PSC deficiency code 15150: ISM
Area 15 ISM Code
Code 15150 usually appears at the end of the Form B, after a set of deficiencies that together show the safety management system (SMS) isn't working on board. The text normally names the ISM element that failed and refers back to the other deficiencies.
What the inspector looks at
The inspector starts from what they found elsewhere and asks why the SMS didn't catch it.
- Planned maintenance: were the defective items in the system, and were jobs done or deferred properly
- Reporting of defects and non-conformities, and whether reports reached the office and got an answer
- Drills and training as recorded against what the crew can actually do
- Familiarisation of newly joined crew and knowledge of their emergency duties
- Master's review of the SMS and the last internal audit, with open findings
- Whether the DPA is known to the crew and how to contact them
Common findings
- ISM element 10: maintenance of the ship and equipment not effective, as shown by deficiencies listed
- Element 8: crew not familiar with emergency procedures, as evidenced during drill
- Element 9: defects not reported or recorded as non-conformities
- Element 6: newly joined crew not familiarised with their duties
- Element 7: shipboard operation procedures not followed
- Previous PSC deficiencies recurring, no corrective action evident
The rule behind it
The International Safety Management Code, made mandatory by SOLAS chapter IX. The elements most often cited are 6 (resources and personnel), 7 (shipboard operations), 8 (emergency preparedness), 9 (reports and analysis of non-conformities) and 10 (maintenance of the ship and equipment). The ship carries a Safety Management Certificate and a copy of the company's Document of Compliance.
Action codes you are likely to see
Inspectors commonly use 18 (rectify the non-conformity within three months) for an ISM deficiency that isn't a ground for detention. When the underlying deficiencies led to a detention, the ISM item may itself be marked 30, or 19 if it's treated as a major non-conformity to be rectified before departure, and an additional audit by the flag or RO is often required. See action taken codes and after a PSC detention.
How to close it
Close the underlying technical deficiencies first. Then raise a non-conformity in the SMS, do a root cause analysis that goes past "crew negligence", and set corrective and preventive actions with owners and dates. If an additional audit is required, arrange it with the flag or the RO and keep the audit report. The company's analysis, the corrective action record, any revised procedure and the audit report form the evidence. Keep them with the Form B.