SMS language neutrality has become one of those phrases that appears in TMSA discussions and vetting preparation meetings as a marker of proactive safety culture. In most fleets I audit, however, the SMS was written by one cultural-linguistic group and is being read by several others — and nobody has examined what happens in that gap.
The SMS Reflects Who Wrote It
When I open an SMS for review, I can usually identify within a few pages which nationality drafted the procedures. Not because of spelling or formatting, but because of sentence construction, modal verb choices, and how accountability is distributed across the text. Indian maritime English has particular patterns. East European drafting has others.
The problem is not that the SMS was written by someone whose mother tongue is not English. The problem is that it is then handed to a multinational crew — Filipino officers, Indian ratings, East European watchkeepers — who each bring their own linguistic assumptions to the same sentence. SMS language neutrality is the industry’s attempt to close that gap. But most implementations stop at the writing side and never examine the reading side.
Three Places the Gap Shows Up
Modal verb mismatch
“Should” is the most dangerous word in a poorly drafted SMS.
In British maritime convention, “shall” is mandatory and “should” is a strong recommendation. Terje Lovoy’s work, presented at BIMCO in 2023 and drawn from analysis of 63 SMSs, formalises this precisely: shall is mandatory, should is a recommendation, consider indicates judgement. But Indian maritime English frequently uses “should” where British convention would use “shall.” The author intended a mandatory action. The word chosen signals a recommendation.
A Filipino officer — operating within a high power-distance culture where explicit instruction is expected before action — reads “should” and waits for authorisation. An East European officer reads the same word as advisory and acts on his own judgement. Neither does what the author intended. The VDR records both responses.
‘Should’ is the most dangerous word in a poorly drafted SMS
Passive voice erasing accountability
“A double watch should be maintained during restricted visibility.”
Who orders it? Who initiates it? The author assumed the Master. The sentence does not say the Master. A Filipino OOW, trained to await explicit direction, waits. An East European watchkeeper, comfortable with autonomous decision-making, acts on his own authority. The accountability that the author built into the procedure in their own mind never reached the page.
Passive construction is the most common structural problem I find in SMS language reviews. It allows the writer to imply responsibility without assigning it. That ambiguity is invisible at the drafting stage and fully visible in an audit — or an incident.
The accountability that the author built into the procedure in their own mind never reached the page
The escalation ladder read as a mandatory sequence
“If in doubt, inform the duty officer. If the matter persists, inform the Chief Officer. If required, inform the Master.”
The author’s intention: escalate as the situation demands. The Filipino crew member’s reading: a sequence to exhaust in order before the Master is contactable. In a fast-developing navigational situation, working through that ladder takes time the ship does not have.
This is not a crew competence issue. It is a drafting issue. The procedure was written by someone whose cultural assumption was that a reasonable person would go straight to the Master if the situation demanded it. That assumption is not universally shared, and the text does not correct for it.
The Writing Side and the Reading Side
Terje Lovoy’s controlled language approach — text washing, structural untangling, active voice — addresses the supply side of SMS language neutrality. How to write procedures that reduce complexity without losing facts. Companies that have applied it report measurable improvement in perceived usability.
NorthStandard P&I, writing on SIRE 2.0 preparation, draws the same connection — plain language SMS procedures and the human factors lens that SIRE 2.0 now applies are not separate workstreams.
What it cannot address is what happens when the revised procedure reaches a crew with different cultural-linguistic assumptions. That is the reading side. The audit reveals it.
I have reviewed SMSs that have been through text simplification exercises and still contain all three failure modes above, because the simplification addressed vocabulary and sentence length without touching modal verb convention, passive accountability, or cultural assumptions about escalation. SMS language neutrality is not the same as shorter sentences.
What SMS Language Neutrality Actually Requires
TMSA KPI 1A.1.3 requires that procedures and instructions are written in plain language, with sufficient detail to ensure tasks can be completed correctly and consistently. It does not specify how. Language neutrality is the industry’s working answer to that requirement — a demonstrable effort to make the SMS accessible to a multinational crew.
But plain language on the page and plain language across cultural-linguistic assumptions are not the same thing. A procedure can satisfy 1A.1.3 on review and still produce all three failure modes above in operation.
The question TMSA is really asking is whether the crew can act on the SMS correctly and consistently. That answer is not found in the document. It is found in how the crew performs when it matters.
