Understanding PSC severity

Low Severity

Definition: Deficiencies or Findings that are minor issues or administrative matters. They pose minimal or no danger to the ship or persons on board nor present an unreasonable threat of harm to the marine environment.

These can include minor non-compliance of a ship’s equipment or arrangements which can be easily rectified or of which rectification is not considered urgent (or where redundancy, exemptions or other approved alternative arrangements are in place to enable the ship’s safe operation pending rectification), non-compliance of a ship’s non-critical equipment or arrangements, administrative errors in ship’s or seafarers’ certification or records, minor breaches of MLC which are not considered to affect health or welfare of seafarers, and minor failures of the ship’s safety management system which are easily rectified.

Urgency: Rectification is generally not urgent. Some deficiencies/findings of a more important nature may still be considered low severity if they are easily and urgently rectified; e.g. incomplete logbook entries, blown navigation light bulbs, etc.

Impact: These deficiencies/findings have minimal impact on safety, performance, or crew welfare, but were still considered by the PSCO/inspector as warranting rectification through a deficiency/finding to maintain vessel standards and compliance.

Examples:

Fire Safety: Minor defects such as small leaks in hoses/hydrants/pumps, where the efficacy of the system overall is not affected. Slightly overdue inspections of equipment where there is no stated evidence of failure.
Excluding: Significant leaks or blockages in hoses/hydrants/pumps/fire lines which may affect delivery pressure. Inoperative fire doors due to defects or from being held open by unapproved arrangements or fire doors that are damaged/holed.

Life Saving Appliances: Minor defects such as defective retroreflective tape, or defects where rectification is simple (eg. lifebuoy and lifeboat re-marking, signage, IMO symbols).
Excluding: Incorrectly rigged hydrostatic release units on liferafts.

Pollution Prevention: Incorrect segregation of non-food waste garbage into food category bins. Missing garbage placarding and procedures in garbage storage and disposal areas. Minor errors in MARPOL record book entries with no pollution risk implications (eg. missing ship positions). Defective 3-way valve from operational sewage treatment plant. Incinerator not operational / out of service. EPL and EGCS records. Storage of food waste (garbage) in cold/freezer rooms.

MLC / Crew Welfare: Minor, administrative, or one-off breaches related to seafarer welfare and employment conditions, and recording of work/rest hours. Small number of defective emergency lights (ie. less than 4). Cleanliness issues in living quarters which do not affect health or safety of seafarers. Isolated cases of inadequately secured items in critical or non-critical areas. Enclosed space entry processes for spaces intended for immediate entry in an emergency (eg. lifeboats, emergency generator room, CO2 room). Anti-slip arrangements not in place/ineffective. Slip hazards. Expired/missing items in first aid kits (not medical locker). Ineffective weekly MLC inspections and missing records of same.
Excluding: Enclosed space entry processes and failures (other than for spaces intended for immediate entry in an emergency). Unsanitary conditions. Defective emergency lights around survival craft embarkation/operation area.

Seafarer certification: Missing/expired short-course certificates (which are required for issue of the certificates of competency/proficiency, which in turn are endorsed accordingly). Missing/expired medical fitness certificates.

Bridge equipment and procedures: Blown navigation light bulbs, as indicated by a functioning navigation light/alarm panel. Defective ‘Christmas tree’ signal lights. Defective equipment that is in use but over and above requirements. Missing signatures from log books. Inappropriate ECDIS setup for intended voyages not yet planned (eg. use of outdated ENCs). Blown bulb for magnetic compass. Defective daylight signalling (Aldis) lamp.
Excluding: Missing signatures from standing orders.

Engine Room Issues: Jacket cooling water leaks.

Mooring and Anchoring Equipment: Small number of broken/damaged studs on anchor cable (ie. less than 4). SWL markings on mooring equipment. Hydraulic oil leaks of a size described as small/minor or not defined.

Steering Gear: Hydraulic oil leaks of a size described as small/minor or not defined. Hydraulic oil storage tank low level.

Load Line: Minor defects to ship’s side rails. Load line and/or draft marks not fully legible. Active load line does not match active certificate (where multiple load lines and certificates are available). Multiple load line certificates available in active certificate folder.

Means of Access: Gangway/Accommodation ladder safety nets incorrectly rigged. Gangway/accommodation ladder markings (eg. SWL, angle limits). Gangway/accommodation ladder suspended or brow in use. Accommodation ladder bottom platform not horizontal. Light and/or buoyant lifeline missing from the lifebuoy placed in the vicinity (specific means of access deficiency).

Pilot boarding arrangements: Pilot ladder markings.

Ship Security: Minor access issues during Security Level 1 or security level not specified (eg. visitor card not issued, visitors’ log errors/omissions).
Excluding: Uncontrolled access to the ship available (eg. unattended gangways and pilot ladders, failure to verify ID).

Hull issues: Fouling.

Ballast Water Management: Minor defect to Ballast Water Treatment System (BWTS) / Ballast Water Management System (BWMS) or ancilliary equipment, not rendering it defective/inoperable overall.

Medium Severity

Definition: Deficiencies or Findings that fall between High Severity and Low Severity – they do not pose an immediate danger to the ship or persons on board nor present an unreasonable threat of harm to the marine environment if it were allowed to proceed to sea unrectified, and nor are they considered minor issues or administrative matters.

These can include absence or less serious non-compliance of equipment or arrangements, less serious breaches of MLC, and failures of the ship’s safety management system as implemented which are not considered to require immediate auditing and correction.

Urgency: Should be addressed promptly to avoid further potential risks occurring.

Impact: While not necessarily immediately dangerous or threatening, these deficiencies/findings can compromise the ship’s operational safety and/or compliance over time.

Examples:

Structural Integrity: Shell plating indents (without accompanying bent/tripped frames/longitudinals).

Fire Safety: Defects where redundancy is available, such that the efficacy of the system overall is not significantly affected (e.g. one defective unit among multiple flame/smoke detector heads in a single space). Inoperative fire doors or pump room doors due to defects or from being held open by unapproved arrangements. Leaks or blockages in hoses/hydrants/pumps/fire lines, to such a degree that the efficacy of the system overall is affected but still likely to be compliant. Fire safety equipment not easily accessible. Fire safety equipment not in position. Fire safety equipment not ready for immediate use. Engine room fan dampers slightly open or not closing fully. Funnel flaps slightly open or not closing fully. Missing cargo line bonding straps. Hydraulic oil tank gauge glasses gagged/held open. Defective oil mist detector in auxiliary engine/generator. Illegible or missing instructions for equipment/system usage. Self-contained breathing apparatus (SCBA) bottle/s low pressure. Fire training manual. Non-compliant bulkhead/deck penetrations. Missing insulation/lagging of bulkheads, deckheads and similar surfaces (not hot, <220oC).
Excluding: Fire doors damaged/holed. Missing or oil-soaked insulation/lagging of hot surfaces in engine room.

Life Saving Appliances: Incorrectly rigged hydrostatic release units on liferafts. Defective lighting around survival craft embarkation/operation area. Lifesaving equipment not easily accessible. Lifesaving equipment not in position. Lifesaving equipment not ready for immediate use (e.g. lifebuoy light battery requires replacement, lifebuoy lifeline not of the non-kinking type, embarkation ladders in position but shackles seized or not connected). Illegible or missing instructions for equipment usage. SOLAS training manual. Muster lists.

Electrical Safety: Low insulation on 240V (and lower) systems. Missing/defective rubber insulation mats. Defective power sockets on 240V (and lower) systems.
Excluding: Defects with higher voltage systems.

Pollution Prevention: Missing bunker sample/receipt documentation. Bunker Delivery Note (BDN) missing/incomplete. Garbage storage unapproved but without risk of illegal discharge (eg. forecastle store). Incinerator in use with intermittent faults. Use of unapproved ballast tanks for storage of treated sewage. Defective inlet valve to oily water separator, without risk of illegal discharge.
Excluding: Storage of food waste (garbage) in cold/freezer rooms.

MLC / Crew Welfare: Minor, administrative, or one-off breaches related to seafarer wage payments, food / drinking water quality, enclosed space entry processes and expired SEAs. Work/rest hours records do not reflect actual hours worked. Unhygienic galley and food preparation areas. Safety and food storage deficiencies related to cold/freezer rooms. Enclosed spaces not labelled or missing from enclosed space list. Missing MSDS. Inadequate inspection arrangements for small lifting gear/loose gear. Expired medicines in medical locker, expired/missing eye wash from eye wash stations. Larger number of defective emergency lights (ie. 4 or more). Multiple inadequately secured heavy/hazardous items in critical or non-critical areas. Appropriate PPE not worn. Safety chains not properly fitted/adjusted. Missing or inadequate risk assessments.
Excluding: Minor, administrative, or one-off breaches related to recording of work/rest hours. Multiple unsecured heavy/hazardous items in critical areas. Missing enclosed space entry permits. PPE related to work permits not worn.

ISM: A failure of the safety management system as implemented. The PSCO will assign an appropriate Action Code to an ISM deficiency, depending on what is observed during the inspection, either a Code 18 or 21 (ISM audit/action required within 3 months) ISM deficiency. SOLAS and fire training manuals and emergency towing booklet and other contingency plans not ship-specific. Documents not in working language of vessel.
Excluding: Code 30 or Code 19 (ISM audit before departure) which are considered a High severity ISM deficiency.

Seafarer certification: Missing or expired flag State endorsements of certificates of competency (noting these only require proof of application to be compliant). Missing/expired short-course certificates (which are required for issue of the certificates of competency/proficiency, which in turn are endorsed accordingly).

Bridge equipment and procedures: Missing signatures from standing orders. Defective whistle where second whistle is operational. Defects associated with magnetic compass where gyro compass is operational. Inappropriate ECDIS setup (e.g. use of outdated nautical publications). Paper charts used as back-up arrangements not up to date. Position plotting frequency not as per voyage plan. GMDSS settings/setup not appropriate for voyage. Rudder angle indicator error 5 degrees or less, or not adjusted with error not specified. Bridge wing rudder angle indicator inoperative/malfunctioning or error more than 5 degrees. BNWAS key left in or password posted. Non-compliant placement of BNWAS reset button. Defective VDR. Overdue routine testing and servicing of GMDSS equipment and GMDSS batteries. Minor errors in calculation of under keel clearance (UKC). Unfamiliarity with minor items of bridge or GMDSS equipment.

Load Line: Defective securing or sealing arrangements on weathertight doors above freeboard deck and engine room skylight. Possible water ingress into chain locker or similar small capacity space. Defective self-closing arrangements on sounding pipes with additional caps. Defective sounding caps. One-off defective ballast tank air pipe closing devices/vents. One-off defective sealing arrangements for small hatches (e.g. booby hatches, rope hatches) and manholes. Multiple load lines visible on hull. Water ingress alarm system with active alarms showing. Defective dewatering system. Significant defects to ship’s side rails.

Machinery maintenance: Issues with engine performance/reliability or overdue maintenance.

Engine Room Issues: Boiler gauge glasses dirty. Accumulation of oil or oily rags around engines (with clear buildup. If no clear buildup then its low severity as its an housekeeping issue). Fuel/oil leaks (not spraying - leading to oil accumulation). Oil in hotwell/cascade tank. Missing or defective/unreadable pressure gauges. Defective engine room bilge alarms/sensors. Leaking safety valve on boiler. Deficiencies related to non-Class approved repairs made in engine room.
Excluding: All engine room bilge alarms/sensors defective.

Mooring and Anchoring Equipment: Safety pins not fitted in place on mooring winches, larger number of broken/damaged studs on anchor cable (ie. 4 or more). Small number of defective mooring lines or roller fairleads (ie. less than 4). Defective anchor swivel. Worn winch brake linings.

Ship Certification: Overdue statutory surveys.

Drills: Drills overdue (overdue period 1 month or less, or unknown). Lifeboat / rescue boat not manoeuvred in water in last 3 months (overdue period 1 month or less, or unknown). Freefall/simulated launching of freefall lifeboat overdue (overdue period 1 month or less, or unknown). Minor issues within drills that did not render the drill unsatisfactory overall in the opinion of the PSCO.

Steering Gear: Illegible or missing instructions for system usage. Single steering mode on single system not operational.

Cargo Handling Equipment: Ineffective/missing hook safety latches for stores crane or engine room crane or chain block. Missing maintenance records for loose gear. Loose gear not identified/labelled.

Means of Access: Gangway/accommodation ladder safety nets not rigged or damaged. Gangway firmly mounted on top of ship’s rail. Gangway/accommodation ladder side rails, ropes and stanchions. Missing lifebuoy and light/lifeline from the vicinity (specific means of access deficiency).

Pilot Boarding Arrangements: Pilot ladder not resting firmly against the ship’s side (and no flag State approved arrangements in place if ship’s construction precludes this). Heaving line not available for immediate use. Pilot ladder certificates.

Ship Security: Uncontrolled access to the ship available during Security Level 1 or security level not specified (e.g. unattended gangways and pilot ladders, failure to verify ID).

Ballast Water Management: Defective Ballast Water Treatment System (BWTS) / Ballast Water Management System (BWMS).

High Severity

Definition: Deficiencies or Findings that pose a clear danger to the ship or persons on board or present an unreasonable threat of harm to the marine environment if it were allowed to proceed to sea unrectified.

These can include absence or non-compliance of principal equipment or arrangements, substantial deterioration of the ship or its equipment, lack of crew proficiency especially with essential operational procedures, insufficient manning/certification, serious breaches of MLC, and serious failures of the ship’s safety management system as implemented.

Urgency: Must be addressed immediately or at least prior to departure.

Impact: These deficiencies/findings can lead to significant events such as death or serious injury, fire or serious failure to control/extinguish it, grounding, pollution breaches, structural failure, and ship detention or banning.

Examples:

Structural Integrity: Hull breaches. Severe corrosion. Cracking in key structural areas such as hatch corners. Bent/tripped frames/longitudinals.

Fire Safety: Non-functional fire protection, detection and extinction systems. Missing or oil-soaked insulation/lagging of hot surfaces in engine room. Fuel tank gauge glasses gagged/held open. Emergency escape arrangements not clear/accessible. Fire doors damaged/holed. Defective oil mist detector in main engine. Fixed pumproom gas detection system defects. Inert gas system not operational. Inert gas system defects rendering inert gas compliance in question. EEBD defective or low in pressure/empty. Self-contained breathing apparatus (SCBA) defective or with empty bottle/s. Defective emergency fire pump. Engine room fan dampers not operating or holed/wasted. Funnel flaps not operating (from outside the space). Defective turbo charger. Defective quick closing fuel valves. Unsatisfactory drill performance. Ineffective explosion-proof / intrinsically safe arrangements.
Excluding: Minor defects such as leaks or blockages in hoses/hydrants/pumps/fire lines. Defects where redundancy is available, such that the efficacy of the system overall is not significantly affected. Fire door self-closing arrangements. Hydraulic oil tank gauge glasses gagged/held open. Self-contained breathing apparatus (SCBA) bottle/s low pressure (not empty). Missing insulation/lagging of bulkheads, deckheads and similar surfaces (not hot, <220oC).

Life Saving Appliances: Non-operational lifeboat or rescue boat engines, steering or davits. Defective embarkation arrangements. Defective on-load release systems. Defective rescue boat davit accumulator. Davit limit switches. Exhaust leakage into lifeboat while engine running and defects with any lifeboat battery. Unsatisfactory drill performance.
Excluding: Minor defects such as defective retroreflective tape, or defects where rectification is simple (eg. lifebuoy light battery replacement, lifebuoy and lifeboat re-marking).

Electrical Safety: Low insulation on 440V systems. Unprotected live electrical equipment, such that a personal safety risk exists.
Excluding: Defects with lower voltage systems.

Emergency source of power: Non-operational emergency generator. Emergency generator unable to connect to emergency switchboard. Batteries not capable of effectively powering relevant equipment (eg. GMDSS radio equipment on DC power setting).

Pollution Prevention: Defective oily water separator (including the plant, its 3-way valve and/or oil content meter). Defective sewage treatment plant and main parts (including plant, dosing pump, blower, sludge return, discharge pump, etc). Evidence of illegal discharge of pollutants, or arrangements in place to facilitate illegal discharges. Unapproved pollutant storage arrangements. Wilfully false entries in MARPOL record books. Incinerator missing refractory material.
Excluding: Garbage storage unapproved but without risk of illegal discharge (eg. forecastle store, cold/freezer rooms). Unapproved storage of treated sewage. Defective inlet valve to oily water separator, without risk of illegal discharge.

MLC / Crew Welfare: Failures in seafarer wage payments. Inadequate food. Work/rest hours breaches. Unsafe work practices. Failures in enclosed space entry processes. Missing enclosed space entry permits. Unsanitary conditions. Crew on board for over 11 months. Expired SEAs. Multiple unsecured heavy/hazardous items in critical areas. Missing guards from pumps, compressors, and workshop equipment. Defective safety stoppers on cargo hatch covers/coamings. Unsatisfactory enclosed space entry drill performance. PPE related to work permits not worn. Failure to carry out and properly record fumigation gas checks.
Excluding: Minor, administrative, or one-off breaches. Enclosed space entry processes for spaces intended for immediate entry in an emergency (eg. lifeboats)

ISM: A serious failure of the safety management system as implemented. The PSCO will assign an appropriate Action Code to an ISM deficiency, depending on what is observed during the inspection. Only a Code 30 or Code 19 (ISM audit before departure) would be considered a High severity ISM deficiency.
Excluding: Code 18 or 21 (3 months) ISM deficiencies.

Seafarer certification: Missing or expired primary certificates of competency/proficiency (noting flag State endorsements of certificates only require proof of application to be compliant).
Excluding: Missing/expired short-course certificates (which are required for issue of the certificates of competency/proficiency, which in turn are endorsed accordingly).

Bridge equipment and procedures: Defective MF/HF and satellite equipment. Inappropriate ECDIS setup (eg. incorrect safety depth and contour settings, use of outdated ENCs, missing ENCs, and missing nautical publications). Paper charts used as primary means of navigation not up to date. Both whistles defective. Incorrect sectors displayed for navigation lights. Rudder angle indicator inoperative/malfunctioning or error more than 5 degrees. Defective GMDSS equipment (eg. Recognised Mobile Satellite Service (RMSS) terminals, MF/HF radios/DSC, VHF radio/DSC, EPIRB, SART, etc). Unfamiliarity with distress procedures. Unfamiliarity with bridge and GMDSS equipment in general. Significant errors or failure or inability to calculate under keel clearance (UKC).
Excluding: Equipment that is over and above requirements. Use of outdated ENCs and publications for intended voyages not yet planned. Paper charts used as back-up arrangements not up to date. Bridge wing rudder angle indicator inoperative/malfunctioning or error more than 5 degrees. Unfamiliarity with minor items of bridge or GMDSS equipment.

Load Line: Defective closing, sealing and securing arrangements affecting watertight integrity (including watertight doors, cargo hatches, ballast tank air pipe closing devices, access hatches/manholes on freeboard deck, doors/hatches on forecastle head). Illegible load line/draft marks. Water ingress alarm system or sensors defective.
Excluding: Defective securing or sealing arrangements on weathertight doors above freeboard deck. Defective self-closing arrangements on sounding pipes with additional caps. One-off defective ballast tank air pipe closing devices/vents. One-off defective sealing arrangements for small hatches (eg. booby hatches, rope hatches). Missing sections of ship’s side rails (unprotected).

Cargo Spaces: Defective hold ladders and platforms. Defective lashing bridges.

Cargo Securing: Cargo loading prohibited (in all or part of the ship) due to defective cargo securing equipment/arrangements.

Overloading: Ship loaded past relevant load line for the intended voyage. Ship loaded in breach of IMO bridge visibility requirements.

Cargo documentation: Cargo on board without appropriate documentation (eg. bulk shipper’s declaration, IMDG documentation, ship-shore checklists). Missing entries from Cargo Record Book for tankers.

Mooring and Anchoring Equipment: Larger number of defective mooring lines or roller fairleads (ie. 4 or more). Worn windlass brake linings.

Ship Certification: Expired certificates.

Drills: Drills overdue (overdue period more than 1 month). Lifeboat / rescue boat not manoeuvred in water in last 3 months (overdue period more than 1 month). Freefall/simulated launching of freefall lifeboat overdue (overdue period more than 1 month); unsatisfactory performance of drills.

Cargo Handling Equipment: Cargo cranes found unfit for use or requiring approval before further use.

Engine Room Issues: Cylinder, liner and piston defects. No reading on boiler gauge glasses. Emergency stops not functional. Fuel/Oil leaks (spraying). Defective high pressure fuel pipe jacket system. All engine room bilge alarms/sensors defective. Stuck or improperly set safety valve on boiler.

Safety and Alarm Systems: Deliberate by-passing of alarms, detectors and safety systems.

Steering Gear: Steering pump not operational. Large/major hydraulic oil leaks.

Means of Access: Gangway/accommodation ladder with defects significantly impacting structural integrity. Gangway/accommodation ladder rigging clearly unsafe for use and/or use was prohibited. Gangway rigged at angle in excess of 30 degrees from horizontal. Accommodation ladder rigged at angle in excess of 55 degrees from horizontal.

Pilot Boarding Arrangements: Defective / damaged pilot ladder. Non-compliant rigging arrangement of ladder and/or man-ropes. Non-compliant access to ship’s deck. Lifebuoy and self-igniting light not available for immediate use. Inadequate lighting overside/on deck.

Ship Security: Uncontrolled access to the ship available during Security Level 2 and 3.

Ballast Water Management: Evidence of illegal/non-compliant discharge of ballast water.

Not Active In Safety Score

Definition: Deficiencies that, at the time of the initial PSC inspection, can clearly be shown from the PSC inspection report or close out documentation, to be:

Incidents – Deficiencies that directly relate to incidents, like fire damage – to ensure fairness by not double counting issues that are already affecting the safety score through the incident reporting process.

Invalid – Not Convention breaches, or otherwise not deemed correct as evidenced by confirmation from flag State or their recognised organisation (RO)), regardless of formal PSC MOU appeal status);

Fully in hand – Those that have been fully reported as required by SOLAS I/11(c) (flag State/recognised organisation (RO) and port State) and exemptions/dispensations issued if deemed appropriate by flag/RO (excluding where the requirements of such exemptions/dispensations are not being fully complied with); or deficiencies issued to the ship having arrived/almost arrived in a shipyard. E. g. inspected in Shanghai whilst en route to Nantong SY

If in doubt as to whether either of the above apply to a given deficiency, the normal severity level (Low, Medium, High) is to apply.