Managing a Non-Conformity (NC)
How a Non-Conformity is opened, classified and formally closed within the Safety Management System — the heart of the ISM Code's continuous improvement cycle.
Operational Explanation
A Non-Conformity (NC) is an observed situation that does not meet a requirement specified by the Company's Safety Management System (SMS) or by the ISM Code itself. The Code conceptually distinguishes between "minor" non-conformities (isolated, with no evidence of systemic breakdown) and "major" ones (indicating a serious or systemic deficiency, such as to pose a risk to the safety of people, the ship or the environment).
NC management is the mechanism through which the ISM Code translates the principle of continuous improvement into daily practice: without an NC → root cause analysis → action → effectiveness verification cycle, the SMS remains a document rather than becoming a living system.
Regulatory Reference
ISM Code, par. 1.2.3 and Section 9 (Reports and Analysis of Non-Conformities, Accidents and Hazardous Occurrences): the Company must establish procedures for identifying, reporting and analysing non-conformities, as well as for taking corrective action.
Scope of Application
Applies to every ISM-certified Company (DOC) and every ship holding a Safety Management Certificate (SMC): NCs may arise from internal audits, external audits (certification or PSC), crew reports, or recurring Near Misses.
Procedure / How to Complete It
- Record the NC as soon as it is observed: what happened, where, when, and which SMS/ISM Code requirement was not met.
- Classify it as minor or major, according to the Company's internal procedure criteria.
- Conduct a root cause analysis, not stopping at the immediate symptom.
- Define a CAPA (corrective and, where relevant, preventive action) with an owner and a deadline.
- Verify the effectiveness of the action after a suitable interval, before formally closing the NC.
- File the closed NC in the SMS register, available for the next internal/external audit and for the Management Review.
Diagram: from Non-Conformity to CAPA closure
Practical Example
Example entry: "NC-2026-014 — Minor. Identified during the internal audit of 12.03.2026: mooring winch maintenance checklist not completed for 3 consecutive shifts. Root cause: no reminder built into the maintenance plan (PMS). Action: automatic reminder added to the PMS + briefing for the deck crew. Effectiveness verification: the following 3 shifts checked, all correctly completed. NC closed on 02.04.2026."
Real Cases
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| NC closed without verifying the effectiveness of the action | The root cause remains and the NC recurs (repeat NC) | Always set a verification date after the formal closure |
| Analysis limited to the symptom, not the root cause | Corrective action ineffective over time | Use structured techniques (5 Whys, Ishikawa) for major NCs |
| Recurring 'minor' NCs on the same topic never aggregated | A systemic pattern goes unnoticed until it becomes a major NC or a PSC deficiency | Periodically review the NC register to identify recurring topics |
PSC Observations
Operational Tips
- Keep the NC register as a living working tool, not a bureaucratic task to fill in only before the audit.
- Use a structured root cause analysis for every major NC.
- Periodically review closed minor NCs: if the same theme recurs, treat it as a signal of a systemic problem.
Checklist
- NC recorded with date, description and the requirement breached
- Minor/major classification assigned
- Root cause identified and documented
- CAPA defined with an owner and a deadline
- Effectiveness verification carried out before closure