Can the ship's superintendent become DPA ?

Can the ship's superintendent become DPA and should the ship's superintendent become DPA will have different answers.

Can the ship's superintendent become DPA? The answer would be Yes.

As per ISM code

every Company, as appropriate, should designate a person or persons ashore having direct access to the highest level of management. The responsibility and authority of the designated person or persons should include monitoring the safety and pollution-prevention aspects of the operation of each ship and ensuring that adequate resources and shore-based support are applied, as required 

So as per ISM code, the only requirement for being a designated person is that he/she should have direct access to the highest level of management.

The company can always claim that the ship's superintendent has the access to the highest level of management.

MSC.MEPC-7/Circ 6 gives the details of qualification, training, and experience required for the designated person of the company.  

After the required training, the ship's superintendent can easily fit into these requirements and can be the designated person for the company.

Some flag states may have their own requirements for the qualification of the designated person. For example, DG shipping India desires the DPA to have at least two years sailing experience as Master or chief engineer of the ship.

In all these requirements, nothing stops a ship's superintendent to be designated person of the company.

But then the question is, should the ship's superintendent become DPA? And my answer would be NO.

I have even seen few companies having appointed the deputy marine superintendent as the designated person. But the question remains, can a deputy marine superintendent who has just been inducted into the shore set up fulfill the expectations required of his role as a DPA.  

Now the ship's superintendents may have been given the authority and access to the highest level of management but the question is, how easily a ship's superintendent will be able to exercise that authority?

Not very easily, I would say.

But all these points are applicable to a bigger company (Vertical organizations). Smaller companies have lesser shore staff and thus the highest level of management is not too high in the hierarchy from the ship's superintendents.

A superintendent in this company would most likely not hesitate to talk to the highest level of management for any issue on board.

So in a bigger company, ship's superintendent should not be the DPA though he/she can be as per rules. But in a smaller company, there is no harm in having a ship's superintendent as the DPA.