ISO 9001:2008 and its Relation to Subchapter M

Introduction, Show Overview, and Guest Background

Captain Aaron Williams: (00:00–00:59) Welcome to Regulatory Excursions, the podcast that delves into the lesser-discussed corners of Subchapter M regulations. In each article, we sit down with subject matter experts and industry thought leaders to discuss topics incorporated by reference that the U.S. Coast Guard, TPOs, or industry groups rarely discuss. Think of this blog as your sub-niche insider's guide to towing vessel compliance.

If there's a specific topic you'd like us to tackle in a future episode, or if you have any comments to share, visit bollardmarineconsulting.com/contact. We'd love to hear from you.

Captain Aaron Williams: (0:59–01:19) This article will cover ISO 9001 and its relation to Subchapter M. Our guest is Julius Da Silva from QMII. This guy is a phenom, and I'm glad I had the opportunity to interview him. First, let’s introduce Julius’ company.

About QMII

Captain Aaron Williams: (01:19–02:26) With over 38 years of industry leadership, QMII is the trusted partner for numerous organizations, guiding them through the complexities of management system consulting, auditing, and training. Its seasoned experts are dedicated to empowering your team, ensuring you meet and exceed your objectives. QMII’s notable projects include developing the Mission Management System for the U.S. Coast Guard, developing a QMS for the Eastern Federal Highways, implementing a QMS for international flag administrations, and developing safety management systems for U.S. Flag Vessel Operators.

QMII clients have all achieved first-time certification following the implementation of the system. QMII is a U.S. Coast Guard-recognized TPO, an associate member of the Passenger Vessel Association, a USC TAG 176 Committee member, which supports the development of the ISO 9001 standard, and a recognized training provider.

Captain Aaron Williams: (02:26–02:32) Julius Da Silva, thank you so much for letting me interview you. I appreciate it.

Julius DeSilva: (02:32–02:36) Aaron, it’s good to be here with you. Thank you for the opportunity.

Captain Aaron Williams: (02:36–02:58) Julius, you're not just an interview guest; you're near and dear to my heart because you're my ISO 9001 Lead Auditor teacher. I had a great time with all of you at QMII in Ashburn, Virginia, when I participated in the ISO 9001 Lead Auditor certification training.

Julius DeSilva: (02:58–03:23) Aaron, it was good to have you in the class. We run a number of those courses, and we're able to connect the standard for folks in the maritime industry back between 9001 and TSMS requirements, as well as the ISM Code, and I guess that's what we're here to talk about today.

Captain Aaron Williams: (03:23–03:46) In your own words, give us some background on your career because you have very deep ties to not only ISO 9001 but also the maritime industry. You have saltwater running through your veins, as they say.

Julius's Background

Julius DeSilva: (03:46–08:41) Prior to my time with QMII, I was in the maritime industry, and my love for the sea started around sixth grade. I always knew I wanted to be in the Navy, where I landed. I sailed with commercial merchant companies for about 15-plus years and went through all the ranks, finally leaving as a master mariner and unlimited license holder. In those 15 years, I sailed with a number of different companies, some ownership companies and some management companies, primarily on tankers, working my way through product tankers. Then, most of my sea time was on very large crude carriers, and I had seen the ISM Code and safety management systems right from its inception when I joined. We were in the ISM Code phasing-in, with the first deadline being 1998 for the first group of ships, tankers, and passenger vessels coming into effect.

I've seen the ISM Code evolve, and with that, I’ve seen good safety management systems, bad safety management systems, good cooperation from top management, and a lack of it, and how that impacts systems. So, I spent about 15 years there. My first introduction to the ISO standards was way back in 2001-2002, while I was still sailing. I remember going through my first course there. It must have been about four or five ships into my career when my love for process-based systems really took hold, and that was a result of a good captain I was sailing with at the time, who was truly able to explain to me why we do what we do, why we use a safety management system, and how it benefits us.

Following my career in the maritime industry, my personal life brought me here to the United States, and I have been working with QMII since 2013. In my capacity at QMIII, where I'm currently the CEO, I have worked with numerous stakeholders within the maritime industry, including flag state authorities, both here in the United States, the U.S. Coast Guard being one entity of the United States flag, as well as with international flag states across the globe, helping them implement their quality management systems by which they provide oversight of vessels that are registered and flagged with them. I've also worked with numerous maritime training institutes implementing quality management systems or quality standard systems, QSS, for these training institutes so they can align with the requirements of the STCW code, as well as requirements of the flag state, as it may be for these particular institutes.

I've also worked with maritime companies in my capacity here at QMII to implement safety management systems at various levels. Also, we support safety management systems, from documenting them from scratch to reviewing them and assisting customers to pare them down to make them more efficient. We also audit safety management systems, both onboard ships and then also ashore. Outside of safety management, we have also assisted our clients in other capacities, whether they are working to meet cybersecurity requirements and implement environmental management systems or quality management systems. Also, from a security standpoint, we have helped small port facilities meet the port facility security requirements, from doing security assessments on board ships and offshore platforms to training.

Aaron, you were part of one training, but we train students to audit the ISM and ISPS Code as DPAs in crisis management, ISO 9001, and many other standards. Apart from that, I've done an MBA from the University of Virginia, Darden School of Business. I am an Associated Fellow with the Nautical Institute, based out of England, and that's kind of me in a nutshell, so to speak.

Origins of ISO 9001 and Connection to Subchapter M

Captain Aaron Williams: (08:41–09:11) I wanted to have you on the show because Subchapter M is based on ISO 9001. I want to explore with you how that even came to be. So, how did 9001 become the standard that the U.S. Coast Guard utilizes for Subchapter M? There are so many ISO standards, so why 9001?

Julius DeSilva: (09:11–11:37) That is a great question, Aaron. And we can start way back in time when management systems and quality management systems find their genesis, so to speak. And if you go way back in time, you'll find that many of them started with the MIL standards developed by the US military. The US Army and other DoD agencies use the MIL standards for quality. And these were used and slowly improved and perfected over time. With a lot of focus initially on documentation, even in the first version of 9001, there was a “document what you do, do what you document” thought process with that focus on documentation.

Some MIL standards have been phased out now, but that's really where it started. It then evolved with the development of the US Navy nuclear program. So, when the US Navy was developing its nuclear program and trying to fit these mini reactors on submarines with the first nuclear submarines, Admiral Rickover was tasked with leading that program.

As part of that program, the admiral came up with what is known as Rickover’s Principles. These principles really enabled the United States Navy to build these reactors and operate its submarines and ships without any nuclear disasters, so to speak, because the quality controls that were put in place were so strict. The U.S. Navy has lost a few nuclear submarines, but not anything that can be connected back to a nuclear disaster, at least to my knowledge.

Over the years, these MIL standards, the nuclear quality assurance standard, evolved, and other allied industries developed their own standards. So, from there, Great Britain was the first country, so to speak, to come up with a national standard for manufacturing. And that was the British standard 5750.

Evolution of Quality Management Systems

Julius DeSilva: (11:37–16:24) The initial focus of 5750 was purely on manufacturing. This development created the British Standards Institute, BSI, which came about when the globalization of the economies started. And as the globalization of economies was starting, you were getting foreign countries delivering goods and services to the United Kingdom. To ensure that the nation received products that met requirements following quality standards that they could accept, the British standard 5750 was created.

It eventually evolved to include services apart from just manufactured products. The first version of ISO 9001 was published in 1987 when it evolved into services. When it was published in its first version in 1987, ISO 9001 was published as three different standards: 9001, 9002, and 9003. While 9001 loosely aligned with the current 9001 standard, focusing on production, including design, 9002 focused on production activities excluding design. This left 9003 for warehouses, where no manufacturing was being done. Still, the warehouses needed some inspection standards to know what they received was of a quality standard.

Along the way, as these standards were being developed, the maritime industry also developed other efforts. So, the ISM Code was not the first initiative by the maritime industry. A number of maritime accidents occurred, and therefore, several maritime initiatives were being developed along the way.

Some of these initiatives were developed with the International Chamber of Shipping and the International Shipping Federation. In 1982, the ICS published the Code of Good Management Practice in Safe Ship Operations. There was also an organization now known as InterManager. At the time, it was known as the International Ship Managers Association or ISMA. So, ISMA developed a code of ship management standards. This was in 1991. At that time, Det Norske Veritas (DNV) also had its standard called the Safety Environment and Pollution Code, or SEP code.

The ISMA Code, which eventually evolved into the ISM Code per se, was built using the requirements from 9002. So, the ISMA Code is the basis for these other standards. And as we look at the ISMA Code, you'll find it was based on the 9002 model.

These models are based on what is known as process-based management systems. They're known as process-based management systems because there's something called the “Plan-Do-Check-Act-Cycle,” where you put a plan together, put the plan into action, and check how it is going. Then, at the “act stage,” you will take action to update and revise this plan. And along the way, they required some risk management, so to speak. So, every good process-based management system requires some appreciation of what the risks are and how we are going to control these risks.

Of course, the ISMA standard also included several other things the ISM Code does not consider. It included a drug policy, personnel training, which is part of the ISM Code, and claims handling. Similarly, the DNV SCP included a media response policy, engineering management, etc. You can now see how 9002 became the starting point for the ISM Code and how I got involved in it.

Captain Aaron Williams: (16:24–17:28) This is perfect, Julius. I wanted to say that the way you explained it, you can see how conditions were shaping up to pave the way for the ISM Code and ISO 9001. The way you explained it makes perfect sense. Although I attempted to research independently, I couldn’t find anything in this regard, so thank you! This is fascinating. I appreciate you sharing all of that with us. And, of course, I wanted you to talk about process-based management systems, but you got into that.

So, can you expand the process-based management concept and relate it directly to towing safety management systems?

Julius DeSilva: (17:28–20:48) Yes, absolutely. So, what is a process-based management system? It's fundamentally a structured approach to managing the organization to allow the organization to achieve its outcomes. In the case of the towing safety management system, or the case of the ISM Code, it would be the functional requirements of the ISM Code and the primary objectives of what the towing safety management system or safety management system intends to achieve. So, it's a structured approach to allow an organization to achieve those objectives, focusing on continual improvement. That means we won't get it 100% right the first time. But we have methodologies and systems in place so that when things go wrong, we can take action to improve. So, going forward, we get better with each iteration and cycle.

Continual improvement is part of the basis and intent of the ISM Code. And we'll come to TSMS, but the intent of the ISM Code was never to have increased oversight and compliance. The ISM Code is developed for implementation by different types and sizes of vessels, companies, and such operating anywhere in the world, keeping in mind that it can be voluntarily applied as well, based on clause 1.3 of the code.

The basis is that there are not many prescriptive requirements. However, as we get into the TSMS requirements and Subchapter M, because it's focused on a very specific part of the maritime industry, you can set more prescriptive requirements for the industry, just like 9001 has its industry-specific versions. So, you have an aerospace industry-specific version of 9001, for example, which is based on 9001.

Then, you have more critical, specific requirements for the aerospace, automotive, and medical device industries, all of which are built on 9001. Because they're so focused on a particular industry, we can get more prescriptive in the requirements for that particular industry. However, each of these process-based management systems requires some policy to be set based on which policy objectives must be met.

There must be clearly outlined roles and responsibilities, processes defined, and training provided to people so that they're aware of their responsibilities and roles within the organization. You have some mechanics to check how the system works, whether it be quality control steps, audits, or anything else. You have risk management, and then you have a management review at the end of the cycle.

Zero Nonconformities Article Discussion

Captain Aaron Williams: (20:48–24:04) All right, Julius. Thank you for all that history and explanation. That was phenomenal. Allow me to jump over to another topic now. Recently, you authored an article on LinkedIn titled “Should We Celebrate Zero Nonconformities?”—I found this article fascinating. I enjoyed every part of the 9001 class where you discussed zero nonconformities.

I just want to discuss that article, which everybody should read. The sections include:

• Should We Celebrate Zero Non-Conformities?

• Does Zero Non-Conformities Mean the System Is Perfect?

• Are Non-Conformities Being Hidden?

• Do Zero Non-Conformities Create a False Sense of Confidence?

• Can Key Issues Go Unaddressed?

• Are Audits a Test That Can Be Passed or Failed?

That article was enthralling. Do you have anything to say about zero nonconformities in safety management systems, maybe Subchapter M in particular?

Julius DeSilva: (22:02–24:04) Thanks, Aaron. You know, this is a topic close to my heart. Incidentally, we recently had someone from the maritime industry doing an internship with us. As part of the internship, they shadowed us when we audited commercial organizations, manufacturing facilities, and others, such as petrochemical plants that we audit. What was surprising for this intern was how open personnel are in these organizations to receiving nonconformities, where there is no pushback from the auditor on why a nonconformity was received.

What was also surprising was how folks were open to reporting nonconformities and near misses when things go wrong. In my own experience, it depends on the type of management commitment from shoreside, which is very critical in the success of your management system, as well as the biases and perceptions of your previous experience for those on board vessels, right? In some cases, writing a nonconformity may be equivalent to -incriminating yourself. And so often, folks don't want to report nonconformities. Further, there may be financial implications to identifying nonconformities, such as potentially losing a charter and your boat not getting hired because you have open nonconformities as part of an audit or a U.S. Coast Guard inspection. And I think it's good to differentiate between audits and inspections, where you know, in audits, we're sampling the system—we're sampling not only conformity but also the system's effectiveness.

Audits vs. Inspections

Julius DeSilva: (24:04–27:43) The audit aims to identify where the system is working well and where it can improve. The purpose of an inspection is that they don't look at the entire process; they look at the output of a process. And in looking at the output process as an inspector, it's your duty to find where the nonconformities and deficiencies lie because you're the final gatekeeper. If you don't catch it, it's gone out the door. Sometimes, newer auditors may be unable to distinguish this point if they come primarily from an inspection background, which I suffered from myself. It took me a while to switch my thinking hat.

But if you come primarily from an inspection background, when you jump into an audit, how do you put on that auditor hat and change to an auditor’s mindset of looking for conformity rather than seeking nonconformity? That leads folks who have had bad experiences to not want to report nonconformities. But often, there's a tendency to prepare for audits when you should not prepare for audits.

Your safety management system should always work as intended. If something is ineffective, there should be a mechanism for you to report it up the chain and say, "Hey, you know, we can't keep up with this." But does the culture allow people to go ahead and report and say, "We can't keep up with this?" Not many companies are out there that may allow that sort of thing to happen.

It's always like, “Captain, you’ve got to manage somehow, you know, do your very best—you know, do what you can.” The captains are always trying to do what they can with limited resources. Therefore, as a result, if you start preparing for audits, there is a tendency to cover up your defects or non-conformities.

But if audits only happen once a year, then you may initially fix those defects at that point in time the audit is occurring. But every other time that it occurs, it may never get reported. By preparing for audits and covering up defects and nonconformities, filling out your paperwork at the last minute—dotting your I's and crossing your T's—you get a good audit report.

This may drive a culture where people are used to hiding their nonconformities. And if you can do it for an audit, why can't you do it at other times? So does the company culture promote and say, “OK, we're doing an audit. Let's just get a fair picture of where we stand. If we get nonconformities, we get nonconformities. We address them and move forward.”

Leadership must question, based on other inputs they're getting, like results from external audits, results and feedback from vessel superintendent visits, U.S. Coast Guard inspectors or other authorities, and maybe even customer audits, whether they are getting an accurate picture. Why are we suddenly getting so many nonconformities during a U.S. Coast Guard inspection or, you know, so many nonconformities during a supplier audit? But outside of that, it seems like a nice, rosy picture. Everything is going smoothly on the vessel. You get the captain's review of the SMS, and they say, hey, everything's great over here.

But is that reflective of the system and what leadership should be asking? Sometimes, it may be so that there are no nonconformities, and your system is a cause for celebration. But in other cases, it may be a cause for concern if those are indeed being hidden.

Detecting the Effectiveness of Safety Management Systems

Captain Aaron Williams: (27:43–29:20) Let’s discuss that final part where you mention scenarios where the safety management system is operating effectively. Let’s compare that to a scenario where individuals hide or conceal information on the vessel level. If there's anybody in management listening and asking themselves, “How could you detect or be able to discriminate which way that's going,” what advice would you give them? In general, how would you even contemplate this issue as management when you're doing management reviews, going through the management of change process, etc.? What direction would you orient yourself in questioning whether your organization’s safety management system is effective and how well it is getting implemented?

Julius DeSilva: (29:20–32:05) One of the immediate red flags is looking at incidents occurring on the vessels. If you have incidents and accidents but no near-misses being reported at all, right? It may just be an uptick in those incidents and accidents. But another indicator is if you have external audits or customer audits evidencing findings that get you to question, “Why was this not caught by the vessel itself? Why was it not reported to us in a timely manner?” But, as my first captain told me when I was a cadet, Aaron, he said to me, “Julius, the paint talks to me.” And, I thought, you know, the captain had lost his mind. This old sea dog has been sailing for years. We always joked that when you're on a ship, under constant vibration, he’d probably just lost his marbles.

Only as I rose through the ranks did I understand what he meant when he said the paint talks to me. If you think about it, with your years of experience, look at any paint job someone has done, and you would immediately be able to tell whether the surface preparation was adequate, right? You can tell whether they took the time to prepare the surface adequately, whether they cleaned their brushes and rollers well, whether the paint was mixed correctly or not, how thickly or thinly it was applied, you know, the temperature at which it was dried, whether they applied the paint on a rainy or a clear sunny day. There are so many things that you can tell just by looking at the paint job, right?

I only realized much later in life that the paint talks to me. In my experience working with many different organizations, I think that leadership has a good knowledge of how their companies and vessels operate. Whether they want to give attention to that matter or not is key. So, in my experience, the paint always talks to them. They know where the rust spots are and whether the paint was applied correctly or not. And it's really about whether they want to change that process of how the paint job is being done or not.

Captain Aaron Williams: (32:05–32:24) That makes perfect sense. I like that metaphor, and as a captain on towing vessels for a significant amount of time, I couldn't stop laughing inside when you gave that example because it's true. It's so true.

Julius, is there any other topic you want to discuss or touch on?

Appreciating Your Management System

Julius DeSilva: (32:24–35:00) I want to discuss something dear to us at QMII. It focuses on what we call “appreciation of your management system.” Each of us has a management system in our own homes. I've run many auditor courses and worked with many folks, and I ask them, “How many of you have a written documented procedure of how you run your laundry or dryer?” Perhaps only one or two students have said they have documented procedures, but the vast majority don't.

Depending on the size of your organization and your fleet, whether you are all operating in a common area or across the United States, something has brought you along this far. The TSMS requirement is relatively new, but some companies have operated for decades and have a management system that has brought them this far. So, don't try to fit your management system into the TSMS requirements; look at it the other way around, where you're fitting the TSMS requirements into your management system.

Most organizations have a TSMS now. They either got a template or hired a consultant to provide a template, and you filled out the blanks and said, here's our documented TSMS. But in many cases, that may not align with how work is done on board your boats. It may not align with the culture of your organization, and it may not align with the hierarchy and the experience of the people where you have experienced personnel who you've been able to retain over the years. Now, you are documenting something and telling your mariners how to do it.

Do you have to document it if they know how to do it? Yes, there are certain things to be documented under the CFRs, but beyond that, organizations should determine the level to which they want to document their system. Because you know, over-documentation can also kill a system.

Captain Aaron Williams: (34:48–35:00) Exactly! I was about to jump in and ask you about over-documentation, but you beat me to the punch.

Julius DeSilva: (35:00–36:53) Outside of that, I think just as background for those in the industry, you either hold yourself or are being held to a certain standard—namely, Subchapter M, the towing safety management system, etc. As a side note, the U.S. Coast Guard also has its own management system, referred to as the Mission Management System. QMI worked with the U.S. Coast Guard when they established this mission management system many years ago. In addition to the U.S. Coast Guard’s Mission Management System, the many classification societies, such as ABS, DNV, Lloyd's, etc., must also have a quality management system. Their quality management system is essentially based on the IACS quality management system standard.

IACS has its own standards, known as the quality management system requirements, which are part of the quality system certification scheme for these classification societies. Additionally, the Mariner credentialing program, run by NMC, implements a quality management system.

All training institutes under STCW are required to have the QSS or a quality standard system. The quality standard system is essentially the same framework as a quality management system with documented procedures of how you will do it, records kept, non-conformities addressed, reviews, etc. So, while folks in the towing industry are held to this standard, change is always difficult, right? When something comes about, there are all these other standards that everyone else is being held to, So it's not them alone, I would say.

Captain Aaron Williams: (36:53–38:01) That's good to point out. I can't speak for anyone else in the towing industry, but I remember times earlier in my career when Subchapter M was implemented at various carriers where I worked. There was a sense among the crews of being singled out by what felt like a stringent regulatory framework we had to follow. So, I believe it's important for those reading to understand that regulatory demands are universal. As you mentioned, they are even present in training environments, such as U.S. Coast Guard-approved training centers. That's what you were talking about, right?

Julius DeSilva: (38:01-38:06) That's right. Yes.

Captain Aaron Williams: (38:06–38:15) So that's great to hear. And I appreciate you shedding some light on the QSS, which is phenomenal.

Julius DeSilva: (38:15–38:56) To add to that, Aaron flag administrations must also have their own framework or process-based management system in place. In the U.S., the flag is composed of multiple entities, including the U.S. Coast Guard. This requirement for flags to have management systems in place stems from the Triple I Code or the Implementation of IMO Instruments Code. Additionally, flag states are audited by the IMO. Periodically, the IMO comes out and audits flag states across the world. I forget the exact length, but I believe it is a five- or six-year cycle where they audit flag states worldwide to ensure that they are doing due diligence in their oversight.

Captain Aaron Williams: (38:56–39:05) I had no idea this happened. I take it this is the flag's version of a third-party audit.

Julius DeSilva: (39:05–39:08) This is their version of a third-party audit.

Captain Aaron Williams: (39:08–39:12) Wow. Please tell us more.

Quality Management Systems Throughout the Maritime Industry

Julius DeSilva: (39:12–39:56) This primarily applies to saltwater vessels under SOLAS, STCW, MARPOL, and other conventions, but essentially, if process-based management is working well for an organization, they will apply it to everything else, right? They don’t want certain elements at a higher standard than something else. It gets applied across the board uniformly. That's why, for example, CVC has work instructions that they publish, et cetera, that are standardizing their interpretations for the whole industry. This way, no one must second-guess the interpretation of a particular requirement.

Captain Aaron Williams: (39:56–40:26) That makes sense. I'm glad you mentioned that because my mind goes straight to the Administrative Procedures Act, which we aren’t even going to touch in this episode. Still, eventually, I want someone to come back on and talk about the APA and how it ties into U.S. Coast Guard guidance, precisely the products you were talking about—CVC work instructions, NVICs, and policy letters.

Julius DeSilva: (40:26–44:30) So, Aaron, I have another topic to address. When we were discussing change, you talked about how, initially, it was a struggle to accept this regulation and implement it on your vessel. Quality management systems are often perceived as a “documentation tiger.”

When a safety management system is implemented, the first response is that it will have all of this documentation. Often, the reason is that you probably talk to blue water folks, and they've told you stories about these big safety management systems they had, which they had no role in developing, right? Someone developed a template and threw it out there. No one asked these mariners if they needed or didn’t need specific checklists.

You have this big documentation tiger, and folks on board are already working with limited resources. You've got so many various compliance requirements, and on top of that, you have operational requirements like meeting your ETAs, delivering cargo on time, and navigating complex waterways.

Beyond that, you want me to keep all these records. What should I focus on, the records or navigating safely through the waterways? This is for the company to consider—and that's why it's essential to have a requirement for company support. How does the company support the vessel with record keeping? Is there any way to make it easier for them to do it? The whole key to the ISM Code coming about was this failure of support from the company to the ship. In 1987, when the Herald of Free Enterprise capsized, it was one of the first cases where the company was implicated. Previously, it has always been the captain and the vessel being implicated. The justice in that case said, “From top to bottom, the corporate body was infected with the disease of sloppiness.” These were the justice’s exact words. The other aspect is that folks see this not only as a documentation burden, but this often becomes, as I mentioned, a collateral duty.

It’s a feeling: "So, besides everything else, you’re not increasing my wages, right?” This is a common thing that I hear seafarers say. At the start here, I mentioned that around my fifth vessel, I had a captain sit down with me to explain why we were doing this. I think it's critical for the leadership to explain to their people why they're using this safety management system and how they can contribute to it. For instance, crews may find ways to reduce documentation while still meeting requirements. It's also helpful to explain the benefits of following a procedure, the drawbacks of not adhering to one, the advantages of keeping records compared to not doing so, and the importance of reporting near-misses. I often feel that this education isn't fully conveyed, particularly regarding why they're doing what they're doing and how their actions contribute to the organization's success, ultimately impacting their job security as the company thrives. You keep getting charters, and you're called for repeat business, so it’s progressive. I think it's important for the “what’s in it for me” question to be answered and conveyed to mariners so they know how they contribute to the system. Of course, mariners must see the commitment from the leadership to stand by and provide the resources and support as needed.

Management Commitment to Safety and its Impact

Captain Aaron Williams: (44:30–45:10) I can't agree more with you. I've worked at multiple carriers and seen that difference in management commitment. It's palpable and makes a big difference, just like you described. Thanks for sharing.

Julius DeSilva: (45:10–45:30) A simple example of the importance of safety culture is when companies pause operations in the interest of safety. Just that tiny step speaks volumes to the people on board, right? This is critical to us from a management perspective, for sure. You're seeing this happen more frequently on Sub-M towing vessels.

Captain Aaron Williams: (45:30–47:04) I think it's great. I feel that for logistics, I know it’s hard for them to see products and barges not moving. I also appreciate that whenever these vessels stop in the name of safety, now in 2025, diplomatic and realistic conversations are happening between vessel masters or pilots and their port captains. The risks are discussed. For example, the only real way to mitigate the risks of shutout fog is to stop. I think it's good that you're seeing dialogue now, especially between operations and vessels, where there might've been more grumbling in the past.

Julius DeSilva: (47:04–47:50) From a risk perspective, Aaron, sometimes the probability of something occurring may be small, but the consequence would be big, right? So, what's the risk of us doing this, but will it result in some major disaster? And, as history has shown us, these major disasters lead to intangible losses, like a loss of reputation, where customers don't want to work with you or don't want to work with your boats; those are significant impacts. And we've seen just that from historical incidents over the years.

I just remembered that the Passenger Vessel Association is implementing its Flagship SMS in addition to all the other quality measures being implemented. We recently applied to become a training provider and a recognized Flagship organization for PVA.

PVA Flagship SMS Program

Julius DeSilva: (47:50–48:26) QMII is also a PVA member, and we're committed to this program because it will drive safety among small passenger vessel operators. From having worked with some small operators, we can tell you that you don't have to document it extensively. With any sound management system, management wants a system documented to the extent needed to have confidence that the operations are being conducted as they envision or plan.

Captain Aaron Williams: (48:26–49:22) I remember briefly touching on PVA's Flagship SMS while in your ISO class. I believe you mentioned the NTSB recommendations for passenger vessel safety management systems. I’ve checked up on it occasionally. Isn't there some possibility that the NTSB might encourage the U.S. Coast Guard to do a Subchapter M-type paradigm for passenger vessels?

Julius DeSilva: (49:22–49:53) With the last two or three significant passenger vessel incidents, the NTSB has re-reinforced its recommendation for implementing safety management systems on these small passenger vessels each time. At the end of the day, it's good for industry, good for all the other waterway operators, and good for the passengers.

Closing Remarks and Additional QMII Resources

Captain Aaron Williams: (49:53–50:10) Julius, I can't thank you enough. This has been phenomenal. This was precisely what I wanted to get out of this interview and much more. I'm really, I'm grateful. I appreciate you allowing me to interview you. It means a whole lot.

Julius DeSilva: (50:10–52:07) As I said earlier, Aaron, I'm glad to be here, and thanks for the opportunity. I'm always happy to help other folks. We have our Alumni for Life Program for most of our students. If you've completed a course with us in a particular standard, you can always reach out to us with questions for the rest of your career.

For instance, if you've done an ISM Code auditor course, you can reach out and ask us questions. We have folks reach out all the time. But outside of that, if folks want to connect on LinkedIn and ask me a question, I'm always happy to help another fellow mariner. As a wise person once said, “The lands divide us, but the seas unite us.”

Captain Aaron Williams: (51:03–52:21) I got it. Julius, let me plug QMII just a bit more. I want to say that you all offer free webinars, and they've never disappointed. I've been through your large ISO 9001 class but returned and viewed some of the free webinars. It's been a nice mini-review of certain aspects of 9001 that you discussed in class.

I also want to support you regarding the alumni association. QMII is dedicated to that. It’s been three years since I took the ISO 9001 Lead Auditor class, and I've reached out to you or Lisa at least 10 or 12 times. You all back the Alumni for Life Program. So, I will direct anyone looking for ISO or ISM certification your way.