Answer
He dint accept loss time injury report.
In an ISM Code audit context, an examiner will instantly reject an LTI (Lost Time Injury) report as proof of ISM implementation verification.
Why he didn't accept it: An LTI report is a lagging indicator and a statistical metric. It simply proves that an accident occurred and a crew member was incapacitated. It does not prove that the Safety Management System (SMS) is being actively implemented, audited, or continuously improved.
What you should have provided instead (The Leading Indicators): To prove active ISM implementation verification under Sections 9 and 12 of the code, you must present:
ISM implementation verification means confirming that the Safety Management System is not only documented but also effectively implemented onboard and ashore. It is verified by internal audits by the Company, external audits by Flag or RO, DOC and SMC audits, Master’s Review, management review, inspection of SMS records, drills, training, maintenance records, risk assessments, permits, accident and near-miss reports, non-conformities and corrective actions. If deficiencies are found, they are reported, corrective action is taken, and follow-up is done to verify effectiveness.
Main methods of verification:
Internal Audit
Conducted by the Company or authorized auditor to check SMS compliance onboard and in the office.External Audit
Conducted by Flag Administration or Recognized Organization/Class on behalf of Flag.DOC and SMC audit
Company office is verified for Document of Compliance — DOC.
Ship is verified for Safety Management Certificate — SMC.Master’s Review
Master reviews effectiveness of SMS onboard and reports deficiencies to shore management.Management Review
Shore management reviews SMS performance, audit findings, accidents, NCs, near misses, PSC observations, and corrective actions.Records and evidence
Verification is done through logbooks, checklist records, drill reports, training records, maintenance records, risk assessments, permits to work, meeting minutes, and corrective action reports.Toolbox Talk Registers and Risk Assessments: Physical proof that before any critical job (like hot work or enclosed space entry), the team systematically assessed hazards, walked through the checklist, and actively implemented controls.