ISM Code in plain words: the safety management system, the DPA, non-conformities and interview questions

The ISM Code is the reason every ship has a thick safety management manual, a checklist for almost every job, and a person ashore called the DPA whom anyone on board may call. It turns safety from a matter of luck and individual habits into a system that the company writes down, the crew follows and auditors check. Senior officers are asked about it at almost every interview, and ratings meet it daily in permits to work, toolbox talks and near-miss reports. This page sets out what the Code requires, the numbers and terms that come up most, what a non-conformity is, the mistakes that turn a small finding into a detention, and questions to test yourself.

What the ISM Code is and where it came from

In the late 1980s a series of disasters showed that ships were sinking not for lack of rules, but for lack of management. The ferry Herald of Free Enterprise capsized in 1987 after leaving port with her bow doors open; the investigation found no clear system, ashore or on board, for making sure they were shut. The fire on the Scandinavian Star in 1990 showed the same gaps in training and organisation.

IMO adopted the ISM Code in 1993 and made it mandatory through SOLAS chapter IX: from 1 July 1998 for passenger ships, tankers, gas carriers, bulk carriers and high-speed cargo craft of 500 GT and above, and from 1 July 2002 for all other cargo ships and mobile offshore drilling units of 500 GT and above. The Code is short — sixteen sections — because it does not tell a company what to do on board. It tells the company to decide, write it down, train people, check that it works, and improve it.

The objectives

The Code wants every company to:

• provide safe practices in ship operation and a safe working environment;
• assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards;
• continuously improve the safety management skills of personnel ashore and on board, including preparing for emergencies.

The sixteen sections

1. General: definitions and objectives.
2. Safety and environmental protection policy.
3. Company responsibilities and authority: who in the company answers for the ship.
4. Designated person(s) ashore — the DPA.
5. Master's responsibility and authority.
6. Resources and personnel: qualified crew, familiarisation, training, a working language.
7. Shipboard operations: procedures, plans and instructions for key operations.
8. Emergency preparedness: procedures, drills and exercises.
9. Reports and analysis of non-conformities, accidents and hazardous occurrences — near misses included.
10. Maintenance of the ship and equipment: planned maintenance, critical equipment.
11. Documentation: control of manuals and forms.
12. Company verification, review and evaluation: internal audits.
13. Certification and periodical verification.
14. Interim certification.
15. Verification.
16. Forms of certificates.

Key numbers

The DPA and the master

The designated person ashore (section 4) is the link between the company and the people on board. The DPA has direct access to the highest level of management and monitors the safety and pollution-prevention side of every ship. Anyone on board — not only the master — may contact the DPA, and the contact details are posted on the ship. If you see something dangerous that nobody on board will deal with, the DPA is the person to call.

The master (section 5) implements the company's policy on board, motivates the crew, issues orders and instructions, checks that the requirements are observed, and reviews the system and reports its deficiencies to the company. Above all, the system must state clearly that the master has the overriding authority and responsibility to make decisions with respect to safety and pollution prevention, and to request the company's assistance when needed. No charterer, no schedule and no office instruction outranks that.

Certificates and audits

• Document of Compliance (DOC) — issued to the company for the ship types it operates; valid for up to five years and verified every year, within three months either side of its anniversary. A copy is kept on board.
• Safety Management Certificate (SMC) — issued to the ship; valid for up to five years, with an intermediate verification between the second and third anniversaries.
• Interim certificates — an interim DOC for up to 12 months for a new company or a new ship type; an interim SMC for up to 6 months for a new ship or a ship that has changed hands.
• Internal audits — on board and ashore, at intervals of no more than 12 months, by people independent of the area they audit.

Non-conformities and observations

These are the terms auditors use, and senior officers are expected to know them exactly:

• Observation — a statement of fact made during an audit and backed by objective evidence. Not a failure in itself, but a warning.
• Non-conformity — a situation where objective evidence shows that a specified requirement is not fulfilled: a procedure not followed, a record missing, a drill not held.
• Major non-conformity — an identifiable deviation that poses a serious threat to the safety of personnel or the ship or a serious risk to the environment and needs immediate corrective action, or the lack of effective and systematic implementation of a requirement of the Code. A major non-conformity can stop a certificate from being issued or keep a ship in port.

For each finding the ship and the company agree a corrective action and a date, and the next audit checks that it worked. The same logic runs on board every day: near misses and hazardous occurrences are reported and analysed, because yesterday's near miss is tomorrow's accident.

What the system looks like on board

• the safety management manual in the working language, with procedures for every key operation — mooring, bunkering, cargo, entry into enclosed spaces, hot work, working aloft and overside;
• risk assessments and permits to work for hazardous jobs, and toolbox talks before them;
• familiarisation for every new crew member before taking up duties, and for anyone moved to a new safety-related job;
• planned maintenance, with the critical equipment — the equipment whose sudden failure could cause a hazardous situation — identified and tested regularly, standby systems included;
• emergency procedures and a drill programme;
• near-miss and accident reports, safety committee meetings, the master's review of the system.

What they ask at the interview

• Masters and chief officers: what the DPA is and when you would call them; the master's overriding authority — give an example; the difference between an observation, a non-conformity and a major non-conformity; DOC and SMC validity and verifications; how often internal audits are held; what you do with a non-conformity found by port state control; how you run a master's review.
• Chief and second engineers: critical equipment and how the planned maintenance system treats it; testing standby equipment; permits to work for hot work and for isolating machinery.
• Junior officers and ratings: the permit-to-work system; a toolbox talk; how to report a near miss and why; familiarisation after joining; your right to stop a job you believe is unsafe — most companies write that right into their system.

Common mistakes

1. Treating the system as paperwork: checklists ticked after the job instead of before it. An auditor compares the times in the records with the log book.
2. Not reporting near misses for fear of blame. The Code exists so that lessons are learned before someone is hurt; a ship with no near-miss reports looks like a ship that hides them.
3. Starting hot work, enclosed space entry or work aloft without the permit and the toolbox talk because "it is a five-minute job".
4. Not knowing the DPA's number, or believing only the master may call.
5. Carrying out a corrective action on paper only. The next audit checks whether the problem is actually gone.
6. Following a company or charterer instruction that endangers the ship. The master's overriding authority is there to be used.

Test yourself

Who on board needs this

Most of all the people who run the system: the master, the chief officer and the chief engineer, who are asked about ISM at every interview for a senior post. The second engineer answers for planned maintenance; every able seaman and bosun works under its permits every day. The legal frame is SOLAS chapter IX — see SOLAS in plain words.

Write the ship types and the companies you sailed with into your maritime CV: a crewing manager judges how well you know a safety management system by where you have worked.

Source: the International Safety Management (ISM) Code, as amended, and SOLAS chapter IX. Each company's own safety management system adds the detail; on board, it is that system that applies. This page is a study aid, not a legal text.