The labyrinth of legislation makes it difficult for a ship to be in complete compliance at
all times. Assistance in maintaining compliance can be shown by the status of the relevant
certificates and documents. To ensure compliance, a maintenance system is required on
board the ship. How this maintenance system is constructed and what methods are used
are totally at the discretion of the company. Many companies have or are about to change
to an electronic system and either have one custom-made or take a ready-made one.
The main point is that no matter what system is used, the identification of all the
structure of the ship, its components and systems needs to be fully assessed. If this initial
assessment is flawed the system put in place will be flawed.
The PSCO will raise deficiencies against the ship, its systems and its personnel. In
addition, deficiencies can be raised against failure to meet the requirements of the ISM
Code. Therefore, it is important that the hardware, software and personnel are totally
integrated. This will result in a uniform working practice, whereby the structure of work
practices removes duplication of work and reduces the administration to accomplish it.
Every PSC deficiency will have to be dealt with and should be identified in the
maintenance system. The problem that is raised is how to resolve a deficiency raised against
the ISM Code. Any PSC deficiency is raised against the SMS, which will have the maintenance
system as part of its structure. But how do you resolve a deficiency against a system that is
not inspected but audited and has non-conformities raised against it, not deficiencies?
Procedures for Port State Control, Appendix 8 (Guidelines for port state control related
to the ISM Code) gives guidance to the PSCO, when dealing with ISM Code matters. The
company and ship’s staff should be aware of this section and its application when dealing
with such matters at an inspection and when deficiencies are raised.
On each page the category ‘other’ appears. It is where a deficiency cannot be exactly
categorised under a specific heading. The majority of deficiencies found are not unusual
but fundamental problems that have to be addressed. It would appear that many of the
deficiencies raised show a failure to meet basic standards of good seamanship.