The interim Document of Compliance (interim DOC) is issued to a shore-based Company (which has not yet had a full DOC audit) that demonstrates it has an effective Safety Management System in preparation, before the full DOC audit is completed. The key requirements (per ISM Code Section 13 and 14) include:
- The Company submits a plan/application that the SMS will be established and a full DOC audit scheduled; the Company must demonstrate an interim DOC is needed (e.g. to allow ships to be registered and sail) and that the SMS functions will be implemented.
- The Company has a safety policy and has made arrangements to develop and implement the SMS.
- The interim DOC is issued for a period not exceeding 12 months.
- Valid interim DOCs are based on a documented assessment or audit by the Administration/RO that the Company's SMS complies (in function) with the ISM requirements, and that there is a clear plan for, and the assignments of, the responsibilities for the ship and shore (including the DPA) and communication.
- An interim SMC (ship) may be issued similarly for a ship pending the full SMC, on evidence the ship and its SMS are in place, with a plan for the first audit within the period.
- After the interim period, the full DOC (valid 5 years) is issued following a successful verification (audit) of the complete SMS, and interim DOCs can be extended provided the Company shows continued progress and has met the audit.
The clauses to ensure compliance: the Company must implement the safety policy, assign the DPA, establish the reporting and audit procedures, and ensure those in the interim period operate the SMS in function; a full (implementation) verification is required before the full DOC.
Purpose: The management review is a formal, periodic review by senior company management of the effectiveness, suitability and adequacy of the Safety Management System (SMS), performed to ensure it continues to meet the objectives of the ISM Code, to evaluate performance, and to identify improvements. It is a key part of the continual-improvement process.
Frequency: There is no rigid ISM-prescribed interval, but good practice and the ISO 9001/ISM-related expectation is that the management review is conducted at planned intervals, typically annually (at least once a year), and additionally whenever there are significant changes (major organizational changes, accidents, major non-conformities, significant regulatory change, or after a major incident). Many companies hold a management review at least annually and after any major occurrence.
Elements addressed in a management review:
- Results of internal audits and external/statutory audits (including SMC/DOC audits) and the non-conformities found.
- Corrective and preventive actions taken and their effectiveness; the status of non-conformities and incident/near-miss reporting.
- Accident/incident investigation outcomes and lessons learned.
- Progress on safety and environmental objectives/targets, trend analysis and safety performance indicators.
- Resource adequacy (manning, training, spares, maintenance) and fulfilment of the company's safety policy.
- Feedback from ships' staff, DPA reports, and the communications to/from ships.
- Changes in legislation, technology or organisation which affect the SMS, and any changes required to procedures.
- Priorities for improvement and the actions to be implemented, together with their verification.
The output is an action plan to improve the SMS; it demonstrates top management commitment and that the SMS is living/effective, and is verified at the ISM audits.