The ISM Code in Practice: Building a Safety Management System That Passes Audits

What the code requires

The International Safety Management Code requires every company operating ships to establish, implement and maintain a safety management system. Two certificates evidence it: the Document of Compliance (DOC) held by the company and the Safety Management Certificate (SMC) held by each ship.

Almost every ship management company has a documented SMS. Far fewer have one that is actually used, and the gap between those two states is where non-conformities, deficiencies and casualties live.

Where audits actually fail

Auditors rarely find that a procedure is missing. They find that it is not followed, not understood, or not applicable to the ship as actually operated.

Procedure not followed. Usually because the procedure describes an idealised ship. Procedures written by someone who has not sailed the vessel type produce workarounds.

Critical equipment maintenance. The code requires identification of equipment whose sudden failure could result in a hazardous situation, with specific measures to promote reliability including regular testing of standby arrangements. Auditors check whether the list is credible and whether the testing is evidenced.

Corrective action that does not correct. A non-conformity closed by "crew reminded" is not closed. Root cause analysis is the weakest area in most systems.

Familiarisation. Joining seafarers must be familiarised with their duties before sailing. Records that show a 45-minute familiarisation covering nineteen topics on the day of departure will not survive scrutiny.

Document control. Superseded revisions in circulation, especially on ships that have changed manager.

Building an SMS people actually use

1. Write for the reader

A procedure a third engineer can follow at 04:00 during a blackout is a procedure. A twelve-page narrative with cross-references is a document. Use checklists, flowcharts and short steps.

2. Involve the crew in writing it

Procedures written with input from serving officers describe the ship as it is. This single practice removes most "procedure not followed" findings.

3. Keep it proportionate

An SMS that has grown by accretion for fifteen years contains procedures nobody has read. Periodic pruning is a safety measure — volume dilutes attention.

4. Make reporting safe

Near-miss and non-conformity reporting only works where reporting is not punished. A fleet reporting fewer than one near miss per vessel per month has a reporting culture problem, not a safety record.

5. Do root cause properly

Immediate cause: the valve was left open. Root cause: the handover checklist does not include valve line-up, and the procedure assumes a two-person check that the manning level does not support. The second answer changes something.

6. Give the DPA real authority

The DPA must have direct access to the highest level of management. If the DPA role is held by someone who reports to the person whose budget would be affected by a stoppage, the arrangement is nominal.

7. Protect the Master's overriding authority

The code requires the Master to have overriding authority to take decisions for safety and pollution prevention. That authority is only real if a Master who uses it faces no adverse consequence. Test this honestly: when did a Master last delay a departure on safety grounds, and what happened afterwards?

The link to inspection performance

The Paris MoU recorded 51,797 deficiencies in 2025 across 16,474 inspections, with 688 detentions — a 4.18% detention rate. ISM-related findings recur, and the report highlights persistent implementation failures alongside specific technical areas: fire safety at 16.8% of deficiencies, structure and machinery at 11.6%, and MLC welfare at 10.1%.

Fire doors wedged open and perished fire hoses are ISM failures as much as they are SOLAS deficiencies. Someone should have found them during an inspection routine that the SMS requires.

Internal audit that adds value