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The ISM Code and the DOC holder
The registered owner of a ship is usually a company with one asset, no staff and no telephone. With that arrangement, nobody could say who was really responsible for how the ship was run. So the ISM Code requires one named company to accept that responsibility in writing and to be audited on it. The name of that company is the most useful single fact about a ship that is not in its particulars.
What the code is
IMO adopted the International Safety Management Code in 1993, by resolution A.741(18). It became mandatory through SOLAS chapter IX and came into force on 1 July 1998. It requires the company that operates a ship to set up, write down and keep a safety management system: a set of written procedures covering how the ship is operated, maintained and crewed, how emergencies are handled, how non-conformities (failures to follow the system) are reported, and how the whole system is reviewed.
The code does not require any engine, fitting or piece of equipment. It is about management, and it starts from the idea that most accidents come from failures in the organisation rather than from a part breaking. For the same reason, it is easy to meet on paper and hard to meet in practice. That is why a good auditor does not ask “do you have a procedure?” A good auditor asks “show me the last time you followed it.”
The company, and why it is not the owner
The code defines “the Company” as the owner, or any other organisation, such as a manager or a bareboat charterer, that has taken responsibility for operating the ship and has agreed to take on the duties the code sets. The definition is wide on purpose. In practice it means the technical manager: the company that employs or hires the crew, plans the maintenance, deals with class and the flag, and answers when something goes wrong.
So a ship usually has two different companies: a registered owner, which is a single-ship company that exists for financing and liability reasons, and a technical manager, which actually runs the ship. A third company, the commercial manager, trades the ship, and that is the one a broker writes to. These roles are explained in who owns a ship. The ISM Code is the reason we can know the second one at all: the technical manager must hold a certificate with its name on it.
Two certificates, and what each one covers
The system produces two documents, and they work at different levels.
| Certificate | Held by | Says | Term |
|---|---|---|---|
| Document of Compliance | The company | This company’s safety management system has been audited and is suitable for these ship types | Up to five years, checked every year |
| Safety Management Certificate | The ship | This ship is run under that company’s audited system | Up to five years, with an intermediate verification (one check during that term) |
| Interim DOC | A new company, or an existing one adding a new ship type | A temporary version while the system is being tested in practice | Up to twelve months |
| Interim SMC | A ship that is newly delivered, has changed flag or has just been taken over by a company | The same, at ship level | Short term |
A copy of the DOC must be kept on board. The key point is that the certificate is specific to a ship type: a DOC valid for bulk carriers does not cover a chemical tanker, and a manager that takes on a type it has never run must be audited for that type. This limits which ships a manager can take on. Remember it before you assume that a manager can take over a ship it has just been offered.
The second point is what a change of manager does. The ship moves from one company’s system to another’s, so its old SMC is no longer the right document and an interim one is issued while the new manager’s system is applied to the ship. The change is visible in the papers, and it marks the date from which a different company is running the ship.
The designated person ashore
The code requires the company to appoint one or more designated persons ashore with direct access to the highest level of management. Their job is to watch the safety and pollution prevention side of each ship, and to make sure the ship gets the resources it needs.
The direct access is the main purpose of the role. It gives the master (the captain) a route to the top of the company that does not go through the commercial department. This matters most when the commercial department wants the ship to sail and the master does not. The code also states clearly that the master has overriding authority to take any action he judges necessary for safety and pollution prevention, and to ask the company for help. When a master refuses to berth in bad weather, or refuses a cargo he does not trust, he is using that authority, and no charterparty term overrides it.
Why the DOC holder is a commercial signal
Port state control (inspection of foreign ships in a country’s ports) gives every ship a risk profile that decides how often and how closely the ship is inspected. One input is the record of the company that holds the DOC, across its whole fleet, so a manager with a poor record brings that record into the profile of every ship it takes over. A ship can be selected for inspection for reasons that have nothing to do with its own condition.
This also works the other way, and that is what makes it useful. When you read a ship’s inspection history, ask who was managing the ship at the time of an old detention. A finding under a manager that no longer holds the DOC describes a company that no longer runs the ship. Only the record since the last change of manager helps you predict how the ship will perform.
The type of deficiency that matters most is an ISM deficiency. A fire door that does not close is a fault, but an ISM finding means the inspector is saying the system that should have noticed the fire door did not notice it. If an ISM finding comes back after it was closed, the system is not correcting itself. That points to a poor maintenance culture rather than a one-off accident, and it is the one pattern in a public record that reliably predicts the next problem.
What it is not
The ISM Code is not a quality standard for the ship. It is not class, and it is not a promise to a charterer. A ship with valid ISM certificates can still be in poor condition, because the certificate says a company’s system was audited, not that a hull is sound. It also does not replace the vetting (inspection and approval) schemes that the big oil and dry bulk companies run, which inspect the ship itself and ask harder questions than an audit does. What ISM gives a commercial desk is a name: the one company that has accepted, in writing and on a certificate, that it is responsible for how the ship is run.
References
- IMO, ISM Code and Guidelines on Implementation of the ISM Code. imo.org
- IMO, International Convention for the Safety of Life at Sea (SOLAS), 1974, chapter IX. imo.org
- IMO, International Management Code for the Safe Operation of Ships and for Pollution Prevention, resolution A.741(18), 1993.
- Paris MoU, Ship risk profile and company performance. parismou.org
Related
Neptune Atlas
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