RESPONSIBILITIES of the DPA (Designated Person Ashore under the ISM Code)
as our industry understands them today By Capt Bertrand Apperry, HonFIIMS and IIMS Past President
After much uncertainty, we can now finally consolidate the actual responsibilities of the DPA as they exist in our industry.
FOREWORD
An atypical function in the industry in general, the DPA concept encountered some difficulties in gaining acceptance from the inception of the ISM Code due to vague interpretations, particularly by some Administrations and shipping companies, to the point that the IMO, as is often the case, had to publish “clarification circulars.”
These is Circular MSC-MEPC.7/Circ.8 of June 2013, which concerns “Revised Guidelines for the Operational Implementation of the ISM Code by Companies,” and Circular MSC-MEPC.7/Circ.6 of October 19, 2007. Both fall under “Guidelines on the Qualifications, Training, and Experience required to fulfil the role of the Designated Person Ashore under the provisions of the ISM Code.”*1
Note: These circulars were issued more than 10 years ago by the IMO’s two most important committees, which join for special occasions.
We therefore have, on the one hand, clarifications for the application of the ISM Code and, on the other, necessary clarifications regarding the role of the DPA. These two circulars detail all of the DPA’s responsibilities from the usual IMO perspective: the “Codes” are the minimum required, and the guidelines are merely recommendations for implementation ... sometimes “fortunately” required later by the better Flag Administrations!
In addition to these circulars, we will examine the reality of things on the ground: how our industry ultimately took the recommendations into account while ensuring necessary compliance with the ISM Code!
INTRODUCTION
After my initial article published in maritime magazines about ten years ago, a sufficient period to “digest” the IMO circulars relating to the DPA, it seemed necessary to clarify again and expand on this strange function of our industry, which still seems unique today. Indeed, with a remarkable inertia specific to our industry, the demand for ISM training in general or ISM internal auditor in particular, is exploding. A demand for specific DPA training is also called for, and if possible, in a hyper-specialised and individual manner.
1-MODALITIES OF THE “DPA TRAINING” TAUGHT UNTIL NOW
For a classic DPA, we could limit ourselves to the three basic requirements of Section 4 of the ISM Code. Even if, like the entire code, this paragraph is condensed, it is very precise and does not allow for any approximation.
Reminder: The three responsibilities required by the ISM Code itself are: • 1-Ensure a privileged link with top management in a “bypass” system for intermediate management, when necessary, to ensure (particularly in emergencies involving safety or the environment) reliable, direct, and instant communication between vessels and their Masters and head of Senior Management - particularly when important rapid decisions need to be carried out. • 2-Monitoring the safety and pollution aspects of vessel operations on a day-to-day basis via the Master, both at sea and in port.
• 3-Ship support: ensuring that appropriate resources are provided to vessels, including at their request even with a classic process of moderation and mitigation when necessary.
THE REPORT | MAR 2026 | ISSUE 115 | 75
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