PR17??

Answer

In the context of management-level maritime administration and Classification Society audits, PR 17 stands for Procedural Requirement No. 17, established by the International Association of Classification Societies (IACS).

Its official title is: "Reporting on deficiencies possibly affecting the implementation of the ISM Code on board."

1. What is the Purpose of IACS PR 17?

Normally, class surveyors perform technical inspections (e.g., Annual Machinery Surveys, Statutory Pollutions Surveys) while separate ISM auditors verify the Safety Management Certificate (SMC).

However, under PR 17, if a Class Surveyor (who is not currently conducting an ISM audit) notices defects that suggest the ship’s crew is failing to implement their SMS properly, they are legally mandated to file a formal PR 17 Report. This report is sent directly to the Classification Society or Flag State department responsible for the vessel's ISM certification to trigger further administrative or physical action (such as an occasional additional ISM audit).

2. What Triggers a PR 17 Report?

A surveyor will not issue a PR 17 for normal wear and tear or a single isolated defect that the crew is already actively repairing. It is triggered by systemic breakdowns categorized into four distinct areas:

A. Technical Deficiencies

• The Trigger: A combination of material defects indicating that the SMS mandatory Planned Maintenance System (PMS) has broken down completely.

• Engine Room Examples:

  1. Severe oil and fuel leaks left completely unattended across multiple engine room decks.

  2. Finding that the quick-closing valves have been intentionally blocked open or bypassed.

  3. Crucial safety devices—like the low-lube oil trips on all auxiliary engines or the 15-ppm bilge monitor—are defective simultaneously.

B. Operational Deficiencies

• The Trigger: Evidence that the crew is incapable of safely executing basic shipboard tasks or mandatory emergency response protocols.

• Engine Room Examples:

  1. During a live drill, the crew fails to successfully start the emergency generator or the emergency fire pump.

  2. Engine ratings and junior officers are unable to effectively communicate or execute critical safety tasks during an enclosed space entry or bunkering scenario.

C. Documentation Deficiencies

• The Trigger: Critical gaps or intentional falsification of mandatory records.

• Engine Room Examples:

  1. The Oil Record Book (ORB Part I) contains missing entries, severe arithmetic discrepancies, or shows signs of manipulation.

  2. The Fire Control Plan posted in the alleyways is completely obsolete and does not accurately reflect the current layout of fire extinguishers or fire dampers.

D. Other Deficiencies

• The Trigger: Situations that compromise overall shipboard safety.

• Example: The engine room manning levels fall short of what is specified on the vessel's Minimum Safe Manning Certificate.

3. When is a PR 17 Report Not Issued?

The surveyor will explicitly omit a PR 17 report under the following conditions:

• The defect is minor and considered typical wear and tear given the vessel's age and trading profile.

• The crew has already identified and logged the defect: If the Second Engineer has already raised a formal non-conformity within the company’s SMS framework, ordered the parts, implemented risk mitigating measures, and notified the office, it shows the system is working. Therefore, no PR 17 is issued.

4. How to Explain PR 17 in an MMD Oral Exam

If an Indian MMD surveyor asks you: "Chief, what is IACS PR 17 and how does it affect your engine room management?"

Your structured verbal response should be:

"Sir, IACS PR 17 is a mandatory procedural requirement that dictates how class surveyors report shipboard deficiencies that point toward a breakdown in the implementation of the ISM Code.

As a Class 1 Engineer, I am aware that if a class surveyor notes multiple critical technical failures—such as an inoperable emergency fire pump during an annual survey, or severe, unaddressed oil accumulation in the bilges—they will conclude that our Planned Maintenance System is failing. Under PR 17, they will file an official report to the organization that issued our Safety Management Certificate, which could lead to an additional, unscheduled ISM audit or the suspension of our certificates.

To prevent a PR 17 trigger, my management strategy is to ensure that any machinery defect or operational breakdown is immediately identified, safely mitigated, and officially logged as an SMS non-conformity before the surveyor or Port State Control boards the vessel. This demonstrates that our Safety Management System is actively working and self-correcting."