ISM Code

Last verified 4 months ago

The International Management Code for the Safe Operation of Ships and for Pollution Prevention — the ISM Code — was adopted by IMO in 1993 (resolution A.741(18)) and made mandatory through SOLAS Chapter IX in 1994. It applies in stages from 1998 (passenger ships, tankers, gas carriers, bulkers ≥ 500 GT, high-speed craft) and from 2002 (other cargo ships and MODUs ≥ 500 GT). It is the regulation that turned shipboard safety from an emergent property of competent crews into an auditable management discipline.

The ISM Code does not prescribe what a safe operation looks like. It requires every Company that operates a ship to design a Safety Management System (SMS) covering 16 prescribed functional elements, to document it, to follow it in practice, to audit it, and to demonstrate compliance to the flag administration. The flag (or a Recognised Organisation acting under it) issues a Document of Compliance (DOC) to the Company and a Safety Management Certificate (SMC) to each ship.

The 16 elements

Element 1General
Definitions, application, objectives. The objective is to ensure safety at sea, prevent human injury and loss of life, and avoid damage to the environment and property.
Element 2Safety and environmental protection policy
The company shall establish a safety and environmental protection policy, ensure it is implemented, and review it for continuing suitability.
Element 3Company responsibilities and authority
The Company is the shipowner or any other organisation that has assumed responsibility for the operation. Its identity and contact details must be reported to the flag administration.
Element 4Designated person(s)
Each company shall designate a person ashore (the DPA) with direct access to the highest level of management. Function: to monitor the safety and pollution-prevention aspects of the operation of each ship and to ensure adequate resources and support.
Element 5Master's responsibility and authority
Override authority. The Master has the overriding authority and responsibility to make decisions for safety and pollution prevention and to request the Company's assistance as may be necessary.
Element 6Resources and personnel
Master is suitably qualified for command. Vessel is manned with qualified, certificated, and medically fit seafarers. New personnel are familiarised with their duties before sailing.
Element 7Shipboard operations
The Company shall establish procedures, plans, and instructions, including checklists as appropriate, for key shipboard operations concerning safety of personnel, ship, and protection of the environment.
Element 8Emergency preparedness
Identify potential emergency shipboard situations; establish procedures to respond; programme of drills and exercises. The Company's organisation should respond to emergencies anywhere at any time.
Element 9Reports and analysis of non-conformities, accidents, and hazardous occurrences
Procedures for reporting, investigation, corrective action, and lessons-learned.
Element 10Maintenance of the ship and equipment
Procedures to ensure the ship is maintained in conformity with rules and regulations, with any additional requirements established by the Company. Includes a planned maintenance system; identification of critical equipment; testing and inspection at intervals.
Element 11Documentation
Procedures to control all documents and data relevant to the SMS. Valid documents are available at relevant locations; obsolete documents are promptly removed.
Element 12Company verification, review, and evaluation
Internal audits at intervals not exceeding 12 months. Management review of the SMS effectiveness.
Element 13Certification and periodical verification
Document of Compliance (DOC) issued to the Company; Safety Management Certificate (SMC) issued to each ship. Both renewed every 5 years with annual / intermediate verifications.
Element 14Interim certification
Provision for newbuilding deliveries, change of company / flag, and similar transitions where a full audit is not yet possible.
Element 15Verification
Conducted by the flag administration or by a Recognised Organisation acting under delegation.
Element 16Forms of certificates
Standard forms of DOC, SMC, and Interim certificates as set out in the appendices.

DOC and SMC certificates

Document of Compliance (DOC) — issued to the Company. Lists the ship types (e.g. "passenger ship", "oil tanker", "chemical tanker", "bulk carrier") for which the SMS has been audited. Valid for 5 years; annual verification audit. A copy is held onboard each ship operated by the Company.
Safety Management Certificate (SMC) — issued to each ship. Confirms the SMS is implemented onboard and the ship is operated in conformity. Valid for 5 years; intermediate verification between the second and third anniversary; annual verification on top of that for some flags. A ship without a valid SMC cannot be cleared by port state control.

Designated Person Ashore (DPA)

The DPA is the named individual ashore who has responsibility for the safety and environmental aspects of each ship's operation. The DPA must have direct access to the highest level of company management — typically reporting to the CEO or to the technical director, but not through the operations chain that they audit. Their name and 24/7 contact must be posted onboard. The DPA is the recipient of safety reports, near-miss reports, and crew complaints that bypass the normal chain. In a master-versus-shore disagreement, the DPA is the agreed escalation route.

Audits

· Internal audit — Element 12. Conducted by the Company against its own SMS at least every 12 months. Each ship and each shore office covered.
· External audit — by the flag or RO. Initial audit (for first DOC/SMC), annual or intermediate verification, renewal every 5 years.
· Findings — categorised as Major Non-Conformity (immediate threat to safety or environment, withdraws the certificate), Non-Conformity (deviation requiring corrective action within an agreed period), and Observation (no action required but flagged for improvement).

Common pitfalls

· SMS-by-the-book — procedures so detailed and prescriptive that they become a tickbox exercise; crew comply on paper, not in spirit.
· Stale risk assessments — assessments that have not been re-visited since drafting; treat each new operation as risk-assessed.
· Master's overriding authority not exercised because of commercial pressure — the Code explicitly protects this.
· Critical equipment list incomplete; PMS not aligned with manufacturer recommendations.
· Near-miss reporting culture — Element 9 expects honest reporting; punitive responses kill the data.