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
The ISM Code defines a non-conformity, at paragraph 1.1.9, as «an observed situation where objective evidence indicates the non-fulfilment of a specified requirement». The decisive element is objective evidence: it is what separates a finding from an opinion, what makes an NC defensible or contestable on appeal, and what an auditor must be able to point to. A situation raised without it is not a non-conformity.
The Code defines two terms, not three: non-conformity (1.1.9) and major non-conformity (1.1.10) — «an identifiable deviation that poses a serious threat to the safety of personnel or the ship or a serious risk to the environment that requires immediate corrective action, and includes the lack of effective and systematic implementation of a requirement of this Code». Those last two elements are what determines the suspension of the SMC and the outcome of an ISM-related detention. The term «minor non-conformity» does not appear in the Code: it is a category of practice, introduced by the implementation guidelines and by the internal procedures of Recognized Organizations and Companies, and it must be presented as such.
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, 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 arise from internal audits, from external certification audits carried out by the Administration or the Recognized Organization, from crew reports and from recurring Near Misses.
Port State Control is not among these sources. The PSC does not conduct audits and does not issue non-conformities: it issues deficiencies, each with its action code. Those relating to the safety management system are classified as ISM-related deficiencies and may lead to detention and to a subsequent additional verification by the Administration or the Recognized Organization — and it is that verification, not the inspection, that produces an NC. Opening an NC in the SMS register in response to a PSC deficiency, and stopping there, means failing to carry out the rectification the action code requires.
Procedure / How to Complete It
- Record the NC as soon as it is observed: what happened, where, when, which SMS or ISM Code requirement was not met, and above all what the objective evidence is — the document, the record, the measurement, the observed condition. Without it the finding is not defensible.
- Establish whether it is a major non-conformity under the definition in paragraph 1.1.10 — serious threat to personnel, ship or environment, immediate corrective action required, or lack of effective and systematic implementation of a requirement of the Code. If it is not, it is a non-conformity: the «minor» label, where the Company uses it, comes from its own procedure and not from the Code.
- 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 — classified minor under the Company’s procedure (a category not provided for by the ISM Code). Identified during the internal audit of 2026-03-12: 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 2026-04-02."
What Typically Goes Wrong
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) | Set the effectiveness-verification date when the action is recorded as implemented, and keep the NC open — or in a declared “pending effectiveness verification” state — until that verification. If the SMS uses provisional closure, it must be named as such and distinguished from final 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 |
What the PSCO Checks
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.
Preparation checklist
Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.
- NC recorded with date, description and the requirement breached
- Classification assigned under the Company’s own procedure: the ISM Code defines non-conformity (para. 1.1.9) and major non-conformity (para. 1.1.10), not the “minor” category
- Root cause identified and documented
- CAPA defined with an owner and a deadline
- Effectiveness verification carried out before closure
FAQ
Related Topics
Last substantive revision of this page: 29 August 2026 · page fingerprint f7e82ff746c4