How to Choose a Ship Manager for Your Vessel

Before you can submit your MSMSR application to Transport Canada, you need to identify a Ship Manager. This is not optional and it is not a formality. Transport Canada will not issue your Canadian Document of Compliance (CDOC) without a Ship Manager named on Form 85-0547A.

For many small vessel operators, choosing a Ship Manager is the first real decision point in the compliance process, and it is one that has real operational consequences. This guide explains what the role is, who can fill it, and how to make the right call for your operation.

What is a Ship Manager?

Under the MSMSR, the Ship Manager is the person responsible for the shore-based management of your Safety Management System. They are the designated point of accountability for how your vessel is operated from a safety standpoint.

The Ship Manager does not need to be on the vessel. In fact, for most small commercial operations, the Ship Manager role is a shore-side function. They are responsible for ensuring that the SMS exists, that it is current, that the crew is trained on it, and that it is being followed.

Transport Canada defines the Ship Manager as the person who has assumed responsibility from the Authorized Representative (the vessel owner or managing owner) for the operation of the vessel and who has agreed to take over all duties and responsibilities imposed by the MSMSR.

Who qualifies as a Ship Manager?

Transport Canada's requirements for Ship Manager qualification vary by vessel class. In general, a Ship Manager must be a qualified person, which means:

• A Canadian citizen or permanent resident, or a corporation incorporated under Canadian law. This means the Ship Manager can be a person or a company.
• Someone with the knowledge and experience to carry out the responsibilities of the role for the class of vessel involved
• Someone who has agreed in writing to accept the responsibilities of Ship Manager

There is no single certification or licence that automatically qualifies someone as a Ship Manager. Transport Canada looks at the overall picture: does this person have the background to actually manage the safe operation of this vessel? For a small Class 4B passenger vessel, that bar is different than for a large Class 2 ferry.

Can I be my own Ship Manager?

Yes, and for most small owner-operated passenger vessels, this is exactly what happens. If you are the Authorized Representative and you are also the person who runs the vessel day to day, you are likely the right person for the Ship Manager role.

Being your own Ship Manager makes sense when:

• You have direct knowledge of the vessel's operations
• You are actively involved in running the business
• You have the time to fulfil the ongoing responsibilities of the role
• Your operation is straightforward enough that one person can realistically manage it

It makes less sense when your operation is large or complex, when you are rarely available, or when you do not have a strong grasp of the regulatory requirements. In those cases, appointing a qualified outside Ship Manager may actually reduce your risk.

What does the Ship Manager role actually involve?

Once appointed, a Ship Manager is responsible for:

• Maintaining the SMS keeping the documentation current, updating procedures when operations change, and ensuring the manual reflects how the vessel actually runs
• Crew training ensuring the crew is trained on the SMS and that training records are kept
• Internal audits conducting or overseeing periodic internal reviews of how well the SMS is being followed
• Incident reporting managing the process for reporting and investigating incidents and near-misses
• Emergency preparedness ensuring emergency procedures are in place, understood, and drilled
• Regulatory liaison being the point of contact with Transport Canada on SMS matters

For a small single-vessel operation, this is manageable. For a larger fleet, it becomes a more significant ongoing commitment.

Appointing someone else as Ship Manager

If appointing yourself does not make sense for your operation, you can designate another qualified person or corporation. This could be:

• A senior employee with the right background and authority
• A partner or co-owner with operational involvement
• A corporation incorporated under Canadian law
• A qualified external marine safety professional

Note that Aurora Marine Safety Group does not accept the role of Ship Manager. We can help you identify and prepare the right candidate, but the ongoing responsibility must sit with you or someone in your operation.

If you appoint an outside person, the agreement must be documented. Transport Canada requires a formal written agreement between the Authorized Representative and the Ship Manager specifying that the Ship Manager has accepted the responsibilities of the role.

Documenting the appointment

The Ship Manager appointment is formalized through two Transport Canada forms:

Form	Purpose	Who submits
Form 85-0547A	Identification of Ship Manager. Names the Ship Manager and documents their acceptance of the role. Required for all classes.	Authorized Representative, with Ship Manager signature
Form 85-0547B	Application for Initial Certification. Required for all classes. Class 4B vessels submit the Declaration of Initial Compliance (included in the form) but do not need to submit the full SMS manual unless Transport Canada requests it. Class 2, 3, and 4A vessels submit the form together with the full SMS manual.	Authorized Representative

Class 2, 3, 4A, and 4B vessels submit both Form 85-0547A and Form 85-0547B. For Class 4B, the Declaration of Initial Compliance within Form 85-0547B is the key submission and the full SMS manual is kept on the vessel unless TC requests it. Class 5 vessels do not submit either form to Transport Canada. They are required to develop and maintain an SMS and appoint a Ship Manager, but there is no application or certification process with TC.

Both forms are available on the Transport Canada website. The information required is straightforward: vessel details, contact information for the Authorized Representative and Ship Manager, and signatures confirming the agreement.

What happens if you need to change your Ship Manager?

Ship Managers can be changed. If circumstances change and you need to appoint a new Ship Manager, you notify Transport Canada using Form 85-0547A again, identifying the new Ship Manager and the date the change takes effect.

There is no penalty for changing Ship Managers, but continuity matters. Frequent changes can create gaps in SMS oversight and may raise questions during an audit about whether the role is being taken seriously. Choose your Ship Manager carefully from the start.