External ISM audits and non-conformities
1The lesson in plain words
The flag, usually through a recognised organisation (RO), audits the company and each ship. Deal with major non-conformities before sailing.
Who audits
The International Safety Management (ISM) Code (SOLAS chapter IX) requires the company to run a safety management system (SMS). The flag, often through an RO, checks it with external audits. The company holds a Document of Compliance (DOC) listing the ship types its SMS is certified to cover. Each ship holds a Safety Management Certificate (SMC), with a copy of the DOC on board. See Safety management for the SMS, the designated person ashore (DPA) and internal audits.
Audit types
Interim certification supports a new company or ship while its SMS is implemented. An interim DOC lasts 12 months; an interim SMC lasts six months, extendable by six in special cases. An initial audit then verifies implementation for full certification. DOC verification is annual, within ±3 months of the anniversary. SMC intermediate verification is between the second and third anniversaries. Renewal is every five years. Additional audits may follow detention, serious casualties or major non-conformities.
Findings
An observation is a recorded fact supported by objective evidence; it need not indicate a failure to meet a requirement. A non-conformity (NC) is a requirement not met, with objective evidence. It needs corrective action within an agreed time, usually up to three months. A major non-conformity is a serious threat to people, the ship or the environment that needs immediate action. It also covers a lack of effective, systematic implementation of an ISM requirement.
A major NC
Before sailing, the auditor must downgrade the major NC to an ordinary NC. Immediate action must remove the danger, and the auditor must accept a plan for the remaining corrective work. The NC stays open until that work is completed. An additional audit must follow within three months to verify effective corrective action. If the major NC cannot be downgraded, the SMC can be withdrawn and the ship cannot trade. A major NC at the office can put the DOC, and so every ship's SMC, at risk.
The master's role
On audit day, show the system as it really works. The auditor looks at records, drills, maintenance and how the crew follow procedures. Answer accurately, check the evidence for each finding and record any disagreement at the closing meeting. Make sure root causes are found, not only symptoms. The master's review of the SMS reported to the company is often checked too.
2Key data
- Interim DOC
- 12 months
- Interim SMC
- 6 months, extendable 6 in special cases
- DOC verification
- Annual, within ±3 months of the anniversary
- SMC verification
- Intermediate, between 2nd and 3rd anniversary
- Full DOC and SMC
- 5 years
3Key points
- 1
The flag or its RO audits the company (DOC) and each ship (SMC).
- 2
Interim DOC: 12 months. Interim SMC: 6 months; only the flag may approve another 6 in special cases.
- 3
DOC annual verification; SMC intermediate between the 2nd and 3rd anniversary.
- 4
A major NC on a ship must be downgraded before she sails.
4Frequent mistakes
Wrong: A non-conformity found at audit can wait until the next audit.
Right: It needs corrective action within the agreed time, usually up to three months, with evidence sent to the auditor.
Wrong: An observation is just a minor non-conformity.
Right: An observation is a recorded fact supported by evidence. An NC means a requirement is not met.
5Practice case & exam keys
At an intermediate SMC audit the auditor finds that the emergency fire pump has not been tested for four months and two crew cannot start it. The SMS says weekly tests. He calls it a major non-conformity. The ship is due to sail in six hours. What must happen?
Show the answer
The ship cannot sail with an open major NC. Test the pump now, train the crew to start it and record it. Show the auditor this immediate action and a plan to find why tests stopped, such as the planned maintenance or the rest-hour pressure. If he accepts, he downgrades it to an NC with a deadline and the ship sails. Report to the DPA. Arrange that additional audit within three months.
Exam keys
- External audits: initial, annual DOC, intermediate SMC, renewal, additional.
- Interim DOC 12 months; interim SMC 6 months (+6 in special cases).
- Observation, non-conformity, major non-conformity.
- Major NC: immediate action and downgrading before sailing.
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