Safety Management System(ISM Code) & latest amendments

Ship owners and managers should have defined procedure for the safety of their personal, environment and equipment. To ensure all this there should a proper safety management system. To achieve this safety ambition in shipping sector IMO (International Maritime Organization) has adopted ISM Code (International Safety Management Code) on 4th Nov 1993 for the safe operation of ships and pollution prevention, in accordance with SOLAS, MARPOL, and STCW. The ISM Code becomes mandatoryonOn 1st July 1998: All passenger ships / high-speed crafts, all cargo high-speed craft, all tankers, all gas carriers and all bulk carriers of GRT 500 and above. By 1st July 2002: All cargo ships and all mobile offshore drill units (Self-propelled) of GRT 500 and above.

ISM code gives only the guidelines to these companies/agencies for developing their Safety Management System or SMS. On the basis of these guidelines, the company prepares their safety management manuals (SMS manuals). These manuals contain responsibility of each and every individual associated with that ship (includes ship’s crew and shore staff), all standard procedures and ships documentation procedure. All these manuals kept onboard at various location. On joining a ship every seafarer has to read and sign these manuals, which indicates that they are familiar with the standard company procedure. SMS manuals are also kept ashore with of the company. Before ISM was adopted by IMO if any accident/incident happens the sea staff was held responsible for it. But after this sea and shore staff, both are liable to take the blame for that incident.

Objectives of ISM Code:

  1. To cover the safety of life
  2. To Prevent Human injury and loss of life
  3. To avoid damage of environment
  4. To avoid damage of machinery, ship or environment
  5. To provide a framework for the achievement of Total Quality System i.e continuously improve safety management skills of personnel aboard and ashore, including preparation for emergencies related to safety and environment both.

To achieve this objective there is two part of ISM Code:

  • Part A-Implementation
  • Part B- Certification and Verification

To cover the purpose and objective of the code there are total 13 clauses are defined:

  1. General Objective, application, and functional requirements
  2. Safety and environmental policy and SMS
  3. Company responsibility
  4. Designated person
  5. Masters responsibility
  6. Resources and personnel
  7. Developments of plans for shipboard operation
  8. Emergency preparedness
  9. Report and analysis on non-conformities, accidents, and hazardous occurrence
  10. Maintenance of ship equipment
  11. Documentation
  12. Company verification, review, and evaluation
  13. Certification, verification, and control

Company Responsibility and authority:

  1. If 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.
  2. 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.
  3. 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 their functions.

In short, we can conclude that the company is responsible for providing the instructions to the persons working on ship and shore, in form of SMS manual and company need to provide all the support to run the ship in safe and healthy condition. The Company should ensure that the SMS operating on Board the ship contains a clear statement emphasizing the master’s authority. The Company should establish in the SMS that the master has the overriding authority and the responsibility to make decisions with respect to safety and pollution prevention and to request the Company’s assistance as may be necessary.

Masters Responsibility and authority:

  • Review and report

It is the responsibility of the master to review the effectiveness of the SMS on board. If any deficiencies or correction is there then master should report to the company and suggest for good implementation.

  • Implement of Safety and Environment Protection Policy

It is masters’ responsibility to maintain the effectiveness of the safety culture and environmental protection on the ship by effectively following SMS manual.

  • The motivation of the crew in observing the policy
  • Issuing the order and instructions for the safe and healthy environment

Designated Person Ashore (DPA)

  • ISM Code makes mandatory for the company to designate a person at the shore, who can provide a link between ship and company.
  • DPA having the authority to direct access to the highest levels of management.
  • DPA is a responsible and authorized person to provide for the safe operation of the vessels. He should monitor the safety and pollution prevention aspect of the operation of each vessel and ensure there are adequate shore side resources and support.

Documents of ISM Code

As per the ISM Code, there are two statuary certificates –

  1. DOC (Document of Compliance)
  2. SMS (Safety Management Certificate)

Document of Compliance (DOC)

DOC is issued to the onshore organization (Company) by flag state or classification society on behalf of the flag state, after a successful audit of the shoreside aspect of the Safety Management System.  DOC is valid for 5 years from the date of issue. It is subject to annual verification.

Document of Compliance is issued to the company. For a different type of fleet different DOCs are issued. For example, if a company is having 100 ships, out of which 30 are tankers, 25 bulk carriers and rest are containers, Flag state will issue three DOCs, one for each type of fleet. Original DOC is kept with the company and a copy of the same must be kept at the ship.

Interim DOC: 

It is for a new company or for an existing company if new ship-type enters the company’s fleet. For DOC, the company is requested to submit SMS within a period of 12 months. It is valid for 12 months. Till this time flag state will issue an interim DOC after successful review and audit (of the company not ship), if the found company is complying with ISM Code (on paper). Within this twelve months, period flag state will conduct one detailed audit of the ship and onshore organization. On successful completion of this audit, Flag state will cancel Interim DOC and issue a Short Term DOC, as a proof of SMS compliance by the company. The validity period of this DOC is six months is issued instead of DOC. Once an original copy of DOC is issued, short-term Doc is scrapped.

Safety Management Certificate (SMC)

It is issued to the ships, after a successful audit and verifies that the company and its shipboard management operate in accordance with approved Safety Management System, SMS. This certificate having a validity of 5 years and required intermediate verification between a 2-3 year from the date of issue.

Interim SMC:

It is issued to the new ship at an initial level having a validity of 6 months. Within this 6 month, an audit is made by flag state or classification society. Once verified that approved safety management system is in place and being implemented and followed on board. Then the ship is issued short-term SMC until the main SMC is issued for 5 years.

Every shipping company should develop, implement and maintain Safety Management System SMS.

The safety management system of the company should ensure:

  1. Compliance with mandatory rules and regulations.
  2. The applicable codes, guidelines & standards recommended by the organization, administration, classification societies, and maritime industry organizations are taken into account.
SMS includes the following requirements:
  1. Safety and Environmental Protection policy.
  2. Instruction and procedure for safe operation of the ship, and protection of the environment, in compliance with International and Flag State Legislation.
  3. Lines of communication between Shore-based and Shipboard personnel.
  4. Procedures for reporting Accidents and Non-Conformities.
  5. Procedures for preparedness and response, to emergency situations.
  6. Procedures for Internal Audits and management reviews.

Quality/safety system should include the following levels:

  1. Quality/Safety Policy Manuals.
  2. Quality/Safety Procedures Manuals.
  3. Instruction Manuals.

Flag State Administration or Government or authorized body, issue Certificates valid for 5-years, after thorough Audit.

General Checklist for Audit:
  1. Certificates and documents including ORB, Logbooks.
  2. Safety in general.
  3. Testing and drills.
  4. Navigation equipment.
  5. LSA equipments
  6. FFA equipments
  7. Radio installation including GMDSS.
  8. Load Line.
  9. Machinery in the ER.
  10. Electrical equipment.
  11. Mooring equipment.
  12. Cargo gears.
  13. Hull construction.
  14. Marine pollution.
  15. Accommodation.
Main Drills in ISM:
  1. Lifeboat Drill
  2. Fire Drill
  3. Abandon Ship Drill
  4. Man Overboard Dill
  5. Enclosed Space Rescue Drill
  6. Oil Spill Response(SOPEP) Drill
  7. Emergency Steering Gear Drill
Recent Amendments in ISM Code

ISM code new edition, January 2018 included“Maritime Cyber Risk Management” in Section 3.8.8 [Ref: [MSC.428 (98)] and MSC-FAL.1/Circ.3]

Ship owner and manager must update their SMS with appropriate plan to address the cyber safety management before 1st January 2021 or the first annual verification of the company’s Document of Compliance (DOC) after 1st January 2021.

Area of concern:
  1. Bridge systems (ECDIS, GNSS, and other Navigational aid)
  2. Cargo handling and management systems ( Loadicato, container data recorder)
  3. Propulsion and machinery management and power control systems.
  4. Access control systems
  5. Passenger servicing and management systems.
  6. Passenger facing public networks
  7. Administrative and crew welfare systems
  8. Communication systems.
  9. Ship’s IT/computer and its software.

This management plan (SMS) includes:

  1. Identify the risk: Define personnel roles and responsibilities for cyber risk management and identify the systems, assets, data, and capabilities that, when disrupted, pose risks to ship operations.
  2. Protect the risk: Implement risk control processes and measures, and contingency planning to protect against a cyber-event and ensure continuity of shipping operations.
  3. Detection: Develop and implement activities necessary to detect a cyber-event in a timely manner.
  4. Respond: Develop and implement activities and plans to provide resilience and to restore systems necessary for shipping operations or services impaired due to a cyber-event.
  5. Recover: Identify measures to back-up and restore cyber systems necessary for shipping operations impacted by a cyber-event.
Training requirement:

Crew and shore staff may require to get appropriate training to deal with this requirement.

References:  Maritime Cyber Risk Management – ClassNK.

 Some important terminology:

Company:– Means the owner of the ship or any other organization or person such as the manager, or the bareboat charterer, who has assumed the responsibility for the operation of the ship from the shipowner and who, on assuming such responsibility, has agreed to take over all duties and responsibility imposed by the Code.

Non Conformity:– When objective evidence indicates nonfulfillment of a specific requirement stated by the safety management system, a situation of non-conformity is considered to have occurred.

Major Non-Conformity:– A major non-conformity is an extremely serious situation which poses a serious threat to the safety of personnel, ship, or the environment. It indicates a major lapse in the effective and systematic implementation of the ISM Code. Major nonconformity would require immediate corrective action to be taken by the ship’s management.

Anniversary Date:- Anniversary date can be defined as the day and month of each year which marks the expiry of a relevant certificate or document of the ship under the ISM Code.

Administration:– It means the governments of the state whose flag the ship is entitled to fly.

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Moshiur Rahman

Ex-chief engineer, Maersk line fleet and ex-classification society surveyor and Auditor

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