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 NC (§1.1.9) and major NC (§1.1.10), not a separate definition of ‘minor NC’. As amended by MSC.273(85), a major includes an identifiable deviation posing a serious threat to personnel/ship or serious environmental risk requiring immediate corrective action, or lack of effective and systematic implementation of a Code requirement. Both conditions need not coexist. Severity assessment and enforcement decisions remain distinct.
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.
Definitions and amended text: MSC.104(73) · MSC.273(85) · IMO ISM.
Section 9.2 requires procedures for implementing corrective action, including measures to prevent recurrence. “CAPA” here describes the Company’s process: the Code does not prescribe this acronym or one particular form or analysis method.
Scope of Application
NCs may arise from audits, crew reports, incidents, Near Misses and inspection findings. A single event can also demonstrate non-fulfilment of a requirement.
PSC records deficiencies and action codes; it does not conduct an ISM certification audit. Its evidence can nevertheless trigger an internal NC and SMS analysis immediately, without waiting for an RO audit. PSC rectification and work on the cause proceed in parallel: opening an NC does not replace the required action.
Procedure / How to Complete It
- Control the hazard immediately: stop or restrict the activity where necessary and adopt safe measures with applicable approvals.
- Record facts, requirement and objective evidence; assess severity and required notifications.
- Analyse causes and contributing factors; missing records alone do not establish the cause.
- Define actions, owner, deadlines and verification criteria; implement them and retain evidence.
- Verify effectiveness using proportionate evidence and timing. If insufficient, keep the NC open and revise the action.
- Record justified closure and review recurrences; comply with agreed conditions and deadlines for external NCs.
Diagram: from Non-Conformity to CAPA closure
Practical Example
Learning example: three winch checks are not recorded. First establish whether maintenance was missed and whether the equipment is safe to use; a missing signature alone proves neither a fault nor that the check took place. The investigation documents causes and measures, including technical rectification where needed. Verification covers actual maintenance and records, not just three completed boxes.
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.
- Hazard assessed and immediate measures taken where necessary
- Requirement and objective evidence recorded
- NC/major assessed against the current definition
- Causes, owner, deadlines and actions documented
- Implementation demonstrated before effectiveness verification
- Closure only with adequate results and external conditions met
FAQ
Related Topics
Last substantive revision of this page: 15 September 2026 · page fingerprint 38eab73c4d67