3-4 Organising and Monitoring ISM Internal Audits
This often raises issues related to the independence of internal auditors. As we can see, the DPA has never been considered as an internal auditor, even though many companies have unfortunately adopted this approach. Indeed, according to the Code, the DPA is responsible for monitoring the safety-related aspects of each vessel’s operation, particularly through the ship’s Master. He cannot then audit something ... for which he is responsible himself! The definition of an audit is unequivocal, “systematic and independent control” ... here, in the case of the DPA as internal auditor, there is no independence, quite … the opposite!
Given this requirement for auditor independence, it makes sense to entrust this task to people outside the Company. Or at least somebody outside of the audited sector, as required by the ISM Code itself (Section 12.5). In rare cases, among certain small shipowners of the “one ship/one Company” type, where any new verification is unfortunately systematically considered “inappropriate,” some internal audits, when they exist, have been conducted by the responsible shore-based manager. The results are generally significant: either they note deficiencies that are their own responsibility (sic!), or the “everything is fine, move along, there’s nothing to see here” syndrome prevails. (0 non- compliances, 0 recommendations!) This is firstly senseless and secondly useless!
For the IMO, therefore, based on this concept of independence, so dear to the logic of self-regulation, it is agreed that, within the framework of the SMS operation entrusted to the DPA, it is up to the latter to appoint internal auditors who can evaluate the SMS’s operation sector by sector.
The concept of independence inspired by ISO standards is essential for obtaining a comprehensive analysis of SMS operation and, by definition, allows for objective, uninfluenced results.
So, while the DPA cannot be one of the internal auditors, according to our circular, they are responsible for organising and monitoring internal audits. This monitoring includes verifying the independence and training of the internal auditors involved. Despite possible translation difficulties from English into another language of the circular, all of this is clear enough to prevent DPAs from auditing themselves!
In practice, while organising internal audits is relatively easy, based on the availability of individual staff, the selection and training of auditors is more difficult.
Indeed, to be an auditor, you must: - Have a thorough understanding of the scope of the SMS sector being audited.
- Choose the key people to be audited. - Interview operators chosen, if possible, with a thorough understanding of the operations concerned.
- Be able to detect possible lies or omissions, sometimes the poor results of a certain “culture of adjustment”
- Quickly consult the corresponding objective evidence such as reports, notifications or recordings.
- Be able, if possible, to make an initial proposal for corrective action and discuss it with the person(s) being audited.
- Be able to reject a statement like “yes, we always do that” or “we know that very well!” without objective evidence!
- Be able to interview a senior executive without apprehension.
- Be able to tell the truth, even if the findings show a failure—including at the very highest level—in your own Company!
- Be able to still report a non-compliance even if corrective action is decided upon instantly (a recording oversight, for example!).
In fact, choosing internal auditors is not easy, especially when the Company is small or young. Using a call for volunteers, which is the recommended method, and then carefully explaining the ins and outs of such an approach, the results are far from guaranteed. Various attempts have been made in all companies, and sometimes a hybrid solution has been found. In this solution, external auditors specialised and unrelated to the flag(s) of the Company’s ships can effectively conduct internal audits, including at the management level, provided they commit to strict confidentiality. *3
Furthermore, the organisation of certification audits and the maintenance of this compliance certification are generally also entrusted to the DPA. This responsibility is all the more important since, according to Flag regulations, it is the Company’s responsibility to request Flag audits on time. With any oversight jeopardising the relevant certificates!
We are wondering, in this context, where the mandatory maritime Administration’s help lies!
Principle of the accurate communication link between CEO & ships CEO
DPA PARALLEL WAY SAFETY OF MARTITIMES OPERATIONS NORMAL WAY MASTER & SHIP’S Personnel 78 | ISSUE 115 | MAR 2026 | THE REPORT
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