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Wednesday, October 17, 2018


The issue of ISM Non-Conformity and Near Miss reports was raised by one of our members after receiving a note of deficiency regarding their ISM system, because the vessel’s Near Miss and Non-Conformity files were empty. The members point of view was that if these files were empty then this was positive proof that the system was operating to 100% efficiency.

The matter was considered at the last Vetting Committee meeting. The Committee agreed that all a vetting inspector should be looking for during a vetting inspection (in relation to this topic) was positive proof that there was a safety management system onboard and that there was documentary evidence to indicate it was operating correctly. To do this the inspector would need to check the vessel’s onboard records. However, if there were no records of any Non-Conformities or Near Miss reports then this would indicate that all was not as it should be with the system. If the Near Miss files were empty then the inspector could become suspicious, because such a safety system was designed for continual improvement, which could only happen by taking note of Near Miss and/or Non Conformity reports

The Committee concluded that members should ensure that the Near Miss and Non-Conformity files contained historical data.

The Committee also agreed that a Non Conformity should not be recorded twice i.e. first as a Non-Conformity and second as a Deficiency during a vetting inspection.

For further questions or comments, please contact Capt Howard Snaith on e-mail