Safety management

Development of the ISM Code

A number of very serious accidents which occurred during the late 1980's, were
manifestly caused by human errors, with management faults also identified as
contributing factors.

Lord Justice Sheen in his inquiry into the loss of the Herald of Free Enterprise
famously described the management failures as "the disease of sloppiness".

At its 16th Assembly in October 1989, IMO adopted resolution A.647(16), Guidelines
on Management for the Safe Operation of Ships and for Pollution Prevention.

The purpose of these Guidelines was to provide those responsible for the operation
of ships with a framework for the proper development, implementation and
assessment of safety and pollution prevention management in accordance with
good practice.

The objective was to ensure safety, to prevent human injury or loss of life, and to
avoid damage to the environment, in particular, the marine environment, and to
property. The Guidelines were based on general principles and objectives so as to
promote evolution of sound management and operating practices within the
industry as a whole.

The Guidelines recognised the importance of the existing international instruments

as the most important means of preventing maritime casualties and pollution of the
sea and included sections on management and the importance of a safety and
environmental policy.

After some experience in the use of the Guidelines, in 1993 IMO adopted the
International Management Code for the Safe Operation of Ships and for Pollution
Prevention (the ISM Code).

In 1998, the ISM Code became mandatory.

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.

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.

Development of the Guidelines on implementation of the ISM Code

Recalling resolution A.741(18) by which the Assembly adopted the International

Management Code for the Safe Operation of Ships and for Pollution Prevention
(International Safety Management (ISM) Code), IMO adopted on 23 November 1995
resolution A.788(19) on Guidelines on implementation of the International Safety
Management (ISM) Code by Administrations.

Noting that the ISM Code was expected, under the provisions of chapter IX of the
International Convention for the Safety of Life at Sea (SOLAS), 1974, to become
mandatory for companies operating certain types of ships, as from 1 July 1998, and
recognizing that an Administration, in establishing that safety standards are being
maintained, has a responsibility to ensure that Documents of Compliance have been
issued in accordance with the Guidelines, and that there may be a need for
Administrations to enter into agreements in respect of issuance of certificates by
other Administrations in compliance with chapter IX of the 1974 SOLAS Convention
and in accordance with resolution A.741(18), IMO recognized further the need for
uniform implementation of the ISM Code.

Having considered the recommendation made by the Maritime Safety Committee at

its sixty-fifth session and the Marine Environment Protection Committee at its thirtyseventh session, the Assembly adopted the Guidelines on Implementation of the
International Safety Management (ISM) Code by Administrations (resolution
A.788(19)).

The resolution urged Governments, when implementing the ISM Code, to adhere to
the Guidelines, in particular with regard to the validity of the Document of
Compliance and the Safety Management Certificate required by the ISM Code; and
also urged Governments to request the companies concerned to apply for
certification under the ISM Code as soon as possible but not later than twelve
months prior to the ISM Code becoming mandatory for ships belonging thereto; to
inform the Organization of any difficulties they have experienced in using these
Guidelines, so that the Maritime Safety Committee and the Marine Environment
Protection Committee could keep the annexed Guidelines under review and to
amend them as necessary.

These Guidelines established basic principles for verifying that the Safety
Management System (SMS) of a Company responsible for the operation of ships or
the SMS for the ship or ships controlled by the company complies with the ISM
Code; and for the issue and periodical verification of the DOC and SMC. These
Guidelines are applicable to Administrations.

Amendments to Guidelines

The Guidelines on implementation of the International Safety Management (ISM)

Code by Administrations, resolution A.788(19) were replaced with revised
Guidelines, which were adopted by resolution A.913(22) in November 2001 which
revoked resolution A.788(19). Further revision of these guidelines resulted in
Guidelines on implementation of the International Safety Management (ISM) Code
by Administrations adopted by resolution A.1022(26) in December 2001. This
resolution revokes resolution A.913(22) with effect from 1 July 2010.

International Safety Management Code

Resolution A.741(18) as amended by MSC.104(73), MSC.179(79), MSC.195(80) and
MSC.273(85)
PREAMBLE
1 The purpose of this Code is to provide an international standard for the safe
management and operation of ships and for pollution prevention.
2 The Assembly adopted resolution A.443(XI), by which it invited all Governments
to take the necessary steps to safeguard the shipmaster in the proper discharge of
his responsibilities with regard to maritime safety and the protection of the marine
environment.
3 The Assembly also adopted resolution A.680(17), by which it further recognized
the need for appropriate organization of management to enable it to respond to the
need of those on board ships to achieve and maintain high standards of safety and
environmental protection.
4 Recognizing that no two shipping companies or shipowners are the same, and
that ships operate under a wide range of different conditions, the Code is based on
general principles and objectives.

5 The Code is expressed in broad terms so that it can have a widespread

application. Clearly, different levels of management, whether shore-based or at sea,
will require varying levels of knowledge and awareness of the items outlined.
6 The cornerstone of good safety management is commitment from the top. In
matters of safety and pollution prevention it is the commitment, competence,
attitudes and motivation of individuals at all levels that determines the end result.

PART A IMPLEMENTATION
1 GENERAL
1.1 Definitions
The following definitions apply to parts A and B of this Code.
1.1.1 International Safety Management (ISM) Code means the International
Management Code for the Safe Operation of Ships and for Pollution Prevention as
adopted by the Assembly, as may be amended by the Organization.
1.1.2 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 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.
1.1.3 Administration means the Government of the State whose flag the ship is
entitled to fly.
1.1.4 Safety management system means a structured and documented system
enabling Company personnel to implement effectively the Company safety and
environmental protection policy.
1.1.5 Document of Compliance means a document issued to a Company which
complies with the requirements of this Code.
1.1.6 Safety Management Certificate means a document issued to a ship which
signifies that the Company and its shipboard management operate in accordance
with the approved safety management system.
1.1.7 Objective evidence means quantitative or qualitative information, records or
statements of fact pertaining to safety or to the existence and implementation of a
safety management system element, which is based on observation, measurement
or test and which can be verified.
1.1.8 Observation means a statement of fact made during a safety management
audit and substantiated by objective evidence.
1.1.9 Non-conformity means an observed situation where objective evidence
indicates the non-fulfilment of a specified requirement.
1.1.10 Major non-conformity means 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 or the lack of effective and systematic
implementation of a requirement of this Code.

1.1.11 Anniversary date means the day and month of each year that corresponds
to the date of expiry of the relevant document or certificate.
1.1.12 Convention means the International Convention for the Safety of Life at
Sea, 1974, as amended.

1.2 Objectives
1.2.1 The objectives of the Code are to ensure safety at sea, prevention of human
injury or loss of life, and avoidance of damage to the environment, in particular to
the marine environment and to property.
1.2.2 Safety management objectives of the Company should, inter alia:
.1 provide for safe practices in ship operation and a safe working environment;
.2 assess all identified risks to its ships, personnel and the environment and
establish appropriate safeguards; and
.3 continuously improve safety management skills of personnel ashore and aboard
ships, including preparing for emergencies related both to safety and environmental
protection.

1.2.3 The safety management system should ensure:

.1 compliance with mandatory rules and regulations; and
.2 that applicable codes, guidelines and standards recommended by the
Organization, Administrations, classification societies and maritime industry
organizations are taken into account.

1.3 Application
The requirements of this Code may be applied to all ships.
1.4 Functional requirements for a safety management system
Every Company should develop, implement and maintain a safety management
system which includes the 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 levels 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; and
.6 procedures for internal audits and management reviews.

2 SAFETY AND ENVIRONMENTAL-PROTECTION POLICY

2.1 The Company should establish a safety and environmental-protection policy
which describes how the objectives given in paragraph 1.2 will be achieved.
2.2 The Company should ensure that the policy is implemented and maintained at
all levels of the organization, both ship-based and shore-based.

3 COMPANY RESPONSIBILITIES AND AUTHORITY

3.1 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.
3.2 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.
3.3 The Company is responsible for ensuring that adequate resources and shorebased support are provided to enable the designated person or persons to carry out
their functions.

4 DESIGNATED PERSON(S)
To ensure the safe operation of each ship and to provide a link between the
Company and those on board, every Company, as appropriate, should designate a
person or persons ashore having direct access to the highest level of management.
The responsibility and authority of the designated person or persons should include
monitoring the safety and pollution-prevention aspects of the operation of each ship
and ensuring that adequate resources and shore-based support are applied, as
required.

5 MASTERS RESPONSIBILITY AND AUTHORITY

5.1 The Company should clearly define and document the masters responsibility
with regard to:
.1 implementing the safety and environmental-protection policy of the Company;
.2 motivating the crew in the observation of that policy;
.3 issuing appropriate orders and instructions in a clear and simple manner;
.4 verifying that specified requirements are observed; and
.5 periodically reviewing the safety management system and reporting its
deficiencies to the shore-based management.
5.2 The Company should ensure that the safety management system operating on
board the ship contains a clear statement emphasizing the masters authority. The
Company should establish in the safety management system that the master has
the overriding authority and the responsibility to make decisions with respect to
safety and pollution prevention and to request the Companys assistance as may be
necessary.
6 RESOURCES AND PERSONNEL
6.1 The Company should ensure that the master is:

.1 properly qualified for command;

.2 fully conversant with the Companys safety management system; and
.3 given the necessary support so that the masters duties can be safely performed.
6.2 The Company should ensure that each ship is manned with qualified,
certificated and medically fit seafarers in accordance with national and international
requirements.
6.3 The Company should establish procedures to ensure that new personnel and
personnel transferred to new assignments related to safety and protection of the
environment are given proper familiarization with their duties. Instructions which
are essential to be provided prior to sailing should be identified, documented and
given.
6.4 The Company should ensure that all personnel involved in the Companys
safety management system have an adequate understanding of relevant rules,
regulations, codes and guidelines.

6.5 The Company should establish and maintain procedures for identifying any
training which may be required in support of the safety management system and
ensure that such training is provided for all personnel concerned.
6.6 The Company should establish procedures by which the ships personnel
receive relevant information on the safety management system in a working
language or languages understood by them.
6.7 The Company should ensure that the ships personnel are able to communicate
effectively in the execution of their duties related to the safety management
system.

7 SHIPBOARD OPERATIONS
The Company should establish procedures, plans and instructions, including
checklists as appropriate, for key shipboard operations concerning the safety of the
personnel, ship and protection of the environment. The various tasks should be
defined and assigned to qualified personnel.

8 EMERGENCY PREPAREDNESS
8.1 The Company should identify potential emergency shipboard situations, and
establish procedures to respond to them.
8.2 The Company should establish programmes for drills and exercises to prepare
for emergency actions.
8.3 The safety management system should provide for measures ensuring that the
Companys organization can respond at any time to hazards, accidents and
emergency situations involving its ships.
9 REPORTS AND ANALYSIS OF NON-CONFORMITIES, ACCIDENTS AND HAZARDOUS
OCCURRENCES
9.1 The safety management system should include procedures ensuring that nonconformities, accidents and hazardous situations are reported to the Company,
investigated and analysed with the objective of improving safety and pollution
prevention.
9.2 The Company should establish procedures for the implementation of corrective
action, including measures intended to prevent recurrence.

10 MAINTENANCE OF THE SHIP AND EQUIPMENT

10.1 The Company should establish procedures to ensure that the ship is
maintained in conformity with the provisions of the relevant rules and regulations
and with any additional requirements which may be established by the Company.
10.2 In meeting these requirements, the Company should ensure that:
.1 inspections are held at appropriate intervals;
.2 any non-conformity is reported, with its possible cause, if known;
.3 appropriate corrective action is taken; and
.4 records of these activities are maintained.
10.3 The Company should identify equipment and technical systems the sudden
operational failure of which may result in hazardous situations. The safety
management system should provide for specific measures aimed at promoting the
reliability of such equipment or systems. These measures should include the regular
testing of stand-by arrangements and equipment or technical systems that are not
in continuous use.
10.4 The inspections mentioned in 10.2 as well as the measures referred to in 10.3
should be integrated into the ships operational maintenance routine.
11 DOCUMENTATION
11.1 The Company should establish and maintain procedures to control all
documents and data which are relevant to the safety management system.
11.2 The Company should ensure that:
.1 valid documents are available at all relevant locations;
.2 changes to documents are reviewed and approved by authorized personnel; and
.3 obsolete documents are promptly removed.
11.3 The documents used to describe and implement the safety management
system may be referred to as the Safety Management Manual. Documentation
should be kept in a form that the Company considers most effective. Each ship
should carry on board all documentation relevant to that ship.

12 COMPANY VERIFICATION, REVIEW AND EVALUATION

12.1 The Company should carry out internal safety audits on board and ashore at
intervals not exceeding twelve months to verify whether safety and pollution-

prevention activities comply with the safety management system. In exceptional

circumstances, this interval may be exceeded by not more than three months.
12.2 The Company should periodically evaluate the effectiveness of the safety
management system in accordance with procedures established by the Company.
12.3 The audits and possible corrective actions should be carried out in
accordance with documented procedures.
12.4 Personnel carrying out audits should be independent of the areas being
audited unless this is impracticable due to the size and the nature of the Company.
12.5 The results of the audits and reviews should be brought to the attention of all
personnel having responsibility in the area involved.
12.6 The management personnel responsible for the area involved should take
timely corrective action on deficiencies found.
PART B CERTIFICATION AND VERIFICATION
13 CERTIFICATION AND PERIODICAL VERIFICATION
13.1 The ship should be operated by a Company which has been issued with a
Document of Compliance or with an Interim Document of Compliance in accordance
with paragraph 14.1, relevant to that ship.
13.2 The Document of Compliance should be issued by the Administration, by an
organization recognized by the Administration or, at the request of the
Administration, by another Contracting Government to the Convention to any
Company complying with the requirements of this Code for a period specified by the
Administration which should not exceed five years. Such a document should be
accepted as evidence that the Company is capable of complying with the
requirements of this Code.
13.3 The Document of Compliance is only valid for the ship types explicitly
indicated in the document. Such indication should be based on the types of ships on
which the initial verification was based. Other ship types should only be added after
verification of the Companys capability to comply with the requirements of this
Code applicable to such ship types. In this context, ship types are those referred to
in regulation IX/1 of the Convention.
13.4 The validity of a Document of Compliance should be subject to annual
verification by the Administration or by an organization recognized by the
Administration or, at the request of the Administration, by another Contracting
Government within three months before or after the anniversary date.
13.5 The Document of Compliance should be withdrawn by the Administration or,
at its request, by the Contracting Government which issued the Document when the

annual verification required in paragraph 13.4 is not requested or if there is

evidence of major non-conformities with this Code.
13.5.1 All associated Safety Management Certificates and/or Interim Safety
Management Certificates should also be withdrawn if the Document of Compliance
is withdrawn.
13.6 A copy of the Document of Compliance should be placed on board in order
that the master of the ship, if so requested, may produce it for verification by the
Administration or by an organization recognized by the Administration or for the
purposes of the control referred to in regulation IX/6.2 of the Convention. The copy
of the Document is not required to be authenticated or certified.
13.7 The Safety Management Certificate should be issued to a ship for a period
which should not exceed five years by the Administration or an organization
recognized by the Administration or, at the request of the Administration, by
another Contracting Government. The Safety Management Certificate should be
issued after verifying that the Company and its shipboard management operate in
accordance with the approved safety management system. Such a Certificate
should be accepted as evidence that the ship is complying with the requirements of
this Code.
13.8 The validity of the Safety Management Certificate should be subject to at
least one intermediate verification by the Administration or an organization
recognized by the Administration or, at the request of the Administration, by
another Contracting Government. If only one intermediate verification is to be
carried out and the period of validity of the Safety Management Certificate is five
years, it should take place between the second and third anniversary dates of the
Safety Management Certificate.

13.9 In addition to the requirements of paragraph 13.5.1, the Safety Management

Certificate should be withdrawn by the Administration or, at the request of the
Administration, by the Contracting Government which has issued it when the
intermediate verification required in paragraph 13.8 is not requested or if there is
evidence of major non-conformity with this Code.
13.10 Notwithstanding the requirements of paragraphs 13.2 and 13.7, when the
renewal verification is completed within three months before the expiry date of the
existing Document of Compliance or Safety Management Certificate, the new
Document of Compliance or the new Safety Management Certificate should be valid
from the date of completion of the renewal verification for a period not exceeding
five years from the date of expiry of the existing Document of Compliance or Safety
Management Certificate.

13.11 When the renewal verification is completed more than three months before
the expiry date of the existing Document of Compliance or Safety Management
Certificate, the new Document of Compliance or the new Safety Management
Certificate should be valid from the date of completion of the renewal verification
for a period not exceeding five years from the date of completion of the renewal
verification.
13.12 When the renewal verification is completed after the expiry date of the
existing Safety Management Certificate, the new Safety Management Certificate
should be valid from the date of completion of the renewal verification to a date not
exceeding five years from the date of expiry of the existing Safety Management
Certificate.
13.13 If a renewal verification has been completed and a new Safety Management
Certificate cannot be issued or placed on board the ship before the expiry date of
the existing certificate, the Administration or organization recognized by the
Administration may endorse the existing certificate and such a certificate should be
accepted as valid for a further period which should not exceed five months from the
expiry date.
13.14 If a ship at the time when a Safety Management Certificate expires is not in
a port in which it is to be verified, the Administration may extend the period of
validity of the Safety Management Certificate, but this extension should be granted
only for the purpose of allowing the ship to complete its voyage to the port in which
it is to be verified, and then only in cases where it appears proper and reasonable to
do so. No Safety Management Certificate should be extended for a period of longer
than three months, and the ship to which an extension is granted should not, on its
arrival in the port in which it is to be verified, be entitled by virtue of such extension
to leave that port without having a new Safety Management Certificate. When the
renewal verification is completed, the new Safety Management Certificate should be
valid to a date not exceeding five years from the expiry date of the existing Safety
Management Certificate before the extension was granted.

14 INTERIM CERTIFICATION
14.1 An Interim Document of Compliance may be issued to facilitate initial
implementation of this Code when:
.1 a Company is newly established; or
.2 new ship types are to be added to an existing Document of Compliance, following
verification that the Company has a safety management system that meets the
objectives of paragraph 1.2.3 of this Code, provided the Company demonstrates
plans to implement a safety management system meeting the full requirements of

this Code within the period of validity of the Interim Document of Compliance. Such
an Interim Document of Compliance should be issued for a period not exceeding 12
months by the Administration or by an organization recognized by the
Administration or, at the request of the Administration, by another Contracting
Government. A copy of the Interim Document of Compliance should be placed on
board in order that the master of the ship, if so requested, may produce it for
verification by the Administration or by an organization recognized by the
Administration or for the purposes of the control referred to in regulation IX/6.2 of
the Convention. The copy of the Document is not required to be authenticated or
certified.

14.2 An Interim Safety Management Certificate may be issued:

.1 to new ships on delivery;
.2 when a Company takes on responsibility for the operation of a ship which is new
to the Company; or
.3 when a ship changes flag.
Such an Interim Safety Management Certificate should be issued for a period not
exceeding 6 months by the Administration or an organization recognized by the
Administration or, at the request of the Administration, by another Contracting
Government.
14.3 An Administration or, at the request of the Administration, another Contracting
Government may, in special cases, extend the validity of an Interim Safety
Management Certificate for a further period which should not exceed 6 months from
the date of expiry.
14.4 An Interim Safety Management Certificate may be issued following verification
that:
.1 the Document of Compliance, or the Interim Document of Compliance, is relevant
to the ship concerned;
.2 the safety management system provided by the Company for the ship concerned
includes key elements of this Code and has been assessed during the audit for
issuance of the Document of Compliance or demonstrated for issuance of the
Interim Document of Compliance;
.3 the Company has planned the internal audit of the ship within three months;
.4 the master and officers are familiar with the safety management system and the
planned arrangements for its implementation;

.5 instructions, which have been identified as being essential, are provided prior to
sailing; and
.6 relevant information on the safety management system has been given in a
working language or languages understood by the ships personnel.
15 VERIFICATION
15.1 All verifications required by the provisions of this Code should be carried out in
accordance with procedures acceptable to the Administration, taking into account
the guidelines developed by the Organization.

16 FORMS OF CERTIFICATES
16.1 The Document of Compliance, the Safety Management Certificate, the Interim
Document of Compliance and the Interim Safety Management Certificate should be
drawn up in a form corresponding to the models given in the appendix to this Code.
If the language used is neither English nor French, the text should include a
translation into one of these languages.
16.2 In addition to the requirements of paragraph 13.3, the ship types indicated on
the Document of Compliance and the Interim Document of Compliance may be
endorsed to reflect any limitations in the operations of the ships described in the
safety management system.

Assessment of the impact and effectiveness of the ISM Code

The success of the ISM Code depends on its effective implementation and is
underpinned to a great extent by the competence and continued commitment and
motivation of individuals at all levels, in both companies and on board ships, who
are tasked with its implementation.
The outcome of the successful implementation of the ISM Code envisages the
enhancement of a safety culture throughout the shipping industry. Through
implementing the ISM Code and the application of its requirements over the past
decade, shipping companies, classification societies and other industry
organizations would have gained significant experience in assessing its manifest
benefits and drawbacks, if any. Evidence of an enhanced safety culture and
acknowledgement of its many benefits would therefore be a measure of the global
impact of the ISM Code on the shipping industry in general, and on safety in
particular.
The Maritime Safety Committee (MSC), at its seventy-fifth session (15 to 24 May
2002), agreed that, an analysis should be undertaken to assess the impact of the
ISM Code on the safety of ships to ascertain its contribution to the enhancement of
safety in the shipping industry. The Secretariat was instructed to collect from
regional PSC MoUs/Agreements, IACS and industry organizations, their information
on the impact of the ISM Code on ISM Code-certificated ships vis--vis detentions,
serious deficiencies, casualties, etc., as well as on any assessment of the impact of
the ISM Code and its effectiveness on ships.
In order to make a meaningful assessment, the Secretary-General established an
Independent Expert Group comprising of experts from Governments, organizations,
universities and the shipping industry and the Secretariat to collect and analyze
data to study the impact of the ISM Code and its effectiveness. This Independent
Expert Group, on conclusion of its study submitted its report to the SecretaryGeneral on its findings and recommendations given below.
Conclusions and recommendations of the Group of Independent Experts:
.1
the group, had recognized that the so called hard data to be collected, for
example from PSC detention records, would have had serious limitations in
indicating any effects of the ISM Code implementation. Therefore, the group had
recognized the need to rely on the experts judgement on the impact of the ISM

Code based on collectively gathered subjective opinions from various levels of the
shipping industry;
.2
the group had developed four questionnaires for shipboard personnel, shorebased personnel, shipping companies and Administrations. All data received in
response to the questionnaires was collated by the World Maritime University
(WMU) and submitted to the IMO Secretariat for preliminary analysis. The group
was then invited to scrutinize and validate the data and preliminary analysis;
.3
the group had found that the overwhelming majority of responses were
supportive of the ISM Code. The consensus among the group was that interest
shown in the study was highest amongst those who had generally enjoyed some
benefit from the implementation of the ISM Code. It was the groups considered
opinion that whilst the results could not be claimed to be a representative sample
from across the industry, they nevertheless represented a model of collective
experience from amongst those that support the Code. The group had also agreed
that this was a limitation in the methodology of the data gathering exercise and
believed that it could only be addressed by investing in a study employing
researchers in the field to ensure that the views of non-supporters could be
specifically captured;
.4

based on the data collected, the group concluded that:

4.1
where the ISM Code had been embraced as a positive step toward
efficiency through a safety culture, tangible positive benefits were evident;
4.2
ISM Code compliance could be made easier through a reduction in the
administrative process by:
.1
streamlining and reducing the paperwork that supported ISM Code
compliance, particularly the SMS;
.2

greater use of technology and IT to reduce paperwork;

.3
identifying common areas in the ISM Code and, for example, the ISPS
Code and integrating documentary requirements;
.4
motivating seafarers to use the reporting and monitoring systems
towards the improvement of safety management systems;
.5
involving the seafarers in the development and continuous
improvement of ISM manuals;
.6

increased integrated training for all concerned;

.7

exploring measures to reduce the cost of compliance; and

.8
improving ISM Code compliance monitoring and developing
performance indicators; and
4.3
the impact of PSC in this area had not been explored but certainly
appeared to merit further study;
.5

the group recommended that:

5.1
a further study should be undertaken, at a later date, specifically to
examine:
.1
cause and effect between ISM Code implementation and flag State
safety records;
.2

the relationship between PSC and ISM Code compliance; and

.3
whether textual changes in the requirements of the Code could make
compliance easier and lead to an improved safety culture;

5.2

in response to data produced for this study:

.1
methods to streamline the implementation of the Code through
technology and increased use of IT should be explored;
.2
the alignment of ISM and ISPS Codes in shipboard documentation
should be considered;
.3

a reduction in paperwork should be encouraged;

.4
guidelines for Administrations should be revised to make them more
user friendly; and
.5
new guidelines to assist companies to implement the Code should be
developed;

5.3
the results of the study be given widespread publicity across the industry in
order to show how positive attitudes to ISM Code could yield tangible operational,
financial and safety benefits.