Notes on reading the IMO International Safety Management (ISM)
by Russell Lunt
(This article was first published in the PYA News, 2000.
Copyright 2000 Russell Lunt)
WHAT IS IT ?
The International Safety Management (ISM) Code means the
International Management Code for the Safe Operation of Ships and for Pollution
Prevention adopted by the International Maritime Organization by resolution
A.741 (18). The ISM Code is the standard for establishing a system for the safe
management and operation of vessels and for pollution prevention. It sets rules
for the organisation of the owner or company management in relation to safety
and pollution prevention, and for the implementation of a Safety Management
System (SMS). The system will have to be approved by the flag Administration, or
an organisation recognised by it (normally Classification Societies), then a
Certificate is issued.
An owner can manage his own ship or appoint a management
company, but for the first time, the owner or company ashore (the office – not
just the ship) has to be approved and have a Certificate.
WILL IT APPLY TO YOU ?
Chapter IX of SOLAS requires compliance to the ISM Code. This
new chapter to SOLAS was added by the 1994 Amendments, and is mandatory for
yachts over 500 Gross Tons, which are ‘engaged in trade’ (considered as ‘cargo
ships’ for the purpose of SOLAS). The ISM Code applies to passenger ships,
tankers, high-speed craft over 500GT and larger ships as from 1st
July 1998, but not to other cargo ships (including yachts ‘engaged in trade’)
over 500GT until 1 July 2002.
The management company or owner ashore and the ship must
comply with the requirements of the ISM Code, and the ship must be operated by a
person or company holding a Document of Compliance.
SIZE DOES MATTER!
Don’t relax yet if you have a smaller yacht which is
operating commercially – Resolution 3 of the Conference of Contracting
Governments to SOLAS (adopted 1994) strongly urges Governments to implement as
far as practicable the ISM Code for cargo ships (which includes yachts ‘engaged
in trade’) of 150 GT and over, and requests Governments to inform IMO of the
action they have taken to implement the ISM Code for those smaller ships.
As at January 2000, the IMO advised that only one or two
Member States had advised IMO of their action in this respect, and this was
along the lines of a watered down version of the ISM Code.
The UK Maritime and Coastguard Agency (MCA) were addressing
the situation, and working on a simplified version of the Code for use by
domestic passenger ships. They thought that that Code may also suit cargo ships
between 150 and 500GT which operated on domestic voyages, and said that
compliance with the Code for ships between 150 and 500GT engaged on
International voyages is voluntary.
WHAT IT’S ABOUT.
Like most Codes and Conventions from IMO, the ISM Code is a
practical set of requirements that should have the following ‘good news’
results for yachtsmen:
- It improves safety standards on board, so making a safer working
- It promotes pollution prevention, so making a better marine environment.
- It defines tasks and responsibilities, so making your job easier for you.
Although obviously written with ‘ships’ (as we understand
them) in mind, not yachts, the ISM Code contains general guidelines on which the
SMS should be based, and owners and skippers should have no problem in
developing a SMS which is practical and which relates exactly to the particular
The following quote from the Code serves to illustrate the
general broad terms of wording of the ISM Code:
Recognising that no two shipping companies or shipowners
are the same, and that ships operate under a wide range of different
conditions, the Code is based on general principals.
The Code is expressed in broad terms so that it can have a
widespread application. Clearly, different levels of management, whether shore
based or at sea, will require varying levels of knowledge and awareness of the
IS THIS THE THIN END OF THE WEDGE ?
Management companies, who will be ‘operating’ a number of
yachts for different owners may tend to standardise their operational procedures
relating to safety and pollution prevention. This will lead to lower costs all
round. Shipboard procedures in these areas are pretty standard anyway, so
shoreside procedures could easily be the same for each vessel IN THESE AREAS. As
each yacht owner wants his or her yacht operated in a manner which reflects
their own very specific requirements, it is important that implementation of ISM
Code is not taken as the ‘thin end of the wedge’ and lead to any attempts to
standardise other aspects of yachting.
The ISM Code is divided into 13 sections, as follows:
As a general object, the SMS should ensure compliance with
mandatory rules and regulations, and that applicable codes, guidelines and
standards recommended by the IMO, Flag Administrations, Classification Societies
and Maritime Industry Organisations are taken into account.
The responsibilities of the owner or manager, and the
skipper, are serious, and there is absolutely no room for conflict between the
‘office’ and the ship. The SMS will normally be drawn up so as to best suit
the particular type of operation of the yacht and the owners or managers. It
must be straightforward, based on normal ways of working, and it must be
practical – it must work and be shown to work.
The SMS will be a written description and details which
covers the normal operating procedures adopted for the running of the yacht, the
identifying of possible risk areas and procedures to be adopted to eliminate
risk, and procedures to be used in the case of emergency. Based on the SMS,
shore based staff at the owners or management company office will fulfil the
roles assigned to them, and the SMS should provide for a self-assessment of the
success of the operation of the system. The logging of the exchanges of
information between ship and office will be a valuable part of this
The functional requirements of the SMS are:
- 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 shipboard personnel.|
|Procedures for reporting accidents and non-conformities with the
provisions of the Code.|
|Procedures to prepare for and respond to emergency situations.|
|Procedures for internal audits and management reviews.|
2. SAFETY AND ENVIRONMENTAL PROTECTION POLICY.
The owner or his appointed shore-based managers (the ‘Company’)
should establish a safety and environmental protection policy which describes
how the objectives given above will be achieved.
The Company should ensure that the policy is implemented and
maintained at all levels, on board and ashore.
3. COMPANY RESPONSIBILITIES AND AUTHORITY.
If the entity who is responsible for the operation of the
yacht is other than the owner, the owner must report the full name and details
of such entity to the Flag State Administration.
The Company has to define and document who does what –
responsibilities and authority - (ashore and on board), and make sure that
enough resources are available to enable the persons responsible to carry out
4. DESIGNATED PERSONS.
To ensure the safe operation of each yacht, and to provide a
link between the Company and those on board, the Company should designate a
person or persons ashore having direct access to the highest levels of
management. The responsibility and authority of the designated person(s) should
include monitoring the safety and pollution prevention aspects of the operation
of the yacht and to ensure that adequate resources and shore based support are
applied, as required.
The designated person(s) should be suitably qualified and
experienced in the safety and pollution control aspects of yacht operations.
5. MASTERS RESPONSIBILITY AND AUTHORITY.
The Company should clearly define and document the Master’s
responsibility with regards to implementing the Companies safety and
environmental-protection policy, and the SMS should include a clear statement
emphasising the Master’s authority.
Any system of checks used by the Company should allow for and
take account of the Master’s overriding authority to take whatever action he
considers to be in the best interests of persons on board, the yacht and the
6. RESOURCES AND PERSONNEL.
The Company should ensure that the Master and crew are fit
and properly qualified; that everyone involved with the implementation of the
SMS understands it as well as relevant rules, regulations and guidelines; and
identify and provide any training which may be required in support of the SMS.
7. DEVELOPMENT OF PLANS FOR SHIPBOARD OPERATIONS,
The Company should establish procedures for the preparation
of plans and instructions for key operations on board concerning the safety of
the ship and the prevention of pollution. Instructions and agreed procedures for
operation to be produced and documented in clear language(s) so as to readily
available and understood to everyone concerned with the operation of the yacht.
8. EMERGENCY PREPAREDNESS.
The Company should establish procedures to identify, describe
and respond to potential emergency shipboard situations, and establish programs
for drills and exercises to prepare for emergency actions. The SMS should
provide for measures ensuring that the Companies organisation can respond at any
time to hazards, accidents and emergency situations involving its ships.
9. REPORTS AND ANALYSIS OF NON-CONFORMITIES, ACCIDENTS AND
The SMS should include procedures for the above to be
reported to the Company, and procedures should be established for the
implementation of corrective action.
10. MAINTENANCE OF THE SHIP AND EQUIPMENT.
The Company should establish procedures to ensure that the
yacht is maintained in conformity with the provisions of the relevant rules and
regulations and with any additional requirements which may be established by the
The SMS should identify critical equipment and systems, the
failure of which may result in hazardous situations. Stand-by arrangements to be
The Company to establish and maintain procedures to control
all documents and data which are relevant to the SMS.
The documents used to describe and implement the SMS may be
referred to as the ‘Safety Management Manual’. All relevant documentation to
be carried on board.
12. COMPANY VERIFICATION, REVIEW AND EVALUATION.
The company to carry out internal checks (audits) to verify
whether safety and pollution prevention activities comply with the SMS.
13. CERTIFICATION, VERIFICATION AND CONTROL.
The yacht should be operated by a Company which is issued
with a Document of Compliance (DOC) relevant to that yacht. A copy to be placed
The yacht to be issued with a Safe Management Certificate.
HOW TO GET GOING.
Buy and study the publications listed at the end of this
article. Pass copies to everyone (ashore and on board) who will be involved with
the Operation Procedures and the formulation and operation of the SMS.
WHAT DO YOU THINK OF THE SHOW SO FAR ?
Meet together, and make an initial and honest assessment of
the existing Company and on board procedures. Identify areas where improved or
new procedures are needed. Discuss which systems may already be in place which
could be integrated into the SMS. Shore based responsible person to be
Establish the program to achieve ISM Code Certification. What
has to be done, and by who. Make a timetable, as best fits into the yacht’s
schedule. Discuss requirements for personnel and equipment. Agree the best
format of the various documentation. Centralise available information, and
gather missing details.
SHARPEN YOUR PENCIL!
The Companies Safety & Environmental Protection Policy
should then be drafted.
All employees should then be informed of the Policy, the
importance of the project, and the importance of their role. Responsibilities
and authority are to be clearly defined, and internal systems kept simple. As an
example, first contact personnel (e.g. telephone switchboard operators) should
be totally conversant with the importance of accurate receipt of urgent
messages, and the need to immediately recognise that they may have an emergency
The detailed work of cataloguing documents, agreeing and
writing new procedures, and building up the whole Safety Management System with
the Safety Management Manual(s), Operational Procedure Manuals & Checklists
and whatever else is needed, can then get underway ashore and on board. This is
a time consuming business, but given the use of PC’s & printers, loose
leaf type presentation, ease of copying plans etc., the documentation can be
assembled section by section, and procedures implemented one by one over a
realistic timescale. Flow chart type presentation is a useful way of setting out
some (especially emergency) procedures, and plastification of A4 and A3 size
procedure cards is an obvious and sensible extra. As an example, the following
subject matter could be taken as headings for the various Operational Procedures
which are used whilst the yacht is in port:
Chapter 3. YACHT IN PORT
(see also separate EMERGENCY PROCEDURES)
3.1 Contact details for Port Authorities and local emergency
3.2 Harbour watches.
3.3 Precautions to be taken to avoid pollution.
3.5 Electric and water supplies.
3.6 Control of tally of persons on board.
3.8 Safe working practices on board.
3.9 Safety and Information Briefing for contractors working
3.10 Contact details for crew if ashore.
3.11 Arrangements for collection and disposal of garbage, oil
and noxious products.
3.12 Policy for containment of noise.
3.13 Policy for visitors on board.
3.14 Accidental spillage or discharge of oil or noxious
3.15 Monitoring of stability and safety of mooring.
3.16 Embarkation and dis-embarkation of passengers.
3.17 Procedures if yacht is out of commission.
3.18 Action to be taken if fire or emergency on other vessel.
3.19 Hours of work.
3.20 Documents available for inspection by authorities.
3.21 Special safety procedures and requirements not
3.22 and so on...
The Operations Procedure Manual(s) could also include
separate chapters dealing with (as an example)
Yacht in Port
Pre Depart Checks
Yacht at Sea
Yacht at Anchor
Pre Arrival Checks
and so on.
Given a loose leaf format, the Manual(s) can be continually
improved and updated as best suits the operation of the yacht.
The Safety Manual would contain chapters dealing with all
identified risks. As an example the following subject matter could be taken as
headings for the various procedures which are used in case of fire:
Safety Manual – Emergency Procedures
Chapter 1. FIRE
1.1 IN CASE OF FIRE
1.2 Fire Plan.
1.3 Fire Prevention.
1.4 Fire Detection and Fire Alarm.
1.6 Fire Fighting.
1.8 Abandon Ship.
1.9 Fire Fighting Manual.
1.10 BA Manual.
1.11 Fire Drills.
1.12 Operation and Maintenance of Fire Fighting
Some subjects may be duplicated – for example the muster
and abandon ship and mayday procedures may well be included in any
of the risk management procedure sections as appropriate.
CLASS 4 FOR THE TYPIST?
Training programmes – for shore based as well as on board
personnel - can then be agreed and put into place.
STAMP OF APPROVAL.
The SMS can then be finally tuned up, and application made to
the yacht’s Flag State Authority (the MCA for UK-ships) for Certification.
Both the Company and the yacht will be inspected, and SMS must be demonstrated
to work smoothly and to have been working for 3 months, and of course comply
with the ISM Code.
Inspectors (Auditors) will satisfy themselves that the
various procedures as set out in the Manuals are understood and followed. It is
essential therefore (and common sense) that the procedures are drafted so as to
exactly suit the yacht’s personnel and equipment and the manageable way of
safe operation – not merely a hypothetical description of how things should
happen in a perfect world. This is not to say that a SMS will pass muster if it
is drafted in vague and casual terms and relies only upon a history of safe
operation. The whole process of creating the SMS and setting down the procedures
is a good opportunity to make a detailed analysis of the various operational
procedures on board, and upgrade them as appropriate.
As an example, there may be a procedure for the launching of
the yachts tenders, which requires the Chief Officer to hold a brief meeting
with the crew involved to explain which boat is being launched by which crane,
agree hand signals, allocate duties, identify risks, make pre-launching checks,
advise the Master before launching &/etc. During his audit, the auditor may
wish to witness the operation and confirm that the Chief Officer does hold the
briefing with the crew, that he does advise the Master before launching , and
does follow the procedures. Failure to do so may lead the auditor raising a
The Companies DOC is valid for 5 years, and subject to annual
verification. The yacht’s Safe Management Certificate is also valid for 5
years, and subject to one intermediate verification and the validity of the
Until Flag State Authorities decide if and how they may
implement the ISM Code to yachts ‘engaged in trade’ over 150GT but below
500GT (2008 Note - Commercial Yacht less than 24m
now need to comply with a diluted version of the Code), the ISM Code will apply (after 2002) only to those yachts over 500GT
being ‘engaged in trade’. Some smaller yachts may decide to voluntarily
comply, with personnel ashore and on board gaining useful and early experience
of the working of the system. A widespread appreciation and adoption of the ISM
Code would certainly set the operational side of our business up a notch or two,
and handled sensibly by capable professional yachtsmen and women on board and
ashore who know the importance of ‘freedom of choice’ to yacht owners, it
should not lead to any loss of fun nor encroach upon the valuable and
traditionally close and confidential relationship which yachtmasters enjoy with
INTERNATIONAL SAFETY MANAGEMENT CODE (ISM CODE)
AND GUIDELINES ON IMPLEMENTATION OF THE ISM CODE
English Language Version IMO-117E
GUIDELINES FOR THE DEVELOPMENT OF
SHIPBOARD OIL POLLUTION EMERGENCY PLANS
English Language Version IMO-586E
International Maritime Organization, 4, Albert Embankment,
London, SE1 7SR.
Tel: +44 (0) 20 77 35 76 11 Fax: +44 (0) 20 75 87 32 41
GUIDELINES ON THE APPLICATION OF THE
IMO INTERNATIONAL SAFETY MANAGEMENT (ISM) CODE
International Chamber of Shipping, and
International Shipping Federation,
12, Carthusian Street, London, EC1M 6EB,
Tel: +44 171 417 8844 Fax: +44 171 417 8877