How is an ISM SMS structured?
This page explores how to structure a ship's safety management system (SMS), regarding the IMO and ISM Code requirements.
How is the ship's ISM SMS structured?
There is really no ideal structure for a ship's SMS, as each ship is different.
However, S1.4 of the ISM Code sets out the functional requirements of a company SMS, which can start as the starting point for establishing a structure. Briefly, these include:
- safety and environmental policies
- instructions and procedures to ensure safe, clean and compliant operation of their ships
- defined levels of authority and communication, including between their ships and shore teams
- non-conformity and accident reporting
- emergency response procedures
- procedures for internal audits and review of the SMS by vessel managers
Each requirement is fleshed out further by the elements of the ISM Code. They are:
1. General
2. Safety and environmental protection policy
3. Company responsibilities
4. Designated person
5. Master’s responsibility and authority
6. Resources and personnel
7. Operational conditions and requirements
8. Emergency preparedness
9. Reports and analysis of non-conformities and accidents
10. Maintenance
11. Documentation
12. Company verification, review and evaluation
While these functional requirements cover quite broad themes, when given full effect in relation to the ISM Code elements, they generate quite a volume of policies, plans and procedures. Taken altogether, this creates quite a lot of documentation.
These documents must be structured into a useable and controllable system for deployment on board the company’s fleet.
In my experience, this system is often broken down into manageable sections or manuals.
Examples of this could be:
1. Company and organisational policies
- Mission value statements
- Company responsibility statements
- Safety and environmental policy statements
- Company organogram and reporting lines
- DPA identified and contact details
- Company contact details
- Management review, internal and external audits
- Document control requirements
2. Personnel policies and practices
- General responsibilities
- Ranking and role responsibilities
- Master’s responsibility and authority statement
- Develop training matrix for ship and shore-based crew
- Onboarding drills and emergency training/equipment requirements
2. Vessel operations manual
- General requirements for the development and verification of shipboard operations
- Maintenance of records on board
- Inspection and maintenance of equipment
- Safety management meetings
- Crew familiarisation procedures
3. Health and safety manuals
- Hazard registration and identification
- Risk assessments and operational checklists
- Crew PPE requirement matrix
- Permits to work system for identified tasks
- Reporting requirements for accidents, incidents and mishaps
- Inspection requirements
4. Navigation manual
- Navigation watch and equipment standards
- Passage planning requirements
- Voyage records
- Bridge checklists
- Navigational emergency procedures
5. Cargo operations manual
- General and specific cargo requirements and procedures depending on vessel type
6. Technical manual
- ER watch arrangements
- Bunkering and lube oil records
- Dry-docking procedures
- Operational guides for engineering tasks
7. Emergency preparedness
- Emergency procedures for at sea and in port
- Emergency and company reporting requirements
Further guidance on how to help structure a ship's SMS can be found in MSC-MEPC.7/Circ.8: Revised guidelines for the operational implementation of the ISM Code by companies.