The ISM Code has served as the cornerstone of maritime safety for over twenty (20) years and also ensures compliance with the standards imposed on each operator of a SOLAS vessel. Thus, every SOLAS vessel must establish a Safety Management System demonstrating that a proactive approach towards hazard identification, risk management, and compliance with applicable regulations is in place; this provides evidence that individual ship operators are conducting themselves in accordance with the ISM Code.
Although the uptake and maturity of Safety Management Systems globally is on the rise, there continue to be reported deficiencies in their implementation, creating vulnerabilities within those businesses utilizing Safety Management Systems to an increase in audit failures, regulatory actions, and exposure to financial liabilities arising from deficiencies identified through global inspections.
With the global shift towards outcome based assessments (by inspection regimes such as SIRE2.0, TMSA3, RightShip [RISQ] and PSC), changing the focus of inspections from determining whether a Safety Management System exists to whether it is demonstrably functioning at sea, the implications will be profound for all employees (compliance personnel and Senior Officers alike) with direct or indirect responsibility for the operation of the fleet, exposure to risk and financial implications.
Global Inspection Data: Persistent SMS Deficiencies
Port State Control statistics provide one of the most objective indicators of safety and compliance performance across the global fleet. According to the Australian Maritime Safety Authority (AMSA) Annual PSC Report 2024:
- ISM-related deficiencies accounted for 27.57% of all detainable deficiencies in 2024, making it the most frequently cited deficiency category.
- The PSC detention rate stood at 5.9%, broadly consistent with the ten-year average of approximately 5.8%.
- The average number of deficiencies per inspection increased to 2.63, exceeding the ten-year rolling average of 2.26.
These figures clearly demonstrate that management system failures remain a leading cause of adverse inspection outcomes, despite decades of regulatory oversight.
A broader review of global PSC regimes indicates a similar trend. In 2024, approximately 71,700 PSC inspections worldwide resulted in more than 150,000 recorded deficiencies and over 3,000 detentions, with ISM-related findings consistently ranking among the most common contributors to detention. This suggests that SMS weaknesses are not confined to specific vessel types, flags, or regions, but represent a systemic industry challenge.
Where Safety Management Systems Commonly Break Down
1. Documentation Exists, but Evidence Is Weak
One of the most frequent audit observations is not the absence of procedures, but the inability to demonstrate their effective application. While SMS manuals are often comprehensive, auditors increasingly focus on alignment between documented procedures and actual onboard practices.
Under SIRE 2.0, RIGHTSHIP and TMSA-3, inspectors/auditors assess whether crew behaviour, operational decisions, and recorded evidence reflect the stated intent of the SMS. Where this alignment cannot be demonstrated, systems are judged as ineffective regardless of how well documented they appear.
2. Poor Data Hygiene and Record Management
The availability of accurate, consistent, and easily retrieved records is essential for audit readiness, however an industry-wide problem continues to be fragmented recordkeeping. Records related to maintenance, drills, risks and training may be located on many different platforms or may be kept inconsistently. According to PSC, technical deficiencies, especially those related to fire safety and lifesaving appliances, often exist in conjunction with incomplete/inconsistent documentation showing that these are not isolated failures of individual pieces of equipment due to deficiencies of the following: Data Governance and evidence management in the SMS.
3. Ineffective Corrective and Preventive Action (CAPA)
Corrective and preventive action is a core requirement of the ISM Code, yet CAPA systems are one of the most frequent points of audit failure. Root cause analyses are often superficial, corrective actions are poorly defined, and effectiveness reviews are either delayed or inadequately documented.
Classification society analysis consistently highlights repeat deficiencies as a critical red flag. From an auditor’s perspective, recurring observations indicate that hazards are being managed reactively rather than systematically, undermining confidence in the SMS as a tool for continuous improvement.
4. Crew Familiarity and Human Factors
Social aspects of human interaction will always have a fundamental role in determining the success of Safety Management Systems. Recent evidence from the ICS Maritime Barometer (2023) has identified continuing concerns related to seafarer's workload, fatigue, and training efficiency, which will affect the way in which a seafarer will comprehend and apply any operational procedures while working on board vessels.
Recent audits have expanded to include interviews with crew members and scenario-based questioning. If there is an inconsistency in answers or if there is little knowledge of Safety Management System requirements, the difference between the enforced written procedures, and what occurs in practical terms will be revealed.
Operational Consequences of SMS Weaknesses
The impact of poor audit readiness extends well beyond the inspection itself:
- PSC Detentions result in schedule disruptions, demurrage exposure, and reputational damage.
- Commercial Vetting Outcomes under SIRE 2.0, RIGHTSHIP and TMSA-3 are increasingly influenced by historical compliance performance and evidence quality.
- Insurance and Risk Exposure may increase where repeated SMS deficiencies indicate systemic management failures.
- Crew Safety and Morale are adversely affected when safety systems are perceived as administrative exercises rather than practical risk-control tools.
These consequences underscore the direct link between SMS performance, operational resilience, and commercial viability.
Future Outlook: Regulatory and Inspection Trends
Looking ahead, several developments will further raise expectations around audit readiness:
- Outcome-Based Inspections: SIRE 2.0 & RISQ 3.2 emphasises decision-making quality, behavioural evidence, and control effectiveness rather than checklist compliance.
- Digital Audit Trails: Regulators and vetting bodies increasingly expect structured, digital evidence that can be easily retrieved and verified.
- Risk-Based Targeting: PSC regimes continue to refine inspection targeting models using historical deficiency and detention data.
- Expanded ISM Scope: Cyber risk management and human-element considerations are becoming more explicitly embedded within SMS expectations under evolving IMO guidance.
These trends indicate that audit readiness will increasingly be treated as a continuous operational discipline rather than a periodic compliance exercise.
Conclusion
Safety Management System failures result from poor implementation and lack of data discipline or effectiveness of corrective actions instead of a lack of regulatory frameworks according to global inspection statistics. When inspections are conducted today, audit readiness will be indicative of how the systems perform under real-world conditions.
For the ship owner, operator and HSEQ leader, the strategic imperative is evident: enhance SMS maturity through effective implementation, robust evidence management and continual improvement. This is vital both for passing audits, but also in maintaining safety, continuing operations, and sustaining commercial confidence in the maritime industry which is under increasing scrutiny.