Limitations of safety management system implementation and the transformation of certification audits for marine accident prevention

Despite the widespread implementation of the International Safety Management (ISM) Code, marine accidents driven by navigational errors and organizational failures persist. This study examines the structural limitations of Safety Management System (SMS) implementation, focusing on certification audits as the primary mechanism linking regulatory compliance to operational safety. By analyzing marine accident data, SMS operational characteristics, and recent international regulatory discourses, this paper identifies a critical decoupling between the preventive objectives of the ISM Code and the conformity-oriented nature of current audit practices. The findings indicate that certification audits disproportionately emphasize documentation and procedural compliance, failing to effectively identify and mitigate operational risks—particularly those rooted in human and organizational factors. To bridge this gap, this study proposes a paradigm shift toward risk-based and performance-oriented audit approaches designed to evaluate the substantive effectiveness of SMS. Ultimately, this study contributes to maritime safety governance by demonstrating how the preventive efficacy of the ISM Code can be enhanced through audit transformation without imposing additional administrative burdens.