Management Review
The moment when the Company — not the DPA alone — 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 of the continuing adequacy and effectiveness of the Safety Management System, which the ISM Code assigns to the Company (§12.3). 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 the top of the organisation is the practical point of this exercise: it exists to prevent safety from being delegated solely to the DPA or technical offices, without real visibility and commitment at the highest decision-making levels. But it is worth stating exactly how the Code expresses this, because it does not use the phrase «top management»: evaluation of the effectiveness of the SMS is attributed to the Company (§12.3), the Designated Person's direct access to the “highest level of management” is imposed by §4, and the commitment of the top is stated in the Preamble (§6). The difference matters the moment an auditor asks which paragraph the claim rests on.
Regulatory Reference
ISM Code, par. 1.4 (Functional Requirements) and par. 12 (Company Verification, Review and Evaluation). The specific provision is §12.3: “The Company should periodically evaluate the effectiveness of the SMS in accordance with procedures established by the Company”.
Two points, on the number and on the words, because both circulate wrongly. On the number: until 31 December 2014 this provision was §12.2; resolution MSC.353(92), in force from 1 January 2015, inserted a new §12.2 on verifying delegated ISM tasks and renumbered the paragraphs that followed. Anyone still citing §12.2 for the effectiveness of the SMS is reading a text that expired more than ten years ago.
On the words: the expression «top management» appears nowhere in the ISM Code. §12.3 attributes the evaluation to the Company, and the Company is a subject defined by §1.1.2, not a rung of the hierarchy. That does not make the top irrelevant: §4 requires the Designated Person to have “direct access to the highest level of management”, and the Preamble, at §6, states that “the cornerstone of good safety management is commitment from the top”. The substance holds; the citation does not. In an audit, presenting «top management involvement» as an explicit requirement of the Code invites a challenge you lose, because the auditor asks for the paragraph number and that paragraph does not exist.
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 applicable external verifications: annual and renewal for the Document of Compliance, intermediate and renewal for the Safety Management Certificate. The DOC has no intermediate verification, and the Code does not require the review to be held immediately before each external verification: the Company procedure sets the interval.
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 meeting with documented attendance of whoever decides on resources, not of the DPA alone: the Code does not use the phrase “top management”, but §4 requires the Designated Person to have direct access to the “highest level of management”, and without that level in the room the review cannot produce decisions on resources.
- 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. (“minor NC” is a category of practice: the ISM Code defines only the major non-conformity — see the dedicated page.) Decision: review of resources allocated to the maintenance department and a special internal audit targeted at the two vessels within the following quarter."
What Typically Goes Wrong
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 that the review was conducted at the level that decides on resources | 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 |
What the PSCO Checks
Operational Tips
- Prepare the Management Review with aggregated data (NC trends, Near Misses, PSC deficiencies), not just itemised lists.
- Always document who actually took part at the level that decides on resources — the Code’s “highest level of management” — not the DPA alone.
- Verify at the next review that the actions decided at the previous one have actually been completed.
Preparation checklist
Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.
- Inputs gathered: audits, NCs, Near Misses, incidents, crew feedback
- Documented participation of the level that decides on resources (“highest level of management”, §4), not of the DPA alone
- Trend analysis, not just event counts
- Decisions recorded with an owner and a deadline
- Actions from the previous review verified as completed
FAQ
Related Topics
Last substantive revision of this page: 29 August 2026 · page fingerprint d546c4d62024