ISM, ISPS and MLC Requirements

RWISR
MARINE CIRCULAR

Circular No: RWISR-MC-04-2026
Status: Active
Subject: ISM, ISPS and MLC Requirements
Title: Guidance on Safety Management, Ship Security and Maritime Labour Compliance under RWISR
Date: 30 / July / 2025
Applicable to: Shipowners, Operators, Managers, Masters, Recognized Organizations (ROs)

1. PURPOSE

This Marine Circular provides guidance on the requirements related to the International Safety Management (ISM) Code, the International Ship and Port Facility Security (ISPS) Code, and the Maritime Labour Convention (MLC, 2006) for vessels registered under the RWISR.

The objective is to ensure that all vessels maintain effective safety management systems, adequate security arrangements, and full compliance with maritime labour standards in accordance with applicable international conventions and RWISR requirements.

2. APPLICATION

This Circular applies to all vessels registered or intended to be registered under RWISR and covers:

  • ISM Code implementation and certification
  • ISPS Code implementation and certification
  • MLC compliance and certification
  • Audit, verification, and certification processes
  • Continuous compliance and monitoring obligations

3. GENERAL REQUIREMENTS

All vessels shall comply with the applicable provisions of:

  • The International Safety Management (ISM) Code
  • The International Ship and Port Facility Security (ISPS) Code
  • The Maritime Labour Convention (MLC, 2006), as amended

Compliance shall be demonstrated through valid certification, proper implementation onboard, and effective operational practices.

4. ISM CODE REQUIREMENTS

All applicable vessels shall operate under an approved Safety Management System (SMS).

Requirements include:

  • A valid Document of Compliance (DOC) issued to the Company
  • A valid Safety Management Certificate (SMC) issued to the vessel
  • Effective implementation of the SMS onboard
  • Regular internal audits and management reviews
  • Reporting and investigation of non-conformities, incidents, and accidents

The SMS shall be maintained and implemented in accordance with the ISM Code and verified through audits conducted by an authorized Recognized Organization or the Flag Administration.

5. ISPS CODE REQUIREMENTS

All applicable vessels shall comply with the ISPS Code and maintain an approved Ship Security Plan (SSP).

Requirements include:

  • A valid International Ship Security Certificate (ISSC)
  • Appointment of a Ship Security Officer (SSO)
  • Implementation of security levels and procedures
  • Maintenance of security records and drills
  • Periodic verification of security arrangements

Security measures shall be maintained at all times in accordance with the vessel’s trading pattern and applicable security levels.

6. MLC REQUIREMENTS

All applicable vessels shall comply with the Maritime Labour Convention (MLC, 2006) requirements regarding seafarers’ working and living conditions.

Requirements include:

  • A valid Maritime Labour Certificate (MLC Certificate)
  • A Declaration of Maritime Labour Compliance (DMLC Part I and II)
  • Compliance with minimum standards relating to:
    • Employment agreements
    • Wages and payments
    • Hours of work and rest
    • Accommodation and recreational facilities
    • Food and catering
    • Medical care and welfare
    • Health and safety protection

All MLC-related conditions shall be effectively implemented and maintained onboard.

7. AUDITS AND VERIFICATION

Audits and inspections shall be conducted by an authorized Recognized Organization or the Flag Administration.

These may include:

  • Initial audits
  • Intermediate audits
  • Renewal audits
  • Additional or occasional audits

Audits shall verify:

  • Effective implementation of ISM, ISPS, and MLC requirements
  • Crew awareness and operational compliance
  • Proper documentation and record keeping

Certificates shall not be issued or endorsed unless compliance is verified.

8. CERTIFICATION

Certificates shall be issued upon satisfactory completion of audits and verification processes.

These include:

  • Safety Management Certificate (SMC)
  • International Ship Security Certificate (ISSC)
  • Maritime Labour Certificate
  • Any interim or short-term certificates where applicable

Certificates shall clearly indicate validity, issuing authority, and any conditions or limitations.

9. VALIDITY AND CONTINUATION

Certificates are generally issued for a period not exceeding five (5) years, subject to:

  • Successful completion of required audits
  • Continuous compliance with applicable requirements
  • Timely completion of intermediate and renewal audits

Failure to maintain compliance may result in suspension or withdrawal of certification.

10. NON-CONFORMITIES AND CORRECTIVE ACTIONS

All deficiencies, non-conformities, and observations identified during audits shall be:

  • Recorded and reported
  • Evaluated for risk and impact
  • Corrected within agreed timeframes

Major non-conformities shall be rectified prior to issuance or endorsement of certificates.

11. RESPONSIBILITIES

The Shipowner / Company shall ensure:

  • Full implementation of ISM, ISPS, and MLC requirements
  • Coordination of audits and certification
  • Maintenance of valid certification

The Master shall ensure:

  • Implementation of procedures onboard
  • Maintenance of records and certificates
  • Crew compliance with applicable requirements

The Recognized Organization shall:

  • Conduct audits and verifications
  • Issue certificates upon satisfactory compliance
  • Report relevant findings to RWISR where required

12. MONITORING AND REPORTING

RWISR may request:

  • Certification status updates
  • Audit reports
  • Deficiency and corrective action records

All parties shall ensure transparency and cooperation with the Registry.

13. ENTRY INTO FORCE

This Circular enters into force on:
30 / July / 2025

14. CONTACT

RWISR
Email: info@rwisr.com
Website: www.rwisr.com
Verification: www.rwisr.com/verify