What the ISM Code Is and Why It Exists
The ISM Code (International Safety Management Code) is a mandatory IMO instrument adopted under SOLAS Chapter IX. Its purpose is to provide an international standard for the safe management and operation of ships, and for pollution prevention. It exists because many casualties — Zeebrugge, Herald of Free Enterprise, Estonia — demonstrated that disasters rarely result from a single technical failure; they stem from systemic failures in management ashore and afloat.
The Safety Management System (SMS)
The Code requires every company to develop, implement and maintain a Safety Management System — a documented set of policies, procedures and instructions. The SMS must cover:
- A safety and environmental protection policy
- Instructions and procedures for safe operation and environmental protection
- Defined levels of authority and lines of communication
- Procedures for reporting accidents, near-misses and non-conformities
- Procedures for emergency preparedness and response
- Procedures for internal audits and management review
Each element links to the next in a continuous improvement loop: plan → do → check → act. The near-miss and non-conformity reporting chain is particularly important in the oral because it demonstrates the Code's proactive philosophy — the system must capture potential failures before they become casualties.
The Company and the Designated Person Ashore (DPA)
The Code places ultimate responsibility on the Company (as defined: owner or any person who has assumed responsibility for the ship). The Company must appoint a Designated Person Ashore (DPA) who provides the direct link between the ship and senior management. The DPA must have direct access to the highest level of management. This matters operationally: as OOW you must know who your DPA is, how to contact them, and when it is appropriate to do so — particularly in an emergency or when a non-conformity cannot be resolved on board.
The Two Certificates
Compliance is verified through two documents:
Document of Compliance (DOC) — issued to the Company, confirming the SMS is verified for that ship type. The DOC is valid for up to five years and is subject to annual verification, which must take place within three months before or after each anniversary date. The original DOC is held ashore by the Company; however, the master is required to keep a copy of the DOC on board the ship. This distinction — original ashore, copy on board — is a classic examiner question.
Safety Management Certificate (SMC) — issued to the ship, confirming the SMS is being implemented on board. The original SMC is kept on board. The SMC is valid for a period not exceeding five years and is subject to at least one intermediate verification, which (where there is one intermediate verification and a five-year validity) must take place between the second and third anniversary dates. The SMC will be withdrawn if the intermediate verification is not requested, or if there is evidence of a major non-conformity. Where renewal is completed within three months before expiry, the new certificate runs from the date of completion for up to five years from the old expiry date.
Both certificates are issued following audits by the flag state or a Recognised Organisation on its behalf.
The OOW's Practical Role
As OOW, you are both a user and a custodian of the SMS. You follow its procedures, report non-conformities and near-misses through the correct channels, and participate in drills and audits. If you observe that a procedure does not match actual practice, you are obliged to raise a non-conformity — this is not disloyalty; it is exactly how the Code is designed to drive improvement.