ISM failures: here’s why it must do better

Is the International Safety Management code working as it was meant to? Those who need to pay attention to it most are failing to take a robust approach, reports ISM auditor Mike Wall.

It is more than 30 years since the MS Herald of Free Enterprise ferry disaster in the North Sea. The capsize of the roll-on, roll-off ferry saw almost 200 souls lost shortly after it left the Belgian port of Zeebrugge on a dark March night in 1987.

That avoidable tragedy – the sea flooded in through the still-open inner and outer bow doors – hastened the introduction of the International Safety Management (ISM) Code which was adopted in 1993 by resolution A.741 (18) at the IMO. It eventually entered into force on 1 July 1998.

The aim of the ISM was to bring substandard ship operators under the umbrella of international regulation to improve ship operating standards. Many had been advocating for ship management legislation for quite some time.

The ISM arrived requiring volumes of documentation and some saw its introduction as something of a ‘knee-jerk’ reaction.

Is the ISM working?

Substandard operators have not really understood the aim of the code, which is continuous improvement in safety. Masters are always keen to point out that they have no accidents, incidents or near misses to report. However, when the medical logbook is checked, numerous injuries are found.

The reality is many who don’t really need an ISM system are applying it diligently, while the ones who most need it only pay it lip service.

To become more effective, ISM must be audited by independent organisations, with less reliance on Class.

It has clearly become a ‘box-ticking’ exercise for the latter. One example is that many bridge procedure checklists are pre-completed with only the Master’s signature required. A key factor in improving ship safety is the Ship Safety Committee, so it is disappointing to find that the minutes of meetings are also pre-recorded.

As an ISM lead auditor, I have been admonished by non-IACS Classification Societies for being over-zealous in my findings. A classic case is that of after-deck fairlead corrosion wastage being covered by canvas and painted over, yet it is a defect that could be life-threatening to the deck crew.

Major conflicts of interest

The code requires a ship owner to audit ships twice and the management to be audited annually during the five-year Class ISM SMC and DOC validity.

With no independent organisation recognised by the Flag States, Class carries out all the audits of ISM systems. This is where they have implemented the ISM system on vessels classed by them, using auditors trained and certified by the same Society – it’s a quadruple conflict of interest.

With the need for Flag to be involved, the previous single unbreakable bond between Owner and Class has become an unbreakable triangle between Owner, Class and Flag State. Many believe this to be because each is tied financially to the others, with owners paying Class and the Flag State for their services.

As owners are paying, commercial pressure can be applied by substandard operators on the other two. To become more effective, ISM must be audited by independent organisations, with less reliance on Class.

Then there are the Port State Control Inspectors (PSCI), seen by many as the policemen of shipping. Defects found by the PSCI are recorded and a list issued to the Master with a time limit for them to be rectified. A poor record can significantly affect the vessel’s earning capacity. While it would be expected that PSC would have the required effect, PSCIs can be thorough in some ports and corrupt in others.

RightShip ratings are more effective

One significant contributor to improving ship safety is RightShip. Under the RightShip inspection regime, vessels are given a one- to five-star rating, the highest score being for a vessel considered to be in excellent condition with no risks for charterers. The number of charters and rates earned by a vessel tend to be reflected in the star rating attained. SIRE and OVID are schemes which maintain a similar database for tankers and offshore vessels respectively.

Further evidence that the principles of ISM are not being applied is when RightShip inspectors find glaring non-conformities during the two-day RightShip inspection.

So, has it succeeded in its aims? The jury is still out.

Having been a teacher for 50 years I would not give ISM a gold star. In fact, I would mark it down as a ‘must do better’.

Mike Wall is an ISM auditor, consultant, and writer.