The International Chamber of Shipping's analysis confirms that ISM Code deficiencies — particularly inadequate internal audit programmes and incomplete SMS documentation — consistently appear in the top three causes of port state control detention worldwide. The sixth edition ICS Guidelines add a dedicated chapter on internal audits.
Port state control (PSC) detention is among the most operationally and commercially damaging events in maritime operations. A detained vessel is taken out of service until deficiencies are rectified to the satisfaction of the inspecting authority — a process that can take days and cost tens of thousands of dollars in commercial losses, repair costs, and reputational damage.
The International Chamber of Shipping's analysis of global PSC inspection data consistently places ISM Code deficiencies in the top three causes of detention. Common ISM-related deficiencies include: incomplete or outdated Safety Management Manuals, SMS procedures that do not reflect actual shipboard practice, inadequate internal audit programmes, non-conformities that were identified but not corrected within required timeframes, and poor documentation of drills and emergency response exercises.
The sixth edition of the ICS Guidelines on the Application of the ISM Code, published in response to this persistent compliance pattern, includes a brand new chapter dedicated to internal audits — reflecting industry recognition that the internal audit programme is the primary mechanism through which SMS gaps are identified and corrected before a PSC inspector arrives.
The UK government's consultation on new ISM Code Merchant Shipping Regulations (published July 2025) further underscores the regulatory direction: modernising compliance frameworks, increasing transparency of SMS documentation requirements, and strengthening accountability for Designated Persons Ashore (DPA).
What this means for DPAs and ship managers: The internal audit programme is not a box-ticking exercise — it is the primary defence against PSC detention. An effective internal audit programme requires: annual audits of every SMS element, qualified auditors who are not auditing their own procedures, findings that are corrected within defined timeframes, and a documented record of the entire process that can be presented to a PSC inspector. Operators who treat internal audits as paperwork rather than governance are systematically exposed to detention risk.
Cybersecurity has also entered the ISM compliance framework: IMO Resolution MSC.428(98) requires that cyber risks be addressed within the SMS, meaning cyber incident management and risk assessment are now mandatory components of ISM-compliant SMS documentation.
SIRAM's Audit & Assurance module with 4-check governance validation directly addresses the two most common ISM PSC deficiencies: inadequate audit programme management and unresolved non-conformities.
See how SIRAM works →14-day free trial. Full access. No credit card required.