The International Safety Management Code (ISM) require Shipping Companies 

ISM internal audits.

7 important elements of ISM Code every seafarer must know about

ISM code has been the most controversial among all the chapters of SOLAS. There
are plenty of seafarers and shore staff who feel that ISM code has only brought
more paper work and nothing else.
But a detailed report on the impact and effectiveness of the ISM code suggests
that “where the ISM Code had been embraced as a positive step toward efficiency
through a safety culture”, tangible positive benefits were evident.
But as you would note that the report has a caveat which is “Where the ISM code
had been embraced as a positive step“.
How do we embrace ISM code as a positive step? The first step would be to know
about the ISM code and its elements.

In this post, we will discuss the 7 important elements of the ISM code.
1. Who is the Company as per ISM code
The first thing we need to know is who is the company. As per ISM code
Company means the owner of the ship or any other organization or person such
as the manager, or the bareboat charterer, who has assumed the responsibility
for operation of the ship from the shipowner and who, on assuming such
responsibility, has agreed to take over all duties and responsibility imposed by the
Code.
So, the company can be
 Owner of the ship
 Any other organization
 Bareboat Charterer
But most importantly, the company is the organization that has agreed to take
over all the duties and responsibilities as per the ISM code.
Now take it this way. If you board a ship as a PSC inspector, how can you find the
details for the ‘Company” of the ship?
No ship can sail with an invalid or a missing statutory certificate. One such
certificate is “Safety Management certificate”.
The details of the “company” are required to be entered into this certificate. This
certificate will have the
 Name of the Company
 Address of the Company and
 Company identification number
A permanent and Unique Number is required to be assigned to all Companies and
Registered Owners managing any ship of 100 gross tones and above engaged on
international voyages.
The company identification number is issued by IHS Maritime and trade on behalf
of IMO.
Most of the flags also require the company to fill a form called “Declaration of the
company“. Which is a self-declaration by the company stating they are the
“company” for the listed ships as required by the ISM code.

2. Company’s responsibilities
ISM code is all about the company.
If you read the ISM code, all the lines of the code start with “Company Should” or
“Company is responsible”.
Even for the master’s responsibilities, it is not directed to the Master but to the
company.

ISM code has not just made the company responsible for shipboard operations
but it also its implications in the shipping business.
Take for example the Hague-Visby rules. These rules has one major rule in favour
of ship owners.
It says that ship owner will not be responsible for any delays or damages resulting
because of faults of master and crew of the ship.
While this rule still stays, its meaning has changed post ISM code.
Now even in the clear case of neglect on part of crew, in many cases the court has
given the verdict against the ship owner.
Why? Court asked what has the company done to avoid crew negligence?
So, ISM code is all about company’s responsibilities. Broadly there are two main
responsibilities.
 To define and document the responsibilities and authority of the persons
involved in work relating to and affecting safety and pollution prevention
 provide support and resources to the persons to carry out their functions
effectively
The first point means that company need to provide the instructions to the ship in
form of SMS manual.
Second, the company need to provide all the support a ship may need for running
the ship safely.

3. Internal Audits
An effective Internal audits is the main dividing line between a good ship
management company and a bad one.
ISM code requires that internal audit of each vessel should be conducted at least
every 12 months.
Who is the right person to conduct internal audit? Well, ISM code has the answer.
As per ISM code
Personnel carrying out audits should be independent of the areas being audited
unless this is impracticable due to the size and the nature of the Company
This means that the superintendents of the vessel cannot carry out the internal
audit of the vessels they are managing.
This is because of obvious reason that they will tend to not highlight any
shortcoming in the system for which they themselves has to blame for.
In most effective systems, it is always someone from the QHSE department that
conducts the internal audits.
Some companies even have a “Shipboard Audit department”, whose only
responsibility is to look after the internal audits of the ships.
Apart from this, there is a formal requirement for the auditor to be trained for
carrying out the internal audits.

4. Certificates as per ISM Code

There are two statutory certificates that are required as per ISM code.
  Document of compliance for company
 Safety management system certificate for ship

Document of compliance
DOC is issued to the company by the flag state or by the classification society on
behalf of the flag state. The certificate is valid for five years and it requires to be
endorsed annually.
DOC is issued to the company after a successful audit to verify that company
complies with the requirements of ISM code.
A company may have multiple documents of compliance from different flags and
from different classification societies.
For example, company may be managing ships of Singapore as well as Hong Kong
flag. Some of these ships may have DNV class and other have Class NK. Now the
company will have following DOCs
 DOC from DNV on behalf of Singapore flag
 DOC from DNV on behalf of Hong Kong flag
 DOC from Class NK on behalf of Singapore flag
 DOC from Class NK on behalf of Hong Kong flag
From the ship’s point of view, we must ensure that we have correct DOC on
board.
So, if you are on a chemical tanker which has DNV as the classification society and
Hong Kong flag, you know what you need to check in the DOC.
Yes, you got it right!!! In this case the DOC should be issued by the DNV on behalf
of Hong Kong flag.
We also need to check that the ship type appears on the DOC.

Safety Management Certificate

Safety management certificate is issued to the ship. The certificate is issued after
verifying two elements required as per ISM code
 That the safety management system is in place and complies with the ISM
code requirements
 That the safety management system is being implemented and followed on
board
This verification process is called “external audit” of the SMS and is usually done
by the class on behalf of the flag of the ship.
Safety management certificate is also issued by the flag of the ship or by its
classification society on behalf of the flag. The certificate is valid for five years and
require intermediate (between 2-3 years from date of issue) verification.
Safety management certificate co-exists with the DOC
We must understand that the issuance of safety management certificate is
conditional to the validity of the DOC.
If for some reason the DOC is revoked or if it becomes invalid, the safety
management certificate will also be invalid.

5. Designated person ashore

ISM code requires the company to nominate a Designated person who will be a link between
ship and shore.
A Designated person ashore
 should have access to the highest level of management
 is responsible for monitoring the safety and pollution prevention aspects of
the operation of each ship
 is responsible for ensuring that adequate resources and shore-based
support are applied, as required
Some companies designate a junior shore personnel (for example a Deputy
marine superintendent) as DPA.
While he may have gone through all the trainings required for the DPA as per MSC
circ 6, he will be ineffective in carrying out his duties because of lack of authority
in the organization.
In an effective system, DPA will be a senior person in the company who has some
authority and control over the company’s activities.

6. Observations, Non-conformity and Major Non-conformity

So far, we have discussed that two audits are carried out on ships to fulfill the
requirements of the ISM code.
 External audit by the Class on behalf of flag of the ship
 Internal audit by the company
During these audits, the auditor may find some deficiencies and shortcomings.
ISM code categorizes these shortcomings as
 Observation
 Minor Non-conformity
 Major Non-conformity

Let us see what is the difference between these findings.

Observation

As per ISM code

Observation means a statement of fact made during a safety management audit
and substantiated by objective evidence
What does this means ? It shows an area of concern that is conforming with the
ISM code now but if it is not improved it may lead to the non-conformance with
the ISM code.
Need examples ??S
hip’s SMS requires that certain critical spares need to be on board all the time.
Ship’s SMS also require that charts and publications need to be kept update and
maintained in good condition.

The observation on this can be

 Two A/E critical spare parts were not on board as these were recently
consumed. The requisition for same was in place.
 One of the charts was torn at the end and was found with a tape
Both of these are observations because the ship is complying with the
requirement of SMS. But if these situations are not corrected, it may lead to a
non-conformity.
Minor non-conformity
As per ISM code
Non-conformity means an observed situation where objective evidence indicates
the non-fulfilment of a specified requirement.
This is different from an observation because in this case a specific requirement of
the ISM code was not met.

In the example we discussed under “Observation”, “non-conformity” will be

 Two A/E critical spare parts were not on board as these were recently
consumed. The requisition for same was not in place.
 On random checking, one permanent correction on one of the voyage
charts was missing.
The SMS requires that minimum inventory of the critical spares need to be
maintained at all times. In this case as the requirement under Section 10 of the
ISM code (maintenance of ship and equipment’s) were not met.

Major non-conformity
As per ISM code
Major non-conformity means an identifiable deviation that poses a serious threat
to the safety of personnel or the ship or a serious risk to the environment that
requires immediate corrective action and includes the lack of effective and
systematic implementation of a requirement of this Code.
If we dissect the definition, we have few elements of a major non-conformity.
These are
 Deviation that poses a serious threat
 Require immediate corrective action
 Lack of effective and systematic implementation of ISM code
One point that a major non-conformity highlights is that there is a systematic
failure of one or more parts of the SMS.
A major non-conformity can be because of one single major deficiency or
incident. Or it can be because of number of small deficiencies from one area.
For example, a single deficiency on Marpol equipment’s or Lifesaving appliances
can be a major non conformity.
Also, a number of small deficiencies on record keeping can be considered as a
major non conformity.
If I have to differentiate between a Minor Non conformity and a major non
conformity, I will do that with one point.
A minor non conformity may be an error, something someone forgot to do or a
non-compliance on a single instance.
A major non-compliance is a system failure. It just indicates that the SMS is not
effectively implemented.

Actions in case a major non conformity is issued

IMO in its MSC circ 1059 and MEPC circ 401 has given the detailed guidelines on
the procedure to handle major non-conformities identified during ISM audits.
Few quick points about handling major conformities
 Ship’s cannot sail with a major non-conformity. Ship can only sail once it
has been downgraded to a minor non conformity
 A major non conformity will be downgraded once flag is satisfied that the
effective corrective actions are being taken
 Corrective actions to close this non conformity need to be completed in less
than three months
 If the nature of major non conformity is very serious, the Safety
management certificate of the ship may be withdrawn. In this case even
 the interim Safety management certificate will not be issued. Ship need to
go through the initial process of obtaining the SMC which would include
initial verification of the SMS.

7. Master’s review

One of the responsibilities of the master as per ISM code is to review the
effectiveness of the SMS on board. ISM code has not mentioned any time frame
for this review but as per the understanding of industry experts, it should be done
at least annually.
Master is required to report any noted deficiencies in the SMS. While reviewing
SMS, Master need to
 review SMS manuals and suggest any edits or corrections. Also, if any
requirement mentioned in the SMS manuals is against the industry practice
or requirements.
 Make suggestions to improve the safety management system on board
ships
 Review and comment on the shore-based support and how this can be
improved
 Review and comment on the ship’s performance on safety and pollution
prevention related matters

Conclusion

ISM code has been criticized for bringing too much of paper work without
comparatively lesser gains. But fact is more often than not, it is
the implementation, in general that has been poor.
If implemented with all the seriousness it deserves, it has many benefits to offer.

Audit
1.0 GENERAL

Verify how the company provides for safe practices in ship operation and a safe working

environment.
2.0 How does the company take continuous efforts to improve safety
management skills of personnel on shore and onboard the ship?
3.0How does the company prepare for emergencies related both to safety and environmental
protection?
4.0Verify the company's safety management system ensures compliance with mandatory rules
and regulations (1.2.3)
5.0Verify Medic inventory matches all medical supplies onboard, check expiration dates of
supplies.
6.0Does the company safety management system define levels of authority and lines of
communication between and amongst shore and shipboard personnel?
7.0 Verify the company identifies and assesses risks to its ship, personnel,
and the environment.
8.0

2.0 SAFETY AND ENVIRONMENTAL PROTECTION POLICY

Has the company established a safety and environmental protection policy (2.1)
Verify if the policy has been implemented onboard generally (2.2):
It shall be displayed conspicuously
Should be signed by top Management to show commitment
Contents shall be made to all crew members
3.0 COMPANY RESPONSIBILITIES AND AUTHORITY
Does the operator of the vessel differ from the registered owner?
If different, has the Administration been informed of who is responsible for the operation of the
ship (3.1)
Verify that he company and the Master have communicated status on any outstanding MNC or
NC's.
Do the crew members know who is the Security Officer of the vessel is and what his functions
are?
DESIGNATED PERSON ASHORE ( DPA)
Has the company nominated a DPA (4.0)
Has the DPA been given sufficient training to carry out his duties efficiently, course attendance?
Does the Master know who the DPA is and what his functions are? (3.2)
Do crew members know who the DPA is and what his functions are?
Is there sufficient evidence to show that the DPA visits the vessel regularly to monitor the SMS?
(4.0)(3.3)
5.0 MASTERS RESPONSIBILITY AND AUTHORITY
Implementing the SMS of the company (5.1.1)
Check to see if there are records to show all crew have read the manual and are familiarized
Proper filing system for manual and checklist available. (5.1.1
Verify safety meeting minutes
Other in-house training provided by company
Issuing orders in clear and simple manner
Look for Masters standing orders
Engineers standing orders
Night order book
Name of employee
Verify that special requirements are observed (5.1.4

Are the crew using protective gears for their daily work?
Yes
No
N/A
Are there records to show that the crew have sufficient rest periods as per STCW requirements?
Yes
No
N/A
Has the Master carried out the Master's Review according to SMS procedures? (5.1.5)
Yes
No
N/A
Does the SMS clearly define the Master's overriding authority?
Yes
No
N/A
Is the Master aware of his overriding authority?
Yes
No
N/A
Enter name and title of employee being interviewed and their response: obtain
signature.
Sign
Enter name and title of employee being interviewed and their response: obtain
signature.
Sign
6.0 RESOURCES AND PERSONNEL
Is the Master properly qualified for command (6.1.1)
Yes
No
N/A
Check the restrictions in the Certificate of Competency against the Safe Manning Certificate
(COI)
Yes
No
N/A
Certificate must be STCW format
Yes
No
N/A
Is the Master fully conversant with the SMS? (6.1.2)
Yes
No
N/A
Enter name and title of employee being interviewed and their response: obtain
signature.
Sign
Enter name and title of employee being interviewed and their response: obtain
signature.
Sign
The vessel should be manned by qualified , certified and medically fit seafarers. (6.2)
Yes
No
N/A
Check certificate of competency for local officers and crew.
Yes
No
N/A
Check watch keeping certificate and Best Safety Training (BST) certificate for watch keeping
ratings.
Yes
No
N/A
Check if crew members have medical certificate.
Yes
No
N/A
Check documentation to show that all newly joined crew members are given the proper
familiarization in relation to their duties with particular regard to safety, security and
environmental protection (6.3)
Yes
No
N/A
Check individually familiarization documentation.
Yes
No
N/A
Has the familiarization covered relevant rules, regulations, codes & guidelines (6.4)
Yes
No
N/A
Master handover notes.
Yes
No
N/A
Does the company have any procedures to identify training needs to support the SMS (6.5)
Yes
No
N/A
Have the ships personnel received relevant information on the SMS in their working languages
(6.6)
Yes
No
N/A
The company should ensure the ships personnel are able to communicate effectively in the
execution of their duties (6.7)
Yes
No
N/A
7.0 DEVELOPMENT OF PLANS FOR SHIPBOARD OPERATIONS
Has the company prepared plans and procedures for preparation of plans, instructions including
checklist for key shipboard operations (7.0)
Yes
No
N/A
Check and verify entries for arrival/departure checklist
Yes
No
N/A
Check and verify entries for permit to work/entry into enclosed space
Yes
No
N/A
Verify standing orders or checklist for navigation, change of watch, at anchorage
Yes
No
N/A
Verify standing orders or checklist for engine room watchkeeping
Yes
No
N/A
Check/ verify passage plan
Yes
No
N/A
Verify bunkering checklist.
Yes
No
N/A
Verify record of daily tank soundings
Yes
No
N/A
Verify record of garbage disposal
Yes
No
N/A
Verify records of crew work/ rest hours and composition of watch keepers
Yes
No
N/A
Verify checklist for preparation of docking
Yes
No
N/A
Verify records of security watch
Yes
No
N/A
8.0 EMERGENCY PREPAREDNESS
Does the company SMS provide procedures on how to respond to potential emergency shipboard
situations? (8.1)
Yes
No
N/A
Collision
Yes
No
N/A
Grounding
Yes
No
N/A
Fire/ Explosion
Yes
No
N/A
Flooding
Yes
No
N/A
Man Overboard
Yes
No
N/A
Steering gear failure/ power failure
Yes
No
N/A
Piracy / Terrorism
Yes
No
N/A
Oil Spill
Yes
No
N/A
Cargo shift
Yes
No
N/A
Bomb search
Yes
No
N/A
Enter name and title of employee being interviewed and their response: obtain
signature.
Sign
Enter name and title of employee being interviewed and their response: obtain
signature.
Sign
Does the company have a schedule of drills to be carried out?
Yes
No
N/A
Are the drills being carried out as planned, past drill records to be verified?
Yes
No
N/A
Are the relevant drills being recorded?
Yes
No
N/A
The company's organization should be able to respond at any time to an emergency situation,
check to see if a table top exercise has been carried out involving office staff (8.3)
Yes
No
N/A
Enter name and title of employee being interviewed and their response: obtain
signature.
Sign
Enter name and title of employee being interviewed and their response: obtain
signature.
Sign
9.0 NEAR MISSES REPORTS AND ANALYSIS OF NCs, ACCIDENTS, INCIDENTS AND
NEAR MISSES
Check that Master is familiar with procedures of reporting nonconformities, accidents, incidents
and near misses (9.1)
Yes
No
N/A
Verify if Master has accurately been reporting the above.
Yes
No
N/A
Verify previous nonconformities, accidents, incidents and near misses (if any)
Yes
No
N/A
Have they been closed effectively by the agreed time (9.2)
Yes
No
N/A
Was the NC investigated and analyzed in order to improve the standards onboard (9.1)
Yes
No
N/A
Enter name and title of employee being interviewed and their response: obtain
signature.
Sign
10.0 MAINTENANCE OF SHIP AND EQUIPMENT
Verify that maintenance inspections are being held at regular intervals. Check for any gaps in the
inspection dates (10.2.1)
Yes
No
N/A
Verify that any non-conformity is being reported (10.2.3)
Yes
No
N/A
Verify that corrective and preventive actions are being taken in a timely manner (10.2.3)
Yes
No
N/A
Records of all maintenance activities up to date
Yes
No
N/A
Regular testing and maintenance of stand-by equipment should include but not be limited to:
FFA
Hoses/nozzles/hose box
Yes
No
N/A
Extinguishers
Yes
No
N/A
Breathing Apparatus
Yes
No
N/A
EEBD
Yes
No
N/A
Fireman outfits
Yes
No
N/A
Emergency fire pump
Yes
No
N/A
Main fire pump
Yes
No
N/A
Foam applicators
Yes
No
N/A
Fixed fire extinguishing system
Yes
No
N/A
Fire detection system
Yes
No
N/A
Fire flaps/dampers
Yes
No
N/A
Fire hydrants
Yes
No
N/A
LSA
Rescue boat, davit and falls
Yes
No
N/A
Rescue boat engine
Yes
No
N/A
Liferafts
Yes
No
N/A
Life jackets
Yes
No
N/A
Life buoys
Yes
No
N/A
Immersion suits
Yes
No
N/A
SART
Yes
No
N/A
EPIRB (cert for annual testing)
Yes
No
N/A
Line throwing apparatus
Yes
No
N/A
Quick closing valves
Yes
No
N/A
Remote stopping of ventilators
Yes
No
N/A
Emergency steering gear system
Yes
No
N/A
Navigation lights
Yes
No
N/A
Emergency lighting for deck/engine accommodations. (maintenance of batteries included)
Yes
No
N/A
Lifting appliances
Yes
No
N/A
Communication, w/h-steering-eng. room
Yes
No
N/A
High level bilge alarm
Yes
No
N/A
Portable gas detectors
Yes
No
N/A
Water tight doors
Yes
No
N/A
Oily water separator
Yes
No
N/A
M/E standby systems including emergency stop, high temp. low pressure
Yes
No
N/A
Verify entries and contents of the planned maintenance schedule, standby items above should be
included for:
Engine Department
Yes
No
N/A
Enter name and title of employee being interviewed and their response: obtain
signature.
Sign
11.0 DOCUMENTATION
Does the company have procedures to control all documents relevant to the SMS (11.1)
Yes
No
N/A
Check to ensure:
Valid documents are available at all relevant locations (11.2.1)
Yes
No
N/A
Changes to documents are reviewed and approved by authorized personnel
Yes
No
N/A
Obsolete documents are promptly removed (11.2.3)
Yes
No
N/A
Is the company SMS kept in a form that is practical and effective?
Yes
No
N/A
All documentation relevant to the ship should be carried onboard (11.3)

Yes
No
N/A
Enter name and title of employee being interviewed and their response: obtain
signature.
Sign
12.0 COMPANY VERIFICATION, REVIEW AND EVALUATION
Has the company carried out internal safety audits to verify that the safety and pollution
prevention activities comply with the SMS (12.1)
Yes
No
N/A
Does the company periodically carry out a management review of the safety management system
and timely corrective actions effected (12.2) (12.6)
Yes
No
N/A
Result of the audits being brought to the attention of all parties involved? (12.5)
Yes
No
N/A
Are the audits and corrective actions being carried out according to documented procedures
(12.3)
Yes
No
N/A
The auditor should be independent of the area being audited unless this is impracticable due to
the size and nature of the company (12.4)
Yes
No
N/A
ANNEX 1: DOCUMENTS, PUBLICATIONS, CERTIFICATES AND RECORDS TO BE
VERIFIED
OFFICIAL DOCUMENTS:
CLASS
Yes
No
N/A
SAFETY CONSTRUCTION
Yes
No
N/A
LOAD LINE
Yes
No
N/A
SAFETY EQUIPMENT
Yes
No
N/A
SAFETY RADIO
Yes
No
N/A
IOPP
Yes
No
N/A
IAPP
Yes
No
N/A
ISSC
Yes
No
N/A
TONNAGE
Yes
No
N/A
DOC
Yes
No
N/A
SMC
Yes
No
N/A
RADIO STATION LICENSE
Yes
No
N/A
CERTIFICATE OF REGISTRY (COD)
Yes
No
N/A
SAFE MANNING CERTIFICATE (COI)
Yes
No
N/A
LIFTING APPLIANCES
Yes
No
N/A
COFR
Yes
No
N/A
CONTINUOUS SYNOPSIS
Yes
No
N/A
BRIDGE TO BRIDGE RADIO CERTIFICATE
Yes
No
N/A
SHORE BASED MAINTENANCE CERTIFICATE
Yes
No
N/A
LRIT
Yes
No
N/A
ENGINEERS CERTIFICATES
NAME AND USCG MMC EXP DATE
Sign
NAME AND USCG MMC EXP DATE
Sign
NAME AND USCG MMC EXP DATE
Sign
NAME AND USCG MMC EXP DATE
Sign
NAME AND USCG MMC EXP DATE
Sign
MUSTER LIST UPDATED AND DISPLAYED
Yes
No
N/A
SOLAS TRAINING MANUAL
Yes
No
N/A
DECK LOG BOOK
Yes
No
N/A
ENGINE LOG BOOK
Yes
No
N/A
OIL RECORD BOOK
Yes
No
N/A
SOPEP MANUAL
Yes
No
N/A
CHARTS AND PUBLICATION
Yes
No
N/A
OFFICIAL LOG BOOK
Yes
No
N/A
APPROVED STABILITY BOOK/ LETTER
Yes
No
N/A
CARGO GEAR CERTIFICATE
Yes
No
N/A
COMPASS ERROR BOOK
Yes
No
N/A
FIRE FIGHTING & APPLIANCE TRAINING MANUAL
Yes
No
N/A
FIRE SAFETY OPERATIONAL BOOKLET
Yes
No
N/A
APPROVED FIRE PLAN
Yes
No
N/A
IMO NUMBER
Yes
No
N/A
AIS
Yes
No
N/A
SHIP SECURITY ALERT SYSTEM
Yes
No
N/A
ISPS SECURITY MANUAL
Yes
No
N/A
CARGO SECURING MANUAL
Yes
No
N/A
ROUTE OPERATIONAL MANUAL
Yes
No
N/A
CRAFT OPERATIONAL MANUAL
Yes
No
N/A
MANUALS FOR EQUIPMENT FITTED ONBOARD
Yes
No
N/A
CURRENT CFRS 33 & 46
Yes
No
N/A
SOLAS, MARPOL, ISM CODE
Yes
No
N/A
FUEL OIL TRANSFER PROCEDURES
Yes
No
N/A
EMERGENCY TOWING PROCEDURES
Yes
No
N/A
SAFETY MANAGEMENT SYSTEM
Yes
No
N/A
ISM INTERNAL AUDIT SUMMARY
CODE. ELEMENT
1. GENERAL

2. HEALTH, SAFETY & ENVIRONMENT

3. COMPANY RESPONSIBILITIES

4. DESIGNATED PERSON ASHORE

5. MASTER'S RESPONSIBILITY & AUTHORITY

6. RESOURCES & PERSONNEL

7. DEVELOPMENT OF PLANS FOR SHIPBOARD OPERATIONS

8. EMERGENCY PREPAREDNESS
9. REPORTS & ANALYSIS

10. MAINTENANCE OF SHIP & EQUIPMENT

11. DOCUMENTATION

12. COMPANY CERTIFICATION, REVIEW & EVALUATION

13. CERTIFICATION & PERIODICAL REVIEW

ADDITIONAL COMMENTS

Please note that this checklist is a hypothetical example and provides basic information only. It is not intended to take the place of, among
other things, workplace, health and safety advice; medical advice, diagnosis, or treatment; or other applicable laws. You should also seek
your own professional advice to determine if the use of such checklist is permissible in your workplace or jurisdiction.
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