International Safety Management (ISM) Code

Q. What is ISM Code?
International Safety Management (ISM) Code means the International Management Code for the Safe Operation of Ships and for Pollution Prevention as adopted by the Assembly, as may be amended by the Organization.

Q. How should the system be, to implement effectively, the Company safety and environmental protection policy?
Safety Management System means a structured and documented system enabling Company personnel to implement effectively the Company safety and environmental protection policy.

Q. What are the important circulars and guidelines related to the ISM?
The provisions relevant to SOLAS chapter IX and the ISM Code include:

  • Revised guidelines for the operational implementation of the International Safety Management (ISM) Code by companies (MSC-MEPC.7/Circ.8)
  • Guidance on the qualifications, training and experience necessary for undertaking the role of the designated person under the provisions of the International Safety Management (ISM) Code (MSC FAL.7/Cir.6)
  • Guidance on near-miss reporting (MSC-MEPC.7/Circ.7)
  • Guidelines on maritime cyber risk management (MSC-FAL.1/Circ.3)
  • Maritime cyber risk management in Safety Management Systems (resolution MSC.428(98)).

Q. How are observation, non-conformity and major non-conformity defined under the ISM Code?
Observation means a statement of fact made during a safety management audit and substantiated by objective evidence.
Non-conformity means an observed situation where objective evidence indicates the non-fulfillment of a specified requirement. Major non-conformity means an identifiable deviation that poses a serious threat to the safety of personnel or the ship or a serious risk to the environment that requires immediate corrective action or the lack of effective and systematic implementation of a requirement of this Code.

Q. Can you give an example of each?
The examples of an observation may be:

  1. a dirty oil rag on the deck;
  2. unsecured dunnage scattered on deck.

The examples of non-conformity may be:

  1. the logbook not signed by the responsible person as required;
  2. the date and time of the drills not entered in the logbook.

The examples of major non-conformity may be:

  1. the emergency procedures for closing the hatch covers not found;
  2. the liferaft not serviced.

Q. What must the Safety-management objectives of the Company provide?
Safety-management objectives of the Company (1.2.2) should, inter alias:

  1. provide for safe practices in ship operation and a safe working environment;
  2. assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards; and
  3. continuously improve safety-management skills of personnel ashore and aboard ships, including preparing for emergencies related both to safety and environmental protection.

Q. What functional requirements for a safety-management system should be provided?
The functions may be remembered by the words: Policy, procedures, levels, report, respond and audit. Thus, every company should develop, implement and maintain a safety management system (SMS) which includes the following functional requirements:

  1. a safety and environmental-protection policy;
  2. instructions and procedures to ensure safe operation of ships and protection of the environment in compliance with relevant international and Flag State legislation;
  3. defined levels of authority and lines of communication between, and amongst, shore and shipboard personnel;
  4. procedures for reporting accidents and non- conformities with the provisions of this Code;
  5. procedures to prepare for and respond to emergency situations; and
  6. procedures for internal audits and management reviews.

Q.  What are company’s responsibilities and authority?
The entity who is responsible for the operation of the ship is other than the owner, the owner must report the full name and details of such entity to the Administration.
1. The Company should define and document the responsibility, authority and interrelation of all personnel who manage, perform and verify work relating to and affecting safety and pollution prevention.
2. The Company is responsible for ensuring that adequate resources and shore-based support are provided to enable the designated person or persons to carry out.

Q. Who is Designated Person(s)?
Commitment from top is one of the underlying principles of ISM. To ensure the safe operation of each ship and to provide a link between the Company and those on board, every Company, as appropriate, should designate a person or persons ashore having direct access to the highest level of management. The responsibility and authority of the designated person or persons should include monitoring the safety and pollution- prevention aspects of the operation of each ship and ensuring that adequate resources and shore-based support are applied, as required.

Q. What responsibilities of the Master are defined by the company?
The Company should clearly define and document the Master’s responsibility with regard to:

  1. implementing the safety and environmental-protection policy of the Company;
  2. motivating the crew in the observation of that policy;
  3. issuing appropriate orders and instructions in a clear and simple manner;
  4. verifying that specified requirements are observed; and
  5. periodically reviewing the SMS and reporting its deficiencies to the shore-based management.

Q. What is the responsibility of company in respect of ensuring the proper manning?
The Company should ensure that each ship is:

  1. manned with qualified, certificated and medically fit seafarers in accordance with national and international requirements; and
  2. appropriately manned in order to encompass all aspects of maintaining safe operation on board.

‘The principles of minimum safe manning’, adopted by the Organization by Resolution A.1047(27) should be referred in this respect.

Q. What are the provisions in respect of ‘emergency preparedness’?
Section 8 deals with this. Thus:

1. The Company should identify potential emergency shipboard situations, and establish procedures to respond to them.
2. The Company should establish programmes for drills and exercises to prepare for emergency actions.

Q. How is the company involved in guiding and assisting the ship in emergency?
The SMS should provide for measures ensuring that the Company’s organization can respond at any time to hazards, accidents and emergency situations involving its ships.

Q. What is the provision in respect of reporting non-conformities, accidents and hazardous situations?
The SMS should include procedures ensuring that non- conformities, accidents and hazardous situations are reported to the Company, investigated and analysed with the objective of improving safety and pollution prevention.

Q. What can be done in order to prevent the recurrence of above situations?
The Master should do the periodic and random review of the procedures. After an accident, incident, near miss and hazardous occurrence, the safety meetings must be conducted to investigate to find the immediate and causal factors. These are then reported to the company. 
The Company should establish procedures for the implementation of corrective action, including measures intended to prevent recurrence.

Q. How can you define the objective of the ISM in a few thumb rules?
The rules can be:

  1. Write the procedures to comply with regulations.
  2. Do what you write, and write what you do.
  3. Commitment from top, and involvement of all.

Q. How should a company ensure that the ship is maintained in conformity with the provisions of the relevant rules and regulations?
The compliance to the regulations and compliance to the properly implemented ISM go simultaneously. Company should ensure that:

  1. inspections are held at appropriate intervals;
  2. any non-conformity is reported, with its possible cause, if known;
  3. appropriate corrective action is taken; and
  4. records of these activities are maintained.

Q. How does company ensure that the safety manual is always updated and available to the users in their individual capacities?
The documents used to describe and implement the SMS may be referred to as the Safety Management Manual. The Company should ensure that:

  1. valid documents are available at all relevant locations;
  2. changes to documents are reviewed and approved by authorized personnel; and
  3. obsolete documents are promptly removed.

Thus, the lifeboat procedures or several checklists, etc. though part of the SMS may be made available in the crew mess room, recreation room, etc.

Q. How often should the company carry out internal audits?
The Company should carry out internal safety audits on board and ashore at intervals not exceeding twelve months to verify whether safety and pollution-prevention activities comply with the SMS. In exceptional circumstances, this interval may be exceeded by not more than three months.

Q. Can any engineering officer audit the deck side activities?
Yes. In fact it may be preferred to auditing the own department. This is because the activity is audited rather than surveyed. While surveying the in depth knowledge of regulations relating to the activity must be known. Personnel carrying out audits should be independent of the areas being audited unless this is impracticable due to the size and the nature of the Company.

Q. What is done with the results of audit?
The results of the audits and reviews should be brought to the attention of all personnel having responsibility in the area involved.

Q. Who all are authorizes to issue, withdraw, verify the certificates related to the ISM?
These certificates may be issued, withdrawn or verified by the Administration, by an organization recognized by the Administration or, at the request of the Administration, by another Contracting Government to the Convention

Q. Who can and for what period can issue the Document of Compliance to a company?
The Document of Compliance should be issued by the Administration, by an organization recognized by the Administration or, at the request of the Administration, by another Contracting Government to the Convention to any Company complying with the requirements of this Code for a period specified by the Administration which should not exceed five years.
Thus, if a ship is Cyprus flagged, then the Cyprus government or a Recognized Organization on the behalf of that government may issue the DOC. At the request of the Flag State, the DOC may also be issued by any state, which is party to the Convention upon request of Flag State. Thus, the Recognized Organization of  a Party State should be able to give DOC in respect of ships of different flags so long as the Company complies with the requirements of the Code

Q. How frequently, the validity of the DOC must be verified?
The validity of a Document of Compliance should be subject to annual verification by the Administration or by an organization recognized by the Administration or, at the request of the Administration by another Contracting Government within three months before or after the anniversary date.

Q. What are the grounds on which the Document of Compliance may be withdrawn?
The Document of Compliance may be withdrawn when:

  1. the annual verification required is not requested; or
  2. if there is evidence of major non-conformities with this Code.

Q. Will the withdrawal of DOC affect the SMC?
All associated Safety Management Certificates and/or Interim Safety Management Certificates should also be withdrawn if the Document of Compliance is withdrawn. Thus, the SMCs or Interim SMCs on different ships under that DOC will also get withdrawn.

Q. What is the validity of SMC? When can it be given to a ship?
The Safety Management Certificate should be issued to a ship for a period which should not exceed five years. The Safety Management Certificate should be issued after verifying that the Company and its shipboard management operate in accordance with the approved safety management system.

Q. What is the condition in respect of intermediate verification of SMC?
The validity of the Safety Management Certificate should be subject to at least one intermediate verification. If only one intermediate verification is to be carried out and the period of validity of the Safety Management Certificate is five years, it should take place between the second and third anniversary date of the Safety Management Certificate.

Q. What is the effect of not requesting an intermediate verification?
The Safety Management Certificate should be withdrawn by the Administration or, at the request of the Administration, by the Contracting Government which has issued it when the intermediate verification required.

Q. Can the SMC be extended beyond its expiry date?
Yes. If:

  1. a renewal verification has been completed; and
  2. a new Safety Management Certificate cannot be issued or placed on board the ship before the expiry date of the existing certificate.

The Administration or organization recognized by the Administration may endorse the existing certificate and such a certificate should be accepted as valid for a further period which should not exceed five months from the expiry date.

Q. In which situations can an interim DOC may  be given to a company?
An Interim Document of Compliance may be issued to facilitate initial implementation of this Code when:

  1. a Company is newly established; or
  2. new ship types are to be added to an existing.

Q. What conditions must be satisfied by the company?
Issuing authority must verify that:

  1. the Company has a safety management system that meets the objectives of paragraph 1.2.3 of this Code;
  2. the Company demonstrates plans to implement a safety management system meeting the full requirements of this Code within the period of validity of the Interim Document of Compliance.

Q. For what period, the above DOC is issued?
Such an Interim Document of Compliance should be issued for a period not exceeding 12 months.

Q. Why, you may have only a copy of DOC on board?
The original is kept in the office. A copy of the Interim Document of Compliance should be placed on board in order that the Master of the ship, if so requested may produce it for verification by;

  1. the Administration or by an organization recognized by the Administration; or
  2. the Pot State Control referred to in regulation IX/6.2 of the Convention.

Q. In which situations, an Interim SMC may be issued?
An Interim Safety Management Certificate may be issued:

  1. to new ships on delivery;
  2. when a Company takes on responsibility for the operation of a ship which is new to the Company; or
  3. when a ship changes flag. Such an Interim Safety Management Certificate should be issued for a period not exceeding 6 months.

Q. Can its validity be extended?
An Administration or, at the request of the Administration, another Contracting Government may, in special cases, extend the validity of an Interim Safety Management Certificate for a further period which should not exceed 6 months from the date of expiry.

Q. What are the conditions on which an Interim Safety Management Certificate may be issued to a ship?
It will be issued following verification that:

  1. the Document of Compliance, or the Interim Document of Compliance, is relevant to the ship concerned;
  2. the safety management system provided by the Company for the ship concerned includes key elements of this Code and has been assessed during the audit for issuance of the Document of Compliance or demonstrated for issuance of the Interim Document of Compliance;
  3. the Company has planned the internal audit of the ship within three months;
  4. the Master and officers are familiar with the safety management system and the planned arrangements for its implementation;
  5. instructions, which have been identified as being essential, are provided prior to sailing; and
  6. relevant information on the safety management system has been given in a working language or languages understood by the ship’s personnel.

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