First of Its Kind

ClassNK recently published the 'Prime Shipmanagement Guidelines,' a 59-page document offering practical guidance on simplifying Safety Management Systems (SMSs). The goal is to improve both safety and sustainability in ship management.
 

The shipping industry first introduced concepts like Bridge Resource Management (BRM) and Engine Room Resource Management (ERM), inspired by aviation’s structured use of manuals and checklists.
 

While developing the guidelines, ClassNK collected insights from Lovoy Training Inc. The text includes extracts covering the history of Lovoy’s work and the Lovoy Method. These parts give concrete ideas on how to simplify SMSs. ClassNK used the Lovoy Method and advice from Lovoy Training Inc. to strengthen this part of the guide.

ClassNK is now promoting the guidelines to ship managers and large shippers. This includes some of the world’s largest mining companies, who rely on shipping companies to meet high standards for safe and sustainable operations. Their expectations often shape how shipping companies write and maintain their Safety Management Systems (SMS).
 

Below, we share reformatted extracts from the guidelines. These include content about Lovoy’s history, his work, and the Lovoy Method. 
You can download the full "Prime Shipmanagement Guidelines" as a free PDF from ClassNK’s website. To get the file, you must first register.

  https://www.classnk.or.jp/account/en/Rules_Guidance/ssl/guidelines.aspx

Registration is simple, fast, and open to everyone. No approval is needed.

Safety Management Manuals and Checklists in the Aviation Industry

The aviation industry has been aware of the importance of the safety management manuals and checklists from the earlier stage. The concept of pre-flight checklist was introduced triggered by a crash of the prototype aircraft in 1935. This accident occurred due to the negligence before the takeoff in unlocking the rudder and elevator surface controls that control the aircraft's lateral and vertical movement in the air. Based on the learning, the pre-flight checklist was developed and spread across the aviation industry with its effectiveness widely recognized. Similar to the checklist, the effectiveness of managing the safety as system was acknowledged based on experiences of many accidents, and the ICAO (International Civil Aviation Organization) made the introduction of the safety management system mandatory on a global scale in 2001.

The shipping industry has introduced BRM (Bridge Resource Management) and ERM (Engine Room Resource Management), which are widely known as the means originally developed in the aviation industry.
Furthermore, Capt. Terje Lovoy an ex-aircraft pilot, is researching how to apply the aviation industry's methods to the shipping industry for the operation of the safety management manuals and checklists. He specifically advocates the way to incorporate (implement) the simple and functional safety management manuals and checklists into the maritime SMS.

Our (ClassNK's) utmost gratitude goes to Capt. Terje Lovoy for introducing the methods to restructure the SMS as well as for providing highly valuable insights for identification of challenges and considerations of further improvement.
The following text is an extract of ClassNK Guidelines Appendix 3.

ClassNK Prime Shipmanagement Guidelines Appendix 3:

Simple SMS and Lovoy Method

In the process of developing the guidelines, we sought insights from Mr. Terje Lovoy regarding the simplification of manuals. Mr. Lovoy is one of the pioneers who first introduced the concept of "manual simplification" to the maritime industry. With 27 years of experience in the aviation industry, he has contributed to enhancing safety at Boeing and major airlines by utilizing functional procedures. Rather than directly applying case studies from the aviation industry, he established the "Lovoy Method" through extensive trial and error and adapted it to the maritime sector.
As one approach to creating simplified manuals, we introduce Mr. Lovoy’s explanation of the Lovoy-Method.

The Need for Effective Manuals

Since 1989, the ISM Code called for a Safety Management System (SMS) aimed at managing ship safety systematically in response to repeated maritime accidents. SMSs have improved safety in the shipping industry, but they also introduced new challenges.

The Story Behind this Guidance and Its Goals

ClassNK and Lovoy Training Inc., parties agreed that overly complex SMSs pose challenges but also present opportunities for improvement.  A user-friendly SMS is good for safety and efficiency. 
It is easier to use onboard, in the office, and during audits. It also makes it easier to keep SMSs up to date and prepare for audits. This guidance recommends how to simplify and improve your SMS for increased safety and efficiency. We will discuss the process, benefits, and risks.

Learning from Aviation's Success with Simplicity

Since the late 1950s, the aviation industry has reduced accident rates by over 100%.  This remarkable achievement has drawn interest from other industries, including shipping, which seeks to learn from aviation’s success. Initial safety gains came from technical improvements. However, human error, responsible for up to 80% of accidents, remained a major issue. Focusing on the human element further lowered accident rates to today's low levels.

The International Civil Aviation Organization (ICAO) is aviation's version of the International Maritime Organization (IMO). ICAO published standards similar to the ISM Code, and these standards also added excessive complexity. In the old days, pilots saw checklists as a nuisance. The checklists were overly complicated, blending trivial and “killer” items. Some experienced pilots even dismissed them as "checklists for dummies." Pilots often read them not because they wanted to, but because they had to. They were more concerned with the cockpit voice recorder. As a result, they read them quickly and superficially rather than carefully checking each item. This checklist complacency contributed to accidents like Delta Airlines Flight 1141 in 1988. After several similar accidents, the industry examined checklist complacency. 

The first checklists in the late 1930s, marked the shift from no checklists to increasingly complex ones. By the late 1990s, these checklists had become so complicated that they interfered with safety, common sense, and good airmanship. This prompted the industry to focus on simplifying procedures and checklists without losing facts. This approach proved to be highly effective. 
Today, pilots read checklists slowly and carefully—not because they have to, but because they want to. They recognize checklists as valuable tools.

In 2009, Terje Lovoy was one of the first to introduce the concept of SMS simplification to the shipping industry, a revolutionary idea at the time. He went public with this issue through speaking, writing, and working with shipping companies to find solutions. Lovoy has 27 years of experience from aviation. He worked for Boeing and major airlines that had made significant safety improvements through effective procedures. Lovoy understood that shipping companies could not just copy airline procedures. After extensive testing, they were able to modify some airline principles to fit the shipping industry. This ultimately led to the Lovoy Method for SMS simplification and improvement. 
The goal was to make systems user-friendly to increase usage and reduce mistakes. Today, most shipping companies recognize that an overly complex SMS is a problem.

What Makes SMSs Too Complex?

There is usually a link between how well we understand problems we are trying to improve and the results. It is therefore worth spending some time discussing why SMSs often become overly complex. Lovoy's team analyzed 63 SMSs over a decade, many containing about half a million words. A survey of over 1,000 seafarers revealed common issues:

• Difficulty locating information
• Instructions that do not follow workflows
• Spaghetti mixing of explanations and tasks duplicated in several places
• Difficult words, too long, and passive sentences
   

Root Causes Analysis

Many shipping and marine insurance companies engaged Lovoy for root cause analysis of why SMSs become too complicated. Initially, they found that failure to follow procedures was a common issue. Further investigation revealed that many procedures were too complicated to use effectively. Some believed this complexity was intentional to pass audits.

But Lovoy discovered something else: 
Writers only know how to write complicated text because that is what we learn in school. Digging deeper, it became clear that this complexity was not a deliberate strategy. It was a lack of strategy altogether. One of the root causes was the absence of writing standards, training, and ways to measure how user-friendly the SMS was. Contrary to common assumptions, Lovoy's research showed that the challenge was not information overload, but rather in how we present the information. 
Unnecessary complexity stemmed from factors like duplications, contradictions, excessive cross-referencing, and poor SMS structure. 
These findings highlight the crucial need for not only quantity but also quality and clarity in information presentation. To tackle these issues, Lovoy developed text simplification techniques to streamline processes, improve comprehension, and create more concise text without sacrificing accuracy.

The Power of Simplicity in Compliance

Surprisingly, many believe it is impossible to make a SMS that complies with audit standards and is user-friendly at the same time. 
Lovoy followed 23 shipping companies who simplified and improved their SMSs using their own people. They simplified by washing out filler words, double talk, and changing from passive to active sentences. They used the Lovoy Text Washing Method to simplify without removing facts or dumbing down the text. They replaced overly complex words such as “elucidate” with more commonly used words such as “explain” or “make clear. ”They continued using maritime terms such as “enclosed space,” “forecastle,” and other IMO standard marine phrases. 
You can read more about text washing methods on https://lovoy.info/

Companies that successfully simplified their SMSs received positive feedback from seafarers with around 70% increased perceived usability. Second, companies performed better in audits because inspectors could see that the procedures matched real-life practices. In summary, the simplified and improved procedures better complied with the true intentions of regulations and guidance.
This led to new industry requirements for more user-friendly SMSs. 

The Dangers of Oversimplification

Contrary to popular belief, the problem with overly complicated SMSs is not an overload of information. Many shipping companies and articles mistakenly focus on this, but Lovoy strongly disagrees. Through their analysis, Lovoy found that the issue is not too much information but rather how SMSs present information. For example, cargo ships need procedures with sufficient details to manage their cargo safely. The challenge is to present this necessary information in a clear, concise manner without losing important facts.

Lovoy argues that a well-structured SMS should function as a reference tool, not as a book to be read from start to finish in one go. New users will initially read the entire system, but most use it to quickly look up specific information. With a logical structure, clear headings, and short, well-organized paragraphs, too much information ceases to be a problem. Like an encyclopedia, a SMS should allow users to find what they need quickly and efficiently.

Lovoy cautions against the misconception that simplifying a SMS means removing a lot of information. What is perceived as unnecessary information might be essential at some point. The old SMS reflects the company’s collective experience. Therefore, a simplified SMS should improve safety and compliance without oversimplification. Lovoy warns that oversimplifying leads to loss of critical details, ultimately compromising the effectiveness.

Spaghetti SMS Structure

Lovoy found a bigger problem than overly complex text. They called it spaghetti SMS structure. This results from copying text blocks from codes and guidance without adapting them to real-life workflows.

How well we succeed with restructuring is an important success factor. Lovoy estimates that 80% of success comes from restructuring and 20% from text washing. One cause of spaghetti SMS structure is that many believe we should not mix guidance and mandatory actions. They split these into different sections, which forces seafarers to read multiple sections simultaneously. Too many sections covering the same topic result in excessive cross-referencing.

A better approach is to group related material in one process, following the user’s workflow.  The text should follow the footsteps of the person doing the job. Some steps are mandatory, and other are guidance. But the most user-friendly way is to keep them together in process-oriented procedures. We still need to clarify what is guidance and mandatory. The words we use tell the user if a step is mandatory or guidance.

• Shall is mandatory
• Should is a recommendation
• Consider indicates to use judgment and decide

The Big Picture SMS Structure
So far, we have focused on how to structure individual procedures. We discussed ensuring each one is clear, concise, and aligned with actual tasks.

However, a SMS is made up of many procedures and documents, each serving a specific purpose. The question now is, how do we approach the overall structure of the entire SMS? It is crucial to design a big-picture framework that organizes these elements effectively. 
SMSs must comply with many standards, but each standard is different. Some companies believe that matching the structure of one standard will simplify audits. While it might seem smart to align with the structure of one standard, this leads to misalignment with the other standards. Most industry standards require a logical, process-oriented structure. They often use a sequential, building-block system to organize content, which helps in explaining requirements. However, this structure does not necessarily align with the actual processes of a shipping company.

It is crucial to recognize that while the standard's organization is useful for presenting information, it may not be the most practical for structuring real-life operations. 
Instead, companies should extract relevant content from all standards and create a process-oriented system that better fits their operational needs.

Lovoy recommends not duplicating any one standard's structure. Instead, reorganize the SMS to follow the workflow of each job. This is a one-time effort. It makes the SMS easier to use, update, and ensures compliance with all relevant standards.

Effective Compliance Through Real-Life Alignment

To comply with standards, we must carefully extract relevant information and incorporate it into our procedures. You might wonder how to do this effectively. The key is to ensure that written procedures closely match real-life practices. When procedures reflect actual work, they are more effective and easier to follow. This alignment reduces confusion, boosts efficiency, and improves safety. Closing the gap between written procedures and real-life practices strengthen compliance, reduce errors, and build trust. 
Well-aligned procedures lead to better outcomes in everyday operations and audit results. Specific standards like SIRE and COSWOP now recommend logic user-centered procedures reflecting actual tasks. ISO 9001 requires process orientation. Many shipping companies with ISO 9001 approval fail to adapt it to real-life practices. However, it is possible to create a user-friendly, process-oriented SMS meeting all relevant standards.

Text Washing

The ISM Code requires SMSs written in a language that seafarers understand. As a result, most SMSs use English. However, many seafarers come from countries where English is not the first language. They speak different native languages. Therefore, it is crucial to use a form of English that is clear and understandable for most seafarers. For this reason, guidelines like TMSA3 call for the use of plain language. Plain language, as defined by various governments and laws, involves using simple, everyday words. This approach ensures that all seafarers, regardless of their background, can easily understand the procedures. Clear communication prevents misunderstandings, and improves safety and compliance.

To achieve this clarity, Lovoy developed a text washing technique. Text washing means to simplify difficult words, passive sentences, long sentences, and remove double talk and filler words. Filler words are words that add little value, such as “completely dead” or “round in shape.” The table below has text washing examples:

Common everyday words are easier to understand and quicker to read. As required by the ISM Code, use them as much as possible. Complex words take more time, even for native speakers. Lovoy published a free online dictionary at https://lovoy.info/dictionary/ . It lists simpler alternatives for typical complex words found in older SMSs.
Successful companies measure their results. Lovoy designed Key Performance Indicators (KPIs) to help writers meet targets. Some examples are Percent Passive Sentences (PPS) and Average Words per Sentence (AWS).

Who Should Rewrite the SMS?

The main risk with SMS simplification is not choosing the right method. This often results in over-simplification. Another risk involves opting for a quick fix by hiring external consultants rather than investing in your own staff. Outsourcing to external consultants may seem like a convenient solution, but it is often a temporary fix. Consultants may lack an in-depth understanding of your company’s specific needs and operational realities. This can result in a SMS not fitting your actual practices, potentially leading to further complications and inefficiencies. Investing in your own staff for SMS simplification ensures a more tailored approach. Your team, being familiar with the company’s day-to-day operations, creates procedures reflecting real-life practices. 
This approach not only promotes long-term improvements but also builds internal expertise that prevents the recurrence of previous complexities. Involving your staff in the process fosters a deeper understanding and ownership of the SMS.

This leads to more effective implementation and adherence to the procedures. Internal writers allow for continuing adjustments and improvements, enhancing the system’s effectiveness over time.
Choosing to develop internal capabilities rather than external consultants is a longer-term solution. 
It ensures that the changes made truly reflect your company’s needs. It supports continuous improvement and adaptation. This customization is evident to auditors and clients, providing a competitive edge in the market. Investing in your own team is low risk and usually far outweigh any short-term extra costs. It will reduce costs in the long run.

The Advantages of Using Subject Experts in Writing

Should companies use a writer with good English writing skills but little knowledge of the content, or should they use a subject expert? Lovoy tested both options and found that:

• True simplicity comes from thorough understanding.
• People without a good understanding of a subject often insist on unnecessary complexity.
• Simplification without understanding is difficult.

Based on this, Lovoy decided to test if they could train seafarers and internal staff to write good SMS procedures. Today, most seafarers come from countries where English is not the native language. Lovoy decided to include what language scientists call a controlled language in the Lovoy Method. It is English but with strict rules for grammar, vocabulary, layout, and structure. When used correctly, it reduces complexity without losing facts. It makes it easier for both native and non-native English speakers to write user-friendly procedures.

Global SMS Writer Training for Seafarers and Office Staff

Lovoy also designed an online training program to train seafarers to become SMS writers. They tested it with seafarers and office staff in different parts of the world. With training and practice, most writers produced high-quality procedures. They got good results from non-native English-speaking nations. The controlled language allowed shipping companies to use their own people to reduce large volumes of complicated, inconsistent text to clear, easy-to-use text.

Is Switching to New Software the Solution?

Some believe that switching to new software for the SMS is a miracle fix for all their previous difficulties. They think that simply transferring old text into a new electronic format will solve the problem. However, the saying “garbage in, garbage out” applies here. If the content is flawed, moving it to a new system will not fix the issues. Seafarers often give feedback that it was hard to find information in the old SMS. After moving to new software, finding information became even more challenging. The real solution is to first address the content and then place it into a new system with a process structure matching real-life practices.

One common problem with many new electronic systems is that they have a fixed structure set by the manufacturer. This can force shipping companies to use a structure not matching their needs. Instead, new software often forces SMSs into a spaghetti, non-process-oriented structure. Shipping companies should first refine their SMS content and create a process-oriented structure before selecting a new electronic system. This approach ensures that the software supports their specific needs rather than forcing them into a structure created by software developers who may not fully understand the practical workflows of seafarers.

The Biggest Challenge

Simplifying a SMS is a strategic move that improves safety and audit results. Most DPAs recognize this, but convincing senior management can be challenging. Owners might assume simplifying the SMS is solely the DPA’s job. But it requires tools, training, methods, and time—resources that DPAs often lack. Investing in these areas is a one-time expense that offers long-term benefits.
In successful SMS simplification, one key factor stands out: The DPA was capable of clearly presenting the advantages of SMS simplification. This ability to make a strong case to senior management is often the most important factor in whether a company succeeds or fails. Many DPAs want to simplify but struggle to convince owners of its importance. 

Therefore, DPAs should gather relevant information, examples from other companies, and insights from new audit standards. This helps show that continuing with a complex SMS poses more risk than making the proposed changes. Simplifying the SMS is not only a safety issue but also a way to give the company a competitive advantage. Audit standards increasingly focus on user-friendly SMSs, making this SMS simplification a priority in many shipping companies. Although it may be challenging and require courage, it is achievable and worthwhile. Building a strong case for SMS simplification is a key factor for success. A DPA who can make a convincing case to owners is therefore probably the most important SMS simplification success factor.

Conclusion

Simplification requires the right tools and knowledge. While it may seem less urgent compared to technical projects, it is crucial for reducing human error. Human error accounts for up to 80% of marine losses. Simplifying SMSs can save time and money in the long run. Companies that simplify their SMS understand that safety and competitiveness go hand in hand.

References

SMS writers who want to learn more can find additional explanations, background information, articles, case studies, and videos on the website: https://lovoy.info/

Link to ClassNK's registration page for the full PDF guidelines.