Q a. What are the functional requirements of ISM code?

b. What are the objectives of and ISM internal audit of a ship? How and internal audit helps in external audit of a vessel? Name the salient issues addressed in the internal audit & the minimum frequency of such an audit to be carried out on board ship assuring the 5 year validity of the ships Safety Management Certificate.

c. How can you assure that the copy of Document of Compliance (DOC) issued to the company & is placed on board is relevant to your ship?

Answer :-

The aim of the ISM Code is to provide an international standard for the safe management & operation of the ships & for the pollution prevention. The aim of the Code are to assure safety at sea, prevention of human injury or loss of the life, & avoidance of damage to the environment, in particular, to the marine environment, & to the property.

Safety management objectives of the Company should, inter alia:

  • Provide for safe practices in the ship operation & a safe working environment;
  • establish safeguards against all the identified risks; &
  • Continuously improve safety management skills of the personnel ashore & aboard ships, including preparing for the emergencies related both to safety & environmental protection.

The safety & management system should assure:

  • compliance with the mandatory rules & regulations; &
  • That applicable codes, guidelines & standards recommended by the Organization, Administrations, classification societies & maritime industry organizations are taken into account.

The requirements of this Code may be applied to all ships.

a) Functional Requirements Of the ISM CODE

Every Company should develop, implement & maintain a Safety Management System (SMS) which includes the following functional requirements:

  • A Safety & Environmental Protection Policy;
  • Instructions & procedures to assure safe operation of ships & protection of the environment in compliance with relevant international & flag State legislation;
  • defined levels of authority & lines of communication between, & amongst, shore & shipboard personnel;
  • Procedures for reporting accidents & non-conformities with the provisions of this Code.
  • Procedures to prepare for & respond to emergency situations.
  • Procedures for internal audits & management reviews.


After July 2010 it became compulsory to carry out internal audit annually under the ISM code. Clause 12.1 of ISM code says “Internal safety audits are now needed to be carried out on board & ashore at intervals not exceeding 12 months, in extreme exceptional cases it can be extended up to 3 months.”


1) It acts as a tool to monitor how well the SMS system is followed on board regarding the safety practices & pollution prevention activities.

2) It helps in checking whether company safety & environmental policy is continually in accordance with the requirement of this code. Provides an opportunity to possible changes in the SMS system

3) Shows the evidence of the SMS working & that the procedures are being followed

4) To determine compliance with the regulatory requirement

How it helps external audit: – Normally an internal audit is done at least 4 weeks prior to external audit. The internal audit is done in same rigorous way as an external audit.

During the internal audit, the shortcomings of the shipboard SMS, identified as the form of NC (Non Conformity), observation can be modified by the ship staff or by the company before any external audit. This provides time & guidance for improving the preparedness towards the external audit. Any deficiency or NC which would have been left unattended untill the time of external audit thus will be brought up & corrective action procedure will be laid down. The internal audit is performed as per the procedure laid down in company’s SMS manual. It is conducted by the company’s person who is other than the field of audit. By this all documents, displays, procedures, emergency equipments etc. are checked for proper order. Thus an internal audit is helpful in conduction of external audit. The effectiveness of the former will certainly affect the effectiveness of the latter.


1) safety & environmental protection policy.

2) Instruction & procedure to assure safe operation of the ship.

3) Level of authority & lines of communication between shore & shipboard personnel.

4) Procedure for reporting accidents & non conformities.

5) Procedure for prepare for & respond to emergency situation.

6) Company’s DOC validation.


The person responsible for the internal audit is a company’s man & most probably from ISM cell. Designated person ashore (DPA) is the responsible person for carrying out or organizing the internal as well as the external audit.

c) DOC

A Document of Compliance or DOC is issued to a company depends on the type of ship. This means that the DOC will be different for the different type of ships i.e. if company have 10 containers & 10 oil tankers, then 2 different  types of DOC will be issued, one to the container fleet & other to the tanker fleet.

DOC is issued under the authority of the flag state government by successfully auditing & reviewing companies SMS & its implementation. i.e after Initial verification / Audit

Hence to assure copy of DOC placed on board is relevant, it must correctly mention type of vessel, flag state & name of the company.