December 31, 2015

Substitute for thought

What most jargon seeks to achieve is exclusivity and a promotion of the notion that the user of a language few understand is somehow more efficient or more professional than the rest of us. Never mind that we see through the game; never mind that jargon is usually pretentious, inaccurate and jarring to the ears. The cute acronyms and the sonorous phrase is meant to awe and impress those not in the inner circle; that is its main function.

Shipping- the birthplace of the wonderfully imaginative language of the lascars- has reduced itself today to stealing jargon from wherever it can find it. Managers love to ‘introduce’- usually at seminars where hostage seamen have no option but to listen- some ‘new concept’ under a suitably impressive sounding name and pretend it is their invention. That it is usually copied and pasted from other professions- often general management or, with safety, the airlines industry- is beside the point. What is not is that this jargon- like all others- misleads, substitutes style for substance and tries, consciously and otherwise, to make a fool of us all.

The jargon shipping likes to steal is also often plain incorrect and is sometimes intended to be so. Take the term ‘Post Traumatic Stress Disorder,’ applied particularly in the last few years to seamen pirate hostages. To me, PTSD is simply shell shock, but by giving it a softer, less urgent sounding acronym, the industry- like the many armies who have substituted the term PTSD for shell shock- downplays the debilitating nature of the problem and pretends it is not urgent. The softer sounding PTSD allows everybody to postpone treatment or ignore the problem altogether. They may actually have to do something about it if they called it what is actually is- shell shock.

Another one I always find wistfully amusing is ‘Near Miss’ because it always brings up the image of a pretty girl walking by so close that I can smell her perfume. That, folks, is a near miss. Two ships almost colliding in the middle of the Pacific is not a near miss. It is a near hit and should be called so. I will bet that, if you called it a Near Hit, everybody- including the people on the ship- would take the incident much more seriously. (Besides, how can you nearly miss? That is like saying somebody is nearly pregnant.)

Don’t forget the stolen management jargon! Don’t get me started on the meaningless, annoying words that we love to steal from those business executives who are busy justifying their existence and who our managers love to copy. Even the word ‘management’ is quite useless- everybody who works manages something or the other- but it is still less galling than many others that shipping loves to ape. Phrases like ‘pushing the envelope’, ‘paradigm shift’, ‘leverage’, ‘core competency,’ ‘CSR activities,’ ‘empowerment’, ‘our corporate values’ (Ha Ha) and ‘Best Practices’ are (sorry, Shakespeare) “told by an idiot, full of sound and fury, signifying nothing”.

My favourite, however, is ‘take it to the next level’. (Maybe they should just take it away instead and be done with it.)

I suppose all jargon is, in the end, a deficit of imagination. But that would still okay; the problem becomes when jargon is used, intentionally or otherwise, to mask real meaning. And the problem is that jargon is too often used- in shipping and elsewhere- as a substitute for thought. 


December 18, 2015

The groupies in Indian shipping

Let me say, first of all, that I am going to avoid using the word ‘seafarer’ from now on. I am a proud seaman and refuse to be an airy fairy seafarer. And, since most of the people sailing on commercial ships are men, the generic word I will use is seamen. The few women out there-may their tribe increase! - are free to call themselves seawomen. I think they might prefer that anyway. 

The irrational exuberance in Indian shipping circles about the performance of the present government defies logic, or perhaps it is the contrast that has everybody all excited, since shipping has been neglected for decades in the country. Even though the many announcements made by the Shipping Minister Nitin Gadkari are welcome, intentions do not mean too much on their own. The fact is, for example, that Indian government controlled ports will continue to struggle for the usual reasons for a long time even if they are (kind of) corporatised, that Indian shipbuilding will remain in the doldrums regardless of whatever sops are thrown its way and that connecting inland waterways or building hundreds of small ports will take decades even if there is continuity of policy and priority, since we do not have the crapload of money that will be required to do this. There is no need to get so excited about what are, in the end and so far, just plans.

None of these facts stops the establishment from behaving like a bunch of star struck teenage girls mooning over Brad Pitt. Delve deeper into this phenomenon, though, and you find that the crowd of groupies is made up of one or more of the following: the usual line-up of businessmen with links to politicians, blinkered supporters that this government has attracted ever since its inception, opportunists hoping to make a quick buck out of empty air, industry bodies trying to peddle influence and professional bodies run by outdated mariners trying to gain some influence so that they can pretend to be relevant. The lure of money and power prevails on the back of a faith in the corrupt system and the mistaken belief that announcements trump viability, capability or delivery.

What is remarkable- though hardly unexpected- in all this is that there is nothing mentioned about the establishment-sponsored plague that has hit Indian seamen for decades. Okay, sorry, there was one solitary announcement: granting some Indian seamen working on Indian registered ships- not all, not by a long shot- parity with Indians working on foreign flags when it came to income tax. That this is too little and far too late is almost beside the point; the really big problems that plague our seamen are not.

The huge falling-competency issue in Indian seamen make it unlikely that India will be a maritime superpower (how the groupies love that term!) anytime soon. Where will the thousands of competent ex-seamen required in maritime operations, insurance, classification, shore establishments, dredging and administration et al come from for this to happen? There is dead silence from the government or the groupies on this question. Can’t blame them since they are not looking beyond their noses; in any case, most are akin to short-term touts with no long term interest in the game.

That this competency issue is directly related to the endemic massive corruption in the recruitment of Indian seamen, the degrading of the profession or the cavalier- spiteful, even- treatment of Indian officers and crews is not spoken of in any official circles, leave alone addressed. There is no announcement on how we are going to address this problem. There are no plans for cleaning up the system that, incidentally, is run by many of the same groupies that are swooning over everything else. No ideas on how we will attract calibre. Those plans would be useless without cleaning up the act anyway, because calibre avoids a rotting carcass.

Somebody needs to tell the groupies that money is easier to attract than people in almost any enterprise. The former requires a robust business plan on paper, which is simpler. The latter requires good sense and a progressive mind-set, both rarities in the cesspool that the shipmanning business in India is today. Somebody should also tell them that announcements, whether made for questionable and corrupt reasons or not, are no substitute for a workable plan that includes, critically, the management of the human resources that will be needed. Somebody should tell them you can’t grow Indian shipping without growing the numbers and competence of Indian seamen and that the first step towards that is to begin to treat seamen like human beings.

But that somebody is not me. I am not going to tell them this, because that would be like breaking wind against thunder. Because, you see, most of these groupies would not recognise the concept of the development of human resources even if jumped up and bit them in the unmentionables; their regressive attitude is in their DNA.


December 03, 2015

Hot water

By now, the hope at the end of last year that shipping would see some kind of revival in 2015 has given way to near despair. That hope was misplaced anyway; the despair today may not be.

The overwhelming consensus at present seems to be that the global economy is still struggling badly and will continue to do so for some time. Maurice Obstfeld of the IMF put it mildly, I thought, when he said, "Six years after the world economy emerged from its broadest and deepest post-war recession, the holy grail of robust and synchronised global expansion remains elusive." We are in an era where the clamorous predictions of global trade doubling in the next fifteen years are starting to sound increasingly like a pipe dream. Damisa Moyo warned the Danish Maritime Forum last month that the pre-2007 type of economic growth ‘will never return’. Strong words.  I would have used may instead of will, but I am in agreement with some other warnings from the experienced economist, especially her opinion that economies are going to be severely disrupted because of erosion of jobs and that social unrest and terrorism will increase as a result of continuing global economic woes and demographics in both developing and developed economies.

What is worse is that the pumping in of money after the financial crisis a few years ago- the euphemistically named quantitative easing- has created a predictably bizarre situation: stockmakerts are doing relatively well even as industry is doing pretty badly. Meanwhile, the economy is going nowhere, demand has collapsed (see what is happening with commodities) and interest rates are close to zero in much of the developed world. 

Something has to give, and there will be panic when it does.

Shipping has its own particular woes, the biggest one being overcapacity. It has another problem not often spoken about openly- less than competent leadership. It is amazing, for example, that industry leaders in the container business- undoubtedly hit the hardest today- could not read the writing on the wall two years ago when they were ordering megaships like there was no tomorrow. Unsurprisingly, Maersk has reported terrible quarterly results, with profits down an unbelievable 61 percent and revenue down fifteen. Analysts are warning that container ship lay-ups, which have already reached their highest levels in five years, will accelerate and may even reach the high levels of 2009, if you ask me. There are years to go before the excess capacity in this segment will be absorbed. 

The dry sector is hardly doing better, with the Baltic Dry Index down to its lowest levels ever. It has collapsed a staggering 95 percent from its all-time high of 11,793 (in 2008) to, believe it or not, sub 500 levels. The drying up of Chinese demand for iron ore and coal that was predictable five years ago was ignored. In any case, I fear that the commodity meltdown is far from over, and prices and movements may stagnate for years. 

The two big reasons shipping is not completely on its knees today is because a) bunker rates are at record laws and b) large crude oil tankers have done pretty well this year. 

There is a question mark over these tankers continuing to do well, though. Speculators and traders bought oil when prices were falling, but the tankers that were used- essentially floating storage- are already piling up in places like Singapore and  the US Gulf. Because, you see, there are few buyers for the oil. The mini-boom in the crude tanker segment may have given a welcome breather to shipowners, but it may not last indefinitely if speculators do not see quick profits.   
Shipping is, then, today an industry that does not have anything much to cheer about. For my money, it is going to stay that way through the next year or two, at least. I am afraid that we are going to see more blood on the street for a while. 


November 28, 2015

Giving the sea-dog a bad name

I promise not to repost old posts again- at least not soon!- but this is a 2012 one I was forced to recall today.

The notion that a ship's Captain is similar in quality or character to a shore based CEO or senior manager is hogwash that has been promoted by the STCW 'management level' certificate claptrap for far too long. Perhaps this way of defining responsibilities at sea may find some takers among sailors who have a complex about their jobs being inferior to those ashore, but as far as I am concerned, this narrow profiling actually devalues what they do. Because I believe that a Master's job is tougher than a CEO's. In fact, the nuances in leadership, strategic or tactical thinking, physical action and mental agility required of a ship Captain- or, indeed, of any rank of officer or crew at sea- are unique. The 'management' or 'operational' level labels are plainly inaccurate. This is not an office, where a manager does no manual work. This is a ship, whose senior most officers often live in boiler suits these days. 

A CEO ashore is probably responsible for larger amounts of money, but no CEO lives, works and eats with his workforce. No CEO faces the same living conditions as the shop floor worker. No CEO suffers acute fatigue and loss of sleep for prolonged periods while making major decisions that affect directly the physical safety of everybody around, including himself. No CEO picks up a screwdriver at work one minute and handles a multimillion-dollar floating behemoth the next. No CEO makes huge decisions all on his own. No CEO is required to be- within any 24 hour period- alternately a clerk, an operator of machinery or equipment, a HR man, a security in charge, a factory manager, a data entry operator, a communications officer, a cashier, an accountant, a payroll controller, a policeman and an environmental mini-specialist. No CEO is required to work while spending months away from his family at a stretch. No CEO will be arrested for even a major disaster- leave alone a minor accident- in most parts of the world: Bhopal, for example. Hell, a CEO does not even stand on his feet too much or too often; he travels, works and lives in a soothing atmosphere with minions to take care of everything, including his cup of coffee. A  Shipmaster, on the other hand, works in a hostile environment- physical and mental both- that is magnified manifold by most of the people he encounters that are not part of his crew- the antagonistic enemies at the gate. 

When a CEO makes a huge mistake, the company goes bankrupt and everybody loses their jobs; when a Captain makes a huge mistake, everybody dies and everything around is polluted forever.

You may choose what you consider to be the more important job here; my only point is that any sailor's job cannot be compared with any job ashore- and promoting that thinking does every seaman an injustice, is inaccurate and pushes the wrong idea- to prospective and existing seafarers both- of what a mariner's working life is all about.

Actually, I cannot think of any job that compares with a sailor's. A soldier's?  Some similarities do exist here- away from family in a hostile environment, for example, but there are massive differences too. A sailor will not be called upon to face bullets as part of his job description, piracy notwithstanding. A solider's life is simpler than a mariners- no commercial, environmental or such considerations and no job insecurity. On the other hand, although a Bosun's job is more complex than a platoon leader's, the latter is responsible much more for the lives of all his men in combat, and the cost of a mistake- or circumstance- is much higher. In a similar vein, a General is far away from the action, usually, unlike a Shipmaster, but he is responsible for hundreds or thousands of lives and his country's security- a huge responsibility. So, no real parallel exists here either. 

I suggest that we should not even try to find a parallel. Instead, we need to realise that a mariner's job description and responsibilities are unique and leave it at that. A formal job description is required only when there is ambiguity or confusion about role, and shipping has never suffered from that problem. Just say Chief Engineer, and every sailor on earth will know what that man does, his responsibility and his authority. This is true for all other ranks, and on any ship on earth.  We don't need organisation charts at sea; we know clearly what everybody is responsible for.

Unfortunately, what has happened is that shipping has fallen into the management jargon trap where style substitutes for substance- or too often replaces substance. The result is not pretty and is there for all to see. Crews are today groaning under the weight of manuals and checklists that have dubious value but enormous repercussions thanks to stress and fatigue that are a direct result of this nonsense. I see the 'management level' certification and the 'CEO' pretentious blah as an extension of this thinking. 

It may seem like a small thing, the wording on a certificate of competency, but it does matter, and I object strongly to it. Not least because I am a Shipmaster by qualification and profession, not a mere CEO.


November 21, 2015

The woods and the trees, redux (first published in December 2007)

In a few days time, this column (or this blog, depending on where you read it) will be eight years old.
The following (long winded and, today, slightly embarrassing) piece was the first one published- in a magazine and on this blog- in December 2007. You be the judge of how much has changed, and how much has worsened.

Over the last few years, the voices bemoaning the manpower shortage, or, to put it more accurately, the shortage of appropriately competent seafarers, have become more strident. Perhaps the writing on the wall is getting larger. As a sailing Master, I have been bemused and dismayed by much of all this. To me, all of us, afloat or ashore, continue to refuse to see the woods for the trees.

So, if I may be permitted to generalise for a moment or two, this is what I see from the bridge of a ship:

Manning agents both love and curse the shortage with equal gusto; on one hand, demand for body shopping is high, on the other hand, they can’t find enough bodies to shop. Their buck stops at putting a body on board for the desired period, and hoping that the body is minimally competent enough, and that their principals stay happy with them.
Or, in any event, happy enough not to take their business elsewhere.

Shipowners, insurers and other commercial and cargo interests see the balance sheet. Are we covered against the mess which may be created by increasingly professionally dubious guys coming out to sea? What is the worst case scenario? Is the ship moving? Are there cargo claims? What is it costing us? Can we put the ‘top four’ of a higher competency and run the ship with other less competent guys? Are we insured against this?
At the end of the day, their buck stops at bean counting.

Management companies and Superintendents see their own profit and loss statements, leading to sometimes amusing comments. One Master is “good but gives away too much overtime, or too many ‘presents’ to shore guys”, a Chief Engineer spends too much on spares (regardless of the problems he may have faced, or the preventive maintenance he has done on machinery); another Master actually has the temerity to put the Owner’s interests on par with that of the Mangement company; A Superintendent sees his budget and possibly his bonus as shot, and does not see (or can’t explain expenses to the Owners, because they are looking short term, too) the long term benefits of actions taken on board.

Seminars are held to create a sense of community (read loyalty); seafarers are asked to attend, by the less reputable Companies, at their own cost; speeches are made indicating that professionalism is low, hands are wrung- how do we attract , not the best, but even the mediocre, to the industry? How do we retain them? Stories are swapped and filed away to be used in future seminars.

Figures are churned out as to the shortage in the next five years, ten years, fifteen years. More hand wringing. More missing the woods for the trees.

Training is conducted if it cannot be mandated as a prerequisite to Certificates of Competency. Seafarers are expected to attend without compensation. In fact, till recently they were sometimes required to attend seminars and training at their own cost of travel and sometimes even lodging. The training is often mediocre or poor, though Owners are probably charged hefty amounts for ‘training’ their crews.

(This system of seminars and training must be indeed unique in any industry, worldwide. Training and seminars without salary, and sometimes training and seminars which leave a seafarer out of pocket, too, though not the other participants. )

The appropriate noises are made about safety, pollution and other such buzzwords. My understanding of what is meant, after about 30 years at sea, is this… Follow the rules, spend minimum money, don’t get caught, and if caught, or if there is an incident involving safety or pollution, don’t point fingers.

And, by the way, we are behind you.

Sure. (Not sure, though, whether these folk are supporting me from behind, or are hiding there)

Statistics are compiled. Studies are done, mostly outside India. Surveys are sometimes announced. Seafarers opinions are rarely sought, and then not too seriously.

Similar conclusions are reached; the seafarer faces problems, unnatural life, away from family, controlled communication and contact with family, criminalisation, paperwork, over-regulation, shortmanning, short port stays, ISPS and shore leave… all of us know this list.

Manuals are compiled with alacrity. Sometimes so quickly that the name of the previous Company, or another ship, is not even deleted from some pages before printing. These manuals, in impeccable English, are supposed to be understood and signed by crews who sometimes have no knowledge of basic English, and who read and sign six manuals in ten minutes.

After so many years in command, I am still confused whether the purpose of the manuals is to pre-empt incidents, help the Master after an incident, or help many worldwide to cover themselves in the event of fallout after an untoward incident.
(Our ISM is in place, therefore the butler, oops Master, did it. )

And, of course, clerical work which belongs to the office is passed on to the ship; it is cheapest this way. Never mind that the ship is touching ten ports in as many days in and around the English Channel and North Sea in winter fog, and never mind if there is pressure to do paperwork on the bridge instead of keeping a proper lookout. Ashore we would have to employ a whole department to deal with this, on board it is free!
Send more forms, and the forms will set you free.

And all of the above is done with the almost complete absence of seafarer input.

Nobody asks a sailor his opinion. Not Governments, not the IMO, not the management ashore. Officers are able to propose changes to manuals, checklists and the like, yes, but they are not expected to provide much input in formulating them. Unsurprisingly then, absurd stories with paperwork abound.

It is almost as if the sailing seafarer has no voice, or has signed away his right to an opinion when he signed his contract.

As an industry, all of us have so far failed to address basic Human Resource issues, besides more pay, shorter contracts, and some other minor sops. The needs of the seafarer have not changed all that much; a safe ship, market wages, decent food, short tenures away from the family… these priorities have remained static for a few decades.
Although for senior officers, changed priorities have been quality of crew and, in view of the increasing criminalisation, the run and quality of management. When the stuff hits the fan, these matter to a Master at sea.

We have also failed to manage the contradictory pulls of contractual employment on one hand and a long term commitment desired by the industry on the other. Relationships within the industry are only based on money, including those between an employer and a seafarer. Both are responsible for this.

Seafarers of my generation came to sea for reasons which don’t exist today. Travelling the world loses its charm when you can’t go ashore and port stays are counted in hours and not days. Salaries lose their charm when shore salaries are comparable, even better if you are suitably qualified. Life on board has deteroriated, accomodations are smaller, food is more basic, entertainment options are more limited, communication is better but restricted or expensive, and a drink may be close to a criminal activity. It is small wonder, then, that many of today’s youngsters want to quit sailing at the first opportunity, and never see it as a career.

I do blame them, however, for wantonly and easily accepting lower professional standards. That is a problem in itself; we have too many people sailing today who are not competent by even a large stretch of the imagination. Every Master, Chief Engineer and Superintendent can fill volumes with incidents which display professional mediocrity at sea, or worse.

The problem is that each stakeholder in shipping does not look beyond his or her immediate benefit. As long as the solution was cheaper crews, this worked, albeit imperfectly; but now it now appears that we may be running out of cheaper officers, at least in the numbers required. New measures are called for-the old ones have obviously not worked.

In conclusion, just some of these suggestions would go a long way in breaking this deadlock:

A career path, including stepping ashore at a later date, for officers. To do this, evaluations systems would have to be improved, internal communication in the organisation shored up. But, subject to performance, a future career path should be clear to an entrant.

Better HRD practices. Present HRD, such as it is, stops at recruitment. HRD has to go beyond that; equally, it has to demonstrate it. The us vs them (shore vs sailing) paradigm has to be shifted. Make HRD an integral part of the Company, and not just restricted to hiring, firing and ticketing issues. A contractual system does not have to mean it should be an adversarial one. Promote a sense of belonging.

Reduction in overregulation within the business. A comprehensive review of paperwork with an intent to cut it down. Promote a system which does not seek a manual as a solution to a problem.

Senior Officers mentoring juniors at sea. This practice has fallen by the wayside because of other pressures. Pressures cannot be reduced, but paper certainly can. Cadets were always cheap labour, now they are just cheap labour, sometimes cheap clerks. We don’t train them at sea, and then we complain they are not trained properly.

Addressing poor motivation issues of many seagoing staff. Reasons include lack of professionalism, inability to recognise how a well-run system will make their own lives safer and sometimes plain cussedness. Another reason is inertia on the part of older, senior officers, some of whom apparently see no reason to change with the times. 

Changing the incentive system. Companies give incentives according to time served or number of contracts completed or on rejoining. Few give incentives based on performance. This does not work; seniority does not necessarily mean superiority in your job.

Include serving seafarers in formulation of policy and documentation issues. Perhaps this should start with the IMO, and not be restricted to developed countries or government nominees, but include a cross section of sailors from the public and private sector.

And finally, let us all, ashore and afloat, refuse to accept lower professional standards at sea. We are shooting ourselves in the foot by doing so.

The industry is chugging along in the absence of a concerted effort by all the stakeholders in it. The results are there for all to see. Unless we determine to change this; unless we can look at the horizon instead of the dirt just in front of our shoes, we might as well close shop and go home.


November 19, 2015

The ISM charade

We in shipping love the International Safety Management Code; we like to think of it as the mother of all codes that could well have come down from Hammurabi himself. We pretend this Code is an all-encompassing solution that makes ships and crews safer. Unfortunately for us, this pretence does not wash. In reality, the ISM Code- like so many of our Codes and regulations- is hardly worth the paper it is written on. It has repeatedly failed in theory and in practice. Worse, instead of becoming the instrument to find and fix loopholes in safety as it was meant to be, it has become a convenient instrument to fix the blame on the ship, to crucify Masters and crews and to allow shipowners and managers to escape moral, financial and legal liability. Most of the regulatory and commercial entities in the world of shipping are complicit in this charade.

The same charade is playing itself out in the Costa Concordia disaster. The much vilified Capt Francesco Schettino has raised some important issues recently, and that some sensible voices are agreeing with some of what the devil incarnate is saying. Schettino says he takes responsibility for the Costa Concordia sinking, by the way, but has also said, in an interview with Lloyds List, that his officers were not trained properly, there were major language difficulties- including with the Indonesian crewmember steering on that fateful night who may have put the helm over the wrong way- that the officers used the ecdis (Was it really fit to be used as an ecdis- were the right types of charts installed? There are, amazingly, questions about that too) like a ‘video game’ without being properly trained on it, and that he had not taken over command of the vessel when he went up to the bridge for the ‘salute’ on the night that we all know about.  Equally surprising is Schettino’s claim that “that neither the defence nor the prosecution had put up experts in maritime technology, ship construction, bridge manning and navigation” on the stand.  If true, that looks suspiciously like a conspiracy.

Basic questions, these. Basic problems that the ISM Code was supposed to have fixed twenty-seven years ago. Basic problems, each of which most Masters sailing on ships today face on a daily basis. I have used the ‘video game’ analogy myself for years, including with the use of radar, an even more basic piece of equipment than the ECDIS that many officers are still unable to operate properly or correctly. (Remember that it is the manager’s responsibility to put equipment-trained crews on ships. But that is on paper. The practice is a joke.)

The crew of the Concordia have struck plea bargains and escaped. The owners and managers have escaped too.  Schettino has been awarded 16 years in jail, a sentence he is appealing. Business as usual. The charade has played out as usual, never mind that others should have been keeping him company in prison.  

The immediate reason for the capsizing of the Herald of Free Enterprise- which spawned the ISM business- was that the bow door of that ill-fated ferry had been left open because a fatigued crewmember directly responsible for closing the door was asleep. Justice Sheen’s enquiry went further, though, and said that shore management was just as blameworthy, and a culture of ‘sloppiness’ was evident from top to bottom. Sound familiar?  If the ISM Code was supposed to address these issues, then- twenty seven years later- it has spectacularly failed. 

The ISM manuals are a joke on ships. Often a copy and paste job, they are codified in a language- usually English- that many crews cannot even read properly, leave alone comprehend or understand  nuances. In any case, the regulations underpinning the heavy, impressive looking manuals that are placed on board are formulated by people who would probably struggle to keep a paper boat afloat in a bathtub. Class rubber stamps the documents without much enquiry. And, in the end, the ISM procedures that look good on paper are often useless in shipboard emergencies.  Small wonder then that it fails again and again. Its only value seems to be in placing the entire blame for every accident on the ships Master, officers or crew. That appears to be the ISM Code’s sole purpose.

The solution to this? There is none, I am afraid, because there are basic questions about the integrity of the powerful players in the game. The ISM Code works for them, you see. So, unless we can solve the integrity issue, I am afraid the charade will continue. Shipping will continue to behave like a skeleton with a sword in its hand fighting shadows in the twilight.