Section 15.1 The Safety Management System (SMS): Structure and Key Elements

A Safety Management System (SMS) is the documented, systematic approach developed by a shipping company (referred to as “the Company” in the ISM Code) to ensure that its ship operations are conducted safely and that its environmental protection policies are effectively implemented. The SMS is tailored to the specific company and its fleet but must meet all the requirements of the ISM Code. It provides the framework for how safety and pollution prevention are managed on a day-to-day basis.

1. Definition and Objectives of an SMS (as per ISM Code):

Definition: The ISM Code (Section 1.1.2) states that a Safety Management System means “a structured and documented system enabling Company personnel to implement effectively the Company safety and environmental protection policy.”

Objectives of the SMS (ISM Code, Section 1.2.2): The objectives of the SMS should, inter alia:

Provide for safe practices in ship operation and a safe working environment.

Assess all identified risks to its ships, personnel, and the environment and establish appropriate safeguards.

Continuously improve safety management skills of personnel ashore and aboard ships, including preparing for emergencies related to both safety and environmental protection.

2. Structure of a Typical SMS:

While the specific structure can vary between companies, an SMS is typically documented in a series of manuals or an integrated electronic system, which must be readily accessible to all relevant personnel, both ashore and onboard. A common structure might include:

A. Safety and Environmental Protection Policy:

A clear, concise statement from top management outlining the company’s commitment to safety, pollution prevention, and continuous improvement. This policy should be displayed prominently onboard and understood by all crew.

B. Company Responsibilities and Authority (ISM Code, Section 3):

Clearly defines the responsibility, authority, and interrelation of all personnel who manage, perform, and verify work relating to and affecting safety and pollution prevention.

Identifies the Designated Person Ashore (DPA), who has direct access to the highest level of management and is responsible for monitoring the safety and pollution prevention aspects of the operation of each ship and ensuring that adequate resources and shore-based support are applied, as required.

C. Master’s Responsibilities and Authority (ISM Code, Section 5):

Defines the Master’s responsibility for:

Implementing the safety and environmental protection policy of the Company.

Motivating the crew in the observation of that policy.

Issuing appropriate orders and instructions in a clear and simple manner.

Verifying that specified requirements are observed.

Periodically reviewing the SMS and reporting its deficiencies to the shore-based management.

Crucially, the ISM Code grants the Master overriding authority and discretion to take whatever action they deem necessary to protect the safety of life, the ship, and the marine environment, even if it means deviating from company instructions or commercial considerations.

D. Resources and Personnel (ISM Code, Section 6):

Procedures to ensure that the Master is properly qualified for command, fully conversant with the SMS, and given necessary support.

Procedures to ensure that each ship is manned with qualified, certificated, and medically fit seafarers in accordance with national and international requirements.

Procedures for identifying training needs and providing training for all personnel involved in the SMS.

Procedures to ensure that ship’s personnel can communicate effectively in the execution of their duties.

Procedures to ensure personnel are familiar with their duties and the ship’s arrangements, installations, equipment, and procedures.

E. Development of Plans for Shipboard Operations (ISM Code, Section 7):

Procedures and instructions for key shipboard operations concerning the safety of the ship and the prevention of pollution. This is a vast section covering:

Navigation (passage planning, bridge procedures, use of equipment).

Cargo handling (stowage, securing, monitoring, hazardous cargo procedures).

Mooring and anchoring.

Machinery operations and maintenance.

Bunkering.

Ballast water management.

Waste management.

Any other operations critical to safety and environmental protection.

Checklists are often used for these key operations.

F. Emergency Preparedness (ISM Code, Section 8):

Procedures to identify, describe, and respond to potential emergency shipboard situations (e.g., fire, collision, grounding, flooding, pollution, heavy weather damage, piracy, man overboard, enclosed space rescue).

Programmes for drills and exercises to prepare for emergency actions.

Integration with other emergency plans (e.g., SOPEP, SMPEP, Ship Security Plan).

G. Reports and Analysis of Non-Conformities, Accidents, and Hazardous Occurrences (ISM Code, Section 9):

Procedures for reporting accidents, hazardous occurrences (near misses), and non-conformities with the provisions of the SMS.

Procedures for investigating these events to determine root causes.

Procedures for taking corrective action to prevent recurrence.

Analysis of data to identify trends and improve the SMS.

H. Maintenance of the Ship and Equipment (ISM Code, Section 10):

Procedures to ensure the ship is maintained in conformity with the provisions of relevant rules and regulations and any additional requirements established by the Company.

Planned Maintenance System (PMS): A systematic approach to inspecting, maintaining, and testing all critical equipment and structures.

Procedures for identifying and reporting defects or non-conformities with equipment.

Procedures for ensuring prompt corrective action.

Maintaining records of maintenance, inspections, and tests.

I. Documentation (ISM Code, Section 11):

Procedures for controlling all documents and data relevant to the SMS.

Ensuring valid documents (manuals, procedures, instructions, forms, checklists) are available at all relevant locations (ship and shore).

Ensuring changes to documents are reviewed and approved.

Ensuring obsolete documents are promptly removed.

J. Company Verification, Review, and Evaluation (ISM Code, Section 12):

Procedures for the Company to carry out internal safety audits (both ashore and onboard ships) to verify whether safety and pollution-prevention activities comply with the SMS.

Procedures for periodic evaluation of the effectiveness of the SMS by shore management and for its review and improvement by the Master onboard.

3. Key Elements of the ISM Code Itself:

The ISM Code is divided into a Preamble, Part A (Implementation), and Part B (Certification and Verification). The functional requirements listed above are primarily from Part A. Some underlying philosophies and key elements include:

Commitment from the Top: Safety culture must be driven by the highest levels of management in the Company.

Defined Responsibilities: Clear lines of authority and responsibility for safety are essential.

Competent Personnel: Ensuring crew are qualified, trained, and medically fit.

Risk Assessment: A proactive approach to identifying potential hazards and implementing safeguards. This is a continuous process.

Procedures for Key Operations: Standardizing procedures for critical tasks to ensure they are performed safely and consistently.

Emergency Preparedness: Being ready to respond effectively to any foreseeable emergency.

Continuous Improvement Cycle (Plan-Do-Check-Act – PDCA):

Plan: Develop policies, procedures, and objectives.

Do: Implement the plans and procedures.

Check: Monitor and measure performance, report incidents and non-conformities, conduct audits.

Act: Take corrective and preventive actions to address deficiencies and improve the system. This cycle is fundamental to the ISM philosophy.

Documentation and Record Keeping: “If it’s not written down, it didn’t happen.” Proper documentation provides evidence of compliance and forms the basis for analysis and improvement.

Verification and Auditing: Regular internal and external audits (by Flag State or Recognized Organization) verify that the SMS is being effectively implemented and meets Code requirements.

4. The SMS as a “Living System”:

It is crucial that the SMS is not viewed as a static set of manuals that sit on a shelf. To be effective, it must be a “living system”:

Actively Used: Procedures and checklists should be consulted and used for relevant operations.

Understood by Crew: All crew members should be familiar with the parts of the SMS relevant to their duties.

Reviewed and Updated: The SMS should be regularly reviewed (by the Master onboard and by the Company ashore) and updated to reflect changes in regulations, vessel operations, lessons learned from incidents, or identified improvements. Feedback from the ship’s crew is vital for this.

Practical and Workable: Procedures should be realistic, practical for shipboard conditions, and written in clear, unambiguous language. Overly complex or impractical procedures are unlikely to be followed.

Analysis for the Master (SMS Structure and Elements): The Master is the lynchpin for the effective implementation of the SMS onboard.

Thorough Familiarization: The Master must be intimately familiar with all aspects of the Company’s SMS that apply to their vessel and their responsibilities.

Championing the SMS: Lead by example in adhering to SMS procedures and promoting a positive safety culture.

Ensuring Crew Familiarization and Training: Verify that all crew members understand their roles and responsibilities under the SMS and are trained in relevant procedures.

Effective Implementation: Ensure that planned operations are conducted in accordance with SMS procedures, that risk assessments are carried out, and that work permits are used where required.

Reporting and Feedback: Encourage open reporting of non-conformities, incidents, and near misses. Provide constructive feedback to the Company on the effectiveness and practicality of the SMS.

Master’s Review: Conduct periodic reviews of the SMS implementation onboard, identify areas for improvement, and report findings to the DPA.

Using Overriding Authority: Understand when and how to exercise overriding authority in the interest of safety or environmental protection, as empowered by the ISM Code.

The Safety Management System, mandated by the ISM Code, provides the essential framework for embedding safety and environmental protection into the very fabric of ship operations. For the Master of a bulk carrier, actively leading its implementation and fostering a robust safety culture onboard is not just a regulatory duty but a profound professional responsibility that safeguards lives, the vessel, and the marine environment.