ISM Code: A practical Guide to the Legal and Insurance Implications

Dr Phil Anderson

Document

Index

ABS see American Bureau of Shipping

accident pyramid 313–14
accidents: and human error 5–7, 150; erecting barriers 339–44; investigation and reporting 32, 119, 309–22; reasons of 6–8; requirements on the Company 311–17; requirements on the flag Administration 317–22; root cause analysis 316, 342; statistics 19–22; watchkeeping-related 268; see also incidents; hazardous occurrences; near-misses
active failures 341–2, 344
actual fault or privity 132–4, 136–8, 263, 280, 281, 294–5; see also privity
Administrations see flag Administrations
Advisory Committee on the Safety of Nuclear Installations (ACSNI) 60
‘agony of the moment’ 139
alcohol abuse 243–4, 248
Allianz 19–20
allisions 268
alter ego 134–5, 138, 300
American Bureau of Shipping (ABS) 100–3
appraisals 257–8
arbitration 110
attribution 131, 135
auditable systems 45–7
audits: DOC verification 164–7, 179–82; external 47, 145; IMO scheme 73; internal 32–3, 47, 142, 143, 145, 306–9; SMC verification 173, 174
audit trail 308–9

Bahamian Merchant Shipping Act 1976 100
ballasting operations 286
Baltic and International Maritime Council (BIMCO) 2, 55, 56, 106, 295; ISM Clause 99, 296
bareboat charterers 51, 105, 162, 349, 354, 371
bills of lading 277, 279, 289
BIMCO see Baltic and International Maritime Council
blind-eye knowledge 135–7
Bourbon Dolphin 267
breakdown policy 298
bridge management 268–76
Bridge Procedures Guide 204, 205, 206
Bridge Team Management – A practical guide 204
bulk carriers 10, 24, 42, 149, 15
burden of proof 134, 280, 281, 294

cargo 39, 51–2; loss or damage to 278, 283
cargo ships 10, 23, 42, 164, 165
cargo underwriters 111, 149
carriage of goods 110, 268, 276–93; due diligence 278
Carriage of Goods by Sea Act 1936 (US) 279
Carriage of Goods by Sea Act 1971 (UK) 279
Carver Report 6
casualties 6
casualty investigations 317–20
Certificate of Competency (COC) 107, 218, 224, 225, 229, 238–9, 273–4; fraudulent 240
certificates: medical 242–3; registers of 241
certification 162–87, 237–40; flag Administrations 34, 76–7; fraudulent 240–2; interim 34, 177–86; MLC 237; Port State Control 155–6; Recognised Organisations 86–7, 90–3; Safety Management System 33–4, 80; SOLAS 161–2, 237; STCW 239, 241–2; STCW Code 237
charterers 146–9
charter hire 147
charterparties 99, 278, 279, 295–6
charts 111, 261, 282, 305, 315
chemical tankers 10, 24, 149, 165
CICs see concentrated inspection campaigns
civil actions 275
Class Certificates 158
Classification Societies 93–105
Coast Guard and Maritime Transportation Act 2004 42
COC see Certificate of Competency
Code of Good Management Practice in Safe Ship Operations 4, 5, 116
Code of Safe Working Practices for Merchant Seamen (COSWP) 189, 191, 203
collisions 268, 275; and human error 6
COLREG see Convention on the International Regulations for Preventing Collisions at Sea 1972
commercial management 106
Companies 105–20; accident prevention 311–17; ‘alter ego’ of 134–5; auditable systems 45–7; commitment to safety 39; Company Security Officers (CSOs) 129; compliance with the ISM Code 40–1, 44–5; culture 59, 64, 208–9; defined 51, 105; DOCs 162–71; DPAs 123, 125, 129–30, 206–7; Drug and Alcohol Policy 243; emergency preparedness 31, 296–8; external audits 47; implementation of corrective action 32; internal safety audits 32–3, 47, 142, 143, 145, 306–9; maintenance of the ship and equipment 31–2; obligations and responsibilities 51, 105–6, 114–19, 118, 219–24, 229, 253; one-ship 50–1; plans for shipboard operations 30–1; requirements placed upon 113, 311–17; role as enforcer 145–6; Safety and Environmental-Protection Policy 113, 141; safety culture 63–6, 339; safety management objectives 41, 215, 265; Safety Management Systems 48–50, 113, 117–19, 193, 207; support for Masters 236–7; threefold mantra 44–5; verification, review and evaluation 33, 35–6, 306–9
Company Security Officers (CSOs) 120
compliance culture 50, 145–6
concentrated inspection campaigns (CICs) 22–4
condition surveys 150
confidentiality 320
container ships 24
contract of carriage 52, 96, 275, 279, 295
contractual disputes 275
Convention on Limitation of Liability for Maritime Claims 1976 (LLMC) 133, 139, 281
Convention on the International Regulations for Preventing Collisions at Sea 1972 (COLREG) 72, 214, 271
Cosco Busan 12
Costa Concordia 345
COSWP see Code of Safe Working Practices for Merchant Seamen
crew: liability for actions of 112; management 106–7; responsibilities 223; see also Designated Persons (DPs); Masters; resources and personnel
criminal prosecutions 275
critical systems 301
CSC see International Convention for Safe Containers 1972
CSOs see Company Security Officers
culture 57–66; company 59, 64, 208–9; compliance 58–9; definition 57–8; flexible 63; informed 61; just 62–3; learning 63; negative 58; ‘no-blame’ 62; of self-regulation of safety 116; positive 58, 59; reporting 62; safety 39, 58–66, 116, 142, 144–5, 208

Deepwater Horizon 13
default 132, 133, 280–1, 293; wilful 112
defences-in-depth 340–1
deficiencies: detainable 155; identifying and taking action 150, 154–5, 157
demise charters 146
Designated Person Ashore (DPA) 36, 122, 115; see also Designated Persons (DPs)
Designated Persons (DPs) 121–39; as ‘alter ego’ of Company 134–5; experience 118–19, 125, 127, 129, 130; qualifications 118–19, 125–6, 130; resources and support for 116, 123, 125, 131; role and duties 119, 121–2, 125; training 118–19, 125, 128, 130
detention rates 22–4
DOCs see Documents of Compliance
Documents of Compliance (DOCs) 50–1, 161–71; and PSCOs 155–6; and SMSs 180–1; Company requirements and records 129–30, 206–7; forms of certificate 187; interim 178–82, 187; interim verification 179–82; issuing 59, 76, 90, 112, 163; on-board copies 171; requirements 81; safety and pollution-prevention 131–2; safety management audits 165–7; validity 164–5; withdrawal 55, 112, 167–9
domestic voyages 42
Dona Paz 344–5
DPA see Designated Person Ashore
drug abuse 243–4, 248
Drug and Alcohol Policy 243
due diligence: and duty of care 291; and liability 133; and seaworthiness 280, 281, 282, 288–91, 293, 300; and carriage of goods 278; in appointment of staff 274; obligation to exercise 283, 289

electro-technical officers 262
emergency equipment 301
emergency preparedness 31, 296–8
employment, continuity of 50, 53–4, 209, 273
EMSA see European Maritime Safety Agency
engineering officers 262
environment, protection of 52–3, 139–44; see also marine pollution; pollution prevention; Safety and Environmental Protection Policy
equipment 298–304
Erika 103–4, 147
Estonia 10
Eurasian Dream 13, 235–6, 267–8
European Maritime Safety Agency (EMSA) 3, 81
evaluation, Company 33, 35–6, 306–9
experience 26, 256; DOCs 118–19, 125, 127, 129, 130
explosions 6

familiarisation 252–4
fatigue 247–52
fault see actual fault or privity
feedback 236, 302, 303
ferries: Ro-Ro passenger 5, 9, 10, 222; safety management 5, 9, 10
fire 6, 113, 281
fire-fighting 91, 150, 178, 266, 277
fitness for duty 248
flag Administrations 76–85; accident prevention 317–22; certification and verification 34, 76, 80; compliance with the requirements of the Code 15, 49; definition 76; detention rates 22–4; DOCs 163–4, 168, 181; external audits 47; Guidelines for 14–15, 26, 80, 113, 116; major shipping flags 77; role as enforcer 146; Safety Management Certificates 34, 171–4, 184–5; Safety Management Systems 197–9; see also Recognised Organisations (ROs)
flags of convenience (FOCs) 7, 77, 80
flexible culture 63
FOCs see flags of convenience
fraudulent certificates 240–2
freight 147

gas carriers 10, 23, 42, 165
GIE see Group of Independent Experts
GMDSS radio operators 261
good faith 101, 138
goods: definition 289; liability for loss or damage 133, 139
government-operated ships 42
Grainville 4
gross negligence 112
groundings 268, 275; and human error 6
Group of Independent Experts (GIE) 17, 25, 26, 56, 117, 124
Guidelines on the Application of the IMO International Safety Management (ISM) Code 116, 194, 299

H&M insurance 6, 7, 149, 150
Hague Rules 279, 292
Hague–Visby Rules 226, 274, 277–83, 289
Hamburg Rules 278, 279
hazardous occurrences 32, 119, 144, 311–13
hazards 28, 29, 188–9
Health and Safety Executive (HSE) 43, 64
health and safety protection 191
Herald of Free Enterprise 3–5, 8, 121, 344, 345
high-speed craft 10, 42, 164
hours of rest 247–52
hours of work 247–52
Human Element in Shipping Casualties, The 6
human error: and accidents/incidents 5–8, 150; and casualties 6; and collisions 6; and fires/explosions 6; and groundings 6; Swiss cheese model 61, 340–1, 343

IACS see International Association of Classification Societies
ICS see International Chamber of Shipping
ILO see International Labour Organization
ILS see International Labour Standards
IMDG Code 277
IMO see International Maritime Organization
imprisonment 199
IMSBC Code 277
incidents: and human error 6; serious 21; statistics 21
incompetency 227–8
inefficiency 227, 228
informed culture 61
inspections: by insurers 150; by Port State Control 22, 80–4, 151, 153–5, 170; pre-vetting 149; reports of 154; campaigns (CICs)
Instructions for the Guidance of Surveyors 180, 194
insurers 149–51
INTERCARGO see International Association of Dry Cargo Shipowners
Inter-Governmental Maritime Consultative Organization (IMCO) 70
interim certification 34, 177–86; DOCs 178–82, 187; SMCs 184–5, 187, 232
INTERMANAGER see International Association of Shipmanagers
International Association of Classification Societies (IACS) 2; Guidelines for Auditors 15, 28, 30, 32, 114–15, 127–8, 200, 224, 231, 254; Guide to Risk Assessment in Ship Operations 29, 187, 189; Procedures and Guidelines 87–9
International Association of Dry Cargo Shipowners (INTERCARGO) 2, 56
International Association of Independent Tank Owners (INTERTANKO) 2, 56
International Association of Shipmanagers (INTERMANAGER) 2
International Chamber of Shipping (ICS) 2, 4, 56, 116
International Convention for Safe Containers (CSC) 1972 277
International Convention for the Prevention of Pollution from Ships 73/78 (MARPOL) 2, 85, 151–2, 318
International Convention for the Safety of Life at Sea 1974 (SOLAS) 2, 9, 41–2, 85, 151, 260, 318–19
International Convention on Standards of Training, Certification and Watchkeeping for Seafarers 1978 (STCW) 2, 214; amendments 25, 216–18, 248–50; PSC inspections 151; resources and personnel 216–24, 253, 260–2
International Labour Organization (ILO) 25, 56, 73–5; conventions 197–8; Member States 76; structure 74
International Labour Standards (ILS) 25, 74
International Maritime Organization (IMO) 70–3; audit scheme 73; Conventions and Protocols 71–2, 197–8; development of ISM Code 8–15; Facilitation Committee 71; ‘Go to Sea!’ campaign 53–4; historical reasons 3–8; Legal Committee 71; Marine Environment Protection Committee (MEPC) 71; Maritime Safety Committee (MSC) 5, 71; Member States 76; Recognised Organisations 85–6; safety culture 64–5; sub-committees 71; Technical Co-operation Committee 71
International Safety Guide for Oil Tankers and Terminals (ISGOTT) 204
International Safety Management Code (ISM Code): amendments to 11, 15, 25–37, 124; application 41–3; background 1–37; compliance requirements 40–1, 44, 49–50, 162–347; developments at IMO 8–15; effectiveness of implementation 1 5–24; enforcers 145–58; facilitators 69–75; Guidance on the Qualifications, Training and Experience 26; Guidelines for Administration 14–15, 26, 80, 113, 116; Guidelines for the Operational Implementation 26; key players 69–159; legislators/regulators 75–105; mandatory compliance with 9–10; non-compliance with 12, 41, 151; personalised system 40; preamble to 37–40, 49, 52, 120–1, 140; purpose and key objectives 37–41, 214; research into implementation 16–19; underlying principles 37–66
International Ship and Port Facility Security Code (ISPS Code) 2
International Shipping Federation (ISF) 2, 4, 55, 56, 65, 116
international standard 37–9
International Transport Workers Federation 56
International Union of Marine Insurance (IUMI) 19–21
international voyage 42
INTERTANKO see International Association of Independent Tank Owners
ISF see International Shipping Federation
ISGOTT see International Safety Guide for Oil Tankers and Terminals
ISM Code see International Safety Management Code
ISM consultants 52, 59
ISPS Code see International Ship and Port Facility Security Code
IUMI see International Union of Marine Insurance

job descriptions 115
just culture 62–3

KISS principle 194, 271
knowledge 227–8; blind-eye 135–7; of unseaworthiness/incompetence issues 136–9; privity 136–8

language 107, 258–63; common 259
latent conditions 341–4
leadership 39, 52
learning culture 63
liability: Classification Societies acting as ROs 93–105; development of 12; fire 133; limits of 139; loss or damage of goods 133, 139, 280; of ship managers 111–12; of shipowners 132–4; unseaworthiness/incompetence issues 136–8
Liberia 77
Limitation Convention 1957 133, 139, 281
live animals 289
LLMC see Convention on Limitation of Liability for Maritime Claims 1976
Loadline Certificates 97
loss or damage 110: and fire 133; and unseaworthiness 280; exemptions from liability 280; to cargos 278, 283

MAIB see Marine Accident Investigation Branch
maintenance: adequate system 302–4; cost cutting 8; non-conformities within 302–4; of the ship and equipment 31–2, 298–304; planned maintenance policy 299
major non-conformities (MNCs) 22, 27–8, 36, 45, 47, 55, 157–8, 168–70, 174–5, 190
management: commitment to safety 39, 52–3, 56, 66; of safety systems 293–5; reviews 119; systems 43–8; systems approach to 43
Managing the Risks of Organisational Accidents 61
manning: and seaworthiness 287; requirements 35, 54, 236; safe 244–7
manning agents 109, 209; commitment to safety 39; monitoring 116
Marchioness disaster 188
Marine Accident Investigation Branch (MAIB) 321, 322
Marine and Coastguard Agency (MCA) 321–2
Marine Guidance Notes (MGNs) 202
Marine Insurance Act 1906 136, 137, 278
marine pollution 70–1
Maritime and Coastguard Agency (MCA) 42, 180, 194
maritime labour certificate 75, 213
Maritime Labour Convention 2006
(MLC) 2, 25, 41, 74, 191; preamble to 214; resources and personnel 210–16; working standards for seafarers 211–12
MARPOL see International Convention for the Prevention of Pollution from Ships 73/78
Masters: and Safety Management Systems 29–30, 119, 141–4, 229–36, 186; and SMS manuals 54; commitment to safety 39; continuity of employment 50, 209, 273; hours of work/rest 251–2; qualifications 224–9; requirements 107; responsibility and authority 30, 141–4, 223; safety and environment protection 139–44; standing orders 144, 270; support for 236–7; verification 36
MCA see Maritime and Coastguard Agency
medical certificates 107, 242–3
medical examination 242–3
mental health 287
Merchant Shipping Act 1906 136
Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 1997 191
Merchant Shipping (ISM Code) Regulations 1998 5, 199
Merchant Shipping (ISM Code) (Ro-Ro Passenger Ferries) Regulations 1997 5
Merchant Shipping (Operations Book) Regulations 1988 5, 9, 121, 122
MGNs see Marine Guidance Notes
Minimum Safe Manning Document 246
MLC see Maritime Labour Convention 2006
MNCs see major non-conformities
mobile offshore drilling units (MODUs) 10, 42, 165
moral dilemmas 344–5
multi-national crew 259, 260
Muncaster Castle 290, 291

Nancy 12
Nautical Institute 204
navigation 268–76
NCN see Non Conformity Note
near-misses 312–13; reporting 26, 118, 144
negative culture 58
negligence 112, 136, 228
Nicholas H 93–100
NKK 94, 96
NLS tankers 24
no-blame culture 62
non-conformities 11, 22, 45–7, 119, 302; major (MNCs) 22, 27–8, 36, 45, 47, 55, 157–8, 168–70, 174–5, 190; reporting and analysis 32, 131, 144, 310, 311–13
Non Conformity Note (NCN) 157
non-governmental organizations (NGOs) 56

observations 45, 119, 131, 313
OCIMF see Oil Companies International Marine Forum
Oil Companies International Marine Forum (OCIMF) 2, 148
oil-majors 148, 149
oil tankers 10, 24, 42, 149, 165; pollution from 70
one-ship companies 50–1
open registers (ORs) 7, 77, 80
operational risks 189–91; see also risks
ORs see open registers
overriding conditions 249

package limitation 281
Panama 77
Passenger Safety Certificates 97
passenger ships 10, 42, 122, 164
Patraikos II 274
personal act or omission 133–4, 139
P&I Clubs 6; accident and loss prevention guides 204; as enforcers 149–51; inspections and condition surveys 150; medical assessments 243
P&I insurance 6, 7, 150
pollution prevention 32–3, 52, 121, 131–2; see also marine pollution
Port State Control (PSC) 2; and
compliance with the ISM Code 18; as enforcer 151–8; certification and implementation 155–6; guidelines for 153–8; inspections 22, 80–4, 151, 153–5, 170; regional organisations 152; standardisation of procedures 152–3
Port State Control Officers (PSCOs) 154–8
positive culture 58
Principles of Minimum Safe Manning 35
privity, concept of 136; see also actual fault or privity
property 27
property damage 38–9
Protection/Protecting and Indemnity Association (P&I Clubs) 2, 21
PSC see Port State Control
PSCOs see Port State Control Officers

qualifications 26, 256
Quality Management Systems 38, 193

Rabaul Queen 345
Reason, James 59, 61, 63, 339–40 recklessness 112, 139, 281, 300
Recognised Organisations (ROs) 85–105; accountability of 158; assignment of authority to 85–6; certification 86–7, 90–3; definition 85; external audits 47; IACS Procedures and Guidelines 87–9; legal status 90–105; MARPOL 85; minimum specifications for 86; performance tables 87–9; responsibility of 84; SOLAS 85; verifying compliance 49
repairs 91–2, 94, 108, 246, 302
reporting: accidents 32; hazardous occurrences 32, 144; near-misses 26, 118, 144; non-conformities 32, 144
reporting culture 62
resources and personnel: adequate understanding 254–5; cost cutting 8; drug and alcohol abuse 243–4, 248; employment and social rights 215; familiarisation 252–4; hours of work/rest 247–52; language 258–63; medical examinations 242–3; MLC 210–16; multi-national crew 259, 260; recruitment and placement 229; safe manning requirements 35, 54, 236; Safety Management Systems 208–64; SOLAS 260; STCW 1978 216–24, 253, 260–2; training 216, 219, 255–8; working standards 211–12
reward schemes 145
RINA 103–4
risk assessment 27–9, 187–92, 232–3, 247; tankers 148
risk-based approach 28
risk management 27, 29, 41, 187–92
risks 28–9, 188–9; operational 189–91
Ro-Ro passenger ferries 5, 9, 10, 222
ROs see Recognised Organisations
Rotterdam Rules 278, 279

safe practices 40–1
Safety and Environmental Protection Policy 52–3, 113, 141, 230
Safety Aspects of Ship Design and Technology 6
safety culture 39, 58–66, 116, 142, 144–5, 208
safety equipment 301
Safety Management Certificate (SMC) 51, 171–7; and DOCs 180–1; and Masters 186; and PSCOs 155–6; forms of certificate 187; interim 184–5, 187, 232; issuing 59, 76, 90, 161, 171; requirements 81; validity 172; verification 33–4, 172–7; withdrawal 55, 173–4
Safety Management Manuals 49–50, 54, 192; document control of 304–5; ready-made 50, 59; reviewing 180
Safety Management Systems (SMSs) 3, 192–309; and competency of staff 54–6; and interim DOCs 178–9; and Masters 141–4, 229–36; and safety culture 65, 142; auditable systems 45–7; auditing and monitoring 47; buy-in by Company personnel 56–7, 66; certification and periodical verification 33–4, 162–87; commitment from the top 52–4, 121; compliance with the ISM code 18, 22–3, 49–50; deficiencies in 157; documented system 194; evaluation 33; guidelines 117–20, 201–3; inspections of 156; instructions and procedures 197; national requirements 199–201; objectives 194–6; Plan, Do, Check, Act model 43, 192, 326–39; ready-made 50, 193; requirements 47–8, 194, 196–7, 199–201, 207–8; review of 29–30, 119–20; risk assessment 29, 190; safety and anti-pollution activities 32; structure of 192–208; tailor-made 48–50
salvage 111, 275
San Francisco Bay 12
Scandinavian Star 9, 259
SDRs see Special Drawing Rights
seafarers: buy-in into SMS 56–7; competency of 54–6; definition 21, 252; labour standards 74–5; nationality of 7–8; requirements 35, 54; training 8; worldwide supply of 55; see also crew; resources and personnel
Seafarers International Research Centre (SIRC) 241
seaworthiness 13, 226; and due diligence 280, 281, 282, 288–91, 293, 300; and loss or damage 280; and Masters 228; and stowage of cargo 287–9; knowledge of 137–9; manning aspect 287; under contracts of carriage 278–9, 285–7; warranty of 132–3; within Hague–Visby Rules 283
self-assessment 148
self-enforcement 145
self-incrimination 310, 320
self-monitoring 145
self-regulation 38, 40, 59, 116, 142, 145; of safety 116
serious incidents 21
ship management agreements 106
ship managers 105–9; and shipowners 106–113; liabilities for the actions of the crew 112; liabilities to owners 111–12; obligations 109; ship operators 105–45
shipboard operations 30–1, 264–96; and risk assessment 265; functional requirements 264; key 265–6, 276, 292; plans and instructions for 292–3
shipping companies see Companies
Shipman ’98 106–11
shipowners 105–7; and ship managers 106–113; liability of 132–4; obligations 109
Ship Security Officers (SSOs) 129
shore management 120–2
short-sea trade 122
SIRC see Seafarers International Research Centre
SIRE Programme 148
skill 227
SMC see Safety Management Certificate
SMS documentation 304–5
SMS Procedure Manuals 149; see also Safety Management Manuals
SMSs see Safety Management Systems
SOLAS see International Convention for the Safety of Life at Sea 1974
sovereign immunity 84, 90, 93
Special Drawing Rights (SDRs) 281
SSOs see Ship Security Officers
standing orders 144, 270
Star Sea 137, 139
Statutory Certificates 84, 90–3, 158; see also Documents of Compliance (DOCs);
statutory investigations 275
STCW see International Convention on Standards of Training, Certification and Watchkeeping for Seafarers 1978
STCW Code 218–23, 237–8, 250–1, 271
stowage 287–8
strandings 268
Sundancer 100–1
Surveyor General’s Organisation 6
surveys 2, 53, 85, 86, 90–1, 150
Swiss cheese model 57, 61, 340–1, 343

tacit acceptance 9
Tanker Management Self-Assessment (TMSA) 2
tanker risk assessment 148
technical management 106, 108–9
THETIS database 81
threefold mantra 44–5, 322, 326
TMSA see Tanker Management Self-Assessment
TMSA Programme 148–9
Torrey Canyon 71
training 26, 118–19, 125, 128, 130, 216, 219, 255–8
transparency 50–2

understanding 254–5
United Kingdom Mutual Steamship Assurance Association (Bermuda) Limited 6
United Nations: maritime-related agencies 70; see also International Labour Organization (ILO); International Maritime Organization (IMO)
United Nations Convention on the Law of the Sea (UNCLOS) 69, 318
United States 199–200

VDR see Voyage Data Recorder
Vector 344
verification 162–87; Company 33, 35–6, 118–19, 306–9; flag Administrations 76–7; interim DOCs 179–82; Masters 36; Safety Management Certificates 33–4, 172–7; Safety Management System 33–4, 80
Vessel Traffic Service (VTS) 275
Viking Islay 12
voyage: domestic 42; international 42; planning 204, 205
Voyage Data Recorder (VDR) 275
VTS see Vessel Traffic Service

watchkeeping 268–76
watchkeeping-related accidents 268
White–Grey–Black Lists 15, 80, 82–4, 162
wilful default 112
witness protection 320

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