Every company I speak with eventually arrives at the same conclusion: the SMS has grown too large, too layered, and too difficult for the people who are supposed to use it. The decision to rationalise it is, by that point, obvious. What is less obvious is how to actually do it — and how much organisational friction stands between the decision and a working outcome. ISM SMS compliance is the stated goal. The path to it is rarely straightforward.
Who Actually Owns This Work
The first difficulty is mandate. Rationalising an SMS is not a document editing exercise that can be delegated to a single person with a laptop and a revision history. It requires authority across departments — fleet operations, HSEQ, crewing, and frequently the DPA — because the decisions it forces are not technical. They are organisational.
When a procedure is identified as redundant, someone has to decide whether to remove it, merge it, or leave it. That decision affects how the vessel operates, how crew are trained, and how auditors will interpret the revised system. No individual below senior management level has the standing to make it.
When the exercise is assigned to a single HSEQ manager, what typically happens is that the document gets reviewed, but the decisions don’t get made. The manager flags issues upward and waits. The exercise stalls before it has properly begun.
This is why ISM SMS compliance work, when assigned internally without a clear mandate structure, rarely produces outcomes proportionate to the effort invested. The review happens. The decisions don’t.
What an ISM SMS Compliance Review Actually Surfaces
A serious ISM SMS compliance review does not produce a tidy list of redundant clauses. It is not an editing exercise and should not be scoped as one.
It surfaces non-conformities. It identifies gaps between what the system says the crew will do and what the crew actually does. It finds procedures added in response to past incidents but never integrated with the procedures around them. It finds contradictions between the SMS and the current fleet profile.
None of this is unusual. Every SMS of any operational age carries accumulated weight from successive revisions. The problem is that once you find it, the company has to decide what to do with it.
A gap identified during rationalisation is a gap the company now officially knows about. Ignoring it is no longer a passive oversight — it becomes an active decision. Some companies find that confronting, and the review loses momentum precisely at the point where it matters most.
Three Patterns That Kill the Exercise Halfway
In my work with operators on SMS revision exercises, three patterns appear consistently.
The first is political discomfort. Rationalisation surfaces findings that reflect poorly on decisions made by people who are still in the room. When the findings become uncomfortable, the appetite for continuing the exercise evaporates at the sponsor level. The project is not formally abandoned — it simply stops being progressed.
The second is workload underestimation. Companies typically assume SMS rationalisation is a weeks-long exercise. Done properly, it runs for months and requires sustained input from people with operational authority. When that demand meets a full port rotation schedule or a SIRE inspection cycle, it is the rationalisation work that gives way.
The third is personnel change. Key personnel who initiated the process — or who held institutional knowledge of the original structure — leave, transfer, or change role mid-exercise. The incoming person has no context, no investment in the outcome, and frequently no brief to continue. The exercise doesn’t fail. It simply loses the thread.
Why Half-Finished Is Worse Than Not Starting
“A partially rationalised SMS is operationally worse than an unrationalised one.”
This outcome is more common than most operators would acknowledge. The instinct is to treat a stalled ISM SMS compliance exercise as a paused project — something that can be resumed when conditions improve. In practice, the institutional memory required to resume it rarely survives the pause.
The original structure, however unwieldy, was navigable. Crew knew where to find things. They knew the sequence of procedures, which cross-references were reliable, and which sections applied to their vessel type. A rationalisation exercise that reaches 60% completion disrupts that learned familiarity without replacing it with anything coherent. The old landmarks are gone. The new ones are incomplete. The crew is left navigating a structure that is neither what it was, nor what it was intended to become.
This is not a hypothetical. I have reviewed systems mid-revision where the navigable and the revised versions existed simultaneously across the fleet — different vessels working from different iterations, with no clear record of which was current. The company’s ISM SMS compliance position, from an external audit perspective, was materially weaker after the revision effort than before it.
What Changes When You Bring in Someone Outside the Company
External facilitation changes the dynamic in one specific and practical way: findings don’t carry internal political weight.
A gap identified during an external review is an industry observation — something a competent external auditor found, consistent with what vetting bodies would expect to find, presented as a recommendation for the operator to consider. The same finding, surfaced internally, is an internal accusation. It names a decision, a department, sometimes a specific individual. The instinct to suppress or minimise it is understandable, even when it is counterproductive.
The external position is not a softer position. The findings are the same. What changes is the company’s ability to receive them and act on them without the organisational cost that internal discovery carries.
If you are planning an SMS rationalisation exercise and are not confident the internal conditions exist to see it through, that is worth examining before the work begins — not after it stalls.
The conditions that allow an ISM SMS compliance exercise to succeed — mandate, time, institutional continuity, and the organisational appetite to act on what the review finds — are worth assessing before the first document is opened. Most are not.
