Understanding the ISM Code: What Shipowners Often Miss

Markus Luostarinen
3 hours ago
5 min read

Sunset on a navigational bridge. — *ISM Code was designed to build and preserve a culture of safety and accountability.*

Introduction

More than three decades after its introduction, the International Safety Management (ISM) Code remains one of the most misunderstood cornerstones of maritime safety.

Too often it’s seen as a bureaucratic exercise, yet the real purpose of the ISM Code is much more practical. It was designed to build and preserve a culture of safety and accountability.

In this article, we’ll look beyond the paperwork to understand what the ISM Code truly demands, and highlight the most common mistakes that shipowners and operators continue to make.

Understanding What the ISM Code Actually Is (and What It Isn’t)

The ISM Code was born out of tragedy. Following the 1987 Herald of Free Enterprise disaster, it became clear that human error and weak safety management were recurring causes of maritime accidents. The IMO (International Maritime Organization) responded with the ISM Code, a framework to ensure that every shipping company establishes a structured, auditable system for safe operation and environmental protection.

But the ISM Code wasn't designed to be mere checklist. It doesn’t exist to generate paperwork or satisfy flag-state inspectors. Its purpose is to embed safety management into the company’s daily operations. It's designed as a proactive system where procedures, reporting, training, and improvement form a continuous loop.

In other words, ISM is about behavior, not about paperwork.

Shipwreck on a beach. — *The purpose of the ISM Code is to be a proactive system where procedures, reporting, training, and improvement form a continuous loop to develop, promote and preserve a safety culture.*

The Core Elements of the ISM Code

At its heart, the ISM Code revolves around twelve key elements:

Safety and environmental protection policy
Company responsibilities and authority
Designated Person Ashore (DPA)
Master’s responsibility and authority
Resources and personnel
Development of plans for shipboard operations
Emergency preparedness
Reporting and analysis of non-conformities and accidents
Maintenance of the ship and equipment
Documentation control
Company verification, review, and evaluation

Together, these form an integrated safety management system (SMS).

Yet many companies treat them as isolated topics, rather than as parts of a unified process that should guide every operational decision from cargo loading to crew training.

Where Shipowners Often Go Wrong

1. Treating the ISM Manual as a Static Document

Many companies still keep their SMS in a printed folder that hasn’t been updated in years. Procedures evolve, technology changes, and yet the manual remains frozen in time.

A static system cannot support dynamic operations. In the heart of the ISM is the thought of continuous improvement, meaning procedures must evolve with lessons learned and with changes in operations.

2. Weak Link Between Ship and Shore

ISM demands a clear connection between onboard management and shore-based decision-makers. In practice, this link is often weak. Masters and engineers report issues that never reach upper management, or shore management issues instructions that don’t reflect operational realities.

The result is frustration on both sides, leading to ever-widening gap that undermines safety.

3. Audits Done for the Wrong Reasons

Internal audits are one of the most powerful tools in the ISM framework, yet they’re often treated as a formality before external verification.

A good internal audit should challenge assumptions, identify systemic weaknesses, and trigger improvement. It’s not about passing, it’s about learning.

Life Saving Appliances on a railing. — *In the heart of the ISM is the thought of continuous improvement, meaning procedures must evolve with lessons learned and with changes in operations.*

4. Fear-Based Reporting Culture

A healthy SMS relies on honest reporting of near misses and non-conformities.

But in many companies, seafarers still hesitate to report problems for fear of blame or punishment. This kills transparency and hides the key information that management needs to prevent accidents.

Building a no-blame culture takes effort, but it’s the foundation of real compliance.

5. Inadequate Training and Familiarization

The ISM Code is only as strong as the people implementing it.

Too often, crew members are told what to do without understanding why.

True compliance requires familiarization, drills, and real engagement, not just signatures on a training form.

6. Missing Evidence of Continual Improvement

Every audit and every report should feed into improvement.

Yet many companies have no measurable proof of learning from their past deficiencies. No trend analysis, no root-cause tracking, no “closing the loop”. Without that, the system stagnates, eventually failing it's purpose.

The Real Cost of Getting ISM Wrong

ISM non-compliance rarely stays hidden for long.

From incomplete procedures to poor maintenance records, Port State Control inspections often reveal safety management failures as part of detentions.

In 2023 alone, thousands of deficiencies recorded by Tokyo and Paris MoU's were related to safety management, fire safety, and operational readiness.

The costs goes beyond fines. Poor ISM implementation can lead to:

PSC detentions and costly delays
Higher insurance premiums or coverage issues
Loss of credibility with charterers
Increased accident and injury risk
Reputational damage that’s hard to repair

A weak SMS affects not just compliance. It impacts shipowners commercial performance and trust.

Life Boat hanging on a davit safely tightened to a ship. — *Deficiencies in ISM are among the most common ones causing detentions during PSC audits, leading to costs reaching far beyond just fines for a shipping company.*

How to Strengthen Your ISM Compliance

Bringing your ISM system to life doesn’t always require a major overhaul.

It starts with understanding where you stand and taking consistent, targeted action.

Here’s how successful operators stay ahead:

Conduct Independent Internal Audits
Bring in an external eye to identify blind spots and evaluate your SMS objectively.
Hold Management Reviews That Drive Change
Instead of just ticking the boxes, use the findings to make strategic decisions.
Promote an Open Reporting Culture
Encourage transparency by removing blame and rewarding proactive reporting.
Digitize and Simplify Your SMS
Move beyond paper. A digital system improves accessibility, tracking, and updates across ship and shore.
Invest in Training and Engagement
Make sure every officer and crew member understands the why behind procedures.
Benchmark with Professional Consultants
External consultants can help you align with best practices, prepare for audits, and avoid common pitfalls before they become findings.

Conclusion

The ISM Code was never meant to burden shipowners. It was meant to protect them instead.

When implemented as intended, it creates safer ships, stronger crews, and more reliable operations. Those who see it as an opportunity rather than an obligation gain not only compliance, but also efficiency, reputation, and trust.

At Ilmarine Maritime Surveys & Consultancy, we help shipowners bridge the gap between documentation and real-world performance, ensuring your systems meet both the letter and the spirit of the ISM Code.