I am a sailing master, and have experienced the positive effects of ISM Code. ISM Code has improved safety standards on board all ships. Accidents still occur and fatigue is identified as the cause almost always. ISM code can offer a solution to the manning and fatigue problem.

 During the past few years I have gone through many ISM audits. What I noticed in the conduct of audit is that the auditor seeks objective evidence to prove compliance of written SMS procedures of the company. It is no secret that rest hour records and operational checklists are the most falsified documents on any ship today. I feel that the scope of a safety audit should examine if the SMS can be implemented with the available manning. To this extent the audit should be conducted with the auditor sailing on board the vessel, if required. The safe Manning Certificate should be unique to every vessel and should be subject to audit. Such audit will ensure adequate manning keeping with the age and trade pattern of the vessel while also ensuring truthful compliance with company's SMS.

After all is it not common sense that a safe ship (possessing a safety management certificate) should be safely manned, to truthfully implement the Safety Management System?