ISM Code and Your PMS: What the Regulations Actually Require

Every engineer on a commercially operated superyacht knows the ISM Code exists. Most have sat through at least one ISM audit. But if you ask the average Chief Engineer what the ISM Code specifically requires from their PMS, the answer is usually vague. Something about having a planned maintenance system. Something about records.

That vagueness is a problem, because auditors are not vague. They know exactly what they are looking for, and they will find the gaps in your database whether you know those gaps exist or not.

This article is a plain-English breakdown of what the ISM Code actually says about maintenance, what auditors check in your PMS, and what you can do to make sure your database stands up to scrutiny.

What the ISM Code actually says

The International Safety Management Code is structured into sections. The one that directly concerns your PMS is Section 10: Maintenance of the Ship and Equipment.

Section 10.1 states that the company should establish procedures to ensure that the ship is maintained in conformity with the provisions of relevant rules and regulations and with any additional requirements which may be established by the company.

Section 10.2 requires the company to ensure that inspections are held at appropriate intervals, any non-conformity is reported with its possible cause (if known), appropriate corrective action is taken, and records of these activities are maintained.

Section 10.3 requires the company to identify equipment and technical systems where sudden operational failure may result in hazardous situations, and to establish procedures for providing reliability through testing of standby arrangements and regular maintenance.

That is the full text on maintenance. Three sub-sections. It reads as fairly high-level, and that is deliberate. The ISM Code is a framework, not a technical specification. It tells you what outcomes you need to achieve, not exactly how to achieve them.

But here is where it gets specific in practice: every one of those requirements generates evidence that auditors will look for. And most of that evidence lives in your PMS.

What auditors actually check

ISM audits come in two forms. Internal audits are conducted by the company (typically the management company or designated person ashore). External audits are conducted by the flag state administration or a recognised organisation acting on their behalf.

Both types follow the same logic. The auditor is checking whether your Safety Management System (SMS) is implemented and working as described in your documentation. For maintenance, that means checking whether your planned maintenance system is doing what your SMS says it does.

Here is what they look at in practice:

Does the PMS exist and is it operational?

This sounds obvious, but it is a genuine check. The auditor will verify that the vessel has an active planned maintenance system, that it is being used, and that it is not just software installed on a computer that nobody opens. They will ask the Chief Engineer to demonstrate the system. They will want to see it running, not described.

If the PMS is effectively dormant — installed but not actively used for planning and recording maintenance — that is a non-conformity.

Do the maintenance tasks match the SMS procedures?

Your SMS documentation describes how the vessel manages maintenance. The PMS should reflect that description. If your SMS says maintenance is carried out in accordance with manufacturer recommendations, the auditor will check whether the tasks in your PMS actually come from manufacturer documentation.

If your SMS says equipment is maintained at intervals defined by the manufacturer, but your PMS has tasks with no defined intervals, or intervals that do not match any OEM manual, that is a gap between documentation and implementation. Auditors live for those gaps.

Are tasks being completed on schedule?

The auditor will look at overdue tasks. Some overdue items are inevitable — operational constraints, parts availability, weather windows. But a pattern of overdue maintenance across multiple systems tells the auditor that the planned maintenance system is not functioning effectively.

The key word is "planned." If your planned maintenance system has thirty overdue tasks, the maintenance is not planned. It is reactive. That undermines the entire purpose of the ISM Code requirement.

Are records complete and accessible?

Section 10.2 requires that records of maintenance activities are maintained. That means every completed task should have a record — what was done, when it was done, and by whom. Auditors will select tasks at random and ask to see the completion records.

If the engineer can pull up a complete maintenance history for any piece of equipment within a couple of minutes, that is a well-functioning system. If there are gaps in the records, if completion dates are missing, if there is no way to verify that a task was actually done, those are findings waiting to happen.

Is critical equipment identified and managed?

Section 10.3 requires identifying equipment where sudden failure could create a hazardous situation. This includes main engines, steering gear, generators, fire pumps, bilge pumps, navigation equipment, and any other system whose failure would affect the safe operation of the vessel.

The auditor will check that this critical equipment is identified in your PMS, that it has appropriate maintenance schedules, and that standby or redundant systems are tested regularly. If your database does not distinguish between critical and non-critical equipment, or if critical equipment has inadequate maintenance coverage, that is a problem.

Minimum PMS requirements for ISM compliance

Based on what auditors actually check, here is what your PMS database needs at a minimum to support ISM compliance:

A complete equipment register. Every piece of equipment that requires planned maintenance should be in the system. Not just the main machinery — the safety equipment, the deck machinery, the navigation systems, the HVAC. If it needs maintaining and it is not in the database, it is a gap.

Maintenance tasks with defined intervals. Every task needs a clear interval — hours-based, calendar-based, or condition-based. Tasks without intervals do not come due and therefore do not get done. An auditor finding tasks with no interval assigned will ask why maintenance is not being planned for that equipment.

Completion records. A log of when each task was completed, who completed it, and any relevant notes. This is your objective evidence that maintenance is being carried out as planned.

A way to identify overdue items. The system needs to show what is overdue and by how long. If the auditor asks "what maintenance is currently overdue on this vessel?" you need to be able to answer immediately, with specifics.

Critical equipment identification. A way to flag or categorise equipment whose failure would create a hazardous situation, with evidence that this equipment receives appropriate attention.

These are minimums. They do not make a good database — they make a database that does not generate automatic non-conformities during an audit. A good database does far more than this.

Common non-conformities related to maintenance records

We have seen these come up repeatedly across different vessels and different audit regimes:

"Maintenance tasks not reflective of manufacturer recommendations"

The auditor opens an OEM manual, checks the recommended service intervals, then looks at the PMS to see if those intervals are reflected. When the manual says to replace a component every 2,000 hours and the PMS has that task set to every 4,000 hours — or does not have it at all — that is a non-conformity.

This finding almost always traces back to how the database was built. If tasks were entered from memory or copied from another vessel rather than extracted from the actual manufacturer documentation, the intervals will not match. The fix is going back to the manuals and rebuilding the tasks properly — exactly the work that should have been done during the original database build.

"No objective evidence of maintenance completion"

The task exists. The schedule shows it was due. But there is no record of it being done. No completion date, no signature, no notes. The auditor cannot verify that the maintenance was carried out.

This one stings because the work was probably done. The engineer probably changed those filters, serviced that pump, checked those belts. But without a record in the system, it did not happen as far as the auditor is concerned.

Objective evidence means documented proof. A completion record in the PMS with a date and the name of the person who did the work. That is the minimum. Better practice includes brief notes on what was found, any anomalies, and any follow-up required.

"Equipment not included in the planned maintenance system"

The auditor walks the engine room, looks at a piece of equipment, and asks to see its maintenance record. The equipment is not in the PMS. Maybe it was installed during a refit and nobody added it to the database. Maybe it was considered too minor to include. Maybe the database was never completed for that system.

Whatever the reason, if equipment that requires maintenance is not in the PMS, the maintenance is not planned. That is a non-conformity by definition.

This is why a complete equipment hierarchy matters so much. Missing equipment is not just a database quality issue — it is a compliance issue.

"Overdue maintenance not addressed or documented"

Overdue tasks happen. Equipment breaks down and takes priority. Spare parts take time to arrive. The vessel is on charter and certain work has to wait. Auditors understand this.

What they do not accept is overdue maintenance with no explanation and no plan to address it. If a task is three months overdue, the auditor will ask why. If the answer is "we did not notice" or "the system is not really up to date," that is a systemic failure, not an individual oversight.

The database needs to show overdue items clearly, and the vessel's maintenance management process needs to include regular review of overdue tasks with documented reasons and planned completion dates.

The difference between having a PMS and having one that passes audit

This is the distinction that matters. Many vessels have a PMS. They have software installed, they have some equipment entered, they have some tasks scheduled. On paper, they have a planned maintenance system.

But having a PMS and having one that supports ISM compliance are different things. The database needs to be:

• -Complete — all equipment, all relevant tasks, all intervals
• -Accurate — tasks and intervals that match actual manufacturer documentation
• -Current — completion records kept up to date, not filled in retrospectively before an audit
• -Accessible — the Chief Engineer can pull up any record within minutes, not hours

An auditor can tell the difference between a database that is actively used and one that was hastily updated the week before the audit. Completion records all dated within the last month. Tasks marked as done in bulk. Equipment added in a rush with incomplete data. These patterns are obvious to anyone who has conducted audits, and they undermine confidence in the entire system.

The vessels that pass audits smoothly are the ones where the PMS is a genuine working tool, not a compliance exercise. Where the engineers use it daily because it helps them do their job, not because they have to. Where the data is trustworthy because it was built properly in the first place.

Internal audits vs external audits

Your SMS should specify an internal audit schedule. For maintenance, this means someone — typically the designated person ashore or a shore-based superintendent — reviews the PMS records periodically.

Internal audits are your opportunity to find and fix problems before an external auditor finds them. If your database has gaps, if completion records are missing, if there are tasks with no intervals, the internal audit should catch those.

The problem is that internal audits are often treated as a tick-box exercise. Someone reviews a handful of records, confirms the system exists, and signs off. This does not catch the systemic issues that external auditors will find.

A proper internal audit of the PMS should include:

• -Random sampling of completion records across different systems (not just the main engines)
• -Checking that overdue tasks have documented explanations and planned completion dates
• -Verifying that recently installed equipment has been added to the system
• -Confirming that task intervals match the manufacturer documentation for a sample of equipment
• -Checking that critical equipment is identified and has adequate maintenance coverage

If your internal audits are finding and fixing these issues, your external audits will go smoothly. If your internal audits are finding nothing, that is not because everything is perfect — it is because the audits are not thorough enough.

Practical advice for engineers preparing for ISM audits

Based on what we have seen across multiple vessels and audit cycles, here is what actually helps:

Review overdue tasks and document the reasons. Before any audit, go through every overdue task. For each one, document why it is overdue and when it will be completed. If a task is overdue because the spare parts are on order, note that with the order date and expected delivery. Auditors are reasonable about operational constraints — they are not reasonable about unexplained overdue maintenance.

Spot-check your completion records. Pick ten tasks at random across different systems. Can you show completion records for the last three cycles of each? If there are gaps, fill them where possible and note any that cannot be verified. Better to have an honest note than an empty field.

Verify that your PMS matches the SMS. Read the maintenance section of your SMS. Check that the PMS actually does what the SMS says it does. If the SMS says maintenance is based on manufacturer recommendations, make sure you can demonstrate that by pointing to specific OEM manuals and corresponding PMS tasks.

Walk the vessel and check the database. Pick five pieces of equipment at random in the engine room. Check that each one is in the PMS with appropriate maintenance tasks. Then do the same in the deck areas and the interior. If you find equipment that is not in the system, add it before the audit.

Make sure the crew can use the system. Auditors sometimes ask junior engineers to demonstrate the PMS, not just the Chief Engineer. Every member of the engineering team should know how to find equipment, view outstanding tasks, and record a completion.

How database quality affects audit outcomes

Everything in this article comes back to one point: the quality of your PMS database directly determines how your vessel performs during ISM audits.

A database built from actual manufacturer documentation, with a complete equipment hierarchy, accurate intervals, and consistent records, gives auditors exactly what they need to see. The audit is straightforward because the evidence is there.

A database that was cobbled together in a hurry, with tasks copied from another vessel, equipment missing from the hierarchy, and sporadic completion records, creates the opposite experience. The auditor has to dig for evidence, finds gaps, and starts looking harder.

We build databases that are designed to withstand audit scrutiny from day one. Every task is traceable to its source documentation. Every piece of equipment is in its proper place in the hierarchy. The structure supports the kind of record-keeping that makes audits a non-event rather than a scramble.

If your database is not giving you that confidence, it might be worth looking at what it would take to get it there. You can see how we approach database builds on our [services page](/services) and understand our methodology on the [process page](/process). If your database was built in-house, our article on [building a PMS database in-house vs hiring a professional](/blog/pms-database-in-house-vs-professional) covers the tradeoffs honestly. And if the issue is documentation gaps, we have a guide on [preparing your documentation for a database build](/blog/preparing-documentation-pms-database-build) that covers exactly what is needed and how to organise it.

The ISM Code is not going away. Audits are not getting less thorough. The vessels that handle them well are the ones that treated their PMS database as a serious piece of infrastructure — not an afterthought.