Module 06 — OOW 3000 GT Oral Preparation
ISM & ISPS
International Safety Management Code · Safety Management System · Flag & Port State Control · ISPS Security Levels
What is the ISM Code? SOLAS Chapter IX / MGN 40
ISM Code objective: To provide an international standard for the safe management and operation of ships and for pollution prevention. It requires companies to implement a documented Safety Management System (SMS) covering both shore and shipboard operations.
The objectives of the Code are to ensure:
- Safety at sea
- Prevention of human injury or loss of life
- Avoidance of damage to the environment
- Avoidance of damage to property
The Three Parties and Their Responsibilities
The Company / Owner
- Produce a safety management policy
- Ensure vessel is seaworthy and certificated
- Ensure vessel is properly manned
- Appoint a qualified Master
- Designate a DPA with direct access to senior management
- Provide procedures for emergencies and drills
- Conduct internal SMS audits at least annually
The Master
- Implement the company's safety and environmental policy
- Motivate the crew to follow the SMS
- Issue clear orders and instructions
- Verify specified requirements are observed
- Review the SMS and report deficiencies to shore management
The Flag State
- Issue Document of Compliance to the company
- Issue Safety Management Certificate to each vessel
- Oversee continued compliance with the Code
- Certificates valid 5 years — inspections in between
- May delegate to Port State to verify SMS functioning
Definitions Every OOW Must Know
| Term | Definition | Key fact |
| SMS — Safety Management System | Structured and documented system enabling implementation of the company's safety and environmental policy ashore and afloat | Internal audits minimum once per year |
| DOC — Document of Compliance | Certificate issued to the company confirming it complies with the ISM Code | Valid 5 years — annual verification. Checked by PSC |
| SMC — Safety Management Certificate | Certificate issued to each individual vessel confirming the vessel and its crew operate in accordance with the SMS | Valid 5 years — intermediate verification between years 2 and 3 |
| DPA — Designated Person Ashore | Person designated by the company with direct access to the highest level of management — monitors safety and pollution prevention aspects of each vessel's operation | Must have direct access to senior management. Not required to be a seafarer but must have operational experience |
| Non-Conformity | A situation where objective evidence indicates non-fulfilment of a specific SMS requirement | Must be corrected — recorded in audit |
| Major Non-Conformity | An identified deviation which poses a serious threat to the safety of personnel, the ship, or the environment | Requires immediate corrective action |
MASTER'S OVERRIDING AUTHORITY: The SMS must contain a statement that nothing in the company's instructions removes from the Master his authority to take any steps or issue any orders he considers necessary for the preservation of life, the safety of the ship, or the prevention of pollution — even if contrary to company instructions.
Flag State and Port State Control
Flag State Control
- Responsible for ensuring vessels flying its flag comply with international conventions the flag has ratified
- Issues statutory certificates (DOC, SMC, Load Line, SOLAS safety certificates)
- Carries out flag state inspections — may be delegated to a recognised organisation (classification society)
- Primary responsibility for ship standards rests with the flag state
Port State Control (PSC)
- Inspection of foreign vessels in national ports to verify compliance with international regulations
- PSC provides the "safety net" — catches substandard vessels that flag state may have missed
- Inspectors check: certificates, SMS, crew competence, vessel condition, equipment
- Can detain a vessel until deficiencies are corrected
- Paris MOU (Europe/North Atlantic), Tokyo MOU (Asia-Pacific), US Coast Guard
ISPS Code — International Ship and Port Facility Security Code SOLAS Chapter XI-2
Purpose: Establish an international framework for cooperation between governments, port authorities, and shipping companies to detect and assess security threats and take preventative measures against security incidents.
| Security Level | Description | What it means on board |
| Level 1 — Normal | Minimum appropriate protective security measures shall be maintained at all times | Normal watchkeeping, access control, monitoring of deck areas and cargo spaces |
| Level 2 — Heightened | Heightened protective security measures shall be maintained for a period as a result of heightened risk of a security incident | Increased frequency of checks, restricted access, greater surveillance, crew briefed |
| Level 3 — Exceptional | Further specific protective security measures shall be maintained for a limited period when a security incident is probable or imminent | Maximum restrictions — may restrict vessel movements, challenge all persons, specific response measures |
Ship Security Officer (SSO)
- Designated on board — responsible for implementing the Ship Security Plan (SSP)
- Liaison with Company Security Officer (CSO) ashore and Port Facility Security Officers (PFSO)
- Reports security incidents and threats
- Maintains ISPS records and drills
ISSC — International Ship Security Certificate
- Issued to vessels that comply with ISPS Code requirements
- Valid 5 years — verified by flag state or RSO
- Must be on board and available for inspection
- Vessels without a valid ISSC may be denied port entry
Large Commercial Yacht Code (LY3) & Small Vessels Code
| Code | Applies to | Key areas covered |
| LY3 (MSN 1851) | Commercial yachts 24m–3000 GT under MCA regulation | Construction, stability, machinery, fire safety, LSA, radio, manning, survey and certification, operational requirements including passage planning |
| Small Vessels Code (MGN 280) | Vessels under 24m in commercial use for sport or pleasure | Survey, stability, safety equipment, radio, manning requirements for smaller commercial vessels |
FOR YOUR ORAL: Know which code applies to your vessel. A superyacht under 3000 GT on a commercial charter is governed by LY3. Know what LY3 requires for your vessel type and route.
The SMS as a Loop — Not a Shelf
The ISM Code turns "safe practice" into a documented loop, and the oral tests whether you live inside it: procedures (write what you do — the navigation, drill and maintenance procedures your watch already follows), compliance (do what's written), reporting (non-conformities, hazardous occurrences and near-misses go INTO the system so it learns — tonight's windlass defect is a report feeding corrective action, not a remark in the mess), and review (internal audits, the master's annual review to the company, management review ashore). A near-miss report culture is the cheapest safety system ever invented: the incident that almost happened teaches at zero cost — but only if it is written down.
| Instrument | Holder | Meaning |
| DOC — Document of Compliance | The COMPANY | The shore management system audited and certified by flag, per ship type operated |
| SMC — Safety Management Certificate | The SHIP | This vessel operates in accordance with the approved SMS; interim/initial/renewal audits |
| ISM 5.2 — master's overriding authority | The MASTER | Documented authority to depart from any procedure and refuse commercial pressure where safety or pollution prevention requires — in writing, in the SMS itself |
| DPA — Designated Person Ashore | Named person, contacts posted | The protected line to shore management ANY crew member may use on a safety or pollution concern unresolved on board |
Lose the DOC and every SMC under it is meaningless; a Port State officer checks both, in date, with the audit trail. And the two personal facts the examiner wants stated without hesitation: the master's 5.2 authority, and the DPA's name and number posted where you can point to them.
Familiarisation — The Part With Your Name On It
Before sailing, every new crew member receives documented familiarisation: emergency duties from the muster list, LSA and FFE locations and operation, escape routes, environmental duties, and the essentials of their role — SIGNED, because "the deckhand didn't know" is an SMS failure with a named officer who skipped the checklist. On a yacht with seasonal turnover this is a weekly reality, not an annual formality — and as OOW you will both deliver it and be audited on it. The drill matrix is its continuation: fire and abandon-ship drills on schedule, entered honestly in the Official Log Book, defects found during drills fed back as reports. A drill that finds a seized valve has succeeded; a drill logged but not held has ended careers.
ISPS — The Machinery Behind the Gangway
| Element | Content |
| Security levels | 1 normal (baseline per the plan) · 2 heightened (a period of raised risk — tightened access, more searching) · 3 exceptional (specific imminent threat — extraordinary measures with authorities). Set by GOVERNMENTS — flag and port state; the ship operates at the higher |
| SSP — Ship Security Plan | Pre-scripts exactly what each level means aboard THIS vessel — approved, protected, and not shown to Port State beyond confirming it exists (limited exceptions) |
| SSO / CSO | Ship Security Officer aboard, Company Security Officer ashore — the pair who run the plan, the drills, and the assessments behind it |
| Declaration of Security | Agreed ship-to-facility (or ship-to-ship) when levels or circumstances demand — who covers which security duty |
| Records & kit | Continuous Synopsis Record (the ship's ownership/flag history), the ship security alert system, security drills on the matrix |
The yacht friction is hospitality vs the plan — guests' visitors, deliveries, day workers, marina foot traffic. The passing answer: the plan wins, politely — visitor logs, ID checks, escorts, search percentages rising with the level, and the waterside watched as carefully as the passerelle, because the gangway watch that ignores the swim platform is theatre.
Flag State, Port State, Class — Who Does What To You
Flag state: the vessel's law-giver — certificates, surveys (often delegated to class as a Recognised Organisation), casualty investigation, the Official Log Book's authority. Port State Control: the visited coast enforcing the conventions on foreign flags — Paris MoU in Europe, targeting by risk profile, inspections from certificates through material condition to OPERATIONAL checks (a drill called on the spot, an officer asked to start the fire pump or show a chart correction), with detention for deficiencies making the ship unsafe to proceed and the record following the vessel and her manager publicly. Class: the technical standard behind hull and machinery certification, whose survey cycle (annual, intermediate, special) keeps the statutory certificates alive. The OOW's stake in all three is the same: maintained gear, honest records, drills actually done — the SMS working is what an inspection finds when there is nothing to find.
Additional Question
The charterer's broker leans on the master to skip tonight's scheduled fire drill because guests are aboard. What does the framework say?
Three layers, same answer. The drill schedule is an SMS requirement — skipping it without cause and record is a non-conformity. The master's ISM 5.2 authority exists precisely for commercial pressure: his decision on safety matters cannot be overridden by the company, let alone a broker. And practically: drills flex — hold it at a guest-friendly hour, split it, or defer with an honest OLB entry and a new date. What never happens is the fiction — a drill logged but not held converts a scheduling problem into falsification. If the pressure persists, that's a DPA conversation, which is exactly what the DPA is for.
Oral Exam Practice Questions
Question 1
What is the ISM Code and what are its objectives?
The ISM Code (International Safety Management Code) is contained in SOLAS Chapter IX. It sets an international standard for the safe management and operation of ships and for pollution prevention. Its objectives are to ensure safety at sea, prevent human injury or loss of life, and avoid damage to the environment and to property. It requires companies to document and implement a Safety Management System covering both shore and shipboard operations.
Question 2
What is the difference between the DOC and the SMC?
The Document of Compliance is issued to the company — it confirms the company complies with the ISM Code. It is valid for 5 years subject to annual verification. The Safety Management Certificate is issued to each individual vessel — it confirms that the vessel and its crew operate in accordance with the SMS. It is valid for 5 years with one intermediate verification between years 2 and 3. Both are checked during Port State Control inspections.
Question 3
What is the DPA and why is the role important?
The Designated Person Ashore is appointed by the company to monitor the safety and pollution prevention aspects of each vessel's operation and to ensure adequate resources and shore-based support are provided. The critical requirement is that the DPA must have direct access to the highest level of management — this is what gives the role authority to act. The MCA regards the role as highly important. The DPA effectively oversees the Master and supports him simultaneously.
Question 4
What are the three ISPS security levels?
Level 1 — Normal: minimum security measures maintained at all times. Normal watchkeeping and access control. Level 2 — Heightened: applied when there is an elevated risk of a security incident. Increased checks, restricted access, greater surveillance. Level 3 — Exceptional: applied when a security incident is probable or imminent. Maximum restrictions — specific protective measures implemented, vessel movements may be restricted. Security levels are set by the flag state or coastal state.