Operational Guide · Registers & Logbooks

# 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.

ISM Code Non-Conformity SMS audit

## 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

1. Record the NC as soon as it is observed: what happened, where, when, and which SMS/ISM Code requirement was not met.
2. Classify it as minor or major, according to the Company's internal procedure criteria.
3. Conduct a root cause analysis, not stopping at the immediate symptom.
4. Define a CAPA (corrective and, where relevant, preventive action) with an owner and a deadline.
5. Verify the effectiveness of the action after a suitable interval, before formally closing the NC.
6. 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

Several PSC detentions with an "ISM related deficiency" cause arise not from the single non-conformity itself, but from the absence of a documented, coherent NC/CAPA system: inspectors, finding no evidence of a functioning continuous improvement cycle, extend their doubt to the whole SMS.

## 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

PSCOs and certification auditors verify that the NC register is up to date, that major NCs have generated a CAPA with documented effectiveness verification, and that the Management Review has actually analysed non-conformity trends.

## 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

## FAQ

What is the difference between a minor NC and a major NC?
A minor NC is an isolated observation of non-compliance with a requirement, with no evidence of systemic breakdown. A major NC indicates a serious or systemic deficiency that poses a risk to the safety of people, the ship or the environment, and can lead to the certificate not being issued or being suspended.
Who can raise a Non-Conformity?
Anyone within the management system: internal/external auditors, the Master, officers, crew, the DPA. What matters is that it is formally recorded in the Company's NC system.
Does a major NC stop the ship from sailing?
A major NC does not automatically amount to a ship detention, but it can lead to suspension of the Safety Management Certificate if not addressed; in a PSC context, a related deficiency can contribute to a detention.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

Corrective and Preventive Action (CAPA)Internal SMS Audit Management Review

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