Internal SMS Audit
How to plan and conduct the internal audit the ISM Code requires at intervals not exceeding twelve months — and how to make it a useful tool, not just a formality.
Operational Explanation
Internal audits verify whether safety and pollution-prevention activities comply with the SMS. Their results feed the Company’s periodic evaluation of SMS effectiveness and management review; follow-up also verifies the effectiveness of corrective action. Auditors must be competent and independent of the area audited, subject to the exception for Company size and nature in para. 12.5; the SMS must make the reasons and objectivity of the arrangement verifiable.
Audits identify deficiencies and trigger risk-proportionate action. A serious hazard requires immediate control: neither the external audit nor the next internal cycle is a reason to wait.
Regulatory Reference
ISM Code, para. 12.1 (text introduced by Res. MSC.273(85), in force since 1 July 2010): the Company shall carry out internal safety audits on board and ashore at intervals not exceeding twelve months; in exceptional circumstances the interval may be exceeded by not more than three months. The interval is therefore a requirement of the Code, not company practice. Para. 12.5 — it was 12.4 until 31 December 2014, res. MSC.353(92) inserted a new 12.2 and renumbered the following paragraphs — requires auditors independent of the area being audited, unless the size and nature of the Company make this impracticable. The exception is part of the rule: where it is used, it is for the SMS to control competence, objectivity and the reason for the arrangement.
Base text and amendments: IMO ISM · MSC.353(92) · MSC-MEPC.7/Circ.8.
Follow-up also engages sections 12.6–12.7: communicate results to those responsible for the area concerned and ensure timely corrective action by responsible management. Circ.8, section 7, includes reporting, distribution and follow-up among audit procedure elements.
Scope of Application
For activities covered by the SMS, schedule shipboard and shore audits within twelve months. Section 12.1 permits at most three additional months in exceptional circumstances: this is not a routine fifteen-month interval. Document circumstances and rescheduling under the SMS and check applicable flag instructions; commercial convenience alone does not establish exceptionality.
Procedure / How to Complete It
- Plan audits on board and ashore within §12.1 intervals, covering the SMS.
- Assign competent auditors independent of the area; document any §12.5 exception and objectivity safeguards.
- Collect evidence through records, interviews and observation of activities.
- Record the requirement, evidence and finding; assign an owner, immediate action where necessary and proportionate deadlines.
- Communicate findings to responsible personnel and Company evaluation.
- Monitor CAPAs and delays at assigned deadlines; verify implementation and effectiveness without waiting for the next audit.
Practical Example
Learning example: two NCs concern missing maintenance evidence. The report distinguishes the requirement, observed situation and risk; it assigns justified actions and deadlines, with immediate containment where necessary. An illustrative 30-day period is not a universal ISM deadline. The Code defines NC and major NC, not a separate definition of ‘minor NC’.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Independence not assessed and no justification of a §12.5 exception | Objectivity not demonstrated | Independent auditor or justified exception with safeguards |
| Checking document presence alone | Implementation not verified | Add interviews and observation |
| Follow-up deferred to the next audit | Overdue actions and continuing risk | Assigned deadlines, verification and escalation |
What the PSCO Checks
Operational Tips
- Schedule internal audits spread across the year, not concentrated just before the external audit.
- Train internal auditors in interview techniques and root cause analysis, not just document checklists.
- Use the aggregated results of internal audits as a primary input for the Management Review.
Preparation checklist
Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.
- Ship and shore audits scheduled within required intervals
- Competence, independence or justification of the §12.5 exception documented
- Records, interviews and observation included
- Requirement and severity assessed for each NC
- CAPA owners, deadlines, implementation and effectiveness monitored
FAQ
Related Topics
Last substantive revision of this page: 15 September 2026 · page fingerprint 1a3b5f9752d4