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A Safety Management System (SMS) is the documented operational framework through which a shipping company implements the requirements of the ISM Code. It defines how the company manages safety at sea: who is responsible for what, how procedures are written and communicated, how incidents are reported and investigated, how maintenance is carried out, how drills are conducted, and how continuous improvement is achieved.
Every company subject to the ISM Code must develop and maintain an SMS. The SMS is not a single document — it is a living system of policies, procedures, checklists, records, and responsibilities that must be kept current and genuinely implemented on board every vessel. An SMS that exists only on paper, unknown to the crew who are supposed to follow it, is both a regulatory failure and a real safety risk.
The SMS must cover the full scope of vessel operations, from routine maintenance and cargo handling to emergency response, environmental protection, and crew welfare. It must also include procedures for internal auditing — the mechanism by which the company checks its own compliance before external auditors arrive. This self-auditing requirement is what makes an SMS a management system rather than just a policy document.
The ISM Code specifies twelve elements that an SMS must address. These include a safety and environmental protection policy signed by senior management; clearly defined roles and responsibilities for company staff and vessel crew; procedures for ship operations covering all key tasks including cargo, navigation, and machinery; and procedures for emergency preparedness — drills, muster lists, and emergency contact trees.
The SMS must also include procedures for reporting and analysing non-conformities, accidents, and near-misses; a planned maintenance procedure linked to the vessel's Planned Maintenance System; procedures for preparing for and conducting internal audits; and a management review process through which senior leadership evaluates SMS performance and drives improvement. Together, these twelve elements form a comprehensive management system, not just a safety manual.
In practice, shipping companies typically structure their SMS as a hierarchy: company-level policies and procedures at the top, vessel-specific procedures and checklists at the vessel level, and a records layer that captures what was actually done and when. The SMS must be kept on board in a form accessible to all crew, and any crew member should be able to demonstrate familiarity with the procedures relevant to their role.
SMS verification is carried out through a two-tier audit process. At the company level, flag state administrations (or their designated Recognised Organisations) audit the company's SMS and issue a Document of Compliance (DOC) confirming that the management system meets ISM Code requirements. The DOC must be renewed every five years, with annual verification audits in between.
At the vessel level, each ship must be audited separately. A successful vessel audit results in a Safety Management Certificate (SMC) — the document a PSC officer will check first when boarding for an Port State Control inspection. The SMC confirms that the vessel's crew understand and follow the SMS, that records are maintained, and that the system is genuinely operational rather than purely theoretical.
Internal SMS audits, required by the ISM Code itself, must be conducted at least annually by persons independent of the area being audited. These internal audits are the primary quality control mechanism — identifying non-conformities before they become external audit findings or, worse, incidents. Companies with robust internal audit programmes consistently perform better in external audits and in Port State Control inspections.
The SMS sits at the centre of a company's broader QHSE management framework. While the SMS specifically addresses ISM Code requirements, many companies integrate it with quality management (ISO 9001), environmental management (ISO 14001), and occupational health and safety (ISO 45001) into a single Integrated Management System (IMS). This avoids duplication and creates a unified compliance framework.
MARPOL compliance procedures are typically embedded within the SMS. This includes oil record keeping procedures, garbage management plans, Shipboard Energy Efficiency Management Plans (SEEMP), and — since 2023 — procedures for monitoring and managing CII Rating performance. The SMS is the mechanism through which vessels translate regulatory requirements into day-to-day crew behaviour and record-keeping.
The relationship between the SMS and the Planned Maintenance System is also direct and important. The ISM Code explicitly requires companies to establish maintenance procedures as part of their SMS. In practice, this means the PMS must reflect the SMS requirements for critical equipment — ensuring that the maintenance schedule aligns with the risk-based approach required by the ISM Code.
Infoship provides a digital environment for maintaining and operating a live SMS. Procedures can be stored, version-controlled, and distributed to vessels through the platform — ensuring all crew have access to the current version of every procedure. When a procedure is updated, the old version is archived automatically, creating an unambiguous audit trail that demonstrates the company's document control practices.
Non-conformities reported through Infoship's QHSE module are automatically linked to the relevant SMS procedure — making it easy to identify which parts of the SMS are generating the most issues and where procedural improvement is needed. Corrective actions are assigned, tracked, and verified within the system, producing the closed-loop evidence trail that ISM auditors and Port State Control officers look for. Combined with Infoship's drill tracking and internal audit management functions, the platform supports end-to-end SMS management from a single interface.
