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.
Read the report’s deficiency code and description, action taken and assigned deadline separately. For each item identify responsibility, intervention, required evidence and status: rectification completed on board, evidence available, and any verification or release still required. An internal “closed” entry does not replace a decision required from the authority.
Connect the finding with follow-up under the SMS: assess cause, significance, recurrence and the need for action to prevent repetition under Company procedure. A technical deficiency is not automatically an ISM deficiency in the PSC report; that link requires evidence of failed or ineffective system implementation. Clearly communicate rectification status and required evidence to the PSCO.
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, may warrant 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.
Control does not depend on flag membership of the MoU or solely on flag ratification: also consider no-more-favourable treatment for ships of non-Parties. IMO A.1206(34), §§1.2–1.5.
Distinguish the deficiency code from action taken. Paris MoU code 17 requires rectification before departure and, without detention, normally does not require a new PSCO check: responsibility rests with the master. Detention requires authority verification and release. Always follow the report’s instructions. Paris MoU: Inspection Outcome.
Scope of Application
Every PSC deficiency, with action and deadline specified in the report. There is no general rule that a minor deficiency is corrected at the next port: follow the assigned action taken.
Procedure / How to Complete It
- Identify the correct requirement and technical condition.
- Agree timing and method with the authority.
- Rectify without altering evidence.
- Provide required evidence and check whether further verification is needed; in detention await formal release by the authority.
Practical Example
Example: a fire door has defective self-closing. If the report assigns code 17 without detention, the master ensures rectification before departure under the instructions; if detainable, authority verification is required before release. Photos and reports support verification but do not replace a required decision.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Rectifying the defect without assessing follow-up under the SMS | Causes or systemic problems may remain unexamined and contribute to recurrence | Assess each finding under SMS procedure and link significant, systemic or recurring ones to NC/CAPA; do not automatically classify every shortcoming as ISM |
| Late communication to the Company of resources needed | Rectification may exceed the assigned deadline; follow-up depends on instructions and ship condition | Promptly inform the DPA/Company under the SMS, identify resources and deadline, and clarify difficulties with the authority before the deadline |
| Declaring rectification without verifiable evidence | It becomes difficult to demonstrate the intervention and result when a subsequent check is required | Retain relevant records, test results or photographs under the instructions; provide required evidence without substituting it for authority release |
What the PSCO Checks
Operational Tips
- Link significant, systemic or recurring PSC deficiencies to the ship's SMS NC/CAPA register under company procedure.
- Promptly communicate to the Company every deficiency requiring resources not available on board.
- Document rectification with the evidence required by the authority and applicable procedure.
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
- SMS follow-up assessed; NC/CAPA linkage under Company procedure
- Rectification documented with verifiable evidence
- Closure formally communicated according to the required procedure
FAQ
Related Topics
Certified substantive revision: 14 October 2026 · page fingerprint b42003c94e20