Answer
A Major Non-Conformity (MNC) under the ISM Code indicates a serious threat to safety or the environment, or a severe breakdown in implementing the Safety Management System (SMS). Bunkering without a controlled checklist violates ISM Element 7 (Development of Plans for Shipboard Operations) and MARPOL Annex I.
- Step 1: Immediate Operation Hold: Suspend any ongoing or scheduled bunkering operations immediately. Do not commence bunkering under any circumstances without the official controlled checklist.
- Step 2: Immediate Notification: Inform the Master and contact the Designated Person Ashore (DPA) right away. An MNC prevents the issuance/validity of the Safety Management Certificate (SMC) and can cause port detention.
- Step 3: Conduct Root Cause Analysis (RCA): Determine why the controlled document was missing (e.g., unapproved revision used, misplacement, digital sync failure from office, or document control oversight).
- Step 4: Execute Corrective & Preventive Action (CAPA):
- Immediate Corrective Action: Obtain the valid, controlled Bunker Checklist directly from the company’s digital SMS portal or office DPA. Verify revision numbers against the SMS master document list, print, and place it at the bunker station.
- Preventive Action: Conduct an audit of all engine room operational checklists under ISM Element 11 (Documentation), ensure physical binders are updated, and train engine personnel on document control.
- Step 5: Downgrade Request: Submit the RCA and completed CAPA evidence to the DPA and the RO (Recognized Organization / Class) auditor. Request a re-inspection or document verification to downgrade the MNC to a standard Non-Conformity (NC) prior to sailing.
- Step 6: Official Logging: Document the MNC, CAPA, DPA communications, and resolution details in the Engine Room Logbook and shipboard SMS safety meeting records.
If last or any other old bunker checklist is missing
If an auditor issues a Major Non-Conformity (MNC) because a completed historical bunker checklist (from a previous or recent bunkering operation) is missing, it is treated as a critical breakdown in Document Control (ISM Code Element 11) and record retention. The Chief Engineer must take immediate action to establish secondary evidence, contact management, and execute a formal corrective action plan to downgrade the MNC before the vessel sails.
Step 1: Immediate Traceability & Archive Search
- Check Digital Archives: Search the Chief Engineer's email sent folders, scanned PDF archives, company cloud portals, or shared drive backups for a scanned copy of the completed checklist that was submitted to the office after the operation.
- Gather Secondary Objective Evidence: Compile all supporting statutory and operational records for that specific bunkering date:
- Corresponding Bunker Delivery Note (BDN) and MARPOL Representative Fuel Sample Receipt.
- Oil Record Book (ORB) Part I entries for fuel receipt (Code I).
- Engine Room Logbook and Deck Logbook entries detailing the pre-bunker meeting, pump start/stop times, line pressure checks, and sounding logs.
- Signed Risk Assessment (RA) and Toolbox Talk (TBT) sheets for that bunkering event.
Step 2: Immediate Escalation to Master and DPA
- Inform the Master immediately and contact the Designated Person Ashore (DPA) to report the MNC.
- An outstanding, un-downgraded MNC invalidates the vessel's Safety Management Certificate (SMC) and will lead to Port State Control (PSC) detention if not resolved prior to departure.
Step 3: Conduct Root Cause Analysis (RCA) Determine why the historical document went missing:
- Physical filing breakdown: Misplaced during binder updates or missing from the historical bunker file.
- Personnel changeover gap: Lost or un-handed-over during a previous Chief Engineer relief/handover.
- Digital failure: Failure in digital filing software or unsynchronized ship-to-shore database backup.
Step 4: Execute Corrective Action (CA)
- If Scanned Copy Found: Retrieve the digital copy from office files or email history, print it, verify its signatures, and file it in the official binder.
- If Permanently Lost: Compile the secondary evidence package (BDN, ORB Part I, Logbooks, TBT). Draft a formal Statement of Facts (SoF) signed by the Chief Engineer and Master explaining the loss of the physical checklist while providing verified secondary proof that the bunkering operation was executed safely and in accordance with MARPOL Annex I and SMS requirements.
Step 5: Execute Preventive Action (PA)
- Dual-Filing Procedure: Implement a strict SMS procedure requiring every completed bunker checklist to be physically filed in the hard-copy binder and scanned/uploaded to the company server within 24 hours of operation.
- Handover Verification: Add a mandatory line item to the Chief Engineer's Handover Checklist requiring physical verification of all historical statutory checklists (Bunker, Hot Work, Enclosed Space, OWS) for the preceding 12 months.
Step 6: MNC Downgrade and Re-Audit Request
- Submit the RCA, secondary evidence package/SoF, and CAPA plan to the DPA and the Recognized Organization (RO) / Auditor.
- Request the auditor to review the objective evidence and downgrade the MNC to a standard Non-Conformity (NC) with an agreed timeline for closure, allowing the vessel to obtain audit clearance and sail safely.
Step 7: Official Logging
- Record the MNC details, root cause findings, CAPA implementation, and auditor response in the Engine Room Logbook and shipboard Safety Management Meeting records.