By IJ Arora, Ph.D.

In my work with maritime clients, I take pride in emphasizing my personal career perspective from both below and above the surface of the world’s oceans. My view of the International Safety Management (ISM) Code has been shaped by a life at sea.

I spent good 22 years of the early part of my career in the Indian Navy, eventually commanding two F-class submarines and later serving on India’s first nuclear submarine. After leaving the service, I served for a decade as master in the mercantile marine. I then spent three years as vice president for the Liberian Registry, the second-largest ship registry in the world. I am currently the leader of the QMII team.

My view of safety management systems

During that time, I have seen safety management systems (SMS) from the control room of a submarine and from the bridge of a merchant ship, in fair weather and during crises. These experiences have convinced me that an SMS only works when it is lived by the people who must make decisions in real time, far from shore support.

I still remember standing on the bridge of a merchant vessel, facing commercial pressure to sail on schedule although weather and equipment concerns suggested otherwise. The manuals and procedures were on board, but what mattered at that moment was whether the company truly backed me and my judgment. That is where the real test of any SMS lies—not in what is written, but in the support given when difficult decisions must be made.

Having sailed for many years, I know how isolating a tough decision at sea can feel. A good, designated person ashore (DPA) is not just a name in the manual but a trusted voice on the other end of the line, someone the master can call at 0200 hours and speak with openly. When that relationship exists, the SMS becomes real; when it doesn’t, the paperwork quickly loses relevance on board.

After a lifetime at sea and many years working ashore with companies to implement the ISM Code, and finally leading QMII for more than two decades in training, auditing, and consulting on management systems, I remain convinced of one thing: the ISM Code itself is not the problem. The real issue is whether we choose to make the SMS a living system that respects the realities of those at sea. When shore and ship learn to listen to each other through the SMS, we honor not just compliance requirements, but the professionalism and lives of the people who sail our ships.

Who is the system for?

More than 25 years after the ISM Code became mandatory, it is still too often treated as merely a paper exercise. Shore offices produce manuals, checklists, and forms; ships receive them, file them, and do their best to keep up. The result is a familiar complaint from both sides: “The system is for auditors, not for us.”

Yet the ISM Code was never intended to create a paperwork gap between shore and ship. It was meant to bridge that gap by providing a common safety language and a shared framework for decision making. When understood and implemented as a living system, the SMS becomes exactly that bridge. I always recollect the curt observation by Justice Sheen following the 1987 sinking of the Herald of Free Enterprise: “I see a disease of sloppiness at every level of the hierarchy.” His direct pointer at the absolute need for a robust management system brought us the ISM Code connecting to the Safety of Life at Sea (SOLAS) treaty.

The ISM Code’s original intent was to have a system that connects people. The ISM Code’s purpose is clear: To provide an international standard for the safe management and operation of ships and to prevent pollution. The Code defines the SMS as a structured and documented system enabling company personnel to effectively implement the company’s safety and environmental protection policies.  From the beginning, the Code placed both shore and ship within the same system. Company objectives in section 1.2 of the ISM Code include:

• Providing safe practices in ship operation and a safe working environment
• Assessing risks to ships, personnel, and the environment and establishing safeguards
• Continuously improving safety management skills of personnel ashore and aboard ships

These are not separate objectives for two separate worlds. They are shared obligations, achievable only when the SMS genuinely links the office and the vessel.

Minding the gap

So where then does the gap come from? Despite the best of intentions, many organizations experience a shore-ship divide in their SMS:

• On shore, staff may focus on satisfying external auditors, producing beautifully formatted procedures that look good in a DOC audit but are hard to use in real operations.
• On board, crews often experience the SMS as extra work: duplicative checklists, complex forms, and procedures that do not reflect the realities of weather, port pressure, and human limitations.

When this happens, several symptoms appear:

• “Cut-and-paste” risk assessments that no one believes in.
• Nonconformities written in audit language instead of operational language.
• Masters and DPAs communicating mainly for certification, not for learning.

The result is an SMS that is formally compliant but functionally weak—it exists on paper but not in daily decision making. The SMS must be a living system. To bridge the gap, we must return to the simple idea that the SMS is not a manual. It is the way the organization manages risk and work, documented so it can be repeated, audited, and improved. A living system has several characteristics:

• It is owned by users, not by paperwork. Procedures and checklists are written in the language of the people who use them. Crew and shore staff participate in their development and revision. Guidance documents are concise, operational, and easy to find.
• It is fed by real feedback. The ISM Code requires procedures for reporting accidents and nonconformities, and for internal audits and management reviews as functional elements of the SMS. In a living system, these are not compliance rituals but mechanisms for learning. Near misses, hazardous observations, and suggestions for improvement from the crew are actively encouraged, analyzed, and acted upon.
• It is adaptable, not frozen.  Clause 12 of the ISM Code calls for review and evaluation of the SMS. A living SMS changes in response to new risks, technology, trade patterns, and lessons learned. Revision is continuous, not something done hurriedly before an audit.
• It includes transparent roles and communication. The ISM Code requires defined levels of authority and lines of communication between shore and shipboard personnel. In a living system, these lines are not just organograms—they are trusted relationships. Masters feel supported, not second-guessed. The DPA is accessible, respected and known by name, not just as a title in the manual.

The DPA, then, should be the human bridge. Perhaps the most powerful bridging mechanism in the ISM Code is the requirement, seen in clause 4, that every company designate a person or persons ashore with direct access to the highest level of management.

Unfortunately, in many organizations the DPA becomes either a paper coordinator, chasing signatures and tracking audits, or a firefighter, reacting to incidents and findings.

To make the SMS a living system, the DPA must instead function as a system integrator. That means:

• Listening systematically to ship feedback and ensuring it reaches senior management.
• Challenging shore practices that create unrealistic demands on ships.
• Ensuring that risk assessments and procedures reflect actual operations, not office assumptions.
• Facilitating honest discussions after incidents—not searching for blame but for system weaknesses.

In short, the DPA should be the voice of the ship in the boardroom and the voice of the system on the ship.

A way forward

Maritime companies should plan practical steps to bridge the shore-ship gap. Companies that wish to transform a static SMS into a living one can take several practical steps to co-create procedures with ship staff by involving the masters, officers, and ratings when developing or revising procedures.

I call this capturing the “as-is” of the system in preference to throwing the ‘baby out with the bath water” by simply adopting a template. Pilot new checklists on board before formal approval. Ask: “Does this help you do the job safely under time pressure?” If not, redesign. Management systems are not etched in stone. They should be open, flexible, and adaptable to change.

Train to be competent and for understanding, not just for compliance. Move beyond “read and sign” familiarization. Use case studies, incident reviews, and simulations that connect ISM clauses with real operational dilemmas. Emphasize why a procedure exists, not just how to follow it.

Most importantly, simplify and prioritize. The ISM Code specifies functional requirements, not thickness of manuals. Focus on critical operations and major risks; remove redundant or overlapping forms. A smaller, well-used SMS is better than a massive, ignored one.

At the same time, strengthen feedback loops. Make incident and near-miss reporting simple and non-punitive. Provide feedback to the crew on what was learned and what changed as a result. When people see that speaking up leads to improvement, not punishment, the system comes alive.

Remember, data drives an understanding of risk and trendlines and makes an organization proactive. Use data—and stories. Combine quantitative indicators (i.e., deficiencies, delays, and injuries) with qualitative insights (i.e., crew narratives and master’s reviews). This blended view gives a more complete picture of safety performance and culture.

A change from compliance culture to learning culture must be brought in to create an environment for quality, safety, security and continual improvement. Port State Control statistics show that ISM-related deficiencies remain among the most frequently reported issues worldwide. This suggests that many SMSs still operate at a minimum compliance level. Bridging the shore-ship gap means moving toward a learning culture, where:

• Deviations are signals to improve the system, not just to correct the individual.
• Masters are empowered to exercise their overriding authority and supported by the shore organization with resources on an as-needed basis.
• Top management sees the SMS not as a cost, but as an asset that protects people, ships, reputation, and the marine environment.

In conclusion, I would repeat that making the ISM Code work as intended is the need. It is not just talk, but walking the talk. The ISM Code gave the maritime industry a powerful framework. It defined objectives, clarified responsibilities, and required an SMS that connects shore and ship. The challenge now is not to “comply” with the Code, but to realize its intent.

When the SMS is treated as a living system—owned by its users, nourished by feedback, continually adapted, and genuinely connecting shore and ship—it becomes what the ISM Code envisioned:

• A bridge between management and operations
• A driver of safety and environmental protection
• A practical expression of the company’s values at sea and ashore

The choice is ours: an SMS that exists for certification, or an SMS that saves lives, protects the environment, and unites shore and ship in a common purpose.

About the author

Inderjit (IJ) Arora, Ph.D., is the Chairman of QMII. He serves as a team leader for consulting, advising, auditing, and training regarding management systems. He has conducted many courses for the United States Coast Guard and is a popular speaker at several universities and forums on management systems. Arora is a Master Mariner who holds a Ph.D., a master’s degree, an MBA, and has a 34-year record of achievement in the military, mercantile marine, and civilian industry.