What the ISM Code asks
Section 12 of the ISM Code asks the company to carry out internal safety audits on board and ashore, to check that safety and pollution prevention activities follow the safety management system and to judge whether the system works.
- Every ship, at least every 12 months. In exceptional circumstances the interval may be extended by up to three months.
- Independent auditors. The people who audit should not be responsible for the area they audit, unless the company is too small for that.
- Documented procedures. The company writes down how audits are planned, carried out and reported.
- Results go to the people responsible. They take timely corrective action on what was found.
The internal audit is also what the flag or the class looks at during the external DOC and SMC audits. A ship with a good internal audit record rarely has surprises there.
Before the ship visit
- Agree the date and the port with the master. Allow enough time alongside: a full audit usually needs a day on board.
- Read the history. The last internal and external audit reports, open findings, recent Port State Control and class reports, incidents and near misses.
- Choose what to look at more closely. Areas with repeated findings, a new master or chief engineer, a recent incident, overdue maintenance.
- Prepare the checklist from the company's own procedures, not a generic list. The audit checks the ship against its own system.
- Send the plan to the master: the date, the areas, the people the auditor wants to talk to and the records to have ready.
On board
- Opening meeting with the master and the heads of department: the plan, the timing, how findings will be reported.
- Records: take a sample and check it against what the procedure asks. Not every entry, but enough to see a pattern.
- Interviews: ask the crew to show, not to tell. "Show me how you test the emergency generator" says more than "do you test it?".
- Walk round: the engine room, the steering gear, the bridge, the lifesaving and firefighting equipment. Compare what is in the records with what is on board.
- A drill, if the schedule allows it.
- Closing meeting: every finding read out and agreed with the master before the auditor leaves. Nothing new should appear later in the report.
What to sample
| Area | Records to sample | What to look for |
|---|---|---|
| Familiarisation and training | Records of the last crew joined | Done before duties started, signed, for every new person |
| Drills | Drill records of the last three months | Done at the intervals required, with participants and remarks |
| Maintenance | The maintenance plan and the job records | Overdue jobs, jobs closed without a record, postponed jobs with a reason |
| Critical equipment | Test records of standby equipment | Tests at the set interval, with a result, not only a signature |
| Certificates and surveys | Certificates on board and survey dates | Valid originals, endorsements done, nothing about to fall out of its window |
| Reports and non-conformities | Near misses, incidents, previous findings | Reported, analysed, corrective actions done and checked |
| Documents | Manuals and forms in use on board | The current revision, no old copies in use |
| Master's review | The last review sent to the office | Done, and the office answered it |
An example. The list follows the company's own safety management system.
Writing a finding the ship can act on
Most companies use two levels. A non-conformity is something that does not meet a requirement of the system or the rules. An observation is a weakness that is not yet a non-conformity but could become one. Some companies add a major non-conformity for a serious risk to people, the ship or the environment.
A good finding has three parts: the requirement, the evidence, and what was found. The ship can then fix exactly that, and the next auditor can check it.
| Weak | Better |
|---|---|
| Maintenance records not in order. | The procedure asks for a record for each job done. Of 20 jobs sampled for the main engine, 4 were marked done with no record of the work. |
| Emergency generator tests not satisfactory. | The procedure asks for a weekly test on load. The records of the last 8 weeks show starts only, with no load and no running time. |
| Familiarisation not done. | The procedure asks for familiarisation before duties start. The record for one rating who joined on 12 May was signed on 20 May. |
After the audit
- Report sent to the master and the office within the days set by the procedure.
- Corrective action for each non-conformity: a correction, the root cause and the action that removes it, with a person responsible and a target date.
- Evidence of the fix: photos, the new record, the changed procedure.
- Close each finding only when the evidence is checked, and verify at the next visit that the change held.
- Look across the fleet. The same finding on three ships points to the procedure or the office, not to the crews.
For the root cause step, see the guide on root cause analysis on board.
Common mistakes
- A generic checklist that does not follow the company's own procedures.
- Auditing the paper only. The records look complete, but nobody checked the equipment they describe.
- The same areas every year, in the same order, while the risks on the ship have changed.
- Findings that are not agreed on board and appear for the first time in the report.
- Vague findings without the requirement or the evidence. The ship cannot fix what it cannot see.
- Findings closed on a promise, without evidence, or carried open from one audit to the next.
Checklist
- Every ship has an internal audit at least every 12 months.
- The auditor is not responsible for the area audited.
- The plan uses the last reports, open findings and recent inspections.
- The checklist follows the company's own procedures.
- Records are checked against the equipment on board.
- Every finding is agreed with the master at the closing meeting.
- Each finding states the requirement, the evidence and what was found.
- Corrective actions have a person responsible and a target date.
- Findings are closed with evidence and checked at the next visit.
Internal audits in SEA360
In SEA360 internal ISM audits are one of the inspection types, next to flag, Port State Control, class, TSI and the external DOC, SMC and ISPS audits. Each type has its interval, so the next due date for every ship is in one list.
Findings are recorded on board and ashore, also without a connection on board. Each one gets a root cause analysis and a corrective action with a responsible person and a target date, and overdue actions are highlighted. Photos and documents can be attached as evidence, and inspection reports can be exported to PDF.