ISO 45003 in Military Operations: A Framework for Psychological Health and Operational Readiness at Sea

Bridging ISO Management Standards and Naval Operational Readiness

Integrating ISO 45003:2021 into military operations, particularly naval operations, specifically in the context of high tempo carrier strike group deployments like the USS Abraham Lincoln and other deployments of armed forces provides a compelling framework for evaluating psychological health, operational fatigue, and organizational resilience. For subject matter experts in management system standards like me and those planning the operations and those in command the standard gives a useful framework. I think ISO 9001 clause 7.1.4 requiring creation of an environment for the operation of the processes is worth considering. This is further amplified by ISO 45001 occupational health and safety standard in general terms. The addition of ISO 45003: 2021 centered on psychological health and safety at work provides very useful guidelines for managing psychological risks. In the present context linking ISO 45003, operational readiness, and naval safety would create a strong bridge between international ISO management system standards and naval oversight. This aligns directly with how Annex SL harmonized structure connects quality, physical safety, and psychosocial well-being into a unified management architecture. After all, as Napoleon said, “morale is to physical, as two is to one”. Not to forget “an army marches on its stomach,” implying understanding risks and planning the logistics.

Operationalizing Psychological Health During Extended Naval Deployments

Operationalizing psychological health at sea is a reality particularly when deployments are extended. Applying ISO 45003 to extended deployment of military units particularly to aircraft carriers and nuclear submarines the application of the standard would enable better and systematized risk appreciation and planning. Operations planning where deployments are away from the country/ home base and the period of deployment is extended and sometimes uncertain the context and the high tempo operational environment the risks must be considered (clause 4 context of the organization of ISO 45003 leading to clause 6.1 actions to address risk and opportunities).

Psychosocial Hazards in High-Tempo Carrier and Submarine Operations

Appreciating the operational context for each deployment must consider the unique psychological hazards of high-stress naval deployments (e.g., high-speed flight operations, extended periods at sea, geopolitical tension, unpredictable schedule shifts, availability of logistics, rest and recreation, changed work hours and isolation etc.). ISO 45003 clause 4.1 explicitly mandates assessing both external aspects (geopolitical instability, extended sea lines of communication) and internal aspects (vessel design limitations, habitability, sleep architecture). For an aircraft carrier and other surface units the bridge physical safety with psychosocial risk management are relevant inputs. Physical safety controls (ISO 45001) are incomplete without addressing operational stress, decision fatigue, sleep deprivation, and psychological safety (ISO 45003). These are further extenuated in nuclear submarines where prolonged submergence, lack of natural light, and extreme isolation amplify cognitive strain.

The Three Domains of Psychosocial Risk Under ISO 45003 Clause 6.1.2.1

Understanding the ISO 45003 framework in a naval unit and incorporating it in operational planning would provide the systematized resource planning and preparations. ISO 45003 as a guidance document that extends ISO 45001 by identifying psychosocial hazards across three key domains outlined in sub-clause 6.1.2.1. It can look at how work is organized (clause 6.1.2.1.1: shift patterns, watch standing rotations, high workload, administrative overload). Then there are the social factors (clause 6.1.2.1.2: command climate, communication, leadership dynamics, isolation) and a discussion on work environment and hazardous tasks (clause 6.1.2.1.3: confined spaces, high noise, operational danger, vibration, high heat on flight decks). All these and more that commanders at sea could provide would enable better defining of the context of the organization.

Mapping ISO 45003 Clauses to Carrier Strike Group Operations

Looking at the clauses in ISO 45003 the key clauses mapping and deployment application would strengthen the planning effort. For example, the operational planners could map key ISO 45003 clauses directly to operational conditions aboard a deployed aircraft carrier.

Clause 4 — Context of the Organization

ISO 45003, clause 4, context of the organization covering context and needs of personnel in clause 4.1 / 4.2 requires assessing external drivers (geopolitical conflict, extended deployments) and internal stressors (watch schedules, habitability, separation from families). Clause 4.3 further reinforces defining the boundary of the management system thereby ensuring psychological safety applies equally to organic ship’s company, embarked air wing personnel, and staff elements.

Clause 5 — Leadership and Worker Participation

Clause 5 related to leadership and worker participation in clause 5.1 / 5.4 provides the inputs for leadership commitment to psychological safety. Clause 5.1 requires top management to demonstrate accountability by ensuring resources are allocated for mental health support, while Clause 5.4 mandates consultation with personnel without fear of reprisal. Demonstrating that leadership balances mission accomplishment with crew fatigue and mental well-being, fostering open communication without stigma or fear of career reprisal.

Clause 6 — Planning and Psychosocial Risk Assessment

Clause 6 related to planning and psychosocial risk assessment in clause 6.1.2 requires proactive identifying of psychosocial hazards. Evaluating the compounded impact of fatigue, high job demands, low autonomy, and environmental stress on deck and in combat direction spaces. Under clause 6.2, commands must establish measurable objectives regarding fatigue metrics, rest-hour compliance, and psychological safety indicators.

Clause 8 — Operational Control and Risk Elimination

Further clause 8, operational control and risk elimination in clause 8.1.2 looks at implementing operational controls managing watch and station bill rotations, enforced rest cycles, access to mental health professionals (e.g., Chaplain, OSCAR t[i]eams), and clear command communication. In line with ISO clause 8.1.1, controls must follow a hierarchy—where hazard elimination isn’t feasible during combat operations, robust administrative controls (enforced circadian watch schedules, rotational relief) become the primary line of defense.

Clause 7 — Support, Competence, and Communication

Clause 7 (support) also plays a key role here through clause 7.2 (competence) and clause 7.4 (communication). Division Officers and Chief Petty Officers must be competent in recognizing early signs of psychological distress, while transparent communication down the chain of command during schedule changes directly mitigates rumor driven anxiety.

Auditing Psychological Safety: The PDCA Cycle and Clause 9

The PDCA (plan, do, check and act) cycle which is the fundamental of the process-based management system approach in implementing all the harmonized standards which includes ISO 45001 and in this case ISO 45003, the check stage is important. Therefore, effective auditing of psychological safety by the armed forces auditors would drive continual improvement. Clause 9.1 (monitoring, measurement, analysis and performance evaluation) combined with clause 9.2 (internal audit) provides the mechanism for this verification. The discussion would bring up how they conduct independent, third-party evaluations across the Naval Enterprise to verify risk controls and safety management systems (SMS). Auditing beyond physical compliance of ISO 45003 lens requires analysis of how service auditors can evaluate whether a command is “safe to operate and operating safely” by assessing psychosocial health metrics including by self-assessment and self-correction. They would ask questions including if the command leadership evaluate fatigue and burnout indicators prior to high-risk flight deck operations? Audit traps and behavioral indicators would include auditing beyond surface-level checklists and looking at medical department stress reports, watch stander qualification pacing, incident reports linked to human error, and command climate surveys.

Worker Involvement and Psychological Safety Within Military Command Structures

One of the underlying principles in OH&S is involvement of the workers. In all other standards the leadership decisions are sufficient. However, in occupational health the worker involvement and perception on feeling safe, secure and healthy is important. This can sometimes cause conflict with military requirements when command and control may require going in harm’s way. This does not imply, not considering the risk. Therefore, incorporation of risk evaluation and communication is a factor. Testing if junior sailors and division officers feel empowered to stop unsafe evolutions caused by acute fatigue or psychological strain (psychological safety in practice) keeping within the military directions is a factor in interpretation of the standard. This directly operationalizes clause 5.4, proving that worker participation can coexist with traditional military command structures by establishing clear boundaries where operational safety interventions are welcomed rather than penalized.

Strategic Benefits of Integrating ISO 45003 and ISO 45001

Strategic benefits and recommendations in incorporating ISO 45003 with ISO 45001 in working systematically would include strengthening operational readiness and resilience. Use of ISO 45003 would address hazards directly reduces human-factor mishaps, improving retention, and enhances tactical focus during critical operations. Clause 10 (improvement) ensures that lessons learned from near-misses, fatigue-related mishaps, or extended surge operations feed back into operational planning for future deployment cycles.

Practical Recommendations for Naval Quality and Safety Systems

Practical recommendations for naval quality and safety systems would include formalizing psychosocial audit criteria by incorporating ISO 45003 guidelines into naval safety audit protocols alongside physical safety metrics. Predictive fatigue management by using data-driven scheduling tools aligned with clause 8 operational controls would be a strong recommendation. Of course, leadership training would educate senior leadership and department heads on identifying early indicators of psychosocial distress within division teams.

Conclusion: Mental Well-Being as a Core Operational Readiness Metric

In conclusion, I would say treating mental well-being and psychosocial risk management as core operational readiness metrics validated through rigorous auditing and oversight helps ensure that capital assets like the USS Abraham Lincoln remain fully combat-capable and resilient.

[i] OSCAR Team Uses Technology to Identify Mental Health Risk Factors — Navy Medicine (link at the “Chaplain, OSCAR teams” reference) — https://www.med.navy.mil/Media/News/Article/2609002/oscar-team-uses-technology-to-identify-mental-health-risk-factors/

About the Author:

Inderjit (IJ) Arora, Ph.D., is the Chairman of QMII. He serves as a team leader for consulting, advising, auditing, and training regarding management systems. He has conducted many courses for the United States Coast Guard and is a popular speaker at several universities and forums on management systems. Arora is a Master Mariner who holds a Ph.D., a master’s degree, an MBA, and has a 35-year record of achievement in the military, mercantile marine, and civilian industry.

Subchapter M and TSMS Certification: What U.S. Towing Vessel Operators Must Know

Subchapter M ushered in a new era for safety on US inland waters. It outlined requirement for towing vessels to improve the overall safety of marine transportation on inland water. Subchapter M compliance began with the publishing of the rule in July 2016 with a phased implementation approach and a requirement for all vessels to hold a valid Certificate of Inspection (COI) by July 2022.

These United States Coast Guard, USCG towing vessel regulations outlined requirements for crew competence, better office oversight of vessel management, equipment standards and requirements for emergency preparedness. Subchapter M requirements 2026 have not changed since inception, however, there has been much additional guidance on interpretation of requirements published by the USCG.

In the 90s and 2000’s, there was an increase in major incidents on inland waterways including collision of towboats & barges with other boats and allisions with shore infrastructure such as bridges resulting in fatalities and impact to the local economy. Studies cite 60–80%+ of incidents owe to human-system interface failure.

With the requirement in force the grace period is now over. These towing vessel safety regulations are now law via US Code and US CFR as outlined in 46 CFR Subchapter M.

TSMS vs. Coast Guard Inspection: Choosing Your Compliance Path

Vessel owners have two options to ensure compliance with the regulations. The two options include a TSMS option and Inspections by the USCG. There are pros to each and below is outlined the TSMS vs Coast Guard inspection options:

Option 1 (Coast Guard inspection): This consists of an annual inspection by the USCG within 3 months of COI anniversary. These are scheduled directly with the USCG and incur a fixed fee as outlined by the USCG. In this option each boat must get inspected each year. For owners with large fleets this cost can be high. These Coast Guard annual inspections are also dependent on USCG personnel availability.

Option 2 (TSMS): Using this option the vessel owner contracts with a USCG approved third-party organization (TPO) who must assess office and vessel operations and issue a TSMS certificate of conformity six months before the COI date. Under this option all vessels under the TSMS must be audited at least once in a 5-year period. Under TSMS costs can be lower and there is more predictable scheduling, but it requires the building of internal systems.

Penalties and Operational Risk of Non-Compliance

With the subchapter M rule in force, towing vessels cannot legally operate without a valid COI. Without a COI or a TSMS Certificate of conformity (on the basis on which a COI is effective), vessel owners can take a direct hit to their revenue because of Subchapter M penalties and downtime.

There is also the potential for marine insurance coverage and liability protection costs to be impacted because of the towing vessel compliance risk. More importantly though non-compliance bears an underlying risk of a vessel not operating to standards. This can lead to major onetime costs for an owner as a result of a major incident/accident on the waterway.

A system approach allows the owners to be aware of potential risks before they impact business and to proactively address them. There are also the intangible risks associated with impact to company reputation.

Lastly substandard vessels not complying with the 46 CFR subchapter M requirements can be detained by the USCG and prevented from operating until all issues have been resolved.

Building a Towing Safety Management System (TSMS)

A compliant TSMS does not start with the TPO showing up to audit, it starts with a gap analysis. TSMS development begins with comparing an operator’s existing procedures against what Subchapter M actually requires, which shows the office and vessels where they stand and what policy and procedure development still needs to happen before an auditor is ever involved.

From there owners build out the actual safety management system for towing vessels — policies covering navigation, mechanical and electrical systems, and towing operations, plus procedures for reporting near misses and hazardous conditions. Crew training has to follow, and it needs to be real familiarization on these procedures rather than a manual handed out and never opened, since Subchapter M puts a lot of weight on crew competence as part of the TSMS certification process.

Documentation and recordkeeping is really the backbone of a defensible TSMS. Auditors and the USCG want objective evidence — training records, maintenance logs, drill records, internal audit findings — that shows the system is being followed day to day, not just written down and filed away.

Once policies, training and documentation are in place, the operator runs its own internal audit before the TPO conducts the external certification audit. That relationship with the TPO does not end at certification — TSMS audit requirements call for periodic external audits going forward, with a full vessel audit at least once every five years and a management audit twice in that same five-year period.

Building a Towing Safety Management System from a blank page can take months, which is why most operators lean on ready-made templates over using a consultant to reduce costs. However, a poorly built foundation can kill a system over time. It results in too much documentation, additional burden for the crew and a system that only lives on paper.

This is where a partner like QMII fits in to help build a strong foundation with a system documented to fit the operational need, to reduce the compliance burden on the crew/office, and to provide valuable insights with their extensive maritime expertise. QMII helps to shorten the runway from initial gap analysis to a certified, audit-ready TSMS.

Designated Person Ashore: Roles and Certification Requirements

One of the key factors for success of a safety management system is the role the company management play in it. This includes the provision of resources needed for the system to be implemented well by the vessel crew. To enable this support the TSMS requires a Designated Person Ashore (DPA). This person is to be nominated by the company and must have a access to the highest level of management ashore.

The DPA has their own TSMS management responsibilities, acting as a shoreside link between vessel operations and management. They are responsible for monitoring safety and compliance of vessel operations across the fleet. The DPA is the person a captain or crew member can approach to escalate a safety concern, knowing it will not just get overridden by production pressure.

This is a role companies often underestimate until an audit finds gaps in how it actually functions day to day. DPA certification and TSMS management responsibilities training give the person in this seat a working knowledge of what the USCG and TPO expect to see documented, not just a title on an org chart.

For owners setting up a TSMS for the first time, or replacing a DPA who has moved on, QMII’s Designated Person training for this role is a natural next step. It helps provide those without prior DPA experience with the knowledge needed to execute in the role.

Auditor Training for Internal TSMS Oversight

Audits play a crucial role in assessing the state of conformity and the effectiveness of the system. Internal auditors conduct audits to provide insight to the leadership on potential risks that may catch them blindsided. While inspections and maintenance checks are regular occurrences, they do not assess the interaction of the processes and the interaction of the shore and the vessel TSMS.

Subchapter M outlines requirements for internal audits to be conducted once annually at a minimum and also identifies the criteria for internal auditors. TSMS auditor training for internal auditors includes them completing an ISO 9001 lead auditor course or equivalent. This maritime compliance auditor course helps auditors prepare for planning, conducting and reporting of audit results. Auditors must objectively assess the evidence they are given and draw conclusions based on factual evidence and not on opinions.

With over 40 years of experience in teaching auditor courses this is key distinction of QMII’s auditor training. QMII’s ISO 9001 auditor training meets the requirements of Subchapter M and teaching auditors to go beyond merely seeking conformity. Trained internal auditors can through internal audit towing vessel better assess the system effectiveness.

Maintaining Certification Through Ongoing Audits and Renewals

Getting the TSMS certificate is not the finish line, it’s the starting point for an ongoing compliance cycle. Once certified, operators must conduct annual internal audits plus the undergo the external audit cycle run by the TPO. A full vessel audit at least once in five years for each vessel and a management audit twice within that five-year window. Missing either side of that cadence puts the certificate, and by extension the COI, at risk.

Most compliance failures at this stage are not drastic, they’re just neglect. Documentation lapses, an internal audit that gets pushed back a quarter and then forgotten, a missed audit window because nobody was tracking the anniversary date. Crew turnover is another common one; a new captain or engineer who was never properly familiarized with the TSMS procedures.

The operators who stay ahead of this treat certification maintenance as a standing responsibility, not a once-a-year scramble before the TPO shows up. That usually means someone managing the audit calendar, keeping training records current as crew changes, and catching small gaps before they become findings. The Master should ensure this on behalf of the company.

This is also where ongoing training and consulting support earns its keep. Rather than relearning TSMS renewal requirements every time an audit window approaches, operators working with a partner like QMII can keep certification active on a predictable schedule instead of managing it as a recurring emergency.

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About the Author

Julius DeSilva is CEO of QMII (Quality Management International, Inc.), with more than 25 years of experience in quality management systems, maritime safety and security, and information security. A former seagoing officer and Exemplar Global Certified Lead Auditor (ISO 9001, ISO 27001, ISO 50001, RC14001), he has trained over 1,500 professionals as lead auditors and led consulting and auditing engagements across manufacturing, government, maritime, and aerospace sectors. He holds an MBA from the Darden School of Business, University of Virginia, and is an Associate Fellow of the Nautical Institute.

What the ISM Code Can Teach Us About Risk: Part Two

Editor’s note: This is the second of a two-part article examining the risk-based thinking lessons to be learned from maritime safety and security protocols. You can read part one here.

The International Safety Management (ISM) Code brings a framework for safety through systematic management. It was introduced by the International Maritime Organization after several major maritime accidents revealed a common problem: The causes were rarely technical alone; instead, they were failures of management systems. The ISM Code, therefore, established a simple but powerful requirement, wherein shipping organizations must implement a documented safety management system (SMS) to ensure the safe operation of ships and the protection of the environment.

The principles embedded in the ISM Code offer valuable lessons for organizations operating in any uncertain environment. Many of these principles also resonate strongly with ISO 9001, the international standard for quality management systems. Let us examine a few of those connections.

Connecting the ISM code and ISO 9001

The ISM Code is not a technical manual for operating ships. Instead, it requires organizations to establish structured processes addressing leadership responsibility, risk assessment, operational control, training and competence, incident reporting, corrective action, and continual improvement. These requirements may sound familiar to anyone working with ISO management system standards such as ISO 9001 and others following the harmonized structure. In essence, the ISM Code recognizes a fundamental truth in that safe operations are the result of disciplined management systems, not individual heroics.

Establishing an SMS based on the ISM code and principles of ISO 9001 means planning for the unexpected. One of the most relevant principles in the ISM Code is the requirement to identify potential emergency situations and establish procedures to respond to them. Ships are required to plan for events such as fire, collision, grounding, machinery failure, person in water, and/or security threats or piracy. (Note that maritime security is covered by the International Ship and Port Facility Security Code and ISO 28001 covering security management systems for the supply chain). These procedures are not theoretical. Crews regularly conduct drills so that when an emergency occurs, the response is not improvised.

Organizations often interpret risk narrowly, focusing only on operational or financial risks. The ISM Code reminds us that effective management systems anticipate unexpected and low-probability events that can disrupt operations. In quality management terms, this is the discipline of considering what could go wrong and if people know their roles if (when) it does. It also means interrogating the system to determine how the organization will handle the ramifications of the adverse event.

Leadership and responsibility are important in maritime life. Another core principle of the ISM Code is clear authority and responsibility. Sections 5.1 and 5.2 require that on board a ship, there is no ambiguity about who is responsible for the safety of the vessel. The master has overriding authority. At the same time, as per section 4, the ISM Code requires those off the ship to support the master through a defined role known as the Designated Person Ashore (DPA). This individual provides a direct link between shipboard operations and top management. This structure reflects two key leadership principles: Authority must match responsibility and top management must remain connected to operational realities.

ISO 9001 expresses the same idea in a different context. As seen in clause 5.1 (“Leadership and commitment”) and clause 5.3 (“Organizational roles, responsibilities, and authorities”) leadership is required to ensure that the quality management system is integrated into the organization’s processes and that responsibilities and authorities are clearly assigned. Without this alignment, procedures quickly become paperwork rather than operational guidance.

In the case of mariners, competence and training are systematized. The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW) ensures that seafarers are properly trained and certified for their duties. But beyond certification, maritime safety culture emphasizes something equally important: continuous drills and practice. Crew members rehearse emergency responses repeatedly. Fire drills, abandon-ship drills, and damage-control exercises are conducted not because emergencies are frequent; instead, it is because although they are rare, they are also highly consequential. This principle translates directly into quality management. Competence is not merely about qualifications; it is about preparedness to perform under pressure. Organizations that rely solely on written procedures without practical rehearsal often discover gaps only when a crisis occurs.

Learning lessons from incidents, as seen in ISO 9001’s clause 7.1.6 (“Organizational knowledge”) is integral to the SMS, making it a critical requirement of the ISM Code requiring the reporting and investigation of nonconformities, accidents, and hazardous occurrences. The purpose is not to blame, but to learn. Each incident becomes an opportunity to ask, “What failed in the system?” “What corrective action is needed?” and/or “How do we prevent recurrence?” Again, this is entirely consistent with ISO 9001’s approach to corrective action and continual improvement. The difference in the maritime world is that the consequences of failure can be immediate and severe. As a result, the discipline around incident learning is deeply embedded in the culture.

Risk decisions at sea and in maritime organizations need consideration about all key decisions, including how and when to transit dangerous areas. These decisions are rarely simple. They require balancing safety risks, commercial pressures, and regulatory requirements, including ever-changing statutory requirements of various contracting governments. This must be seen within the contexts of operational capability and the need to ensure crew welfare. The ISM Code does not dictate the decision. Instead, it ensures that the process for making the decision is structured and informed. This is perhaps the most valuable lesson for quality professionals. Management systems do not eliminate risk; they provide a framework for making better decisions about risk.

The ISM Code as a case study for risk-based thinking

Mariners have much to teach quality professionals on the use of the system approach for considering risks. For those working in quality assurance, auditing, or conformity assessment, the maritime experience offers several enduring lessons:

  • Systems matter more than individuals; therefore, while competent people are essential, reliable operations depend on structured systems.
  • Leadership must remain engaged in safety or quality, and this accountability cannot be delegated away.
  • Leaders must prepare for rare but high-impact events, because risk management is not only about what happens frequently.
  • Practice builds readiness.
  • ISM auditor Training and drills ensure procedures work under real conditions.

The takeaway is that there is a need to learn relentlessly from failure and use nonconformities as opportunities to strengthen the system.

The need to navigate uncertainty strengthens the importance of the ISM Code and/or ISO 9001 to inform leaders about risk and process management. For ship owners and masters, decision-making requires a complete and quick update of risks and other factors. For those who have spent a lifetime at sea, uncertainty is part of the profession. Mariners routinely navigate storms, mechanical failures, and complex navigational environments. Yet despite these uncertainties, global shipping remains remarkably reliable. More than 80 percent of world trade moves by sea, and the system functions with a level of safety and predictability that most industries take for granted.

The ISM Code, as well as ISO 9001, recognize that outcomes, whether safety or quality, depend on well-defined processes and leadership oversight. To mariners and quality professionals alike, I would advise another close look at your management system. Strengthen it. Maritime leaders ashore, like executives in the boardroom, must stay involved in assessing and mitigating risks to provide the best chance for safety, security, and success.

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About the author

Inderjit (IJ) Arora, Ph.D., is the Chairman of QMII. He serves as a team leader for consulting, advising, auditing, and training regarding management systems. He has conducted many courses for the United States Coast Guard and is a popular speaker at several universities and forums on management systems. Arora is a Master Mariner who holds a Ph.D., a master’s degree, an MBA, and has a 35-year record of achievement in the military, mercantile marine, and civilian industry.

Home » Maritime

What the ISM Code Can Teach Us About Risk: Part One

For centuries, individuals have sailed the sea, perhaps for their livelihood, perhaps for adventure, or perhaps for reasons of their own. Christopher Columbus, Ferdinand Magellan, James Cook, and countless others changed the world.

Today, sailing through international waters to meet the basic needs of the world brings challenges. Without merchant ships, tankers, bulk carriers, and container vessels, the global supply chain stops. Doesn’t the world owe these mariners all due safety and security?

I am a former seafarer who commanded submarines in the Indian Navy and then continued my career as a master in the merchant marine. Today, I am a subject matter expert in issues related to maritime safety and security. Given this background, I feel compelled to analyze what I hear and read about current events and provide a structure whereby the merchant marine industry might better prepare for any and all eventualities. The International Safety Management (ISM) Code, the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), and ISO 9001 all provide process-based approaches that can be used by those in this industry for planning and risk mitigation.

Most of us do not have to deal with high-risk challenges at sea. For those who do, however, there are guidelines they can use. As one example, the ISM Code provides some lessons into anticipating the unexpected and planning for these risks in a systematic manner.

In this article I will touch on how portions of the ISM Code connects to elements of ISO 9001 and provide input that might be useful to maritime leadership in ensuring quality assurance and conformity assessment based on risk and considering the context in which these organizations operate. This is guidance that applies to any of us, on the water or in a facility or factory.

Similarities between the ISM Code and ISO 9001

For professional mariners, a simple rule applies: Conditions that appear routine can change without warning. The ISM Code emphasizes preparedness for emergencies and abnormal situations. Section 8.1 requires the organization to establish procedures to identify, describe, and respond to potential emergency situations aboard the ship. In other words, the ISM Code requires organizations to plan not only for technical failures or weather hazards, but also for security risks and unexpected external threats. Navies may refer to this as an operational assessment, but (in Shakespearean language) a risk by any other name would still be a risk.

ISO 9001 expresses a comparable idea through the requirement for risk-based thinking. As emphasized in clause 6.1.1, the organization shall determine the risks and opportunities that need to be addressed to give assurance that the quality management system can achieve its intended results.

From a management systems perspective, the broader lesson is clear: Organizations must plan for situations that may appear unlikely until they occur. For a ship’s captain or master, that planning may involve security drills, contingency routing, and coordination with naval authorities. For a quality manager or organizational leader, it may involve supply chain disruption, cybersecurity incidents, or geopolitical shocks. Ultimately, the decision on whether to sail should be based on a proper risk assessment. Events at sea sometimes remind us, in stark terms, why disciplined safety and command systems matter. What makes an incident significant in the context of this discussion is the reminder of just how quickly circumstances can change at sea.

Within ISO 9001, the context of the organization (clauses 4.1 and 4.2) leads to risk appreciation (clause 6.1). All of this must be integral parts of the maritime management system, at sea or ashore.

This is precisely why the ISM Code emphasizes preparedness for emergencies and abnormal situations as per section 8.1. Good organizations connect real maritime events with risk-based thinking. They understand that commercial interests must mesh with the emergency planning sections in the ISM Code. This understanding is also found in ISO 9001, specifically in clause 6 (“Planning”) and clause 8 (“Operation”).

Expecting the unexpected

My own appreciation for disciplined systems thinking was shaped long before the ISM Code was widely implemented in commercial shipping. During my years in the Indian Navy, I had the privilege of commanding vessels, first on F-class boats and later through service on a Charlie II-class submarine. Submarines operate in an environment where uncertainty is not theoretical and the margin for error is extremely small. Any failure in equipment, communication, or procedure can quickly become critical. What keeps submarines safe is not individual brilliance on the part of a captain or crew. That is part of it, of course, but even more important is the relentless adherence to procedures and constant preparation for contingencies. Before every patrol, the crew repeatedly rehearses emergency actions such as flooding drills, fire drills, loss of propulsion, and loss of power. Each crew member knows precisely where to go, what valve to operate, and what sequence of actions to follow. These procedures are not simply found in written manuals. They are practiced until they become instinctive.

At that time, we did not describe this discipline in terms of “process-based management systems,” but that is exactly what it was. The system existed to ensure that when the unexpected occurred, as it inevitably does at sea, the crew would not rely on improvisation alone. The response would already be embedded in the system and in themselves. Years later, when I sailed as a master in the merchant marine and then began to work with ISO management systems, I recognized the same principles expressed in a different language. ISO 9001 requires organizations to establish, implement, and maintain the processes needed for the quality management system and their interactions, as per clause 4.4 (“Quality Management System and its Processes”). Section 1.2 of the ISM Code similarly requires organizations to ensure safe practices in ship operation and a safe working environment. Different industries, different terminology, but the underlying idea is identical: Safety, quality, and reliability are the result of preparation and training, not simply reacting well to emergencies.

I can confirm through my experience that this reflection is not merely theoretical. It comes from first-hand experience wherein I led teams and where preparation truly mattered. This background gives me a clear perspective on risk, command responsibility, and disciplined procedures under uncertainty. This perspective can make a very compelling bridge between maritime safety management (ISM/STCW) and organizational quality systems (ISO 9001).

As we consider dangerous situations on or in the water, we can see what the ISM Code and ISO 9001 (in addition to other maritime protocols and ISO standards) can teach us about risk in uncertain times. In today’s volatile world, commercial shipping once again finds itself navigating geopolitical tension. News headlines remind us that vessels may need to transit waters where the risks are not merely commercial, but also matters of safety and survival. For those who have spent a career at sea, such circumstances are not entirely unfamiliar. The maritime profession has long recognized that uncertainty is inherent to operations. Ships sail through storms, equipment failures, and occasionally conflict zones. Yet despite these uncertainties, shipping remains one of the safest and most reliable global industries. This is not an accident. Much of that safety culture comes from the ISM Code, supported by training standards such as STCW. These frameworks provide reliable, structured guidance on how organizations anticipate risk, prepare crews, and maintain operational control.

In the next part of this two-part article, we will further discuss the framework of maritime systems and how they relate to risk and ISO 9001.

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About the author

Inderjit (IJ) Arora, Ph.D., is the Chairman of QMII. He serves as a team leader for consulting, advising, auditing, and training regarding management systems. He has conducted many courses for the United States Coast Guard and is a popular speaker at several universities and forums on management systems. Arora is a Master Mariner who holds a Ph.D., a master’s degree, an MBA, and has a 35-year record of achievement in the military, mercantile marine, and civilian industry.

Procedure, Work Instruction, or Flowchart?

-by Dr. IJ Arora

The choice between writing a procedure or a work instruction is an essential decision when designing a management system. Clause 4.4.1 of ISO 9001:2015 (as well as all the ISO management system standards using the harmonized structure) requires the establishment and implementation of a management system. This management system will have procedures and work instructions and further down the hierarchy, checklists and forms.

Processes can be actualized in many forms. Today, mapped processes make it easy to visualize the functioning of the process. This is an important distinction in quality management systems based on ISO 9001—or for that matter any sector-specific standard like those dedicated to management within maritime, aerospace, etc. Many organizations struggle with when to write a procedure, when to write a work instruction, and how and when a flowchart should be used.

I think the core difference between a procedure and a work instruction is that a procedure answers the question, “What happens and who does it?” A procedure defines the process, its purpose, its sequence (clause 4.4.1b), and who is responsible for the work, perhaps as process owners (clause 4.4.1e). It answers what is to be done, when it must be done, who is responsible, and why it matters. The flowchart then helps visualize the inputs and outputs that flow between the steps.

What is a procedure and how it is used?

A procedure does not tell someone how to do a task; it simply describes the steps or stages necessary to accomplish it. I think of the procedure as the blueprint of the workflow. Therefore, I would recommend using the procedure when multiple people or departments are involved, when there is decision-making or sequencing, when the process crosses functional boundaries, and when documenting the process supports consistency, audits, or training. The procedure is also best when regulatory bodies expect clearly defined processes.

What is a work instruction and how is it used?

On the other hand, a work instruction shows stakeholders how exactly a task is to be accomplished. A work instruction “goes into the weeds” to the extent required by the workforce (depending on their confidence, competence, knowledge, and so on). It describes specific methods, often at a deep level of detail. It answers questions such as:

  • “How do I perform this task?”
  • “What tools, equipment, settings, forms, and/or software steps are required?”
  • “What are the acceptance criteria?”
  • “What do I check and how do I measure performance?”

Remember, work instructions are intended to be simple, direct documents for use by the workforce. Use them when:

  • A task requires technical, step-by-step details
  • Training new personnel
  • Incorrect execution can create quality or safety risks
  • Standardization is essential
  • Variation in execution must be eliminated

What is a flowchart and how is it used?

Flowcharts can technically be used to support both procedures and work instructions, but I generally recommend their use in conjunction with procedures. This helps make the procedure visual by mapping the 50,000-foot view of a process. A flowchart is ideal when the process has multiple decision points, parallel paths, several departments interacting, and inputs/outputs that must be made clear. The flowchart helps avoid the confusion that can come when procedures are described in long paragraphs. Flowcharts make complex processes easy to understand immediately. I therefore believe in flowcharting a procedure when the process needs high-level clarity, the sequence matters, when an organization wants to show interactions between departments, when it supports risk-based thinking, and when you want to simplify training for new personnel.

Flowcharts work best for document control, non-conformances, and corrective action processes, purchasing and supplier management, production scheduling, quality inspection, and testing flows and change management processes (as seen in clauses 5.3e, 6.3., 8.2.4, 8.3.6, and 8.5.6). Flowcharts do not replace work instructions; they complement them.

Final thoughts

To sum up how these tools work together, the practical document hierarchy an organization could consider starting with policy (and why that policy exists), move into documenting the procedure (preferably supported by a flowchart) to convey what happens and in what order, and then crafting work instructions to clarify how to carry out specific tasks. Finally, document everything through records and forms to provide evidence that the work was performed.

All this should connect as a system where a flowchart procedure should describe the process, a work instruction explains each critical task, and the documented information provides traceability. Performance monitoring (clause 9) can be documented via procedures, work instructions, and flowcharts.

 

Note – The above article was recently featured in an Exemplar Global publication ‘The Auditor’. 

ISM Code to Bridge the Shore – Ship Gap: Making SMS a Living System

I take pride on my experience as I work with our maritime clients emphasizing the personal perspective from both below and above the surface of this ocean. My view of the ISM Code is shaped by a life at sea. I spent good 22 years of the early part of my career in the Indian Navy, eventually commanding two F-class submarines and later serving on India’s first nuclear submarine a Charlie II. After leaving the Navy, I served for a decade as Master in the mercantile marine. Then as a VP in the second largest ship registry, the Liberian Flag for 3 years and now as the leader of the QMII team. I have seen safety management from the control room of a submarine and from the bridge of a merchant ship, in fair weather and in crisis. These experiences have convinced me that a Safety Management System only works when it is lived by the people who must make decisions in real time, far from shore support.

I still remember standing on the bridge of a merchant vessel, facing commercial pressure to sail on schedule while weather and equipment concerns suggested otherwise. The manuals and procedures were on board, but what mattered in that moment was whether the company truly backed me and my Master’s judgment. That is where the real test of any SMS lies, not in what is written, but in the support given when difficult decisions must be made.

Having sailed for many years, I know how isolating a tough decision at sea can feel. A good DPA is not just a name in the manual but a trusted voice on the other end of the line, someone the Master can call at 0200 hours and speak openly with. When that relationship exists, the SMS becomes real; when it doesn’t, the paperwork quickly loses relevance on board.

After a lifetime at sea and many years working ashore with companies to implement the ISM Code, and finally leading QMII for over two decades in training, auditing and consulting in management systems, I remain convinced of one thing that the Code itself is not the problem. The real issue is whether we choose to make the SMS a living system that respects the realities of those at sea. When shore and ship learn to listen to each other through the SMS, we honor not just compliance requirements, but the professionalism and lives of the people who sail our ships.

More than 25 years after the ISM Code became mandatory, the International Safety Management (ISM) Code is still too often treated as a paper exercise. Shore offices produce manuals, checklists and forms; ships receive them, file them, and do their best to keep up. The result is a familiar complaint from both sides, “The system is for auditors, not for us.”

Yet the ISM Code was never intended to create a paperwork gap between shore and ship. It was meant to bridge that gap by providing a common safety language and a shared framework for decision-making. When understood and implemented as a living system, the Safety Management System (SMS) becomes exactly that bridge. I always recollect the curt observation by Justice Sheen post the sinking of the Herald of Free Enterprise: “…. I see a disease of sloppiness at every level of the hierarchy….”. His direct pointer at having a management system brought us the ISM Code connecting to the SOLAS.

The ISM Code’s original Intent was to have a system that connects people. The ISM Code’s purpose is clear: to provide an international standard for the safe management and operation of ships and for pollution prevention. The Code defines the Safety Management System as a structured and documented system enabling company personnel to implement the company’s safety and environmental protection policy effectively.  From the beginning, the Code placed both shore and ship within the same system. Company objectives in section 1.2 of the ISM Code include:

  • providing safe practices in ship operation and a safe working environment,
  • assessing risks to ships, personnel and the environment and establishing safeguards, and
  • continuously improving safety management skills of personnel ashore and aboard ships.

These are not separate objectives for two separate worlds. They are shared obligations, achievable only when the SMS genuinely links the office and the vessel.

So where then does the gap come from? Despite this intent, many organizations experience a shore–ship divide in their SMS.

  • On shore, staff may focus on satisfying external auditors, producing beautifully formatted procedures that look good in a DOC audit but are hard to use in real operations.
  • On board, crews often experience the SMS as extra work: duplicative checklists, complex forms, and procedures that do not reflect the realities of weather, port pressure and human limitations.

When this happens, several symptoms appear:

  • “Cut-and-paste” risk assessments that no one believes in.
  • Non-conformities written in audit language instead of operational language.
  • Masters and Designated Persons Ashore (DPAs) communicating mainly for certification, not for learning.

The result is an SMS that is formally compliant but functionally weak—it exists on paper but not in daily decision-making. The SMS must be a living system. To bridge the gap, we must return to a simple idea, the SMS is not a manual. It is the way the organization manages risk and work, documented so it can be repeated, audited and improved. A living system has several characteristics:

  • Owned by users, not by paperwork Procedures and checklists are written in the language of the people who use them. Crew and shore staff participate in their development and revision. Guidance documents are concise, operational and easy to find.
  • Fed by real feedback The Code requires procedures for reporting accidents and non-conformities, and for internal audits and management reviews as functional elements of the SMS. In a living system, these are not compliance rituals but mechanisms for learning. Near misses, hazardous observations and improvement suggestions from crew are actively encouraged, analyzed and acted upon.
  • Adaptable, not frozen, clause 12 of the Code calls for review and evaluation of the SMS.
     A living SMS changes in response to new risks, technology, trade patterns and lessons learned. Revision is continuous, not something done hurriedly before an audit.
  • Transparent roles and communication The Code requires defined levels of authority and lines of communication between shore and shipboard personnel. In a living system, these lines are not just organograms—they are trusted relationships. Masters feel supported, not second-guessed. The DPA is accessible, respected and known by name, not just as a title in the manual.

 The DPA then should be the human bridge. Perhaps the most powerful bridging mechanism in the ISM Code is the requirement that every company designate a person or persons ashore with direct access to the highest level of management (ISM Code clause 4).

In many organizations, the Designated Person Ashore (DPA) becomes either:

  • a paper coordinator, chasing signatures and tracking audits, or
  • a firefighter, reacting to incidents and port state control findings.

To make the SMS a living system, the DPA must instead function as a system integrator:

  • Listening systematically to ship feedback and ensuring it reaches senior management.
  • Challenging shore practices that create unrealistic demands on ships.
  • Ensuring that risk assessments and procedures reflect actual operations, not office assumptions.
  • Facilitating honest discussions after incidents—not searching for blame but for system weaknesses.

In short, the DPA should be the voice of the ship in the boardroom and the voice of the system on the ship.

The companies should plan practical steps to bridge the shore–ship gap. Companies that wish to transform a static SMS into a living one can take several practical steps as to co-create procedures with ship staff by involving the masters, officers and ratings when developing or revising procedures. I call it capturing the “as-is” of the system in preference to throwing the ‘baby with the bath water” by simply adopting a template. Pilot new checklists on board before formal approval. Ask: “does this help you do the job safely under time pressure?” If not, redesign. Management systems are not etched in stone. They should be open, flexible and adoptable to change.

Train to be competent and for understanding, not just for compliance. Move beyond “read and sign” familiarization. Use case studies, incident reviews and simulations that connect ISM clauses with real operational dilemmas. Emphasize why a procedure exists, not just how to follow it.

Most importantly, simplify and prioritize. The ISM Code specifies functional requirements, not thickness of manuals. Focus on critical operations and major risks; remove redundant or overlapping forms. A smaller, well-used SMS is better than a massive, ignored one. While doing this, also strengthen feedback loops. Make incident and near-miss reporting simple and non-punitive. Provide feedback to the crew on what was learned and what changed as a result. When people see that speaking up leads to improvement, not punishment, the system comes alive.

Remember data drives risk and trends and makes an organization proactive. Use data—and stories. Combine quantitative indicators (deficiencies, delays, injuries) with qualitative insights (crew narratives, master’s reviews). This blended view gives a more complete picture of safety performance and culture.

A change from compliance culture to learning culture must be brought in to create an environment for quality, safety, security and continual improvement. Port State Control statistics show that ISM-related deficiencies remain among the most frequently reported issues worldwide. This suggests that many SMSs still operate at a minimum compliance level. Bridging the shore–ship gap means moving toward a learning culture, where:

  • Deviations are signals to improve the system, not just to correct the individual.
  • Masters are empowered to exercise their overriding authority and supported by the shore organization with resources on as needed basis.
  • Top management sees the SMS not as a cost, but as an asset that protects people, ships, reputation and the marine environment.

In conclusion I would repeat that making the Code work as intended is the need. Not just talk but walk the talk. The ISM Code gave the maritime industry a powerful framework. It defined objectives, clarified responsibilities, and required a documented Safety Management System (SMS) that connects shore and ship. The challenge now is not to “comply” with the Code, but to realize its intent.

When the SMS is treated as a living system—owned by its users, nourished by feedback, continually adapted and genuinely connecting shore and ship—it becomes what the Code envisioned:

  • a bridge between management and operations,
  • a driver of safety and environmental protection, and
  • a practical expression of the company’s values at sea and ashore.

The choice is ours: an SMS that exists for certificates, or an SMS that saves lives, protects the environment, and unites shore and ship in a common purpose.  

 

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About the Author

This article was written by Inderjit “IJ” Arora, Chairman, Board of Directors at QMII. With more than 30 years’ experience spanning military service, merchant marine and civilian industries, he is an Exemplar Global-certified lead auditor and member of the U.S. TAG to ISO/TC 176 (the ISO 9000 family of standards). IJ holds an MBA from The College of William & Mary and an MSc in Defense Studies, and he brings a unique leadership and crisis-management background into quality systems consulting. He specialises in transforming management-system certification into a strategic advantage for organisations.

Domestic Passenger Vessel Accidents Are Preventable Using a Management System (Part Two)

In the first part of this two-part article, we began to consider the key commonality of accidents involving domestic vessels such as the Conception and the Spirit of Boston, namely, the absence of a fully functional management system. Here in part two, we will examine this in more depth from the perspective of the Plan-Do-Check-Act (PDCA) cycle.

Emphasizing a proactive safety culture and systematically addressing risks can greatly enhance safety in the domestic passenger vessel industry. By being vigilant and forward-thinking, companies can significantly reduce the likelihood of accidents and ensure the well-being of both crew and passengers. A comprehensive systems approach that prioritizes safety at all levels is essential for fostering a resilient maritime environment.

As a consultant with almost four decades of experience, I feel that my emphasis on fostering a proactive safety culture within the domestic passenger vessel industry is both timely and essential. The sector has historically witnessed incidents that stem not just from operational failures but from lapses in systematic risk management. The simple PDCA cycle makes risk appreciation essential and helps create a proactive management system. A proactive safety culture is not reactionary, but anticipatory. It is focused on identifying and mitigating risks before they evolve into incidents.

In domestic passenger operations, where crew and passengers coexist in dynamic and sometimes unpredictable environments, the safety culture must be leadership-driven, with management exemplifying and enforcing safety values. It must also be behavior-based, encouraging crew to speak up about near-misses or unsafe practices. An environment for quality, health, safety, and security must be built and maintained. The overall management system must be systems-supported, with procedures that make it easy to report, track, and correct hazards. A genuine safety culture is evident when every level of the organization—from executives to deckhands—considers safety an integral part of their responsibilities, not an afterthought.

Right at the start of the PDCA cycle, at the Plan stage, organizations must commit to identifying, evaluating, and mitigating risks. This is not just a best practice, but a requirement under clause 6.1 of ISO 9001:2015, which requires “… actions to address risks and opportunities.” It emphasizes understanding internal and external issues and planning actions accordingly to mitigate risk. In a similar vein, clause 8 of the ISM Code requires organizations to evaluate all identified risks to their ships, personnel, and the environment and establish appropriate safeguards. Failure to account for risks at this stage can cascade into the Do stage, with flawed procedures or untrained personnel resulting in increased chances of accidents.

In a systems approach it should be completely unacceptable to transfer uncertainty to the crew. Uncertainty in procedures, poorly defined emergency roles, or ambiguous hazard controls lead to hesitation and confusion during critical moments. The vessel crew should never be the first line of discovery for unanticipated risks. The shore-based organization must do the heavy lifting in identifying, documenting, and training for these risks. This principle aligns with clause 5 of the ISM Code, which mandates the establishment of safe practices in ship operations and a safe working environment.

Systemic safety as a shield against repetition must be created from lessons learnt. Clause 7.6 of ISO 9001 on knowledge is relevant and a requirement. As can be seen from various NTSB investigation reports, many vessel accidents share common causal factors: complacency, procedural lapses, miscommunication, or design flaws. These can be mitigated when a systems approach is employed linking technical systems, human factors, procedures, and training into one cohesive safety net. Lessons learned from past accidents are institutionalized not just in the safety management system (SMS) but in organizational memory and training routines.

Most importantly, risk appreciation must be the foundation of resilience. The ability to appreciate (not just assess) risk is what distinguishes a compliant company from a truly resilient one. Appreciating risk means embedding foresight into the organizational DNA, training teams to ask, “What if?” before a situation turns critical. This should holistically lead to and support the creation of maritime systems that do more than tick boxes—they save lives.

Applying the PDCA Cycle

Connecting these insights to the 2019 Conception tragedy not only reinforces the urgency of implementing a proactive safety culture but also illustrates precisely how systemic failures in risk appreciation, planning, and organizational accountability can lead to devastating outcomes.

As you will recall, the dive boat Conception caught fire while anchored off Santa Cruz Island, California. This resulted in the deaths of 34 people, which was the deadliest domestic maritime disaster in modern California history. The victims were asleep in a bunkroom below deck, and none of them survived. Only five crew members escaped. This tragedy was a catastrophic failure of planning, risk management, and safety culture.

The Conception disaster links clearly to a breakdown in the PDCA cycle, as follows:

  • Plan. Inadequate risk appreciation was a vital failure. There was no comprehensive risk assessment identifying the dangers of leaving charging lithium-ion batteries unattended overnight in a confined space. The lack of clearly marked and accessible escape routes was a known risk that was neither mitigated nor escalated. There was no SMS, nor was one legally required for that vessel. Still, a proactive operator would have voluntarily implemented one. As has been said, “Failing to plan is planning to fail,” and in this case, a lack of foresight into fire hazards, emergency egress, and nighttime watchkeeping was fatal.
  • Do. Lapses in implementation are apparent and have been pointed out in the NTSB report. A night watchman was required by regulation and the vessel’s certificate of inspection but was not on duty. The crew had no fire detection system below deck that could alert sleeping occupants of danger. Emergency drills and preparedness procedures were either nonexistent or insufficiently enforced.
  • Check. The investigators saw no monitoring or audit mechanisms. The vessel operator, Truth Aquatics, had no self-checking mechanism for compliance with watchkeeping requirements. There was no internal audit or reporting structure that caught repeated violations, such as skipping the night watch.
  • Act. This final stage of the PDCA cycle is intrinsically connected to leadership both ashore and at sea. However, there was almost a complete absence of any corrective action, despite past observations and near-miss warnings about battery charging risks and poor escape routes. The organization normalized deviation, operating under the illusion of safety through habit.

Failure to appreciate risk is a violation of ISO 9001 and ISM principles. The Conception incident demonstrates how not appreciating risk in the Plan stage—especially related to emerging threats like battery fires—can result in fatal vulnerabilities. Had a formal risk-based approach been followed, battery charging, watchkeeping, and egress issues would have been flagged and corrected.

Mitigating risks with an SMS

Although not mandated for this class of vessel, the absence of an SMS and risk-based approach violated the spirit of the ISM Code. Clause 8 calls for evaluating all risks and preparing for emergencies. The lack of a nighttime watch, poor escape design, and no contingency procedures represent failures in both design and culture.

The failure to appreciate hazards and risks by the organization on shore was passed to the crew and passengers, who paid for it with their lives. Passengers had no idea there was no overnight watch, a basic safety expectation. The crew was not empowered with procedures or tools to manage an emergency, placing them in an impossible position once the fire began. I therefore emphasize “companies cannot pass uncertainty to those on board.” The burden of risk must be identified, mitigated, and managed ashore, before the ship even leaves port. All that was required was a proper management system, resourced and implemented effectively and efficiently.

By not having an SMS, organizations are ensuring that there is no safety net in case the worst occurs! A comprehensive, systems-based approach could have identified the risk of charging batteries and flammable materials in confined quarters and ensured continuous watchkeeping practices were in place. The SMS would have required mandated drills, escape route evaluations, and fire detection systems. Simple internal audits would have perhaps given the management the inputs to ensure continual improvement and planned a system to ensure compliance. This would have embodied the PDCA cycle, where each stage feeds the next with learning, foresight, and action.

Conclusion

My final thought on lessons written in loss and tragedy are that having a system is the least those charged with entertaining people can do to guarantee that lives are not lost. The Conception tragedy in particular is a grim testament to what happens when safety is assumed rather than engineered. The call for a systems approach rooted in proactive risk appreciation is exactly the kind of thinking needed to prevent another such disaster.

My argument for the mandated or voluntary adoption of an SMS in the domestic passenger vessel sector draws on evidence from NTSB investigations and international best practices. Domestic passenger vessels, though subject to U.S. Coast Guard inspection regimes, are often not required to implement a formal SMS. This omission has led to repeated safety lapses where identifiable risks were not systematically mitigated. As we have seen, the consequences of such lapses can often be fatal.

It is time for the overall national policy to encourage the U.S. Coast Guard to extend SMS requirements to large domestic passenger vessels and establish tiered SMS models scalable by vessel type and operation. To the industry czars my recommendations are to encourage industry bodies to provide incentives and recognition for SMS adopters and promote voluntary adoption through education and resource support. To the organizations and companies operating in the domestic U.S. waters, I suggest these company-level actions:

  • Begin voluntary SMS implementation aligned with ISO or ISM principles.
  • Train personnel in the PDCA methodology.
  • Perform internal audits and hazard reviews regularly.

The tragedy of the Conception and the other incidents we have discussed reveal that compliance alone does not ensure safety. Only a structured, systems-based approach can prevent recurrence. It is time for the domestic passenger vessel industry to adopt SMS—not only as a regulatory checkbox but as a foundational safety ethos.

Note – The above article (Part 2) was recently published in an Exemplar Global publication – ‘The Auditor’

Click here to read the article.

Click here to read part 1 of the article

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About the Author

This article was written by Inderjit “IJ” Arora, Chairman, Board of Directors at QMII. With more than 30 years’ experience spanning military service, merchant marine and civilian industries, he is an Exemplar Global-certified lead auditor and member of the U.S. TAG to ISO/TC 176 (the ISO 9000 family of standards). IJ holds an MBA from The College of William & Mary and an MSc in Defense Studies, and he brings a unique leadership and crisis-management background into quality systems consulting. He specialises in transforming management-system certification into a strategic advantage for organisations.

Domestic Passenger Vessel Accidents Are Preventable Using a Management System (Part One)

Think of any accident, mishap, or tragedy involving a passenger vessel through history (or in recent times) and then look at the post-event investigation report. If you do this, you will find one shortcoming common to these tragedies: a poor appreciation of risk and the practical nonexistence of a management system. Occasionally, in slightly less disastrous events, you may see the existence of a system, but it is usually poorly implemented.

This two-part article considers the domestic passenger vessel industry in the United States, where there have been several tragedies. I hope (although hope is not a plan) that this work will inspire the industry to look at the proper implementation of management systems. In trying to narrow the discussion, we will analyze and learn lessons from the 2019 sinking of the Conception and to a limited extent the 2023 fire aboard the Spirit of Boston cruise ship. I will mention a few other incidents as well to make the connection and bring out the failure of the various systems that broke down.

A systems-based approach in analyzing accidents in the domestic U.S. passenger vessel industry involves looking at the various components and process interactions that could potentially lead to incidents. This can include factors such as crew training, vessel design, regulatory compliance, maintenance practices, and emergency preparedness. However, the major factor is usually the absence of a management system (or a badly designed and/or poorly implemented one). This is a tragedy in the making.

I am studying these accidents to demonstrate how a systems approach could have helped prevent many of these mishaps. The reluctance to implement an effective management system pains me, not to mention primary investigation agencies like the National Transportation Safety Board (NTSB), the United States Coast Guard (USCG), and other responsible bodies.

Note that I am not discussing technical processes here. Yes, those often fall short of the mark as well, but the bigger issue is the failure to apply simple systematic thinking based on existing management system standards. This reluctance to work systematically surprises me. I’ve recently expressed my views on the Baltimore Bridge collapse, the implosion of the Titan submersible, the collision between an American Airlines flight and a military helicopter over the Potomac, and the Boeing 737 Max inspection failures. In all cases, I cannot understand why a simple, cost-effective action such as properly implementing a management system should be such a critical weakness within so many different organizations. It is a leadership flaw, for (as W. Edwards Deming said) “A bad system will let down a good person every time!”

Titanic and Herald of Free Enterprise

When discussing this topic, many will think back to the Titanic tragedy which goes back more than 100 years. This is of course perhaps the most well-known sinking of all time, so I will not rehash the details, which are easily available online. However, I do want to mention that events like the sinking of the Titanic create the ultimate push—it caused a reaction and, ultimately, the creation of a workable system to help save lives and the vessels themselves. Depending on owners, operators, and masters, to use their judgment and do the right thing at the time of crisis was no longer enough. What the Titanic demonstrated was that the industry needed enforceable regulations and requirements. The result was the Safety of Life at Sea (SOLAS) Convention, which formalized a systematic approach to safety.

Before studying incidents occurring in U.S. domestic waters, I also want to mention the tragedy of the Herald of Free Enterprise, which occurred on March 6, 1987, at Zeebrugge, Belgium. The Herald of Free Enterprise was a roll-on/roll-off ferry owned by the Townsend Thoresen company. On that day, the ship capsized shortly after leaving port and 193 people lost their lives. It had departed with its bow doors open, allowing seawater to flood the car deck. Within minutes, the ship was lying on its side in shallow water.

The tragedy exposed severe deficiencies in the company’s safety culture and operational practices. Justice Barry Sheen was appointed to head the official inquiry into the disaster. His report, published in October 1987, was scathing and unprecedented in its criticism of the ferry operator, management, and the broader safety practices in the maritime industry. Justice Sheen’s report identified a “… disease of sloppiness and negligence at every level of the hierarchy.” This became one of the most quoted phrases from the report. Sheen emphasized that the disaster was not due to a single act of negligence but rather a “… catalogue of failures…” including the failure to ensure the bow doors were closed, poor communication between crew and bridge, inadequate safety procedures, and the absence of proper checks before sailing.

The report placed heavy blame on the senior management, asserting that safety was not a high priority for the company. It also noted that management failed to implement procedures that could have prevented such a tragedy.

It is indeed shocking and surprising that even today, decades later, investigations reports are still pointing out these same drawbacks. Lessons learned seem to be forgotten. I particularly wanted to focus on this incident because Justice Sheen’s report was a turning point in maritime safety regulation. It directly influenced the creation of the ISM Code under the International Maritime Organization (IMO), which mandated formal safety procedures and accountability in international shipping operations.

Conception

The Conception was a dive boat that caught fire off the coast of California, resulting in the deaths of 34 people in 2019.

Investigations into this disaster revealed several deficiencies, including inadequate fire safety procedures, lack of a proper emergency escape route, and insufficient crew training. There were also issues related to the vessel’s sleeping arrangements, where most of the passengers were asleep below deck at the time of the fire.

A systems approach would emphasize the need for comprehensive safety protocols, regular training for crew members, proper vessel design for evacuation, and effective regulatory oversight to ensure the robust implementation of safety measures.

Spirit of Boston

This incident involved a fire that broke out on the dining cruise ship Spirit of Boston while docked in 2022.

The fire was linked to a potential electrical malfunction, but it highlighted issues related to maintenance practices and emergency response protocols.

By applying a systems approach, stakeholders could focus on root cause analysis, looking into how maintenance schedules, crew training, and emergency responses are integrated and managed.

Overall recommendations for the systems approach

There are several important elements to consider in favor of the systems approach, as follows:

  • Interdisciplinary collaboration. Promoting collaboration among various stakeholders, including regulatory bodies, ship management companies, and safety experts, to share information and best practices
  • Root cause analysis. Encouraging investigations that go beyond the immediate causes of accidents to identify systemic failures that could contribute to unsafe conditions
  • Regular training and drills. Implementing continuous training and emergency drills for crew members to ensure readiness, competence and enhance situational awareness
  • Maintenance and safety protocols. Establishing stringent protocols for vessel maintenance and safety checks, with thorough documentation and compliance checks
  • Regulatory oversight. Advocating for robust regulatory frameworks that require adherence to safety standards and proactive risk management strategies
  • Cultural change. Fostering a safety-first culture within organizations that prioritize safety above operational pressures

We can see in these two recent incidents that, as with the case of the Herald of Free Enterprise, a systems approach enables a comprehensive understanding of the complexities involved in maritime operations, leading to better prevention measures and enhanced safety outcomes in the passenger vessel industry.

Other examples

Over the years, the NTSB has investigated numerous accidents involving passenger vessels. A few notable examples follow:

  • Estonia. Although this accident occurred in European waters, its implications affected international passenger shipping, including practices adopted in the United States. The Estonia sank in the Baltic Sea in 1994, resulting in the deaths of 852 people. The investigation revealed that the key issues were related to vessel design, including hull integrity and cargo securing. This incident led to enhanced safety regulations regarding passenger vessel construction and operational safety protocols.
  • Andrew J. McHugh. This collision involving the ferry Andrew J. McHugh and another vessel occurred in the narrow Houston Ship Channel, leading to the deaths of 17 passengers in 1980. The key factors included poor visibility, navigational errors, and inadequate communication between vessels. Subsequent recommendations from the NTSB aimed at improving navigational practices and vessel traffic control in critical areas.
  • Benson. The Benson, a tour boat in New York, capsized during a sudden storm. A total of 10 people died in this 2000 incident. The investigation pointed out questionable weather assessment practices and inadequate safety measures for handling sudden weather changes. The NTSB recommended better training for crew members regarding weather evaluation and emergency response.
  • Dawn Princess. A fire aboard this cruise ship in the South Pacific led to emergency evacuations in 2003. Although there were no fatalities, more than 150 passengers were affected. The fire was linked to flaws in electrical systems. The NTSB emphasized improved fire safety systems and crew training on firefighting and evacuation protocols.
  • Emotion. This fishing vessel capsized near Alaska in 2010, resulting in several fatalities. The investigation pointed out structural problems and issues with the vessel’s stability while loaded. Recommendations focused on vessel stability assessments and the importance of adherence to safety regulations during fishing operations.
  • Explorer. In 2007, the Explorer ran aground off the coast of the Antarctic Peninsula, leading to evacuations. All passengers were saved, but the incident raised alarms about navigational practices and inappropriate response to weather changes. The NTSB highlighted the need for enhanced navigational training and real-time communication.

For each of these incidents, a systems approach would involve comprehensive training programs for crew related to emergency preparedness, rigorous maintenance and operational checks, research and implementation of advanced technologies for navigation and safety, and collaboration among regulatory bodies to create uniform safety standards that encompass all aspects of vessel operation. These historical examples underscore the importance of a proactive stance on maritime safety, highlighting that every component of the system must work together to prevent accidents and improve safety outcomes in the passenger vessel industry.

A poor approach that fails to be proactive can significantly contribute to accidents such as these. When risks are not systematically identified and appreciated, several detrimental consequences can arise. Without a systematic approach to risk assessment, potential hazards may go unnoticed, increasing the likelihood of incidents. Vessels may not be adequately equipped to handle specific risks, such as extreme weather or equipment failures. There is a requirement for safety protocols, adequate training, and improvement of communications.

On the other hand, a reactive approach undermines effective communication within the organization and between vessels. Without established systems for reporting and discussing risks, lessons learned from previous incidents may be ignored.

The other factors are regulatory compliance lapses. In the absence of a proactive culture, vessels may not adhere to regulatory requirements consistently or may develop a compliance mindset that prioritizes minimum standards over comprehensive safety practices. Neglecting lessons learned from past incidents is another flaw. A failure to learn from past accidents can lead to repetitive mistakes. If organizations do not analyze historical incidents and implement changes based on those insights, they risk encountering similar situations again and again.

In the second part of this article, we will discuss the importance of using the Plan-Do-Check-Act cycle in embracing a safety management system.

To read Part 2 of the article – Click here

Note – The above article was recently published in an Exemplar Global publication – ‘The Auditor’

Click here to read the article.

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About the Author

This article was written by Inderjit “IJ” Arora, Chairman, Board of Directors at QMII. With more than 30 years’ experience spanning military service, merchant marine and civilian industries, he is an Exemplar Global-certified lead auditor and member of the U.S. TAG to ISO/TC 176 (the ISO 9000 family of standards). IJ holds an MBA from The College of William & Mary and an MSc in Defense Studies, and he brings a unique leadership and crisis-management background into quality systems consulting. He specialises in transforming management-system certification into a strategic advantage for organisations.

Understanding ISM Code Compliance for Maritime Operators

ISM

Having spent over 15 years in the maritime and compliance world, and a further decade working with various international Flag Administrations, I’ve seen firsthand the shift from traditional shipping operations to a more safety- and systems-driven industry. One of the major forces behind that transformation? The International Safety Management (ISM) Code. For maritime operators today, ISM Code compliance isn’t just about ticking boxes, it’s about embedding a culture of safety, responsibility, and continual improvement into every layer of their operation.

What is the ISM Code?

There is a saying that regulations are written in blood. The ISM Code was born out of hard lessons learned from major marine accidents. The major event that acted as a catalyst in its development was the MV Hearld of Free Enterprise. Introduced by the International Maritime Organization (IMO) under the SOLAS convention, the code mandates that every shipping company operating SOLAS compliant vessels implement a Safety Management System (SMS), a system that governs practices for the safe operation of ships and prevention of marine pollution.

I remember when the ISM Code first rolled out in the ’90s. Many shipowners were skeptical, and some even resistant. Back then, I was sailing with a company who was navigating the early implementation. The real challenge was shifting the mindset, from reactive firefighting to proactive risk management. From a documentation exercise to a shift in the way operations were done. That’s where I learned: policies are easy to write, but real compliance starts with people.

Why ISM Code Compliance Matters More Than Ever

Today, ISM Code compliance is not optional—it’s foundational. For operators navigating increasingly complex global regulations, it offers several key benefits:

  • Safety First: The SMS serves as a blueprint for safe operations at sea. I’ve seen it reduce incidents dramatically when implemented properly.
  • Environmental Responsibility: With public scrutiny and environmental regulations tightening, having structured pollution control measures is non-negotiable.
  • Credibility & Trust: In one of my past sailing tenures with a major operator, ISM compliance helped secure long-term contracts with charterers. Clients want to work with companies that can prove they’re managing risks responsibly.
  • Operational Clarity: When roles, responsibilities, and procedures are clearly outlined, decision-making becomes faster and more consistent.

The Core Objectives of the ISM Code

The ISM Code objectives listed in clause 1.2 remain as relevant now as when the code was first introduced. Clause 1.2 is about outcomes, not just documents. It’s about creating a system that actually prevents harm, not just reacts to it.

For me, ISM Code compliance under Clause 1.2 isn’t just about passing an audit, it’s about building a culture where every person onboard understands their role in safeguarding lives, the vessel, and the environment. It requires integrating risk assessments into planning, ensuring safe working practices, maintaining the ship properly, and always being prepared for emergencies.

I always emphasize these objectives when training ship and shore staff. It’s not about overwhelming them with paperwork, it’s about aligning them with a purpose. The code provides the structure; we provide the commitment.

Key Elements of ISM Code Compliance

A fully compliant SMS includes:

  • Safety and Environmental Protection Policy
  • Defined Roles and Responsibilities
  • Safe Operating Procedures
  • Emergency Preparedness
  • Reporting and Analysis of Incidents
  • Internal Audits and Continuous Improvement

One of the best implementations I facilitated was for a regional bulk carrier. We not only developed the vessel SMS but aligned office procedures, and built an SMS that didn’t just sit in a manual, it lived on the bridge, in the boardroom and in the daily practices of personnel.

The Compliance Process for Maritime Operators

Getting compliant involves more than a checklist. Here’s a simplified roadmap:

  1. Gap Analysis – Review what you already do and what the code expects. Does it reflect the operational reality or is it a fictional system?
  2. SMS Development/Update – Build or refine your safety management system. Comprehensive reviews when done after many years can lead to a reduction in documentation by over 20 percent.
  3. Training & Awareness – Everyone onboard and ashore must know their part. How do they contribute to the effectiveness of the system.
  4. Certification – Obtain the Document of Compliance (DOC) and Safety Management Certificate (SMC) through audits.
  5. Ongoing Monitoring – Regular internal audits and management reviews keep the system alive and evolving.

Common Challenges in ISM Code Compliance

Let’s be real, compliance has its hurdles:

  • Top-down Disconnect: Without leadership buy-in, the SMS becomes a box-ticking exercise.
  • Crew Resistance: “We’ve always done it this way” is a common attitude.
  • Training Gaps: If your crew doesn’t understand the ‘why’ behind procedures, they won’t follow them.
  • Audit Fatigue: Poor recordkeeping and rushed preparation can derail audits.

My advice? Keep it simple. Make procedures practical, not bureaucratic. Involve the crew in developing routines. That’s how you make compliance sustainable.

The Future of ISM Code Compliance and Technology’s Role

The maritime industry is changing fast. Digital tools are making compliance easier and smarter:

  • Cloud-based SMS systems offer real-time updates and reduce paperwork.
  • Remote audits became mainstream during the pandemic—and they’re here to stay. Where a full remote audit is not feasible consider hybrid audits.
  • Data analytics can identify patterns in incidents and help prevent them.
  • Mobile apps for onboard reporting are empowering seafarers to be active players in the compliance process.

Look at mistake proofing of the system. So even if a human wanted to make an error the system would prevent it.

In Conclusion, ISM Code compliance isn’t just about certificates. It’s about creating a safety culture that protects your people, your assets, and the environment. For maritime operators willing to invest the effort, the returns in safety, efficiency, and reputation are well worth it.

If you’re a maritime operator looking to simplify or strengthen your ISM safety management system, I’m happy to share more from my experiences. As someone who’s walked ship decks, sat in boardrooms, worked with Flag Administrations and led audits, I believe that compliance done right isn’t a burden-it’s a competitive advantage.

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About the Author

Dr. Julius is a Senior Consultant at QMII with over 25 years of experience in ISO and aerospace quality systems. He has trained and guided hundreds of U.S. defense contractors on AS9100 and compliance, turning certification into a competitive advantage.

 

Controlling Sub-Sea Infrastructure


The recent implosion of the Titan, a sub-sea submersible used for taking elite, high-paying tourists to see the wreck of the Titanic, brought the safety protocols of both vessels into focus. There were no statutory requirements for regulating the Titan and neither were there any when the Titanic sank in 1912! As a reactive measure, the maritime community came up with the Safety of Life at Sea (SOLAS) Convention soon after the sinking of the Titanic. Ironically, after the Titan submersible imploded, we have come to realize there are no requirements covering this vessel. Perhaps with time, the involved counties will react.

The question is, why was nothing done proactively? Tourists go up in hot air balloons all the time. Is there any statutory requirement that these tourist companies must meet? Is there even a requirement to have a management system in place so that these companies work systematically, appreciate the risks in the context of the organization, and plan their operations keeping risks in mind? It is true that entrepreneurs do not like regulations and consider requirements a hindrance in a free business environment. And yet the Titanic, which was declared to be “unsinkable,” did, in fact, sink! In the United States, the domestic towing vessel industry functioned without statutory requirements until recently. The industry avoided regulation, but tragedies occurred, and now the industry is regulated under the U.S. regulatory framework. A process-based management system is the best systematic structure to produce conforming products and services, ensure continual improvement, and implement the statutory requirements if available.

The intent of this article is to proactively start a discussion on the need for regulating sub-sea infrastructure to reduce its affect on the marine transportation system. The phrase “sub-sea infrastructure” refers to equipment and technology placed on or anchored to the ocean floor. This infrastructure may include, but is not limited to, cables for telecommunication, cables for power transmission, pipelines for transmission of fluids, and other stationary equipment for scientific research.

The growth of sub-sea infrastructure is a global phenomenon. As an example, is in the interest of all nations, and particularly here in United States, to promote wind farms, which are a source of renewable energy. When these wind farms are placed in selected geographical locations along the continental shelf, they need sub-sea cables. But are there any laws controlling the systematic development of the industry to enable an effective marine transportation system and its protection of maritime community interests and environmental interests? Is there a central agency responsible for this coordination to allow for a balanced approach to risks? The amount of cabling piling up needs management and oversight.

Sub-sea infrastructure, the definition of the problem

Numerous industries have a stake in sub-sea infrastructure. Examples include oil and gas, telecommunications, fishing, scientific research, and perhaps military/defense applications such as sonar and other arrays and obstacles. This infrastructure is a requirement, but it also faces various challenges including those that can lead to accidents, environmental damage, and possible breaches in national security. All these bring out very significant concerns related to sub-sea infrastructure and the lack of comprehensive and globally accepted standards, requirements, obligations, and assurance mechanisms. It is not that organizations such as the United States Coast Guard, the National Oceanic and Atmospheric Administration, the Bureau of Safety and Environmental Enforcement, the U.S. Army Corps of Engineers, the Environmental Protection Agency, and other federal and state agencies do not look at these issues.

Nevertheless, it remains a concern that there is no single agency or overarching requirement to provide a framework to the industry on harmonized implementation of requirements. This lack of harmonization can mean inconsistencies in design, installation, and maintenance practices which may not address risks uniformly. This can generate consequential risks, leading to increased accidents, mechanical failures, and costs to the industry and the nation.

Recent tragedies and accidents

Recent tragedies and accidents involving sub-sea infrastructure have been limited, and yet must not lead to complacency by the agencies involved. The few that have occurred indicate the challenges and trends pointing to the need for proactive requirements. The recent tragedies include:

  • Deepwater Horizon. The potential consequences and challenges inherent in deep-water oil drilling were brought out by the Deepwater Horizon tragedy in 2010. The oil rig explosion in the Gulf of Mexico caused a massive oil spill and resulted in the loss of 11 lives. Although not technically a sub-sea incident, it highlighted a series of failures in design, maintenance, and company oversight—all factors pointing to the importance of robust safety standards and requirements, and the implementation thereof. The Deepwater Horizon incident was not directly related to sub-sea infrastructure; however, it heightened the risks associated with offshore oil and gas production and the potential for catastrophic environmental damage.
  • Nord Stream 1 and Nord Stream 2. Occurring in September 2022, the damage to these gas pipelines in the Baltic Sea highlighted concerns around sub-sea infrastructure. These pipelines transport natural gas from Russia to Europe; in this incident, they sustained multiple leaks. The exact cause of the damage is unclear, though deliberate sabotage was suspected and is still under investigation. Regardless of the ultimate findings, this incident exposed the vulnerabilities of sub-sea infrastructure to sabotage, and the potential for significant environmental and economic consequences are real. Intentional attacks to the sub-sea infrastructure have the potential for widespread disruption of energy supplies. Apart from the Nord Stream, there have been other sub-sea incidents affecting the gas and oil industry. In 2021 a fire broke out on a sub-sea production control umbilical off the coast of Brazil, causing significant damage to the underwater equipment and resulting in a major oil spill.
  • English Channel Internet Disruption. In 2021, a ship dragging its anchor on the seabed in the English Channel cut the three main internet cables to the Channel Islands. Although this only resulted in slower broadband speeds in this instance, there remains the possibility that it could have resulted in a complete outage.

Looking ahead

These incidents represent leading indicators of a tragedy in the making should proactive action not be taken. The critical importance of safety for sub-sea infrastructure underscores the need for a more comprehensive and rigorous approach to standards and assurance. Industry stakeholders together with regulatory bodies within the United States and global organizations such as the International Maritime Organization must work together to establish a harmonized set of safety standards, implement robust assurance mechanisms, and foster a culture of safety throughout the sub-sea industry.

The increasing reliance on sub-sea infrastructure for various industries (including wind farms) necessitates a proactive approach to safety and risk management. There is definitely a need to invest in research and development to enhance the resilience and monitoring capability of sub-sea infrastructure. The various companies in the sub-sea industry are holding their proprietary information close to the vest. This is understandable. However, these organizations are in competition with totalitarian governments, in which control of business practices is the exclusive dominion of the state. It is necessary to enhance transparency and information-sharing among industry stakeholders to facilitate better risk assessment and incident prevention.

Conclusion

Promoting a culture of safety that prioritizes risk identification, risk mitigation, and continual improvement is essential. There is no common ISO standard for sub-sea management systems. Of course, ISO 9001 is interpretable and can be used as the basis for now. Environmental protection is a challenge for a developing industry, and as such, even greater urgency is needed for statutory requirements encompassing all aspects of stakeholder interests, the marine industry in general, and the protection of the environment for generations to come.

Marine transportation remains the most important way for goods to be shipped across the world, as approximately 80 percent of the world’s goods are transported by ships. Vessels need a place to anchor in normal operating conditions as also in emergencies. A crowded seabed in harbors makes this a challenge for the entire maritime industry.

Without adequate and effective regulatory oversight, it may be too late to take action once cables and other sub-sea equipment have already been laid. Further, multiple agencies regulating the same aspects of the industry can potentially lead to bureaucratic delays.  There is therefore an urgent need to create a single statutory body to regulate the sub-sea infrastructure industry, which will greatly benefit all parties invested in the maritime transportation system.

Exemplar Global Publication “The Auditor”