Operational guide · SMS process

Management Review

The periodic evaluation through which the Company checks SMS effectiveness and decides how to improve resources, procedures and results.

ISM CodeManagement Reviewtop managementSMS

Operational Explanation

The Management Review is the periodic assessment of the continuing adequacy and effectiveness of the Safety Management System, which the ISM Code assigns to the Company (§12.3). 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?

§12.3 assigns evaluation to the Company under its established procedures. Format, delegations and participants depend on Company arrangements: documented evaluation, effective decisions and access to resource decision-makers matter, not a meeting with Code-prescribed attendees.

Regulatory Reference

ISM Code, par. 1.4 (Functional Requirements) and par. 12 (Company Verification, Review and Evaluation). The specific provision is §12.3: “The Company should periodically evaluate the effectiveness of the SMS in accordance with procedures established by the Company”.

Two points, on the number and on the words, because both circulate wrongly. On the number: until 31 December 2014 this provision was §12.2; resolution MSC.353(92), in force from 1 January 2015, inserted a new §12.2 on verifying delegated ISM tasks and renumbered the paragraphs that followed. Anyone still citing §12.2 for the effectiveness of the SMS is reading a text that expired more than ten years ago.

Section 12.3 assigns review to the Company without prescribing an attendee list. Preamble paragraph 6 emphasizes leadership commitment, and section 4 requires the DPA’s direct access to the highest management level. Define responsibilities, delegations and involvement of resource decision-makers in the SMS, and verify implementation rather than focusing on whether a particular phrase appears in the Code.

For inputs and the Master’s review: MSC-MEPC.7/Circ.8 · MSC.273(85).

Scope of Application

For Companies subject to ISM, section 12.3 requires periodic evaluation under Company procedures, without a universal annual interval. MSC-MEPC.7/Circ.8, paragraph 5.2, recommends review also when needed, for example following serious system failures. The DOC/SMC verification schedule is separate and does not replace this evaluation.

Procedure / How to Complete It

Collect audits, NCs/CAPAs, events, inspections, complaints and periodic Master’s reviews, including SMS deficiencies reported ashore (§5.1.5).
Evaluate effectiveness, risks, resources and trends under Company procedures, with appropriate delegations and input.
Record decisions and resource requests, engaging the level authorised to approve them.
Assign an owner and deadline to each action and communicate relevant outcomes to the ship.
Monitor implementation at deadlines and address delays; the next review evaluates outcomes but does not replace follow-up.

Practical Example

Learning example: audits and Master’s reviews identify overdue maintenance on two ships. The Company evaluates causes, personnel and spare-part availability, approves resources and assigns owners and deadline checks. Minutes or another SMS-defined record capture decisions and follow-up. If ‘minor NC’ is used, clarify that the Code defines NC and major NC, not a separate minor category.

What Typically Goes Wrong

A completed form without evaluation evidence does not demonstrate compliance with §12.3. The problem is not the absence of a meeting or named attendee: it is missing analysis, decisions and follow-up under the SMS.

Common Mistakes Mistake Library

Mistake	Consequence	How to avoid it
Review without evidence of evaluation	SMS effectiveness not demonstrated	Document inputs, analysis, decisions and follow-up under the procedure
Event counts alone	Causes and recurrences overlooked	Assess trends and operating context
Actions without owner or deadline	Decisions not implemented	Deadline monitoring and escalation

What the PSCO Checks

PSC inspects the ship and may examine relevant SMS implementation evidence, including actions and ship-shore communications. Company review falls within ISM verification according to the auditor’s mandate. Make relevant outcomes and action follow-up available on board; any vetting requests depend on the applicable programme.

Operational Tips

Combine Master’s reviews with shore findings.
Document responsibilities and decision approval without imposing a single format.
Provide shipboard feedback and verify actions at deadlines.

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.

Inputs include periodic Master’s reviews
Evaluation follows Company procedures and delegations
Trends, resources and risks assessed
Decisions and approvals documented
Owners, deadlines, follow-up and feedback to ships

FAQ

How often?

Periodically under Company procedures; §12.3 sets no universal annual interval.

Can the DPA lead it?

The DPA may coordinate or lead it where Company arrangements provide for this. Company responsibility, appropriate delegation, necessary input and authorised decisions remain; there is no universal attendee list.

How does it relate to an audit?

Audits verify the SMS; review periodically evaluates its overall effectiveness. Audit results are inputs, not a substitute for review.

Management Review

Operational Explanation

Regulatory Reference

Scope of Application

Procedure / How to Complete It

Practical Example

What Typically Goes Wrong

Common Mistakes Mistake Library

What the PSCO Checks

Operational Tips

Preparation checklist

FAQ

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