Implementation of ISM

(Sea Venture Volume 20)

On 1^st July 2002 the International Management Code for the Safe Operation of Ships and for Pollution Prevention (the ISM Code) must be implemented on all cargo ships and mobile off-shore drilling units of 500GT and above¹. The purpose of this article is to remind Members that time is slipping away and the countdown for all vessels to comply with the ISM Code ends on 1^st July 2002.

Much has been written about the ISM Code and this article is not intended to explore the workings of the system but to remind Members of Club Rule 23 (v) which states that it is a condition of cover that members comply with statutory requirements. On 1^st July 2002 compliance with the ISM Code will be a statutory requirement for all ships and rigs over 500GT.

The ISM Code requires every company to be issued with a Document of Compliance (DOC) to show that it complies with the requirements of the ISM Code. The DOC is issued for a period of 5 years, is subject to annual verification audit and a copy of the certificate must be carried on board each ship. The ISM Code also requires every ship to be issued with a Safety Management Certificate which verifies that the operating company and the shipboard management operation are in accordance with the approved safety management system. It should be remembered that the existence of ISM certification does not mean that the Code has been implemented.

Implementation of the safety management system takes time. For those Members that do not yet have an ISM system on their cargo ships urgent action is required - July 2002 is not far off. Between now and July they must develop, implement and maintain a safety management system which will include the following:

1.               A safety environmental protection policy

2.               Instructions and procedures for safe operation and environmental protection

3.               Procedures for responding to emergencies and for reporting accidents

4.               Clearly defined levels of authority for those ashore and afloat

5.               Procedures for communications, internal audits and management reviews

6.               An audit trail that can demonstrate that the system is operational and that the operating company and its servants are actively involved in, and understand, the system and its procedures.

After the policies, procedures and instructions are installed, an internal audit of the Shipping Office and all the individual Ships will be necessary to prove that the system is working. Only after the internal audits have been completed will the flag state, or the flag state representative, make external audits and, if satisfied, issue certification. Members will then probably require a further two or three months in which to ensure that the system that they have implemented on their ships is actually working. However, it must be said that without the total commitment and determination of the most senior managers the system will fail.

After 1^st July 2002 it will not be sufficient merely to produce certification to Port State; it will also be necessary to prove that the system is implemented, that the Master and his Officers understand the procedures and that an audit trail is in place.

¹ These represent the last category of vessels required to implement the ISM Code.