INTERNATIONAL MANAGEMENT CODE FOR THE SAFE OPERATION OF SHIPS

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MSIS 2/Rev 06/20 
Page 1 
 
 
 
 
INSTRUCTIONS FOR THE GUIDANCE OF 
SURVEYORS ON 
INTERNATIONAL MANAGEMENT CODE FOR THE 
SAFE OPERATION OF SHIPS AND FOR 
POLLUTION PREVENTION 
(THE ISM CODE) 
MSIS02 
 
Rev 06-2020 
 
 
 
 
 
 
 
© Crown Copyright 
 
PREFACE 
 
0.1 These instructions for the guidance of surveyors are not legal requirements in 
themselves. They may refer to statutory requirements elsewhere. They do 
represent the MCA Policy for MCA surveyors to follow. 
0.2 If for reasons of practicality, for instance, these cannot be followed then the 
surveyor must seek at least an equivalent arrangement, based on information 
from the owner/operator. Whenever possible, guidance should be sought in the 
first instance from either the Technical Manager, or Principal Consultant 
Surveyors or the Survey Operations Branch, in order to maintain a consistent 
approach between Marine Offices. 
 
 
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MAIN CONTENTS 
 
 
CHAPTER 1 ................................................................................................................................ 4 
INTRODUCTION AND BACKGROUND ..................................................................................... 4 
1.1 
PURPOSE OF THE INSTRUCTIONS ............................................................................. 4 
1.2  
THE ISM CODE .............................................................................................................. 4 
1.3  WHY IS THERE AN ISM CODE? .................................................................................... 4 
1.4  
UK AND IMO MEASURES TOWARDS  SAFE MANAGEMENT OF SHIPS .................. 5 
1.5  
PRINCIPLES AND OBJECTIVES OF THE ISM CODE .................................................. 5 
1.6  
THE SAFETY CULTURE ................................................................................................ 6 
1.7  
THE UK POLICY ............................................................................................................. 6 
1.8  
THE ISM AUDIT FOR COMPLIANCE ............................................................................ 6 
1.9 
INDEX OF DOCUMENTS ............................................................................................... 6 
CHAPTER 2 ................................................................................................................................ 8 
LEGISLATIVE REQUIREMENTS ............................................................................................... 8 
2.1  
INTERNATIONAL LEGISLATION ................................................................................. 8 
2.2  
EUROPEAN UNION LEGISLATION .............................................................................. 8 
2.3  MERCHANT SHIPPING (ISM CODE) REGULATIONS 2014 ........................................ 8 
CHAPTER 3 ................................................................................................................................ 9 
THE CERTIFICATION PROCESS .............................................................................................. 9 
3.1 
THE DOCUMENT OF COMPLIANCE (DOC) ................................................................. 9 
3.2  
THE SAFETY MANAGEMENT CERTIFICATE (SMC) ................................................... 9 
3.3 
ISSUE OF INTERIM DOC AND SMC ............................................................................. 9 
3.4 
COMPANIES OPERATING A MULT-FLAGGED FLEET ............................................10 
3.5 
AMENDING THE DOC TO INCLUDE NEW SHIP TYPES ............................................10 
3.6 
CANCELLATION OR SUSPENSION OF DOC OR SMC .............................................11 
CHAPTER 4 ..............................................................................................................................13 
CONDUCTING THE AUDIT ......................................................................................................13 
4.1 
AUDITOR QUALIFICATIONS: BASIC COMPETENCE FOR PERFORMING  ............13 
VERIFICATION ................................................................................................................. 
4.2 
THE SAFETY MANAGEMENT SYSTEM (SMS) ..........................................................14 
4.3 
REQUEST FOR AUDIT ................................................................................................15 
4.4 
DOCUMENT REVIEW AND PLANNING ......................................................................15 
4.5 
INITIAL AUDITS ...........................................................................................................16 
4.6 
DECLARATION OF AUDIT AND ISSUE OF CERTIFICATES .....................................17 
4.7 
THE DOCUMENT OF COMPLIANCE (DOC) ...............................................................17 
4.8 
THE SAFETY MANAGEMENT CERTIFICATE (SMC) AUDIT .....................................19 
4.9 
ANNUAL VERIFICATION (DOC) AND INTERMEDIATE VERIFICATION (SMC)   .....20 
AUDITS ............................................................................................................................. 
4.10 DOC AND SMC RENEWAL AUDIT ..............................................................................21 
4.11 RESPONSIBIILITIES OF LEAD AUDITOR ..................................................................21 
4.12 THE AUDIT PLAN ........................................................................................................22 
4.13 GUIDANCE ON TYPICAL AGENDA FOR OPENING AND CLOSING MEETINGS ....22 
4.14 CATEGORIES OF AUDIT FINDINGS ..........................................................................24 
4.14.1 OBSERVATION ............................................................................................................24 
4.14.2 NON-CONFORMITY .....................................................................................................24 
4.14.3 MAJOR NON-CONFORMITY .......................................................................................24 
4.15 NON-CONFORMITY NOTE ..........................................................................................24 
4.16 HUMAN ELEMENT .......................................................................................................25 
4.17 AUDIT REPORT ...........................................................................................................26 
4.17.1 AUDIT REPORT FOR DOCUMENT OF COMPLIANCE AUDIT ..................................26 
4.17.2 AUDIT REPORT FOR SAFETY MANAGEMENT CERTIFICATE AUDIT ....................26 
4.18 CLOSE OUT OF NON-CONFORMITIES ......................................................................26 
4.19 CORRECTIVE ACTION ................................................................................................27 
4.20 CONFIDENTIALITY OF AUDIT ...................................................................................27 
 
 
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CHAPTER 5 ..............................................................................................................................29 
EXTRACT OF ISM CODE & UK (POLICY) INTERPRETATION .............................................29 
PART A – IMPLEMENTATION .................................................................................................29 
5.1  
GENERAL ....................................................................................................................29 
5.1.1 DEFINITIONS .................................................................................................................29 
5.1.2 OBJECTIVES .................................................................................................................30 
5.1.3 APPLICATION ................................................................................................................31 
5.1.4 
 FUNCTIONAL REQUIREMENTS FOR A SAFETY MANAGEMENT SYSTEM  ..................31 
(SMS) ................................................................................................................................ 
5.2  
SAFETY AND ENVIRONMENTAL PROTECTION POLICY .......................................31 
5.3  
COMPANY RESPONSIBILITIES AND AUTHORITY ..................................................32 
5.4  
DESIGNATED PERSON(S) .........................................................................................33 
5.5  MASTER’S RESPONSIBILITY AND AUTHORITY .....................................................33 
5.6  
RESOURCES AND PERSONNEL ...............................................................................34 
5.8  
EMERGENCY PREPAREDNESS ................................................................................36 
5.9  
REPORTS AND ANALYSIS OF NON-CONFORMITIES, ACCIDENTS AND  ...........38 
HAZARDOUS OCCURRENCES ...................................................................................... 
5.10  MAINTENANCE OF THE SHIP AND EQUIPMENT ....................................................39 
5.11  DOCUMENTATION ......................................................................................................41 
5.12  COMPANY VERIFICATION, REVIEW AND EVALUATION .......................................41 
PART B – CERTIFICATION AND VERIFICATION ..................................................................43 
5.13  CERTIFICATION AND PERIODICAL VERIFICATION ................................................43 
5.14  
INTERIM CERTIFICATION ..........................................................................................46 
5.15  VERIFICATION .............................................................................................................47 
5.16  FORMS OF CERTIFICATES ........................................................................................48 
CHAPTER 6 ..............................................................................................................................49 
REPORTING & FILING ETC .....................................................................................................49 
6.1  
REPORTING & QUALITY CONTROL PROCEDURES (DOC & SMC) ......................49 
6.2  
PELORUS .....................................................................................................................49 
CHAPTER 7 ..............................................................................................................................50 
PORT STATE CONTROL .........................................................................................................50 
7.1  
EXAMINATION OF CERTIFICATES ...........................................................................50 
CHAPTER 8 ..............................................................................................................................51 
PARTICULAR ISSUES .............................................................................................................51 
8.1 
LAID UP SHIPS ............................................................................................................51 
8.2  
SUBMERSIBLE CRAFT...............................................................................................51 
ANNEX A ...................................................................................................................................52 
ANNEX B ...................................................................................................................................55 
MCA AUDIT OPENING & CLOSING MEETINGS ....................................................................55 
MCA AUDIT INTERVIEWEE LIST ................................. ERROR! BOOKMARK NOT DEFINED. 
 
 
 
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CHAPTER 1 
 
INTRODUCTION AND BACKGROUND 
 
1.1 
PURPOSE OF THE INSTRUCTIONS 
These Instructions to Surveyors have been produced by the Maritime and 
Coastguard Agency (MCA), an Executive Agency of the Department for 
Transport (DfT), 
for 
the guidance of surveyors auditing safety 
management systems both at sea and ashore. Additionally, they provide 
guidance for those concerned with the procedures adopted by the MCA 
for carrying out audits for verification of compliance with the International 
Safety Management Code for the Safe Operation of Ships and for 
Pollution Prevention (ISM Code). 
1.2  
THE ISM CODE 
The ISM Code was adopted by the IMO as Resolution A.741(18), in 
November 1993. It came into force on 1 July 1998 through SOLAS 
Chapter IX, ‘‘Management for the Safe Operation of Ships’’. The ISM 
Code provides an international standard for the safe management and 
operation of ships and for pollution prevention. 
1.3  
WHY IS THERE AN ISM CODE? 
The origins of the ISM Code go back, internationally, to the late 1980s 
when there was mounting concern about poor management standards in 
shipping. It is estimated that a high proportion of maritime accidents 
(80%–90%) are attributable to human error. Investigations into accidents 
highlighted shortcomings on the part of ship management both at sea and 
ashore.  In 1987 the IMO Assembly adopted Resolution A.595(15) which 
called upon the Maritime Safety Committee to develop guidelines 
concerning shipboard and shore-based management to ensure the safe 
operation of roll-on/roll-off (Ro-Ro) passenger ferries. The tragic loss of 
the Herald of Free Enterprise in 1987 was a catalyst in this process. 
Following this, the UK unilaterally introduced, for UK passenger ships of 
Classes II and IIA, The Merchant Shipping (Operations Book) 
Regulations 1988 (S.I.1988 No.1716). These regulations, which were 
superseded by S.I. 1997/3022 and S.I. 1998/1561, were developed 
around the two central tenets that; 
• such ships carry a book (called the operations book) containing 
instructions and 
information for safe and efficient operation;  
 
and 
 
• owners of ships nominate a person (known as the Designated Person 
Ashore (DPA)) to oversee the operation of their ships and to ensure  
 
 
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proper provisions are made so that the requirements of the operations 
book are complied with. 
These requirements are also fundamental provisions of the ISM Code. 
The ISM Code seeks to address the human element of ship operations. 
After the loss of the Estonia in 1994 the Council of the European Union 
adopted Council Regulation (EC) No. 3051/95 on 8 December 1995 on 
the safety management of roll-on/roll-off passenger ferries. From 1 July 
1996 this Regulation made compliance with the ISM Code mandatory for 
seagoing passenger Ro-Ro ferries operating a regular service to or from 
a port of an EU Member State. The Merchant Shipping (ISM Code) (Ro-
Ro Passenger Ferries) Regulations 1997 (S.I. 1997 No. 3022) provide for 
the enforcement of this Council Regulation.  At the Conference of 
Contracting Governments to the 1974 Safety of Life at Sea (SOLAS) 
Convention, held in May 1994, a new chapter (Chapter IX) was added to 
the Convention which made compliance with the ISM Code mandatory, 
from either 1 July 1998 or 1 July 2002 depending on ship type. The ISM 
Code itself was adopted on 4 November 1993 under Resolution 
A.741(18). The ISM Code has since undergone amendments in 2006, 
2009, 2010, 2015 and 2018.   
1.4  
 UK AND IMO MEASURES TOWARDS SAFE MANAGEMENT OF 
SHIPS 
 As a result of the major incidents detailed above, a number of measures 
were taken both nationally and internationally: 
• Resolution A.596 entitled ‘‘Safe Management and Operation of 
Ships’’ was adopted in 1987;  
• 
the UK implemented the Merchant Shipping (Operations Book) 
Regulations, S.I. 1988 No. 1716 (now superseded);  
• Resolution A.647 ‘‘IMO Guidelines on Management for Safe 
Operation of Ships and for Pollution Prevention’’ was adopted in 1989 
(superseding A.596);  
• 
a further Resolution, A.680, entitled ‘‘IMO Guidelines on Management 
for the Safe Operation of Ships and for Pollution Prevention’’ was 
adopted in 1991, superseding A.647; and  
• Resolution A.741 ‘‘International Management Code for the Safe 
Operation of Ships and for Pollution Prevention’’, the ISM Code, was 
adopted in 1993. 
 
1.5  
 PRINCIPLES AND OBJECTIVES OF THE ISM CODE 
 Given that no two shipping companies or ship managers are identical and 
that ships operate under a wide range of different conditions, the ISM 
Code is expressed in broad terms and based on general principles and 
objectives. This provides companies with the scope to develop their own 
safety management system (SMS) whilst meeting the provisions of the 
ISM Code. The Code imposes no prescriptive measures and takes a 
holistic view of a Company and the way in which it operates its ships. The 
objectives of the ISM Code are to ensure safety at sea, prevention of 
 
 
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human injury, loss of life and the avoidance of damage to the 
environment, in particular to the marine environment. The ISM Code 
requires owners and operators of ships to put in place a Safety 
Management System (SMS), the mandatory application of which is to 
ensure compliance with rules and regulations related to the objectives of 
the Code and the effective implementation and enforcement thereof by 
Flag State Administrations.  
1.6  
THE SAFETY CULTURE 
The Code aims to support and encourage the development of a safety 
culture within the shipping industry whilst improving compliance with the 
requirements of international conventions. The Code requires that 
Companies establish safety and pollution prevention objectives and 
develop, implement and maintain a SMS and a systematic approach to 
the safe management of ships by those responsible, both ashore and 
afloat. 
1.7  
THE UK POLICY 
The MCA recognises that the ISM Code encourages an enhanced safety 
and pollution prevention culture within the shipping industry. Therefore, it 
was decided that the MCA (as the UK Flag State Administration) would 
retain direct responsibility for the assessment and audit of UK shipping 
companies and ships against the ISM Code. All UK flag vessels are 
expected to have the SMS Manual written in or translated into English to 
enable MCA Auditors to carry out audits.  
1.8  
THE ISM AUDIT FOR COMPLIANCE 
Audits are carried out to verify compliance with the ISM Code in 
accordance with the ‘‘Guidelines on Implementation of the ISM Code by 
Administrations’’, 
IMO Resolution A.1022 (26). 
In addition, 
the 
International Chamber of Shipping, in association with the International 
Shipping Federation, has produced ‘‘Guidelines on the Application of the 
IMO International Safety Management (ISM) Code’’ and IACS has 
produced PR 09 on “Procedural requirements for ISM Code certification”. 
It is recommended that surveyors become familiar with these publications 
as they establish underlying principles for verifying that a shipping 
Company’s SMS complies with the ISM Code. 
1.9 
INDEX OF DOCUMENTS 
 
The following documents are particularly relevant to the ISM Code: 
• The ISM Code: IMO Resolution A.741 (18), adopted in November  
1993; 
• Revised guidelines on the implementation of the ISM Code by 
Administrations: IMO Resolution A.1118 (30) adopted on 6 Dec 2017; 
• Guidance 
to Companies operating multi-flagged 
fleets and 
supplementary guidelines to Administrations: IMO MSC/Circ. 762 of 11 
July 1996; 
 
 
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• Guidelines on the application of the IMO International Safety 
Management (ISM) Code, third edition, published jointly in 1993 by the 
ICS/ISF, amended and updated in 2018;  
• The Merchant Shipping (International Safety Management (ISM) Code) 
Regulations 2014 (S.I. 2014 No. 1512); 
• Guidance on the Qualifications, Training and Experience necessary for 
undertaking the role of the Designated Person under the provisions of 
the International Safety Management Code (ISM). IMO Circular (MSC-
MEPC.7/Circ. 6 19 October 2007); 
• Revised guidelines for the Operational Implementation of the 
International Safety Management (ISM) Code by Companies. IMO 
Circular MSC-MEPC.7/ Circ. 8 28 June 2013); and 
• Regulation (EC) No. 336/2006 on the implementation of the ISM Code 
within the community. 
• Maritime Cyber Risk Management in Safety Management Systems - 
Resolution MSC.428(98) (adopted on 16 June 2017)  
• Guidelines on Maritime Cyber Risk Management (MSC-FAL.1/Circ.3) 
 
 
 
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CHAPTER 2 
 
LEGISLATIVE REQUIREMENTS  
 
2.1  
INTERNATIONAL LEGISLATION 
Chapter IX of Safety of Life at Sea (SOLAS), Management for the Safe 
Operation of Ships, requires the mandatory application of the ISM Code 
on ships engaged on international voyages. 
2.2  
EUROPEAN UNION LEGISLATION 
The Council of the European Union adopted Council Regulation (EC) No. 
3051/95 in December 1995, which required advance mandatory 
application of the ISM Code for all sea going passenger roll-on/roll-off 
ferries operating a regular service to or from a port of a Member State of 
the European Community, regardless of the vessel’s flag. The Regulation 
entered into force on 1 July 1996. 
EC Regulation 336/2006 repeals Regulation (EC) No. 3051/95 and 
requires certain domestic cargo and passenger vessels to comply with 
ISM Code not later than 24 March 2008. Regulation 336/2006 applies to 
the following types of ships and companies operating them:   
• cargo ships and passenger ships, flying the flag of a Member State, 
engaged on international voyages; 
• cargo ships and passenger ships in EU category A and B waters 
engaged exclusively on domestic voyages, regardless of their flag; 
• cargo ships and passenger ships operating to or from ports of the 
Member States, on a regular shipping service, regardless of their flag; 
and 
• mobile offshore drilling units operating under the authority of a Member 
State.  
2.3  
 MERCHANT SHIPPING (ISM CODE) REGULATIONS 2014 
 The Merchant Shipping (ISM Code) Regulations 2014 (S.I. 2014 
No.1512) provide for the application of the ISM Code on all vessels to 
which the SOLAS Convention applies and to other vessels to which the 
EC Regulation 336/2006 applies.  
 
 
 
 
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CHAPTER 3  
  
THE CERTIFICATION PROCESS 
 
3.1 
 THE DOCUMENT OF COMPLIANCE (DOC) 
 A Document of Compliance (DOC) will be issued to a Company when the 
shore-side aspects of the SMS are fully compliant with the requirements 
of the ISM Code. The DOC is specific to the ship type(s) operated by the 
Company and for which the SMS is implemented at the time of audit. 
During a Safety Management Certificate (SMC) audit on board a ship, a 
copy of the DOC should be accepted as evidence that the Company’s 
shore-side management structure complies with the requirements of the 
ISM Code. A copy of the DOC should be placed on board each of the 
Company’s ships. It is not necessary for the copy of the DOC to be 
authenticated or certified.  
3.2  
 THE SAFETY MANAGEMENT CERTIFICATE (SMC) 
 Following a successful audit a SMC will be issued to each individual ship 
provided that the Company holds a valid DOC. A copy of each SMC 
should be retained in the Company’s office records, the original being 
placed on board and retained with all other statutory certificates. 
3.3 
ISSUE OF INTERIM DOC AND SMC 
An interim DOC may be issued to facilitate initial implementation of the 
Code when: 
• a Company is newly established; or  
• new ship types are to be added to an existing DOC (as described  
  
above). 
 
 
An interim SMC may be issued: 
 
• to new ships on delivery;  
• when a Company takes on responsibility for the operation of a ship 
which is new to the Company; or  
• when a ship changes flag. 
An interim DOC, valid for a maximum of twelve months, may be issued 
providing a Company can demonstrate its SMS meets the objectives of 
paragraph 1.2.3 of the ISM Code. The Company will need to prove that 
measures are in place to implement the full requirements of the ISM 
Code within the period of validity of the interim DOC.  When conducting 
interim DOC audits consideration should be given to Section 14.4 of the 
ISM Code that stipulates the requirements in respect of interim SMC 
audits.   
 
 
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An interim SMC, valid for not more than six months, may be issued to a 
new ship on delivery and when a Company takes on responsibility for the 
management of a ship which is new to the Company. In special 
circumstances the interim SMC may be extended for a further six months. 
This is only to be done in consultation with MCA HQ. When an interim 
SMC is extended, the full-term SMC should be dated from the expiry of 
the first interim certificate. 
Before an interim SMC is issued the auditors should satisfy themselves 
that: 
• the DOC or interim DOC is relevant to that ship;  
• key elements of the ISM Code have been included in the shipboard 
SMS and have been assessed during the audit of the Company’s 
SMS;  
• the master and officers are familiar with the SMS and arrangements for 
its implementation;  
• instructions identified as being essential have been provided prior to 
sailing;  
• there are plans in place for the Company to carry out an internal audit 
of the ship within three months; and  
• relevant information on the SMS is given in a working language 
understood by the ship’s personnel. 
 
3.4 
COMPANIES OPERATING A MULT-FLAGGED FLEET 
When a Company operates a multi-flagged fleet it should propose a plan 
of action to the relevant Flag Administrations and secure a consensus on 
the audit process.  A DOC should be issued by each of the Flag States. 
The IMO has issued a MSC Circular entitled ‘‘Guidelines to Companies 
operating multi-flagged fleets and Supplementary Guidelines 
to 
Administrations’’ (see MSC/Circ. 762). 
DOC audits are always carried out by the MCA unless  UK flag ship(s) 
form a minor proportion of a multi-flagged fleet in which case MCA may 
delegate the DOC audit to another flag state or  recognised organisation 
which can perform the audit and issue the DOC on behalf of MCA. If the 
Company operates passenger ships, the DOC audit will have to be 
carried out by the MCA. 
3.5 
 AMENDING THE DOC TO INCLUDE NEW SHIP TYPES 
 When a Company decides to expand its scope of operations to include 
additional ship type(s) an interim audit will be required prior to issuance of 
a DOC to ensure that the necessary provisions are in place within the 
SMS to manage the additional ship type(s). Following a successful audit, 
an interim DOC, valid for no more than 12 months, should be issued. The 
existing DOC will remain unaffected for the period of validity of the interim 
DOC (see paragraph 3.3 of these Instructions). 
 When sufficient objective evidence has been compiled to demonstrate 
that the SMS is effectively implemented in respect of the new ship 
 
 
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type(s), the Company should be revisited prior to the expiry of the interim 
DOC. Following a successful audit, both the interim and full-term DOC’s 
should be withdrawn and a new DOC issued to include all additional ship 
type(s). The expiry date of the new DOC should coincide with that of the 
original full-term DOC. 
 During the period of validity of the interim DOC, the new ship types will 
carry a copy of the interim DOC together with their interim SMC’s.  It must 
be noted that only an interim SMC can be issued on the back of an 
interim DOC. The existing ships of the fleet will be unaffected and will 
hold copies of the full-term DOC. 
 If during an annual DOC audit, it is evident that the Company has not 
operated a particular ship type for the last two years, the particular ship 
type should be removed from the DOC. This needs to be done in 
consultation with MCA HQ. 
3.6 
 CANCELLATION OR SUSPENSION OF DOC OR SMC 
 Only the MCA may cancel or suspend a DOC or SMC. When a major 
non-conformity (NCN) has been identified the MCA may either suspend 
or cancel the DOC and require such a certificate to be surrendered. In 
this case all SMCs associated with the DOC will likewise be invalidated, 
rendering the ship(s) liable to detention if the MCA considers that a 
Company is unable to operate ships without creating a risk of:  
• serious danger to safety of life;   
• serious damage to property; or  
• serious harm to the environment or that Company. 
 An authorised person (S.I. 1998 No.1561 Reg. No. 16(b)) may suspend 
the operation of ships by that Company until such time as any risk is 
removed or a valid DOC held. 
 
EXTENSION OF CERTIFICATES/AUDITS NOT REQUESTED ON TIME 
 
Extension of any ISM certificate should not be encouraged as owners/ 
managers have ample opportunity to get these organised. The ISM Code 
allows the extension of the validity of an interim SMC for a further period 
of 6 months. This should only be done, if the MCA is unable  to put a 
surveyor on board before the expiry of the interim certificate, and the 
Company had given appropriate notice for carrying out the audit or the 
vessel is in an area to where travel is prohibited. Any such extension is to 
be given only after consulting MCA HQ.  
If during an initial audit (DOC or SMC) it is found that the Company/ship 
does not merit the issuance of a full term certificate due to the number of 
non-conformities, a short term certificate valid for 3 months is to be 
issued so that another audit can be carried out prior to the issuance of a 
full term certificate. This is to be done in consultation with MCA HQ. 
 
 
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If the Company/ship fails to request the initial/intermediate/renewal audits 
and the DOC/SMC does not get endorsed or expires, the certificate 
becomes invalid. The Company needs to provide a written explanation for 
allowing the certificate to lapse and the auditor should consider further 
action in consultation with MCA HQ. In such a case an audit to the scope 
of a renewal audit is to be carried out and a new certificate issued. For all 
such cases a new certificate would need to be issued with the same 
expiry date as the earlier certificate. A major non-conformity needs to be 
raised, which can be downgraded on satisfactory completion of the audit 
and an additional audit would need to be carried out for closing out the 
downgraded non-conformity. 
 
 
 
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CHAPTER 4  
 
CONDUCTING THE AUDIT 
 
4.1 
 AUDITOR 
QUALIFICATIONS: 
BASIC 
COMPETENCE 
FOR 
PERFORMING VERIFICATION 
 
4.1.1  
Minimum Educational Requirements 
In accordance with the requirements of the ISM Code, appendix 
“Standards on ISM Code certification arrangements” sections 3 and 4, 
prospective MCA ISM Code auditors must have a minimum of formal 
education comprising the following: 
• 
qualifications from a tertiary institution recognised by the MCA within 
a relevant field of engineering or physical science (minimum two year 
programme); or  
• 
qualifications from a marine or nautical institution and relevant 
seagoing experience as a certified ship’s officer. 
Each application for Lead Auditor training will be reviewed on a case by 
case basis. The minimum standard of certification from a tertiary institution 
will be Higher National Diploma (or equivalent) in a relevant engineering or 
technical subject. 
The minimum level of certification will be either Master (Unlimited) STCW 
II/2 or Chief Engineer (Unlimited) STCW III/2. 
4.1.2  
Minimum Training Requirements 
Provided that prospective ISM Code Lead auditors meet the educational 
standards as detailed above, the following minimum standard of training 
must be met in order to ensure an adequate level of competence and 
skills particularly with regard to: 
• knowledge and understanding of the ISM Code;  
• mandatory rules and regulations;  
• the terms of reference which the ISM Code requires that the 
companies take into account;  
• assessment techniques of examining, questioning, evaluating and 
reporting; 
• technical and operational aspects of safety management; 
• basic knowledge of shipping and shipboard operations; and  
• participation in a minimum of three Safety Management System audits.  
4.1.3  
Theoretical Training 
All prospective auditors must achieve a pass grade from either the MCA 
Lead Auditor Course or an acceptable equivalent which is deemed to 
cover all the above requirements.   
 
 
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4.1.4  
Practical Training 
In general, the practical phase of training will not commence until the 
theoretical phase has been completed.   
A minimum of three supervised audits are to be successfully completed 
prior to qualification.  although some candidates may need to fulfil 
additional re audits before qualifying as Lead Auditor. There is no 
maximum number of audits after which a candidate automatically 
qualifies.  
In general, the three minimum audits will comprise of one DOC, one SMC 
and one more of either. Interim/additional audits are not considered as 
qualifying audits for a Lead Auditor.   
New entrants into the MCA who have qualified as Lead Auditors with any 
of the MCA recognised classification societies and have maintained their 
continuous professional development need not attend the MCA Lead 
Auditor Course. They will however need to undergo a familiarisation with 
MCA procedures and conduct a minimum of two audits under supervision 
in order to verify familiarity with MCA requirements and procedures. 
4.2 
 THE SAFETY MANAGEMENT SYSTEM (SMS) 
 In order to comply with the requirements of the ISM Code every Company 
should develop, implement and maintain a SMS which should embrace 
the objectives of the Code. Compliance with the requirements of the ISM 
Code should be verified by determining: 
• that the SMS meets the requirements of the ISM Code;   
• that the objectives laid down in paragraph 1.2.1 of the ISM Code are 
met; 
• that all identified risks to the ships, personnel and the environment        
have been assessed and safeguards established; 
• that personnel have 
received 
the appropriate 
training and 
familiarisation in the tasks for which they have responsibility; 
• that they are carrying out their work in accordance with the Company’s 
procedures; and 
• that tasks are being carried out with due regard for safety. 
In the normal course of events, a General Inspection (GI) will be 
conducted in parallel with the SMC audit. Previous reports of MCA 
inspection and deficiencies and post state control inspection reports 
should be reviewed to obtain a fuller perspective of the ship’s history. An 
emergency drill should be witnessed as far as is practicable. Since it is 
likely that UK ships, other than passenger ships, may not be visited by 
MCA surveyors for intervals of up to three years the SMC audit should 
take into consideration the MCA's Survey and Inspection Policy with 
regard to the conduct of emergency drills and exercises. In the case of 
passenger ships that undergo a Passenger Safety Certificate Survey on 
an annual basis, if a drill has been conducted within the last 12 months 
and evidence of this can be provided, the requirement for a drill may be 
 
 
MSIS 2/Rev 06/20 
Page 15 
 
waived. In the case of ships other than passenger ships, an emergency 
drill should be witnessed at the time of the SMC audit. The Company 
must be made aware of this requirement prior to the audit in order that 
appropriate arrangements may be made.  
 The Maritime Safety Committee (MSC) affirms that an approved SMS 
should take into account cyber risk management in accordance with the 
objectives and functional requirements of the ISM Code. The Companies 
are therefore encouraged to ensure that cyber risks are appropriately 
addressed in safety management systems no later than the first annual 
verification of the company's Document of Compliance after 1 January 
2021. 
(Reference Maritime Cyber Risk Management 
in Safety 
Management Systems - Resolution MSC.428(98)). The associated 
guidance which needs to be referred to are - Guidelines on Maritime 
Cyber Risk Management (MSC-FAL.1/Circ.3). DfT have produced a Code 
of Practice for cyber security for ships which would be useful for 
companies. 
4.3 
REQUEST FOR AUDIT 
 
Applications (MSF 5100 forms) for the initial, annual or renewal DOC 
verification audits and for initial, intermediate or renewal SMC verification 
audits should be made by the Company direct to the Company’s 
Customer Service Manager (CSM) at the designated/most appropriately 
located MO to where the ship is located. The MO will then raise an 
electronic file in SharePoint (if one does not already exist) and organise 
the audit.  
 
4.4 
DOCUMENT REVIEW AND PLANNING 
The first stage of a DOC interim audit (and renewal audits if the SMS has 
undergone considerable changes) will be the document review. The 
purpose of the document review is to verify that the Company has a SMS 
that addresses the requirements of the ISM Code prior to an interim DOC 
audit. Following the receipt of an application requesting an interim DOC 
audit and payment of the appropriate fees, the MCA will review the SMS 
documentation as part of the pre-audit assessment. The Company would 
need to send the SMS documentation (electronic or hard copy) to the 
MCA Lead Auditor to enable this to happen. 
The documents used to define and implement the SMS may be described 
as the SMS Manual and may take the form that the Company considers 
most appropriate. As a basis for planning the audit, the auditor should 
review the SMS Manual to ensure the requirements of the ISM Code are 
met. The documents submitted should be the latest version and the 
review should preferably take place two weeks prior to the proposed 
audit. If it is established that the system is inadequate, the audit may be 
delayed until the Company has undertaken corrective action. The 
document review will provide an overview of the management structure 
and SMS used by the Company and assist the auditor(s) in developing an 
audit plan.  
 
 
MSIS 2/Rev 06/20 
Page 16 
 
The KISS (Keep it Short and Simple) principle should be fully embraced 
as excessive documentation may hinder the effectiveness of the SMS. 
Care should be taken to limit the SMS documentation to sufficiently cover 
its application to safety and environmental protection. Companies should 
structure their documentation in the way they find most effective and is 
clearly demonstrated by objective evidence. Auditors need to be aware 
that the SMS documentation may often be part of an integrated system 
which includes other management systems like quality and environmental 
management. Provided all the elements of the ISM Code are covered, 
this should not prove problematic. 
The ISM Code presents a challenge to the management of ships, both 
ashore and sea-going by providing a reasonable balance of procedures 
and records etc. If the documentation is insufficient, the requirements of 
the SMS will not be adequately met; equally, if overcomplicated the SMS 
will overwhelm the users and be counterproductive to safety. 
When a SMC audit has been requested for a ship which operates under a 
DOC issued by, or on behalf of another Administration, a copy of that 
DOC and sufficient previous DOC audit reports should be obtained for 
review prior to the audit. In addition, copies of the SMS manuals may be 
requested.    
4.5 
INITIAL AUDITS 
 
Initial audits will generally be in two phases: 
• 
an audit of the Company’s shore-based management organisation for 
compliance with the requirements of the ISM Code. Following the 
satisfactory completion of this audit a DOC will be issued to the 
Company; and  
• 
an audit of the Company’s ships in order to verify compliance with the 
requirements of the ISM Code. This will include a verification that the 
DOC for the Company, which is responsible for the operation of the 
ship, is applicable to that particular type of ship and that a copy is 
held on board. Upon successful audit of each ship a SMC will be 
issued. 
In general, an initial or renewal audit can be expected to be completed by 
one auditor in one day on a cargo ship, however the time-scale would 
vary in accordance with the size, type of ship, the nature and size of the 
Company and their preparedness for the audit. 
A rule of thumb for calculating duration is as follows (see table 1): The 
duration of the DOC audits would be dependent on the size of the 
Company/fleet and the presence of satellite offices. The duration of the 
SMC audits would be dependent on the size / complexity of the vessels 
and the number of crew.  
 
 
 
 
MSIS 2/Rev 06/20 
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Table 1: 
Companies operating cargo vessels 
Estimated duration of audit 
Document review (cargo) 
2 - 4 hrs 
DOC interim audit (cargo) 
4 - 6 hrs 
DOC initial/renewal audit (cargo) 
6 - 8 hrs 
DOC annual audit (cargo) 
6 - 8 hrs 
SMC interim audit (cargo) 
4 - 6 hrs 
SMC initial/renewal audit (cargo) 
6 - 12 hrs 
SMC intermediate audit (cargo) 
6 - 10 hrs 
Companies operating passenger 
vessels 
 
Document review (passenger) 
6 - 8 hrs 
DOC interim audit (passenger) 
8 - 12 hrs 
DOC initial/renewal audit (passenger) 
12 - 24 hrs 
DOC annual audit (passenger) 
8 - 24hrs 
SMC interim audit (passenger) 
6 - 8 hrs 
SMC initial/renewal audit (passenger) 
16 - 48 hrs 
SMC intermediate audit (passenger) 
16 - 24 hrs 
 
4.6 
DECLARATION OF AUDIT AND ISSUE OF CERTIFICATES 
On successful completion of the DOC audit a declaration shall be 
completed by the lead auditor and then the DOC will be issued. All ships 
are required to hold a copy of the DOC, which does not need to be 
authenticated or certified (Section 13.6 of the ISM Code refers). 
Similarly, subsequent to a successful SMC audit, a Declaration shall be 
completed, and the SMC issued. The original version shall be retained on 
board and a copy placed in the Company office files. Companies should 
acknowledge the safe receipt of DOCs and SMCs. 
The Lead Auditor should complete an audit report—see paragraphs 4.15, 
4.17 and 4.17.1 of these Instructions.  
4.7 
 THE DOCUMENT OF COMPLIANCE (DOC)  
 The purpose of the audit is to assess the ability of the SMS to meet the 
provisions of the ISM Code and to ensure that these are fully 
implemented and understood at all levels within the Company. These 
include: 
• compliance with mandatory rules and regulations; and  
• that Codes, guidelines and standards recommended by the IMO, MCA, 
or other industry bodies have been taken into consideration. These 
documents may be incorporated into the Company’s SMS. 
The DOC audit will take place at the Company’s principal place of 
business (normally the office from which the DPA operates). If a 
Company operates from more than one location where different safety 
management functions are performed, then these other locations will 
 
 
MSIS 2/Rev 06/20 
Page 18 
 
need to be visited. All records within the Company should be available for 
examination during an audit. These can include records of all relevant 
ship types operated by the Company, statutory and classification records, 
personnel records and records of ship maintenance etc. 
The auditor should also be satisfied that personnel, both ashore and sea-
going, have received training and are competent to perform their duties 
within the SMS. The manner in which the auditor assesses the ability of 
the Company to meet the objectives of the ISM Code is as follows: 
• review of the Company’s documentation i.e. the SMS;  
• discussion and interview with members of staff at all levels of the 
management team holding responsibility for functions within the SMS;  
• observation of documentary evidence (e.g. records, log books, 
checklists and reports concerning UK flag vessels); and  
• observation of working practices. 
A DOC will be issued following a successful audit of the shore side 
aspects of a Company’s SMS. Objective evidence should be available to 
demonstrate that the Company has been operating the SMS for a 
minimum of three months ashore and on board their ships for a full-term 
DOC to be issued. Records of internal audits would also need to be 
verified. 
Prescriptive management of packaged systems produced by consultancy 
firms may result in Companies implementing requirements which are not 
suited to their operation and in so doing undermine the philosophy of the 
ISM Code. The SMS needs to be specific to the vessel and to their type 
of operation (section 11.3 of the ISM Code refers). 
Auditors are reminded that they are attending for the purpose of verifying 
compliance with the ISM Code and not to criticize the methodology a 
Company has adopted to achieve compliance. Although some systems 
may appear to be cumbersome, this should not be of concern if the 
personnel can demonstrate their familiarity.  
A DOC is issued in respect of the type(s) of ship(s) operated by the 
Company at the time of initial verification and for the type of ships they 
intend to operate in the near future and which are covered within the 
SMS. Should the Company wish to extend the scope of management at a 
later stage to include additional ship types a further audit should be 
carried out and, if successful, the DOC replaced. See section 3.5 of these 
Instructions. 
The renewal verification should include an assessment of each element 
of the SMS and its effectiveness in meeting the objectives of the ISM 
Code. A renewal audit is required prior to the expiry date (it may be 
arranged within 3 months before the expiry) of the existing DOC. If a 
renewal audit is carried out prior to this 3 month window, the certificate 
will be dated from the date of completion of the audit. 
 
 
MSIS 2/Rev 06/20 
Page 19 
 
When a major non-conformity is raised a DOC or SMC cannot be issued. 
Similarly, an existing certificate cannot be endorsed for either annual or 
intermediate verification and should be withdrawn until sufficient 
corrective action has been taken to downgrade the major non-conformity. 
Any major non-conformity requires an additional audit within 3 months to 
close out the downgraded non-conformity. 
When non-conformities are raised, a timescale for the implementation of 
corrective action should be agreed. Several non-conformities in the same 
area of operation may be raised as a single major non-conformity. 
Similarly, a number of observations under the same section of the Code 
may be issued as a single non-conformity. 
The following arrangements, if put in place by the Company, will assist 
the auditor(s) in carrying out the audit: 
• 
The appointment of an individual, who is fully conversant with the 
Company’s SMS, to act as audit guide. The guide should make any 
introductions necessary, arrange for meetings and interviews with 
Company personnel, provide a steer around the offices and make 
available the Company’s files, reports and other documents as 
requested; 
• 
The allocation of office space, ideally separate from that used by 
company personnel, for use by the auditor(s); and 
• Access to all relevant documents. Where documentation is stored 
electronically access to a computer terminal is essential. 
Although these arrangements would be beneficial, it might not always be 
practical to follow this process. 
4.8 
 THE SAFETY MANAGEMENT CERTIFICATE (SMC) AUDIT  
 The objective of the SMC audit is to assess the implementation of the 
Company SMS on board their ships to meet the operational requirements 
of the ISM Code and to ensure that these are fully implemented and 
understood at all levels within the vessel. These include: 
• compliance with mandatory rules and regulations; and  
• that codes, guidelines and standards recommended by the IMO, MCA, 
or other industry bodies have been taken into consideration. These 
documents may be incorporated into the Company’s SMS. 
The SMC audit should only be carried out on a ship operated by a 
Company which holds a valid DOC relevant to that ship type. If there is 
any doubt in this regard MCA HQ should be consulted. Objective 
evidence should be available to demonstrate the effective implementation 
of the Company’s SMS over a period of at least three months. This 
should include records of the Company’s internal audit of the vessel. 
Co-operation between the MCA and the Company/ships is essential in 
order to establish an audit timetable which is convenient to all parties 
concerned. In order to assess the implementation of the SMS on board, 
 
 
MSIS 2/Rev 06/20 
Page 20 
 
sufficient time must be allowed for an effective audit to be conducted. The 
scope of the SMC audit will cover all aspects of the vessel’s operation 
and will include verification of compliance with documented procedures, 
the interview of a random sample of personnel and risk assessments, the 
examination of documentation and records etc. 
The SMC is valid for five years from the date of completion of the initial 
audit except when an interim has been extended. An intermediate audit is 
required between the second and third anniversaries. The intermediate 
audit should determine the effective functioning of the SMS and ensure 
that any amendments made since the previous audit comply with the 
requirements of the ISM Code. Depending on the nature of any non-
conformities identified the MCA may consider it necessary to carry out 
additional verification audits. The Company should conduct audits of its 
ships, at intervals of not more than 1 year, dependent on the size of the 
fleet, which allows for a meaningful assessment of the effectiveness of its 
SMS. The renewal audit should include an assessment of each element 
of the SMS relating to that vessel and the effectiveness of the SMS in 
meeting the objectives of the ISM Code. The fees charged for ISM audits 
should be based on the time taken by surveyors to complete all aspects 
of the work at the hourly rate applicable at the time of audit. Estimated 
fees are payable in advance of audits. 
SMC audits should not be carried out when the vessel is in dry 
dock/extensive refit as the ship is not considered operational during that 
time. 
4.9 
 ANNUAL VERIFICATION (DOC) AND INTERMEDIATE VERIFICATION 
(SMC)  AUDITS 
 A DOC is valid for a period of up to five years and is subject to an annual 
audit in order to ensure that the Company is continuing to operate its 
SMS in accordance with the requirements of the ISM Code and to verify 
any amendments made to it. The audit should include the examination of 
statutory and class records relating to at least one ship of each type to 
which the DOC applies. All sections of the Code must be addressed. The 
annual DOC verification must be carried out within a six-month window 
that falls three months either side of the anniversary date of the DOC. 
The intermediate SMC verification must be carried out between the 2nd 
and 3rd anniversary dates of the SMC.  
 If the annual DOC verification or the intermediate SMC verification is not 
carried out within the specified window, the relevant certificate 
(DOC/SMC) becomes invalid. When the verification is subsequently 
carried out, a major non-conformity needs to be raised which can be 
downgraded on successful completion of the verification. An additional 
audit would then need to be carried out within 3 months to close out the 
downgraded major non-conformity. 
 In general, annual and intermediate audits will follow the same process 
and methodology as the initial or renewal audits. The main difference 
being that a smaller sample of records will be taken. 
 
 
MSIS 2/Rev 06/20 
Page 21 
 
 
4.10 
DOC AND SMC RENEWAL AUDIT 
The audit for the renewal of a DOC or SMC should be carried out prior to 
the expiry date of the existing certificates. If the renewal audit is 
conducted within three months of the expiry date of the existing 
certificate, the new certificate will run for a period of no more than five 
years from the date of expiry of the existing certificate. In this case a 
certificate may appear to have been issued with a validity of more than 
five years. The auditor must ascertain the circumstances under which the 
certificate was issued. If the audit is conducted more than three months 
prior to the expiry date of the existing DOC or SMC then the new 
certificate will be valid for a period of no more than five years from the 
date of completion of the audit. The renewal DOC or SMC audit should 
include an assessment of all elements of the SMS relating to the ship and 
shore management, address all sections of the ISM Code and evaluate 
the effectiveness of the SMS in meeting the objectives of the ISM Code.   
NB If the Company holds an interim DOC, the validity of the interim SMC 
should be 6 months or 12 months if extended (see section 4.8), but under 
no circumstances shall it exceed the date of expiry of the interim DOC. 
On issuance of the full-term DOC, the full-term SMC may then be issued. 
 4.11 
RESPONSIBIILITIES OF LEAD AUDITOR 
 
The responsibilities of the lead auditor include the following: 
• 
liaising with the Company; 
• 
ensuring fees are received prior to audit; 
• 
reviewing the Company’s documentation;  
• 
raising the Company /ship file in SharePoint if not already present;  
• 
preparing an audit plan and sending it to the Company prior to the 
audit; 
• 
selecting 
the audit 
team, 
including verifying 
their auditor 
qualifications; 
• 
chairing the opening meeting;  
• 
co-ordinating the audit;  
• 
chairing the closing meeting;  
• 
agreeing corrective action with the Company and the timescale for 
completion;  
• 
completing the declaration;  
• 
preparing the certificate(s) for issue;  
• 
preparing the audit report within 15 days from date of audit 
completion as far as practicable; 
• 
ensuring that the Technical Manager (TM) reviews the audit report. If 
the TM is not available, the report should be reviewed by another 
auditor or G7 Principal or Consultant Surveyor who has not been 
involved in the audit;  
• 
sending copies of the audit plan, audit report and NCNs to HQ by e-
mail or via a link in SharePoint for quality control and also notify HQ 
of closure of NCNs; and 
 
 
MSIS 2/Rev 06/20 
Page 22 
 
• 
completing the survey works order. 
 
4.12 
THE AUDIT PLAN 
 
In preparation for an audit the lead auditor should prepare the audit plan 
given in the Annex A and forward it to the Company/vessel prior to the 
commencement of the audit (preferably a few days prior to the audit).  
The auditors should examine the Company’s documentation, files and 
procedures taking into consideration that auditing is a sampling process 
and that not every file and procedure can be examined within the time 
allocated for the audit.  In addition to the audit of files and other 
appropriate documentation, time must be allocated for interviews and 
discussions with members of the management team. The period 
allocated for the audit will be dependent upon the size and complexity of 
the Company and the number of ships in the fleet. A fire/boat drill should 
be carried out as far as practicable as part of SMC audits and time should 
be allocated for the same in the audit plan. 
4.13 
 GUIDANCE ON TYPICAL AGENDA FOR OPENING AND CLOSING 
MEETINGS 
 
 The opening meeting should be chaired by the lead auditor and will 
usually include the following elements which will be applicable to both 
DOC and SMC audits:   
 
• introductions by members of the audit team and the Company’s 
management;  
• a record of company personnel who attended the meeting to be 
included in the audit report; the purpose and scope of the audit to be 
explained e.g. the ISM Code;  
• the authority of the MCA to conduct the audit on its own behalf, or on 
behalf of another Flag State, to be emphasised;   
• the audit plan, drawn up in advance, to be reviewed and any changes 
agreed between the Company and the auditors.  This will include, but 
not be limited to, the sites/areas to be visited, persons to be 
interviewed, documentation to be reviewed and the timing of meetings 
to accommodate meal breaks; 
• flexibility is essential. It should be made clear that the audit will work 
around the demands of the Company, movements of personnel, 
meetings and any other requirements; 
• the lead auditor will ensure that in a SMC audit the safety of the vessel 
and crew should not be compromised at any time and the audit should 
not affect vessels normal operation like cargo commitments, crew rest 
periods, doctor going ashore etc.; 
• the categories of non-conformities should be clearly explained; all non-
conformities or observations found during the audit must be brought to 
the attention of the auditees as soon as they are identified and not to 
be raised only during the closing meeting; 
• confidentiality of the audit between the Company, MCA and any other 
responsible administration(s) should be confirmed, noting legitimate 
Freedom of Information (FOI) requests may need to be considered. 
 
 
MSIS 2/Rev 06/20 
Page 23 
 
This is important as the auditor(s) will require access to a wide range 
of files and documents which support the SMS; 
• disclaimer: auditing is a sampling process and the auditor(s) may not 
identify all existing non-conformities; and 
• company representatives should be given an opportunity to raise 
questions. 
The method of carrying out the audit should be outlined and will include, 
but not be limited to, the following: 
• interviews with key members of the management team as laid down in 
the audit plan;  
• a detailed examination of the SMS; familiarity with and understanding 
of the safety and environmental policy, manuals, procedures and 
instructions, working practices, recruitment and training records, 
management reviews, internal audits, classification records, accident 
and non-conformity reports; 
• discussions with members of staff at all levels;  
• findings which may result in the raising of a specific non-conformity 
should be promptly drawn to 
the attention of a company 
representative, preferably at the time this is identified; and 
• it should be emphasised that a ship audit should not be rushed for 
completion due to vessel’s cargo commitments/schedules. If there is 
insufficient time for completion of the audit the owners/managers must 
make arrangements to carry out the audit at a later date and bear the 
additional expenses. 
 
The standard closing meeting agenda (very similar to the opening 
meeting) will include the following elements and be applicable to both 
DOC and SMC audits: 
 
• introductions by members of the audit team and the Company’s 
management; 
• a record of company personnel who attended the meeting to be kept 
and included in the audit report;  
• the purpose and scope of the audit to be reiterated;  
• the authority of the MCA to conduct the audit on its own behalf, or on 
behalf of another Flag State, to be re-stated;   
• the audit findings to be presented, including both the positives and the 
negatives (NCNs); 
• confidentiality of the audit between the Company, MCA and any other 
responsible administration(s) to be reiterated;  
• the disclaimer to be clearly explained: that auditing is a sampling 
process and the auditor(s) may not identify all existing non-
conformities. For example, if no non-conformities are identified in a 
particular area it does not necessarily mean that none exist; and if non-
conformities are raised it does not necessarily mean that these are the 
only ones in that particular area.   
• company representatives should be given an opportunity to raise 
questions. 
 
 
 
MSIS 2/Rev 06/20 
Page 24 
 
The lead auditor may not continue with an audit if any of the following 
conditions prevail: 
• there is insufficient time to complete the audit; 
• the conduct and support from the auditees is not acceptable; and 
• a major incident/accident has occurred on board/company which might 
affect conducting the audit. 
 
A note giving reasons for not completing the audit must be included in 
report MSF 1602/1603. 
 
4.14 
CATEGORIES OF AUDIT FINDINGS 
Audit findings fall into three categories, details of which are outlined 
below and in “Definitions”. 
4.14.1 OBSERVATION 
An observation means a statement of fact made during a safety 
management audit and substantiated by objective evidence. The 
Company/ship is not liable to provide evidence of the corrective action 
taken for an observation. 
4.14.2 NON-CONFORMITY  
A non-conformity means an observed situation where objective evidence 
indicates the non-fulfilment of a specified requirement of the ISM Code. A 
non-conformity should normally be closed out within three months from 
the date of the audit. 
4.14.3 MAJOR NON-CONFORMITY 
A major non-conformity means an identifiable deviation which poses a 
serious threat to the safety of personnel, the ship or to the environment 
that requires immediate corrective action or the lack of effective and 
systematic implementation of a requirement of the ISM Code. 
A major non-conformity on ship audits requires downgrading to a non- 
conformity in order to allow the vessel to sail (Ref. MEPC/Circ. 1059 of 
16-12-2002). 
An additional audit (timed to verify the effectiveness of the corrective 
action) is required within 3 months to close out a downgraded major non-
conformity. 
4.15 
NON-CONFORMITY NOTE 
Non-conformities should be recorded on the form MSF 1902 (‘‘Non-
Conformity Note’’). If the form is completed in PELORUS, there are 
separate forms for the company and the ship, which need to be 
completed as appropriate. However, if the form is completed manually 
(on the carbonated pads), then it is the combined form. Auditors should 
 
 
MSIS 2/Rev 06/20 
Page 25 
 
refer to the guidelines for completing the form which can be found on the 
reverse of the NCN.  
4.16 
HUMAN ELEMENT 
The achievement of the ISM Code’s goals is heavily dependent on the 
human element i.e. the people who operate the system.  The knowledge 
and experience of the officers and crew, their familiarity with the 
Company’s SMS, their training and records thereof should be verified by 
observation and interview. Where practicable, the auditor(s) should 
witness as many on board procedures as practicable and these may 
include, but are not limited to:   
• 
pre arrival and departure checks on the Bridge and in the engine 
control room;  
• 
securing the vessel for sea;  
• 
voyage planning;  
• 
navigational briefing;  
• mooring stations fore and aft;  
• 
bridge procedures in harbour;  
• 
engine room operations;  
• 
preparation of machinery for sea  
• machinery maintenance including system preparation  
• 
anchor stations;  
• 
bunkering operations;  
• 
pilot embarkation/disembarkation;  
• 
passenger musters and handling;  
• 
cargo operations/handling;  
• watch handover;  
• 
on-board training;  
• 
new joiner (crew) instructions;  
• 
emergency drills;  
• 
safety committee meetings;  
• 
routine inspections;  
• 
navigation under pilotage; and  
• watch keeping at sea. 
The above on-board procedures when sampled during audit must be 
reported in section 7 of the ISM report form (MSF1911). 
 
 
MSIS 2/Rev 06/20 
Page 26 
 
4.17 
AUDIT REPORT 
An audit report should be completed to record the audit findings within 15 
working days from the date of the audit. The report is confidential 
between the Company, MCA and any other responsible Administration(s) 
bearing in mind the requirements of the Freedom of Information Act. 
When the MCA has been requested to carry out the audit on behalf of 
another Administration the report should be copied to that Administration. 
The report provides useful information for future audits. The Company 
should receive a copy of the report and a further copy should be held on 
the relevant SharePoint file. When another Administration requests a 
copy of the report, as might be the case with a multi-flagged fleet, it 
should be issued providing the Company is in agreement. The audit 
report must be reviewed by the Technical Manager (TM) or a G7 Principal 
or Consultant Surveyor or another auditor who has not been involved in 
the audit before it is sent to the client. A copy of the audit report must 
then be sent to MCA HQ. When done on Pelorus, MCA HQ need to be 
advised when the report is uploaded. 
4.17.1 AUDIT REPORT FOR DOCUMENT OF COMPLIANCE AUDIT 
 
The report should include the following: 
• name of the lead auditor; 
• a list of the audit team members;  
• a list of personnel interviewed and positions held within the Company;  
• an assessment of compliance with each relevant section of the ISM 
Code;  
• opening and closing meeting details; 
• the types of ships managed by the Company;  
• the operational patterns of the Company’s ships;  
• audit plan; and 
• areas covered and audit findings. 
 
4.17.2 AUDIT REPORT FOR SAFETY MANAGEMENT CERTIFICATE AUDIT 
 
The report should include the following: 
• name of the lead auditor; 
• names and ranks of auditees;  
• names of audit team members;  
• an assessment of compliance with each relevant section of the ISM 
Code;  
• opening & closing meeting details; 
• the type of ship and employment patterns;   
• audit plan; and 
• areas covered and audit findings. 
 
4.18 
CLOSE OUT OF NON-CONFORMITIES 
 
 
MSIS 2/Rev 06/20 
Page 27 
 
When a major non-conformity is raised corrective action must be 
implemented before a new certificate can be issued or an existing 
certificate endorsed at annual (DOC) or Intermediate (SMC) verification. 
A major non-conformity may be down-graded to a non-conformity as soon 
as appropriate initial corrective action has been taken.  Corrective action 
and an agreed timescale for closure against this non-conformity may then 
be agreed.  A significant number of non-conformities identified against the 
same section of the ISM Code may be issued as a single major non-
conformity. When an auditor identifies a major non-conformity, agreement 
MUST be sought immediately from MCA HQ or the duty surveyor if out of 
hours. Where a major non-conformity is downgraded in a SMC or DOC 
audit, at least one additional audit should be carried out within 3 months 
to verify that effective actions are taken (Ref: MSC Circ. 1059).  
When an auditor identifies a potential non-conformity, agreement must be 
reached with the head of the department or area concerned that the 
perceived non-conformity actually exists.  Agreement should be reached 
prior to the closing meeting. Suitable corrective actions and appropriate 
corrective action time-scales must also be discussed and agreed with the 
Company. Auditors are reminded that corrective action times cannot 
exceed three months. In the event that a Company cannot complete a 
corrective action within the maximum time of three months, the non-
conformity note is to be closed out and another raised (National Audit 
Office instructions). 
4.19 
CORRECTIVE ACTION 
A representative from the Company or ship should propose corrective 
action which identifies the root cause of the non-conformity and an action 
to eliminate the same and to avoid re-occurrence. 
The Company is responsible for ensuring that the agreed corrective 
actions are completed by the agreed dates as failure to do so may affect 
the validity of certificates. Corrective action and possible follow-up audits 
should also be completed within the agreed timescale. 
Closing-out of non-conformities will not normally require a revisit by an 
auditor. Written notification of the completion of corrective action, 
accompanied where possible by objective evidence, shall be forwarded to 
the lead auditor through the DPA. This should be accompanied by the 
appropriate copy of the NCN. When the lead auditor is satisfied that the 
agreed corrective action has been completed the NCN will be closed out, 
signed and returned to the DPA. During annual DOC audits the 
opportunity should be taken to confirm that NCN’s raised at the previous 
audit have been closed out on time. The corrective actions may also be 
verified. In the case of SMC audits the foregoing may be achieved during 
either the next intermediate audit or a general inspection.  
4.20 
CONFIDENTIALITY OF AUDIT 
 
The audit and the subsequent reports are confidential (subject to any 
disclosures under the law) between the Company and any other Flag 
 
 
MSIS 2/Rev 06/20 
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State Administration on whose behalf the MCA may have been requested 
to act. A statement to this effect should be made at both the opening and 
the closing meetings. However, the auditor should not sign the 
Company’s confidentiality forms or contracts. The confidentiality clause 
must be included in all audit reports. 
 
 
 
 
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CHAPTER 5 
 
 
EXTRACT OF ISM CODE & UK (POLICY) 
INTERPRETATION 
The following is an extract of the ISM Code with UK interpretation in 
italics. 
 
PART A – IMPLEMENTATION 
 
5.1  
GENERAL 
 
5.1.1 
DEFINITIONS 
 
The following definitions apply to parts A and B of this Code. 
• 
International Safety Management Code (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 Organisation (1.1.1 of the Code).  
• Company means the owner of the ship or any other organisation or 
person such as the manager, or the bareboat charterer, who has 
assumed the responsibility for operation of the ship from the ship-
owner and who, on assuming such responsibility, has agreed to take 
over all duties and responsibility imposed by the Code (1.1.2 of the 
Code).  
• Administration means the Government of the State whose flag the 
ship is entitled to fly (1.1.3 of the Code).  
• Safety Management System means a structured and documented 
system enabling company personnel to effectively implement the 
Company safety and environmental protection policy (1.1.4 of the 
Code).  
• Document of Compliance means a document issued to a company 
which complies with the requirements of the Code (1.1.5 of the 
Code).  
• 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 SMS (1.1.6 of the Code). 
• Safety Management Audit means a systematic and independent 
examination to determine whether the SMS activities and related 
results comply with planned arrangements, whether 
these 
arrangements are implemented effectively and whether they are 
suitable to achieve the objectives of the ISM Code. 
• Objective Evidence means quantitative or qualitative information, 
records or statements of fact pertaining to safety or to the existence 
and implementation of a SMS element, which is based on 
observation, measurement or test and which can be verified (1.1.7 of 
the Code). 
 
 
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• Observation means a statement of fact made during a safety 
management audit and substantiated by objective evidence (1.1.8 of 
the Code).  
• Non-conformity means an observed situation where objective 
evidence indicates the non-fulfilment of a specified requirement (1.1.9 
of the Code).  
• 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 and 
includes the lack of effective and systematic implementation of a 
requirement of this Code (1.1.10 of the Code).  
• Designated Person is defined in Section 5 of the Code. 
• Ro-Ro passenger ferry means a seagoing passenger vessel with 
facilities to enable road or rail vehicles to roll on and roll off the vessel 
and which carries more than twelve passengers.  
• Anniversary date means the day and month of each year that 
corresponds to the date of expiry of the relevant document or 
certificate (1.1.11 of the Code).  
• Convention means the International Convention for the Safety of Life 
at Sea, 1974, as amended (1.1.12 of the Code). 
 
5.1.2 
OBJECTIVES 
5.1.2.1  
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.  
5.1.2.2  
Safety management objectives of the Company should, inter alia: 
• 
provide for 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 and 
• 
continuously improve safety-management skills of personnel ashore 
and aboard ships, including preparing for emergencies related both to 
safety and environmental protection 
5.1.2.3  
The safety management system should ensure: 
• 
compliance with mandatory rules and regulations; and 
• 
that applicable codes, guidelines and standards recommended by the 
Organization, Administrations, Classification Societies and maritime 
industry organizations are taken into account.  
 
The Company SMS should provide for methods of identification of risks 
(including risks related to cyber security) and establishment of safeguards 
against the same. This shall be verified during the course of audits of the 
Company for issuance of the DOC, subject to the Company providing 
sufficient evidence of following the risk assessment procedures. During 
the SMS audits on board, a few risk assessments need to be randomly 
sampled and verified for effectiveness. Inadequacies in the general 
standard of risk assessment will require closer examination of onboard 
 
 
MSIS 2/Rev 06/20 
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risk assessments and the related procedure. While selecting the sample, 
auditors should be guided by incidents/ accidents on board the vessel 
and other vessels in the fleet or by operations which are taking place 
while on board. Please note that there is no requirement to comply with 
codes, guidelines, standards, etc. (1.2.3.2), however the SMS should 
take these into account and alternative measures should be in place if the 
Company has decided not to comply. 
 
5.1.3 
APPLICATION 
 
The requirements of this Code may be applied to all ships. 
This means that the ISM Code may be applied to any ships irrespective 
of whether they are required to comply with the same. This is what allows 
Companies/ships to voluntarily comply with the Code. Voluntary ISM 
certificates should ideally have the SOLAS reference removed. 
 
5.1.4 
 FUNCTIONAL REQUIREMENTS FOR A SAFETY MANAGEMENT 
SYSTEM (SMS) 
 Every Company should develop, implement and maintain a SMS which 
includes the following functional requirements: 
• 
a safety and environmental protection policy; 
• 
instructions and procedures to ensure safe operation of ships and 
protection of the environment in compliance with relevant 
international and flag State legislation; 
• 
defined levels of authority and lines of communication between and 
amongst, shore and ship board personnel; 
• 
procedures for reporting accidents and non-conformities with 
provisions; 
• 
procedures to prepare for and respond to emergency situations; and 
• 
procedures for internal audits and management reviews. 
The objectives lay down clear guidelines for the development of a SMS 
that complies with the ISM Code. The Company’s policy statement is 
fundamental to the system and should be examined during the document 
review. Some Companies have a single policy statement while others 
have a number of statements which together comprise the Company’s 
safety and environmental protection policy. The statement(s) should (i) 
describe how the objectives of the Code will be met and (ii) serve to 
demonstrate the Company’s commitment to its SMS and the ISM Code. 
5.2  
SAFETY AND ENVIRONMENTAL PROTECTION POLICY 
5.2.1  
The Company should establish a safety and environmental protection 
policy which describes how the objectives given in paragraph 1.2 will be 
achieved. 
 The policy statement(s) should be clear and concise, with emphasis 
being placed on the Company’s commitment to safety and the 
environment. It should identify a strategy by which the Company aims to 
 
 
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achieve its policy objectives and include methods to encourage 
improvement in safety awareness and safety management. The policy 
should be endorsed (not necessarily signed) by the Senior Management 
of the Company. 
5.2.2  
 The Company should ensure that the policy is implemented and 
maintained at all levels of the organization, both ship based as well as 
shore based. 
 The strategy for implementation of the policy should be clear so that it 
can be understood at all levels within the Company. Members of the 
Company’s management team should be interviewed during an 
assessment. This is an effective means of establishing whether there is 
commitment to the SMS at the highest levels within the Company. 
Personnel to be interviewed should include, but not be limited to, the 
following: 
Shore 
Ship 
Managing Director  
Master 
Operations Manager  
Chief Engineer 
Technical Managers  
Safety Officer 
Designated Person  
Chief Officer/Mate 
Quality Manager  
Training Officer 
Safety Manager  
Engineer / Deck Officers 
Personnel/Training Manager  Bosun / CPO 
Superintendents 
Sample of Deck / Engine / Catering Ratings 
Other Office Staff 
Cook & Galley Staff 
Junior personnel should be interviewed on a random basis concerning 
their responsibilities within the SMS. They must have the background and 
experience appropriate to their role, received suitable training, and 
possess adequate knowledge of the SMS. There should be procedures in 
place to ensure that adequate training is provided as required. 
5.3  
COMPANY RESPONSIBILITIES AND AUTHORITY  
5.3.1  
If the entity that 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. 
 The Company must ensure that the owner fulfils the requirement of this 
section of the Code. These details should be reported to the MCA. The 
identification of the ISM manager on the Continuous Synopsis Record 
issued by the MCA should be considered as evidence of compliance with 
this requirement. 
5.3.2  
 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. 
 
 
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 Responsibilities and authorities should be documented to enable 
personnel involved in the SMS to understand what is expected of them 
and ensure that the safety and environmental functions have been 
allocated. The Company’s documented management system should 
outline descriptions of the responsibilities and authorities together with the 
reporting lines of personnel within the management structure. Schematics 
or flowcharts to document lines of authority and inter-relations between 
roles are acceptable. 
5.3.3  
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.  
 It must be established whether the Company is committed to providing 
the support necessary for the Designated Person Ashore (DPA) to fulfil 
their duties. This may include reviewing correspondence between the 
DPA and the management board, the budget for safety training and the 
attitude towards safety issues at management level. Commitment must 
start at the top and be prevalent throughout the Company. 
5.4  
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 DP 
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. 
The task of implementing and maintaining the SMS is a management 
responsibility, however, the DPA holds a key role in the monitoring 
process. DPAs should be suitably qualified 
(refer 
to MSC-
MEPC.7/Circ.6), experienced in ship operations or management systems 
and be fully conversant with the Company’s safety and environmental 
protection policies and SMS. It is essential that they have the 
independence and authority to report to the highest level of management. 
Their responsibilities may include the organisation of the Company’s 
internal safety audits. 
In order for any system of management to be adequately maintained it is 
essential that it is monitored at regular intervals. This will ensure that:  
• 
implementation is verified;  
• deficiencies are reported; and  
• those responsible for corrective action are identified and that 
appropriate action is taken. 
 
5.5  
MASTER’S RESPONSIBILITY AND AUTHORITY 
5.5.1  
 The Company should clearly define and document the master’s 
responsibility with regard to:  
 
 
MSIS 2/Rev 06/20 
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.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 SMS and reporting its deficiencies to the 
shore-based management. 
The responsibility for overseeing and implementing all relevant aspects of 
the Company’s SMS on the vessel rests with the master. Clear guidance 
should be provided to masters concerning their responsibility on matters 
affecting the safety of the ship, its passengers and/or cargo and the 
environment.   
5.5.2  
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 and to request the Company’s assistance as may be 
necessary. 
Masters should expect support and encouragement from the Company at 
all times. There must be a clear statement in the documented 
management system that the master has overriding authority to deviate 
from this in time of crisis and seek assistance from the Company if 
required. Both statements must be clear and unequivocal with the 
appropriate emphasis placed on the master’s overriding authority. 
5.6  
RESOURCES AND PERSONNEL   
5.6.1  
The Company should ensure that the master is: 
.1 properly qualified for command; 
.2 fully conversant with the Company’s SMS; and 
.3 given the necessary support so that the master’s duties can be safely 
performed. 
5.6.2  
The Company should ensure that each ship is: 
.1 manned with qualified, certificated and medically fit seafarers in 
accordance with national and international requirements; and 
.2 appropriately manned in order to encompass all aspects of maintaining 
safe operations on board. 
The Company has a clear responsibility to employ properly qualified and 
medically fit seafarers, and be satisfied that they are familiar with the 
management system in operation. The Company should be able to satisfy 
the auditors, by whatever means, that this requirement of the Code is 
being adequately addressed. This is also a requirement under MLC 
2006. Copies of certificates may be held on file in the office, or it may be 
necessary to have a random sample of certificates e-mailed from a cross 
 
 
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section of the fleet. Some companies maintain electronic databases as 
opposed to a paper filing system. In this case a random sample of 
certificates should be obtained to verify the accuracy of the database.  
The manning of the ship should cater for all operations on board while the 
ship is at sea, anchor or alongside, loading / discharging or carrying out 
any other activity e.g. tank cleaning, gas freeing, etc.  
5.6.3  
 Th e 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 familiarisation with their 
duties. Instructions which are essential to be provided prior to sailing 
should be identified, documented and given. 
 STCW A-I/14 (Responsibilities of Companies) requires the Company to 
provide written instructions to the master regarding the policies and 
procedures to be followed, ensuring newly recruited seafarers are familiar 
with their duties before they are assigned tasks on board. This shipboard 
familiarisation should include sufficient time to become acquainted with: 
• emergency / evacuation procedures and arrangements to perform 
assigned duties properly;  
• ship specific duties related to the role the seafarer will fulfil on-board; 
and 
• ship specific knowledge of any safety and environmental protection 
procedures with which the seafarer should be acquainted. 
A knowledgeable crew member should be designated to ensure that 
newly recruited seafarers are made aware of essential information in a 
language they understand. The STCW Code requires mandatory training 
in crowd management for some personnel serving on passenger ships. 
Records of familiarisation and instructions received by crew members 
should be available for examination by the auditor(s). 
5.6.4  
The Company should ensure that all personnel involved in the Company’s 
SMS have an adequate understanding of relevant rules, regulations, 
codes and guidelines. 
 While the ISM Code does not introduce new legislative requirements, the 
SMS must embrace all existing international conventions, national rules 
and regulations, industry guidelines and codes of practice. It is acceptable 
for the SMS to encompass such documents as the Code of Safe Working 
Practices for Merchant Seamen, the Bridge Procedures Guide, the 
Tanker Safety Guide, etc. 
5.6.5  
The Company should establish and maintain procedures for identifying 
any training which may be required in support of the SMS and ensure that 
such training is provided for all personnel concerned. 
 The means of identifying the training needs of individuals, both ashore 
and seagoing, is for the Company to address. This may be achieved by 
staff appraisal, the end of contract report for seagoing staff, results of 
 
 
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internal audits, drills, analysis of accidents, etc. Training requirements 
could be met by refresher training courses and on the job training. 
5.6.6  
The Company should establish procedures by which the ship’s personnel 
receive relevant information on the SMS in a working language or 
languages understood by them. 
 The SMS, in whatever form, must be available to all personnel, both 
ashore and seagoing. It is the Company’s responsibility to ensure that the 
manuals are in a language(s) understood by all crew members. Many 
Companies employ the services of manning agencies, often in several 
countries world-wide. The Company’s procedures should detail the 
process by which crew members are selected, assigned to its ships and 
familiarised with their responsibilities prior to taking up a position on 
board. 
5.6.7  
The Company should ensure that the ship’s personnel are able to 
communicate effectively in the execution of their duties related to the 
SMS. 
The ability of crew members to communicate effectively is essential to the 
safety of the ship. This should be assessed at the recruitment stage and 
manning agencies should be vigilant in this exercise. The Company 
should ensure that there are procedures in place to monitor the manning 
agencies which they use. 
5.7  
SHIPBOARD OPERATIONS 
5.7.1  
 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 involved should be defined and assigned 
to qualified personnel. 
 The Company should establish the key shipboard operations and ensure 
that procedures and instructions are available for carrying out these 
operations. While shipboard operations will vary depending on ship type, 
it is suggested that plans and instructions for the following operations 
should be documented: 
• general shipboard operations;  
• port operations;  
• preparation for sea;  
• conduct of the voyage;  
• preparation for arrival in port; and  
• emergency response organisation. 
The auditor(s) should verify that the operations established by the 
Company are relevant and comprehensive for the ship type(s) that the 
Company operates. 
5.8  
EMERGENCY PREPAREDNESS 
 
 
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5.8.1 
The Company should establish procedures to identify describe and 
respond to potential emergency shipboard situations. 
 The procedures should integrate the response to potential emergencies 
by shore-side and shipboard operations. The Maritime Safety Committee 
of the IMO produced 
‘‘Guidelines for an Integrated System of 
Contingency Planning for Shipboard Emergencies’’ as MSC/Circ. 760. 
This circular is not intended to impose a new system or supersede 
existing systems which are tried and tested, such as SOPEP, however 
the Guidelines may be of assistance to Companies in developing an 
integrated emergency response system. 
 
Contingency plans may include but are not limited to: 
• the role and responsibilities of shore and ship personnel during an 
emergency;  
• a list of names and contact numbers of all relevant parties;  
• procedures to be followed in response to varying emergency 
scenarios;  
• procedures for communication between ship and shore;  
• a database of plans, particulars of vessels, emergency response 
capabilities, damage stability information and pollution prevention 
equipment;  
• checklists for a range of emergencies (the use of checklists is strongly 
encouraged);  
• procedures for notifying next of kin;  
• guidelines for liaising with the press and media; and procedures for 
requesting emergency services from third parties. 
 
Latest guidelines covered by: 
Resolution A.1072(28) Adopted on 4 December 2013 Revised Guidelines 
for a Structure of an Integrated System of Contingency Planning for 
Shipboard Emergencies. 
Emergency scenarios for which contingency plans might be developed, 
include, but are not limited to: 
• structural failure;  
• main engine failure;  
• failure of steering gear;  
• failure of electrical power;  
• collision;  
• grounding;  
• shift of cargo;  
• pollution (spillage of oil or other cargo);  
• fire;  
• flooding;  
• abandon ship;  
• man overboard;  
 
 
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• entry into enclosed spaces;  
• terrorism or piracy;  
• helicopter operations for medical evacuation;  
• heavy weather damage; and  
• treatment of serious injury. 
 
5.8.2  
The Company should establish programmes for drills and exercises to 
prepare for emergency actions. 
 The drill programme should exercise the emergency plans listed in 8.1 
above and where appropriate, mobilise the shore-side emergency 
contingency plans. 
5.8.3  
The SMS should provide for measures ensuring that the Company’s 
organization can respond at any time to hazards, accidents and 
emergency situations involving it ships. 
 Drills should be carried out regularly in order to test the Company’s 
emergency response organisation and the competence of those who will 
be called upon in a real emergency. The ability of the personnel ashore to 
respond to emergencies should also be tested periodically. Records of all 
drills and exercises should be retained and made available for 
examination. In the event of the Company having to respond to a real 
emergency this may be considered in lieu of an exercise drill, providing 
that records have been retained and analysed. 
5.9  
REPORTS AND ANALYSIS OF NON-CONFORMITIES, ACCIDENTS 
AND HAZARDOUS OCCURRENCES 
5.9.1  
The SMS should include procedures ensuring that non-conformities, 
accidents and hazardous situations are reported to the Company, 
investigated and analysed with the objective of improving safety and 
pollution prevention.  
5.9.2  
The Company should establish procedures for the implementation of 
corrective action, including measures intended to prevent recurrence. 
 The SMS should contain procedures that require reports to be prepared 
and forwarded to the Company on all accidents, hazardous occurrences 
and non-conformities. They should be monitored by the Designated 
Person Ashore (DPA) and the appropriate corrective action agreed in 
order to avoid a recurrence of the incident or non-conformity. 
 Any deviation from the SMS procedures and instructions, that represents 
a non-conformity, should be recorded, raised on a non-conformity note 
and forwarded to the DPA. The system should be designed to allow 
continual updating, amendment and improvement due to the reporting 
procedures. 
 The reports should be recorded, investigated, analysed and acted upon 
as necessary. There should be procedures for reporting feedback to the  
ship and for circulation around all appropriate areas. Motivation is a 
 
 
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Page 39 
 
significant factor in the success of the management system and feedback 
is a powerful motivator. Feedback should be recorded as evaluation and 
analysis may lead to: 
• 
identification and implementation of corrective action;  
• benefits to the whole Company;  
• amendments to existing procedures; and 
• development of new procedures. 
The Accident Reporting and Investigation Regulations (S.I. 2005 No. 881) 
define accidents, serious injuries and dangerous occurrences along with 
statutory reporting requirements. 
5.10  
MAINTENANCE OF THE SHIP AND EQUIPMENT 
5.10.1  
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. 
5.10.2  
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. 
Procedures should be developed to ensure that maintenance, surveys, 
repairs and dry-docking are undertaken in a planned and structured 
manner with safety as a priority. All personnel responsible for 
maintenance should be suitably qualified and familiar with national and 
international legislation as well as classification society requirements. The 
management team ashore shall provide technical support and advice to 
the seagoing staff. 
 
Maintenance procedures could include: 
• hull and superstructure;  
• 
lifesaving, firefighting and anti-pollution equipment;  
• navigational equipment;  
• steering gear;  
• anchors and mooring equipment;  
• main engine and auxiliary machinery including pressurised systems;  
• cargo loading and discharge equipment;  
• tank venting and inerting systems;  
• fire detecting systems;  
• bilge and ballast pumping systems;  
• waste disposal and sewage systems;  
• communications equipment;  
• emergency lighting; and  
• gangways and means of access. 
 
 
MSIS 2/Rev 06/20 
Page 40 
 
Maintenance procedures must also include work instructions ensuring 
that machinery or systems undergoing maintenance have been rendered 
safe prior to starting work i.e., that systems under pressure such as 
engine cooling water, oil fuel and steam systems have been securely 
isolated and de-pressurised.   
The Company should arrange for inspections of its vessels to be carried 
out regularly. These inspections should be executed in compliance with 
the 
appropriate 
procedures 
by 
competent 
and 
qualified 
personnel. Records of maintenance, inspections, certificates and reports 
may be maintained both on board ship and ashore if considered 
appropriate by the Company. 
There should be procedures for reporting non-conformities and 
deficiencies that should include a time scale for completion of corrective 
action. It is the Company’s responsibility to ensure that reports are 
investigated and feedback provided to the reporting officer. The Company 
should actively provide support to enable the SMS to function effectively. 
5.10.3  
The Company should identify equipment and technical systems the 
sudden operational failure of which may result in hazardous situations. 
The SMS 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. 
 This equipment is commonly referred to as ‘critical equipment’. It is the 
Company’s responsibility to identify critical systems and equipment. Once 
the critical systems have been identified, procedures should be 
developed to ensure reliability of these systems or the provision of 
alternative arrangements in the event of sudden failure. The procedures 
implemented should include the regular testing of stand-by systems to 
ensure that one failure does not result in the total loss of that critical 
function. Routine maintenance should include the regular and systematic 
testing of all critical and stand-by systems. 
5.10.4  
The inspections mentioned in 10.2 as well as the measures referred to in 
10.3 should be integrated into the ship’s operational maintenance routine.  
 Most companies have a preventive maintenance process in place which 
can range from a card-based system to sophisticated software based 
systems. 
 The auditor(s) should examine the measures which have been developed 
to promote reliability including records, frequency of inspection/testing 
and maintenance procedures. In accordance with Section 10.3, these 
items should be incorporated into the vessels planned maintenance 
system (PMS). 
 
 
 
 
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5.11  
DOCUMENTATION 
5.11.1  
The Company should establish and maintain procedures to control all 
documents and data which are relevant to the SMS. 
5.11.2  
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. 
Procedures should be in place for the control of all documentation, which 
should be approved prior to issue and assessed for its user friendliness. 
This is an essential element of any SMS. Personnel at all levels within the 
Company should be familiar with the procedures and with the latest 
version of the documentation. Obsolete documentation should be 
removed from all locations, otherwise, there is the risk that superseded 
procedures may remain in use. 
Companies should be encouraged to limit their documentation to satisfy 
safety and environmental protection requirements. The Keep it Short and 
Simple (KISS) principle should be promoted in the development of 
procedures and instructions. The documentation developed by the 
Company should not be overly long as excessive documentation may be 
counter-productive to the effective functioning of a SMS and prove 
cumbersome for the personnel implementing the system. This however 
should not be of concern if the personnel are able to demonstrate their 
familiarity with the system and are able to locate documents without much 
delay. 
5.11.3  
The documents used to describe and implement the SMS 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. 
 The Company’s SMS should encompass all elements of the ISM Code. 
The use of a matrix to identify relevant sections is a simple and effective 
method. The Company may consider appointing a person ashore with 
responsibility for control, amendment, approval and distribution of SMS 
documentation, which should be monitored by the DPA. On board ship, 
the master will ordinarily have control of the documentation. 
5.12  
COMPANY VERIFICATION, REVIEW AND EVALUATION 
5.12.1  
The Company should carry out internal safety audits on board and ashore 
at intervals not exceeding 12 months to verify whether safety and 
pollution-prevention activities comply with the SMS. In exceptional 
circumstances, this interval may be exceeded by not more than 3 months. 
 Internal audits should be conducted in order to verify that the SMS is 
functioning effectively. All sections of the SMS should be audited on a