The development of human factor- (HF) related regulations of the International Maritime Organization (IMO) has often been the result of responses to maritime accidents. The typical reaction to an accident has been a combination of (mainly technical) regulations, changing of procedures and training. Systemic evaluations and changes have rarely been done. Statements made by IMO in recent years claim a shift towards a proactive approach in maritime safety. Key documents, like the IMO Human Element vision, would confirm such statements. This article reviews documents submitted to IMO's Maritime Safety Committee (MSC) in order to evaluate the 'mechanisms' of decision-making and the priorities for setting the agenda in MSC regarding maritime human factors. The review confirms that the IMO work related to HF was reactive in the 1990s. There are a number of examples of more recent regulations that can be considered proactive. However, it is too early to fully confirm a proactive policy in the IMO rule-making process.