Managing Deficiencies
Each deficiency is technically described, rectified and evidenced under authority instructions; formal closure and any release remain port-State decisions.
Operational Explanation
A deficiency is a condition found not to comply with the requirements of an applicable convention. Every deficiency is classified by code and area, and the most serious can lead to detention if the shortcoming is such as to expose the ship, the crew or the environment to unacceptable risk.
Effective deficiency management does not end with immediate rectification on board: it requires root cause analysis (to prevent recurrence, linking into the SMS's NC/CAPA management) and clear communication with the Port State Control Officer (PSCO) on the timing and manner of closure.
Regulatory Reference
The deficiency classification system is defined by the Paris MoU (and equivalent regimes) in implementation of the underlying conventions; the most serious deficiencies, involving significant risk, lead to detention according to the criteria set out in the MOU's procedures.
Where the power to come on board comes from. Not from the Memorandum. A regional MoU is an administrative arrangement between Administrations: it harmonises how inspections are done, it does not create the right to inspect. That right sits in the control articles of the Conventions, which resolution A.1206(34) — Procedures for Port State Control, 2025 — lists one by one at its paragraph 1.4. For SOLAS there are four regulations, not one: I/19, IX/6.2 (ISM), XI-1/4 and XI-2/9 (ISPS). For MARPOL, Articles 5 and 6 plus one provision per Annex: reg. 11 of Annex I, reg. 16.9 of II, reg. 9 of III, reg. 14 of IV, reg. 9 of V and reg. 10 of VI. The “reg. 9 of III” surprises anyone who opens Annex III in the text adopted by res. MEPC.193(61), where port State control on operational requirements is Regulation 8: res. MEPC.246(66), in force from 1 January 2016, inserted a new Regulation 1 “Definitions” into it and provided that “the subsequent regulations are renumbered accordingly”. Since 2016 that provision has been Regulation 9, and that is the number A.1206(34) carries. Then Article 21 of the Load Lines Convention 1966 as modified by the 1988 Protocol, Article X of STCW, Article 12 of TONNAGE 1969, Article 11 of AFS 2001 and Article 9 of BWM 2004. For the MLC, an ILO and not an IMO instrument, the basis is Regulation 5.2.1 with Standard A5.2.1.
The practical consequence is that challenging an inspection on the ground that your flag State is not party to the Memorandum leads nowhere: the inspector is not acting under the Memorandum, but under the control article of the Convention the flag State has ratified.
Scope of Application
Every deficiency found during a PSC inspection, from the mildest (to be rectified at the next port call) to the most serious (leading to immediate detention).
Procedure / How to Complete It
- Identify the correct requirement and technical condition.
- Agree timing and method with the authority.
- Rectify without altering evidence.
- Provide evidence as instructed and await formal closure/release decision.
Practical Example
A self-closing fire door in an A-class division does not close and latch completely — rectification required before departure. Evidence is submitted as instructed; photographs or reports do not themselves close the deficiency.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Deficiency rectified but not linked to the SMS's NC/CAPA system | The root cause is not analysed and the deficiency recurs at subsequent inspections | Treat every PSC deficiency as an input for the NC/CAPA system, not as an isolated event |
| Late communication to the Company of the need for resources to rectify | Rectification deadline missed, risk of detention | Inform the DPA/Company immediately as soon as the deficiency requires external resources |
| No photographic/written documentation of the rectification carried out | Difficulty proving closure in the event of a subsequent check | Always document the rectification with verifiable evidence |
What the PSCO Checks
Operational Tips
- Systematically link every PSC deficiency to the ship's SMS NC/CAPA register.
- Promptly communicate to the Company every deficiency requiring resources not available on board.
- Always document the rectification with verifiable photographic or written evidence.
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.
- Deficiency recorded with code, description and rectification deadline
- Corrective action initiated immediately if possible on board
- Deficiency linked to the SMS's NC/CAPA system
- Rectification documented with verifiable evidence
- Closure formally communicated according to the required procedure
FAQ
Related Topics
Last substantive revision of this page: 31 August 2026 · page fingerprint 83a814fc968f