SOLAS Chapter IX · ISM Code & DPA

ISM Internal Audit & DPA Checklist: Elements 1–16, SMC/DOC Windows & PSC Readiness

The International Safety Management (ISM) Code (SOLAS Chapter IX, IMO Resolution A.741(18) as amended, and IMO Resolution A.1188(33) 2023 Implementation Guidelines) is the backbone of every shipboard inspection. Whether you are preparing for your annual Company Internal Audit, an external SMC Intermediate or Renewal Verification by Flag/RO, a DPA or Superintendent vessel visit, or defending against an ISM-related Port State Control deficiency under IMO Resolution A.1206(34), auditors test whether the ship’s daily operations actually match what is written in the Safety Management System (SMS).

This guide covers all 16 Elements of the ISM Code (Parts A & B), the 12-month internal audit and SMC/DOC verification windows, Master’s overriding authority (Section 5), Critical Equipment (Section 10.3), and a complete pre-audit document and walkthrough checklist.

Updated 22 October 2026 · Written by SeaReady in our own words. Not affiliated with OCIMF, RightShip, CDI, any MoU or any administration — always check the current official documents.

1. The 16 Elements of the ISM Code (Parts A & B)

Every ISM internal audit and external SMC verification is structured around Part A (Implementation — Elements 1 to 12) and Part B (Certification and Verification — Elements 13 to 16) of the ISM Code:

ISM Code Parts A and B (Elements 1–16) under SOLAS Chapter IX and IMO Resolution A.741(18) as amended.
ISM Element	Title	What Auditors, DPAs & PSCOs Verify on Board
Elements 1–3	General, Safety & Environmental Policy, Company Responsibilities	Company safety and environmental protection policy signed by senior management, posted on board and understood by crew; clear ashore/onboard responsibility and resource allocation.
Element 4	Designated Person(s) Ashore (DPA)	A person or persons ashore having direct access to the highest level of management, responsible for monitoring the safety and pollution-prevention aspects of each ship and ensuring adequate resources and shore-based support are applied.
Element 5	Master’s Responsibility and Authority	Clear statement of the Master’s overriding authority and responsibility to make decisions with respect to safety and pollution prevention and to request the Company’s assistance; Master’s periodic (at least annual) review of the SMS with deficiencies reported ashore.
Element 6	Resources and Personnel (incl. Cyber Risk & Bullying/Harassment)	Master properly qualified and fully conversant with the SMS; ship manned with qualified, certificated and medically fit seafarers; pre-sailing familiarisation with essential duties; training and human-factors / cyber-risk management (IMO Res. MSC.428(98)).
Element 7	Shipboard Operations	Documented procedures, plans and checklists for key shipboard operations concerning the safety of the personnel, ship and protection of the environment (navigation, cargo, bunkering, mooring, enclosed space entry, hot work, working aloft).
Element 8	Emergency Preparedness	Identification of potential emergency shipboard situations, established drill and exercise programmes (SOLAS III/19, MARPOL SOPEP/SMPEP, steering gear, enclosed space rescue, cyber incident), and 24/7 Company emergency response capability.
Element 9	Reports and Analysis of Non-Conformities, Accidents and Hazardous Occurrences	Reporting, investigation and Root Cause Analysis (RCA) of every non-conformity, accident and near-miss (hazardous occurrence), with documented corrective and preventive actions verified for effectiveness.
Element 10	Maintenance of the Ship and Equipment (incl. Critical Equipment)	Planned maintenance inspections at appropriate intervals, reporting of any known non-conformity, corrective action records, and specific measures (standby arrangements, spares, regular testing) for equipment whose sudden operational failure may result in hazardous situations (Critical Equipment).
Element 11	Documentation	Document control ensuring valid, current SMS manuals, forms, checklists, statutory certificates and onboard publications are available at all relevant locations and obsolete documents are promptly removed.
Element 12	Company Verification, Review and Evaluation (Internal Audits)	Internal safety audits on board and ashore at intervals not exceeding 12 months (extendable by not more than 3 months in exceptional circumstances) by auditors independent of the areas being audited, plus periodic management review of SMS effectiveness.
Elements 13–16 (Part B)	Certification and Verification (DOC, SMC, Interim Certificates — IMO Res. A.1188(33))	Document of Compliance (DOC — 5-year validity, subject to annual verification within ±3 months of anniversary date); Safety Management Certificate (SMC — 5-year validity, subject to one intermediate verification between the 2nd and 3rd anniversary dates); non-conformity 3-month corrective-action window and major non-conformity downgrade rules under IMO Res. A.1188(33) §§ 4.14.2 & 4.15.3 and MSC/Circ.1059–MEPC/Circ.401.

2. Pre-Audit Document & Record Verification Checklist

Before the internal auditor, DPA or Recognised Organisation (RO) surveyor boards the vessel, verify these six core ISM document groups on the bridge and in the ship’s office:

Master and DPA pre-audit verification checklist for ISM internal and external SMC audits.
Document / Record Group	ISM Reference	Mandatory Verification Check
DOC & SMC Certificates	ISM Code §§ 13–14	Original SMC on board with intermediate endorsement (if past 3rd anniversary); copy of the Company’s DOC on board matching the ship type on the SMC and carrying the latest annual verification endorsement.
Master’s SMS Review	ISM Code § 5.1.5 & § 12.2	Documented Master’s review of the Safety Management System within the last 12 months, together with the Company/DPA’s written feedback and action items.
Internal Audit Report & Close-Out	ISM Code § 12.1	Last onboard internal ISM audit conducted within 12 months (or ≤ 15 months with documented exceptional Flag/Company extension), auditor independence verified, and all non-conformities closed with Root Cause Analysis (RCA) or tracked within their agreed due dates.
Pre-Departure Familiarisation & Handover	ISM Code §§ 6.2–6.3 & STCW Reg. I/14	Signed pre-sailing SOLAS/SMS familiarisation checklists for every newly joined crew member and signed handover notes for senior officers and engineers.
Critical Equipment & Standby Systems	ISM Code §§ 10.3–10.4	Written list of Critical Equipment and Systems (steering gear, emergency generator, emergency fire pump, OWS, GMDSS, main engine safety trips, bridge radars/ECDIS), regular functional test logs, and minimum critical spare parts inventory verified.
Near-Miss, Safety Committee & Permit to Work Records	ISM Code §§ 7, 9	Monthly Safety Committee meeting minutes signed by Master and safety representatives; near-miss reports analysed with corrective feedback; completed Permits to Work (enclosed space, hot work, working aloft/overside, LOTO) cross-checked against deck/engine logbooks.

3. How to prevent technical defects from escalating into an ISM Code 30 Detention

Under IMO Resolution A.1206(34) Appendix 8 and the Paris/Tokyo MOU ISM guidelines, the fastest way to suffer a Code 30 PSC detention or an Action Code 18 (additional external audit within 3 months) is to have undocumented defects sitting on board at arrival:

Log every known defect under ISM Element 10 BEFORE arrival: If a piece of equipment breaks down at sea or before entering port, immediately open a defect/non-conformity report in the SMS (and SeaReady’s Findings tracker), implement a documented risk assessment and temporary mitigating measure, order the spare part or shore service with requisition evidence, and notify the DPA/Flag/RO and Port State Authority before arrival where required. An unlogged defect discovered by a PSCO is treated as evidence that the SMS maintenance and reporting system (Elements 9 & 10) is not working.
Cross-check Permits to Work against deck and engine logbooks: Auditors routinely pick a recent enclosed space entry, hot work job or bunker operation from the Deck/Engine Logbook or Oil Record Book and ask to see the matching signed Permit to Work, gas-test log, toolbox talk and Risk Assessment from that exact date and time.
Verify Root Cause Analysis (RCA) depth on closed findings: Never close a non-conformity or accident report with “crew error — warned officer” as the root cause. Auditors check that the investigation identified the underlying systemic factor (procedural gap, equipment design, workload/rest hours, training/familiarisation) and verified that the corrective action prevented recurrence.

Questions seafarers ask

How often must an onboard ISM Internal Audit be carried out under ISM Code Section 12.1?

Under ISM Code Section 12.1, the Company must carry out internal safety audits on board and ashore at intervals not exceeding 12 months to verify whether safety and pollution-prevention activities comply with the Safety Management System. In exceptional circumstances (such as prolonged lack of port access), this 12-month interval may be exceeded by not more than 3 months (up to 15 months maximum), provided the justification and authorisation are documented under the SMS.

What is the difference between the Document of Compliance (DOC) and the Safety Management Certificate (SMC) survey windows?

The Document of Compliance (DOC) is issued to the Company for specific ship types and is valid for 5 years, subject to mandatory Annual Verification within 3 months before or after each anniversary date (the ship carries a copy of the endorsed DOC, not the original). The Safety Management Certificate (SMC) is issued to the individual ship for 5 years and requires at least one Intermediate Verification, which must take place between the second and third anniversary dates of the SMC (the ship must carry the original SMC on board).

When can a Port State Control officer raise an ISM deficiency or detain a ship on ISM grounds?

Under IMO Resolution A.1206(34) Appendix 8 (Guidelines for Port State Control Officers on the ISM Code), a PSCO does not perform a full ISM audit during a routine PSC inspection. Instead, when technical or operational deficiencies are found under SOLAS, MARPOL, STCW or MLC, the PSCO evaluates whether those hardware/operational defects individually or collectively indicate that the Safety Management System is failing on board. Multiple serious technical deficiencies (for example, inoperative fire dampers, uncalibrated gas detectors and unlogged OWS failures) frequently trigger an additional ISM-related deficiency (Action Code 18 — complete an additional external ISM audit within 3 months, or Action Code 30 — detention).

What must every crew member know if an auditor or PSCO asks about the DPA?

Every seafarer on board must be able to point to the posted DPA contact notice and state the name and 24/7 contact details of the Designated Person Ashore (DPA) and alternate DPA, explain that the DPA provides a direct link between the ship and the highest level of company management for safety and pollution prevention, and confirm that any crew member can contact the DPA confidentially if a safety concern is not resolved on board.

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