong safety Yes culture across the fleet. A formal safety meeting should be held with all crew during the visit. The latest safety campaigns shall be presented and discussed and the status of the on-going campaigns shall be reviewed. Any visit shall be followed by a “Ship visit Report”, any action plan shall be discussed onboard, and include responsible person and a deadline. Internal Ship Inspections / Internal Audits Reports shall be entered and processed in the UniSea Audit. Company Ref. - ADM 12.08 Reports and documentation system - ADM 12 App A Ship visit report. - HSE 6.1.6 Company Inspections onboard the vessels.



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9.1.3



Procedures include a documented risk assessment system. Yes Risk Assessment shall be carried out prior to any Permit to work as described in HSE manual and established operations procedures. There may not be a need to carry out a new Risk Assessment if the established Risk Assessment is relevant for the planned work/operation. In this instance, the previous Risk Assessment should be reviewed/ revised in order: - To ensure that the controls identified are still relevant. - To ensure that the controls identified are appropriate to the specific job, location, weather conditions and personnel involved. - To identify any additional controls where appropriate. In case there is any concern about a previous Risk Assessment or Procedure, a new Risk Assessment should be performed. The Risk Assessment in use shall not be older than one year. If there are any unplanned changes to the operational conditions when performing the work, the job must be stopped and the Risk Assessment should be reviewed. The following Shipboard activities/tasks/operations shall always be Risk Assessed: - Cargo operations including topping up cargo tanks. - Work in tank and enclosed compartments including tank cleaning. - Cold work. - Working with Asbestos. - Non routine maintenance work. - Mooring. - Work requiring Lockout/tagout. - Working over the side (outboard). - Working aloft (height). - Working in bilges. - Welding / Hot Work. - Handling of chemicals/ Hazardous substances. - Sandblasting, spray painting. - Electrical work including Electrical Isolation Certificate and high voltage. - Each Heavy Lift Operation. - Shut down of Critical Equipment. - Management of change. New or Changed (Permanent or Temporary) Equipment, Personnel, Procedures and Environmental Circumstances e.g. weather conditions. - Non compliance with Officer Matrix as required by Charters/Operators. - Work on weather deck during extreme weather (green sea/extreme winds). Identify Hazards for the various job steps, the most probable outcome for each hazard shall be considered. Describe all Hazards identified by using the Hazard Severity Matrix, and their effects for each job step. All hazards to the health and safety of the workers must be identified. Company Ref - HSE 5.1.6 Risk Assessment in connection with Company “Permit to Work System” and established procedures - HSE 5.1.2.2 Introduction to method of Risk Assessment / Identifying hazards.



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9.1.4



A documented permit to work system is in place. Yes Planning and preparation of work operations are essential if personnel are to successfully prevent ill health, accidents and emergencies on board. A full set of work permit are available and cover work such as; Working aloft, Enclosed space entry, Cold & Hot work critical equipment. Hot work outside the engine room and critical equipment without redundancy will require shoreside approval. Company Ref - HSE 4.1.1 Work Permit”- System – General information. - HSE 4.2.1 work permits in use. - HSE 4.5 Hot work approval - HSE 4.31.5 Critical equipment maintenance - Flow chart.



Stage 2



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9.2.1



Risk assessments for routine tasks are used to develop safe working procedures. Yes All findings related to the RA-Process shall be documented in KNOT standard Risk Assessment Form. The following steps are described in the form: 1. Identification of job steps in the work procedure. 2. identifying all Hazards associated with the interdependent job step. 3. identify population/equipment at risk Potential for harm. 4. Rate hazard and likelihood to calculate initial risk. 5. Once the Risk rating has been determined, the next stage is to identify the controls that are required to reduce or to control the risk. 6. Rate hazard and likelihood of residual risk. The Risk Assessment Team shall work systematically through the list of hazards, in order to specify all the measurements/barriers required to control each of the associated Risks. These measures should be based on good safe working practice (Best practice), in order to reduce the residual risks to “As low as reasonably practicable“(ALARP). Once all the controls have been identified, the following final questions should be asked. - Have all the necessary control measures/barriers been fully and effectively identified? - Are any additional competencies required to control- or to eliminate the Risk? - Is the Risk effectively controlled? Once the task/operation commences, it is important to monitor the worksite for any changes in conditions in place. If there is any concern, stop the work, re-evaluate the control measures and if necessary re-plan and re-evaluate the task. On completion of the task, it is important to bring forward any lessons learned, and the next time to implement the appropriate improvements. The Risk Assessment Team should, as a general rule, consist of the minimum persons: - Head of Department, for the actual operation - Responsible person, for the execution of the work (other than head of department). - Safety delegated (P&E Supervisor) In addition the following personnel could attend the Risk Assessment Team, if found relevant by Master or Head of Department: - Executing personnel - Other personnel with relevant knowledge/experience. Toolbox Talk shall always be used if a Risk Assessments is issued for the upcoming task/operation and any refreshments of same. Likewise shall Toolbox Talk be used in connection with the morning meeting, on regular basis for routine tasks on deck and in engine department. The following elements should be on the Toolbox Talk agenda: - The details of the activities involved, for all participants in the task/operation. - The potential hazards identified for each stage of the task, attention should be given to hazards with high risk rating (>7). - The control measures in place, or to be put in place, in order to eliminate the hazards. - Individual actions and responsibilities at various stages of the task. - Are procedure(s) and checklist(s) for the operation available and are these used and followed (adhered to)?



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- Is all equipment to be used in the ongoing operation/task checked and ready for use? - Are the required protection and safety equipment (PPE) available and ready for use? - Have communication equipment been tested and have lines of command been established? Risk Assessments in use shall not be older than one year. Company Ref: HSE 5.1.7.5 Documenting the RA-Process. HSE 5.1.7.4 Review of residual risk. HSE 5.1.7.3 Identifying controls. HSE 5.3 Toolbox talk risk identification form HSE 5.4 Toolbox talk light HSE 5.5 Risk assessment form



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9.2.2



The risk assessment process includes provision for assessing new, non-routine Yes and unplanned tasks. A Risk Assessment shall be carried out prior to any Permit to work as described in HSE manual and established operations procedures (VOM). There may not be a need to carry out a new Risk Assessment if the established Risk Assessment is relevant for the planned work/operation. In this instance, the previous Risk Assessment should be reviewed/ revised in order: - To ensure that the controls identified are still relevant. - To ensure that the controls identified are appropriate to the specific job, location, weather conditions and personnel involved. - To identify any additional controls where appropriate. In case there is any concern about a previous Risk Assessment or Procedure, a new Risk Assessment should be performed. The Risk Assessment in use shall not be older than one year. If there are any unplanned changes to the operational conditions when performing the work, the job must be stopped and the Risk Assessment should be reviewed. The following Shipboard activities/tasks/operations shall always be Risk Assessed: - Cargo operations including topping up cargo tanks - Work connected to permits - Non routine maintenance work - Mooring; - Work requiring Lockout/tagout - Working in bilges. - Handling of chemicals/ Hazardous substances. - Sandblasting, spray painting. - Electrical work including Electrical Isolation Certificate and high voltage. - Each Heavy Lift Operation. - Shut down of Critical Equipment. - Management of change. - Non compliance with Officer Matrix as required by Charters/Operators. - Work on weather deck during extreme weather (green sea/extreme winds). Shipboard Management is to decide when a Risk Assessment should be carried out. If in doubt, the Ship’s Superintendent or HSSE&QA Department are to be contacted for advice and guidance. All significant hazards and risk should be listed and then reviewed, in order to determine what foreseeable effects they could cause if not eliminated or controlled. This should be done by way of full group discussion under direction of “Risk Assessment Team Leader”, in order to ensure that all members are given adequate opportunity to express their views. - Risk rating 1-6 Acceptable; however, the task may be reviewed to see if risk can be reduced further. - Risk rating 7-14 The Task/Operation can be continued. Where possible, the task/operation should be redefined to take account of the Hazard involved, or the Risk should be reduced further prior to task commencement. - Risk rating 15-25 The Task/Operation must not be continued. Superintendent/ Fleet Manager to be contacted for further decision.



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Company Ref: - HSE 5.1.6 Risk Assessment in connection with Company “Permit to Work System” and established procedures. - HSE 5.2.2 Identification of Hazards and Risks - Identifying hazards Table. 9.2.3



Risk assessments for new, non-routine and unplanned tasks are available to all Yes relevant personnel. Risk Assessment shall be carried out prior to any Permit to work and established operations procedures. There may not be a need to carry out a new Risk Assessment if the established Risk Assessment is relevant for the planned work/operation. In this instance, the previous Risk Assessment should be reviewed/ revised in order: - To ensure that the controls identified are still relevant. - To ensure that the controls identified are appropriate to the specific job, location, weather conditions and personnel involved. - To identify any additional controls where appropriate. In case there is any concern about a previous Risk Assessment or Procedure, a new Risk Assessment should be performed. The Risk Assessment in use shall not be older than one year. If there are any unplanned changes to the operational conditions when performing the work, the job must be stopped and the Risk Assessment should be reviewed All risk assessments are stored in UniSea Risk and is thus available to all vessels regardless of where it was generated. UniSea software is available for all both vessel and shore organization. Company Ref; - HSE 5.1.6 Risk Assessment in connection with Company PTW and established procedures. - VOM 8.1.2 Execution of maintenance.



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9.2.4



Procedures ensure that all identified mitigation measures are completed prior Yes to commencing work. Toolbox Talk shall always be used if a Risk Assessments is issued for the upcoming task/operation and any refreshments of same. The following elements should be on the Toolbox Talk agenda: - The details of the activities involved, for all participants in the task/operation. - The potential hazards identified for each stage of the task, attention should be given to hazards with high risk rating (>7). - The control measures in place, or to be put in place, in order to eliminate the hazards. - Individual actions and responsibilities at various stages of the task. - Are procedure(s) and checklist(s) for the operation available and are these used and followed (adhered to)? - Is all equipment to be used in the ongoing operation/task checked and ready for use? - Are the required protection and safety equipment (PPE) available and ready for use? - Have communication equipment been tested and have lines of command been established? On the basis that all control measures have been put in place, an assessment of the residual risks should be made for each of the hazards. If the residual risk is unacceptable, additional control measures should be identified. When further control measures has to be taken, in order to reduce the risk to an acceptable level, these control measures should then be recorded with the new residual risk rating. If further control measures cannot reduce the risk to an acceptable level, the task must not proceed and the RA Team Leader must immediately contact vessel’s Superintendent for assistance. If the residual risk is acceptable and as low as reasonably practicable (ALARP), the Risk Assessment Team may decide to go ahead with the task operation, however all identified control measures shall then be in place. Responsible Officers must also take into consideration that any unplanned/unscheduled work could affect the already planned work by means of increased hazard. All crew have a responsibility to evaluate their work in regards to hazards affecting them and others. When someone is in doubt if their work will affect others, this must be immediately forwarded to Responsible Officer(s). All work permits and procedures also apply to any unplanned/unscheduled work that might occur during working hours.



Company Ref HSE 5.1.8 Toolbox talk HSE 5.1.7.5 Review of residual risk HSE 4.2 Work planning.



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9.2.5



Procedures manage the safety of contractors onboard. Yes For non-crewmembers following the vessel from one port to another established checklist that shall be completed. Visitors shall during an emergency/contingency situation at sea or in port be able to: - Recognize the alarm signals given; - Use the required lifesaving- and personal protection equipment; - Evacuate cabin and accommodation; - Proceed to mustering station assigned or instructed; - Follow instructions from the officer in charge. Riding squad members / Service Engineers etc. shall during an emergency / contingency situation at sea or in port be able to: - Recognize the alarm signals given - Use the required lifesaving and personal protection equipment - Evacuate cabin and accommodation - Proceed to mustering station assigned or instructed - Follow instructions from the officer in charge Riding squad members / service engineers etc shall have sufficient information knowledge and training in use of following Safety, Occupational Health, Environment and security requirement and precautions: - Personal Protection Equipment - Company Policy & Guidelines on Personal hygiene and conduct vessel specific routines. - Work permit system - Risk assessment, toolbox talk and time out - QRF reporting including near miss reporting, accident / incident, non – conformities and suggestion for improvement - Alcohol & drug policy guidelines - HSE&QA Policy - Smoking policy, restricted smoking areas and use of lighters, open flame - Electrical equipment – Hazards - Use of tools – Hazards - Location of first aid and eye watch stations - Use of chemicals – Hazards - Security requirements including restricted areas, use of mobile telephones, lighters and general security precautions - Waste management – segregation of waste in accordance with vessel Waste Management Plan - Rest hours Besides service technicians, repair teams, no contractors are employed on company vessel. Company Ref - FAT 8.1 Visitor familiarization. - FAT 8.2 Visitor familiarization non-crew. - FAT 8.3 Riding squad / Service engineers. - FAT 8.4 Riding squad / service engineers - checklist Immediate Familiarization. - FAT 8.5 Riding squad members / service engineer checklist Initial Familiarization.



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Stage 3 9.3.1



A formal process is in place for shore management to review all risk assessments periodically. Review of Company Risk Assessments is a part of HSSE&QA department revision routines.



Yes



Company ref: 5.1.3 HSSE & QA Department Organization and Responsibilities. 9.3.2



Proprietary safety tools are used to encourage hazard identification and to Yes improve safety awareness throughout the organisation. Company Behavior based safety program was established in 2009(Committed to Safety) Program consists of 6 DVDs (4 DVDs in committed to safety) & (2 DVDs Active leadership) 1 new movie in the works. Near miss reporting minimum requirement (20 reports pr vessel pr year) is included in Company KPI's. Eye, Finger, hand campaigns are also introduced according to need/trends identified from reporting system. Company Ref - We are committed to safety. - Company Action plan. - Monthly KPI's.



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9.3.3



The company selects and maintains a list of approved contractors. Yes The KNOT Management Supplier Code of Conduct (herein referred to as the “Code”) formalizes the key principles under which suppliers to KNOT Management, any subsidiary, other associated company or companies under management of KNOT Management are required to operate. In selecting suppliers, KNOT Management works hard to choose reputable business partners who are committed to ethical standards and business practices compatible with those of KNOT Management. The Code formalises KNOT Management’ practices and makes clear that, recognizing differences in cultures and legal requirements, we expect that wherever services for our business are procured, and/or where our products and the components that comprise them are produced, they are procured and/or produced in a manner compatible with the high standards that contribute to the outstanding reputation of KNOT Management and our brands. Suppliers, including agents and intermediaries, are required to comply with this Code, and are accountable for ensuring that their subcontractors, subsidiaries and associated companies comply with the same Code. This Code applies to all stages and facilities involved in the service and/or production of products and components for KNOT Management or any subsidiary or other associated company. To ensure a socially responsible maritime industry worldwide, KNOT Management require its suppliers to adhere to all relevant laws, rules and regulations, and to strive to improve their practices where necessary. Improvements also involve suppliers making certain their individual sub -suppliers adhere to the same standards and legal requirements. KNOT Management acknowledges that reaching the standards established in this Code is a dynamic rather than static process and encourages suppliers to continually improve their standards in areas where required.



In addition to complying with this Supplier Code of Conduct the Supplier shall comply with applicable local laws. If the applicable local laws and this Code address the same subject, and are not in conflict, the highest standard shall apply. Should this Code in any area conflict with local laws in the sense that the Code would result in a breach of applicable local law, the highest standard consistent with applicable local laws shall apply. Such conflict shall be reported in writing by the Supplier to KNOT Management. The Supplier shall respect internationally proclaimed human rights, and shall avoid being complicit in human rights abuses of any kind. The Supplier shall respect the personal dignity, privacy and rights of each individual. Supplier strategy - KNOT Management shall use approved supplier list in all procurement processes when tendering and also when choosing suppliers. This is to achieve economies of scale and to contribute to the procurement's’ objectives of quality, price and time. If an approved supplier is not available the relevant department shall be notified. This makes it possible for the department to start the approval process. - KNOT Management shall follow internal requirements when choosing suppliers, the requirements will be adapted in regard to the size and value of the procurement and also in which country the supplier has its headquarters, but always consist of an approved minimum of requirements. This is to ensure fair competition and anti-corruption. © Copyright OCIMF 2018



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- KNOT Management shall document the process of choosing suppliers to ensure that the process is re-traceable Company Ref - ADM 1.8 Procedure for business partner integrity due diligence. - ADM 3.2 code of conduct. - ADM 3.3 Supplier Code of conduct. - ADM 13.1 Procurement policy. - ADM 13 App C supplier approval form. Stage 4 9.4.1



Management collates all risk assessments for best practice sharing, in order to Yes improve the company safety culture. Risk Assessment Software is an online tool enabling vessel to share and borrow risk assessment cross vessels and the individual fleets.



Company ref: - Unisea Risk 9.4.2



Periodic (at least quarterly) safety related publication(s) are issued. Yes Company Safety Bulletin is issued every quarter and distributed to all vessels. Safety Bulletins include comments on the HSE-results achieved, The bulletins also include experience feedback to the ships, based on occurrences of mutual interest that have taken place during the last quarter, in order for the other vessels to implement preventive measures to avoid the same incident. Important Safety Information, which requires immediate distribution to the ships are distributed in safety flash. UniSea Bulletin. include Safety publications from Authorities, Flag state, Class, P&I clubs, regarding safety issues are submitted to the whole fleet as experience feedback on an continuous basis. Company Ref - HSE 6.3.4 Safety Bulletin and safety Flash issuing and distribution. - Safety bulletin. - Uni sea Bulletins.Safety publications from Authorities, Flag state, Class, P&I clubs etc, regarding safety issues are submitted to the whole fleet as experience feedback.



9.4.3



A formal contractor HSSE management system is in place. Yes Question is not relevant as the company does not hire Contract workers, all workers are employees in the company.



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Safety Management – Fleet Monitoring Stage 1 9A.1.1



Procedures require that safety inspections are conducted at scheduled intervals Yes by a designated Safety Officer. Health, Safety, Environment (HSE) Protection, is carried out to confirm that the following issues satisfy the requirements of the Operator, Authorities and the Company: - Vessel’s seaworthiness; - Shipshape, cleanliness, hygiene; - Safety- and protection equipment; - Fire-fighting equipment; - Personal safety equipment (PPE); - Life-saving- & rescue equipment; - Lighting & illumination; - Hazardous substances - control and use; - Excessive noise; - Equipment and tools; - Signs, signboards & paint marking; Master and Safety Delegates are responsible for HSE-Inspection being carried out, in accordance with these procedures. The HSE-Inspection shall be carried out minimum once a month and shall include all departments. These inspections are reported to Company by vessels Protection & Environment Committee and Ship Management Team reports. Company Ref - HSE 11.1 HSE - Inspections - Monitoring and Control of Work Environment. - HSE 11.2 Periodic HSE Inspection – Checklists. - HSE 9.1.14 Working environment committee training requirement - UniSea.



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9A.1.2



The company safety culture encourages all personnel to identify, report and Yes where applicable address hazards. The Master, with the active support of the Shipboard Management Team is responsible for informing about, motivating and encouraging the crew to report Accident/Incidents, Near Miss events, Non-Conformities and Suggestions for Improvements. All crew have an individual responsibility to report all undesired events occurred onboard, in accordance with Company requirements All vessels have onboard a mailbox for postage of Company Report Form, which is to be used for reports from the crew. The mailbox is to be locked and emptied at least once a week. The Master is responsible for the mailbox system, but can delegate the handling of the mailbox to one of his Officers. Company Ref. - HSE 6.1.2 Ship Personnel responsibility to report. - HSE 6.1.3 Mailbox.



9A.1.3



Onboard safety meetings are held at least monthly. In addition, extraordinary Yes meetings are held as soon as practicable after any serious incident onboard or within the fleet. On-board safety meetings (PEC) are held at least monthly and as soon as possible after any serious incident or accident within the company. The main purpose of these meetings shall be to implement initiatives and actions, in order to prevent- or to avoid injuries and accidents, and to follow up safety-measures previously implemented. The Master shall see to that “Minutes of Meetings” from the PEC-Meetings are taken down in a designated P&E Reporting Form. Each member of the P&EC shall sign the completed form and a copy shall be submitted to Company HSSE&QA-Department via Univu, for review by the Shore Organisation. The Company shall reply in writing in all instances in, which there are cases on the agenda involving the Company Management. Company Ref; - HSE 9.1.4 Meetings; objectives, implementation & reporting. - HSE 9.1.6 Minutes of meeting. - UniSea Univu.



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9A.1.4



Procedures require daily work planning meetings to take place. Yes Morning meetings, the purpose is to plan the work in each department and coordinate between the departments. As an opinion to the morning meetings described below, such meetings may be held at the end of the previous day. Every morning (normally at 7.45 am) the chief engineer shall have a planning meeting with the Second Engineer and other engineers as required. At the same time, Chief Officer shall meet with the bosun and other persons as required. Issues to be clarified are: - Identify and organize work and tasks for the day - Work and rest hours; review the day before and plan for present day - Safety issues, work permit and risk assessment requirements - Safety performance the day before Immediately afterwards, the Captain, Chief Engineer and Chief Officer shall have a coordinating meeting. The Bosun and Second Engineer respectively shall also plan and discuss the day’s work with their deck and engine Officers/crews respectively. Deck Daily meeting and Engine Daily meeting forms to be used on all morning meeting to document the conduct of these meetings. Files to be kept in Engine department (engine control room) in Deck department (Chief Officer Office). The forms to be signed by the dedicated persons as detailed in the forms. Company Ref. - VAM 2.1.6 Morning meetings. - VAM 2.1.7 Documentation. - VAM App 19 & 20 Deck/Engine Daily meeting.



Stage 2



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9A.2.1



Intervention to prevent unsafe acts and unsafe conditions occurring is actively Yes encouraged. The Master, with the active support of the Shipboard Management Team is responsible for informing about, motivating and encouraging the crew to report Accident/Incidents, Near Miss events, Non-Conformities and Suggestions for Improvements. All vessels shall have onboard a mailbox for postage of Company Report Form, which is to be used for reports from the crew. All crew have an individual responsibility to report all undesired events occurred onboard. Each of the crewmembers has the Authority and Responsibility to STOP THE JOB, if he/she feels that the Safety is not sufficient taken care of. It is essential that all persons involved in an activity are made fully aware that they have both the Authority and the Responsibility to Stop the Job / call for Time-Out, if there is any doubt about the safety of the operation. If any person concerned about the safety of a task/operation stops the Job, that person’s decision must be supported, even if it turns out to be based on wrong reasoning. The officer/Person in charge of the operation/task, shall respond immediately to any initiative from any participants in the operation/task when he/she call for a time out. The operation shall not resume until situation again is normalized. This means that the risk has been reviewed and is considered at a level acceptable or normal for the operation (ALARP) and the control measures have been re-validated. Familiarization of new crew is on the fixed agenda of monthly safety meetings onboard. All crewmembers to be familiarized with Company safety procedures as a part of the HSE familiarization. Any deviations to be reported.



Company Ref - HSE 6.1.2 Ship Personnel responsibility to report - HSE 6.1.3 Mailbox - HSE 9.2 item 1 & 3 (PEC) Report. - FAT 3.1.0 Initial Familiarization - General SMS, HSE & HAZARDS - Company report form. - HSE 5.1.9 Time Out



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9A.2.2



Appropriate training in hazard identification and risk assessment is provided to Yes vessel personnel. All Masters, Chief Officer, Chief Engineer’s and 2nd Engineers onboard KNOT vessels will be offered a Risk Assessment course. The training is arranged by the company and is a one-day course. The course is a combination of Risk Assessment and Root Cause Investigation. For Junior Officers and Ratings an on board CBT training course in Risk Assessment is available (Seagull). HR maritime personnel is in charge of arranging and ensuring compliance with company training matrix, Company Ref - HSE 5.1.11 Training - FAT 6.2 Onboard training Matrix - FAT 7.2 Course matrix. - KPI Monthly report.



Stage 3 9A.3.1



Procedures encourage the reporting of safety best practices. Yes All Masters, Chief Officer, Chief Engineer’s and 2nd Engineers onboard KNOT vessels will be offered a Risk Assessment course. The training is arranged by the company and is a one-day course. The course is a combination of Risk Assessment and Root Cause Investigation. For Junior Officers and Ratings an on board CBT training course in Risk Assessment is available (Seagull). HR maritime personnel is in charge of arranging and ensuring compliance with company training matrix, Company Ref - HSE 5.1.11 Training - FAT 6.2 Onboard training Matrix - FAT 7.2 Course matrix. - KPI Monthly report.



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9A.3.2



Procedures measure and compare the strength of the safety culture across the Yes fleet to identify areas for improvement and to provide motivation to vessel personnel. All Masters, Chief Officer, Chief Engineer’s and 2nd Engineers onboard KNOT vessels will be offered a Risk Assessment course. The training is arranged by the company and is a one-day course. The course is a combination of Risk Assessment and Root Cause Investigation. For Junior Officers and Ratings an on board CBT training course in Risk Assessment is available (Seagull). HR maritime personnel is in charge of arranging and ensuring compliance with company training matrix, Company Ref - HSE 5.1.11 Training - FAT 6.2 Onboard training Matrix - FAT 7.2 Course matrix. - KPI Monthly report.



9A.3.3



Management identifies opportunities to strengthen their safety culture through Yes interaction with fleet personnel. Company Best Practice Management Program (BPMM) is a mini conference with attendance of senior managements from up to 3 vessels each time. During these mini conferences/gatherings at the main office, best management practice based on sharing of information and experience gained from operating similar vessels, trade, equipment, charterers, geographical position, terminals and offshore installations will be targeted . These meetings will be attended by Technical Operation, Vetting, Personnel and HSSE & QA department. in addition suitable forums like the following have been established · Annual officers’ conference - It is as a main rule necessary for all our officers to take part of Company Officers Conference if not every year so at least every 3rd year as minimum. · Internal courses · Workshops · Temporary office employment · Briefing seminars · Ship visits · Briefings and debriefings with superintendent in connection with on or off signing At least two meetings listed above shall be attended every year, and for the Captains at least one shall take place at the office. If the briefing takes place at the office, the Superintendent is responsible to coordinate with the other departments. Company Ref: - HSSE&QA action plan. - KPI report. - ADM 6.9.3 Officer conference. - ADM 12.4.3 Meetings with senior officers.



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Stage 4 9A.4.1



9A.4.2



Leading and lagging indicators of safety performance are analysed, both across the fleet and on an individual vessel basis, in order to identify areas where the safety culture can be improved.



No



Fleet safety trainers sail with the vessel to conduct training and promote the company values and safety culture.



No



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Environmental and Energy Management Stage 1 10.1.1



An environmental protection policy and management plan is in place. Yes The environmental policy is an integrated part of the company Health, Safety and Environment (HSE) policy. policies are reviewed annually and signed by President and CEO. Policy is posted onboard all vessel and in the company offices ashore. KNOT Management and its employees shall pay appropriate regard to the environment by acting to preserve air, water, soil, plant life and animals from adverse effects and to minimize any nuisance that may arise from our activities. We also strongly believe that accidents – being harm to people, the environment or physical damage – don’t just happen, and are preventable. To ensure that service engineers/riding squad etc. is familiar with company policies, they are included in familiarization program. Responsibility for implementation of HSE policy is assigned to HSSE&QA director ashore, for follow up onboard the responsibility for implementation of HSE policy rests with the master.



Company Ref: - HSE 30.1.2 Environmental Policy. - FAT 8.0 Visitor's safety Familiarization (Non-Crew). - HSE 2.2 Shipboard HSE-Organization. - VAM 2.0 Job descriptions. - Environmental Awareness booklet. - HSE 20 Waste Management 10.1.2



All sources of marine and atmospheric emissions attributable to company and Yes vessel activities have been systematically identified. The company is aware of the growing concern about-, and the increasing importance of Waste Management to protect the Marine Environment from Pollution. Waste Management Policy and Procedures therefore are included in-, and an integrated part of Company HSSE&QA-System, implemented on all Company vessels and in Company Management. All sources of marine and atmospheric pollution have been systematically identified in connection with the ISO 14001 certification project. Comapny ref: - VOM 6.9 Fuel emissions - HSE 30.6 Greenhouse gases & Ozone depleting substance emissions - HSE 20 Garbage/ waste management. - VOC management plan. - Oil emissions (stern tube lube oil, bilge, sludge). - Ballast water management plan. - Ship specific Sewage procedure . - Evaluation of Antifouling paints. - Environmental Aspects ISO 14001



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10.1.3



Procedures minimise marine and atmospheric emissions and ensure that they Yes are always within permitted levels. KNOT Management and its employees shall pay appropriate regard to the environment by acting to preserve air, water, soil, plant life and animals from adverse effects and to minimize any nuisance that may arise from our activities. The Company requires the use of fuel with Sulphur content below or equal to 3.50 %. Except for vessel with ENVIRO+ notation (ABS), the sulfur content of the fuel oil used onboard is not to exceed the limit of 3.0% mass/mass prior to 1 January 2020" (accordance with 4/17.2 of the ABS Guide for the Environmental protection notation for vessels (ENVIRO+ notation)) Fuel samples shall be taken from each bunkering of HFO, MDO and MGO, for analysis, and the bunker-oils shall not be taken into use, until the results have been received. Samples are also checked for certain chemicals. The results are sent to the vessel and the Superintendent. With regard to Waste Management, it is the Policy of KNOT that the Company shall operate and manage our ships, in accordance with the principles laid down in MARPOL (Latest edition), IMO ISM-Code and with National and International Rules and Regulations. Company Ref: VOM 6.7 Bunkering procedure. VOM 6.9 Fuel change over. VOM 8.1.9 Lub oil analysis. CEEMP/SEEMP implemented. VOC management plan. HSE 20.1.2 Policy



Stage 2



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10.2.1



The environmental management plan includes energy efficiency and fuel Yes management. The Company has developed a Company Energy Efficiency Management Plan (CEEMP) that addresses areas common across all vessels in the fleet. In turn, based on the CEEMP, ship specific versions - the SEEMPs - have been developed incorporating an evaluation of current practice and existing equipment. Existing energy efficiency initiatives have been identified and included within both documents, thus forming a foundation from which the current status of energy efficiency within the Company can be assessed. Additionally, the scope is defined, along with prioritized measures resulting from the C/SEEMP development process. The documents will be reviewed at defined intervals to ensure periodic updating is undertaken to facilitate a continuous improvement process of the SEEMP, both in terms of the vessel’s baseline, the effect of the measures already undertaken and the prioritized list of activities. The fuel consumption baseline will be monitored regularly both on board and onshore to ensure optimum performance. Should the vessel operate with a higher consumption than the baseline for a given operational mode, then the reason for this is to be investigated and reported through the appropriate channels. If possible, the modes of monitoring the different initiatives can be used for this purpose. Any piloted initiatives are to be monitored carefully and their effectiveness and feasibility assessed by the responsible person. The Company seeks to meet its’ customers increasing expectations with respect to reduced environmental impact, and will comply with all relevant legislation, exceeding requirements wherever possible. The Master is responsible that the noon reports and voyage/sea passage reports have correct entries of times, distances, speeds and consumption's Voyage report VOM App 02 shall be used, unless the charterer’s form contains the same information and the superintendent has agreed it can be used. Voyage reports shall be sent to the Operator and Superintendent after each voyage unless otherwise agreed. Whichever form is used, it is very important to make remarks and take necessary actions if the performance requirements cannot be met. Company Ref. - HSE 31.1.1 Introduction and Background. - HSE 31.1.2 Purpose and Utilisation of the CEEMP. - Monitoring. - VOM 4.22 Speed and consumption. - VOM App 02 Voyage report. - VAM 4.5 Periodic reporting.



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10.2.2



The environmental management plan addresses efficient use of energy and Yes includes actions to improve environmental performance. The Company has developed a Company Energy Efficiency Management Plan (CEEMP) that addresses areas common across all vessels in the fleet. In turn, based on the CEEMP, ship specific versions - the SEEMPs - have been developed incorporating an evaluation of current practice and existing equipment. Existing energy efficiency initiatives have been identified and included within both documents, thus forming a foundation from which the current status of energy efficiency within the Company can be assessed. Additionally, the scope is defined, along with prioritized measures resulting from the C/SEEMP development process. The documents will be reviewed at defined intervals to ensure periodic updating is undertaken to facilitate a continuous improvement process of the SEEMP, both in terms of the vessel’s baseline, the effect of the measures already undertaken and the prioritized list of activities. The SEEMP review will form part of the Management Review and will include feedback from vessel personnel, office staff and calculated measures. Any changes in the implementation status of the initiatives will be evaluated and any necessary changes are to be recorded and implemented in a revision of the SEEMP. Should any initiatives prove ineffective or unfeasible, then these shall be removed from the SEEMP. Should any new initiatives be proposed through company ECO Care Actions and deemed appropriate to include in the SEEMP, then these should be included in the next years SEEMP. The assessment will ensure alignment of the SEEMP with the Company’s overall environmental strategy and goals. Company Ref: - HSE 31.1.2 Purpose and Utilization of the CEEMP. - EU MRV. - ECO Care Action.



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10.2.3



The company seeks to optimise vessel energy efficiency. Yes As a part of the development of the company CEEMP the Company has assessed a number of activities in order to reduce fuel consumption and thereby reducing the environmental impact of the company as a whole. The activities have been given a priority based on an assessment of the estimated potential for increasing the energy efficiency and the perceived effort required in order to implement the activities. The complete list of energy efficiency activities identified for the Company can be found in HSE3106. These activities will be subject to annual review where the complete list of activities will be revisited, new activities can be added to the list, and a new assessment of activities to be implementation will be undertaken. As a tool to identify any day to day savings towards fuel and energy consumption onboard, an ECO Care action has been implemented and is available in reporting module. These reports are used to document any onetime, temporary or permanent energy reducing actions the vessels make. If ECO Care Actions made by vessel can be implemented on a higher level than just that one individual vessel, it may be included on the company list of saving measures HSE31-06. Company Ref. - HSE 31.5 Prioritized List of Activities - HSE 31.4 Best Practice Development - HSE 31.6 Total List of Energy Efficiency Activities Identified - HSE 31.7 Document Development Input



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10.2.4



The environmental management plan includes procedures for fuel management Yes in order to ensure regulatory compliance, energy efficiency and reduced emissions. The fuel shall be according to the Charter-Party, as a grade listed in the ISO 8217 standard. It is the responsibility of the Master to order sufficient fuel oil for the intended voyage. As a guideline, a safety margin for deviations and bad weather should include bunkers for about 4-5 extra sailing days. The Company requires the use of fuel with Sulphur content below or equal to 3.50 %. Except for vessel with ENVIRO+ notation (ABS), the sulfur content of the fuel oil used onboard is not to exceed the limit of 3.0% mass/mass prior to 1 January 2020" Fuel samples shall be taken from each bunkering of HFO, MDO and MGO, by continuous drip sampling from the manifold. The samples shall be sent as soon as possible for analysis, and the bunker-oils shall not be taken into use, until the results have been received. If the oil does not meet the specifications, the Charterer, or the Bunker Supplier, shall be immediately informed. The Company will then discuss whether the fuel shall be redelivered (landed), for which compensation may be claimed. If the fuel has to be taken in use, Company will revert with precautions to be taken. Ships using separate fuel oils to comply with MARPOL – Annex VI, and entering or leaving an Emission Control Area set forth in MARPOL – Annex VI, shall carry a written procedure showing how the fuel oil change-over is to be done, allowing sufficient time for the fuel oil service system to be fully flushed of all fuel oils exceeding the applicable sulphur content specified in MARPOL – Annex VI, prior to entry into an Emission Control Area. The vessel specific procedure should containing: - A step-by-step procedure for carrying out the fuel oil change over - The date, time and position of the vessel - Methodes for calculating the time necessary to ensure the fuel oil service system is fully flushed of all fuel oils exceeding the applicable sulphur content limit prior to entering the ECA. Company Ref; - HSE 6.7 Bunkering - HSE 6.9.2 MARPOL Annex VI



Stage 3



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10.3.1



The potential environmental impact of all company and vessel activities is Yes subjected to evaluation. Systematic environmental review is undertaken to identify the Company’s environmental aspects. The review, which includes both vessel and land activities, takes into account: Types of environmental impacts, operational and accidental, e.g: - Use of energy - Emissions to air - Discharges to water - Delivery to land - Use of raw materials and natural resources - Noise and vibration - Waste - Aesthetics - Wild life and biodiversity Systems to be reviewed: - Life cycle of vessels (design, building, operation, maintenance including docking, recycling) - Vessel operational modes (sailing, manoeuvring, quay-side, loading and unloading) - Existing fleet and planned newbuildings - Contractors’ and suppliers’ products and services The result of the identification of environmental aspects is documented in the Environmental aspect matrix in the company document filing system. The environmental review and resulting list of environmental aspects shall be updated as a minimum every year or considered revised whenever there are any major changes to the Company’s activities or products like new types of vessels or services, as well as any new or revised legal or other requirements.



Company Ref; - HSE 30.2.1.1 Procedure for identifying environmental aspects. - Environmental aspects evaluation matrix. - ISO 14001 certificate.



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10.3.2



Specific emissions reduction targets are set in the environmental management Yes plan. The purpose of this procedure is to ensure that the company collect, process and present environmental performance of the company and its’ vessels in a way that where possible allows for monitoring environmental performance relative to legal and other requirements and the company’s environmental policy, objectives and targets. Measurable significant environmental aspects required by law and others shall be tracked in an environmental accounting system and involves reporting from each company vessel and the office units to a central coordinator at the KNOT head office. The environmental input data and output indicators for vessels and the company are available in the KNOT Environmental Accounting System, except for input data for spills, which are handled through the non-conformity reporting system. Input data to the environmental accounting system shall be updated as a minimum on an annual basis. However it is up to the reporting responsible for each unit to decide upon a more frequent reporting. The reporting shall be carried out according to a standard format and shall be sent by e-mail or any other implemented electronic reporting system from the reporting unit to the central coordinator. The HSSE-QA Director shall appoint a central coordinator and reporting responsible for operational environmental aspects for the land-based organization. The Technical Director shall be appointing the reporting responsible for environmental measures taken onboard the sailing fleet and newbuildings. The master shall appoint reporting responsible onboard. The central coordinator is responsible for control of the reporting documents and to aggregate the reported figures into an annual environmental performance report for internal usage. The annual environmental report shall be an input to the management review process. The annual environmental report shall contain the following: - documented environmental performance for defined indicators for the reported year and historical development; - overview of environmental measures taken and ongoing initiatives; - evaluation of environmental performance against: --Legal and other requirements, see Evaluation of compliance section below for details ---Objectives and targets, ref. Environmental Objectives and Targets document The report shall form a basis for further evaluation of environmental improvement measures within the Company and fleet. Parameters in the KNOT Environmental Accounting System for tracking the environmental performance shall be considered for update whenever there is a change in significant environmental aspects, rules and requirements, policies, objectives or targets. This shall be done by the central coordinator and new reporting instructions shall be distributed to all units concerned. Company Ref - HSE 30.4.1 Monitoring and evaluation of compliance. - KPI report environmental section.



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10.3.3



A long-term environmental plan is maintained. Yes The 5 year plan is developed based on the experience gained and lessons learnt from the first phase (2009 – 2014) 5 year plan. The targets set out in the first phase were under constant reevaluation and dynamic targets. However with this in mind all were met or modified whilst maintaining the original mind-set and desired results. Knutsen Group managed to commercialize and sell to customers it’s VOC system (KVOC® ) as well as obtain approval and delivery to vessels of its ballast water treatment system (KBAL® ). Knutsen Group managed to significantly reduce its NOx emissions by the use of NOx abatement technology and more specifically the installation of and Selective Catalytic Reducer onboard one of its Product Chemical Tankers. Additionally many project have been run in order to evaluate the reduction of SOx emissions which lead to the preparation for one of Knutsen Group’s Shuttle Tankers being prepared for SOx Scrubber installation. Finally Knutsen Group has investigated means of reducing fuel and oil consumption onboard its vessels (propeller efficiency, rudder efficiency, hull efficiency, paint efficiency, trim optimization, energy management, …) and the use of alternative fuels, such as LNG. The latter has led to a shift in thinking of not only office staff but also the perception that the vessel management take towards fuel consumption. ISO 5 year plan is reviewed annually Company ref; ISO 14001:2004 5-year plan. ADM 5.5.1 Management Review.



10.3.4



Environmentally sound ship recycling practices are employed/adhered to. Yes KNOT Management will follow the intention of The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships and if a Company owned vessel are planned sold to scraping yard or to a buyer that obviously intend to scrap the vessels, green recycling procedures shall be followed in all cases. If vessel is consider to be end of life, or by other means will be consider sold for ¨scrap value¨ Then vessel shall be sold directly to a recycling company which is included on the European list, Vessel IHM part 1, 2, 3 and "Ready for Recycling Certificate" to be delivered with the vessel. The selected facility shall be audited prior to signing “contract of sale”. Company Ref; - ADM 12.12.3 Scrapping of vessels. - ADM 12 App E.



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10.3.5



Environmental performance improvements are incorporated during the new Yes build process. Systematic environmental review is undertaken to identify the Company’s environmental aspects. The review, which includes both vessel and land activities, takes into account the Life cycle of vessels (design, building, operation, maintenance including docking, recycling) Selection of design and technology is evaluated as a Key environmental aspect on an annual basis. Knutsen technology has developed VOC & ballast water treatment technology, technology is utilized on own new buildings. Knutsen technology has sign a letter of intent for USCG approval of KBAL system. LNG Design development; - From steam propulsion to diesel electric to ME-GI. - From HFO to triple fuel engines. - Improved hull design. - Wake-improvement measures. Company Ref: - HSE 30.2.1.1 Procedure for identifying environmental aspects. - 14001 environmental aspects. - Company presentation.



Stage 4 10.4.1



Available technology is used to enhance energy efficiency.



No



10.4.2



The company explores new ideas and engages in technology partnerships related to environmental performance.



No



10.4.3



Fleet environmental performance and energy efficiency is benchmarked.



No



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Emergency Preparedness and Contingency Planning Stage 1 11.1.1



Detailed vessel emergency response plans include initial notification procedures Yes and cover all credible emergency scenarios. The Company has established a duty system for receiving notification of emergencies 24/7. This system also forms the basis for notifications of operational or security related situations after office closing times Vessel contingency plan is developed and include a detailed emergency response system, describing; - notification, - required actions depending on situation. - resources and responsibilities. Qualified Individual "ECM" reviews the VRP on an annual basis. Company Ref: - VCP 3.1.1 Emergency Contact - Notification. - VCP 5.0 Emergency Control procedures. - Emergency booklet.



11.1.2



A detailed shore-based emergency response plan covers all credible emergency Yes scenarios. 24 - Hour Duty Officer is appointed for one week length and the rotation plan, the Hour Duty Officer shall be able to reach the office within 60 minutes and shall during the duty period be able to drive legally to the office Emergency response team functions have primary and alternate members, this ensures effective response regardless of vacation(s) or travel arrangements. The KOAS/KNOT Duty Officer will be the Company’s first responder and shall act according to procedure in the duty document: ¨Instruction to KOAS/KNOT 24- hour Duty Officer¨. The KOAS/KNOT Duty Officer shall upon receiving any emergency call immediately call the Fleet responsible, his alternate or any other of the permanent team members. Regular and realistic emergency exercises focus on: - Notification. - Operation of the Emergency Control Center. - Clarification of roles, responsibilities, tasks and communication lines. - Communication with media. - Servicing next-of-kin. At least one exercise shall be carried out annually – and may involve company vessel. Record of participants shall be entered in the exercise log. Real accidents shall be recorded in the exercise log and in the ship’s Emergency Manual located in the library. Company Ref: - CCP 2.2 Emergency Organization. - CCP 4.1 Company Contingency Exercise.



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11.1.3



The shore-based emergency response plan has clearly defined roles, Yes responsibilities and record keeping procedures. The Emergency Task Force (ETF) Leader is the person designated by the President/Managing director to coordinate all aspects of an emergency response; including quickly developing incident objectives, managing all incident operations, reporting/notification procedures application of resources as well as responsibility for all persons involved. The ETF Leader sets priorities and defines the organization of the emergency task force and the overall incident action plan. General support consists of all permanent members of the ETF, which may be used as required by the ETF Leader. Team members which have specific responsibilities: - Vice President Chartering: Designated Media spokesman, communication with P&I (insurance) and charters. - Director New Building: Structural /technical and general advisor. - Director HSSE&QA: Designated contact for US authorities and QI. Safety environment and general advisor. - Crew Manager: Designated next of kind leader, designated contact person for manning agencies. - Vetting Manager: Designated for handling OIL major’s notification and updates. Nautical advisor for the team - Marine Operations Compliance Manager (KNOT): Offshore operation advisor Following positions may be called in by the ETF for additional support: - Technical Secretary: Contingency logbook & personal recordkeeping. - Superintendents: Vessel specific information. - Chief Information Officer: General IT support. - Communication & Navigation Manager: Communication systems support. - Company Security Officer: Security advisor. In principle, the members of the Emergency Organization shall take care of their normal areas of responsibility. All emergency responsibilities have defined both a primary and alternate personnel performing the individual duties. Company Ref. - CCP 2.2.2 Emergency Task Force. - CCP 2.2.2 General support. - CCP 2.2.9 ETF Team Members.



Stage 2



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11.2.1



The company provides suitable emergency response facilities. Yes The board room serves as Emergency Control Center (ECC), which is equipped with all necessary equipment such as; - Telephones - Voice recording system - Dedicated emergency Computer w/access to the server ([email protected]). - Video projector. - Charts on ECDIS Computer. - Emergency manual with ship’s drawings (must be brought from technical secretary office). - Updated manuals online Media group takes care of communication with media and all external public parties not directly involved in the emergency situation The group is also responsible for updating a crisis web page on the Company’s home page and to give internal information about the emergency situation. The group will be situated in a neighboring room to the Emergency Control Room, consists of a Manager and a number of spokespersons answering incoming questions. ext-of-kin consists of crew Manager and specially trained employees. They perform their tasks from their offices. The objective is to provide sober information and personal support to Next-of-Kin and others claiming personal interest in the incident. Company Ref: - CCP 2.2.1 Location and equipment. - CCP 2.2.4 Group functions - Media group - CCP 2.2.4 Group functions - next of kin



11.2.2



The scope and frequency of drills and exercises is determined by the number and type of vessels within the fleet and their trading pattern(s). Regular and realistic emergency exercises focus on: - Notification. - Operation of the Emergency Control Center. - Clarification of roles, responsibilities, tasks and communication lines. - Communication with media. - Servicing next-of-kin.



Yes



At least one exercise shall be carried out annually – and may also involve a Company vessel. Record of participants shall be entered in the exercise log. Real accidents shall also be recorded in the exercise log. Real cases will verify that the contingency plan meets its purpose. Company also participate in drills required by USCG. Company Ref - CCP 4.1 Company Contingency Exercise - Emergency Drill Matrix - QA:Server



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11.2.3



The plan includes procedures and resources to interact with media. Yes Media group takes care of communication with media and all external public parties not directly involved in the emergency situation (local communities, politicians, environmental organizations and other persons or groups claiming interest in the situation). The group is also responsible for updating a crisis web page on the Company’s home page and to give internal information about the emergency situation. The objective is to give external parties sober and correct information about the incident and to provide background information about the involved vessel and the company. Some tasks managed by the media group during an emergency: - Manager to establish contact with his media counterparts with relevant involved parties (shipowner, cargo-owner, insurance companies, rescue center, police, local communities) to agree on roles on the public scene. - Manager to liaise closely with the ETF to provide the spokespersons with valid statements to the public on the development of the emergency situation. - Update the crisis web page, prepare and give press releases and internal information. Assistance may be required for this. - Manager to evaluate the need of proactive actions towards the media or other public parties. - Manager to arrange interviews with media, press briefings or press conferences. - Manager to evaluate the need for sending a Company spokesperson to the scene of the accident. - Have prepared general statements ready for the press, including all relevant positive features of the Company. - Inform ship that KNOT is the main contact with the press An external company has been appointed to assist with handling the press/media and publishing press releases. Press releases shall be prepared for at an early stage, and coordinated with the Charterers. One person may be appointed to handle meetings with representatives from the media. Company Ref - CCP 2.2.4 Group Functions - Media group - CCP 2.2.6 External support - Media support



11.2.4



Lessons learnt from exercises and actual incidents are incorporated into the Yes emergency response plans. When a drill is completed, important aspects of the drill shall be evaluated at a debriefing meeting: - Did all means of communication work satisfactorily? - Were all members of the ETF comfortable with their duties? - Were external parties responding satisfactorily? A final summary with lessons learned, shall be prepared. Company Ref: - CCP 4.1.3 Company Contingency Exercise - Debriefing.



Stage 3



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11.3.1



Records are kept of participants who have been involved in emergency drills Yes and exercises. At least one exercise shall be carried out annually – and may also involve a Company vessel. Record of participants shall be entered in the exercise log. Real accidents shall be recorded in the exercise log. When completed, important aspects of the drill shall be evaluated at a debriefing meeting. - Did all means of communication work satisfactorily? - Were all members of the ETF comfortable with their duties? - Were external parties responding satisfactorily? A final summary with lessons learned, shall be prepared. Company Ref: - CCP 4.1 Company Contingency Exercise. - Emergency computer logs



11.3.2



Arrangements are in place to use external resources in an emergency. Different parties may provide support in an emergency situation. Such help should always be considered. Relevant organizations are: - Rescue control centers - Insurance companies - Flag state authorities - Class societies - Charterers - Cargo owners - Salvage companies - Oil spill clean-up organizations and companies



Yes



In connection with the US OPA 90 regulations, the Company has an agreement with ECM Maritime Services, who represents the company as a “Qualified Individual”. Also a next-of-kin support agreement with the Norwegian Seamen’s Mission and an agreement with media consultants have been arranged. - CCP 2.2.7 Third party support. - CCP 3.2 Emergency Telephone numbers.



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11.3.3



Drills and exercises test the effectiveness of arrangements to call on external Yes consultants and resources. During the annual exercise external parties are involved either to play a part or to arrange the exercise and may also involve a Company vessel. - Record of participants shall be entered in the exercise log. - Real accidents shall be recorded in the exercise log. When completed, important aspects of the drill shall be evaluated at a debriefing meeting. - Did all means of communication work satisfactorily? - Were all members of the ETF comfortable with their duties? - Were external parties responding satisfactorily? A final summary with lessons learned, shall be prepared. - CCP 4.1 Company Contingency Exercise.



11.3.4



Business continuity, in the event of potential disruption to the main place of Yes business, has been addressed. The main purpose of the Business Continuity Plan document is to identified roles and responsibility and in order to maintain business operations after a potential crisis or other situation result in restricted or no access to the main office premises the main office in Haugesund. The document outline functions and roles of the emergency task force, describe task procedures and requirements necessary for the Office Organisation to handle emergency/crisis situation professionally at site of the main office in Haugesund. Such situations could be total loss off office due to fire, nature disaster or other criminal threat. Contingency location; In the case of a crisis has occurred and the main office building is not available, alternative locations are identified.



Company Rep: - CCP APP 01 Business Continuity Plan. - CCP APP 01 Business Continuity Plan 2.2 Contingency location. 11.3.5



Procedures address recovery following an incident. Yes It is Company Policy that all serious incidents, which have caused death or serious injury to personnel and damage to environment, material or to third person’s property, shall be investigated (e.g. collision, grounding, fire, serious LTI, fatality etc.) While the facts are fresh in the minds of the witnesses, it is of utmost importance to secure evidence as soon as possible. This is very important in order to protect Owner’s interests in a claim raised against the vessel. The publication “Master’s Role in Collecting Evidence” should be used as a guide. Company Ref - VCP 4.2 Post incidents - securing of evidence - FAT 9.0.Emergency takeover Checklists



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11.4.1



There is a formal business continuity plan identifying and addressing events Yes that may result in serious disruption to the business. Risk Management included in the business continuity plan assesses and prioritizes the identified risk scenarios that may occur. Company ref: - CCP APP 01 Business Continuity Plan 2.2 Contingency location. - IT Business Continuity and Recovery Plan. - IT Backup and Recovery Plan.



11.4.2



The company participates in major emergency exercises involving external Yes agencies. The company has on several occasions been involved in major exercises that have been set up by the Norwegian coastal directorate. The annual Emergency drill is normally set up by Norwegian hull and machinery our H&M Insurer, the insurer will then play the roles of different parties having interest in the incident, form media to next of kin. thus making it a challenge for the Emergency task force. Company Ref - CCP 4.1 Company Contingency Exercise - exercise log/records.



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11.4.3



Means to support a protracted emergency response have been identified. Yes The ETF Leader is the person designated by the President/Managing director to coordinate all aspects of an emergency response; including quickly developing incident objectives, managing all incident operations, reporting/notification procedures application of resources as well as responsibility for all persons involved. The ETF Leader sets priorities and defines the organization of the emergency task force and the overall incident action plan; - Establish a strategic plan for actual and potential danger to people, cargo spills, ship damage etc. - He evaluates the emergency situation and takes proper actions. - He conducts meetings to update the emergency task force. - He co-operates closely with the Managers of media communication and Next-of-Kin communication. - He decides whether the Company shall place Liaison Officers with Rescue Centers or with other parties – or to accept liaisons from involved parties to arrive. - He informs and advises the President & CEO/ Managing Director about the situation and any actions taken. - For cases related to KNOT, reports according to CCP 3.3.0 - if early signs indicate a protracted emergency response, a plan shall be established to address the needs of the emergency task force i.e.: (Fatigue, food and hygiene, accommodation, transport, review of ETF manning level, maintaining safe operations of existing fleet) plan should be revisited and updated as required.



Company Ref; - CCP 2.2.2 Emergency Task Force



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11.4.4



Additional resources to support crisis management have been identified. Different parties may provide support in an emergency situation. Such help should always be considered. Relevant organizations are: • Rescue control centers • Insurance companies (P&I / DNK) Specialist post trauma support, Negotiators) • Flag state authorities • Class societies • Charterers • Cargo owners • Salvage companies • Oil spill clean-up organizations and companies



Yes



In connection with the US OPA 90 regulations, the Company has an agreement with ECM Maritime Services, who represents KNOT as a “Qualified Individual”. KNOT has also a next-of-kin support agreement with the Norwegian Seamen’s Mission and an agreement with media consultants.



Company Ref: - CCP 2.2.7 Third party support. - DNK War risk cover - https://www.warrisk.no/cover/ "The basic insurance program offered by DNK covers total loss, damage, collision liability, hull/freight interests, loss of hire, owner's liability (P&I) and occupational injuries caused by war perils. The war risk insurance offered by the Association is covered on the basis of the Nordic Marine Insurance Plan (of 2013)."



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Measurement, Analysis and Improvement – Inspections Stage 1 12.1.1



A company specific format is used for conducting and reporting vessel Yes inspections. Each vessel shall be subject to an annual inspection by the Superintendent. Any visit shall normally be followed by a “Ship visit Report”, Appendix A. The action plan shall be discussed onboard, and include responsible person and a deadline. All Ship Visit Reports shall be created by the person responsible for the various inspections carried out for the Company (Observer). UniSea Audit allows reporting several different types of visits, these are: - Ship Visit Reports (Personnel Ship Visit, Purchase Ship Visit, Technical Annual Ship Visit and Technical Ship Visit) - Management Visit Reports



Company has established a document control system in accordance with international standards and applicable requirements described in ISO 9001:2008, ISO 14001:2004, OHSAS 18001:2007 and the ISM Code. The following steps in a document’s life shall be considered: - Preparation, verification and approval of the document; - Revision identification; - Document file management; - Distribution management; - Updating and revision control;



Company Ref: - ADM 12.8.4 Ship visit and internal audits. - ADM 12.App A - HSE 6.1.6.1 Ship visit reports - Unisea Audit.



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12.1.2



An inspection plan covers all vessels in the fleet, with at least two inspections of Yes each vessel a year. Each vessel shall be visited minimum 3 times a year, two of these visits should be performed by the vessels superintendent. One of the visits should preferable be conducted while sailing with the vessel. Any visit from superintendent shall be followed by a “Ship visit Report”, Appendix A. Plan for annual ISM established and maintained by Safety manager. Fleet managers are responsible for that a ship visit plan is established for their respective fleets. Company Ref: - ADM 5.2.4 Audit plan internal vessels - ADM 12.8.4 Ship visit and internal audits. - ADM 12.App A. - HSE 6.1.6.1 Ship visit reports. - JD Fleet manager. - Unisea Audit.



Stage 2 12.2.1



The inspection format is of a standard that is at least equivalent to the vessel Yes inspection reports issued by industry bodies such as OCIMF, CDI or EBIS. Each vessel shall be visited minimum 3 times a year, two of these visits should be performed by the vessels superintendent. One of the visits should preferable be conducted while sailing with the vessel. Any visit from superintendent shall be followed by a “Ship visit Report”, Appendix A. Plan for annual ISM established and maintained by Safety manager. Fleet managers are responsible for that a ship visit plan is established for their respective fleets. Company Ref: - ADM 5.2.4 Audit plan internal vessels - ADM 12.8.4 Ship visit and internal audits. - ADM 12.App A. - HSE 6.1.6.1 Ship visit reports. - JD Fleet manager. - Unisea Audit.



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12.2.2



A system records any deficiencies identified by the inspections and tracks them through to close out. The Internal Ship Inspections / Internal Audits Reports shall be entered and processed in the UniSea Audit.



Yes



Audit Reports in Unisea shall have: - A brief title describing the content. If there are no findings – this shall be mentioned in the “comments” - Due date according to the auditor’s report - The auditor’s observation in full (verbatim or accurately translated if presented in another language than English) - A reference to external or internal regulations if given or found. - Findings shall be assigned to ranks onboard (Master, Chief Officer or Chief Engineer) or to named individuals in the shore organization if relevant. - Analysis; -- The person assigned a specific finding shall ensure that the direct and root cause(s) are ticked off and a brief explanation to the root cause given. -- The Corrective action shall reflect on the Direct Cause for the finding. -- The preventive action(s) should normally be based on the root cause. The learning elements gained shall be described. The preventive measures shall primarily reduce the chance of reoccurrence and must thus be well thought through, realistic and (preferably) verifiable at a later stage. -- Corrective measures taken to avoid re-occurrence of the direct cause shall be described in “Corrective action” -- If relevant; an analysis of the Risk Potential shall be done. - Based on the analysis the corrective action and preventive measures shall be described. - Attachments (References) as required, (photo, document, etc.). The surveyor’s reports shall be attached to the “Audit Report”. Underlying documentation for each finding can be attached to these. Ship visit report UniSea audit The Ship Visit Reports shall be issued by the person who conducted the visit (Observer), it shall be entered in UniSea Audit after completion of the report. The Ship Visit Report will be monitored by the responsible person representing the Company, until all actions are considered taken, in order to process and close the report, within the determined limit. If the vessel is visited by someone else than the Superintendent he/she shall be informed about this report when it is forwarded to the vessel. The Master (Reporter) will forward the report to the origin of the document (Responsible), for review of closing actions, when all actions in the report are taken. The origin of the document (Responsible) will forward the report for final approval by Fleet Manager (Approver), when all actions are considered taken. If no further comments, the Ship Visit Reports will be closed. Trends and stats from UniSea Audit included in quarterly Safety bulletins. Company ref - HSE 6.1.6.1 Ship Visit Reports



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- HSE 6.1.7.1 Content of reports in UniSea Audit - Unisea audit records. Stage 3 12.3.1



To improve vessel standards, the company analyses its inspection results and Yes makes comparisons within the fleet. HSSE&QA performance encompasses all activities, e.g. functions performed, services provided or products made. The key element of HSSE&QA performance is continuous improvement towards doing the work right the first time. Improvement is tangible by a better output and a safer and more cost-effective performance. Improvement shall be based on experience, and all managers are in this respect responsible for measuring and analyzing performance within their units, and for using the results to obtain improvements. External inspection results from oil majors, flag state authorities etc. are checked and compared with internal inspections. Best practices & Lessons learned are shared to fleet through Lateral learning, vetting focus, Safety bulletin and/or technical bulletin. Company ref: - ADM 5.1.2.1 General. - Safety Bulletin, Vetting focus, Lateral learning & Technical bulletin.



12.3.2



In order to improve the inspection process, analysis of inspection results is Yes compared with data from third party inspections. External inspection results from Majors, flag, port authorities are checked and compared with internal inspections (unisea Dashboard) If needed, internal inspection routines are improved based on the findings external inspections. Company Ref. - ADM 5.5 Management review.



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12.3.3



The inspection process identifies weaknesses in personnel familiarity with Yes equipment and operations. The company has a target to have a safety audit onboard every vessel at least once per year. All new buildings and purchase of second hand vessels shall be inspected prior to delivery to the company. An audit plan shall be made for each year and visits will be coordinated with the vessel superintendent visits and the internal ISM/ISPS audits. Through the vetting department, several Fleet Safety inspectors are engaged in carrying out the internal safety audits onboard the vessels. The safety audits shall be carried out according to a checklist made for the purpose, based on both internal procedures and routines and OCIMF vessel inspection questionnaire (VIQ) The safety audits will include a navigational audit of all navigation officer to ensure familiarity to company procedure and routines and navigational equipment onboard the vessel. a cargo operation audit to ensure all critical items in an operation is included in the load/discharge plans. a mooring operation audit, which will include check of inspection of mooring wires/ropes and records available onboard. An engine room audit to ensure familiarity with all company procedures and routines and equipment. General meeting with SMT and crew. Highlighting the latest company campaigns and root cause investigations from the fleet. If time permits, a fire- and lifeboat drill shall be conducted.



Stage 4 12.4.1



Information from detailed analysis of inspections is fed into a continualYes improvement process. Management Review process include analysis of internal and external audit requirements and performance. Bench-marking of specific company KPIs are done towards industry peers. Evaluation of equipment manufacturers, vendors, service providers etc is part of masters review and is evaluated by each vessel. Company ref: - ADM 5.5 Management Review. - Masters Review. - Management Review.



12.4.2



Information technology is used to enhance the inspection process.



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No



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Measurement, Analysis and Improvement – Audits Stage 1 12A.1.1



The company has documented audit procedures and standard audit formats. Yes Audit procedure and standard elements for both office and vessel audits is laid down in detail. Safety Manager is responsible for that corrective action is carried out in accordance with the procedures. Company Ref - ADM 5.2 Internal Audits - ADM 5.6 Internal ISM, ISPS, ISO & OHSAS Audit Program - UniSea Audit.



12A.1.2



Company auditors are appropriately trained and qualified. Yes The company maintain a pool of qualified Auditors (HSSE&QA & Vetting dept.) Every internal audit shall be led by adequately trained and qualified auditor. Company Ref: ADM Job description HSSE&QA and vetting dept.



12A.1.3



An audit plan covers all vessels and company offices. Yes At the start of the year, audit schedules shall be set up based among others on input from discipline responsible personnel and operational experience. Company Safety Manager is responsible for the overall co-ordination of this process. All audits shall follow the guidelines of the International Standard ISO 19011 and the ISM - Code. All vessels should be audited at interval not exceeding 12 months. If for any reasons this requirement is not possible to be meet the Safety Manager must, in cooperation with the HSSE&QA Director immediately contact the vessels flag and /or class for guidance. The Main Office in KNOT should be audited at interval not exceeding 12 months. Branch Offices should be audited annually The HSSE & QA Director shall be responsible for the coordination and performance of the process. Audit plans are established for shore and fleet. Company ref: - ADM 5.2 Internal Audit - Internal Audit plan.



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Stage 2 12A.2.1



Audit results are reported to management within a specified time frame. Yes The Auditor has the overall responsibility for internal follow-up and distribution of the Internal Audit Report. Company standard Internal Audit Report Form, are to be used. Within 3 weeks after completion of the Audit, the Auditor shall have completed the “Internal Audit Report”. Company ref: - ADM 5.6.6 Internal Audit Report. - ADM 5.6.7 Distribution and follow-up of Audit Report.



12A.2.2



Audits are performed in line with the audit plan. All vessels should be audited at interval not exceeding 12 months. If for any reasons this requirement is not possible to be meet the Safety Manager must, in cooperation with the HSSE&QA Director immediately contact the vessels flag and /or class for guidance.



Yes



Company audit plans are checked against performance by end of each month (KPI). The monthly performance report is distributed to senior Management, during management meeting. Company Ref - ADM 5.2.4 Audit plan internal Vessels. - KPI report Stage 3 12A.3.1



All audit non-conformities are closed out within the prescribed time frame. Yes The Auditor has the overall responsibility for internal follow-up and distribution of the Internal Audit Report. Company standard Internal Audit Report Form, are to be used. Director of Department /The Masters are responsible for actions taken and closing of the Findings, NonConformities and Observations, within given deadlines. Deadlines given may extend up to 3 months, longer deadlines are normally not granted if not specific cause, e.g. delivery of Item on order, requirement for dry docking etc. Unisea Audit Software gives good oversight over approaching deadlines. Company Ref: - ADM 5.6.7 Distribution and follow-up of Audit Report. - Unisea Audit.



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Stage 4 12A.4.1



Formal analysis of audit results is performed at least annually and this drives Yes continual improvement of the SMS. The audit performance is a vital part of the Management Review. The management to initiate actions whenever needed in order to find root cause, and to improve Company HSSE&QA system and performance in general. Audit results and trends are analyzed on a yearly basis as a part of the management review, any input from the audits to improve company’s HSSE&QA performance will be brought forward as actions points in the HSSE&QA program for the year. Company Ref: - ADM 5.5 Management review. - Management review records.



12A.4.2



Information technology is used to enhance the audit.



No



12A.4.3



A contractor management system which includes periodic auditing is in place. Company carries out Audits / System Evaluations of Subcontractors, Manning Companies, Suppliers, Yards, etc. to verify that the companies are in compliance with KNOT HSSE&QA



No



Requirements. The general responsibility for performing Audits/System Evaluations of companies sub-contractors rests with the organisational unit that makes use of the sub-contractor The HSSE&QA Director shall prepare an annual audit plan scheduling the planned evaluation of subcontractors for the various departments.



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Maritime Security Stage 1 13.1.1



Documented security plans are in place. Yes Ship Security Plan is developed for each ship to ensure the application of measures on board the ship designed to protect persons on board, cargo, cargo transport units, ship’s stores or the ship from the risks of a security incident, meaning any suspicious act or circumstance threatening the security of a ship. Business Continuity and IT security plan addresses the threats that may occur at the company office. Ship security Officer is responsible for all Shipboard Security Familiarization and Training defined in Ship security officers Vetting Manager has been appointed Company Security Officer, and Marine Superintendent has been appointed deputy Company Security Officer. Company ref. - Ship security Plan - ADM 1.4.6 Company Security Officer (CSO) and deputy Company Security Officer. - ADM 3.10 IT security policy - ADM 10.5 Procedure for information security. - VAM 2.6 Job description 2nd officer. - SSP 4.1 Security organization map. - CCP app 1. Business Continuity Plan



13.1.2



The company has documented procedures in place to identify security threats Yes applicable to vessels trading areas and shore-based locations. Ship security Assessment included in Ship security plan addresses security threats applicable to vessels, while business continuity and IT security plan addresses the threats that may occur at the company office. Company Ref - SSP Ship security assessment. - CCP APP.1 business continuity plan - ADM 3.10 IT security policy



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13.1.3



Measures have been developed to mitigate and respond to all identified threats Yes to vessels and shore-based locations. Ship security plan and ship security assessment addresses: access control, Physical security, training & drills, Monitoring of vessel and surrounding area and search plans including guide on how to perform searches. Procedure for information security is divided into the following five topics: - Program and data security management, - Data security, - Operating system security, - Network security, - Physical security. in addition information security, office location security is addressed in emergency control procedures included in business continuity plan for identified risk scenarios. Company Ref - SSP Ship security plan. - CCP APP.1 business continuity plan. - ADM 10.5 Procedure for Information Security.



13.1.4



Procedures are in place to obtain, manage and review current security related Yes information. - Intelligence information from reliable sources, e.g. National and regional agencies, NATO, UKMTO, M-DAT, Fusion center, DNK, Risk Intelligence, etc. shall be evaluated by CSO and distributed to the senior management and to the vessels trading in HRA. - All vessels trading in HRA are included in Risk Intelligence service and receive automatically all reports related to security, piracy, etc. - Port intelligence information is also a part of the Risk Intelligence service. - In areas where smuggling, trafficking of people and drugs have a potential, vessels will be contacted to carry out searches of the vessels.



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13.1.5



Procedures include the reporting of potential security threats and actual Yes security incidents. Security briefing is provided to all visitors and crew, prior to departing, on any specific threats and the need for vigilance and reporting suspicious persons, objects, or activities. A Security Incident is any act that may threaten the security of the ship. Depending on the seriousness of the breach will depend on the action that is carried out. Reports on the incident and measures taken should be employed to prevent the recurrences. All Security Incidents shall be reported to the Company security officer. Company Security Officer shall have the responsibility and authority for reporting security incidents to vessel’s relevant flag administration and eventually other Contracting Governments as relevant. Company Ref - SSP 10.5 Measures for Controlling the Embarkation of Persons and Their Effects. - SSP 12.2 Report of a Security Incident. - ADM 1.4.5 Company Security Officer (CSO)



Stage 2 13.2.1



Formal risk assessments of company activities are undertaken to identify and Yes mitigate potential security threats. Risk assessment are made by the company to identify and mitigate threats for vessels trading in HRA and reviewed on annual basis. Company Ref - Unisea Risk



13.2.2



The personnel responsible for security receive training appropriate to their role Yes and the company’s activities. Security briefing is provided to all visitors and crew, prior to departing, on any specific threats and the need for vigilance and reporting suspicious persons, objects, or activities. A Security Incident is any act that may threaten the security of the ship. Depending on the seriousness of the breach will depend on the action that is carried out. Reports on the incident and measures taken should be employed to prevent the recurrences. All Security Incidents shall be reported to the Company security officer. Company Security Officer shall have the responsibility and authority for reporting security incidents to vessel’s relevant flag administration and eventually other Contracting Governments as relevant. Company Ref - SSP 10.5 Measures for Controlling the Embarkation of Persons and Their Effects. - SSP 12.2 Report of a Security Incident. - ADM 1.4.5 Company Security Officer (CSO)



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13.2.3



Policy and procedures include cyber security and provide appropriate guidance Yes and mitigation measures. The Procedure for Information Security is part of the company governing documents and is anchored in the IT Policy. The purpose of the procedure is to provide an understanding of how activities related to information security are performed. Topics included in Procedure: - Program and data security management, - Data security, - Operating system security, - Network security, - Physical security. Company Ref: - ADM 3.11 IT Security Policy. - ADM 10.5 Procedure For Information Security.



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13.2.4



The company actively promotes cyber security awareness. Yes The company shall have bi-annual awareness campaign/training to inform all employees about potential consequences related to unauthorized access, both physical and logical. Only authorized users are allowed to access the Company system. Care should be taken to prevent unauthorized users from accessing the system and especially taking care not to leave the computer unprotected. Copying data from/to KNOT servers/computers for personal use is prohibited. Access to data shall be granted on a need-to-know basis. This is achieved through the network operating system’s access control functionality. The systems are administered by the IT Department. Passwords are considered as confidential Company information, and must not be given to others. It is prohibited to use other people’s passwords and usernames without approval. Users should be aware that all network printers are accessible to everyone. Care should, consequently, be taken when ordering printouts of a confidential nature. Users shall, furthermore, always log out of the network when leaving their office at the end of the day. All electronic equipment shall, as a general principle, be switched off or set to standby. Code of conduct include Social media guidance. The use of social networks and blogging by employees, whether using company property and systems or personal computer systems, is subject to the terms and restrictions. Limited and occasional use of company systems to engage in social networks is acceptable, provided that it is done in a professional and responsible manner and does not interfere with an employee’s regular work duties. Employees are prohibited from revealing any company confidential or proprietary information, trade secrets or any other material when engaged in social networks. Employees shall not engage in any activity that may harm or tarnish the image, reputation or goodwill of the company or any of its employees. Employees are prohibited from making any discriminatory, disparaging, defamatory or harassing comments when using social networks It is prohibited to connect unauthorized equipment to the network without getting prior approval from the IT department. This also applies to any other non-KNOT equipment, private or otherwise including, but not limited to CD –RW, DVD-RW, USB Drive, External/Internal Drive, Printers, Scanners, MP3 Players, etc. Any approved external media such as floppy discs, CDs, USB Drives, and DVDs must be scanned using the Company antivirus software before use. Company Ref: - ADM 10.5.3.2 Educating employees in information security - VAM 5.1.8 Access - ADM 3.2 Code of conduct - IX. IT activities and security. - VAM 5.1.10. Unauthorised Equipment / External Media



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Stage 3 13.3.1 13.3.2



A travel policy is in place to minimise security threats to personnel.



Yes



Security procedures are updated taking into account current guidance. Yes The company shall carry out a ship security assessment (SSA) for every new building and second hand vessel and based on the assessment develop a Ship Security Plan (SSP). The SSA will include all relevant security measures prepared and made during the new building stage. E.g. door closing devises, CCTV, access control, communication, vulnerable areas trading areas, citadel, etc. Best Management Practice (BMP latest edition), shall always be used as reference. The SSP shall include drill plan, security patrols and search plans as well as Ship Security Alarm System (SSAS) details. This Plan will be regularly reviewed and updated. Review will be the responsibility of the Company and will be carried out at intervals not exceeding 12 months. Company Ref - ISPS Review.



13.3.3



The security policy and related procedures are included in the internal audit Yes programme. Auditor shall express his opinion on how he found office, employees, the vessel, the crew (cooperation, knowledge, motivation, behavior and interest) and compliance with the Safety Management System. Elements of the audit will include control of relevant documentation on safety, security, work environment, environmental issues and quality assurance - including internal procedures and reporting, meeting structure, instructions and checklists. Company Ref ADM 5.6.5 Internal audit program



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Stage 4 13.4.1



Assessments are undertaken of the company’s security measures and Yes preparedness. - The company has developed procedures in Company Contingency Plan (CCP) and Vessel Contingency Plan (VCP) to ensure that security threats are identified and procedures to mitigate potential threats are described. - Security drills shall be carried out every 2 months onboard the vessels. Ship Security Alarm System (SSAS) are tested at least once per year with all vessels, this also include national RCC. - Security drills for office staff shall be held on regular intervals and drills including testing of reporting lines between vessels, company, insurers and external authorities. - Assessment and debrief of the drills are evaluated by the Emergency task force and CSO



13.4.2



Independent specialist support is used to mitigate identified security threats. Yes Due diligence audits of potential Private Maritime Security Contractors (PMSC) shall be carried out before any contracts, based on BIMCO, are signed. Before employment of a potential PMSC, Flag authorities must be consulted and approval of the potential PMSC must be received



13.4.3



Vessels are provided with enhanced security and monitoring equipment. Yes - The ship security assessment (SSA) will include all relevant security measures prepared and made during the new building stage. E.g. door closing devises, CCTV, access control, communication, vulnerable areas trading areas, citadel, etc. - Best Management Practice (BMP latest edition), shall always be used as reference. - The SSP shall include drill plan, security patrols and search plans as well as Ship Security Alarm System (SSAS) details. - Vessels trading in HRA shall be equipped with night vision binoculars, helmets, bullet proof vests, razor wires or ARX devises.



13.4.4



Security enhancements are considered for inclusion in refit specifications and Yes new-build design. Security enhancements are considered as part of the new building design and takes into account vessels trading area, vessel type and size and manning levels.



13.4.5



The company is involved in the testing and implementation of innovative security technology and systems. The company has close cooperation with security actors and is participating in testing of new innovative security technology and systems. This include both hardware and software systems.



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Yes



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