IMO study on the effective implementation of the ISM Code

The report sets out 6 recommendations based on the study’s findings and the supporting literature.

#1: The IMO should consider improving the implementation of the ISM Code, in order to ensure consistency in the uniform application and interpretation of mandatory provisions, as well as compliance and enforcement by Administrations and/or companies.

#2: The IMO should consider reviewing the port State control guidelines in relation to the ISM Code, in order to ensure that the provisions of the ISM Code are implemented consistently on all ships

#3: IMO should consider reviewing elements of the ISM Code. Among other things it is stated that “…strengthening section 5 on master’s responsibility and authority, in order to ensure that the master is afforded the right protection and to allow the master to escalate ISM related relevant breaches directly to the flag or port States”

#4: IMO should consider initiating a holistic review of its instruments dealing with resources and personnel

#5: IMO should consider effective measures to promote the development of training guidance for non-technical skills to optimize the human contributions to organizational safety. This should specifically address human factors competency designed for shipping, and training should initially focus on risk assessment, decision making, incident analysis (including root cause analyses), open reporting, communication, handling non-conformities, task management and fatigue. (Fatigue is mentioned 52 times in the report)

#6: IMO should consider enhancing capacity building on the effective implementation of the ISM Code and its related instruments

Trends in incident data: The effectiveness of the ISM Code is a matter of significant interest that has attracted considerable attention in recent years. Since the introduction of the Code, safety levels in the maritime industry have generally improved.

While ship losses have declined over the years, the number of reported serious shipping casualties has gradually increased over the last 10 years (2,773 in 2014 compared with 2,951 in 2023, a rise of 6%).

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During the same period ISM-related deficiencies there was an overall decrease in the number of inspections with ISM-related deficiencies, from 2,329 (in 2013) to 1,190 (in 2023) (based on Tokyo MoU data)

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Based on input gathered from seafarers: "Safety Management systems have become unwieldy. They should be simple instructions that can be followed. Forms and records should support a seafarer in safely operating ships, not a mechanism for blame, personal liability or corporate protection. How can a 29-page familiarisation form support a seafarer?!"

All stakeholder groups mentioned that the SMS increased paperwork, and most commented that it created a checklist/compliance-driven approach to safety management. In addition, interviewees indicated that procedures often did not correspond to the actual work being done…

Additionally, as it is mentioned in the report “…the analysis of accident reports done for this study shows that, in some cases, the implementation of the ISM is handled as a tick-box exercise. Additionally, 17% of these accident reports identified a lack of written procedures, and 94% of them noted that the ISM and/or SMS was not complete or fully implemented…”

The outcome of any survey is strictly correlated with the validity and reliability of the data used. In this particular case, the focus regarding the PSC inspections was on the TOKYO MoU. If someone wants to make a comparison among authorities (countries) / members of the said MoU, for the period from 01.01.2023 to 22.10.2024 would retrieve the figures shown in the following three tables. Among other things, the data from the TOKYO MoU database show that, following a PSC inspection, the detention rate in Australia was 39 times higher than the respective figure in Vietnam...