ISM Code and implementation of the SMS
This page provides an overview of the objectives, responsibilities and documentation of the ISM Code as they apply to the ship's master. It further summarises the practical elements of the implementation, functions and verification of the ISM safety management systems on board ships.
Introduction to the ISM Code
The original catalyst for introducing the ISM Code dates back to the 1980s when there were increasing concerns about significant maritime disasters caused by poor management of ships.
On the 6th March 1987, the Herald of Free Enterprise, a roro-pax vessel capsized, killing many passengers and crew. A UK government public inquiry into the disaster attributed the losses to a "disease of sloppiness" which had "infected the body corporate from top to bottom" (Sheen, 1987).
The inquiry revealed errors by shore-based and shipboard management, which led to a laissez-faire culture on board their ships, whereby procedural lapses allowed systemic failures to become routine practice. On the night of the 6th of March, this culture meant the crew failed to lock watertight doors at the forward end of the vehicle deck.
The surviving crew stated such actions had occurred regularly before the fateful night, as leaving the doors open was the easiest way to ventilate the car decks of engine fumes.
As the vessel moved away from the berth in Zeebrugge, Belgium, none of the Bridge team noticed the open bow door and the vessel proceeded at over 18 knots out into the North Sea.
The sudden, inevitable deluge of seawater rapidly surpassed the vessel's ability to clear water from her decks, and within moments of departing the breakwaters, the vessel began listing 30˚ to port. However, the resultant-free surface of the water ingress caused the vessel to eventually capsize.
This sequence of events played out in only 90 seconds, and less than six cables from shore, the vessel came to rest on a sandbar partially submerged at the side.
The result was that one hundred and ninety-three lives were lost.
The UK government, driven to act on the catastrophe, called for action from the IMO, which responded by proposing broad guidelines for the use of ship’s crew on the safe management of ships.
In response, the Assembly, the highest governing body of the IMO, then in its 15th session, adopted Resolution A.596 (15), which ordered the Maritime Safety Committee to draw up guidelines concerning on-board and shore-based management to ensure the safe operation of RoRo passenger ferries.
A year later, in October 1989, the Assembly, then in its 16th session, adopted Resolution A.647, which broadened the application of the guidelines to all ships, in recognition of the universal need for sound management practices.
The result was the ISM Code, the International Code for the Safe Operation of Ships and for Pollution Prevention, whose purpose was to ensure the safety of life at sea by preventing human injury and loss of life. It also sought to avoid damage to the marine environment and ships.
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Which IMO instruments mandated the ISM Code?
Amendments were made to the 1974 International Convention for the Safety of Life at Sea in 1994.
They introduced Chapter IX to SOLAS, which came into force on the 1st of July 1998. Chapter IX contained six regulations that made the requirements of the ISM Code mandatory.
The ISM Code has been amended several times since then, with the most recent amendment entering force on 1st January 2015.
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Major elements of the ISM Code
The ISM Code consists of two parts.
Part A contains 12 elements related to implementing the code. These prescriptive elements place responsibility for the safe and clean operation of ships on the Master, the DPA and the company, without giving explicit instructions. The 12 elements are:
- General which includes definitions, objectives and application of the ISM Code
- Safety and environmental protection policy
- Company responsibility and authority
- Designated person ashore
- Master’s responsibility and authority
- Resources and personnel
- Development of plans for shipboard operations
- Emergency preparedness
- Reports and analysis of non-conformities, accidents and hazardous occurrences
- Maintenance of the ship and equipment
- Documentation
- Company verification, review and evaluation
Part B of the code pertains to certification and verification of compliance with the code. Part B elements are:
- Certification and periodical verification
- Interim certification
- Verification
- Forms of certificates
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Objectives and principles of the ISM Code?
The ISM Code provides an international standard for the safe management and operation of ships and pollution prevention. The ISM Code aims to ensure safety at sea, prevent human injury and loss of life, and avoid damage to property and pollution of the marine environment. To ensure these aims are met, the code has three general safety management objectives:
- To ensure safe practice in ship operations and a safe working environment
- To assess all identified risks to ships, their personnel and the environment, and establish safeguards
- To ensure constant improvement of safety management skills of personnel ashore and aboard, as well as preparation for safety and environmental emergencies
The principles of ISM can be summed up by the following maxim:
Say what you do, do what you say, and record it.
By ‘saying what you do’, you are analysing the task at hand, and putting in place a safe procedure so that crew members can tackle it. Each procedure must be drafted with the full awareness of the legislative, pollution prevention and industry requirements.
By ‘doing what you say’, you are ensuring that the job is performed according to defined procedures and that no risky deviation, corner-cutting, error or omission occurs.
By ‘recording’ the successful completion of the job, you are providing an audit trail verifying your ongoing compliance with the safety management system, and establishing objective and traceable data which may be reviewed during an accident or incident investigation.
Regardless of how any SMS is structured to be successful, it will meet these three general principles.
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Verification schedule under ISM Code
The ISM certification process, initiated at the request of a company, consists of the following stages:
- Initial verification, after which interim and, eventually, full certification will be issued
- Annual verification of the company DoC
- Intermediate verification of the Safety Management Certificate (SMC) between the second and third anniversary of the issue
- Renewal verification for both on the fifth anniversary of the issue
- Additional verification whenever further surveillance is deemed necessary by flag or port state inspections
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What is an observation? Give an example.
An observation is a statement of fact made during an ISM audit that is substantiated by objective evidence. An example of this would be objective evidence showing that a certain record is unavailable. If LSA safety checks for June were missing, but all equipment and other records were present and correct, this would suggest that the records had gone missing, not that the crew had failed to carry out checks as required by the SMS.
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What is non-conformity? Give an example.
A non-conformity is an observed situation where objective evidence indicates the non-fulfilment of a specific requirement of the SMS.
An example of this might be when objective evidence shows that pre-arrival checklists were not completed on multiple occasions due to the time constraints of arriving in port. Since SMS explicitly requires the completion of these forms, failure to do so beyond an isolated clerical error constitutes a non-conformity.
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What is a major non-conformity? Give an example.
A major non-conformity is a deviation that:
- poses a serious threat to the safety of personnel or the ship, or
- poses a serious risk to the environment that requires immediate corrective action, or
- shows a lack of effective, systematic implementation of a requirement of the code
An example of this would be when objective evidence indicates that a vessel is insufficiently manned, according to the Minimum Safe Manning Document. Here, the vessel cannot set sail until the principles of safe manning are observed.
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Certification required under ISM and periods of validity.
A Document of Compliance (DoC) is issued to every company which meets the requirements of and complies with the ISM Code.
The DoC can be issued by the vessel’s flag state administration, by a recognised organisation, or by another contracting government at the request of the flag state administration. A copy of the DoC must be retained on board the vessel for inspection.
A #DOC certificate or Document of Compliance is a safety certificate issued to the #shipping companies in compliance with the #ISM Code 1998 under chapter IX of #SOLAS. This includes a set of guidelines to be followed.https://t.co/xcWCVDKHh8
— Shipfever (@Shipfever1) July 30, 2020
A Safety Management Certificate (SMC) is issued to every ship by the flag state or by a recognised organisation at the request of the flag state. The SMC certifies that the vessel and the on board management conform fully to the safety management system.
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How the company should verify the proper operation of the SMS
To ensure that the safety management system is functioning properly, the company should carry out internal safety audits on board and ashore at intervals not exceeding 12 months. In exceptional circumstances, no more than three months may exceed this.
Personnel carrying out the audits should be independent of the areas being audited unless this is impractical due to the size and nature of the company.
Audits and any corrective action should be carried out under documented procedures.
The results of audits and reviews should be brought to the attention of all personnel with responsibilities in the area involved.
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Preparations for audits under the ISM Code
For a properly functioning ISM safety management system, preparations for an ISM audit should be minimal. Preparations should be limited to ensuring that the correct documents, certificates, procedures, records and reports are on hand and can be accessed during the briefing interview with the auditor. These include:
- PM records
- Hours of rest
- Officer and crew certificates
- Record of non-conformities and master’s review
- Crew training and drill record
- Checklist folders for procedures
- Crew familiarisation records
- Bridge and navigation records
- Up-to-date bridge p/ps, corrections and publications
- Drill and training records
- Procedures in place for principal operations
- Procedures being followed
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How will the ship's master ensure the SMS is functioning correctly on board the vessel
Given the wide scope of the Safety Management System, verifying the implementation of the SMS on an ongoing basis is best achieved by using a sampling process.
The ship's master can review the various records monthly to ensure that the required actions are being correctly performed. They could then check for defects and records of incidents and accidents.
The ship's master should ensure that the required training and drills are being conducted on an ongoing basis.
This is achieved most easily while preparing the monthly export of SMS records to the company.
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How the ship's master would implement the Environmental Protection Policy
The ship's master would implement the environmental protection policy by ensuring that he has an overview of the tenets of MARPOL annexes 1 to 6 and verify that these are being followed. He should check that all associated documents and certificates are being correctly observed.
The ship's master should also motivate the crew to meet the following requirements:
- Anti-fouling certificate is in place and good order
- Ballast water management plan is in place and being demonstrably observed
- Garbage management plan is in place and is being met
- SEEMP is in place and being incorporated
- ODME equipment is functioning and being correctly recorded in the ORB
- Fuel SOX change-over records are complete
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How the SMC would be affected if a vessel was laid up for four months and the crew stood down. What subsequent actions would be required to remedy the situation?
Given that the vessel is not operating, we assume the SMS is dormant.
A dormant safety management system can no longer be considered able to ensure the safe operation of ships and the prevention of pollution.
If no more than three months’ worth of evidence is available, the master must arrange an initial audit of the vessel.
For more information, please see the IMO Guidelines for the reactivation of the Safety Management Certificate following an operational interruption of the safety management system due to lay-up over a certain period, MSC-MEPC.7/Circ.9 (14th July 2014).
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