The International Safety Management (ISM) Code was developed, and was never intended to be a tool for lawyers and the courts to determine issues of liability. Nor was it developed to make the lives of ship operators and seafarers unbearably difficult or to down load their ships with mountains of paper. At one level it provides great latitude recognising that there are many different types and sizes of commercial ship-operating companies which will operate in quite different ways but, at another level, it requires each Company to achieve certain common objectives or goals through the development of its safety management system. By following the process through, by observing objective evidence by following an audit trail it should be possible to verify whether or not what was supposed to be done was actually done, on that occasion. The changes are at the evidential level – because of “new” expectations which have been created through the ISM Code.