Introduction

When I was promoted to Chief Officer, I dedicated considerable time and attention to ensuring that my department’s activities and operations adhered strictly to the Safety Management System (SMS). What I find particularly interesting about the ISM Code is that, while it regulates general principles, it allows ship operators ample space to imprint their own operational personality and safety culture.

Understanding the ISM Code

The ISM Code is an essential framework established by the International Maritime Organization (IMO) to enhance the safety of ships and the prevention of marine pollution. It sets out the responsibilities of ship owners and operators to ensure that their vessels are operated safely and that risks are managed effectively. The code is designed to promote a safety culture within the maritime industry, encouraging continuous improvement and adherence to best practices.

Internal SMS Audit

The internal audit of the SMS is a crucial aspect of the ISM Code. These audits are conducted to verify whether safety management activities comply with the requirements of the SMS. The process involves several phases, each of which plays a vital role in ensuring the effectiveness and compliance of the SMS.

Audit Scheduling, Preparation, and Planning

Proper scheduling, preparation, and planning are essential for the success of internal SMS audits. The Marine Surveyor, as the appointed auditor, plays a key role in the preparation and planning phases, while the scheduling is provided by the ISM operator.

1. Audit Scheduling:
   • Develop and implement an internal SMS audit schedule.
   • Ensure coverage of all SMS elements.
   • Make the schedule realistic, accounting for time and resources.
2. Audit Preparation:
   • Identify all audit requirements beforehand.
   • Gather necessary documentation:
     • Safety Management System (SMS) manuals.
     • Previous audit reports.
3. Audit Planning:
   • Establish early communication with the auditee.
   • Agree on:
     • Audit timetable.
     • Areas, activities, or personnel to be audited.
   • Minimise disruptions to regular operations.

Phases of the ISM Audit

1. Opening Meeting: The audit begins with an opening meeting, chaired by the lead auditor. During this meeting, the audit team is introduced, and the purpose, scope, and methodology of the audit are confirmed. This meeting ensures that all personnel involved are aware of the audit’s objectives and procedures.
2. Audit of the SMS: The main phase of the audit involves observing activities, reviewing documentation and evidence, and interviewing personnel. The auditor must reference specific parts of the SMS being audited to ensure compliance with the company’s policies, procedures, work instructions, and record-keeping.
3. Audit Review: After the audit of the SMS, the lead auditor and the audit team review the findings. This review helps in identifying any non-conformities or areas that require improvement.
4. Closing Meeting: The audit concludes with a closing meeting, where the lead auditor presents the findings. This meeting includes a brief reminder of the audit’s scope and purpose, an explanation of the non-conformities, and the signing of the non-conformities. The personnel present at the closing meeting should include those who attended the opening meeting and any additional personnel relevant to the findings.
5. Audit Report: The audit report is prepared and documented, containing all major audit findings. The report includes the final audit plan, audit checklist, records of the opening and closing meetings, and non-conformity reports. The audit file, which contains every piece of information for the internal audit, is maintained by the lead auditor.
6. Clearance and Closure of Non-Conformities: The final phase involves addressing and closing out any non-conformities raised during the audit. There is a maximum time limit of three months to resolve non-conformities. If not dealt with within this period, they are escalated to major non-conformities, which require immediate corrective action.

Challenges and Solutions

Applying the ISM Code and performing internal audits comes with some challenges. It’s not always easy to make sure all crew members fully understand and follow the procedures in the Safety Management System (SMS). This requires ongoing training and clear communication. On top of that, regular audits and inspections, though essential for finding areas to improve and staying compliant, can take a lot of time and effort.

Another issue is the risk of developing a “tick-box mentality,” where the focus shifts to simply completing paperwork and meeting formal requirements rather than addressing real operational safety concerns. This perception can make the ISM audit and SMS processes feel like just another formality, an extra burden for already overworked crew members.

To overcome these challenges, it’s important to reduce and rationalise the administrative load, engage the crew more effectively, and show the real benefits of having a strong SMS. This can help make compliance smoother and create a true safety-first culture.

Benefits of ISM Audits

The benefits of ISM audits are numerous. By promoting a safety culture and encouraging continuous improvement, the audits help reduce the risk of accidents and incidents. They also enhance the efficiency of operations, leading to cost savings and improved performance. Furthermore, compliance with the ISM Code demonstrates a commitment to safety and environmental protection, which can enhance the reputation of the company.

Conclusion

In conclusion, the internal SMS audit is a vital component of the ISM Code. Its structured phases provide a systematic approach to verifying compliance and identifying areas for improvement. As a Senior Officer on board, I have seen firsthand the positive impact of ISM audits on our operations, and I am confident that they will continue to play a crucial role in promoting safety and compliance within the maritime industry.