Operational Guide · Registers & Logbooks

# Management Review

The moment when the Company's top management formally takes responsibility for verifying that the SMS truly works — not just that it exists on paper.

ISM Code Management Review top management SMS

## Operational Explanation

The Management Review is the periodic assessment, conducted by the Company's top management, of the continuing adequacy and effectiveness of the Safety Management System. It is not an audit (which verifies point-in-time compliance), but a strategic evaluation: is the SMS still achieving the Company's safety and environmental protection objectives? Does it need to be changed?

Direct involvement of top management is an explicit requirement of the ISM Code precisely to prevent safety from being delegated solely to the DPA or technical offices, without real visibility and commitment at the highest decision-making levels.

## Regulatory Reference

ISM Code, par. 1.4 (Functional Requirements) and par. 12 (Company Verification, Review and Evaluation): top management must periodically review the SMS to ensure its continuing suitability and effectiveness.

## Scope of Application

Every ISM-certified Company, typically on an annual basis (or at intervals defined in its own internal procedure), before or in preparation for the external renewal/intermediate audit of the Document of Compliance.

## Procedure / How to Complete It

1. Gather inputs: outcomes of internal and external audits, open/closed NCs, Near Misses and incidents, crew feedback, complaints, PSC/vetting inspection results.
2. Convene the Management Review meeting with documented attendance of top management (not only the DPA).
3. Assess the adequacy of resources assigned to the SMS (personnel, training, maintenance and safety budget).
4. Identify trends, areas for improvement and any need to amend SMS procedures or objectives.
5. Record decisions and assigned actions, with an owner and a deadline, and verify their implementation at the next review.

## Practical Example

Example minutes: "2026 Management Review — Reviewed 18 NCs (3 major, 15 minor) and 42 Near Misses for the year. Trend identified: 6 minor NCs linked to overdue preventive maintenance on two fleet vessels. Decision: review of resources allocated to the maintenance department and a special internal audit targeted at the two vessels within the following quarter."

## Real Cases

During external DOC renewal audits, certification auditors often raise as an NC the fact that the Management Review is reduced to a completed form without real, documented discussion, or that top management does not actually take part: this undermines the credibility of the entire management system in the certifier's eyes.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
Management Review reduced to a completed form without real discussion | NC in certification audit for lack of evidence of genuine top management involvement | Document the meeting with minutes, participants and concrete decisions
Data analysis (NC, Near Miss) purely quantitative, without looking for trends | Systemic problems remain invisible until an incident or a serious deficiency occurs | Always include trend analysis, not just event counts
Management Review decisions without an owner or a deadline | Agreed actions are never completed | Always assign an owner and a date to every decided action

## PSC Observations

The Management Review is not typically subject to direct verification by PSCOs (who inspect the ship, not the shore offices), but it is a central element of external ISM audits (DOC/SMC) and is often requested during oil major vetting.

## Operational Tips

- Prepare the Management Review with aggregated data (NC trends, Near Misses, PSC deficiencies), not just itemised lists.
- Always document the actual participation of top management, not only the DPA.
- Verify at the next review that the actions decided at the previous one have actually been completed.

## Checklist

- Inputs gathered: audits, NCs, Near Misses, incidents, crew feedback
- Top management participation documented
- Trend analysis, not just event counts
- Decisions recorded with an owner and a deadline
- Actions from the previous review verified as completed

## FAQ

How often must the Management Review be conducted?
The ISM Code does not impose a fixed frequency, but requires it to be periodic; established practice at most Companies is annual, often in preparation for the external audit.
Can the DPA conduct the Management Review alone?
No: the ISM requirement is that top management reviews the SMS. The DPA prepares and presents the data, but the review and decisions must involve the Company's top level.
What distinguishes the Management Review from an internal audit?
The internal audit verifies point-in-time compliance of procedures and records; the Management Review is a strategic assessment, conducted by top management, of the overall adequacy of the SMS over time.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

Non Conformity (NC) Management Internal SMS Audit Designated Person Ashore (DPA)

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