The future of the ISM Code: navigating new horizons in maritime safety
The International Maritime Organization (IMO) has been recently reviewing the effectiveness of the International Safety Management (ISM) Code to address emerging issues in maritime safety. In this article I provide an insight to my opinion on the current performance of the Code, what the situation is behind the current work at the IMO and how I believe the ISM may develop in the future.
The ISM Code, has been a cornerstone of maritime safety and pollution prevention since its adoption in 1993*. As the maritime industry evolves, so too must the ISM Code to address emerging challenges and opportunities. Here, I explore the future of the ISM Code and its potential developments.
But first, here are some (published) key points from what is on the table:
Comprehensive Review Proposal: Norway proposed a comprehensive review of the ISM Code and its related guidelines. Opinion of some is that the ISM Code has not developed at the same pace as shipping technology / best practice, nor has the IMO taken suitable review of the performance of the Code for an unprecedented period of time. Their proposal aims to update and improve the ISM Code to meet the evolving needs of global maritime safety management.
Human Element Focus: The Joint ILO/IMO Working Group has emphasized the need to address seafarer-related issues such as violence, harassment, bullying, and sexual assault on ships. The review aims to incorporate policies and procedures to prevent and address these issues within company safety management systems
Implementation Challenges: Concerns have been raised about the inconsistent implementation of safety management systems under the ISM Code. The review seeks to provide clearer guidelines and support to ensure uniform compliance across different regions and companies
Cybersecurity Integration: Although with the last revision of the code, Cyber Security was featured for the first time specifically, with the increasing reliance on digital systems, the review includes integrating robust cybersecurity protocols to protect ships from cyber threats. This involves guidelines on cyber risk management and training for crew members
Environmental Regulations: Another thing to consider is stricter environmental regulations, particularly those focusing on minimising the environmental impact of shipping operations rather than malicious and non-malicious pollution
The unavoidable future of the ISM code will be to cover a shipping sector transformed by cutting-edge technology and I hope, a deepened commitment to human welfare. But, some significant considerations will need to be made around new developments and acceptable cultures in human and environmental welfare, safe and modern operational practices and the security and business threats of the current world.
Embracing technological advancements
The maritime industry is undergoing a digital transformation, with advancements in automation, artificial intelligence, and data analytics. As technology in the industry advances, new systems and equipment are quickly being introduced on board ships. These advancements can improve efficiency and safety but also introduce new risks and complexities that need to be managed effectively. Im not sure it is the place of the ISM Code to incorporate details on the control of these specific new technologies into the wording itself, but I know that shipping operators will continue to invest further into digital technology to enhance their safety management systems (SMS) and remote access to their ships. For instance, real-time monitoring and predictive maintenance to improve the reliability of ship operations, while AI-driven analytics are able identify potential safety risks before they materialize. Many of these systems will be (and are) being used to comply with a number of ISM code requirements, but this also often brings with it a single point failure risk, where operators are quickly not in compliance of the code should the technology fail.
Strengthening human element considerations
As previously discussed, the human element remains a critical factor in maritime safety. Although this is one of the original elements at the heart of the creation of the ISM Code, recent discussions within the IMO highlight the need to address wider issues such as seafarer well-being, mental health, and the prevention of harassment and bullying on board. All points that could be negatively influenced, or increased, with a code currently written to focus on physical safety, rather than holistic safety**. Future revisions of the ISM Code may include more comprehensive guidelines on these aspects, ensuring that the safety management systems not only focus on technical compliance but also on the holistic well-being upkeep of the crew.
Enhancing cybersecurity measures
With the increasing implementation and reliance on evolving digital systems, cybersecurity has become a paramount concern in the recent years. I could imagine the ISM Code detailing more robust cybersecurity protocols, other than those already included, to protect ships from cyber threats. Including bullet points of control methodology to implement, not only overall cyber risk management. For example: More detail on assessing and managing the risk of cyber threat, physical and administrative controls, training for crew members, and the implementation of secure communication channels
Adapting to environmental regulations
Environmental sustainability is a growing priority for whole world, not only the Maritime industry. But, it is obvious to say that Maritime is taking it seriously. The ISM Code will most likely have to evolve in requirements to be easier aligned with stricter common environmental regulations or structure, for example the differences in those related to greenhouse gas emissions, malicious and non-malicious pollution and ballast water management to name a few. Not to forget the utilisation of non-conventional fuel types for propulsion and hotel needs that will not only be in the say tanks of ships, but becoming more common as cargo. This is not going to be easy, considering the vast number of differing geographical, national and international legislation both in and outside of the IMO.
Addressing implementation challenges
Despite its widespread adoption, the ISM Code faces world-wide challenges in consistent implementation across different regions, cultures, companies and vessel sizes. Future updates may focus on providing clearer guidelines and support for smaller shipping companies to ensure uniform compliance, whilst also adding supplementary guidance to provide a common expectation of suitable controls. This could include more detail on training programs and resources to help companies effectively implement, maintain their safety management systems and bring a more defined focus on wellbeing controls.
Conclusion
The ISM Code is poised to evolve, though nothing sits formally within the IMO’s schedule for any session to meet and do this. I hope the IMO will soon schedule a workgroup to review the effectiveness of the code, and that work will begin to evolve it to something that reflects the dynamic nature of the maritime industry. Without action, it will just simply stagnate – a failed anachronism that has not kept up with other, more nimble standards such as ISO 9001, 14001 and 45001.
The IMO’s recent reflection on the ISM Code (if acted upon) could be the start of a significant step towards ensuring that the code remains relevant and effective in addressing the modern challenges of a rapidly changing maritime safety management requirement. The ISM Code has the potential to play a vital role in ensuring the safety and sustainability for the next generation/ evolution of vessels, crew and global shipping operations, should action be made.
*The ISM Code in its current form was adopted in 1993 by resolution A. 741(18) and was made mandatory with the entry into force, on 1 July 1998, of the 1994 amendments to the SOLAS Convention, which introduced a new chapter IX into the Convention. The ISM Code was originally mandated for Passenger ships, oil and chemical tankers, bulk carriers, gas carriers and cargo high speed craft of 500 gross tonnage and above. It became applicable to other cargo ships and mobile offshore drilling units of 500 gross tonnage and above from 1 July 2002.
** Holistic safety is a way of more thoroughly and comprehensively managing operational safety. Organisational safety performance is analysed by examining technological, human and organisational aspects including the complex interrelationships and interdependencies between these three aspects. Such an approach allows the organisation to better understand and manage the key factors that can affect the safety of day-to-day work. A holistic approach captures key aspects of safety that might otherwise be missed, and helps analyse and identify weaknesses and strengths in work procedures and practices. Other approaches often focus only on the technology—equipment or machinery—or on documentation—policies, procedures or work instructions, and place less importance on other key aspects such as human, organisational and conditional factors (such as repetitional fatigue or complacency).