Answer
1. Can PSC give an ISM Deficiency?Yes, PSC Officers (PSCOs) can and frequently do issue ISM deficiencies.
A PSCO does not issue an ISM deficiency out of nowhere; it is derived from objective evidence gathered from individual or cumulative technical/operational deficiencies found during the inspection.
How PSC Assigns ISM Deficiencies (Action Codes):
| Deficiency Scenario | PSCO Action | Action Code |
| Minor / Isolated Technical Deficiency: (e.g., single burnt-out navigation light bulb). | Recorded as a standard technical deficiency. No ISM deficiency issued. | Standard Action Code (e.g., Code 17) |
| Non-Detainable ISM Failure: Technical/operational deficiencies that do not warrant detention individually, but show a clear lack of SMS effectiveness (e.g., multiple overdue maintenance tasks in PMS, dirty bilges, lack of familiarity with emergency drills). | Non-Detainable ISM Deficiency Issued. The company must take corrective action and/or conduct an internal ISM audit within 3 months. | Action Code 18 (Corrective action within 3 months) |
| Serious ISM Failure / Detention: A major technical failure (e.g., emergency fire pump completely non-operational) OR a accumulation of multiple deficiencies indicating a systemic breakdown of the Safety Management System (SMS). | Detainable ISM Deficiency Issued. The vessel is detained. The Flag State Administration or Recognized Organization (RO / Class) must conduct an external additional Safety Management Audit before the ship can be released. | Action Code 19 (Safety Management Audit required prior to departure) |
2. Can PSC do an ISM Audit?Note: Even if 5 different equipment failures point to a single root cause, the PSCO will list those technical defects individually and then link them together under one single overarching ISM deficiency entry (Code 15150) on the PSC report.
No, Port State Control Officers CANNOT perform an Safety Management (ISM) Audit.
Under IMO Resolution A.1155(32) Appendix 8 (Guidelines for Port State Control Officers on the ISM Code), it is explicitly stated:
"Port State control officers (PSCOs) do not perform safety management audits. ISM auditing is the responsibility of the flag State and the company and does not fall under the scope of port State control."