Thematic module · second module developed

# ISM in Practice Live

Non-Conformities, Near Miss, Management Review, CAPA, Internal Audit, DPA, DOC/SMC, Crew Familiarisation, Emergency Preparedness, MLC Complaint Handling, Management of Change, Contractor Management, Whistleblowing, Prevention of Violence and Harassment, Master's Authority and Safety Culture, Crew Fatigue and the 2026-2027 IMO Review: the Safety Management System in daily practice.

Each topic below brings together, in a single place: an operational explanation, the regulatory reference, scope of application, procedure, practical example, real cases, common mistakes, PSC observations, operational tips, a checklist and FAQ — regulations verified as of July 2026.

### Managing a Non-Conformity (NC)

How a Non-Conformity is opened, classified and formally closed within the Safety Management System — the heart of the ISM Code's continuous improvement cycle.

### Reporting a Near Miss

A near miss is the most valuable and hardest-to-collect piece of information: how to build a reporting culture that does not punish the person who reports.

### 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.

### Corrective and Preventive Action (CAPA)

The action that truly closes the loop: how to plan, document and verify the effectiveness of a CAPA so the Non-Conformity does not recur.

### Internal SMS Audit

How to plan and conduct the internal audit the ISM Code requires before every external audit — and how to make it a useful tool, not just a formality.

### Designated Person Ashore (DPA)

The direct, independent link between the ship and the Company's top management: who the DPA is, what powers they hold, and why their independence is a requirement, not an option.

### Document of Compliance (DOC) and Safety Management Certificate (SMC)

The two certificates that make ISM compliance tangible: what they attest, who issues them, when they must be renewed, and what happens if they expire or are suspended.

### Crew Familiarisation and Training

The ISM Code doesn't just ask you to train the crew: it asks you to demonstrate that every new member knows their duties before the ship leaves port.

### Emergency Preparedness and Contingency Plan

Having a written emergency plan is not enough: the ISM Code requires proof, through regular drills, that the crew could really carry it out.

### Handling Seafarer Complaints (MLC 2006)

Every ship subject to MLC must have an internal complaint procedure with precise response times: ignoring it, or treating it as a formality, exposes the Company to a real risk during inspection.

### Management of Change (MoC)

Not every change is equal: a formal MoC process distinguishes a modification that requires a structured risk assessment from one that can proceed without.

### Contractor and External Supplier Management

2026 brings a stricter audit environment, with Classification Societies demanding documented evidence rather than simple declarations of compliance: the qualification and monitoring of external suppliers is no exception.

### Whistleblowing and Anonymous Reporting of Non-Conformities

A seafarer dismissed after reporting a safety concern directly to the US Coast Guard without first informing their employer led to a change in company policy: protection from retaliation is not a minor detail.

### Prevention of Violence and Harassment Onboard

From 1 January 2026, mandatory PSSR training includes for the first time a specific competence on preventing and responding to violence, sexual harassment, bullying and sexual assault on board.

### Master's Authority and Safety Culture

The Master's authority is not a hierarchical formality: the ISM Code requires it to be explicitly defined, documented and recognised as overriding any other pressure, including commercial ones.

### Crew Fatigue: The IMO 2026-2027 Review Process

Not yet a new requirement, but the first formal step towards one: the HTW sub-committee has launched a review of the effectiveness of hours of work and rest rules, with conclusions expected in 2027.

### Cyber Risk Management in the SMS (MSC.428(98))

The ISM Code has never had a dedicated cyber risk chapter: Resolution MSC.428(98) folded it into the existing risk management framework, making it a mature and auditable requirement from 2021 onward.

### Autonomous Ships (MASS): the Company's Responsibility under the SMS

The MASS Code governs the ship; but according to the IMO, who answers when a remote operation goes wrong remains the ISM Company, and its SMS must say so explicitly.

Coming in future updates to this module: outcome of the HTW scoping exercise on the review of hours of work and rest rules, expected in 2027, formal adoption of the revised Guidelines on Implementation of the ISM Code covering reporting infrastructure and psychological support, review of the DPA's role in light of the ISM guidelines evolving through 2028.

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