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Operational guide · Operational procedure

Managing Deficiencies

Each deficiency is technically described, rectified and evidenced under authority instructions; formal closure and any release remain port-State decisions.

PSCdeficiencydetentionrectification

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.

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

  1. Identify the correct requirement and technical condition.
  2. Agree timing and method with the authority.
  3. Rectify without altering evidence.
  4. 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

Fire safety is among the recurring areas highlighted in the Paris MoU 2025 report. Statistical frequency and the severity of an individual finding are distinct: assess actual risk and assigned instructions.

Common Mistakes Mistake Library

MistakeConsequenceHow to avoid it
Deficiency rectified but not linked to the SMS's NC/CAPA systemThe root cause is not analysed and the deficiency recurs at subsequent inspectionsTreat 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 rectifyRectification deadline missed, risk of detentionInform the DPA/Company immediately as soon as the deficiency requires external resources
No photographic/written documentation of the rectification carried outDifficulty proving closure in the event of a subsequent checkAlways document the rectification with verifiable evidence

What the PSCO Checks

The PSCO assesses compliance, severity and rectification under the procedure. A quick response does not automatically erase a finding or detention; the need for a further visit depends on assigned action and the authority’s decision.

Operational Tips

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.

FAQ

Does a photograph formally close a deficiency?
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.
Must a fire door be weathertight?
Describe the deficiency against fire integrity, self-closing, latching and applicable SOLAS II-2 requirements, not generic weathertightness.

Related Topics

Last substantive revision of this page: 15 September 2026 · page fingerprint 585a5671808e