3-5 Conduct appropriate SMS reviews
This system review can be decided upon following a management review for reasons as diverse as they are important: a need identified during a management review, fleet expansion, change of management, search for a charter, response to a call for tenders, a customer request, etc.
This review is the responsibility of senior management, and it is quite logical that the proposal and then practical implementation are entrusted to the DPA with the help of cross-functional managers. They would certainly have their own ideas for this review over the course of the annual inspections, which generally tend towards improvement!
Amendments and revisions to the SMS, prepared and then proposed by the DPA to senior management, are part of the DPA’s normal actions. These proposals are then subject to acceptance and decision by the CEO after consultation with managers from all areas of the Company.
3-6 Ensure that adequate resources and appropriate shore-based support for all ships are provided by the Company
This is perhaps the most difficult responsibility the DPA has to fulfil.
Indeed, in this particular environment of the shipping industry, which is all too often focused on finding the cheapest option, assigning such responsibility to the DPA sometimes borders on outrageous!
I’m joking of course, but since the purse strings are in the hands of management and its shareholders everywhere, the DPA will certainly often have their work cut out to obtain the resources/support requested by vessels and their Masters. When the requests are reasonably costly, there is generally no problem. However, when the costs are substantial, decisions are often more difficult to obtain, are postponed, forgotten, etc.
While all this is logical in principle, the reality on the ground is different. It sometimes takes extraordinary tenacity for the DPA to succeed in obtaining significant corrective action at the request of those responsible, even though senior and/or financial management are not initially “convinced” of it.
This is reminiscent of the accident we are all familiar with and which is practically the “progenitor” of the ISM Code. Namely the sinking of the HERALD of FREE ENTERPRISE March 6, 1987, in Zeebrugga. While the causes of accidents are always multiple, the urgent request from the senior officers of the HOFE and its sister ships (POFE/ PRIDE OF FREE ENTERPRISE and SOFE/SPIRIT OF FREE ENTERPRISE) for a ballast water transfer pump twice as powerful as the existing one, which could rectify the trim more quickly, could have been granted ... one of the holes in James REASON’s « Swiss cheese model » might not have existed on this occasion!
This problem naturally exists, but here we come close to the human factor. “I am myself completely convinced, but can I insist beyond what is reasonable?” A cruel dilemma that, for some truly motivated DPAs, borders on a case of conscience, going as far as the right to quit!
Without dwelling on the criminal liability aspect of the DPA, it is certain that in cases of serious accidents due to a failure of critical equipment not knowingly addressed by the Company, the judge will seek liability, including that of the DPA in its role of providing ultimate information to the CEO!
3-7 DPA Resources: staff, budget, appropriate training, job description, and the effective power to report irregularities at the highest level
From the very beginning of the code’s implementation, the problem of a DPA’s resources was apparent. Well, at least in companies that had understood the DPA’s role needing staff, a budget and traditional resources! By appointing a DPA without truly understanding their supervisory role, or by establishing a DPA department without a proper description of responsibilities, the Code’s early days were disastrous. They appeared completely useless ... which, among other things, gave the ISM Code a completely false reputation initially. We’re still struggling to overcome this almost 20 years later!
So today, a DPA service is included in the budget and is a natural part of budgetary decisions.
But let’s not kid ourselves, things don’t always go smoothly, especially when the sums involved are substantial!
THE REPORT | MAR 2026 | ISSUE 115 | 79
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