What a Modern Safety & Environmental Policy Should Look Like in 2025

A well-written Safety and Environmental Policy is often described as “the first page of the SMS.” In reality, it is much more than that. It sets the tone for the entire organisation, shapes how decisions are made. Furthermore, it communicates to auditors, and to your own people, what kind of company you actually are.

When this policy is vague or outdated, the rest of the SMS tends to fail it's purpose. When it is strong, clear and supported in practice, it forms the backbone of a healthy safety culture.

This post breaks down what an effective policy looks like in 2025, what auditors really expect to see, and how new industry trends are reshaping the expectations placed upon companies today.

1. What the ISM Code Really Expects — In Simple Terms

The ISM Code requires every company to have a documented Safety and Environmental Protection Policy that:

• States how the company will protect people, ships and the marine environment.

• Applies at all levels — shore and ship.

• Is implemented, not just published.

This means the policy is not a ceremonial poster; it is the top-level commitment that every subsequent SMS element must support.

A strong policy usually expresses commitments such as:

• Safe operation of ships.

• Pollution prevention and responsible environmental performance.

• Full compliance with mandatory rules and regulations.

• Continuous improvement through reporting, learning and corrective actions.

• Clear support for the Master’s overriding authority.

If these core ideas are missing or watered down with soft words (“try,” “aim,” “endeavour”), the policy loses its authority.

2. What a Good Safety and Environmental Policy Actually Looks Like

The best Safety and Environmental Policies share several practical characteristics:

Clear, direct commitments

Strong companies use language that leaves no ambiguity about intention. For example:

• “The Company shall ensure safe operations…”

• “The Company is committed to preventing pollution…”

This signals to auditors, and to your own crews, that management takes responsibility seriously.

Alignment with the company’s real operations

Generic policies copied from templates no longer pass the credibility test. The policy should reflect the genuine risk profile of your trades, cargoes and vessel types.

For example:

• Ro-Ro operations → stability, cargo securing, fire risks.

• Chemical tankers → cargo handling, spill prevention, specialised training.

• Passenger ships → human factors, emergency management.

If your policy does not echo your operational risks, auditors will immediately question the SMS beneath it.

Defines responsibilities and authority

The policy should clearly connect to:

• Senior management responsibility.

• The DPA’s monitoring role.

• The Master’s overriding authority.

This reminds everyone that the policy is not “owned” by the safety department. Instead, it is owned by top management.

Linked to measurable objectives

Objectives such as reduced LTIF, near-miss reporting levels, spill prevention, or emissions-reduction targets give the policy weight and allow the company to track progress.

3. What Auditors Will Definitely Check

When a DOC or SMC audit takes place, auditors typically start with the policy since it’s a quick way to see whether the company’s SMS is alive or just paperwork.

Here is what every auditor will always verify:

1. Existence and validity

• Is the policy documented, signed and dated by top management?

• Is it up-to-date?

• Is the policy visible on board and ashore?

Old or unsigned policies lead to findings within minutes.

2. Crew awareness

Auditors will interview seafarers and ask:

“Can you explain your company’s Safety and Environmental Policy?”

If key personnel cannot answer in their own words, it is usually an immediate non-conformity.

3. Practical implementation

Auditors will trace statements from the policy into:

• Relevant procedures.

• Risk assessments.

• Training and drills.

• Records of monitoring, audits and corrective actions.

If the policy commits to pollution prevention, they will look at bilge, bunkering, waste, sewage, SOx/NOx, ballast and spill-response processes.

If the policy commits to continuous improvement, auditors will expect to see investigations, lessons learned and management review minutes.

4. Top management involvement

A policy is only credible if:

• Management reviews it periodically.

• Changes in operations or regulations lead to updates.

• Safety and environment are visibly supported from the top.

Many DOC findings each year stem from policy documents that have not been reviewed for years despite major operational changes.

4. What Research Tells Us About Effective Policies

Recent studies across shipping and other high-risk sectors consistently show the same pattern:

• Safety behaviour improves when officers feel the company’s values genuinely support safety. Not just in documentation but in decisions and conversations.

• SMS effectiveness increases when leadership, communication and organisational culture are strong, not just when paperwork is in order.

• Involving seafarers in the creation and review of SMS elements leads to higher ownership and fewer “paper-only” procedures.

In short: a good policy only works if your people see that you mean it.

5. How Policies Are Evolving in 2025 — Trends to Consider

The expectations for Safety and Environmental Policies are shifting. Companies with forward-looking SMS structures already reflect these themes:

1. Integration with ESG

Many owners now connect safety and environment with broader sustainability commitments. This can include:

• Decarbonisation strategy and emission targets.

• Reporting transparency.

• Social and governance commitments.

This is no longer unusual. Many charterers increasingly expect it.

2. Decarbonisation and climate action

With IMO tightening its GHG strategy, many policies now reference:

• Energy efficiency.

• Fuel management.

• Carbon intensity goals.

• Safe use of alternative fuels.

This shows alignment with global regulatory trends.

3. Crew wellbeing and human factors

Modern policies sometimes include:

• Fatigue management.

• Mental health considerations.

• Diversity and fair treatment.

These are not ISM requirements, but they are rapidly becoming best practice.

4. Cyber safety as part of operational safety

With IMO cyber risk guidelines now embedded in SMS structures, some companies extend the policy to state commitments related to:

• Protecting critical systems and data.

• Treating cyber incidents as safety events.

5. Contractor and supply-chain expectations

Leading companies increasingly require contractors to uphold comparable HSE standards. Including this in the policy signals maturity and aligns with ESG and client expectations.

6. A Simple Test: Would Your Policy Pass These Questions?

Ask yourself:

• Does it clearly express our real commitments, or is it just a poster?

• Does the wording reflect our actual operational risks?

• Can every senior officer explain the policy in their own words?

• Can we show how each statement is implemented in practice?

• Has management reviewed it recently and meaningfully?

• Does it reflect today’s regulatory and industry landscape, not that of a decade ago?

If any answer is “no,” there is room to strengthen the policy and align it with modern expectations.

Closing Thought

A Safety and Environmental Policy is not simply the first chapter of your SMS.

It is the document that tells your crews, auditors and clients who you are and what you stand for.

When done well, backed by real implementation, clear leadership and continuous improvement, it becomes one of the most powerful tools a company has for building a safe, efficient and reputable operation.