Re-thinking the ISM Code

The ISM code, when implemented in 1998, was meant to encourage organizations to take ownership for the safe operations of their ship and the safety of the environment they operate within. Many years hence and the benefit of the ISM code is still being debated. Has it been a boon or a burden to the maritime industry?

Given the number or maritime accidents and loss of lives, most would opine that safety would be second nature to those at sea. Something like wearing a seatbelt when driving a car where the person does it for their own safety and for those travelling with them. It is not done out of fear of the enforcement authorities. So then why has the ISM code not driven a similar safety culture within the maritime industry?

Boon or Burden?

In many companies, the ISM code implementation has become a paperwork drill; where it is seen as a means of demonstrating to regulators that the requirements have been met. The reasons for this culture are many, including but not limited to:

  • Lack of effective communication between ship and shore staff (one of the key issues the ISM code aimed to address)
  • Fear of reporting of non-conformities / near misses (lack of job security)
  • Hierarchical structure of companies
  • Authoritarian leadership (my way or the highway)
  • Systems not customized to the vessel (generic to the fleet)
  • Poor system implementation

The ISM code provides a system approach to continual improvement but only when the code is implemented in the right spirit. Personnel often do not understand the ‘WHY’ for implementing an SMS and their need to do the right thing. Often conformity/compliance is stressed even when the actions may not be the right thing to do. Measures such as Bridge Resource Management are add-ons to ensure effective communication of risks and challenging of group thinking. However, often the training is not sufficient to enable challenging a senior officer unless they are encouraged to do so. Most mariners today view the SMS on board as a burden. Over-documentation is slowly killing the system and once incorporated into the system, requirements rarely get removed. SMS reviews done by the Master do not truly evaluate how the SMS is adding value to the effectiveness of the system.

The Case for Risk-Based Thinking

ISO 9001 in its revision in 2015 introduced the concept of risk-based thinking, wherein organizations shall assess the risks to their system given the changing environment they operate within and then plan to take actions to address these risks. This concept of risk-based thinking is driven down to awareness of the entire staff of the need to contribute to the effectiveness of the system. While the ISM code in its objectives requires companies to identify and safeguard against all risks this has in many cases become a paperwork exercise of completing a risk assessment form and filing it. The ISM code in essence has encouraged companies to identify potential emergencies, prepare contingency plans for them and the drill in these. Often these are limited to the same 10 or 12 scenarios such as grounding, oil spill, man overboard etc. Many maritime companies are ISO 9001 certified but often the scope of this certification only extends to the shore-based offices. While the certification scope may be limited, there is nothing stopping companies from extending the system to vessels or at the least the concept of risk-based thinking.

The safety culture must start with the commitment of the leadership and then be reinforced throughout the organization. The fear of reporting non-conformities must be eradicated. This can only be achieved when personnel are confident that there will be no repercussions. Regardless of the safety culture of organizations however, given the contractual nature of employment at sea, it is often difficult to inculcate a sense of commitment to the SMS. Mariners in general tend to work safely and watch out for safety of their shipmates. At times though, the culture of “follow the procedure” leads to actions being taken even when they may not be the best, given external influences and circumstances.

Consultation and Participation

ISO 45001, a standard for occupational health and safety management systems, introduces the need for ‘organizations to maintain a process for consultation and participation of workers at all applicable levels and functions, and, where they exist, workers’ representatives, in the development, planning, implementation, performance evaluation and actions for improvement of the OH&S management system’. Getting inputs from the entire workforce enables quicker and easier buy-in to the system. The SMS while capturing the various requirements should be designed for easy use by the users of the system. Often SMS manuals on board are bulky and rarely referenced. Personnel choose to follow the practices they have learned over the years from other ship mates and mentors rather than reference the SMS.

When asked for feedback on how to improve the system, many mariners have ideas but the system at times does not provide an avenue for this feedback to be captured and formally implemented within the SMS. Best practices often remain limited to a vessel as a result. Following the concept of risk-based thinking, organizations need to consider the risk of barriers to participation and take measures to reduce these. Many accidents/incidents and near misses could be addressed if mariners could have asserted themselves in the situation and alerted someone to the problem/potential non-conformity.


Some in the industry are calling for increased regulation to improve the maritime industry in ensuring ships are operated safely. However, regulators can only do spot checks. They are not on board 365 days of the year. Operational pressures play a major role in how risks are assessed. The grounding of the Torrey Canyon is a prime example of this as is perhaps the Titanic.

As the use of technology increases and reliance on electronic systems, consequently new risks will be introduced to the maritime industry. This new era will benefit from a re-think of the ISM code to encourage the inclusion of risk-based thinking (beyond just a documentation exercise) and the participation of mariners to actively improve the SMS and embrace safety. In conclusion, maritime companies (with or without a change to the ISM code), in the interest of their mariners and the maritime industry at large need to rethink their approach to implementation and maintenance of the SMS.