Why Safety and Marketing Should Never Share the Same Manual — And What It Says About Your Safety Management

Safety Management Manual is not a branding statement. It exists to support safe operations, pollution prevention, and continual improvement.

In the last decade, the maritime industry has made real progress toward clearer, leaner, and more functional Safety Management Systems (SMS). Yet one persistent problem still appears across fleets of all sizes:

Safety manuals filled with marketing slogans, corporate values, and branding material.

Some companies still publish “Main Manuals” where on the very top of the topics they include things such as:

• Vision & Mission

• Diversity and Inclusion

• “We strive to be the world’s best cruise experience”

• Loyalty, Passion, Respect

• Customer service philosophy

• Corporate branding language

These fancy headlines and statements may look impressive in an office, but to actual operators of the ship, the seafarers, they quickly become a problem.

This blending of safety and marketing signals a total misunderstanding of the ISM Code’s intent, and it can lead to practical, structural, and compliance issues that affect both shore staff and shipboard teams.

Let’s break down why this matters, what risks it creates, and what good practice actually looks like.

The Purpose of the Safety Management Manual (SMM)

The ISM Code is very simple and clear in its expectation: the company must maintain a clear, operational, and effective Safety Management System.

The manual supporting it, the SMM, must be:

• Practical

• Task-focused

• Operational

• Clear and concise

• Used by seafarers

• Aligned with actual shipboard practice

Safety Management Manual exists to support safe operations, pollution prevention, and continual improvement.

“The purpose of the ISM Code is to provide an international standard for the safe management and operation of ships and for pollution prevention.”

What it does not exist for:

• branding

• employee engagement culture

• corporate mission statements

• human resources messaging

• customer-facing values

• passenger experience philosophy

These may be meaningful in a boardroom, but they dilute the functional purpose of the SMM, and franckly, have no place in the SMM.

Why Marketing Content Has No Place in an SMM

When customer satisfaction becomes part of your safety management system, operational judgement gets compromised. Possibly leading to catastrophic results.

When a company mixes marketing language with safety documentation, several problems emerge.

a) It dilutes the purpose of the manual

A safety manual should send one signal, and one signal only:

“This is how we operate safely.”

When the opening chapters are filled with corporate vision statements, the crew receives a different message:

“This is how we keep our customers happy.”

b) It reduces usability

The ISM Code expects documentation to be clear and user-friendly.

If a seafarer must scroll through corporate slogans to find bunkering procedures, the manual has failed its purpose.

c) It indicates a disconnect between office and ship

Marketing and HR departments tend to write in a polished, abstract style. Operational departments expect clarity, task steps, responsibilities, and risk controls. When both worlds are forced into a single document, neither purpose is served well.

d) It complicates document control

Corporate messaging changes frequently. Every update requires reissuing the entire “Main Manual”, creating a needless administrative burden and increasing the risk of outdated operational content.

e) It raises questions about the maturity of the SMS

An auditor seeing slogans like “Passion. Loyalty. Diversity.” at the front of an SMM will wonder:

• Does this company even understand the ISM Code?

• How much of the SMS exists for “paper compliance”?

• Are operational procedures buried under corporate wallpaper?

• Is the SMM written for auditors rather than seafarers?

• In an event of emergency, are you going to follow your "Passion" or "Vision" or are you going to do what is safe and what you should be prepared for?

• If due to safety or due to preventing an environmental pollution, you have to apply practises that might dissapoint your customers, which desicion are you going to make? Are you going to follow your "Excellence in Indulging Customer Satisfaction" or your "Safety And Environmental Policy"?

These questions are serious and they arise for a reason. Perhaps your Passions and Visions are telling you that customer satisfaction requires unsafe practices. If your SMM is encouraging this, in the event of an accident the captain could, and rightly so, argue that he was following the Company Policy.

What Good Practice Looks Like: A Lean, Functional SMS

Effective SMM's guide real operations, from daily tasks to emergency drills. Not your Visions or Missions or customer satisfactions.

Modern high-performing companies follow a very different approach.

They separate documentation into clear categories, each with its own purpose.

Safety Management Manual (SMM) – ISM-focused

• Safety & Environmental Policy

• Roles and responsibilities

• Core operational procedures

• Emergency preparedness

• Reporting & investigation

• Maintenance and documentation control

• Internal audits and continual improvement

• Risk management framework

Only content that directly supports safe operations belongs here.

Corporate / Vision / HR / Marketing Manuals – separate documents

These may include:

• Vision & mission

• Corporate values

• Leadership messages

• Customer service philosophy

• Diversity policy

• Brand and communication guidelines

• Sustainability branding

These documents support the corporate identity, not the SMS.

Why “Bloated” Manuals Are a Red Flag for Auditors

Although PSC will not write a deficiency for “too many pages,” experienced ISM auditors recognize the risk immediately.

A bloated SMM typically leads to:

a) Poor navigability

Procedures get lost under unnecessary content.

b) Reduced implementation

Crew don’t use manuals that feel like corporate brochures.

c) Generic or contradictory procedures

Bloated manuals often indicate a reliance on templates and “compliance theatre.”

d) Gaps between documented and actual practice

If the SMM feels disconnected from reality, the SMS likely is too.

e) Higher likelihood of NCs

Particularly under:

• ISM 6 (Resources and Personnel)

• ISM 7 (Shipboard Operations)

• ISM 11 (Documentation)

• ISM 12 (Company Verification)

Not because of the fluff, but because of the effects the fluff has on the system.

The Movement Toward Leaner, Task-Focused Safety Systems

Industry guidance bodies increasingly push for simplicity and operational focus:

• OCIMF TMSA3

• RightShip RISQ v4

• INTERTANKO Human Element guidance

• IACS recommendations

• Just Culture and Human Factors initiatives

The message is consistent:

Documentation should be clear, concise, and designed for the end-user — the crew.

This means:

• shorter manuals

• task-based instructions

• integrated risk management

• separation of corporate and operational content

• rapid navigability

• precise responsibilities

A modern SMS is a working tool, not a corporate branding document.

What do guidelines and best practice say about SMS documentation?

Flag State and industry guidance is remarkably consistent on this point. Dominica’s ISM circular (CD-MSC 15-04), for example, requires that SMS documents are “user friendly and not so voluminous as to hinder the effectiveness of the SMS”. OCIMF’s TMSA describes an effective SMS as one built on “clear and concise documented procedures” that define roles and responsibilities ashore and afloat. The IMO itself defines the purpose of the ISM Code as setting a standard for the safe management and operation of ships and for pollution prevention, not for corporate branding.

Human-factors work in other high-risk industries goes even further, warning that unnecessary complexity in safety procedures is “the enemy of reduced risk”. Taken together, these sources all point in the same direction: safety documentation should be simple, focused and operational. Furthermore, it should be designed for the crew who must use it, not for marketing purposes.

Conclusion: Safety and Marketing Must Live in Different Worlds

Every company exists to serve their customers. Nevertheless, safety documentation exists to guide action, not to please customers.

Mixing safety and marketing content into one “Main Manual” might look neat at head office, but it sends the wrong signal to the people who actually run the ship.

A strong SMM must be:

• operational

• clear

• functional

• risk-based

• practical

• free of irrelevant content

• trusted by the crew

Everything else belongs in its own manual.

Evidence from broader industrial research confirms that well-implemented Safety Management Systems enhance safety performance, compliance behavior, and employee engagement. Ensuring that safety documentation remains clean, operational, and free from unrelated corporate messaging aligns with the conditions that make an SMS effective.