The article takes as its point of departure the apparently contradictory findings in recent research about accident rates in shipping and IMO implementation records. It is argued here that although IMO conventions have probably greatly improved shipping safety, they cannot credibly be held to be the chief cause of reduced accident rates as claimed in a recent Marine Policy article, when the documented failures of flag state and port state implementation continue to leave vessels sailing with grave deficiencies. The present analysis posits and corroborates a cluster of linked tendencies that jointly undermine IMO implementation. The core problem is IMO’s weak connection to the national maritime administrations, leading to broadly discretionary practices, exacerbated by language difficulties. Adding new rules is no panacea, as new rules in some cases negatively affect the functioning of existing regulations, and sometimes seem motivated mainly to show political alertness. The structural weakness of the IMO/member state link is the core implementation problem that urgently needs to be dealt with if marine safety is to be improved. The concluding section proposes a reform to bring the IMO out of this conundrum and ensure effective implementation.