PSC deficiency code 04109: Fire drills

Area 04 Emergency systems

This code is used when fire drills are missing, poorly recorded or when the crew fails a drill the inspector asks for. PSC officers can witness a drill as an operational check, and they often do when the records or the crew's answers raise doubts.

What the inspector looks at

The inspector usually reads the drill records first, then may call a drill with a scenario such as a fire in the galley or engine room.

  • Are drills held at the required frequency, with every crew member taking part, and recorded with date, scenario and participants?
  • Does the alarm get raised correctly and does everyone go to the stations on the muster list?
  • Does the fire party dress in fire-fighter's outfits and breathing apparatus correctly and quickly, with checks of the BA set?
  • Are fire pumps started and hoses charged, with water at the nozzle?
  • Do the team leader and the bridge communicate by radio, and is the situation reported?
  • Are boundary cooling, closing of doors, dampers and ventilation stop part of the drill?

Common findings

  • Crew not familiar with their duties during fire drill
  • Fire drill not satisfactorily performed
  • Fire party unable to don breathing apparatus correctly
  • No water at the nozzle within reasonable time
  • Fire drills not carried out as required / not recorded
  • Muster list not updated after crew change

The rule behind it

SOLAS Chapter III, Regulation 19 sets the frequency of drills, including that each crew member takes part in at least one fire drill every month, and requires drills to be recorded. SOLAS Chapter II-2, Regulation 15 deals with fire safety training and drills. The muster list and emergency instructions come from SOLAS Chapter III. The ISM Code requires the company to set out drill programmes and maintain the crew's emergency preparedness.

Action codes you are likely to see

Missing records with evidence the drill was done may be marked 10 or 16. A poorly performed drill is usually 17: the ship is told to hold another drill to the inspector's satisfaction before sailing. When the crew clearly can't carry out basic fire duties, the inspector can treat it as a ground for detention (30), and an ISM deficiency may be added if the failure points to the safety management system. See action taken codes.

How to close it

Hold a fresh drill, ideally on a realistic scenario, with the fire party fully dressed and water on the fire. Record it with the date, time, scenario, participants and lessons learned, and if the inspector requires, repeat it in their presence. Update the muster list if it was wrong, and carry out recorded training in breathing apparatus and fire-fighter's outfits where crew struggled. Keep the drill record, training record and any company follow-up with the Form B. If a detention followed, see after a PSC detention. Abandon ship drills are covered under 04110.

Questions

Can a failed fire drill lead to a detention?

Yes. If the crew can't show basic competence in fire fighting, the inspector can detain the ship until a satisfactory drill is held, usually in their presence.

How often must fire drills be held on a cargo ship?

Each crew member has to take part in at least one fire drill every month. Additional drills are required after a large crew change, so check the company procedures and SOLAS Chapter III for the exact trigger.

What should a fire drill record contain?

Date and time, scenario and location, who took part, equipment used, and what was learned or needs fixing. Inspectors compare the names with the crew list.

Sources

Written by the SuperRonin team from the sources above. Last updated 27 Oct 2026. This page explains the rules; the regulation, the PSC officer and your flag and class have the final word. If something here doesn't match what you see on board, write to [email protected] and we'll correct it.

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Other codes in Emergency systems

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