The annual management review is the one meeting where top management is expected to look at the whole safety management system and decide what changes. Too often it becomes a slide pack nobody acts on. This guide shows DPAs how to prepare a review that meets the ISM Code, uses audit trends and incident analysis properly, and produces decisions an auditor can follow, with every input collected automatically in Marine Inspection.

ISM Code 12.2 · DPA preparation

Management review meeting: prove the SMS works and decide what changes

A management review has two jobs: judge whether the safety management system is effective, and commit resources to fix what is not. If the minutes show no decisions, the review did not happen in any meaningful sense.

Minimum inputs (IMO company guidelines)

Internal audit results
Non-conformities reported by personnel
Masters’ reviews of the SMS
Analysis of non-conformities, accidents and hazardous occurrences
External evidence such as PSC inspection reports
Build your review pack free See the action carry-over ledger

What the ISM Code requires from a management review

The ISM Code does not use the words “management review meeting”, but it requires the outcome. IMO’s guidelines for companies (MSC-MEPC.7/Circ.8) describe how the review should work in practice. Fleets that want to see these duties tracked can ask for a demo.

ISM 12.2

Evaluate effectiveness

The company periodically evaluates the effectiveness of the SMS and, when needed, reviews it, following its own procedures.

ISM 5.1.5

Master’s review

Each master periodically reviews the SMS and reports its deficiencies to shore-based management.

ISM 4

DPA monitors

The designated person, with direct access to the highest level of management, monitors the evaluation and review of SMS effectiveness.

Circ.8 §5.2

Review and communicate

Reviews are periodic or triggered by events such as serious system failures; deficiencies get corrective action and results are formally communicated to the people involved.

Management review inputs: the minimum data set and what to add

The IMO guidelines list five minimum inputs. A useful review adds the measures that show direction over time, so the meeting can see whether last year’s decisions worked. Our ISM internal audit guide covers the audit side; collect every input automatically, free.

IMO minimum
  • Internal audit results, ship and shore
  • Non-conformities reported by personnel
  • Masters’ reviews from every ship
  • Analysis of non-conformities, accidents and hazardous occurrences
  • External evidence: PSC reports, flag and class audits
Good practice to add
  • Status of actions from the last review
  • Safety and environmental objectives against targets
  • Vetting results and SIRE 2.0 observation trends for tankers
  • Near-miss reporting rates and themes
  • Management of change: what changed and how it went
  • Coming regulatory changes and resource needs

Audit trends for the management review: seeing direction, not snapshots

A list of this year’s findings tells management very little. Trends over several years show whether the system is getting better, and where it is not. Present a few measures the same way every year so the meeting can compare. The tiles below are illustrative.

Findings per internal audit
Down 31%over three years
Repeat findings
Up to 18%of all findings
Average days to close
41 daysfrom 62
Near misses per ship per month
Up to 4.2more reporting is good

Illustrative figures. Repeat findings rising while total findings fall usually means corrective actions are not removing root causes.

Incident analysis for the management review: what the data should answer

Incident analysis is where the review earns its value. The question is not how many incidents happened but what they have in common, and whether the system would stop the next one. Treat PSC findings as signals too: DNV notes that ISM-related detentions often build up from several deficiencies that are not detainable on their own. Our PSC deficiency codes guide explains how those findings are coded.

What are the top three causes?Across incidents, near misses and findings, grouped by root cause, not by ship.
Which barriers failed?Procedure, equipment, training or supervision, and whether it was the same barrier more than once.
Are leading indicators moving?Near-miss reports, drills and training completion change before incidents do.
Where is reporting quiet?A ship with no near misses is more likely under-reporting than perfect.
What did PSC and vetting see?External findings that internal audits missed show where the internal programme is blind.
Did last year’s fixes work?Compare the causes targeted last year with this year’s data.

For context, ISM Code items made up 4.6% of all Paris MoU deficiencies in 2024.

Walk into the review with the data already prepared

Audit trends, incident themes, masters’ reviews and last year’s actions gathered into one review pack, ready for top management.

Prepare your review Book a DPA demo

Top management involvement in the ISM management review

The ISM Code expects the designated person to have direct access to the highest level of management, and the review is where that access is used. Auditors look at who attended and whether the minutes show decisions only top management can make. See attendance and decisions recorded.

Who should attend

Managing director or CEODesignated person ashoreTechnical managerMarine or fleet managerCrewing managerQHSE managerCompany security officer

Decisions only they can make

  • Approve resources: people, budget, training, equipment
  • Set or revise safety and environmental objectives
  • Approve significant SMS changes
  • Accept or reject risks that cannot be removed
  • Assign owners for system-level actions

Management review meeting agenda

A fixed agenda keeps the review focused and makes year-on-year comparison easy. Send the pack at least a week before, so the meeting discusses decisions rather than reading data. Use this agenda as a free template.

1Actions from the last reviewstatus and effect
2Objectives and KPIsresults against targets
3Audit results and trendsinternal and external
4Incidents and near missescauses and barriers
5Masters’ reviewsthemes across the fleet
6External findingsPSC, flag, class, vetting
7Changes and resourcesregulation, fleet, people
8Decisions and actionsowners, dates, communication

Management review outputs auditors look for

External auditors judge the review by its outputs. They look for decisions, owners and dates, evidence that results reached the fleet, and proof the actions were followed up. If findings did become a formal non-conformity, our major non-conformity recovery guide covers what follows.

Signed minutesAttendees, inputs reviewed, conclusion on SMS effectiveness
Decisions with ownersEach action named, dated and linked to the issue it addresses
Revised objectivesTargets for the coming year, based on the trends reviewed
SMS changesProcedure revisions approved, with the reason recorded
Fleet communicationResults formally shared with masters and crews, as the IMO guidelines expect
Follow-upActions tracked between reviews and reported at the next one

Management review preparation checklist

Tick these items before and after the meeting. The DPA usually owns this list.

How Marine Inspection makes management review actions stick

The weakest part of most reviews is what happens after the meeting. Marine Inspection builds the review pack from live fleet data and carries every decision forward as a tracked action, so the next review opens with an honest account of what was done. The ledger below is an illustrative example.

Actions carried from last management review9 actions · 6 done · 2 in progress · 1 overdue
DecisionOwnerDueStatusEffect seen
Revise emergency fire pump test record fleet-wideTechnicalQ1DoneNo repeat findings
Add two navigation assessors for sailing auditsMarineQ2DoneNav findings down
Near-miss campaign on three quiet shipsDPAQ2DoneReports up 2.5x
Crew wellbeing survey and follow-upCrewingQ3In progressSurvey 70% returned
Chart correction workload reviewMarineQ2OverdueRepeat finding on 2 ships
Pack built from live dataAudit, incident, PSC and master’s review data compiled automatically.
Trends the same way every yearKPIs calculated consistently, so years can be compared.
Decisions become actionsEach decision tracked with owner, date and evidence.
Fleet communication loggedProof that results reached every ship.

ISM management review FAQs

Does the ISM Code require a management review?

The Code requires the company to periodically evaluate the effectiveness of the SMS and review it when needed (12.2). IMO’s guidelines for companies describe this as a management review and list its minimum inputs.

How often should the management review be held?

Most companies hold it at least once a year, and the IMO guidelines also call for a review when needed, for example after a serious system failure.

What are the minimum inputs?

Internal audit results, non-conformities reported by personnel, masters’ reviews, analysis of non-conformities, accidents and hazardous occurrences, and external evidence such as PSC inspection reports.

What is the master’s review?

The master’s periodic review of the SMS on board, with deficiencies reported to shore management, as ISM 5.1.5 requires. It is a required input to the management review.

What role does the DPA play?

The DPA monitors the evaluation and review of SMS effectiveness and has direct access to top management. In practice the DPA usually prepares the review pack and tracks the actions.

What do auditors check in management review records?

That the required inputs were reviewed, top management took part, decisions were made with owners and dates, results were communicated, and actions were followed up. Marine Inspection can keep that trail for every review.

One review a year, twelve months of follow-through

Give top management a review built on live fleet data, and give the DPA a way to make every decision stick.

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