ISM Code - An external auditor's view

In Issue 143 of The Superyacht Report, Peter Southgate of The Cayman Islands Registry explains how correct implementation of the ISM Code can prove to be an effective tool, and is much more than an administrative bureaucratic formality. We provide you with a small excerpt of his advice.



The implementation of the International Safety Management (ISM) Code has definitely brought significant benefits and has contributed to the safety culture on board vessels; however, there are still some that regard the ISM Code as unnecessary bureaucracy. As a consequence, the degree of ISM implementation varies tremendously from operator to operator. It should be remembered that ISM is about promoting a culture of safe practices and environmental responsibility and should not be simply regarded as slavishly following procedures that do not actually contribute to these objectives.

THE SAFETY MANAGEMENT SYSTEM (SMS)

It is recognised that yacht management, both under and over 500gt, is handled in numerous ways, but this need not be a barrier to effective implementation of ISM principles. For example, we encounter many different instances where a particular ISM company is not responsible for technical management or for the recruitment of officers. While the company holding the Document of Compliance (DOC) may not necessarily have the authority for these matters, they still retain responsibility for these elements and ultimately it is their name on the DOC under their ISM 3.1 appointment. On the whole this is recognised, but there are some occasions where gaps may be identified during audits and these gaps must be plugged to ensure effective implementation.

Another common issue concerns the SMS whereby the system will contain certain procedures that are generic across the fleet or may be simply impossible to comply with and, when this occurs, it is inevitable that things will go wrong. If a procedure makes you take inappropriate steps, human nature will dictate that short-cuts will be taken and the omission of these steps can lead to non-conformities and possibly accidents. Countless non- conformities have been raised due to a procedure that is impracticable or unworkable and it is vitally important that the SMS is under continual review to eliminate the steps that are not appropriate.

RISK ASSESSMENTS

Lack of attention to risk assessments is another common observation found during ISM audits, which is of great concern, as failure to identify and mitigate risks is probably the single most cause of accidents and incidents aboard ships.

Many regard risk assessment as an administrative formality, but it has been shown time and time again that effective identification of hazards and implementation of mitigation measures are vital. Moreover, it is often easy to spot the dangers when you are conducting hazardous activities, for example mooring or working aloft. But sometimes even the most routine activities that have been carried out hundreds of times can throw up unexpected hazards and these routine processes should never be ignored.

CORRECTIVE ACTION FOLLOW-UP

Another aspect worthy of note is attention to corrective action follow- up. Clearly, if you go to the trouble of identifying issues, then it is imperative that you follow up on them. Aside from being ‘audit fodder’ for external auditors, the failure to follow up on non-conformities and other issues can lead to more serious breakdown further down the line.

To subscribe to The Superyacht Report, please click here.

---

Click here to become part of The Superyacht Group community, and join us in our mission to make this industry accessible to all, and prosperous for the long-term. We are offering access to the superyacht industry’s most comprehensive and longstanding archive of business-critical information, as well as a comprehensive, real-time superyacht fleet database, for just £10 per month, because we are One Industry with One Mission. Sign up here.