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World of procedures, which aren't expected to be complied at all times, but could be used as a whip to get lashed or blamed

· Safety Culture,System,Compliance

Travelled from Hong Kong to Dubai and to Cochin in the last week of April after almost 16 months on the ground. It was indeed good to fly after a long while. Change of place and scenery is also good for reflections.   Made lots of observations on this journey and realized that we live in the world of procedures. There are procedures for everything. In regulatory compliance, auditors ask us for procedures, so that they can audit compliance with our procedures, issue non-conformity or observations for continual improvement, whereby procedures get reviewed, amended and added for enhancing the system. Sounds, cool. Indeed, it just sounds cool, but reality? 

  Are all procedures developed with the user and compliance in mind? Are we expected to comply with them 100%, or as best as possible to our own compliance criteria, which will vary from 0~100%, subject to everyone’s perception, belief, acceptance of the procedures? When we look at some procedures, it appears that they aren't developed with focus on practicality or extent of compliance, though they sound good or look good. No questions are asked if intended outcome from procedures is achieved or something doesn't go wrong terribly. 

  In Hong Kong, extremely stringent social distancing, and safe procedures for preventing the spread of Covid-19 are practiced, by both the people and authorities working in tandem. However, during boarding the flight from Hong Kong, social distancing wasn't required. The flight was full and the seating row of 3+4+3 on the airbus was fully occupied. Let's be considerate and happy that every passenger had to undergo RT-PCR test within 72 hours of departure and airline required every passenger to wear mask during the entire flight except for enjoying the drinks and meal service. The degree of compliance varied among the individual passengers with some of them donning PPE gear as if they were working in a Covid ward of a hospital, though they felt safe to remove their face shield and masks to enjoy the drinks and meal service. 

  Footprints were marked on the floor in the airport at Dubai for social distancing, but no one enforced compliance, nor did anyone seem to follow. I understood that it was good to mark the footprints 2 ft apart in lifts and floor in public areas, though we all know that it isn't always practical for people to follow in a busy airport, unless authorities are enforcing it strictly by giving warnings and notice to passengers to comply. Besides, the marked footprints on the floor and notices to sing a Dubai song to fight Covid (cheering up people is always good), it was travel as usual like 2019 and duty free shops were busy, though not crowded like 2019. Temperature checks were not mandatory in all the shops, but restaurants had tables laid out with social distancing in mind. In Hong Kong, duty free shops were shuttered and were empty inside, as the airport is very much under-utilized these days, with travel restrictions to Hong Kong.  On the onward flight to Cochin, airline provided face shields to every passenger and a PPE suit to those passengers, sandwiched in the middle seat. This wasn't the case in Hong Kong with the same airline where Hong Kong~Bangkok~Dubai may have been perceived by them to be very safe without any risk in flight, while their risk assessment and mitigation measures for Dubai~Cochin resulted in some freebies at boarding gate. 

  Earlier in 2020, we used to hear that flights were going with 30~50% passenger capacity for social distancing. However, how could airlines sustain flying with such limitations or restrictions and especially when the aircraft had to come into Hong Kong empty and return empty from India? To be fair, we looked for economic flights to get most value for the money and were not willing to pay for couple of empty seats around us for social distancing on flight. 

  Kept on thinking about the ever-increasing procedures and was wondering whether the procedures are developed as they sound/look good, even though the developers of the procedure may not be able to comply even 10% of it by themselves. Are the procedures developed for one more purpose? When things go wrong, they can be used as a whip to lash people or apportion blame for non-compliance.   Think about the shipping accidents. Container ships speeding in adverse weather to arrive on published schedules, while the Masters are expected to navigate safely at reduced speed and Chief Engineers are expected to not to overload the engine in rough weather. Are Masters and Chief Engineers expected to comply with safe procedures and reduce speed, or sail through the adverse weather and arrive on schedule? What happens when Containers go overboard or the container stacks collapse? Won't the procedures be used against the Master and Chief Engineer that they didn't comply with safe procedures for navigation?

Look at the "Ever Given" which blocked the Suez canal for 6 days from 23~29 March 2021, which is still held in Egypt until the owners pay up SCA 's claim, US$916 million. We still haven't heard from the Suez Canal Authority or the Flag State Administration of the vessel, Panama on the investigation results. We know the writng on the wall. Settle the claim and move on.

There are lots of procedures which can be used for issuing non -compliance. The most significant one which comes to my mind is the excessive speed - 13.5 kts at the time of the Ever Given incident and neither the 2 Pilots nor the Master on Ever Given complied with the much reduced SCA's speed limit (a procedure, which is  described as not practical to comply with by many  Masters. Is the 7~8 kts speed limit only for giving non-compliance?).  I see speed limit 30 kms on road in many places while driving and think about SCA's speed limit for Suez canal transit, where ships are rushed through to clear the canal and maximise transits and revenues.

Thanks to the advancement of ship building design and technology, we are seeing orders for 22,000~24,000 TEU Container vessels. While it's good that the scale of economy is achieved by these mammoth container vessels, and we are benefited by reduced freight costs for the goods we buy, which arrive us by surface transportation. Won't these 20,000~24,000 TEU ships use continue to transit Suez Canal? Of course, they will. 

What do we learn from Ever Given? We have to be patient and we  shouldn’t jump into conclusions until the ship clears Egypt to hear from the stakeholders. Aren't the 20,000 TEU ships passing through the canal now and sailing past the Ever Given, detained and anchored at Great Bitter Lake? 

Interesting world of procedures and feel lucky to have sailed from 1976~1996 with hardly any procedures and managed ships from 1996~2020 with as minimal procedures as possible. Feel happy to have resisted every cry to issue more and more procedures, just because they looked "good to have", but "not practical for compliance". Believed in empowering people to do the right thing and focus on what matters. 

Don't we all need less procedures and focus on doing what matters?.