International Safety Management (ISM) Code

ISM Code has now stood the test of time, as the fundamental in implementing the process-based management system approach in the maritime industry. All too often, major accidents are the catalyst for change in the maritime industry.  Evidence of this is seen in the development and implementation of maritime conventions and codes in existence today. The International Safety Management (ISM) Code, the result of such a catalyst, was meant to change this reactive nature. The ISM Code intended to promote a safety culture wherein risks are properly considered, work is effectively planned, personal accountability is enhanced, and operations are continually improved.   

Unfortunately, this target was missed in many cases and a pervasive by-product called compliance culture set in, wherein the system achieves the minimum and only to satisfy regulators.  The maritime industry and regulators learned much from this experience.  We know now that if the true value of safety management systems (SMS) is not realized, further implementation efforts become self-defeating. This leads to even more than normal resistance from many who have seen colleagues, shipmates and competitors negatively impacted.  A carefully planned implementation strategy expanding the use of safety management systems (SMS) to all vessels, domestic or internationally trading therefore be executed to avoid these pitfalls. Within the USA a Safety Management Systems for domestic passenger vessels should be a priority. The use would be as intended in the same way as those for SOLAS vessels. The lessons that have been learned from similar efforts should be used. 

Looking at the data from the 1980’s to date, one would expect to see a decline in marine casualties starting in 1998 when the ISM code’s first compliance deadline came into effect. Initially the data shows a downward trend for a few years and then a spike starting in 2001. Those resisting change brought about by the ISM code would argue that the code had not delivered any improvements. However, the upward trend peaked in 2008 and has since seen a decline. When a new management system is put in place, irrespective of industry, the first sign of success albeit non-intuitive, is a spike in accidents, incidents and hazardous occurrences. This leading indicator should be accepted as a positive as it demonstrates that the personnel within the system have started reporting non-conformities that went unreported before. This reporting enables corrective action to be taken in a systematic manner to prevent a similar non-conformity from occurring again. Famous tragic quote from Captain of the MV Titanic: “I will say that I cannot imagine any condition which could cause a ship to founder. I cannot conceive of any vital disaster happening to this vessel.”  

In the domestic passenger vessel industry, those against regulations for SMSs will claim that there have only been a few major incidents and therefore not everyone should suffer from more regulation. These few major incidents were identified because they were too large to be missed. Many leading indicators of passenger vessel risk are undetected or unreported (including near misses).  As seen with data related to the ISM code, the eventual decline in major occurrences was a result of the sharing of information across companies and countries to improve the maritime transportation system and industry. The corrective actions implemented have led to improved and streamlined inspection regimes, better construction requirements and standardized competency criteria. Naysayers of the ISM Code and Safety Management Systems will also say the Code has only created unnecessary bureaucracy and paperwork. Those familiar with the 12-page ISM Code know that the code does not prescribe this at all.  If unnecessary bureaucracy and paperwork are produced, it is likely a function of poor system design, poor implementation, or other external drivers, not the prescription of the Code. 

Another common criticism of implementing SMSs is assumed costs. Implementing a SMS, however, need not be expensive. As regulated vessels, domestic passenger vessels already have many relevant safety standards and best practices implemented through industry association recommendations or through compliance with regulations. In the case of passenger vessels, the complexity in implementing the SMS (and therefore the related costs) will depend on the size and structure of the organization, the number of vessels it operates, and the number of employees engaged on each vessel.  Smaller companies with a fewer number of vessels (less than five) should be able to implement a SMS within a relatively short period of three to five months, especially with external technical assistance or through the expert advice provided by consultants specializing in the industry.  

QMII (www.qmii.com) specializes in maritime work and has over 35 plus years met the objectives of auditing, training and system implementation for maritime companies across the spectrum of domestic, or internationally trading.