ISM Code - Are audits once a year enough?

 

The ISM Code or the international management code for the safe operation of ships and for pollution prevention was initiated as means for the shipping industry to self-regulate itself. There is an ongoing debate whether the ISM code has been able to achieve this objective. ISM code internal auditors do the needful as delegated by assessing the conformity of the system once a year. However, is this enough and why is the ISM code not adding the value it should? Why are there still so many maritime accidents occurring?

For clarity on how often audits should be conducted let us look at the requirement of the ISM code. Clause 12.1 states “The Company should carry out internal safety audits on board and ashore at intervals not exceeding twelve months to verify whether safety and pollution-prevention activities comply with the SMS.” ISMcode internal auditors and vessel management should note that the requirement does not say audit once a year. It states, ‘not exceeding twelve months.’ Often ISM code internal auditors are serving vessel superintendents within the company. As audits are seen as an overhead cost and given that it may not be cost effective to sly auditors to various locations the audits are limited to once a year. We may also question the independence of the audit if it is being done by the vessel superintendent then. How are non-conformities against the company then identified?

While a guideline exists for the qualification needed for a DPA there is no guideline for the qualifications of an ISM code internal auditor. This is as determined by the company. Generally, a two-day auditor course is the norm but QMII often recommends that ISM code auditors also do an ISO 9001 4-day Lead Auditor course to gain a better grounding in auditing principles and how to add value from audits. Audits must be conducted to assess the effectiveness of the system. ISMCode internal auditors and management must be cognizant that the audit is usually only a day long but ahs to assess the system effectiveness for the remaining 364 days of operation. It may be beneficial to have internal audits done more frequently for it is better to identify a non-conformity through an internal audit then to find one during an external audit / inspection.

Perhaps is audits were conducted more frequently it would bring to light risks that could be addressed timely rather than learning from a costly mistake. ISM codeinternal auditors while guided by company requirements must recognize the importance of the task they are undertaking and how a bad sample size may avoid the identification of critical risks. Auditors may consider combining their ISMcode internal auditor training with an ISO 9001 lead auditor training for broader exposure. Vessel management too must consider the independence of the audits being conducted and the intervals of the audit in ensuring that the audit scheme adds value.