Abstract: The ISM Code's functional approach aims to ensure that management systems are tailored to meet the specific needs of each ship and shipping company. However, our literature review reveals that the Code may lead to a documentation-centric approach, disconnected from the operational reality of the ship (Størkersen, 2020). This documentation describes a parallel reality that is commonly referred to as audit loops3. It should be noted that these harmful issues should not be attributed to the Code itself. Some inspectors, auditors, and shipping companies view the Code as a mere source of prescriptive rules, overlooking its functional intent. This may be due to the fact that the functional approach of the Code can only be fully understood from a thorough knowledge of what an operational management system is and how it works. In this article, we will examine the root causes of the aforementioned negative effects of the Code and provide recommendations on how to mitigate them.

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