Company Safety and Environmental Policy
The policy establishes the company’s commitment to safe operations, pollution prevention and the implementation of its Safety Management System.
PAMS Pacific Admiralty Maritime Services | Maritime Technical Article
The ISM Code and Safety Management Systems: A Practical Maritime Guide
An independent technical overview of the International Safety Management Code, Safety Management System documentation, operational risk controls, emergency preparedness, internal audits, corrective actions and continuous improvement in ship operations.
Understanding the International Safety Management Code
The International Safety Management (ISM) Code establishes an international framework for the safe management and operation of ships and for pollution prevention. It emphasizes the responsibilities of shipping companies, the implementation of a Safety Management System (SMS), the identification of operational risks and the establishment of appropriate safeguards.
Effective ISM compliance involves more than preparing an ISM manual or maintaining a collection of procedures. The company’s documented system must be suitable for its operations and supported by practical implementation, defined responsibilities, adequate resources, reporting arrangements, maintenance controls, emergency preparedness and management oversight.
The ISM Code applies within the scope established by the applicable international requirements and the vessel’s statutory circumstances. Owners, operators and technical managers should determine the requirements applicable to their individual ships and company operations.
Core principle:
An effective Safety Management System connects company policy,
shipboard procedures, shore-based support, risk control, operational
implementation and continual improvement. Documentation should reflect
how the organization actually manages safety and pollution prevention.
What Is the Purpose of the ISM Code?
The ISM Code provides a structured approach to managing safety and preventing pollution through organized responsibilities, procedures, risk controls and verification. It supports the development of a safety management culture in which both shore-based and shipboard personnel understand their duties and follow the company’s established system.
Safe Ship Operations
Establishing procedures and controls appropriate to the vessel, its equipment, intended operations and foreseeable operational hazards.
Pollution Prevention
Supporting the implementation of operational precautions, environmental safeguards and applicable pollution-prevention requirements.
Defined Responsibilities
Establishing clear responsibilities, authority, communication arrangements and lines of reporting between the company and shipboard personnel.
Continual Improvement
Identifying deficiencies, investigating relevant incidents, implementing corrective actions and reviewing the effectiveness of the Safety Management System.
What Is a Safety Management System?
A Safety Management System is the documented and implemented framework through which a shipping company manages safety and pollution prevention. It establishes policies, responsibilities, procedures, operational controls, reporting processes and verification arrangements relevant to the company’s activities.
The SMS should be understandable and usable by the people expected to apply it. Procedures that are excessively complicated, outdated, inconsistent with actual operations or poorly communicated can weaken the practical effectiveness of the system.
Responsibilities and Authority
Defined responsibilities help establish who makes decisions, who reports deficiencies, who authorizes relevant activities and who provides shore-based support.
Operational Procedures
Procedures describe how relevant shipboard and shore-based activities are controlled, including applicable safety precautions and reporting requirements.
Emergency Preparedness
Emergency arrangements define relevant response responsibilities, communication procedures, preparedness measures and applicable drills or exercises.
Reporting and Corrective Action
Reporting processes support the identification of accidents, hazardous occurrences, non-conformities and other matters requiring investigation or corrective action.
Verification and Management Review
Internal audits, monitoring and management review help determine whether the system is implemented effectively and whether improvements are required.
ISM Manual and Safety Management System Documentation
ISM documentation provides the structure through which a company communicates its safety-management arrangements. The documentation should describe applicable responsibilities, procedures, controls and verification processes without creating unnecessary duplication or conflicting instructions.
The exact documentation structure depends on the company, vessel types, operational profile and applicable requirements. An ISM manual should not be treated as a substitute for effective implementation onboard and ashore.
Document Control
Documents should be identifiable, reviewed and maintained under appropriate controls. Personnel should have access to the applicable versions of instructions and procedures.
Procedure Consistency
Related procedures should be consistent with company policy, assigned responsibilities, vessel operations and other relevant parts of the Safety Management System.
Records and Evidence
Relevant records can demonstrate that required activities, checks, reports, drills, reviews and corrective actions have been completed in accordance with the applicable system.
Periodic Review
Documentation should be reviewed when operational changes, audit findings, incidents, revised requirements or other relevant circumstances indicate that an update may be needed.
Documentation principle:
The quality of an ISM manual is not determined by its length. Its value
depends on whether it clearly communicates the company’s arrangements,
reflects applicable requirements and supports effective implementation.
Company Responsibilities Under the ISM Framework
The company responsible for the operation of a ship must establish and maintain the applicable Safety Management System in accordance with relevant requirements. Responsibilities must be allocated clearly so that safety-related decisions, communication and shore-based support operate effectively.
Shore-Based Support
The company should provide the support, resources, communication arrangements and oversight necessary for the effective operation of the Safety Management System.
Designated Person Ashore
Where required by the applicable ISM provisions, the designated person ashore provides a link between the company and those onboard and has access to the relevant level of shore-based management.
Master’s Authority
The Safety Management System must recognize the Master’s responsibilities and authority in relation to ship safety, pollution prevention and decisions necessary to protect the ship and persons onboard.
Personnel Familiarization
Relevant personnel should understand their duties, applicable procedures, emergency responsibilities and the safety controls associated with their assigned work.
Operational Risk Assessment and Safety Controls
Risk management is an important element of effective safety management. The company and shipboard personnel need arrangements for identifying foreseeable hazards, assessing relevant risks and applying suitable safeguards. The level of assessment should be appropriate to the activity and its potential consequences.
Risk assessments should support operational decisions rather than become a paperwork exercise. Controls need to be communicated, understood and applied, with additional measures considered when circumstances change or existing safeguards prove inadequate.
Hazard Identification
Identify relevant hazards associated with shipboard work, machinery, deck operations, cargo activities, maintenance, environmental conditions and emergency situations.
Risk Evaluation
Consider the potential consequences and likelihood of identified hazards using the company’s established risk-assessment method.
Existing Safeguards
Review the suitability of engineering controls, procedures, protective equipment, supervision and other safeguards applicable to the activity.
Additional Risk Controls
Identify additional precautions or corrective measures where existing controls do not adequately address the identified risks.
Communication and Implementation
Ensure that relevant personnel understand the identified risks, assigned precautions and responsibilities before the activity proceeds, where required by the applicable procedures.
Review After Change
Reassess relevant controls when working conditions, equipment, procedures or operational circumstances change materially.
Emergency Preparedness and Response
Emergency preparedness is a fundamental part of a functioning Safety Management System. Ships may encounter fire, flooding, machinery failure, loss of propulsion, collision, grounding, pollution incidents, medical emergencies and other events requiring a coordinated response.
Emergency arrangements should identify applicable responsibilities, communication methods, response actions and available resources. The arrangements should be appropriate to the vessel and supported by relevant familiarization, drills, exercises and records in accordance with applicable requirements.
Emergency Procedures
Review whether documented emergency procedures address relevant foreseeable scenarios and clearly communicate the actions expected from responsible personnel.
Roles and Communication
Confirm that response responsibilities, reporting arrangements and communication methods are appropriately addressed in the applicable emergency plans.
Drills and Exercises
Review relevant drill arrangements, records, observations and follow-up actions to identify opportunities to improve emergency preparedness.
Lessons Learned
Relevant lessons from drills, incidents and exercises should be evaluated and used to improve procedures, preparedness and personnel understanding where appropriate.
Maintenance, Equipment Reliability and Defect Reporting
A Safety Management System should address applicable arrangements for maintaining the ship and its equipment in conformity with relevant requirements. Effective maintenance management supports operational reliability, helps identify deterioration and provides a framework for reporting and addressing defects.
The company’s procedures should address relevant inspections, testing, maintenance intervals, defect reporting, corrective action and the handling of equipment failures. Particular attention should be given to equipment and systems identified as safety-critical under the applicable company arrangements and requirements.
Planned Maintenance
Review relevant maintenance schedules, completion records and procedures for identifying overdue tasks and outstanding maintenance requirements.
Defect Reporting
Assess whether defects are reported, recorded, evaluated and communicated to the personnel responsible for deciding and implementing the appropriate response.
Safety-Critical Equipment
Review applicable maintenance and testing arrangements for designated safety-critical equipment and systems, within the agreed assessment scope.
Corrective Action Follow-Up
Consider whether identified defects are tracked to an appropriate conclusion and whether relevant outstanding risks are managed while corrective work is pending.
ISM Internal Audits and Verification
Internal audits provide a structured means of assessing whether the Safety Management System conforms to applicable requirements and whether it is effectively implemented and maintained. Audit arrangements should follow the applicable ISM requirements and the company’s documented procedures.
An effective audit considers objective evidence rather than relying solely on the existence of documents. Depending on the audit scope, evidence may include records, interviews, observed practices, procedures, maintenance information and the handling of previous findings.
Audit Planning
Define the audit scope, applicable criteria, arrangements, responsibilities and relevant areas of the Safety Management System to be examined.
Documentation Review
Examine applicable procedures, records and documented arrangements against the relevant audit criteria.
Implementation Verification
Consider whether actual practices and available evidence are consistent with documented procedures and assigned responsibilities.
Findings and Evidence
Record findings clearly, identify supporting evidence and distinguish confirmed non-conformities from observations or improvement opportunities.
Corrective Action Review
Review proposed corrective actions, their implementation and evidence of effectiveness in accordance with the applicable company procedures.
Follow-Up Verification
Confirm the status of relevant actions and identify unresolved issues that require further attention under the established audit and corrective-action process.
Verification principle:
A completed audit report alone does not establish that the Safety
Management System is effective. Relevant findings must be evaluated,
addressed through the applicable process and followed up appropriately.
ISM Non-Conformities and Corrective Action Management
Non-conformities, incidents, hazardous occurrences and other identified weaknesses should be managed in accordance with applicable requirements and company procedures. Effective handling involves more than recording a problem: the organization should determine what happened, evaluate contributing factors and implement appropriate measures to prevent recurrence where practicable.
Clear Identification
Describe the issue accurately, identify the relevant requirement or procedure where applicable, and retain sufficient supporting evidence.
Investigation
Examine relevant circumstances and contributing factors in accordance with the company’s procedures and the significance of the issue.
Immediate Control
Where necessary, establish appropriate immediate measures to manage the identified risk while a longer-term response is considered.
Corrective Measures
Define practical corrective measures, responsible persons and applicable completion arrangements according to the nature of the finding.
Evidence of Completion
Retain relevant records demonstrating the actions taken and their completion, in accordance with the applicable procedures.
Effectiveness Review
Consider whether the action addressed the identified issue and whether additional measures or changes to the Safety Management System are necessary.
Management Review and Continual Improvement
Management review helps the company evaluate the performance and continuing suitability of its Safety Management System. Relevant information may include audit results, incidents, non-conformities, corrective actions, operational changes, safety performance and feedback from shipboard personnel.
The review should lead to considered decisions where improvement is necessary. The objective is to maintain a system that remains relevant to the company’s operations and supports effective safety management rather than merely preserving existing documentation.
Review of Performance
Consider relevant audit outcomes, reports, identified risks, recurring deficiencies and other available indicators of SMS performance.
Evaluation of Recurring Issues
Determine whether repeated findings indicate a wider procedural, technical, communication or management issue requiring attention.
Updates to Procedures
Revise relevant documentation when justified by changed requirements, operational experience, findings or changes to company arrangements.
Verification of Improvement
Review whether implemented improvements have achieved their intended purpose and whether further action is necessary.
ISM Compliance, DOC and SMC
The ISM certification framework includes the Document of Compliance (DOC) associated with the company and the Safety Management Certificate (SMC) associated with the individual ship, as applicable under the relevant requirements. These certificates are subject to the applicable verification and certification arrangements.
Consultancy, documentation review and audit preparation can help an organization identify areas requiring attention. However, consultancy support does not itself issue, renew or guarantee an ISM certificate. Formal verification and certification remain the responsibility of the competent administration or duly authorized organization, as applicable.
Document of Compliance (DOC)
Relates to the company's compliance with the applicable ISM
requirements and the relevant certification process.
Safety Management Certificate (SMC)
Relates to the ship's compliance with the applicable Safety
Management System requirements and the relevant verification
process.
Verification Arrangements
The applicable initial, periodic, intermediate, renewal or
additional verification arrangements depend on the relevant
requirements and circumstances.
Consultancy Boundaries
Independent technical review can support preparation and
improvement but does not replace statutory verification,
certification or decisions of an authorized body.
Regulatory Framework and Related Requirements
ISM implementation should be considered alongside the regulatory requirements applicable to the vessel, company and intended operations. The precise obligations depend on the vessel's type, tonnage, service, flag, operational status and other relevant circumstances.
International Safety Management Code
The principal framework for the safe management and operation
of ships and pollution prevention within its applicable scope.
SOLAS
Applicable International Convention for the Safety of Life at
Sea requirements relevant to the vessel and its operations.
MARPOL
Applicable international requirements for the prevention of
pollution from ships.
Flag State Requirements
Relevant statutory requirements, instructions and verification
arrangements applicable to the ship's flag and status.
Company Procedures
Operational instructions, safety policies, risk controls and
documented arrangements established for the company's activities.
Applicable Industry Guidance
Relevant industry guidance may inform technical reviews where
appropriate, without replacing mandatory legal requirements.
Regulatory note:
Applicability should be determined using the current official
instruments and requirements relevant to the vessel and company.
This article is a general technical overview and is not a substitute
for reviewing the applicable legal provisions.
Common Safety Management System Weaknesses
The following areas may warrant attention during an independent technical review. Their presence should not be assumed for any particular company or vessel; findings must be established from the available evidence and the agreed scope of assessment.
Outdated Documentation
Procedures may not reflect current operations, organizational responsibilities, equipment arrangements or applicable requirements.
Unclear Responsibilities
Duties, authority, reporting channels or shore-based support arrangements may be insufficiently defined or understood.
Inconsistent Implementation
Observed practices may differ from documented procedures or available evidence may be insufficient to demonstrate implementation.
Weak Corrective-Action Follow-Up
Findings may remain open without adequate tracking, supporting evidence or a documented evaluation of effectiveness.
Inadequate Risk Controls
Risk assessments may not adequately address actual work conditions, operational changes or the effectiveness of existing safeguards.
Limited Learning from Incidents
Lessons from incidents, near misses, drills and audits may not be adequately evaluated or translated into appropriate improvements.
Independent ISM Technical Review and Consultancy
An independent technical review can provide an additional perspective on the documented and implemented Safety Management System. Depending on the agreed scope, the review may examine documentation, operational procedures, maintenance arrangements, risk assessments, emergency preparedness, audit findings and corrective-action records.
The objective is to identify evidence-based observations and practical opportunities for improvement. Any review should distinguish between confirmed findings, matters requiring further verification and recommendations for consideration by the responsible company.
Documentation Review
Examine relevant ISM manuals, procedures, records and supporting documents within the agreed scope.
Implementation Review
Compare available evidence and observed practices with the applicable documented arrangements and assessment criteria.
Gap Identification
Identify substantiated gaps, inconsistencies or areas requiring additional evidence, clarification or corrective action.
Technical Recommendations
Provide practical recommendations for consideration by the responsible company, consistent with the agreed assignment and applicable requirements.
Independence and scope:
PAMS Pacific Admiralty Maritime Services provides independent marine
surveying and technical consultancy. The scope of an ISM review is
defined by the assignment and does not confer statutory authority or
replace the responsibilities of the shipowner, operating company,
flag administration or authorized certification organization.
Practical ISM Review Process
A structured review helps organize the available evidence, identify relevant issues and communicate the results clearly. The precise process depends on the objectives of the assignment, the documentation available and whether the work is limited to document review or also includes interviews, observations or vessel attendance.
Scope Definition
Establish the review objectives, vessel and company context, applicable criteria, available documentation and limitations of the assignment.
Document Examination
Review the relevant ISM manual, procedures, records, audit findings, risk assessments and supporting information supplied for the assignment.
Technical Evaluation
Evaluate the available evidence against the agreed review criteria and identify inconsistencies or matters requiring further verification.
Findings and Recommendations
Present the findings in a clear structure, explain their significance where supported by evidence and identify practical recommendations for consideration.
Corrective-Action Planning
Where included in the agreed scope, help organize identified issues, proposed corrective measures and follow-up requirements.
Follow-Up Review
Where separately agreed, review available evidence of completed actions and identify outstanding matters requiring further attention.
Possible Deliverables of an ISM Consultancy Assignment
Deliverables depend on the agreed scope, the information provided and the nature of the work undertaken. The following are examples of possible outputs and should not be interpreted as a fixed package included in every assignment.
Technical Review Findings
A structured summary of the documentation, procedures or implementation areas examined and the findings supported by the available evidence.
Identified Gaps
A description of identified inconsistencies, missing evidence, potential weaknesses or matters requiring additional verification.
Recommendations
Practical technical recommendations for consideration by the company in addressing the findings and improving relevant safety-management arrangements.
Corrective-Action Review
Where agreed, a review of proposed or completed corrective actions and the available evidence of their implementation.
Related ISM Services, Case Study and Project
The following pages provide additional information about the ISM documentation service, a related case study and the ISM project reference published by PAMS Pacific Admiralty Maritime Services.
ISM Code and Safety Management System FAQ
What is the ISM Code?
The International Safety Management Code establishes an international framework for the safe management and operation of ships and for pollution prevention within its applicable scope.
What is a Safety Management System?
A Safety Management System is the documented and implemented framework of policies, responsibilities, procedures, operational controls and verification arrangements used to manage safety and pollution prevention.
What should an ISM manual contain?
The documentation should describe the company's applicable safety-management arrangements, responsibilities, procedures, reporting processes and verification controls. Its exact structure depends on the organization, vessel operations and applicable requirements.
Is having an ISM manual enough to demonstrate compliance?
No. Documentation alone does not demonstrate that a Safety Management System is effectively implemented. Relevant procedures, responsibilities, records, risk controls, audits and management arrangements must be applied in practice in accordance with applicable requirements.
What is the difference between a DOC and an SMC?
The Document of Compliance relates to the company under the applicable ISM certification framework, while the Safety Management Certificate relates to an individual ship. The applicable verification and certification requirements depend on the relevant circumstances.
Why are ISM internal audits important?
Internal audits help assess conformity with applicable requirements and whether the Safety Management System is implemented and maintained effectively. Findings should be documented and addressed through the applicable corrective-action and follow-up processes.
How should ISM non-conformities be handled?
Non-conformities should be recorded and addressed in accordance with applicable requirements and company procedures. Depending on the issue, this may include investigation, immediate risk controls, corrective measures, evidence of completion and review of effectiveness.
Does the ISM Code address emergency preparedness?
Yes. Emergency preparedness and response arrangements form an important part of the Safety Management System. Applicable procedures should address relevant foreseeable emergencies, response responsibilities, communication and preparedness measures.
Can an independent consultant review ISM documentation?
Yes. Depending on the agreed scope, an independent marine technical consultant may review ISM manuals, procedures, records, risk assessments, audit findings and corrective-action arrangements, and provide evidence-based technical observations and recommendations.
Does ISM consultancy guarantee certification?
No. Consultancy and audit preparation do not guarantee certification. Formal verification, certification and related statutory decisions remain with the competent administration or duly authorized organization, as applicable.
Can an ISM review include corrective-action follow-up?
Yes, where included in the agreed assignment. Follow-up may involve reviewing the evidence of actions taken, assessing whether identified issues have been addressed and recording outstanding matters requiring further attention.
What is the role of PAMS Pacific Admiralty Maritime Services in ISM consultancy?
PAMS Pacific Admiralty Maritime Services provides independent marine surveying and technical consultancy. Depending on the agreed scope, its work may include ISM documentation review, technical assessment, identification of gaps and practical recommendations. Such consultancy does not replace the responsibilities of the company or the authority of a statutory or certification body.
About the Technical Author
Technical Content Review
Article Subject
International Safety Management Code, Safety Management Systems, ISM documentation, operational risk management and maritime compliance.
Review Approach
The article is intended as a general technical overview. Applicable requirements should be checked against the current official instruments and the specific circumstances of the vessel and company.
Technical framework:
International Safety Management Code, applicable SOLAS and MARPOL
provisions, relevant flag-state requirements, company procedures
and applicable statutory verification arrangements.
Engineering and Regulatory Reference Notice
This article provides general technical information concerning the International Safety Management Code, Safety Management Systems, ISM documentation, risk assessment, internal audits, corrective action and maritime compliance. It is not legal advice, a statutory interpretation for a particular vessel or a substitute for reviewing the current official requirements. Applicability depends on the vessel, company, flag, operational profile and relevant circumstances. Any consultancy findings depend on the agreed scope and the information and evidence available. Independent consultancy does not replace statutory surveys, formal verification, certification or the responsibilities of the company and competent authorities.
ISM Documentation and Technical Consultancy
PAMS Pacific Admiralty Maritime Services provides independent marine technical consultancy. Explore the ISM service page for information about Safety Management System documentation and related technical support within an agreed scope.
View ISM Manual Services