International Safety Management (ISM) Code: Yachts Have Some Catching Up to Do

Giuseppe Corrado

Giuseppe Corrado

Riela Yachts Safety & Compliance Manager

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I first joined the yachting industry five years ago after several years at sea onboard cruise ships. Initially, I could not understand why many of the international conventions and regulations I previously worked, lived by and was required to follow did not apply to privately registered yachts. This included the International Safety Management (ISM) Code.

During my deep-sea career, ISM was a fundamental part of daily life. Having experienced the benefits of the ISM Code first-hand, I am surprised that the same standards do not apply to many yachts. In my opinion, if the yachting industry wants to be recognised as a professional area within the wider maritime sector, with regards to safety management, we have some catching up to do.

The Private Problem

Being privately registered, yachts are presented with the choice of complying with the ISM Code, but it is not mandatory. A sizeable portion of privately registered yachts choose not to comply on a voluntary basis and so are not supported by a shore-based ISM company or have an allocated Designated Person Ashore (DPA) and his or her team of safety and compliance specialists.

Find out more about the roles of a Designated Person Ashore (DPA) here.

However, it is encouraging to see that despite compliance being non-mandatory for privately registered yachts, more and more are deciding to do so voluntarily.

But why should yachts comply with the ISM Code in the first place? Why should more, if not all, privately registered yachts comply with the ISM Code (over 500GT or over 300GT)?

Man shrugging his shoulders looking confused

The ISM Code and The Benefits of Compliance

Full disclosure, the benefit of ISM compliance is challenging to objectively and accurately measure. This is in part a result of the disproportionate number of vessels now complying in comparison to when the ISM Code was first introduced in 1997. Since then, the total number of vessels sailing and operating today under the ISM Code has more than doubled. An argument could be made that despite this increase in fleet size, the number of marine safety incidents has not increased at same rate. However, this simple analysis cannot reflect upon the effectiveness of the ISM Code as a whole.

The International Maritime Organization (IMO), back in 2005, published an assessment of the impact and effectiveness of the implementation of the ISM Code and the conclusion was: “Based on the data collected, the group concluded that where the ISM Code had been embraced as a positive step toward efficiency through a safety culture, tangible positive benefits were evident” .

In yachting, a common path to yacht Ownership stems from chartering. Future Owners start their experience onboard yachts that are commercially registered which are therefore yachts that must comply with the ISM Code. As a reminder, ISM Compliance is mandatory for yachts that are:

  • 500GT or carrying more than 12 passengers must enable a Full ISM SMS system
  • Less than 500GT carrying less than 12 passengers must implement a mini-ISM SMS system as required by the yacht’s Flag State.

So, the question is, are Owner’s aware that when using chartering as a stepping stone or testing ground for yacht ownership they are benefiting from safety standards which may not be necessary replicated on their private yachts?

Based on my experience, yacht owners may sometimes be unaware of this and the pivotal role of senior officers in maintaining those standards on private yachts cannot be underestimated.

The SMS of private yachts are commonly developed ‘in-house’ without seeking the support of safety and compliance specialists or obtaining Flag State certification voluntarily. As a result, these ‘in-house’ SMS systems do not receive the benefit which arises from external verification of the system’s effectiveness. I view this approach as a ticking time-bomb. An accident waiting to happen. Shortfalls will only come to light when it is too late.

An Industry Leader... or Not?

In areas such as technology, innovation and design, the yachting industry is (nautical) miles ahead in terms of leading industry standards. However, when it comes to safety management, this statement is far from true.

During my career at sea, I have been fortunate to experience a harmonisation of safety management systems at a corporate level. This meant any areas of the system which could have been improved was changed based on lessons learned, as well as experience gained by other companies and vessels within the same corporation. The changes applied at the time helped me understand the significant positive impact of a Safety Management System (SMS). Constant review by several different Flag States, Companies, Captains and Crew led to regular improvements compared to any other systems which do not benefit from the same widespread review and input.

A core objective of the ISM Code is to reduce the high proportion of maritime accidents attributable to human error. Therefore, greater participation and effective compliance with the ISM Code will undoubtedly achieve a much safer industry for our Crew, Owner’s, and their guests to enjoy their time aboard. None of us want to see accidents or fatalities due to a lack of oversight, accountability, or the ability to learn from the accidents and mistakes of others.

Unfortunately, due to several different factors there seem to be yachts operating their very own Safety Management Systems (SMS ) or in some cases, none at all. Whether or not external support is required, there is undoubtedly some catching up to do compared to the rest of the maritime industry. For me, it can only start with uniform participation in ISM compliance and external verification of the safety management activities across the yachting sector.

Why not make scalable ISM compliance mandatory for all private or commercially registered over 300GT? Or 200GT? What do you think? Would the yachting sector be safer? Would the costs deter smaller yacht Owners from becoming yacht Owners?

ISM: Steps to Success

If you are a privately registered yacht using an in-house Safety Management System or just a small collection of onboard procedures, I would suggest you first engage with safety and compliance specialists. The likelihood is the in-house Safety Management System (SMS) has not been inspected externally or received a thorough inspection or audit in the past 12 months. Maritime safety and compliance specialists can then arrange internal audits and conduct a GAP analysis against the ISM standards to ensure the SMS is fit for purpose and compliant with the functional objectives of the ISM Code.

As with any audit or inspection, there will likely be areas identified that can benefit from more detail or improvement.

After an internal audit or GAP analysis, the Safety Management System (SMS) can then be developed further with the results of the internal audit until an ISM Company and DPA are appointed. An “Interim Audit” may be requested by the yacht’s Flag Administration. An interim flag audit would be the first step towards voluntary compliance and the achievement of full-term certification. This commitment speaks to the crew and the industry that despite not having a mandate to comply, the beginning of a continuous improvement process has begun with the aims of embracing the highest standards of maritime safety.

The yachting industry is one of a kind. I feel lucky having met large volumes of extraordinary professionals over the years. The industry is full of visionary characters who make yachting one of the leading industries of innovation. However, if we want yachting to become a true industry-leader, safety is where innovation is required.

Written by our Deputy DPA, Giuseppe Corrado. Connect with him on LinkedIn and continue the conversation here.

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