ISM Code Compliance for Charter Yachts: Captain's Practical Guide

The 500 GT threshold covers most large superyachts in commercial charter service. For yachts between 300-500 GT operating under MCA, Cayman, or Marshall Islands charter codes, the flag state may require ISM-equivalent safety management standards as part of the commercial certification process even without mandatory ISM. For smaller charter yachts (under 300 GT), the LY3 (Large Yacht Code 3) and equivalent codes require a simplified SMS without full ISM certification.

Many charter yachts purchase a template SMS from a ship management company or flag state recognised organisation and adapt it. The critical step is adaptation — a generic SMS not tailored to the specific vessel, its operations, crew, and equipment creates a paper trail that does not reflect actual operations. Auditors and PSCOs quickly identify SMS documentation that has not been implemented. The captain must own the SMS operationally, not just file it.

On independently operated charter yachts (not managed by a large company), the DPA is often a contracted individual — a retired officer or shore-based yacht manager. The arrangement must be documented in the SMS. The DPA must have genuine authority to access senior management and take decisions on safety matters. For emergencies — grounding, fire, medical emergency — the DPA is the captain's shore-based support chain. Their contact details must be posted on board in the crew's working language.

The ISM Code requires that the company conduct internal audits to verify that SMS activities comply with the requirements. On a charter yacht, the DPA typically conducts the shipboard internal audit annually. The audit checks that: documented procedures are being followed; PMS records are complete and up to date; all crew are familiar with emergency procedures; nonconformities from previous audits are closed. The audit findings and close-out evidence must be filed in the SMS documentation.

The Safety Management Certificate must be renewed every five years (with an intermediate survey at year 2.5). The renewal survey is conducted by the flag state or RO and covers both shore (company audit) and shipboard elements. Preparation: conduct an internal audit 2-3 months before the renewal survey to identify and resolve any gaps; ensure the SMS is current and reflects actual operations; verify that the PMS has no significant gaps in the survey period; and prepare the documentation package (SMC, DOC, previous audit reports, drill records, incident reports, and corrective action records).