The ISM Code: definition, application on board and maintenance compliance

The ISM Code is the regulatory backbone of modern maritime safety. It prescribes no equipment list and no plate thickness. What it requires is that the shipowner build an organisation able to demonstrate, at any moment, that it controls its risks. That shift from hardware to organisation is what makes it unusual, and it explains why so many fleet operators experience it as paperwork when it is, first and foremost, a management tool.

This guide covers the subject end to end: what ISM stands for, what the Code actually requires, who it applies to, how certification works, and above all how chapters 9, 10 and 11 — the ones responsible for most audit findings — are handled today with a marine CMMS rather than with binders.

What does ISM stand for? Definition of the Code

ISM stands for International Safety Management. Its full title is the International Management Code for the Safe Operation of Ships and for Pollution Prevention.

Adopted by the International Maritime Organization (IMO) under resolution A.741(18) in 1993, it became mandatory through its incorporation into chapter IX of the SOLAS Convention. It is not guidance: it is a binding instrument, and failure to comply detains ships.

Its objective is stated in the text itself — to ensure safety at sea, prevent human injury and loss of life, and avoid damage to the environment, in particular to the marine environment, and to property.

Why the ISM Code was created

The Code came out of a series of disasters in the 1980s, including the capsizing of the ferry Herald of Free Enterprise in 1987, which killed 193 people. The inquiry did not identify an isolated technical fault but a systemic failure of the shore organisation: vague procedures, an unclear chain of responsibility, a corporate culture that tolerated shortcuts.

The IMO's conclusion was decisive: regulating the ship is not enough, the company operating it must be regulated too. That founding idea explains the Code's form. It almost never states what to do; it states what you must be able to demonstrate.

An objective-based Code, not a prescriptive one

The Code explicitly recognises that no two shipping companies are alike and that ships operate under widely differing conditions. It is therefore written in general terms, around principles and objectives rather than technical specifications.

That is both a strength and a difficulty. A strength, because a six-trawler operator and a container line apply the same text. A difficulty, because compliance cannot be read off a checklist — it is demonstrated through evidence. And evidence is precisely where audits are won or lost.

Who does the ISM Code apply to?

Application came in two phases, above a threshold of 500 gross tonnage:

Fishing vessels, pleasure craft and government ships fall outside the ISM Code under SOLAS. Many flag States and charterers nonetheless impose equivalent systems on these fleets, and a growing number of operators adopt them voluntarily, because the documentary structure is worth having in its own right.

Responsibility rests with what the Code calls “the Company”: the shipowner, or any entity that has assumed responsibility for operating the ship — technical manager, bareboat charterer. This matters. The Code follows real operational responsibility, not ownership.

The Safety Management System (SMS)

The Code requires every company to establish a Safety Management System. This is the heart of the arrangement: a documented and applied set of policies, procedures and responsibilities covering the operation of the ship.

The SMS must provide for six things:

• a safety and environmental protection policy, owned by senior management;
• instructions and procedures ensuring safe operation and environmental protection, in compliance with international and flag State legislation;
• clearly defined levels of authority and lines of communication, on board and between ship and shore;
• procedures for reporting accidents and non-conformities;
• procedures to prepare for and respond to emergency situations;
• procedures for internal audits and management reviews.

The safety management manual compiling these procedures must be available on board — not filed in a drawer in the master's office but accessible to the people expected to apply it, which auditors verify by questioning the crew directly.

The Designated Person Ashore

Chapter 4 requires every company to designate one or more persons ashore — the DPA — having direct access to the highest level of management.

That wording is deliberate. It was written so that a safety manager cannot be filtered by his own hierarchy when raising a problem. The DPA links ship to management, monitors the safety and pollution-prevention aspects of each vessel, and ensures that adequate resources and shore-based support are actually provided.

In small operators this is usually the technical manager; in large ones, a dedicated role. Either way, it is the first person an auditor will want to meet.

The master's authority

Chapter 5 deserves quoting because it is routinely overlooked: the company must clearly establish, in writing, that the master has overriding authority and responsibility to take any decision with respect to safety and pollution prevention, and to request the company's assistance when needed.

In other words, the ISM Code forbids commercial pressure from overriding a safety judgement. It is one of its most protective provisions, and one of the least known among crews.

Structure of the Code: 16 chapters, two parts

The Code comprises Part A on implementation and Part B on certification.

Three chapters account for most audit findings: 9, 10 and 11. They are the ones demanding a continuous record of daily activity, and precisely the ones a paper system handles badly.

DOC, SMC and the audit cycle

Compliance takes the form of two distinct certificates, which should not be confused.

A ship can only hold a valid SMC if its company holds a valid DOC covering its type. If the DOC falls, every SMC in the fleet falls with it — the mechanism that gives the ISM Code its real force.

For new companies or newly delivered ships, interim certificates exist: the interim DOC is valid for twelve months, the interim SMC for six.

What happens when compliance is no longer demonstrated

Consequences are graduated but fast. A major non-conformity raised at audit must be addressed before the ship sails. It can lead to suspension of the SMC, and of the DOC where the failure lies with the shore organisation.

In practice the most immediate effect comes from port State control. A poorly kept ISM file is a classic detention ground: port call blocked, cargo delayed, charterer unhappy — and an entry on the memoranda of understanding's public lists that follows the ship for years.

Chapter 10: maintenance, where the evidence is built

Chapter 10 is the most operational part of the Code. It requires the company to establish procedures ensuring that the ship is maintained in conformity with applicable rules, through a planned maintenance programme — what the industry calls the PMS, or Planned Maintenance System.

Having a plan is not enough. The Code requires inspections to be held at appropriate intervals, any non-conformity to be reported with its possible cause, corrective action to be taken, and records of all of it to be kept.

Critical equipment

The most frequently mishandled provision is paragraph 10.3. It requires identifying equipment and technical systems whose sudden operational failure may result in hazardous situations, then providing specific measures to promote their reliability — including regular testing of stand-by arrangements not in continuous use.

Concretely: your emergency generator, your emergency fire pump, your auxiliary steering gear must not merely exist, they must be tested to a programme, and those tests must leave a dated, signed trace. That is the question the auditor asks, and the one that catches out operators whose tests are pencilled on a board in the engine room.

Three maintenance triggers to structure

A PMS compliant with chapter 10 combines three triggering logics:

• Calendar — annual surveys, quarterly checks, monthly tests. Easy to plan, but disconnected from actual use.
• Running hours — engine hours, cycles, nautical miles. This reflects genuine wear and is what manufacturers recommend.
• Condition — oil analysis, vibration measurement, thermography. The higher level, allowing intervention before failure rather than after. We cover the approach in our article on moving from corrective to condition-based maintenance.

Building such a plan is an exercise in itself; our guide to the four-step planned maintenance programme sets out the method.

Spare parts availability

Chapter 10 also implies that the ship carries the spares, consumables and equipment needed to execute the plan. A PMS that is faultless on paper but impossible to execute for want of parts is a non-conformity waiting to happen — and a detention in the making. The subject is covered in depth in our article on managing spare parts at sea.

Chapter 9: non-conformities, accidents and corrective action

Chapter 9 requires procedures ensuring that non-conformities, accidents and hazardous situations are reported to the company, investigated and analysed, and followed by corrective action, with the objective of improving safety and preventing pollution.

Two classic mistakes here.

The first is reporting only serious events. A near-empty non-conformity register does not reassure an auditor: it signals a culture of silence, not a trouble-free fleet. A mature SMS generates plenty of minor reports — that is the sign it works.

The second is closing non-conformities without root-cause analysis. Replacing a pump that failed is a repair. Understanding why it failed, checking whether the three others of the same model carry the same risk, and adjusting the maintenance plan accordingly is corrective action in the sense of the Code. That difference is exactly what the auditor is assessing.

Statistical analysis of recurrence — the worst-performing equipment, the most frequent finding types, average closure times — is what feeds the continual improvement process required by chapter 12. It is also what turns the SMS from a defensive arrangement into a cost-reduction tool.

Chapter 11: documentation, the audit weak point

Chapter 11 requires establishing and maintaining procedures to control all documents and data relevant to the SMS. Three specific requirements follow:

• valid documents must be available at all relevant locations;
• changes must be reviewed and approved by authorised personnel;
• obsolete documents must be promptly removed.

That third requirement fails more audits than any other. A procedure revised ashore and still applied in its previous version on board is a non-conformity — even if the on-board version is followed perfectly. Across a fleet of ten ships on paper procedures, guaranteeing that no obsolete version is in circulation is a full-time job.

Retention adds to it. Maintenance records, non-conformity reports and drill records must be producible over several years. Losing one binder during a crew change is enough to create a gap in the history that nothing will fill. Our article on the digital engine room logbook returns to this point.

Why a CMMS became the ISM compliance tool

Chapters 9, 10 and 11 share one requirement: producing, keeping and presenting a continuous trace of what happens on board. That is exactly what a CMMS does — provided it is built for the maritime world, meaning it works offline and handles multi-vessel logic.

Here is how the Code's requirements translate into concrete functions in Smart Sailors:

Offline operation is not optional

This is what disqualifies most general-purpose CMMS products. Work done at sea must be recorded when it is done, not three weeks later from memory alongside. A CMMS requiring a permanent connection mechanically produces deferred, imprecise, sometimes reconstructed records — and an experienced auditor spots a register entered in one block the day before his visit.

Audit preparation, from weeks to hours

This is the most tangible benefit for a fleet operator. Traditional ISM audit preparation means reconstructing a file: finding the job cards, checking that stand-by tests were noted somewhere, making sure no obsolete procedure is still circulating, rebuilding the non-conformity history. When everything is captured as it happens in one system, the file already exists; it only has to be exported.

Beyond ISM, the same documentation serves classification surveys, port State control inspections and verification of vessel and crew certificates. One capture effort, several compliance regimes served.

Implementing or modernising your SMS: what to watch

The operators who get real value from the ISM Code are those who approached it as an organisational project rather than a certification formality. A few observations from the field:

1. Do not over-document. A 400-page manual nobody reads creates more non-conformities than it prevents, because every written procedure becomes an audited promise. Write what you actually do.
2. Involve the crew from the design stage. A procedure drafted ashore without the ship will be worked around on board. The Code says as much in its own way: it is the commitment and motivation of individuals at all levels that determines the end result.
3. Take familiarisation seriously. Chapter 6 requires every newcomer to receive documented familiarisation. It is a frequent finding and an easy one to avoid.
4. Keep internal audits alive. Chapter 12 requires periodic internal verification. An internal audit that never finds anything is more suspicious than useful.
5. Reduce the administrative load. This is the main obstacle in mid-sized fleets. Compliance is expensive in human time when it rests on re-keying; it becomes sustainable when the record is produced automatically from the actual work.

Frequently asked questions about the ISM Code

What does ISM stand for?

ISM stands for International Safety Management. The ISM Code is the International Management Code for the Safe Operation of Ships and for Pollution Prevention, adopted by the IMO and made mandatory through chapter IX of the SOLAS Convention.

What is the difference between the DOC and the SMC?

The Document of Compliance (DOC) certifies the company and its ship types; the Safety Management Certificate (SMC) certifies an individual ship. Both are valid for five years. A ship cannot hold a valid SMC without a valid DOC covering its type.

Does the ISM Code apply to fishing vessels?

Not under SOLAS. Fishing vessels fall outside the mandatory scope. Many flag States and charterers nonetheless require equivalent management systems, and a growing share of fishing operators adopt one voluntarily to structure their maintenance and certificates.

Who is the Designated Person Ashore?

The DPA is the person appointed by the company to link the ship and management on safety and pollution-prevention matters. The Code requires direct access to the highest level of management, with no hierarchical filter.

How long does ISM certification take?

It depends on the maturity of the existing organisation. The Code requires the SMS to be operating before the initial audit, which presupposes a period of real application generating records — generally several months between writing the system and the certification audit. A brand-new SMS with no track record does not pass.

Is a CMMS mandatory for ISM compliance?

No. The Code imposes no tool, it imposes an outcome: a planned maintenance programme, applied and provable. A rigorous paper system can satisfy it. The difficulty is that it becomes very expensive to maintain beyond a handful of vessels, and it copes badly with crew changes.

Making ISM a tool rather than a burden

Evidence gathered since the Code entered into force shows one consistent pattern: operators who adopted it as a performance exercise, rather than a box to tick, obtained measurable benefits — fewer breakdowns, fewer detentions, better-controlled maintenance costs. Those who merely endured it harvested paperwork.

The difference rarely lies in the text and almost always in the tooling. An SMS that forces the same information to be entered three times will be worked around. An SMS where the evidence produces itself from work actually performed becomes an asset.

At Smart Sailors we build a marine CMMS with exactly that goal, alongside operators running more than 400 vessels today. Our teams know the subject from the inside: they come from the deck and the engine room.

Book a demo to see how your PMS, your non-conformities and your documentation can live in a single system — or review our plans and try the platform for 30 days.

This article presents the ISM Code for information purposes. The requirements applicable to your fleet depend on your flag State and on the type and tonnage of your vessels. Consult your classification society or maritime administration for a formal opinion.