An effective safety management system should help a master make a sound decision during a difficult operation. It should also help the office understand why that decision was necessary. The International Safety Management Code provides a framework for that relationship: assess risks, establish safeguards, support the ship and learn from what happens. Compliance becomes fragile when the system exists mainly as a collection of certificates or procedures that nobody can readily use.

For Indian ship owners, the starting point is to establish which flag, vessel type, trading pattern and statutory requirements apply. This guide describes an operational approach rather than a substitute for current flag administration instructions. It is particularly relevant when an owner appoints a company to provide technical and crew management.

1. Define the company and its responsibilities

Confirm which entity has assumed responsibility for operating the ship under the ISM Code. Record the division of duties between owner, technical manager, crew manager and commercial team. A contract may allocate tasks, but the safety management system must make the practical reporting route clear to the people doing the work.

Document the master’s authority, including the overriding authority to take decisions concerning safety and pollution prevention. Identify the designated person ashore, the route to senior management and an alternative contact. Test those arrangements outside normal office hours. A contact list is useful only when the listed people understand what action they are expected to take.

Distinguish the company-level Document of Compliance from the vessel’s Safety Management Certificate. Verify the vessel types covered by the company’s document and the current verification status of both documents. For an Indian-flag operation, confirm the applicable arrangements with the Directorate General of Shipping or the authorised recognised organisation. An Indian owner operating a foreign-flag ship must also address that flag’s requirements. Changes of company, flag or vessel type deserve an early certification review so that commercial handover dates do not run ahead of the necessary verification.

2. Start with a vessel-specific gap assessment

Review the ship against the requirements actually applicable to it. Include certification, maintenance, safe manning, training, navigation, cargo operations, environmental controls and emergency preparedness. Compare the written system with a normal working day on board. Ask an officer to locate a procedure, explain it and show the associated equipment or record.

Prioritise gaps by consequence and exposure, rather than by the order of an audit checklist. An unavailable emergency pump deserves a different response from an outdated office reference. Give every action an owner, an achievable due date and a clear criterion for closure. Where temporary safeguards are necessary, obtain the appropriate technical and statutory advice.

3. Make procedures usable at the point of work

Procedures should reflect the vessel, its equipment and its operating environment. A generic enclosed-space entry form cannot replace identification of the actual space, hazards, isolations, atmosphere testing and rescue arrangements. Similarly, a cargo procedure should connect the ship’s limits to the terminal’s operating requirements.

Check the link between assessment and execution

For a critical task, follow the chain from risk assessment to permit, toolbox talk, supervision and close-out. Check that changes in weather, personnel or equipment trigger a fresh assessment where necessary. The aim is a consistent decision process, not a larger stack of signatures. Crew members should be able to explain when they must stop work and whom they should inform.

4. Connect maintenance to operational risk

Identify equipment and technical systems whose sudden failure could create a hazardous situation. Build appropriate testing, standby arrangements and maintenance into the planned maintenance system. Consider how overdue work is escalated, how defects affect an intended voyage and who can authorise a temporary operating restriction.

Useful maintenance evidence includes the actual condition found, measurements where relevant, parts used and the result of a functional test. A closed job with no supporting detail may conceal uncertainty. Review repeated defects together: several small failures can point to poor spares, an unsuitable interval or a deeper problem with operating conditions.

5. Treat competence as a continuing process

Valid certificates are necessary, but they do not demonstrate familiarity with a particular ship. Verify flag acceptance, role requirements and relevant experience before assignment. After joining, allow time for equipment familiarisation, emergency duties and the company’s reporting arrangements before an individual takes independent responsibility.

Use drills to examine understanding and coordination. Vary the scenario, include realistic communications and debrief the result. A drill report should distinguish what happened from what was intended. Where a crew member needs additional support, agree a specific learning action rather than repeating the same drill without changing the underlying conditions.

6. Make reporting useful and credible

Near misses, non-conformities and hazardous occurrences offer information about the system. Establish a reporting culture in which people can describe operational difficulties accurately. Separate immediate corrective measures from investigation of the causes. Replacing a damaged component may restore service while leaving its failure mechanism unresolved.

Look for organisational contributors such as workload, unclear responsibilities, purchasing decisions or incomplete instructions. Assign corrective actions that address those contributors and check their effectiveness later. If the same finding appears on another vessel, consider whether the response should apply across the fleet rather than only to the ship that reported it.

7. Audit the operation, then review the system

Plan internal audits to examine how the system works, including the connection between ship and shore. Select samples that follow complete processes: a defect through repair, a purchase through installation, or a new crew member through familiarisation. Preserve auditor independence as required and give findings enough context for a manager to act.

Management review should bring together audit findings, incidents, maintenance trends, training needs and resource decisions. Record the decisions, responsible people and follow-up dates. Certification audits are milestones within this process; they do not replace continuous supervision. Confirm survey and verification arrangements with the relevant recognised organisation and administration.

A practical owner review before the next voyage

Owners can use these questions to structure a discussion with their manager. The most valuable result is clarity: what is safe to do, what needs attention and who will provide the necessary support. Explore Lilly Maritime’s ship management service scope when preparing that discussion.