What are the 12 elements of the ISM Code?

The ISM Code (SOLAS Chapter IX) requires a Safety Management System covering 12 elements: (1) General, (2) Safety and Environmental Protection Policy, (3) Company Responsibilities, (4) Designated Person Ashore (DPA), (5) Master Responsibility and Authority, (6) Resources and Personnel, (7) Shipboard Operations, (8) Emergency Preparedness, (9) Non-conformities and Accidents, (10) Maintenance, (11) Documentation, and (12) Verification, Review and Evaluation.

What is the difference between a DOC and SMC audit under the ISM Code?

A DOC (Document of Compliance) audit is conducted at the Company level and verifies the Safety Management System meets ISM Code requirements. An SMC (Safety Management Certificate) audit is conducted at the vessel level and confirms onboard SMS implementation. Both must be current and valid for SOLAS trading vessels.

Who must comply with the ISM Code?

The ISM Code is mandatory under SOLAS Chapter IX for passenger ships, oil tankers, chemical tankers, gas carriers, bulk carriers, and cargo high-speed craft of 500 GT and upwards. Many flag states extend ISM requirements to commercial yachts at lower tonnage thresholds.

What is the Designated Person Ashore (DPA) requirement under the ISM Code?

ISM Code Element 4 requires every company to appoint a DPA with direct access to the highest level of management. The DPA monitors safety and pollution prevention aspects of the SMS and must be contactable 24/7. Contact details must be posted on board.

ISM Code Audit Checklist — DOC & SMC Readiness (All 12 Elements) | HelmOps

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Element 1

General

Safety Management System (SMS) documented and implemented on board
ISM 1.4BothCritical
SMS is specific to the vessel type and operations
ISM 1.2SMCCritical
Objectives of the SMS are defined and communicated to crew
ISM 1.2.2Both
SMS covers all vessels operated by the Company
ISM 1.4DOC
Functional requirements of SMS are addressed (safety policies, emergency procedures, audit programmes)
ISM 1.4DOCCritical

Element 2

Safety & Environmental Policy

Company Safety and Environmental Protection Policy is documented
ISM 2.1DOCCritical
Policy is posted on board and accessible to all crew
ISM 2.1SMC
Policy is signed by the Designated Person Ashore (DPA) or senior management
ISM 2.1DOCCritical
Master and crew can explain the policy objectives when interviewed
ISM 2.2SMC
Policy reviewed and updated at defined intervals
ISM 2.1DOC

Element 3

Company Responsibilities

Company (as defined by ISM Code) is identified and named in the SMS
ISM 3.1DOCCritical
Designated Person Ashore (DPA) is appointed, named, and contactable 24/7
ISM 4BothCritical
DPA has direct access to the highest level of management
ISM 4DOCCritical
Resources and shore-based support are identified and provided to the Master
ISM 3.3SMC
Responsibility for implementation of the SMS is clearly allocated
ISM 3.2DOC

Element 4

Designated Person Ashore

DPA role and responsibilities are defined in writing within the SMS
ISM 4DOCCritical
DPA contact details posted on board (24/7 phone / email)
ISM 4SMCCritical
DPA monitors safety and pollution prevention aspects of each vessel
ISM 4DOC
Records of DPA communications with Master on safety matters maintained
ISM 4Both
Deputy DPA or backup contact identified for periods of absence
ISM 4DOC

Element 5

Master's Responsibility

Master's overriding authority to ensure safety is documented in the SMS
ISM 5.2BothCritical
Master implements the Safety and Environmental Protection Policy
ISM 5.1SMCCritical
Master motivates crew in observation of the SMS
ISM 5.1SMC
Master issues appropriate orders and instructions clearly
ISM 5.1SMC
Master reviews and updates the SMS where necessary
ISM 5.1SMC

Element 6

Resources & Personnel

All crew hold valid STCW certificates for their position
ISM 6.2 / STCWSMCCritical
Familiarisation procedure for new crew members documented and implemented
ISM 6.3BothCritical
Training needs assessment conducted and training records maintained
ISM 6.5DOC
Crew can communicate effectively — language proficiency assessed
ISM 6.6SMC
Safe Manning Certificate is current and vessel is not undermanned
ISM 6.2SMCCritical
Company provides procedures for crew repatriation and welfare
ISM 6 / MLC 2.5DOC

Element 7

Shipboard Operations

Procedures for key shipboard operations are documented (bunkering, anchoring, port entry, tender ops)
ISM 7SMCCritical
Checklists used for critical operations (departure, watchkeeping, heavy weather)
ISM 7SMC
Permit-to-Work system in place for hot work, enclosed space entry, electrical work
ISM 7BothCritical
Passage planning procedures comply with IMO guidelines and are applied
ISM 7 / SOLAS V/34SMC
Risk assessments conducted for non-routine operations and documented
ISM 7Both

Element 8

Emergency Preparedness

Emergency procedures documented for all potential scenarios (fire, flooding, man overboard, grounding)
ISM 8.1BothCritical
Muster list posted in crew areas and guest cabins
ISM 8 / SOLAS IIISMCCritical
Emergency drills conducted at required intervals and logged (fire, abandon ship, MOB)
ISM 8.2 / SOLAS III/19SMCCritical
Emergency contact list (flag state, DPA, insurer, owner) current and accessible
ISM 8SMC
Emergency equipment (life rafts, EPIRBs, flares) inspected and certification current
ISM 8 / SOLAS IIISMCCritical
Damage control plan and stability information available on the bridge
ISM 8 / SOLAS II-1SMC

Element 9

Non-conformities & Accidents

Procedure for reporting non-conformities, near misses, and accidents is documented
ISM 9.1BothCritical
Non-conformity reports (NCRs) are recorded, investigated, and closed out
ISM 9.1BothCritical
Root cause analysis performed for significant incidents
ISM 9.1DOC
Near-miss reporting culture encouraged — crew aware of no-blame policy
ISM 9.1SMC
Corrective actions from previous audits and incidents reviewed for effectiveness
ISM 9.2Both

Element 10

Maintenance

Planned Maintenance System (PMS) implemented for hull, machinery, and safety equipment
ISM 10.1SMCCritical
Maintenance records demonstrate compliance with the PMS
ISM 10.3SMCCritical
Statutory and class certificates for all equipment are current
ISM 10.3SMCCritical
Procedure for identifying and reporting defective equipment and requesting spares
ISM 10.2Both
Critical equipment (steering, bilge pumps, fire detection) tested at defined intervals
ISM 10.1SMCCritical
Spare parts management system in place; critical spares carried
ISM 10.3SMC

Element 11

Documentation

SMS documents are controlled — versioned, dated, and obsolete copies removed
ISM 11.1BothCritical
Document distribution list maintained; Masters acknowledge receipt of updates
ISM 11.1DOC
Statutory certificates (SMC, DOC, IOPP, SafetyMgmt, etc.) held on board and valid
ISM 11 / SOLAS IX/4SMCCritical
Log books (deck, engine, oil record) maintained in the correct format
ISM 11.3 / MARPOLSMC
Records are legible, protected from damage, and retained for required periods
ISM 11.3Both

Element 12

Audits & Review

Internal audits conducted at intervals not exceeding 12 months
ISM 12.1BothCritical
Internal auditors are independent of the area being audited
ISM 12.1DOC
Management review of SMS effectiveness conducted by senior management
ISM 12.2DOCCritical
Corrective actions from internal audits tracked to close-out with evidence
ISM 12.1Both
External (flag state / RO) audit schedule current — no overdue audits
ISM 12 / SOLAS IX/6BothCritical
Audit findings and management review outcomes used to drive SMS improvements
ISM 12.2DOC

Legend

DOC— Document of Compliance (Company audit)

SMC— Safety Management Certificate (Vessel audit)

Critical— Major non-conformity if missing

ISM Code Audit Checklist

Element 1

Element 2

Element 3

Element 4

Element 5

Element 6

Element 7

Element 8

Element 9

Element 10

Element 11

Element 12

Keep your ISM documentation audit-ready

Related Resources

ISM Code Audit Checklist

Element 1

Element 2

Element 3

Element 4

Element 5

Element 6

Element 7

Element 8

Element 9

Element 10

Element 11

Element 12

Keep your ISM documentation audit-ready

Related Resources