Is the ISM Code beneficial or with drawbacks?

From the International Safety Management (ISM) Code 2002:

Assessment of the impact and effectiveness of the ISM Code

The International Safety Management (ISM) Code evolved through the development of Guidelines on Management for the Safe Operation of Ships and for Pollution Prevention adopted in 1989 at the 16th regular session of the IMO Assembly by resolution A.647(16). The objective of the Code was to provide an international standard concerning shipboard and shore-based management.
The outcome of the successful implementation of the ISM Code envisages the enhancement of a safety culture throughout the shipping industry. Through implementing the ISM Code and the application of its requirements during the past six and a half years, shipping companies, classification societies and other industry organizations would have gained significant experience in assessing its manifest benefits and drawbacks.
In order to make a meaningful assessment, the Secretary-General has established an Independent Expert Group comprising of experts from Governments, organizations, universities and the shipping industry and the Secretariat to collect and analyze data to study the impact of the ISM Code and its effectiveness. The Expert Group has developed two questionnaires for shore based and shipboard personnel to obtain as much information as possible from both seafarers as well as those ashore responsible for implementing the ISM Code.

Shipboard and shore-based shipping personnel, do participate and contribute your views.