2 Verifying compliance with the ISM code
2.1.1 To comply with the requirements of the ISM Code, Companies should
develop, implement and maintain a safety management system to ensure that the safety and
environmental protection policy of the Company is implemented. The Company policy should
include the objectives defined by the ISM Code.*
2.1.2 Administrations should verify compliance with the requirements of the
ISM Code by determining:
- the conformity of the Company’s safety management system with the requirements of the
ISM Code; and
- that the safety management system ensures that the objectives defined in paragraph
1.2.3 of the ISM Code are met.
2.1.3 Determining the conformity or non-conformity of safety management
system elements with the requirements specified by the ISM Code may demand that criteria for
assessment be developed. Administrations are recommended to limit the development of criteria
in the form of prescriptive management system solutions. Criteria for assessment in the form
of prescriptive requirements may have the effect that safety management in shipping results in
Companies implementing solutions prepared by others, and it may then be difficult for a
Company to develop the solutions which best suit that particular Company, operation or
2.1.4 Therefore, Administrations are recommended to ensure that these
assessments are based on determining the effectiveness of the safety management system in
meeting specified objectives, rather than conformity with detailed requirements in addition to
those contained in the ISM Code, so as to reduce the need for developing criteria to
facilitate assessment of the Companies’ compliance with the Code.
2.2 The ability of the safety management system to meet general safety
2.2.1 The ISM Code identifies general safety management objectives. These
- to provide for safe practices in ship operation and a safe working environment;
- to assess all identified risks to its ships, personnel and the environment and
establish appropriate safeguards; and
- to improve continuously the safety-management skills of personnel ashore and aboard,
including preparing for emergencies related both to safety and to environmental
The verification should support and encourage Companies in achieving these objectives.
2.2.2 These objectives provide clear guidance to Companies for the
development of safety management system elements in compliance with the ISM Code. Since,
however, the ability of the safety management system to achieve these objectives cannot be
determined beyond whether the safety management system complies with the requirements of the
ISM Code, they should not form the basis for establishing detailed interpretations to be used
for determining conformity or non-conformity with the requirements of the ISM Code.
2.3 The ability of the safety management system to meet specific
requirements of safety and pollution prevention
2.3.1 The main criterion which should govern the development of
interpretations needed for assessing compliance with the requirements of the ISM Code should
be the ability of the safety management system to meet the specific requirements defined by
the ISM Code in terms of specific standards of safety and pollution prevention.
The specific standards of safety and protection of the environment specified by the ISM Code
- compliance with mandatory rules and regulations; and
- that applicable codes, guidelines and standards recommended by the Organization,
Administrations, classification societies and other maritime industry organizations are taken
2.3.2 All records having the potential to facilitate verification of
compliance with the ISM Code should be open to scrutiny during an examination. For this
purpose the Administration should ensure that the Company provides auditors with statutory and
classification records relevant to the actions taken by the Company to ensure that compliance
with mandatory rules and regulations is maintained. In this regard the records may be examined
to substantiate their authenticity and veracity.
2.3.3 Some mandatory requirements may not be subject to statutory or
classification surveys, such as:
- maintaining the condition of ship and equipment between surveys; and
- certain operational requirements.
Specific arrangements may be required to ensure compliance and to provide for the objective
evidence needed for verification in these cases, such as:
- documented procedures and instructions; and
- documentation of the verification carried out by senior officers of day-to-day
operation when relevant to ensure compliance.
2.3.4 The verification of compliance with mandatory rules and regulations,
which is part of the ISM Code certification, neither duplicates nor substitutes surveys for
other maritime certificates. The verification of compliance with the ISM Code does not relieve
the Company, the master or any other entity or person involved in the management or operation
of the ship of their responsibilities.
2.3.5 Administrations should ensure that the Company has:
- taken into account the recommendations, as referred to in 18.104.22.168 of the ISM Code, when
establishing the safety management system; and
- developed procedures to ensure that these recommendations are implemented on shore
and on board.
2.3.6 Within a safety management system, implementation of codes,
guidelines and standards recommended by the Organization, Administrations, classification
societies and other maritime industry organizations does not make these recommendations
mandatory under the ISM Code
Nevertheless auditors should encourage
Companies to adopt these recommendations whenever applicable to the Company.
The ICS/ISF Guidelines on the application of the International Safety Management Code
provide useful guidance on important individual elements of a safety management system and its
development by Companies