For any shipping company today, these requirements are understood and applied at least in theory. This must be true since all 100,000+ vessels subject to the ISM Code continue to sail, i.e., with their SMC-DOC (Safety management certificate/document of compliance) and operate under a Company safety and environmental protection management system complying with the Code!
However, we must not be naive, especially in this profession. Regarding the DPA’s role in maintaining this compliance, there are still “holes in the bag,” and sometimes even some analysts insist on different concepts ... unfortunately bordering on heresy!
NB: The responsibility for monitoring ship operations includes operations at sea and in port. Port operations regulations are the primary domain of the ILO. However, the interface is such that the ILO long ago issued “best practices” that concern us, such as “Safety and health in ports” and its counterpart, “Prevention of accidents on board ships at sea and in port”.
NB: These “two little gems” are therefore naturally in the libraries of companies and ships and should be familiar to the DPA.
The classic flow chart of the DPA role: CHIEF EXECUTIVE OFFICER (CEO)
ISM/DPA STRUCTURE:
Monitoring of Safety of SHIP’s operations &
support to ships ISM WAY RETURN
DIRECT LINK
USUAL WAY
Moderation Mediation
OPERATIONAL STRUCTURE of the Company MARINE OPERATIONS DEPARTMENT TECHNICAL DEPARTMENT
HUMAN RESCOURCES DEPARTMENT/QHSSE COMMERCIAL DEPARTMENT LOGISTIC DEPARTMENT FINANCES DEPARTMENT
USUAL WAY RETURN SHIP’S PERSONNEL/MASTER/Ship’s Safety Committee
2-PUBLICATION OF TWO IMO CIRCULARS ON THE SUBJECT
The IMO is ultimately just an international regulatory body, but fortunately, it always effectively clarifies these regulations. Indeed, the world’s best experts work and rework on them with the sole aim of helping us implement what we have agreed upon by a majority to reduce maritime accidents and clarify all the other existing approximations in our industry.
Refusals or approximations still exist, based on a certain narrow view of “freedom of enterprise”. They are the prerogatives of those who transport goods and passengers across the “beautiful sea” without concern for others ... often deliberately forgetting the professional code of ethics!
The IMO committees, which are made up of our representatives, conscientiously study and publish the results “free of charge”. We cannot deliberately ignore them without facing sanctions at the first PSC (Port State Control) ... so feared by shipowners!
The publication of the two ISM circulars drawn up by the IMO’s committees: one on safety and the other on environmental protection, jointly issued for special occasions, had the effect of a mini bombshell but fortunately reducing the proliferation of existing heresies in the application of the code.
76 | ISSUE 115 | MAR 2026 | THE REPORT
3-CIRCULAR MSC-MEPC.7/circ.8: Revised Guidelines for the Operational Application of the ISM Code by Companies
A set of intelligent recommendations to assist companies, including clarifications on the role and responsibilities of the DPA, namely:
3-1 Communicate and implement the safety and environmental policy to which the Company has committed in its general statement signed by the CEO.
There is a significant responsibility for “communication” in this, and even if today this “communication” often hides a lack of effective implementation, it must exist, and it is therefore the DPA in particular that should be responsible for it. This responsibility includes the DPA being part of the Company’s communications department, which can be important, but its role will remain limited to the already broad “safety and environmental protection” sector. Its sector will only grow with the increasing consideration of crew wellbeing and new environmental issues caused by ships: transfers of fauna and flora via stability ballast water; underwater noise disrupting the life and reproduction of marine species; difficulties extinguishing fires on PCs and RoRos; different pollution levels from new fuels; the dangers of liquid-electrolyte li-ion batteries transported alone in containers or in electric or hybrid vehicles; the acceptability of future nuclear PCs, etc…
RP
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