Management Review
The moment when the Company's top management formally takes responsibility for verifying that the SMS truly works — not just that it exists on paper.
Operational Explanation
The Management Review is the periodic assessment, conducted by the Company's top management, of the continuing adequacy and effectiveness of the Safety Management System. It is not an audit (which verifies point-in-time compliance), but a strategic evaluation: is the SMS still achieving the Company's safety and environmental protection objectives? Does it need to be changed?
Direct involvement of top management is an explicit requirement of the ISM Code precisely to prevent safety from being delegated solely to the DPA or technical offices, without real visibility and commitment at the highest decision-making levels.
Regulatory Reference
ISM Code, par. 1.4 (Functional Requirements) and par. 12 (Company Verification, Review and Evaluation): top management must periodically review the SMS to ensure its continuing suitability and effectiveness.
Scope of Application
Every ISM-certified Company, typically on an annual basis (or at intervals defined in its own internal procedure), before or in preparation for the external renewal/intermediate audit of the Document of Compliance.
Procedure / How to Complete It
- Gather inputs: outcomes of internal and external audits, open/closed NCs, Near Misses and incidents, crew feedback, complaints, PSC/vetting inspection results.
- Convene the Management Review meeting with documented attendance of top management (not only the DPA).
- Assess the adequacy of resources assigned to the SMS (personnel, training, maintenance and safety budget).
- Identify trends, areas for improvement and any need to amend SMS procedures or objectives.
- Record decisions and assigned actions, with an owner and a deadline, and verify their implementation at the next review.
Practical Example
Example minutes: "2026 Management Review — Reviewed 18 NCs (3 major, 15 minor) and 42 Near Misses for the year. Trend identified: 6 minor NCs linked to overdue preventive maintenance on two fleet vessels. Decision: review of resources allocated to the maintenance department and a special internal audit targeted at the two vessels within the following quarter."
Real Cases
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Management Review reduced to a completed form without real discussion | NC in certification audit for lack of evidence of genuine top management involvement | Document the meeting with minutes, participants and concrete decisions |
| Data analysis (NC, Near Miss) purely quantitative, without looking for trends | Systemic problems remain invisible until an incident or a serious deficiency occurs | Always include trend analysis, not just event counts |
| Management Review decisions without an owner or a deadline | Agreed actions are never completed | Always assign an owner and a date to every decided action |
PSC Observations
Operational Tips
- Prepare the Management Review with aggregated data (NC trends, Near Misses, PSC deficiencies), not just itemised lists.
- Always document the actual participation of top management, not only the DPA.
- Verify at the next review that the actions decided at the previous one have actually been completed.
Checklist
- Inputs gathered: audits, NCs, Near Misses, incidents, crew feedback
- Top management participation documented
- Trend analysis, not just event counts
- Decisions recorded with an owner and a deadline
- Actions from the previous review verified as completed