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.