For shipowners and fleet operators, the gap between having a Safety Management System and actually managing safety has never been more consequential — or more visible to the people who matter most.
The ISM Code has been mandatory for over two decades. Most operators have an SMS. Most vessels carry a binder of procedures, a file of risk assessments, and a certificate from their flag state confirming that their safety management meets the minimum requirements of the Code.
And yet Port State Control detentions continue to climb. OCIMF SIRE 2.0 inspections reveal the same categories of deficiency year after year. Incidents occur on vessels whose SMS documentation would satisfy any auditor — until something goes wrong and the investigation reveals that the system existed on paper only.
The hard question for any shipowner or technical manager is this: does your SMS actually protect your vessels, your crew, and your commercial relationships — or does it protect you from the auditor?
The difference matters enormously. And it is the difference that the Fleet Safety Assurance Program (FSAP™), developed by Marine Surveyor Consultant Sagl, is specifically designed to address.
| 40% Average incident reduction | 45% Average PSC deficiency drop | 30 days To full SMS implementation |
The Tokyo MOU and USCG data tell the same story. Despite decades of ISM implementation, the same deficiencies recur on the same vessel types. The conclusion is not that operators are negligent — it is that compliance-focused safety management, without genuine operational integration, produces documentation that satisfies the auditor and fails the inspector.
| A PSC detention is rarely caused by one catastrophic failure. It is almost always the result of accumulated small failures — a procedure that was never properly implemented, a piece of equipment that was not maintained because no one was tracking it, a crew who had not been trained because training records were filed but never verified. — Senior Port State Control Officer, Paris MOU |
For operators, the implications are clear. The question is not whether your documentation is in order — most operators can produce documentation. The question is whether your safety management system is actually working on the vessel, at sea, under pressure, when the inspector is not present.
The Regulatory Environment Has Changed. Has Your SMS?
The maritime regulatory landscape of 2025 looks very different from the one in which most SMSs were originally written. The introduction of OCIMF SIRE 2.0 has fundamentally raised the bar for tanker vetting, demanding not just documented procedures but demonstrable evidence of a safety culture that permeates the vessel from the Master to the most junior rating.
The revised MLC 2006 requirements, the Ballast Water Management Convention, MARPOL Annex VI amendments, and the growing focus on cyber risk management have each added new layers of obligation. Flag states and port state authorities have become more sophisticated in their inspections, and the consequences of non-compliance — financial, reputational, and criminal — have escalated accordingly.
For many operators, the SMS they implemented five or ten years ago has not kept pace. Procedures have not been updated. Training has not been refreshed. The system has grown rigid and bureaucratic — something that crew comply with formally and ignore practically.
| Key regulatory frameworks your SMS must address in 2025: ISM Code (MSC-MEPC.7/Circ.8 — latest circular guidance) OCIMF SIRE 2.0 — Vessel Inspection Questionnaire, 5th edition STCW Convention as amended (Manila Amendments) MLC 2006 and subsequent amendments MARPOL Annex I–VI including 2020 sulphur cap compliance Ballast Water Management Convention (BWM) IMO Cyber Risk Management guidelines (MSC-FAL.1/Circ.3) |
What PSC Data Tells Us About the State of Fleet Safety
The Paris MOU Annual Report makes for uncomfortable reading. Year after year, the top categories of PSC deficiency remain stubbornly consistent: fire safety equipment, life-saving appliances, ISM Code implementation, working and living conditions, and safety of navigation. These are not obscure technical requirements — they are the foundations of any credible SMS.
The Tokyo MOU and USCG data tell the same story. Despite decades of ISM implementation, the same deficiencies recur on the same vessel types. The conclusion is not that operators are negligent — it is that compliance-focused safety management, without genuine operational integration, produces documentation that satisfies the auditor and fails the inspector.
| A PSC detention is rarely caused by one catastrophic failure. It is almost always the result of accumulated small failures — a procedure that was never properly implemented, a piece of equipment that was not maintained because no one was tracking it, a crew who had not been trained because training records were filed but never verified. — Senior Port State Control Officer, Paris MOU |
For operators, the implications are clear. The question is not whether your documentation is in order — most operators can produce documentation. The question is whether your safety management system is actually working on the vessel, at sea, under pressure, when the inspector is not present.
Introducing the Fleet Safety Assurance Program
FSAP™ is the structured response to this challenge — a fully managed, end-to-end maritime safety partnership delivered by Marine Surveyor Consultant Sagl, a Mendrisio-based consultancy whose team combines sea-going experience at senior officer level with extensive shore-side safety management expertise.
The program is not a consultancy report delivered and forgotten. It is an ongoing partnership built around six integrated service modules, each addressing a specific dimension of safety performance:
Module 01 — SMS Design & Implementation
We design and implement Safety Management Systems from scratch, or audit and rebuild existing systems that have fallen behind current regulatory requirements. Every SMS we deliver is fully aligned with the ISM Code, the applicable flag state requirements, the trading area of the vessel, and the specific operational profile of the fleet. Crucially, we write procedures that seafarers can actually follow — not procedures that satisfy a checklist.
Module 02 — Regulatory Compliance Monitoring
The regulatory environment does not stand still, and neither do we. Our compliance monitoring service tracks every relevant IMO circular, flag state notice to owners, and port state policy change, translating each development into practical actions for your fleet. You receive regular compliance updates and — where necessary — revised procedures and forms before a deficiency can occur.
Module 03 — Audit & Vetting Preparation
We conduct internal ISM audits on a scheduled and unannounced basis, using the same methodology and rigour as external auditors and vetting inspectors. For tanker operators, we provide dedicated OCIMF SIRE 2.0 preparation — a structured programme that goes beyond the VIQ checklist to address the behavioural and cultural elements that SIRE 2.0 specifically targets. We do not just identify deficiencies: we fix them.
Module 04 — Incident Management & Investigation
Our 24/7 incident response service provides immediate advisory support when things go wrong — whether that is a cargo incident, a personal injury, a collision, or a PSC detention. We manage the investigation process, ensure that root cause analysis is properly conducted, and — critically — ensure that the lessons learned are translated into SMS improvements that prevent recurrence across the fleet.
Module 05 — Crew Training & Competency
Safety culture is built through training, not documentation. Our crew training programmes are STCW-aligned and designed for delivery onboard and ashore. We cover safety management system familiarisation, risk assessment methodology, bridge resource management, and the specific requirements of SIRE 2.0 for tanker crew. Training is documented, tracked, and verified — not just filed.
Module 06 — Performance Analytics & Reporting
What gets measured gets managed. Our performance analytics service provides real-time KPI dashboards tracking Lost Time Injury Frequency, PSC deficiency rates, near-miss ratios, drill completion rates, and vetting performance trends. Quarterly management reviews give owners and technical managers the data they need to make informed decisions about safety investment and fleet risk.
Who Is FSAP Designed For?
The program is scalable and available in three tiers — Essential, Professional, and Enterprise — designed to suit fleets of any size and complexity. In our experience, FSAP delivers the greatest impact for:
- ▸ Independent shipowners (1–10 vessels) who lack the resources to maintain a dedicated in-house QHSE function but cannot afford the commercial and reputational consequences of inadequate safety management.
- ▸ Ship management companies seeking to standardise safety performance and reporting across a diverse fleet, and to demonstrate a credible safety culture to charterers and vetting organisations.
- ▸ Tanker operators facing the specific demands of OCIMF SIRE 2.0 and the safety requirements of major oil company vetting programmes, where a single failed inspection can cost a fixture.
- ▸ Dry bulk and container operators with high PSC exposure in key port states — particularly in the Paris MOU and Tokyo MOU regions — where deficiency rates directly affect operational efficiency and insurance premiums.
- ▸ Investment funds and private equity groups acquiring vessel portfolios who require rapid, credible SMS implementation to protect asset value and satisfy the safety requirements of charter counterparties.
Download the FSAP Programme Overview
The following link contain a detailed overview of the Fleet Safety Assurance Program — including the full scope of each service module, our four-phase implementation methodology, and the three programme tiers available to operators of all fleet sizes.
Start with a Free Fleet Safety Review
Every new client engagement begins with a complimentary Fleet Safety Review — a structured, two-hour consultation with one of our senior advisors in which we assess your current SMS against ISM Code and applicable vetting requirements, review your recent PSC and inspection history, and identify the specific gaps that represent the greatest risk to your operations.
The review is confidential, without obligation, and without charge. It is the starting point for understanding where your fleet stands — and what it would take to make it genuinely safe, commercially competitive, and inspection-ready at any time.
Results from Operators Who Have Made the Transition
| Within 18 months of enrolling in FSAP, our PSC deficiency rate dropped by 45% and we passed our first SIRE 2.0 inspection with zero observations. The team at Marine Surveyor Consultant Sagl genuinely understands what vetting inspectors look for — because they have been there themselves. This is not a consultancy that sends you a report and disappears. — Fleet Director, Independent Greek Tanker Owner, Athens |
| We manage 32 vessels across three vessel types. Standardising safety performance across that kind of fleet is genuinely difficult. FSAP gave us the framework to do it, and the monthly KPI reports transformed the way we present safety performance to vessel owners. For the first time, we can show them data, not just assurances. — Technical Director, Ship Management Company, Limassol |
