Notebook: Guidelines rewritten for ISM Code

Who does the ISM Code work for? It’s time to redress the balance in favour of seafarers, says Mark Rawson, who has led the expert group tasked with rewriting the International Chamber of Shipping’s ISM Guidelines.

“The point of the ISM Code when it entered into force in 1998 was to make it easier and safer for ships’ crews to carry out their work, day to day. But over the years, external pressures have seen the code morphing into something that can be for the benefits of external bodies – and that has been a problem,” he said. “The industry has changed so much and 21 years on we are in a very different and far more complex place. There is so much pressure from stakeholders – flag states, port states, charterers and commercial interests including banks and underwriters. They will use your SMS in their own way to judge you.”

The ICS issued its first ISM guidelines for ship owners and managers when the code was introduced and since then there have been second, third and fourth editions. “There was no large change to the code itself and the ICS only required minor changes in context and practice over the years,” said Mr Rawson. “These were more of an update here and there.”

What emerged more recently was a strong enthusiasm to make more radical changes to the guidelines, he said. “The view from ship owners and ship managers, myself included, was that we should look at where we can simplify the ISM Code and adoption of its requirements. Work started at the end of 2018. I was fortunate to head up an excellent group of experts drawn from ship managers and ship owners across different shipping sectors, all with huge experience of working with management systems.  We needed to write a guidance document that looked forward and addressed the balance between encouraging the owner to write an SMS to improve safety and environmental protection and helping the crew to do their job properly.”

The rewritten guidelines also address how to engage with new technology, how to manage the pressures of the various audits and how to ‘push back’, where appropriate, against overdemanding inspectors and auditors with their own requirements outside the ISM scope.

“Inspectors and auditors have increasingly wanted to see really complex procedures and systems as part of a vessel’s SMS – not because that makes it easier to operate but because those items are on their checklist. “The commercial pressures on the shipping industry are stronger than ever before and the balancing of power between the needs of the crew and the needs of regulators or commercial interest does not always result in a good SMS and the effective implementation of safe working practices.”

This has led to many SMSs being written that are very difficult for the crew to follow and less effective, while having a checklist that includes “all the words you want to see”.

“The ISM Code can be used very effectively to manage the complexities of today’s operations. We just need to refocus on what the ISM Code actually says. Over the years, a lot of people have tried to do too much – and ended up doing it badly because they were doing things that did not add any value.”

In writing the new guidelines, which are themselves about two-thirds of the length of previous editions, the group has focused on using simple English, for clarity and ease of use. The guidelines are divided into three sections: first, where we are now, setting the scene, outlining the significant stakeholders and objectives; second, the experience of companies and the benefit of experience, including a large amount of risk assessment content and a focus on best practice; and third, new ideas and suggestions, using the ISM Code to deal with new technologies and complexities in the future, and how to replicate success.

“We should be learning from success and we have focused on SMS concepts that encourage this,” said Mr Rawson. “All too often the emphasis is on trying to learn from random, infrequent outputs/incidents, whereas we don’t focus on learning from consistent, well-planned success.”

“Our new guidelines are written for ship owners, operators and managers – and, above all, for the benefit of the crew. We want to provide clarity on what is actually required by the ISM Code. The code is actually very simple in its approach and quite easy to comply with. Over the years different stakeholders have added their own interpretations but, in reality, how you manage the ISM is up to you. If the SMS is effective other stakeholder needs will take care of themselves. In a complex business it is time to refocus the SMS on the fundamental objectives of safety and environment protection.”