An ISM ISPS MLC internal audit examines three separate regimes, usually in a single visit. Each has its own certificate and its own requirement for audits, which makes combined auditing practical for managers with several ships.
The ISM Code, made mandatory through SOLAS Chapter IX, requires a company to hold a document of compliance and each ship to hold a safety management certificate. The code itself calls for internal audits on board and ashore at intervals the company defines, with corrective action, and for management review. The ISPS Code, under SOLAS Chapter XI-2, requires an approved ship security plan, a designated ship security officer, a company security officer, and an International Ship Security Certificate; drills and security records must be kept. The Maritime Labour Convention, 2006 requires a Declaration of Maritime Labour Compliance, with Part I issued by the flag and Part II drawn up by the owner, setting out how the ship meets standards for employment agreements, hours of rest, wages, accommodation, food, medical care and repatriation.
An external auditor can give the independence an in-house team lacks. The auditor reads the manuals against the code requirements, then tests whether the ship does what the documents say. Examples include tracing a reported non-conformity to its closure, checking the master's review, verifying that security levels are understood, testing access control at the gangway, and comparing rest hour records with watch schedules, wage accounts and crew agreements.
When selecting an auditor, confirm their lead auditor qualifications, whether they can work under the company's flag-approved procedures, and how they will treat sensitive security material, since the ship security plan is confidential.
The report lists observations and non-conformities with the clause concerned, separates major and minor items, and sets out corrective action requests with dates.
Common non-conformities include overdue drills, rest hour records that do not reconcile, security plan amendments not approved, and corrective actions closed without evidence.
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