Inspections and audits

The order and duration of the Interim DOC and Interim SMC on the day the company changes (ISM Code chapter 14)

On the day a ship passes to a new managing company, the SMC on board is a certificate that was tied to the previous company’s DOC. ISM Code paragraph 13.1 has the ship operated by a company holding a DOC or an Interim DOC relevant to that ship, and the SMC form states that the certificate is valid only while the DOC remains valid. When the company changes, that link breaks.

Chapter 14 on interim certification fills the gap. Chapter 14 was added as a new chapter by resolution MSC.104(73), which entered into force on 1 July 2002. The Interim DOC goes to the company and the Interim SMC to the ship, and their periods and conditions differ.

This article follows the order from the day the company changes. Which certificate comes first, how long each runs, what is verified before issue, and how the two are tied together.

An Interim DOC runs up to 12 months when a company is newly established or adds a ship type

14.1 An Interim Document of Compliance may be issued to facilitate initial implementation of this Code when: .1 a Company is newly established; or .2 new ship types are to be added to an existing Document of Compliance, following verification that the Company has a safety management system that meets the objectives of paragraph 1.2.3 of this Code, provided the Company demonstrates plans to implement a safety management system meeting the full requirements of this Code within the period of validity of the Interim Document of Compliance.

There are two grounds. A newly established company, and new ship types being added to an existing DOC. An existing company taking over a ship of a type already on its DOC does not need an Interim DOC. Its existing DOC is relevant to that ship as it stands.

There are two conditions as well. Verification that the company’s safety management system meets the objectives of paragraph 1.2.3, and a demonstrated plan to implement a system meeting the full requirements of the Code within the validity of the Interim DOC.

Such an Interim Document of Compliance should be issued for a period not exceeding 12 months by the Administration or by an organization recognized by the Administration or, at the request of the Administration, by another Contracting Government. A copy of the Interim 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.

The period cannot exceed 12 months. As with a full-term DOC, a copy goes on board and the copy needs no authentication or certification.

An Interim SMC runs up to 6 months in three cases and gains 6 more in special cases

14.2 An Interim Safety Management Certificate may be issued: .1 to new ships on delivery; or .2 when a Company takes on responsibility for the operation of a ship which is new to the Company; or .3 when a ship changes flag. Such an Interim Safety Management Certificate should be issued for a period not exceeding 6 months by the Administration or an organization recognized by the Administration or, at the request of the Administration, by another Contracting Government.

There are three grounds. New ships on delivery, a company taking on responsibility for the operation of a ship new to it, and a change of flag. A change of managing company is the second. The period cannot exceed 6 months.

14.3 An Administration or, at the request of the Administration, another Contracting Government may, in special cases, extend the validity of an Interim Safety Management Certificate for a further period which should not exceed 6 months from the date of expiry.

Extension is for the Administration, or another Contracting Government at its request, in special cases only, and cannot exceed 6 months from the expiry date. The Interim SMC form carries a separate extension box. Chapter 14 has no extension provision for the Interim DOC.

Six items are verified before an Interim SMC is issued

14.4 An Interim Safety Management Certificate may be issued following verification that: .1 the Document of Compliance, or the Interim Document of Compliance, is relevant to the ship concerned; .2 the safety management system provided by the Company for the ship concerned includes key elements of this Code and has been assessed during the audit for issuance of the Document of Compliance or demonstrated for issuance of the Interim Document of Compliance; .3 the Company has planned the audit of the ship within three months; .4 the master and officers are familiar with the safety management system and the planned arrangements for its implementation; .5 instructions, which have been identified as being essential, are provided prior to sailing; and .6 relevant information on the safety management system has been given in a working language or languages understood by the ship’s personnel.

The six items read in order. First, the DOC or Interim DOC has to be relevant to the ship. The company-side certificate must exist before the ship-side certificate can be issued. Second, the safety management system given to the ship has to include the key elements of the Code and have been assessed at the DOC audit or demonstrated at Interim DOC issue.

Third, the company has to have planned the audit of the ship within three months. MSC.273(85) inserted internal into this item, making clear that the audit is the company’s own internal audit. Fourth, the master and officers have to be familiar with the safety management system and the planned arrangements for its implementation. Fifth, instructions identified as essential have to be provided before sailing. Sixth, information on the safety management system has to be given in a working language the ship’s personnel understand.

The fourth to sixth items are checked on board. If the master and officers do not know the new system on the day the company changes, the conditions for the Interim SMC are not met.

The office assessment comes first and the ship follows

The Administration-side procedure is in paragraph 4.2 of the guidelines in resolution A.1118(30).

4.2.3 The process of interim verification for the issuance of an Interim Document of Compliance undertaken by the Administration would require an assessment at the company’s offices in accordance with paragraph 14.1 of the ISM Code.

4.2.4 On satisfactory completion of the assessment of the shoreside safety management system, arrangements/planning may commence for the assessment of applicable ships in the company’s fleet.

Once the company applies to the Administration for interim certification, the Administration assesses the company’s offices first under 14.1. Only after the shoreside system has been assessed satisfactorily does planning begin for the assessment of the ships in the fleet. The interim verification of a ship checks under 14.4 that the ship has been provided with a safety management system.

4.2.6 On satisfactory completion of the interim verification, an Interim Document of Compliance will be issued to the company; copies should be made available by the company to each shoreside premises and each applicable ship in the company’s fleet. As each ship is assessed and issued with an Interim Safety Management Certificate, a copy of the certificate should also be forwarded to the company’s head office.

When the Interim DOC is issued, the company sends copies to each shoreside premises and to each applicable ship. When a ship receives its Interim SMC, a copy goes the other way, up to the head office. Certificate copies travel in both directions.

Interim certificates also go when the DOC goes

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.

Paragraph 13.5.1 does not distinguish a full-term SMC from an Interim SMC. When the DOC is withdrawn, both are withdrawn. The Interim SMC form likewise states that the certificate is valid only while the DOC or Interim DOC remains valid. Where the company-side certificate is an Interim DOC, the Interim SMC stops being valid the moment that Interim DOC expires.

Side by side, the two certificates look like this.

	Interim DOC	Interim SMC
Issued to	The company	The ship
Grounds for issue	New company, new ship type	New ship on delivery, ship new to the company, change of flag
Period ceiling	12 months	6 months
Extension	No provision	6 months in special cases
Carried on board	A copy	The certificate (a copy goes to head office)

Worth confirming

This article covers only the chapter 14 text added by MSC.104(73), the amendment to 14.4.3 by MSC.273(85), and paragraph 4.2 of A.1118(30). Chapter 14 says the Administration may issue an interim certificate, so whether one is issued and by what procedure follows the requirements of the flag and the recognized organization. The expiry date of the ship’s Interim SMC, the internal audit date scheduled within three months, and whether the company-side DOC is full-term or interim 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 interim certificate expiry dates in the same register as full-term certificates

The 6 months of an Interim SMC run shorter than a full-term certificate, and the internal audit has to be scheduled inside them. Bellbook puts the issuing body and expiry date of an interim certificate on the ship certificate register and shows them on the fleet calendar in the order they come due.

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