Inspections and audits

Where the DOC annual verification and the SMC intermediate verification run on different clocks (ISM Code chapter 13, MSC.104(73))

The ISM Code splits certification in two. The company receives a Document of Compliance (DOC) and the ship receives a Safety Management Certificate (SMC). The two certificates go to different holders, carry different anniversary dates, and open their verification windows at different times.

This article covers Part B chapter 13 of the ISM Code as inserted by resolution MSC.104(73). The resolution entered into force on 1 July 2002, replaced the old chapter 13 with the Part B chapter on certification and verification, and brought certificate validity and verification intervals into the text of the Code. Paragraphs 13.12 to 13.14, added later by MSC.273(85), are covered as well.

Read the two clocks as one and a window gets missed. If the DOC annual verification is not requested, the DOC is withdrawn, and when the DOC is withdrawn every SMC of that company goes with it. Tracking one ship’s intermediate verification date alone does not reveal that the company clock has stopped.

The DOC is issued to the company and the ship carries only a copy

13.2 The Document of Compliance should be issued by the Administration, by an organization recognized by the Administration or, at the request of the Administration, by another Contracting Government to the Convention to any Company complying with the requirements of this Code for a period specified by the Administration which should not exceed five years. Such a document should be accepted as evidence that the Company is capable of complying with the requirements of this Code.

Paragraph 13.2 sets who issues the DOC and for how long. The issuer is the Administration, an organization recognized by the Administration, or another Contracting Government at the Administration’s request. The period is set by the Administration and cannot exceed five years. Under 13.3 the DOC is valid only for the ship types indicated on it, and adding a ship type requires verifying the company’s capability for that type first.

13.6 A copy of the Document of Compliance should be placed on board in order that the master of the ship, if so requested, may produce it for verification by the Administration or by an organization recognized by the Administration or for the purposes of the control referred to in regulation IX/6.2 of the Convention. The copy of the document is not required to be authenticated or certified.

Paragraph 13.6 says what goes on board is a copy. On request the master produces it for verification by the Administration or a recognized organization, or for control under SOLAS regulation IX/6.2. The copy needs no authentication or certification.

The DOC annual verification falls within three months either side of the anniversary date

13.4 The validity of a Document of Compliance should be subject to annual verification by the Administration or by an organization recognized by the Administration or, at the request of the Administration, by another Contracting Government within three months before or after the anniversary date.

The annual verification window is centred on the anniversary date and opens three months before and three months after it. The reference is the anniversary date, not the date of issue. The window returns every year, and the DOC form in the appendix carries four annual verification endorsement boxes before renewal.

What the Administration looks at during the annual verification is set out in the guidelines of resolution A.1118(30).

4.4.1 Annual safety management audits are to be carried out to maintain the validity of the Document of Compliance and should include examining and verifying the correctness of the statutory and classification records presented for at least one ship of each type to which the Document of Compliance applies.

The annual verification pulls the statutory and classification records of at least one ship of each type covered by the DOC. It is a company-side audit, but ship records come in as evidence. Paragraph 4.4.4 of the same guidelines adds that the annual verification checks whether the company still operates every ship type stated on the DOC.

The SMC is issued to the ship and the intermediate verification falls between the second and third anniversary dates

13.7 The Safety Management Certificate should be issued to a ship for a period which should not exceed five years by the Administration or an organization recognized by the Administration or, at the request of the Administration, by another Contracting Government. The Safety Management Certificate should be issued after verifying that the Company and its shipboard management operate in accordance with the approved safety management system. Such a certificate should be accepted as evidence that the ship is complying with the requirements of this Code.

The SMC also has a five-year ceiling. What differs is what is verified before issue. The SMC is issued after confirming that the company and its shipboard management operate in accordance with the approved safety management system. The SMC form records that the DOC applies to that ship type, and the SMC stays valid only while the DOC remains valid.

13.8 The validity of the Safety Management Certificate should be subject to at least one intermediate verification by the Administration or an organization recognized by the Administration or, at the request of the Administration, by another Contracting Government. If only one intermediate verification is to be carried out and the period of validity of the Safety Management Certificate is five years, it should take place between the second and third anniversary date of the Safety Management Certificate.

At least one intermediate verification is required. Where only one is carried out and the SMC runs five years, the window is between the second and the third anniversary date. Unlike the annual verification it is not a band around an anniversary but the full year between two anniversaries. Paragraph 4.5.1 of A.1118(30) notes that the Administration may increase the frequency of intermediate verifications during the initial period of operation or depending on the nature of non-conformities.

Side by side, the two clocks look like this.

	DOC	SMC
Issued to	The company	The ship
Validity ceiling	Five years	Five years
Periodical verification	Annual verification, three months either side of the anniversary	Intermediate verification, between the second and third anniversary dates
Grounds for withdrawal	Annual verification not requested, major non-conformity	Intermediate verification not requested, major non-conformity, DOC withdrawn

The renewal verification completion date sets the new expiry date

13.10 Notwithstanding the requirements of paragraphs 13.2 and 13.7, when the renewal verification is completed within three months before the expiry date of the existing Document of Compliance or Safety Management Certificate, the new Document of Compliance or the new Safety Management Certificate should be valid from the date of completion of the renewal verification for a period not exceeding five years from the date of expiry of the existing Document of Compliance or Safety Management Certificate.

13.11 When the renewal verification is completed more than three months before the expiry date of the existing Document of Compliance or Safety Management Certificate, the new Document of Compliance or the new Safety Management Certificate should be valid from the date of completion of the renewal verification for a period not exceeding five years from the date of completion of the renewal verification.

Both paragraphs apply to the DOC and the SMC alike. The test is whether the renewal verification was completed within the three months before the existing expiry date. If it was, the new certificate is valid from the completion date with a ceiling of five years from the existing expiry date. If it was completed earlier than three months before, the ceiling is counted as five years from the completion date. The earlier the renewal is completed, the earlier the next expiry date moves.

MSC.273(85) added the case of completion after expiry as 13.12.

13.12 When the renewal verification is completed after the expiry date of the existing Safety Management Certificate, the new Safety Management Certificate should be valid from the date of completion of the renewal verification to a date not exceeding five years from the date of expiry of the existing Safety Management Certificate.

Even when the renewal verification is completed after expiry, the ceiling is five years from the existing expiry date. This paragraph speaks of the SMC only.

Take an existing SMC expiring on 31 March 2028 and put the three cases side by side.

Renewal verification completed	Paragraph	New SMC valid from	New SMC expiry ceiling
15 February 2028 (within three months before expiry)	13.10	Completion date	31 March 2033
20 November 2027 (more than three months before expiry)	13.11	Completion date	20 November 2032
20 April 2028 (after expiry)	13.12	Completion date	31 March 2033

The dates are fictional worked examples of the rule; the actual expiry date is the one the issuing body writes.

There is also the case where the new certificate cannot be placed on board straight away.

13.13 If a renewal verification has been completed and a new Safety Management Certificate cannot be issued or placed on board the ship before the expiry date of the existing certificate, the Administration or organization recognized by the Administration may endorse the existing certificate and such a certificate should be accepted as valid for a further period which should not exceed five months from the expiry date.

Where the renewal verification is done but the new SMC does not reach the ship before expiry, the existing certificate can be endorsed and accepted as valid for not more than five months from the expiry date. Paragraph 13.14 covers a ship that is not in the port where it is to be verified. It allows an extension of not more than three months, only so the ship can complete its voyage to that port, and the new SMC ceiling after an extension is five years from the expiry date before the extension was granted.

A certificate is withdrawn when verification is not requested, and the SMC goes when the DOC goes

13.5 The Document of Compliance should be withdrawn by the Administration or, at its request, by the Contracting Government which issued the document, when the annual verification required in paragraph 13.4 is not requested or if there is evidence of major non-conformity with this Code.

13.5.1 All associated Safety Management Certificates and/or Interim Safety Management Certificates should also be withdrawn if the Document of Compliance is withdrawn.

There are two grounds. Not requesting the annual verification under 13.4, and evidence of major non-conformity with the Code. Failing the verification is not the only trigger; not requesting it is a ground in itself. Paragraph 13.5.1 withdraws every associated SMC and Interim SMC once the DOC is withdrawn. When the company clock stops, every ship of that company stops with it.

13.9 In addition to the requirements of paragraph 13.5.1, the Safety Management Certificate should be withdrawn by the Administration or, at the request of the Administration, by the Contracting Government which has issued it, when the intermediate verification required in paragraph 13.8 is not requested or if there is evidence of major non-conformity with this Code.

The SMC side has the same structure. Not requesting the intermediate verification under 13.8, or evidence of major non-conformity, withdraws the certificate. Add 13.5.1 and an SMC can be lost by three routes.

Worth confirming

This article covers only the chapter 13 text of MSC.104(73) and paragraphs 13.12 to 13.14 as added by MSC.273(85). Later amendments to the ISM Code are not covered. A.1118(30) is guidance for Administrations, not the text of the Code. The expiry dates written on the ship’s DOC and SMC, how many annual verification endorsements have been stamped, and whether the intermediate endorsement is already on the SMC are where the actual judgement starts.

You can consult the cited source documents

These links lead to the official publishers of the documents discussed here. Match the edition and provisions cited in the article, and check subsequent amendments and flag-state implementation before applying them.

Bellbook keeps the annual, intermediate and renewal verification dates next to each certificate's expiry

The DOC and the SMC have different anniversary dates and their windows open differently. Bellbook holds the issuing body, the expiry date and the annual, intermediate and renewal dates on one line of the ship certificate register, so which window closes first can be read off the expiry date.

Start for free