ISM Code

The company is required to perform internal safety audits to confirm that safety and pollution prevention activities comply with the Safety Management System (SMS). Periodically, the company should evaluate the SMS's effectiveness and, when necessary, review it in accordance with established company procedures.

Both the audits and any resulting corrective actions must be carried out in line with documented procedures. Personnel conducting audits should be independent of the areas being audited, unless this is impractical due to the company's size and nature. The findings from audits and reviews must be communicated to all personnel responsible for the areas involved. Furthermore, the management personnel accountable for these areas should take timely corrective action on any deficiencies identified.

The Safety Management Document forms the backbone of the SMS. Personnel must clearly understand the SMS and how it functions. The SMS must include procedures to fulfill the requirements of the ISM Code, with all activities related to safety and pollution prevention being identified and documented. The company is mandated to provide procedures within the SMS document for key shipboard operations, emergency preparedness, and the maintenance of critical equipment.

Training is a crucial element in implementing the SMS; its success or failure can largely depend on it, even with a well-designed and well-documented system. Regularly conducting emergency drills for all persons onboard is a vital part of this training.

The drills and procedures offer several advantages:

• They improve the safety consciousness and safety management skills of personnel.
• They create greater confidence among shippers.
• They minimize exposure to claims in the event of a major marine disaster.
• They reduce the risk of detention by Port State Control due to better maintenance operations and increased safety consciousness.
• Ultimately, drills and procedures improve overall morale and efficiency.

The company must ensure that the SMS operating onboard the ship contains a clear statement emphasizing the Master's authority. The SMS should establish that the Master possesses overriding authority and responsibility to make decisions concerning safety and pollution prevention, and to request the company's assistance as needed.

While, in practice, such overriding authority might typically be exercised only in critical or emergency situations, the Master is, in fact, free to utilize these powers in other situations as well, if they impact safety and pollution prevention.