Neptune Atlas
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. The ISM Code exists because that arrangement made it impossible to say who was actually responsible for how a ship was run, so the convention now requires a named company to take that responsibility in writing and be audited on it. That company is the most informative single fact about a hull that is not on her particulars.
What the code is
The International Safety Management Code was adopted in 1993 by IMO resolution A.741(18) and made mandatory through SOLAS chapter IX, entering into force on 1 July 1998. It requires the company operating a ship to establish, document and maintain a safety management system: written procedures for how the ship is operated, maintained and crewed, how emergencies are handled, how non-conformities are reported and how the whole thing is reviewed.
Nothing in it prescribes an engine, a fitting or a piece of equipment. It is a code about management, and its premise is that most casualties come from organisational failure rather than from a component breaking. That premise is also why it is easy to satisfy on paper and hard to satisfy in fact, and why an auditor’s useful question is never “do you have a procedure” but “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 assumed responsibility for operating the ship and has agreed to take over the duties the code imposes. That definition is deliberately wide, and in practice it lands on the technical manager: the company that employs or contracts the crew, plans the maintenance, deals with class and the flag, and answers when something goes wrong.
So a hull typically has a registered owner that is a single-ship company existing for financing and liability reasons, and a separate technical manager that actually runs her. A third company, the commercial manager, trades her, and that is the one a broker writes to. Those roles are set out in who owns a ship, and the ISM Code is the reason the second one is knowable at all: the technical manager has to hold a certificate with its name on it.
Two certificates, and what each one covers
The system produces two documents and they operate at different levels.
| Certificate | Held by | Says | Term |
|---|---|---|---|
| Document of Compliance | The company | This company’s safety management system has been audited and is fit for these ship types | Up to five years, with annual verification |
| Safety Management Certificate | The ship | This ship is operated under that company’s audited system | Up to five years, with an intermediate verification |
| Interim DOC | A new company, or an existing one adding a new ship type | A temporary version while the system is proved | Up to twelve months |
| Interim SMC | A ship newly delivered, reflagged or newly taken over by a company | The same, at ship level | Short term |
A copy of the DOC has to be carried on board. The important consequence is that the certificate is ship-type specific: a DOC valid for bulk carriers does not cover a chemical tanker, and a manager taking on a type it has never held has to be audited for it. That is a real constraint on which fleets a manager can pick up, and it is worth remembering before assuming a manager can absorb a hull it has just been offered.
The second consequence is what a change of manager does. The ship moves from one company’s system to another’s, so her existing SMC ceases to be the right document and an interim one is issued while the new manager’s system is applied to her. That transition is visible in the paperwork and it dates the moment the ship’s record starts describing a different operation.
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, whose job is to monitor the safety and pollution prevention aspects of each ship and to make sure resources are provided.
The point of the role is the direct access. It gives the master a route to the top of the company that does not pass through the commercial department, which matters on exactly the occasions when the commercial department wants the ship to sail and the master does not. The code also states plainly that the master has overriding authority to take whatever action he judges necessary for safety and pollution prevention, and to request the company’s assistance. When a master refuses to berth in weather, or refuses a cargo he does not trust, that authority is what he is exercising, and no charterparty term overrides it.
Why the DOC holder is a commercial signal
Port state control regimes score every hull into a risk profile that decides how often and how hard she is inspected. One of the inputs is the performance of the company holding the DOC, across its whole fleet. So a manager with a poor record imports that record into the profile of every ship it takes over, and a hull can find herself targeted for reasons that have nothing to do with her own condition.
That runs in the other direction as well, which is what makes it useful. When you are reading a hull’s inspection history, the question to ask of an old detention is who was managing her at the time. A finding under a manager who no longer holds the DOC describes a company that is no longer running her. The record since the last change of manager is the part that predicts anything.
The deficiency category that carries the most weight is ISM itself. A fire door that does not close is a fault. An ISM finding is an inspector saying the system that was supposed to notice the fire door did not notice it, and an ISM finding that recurs after being closed out says the system is not correcting itself. That is a maintenance culture rather than an accident, and it is the one pattern in a public record that reliably predicts the next one.
What it is not
The ISM Code is not a quality standard for the ship, it is not class, and it is not a warranty to a charterer. A ship with valid ISM certification can still be in poor condition, because the certificate says a company’s system was audited rather than that a hull is sound. It is also not a substitute for the vetting regimes the oil and dry bulk majors run, which inspect the ship herself 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
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