International Safety Management Code
The International Safety Management (ISM) Code is an international regulatory framework that establishes standards for the safe management and operation of ships, as well as pollution prevention, by requiring shipping companies to implement a structured Safety Management System (SMS).[1] Adopted by the International Maritime Organization (IMO) in 1993 through resolution A.741(18), it became mandatory for certain categories of ships engaged in international voyages on 1 July 1998 as Chapter IX of the International Convention for the Safety of Life at Sea (SOLAS).[1] The ISM Code's primary objectives are to ensure safety at sea, prevent human injury or loss of life, avoid damage to the environment in case of maritime accidents, and prevent loss of ships or property through proactive risk management and continuous improvement.[1] It emphasizes the responsibility of shipowners and operators to foster a culture of safety at all levels, from top management to onboard personnel, by defining clear policies, procedures, and lines of communication.[1] Key functional requirements include the development of safe practices for shipboard operations, maintenance of ship and equipment, defined responsibilities and authorities for key roles (such as the Designated Person Ashore), and mechanisms for reporting and addressing non-conformities, accidents, and hazardous situations.[1] Implementation of the ISM Code involves certification processes administered by flag states and recognized organizations: companies must obtain a Document of Compliance (DOC) verifying compliance of their SMS, while individual ships receive a Safety Management Certificate (SMC) upon audit.[1] The Code has been amended several times to address evolving risks, including updates in 2000 (effective 2002), 2004 (2006), 2005 (2009), 2008 (2010), and 2013 (2015), with later guidelines incorporating elements like cyber risk management and near-miss reporting.[1] These provisions apply broadly to cargo ships over 500 gross tonnage and passenger ships on international routes, promoting global uniformity in maritime safety standards.[1]Overview and Purpose
Definition and Objectives
The International Safety Management (ISM) Code is an international standard adopted by the International Maritime Organization (IMO) for the safe management and operation of ships and for pollution prevention.[2] It establishes a framework requiring shipping companies to develop, implement, and maintain a safety management system (SMS) that integrates safety and environmental protection into all aspects of ship operations.[3] The primary objectives of the ISM Code are to ensure safety at sea, prevent human injury or loss of life, and avoid damage to the environment—in particular, the marine environment—and to property.[3] Additionally, it aims to extend these safety management objectives to shore-based support processes, thereby promoting active involvement from company management in shipboard operations to foster a culture of continuous improvement in safety practices.[3] At its core, the ISM Code is guided by key principles emphasizing top management's commitment to safety, the systematic identification and assessment of risks, and the establishment of appropriate safeguards against those risks.[2] These principles require competence and motivation at all organizational levels to maintain high standards of safety and pollution prevention tailored to varying operational conditions.[2] The ISM Code integrates seamlessly into the broader IMO framework as a mandatory component of the International Convention for the Safety of Life at Sea (SOLAS), specifically Chapter IX, thereby supporting overall maritime safety goals without duplicating other SOLAS regulations on ship construction, equipment, or operational standards.[4]Scope and Applicability
The International Safety Management (ISM) Code, as mandated by Chapter IX of the International Convention for the Safety of Life at Sea (SOLAS), 1974, applies to companies operating specific categories of ships engaged on international voyages, irrespective of the ship's construction date or flag state. These include all passenger ships and high-speed passenger craft, oil tankers, chemical tankers, gas carriers (including high-speed craft), bulk carriers as defined in SOLAS regulation XII/1 (i.e., those with a deadweight of 20,000 tonnes or more), and other cargo high-speed craft of 500 gross tonnage and upwards. The applicability extends to all other cargo ships and mobile offshore drilling units of 500 gross tonnage and upwards constructed on or after 1 July 1998, with the requirement broadening to existing such vessels by 1 July 2002. This framework ensures that safety management practices are standardized for vessels posing significant risks to life, property, and the marine environment during international operations.[5] The Code's requirements target the "Company," defined as the shipowner or any other organization or person—such as a manager or bareboat charterer—who assumes operational responsibility for the ship from the owner, with the owner's consent, and agrees to fulfill all duties and responsibilities under the ISM Code. Companies must develop, implement, and maintain a safety management system (SMS) encompassing policies, procedures, and resources to ensure safe ship operation and pollution prevention, applicable to all covered vessels under their control. This obligation holds regardless of the flag state, promoting accountability across global shipping operations.[5][2] Certain vessels are exempt from the ISM Code to account for their limited risk profiles or specialized uses. Exemptions include cargo ships of less than 500 gross tonnage, ships not propelled by mechanical means, wooden ships of primitive build, pleasure yachts not engaged in trade, fishing vessels, and warships, naval auxiliaries, or other government-operated ships used only on non-commercial service. Flag state administrations may grant additional exemptions for ships not normally engaged on international voyages but required to undertake a single such voyage without refitting, or for ships operating exclusively in sheltered waters or short voyages, provided they comply with equivalent safety standards determined by the administration.[5][6] The ISM Code's global enforcement is underpinned by SOLAS ratification, with 168 contracting states as of 2024, representing approximately 98.63% of the world's merchant shipping gross tonnage—a figure that ensures coverage of nearly all international maritime trade. Port state control authorities worldwide verify compliance through inspections, with powers to detain non-conforming ships until deficiencies are rectified, reinforcing uniform application across jurisdictions.[7]Historical Development
Background and Key Incidents
In the 1980s, a series of maritime incidents exposed systemic failures in ship management and oversight, underscoring the need for enhanced safety protocols beyond traditional ship-specific regulations.[8] One pivotal event was the capsizing of the roll-on/roll-off ferry Herald of Free Enterprise on March 6, 1987, shortly after departing Zeebrugge, Belgium. The vessel listed severely due to open bow doors, which allowed water to flood the car deck, resulting in 193 deaths among the 539 passengers and crew aboard.[9] Investigations revealed shore-side management negligence, including the absence of clear procedures for door closure confirmation and pressure to expedite departures at the expense of safety checks.[10] Other notable disasters further highlighted procedural and company-level shortcomings. The 1989 grounding of the Exxon Valdez oil tanker off Alaska's coast spilled approximately 11 million gallons of crude oil, attributed to navigational errors compounded by inadequate company procedures for fatigue management and voyage planning.[11] Similarly, the 1991 sinking of the Egyptian ferry Salem Express in the Red Sea, after striking a coral reef during a storm, claimed over 460 lives due to procedural lapses in navigation and emergency response under adverse weather conditions.[12] These events collectively demonstrated how management oversights, rather than isolated technical faults, contributed to catastrophic outcomes. The formal inquiry into the Herald disaster, known as the Sheen Report, played a crucial role in shaping responses to these failures. Released in 1987 by the UK Department of Transport, it criticized the ferry operator's lack of a safety culture, pointing to disorganized shore management, ignored crew reports on hazards, and the absence of accountability from the board level downward.[13] The report recommended establishing international standards to enforce company responsibility for safe operations, influencing subsequent IMO guidelines on management practices.[8] These incidents marked a paradigm shift in maritime regulation, transitioning from reactive measures focused on individual vessels to proactive, company-wide safety management systems that prioritize prevention and cultural change.[10] This evolution addressed the root causes of negligence identified across multiple disasters, laying the groundwork for formalized international requirements.[9]Adoption and Entry into Force
The development of the International Safety Management (ISM) Code was initiated in response to major maritime incidents in the late 1980s, particularly those highlighting deficiencies in ship management practices. Following investigations into accidents such as the capsizing of the Herald of Free Enterprise in 1987, the International Maritime Organization (IMO) directed the Maritime Safety Committee to develop guidelines for the management of safe operations on roll-on/roll-off passenger ships and for pollution prevention. Over the subsequent years, the Maritime Safety Committee drafted and refined the code with contributions from industry experts, including Captain Graham Botterill, who served as a specialist advisor on ship safety matters during consultations in the early 1990s.[14][15][16] The ISM Code was formally adopted by the IMO Assembly on November 4, 1993, as resolution A.741(18), titled "International Management Code for the Safe Operation of Ships and for Pollution Prevention." This resolution built upon earlier guidelines, including those from resolutions A.647(16) in 1989 and A.680(17) in 1991, which had progressively outlined management principles for safe shipping operations.[14][17] The adoption represented a consensus among IMO member states to establish a comprehensive framework for safety management systems (SMS) applicable to shipowners and operators. To integrate the code into binding international law, the IMO amended the International Convention for the Safety of Life at Sea (SOLAS) in 1994 by adding Chapter IX, which made compliance with the ISM Code mandatory.[14][17] The amended SOLAS provisions entered into force on July 1, 1998, after ratification by sufficient IMO member states representing the required gross tonnage threshold. Initial application targeted passenger ships of 500 gross tonnage and above, as well as international oil tankers, chemical tankers, gas carriers, bulk carriers, and high-speed craft, requiring these vessels to hold ISM certification. A phased approach extended the requirements to all other cargo ships of 500 gross tonnage and above engaged on international voyages by July 1, 2002, allowing time for global implementation and certification infrastructure to develop. This staggered rollout facilitated widespread adoption across the maritime sector.[14][17][18] The entry into force of the ISM Code through SOLAS solidified its status as a foundational element of international maritime safety regulation, with key flag states such as the United States, United Kingdom, and Japan among the early ratifiers ensuring broad compliance. By mandating SMS implementation, it shifted focus from reactive measures to proactive risk management, influencing over 100,000 vessels worldwide and reducing accident rates attributable to human and organizational factors in the years following 1998. This integration into SOLAS, ratified by more than 150 IMO member states by the early 2000s, established the code as a globally enforceable standard under the auspices of the United Nations specialized agency for shipping.[14][19][15]Key Components
Safety Management System Elements
The Safety Management System (SMS) under the International Safety Management (ISM) Code is defined as a structured and documented system that enables company personnel to effectively implement the company's safety and environmental protection policy.[3] This system provides a framework for managing risks associated with ship operations, ensuring compliance with international standards for safe navigation, pollution prevention, and overall maritime safety.[2] The ISM Code's Part A outlines key components in 12 sections that form the foundation of an effective SMS, based on the functional requirements in section 1.4, each addressing specific aspects of safety management. These components begin with a clear safety and environmental protection policy established by top management, which sets the company's commitment to continuous improvement in safety practices and pollution prevention.[3] Defined levels of authority and communication between shore-based and shipboard personnel ensure seamless coordination, while procedures for reporting non-conformities, accidents, and hazardous occurrences promote proactive hazard identification and resolution.[3] Maintenance programs for ships and equipment are required to prevent breakdowns that could lead to safety incidents, and emergency preparedness procedures outline responses to crises such as fires, collisions, or man-overboard situations.[3] Additionally, the system mandates documentation procedures for all operational aspects, along with mechanisms for data analysis to evaluate performance and drive improvements.[3] A key role within the SMS is the Designated Person Ashore (DPA), who serves as the primary interface between the company and its ships. The DPA is responsible for monitoring the implementation of the SMS, ensuring adequate resources and shore-based support are provided, and reporting directly to the highest level of management on safety and pollution prevention matters.[3] This position underscores the company's accountability in bridging onshore oversight with onboard operations. The integration of human factors is central to the SMS, recognizing that safety outcomes depend on the commitment, competence, attitudes, and motivation of individuals at all levels.[3] Companies must ensure crew members are qualified, certificated, and medically fit, with procedures in place to identify and provide necessary training to support the SMS.[3] This emphasis fosters a strong safety culture, where ongoing education and motivation enhance crew performance and reduce human-error-related risks in maritime operations.[2]Functional Requirements
The functional requirements of the International Safety Management (ISM) Code outline the essential operational outcomes that a company's safety management system (SMS) must achieve to ensure safe ship operations and environmental protection. These requirements, detailed in section 1.4 of the Code, are:- A safety and environmental-protection policy.
- Instructions and procedures for safe operation of ships and protection of the environment.
- Defined levels of authority and communication between shore and shipboard personnel.
- Procedures for reporting accidents and non-conformities.
- Procedures to prepare for and respond to emergency situations.
- Procedures for internal audits and management reviews.[3]