• To ensure existing all best practices are taken into account in the SMS, given the very good knowledge of these published practices, certainly in English, but sometimes also in a different working language. Today, the IMO’s free GISIS database ensures an update of these “best practices,” particularly in the port sector ... which is not, however, the exclusive domain of the IMO.
• Finally, to collect and study accident cases not just within the Company but also within our industry in order to draw lessons to improve the SMS. The IMO’s GISIS website also publishes the regulatory accident investigation reports according to SOLAS and international maritime newspapers … Some publish the results of near misses in a voluntarily and anonymously manner (CHIRP). Considering the results or recommendations can then be used to develop appropriate preventive measures. This approach is logical and should become popular in our industry. Just think, this is completely free feedback!
Ultimately, this type of experience, highly recommended for a DPA, is acquired through training and maintained through continuing education. Today, various analyses are published on many related
82 | ISSUE 115 | MAR 2026 | THE REPORT
websites, which generally include feedback. It would be counterproductive to refuse to participate, even if the circular above does not specify it.
NB: Civil aviation is also testing this CHIRP (Confidential Human Incident Reporting Program[FB1.1][MS1.2]) system.
For your information: near-miss reports are submitted to
reports@chirp.co.uk
5-LEGAL ASPECT OF THE FUNCTION
The DPA was created 30 years ago, and of course, the legal risks associated with this function have generated a lot of discussion. The subject is not easy because, deliberately, the code is written in general terms ... which are not at all part of the normal legal process ... criminal liabilities related to the ISM Code have therefore, admittedly, had a hard time to emerge.
Philip Anderson deserved credit for starting work on the legal aspect of the DPA’s responsibilities, and he said he was waiting for the courts to clarify reciprocal responsibilities, especially in emergency situations.
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