What is a Non-Conformity (NC) in ship management?

A Non-Conformity (NC) in ship management is a documented deviation from an established procedure, standard, requirement, or expectation — whether defined in the company's Safety Management System, a classification society rule, a flag state regulation, or a charterer's operating requirements. Non-conformities are identified through multiple channels: internal ISM audits, external audits by flag states or classification societies, Port State Control inspections, vetting inspections by charterers or oil majors, and self-reporting by vessel crew when procedures are found to be inappropriate or impossible to follow as written.

The concept of a non-conformity is closely aligned with the ISM Code's broader approach to safety management: that the goal of a management system is not merely to document compliant procedures but to ensure that operations actually conform to those procedures — and that when they do not, the reasons are investigated and corrective actions are implemented. An NC is therefore not a failure of the management system; it is the management system working as intended — surfacing gaps between documented requirements and operational reality so they can be addressed.

Non-conformities vary significantly in severity. A minor NC may be a documentation gap — a required record not completed to the specified format — which carries low immediate safety risk but indicates a process that needs tightening. A major NC is a significant or systematic failure to fulfil a requirement of the SMS — for example, a maintenance programme not being followed, emergency equipment not in serviceable condition, or crew repeatedly unable to demonstrate knowledge of emergency duties. Major NCs require immediate corrective action and may result in conditions on class certificates, SMC suspension, or PSC detention if left unaddressed.

Internal ISM audits are the primary mechanism for identifying NCs within a shipping company's management system. Under the ISM Code, companies are required to conduct internal audits at least annually, carried out by persons independent of the area being audited. These audits review whether SMS procedures are documented to the required standard, whether they are actually implemented on board, and whether records demonstrate they are consistently followed. Findings that reveal deviations from SMS requirements are documented as NCs — minor or major — depending on their significance.

External audits conducted by flag state administrations or classification societies acting as Recognised Organisations also identify NCs during DOC renewal and SMC verification audits. These are formal regulatory reviews, and NCs identified in this context must be resolved within defined timeframes or the company risks suspension of its DOC — and vessels risk suspension of their SMCs. The distinction between internal and external audit NCs is important: internal NCs are discovered and managed by the company; external audit NCs are discovered by the regulator and are subject to formal follow-up timelines.

PSC inspections frequently generate deficiencies that correspond to NCs in the vessel's SMS — a failure to maintain required records, equipment not in required condition, crew not familiar with emergency procedures. PSC deficiency codes map directly onto the ISM Code requirements that were not met. A vessel that accumulates PSC deficiencies is providing external evidence that its SMS is not working in practice. Companies with effective NC management consistently perform better in PSC inspections.

Effective NC management follows a defined cycle: identification and documentation, investigation and root cause analysis, corrective action definition and assignment, implementation, verification of effectiveness, and closure. Each stage requires specific actions and documentation — and the quality of each stage determines whether the NC leads to genuine improvement or merely generates paperwork. The ISM Code's requirement that NCs be evaluated for effectiveness means that closing a corrective action is not sufficient; the company must verify that the corrective action has actually addressed the root cause and prevented recurrence.

Root cause analysis is the most critical and most frequently shortcut stage of NC management. An NC that is closed with an immediate cause description — "crew forgot to complete the checklist" — and a corrective action limited to "crew reminded to use the checklist" has not addressed the root cause and will recur. A properly conducted root cause analysis asks why the crew forgot, what factors made the checklist easy to skip, whether the procedure is well-designed, whether workload makes checklist completion practical, and whether there is a training or supervision gap. The corrective actions that emerge from this analysis are more substantive — and more effective in preventing recurrence.

The distinction between corrective actions and preventive actions is also important. A corrective action addresses the specific NC identified — fixing the immediate problem. A preventive action addresses the systemic factors that could cause the same type of NC to occur elsewhere — on the same vessel in different circumstances or on other vessels in the fleet. For significant NCs, both types of action are required. Near-miss reports and NCs that share the same root causes should generate fleet-wide preventive actions, not just vessel-level corrective ones.

The relationship between NC management and PSC performance is one of the most direct cause-and-effect relationships in maritime compliance management. PSC officers assessing a vessel's SMS implementation specifically look for evidence that NCs are being identified, investigated, and closed — not just that procedures are documented. They will ask crew whether they report non-conformities, review the NC register to assess reporting volume, examine whether corrective actions are completed on time, and check whether lessons from previous NCs have been shared across the fleet.

A vessel with an active NC reporting culture — where crew regularly identify and report deviations from procedures — demonstrates to PSC officers and auditors that the SMS is genuinely operational. By contrast, a vessel with almost no NC records is almost certainly under-reporting: any fleet operating at scale will have regular deviations from procedures. The absence of NCs in an active operation suggests either that crew are not identifying deviations or not reporting them — both of which are themselves ISM non-conformities.

ISM auditors pay particular attention to the quality of NC management documentation. They look for: NCs categorised by type and severity; root cause analysis going beyond immediate cause description; corrective actions that are specific, assigned, and time-bound; evidence that corrective actions were implemented and verified; and communication of lessons to other vessels where appropriate. A company that meets all of these standards not only achieves good audit outcomes — it builds the management system capability that prevents incidents, reduces PSC deficiencies, and lowers the cost of compliance management over time.

Infoship's QHSE module provides a complete NC management workflow, from initial reporting through investigation, corrective action assignment, and verified closure. Crew members can raise NCs directly from the vessel — with the SMS procedure reference, a description of the deviation, and an initial severity assessment — triggering automatic notification to the shore-side quality team. This removes the delay and communication friction that causes NCs to be under-reported in companies relying on email-based reporting.

The investigation workflow supports structured root cause analysis, with corrective and preventive actions assigned to specific individuals with defined deadlines and tracked through to closure. Verification of corrective action effectiveness is built into the close-out process — the system requires confirmation that the action has been implemented and is working before the NC can be marked as closed. Fleet-wide lessons can be flagged and distributed through the platform, ensuring that significant findings are communicated to all vessels. KPI reporting aggregates NC data across the fleet — open NC volume, average close-out time, NC rate by vessel, and NC type distribution — giving quality managers the fleet-level visibility needed to identify systemic issues and prioritise intervention before they become PSC deficiencies or ISM audit findings.