MSIS 2/Rev 7/23

Instructions for the guidance of surveyors on

International management code for the safe operation of
ships and for
Pollution prevention
(The ISM code)
MSIS02

Rev 07-2023

© Crown Copyright

PREFACE

0.1 These instructions for the guidance of surveyors are not legal requirements in themselves.
They may refer to statutory requirements elsewhere. They do represent the MCA Policy for
MCA surveyors to follow.
0.2 If, for reasons of practicality, for instance, these cannot be followed then the surveyor must
seek at least an equivalent arrangement, based on information from the owner/operator.
Whenever possible, guidance should be sought in the first instance from either the Technical
Manager, or Principal Consultant Surveyors or the Survey Operations Branch, in order to
maintain a consistent approach between Marine Offices.

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CONTENTS
1. INTRODUCTION AND BACKGROUND.............................................................................................................. 4
1.1. PURPOSE OF THE INSTRUCTIONS ........................................................................................................................ 4
1.2. THE ISM CODE .................................................................................................................................................. 4
1.3. WHY IS THERE AN ISM CODE?............................................................................................................................ 4
1.4. UK AND IMO MEASURES TOWARDS SAFE MANAGEMENT OF SHIPS ....................................................................... 5
1.5. PRINCIPLES AND OBJECTIVES OF THE ISM CODE ................................................................................................. 5
1.6. THE SAFETY CULTURE ........................................................................................................................................ 6
1.7. THE UK POLICY ................................................................................................................................................. 6
1.8. THE ISM AUDIT FOR COMPLIANCE ...................................................................................................................... 6
1.9. INDEX OF DOCUMENTS ....................................................................................................................................... 6
2. LEGISLATIVE REQUIREMENTS........................................................................................................................ 8
2.1. INTERNATIONAL LEGISLATION ............................................................................................................................. 8
2.2. EUROPEAN UNION LEGISLATION.......................................................................................................................... 8
2.3. MERCHANT SHIPPING (ISM CODE) REGULATIONS 2014 ....................................................................................... 8
3. THE CERTIFICATION PROCESS....................................................................................................................... 9
3.1. THE DOCUMENT OF COMPLIANCE (DOC)............................................................................................................. 9
3.2. THE SAFETY MANAGEMENT CERTIFICATE (SMC) ................................................................................................. 9
3.3. ISSUE OF INTERIM DOC AND SMC...................................................................................................................... 9
3.4. COMPANIES OPERATING A MULTI-FLAGGED FLEET ............................................................................................. 10
3.5. AMENDING THE DOC TO INCLUDE NEW SHIP TYPES ............................................................................................. 10
3.6. CANCELLATION OR SUSPENSION OF DOC OR SMC........................................................................................... 11
3.7. EXTENSION OF CERTIFICATES/AUDITS NOT REQUESTED ON TIME ........................................................................ 11
4. CONDUCTING THE AUDIT............................................................................................................................... 13
4.1. AUDITOR QUALIFICATIONS: BASIC COMPETENCE FOR PERFORMING VERIFICATION ............................................... 13
4.2. THE SAFETY MANAGEMENT SYSTEM (SMS)....................................................................................................... 14
4.3. REQUEST FOR AUDIT ........................................................................................................................................ 15
4.4. DOCUMENT REVIEW AND PLANNING .................................................................................................................. 15
4.5. INITIAL AUDITS ................................................................................................................................................. 16
4.6. THE DOCUMENT OF COMPLIANCE (DOC)........................................................................................................... 17
4.7. THE SAFETY MANAGEMENT CERTIFICATE (SMC) AUDIT...................................................................................... 19
4.8. ANNUAL VERIFICATION (DOC) AND INTERMEDIATE VERIFICATION (SMC) AUDITS ................................................ 20
4.9. DOC AND SMC RENEWAL AUDIT ...................................................................................................................... 20
4.10. RESPONSIBILITIES OF LEAD AUDITOR ................................................................................................................ 21
4.11. THE AUDIT PLAN .............................................................................................................................................. 21
4.12. GUIDANCE ON TYPICAL AGENDA FOR OPENING AND CLOSING MEETINGS ............................................................. 22
4.13. CATEGORIES OF AUDIT FINDINGS ...................................................................................................................... 23
4.14. NON-CONFORMITY NOTE .................................................................................................................................. 24
4.15. HUMAN ELEMENT ............................................................................................................................................. 24
4.16. AUDIT REPORT................................................................................................................................................. 25
4.17. AUDIT REPORT FOR DOCUMENT OF COMPLIANCE AUDIT ..................................................................................... 25
4.18. AUDIT REPORT FOR SAFETY MANAGEMENT CERTIFICATE AUDIT .......................................................................... 25
4.19. CLOSE OUT OF NON-CONFORMITIES .................................................................................................................. 26
4.20. CORRECTIVE ACTION ....................................................................................................................................... 26
4.21. CONFIDENTIALITY OF AUDIT ............................................................................................................................. 27
5. EXTRACT OF ISM CODE & UK (POLICY) INTERPRETATION ...................................................................... 28
5.1. GENERAL ........................................................................................................................................................ 28
5.2. SAFETY AND ENVIRONMENTAL PROTECTION POLICY ......................................................................................... 30
5.3. COMPANY RESPONSIBILITIES AND AUTHORITY .................................................................................................. 31
5.4. DESIGNATED PERSON(S) ................................................................................................................................. 32
5.5. MASTER’S RESPONSIBILITY AND AUTHORITY .................................................................................................... 33

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5.6. RESOURCES AND PERSONNEL.......................................................................................................................... 33

5.7. SHIPBOARD OPERATIONS ................................................................................................................................ 35
5.8. EMERGENCY PREPAREDNESS .......................................................................................................................... 36
5.9. REPORTS AND ANALYSIS OF NON-CONFORMITIES, ACCIDENTS AND HAZARDOUS OCCURRENCES ....................... 37
5.10. MAINTENANCE OF THE SHIP AND EQUIPMENT .................................................................................................... 38
5.11. DOCUMENTATION............................................................................................................................................. 39
5.12. COMPANY VERIFICATION, REVIEW AND EVALUATION ......................................................................................... 40
5.13. CERTIFICATION AND PERIODICAL VERIFICATION ................................................................................................. 42
5.14. INTERIM CERTIFICATION.................................................................................................................................... 45
5.15. VERIFICATION .................................................................................................................................................. 46
5.16. FORMS OF CERTIFICATES ................................................................................................................................. 46
6. REPORTING & FILING ETC ............................................................................................................................. 48
6.1. REPORTING & QUALITY CONTROL PROCEDURES (DOC & SMC)....................................................................... 48
6.2. PELORUS ........................................................................................................................................................ 48
7. PORT STATE CONTROL .................................................................................................................................. 49
7.1. EXAMINATION OF CERTIFICATES ....................................................................................................................... 49
8. PARTICULAR ISSUES ...................................................................................................................................... 49
8.1. LAID UP SHIPS ................................................................................................................................................. 49
8.2. SUBMERSIBLE CRAFT ....................................................................................................................................... 50
9. ANNEX A – AUDIT PLAN ................................................................................................................................. 51
10. ANNEX B - MCA AUDIT OPENING & CLOSING MEETINGS ......................................................................... 54

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1. Introduction and background

1.1. Purpose of the instructions

These Instructions to Surveyors have been produced by the Maritime and

Coastguard Agency (MCA), an Executive Agency of the Department for Transport
(DfT), for the guidance of surveyors auditing safety management systems both at
sea and ashore. Additionally, they provide guidance for those concerned with the
procedures adopted by the MCA for carrying out audits for verification of
compliance with the International Safety Management Code for the Safe Operation
of Ships and for Pollution Prevention (ISM Code).

1.2. The ISM Code

The ISM Code was adopted by the IMO as Resolution A.741(18), in November
1993. It came into force on 1 July 1998 through SOLAS Chapter IX, ‘‘Management
for the Safe Operation of Ships’’. The ISM Code provides an international standard
for the safe management and operation of ships and for pollution prevention.

1.3. Why is there an ISM code?

1.3.1. The origins of the ISM Code go back, internationally, to the late 1980s when there
was mounting concern about poor management standards in shipping. It is
estimated that a high proportion of maritime accidents (80%–90%) are attributable
to human error. Investigations into accidents highlighted shortcomings on the part
of ship management both at sea and ashore. In 1987 the IMO Assembly adopted
Resolution A.595(15) which called upon the Maritime Safety Committee to develop
guidelines concerning shipboard and shore-based management to ensure the safe
operation of roll-on/roll-off (Ro-Ro) passenger ferries. The tragic loss of the Herald
of Free Enterprise in 1987 was a catalyst in this process.

1.3.2. Following this, the UK unilaterally introduced, for UK passenger ships of Classes II
and IIA, The Merchant Shipping (Operations Book) Regulations 1988 (S.I.1988
No.1716). These regulations, which were superseded by S.I. 1997/3022 and S.I.
1998/1561, were developed around the two central tenets that;

1.3.3. Such ships carry a book (called the operations book) containing instructions and
information for safe and efficient operation;

1.3.4. Owners of ships nominate a person (known as the Designated Person

Ashore (DPA)) to oversee the operation of their ships and to ensure
proper provisions are made so that the requirements of the operations book are
complied with.

1.3.5. These requirements are also fundamental provisions of the ISM Code. The ISM
Code seeks to address the human element of ship operations.

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1.3.6. After the loss of the Estonia in 1994 the Council of the European Union adopted
Council Regulation (EC) No. 3051/95 on 8 December 1995 on the safety
management of roll-on/roll-off passenger ferries. From 1 July 1996 this Regulation
made compliance with the ISM Code mandatory for seagoing passenger Ro-Ro
ferries operating a regular service to or from a port of an EU Member State.

1.3.7. The Merchant Shipping (ISM Code) (Ro-Ro Passenger Ferries) Regulations 1997
(S.I. 1997 No. 3022) provide for the enforcement of this Council Regulation. At the
Conference of Contracting Governments to the 1974 Safety of Life at Sea
(SOLAS) Convention, held in May 1994, a new chapter (Chapter IX) was added to
the Convention which made compliance with the ISM Code mandatory, from either
1 July 1998 or 1 July 2002 depending on ship type. The ISM Code itself was
adopted on 4 November 1993 under Resolution A.741(18). The ISM Code has
since undergone amendments in 2006, 2009, 2010, 2015 and 2018.

1.4. UK and IMO measures towards safe management of ships

1.4.1. As a result of the major incidents detailed above, several measures were taken
both nationally and internationally:

• Resolution A.596 entitled ‘‘Safe Management and Operation of Ships’’ was

adopted in 1987;
• The UK implemented the Merchant Shipping (Operations Book) Regulations, S.I.
1988 No. 1716 (now superseded);
• Resolution A.647 ‘‘IMO Guidelines on Management for Safe Operation of Ships
and for Pollution Prevention’’ was adopted in 1989 (superseding A.596);
• A further Resolution, A.680, entitled ‘‘IMO Guidelines on Management for the Safe
Operation of Ships and for Pollution Prevention’’ was adopted in 1991, superseding
A.647
• Resolution A.741 ‘‘International Management Code for the Safe Operation of
Ships and for Pollution Prevention’’, the ISM Code, was adopted in 1993.

1.5. Principles and objectives of the ISM code

Given that no two shipping companies or ship managers are identical and that ships
operate under a wide range of different conditions, the ISM Code is expressed in
broad terms and based on general principles and objectives. This provides
companies with the scope to develop their own safety management system (SMS)
whilst meeting the provisions of the ISM Code. The Code imposes no prescriptive
measures and takes a holistic view of a Company and the way in which it operates
its ships. The objectives of the ISM Code are to ensure safety at sea, prevention of
human injury, loss of life and the avoidance of damage to the environment, in
particular to the marine environment. The ISM Code requires owners and operators
of ships to put in place a Safety Management System (SMS), the mandatory
application of which is to ensure compliance with rules and regulations related to
the objectives of the Code and the effective implementation and enforcement
thereof by Flag State Administrations.

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1.6. The safety culture

The Code aims to support and encourage the development of a safety culture within
the shipping industry whilst improving compliance with the requirements of
international conventions. The Code requires that Companies establish safety and
pollution prevention objectives and develop, implement and maintain a SMS and a
systematic approach to the safe management of ships by those responsible, both
ashore and afloat.

1.7. The UK policy

The MCA recognises that the ISM Code encourages an enhanced safety and
pollution prevention culture within the shipping industry. Therefore, it was decided
that the MCA (as the UK Flag State Administration) would retain direct responsibility
for the assessment and audit of UK shipping companies and ships against the ISM
Code. All UK flag vessels are expected to have the SMS Manual written in or
translated into English to enable MCA Auditors to carry out audits.

1.8. The ISM audit for compliance

Audits are carried out to verify compliance with the ISM Code in accordance with
the ‘‘Guidelines on Implementation of the ISM Code by Administrations’’, IMO
Resolution A.1022 (26). In addition, the International Chamber of Shipping, in
association with the International Shipping Federation, has produced ‘‘Guidelines
on the Application of the IMO International Safety Management (ISM) Code’’ and
IACS has produced PR 09 on “Procedural requirements for ISM Code certification”.
It is recommended that surveyors become familiar with these publications as they
establish underlying principles for verifying that a shipping Company’s SMS
complies with the ISM Code.

1.9. Index of documents

The following documents are particularly relevant to the ISM Code:

• The ISM Code: IMO Resolution A.741 (18), adopted in November

1993;
• Revised guidelines on the implementation of the ISM Code by Administrations:
IMO Resolution A.1118 (30) adopted on 6 Dec 2017;
• Guidance to Companies operating multi-flagged fleets and supplementary
guidelines to Administrations: IMO MSC/Circ. 762 of 11 July 1996;
• Guidelines on the application of the IMO International Safety Management (ISM)
Code, third edition, published jointly in 1993 by the ICS/ISF, amended and updated
in 2018;
• The Merchant Shipping (International Safety Management (ISM) Code)
Regulations 2014 (S.I. 2014 No. 1512);
• Guidance on the Qualifications, Training and Experience necessary for
undertaking the role of the Designated Person under the provisions of the
International Safety Management Code (ISM). IMO Circular (MSC-MEPC.7/Circ. 6
19 October 2007);

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• Revised guidelines for the Operational Implementation of the International Safety

Management (ISM) Code by Companies. IMO Circular MSC-MEPC.7/ Circ. 8 28
June 2013); and
• Regulation (EC) No. 336/2006 on the implementation of the ISM Code within the
community.
• Maritime Cyber Risk Management in Safety Management Systems - Resolution
MSC.428(98) (adopted on 16 June 2017)
• Guidelines on Maritime Cyber Risk Management (MSC-FAL.1/Circ.3)

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2. Legislative requirements

2.1. International legislation

Chapter IX of Safety of Life at Sea (SOLAS), Management for the Safe Operation
of Ships, requires the mandatory application of the ISM Code on ships engaged on
international voyages.

2.2. European union legislation

2.2.1. The Council of the European Union adopted Council Regulation (EC) No. 3051/95
in December 1995, which required advance mandatory application of the ISM
Code for all sea going passenger roll-on/roll-off ferries operating a regular service
to or from a port of a Member State of the European Community, regardless of the
vessel’s flag. The Regulation entered into force on 1 July 1996.

2.2.2. EC Regulation 336/2006 repeals Regulation (EC) No. 3051/95 and requires
certain domestic cargo and passenger vessels to comply with ISM Code not later
than 24 March 2008. Regulation 336/2006 applies to the following types of ships
and companies operating them:

• Cargo ships and passenger ships, flying the flag of a Member State, engaged on
international voyages.
• Cargo ships and passenger ships in EU category A and B waters engaged
exclusively on domestic voyages, regardless of their flag.
• Cargo ships and passenger ships operating to or from ports of the Member
States, on a regular shipping service, regardless of their flag.
• Mobile offshore drilling units operating under the authority of a Member State.

2.3. Merchant shipping (ISM code) regulations 2014

The Merchant Shipping (ISM Code) Regulations 2014 (S.I. 2014 No.1512) provide
for the application of the ISM Code on all vessels to which the SOLAS Convention
applies and to other vessels to which the EC Regulation 336/2006 applies.

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3. The certification process

3.1. The document of compliance (DOC)

A Document of Compliance (DOC) will be issued to a Company when the shore-

side aspects of the SMS are fully compliant with the requirements of the ISM Code.
The DOC is specific to the ship type(s) operated by the Company and for which the
SMS is implemented at the time of audit. During a Safety Management Certificate
(SMC) audit on board a ship, a copy of the DOC should be accepted as evidence
that the Company’s shore-side management structure complies with the
requirements of the ISM Code. A copy of the DOC should be placed on board each
of the Company’s ships. It is not necessary for the copy of the DOC to be
authenticated or certified.

3.2. The safety management certificate (SMC)

Following a successful audit, a SMC will be issued to each individual ship provided
that the Company holds a valid DOC. A copy of each SMC should be retained in the
Company’s office records, the original being placed on board and retained with all
other statutory certificates.

3.3. Issue of interim DOC and SMC

3.3.1. An interim DOC may be issued to facilitate initial implementation of the Code
when:

• A Company is newly established; or

• New ship types are to be added to an existing DOC (as described above).

3.3.2. An interim SMC may be issued:

• To new ships on delivery.

• When a Company takes on responsibility for the operation of a ship which is new
to the Company; or
• When a ship changes flag.

3.3.3. An interim DOC, valid for a maximum of twelve months, may be issued providing a
Company can demonstrate its SMS meets the objectives of paragraph 1.2.3 of the
ISM Code. The Company will need to prove that measures are in place to
implement the full requirements of the ISM Code within the period of validity of the
interim DOC. When conducting interim DOC audits consideration should be given
to Section 14.4 of the ISM Code that stipulates the requirements in respect of
interim SMC audits.

3.3.4. An interim SMC, valid for not more than six months, may be issued to a new ship
on delivery and when a Company takes on responsibility for the management of a
ship which is new to the Company. In special circumstances the interim SMC may
be extended for a further six months. This is only to be done in consultation with
MCA HQ. When an interim SMC is extended, the full-term SMC should be dated
from the expiry of the first interim certificate.
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3.3.5. Before an interim SMC is issued the auditors should satisfy themselves that:

• The DOC or interim DOC is relevant to that ship.

• Key elements of the ISM Code have been included in the shipboard SMS and
have been assessed during the audit of the Company’s SMS.
• The master and officers are familiar with the SMS and arrangements for its
implementation.
• Instructions identified as being essential have been provided prior to sailing.
• There are plans in place for the Company to carry out an internal audit of the ship
within three months.
• Relevant information on the SMS is given in a working language understood by
the ship’s personnel.

3.4. Companies operating a multi-flagged fleet

3.4.1. When a Company operates a multi-flagged fleet, it should propose a plan of action
to the relevant Flag Administrations and secure a consensus on the audit
process. A DOC should be issued by each of the Flag States. The IMO has
issued a MSC Circular entitled ‘‘Guidelines to Companies operating multi-flagged
fleets and Supplementary Guidelines to Administrations’’ (see MSC/Circ. 762).

3.4.2. DOC audits are always carried out by the MCA unless UK flag ship(s) form a
minor proportion of a multi-flagged fleet in which case MCA may delegate the
DOC audit to another flag state or recognised organisation which can perform the
audit and issue the DOC on behalf of MCA. If the Company operates passenger
ships, the DOC audit will have to be carried out by the MCA.

3.4.3. For a Company with UK flag ship(s) on the Enhanced Authorisation Scheme,
forming a minor proportion of a multi-flagged fleet, MCA will carry out the
initial/renewal DOC Audits and may delegate the annual DOC audits to another
flag state or recognised organisation which can perform the audit on behalf of
MCA.

3.5. Amending the DOC to include new ship types

3.5.1. When a Company decides to expand its scope of operations to include additional
ship type(s) an interim audit will be required prior to issuance of a DOC to ensure
that the necessary provisions are in place within the SMS to manage the additional
ship type(s). Following a successful audit, an interim DOC, valid for no more than
12 months, should be issued. The existing DOC will remain unaffected for the
period of validity of the interim DOC (see paragraph 3.3 of these Instructions).

3.5.2. When sufficient objective evidence has been compiled to demonstrate that the
SMS is effectively implemented in respect of the new ship type(s), the Company
should be revisited prior to the expiry of the interim DOC. Following a successful
audit, both the interim and full-term DOC’s should be withdrawn and a new DOC

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issued to include all additional ship type(s). The expiry date of the new DOC
should coincide with that of the original full-term DOC.

3.5.3. During the period of validity of the interim DOC, the new ship types will carry a
copy of the interim DOC together with their interim SMC’s. It must be noted that
only an interim SMC can be issued on the back of an interim DOC. The existing
ships of the fleet will be unaffected and will hold copies of the full-term DOC.

3.5.4. If during an annual DOC audit, it is evident that the Company has not operated a
particular ship type for the last two years, the particular ship type should be
removed from the DOC. This needs to be done in consultation with MCA HQ.

3.6. Cancellation or suspension of DOC or SMC

3.6.1. Only the MCA may cancel or suspend a DOC or SMC. When a major non-
conformity has been identified the MCA may either suspend or cancel the DOC
and require such a certificate to be surrendered. In this case all SMCs associated
with the DOC will likewise be invalidated, rendering the ship(s) liable to detention if
the MCA considers that a Company is unable to operate ships without creating a
risk of:

• Serious danger to safety of life;

• Serious damage to property; or
• Serious harm to the environment or that company.

3.6.2. An authorised person (S.I. 1998 No.1561 Reg. No. 16(b)) may suspend the
operation of ships by that Company until such time as any risk is removed or a
valid DOC held.

3.7. Extension of certificates/audits not requested on time

3.7.1. Extension of any ISM certificate should not be encouraged as owners/ managers
have ample opportunity to get these organised. The ISM Code allows the
extension of the validity of an interim SMC for a further period of 6 months. This
should only be done, if the MCA is unable to put a surveyor on board before the
expiry of the interim certificate, and the Company had given appropriate notice for
carrying out the audit or the vessel is in an area to where travel is prohibited. Any
such extension is to be given only after consulting MCA HQ.

3.7.2. If during an initial audit (DOC or SMC) it is found that the Company/ship does not
merit the issuance of a full-term certificate due to the number of non-conformities,
a short term certificate valid for 3 months is to be issued so that another audit can
be carried out prior to the issuance of a full term certificate. This is to be done in
consultation with MCA HQ.

3.7.3. If the Company/ship fails to request the initial/intermediate/renewal audits and the
DOC/SMC does not get endorsed or expires, the certificate becomes invalid. The
Company needs to provide a written explanation for allowing the certificate to
lapse and the auditor should consider further action in consultation with MCA HQ.
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In such a case an audit to the scope of a renewal audit is to be carried out and a
new certificate issued. For all such cases a new certificate would need to be
issued with the same expiry date as the earlier certificate. A major non-conformity
needs to be raised, which can be downgraded on satisfactory completion of the
audit and an additional audit would need to be carried out for closing out the
downgraded non-conformity.

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4. Conducting the audit

4.1. Auditor qualifications: basic competence for performing

verification
4.1.1. Minimum Educational Requirements

4.1.1.1. In accordance with the requirements of the ISM Code, appendix “Standards on
ISM Code certification arrangements” sections 3 and 4, prospective MCA ISM
Code auditors must have a minimum of formal education comprising the following:

• Qualifications from a tertiary institution recognised by the MCA within a relevant

field of engineering or physical science (minimum two-year programme); or
• Qualifications from a marine or nautical institution and relevant seagoing
experience as a certified ship’s officer.

4.1.1.2. Each application for Lead Auditor training will be reviewed on a case by case
basis. The minimum standard of certification from a tertiary institution will be
Higher National Diploma (or equivalent) in a relevant engineering or technical
subject.

4.1.1.3. The minimum level of certification will be either Master (Unlimited) STCW II/2 or
Chief Engineer (Unlimited) STCW III/2.

4.1.2. Minimum Training Requirements

Provided that prospective ISM Code Lead auditors meet the educational standards
as detailed above, the following minimum standard of training must be met in order
to ensure an adequate level of competence and skills particularly with regard to:

• Knowledge and understanding of the ISM Code.

• Mandatory rules and regulations.
• The terms of reference which the ISM Code requires that the companies take into
account.
• Assessment techniques of examining, questioning, evaluating and reporting.
• Technical and operational aspects of safety management.
• Basic knowledge of shipping and shipboard operations; and
• Participate in 4 audits (at least 1 DOC & at least 1 SMC) and Lead in 2 more audits
(DOC or SMC) under supervision.

4.1.2.1. Theoretical Training

All prospective auditors must achieve a pass grade from either the MCA Lead
Auditor Course or an acceptable equivalent which is deemed to cover all the above
requirements.

4.1.2.2. Practical Training

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4.1.2.2.1. In general, the practical phase of training will not commence until the theoretical
phase has been completed.

4.1.2.2.2. Participate in 4 audits (at least 1 DOC & at least 1 SMC) and Lead in 2 more
audits (DOC or SMC) under supervision are to be successfully completed prior to
qualification. Although some candidates may need to fulfil additional re-audits
before qualifying as Lead Auditor. There is no maximum number of audits after
which a candidate automatically qualifies.

4.1.2.2.3. Interim/additional audits are not considered as qualifying audits for a Lead
Auditor.

4.1.2.2.4. New entrants into the MCA who have qualified as Lead Auditors with any of the
MCA recognised classification societies and have maintained their continuous
professional development need not attend the MCA Lead Auditor Course. They
will however need to undergo a familiarisation with MCA procedures and conduct
a minimum of two audits under supervision in order to verify familiarity with MCA
requirements and procedures.

4.2. The safety management system (SMS)

4.2.1. To comply with the requirements of the ISM Code every Company should develop,
implement and maintain a SMS which should embrace the objectives of the Code.
Compliance with the requirements of the ISM Code should be verified by
determining:

• That the SMS meets the requirements of the ISM Code.

• That the objectives laid down in paragraph 1.2.1 of the ISM Code are met.
• That all identified risks to the ships, personnel and the environment have been
assessed and safeguards established.
• That personnel have received the appropriate training and familiarisation in the
tasks for which they have responsibility.
• That they are carrying out their work in accordance with the Company’s
procedures.
• That tasks are being carried out with due regard for safety.

4.2.2. In the normal course of events, a General Inspection (GI) will be conducted in
parallel with the SMC audit. Previous reports of MCA inspection and deficiencies
and port state control inspection reports should be reviewed to obtain a fuller
perspective of the ship’s history. An emergency drill should be witnessed as far as
is practicable. Since it is likely that UK ships, other than passenger ships, may not
be visited by MCA surveyors for intervals of up to three years the SMC audit
should take into consideration the MCA's Survey and Inspection Policy with regard
to the conduct of emergency drills and exercises. In the case of passenger ships
that undergo a Passenger Safety Certificate Survey on an annual basis, if a drill
has been conducted within the last 12 months and evidence of this can be
provided, the requirement for a drill may be waived. In the case of ships other than
passenger ships, an emergency drill should be witnessed at the time of the SMC
audit. The Company must be made aware of this requirement prior to the audit in
order that appropriate arrangements may be made.
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4.2.3. The Maritime Safety Committee (MSC) affirms that an approved SMS should take
into account cyber risk management in accordance with the objectives and
functional requirements of the ISM Code. The Companies are therefore
encouraged to ensure that cyber risks are appropriately addressed in safety
management systems no later than the first annual verification of the company's
Document of Compliance after 1 January 2021. (Reference Maritime Cyber Risk
Management in Safety Management Systems - Resolution MSC.428(98)). The
associated guidance which needs to be referred to are - Guidelines on Maritime
Cyber Risk Management (MSC-FAL.1/Circ.3). DfT have produced a Code of
Practice for cyber security for ships which would be useful for companies.

4.3. Request for audit

Applications (MSF 5100 forms) for the initial, annual or renewal DOC verification
audits and for initial, intermediate or renewal SMC verification audits should be
made by the Company direct to the Company’s Customer Service Manager (CSM)
at the designated/most appropriately located MO to where the ship is located. The
MO will then raise an electronic file in SharePoint (if one does not already exist) and
organise the audit.

4.4. Document review and planning

4.4.1. The first stage of a DOC interim audit (and renewal audits if the SMS has
undergone considerable changes) will be the document review. The purpose of
the document review is to verify that the Company has a SMS that addresses the
requirements of the ISM Code prior to an interim DOC audit. Following the receipt
of an application requesting an interim DOC audit and payment of the appropriate
fees, the MCA will review the SMS documentation as part of the pre-audit
assessment. The Company would need to send the SMS documentation
(electronic or hard copy) to the MCA Lead Auditor to enable this to happen.

4.4.2. The documents used to define and implement the SMS may be described as the
SMS Manual and may take the form that the Company considers most
appropriate. As a basis for planning the audit, the auditor should review the SMS
Manual to ensure the requirements of the ISM Code are met. The documents
submitted should be the latest version and the review should preferably take place
two weeks prior to the proposed audit. If it is established that the system is
inadequate, the audit may be delayed until the Company has undertaken
corrective action. The document review will provide an overview of the
management structure and SMS used by the Company and assist the auditor(s) in
developing an audit plan.

4.4.3. The KISS (Keep it Short and Simple) principle should be fully embraced as
excessive documentation may hinder the effectiveness of the SMS. Care should
be taken to limit the SMS documentation to sufficiently cover its application to
safety and environmental protection. Companies should structure their
documentation in the way they find most effective and is clearly demonstrated by
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objective evidence. Auditors need to be aware that the SMS documentation may
often be part of an integrated system which includes other management systems
like quality and environmental management. Provided all the elements of the ISM
Code are covered, this should not prove problematic.

4.4.4. The ISM Code presents a challenge to the management of ships, both ashore and
sea-going by providing a reasonable balance of procedures and records etc. If the
documentation is insufficient, the requirements of the SMS will not be adequately
met; equally, if overcomplicated the SMS will overwhelm the users and be
counterproductive to safety.

4.4.5. When a SMC audit has been requested for a ship which operates under a DOC
issued by, or on behalf of another Administration, a copy of that DOC and
sufficient previous DOC audit reports should be obtained for review prior to the
audit. In addition, copies of the SMS manuals may be requested.

4.5. Initial audits

4.5.1. Initial audits will generally be in two phases:

• An audit of the Company’s shore-based management organisation for compliance

with the requirements of the ISM Code. Following the satisfactory completion of this
audit a DOC will be issued to the Company. All ships are required to hold a copy of
the DOC; however, this need not be authenticated or certified (Section 13.6 of the
ISM code); and

• An audit of the Company’s ships in order to verify compliance with the

requirements of the ISM Code. This will include a verification that the DOC for the
Company, which is responsible for the operation of the ship, is applicable to that
particular type of ship and that a copy is held on board. Upon successful audit of
each ship a SMC will be issued. The original version of which shall be retained
onboard, and a copy placed in the company office files.

4.5.2. Companies should acknowledge the safe receipt of DOCs & SMCs.

4.5.3. In general, an initial or renewal audit can be expected to be completed by one

auditor in one day on a cargo ship, however the timescale would vary in
accordance with the size, type of ship, the nature and size of the Company and
their preparedness for the audit.

4.5.4. A rule of thumb for calculating duration is as follows (see table 1): The duration of
the DOC audits would be dependent on the size of the Company/fleet and the
presence of satellite offices. The duration of the SMC audits would be dependent
on the size / complexity of the vessels and the number of crew.

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Table 1:

Companies operating cargo vessels Estimated duration of audit

Document review (cargo) 2 - 4 hrs
DOC interim audit (cargo) 4 - 6 hrs
DOC initial/renewal audit (cargo) 6 - 8 hrs
DOC annual audit (cargo) 6 - 8 hrs
SMC interim audit (cargo) 4 - 6 hrs
SMC initial/renewal audit (cargo) 6 - 12 hrs
SMC intermediate audit (cargo) 6 - 10 hrs
Companies operating passenger
vessels
Document review (passenger) 6 - 8 hrs
DOC interim audit (passenger) 8 - 12 hrs
DOC initial/renewal audit (passenger) 12 - 24 hrs
DOC annual audit (passenger) 8 - 24hrs
SMC interim audit (passenger) 6 - 8 hrs
SMC initial/renewal audit (passenger) 16 - 48 hrs
SMC intermediate audit (passenger) 16 - 24 hrs

4.6. The document of compliance (DOC)

4.6.1. The purpose of the DOC audit is to assess the ability of the SMS to meet the
provisions of the ISM Code and to ensure that these are fully implemented and
understood at all levels within the Company. These include:

• Compliance with mandatory rules and regulations; and

• That Codes, guidelines and standards recommended by the IMO, MCA, or other
industry bodies have been taken into consideration. These documents may be
incorporated into the Company’s SMS.

4.6.2. The DOC audit will take place at the Company’s principal place of business
(normally the office from which the DPA operates). If a Company operates from
more than one location where different safety management functions are
performed, then these other locations will need to be visited. All records within the
Company should be available for examination during an audit. These can include
records of all relevant ship types operated by the Company, statutory and
classification records, personnel records and records of ship maintenance etc.

4.6.3. The auditor should also be satisfied those personnel, both ashore and sea-going,
have received training and are competent to perform their duties within the SMS.
The way the auditor assesses the ability of the Company to meet the objectives of
the ISM Code is as follows:

• Review of the Company’s documentation i.e. The SMS.

• Discussion and interview with members of staff at all levels of the management
team holding responsibility for functions within the SMS.
• Observation of documentary evidence (e.g., Records, logbooks, checklists and
reports concerning UK flag vessels); and

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• Observation of working practices.

4.6.4. A DOC will be issued following a successful audit of the shore side aspects of a
Company’s SMS. Objective evidence should be available to demonstrate that the
Company has been operating the SMS for a minimum of three months ashore and
on board their ships for a full-term DOC to be issued. Records of internal audits
would also need to be verified.

4.6.5. Prescriptive management of packaged systems produced by consultancy firms

may result in Companies implementing requirements which are not suited to their
operation and in so doing undermine the philosophy of the ISM Code. The SMS
needs to be specific to the vessel and to their type of operation (section 11.3 of the
ISM Code refers).

4.6.6. Auditors are reminded that they are attending for the purpose of verifying
compliance with the ISM Code and not to criticize the methodology a Company
has adopted to achieve compliance. Although some systems may appear to be
cumbersome, this should not be of concern if the personnel can demonstrate their
familiarity.

4.6.7. A DOC is issued in respect of the type(s) of ship(s) operated by the Company at
the time of initial verification and for the type of ships they intend to operate in the
near future, and which are covered within the SMS. Should the Company wish to
extend the scope of management at a later stage to include additional ship types a
further audit should be carried out and, if successful, the DOC replaced. See
section 3.5 of these Instructions.

4.6.8. The renewal verification should include an assessment of each element of the
SMS and its effectiveness in meeting the objectives of the ISM Code. A renewal
audit is required prior to the expiry date (it may be arranged within 3 months
before the expiry) of the existing DOC. If a renewal audit is carried out prior to this
3-month window, the certificate will be dated from the date of completion of the
audit.

4.6.9. When a major non-conformity is raised a DOC or SMC cannot be issued. Similarly,
an existing certificate cannot be endorsed for either annual or intermediate
verification and should be withdrawn until sufficient corrective action has been
taken to downgrade the major non-conformity. Any major non-conformity requires
an additional audit within 3 months to close out the downgraded non-conformity.

4.6.10. When non-conformities are raised, a timescale for the implementation of corrective
action should be agreed. Several non-conformities in the same area of operation
may be raised as a single major non-conformity. Similarly, a number of
observations under the same section of the Code may be issued as a single non-
conformity.

4.6.11. The following arrangements, if put in place by the Company, will assist the
auditor(s) in carrying out the audit:

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• The appointment of an individual, who is fully conversant with the Company’s

SMS, to act as audit guide. The guide should make any introductions necessary,
arrange for meetings and interviews with Company personnel, provide a steer
around the offices and make available the Company’s files, reports and other
documents as requested.
• The allocation of office space, ideally separate from that used by company
personnel, for use by the auditor(s); and
• Access to all relevant documents. Where documentation is stored electronically
access to a computer terminal is essential.

4.6.12. Although these arrangements would be beneficial, it might not always be practical
to follow this process.

4.7. The safety management certificate (SMC) audit

4.7.1. The objective of the SMC audit is to assess the implementation of the Company
SMS on board their ships to meet the operational requirements of the ISM Code
and to ensure that these are fully implemented and understood at all levels within
the vessel. These include:

• Compliance with mandatory rules and regulations; and

• That codes, guidelines and standards recommended by the IMO, MCA, or other
industry bodies have been taken into consideration. These documents may be
incorporated into the company’s SMS.

4.7.2. The SMC audit should only be carried out on a ship operated by a Company which
holds a valid DOC relevant to that ship type. If there is any doubt in this regard
MCA HQ should be consulted. Objective evidence should be available to
demonstrate the effective implementation of the Company’s SMS over a period of
at least three months. This should include records of the Company’s internal audit
of the vessel.

4.7.3. Co-operation between the MCA and the Company/ships is essential in order to
establish an audit plan which is convenient to all parties concerned. In order to
assess the implementation of the SMS on board, sufficient time must be allowed
for an effective audit to be conducted. The scope of the SMC audit will cover all
aspects of the vessel’s operation and will include verification of compliance with
documented procedures, the interview of a random sample of personnel and risk
assessments, the examination of documentation and records etc.

4.7.4. The SMC is valid for five years from the date of completion of the initial audit
except when an interim has been extended. An intermediate audit is required
between the second and third anniversaries. The intermediate audit should
determine the effective functioning of the SMS and ensure that any amendments
made since the previous audit comply with the requirements of the ISM Code.
Depending on the nature of any non-conformities identified the MCA may consider
it necessary to carry out additional verification audits. The Company should
conduct audits of its ships, at intervals of not more than 1 year, dependent on the
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size of the fleet, which allows for a meaningful assessment of the effectiveness of
its SMS. The renewal audit should include an assessment of each element of the
SMS relating to that vessel and the effectiveness of the SMS in meeting the
objectives of the ISM Code. The fees charged for ISM audits should be based on
the time taken by surveyors to complete all aspects of the work at the hourly rate
applicable at the time of audit. Estimated fees are payable in advance of audits.

4.7.5. SMC audits should not be carried out when the vessel is in dry dock/extensive refit
as the ship is not considered operational during that time.

4.8. Annual verification (DOC) and intermediate verification (SMC)

audits

4.8.1. A DOC is valid for a period of up to five years and is subject to an annual audit in
order to ensure that the Company is continuing to operate its SMS in accordance
with the requirements of the ISM Code and to verify any amendments made to it.
The audit should include the examination of statutory and class records relating to
at least one ship of each type to which the DOC applies. All sections of the Code
must be addressed. The annual DOC verification must be carried out within a six-
month window that falls three months either side of the anniversary date of the
DOC. The intermediate SMC verification must be carried out between the 2nd and
3rd anniversary dates of the SMC.

4.8.2. If the annual DOC verification or the intermediate SMC verification is not carried
out within the specified window, the relevant certificate (DOC/SMC) becomes
invalid. When the verification is subsequently carried out, a major non-conformity
needs to be raised which can be downgraded on successful completion of the
verification. An additional audit would then need to be carried out within 3 months
to close out the downgraded major non-conformity.

4.8.3. In general, annual and intermediate audits will follow the same process and
methodology as the initial or renewal audits. The main difference being that a
smaller sample of records may be taken.

4.9. DOC and SMC renewal audit

The audit for the renewal of a DOC or SMC should be carried out prior to the expiry
date of the existing certificates. If the renewal audit is conducted within three months
of the expiry date of the existing certificate, the new certificate will run for a period
of no more than five years from the date of expiry of the existing certificate. In this
case a certificate may appear to have been issued with a validity of more than five
years. The auditor must ascertain the circumstances under which the certificate was
issued. If the audit is conducted more than three months prior to the expiry date of
the existing DOC or SMC then the new certificate will be valid for a period of no
more than five years from the date of completion of the audit. The renewal DOC or
SMC audit should include an assessment of all elements of the SMS relating to the
ship and shore management, address all sections of the ISM Code and evaluate the
effectiveness of the SMS in meeting the objectives of the ISM Code.

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NB If the Company holds an interim DOC, the validity of the interim SMC should be
6 months or 12 months if extended (see section 4.8), but under no circumstances
shall it exceed the date of expiry of the interim DOC. On issuance of the full-term
DOC, the full-term SMC may then be issued.

4.10. Responsibilities of lead auditor

The responsibilities of the lead auditor include the following:

• Liaising with the Company.

• Ensuring fees are received prior to audit.
• Reviewing the Company’s documentation.
• Raising the Company /ship file in sharepoint if not already present.
• Preparing an audit plan and sending it to the Company prior to the audit.
• Selecting the audit team, including verifying their auditor qualifications.
• Chairing the opening meeting.
• Co-ordinating the audit.
• Chairing the closing meeting.
• Agreeing corrective action with the Company and the timescale for completion.
• Preparing the certificate(s) for issue.
• Preparing the audit report within 15 days from date of audit completion as far as
practicable.
• Ensuring that the Technical Manager (TM) reviews the audit report. If the TM is
not available, the report should be reviewed by another auditor or G7 Principal or
Consultant Surveyor who has not been involved in the audit.
• Completing the survey works order.

4.11. The audit plan

4.11.1. In preparation for an audit the lead auditor should prepare the audit plan given in
the Annex A and forward it to the Company/vessel prior to the commencement of
the audit (preferably a few days prior to the audit).

4.11.2. The auditors should examine the Company’s documentation, files and procedures
taking into consideration that auditing is a sampling process and that not every file
and procedure can be examined within the time allocated for the audit. In addition
to the audit of files and other appropriate documentation, time must be allocated
for interviews and discussions with members of the management team. The period
allocated for the audit will be dependent upon the size and complexity of the
Company and the number of ships in the fleet. A fire/boat drill should be carried
out as far as practicable as part of SMC audits and time should be allocated for
the same in the audit plan.

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4.12. Guidance on typical agenda for opening and closing meetings

4.12.1. The opening meeting should be chaired by the lead auditor and will usually include
the following elements which will be applicable to both DOC and SMC audits:

• Introductions by members of the audit team and the Company’s management.

• A record of company personnel who attended the meeting to be included in the
audit report; the purpose and scope of the audit to be explained e.g. The ISM Code.
• The authority of the MCA to conduct the audit on its own behalf, or on behalf of
another Flag State, to be emphasised.
• The audit plan, drawn up in advance, to be reviewed and any changes agreed
between the Company and the auditors. This will include, but not be limited to, the
sites/areas to be visited, persons to be interviewed, documentation to be reviewed
and the timing of meetings to accommodate meal breaks.
• Flexibility is essential. It should be made clear that the audit will work around the
demands of the Company, movements of personnel, meetings and any other
requirements.
• The lead auditor will ensure that in a SMC audit the safety of the vessel and crew
should not be compromised at any time and the audit should not affect vessels
normal operation like cargo commitments, crew rest periods, doctor going ashore
etc.
• The categories of non-conformities should be clearly explained; all non-
conformities or observations found during the audit must be brought to the attention
of the auditees as soon as they are identified and not to be raised only during the
closing meeting.
• Confidentiality of the audit between the Company, MCA and any other responsible
administration(s) should be confirmed, noting legitimate Freedom of Information
(FOI) requests may need to be considered. This is important as the auditor(s) will
require access to a wide range of files and documents which support the SMS.
• Disclaimer: auditing is a sampling process, and the auditor(s) may not identify all
existing non-conformities; and
• Company representatives should be given an opportunity to raise questions.

4.12.2. The method of carrying out the audit should be outlined and will include, but not be
limited to, the following:

• Interviews with key members of the management team as laid down in

the audit plan.
• A detailed examination of the SMS; familiarity with and understanding of the safety
and environmental policy, manuals, procedures, and instructions, working practices,
recruitment and training records, management reviews, internal audits,
classification records, accident and non-conformity reports.
• Discussions with members of staff at all levels.
• Findings which may result in the raising of a specific non-conformity should be
promptly drawn to the attention of a company representative, preferably at the time
this is identified; and
• It should be emphasised that a ship audit should not be rushed for completion due
to vessel’s cargo commitments/schedules. If there is insufficient time for completion
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of the audit the owners/managers must make arrangements to carry out the audit at
a later date and bear the additional expenses.

4.12.3. The standard closing meeting agenda (very similar to the opening meeting) will
include the following elements and be applicable to both DOC and SMC audits:

• Introductions by members of the audit team and the Company’s

management.
• A record of company personnel who attended the meeting to be kept and included
in the audit report.
• The purpose and scope of the audit to be reiterated.
• The authority of the MCA to conduct the audit on its own behalf, or on behalf of
another Flag State, to be re-stated.
• The audit findings to be presented, including both the positives and the negatives
(NCN’s).
• Confidentiality of the audit between the Company, MCA and any other responsible
administration(s) to be reiterated.
• The disclaimer to be clearly explained: that auditing is a sampling process, and
the auditor(s) may not identify all existing non-conformities. For example, if no non-
conformities are identified in a particular area, it does not necessarily mean that
none exist; and if non-conformities are raised it does not necessarily mean that
these are the only ones in that area.
• Company representatives should be given an opportunity to raise questions.
• The lead auditor may not continue with an audit if any of the following conditions
prevail:
- There is insufficient time to complete the audit.
- The conduct and support from the auditees are not acceptable; and
- A major incident/accident has occurred on board/company which might affect
conducting the audit.

4.12.4. A note giving reasons for not completing the audit must be included in report MSF
1602/1603.

4.13. Categories of audit findings

Audit findings fall into three categories, details of which are outlined below
and in “Definitions”.

4.13.1. Observation

An observation means a statement of fact made during a safety management audit

and substantiated by objective evidence. The Company/ship is not liable to provide
evidence of the corrective action taken for an observation.

4.13.2. Non-conformity

A non-conformity means an observed situation where objective evidence indicates

the non-fulfilment of a specified requirement of the ISM Code. A non-conformity
should normally be closed out within three months from the date of the audit.

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4.13.3. Major non-conformity

4.13.3.1. A major non-conformity means an identifiable deviation which poses a serious

threat to the safety of personnel, the ship or to the environment that requires
immediate corrective action or the lack of effective and systematic implementation
of a requirement of the ISM Code.

4.13.3.2. A major non-conformity on ship audits requires downgrading to a non- conformity

to allow the vessel to sail (Ref. MEPC/Circ. 1059 of 16-12-2002).

4.13.3.3. An additional audit (timed to verify the effectiveness of the corrective action) is
required within 3 months to close out a downgraded major non-conformity.

4.14. Non-conformity note

4.14.1. Non-conformities should be recorded on the form MSF 1902 (‘‘Non-Conformity

Note’’). If the form is completed in PELORUS, select Company or Vessel audit
from relevant dropdown. However, if the form is completed manually (on the
carbonated pads), then it is the combined form. Auditors should refer to the
guidelines for completing the form which can be found on the reverse of the NCN.

4.14.2. All NCN’s are allocated a unique NCN number, the number should follow the form:
Standard/Name of ship/Year/Serial no.

For example: SMC/Testship/2023/01.

4.15. Human element

4.15.1. The achievement of the ISM Code’s goals is heavily dependent on the human
element i.e. the people who operate the system. The knowledge and experience
of the officers and crew, their familiarity with the Company’s SMS, their training
and records thereof should be verified by observation and interview. Where
practicable, the auditor(s) should witness as many on board procedures as
practicable and these may include, but are not limited to:

• Pre arrival and departure checks on the Bridge and in the engine control room;
• Securing the vessel for sea.
• Voyage planning.
• Navigational briefing.
• Mooring stations fore and aft.
• Bridge procedures in harbour.
• Engine room operations.
• Preparation of machinery for sea
• Machinery maintenance including system preparation
• Anchor stations.
• Bunkering operations.
• Pilot embarkation/disembarkation.
• Passenger musters and handling.

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• Cargo operations/handling.
• Watch handover.
• On-board training.
• New joiner (crew) instructions.
• Emergency drills.
• Safety committee meetings.
• Routine inspections.
• Navigation under pilotage; and
• Watch keeping at sea.

4.15.2. The above on-board procedures when sampled during audit must be reported in
section 7 of the ISM report form (MSF1911).

4.16. Audit report

An audit report should be completed to record the audit findings within 15 working
days from the date of the audit. The report is confidential between the Company,
MCA and any other responsible Administration(s) bearing in mind the requirements
of the Freedom of Information Act. When the MCA has been requested to carry out
the audit on behalf of another Administration the report should be copied to that
Administration. The Company should receive a copy of the report and a further copy
should be held on the relevant SharePoint file. When another Administration
requests a copy of the report, as might be the case with a multi-flagged fleet, it
should be issued providing the Company agrees. The audit report must be reviewed
by the Technical Manager (TM) or a G7 Principal or Consultant Surveyor or another
auditor who has not been involved in the audit before it is sent to the client.

4.17. Audit report for document of compliance audit

The report should include the following:

• Name of the lead auditor.

• A list of the audit team members.
• A list of personnel interviewed, and positions held within the company.
• An assessment of compliance with each relevant section of the ism code.
• Opening and closing meeting details.
• The types of ships managed by the company.
• The operational patterns of the company’s ships.
• Audit plan; and
• Areas covered and audit findings.

4.18. Audit report for safety management certificate audit

The report should include the following:

• Name of the lead auditor.

• Names and ranks of auditees.
• Names of audit team members.
• An assessment of compliance with each relevant section of the ism code.
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• Opening & closing meeting details.

• The type of ship and employment patterns.
• Audit plan; and
• Areas covered and audit findings.

4.19. Close out of non-conformities

4.19.1. When a major non-conformity is raised corrective action must be implemented

before a new certificate can be issued or an existing certificate endorsed at annual
(DOC) or Intermediate (SMC) verification. A major non-conformity may be
downgraded to a non-conformity as soon as appropriate initial corrective action
has been taken. Corrective action and an agreed timescale for closure against this
non-conformity may then be agreed. A significant number of non-conformities
identified against the same section of the ISM Code may be issued as a single
major non-conformity. When an auditor identifies a major non-conformity,
agreement MUST be sought immediately from MCA HQ or the duty surveyor if out
of hours. Where a major non-conformity is downgraded in a SMC or DOC audit, at
least one additional audit should be carried out within 3 months to verify that
effective actions are taken (Ref: MSC Circ. 1059).

4.19.2. When an auditor identifies a potential non-conformity, agreement must be reached

with the head of the department or area concerned that the perceived non-
conformity exists. Agreement should be reached prior to the closing meeting.
Suitable corrective actions and appropriate corrective action timescales must also
be discussed and agreed with the Company. Auditors are reminded that corrective
action times cannot exceed three months. If a Company cannot complete a
corrective action within the maximum time of three months, the non-conformity
note is to be closed out and another raised (National Audit Office instructions).

4.20. Corrective action

4.20.1. A representative from the Company or ship should propose corrective action which
identifies the root cause of the non-conformity and an action to eliminate the same
and to avoid re-occurrence.

4.20.2. The Company is responsible for ensuring that the agreed corrective actions are
completed by the agreed dates as failure to do so may affect the validity of
certificates. Corrective action and possible follow-up audits should also be
completed within the agreed timescale.

4.20.3. Closing out of non-conformities will not normally require a revisit by an auditor.
Written notification of the completion of corrective action, accompanied where
possible by objective evidence, shall be forwarded to the lead auditor through the
DPA. This should be accompanied by the appropriate copy of the NCN. When the
lead auditor is satisfied that the agreed corrective action has been completed the
NCN will be closed out, signed, and returned to the DPA. During annual DOC
audits the opportunity should be taken to confirm that NCN’s raised at the previous
audit have been closed out on time. The corrective actions may also be verified. In
the case of SMC audits the foregoing may be achieved during either the next
intermediate audit or a general inspection.
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4.21. Confidentiality Of Audit

The audit and the subsequent reports are confidential (subject to any disclosures
under the law) between the Company and any other Flag State Administration on
whose behalf the MCA may have been requested to act. A statement to this effect
should be made at both the opening and the closing meetings. However, the auditor
should not sign the Company’s confidentiality forms or contracts. The confidentiality
clause must be included in all audit reports.

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5. Extract of ISM Code & UK (policy) interpretation

The following is an extract of the ISM Code with UK interpretation below

Part A – implementation

5.1. General
5.1.1. Definitions

The following definitions apply to parts A and B of this Code.

International Safety Management Code (ISM) Code means the International

Management Code for the Safe Operation of Ships and for Pollution Prevention as
adopted by the Assembly, as may be amended by the Organisation (1.1.1 of the
Code).

Company means the owner of the ship or any other organisation or person such as
the manager, or the bareboat charterer, who has assumed the responsibility for
operation of the ship from the ship-owner and who, on assuming such responsibility,
has agreed to take over all duties and responsibility imposed by the Code (1.1.2 of
the Code).

Administration means the Government of the State whose flag the ship is entitled to
fly (1.1.3 of the Code).

Safety Management System means a structured and documented system enabling

company personnel to effectively implement the Company safety and environmental
protection policy (1.1.4 of the Code).

Document of Compliance means a document issued to a company which complies

with the requirements of the Code (1.1.5 of the Code).

Safety Management Certificate means a document issued to a ship which signifies

that the Company and its shipboard management operate in accordance with the
approved SMS (1.1.6 of the Code).

Safety Management Audit means a systematic and independent examination to

determine whether the SMS activities and related results comply with planned
arrangements, whether these arrangements are implemented effectively and
whether they are suitable to achieve the objectives of the ISM Code.

Objective Evidence means quantitative or qualitative information, records or

statements of fact pertaining to safety or to the existence and implementation of a
SMS element, which is based on observation, measurement or test and which can
be verified (1.1.7 of the Code).

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Observation means a statement of fact made during a safety management audit and
substantiated by objective evidence (1.1.8 of the Code).

Non-conformity means an observed situation where objective evidence indicates

the non-fulfilment of a specified requirement (1.1.9 of the Code).

Major non-conformity means an identifiable deviation that poses a serious threat to

the safety of personnel or the ship or a serious risk to the environment that requires
immediate corrective action and includes the lack of effective and systematic
implementation of a requirement of this Code (1.1.10 of the Code).

Designated Person is defined in Section 4 of the Code.

Ro-Ro passenger ferry means a seagoing passenger vessel with facilities to enable
road or rail vehicles to roll on and roll off the vessel and which carries more than
twelve passengers.

Anniversary date means the day and month of each year that corresponds to the
date of expiry of the relevant document or certificate (1.1.11 of the Code).

Convention means the International Convention for the Safety of Life at Sea, 1974,
as amended (1.1.12 of the Code).

5.1.2. Objectives

5.1.2.1. The objectives of the Code are to ensure safety at sea, prevention of human injury
or loss of life, and avoidance of damage to the environment, in particular to the
marine environment and to property.

5.1.2.2. Safety management objectives of the Company should, inter alia:

.1 Provide for safe practices in ship operation and a safe working environment.
.2 Assess all identified risks to its ships, personnel and the environment and establish
appropriate safeguards.
.3 Continuously improve safety-management skills of personnel ashore and aboard
ships, including preparing for emergencies related both to safety and
environmental protection.

5.1.2.3. The safety management system should ensure:

.1 Compliance with mandatory rules and regulations; and

.2 That applicable codes, guidelines and standards recommended by the
organization, administrations, classification societies and maritime industry
organizations are taken into account.

UK Interpretation - The Company SMS should provide for methods of

identification of risks (including risks related to cyber security) and establishment
of safeguards against the same. This shall be verified during audits of the
Company for issuance of the DOC, subject to the Company providing sufficient
evidence of following the risk assessment procedures. During the SMS audits on
board, a few risk assessments need to be randomly sampled and verified for
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effectiveness. Inadequacies in the general standard of risk assessment will require

closer examination of onboard risk assessments and the related procedure. While
selecting the sample, auditors should be guided by incidents/ accidents on board
the vessel and other vessels in the fleet or by operations which are taking place
while on board. Please note that there is no requirement to comply with codes,
guidelines, standards, etc. (1.2.3.2), however the SMS should take these into
account and alternative measures should be in place if the Company has decided
not to comply.

5.1.3. Application

5.1.3.1. The requirements of this Code may be applied to all ships.

UK Interpretation - This means that the ISM Code may be applied to any ships
irrespective of whether they are required to comply with the same. This is what
allows Companies/ships to voluntarily comply with the Code. Voluntary ISM
certificates should ideally have the SOLAS reference removed.

5.1.4. Functional requirements for a safety management system (SMS)

5.1.4.1. Every Company should develop, implement, and maintain a SMS which includes the
following functional requirements:

.1 A safety and environmental protection policy.

.2 Instructions and procedures to ensure safe operation of ships and protection of the
environment in compliance with relevant international and flag state legislation.
.3 Defined levels of authority and lines of communication between and amongst,
shore and shipboard personnel.
.4 Procedures for reporting accidents and non-conformities with provisions.
.5 Procedures to prepare for and respond to emergency situations; and
.6 Procedures for internal audits and management reviews.

UK Interpretation - The objectives lay down clear guidelines for the development
of a SMS that complies with the ISM Code. The Company’s policy statement is
fundamental to the system and should be examined during the document review.
Some Companies have a single policy statement while others have several
statements which together comprise the Company’s safety and environmental
protection policy. The statement(s) should (i) describe how the objectives of the
Code will be met and (ii) serve to demonstrate the Company’s commitment to its
SMS and the ISM Code.

5.2. Safety and Environmental Protection Policy

5.2.1. The Company should establish a safety and environmental protection policy which
describes how the objectives given in paragraph 1.2 will be achieved.

UK Interpretation- The policy statement(s) should be clear and concise, with

emphasis being placed on the Company’s commitment to safety and the
environment. It should identify a strategy by which the Company aims to achieve
its policy objectives and include methods to encourage improvement in safety

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awareness and safety management. The policy should be endorsed (not

necessarily signed) by the Senior Management of the Company.

5.2.2. The Company should ensure that the policy is implemented and maintained at all
levels of the organization, both ship based as well as shore based.

UK Interpretation - The strategy for implementation of the policy should be clear

so that it can be understood at all levels within the Company. Members of the
Company’s management team should be interviewed during an assessment. This
is an effective means of establishing whether there is commitment to the SMS at
the highest levels within the Company. Personnel to be interviewed should
include, but not be limited to, the following:

Shore Ship
Managing Director Master
Operations Manager Chief Engineer
Technical Managers Safety Officer
Designated Person Chief Officer/Mate
Quality Manager Training Officer
Safety Manager Engineer / Deck Officers
Personnel/Training Bosun / CPO
Manager
Superintendents Sample of Deck / Engine / Catering
Ratings
Other Office Staff Cook & Galley Staff

Junior personnel should be interviewed on a random basis concerning their

responsibilities within the SMS. They must have the background and experience
appropriate to their role, received suitable training, and possess adequate
knowledge of the SMS. There should be procedures in place to ensure that
adequate training is provided as required.

5.3. Company Responsibilities and Authority

5.3.1. If the entity that is responsible for the operation of the ship is other than the owner,
the owner must report the full name and details of such entity to the
Administration.

UK Interpretation - The Company must ensure that the owner fulfils the
requirement of this section of the Code. These details should be reported to the
MCA. The identification of the ISM manager on the Continuous Synopsis Record
issued by the MCA should be considered as evidence of compliance with this
requirement.

5.3.2. The Company should define and document the responsibility, authority and
interrelation of all personnel who manage, perform and verify work relating to and
affecting safety and pollution prevention.

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UK Interpretation - Responsibilities and authorities should be documented to

enable personnel involved in the SMS to understand what is expected of them and
ensure that the safety and environmental functions have been allocated. The
Company’s documented management system should outline descriptions of the
responsibilities and authorities together with the reporting lines of personnel within
the management structure. Schematics or flowcharts to document lines of authority
and inter-relations between roles are acceptable.

5.3.3. The Company is responsible for ensuring that adequate resources and shore-
based support are provided to enable the Designated Person or persons to carry
out their functions.

UK Interpretation - It must be established whether the Company is committed to

providing the support necessary for the Designated Person Ashore (DPA) to fulfil
their duties. This may include reviewing correspondence between the DPA and the
management board, the budget for safety training and the attitude towards safety
issues at management level. Commitment must start at the top and be prevalent
throughout the Company.

5.4. Designated Person(s)

5.4.1. To ensure the safe operation of each ship and to provide a link between the
Company and those on board, every Company, as appropriate, should designate
a person or persons ashore having direct access to the highest level of
management. The responsibility and authority of the DP or persons should include
monitoring the safety and pollution prevention aspects of the operation of each
ship and ensuring that adequate resources and shore-based support are applied,
as required.

UK Interpretation - The task of implementing and maintaining the SMS is a

management responsibility, however, the DPA holds a key role in the monitoring
process. DPAs should be suitably qualified (refer to MSC-MEPC.7/Circ.6),
experienced in ship operations or management systems and be fully conversant
with the Company’s safety and environmental protection policies and SMS. It is
essential that they have the independence and authority to report to the highest level
of management. Their responsibilities may include the organisation of the
Company’s internal safety audits.

In order for any system of management to be adequately maintained it is essential

that it is monitored at regular intervals. This will ensure that:

• Implementation is verified.
• Deficiencies are reported.
Those responsible for corrective action are identified and that appropriate action
is taken.

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5.5. Master’s Responsibility and Authority

5.5.1. The Company should clearly define and document the master’s responsibility with
regard to:

.1 Implementing the safety and environmental protection policy of the Company.

.2 Motivating the crew in the observation of that policy.
.3 Issuing appropriate orders and instructions in a clear and simple manner.
.4 Verifying that specified requirements are observed; and
.5 Periodically reviewing the SMS and reporting its deficiencies to the shore-based
management.

UK Interpretation - The responsibility for overseeing and implementing all relevant

aspects of the Company’s SMS on the vessel rests with the master. Clear guidance
should be provided to masters concerning their responsibility on matters affecting
the safety of the ship, its passengers and/or cargo and the environment.

5.5.2. The Company should ensure that the SMS operating on board the ship contains a
clear statement emphasizing the master’s authority. The Company should
establish in the SMS that the master has the overriding authority and the
responsibility to make decisions with respect to safety and pollution and to request
the Company’s assistance as may be necessary.

UK Interpretation - Masters should always expect support and encouragement

from the Company. There must be a clear statement in the documented
management system that the master has overriding authority to deviate from this in
time of crisis and seek assistance from the Company if required. Both statements
must be clear and unequivocal with the appropriate emphasis placed on the
master’s overriding authority.

5.6. Resources and Personnel

5.6.1. The Company should ensure that the master is:

.1 Properly qualified for command.

.2 Fully conversant with the company’s SMS; and
.3 Given the necessary support so that the master’s duties can be safely performed.

5.6.2. The Company should ensure that each ship is:

.1 Manned with qualified, certificated and medically fit seafarers in accordance with
national and international requirements; and
.2 Appropriately manned in order to encompass all aspects of maintaining safe
operations on board.

UK Interpretation - The Company has a clear responsibility to employ properly

qualified and medically fit seafarers and be satisfied that they are familiar with the
management system in operation. The Company should be able to satisfy the
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auditors, by whatever means, that this requirement of the Code is being adequately
addressed. This is also a requirement under MLC 2006. Copies of certificates may
be held on file in the office, or it may be necessary to have a random sample of
certificates e-mailed from a cross section of the fleet. Some companies maintain
electronic databases as opposed to a paper filing system. In this case a random
sample of certificates should be obtained to verify the accuracy of the database. The
manning of the ship should cater for all operations on board while the ship is at sea,
anchor or alongside, loading / discharging or carrying out any other activity e.g. tank
cleaning, gas freeing, etc.

5.6.3. The Company should establish procedures to ensure that new personnel and
personnel transferred to new assignments related to safety and protection of the
environment are given proper familiarisation with their duties. Instructions which
are essential to be provided prior to sailing should be identified, documented and
given.

UK Interpretation - STCW A-I/14 (Responsibilities of Companies) requires the

Company to provide written instructions to the master regarding the policies and
procedures to be followed, ensuring newly recruited seafarers are familiar with their
duties before they are assigned tasks on board. This shipboard familiarisation
should include sufficient time to become acquainted with:

• Emergency / evacuation procedures and arrangements to perform assigned duties

properly;
• Ship specific duties related to the role the seafarer will fulfil on-board; and
• Ship specific knowledge of any safety and environmental protection procedures
with which the seafarer should be acquainted.

A knowledgeable crew member should be designated to ensure that newly

recruited seafarers are made aware of essential information in a language they
understand. The STCW Code requires mandatory training in crowd management
for some personnel serving on passenger ships. Records of familiarisation and
instructions received by crew members should be available for examination by the
auditor(s).

5.6.4. The Company should ensure that all personnel involved in the Company’s SMS
have an adequate understanding of relevant rules, regulations, codes and
guidelines.

UK Interpretation - While the ISM Code does not introduce new legislative
requirements, the SMS must embrace all existing international conventions,
national rules and regulations, industry guidelines and codes of practice. It is
acceptable for the SMS to encompass such documents as the Code of Safe
Working Practices for Merchant Seamen, the Bridge Procedures Guide, the
Tanker Safety Guide, etc.

5.6.5. The Company should establish and maintain procedures for identifying any
training which may be required in support of the SMS and ensure that such
training is provided for all personnel concerned.

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UK Interpretation - The means of identifying the training needs of individuals, both

ashore and seagoing, is for the Company to address. This may be achieved by staff
appraisal, the end of contract report for seagoing staff, results of internal audits,
drills, analysis of accidents, etc. Training requirements could be met by refresher
training courses and on the job training.

5.6.6. The Company should establish procedures by which the ship’s personnel receive
relevant information on the SMS in a working language or languages understood
by them.

UK Interpretation - The SMS, in whatever form, must be available to all personnel,

both ashore and seagoing. It is the Company’s responsibility to ensure that the
manuals are in a language(s) understood by all crew members. Many Companies
employ the services of manning agencies, often in several countries world-wide.
The Company’s procedures should detail the process by which crew members are
selected, assigned to its ships and familiarised with their responsibilities prior to
taking up a position on board.

5.6.7. The Company should ensure that the ship’s personnel are able to communicate
effectively in the execution of their duties related to the SMS.

UK Interpretation - The ability of crew members to communicate effectively is

essential to the safety of the ship. This should be assessed at the recruitment stage
and manning agencies should be vigilant in this exercise. The Company should
ensure that there are procedures in place to monitor the manning agencies which
they use.

5.7. Shipboard Operations

5.7.1. The Company should establish procedures, plans and instructions, including
checklists as appropriate, for key shipboard operations concerning the safety of
the personnel, ship and protection of the environment. The various tasks involved
should be defined and assigned to qualified personnel.

UK Interpretation - The Company should establish the key shipboard operations

and ensure that procedures and instructions are available for carrying out these
operations. While shipboard operations will vary depending on ship type, it is
suggested that plans and instructions for the following operations should be
documented:

• General shipboard operations.

• Port operations.
• Preparation for sea.
• Conduct of the voyage.
• Preparation for arrival in port; and
• Emergency response organisation.

The auditor(s) should verify that the operations established by the Company are
relevant and comprehensive for the ship type(s) that the Company operates.

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5.8. Emergency Preparedness

5.8.1. The Company should establish procedures to identify describe and respond to
potential emergency shipboard situations.

UK Interpretation - The procedures should integrate the response to potential

emergencies by shore-side and shipboard operations. The Maritime Safety
Committee of the IMO produced ‘‘Guidelines for an Integrated System of
Contingency Planning for Shipboard Emergencies’’ as MSC/Circ. 760. This circular
is not intended to impose a new system or supersede existing systems which are
tried and tested, such as SOPEP, however the Guidelines may be of assistance to
Companies in developing an integrated emergency response system.

Contingency plans may include but are not limited to:

• The role and responsibilities of shore and ship personnel during an emergency.
• A list of names and contact numbers of all relevant parties.
• Procedures to be followed in response to varying emergency scenarios.
• Procedures for communication between ship and shore.
• A database of plans, particulars of vessels, emergency response capabilities,
damage stability information and pollution prevention equipment.
• Checklists for a range of emergencies (the use of checklists is strongly
encouraged);
• Procedures for notifying next of kin.
• Guidelines for liaising with the press and media; and procedures for requesting
emergency services from third parties.

Latest guidelines covered by:

Resolution A.1072(28) Adopted on 4 December 2013 Revised Guidelines for a

Structure of an Integrated System of Contingency Planning for Shipboard
Emergencies.

Emergency scenarios for which contingency plans might be developed, include, but
are not limited to:

• Structural failure.
• Main engine failure.
• Failure of steering gear.
• Failure of electrical power.
• Collision.
• Grounding.
• Shift of cargo.
• Pollution (spillage of oil or other cargo).
• Fire.
• Flooding.
• Abandon ship.
• Man overboard.
• Entry into enclosed spaces.
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• Terrorism or piracy.
• Helicopter operations for medical evacuation.
• Heavy weather damage; and
• Treatment of serious injury.

5.8.2 The Company should establish programmes for drills and exercises to prepare for
emergency actions.

UK Interpretation - The drill programme should exercise the emergency plans

listed in 8.1 above and where appropriate, mobilise the shore-side emergency
contingency plans.

5.8.3 The SMS should provide for measures ensuring that the Company’s organization
can respond at any time to hazards, accidents and emergency situations involving
it ships.

UK Interpretation - Drills should be carried out regularly in order to test the

Company’s emergency response organisation and the competence of those who
will be called upon in a real emergency. The ability of the personnel ashore to
respond to emergencies should also be tested periodically. Records of all drills and
exercises should be retained and made available for examination. In the event of
the Company having to respond to a real emergency this may be considered in lieu
of an exercise drill, providing that records have been retained and analysed.

5.9. Reports and Analysis of Non-conformities, Accidents and

Hazardous Occurrences

5.9.1 The SMS should include procedures ensuring that non-conformities, accidents and
hazardous situations are reported to the Company, investigated and analysed with
the objective of improving safety and pollution prevention.

5.9.2 The Company should establish procedures for the implementation of corrective
action, including measures intended to prevent recurrence.

UK Interpretation - The SMS should contain procedures that require reports to be

prepared and forwarded to the Company on all accidents, hazardous occurrences
and non-conformities. They should be monitored by the Designated Person Ashore
(DPA) and the appropriate corrective action agreed in order to avoid a recurrence
of the incident or non-conformity.

Any deviation from the SMS procedures and instructions, that represents a non-
conformity, should be recorded, raised on a non-conformity note and forwarded to
the DPA. The system should be designed to allow continual updating, amendment
and improvement due to the reporting procedures.

The reports should be recorded, investigated, analysed and acted upon as

necessary. There should be procedures for reporting feedback to the ship and for
circulation around all appropriate areas. Motivation is a significant factor in the
success of the management system and feedback is a powerful motivator.
Feedback should be recorded as evaluation and analysis may lead to:
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• Identification and implementation of corrective action.

• Benefits to the whole company.
• Amendments to existing procedures; and
• Development of new procedures.

The Accident Reporting and Investigation Regulations (S.I. 2005 No. 881) define
accidents, serious injuries and dangerous occurrences along with statutory
reporting requirements.

5.10. Maintenance of the Ship and Equipment

5.10.1. The Company should establish procedures to ensure that the ship is maintained in
conformity with the provisions of the relevant rules and regulations and with any
additional requirements which may be established by the Company.

5.10.2. In meeting these requirements, the Company should ensure that:

.1 Inspections are held at appropriate intervals.

.2 Any non-conformity is reported, with its possible cause, if known.
.3 Appropriate corrective action is taken; and
.4 Records of these activities are maintained.

UK Interpretation - Procedures should be developed to ensure that maintenance,

surveys, repairs and dry-docking are undertaken in a planned and structured
manner with safety as a priority. All personnel responsible for maintenance should
be suitably qualified and familiar with national and international legislation as well
as classification society requirements. The management team ashore shall provide
technical support and advice to the seagoing staff.

Maintenance procedures could include:

• Hull and superstructure.

• Lifesaving, firefighting and anti-pollution equipment.
• Navigational equipment.
• Steering gear.
• Anchors and mooring equipment.
• Main engine and auxiliary machinery including pressurised systems.
• Cargo loading and discharge equipment.
• Tank venting and inerting systems.
• Fire detecting systems.
• Bilge and ballast pumping systems.
• Waste disposal and sewage systems.
• Communications equipment.
• Emergency lighting; and
• Gangways and means of access.

Maintenance procedures must also include work instructions ensuring that

machinery or systems undergoing maintenance have been rendered safe prior to

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starting work i.e., that systems under pressure such as engine cooling water, oil fuel
and steam systems have been securely isolated and de-pressurised.

The Company should arrange for inspections of its vessels to be carried out
regularly. These inspections should be executed in compliance with the appropriate
procedures by competent and qualified personnel. Records of maintenance,
inspections, certificates and reports may be maintained both on board ship and
ashore if considered appropriate by the Company.

There should be procedures for reporting non-conformities and deficiencies that

should include a time scale for completion of corrective action. It is the Company’s
responsibility to ensure that reports are investigated and feedback provided to the
reporting officer. The Company should actively provide support to enable the SMS
to function effectively.

5.10.3. The Company should identify equipment and technical systems the sudden
operational failure of which may result in hazardous situations. The SMS should
provide for specific measures aimed at promoting the reliability of such equipment
or systems. These measures should include the regular testing of stand-by
arrangements and equipment or technical systems that are not in continuous use.

UK Interpretation - This equipment is commonly referred to as ‘critical equipment’.

It is the Company’s responsibility to identify critical systems and equipment. Once
the critical systems have been identified, procedures should be developed to ensure
reliability of these systems or the provision of alternative arrangements in the event
of sudden failure. The procedures implemented should include the regular testing
of stand-by systems to ensure that one failure does not result in the total loss of that
critical function. Routine maintenance should include the regular and systematic
testing of all critical and stand-by systems.

5.10.4. The inspections mentioned in 10.2 as well as the measures referred to in 10.3
should be integrated into the ship’s operational maintenance routine.

UK Interpretation - Most companies have a preventive maintenance process in

place which can range from a card-based system to sophisticated software-based
systems.

The auditor(s) should examine the measures which have been developed to
promote reliability including records, frequency of inspection/testing and
maintenance procedures. In accordance with Section 10.3, these items should be
incorporated into the vessels planned maintenance system (PMS).

5.11. Documentation

5.11.1. The Company should establish and maintain procedures to control all documents
and data which are relevant to the SMS.

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5.11.2. The Company should ensure that:

.1 Valid documents are available at all relevant locations.

.2 Changes to documents are reviewed and approved by authorized personnel; and
.3 Obsolete documents are promptly removed.

UK Interpretation - Procedures should be in place for the control of all

documentation, which should be approved prior to issue and assessed for its user
friendliness. This is an essential element of any SMS. Personnel at all levels within
the Company should be familiar with the procedures and with the latest version of
the documentation. Obsolete documentation should be removed from all locations,
otherwise, there is the risk that superseded procedures may remain in use.

Companies should be encouraged to limit their documentation to satisfy safety and

environmental protection requirements. The Keep it Short and Simple (KISS)
principle should be promoted in the development of procedures and instructions.
The documentation developed by the Company should not be overly long as
excessive documentation may be counter-productive to the effective functioning of
a SMS and prove cumbersome for the personnel implementing the system. This
however should not be of concern if the personnel are able to demonstrate their
familiarity with the system and are able to locate documents without much delay.

5.11.3. The documents used to describe and implement the SMS may be referred to as
the Safety Management Manual. Documentation should be kept in a form that the
Company considers most effective. Each ship should carry on board all
documentation relevant to that ship.

UK Interpretation - The Company’s SMS should encompass all elements of the

ISM Code. The use of a matrix to identify relevant sections is a simple and effective
method. The Company may consider appointing a person ashore with responsibility
for control, amendment, approval and distribution of SMS documentation, which
should be monitored by the DPA. On board ship, the master will ordinarily have
control of the documentation.

5.12. Company Verification, Review and Evaluation

5.12.1. The Company should carry out internal safety audits on board and ashore at
intervals not exceeding 12 months to verify whether safety and pollution-
prevention activities comply with the SMS. In exceptional circumstances, this
interval may be exceeded by not more than 3 months.

UK Interpretation - Internal audits should be conducted in order to verify that the

SMS is functioning effectively. All sections of the SMS should be audited on a
regular basis. The Company must complete internal audit procedures prior to
requesting an external audit. Resolution MSC.273(85) clarifies that the internal audit
should not normally be exceeded and the company should be in a position to explain
the “exceptional circumstances” under which the audit could not be carried out.
Furthermore, for UK flagged vessels we do not intend to ask a Company to seek
approval for an extension in “exceptional circumstances”. However, when we

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conduct an audit of a vessel or company, if we see that the extension clause has
been used inappropriately, then the MCA auditor should consider issuing an NCN.

5.12.2. The Company should periodically verify whether all those undertaking delegated
ISM-related tasks are acting in conformity with the Company’s responsibilities
under the Code.

UK Interpretation - The Company should evaluate those entities undertaking ISM-

related tasks e.g. recruitment agency, maintenance contractor, etc. If ISM related
tasks are delegated to another entity, there should be evidence to demonstrate that
their activities are periodically verified.

5.12.3. The Company should periodically evaluate the effectiveness of the SMS in
accordance with procedures established by the Company.

UK Interpretation - A periodic review of the SMS should be undertaken by the

Company’s management. This review will form part of the safety management
strategy of the Company and will be conducted in accordance with documented
procedures. Minutes of the management review meetings should be recorded and
corrective actions allocated to appropriate members of the management team with
a view to improvement. The management review should provide an opportunity for
a critical review by the Company and ship, of the performance of the SMS over the
past year, or other period. Audit reports, inspection reports, non-conformity reports,
accident reports, risk assessments, permits to work, near miss reports, deficiency
lists, complaints, etc., should be reviewed with the objective of identifying trends,
root causes, areas of concern, etc., with a view to continually improve the operation
of the SMS both ashore and on board.

5.12.4. The audits and possible corrective actions should be carried out in accordance
with documented procedures.

UK Interpretation - Procedures and instructions for carrying out internal audits

should be incorporated into the SMS and the audits should be conducted
according to these procedures. Checklists are useful as an aid to the auditor and
may be used as appropriate.

5.12.5. Personnel carrying out audits should be independent of the areas being audited
unless this is impracticable due to the size and the nature of the Company.

UK Interpretation - Internal auditors should be independent of the operation being

audited. However, this may not always be possible in small companies with limited
management resources. Wherever practicable, the auditor should not normally be
involved in the working of the area being audited. Personnel carrying out internal
audits should have received appropriate training.

5.12.6. The results of the audits and reviews should be brought to the attention of all
personnel having responsibility in the area involved.

UK Interpretation - It is important that the results of the audits are brought to the
attention of the personnel responsible for the area, for example, a finding in the

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engine room should be brought to the attention of the Chief Engineer. Copies of
vessel audits should be retained on board.

5.12.7. The management personnel responsible for the area involved should take timely
corrective action on deficiencies found.

UK Interpretation - To improve the SMS, it is important that the results of the

Company’s internal audits and reviews are promulgated to all persons having
responsibility for the SMS. Findings, conclusions and recommendations should be
recorded. The persons with responsibility for that area should take timely corrective
action.

Part B – Certification and Verification

5.13. Certification and periodical verification

5.13.1. The ship should be operated by a Company which has been issued with a
Document of Compliance or with an interim Document of Compliance in
accordance with paragraph 14.1, relevant to that ship.

UK Interpretation -This is self-explanatory; cargo ships over 500GT and passenger

ships engaged in international trade should not operate if the Company does not
hold a DOC or interim DOC valid for the relevant ship type.

5.13.2. The DOC should be issued by the Administration, by an organisation recognised

by the Administration or, at the request of the Administration, by another
Contracting Government to the Convention to any Company complying with the
requirements of this Code for a period specified by the Administration which
should not exceed five years. Such a document should be accepted as evidence
that the Company is capable of complying with the requirements of this Code.

UK Interpretation -The period of validity of a DOC must not exceed 5 years (except
when the renewal audit is carried out in the 3-month window prior to the expiry of
the certificate). During PSC inspections etc., the DOC should be accepted as
evidence that the Company complies with the Code unless there is objective
evidence to the contrary.

5.13.3. The DOC is only valid for the ship types explicitly indicated in the document. Such
indication should be based on the types of ships on which the initial verification
was based. Other ship types should only be added after verification of the
Company’s capability to comply with the requirements of this Code applicable to
such ship types. In this context, ship types are those referred to in regulation IX/1
of the Convention.

UK Interpretation - The Company must only operate the ship types on the DOC
and the initial verification must have included these ship types. If the Company
wants to operate a ship type not included on the DOC, an additional interim
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verification audit must be conducted. In this case, an interim certificate carrying the
new ship type alone will be issued. An audit of procedures and records relevant to
the new ship type must be completed before the full-term DOC can be amended.

5.13.4. The validity of a DOC should be subject to annual verification by the

Administration or by an organisation recognised by the Administration or, at the
request of the Administration, by another Contracting Government within three
months before or after the anniversary date.

UK Interpretation -The validity of the DOC is subject to annual verification the

window for which is three months either side of the anniversary date. The annual
verification window should include an examination of:

• The reports of internal audits of offices and ships.

• Follow up of corrective action and closing out of non-conformities.
• Records of management reviews.
• Reporting of accidents, hazardous occurrences and non-conformities.
• Amendments to procedures, instructions and revisions to documentation.
• Recruiting and training records of staff, ashore and seagoing.
• Reports of inspections of ships.
• Forward planning schedules for the SMC audits of the company ships; and
• Reports on any initial, intermediate or renewal audits conducted to date.

Non-conformities may be issued during the annual verification. The DOC should be
endorsed after verification.

Word of caution - when verifying the anniversary date, work BACKWARDS from the
expiry date. The issue date has little relevance in this context since the certificate
may have been reissued due to a change of Company name or address etc. There
is no discretion allowed for an extension to the annual audit window.

5.13.5. The DOC should be withdrawn by the Administration or, at its request, by the
Contracting Government which issued the Document when the annual verification
required in paragraph 13.4 is not requested or if there is evidence of major non-
conformities with this Code.

UK Interpretation - If the annual verification is not requested or if there is evidence

of major non-conformities, the DOC can be withdrawn. This should only be done in
consultation with MCA HQ.

5.13.6. All associated SMCs and/or interim SMCs should also be withdrawn if the DOC is
withdrawn.

UK Interpretation -If the DOC is withdrawn, all SMCs need to be withdrawn. These
can only be reinstated following audits both ashore and on each ship.

5.13.7. A copy of the DOC should be placed on board in order that the master of the ship,
if so requested, may produce it for verification by the Administration or by an
organisation recognised by the Administration or for the purposes of the control

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referred to in regulation IX/6.2 of the Convention. The copy of the Document is not
required to be authenticated or certified.

UK Interpretation - A copy of the DOC must be placed on board and produced on

request, although it need not be authenticated or certified.

5.13.8. The SMC should be issued to a ship for a period which should not exceed five
years by the Administration or an organisation recognised by the Administration or,
at the request of the Administration, by another Contracting Government. The
SMC should be issued after verifying that the Company and its shipboard
management operate in accordance with the approved SMC. Such a Certificate
should be accepted as evidence that the ship is complying with the requirements
of this Code.

UK Interpretation - A SMC is valid for 5 years from date of completion of the initial
audit and should only be issued after confirmation that the full-term DOC has been
issued, implying that it may be for a shorter period. A SMC should be accepted as
evidence that the ship complies with the Code unless there is objective evidence to
the contrary.

5.13.9. The validity of the SMC should be subject to at least one intermediate verification
by the Administration or an organisation recognised by the Administration or, at
the request of the Administration, by another Contracting Government. If only one
intermediate verification is to be carried out and the period of validity of the SMC is
five years, it should take place between the second and third anniversary dates of
the SMC.

UK Interpretation - At least one intermediate audit is required (which implies that

the flag can insist on more than one), and the SMC is valid for 5 years. If only one
Intermediate Audit is required then it must be undertaken between the 2nd and 3rd
anniversaries of the EXPIRY of the SMC. The MCA process is to have one
intermediate audit between the 2nd and 3rd anniversary dates. However, if there are
concerns about a ship or a Company, MCA has the discretion to undertake
additional audits.

5.13.10. In addition to the requirements of paragraph 13.5.1, the Safety Management

Certificate should be withdrawn by the Administration or, at the request of the
Administration, by the Contracting Government which has issued it when the
intermediate verification required in paragraph 13.8 is not requested or if there is
evidence of major non-conformity with this Code.

UK Interpretation - The SMC can be withdrawn if the audit is not requested or if

there is evidence of major non-conformities.

Word of caution — when verifying the anniversary date, work BACKWARDS from
the expiry date. The issue date has little relevance in this context since the
certificate may have been reissued due to a change of Company name or address
etc. There can be no extension to the intermediate audit window.

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MSIS 02/Rev7/23

5.13.11. Notwithstanding the requirements of paragraphs 13.2 and 13.7, when the renewal
verification is completed within three months before the expiry date of the existing
DOC or SMC the new DOC or the new SMC should be valid from the date of
completion of the renewal verification for a period not exceeding five years from
the date of the expiry of the existing DOC or SMC.

UK Interpretation - Where the renewal audit is conducted within the three-month

window, the new DOC or SMC is valid for a period not exceeding five years from
the expiry date of the old certificate.

5.13.12. When the renewal verification is completed more than three months before the
expiry date of the existing DOC or SMC, the new DOC or the new SMC should be
valid from the date of the completion of the renewal verification for a period not
exceeding five years from the date of completion of the renewal verification.

UK Interpretation - Where the renewal audit is conducted prior to the beginning of

the three-month window then the new DOC or SMC will be valid from the date of
completion of the audit.

5.14. Interim certification

5.14.1. An interim Document of Compliance may be issued to facilitate initial

implementation of this Code when:

.1 A Company is newly established; or

.2 New ship types are to be added to an existing DOC.

5.14.2. Following verification that the Company has a SMS that meets the objectives of
paragraph 1.2.3 of this Code, provided the Company demonstrates plans to
implement the SMS meeting the full requirements of this Code within the period of
validity of the interim DOC. Such an interim DOC should be issued for a period
not exceeding 12 months by the Administration or by an organisation recognised
by the Administration or, at the request of the Administration, by another
Contracting Government. A copy of the interim DOC should be placed on board in
order that the master of the ship, if so requested, may produce it for verification by
the Administration or by an organisation recognised by the Administration or for
the purposes of the control referred to in regulation IX/6.2 of the Convention. The
copy of the Document is not required to be authenticated or certified

UK Interpretation - Interim DOC’s may be issued to a new Company or when new

ship types are to be added to an existing DOC. After a document review and an
interim audit an interim DOC may be issued provided that:

.1 The Company can demonstrate plans to implement the system within the validity
of the interim DOC; and
.2 A copy of the interim DOC is placed on board (it does not have to be authenticated
or certified).

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5.14.3. An interim SMC may be issued:

.1 To new ships on delivery.

.2 When a company takes on responsibility for the operation of a ship which is new
to the company; or
.3 When a ship changes flag.

5.14.4. Such an interim SMC should be issued for a period not exceeding 6 months by the
Administration or an organisation recognised by the Administration or, at the
request of the Administration, by another Contracting Government.

UK Interpretation - Self-explanatory

5.14.5. An Administration or, at the request of the Administration, another Contracting

Government may, in special cases, extend the validity of an interim SMC for a
further period which should not exceed six months from the date of the expiry.

UK Interpretation - Interim SMCs are valid for 6 months, but it is possible to extend
for a further 6 months under exceptional circumstances e.g. ship is in an area to
where travel is prohibited, or external circumstances prevent an inspection from
taking place. This is to be done only in consultation with MCA HQ.

5.14.6. An interim SMC may be issued following verification that:

.1 The DOC, or the interim DOC, is relevant to the ship concerned.

.2 The SMS provided by the Company for the ship concerned includes key elements
of this Code and has been assessed during the audit for issuance of the DOC or
demonstrated for issuance of the interim DOC.
.3 The Company has planned the audit of the ship within three months
.4 The master and officers are familiar with the SMS and the planned arrangements
for its implementation.
.5 Instructions which have been identified as being essential, are provided prior to
sailing; and
.6 Relevant information on the SMS has been given in a working language or
languages understood by the ship’s personnel.

UK Interpretation – Self-explanatory

5.15. Verification

5.15.1. All verifications required by the provisions of this Code should be carried out in
accordance with procedures acceptable to the Administration, taking into account
the guidelines developed by the Organisation (IMO Resolution A.1118 (30)).

5.16. Forms of certificates

5.16.1 The DOC, the SMC, the interim DOC and the interim SMC should be drawn up in a
form corresponding to the models given in the appendix to this Code. If the
language used is neither English nor French, the text should include a translation
into one of these languages.
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UK Interpretation - Self explanatory

5.16.2 In addition to the requirements of paragraph 13.3, the ship types indicated on the
DOC and the interim DOC may be endorsed to reflect any limitations in the
operations of the ships described in the SMS.

UK Interpretation – Self-explanatory

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6. Reporting & filing etc

6.1. Reporting & Quality Control Procedures (DOC & SMC)

6.1.1. Prior to the commencement of the audit the surveyor should obtain the appropriate
documentation from Pelorus and SharePoint, e.g., DOC (MS) or SMC (CM).

6.1.2. DOC files are prefixed/ suffixed MS 166/004/XXX and SMC files CM
XXXXX/48/01.

6.1.3. At the conclusion of the audit the following documents should have been added to
SharePoint, under the relevant Vessels folder:

• Any correspondence between MCA and the Company.

• Audit plan.
• Contemporaneous notes (if appropriate).
• Audit report.
• Nonconformity notes (if appropriate).
• Copy of DOC / SMC (initial / renewal audits); and
• Endorsed copy of DOC / SMC (annual / intermediate verifications).

6.2. Pelorus

6.2.1. Before visiting a vessel, Pelorus should be checked to identify if any outstanding
deficiencies will need verification.

6.2.2. In addition to the audit report MSF 1911, audits must be reported on Pelorus
survey report. Any NCN(s) (MSF 1902) raised during the audit should also be
listed on Pelorus. The NCN form MSF 1902 and the audit report form MSF 1911
are available on Pelorus.

6.2.3. In events where Pelorus forms are not available, complete forms MSF 1602 and
MSF 1603, when applicable and upload to vessel folder in SharePoint.

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7. Port state control

7.1. Examination of Certificates

7.1.1. The DOC and SMC are statutory certificates which will be examined, along with
other certificates, by Port State Control inspectors. Each ship should carry the
original SMC and a copy of the DOC with the relevant endorsements for the
required audits. The copy of the DOC need not be authenticated or
certified. Provided technical or operational deficiencies are not identified during an
initial inspection carried out in accordance with the Paris MOU procedures and
guidelines, there is no need to consider the ISM aspect.

7.1.2. Since the PSCO is not carrying out a safety management audit of the SMS during
a PSC inspection, the term “clear grounds” is not applicable in this context.

8. Particular issues

8.1. Laid up ships

8.1.1. Lay-up: A ship is considered to be in lay-up mode when for commercial reasons or
otherwise it has ceased trading for any period of time and the Company has
notified the Administration accordingly.

8.1.2. Hot lay-up: the machinery and equipment is kept in operation for the sake of fast
re-commissioning in 24 hours.

8.1.3. Cold lay-up: means the ship is deliberately shut down.

8.1.4. Based on the duration, and type of the lay-up, determine the scope and depth of
the audit, which may vary from case to case (see table below).

Hot Cold
Lay-up
The ship is deliberately shut
mode The ship is fully operational in 24 hours
down
Lay-up 3 < 12 > 12
< 3 months < 3 months > 3 months
Periods months months
As in To be To be
SMC Invalid Invalid
operation revalidated revalidated
Additional
Additional
Audit Not required (scope Interim Interim
(scope initial)
initial)

8.1.5. On satisfactory completion of the shipboard audit, the existing SMC should be
endorsed or renewed in accordance with the above table.

8.1.6. By way of exception, where a Company manages a ship, which only operates
seasonally, the Company should establish specific procedures for the lay up
period and reactivation, based on their commercial activities (FR).

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8.2. Submersible craft

It needs to be borne in mind that the operation of a submersible craft is very different
from conventional ships. Some of these may have a mother craft associated with its
operations. The so-called master of the submersible might be on the mother craft,
the submersible being operated by the pilot. In such cases compliance with section
5 of the ISM Code needs to be verified. Guidance on the operational aspects is
available in SI 1987 no. 311.

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9. Annex A – Audit plan

AUDIT PLAN
DOCUMENT OF COMPLIANCE INITIAL/ANNUAL AUDIT

Date:

DATE / Times (approx. LEAD AUDITOR:

duration)

Opening meeting
General review of the company policy/procedures/manual
Document review office and ships
Interview: DPA responsibilities/meetings
Review internal audits, office & ship, DPA responsibilities, resources and personnel
Interview: MD/President/Vice President/Director (any one person involved in Safety Management System of company)
Interview: Technical/Finance Manager
Interview: Technical /Marine Superintendents
Interview: Fleet/Managers(personnel) crewing department
Crew records and crewing procedures
Interview: Admin staff involved in ISM procedures
Documentation verification - records office & ships
Internal/external audit, corrective actions/emergency preparedness & drills
Follow-up & prepare findings
Closing meeting
Due to size of office personnel involved in the audit, the above timings may reduce.
Notes:
1. The above is a guide plan but may be altered as circumstances dictate. Times are given for guidance, but please ensure the main persons identified will be
available for interview.
2. Normal office lunch hours may be maintained.
MSIS 02/Rev7/23

AUDIT PLAN
SAFETY MANAGENT CERTIFICATE INTERIM /INITIAL /INTERMEDIATE/ADDITIONAL AUDIT
VESSEL NAME: IMO NO. :
LOCATION:
Date:

DATE / Times LEAD AUDITOR: AUDIT TEAM MEMBERS

(approx. duration)

Opening meeting

General inspection of vessel

Document review - SMS
Interview: Master
Master’s review, internal audits, ship’s SMS file, resources & personnel, documentation
Interview: Chief Engineer
SMS, maintenance of ship & equipment, emergency preparedness, shipboard operations, section 9 – defect reporting

Interview: Chief Officer

Deck maintenance, cargo operations, maintenance of ship & equipment, emergency preparedness
Interview Deck Officer/Deck Crew
Interview Engineer Officer, Engine Crew
Interview Cook/Catering Staff
Cargo operations, emergency preparedness
Assessment
Emergency drill (to be carried out preferably in day light)
Follow-up & prepare findings
Closing meeting

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MSIS 2/Rev 7/23

Notes:

1) The above is a guide plan but may be altered as circumstances dictate.

Times are given for guidance, but please ensure the main persons identified
will be available for interview.

2) Please ensure that the following documents (relevant to your vessel) are
made available for the audit:

Ships statutory certificates.

Class certificates and survey status reports and conditions of class.
Stability book.
Oil record book part 1.
Garbage record book.
Officer certificates of competency and certificates of equivalent
competency.
Crew agreement.
Safety management manuals.
Training and familiarisation records.
Record of drills.
Details of accidents, non-conformities and hazardous occurrences.
Minutes of safety meetings.
Planned maintenance records.
Cargo loading/discharge plans.
Permit to work records.
Records of previous internal audits.
Hours of work records; and
Port state control inspection records.

MSIS 2/Rev 10/22

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10. Annex B - MCA audit opening & closing meetings

Attendance Record

The following representatives of _____________________________________ were in attendance at the

opening and closing meetings as indicated below:

Opening Meeting Time: __________ Date: __________

Closing Meeting Time: __________ Date: __________

Closing
Opening
Name: Department

1. __________________________________ __________________________________

2. __________________________________ __________________________________

3. __________________________________ __________________________________

4. __________________________________ __________________________________

5. __________________________________ __________________________________

6. __________________________________ __________________________________

7. __________________________________ __________________________________

8. __________________________________ __________________________________

9. __________________________________ __________________________________

10. __________________________________ __________________________________

11. __________________________________ __________________________________

12. __________________________________ __________________________________

13. __________________________________ __________________________________

14. __________________________________ __________________________________

15. __________________________________ __________________________________

16. __________________________________ __________________________________

17. __________________________________ __________________________________

18. __________________________________ __________________________________

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