ISM Code – All you should know about International Safety Management Code

ISM code is International Safety Management code for the safe operation of ships and for pollution prevention, as adopted by IMO assembly.

The basic principles of the ISM code

1. Safety of people on board
2. Safety of the ship and cargo
3. Safety of environment

The Code establishes safety management objectives and requires a safety management system (SMS) to be established by “the Company”, which is defined as the shipowner or any person, such as the manager or bareboat charterer, who has assumed responsibility for operating the ship. The Company is then required to establish and implement a policy for achieving these objectives. This includes providing the necessary resources and shore-based support. Every company is expected “to designate a person or persons ashore having direct access to the highest level of management”.The procedures required by the Code should be documented and compiled in a Safety Management Manual, a copy of which should be kept on board.

Responsibilities of safety could not be left entirely to the master of the ship alone. The cornerstone of good safety management is the commitment from the top. In matters of safety and pollution prevention, it is the commitment, competence, attitude and motivation of individuals at all levels that determines the end result.

Amendments to the ISM Code

The ISM Code was amended in December 2000 by resolution MSC.104(73), and these amendments entered into force on 1 July 2002. It was further amended in December 2004 by resolution MSC.179(79), and these amendments entered into force on 1 July 2006. It was further amended in May 2005 by resolution MSC.195(80), and these amendments entered into force on 1 January 2009. The ISM Code was also amended in December 2008 by resolution MSC.273(85). This resolution was adopted on 1 January 2010, and the amendments entered into force on 1 July 2010. The Code was further amended in June 2013 by resolution MSC.353(92) and these amendments entered into force on 1 January 2015.

Important Definitions

1. The company is the owner of the ship or any other organization or person such as a manager or bareboat charterer, who has responsibility for the operation of the ship from the owner, and who on assuming responsibility has agreed to take over all duties and responsibilities imposed by the code.
2. The administration is the Government of the State whose flag the ship in entitled to fly.
3. Safety Management System is a structured and documented system enabling the company and its personnel to implement effectively the safety and environmental protection policy.
4. Document of Compliance is a document issued to a company complying with Code’s requirements.
5. Safety Management Certificate is a document issued to a ship signifying that company and its shipboard management operate in accordance with the approved SMS.
6. Objective Evidence is qualitative or quantitative information, records or statements of fact pertaining to safety or the existence and implementation of a safety management system element, which is based on observation, measurement or test and which can be verified.
7. Observation is a statement of fact made during a safety management audit and substantiated by objective evidence.
8. Non-conformity is an observed situation where objective evidence indicates the non-fulfilment of a specified requirement.
9. Major non-conformity is 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 and includes the lack of effective and systematic implementation of a requirement of this code.
10. The anniversary date is the day and month of each year corresponding to the expiry date of relevant document or certification.
11. The convention is SOLAS 1974 as amended.

The objective of SMS is to ensure compliance with mandatory rules and regulations; and that applicable codes, guidelines and standards recommended by IMO, administrations, classification societies and maritime industry organizations are taken into account.

Functional requirements for SMS

Every company should develop, implement and maintain SMS which includes 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 level 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.
6. Procedures for internal audits and management reviews.

Responsibilities

Company

If the owner is not responsible for the implementation of the code, he must inform the Flag State Administration (FSA) the name and details of the entity.
The company should define and document responsibilities, authorities, and interrelation of all personnel who manage, perform and verify work related to and affecting safety and pollution prevention.
Company is responsible for ensuring that adequate resources and shore-based support are provided to enable DPA to carry out their functions.

Company should:

1. Ensure that the ship is manned with qualified, certificated and medically fit seafarers in accordance with national and international requirements.
2. Establish procedures to ensure new personnel and personnel transferred to new assignments related to safety and environment protection are given proper familiarization with their duties.
3. Identify essential pre-sailing instructions and have it documented and be given to all concerned.
4. Ensure all personnel are familiar with the SMS and have an adequate understanding of all relevant rules, regulations, codes and guidelines.
5. Establish and maintain procedures for identifying any training required in support of SMS and ensure such training is provided for personnel concerned.
6. Establish procedures by which the ship’s personnel receive relevant information on the SMS in a working language or languages understood by them.
7. Ensure that the ship’s personnel are able to communicate effectively in the execution of their duties related to the SMS.

DPA (Designated Person Ashore)

DPA is the Designated Authority Ashore. The person responsible is to ensure safe operation of each ship and provide a link between the company and the crew.

The DPA should have direct access to the highest level of management.
Responsibility and authority of the DPA should include monitoring safety and pollution prevention aspects of the operation of each ship and ensuring adequate resources and shore-based support are applied, as required.

Master

Master’s responsibilities and authorities are:

1. Implementation of the safety and environmental protection policy of the company motivating the crew in the observation of the policy.
2. Motivating the crew in the observation of the policy issuing appropriate orders and inspections in a clear and simple manner.
3. Issuing appropriate orders and inspections in a clear and simple manner and verifying that specified requirements are observed.
4. Reviewing the SMS and reporting its deficiencies to shore based management.

The company should ensure that SMS operating on ship contains a clear statement emphasizing the master’s authority. The Company should ensure that the master is properly qualified for command, fully conversant with the company’s SMS and given the necessary support for the safe performance of the master’s duties. The company should establish in SMS that the master has the overriding authority and responsibility to make decisions with respect to safety and pollution prevention and to request company’s assistance as may be necessary.

ISM Code Implementation on Ship

1. Development of plans for shipboard operations, instructions and checklists for key shipboard operations concerning the safety of the ship and pollution prevention. Tasks involved should be defined and assigned to qualified personnel.
2. Emergency preparedness to respond to onboard emergencies. The company should establish programs for drills and exercises to prepare for emergency actions.
3. Reports and analysis of non-conformities, accidents, and hazardous occurrences. SMS should include procedures to report and analyze above. All incidents are to be investigated with the objective of improving the safety and pollution prevention record. Procedures are established for implementation of corrective action.
4. Maintenance of the ship and equipment.

This will include:

• inspections are held at appropriate intervals; any non-conformity is reported with its cause if possible; appropriate corrective action is
• inspections are held at appropriate intervals
• any non-conformity is reported with its cause if possible appropriate corrective action is
• appropriate corrective action is taken and records of these activities are maintained;
• all equipment and systems are tested regularly
• inspections and measures as above must be integrated into ship’s operational maintenance routine

5. Documentation should ensure that valid documents are available at all times, changes in documentation are reviewed and approved by authorized personnel and obsolete documents are promptly removed. Documents are incorporated in the SMS manual.
6. Company verification, review, and evaluation should ensure audits are conducted at regular intervals. Corrective actions should be carried out. Auditors should be independent.

Certification and Verification

A ship can only be operational with a valid DOC (Document of Compliance) issued to a company. DOC is valid for ship types it lists e.g. tanker, gas carrier, container ship etc. DOC is issued by the FSA (Formal Safety Assessment) and valid for 5 years, with annual verification by FSA within 3 months before or after the anniversary date. A copy of the DOC must be kept on board and need not be authenticated or certified.
DOC can be withdrawn if the annual verification is not requested or there is a reported major non-conformity. If a DOC is withdrawn, all associated SMC (Safety Management Certificate) or ISMC (Interim Safety Management Certificate) will be withdrawn.

SMC (Safety Management Certificate) is issued to ship by the FSA. The period of validity for SMC is 5 years with annual verification within 3 months before or after the anniversary date. Interim verification is done between 2nd and 3rd-anniversary dates. SMC can be withdrawn if the annual verification is not requested or there is a reported major non-conformity.

IDOC (Interim Document of Compliance) is issued to a company newly established or a new type of ship is added to an existing DOC.  IDOC is issued by the FSA and valid for not more than 12 months.

ISMC (Interim Safety Management Certificate) is issued to a new ship on delivery or when a company takes on responsibility for the operation of a ship which is new to the company or when a ship changes flag. ISMC is issued by the FSA and valid for not more than 6 months but can be extended as a special case by the FSA.

IMSC is issued after verification that:

1. DOC or IDOC is relevant to the ship;
2. SMS provided by the company for the ship includes key elements of ISM code and has been assessed during the audit for issuance of DOC or IDOC;
3. the company has planned a ship audit within 3 months;
4. master and officers are familiar with SMS and planned arrangements for its implementation;
5. essential pre-sailing inspections are provided; and
6. relevant information on SMS has been given in working language (s) understood by ship’s personnel.

Questions and Answers

Q1. How will you ensure from your Office that the ship you are joining is a safe ship (before joining)? – *In context of ISM code

A. By checking DOC, SMC, SMS Manuals, Internal / External audits reports, PSC & Flag state deficiency reports.

Q2. How does company ensure compliance with ISM Code?

A. By conducting Internal / External Audits.

Q3. What do you understand by SMM or Safety Management Manual?

A. It is the documentation used to describe and implement the Safety Management System (SMS).

Q4. What do you understand by “Audit ” and an “Auditor”?

A. “Audit” means a process of systematic and independent verification, through the collection of objective evidence, to determine whether the SMS complies with the requirements of the ISM Code and whether the SMS implemented effectively to achieve the Code’s objective.

“Auditor” means a person who is qualified and authorized to carry out ISM audits in accordance with the requirements of ISM code.

Q5. What is “Internal” and “External” Audits?

A. Internal Audit: Carried out by the company itself. This is to ensure that all the on board practices and methods are in accordance with the SMS.

External Audit: Carried out by the classification bureau and a DOC is granted only if the conditions are met satisfactorily.

Q6. Can an SMC audit be carried out whilst the vessel is in Dry-Dock?

A. No, since the vessel is not considered operational at that time.

Q7. What are the bare-bones of a S.M.S?

A. The Code of Safe Working Practice

Q8. What level of management can D.P.A approach?

A. Straight to the Top (Chief Executive)

Q9. What ships does ISM Code apply to?

A. From 2002 onwards, all ships over 500 grt.

Q10. What size of ships should voluntarily use ISM Code?

A. Ships between 150 grt and 500 grt.

Q11. Where are the DOC and SMC kept at?

A. They are kept onboard the vessel.