Top 12 Common Violations Under the ISM Code in Maritime

Avoid costly detentions and keep your crew safe. This deep-dive explains the Top 12 common violations under the ISM Code—what they look like onboard, why they happen, and how to fix them for good. Packed with real-world cases, checklists, and links to authoritative guidance (IMO, Paris/Tokyo MoU, USCG, IACS, Class societies).

The ISM Code is only nine letters, but it carries the weight of your entire safety culture. When it works, jobs feel smoother, audits feel calmer, and crews go home safe. When it doesn’t, small cracks—an overdue drill here, a missing signature there—can widen into detentions, claims, and headlines nobody wants. This guide translates the Top 12 common ISM violations into everyday language. You’ll see how they show up on deck and on the bridge, what port State control (PSC) officers look for, and proven, human-friendly ways to close the gaps. It’s built for global English readers and backed by authoritative sources (IMO, Paris/Tokyo MoU, USCG, class & industry guidance).

Why ISM compliance matters in modern maritime operations

On a good ship, the Safety Management System (SMS) is not a binder—it’s a living playbook. It keeps equipment maintained, people trained, and risks visible long before they become incidents. PSC regimes (Paris/Tokyo MoU, USCG) and class societies use ISM as a lens: if your SMS is healthy, defect rates fall; if it’s dusty or misused, seemingly unrelated findings (fire doors, lifesaving appliances, work/rest, documentation) pile up. The stakes are real. Detentions cost time and reputation. Insurers and charterers track company performance. EMSA’s THETIS system publicly profiles company risk based on inspections, deficiencies, and detentions linked to the same ISM company. That creates incentives to get the basics consistently right, not just right before vettings.

Key developments shaping ISM today

Cyber risk in the SMS. IMO’s decision to integrate cyber risk management into ISM made cyber readiness a safety topic, not just an IT topic. Class guidance (e.g., DNV) frames awareness, roles, and recovery plans as part of the SMS.

Data-driven PSC. Paris and Tokyo MoU annual reports now visualise trends across deficiency codes. You’ll often see clusters that reflect ISM health: fire safety management, drills, documentation control, and crew familiarisation.

Alternative fuels and new tech. New guidance (e.g., BIMCO/MTF) encourages companies to embed alternative fuel risks into the SMS—procedures, training, emergency response—so “new energy” doesn’t outpace safety culture.

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The Top 12 Common ISM Violations—and how to fix them for good

Quick note on language: we’re using “violation” in the everyday sense—things that breach ISM or your own SMS. Auditors will classify them as non-conformities (NC), major NC, or observations. The fixes below aim to remove root causes, not just close the paper gap.

1) Paper SMS vs. Real SMS (the “binder problem”)

What it looks like onboard
Procedures say one thing; practice shows another. Work instructions exist but aren’t used. Crew “work around” checklists to keep up with operations. Masters sign night orders; OOWs never read them. Everyone is busy, but the system is silent.

Why it happens
Templates copy-pasted from other fleets, too many steps, language that doesn’t fit the crew, updates not briefed, and an audit culture that rewards neat forms over usable processes.

How PSC/class spot it
Inconsistent answers during interviews, identical pen strokes across different people’s signatures, old versions of forms still in circulation, or control measures that cannot be demonstrated in practice (e.g., toolbox talks that don’t match how the job is actually done).

Fix—make the SMS “the easy way”

  • Rewrite one high-friction procedure with the crew that uses it most. Strip jargon. Keep steps short.

  • Move checklists closer to the job (laminated, QR, or app) and capture who/when automatically.

  • Train supervisors to coach the procedure, not just enforce it; praise crews who stop a job to use the list.

  • Update the controlled documents register and purge old versions in one sweep.

2) Weak Master’s Review & Management Review

What it looks like
Annual reviews are back-dated or vague (“no significant issues”). There’s no link between near-miss trends and resource requests. Corrective actions repeat with new dates but no new ideas.

Why it matters
ISM expects a real feedback loop: ships surface issues; shore removes barriers. Weak reviews break that loop, so the same near-miss keeps coming back with a different timestamp.

Fix—turn reviews into decisions

  • Build a one-page dashboard: top 5 risks, top 5 overdue actions, training gaps, defect backlog, PSC findings.

  • Invite the DPA (virtually is fine) to the Master’s Review call; log the action/owner/date.

  • In the Management Review, link trend → budget (e.g., “Recurrent fire door defects → order spare kits; training with maker”).

  • Close the loop with ships: a short “what changed because you told us” note boosts reporting culture.

3) Corrective & Preventive Action (CAPA) without root cause

What it looks like
CAPAs read like to-do lists: “re-train crew,” “remind to follow procedure.” The same finding reappears at the next audit.

Why it happens
Time pressure and fear of blame. Teams fix the symptom (e.g., a missed signature) without asking why the signature is often missed (e.g., form is placed far from the job; workload peaks at wrong times).

Fix—go one level deeper, quickly

  • Use a five-whys mini-drill on the spot. Document the systemic cause (layout, staffing, training, design).

  • Pair every corrective action with a preventive one that changes the system (move the form; change the sequence; add a prompt).

  • Assign an owner who wasn’t part of the incident to review effectiveness after 30–60 days.

4) Drill performance that only looks good on paper

What it looks like
Muster lists are current, but drills are predictable and slow. The same two people always lead. Hoses kink. Nobody times anything. New crew learn drills by osmosis.

Why it matters
PSC and class observe—not just check boxes. Fire, abandon ship, enclosed space rescue, steering gear failure: drills need clarity, speed, and safe choreography.

Fix—make drills bite-sized and varied

  • Split the big drill into rotating micro-drills (e.g., “stretch and charge one hose to aft locker” this week; “donning & BA comms” next).

  • Randomise timing and inject a curveball (“simulate blocked escape route”).

  • Time the evolution. Use video briefly for debrief (even a phone).

  • Record specific learning points, not just “drill carried out.”

5) Maintenance system: overdue, mis-prioritised, or unverified

What it looks like
Planned maintenance (PMS) shows green dashboards ashore, but critical tasks are “task-complete/no spares used.” Critical alarms muted for convenience. Temporary repairs become permanent.

What auditors see
Missed maintenance on critical equipment (steering gear tests, fire pumps, watertight doors, fixed fire systems), calibration dates expired, or PMS closed out with no evidence beyond a tick.

Fix—treat critical jobs like flights

  • Define a critical equipment list and tag their PMS tasks.

  • Require evidence for closure (photo of gauge reading/serial, torque sheet, maker test printout).

  • Run a monthly “top ten overdue” call; DPA joins if any are safety-critical.

  • After any critical breakdown, add a one-time task to prevent recurrence (guards, stoppers, spares).

6) Familiarisation that forgets the human

What it looks like
Sign-on brief is a flurry of signatures. The new OOW hasn’t learned the ECDIS alarm philosophy; the motorman hasn’t practiced quick-closing valves. Night orders are copied, not read.

Real-world risk
Familiarisation is at the heart of ISM. PSC officers will interview crew away from supervisors and ask them to demonstrate. If they can’t, it’s an ISM red flag regardless of neat paperwork.

Fix—coach, don’t just collect signatures

  • Build role-based “Day 1 / Day 3 / Day 7” checklists tied to practical demos (e.g., start emergency fire pump at location; explain CO₂ release interlocks).

  • Pair every newcomer with a buddy for the first week.

  • Run a 10-minute “show me” session per watch: one safety-critical control per shift.

7) Permit-to-Work (PTW) that doesn’t frame the risk

What it looks like
PTWs are issued far from the job. Gas tests are done once at the start. Toolbox talks use generic hazards. Hot work maps are out-of-date. Isolation tags aren’t cross-checked.

What PSC looks for
Consistency between PTW, toolbox talk, and the scene: isolation points identified, gas test log current, fire watch briefed and equipped, ventilation/lighting adequate, rescue planned.

Fix—bring PTW to the point of work

  • Issue PTWs at the job site whenever possible; re-check after breaks.

  • Tie PTWs to a live risk assessment (specific location, weather, team mix).

  • Add a 2-minute “Stop-Think-Act” halt before ignition or entry.

  • Post a visual PTW board with active permits and expiring times.

8) Document control & record integrity

What it looks like
Multiple uncontrolled copies of procedures on crew phones. Old muster lists in lockers. “White-outs” in logs. ECDIS checklists from a previous version of the manual.

Auditor cues
Version mismatches, uncontrolled edits, missing approvals, and records with identical handwriting for different crew. PSC will compare your controlled list with what’s used at workstations.

Fix—tighten the document chain

  • Move to a controlled digital library with read-only distribution; sync to workstations automatically.

  • Keep a single controlled print point onboard for must-have hard copies.

  • Train on good recordkeeping (ink, no blanks, corrections initialled and dated).

  • Run quarterly “document hygiene rounds.”

9) Incident/near-miss reporting that hides pain points

What it looks like
A near-miss book that’s empty for months. Or: reports exist but read like blame or trivia. Root causes aren’t analysed; lessons stay on one vessel.

Reality check
Healthy companies report more near-misses because crews trust the system. PSC and vetters recognise this pattern.

Fix—make reporting safe and useful

  • Quick, mobile-friendly reporting with optional anonymity.

  • DPA shares a monthly “lessons learned” one-pager across the fleet.

  • Reward useful reports (e.g., small recognition; public thanks in the Master’s meeting).

  • Close every report with “what changed.”

10) Work/rest hour violations disguised as neat sheets

What it looks like
Perfect 6-on/6-off records during cargo ops that obviously ran 18 hours. Crew quietly fix times after the fact. Fatigue shows up elsewhere: slow drills, near-misses, irritable bridge teams.

What inspectors do
Cross-check logs with port papers, AIS movements, cargo logs, and CCTV (where available). If the story doesn’t match, ISM credibility suffers.

Fix—schedule honestly, escalate early

  • Treat work/rest compliance as a safety control. Plan extra lookout/AB for known peak loads.

  • Empower masters to delay non-critical tasks to protect rest.

  • Use software that warns before breaches and suggests swaps.

  • Address root causes (manning levels, port turnarounds, chronic overtime).

11) Emergency readiness: plans exist, interfaces don’t

What it looks like
The plan says one thing, the port’s reality says another. Contact lists are outdated. Shore exercises are annual “tick-box” calls. Nobody has tested the satellite voice group recently.

Auditor focus
Evidence of integrated drills (ship–shore–contractors), tested communications, and clear role cards. Familiar, current SOPEP/SMPEP contacts. Quick access to musters, MSDSs, and port numbers.

Fix—exercise interfaces, not paper

  • Run short, realistic tabletop drills with shore once per quarter (15–20 minutes each).

  • Verify all phone/email groups, VDR bookmarks, and satellite contacts quarterly.

  • After any real incident, hold a hot debrief within 72 hours and update checklists.

12) Cyber risk treated as “IT’s problem”

What it looks like
Shared passwords. Unpatched ECDIS PCs. USBs used freely. No backup/restore drill. No awareness of spoofing risk on GNSS/AIS.

Why this is now an ISM topic
Cyber is explicitly linked to ISM: loss of navigation data, ransomware on a cargo-critical system, or tampered permits can cripple safe operation.

Fix—embed cyber hygiene into routine

  • Minimums: unique credentials, role-based access, patch plans, and offline backups.

  • Run a 15-minute “restore from backup” drill per quarter on a non-critical workstation.

  • Add cyber prompts to existing checklists (e.g., pre-arrival: “ECDIS patches current?”).

  • Teach crews to validate with secondary sources (radar ranges, visual bearings) when GNSS looks “too perfect.”

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In-depth analysis: patterns behind most ISM deficiencies

They’re rarely technical; they’re mostly human-system.
A stuck valve is technical. But repeated stuck valves on the same line are organisational: spares, lubrication standards, shift handover, environment. ISM is about that second layer—how your system makes success repeatable.

PSC statistics tell the same story.
Recent Paris MoU annual reports and press material highlight persistent deficiency clusters in fire safety, employment agreements, and more general ISM controls, while company performance metrics in THETIS tie detentions to the responsible ISM company. USCG PSC summaries repeatedly show Safety Management Systems among leading detainable categories, alongside fire and lifesaving systems. Tokyo MoU reports mirror similar patterns across Asia-Pacific. These are not “gotchas”—they’re windows into system health.

Maturity beats makeup.
Ships that rehearse small things (e.g., parallel indexing every pilotage, 2-minute pause before hot work) rarely surprise auditors. The opposite is also true: spotless binders plus uncertain answers invite deeper probing.

Challenges and solutions (in plain language)

Multinational crews and dense English

  • Solution: Rewrite high-use procedures at A2–B1 English level. Use diagrams. Pilot an audio-read option with QR codes.

Short port stays, long checklists

  • Solution: Reduce to “critical 5” steps that would actually stop the job if missed. Everything else becomes supportive guidance.

Fear of reporting

  • Solution: Make “no blame” visible: publicly thank the crew who reported a near-miss that prevented a loss. Show the change it caused.

Complacency on “easy” voyages

  • Solution: Rotate micro-drills and spot checks even in open sea: one BA set per week, one steering gear test, one GMDSS DSC test call (as permitted).

Change management fail

  • Solution: Any manual update triggers a short ship-shore brief with “what changed/why/how to show”. Capture “read & understood” in the app—not a loose sheet.

Four brief case studies from the real world

Case 1: The back-dated drill
A crew logged monthly enclosed space drills on time—but PSC found BA sets dusty and one crew member unsure of rescue tripod setup. Detainable deficiencies followed. The company rebuilt drills into weekly 10-minute micro-sessions and reassigned BA custodianship to a specific rank with rotating checks. Next PSC: clean.

Case 2: The “perfect” work/rest sheet
A ship turned around two cargoes in 24 hours with flawless rest records. PSC cross-checked times with terminal logs and bell book: impossible. The master explained “we just had to make it fit.” The company introduced fatigue “red lines,” adjusted manning during peak ops, and required honest exceptions with short-term mitigations. DPA backed masters who refused unsafe schedules.

Case 3: Hot work with cold oversight
A fitter performed hot work on deck with a generic permit. A PSCO visited; the team couldn’t show gas tests after lunch or a clear exclusion zone. Detention risk. The fix: PTW board at the job site, fixed gas-testing intervals, thermal camera checks near insulated spaces, and snap-back-style marked zones for hot work.

Case 4: Cyber by accident
An ECDIS froze during approach because Windows updates triggered at the wrong time. No offline chart backup had been tested in months. Luckily, radar and paper extracts kept situational awareness. The company added “patch window” rules, blocked auto-updates during critical periods, and instituted a quarterly “switch to backup” drill.

Future outlook: ISM in the next five years

From static to dynamic UKC and risk.
As S-100 products mature, expect live bathymetry/UKC overlays and “dynamic no-go” alarms. SMSs will need to define how crews validate and act on this richer data consistently.

Decision support that speaks ISM.
Bridge and engine decision-support systems will flag trends using the same words auditors use: “repeated deferred critical maintenance,” “fatigue risk rising,” “drill performance declining.” That makes audits faster—and excuses thinner.

Alternative fuels integrated end-to-end.
As methanol, LNG, and ammonia expand, SMSs will carry fuel-specific PTWs, firefighting tactics, gas detection regimes, and rescue profiles that PSC will expect to see demonstrated, not just described.

Cyber drills become normal.
Expect vetters and PSC to ask, “Show me how you restore from backup,” or “How do you navigate if GNSS is unreliable?” Seamanship plus cyber hygiene will be the new standard.

Frequently asked questions (FAQ)

What single habit reduces most ISM findings?
Treat every checklist as a conversation, not a form. Read it aloud in the toolbox talk. If steps don’t fit reality, change the document—don’t change the job to match paper.

How do I convince busy crews to report near-misses?
By acting on them fast and feeding back outcomes. One solved pain point (e.g., spare BA masks that actually fit) creates more willing reporters than a dozen posters.

Are PSC officers targeting ISM on purpose?
They’re targeting risk. ISM is where systemic risk hides. If drills are weak, maintenance is overdue, or records are unbelievable, ISM is the right lever.

What makes a corrective action “stick”?
It changes the system: layout, sequence, training, spares, or responsibility. “Remind crew” is not a system change.

Is cyber really part of ISM now?
Yes. Risk assessment, controls, backup/restore, and awareness sit inside the SMS for ships covered by ISM. Treat it like any other hazard that can degrade safe operation.

How much English complexity is acceptable in procedures?
Aim for A2–B1 (simple, direct). Technical accuracy with plain words beats impressive grammar that nobody uses under pressure.

Conclusion

The ISM Code isn’t a chore; it’s a choreography. When everyone knows their step—how to drill, when to report, what to check, who to call—the ship moves with quiet confidence. The Top 12 violations here are common for a reason: they grow slowly in the gaps between paper and practice. Close those gaps with human-centred fixes—simpler procedures, honest records, meaningful drills, smarter maintenance, open reporting—and you’ll feel the difference in fewer findings, stronger morale, and safer voyages.

Start small. Pick one high-friction procedure, one drill, and one recordkeeping habit. Make each the “easy way” this month. Your next audit will look different because your daily work will feel different. ⚓

References

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