4.3.3 Auditing Voluntary Adopted Safety Management Systems
The objectives of the International Safety Management Code (ISM Code) are to prevent human
injury, loss of life, and damage to the environment. Although most vessel operators in Canada
are not required to comply, several have done so voluntarily.

The goal of a safety management system (SMS) is to permit participants to detect and prevent
unsafe practices and conditions before an accident occurs rather than having others identify
safety shortcomings afterward. It is therefore important that, when any non-conformity is
reported, appropriate corrective action be taken in a timely manner.

In this occurrence, internal and external audits failed to identify a number of shortcomings. It
was also reported that external audits did not always apply the same standards regarding
compliance. Major non-conformities, for example, which would have otherwise been cited, may
not have been issued because the ISM Code had been adopted voluntarily. Therefore, less
emphasis may have been placed on taking corrective action—effectively defeating the objectives
of both the ISM Code and an effective SMS.

In Canada, TC has delegated five classification societies108 to perform ISM Code audits on
Convention vessels. TC also monitors, via audits, the activities of these classification societies.
However, TC’s monitoring, auditing, and overview is for mandatory systems only: TC does not
monitor the application of the ISM Code where it has been voluntarily adopted.
The Board is concerned that this lack of consistent application compromises the objectives of the
ISM Code. Moreover, the Board believes that, with the large numbers of passengers that may be
carried at any one time on a passenger vessel, quality audits are essential in being able to
identify deficiencies requiring corrective action. The Board, therefore, will monitor the situation.