The ISM Code, modelled the way it is actually written.
Eighty-six ISM requirements, each carrying the exact sentence of the Code it comes from. The Company holds the Document of Compliance, each ship holds its Safety Management Certificate - and the six detention grounds that follow from certificate dates, endorsements and the join between those two documents are computed rather than inspected.
86
ISM requirement checks, every one quoting the Code
6 of 10
ISM detention grounds computable without an inspection
DOC + SMC
Company and ship certificates modelled separately
13
Maritime risks, not one of them relabelled cyber
Safety management held in a spreadsheet the Code doesn't fit
ISM has a two-level structure and a certificate lifecycle. Tools that treat a certificate as a column on a hull cannot express either.
Certificates as fields on a hull
Detention ground 7 asks whether the ship type shown on a ship's Safety Management Certificate is listed on its manager's Document of Compliance. That is a join between two certificates - a question a spreadsheet column cannot ask, let alone answer across a fleet.
One withdrawal, every hull
ISM ¶13.5.1 withdraws every associated Safety Management Certificate when the Document of Compliance is withdrawn. A company-level lapse is not an amber flag - it reaches the certificate of every ship under management.
Blanket tonnage rules
A single 'over 500 GT' test exempts passenger vessels the Code reaches at any tonnage. The floor is written as an exclusion, and it reaches only cargo ships and mobile offshore drilling units.
The Code as structured, cited data
Applicability, certificates and detention exposure derived from the instrument's own text and your own records.
Every requirement quotes the Code
All 86 requirement checks carry the exact sentence of the Code they come from, verified character-for-character against the published text. When an auditor asks where a requirement comes from, the answer is a quote and a paragraph number.
The Company, as ISM defines it
Duties attach to ¶1.1.2's Company - the owner, or the manager or bareboat charterer who has assumed responsibility for the operation of the ship - not necessarily the registered owner. Third-party ship managers are first-class here, not an edge case.
Ground 7, answerable fleet-wide
ISM ¶13.3: the Document of Compliance is only valid for the ship types explicitly indicated in it. We hold the DOC's ship-type endorsements and each vessel's type as separate objects, so the question is one query across every hull under management.
The withdrawal cascade, modelled correctly
The graph is Company → DOC → many SMCs, because that is what ¶13.5.1 describes. Withdrawal reaches every associated Safety Management Certificate and interim certificate, regardless of who owns the hull.
Two SMC extensions, told apart
Five months when the renewal verification is complete but the certificate cannot be issued or placed on board (¶13.13). Three months to complete a voyage to the port of verification (¶13.14), on which the ship may not then leave that port without a new Safety Management Certificate. The five-month limit runs from the original expiry date, and the three-month extension extends a period that has already ended - so granting either late buys no extra time.
The EU and IMO scopes kept apart
Regulation (EC) No 336/2006 Art. 3(1)(b) reaches ships engaged exclusively on domestic voyages, regardless of flag. The IMO instrument does not. The two are modelled as separate regimes rather than collapsed into one rule.
Undetermined is never exempt
A hull whose tonnage or ship type nobody recorded returns an explicit undetermined verdict, never a clean one. Gross tonnage is stored with the convention that produced it, because a Suez or Panama figure is a different number for the same hull and is never the applicability figure.
Vessels are first-class assets
A ship sits on the same asset spine as everything else you govern - IMO number, flag, gross tonnage and its measurement convention, and ship type in the Code's own categories. Fifty-two requirements sit at company level; thirty-four attach per hull.
State powers stripped out
Annex II - the provisions for the Administration - produces no obligation. Elements 15 and 16, verification and the forms of certificates, are Administration-facing and yield nothing. Element 14 binds you only on its ¶14.4 limb: the conditions you must satisfy, not the act of issuing.
What we bind, and where it comes from
This is the ISM Code. SOLAS proper, MLC, ISPS, MARPOL and the Polar Code are not part of it, and nothing here implies them.
ISM Code - Part A, elements 1–12
International, via EU law
Reg. (EC) No 336/2006, Annex I
Safety-management system and policy, the Designated Person Ashore, the master's authority, resources and personnel, shipboard operations, emergency preparedness, non-conformity reporting, maintenance, documentation and internal audit.
ISM Code - Part B, elements 13–14
International, via EU law
Annex I ¶¶ 13.1–13.9, 14.4
Certification and interim certification. Element 14 binds only its ¶14.4 qualifying-conditions limb.
Certificate validity and survey windows
IMO ISM Code
¶¶ 13.2, 13.4, 13.7, 13.10–13.14
Five-year maximum validity, the DOC annual verification window of three months either side of the anniversary date, renewal arithmetic before and after expiry, and the two SMC extensions.
ISM detention grounds
IMO res. A.1206(34), App. 2
Grounds 4, 5, 6, 7, 8, 10
The six grounds that are pure date computation, a referential join between the DOC and the SMC, or a missing verification endorsement. Ground 10 is checked on the issuing authority. Grounds 1, 2, 3 and 9 need a physical inspection and are out of scope by design.
Applicability and exclusions
EU and IMO
Reg. (EC) No 336/2006, Art. 3(1); Art. 3(2)(a), (c), (d)
Ship type and gross tonnage with its measurement convention, and the government, fishing-vessel and sub-500 GT cargo/MODU exclusions. Passenger ships carry no tonnage floor.
Elements 15 and 16, and Annex II
Excluded, deliberately
Annex I elements 15–16; Annex II
Nothing. Verification, the forms of certificates and the flag-State implementation provisions are what the Administration does, not what you must do.
