PSC ACTION codes, rectification deadlines and how to handle each

When a port State control (PSC) inspection ends, the inspector leaves a report listing the deficiencies. Two kinds of code appear on it. The deficiency code classifies what is wrong. The ACTION code says by when and through what procedure it has to be handled. The one that touches the sailing schedule is the ACTION code.

Two ships can carry the same deficiency code and be in different positions. ACTION code 17 means rectify before leaving this port, 18 gives three months, and 30 stops the ship from sailing.

Codes that set a date and codes that set a contact are different things

These are the standard action codes used by the Tokyo MOU and the Paris MOU.

Code	Meaning	What it means for time and procedure
10	Rectified	Fixed on the spot during the inspection. The deficiency still appears in the record
15	Rectify at next port	Measured from the next port of call
16	Rectify within 14 days	14 calendar days
17	Rectify before departure	Before the ship leaves this port
18	Rectify within 3 months	3 calendar months
30	Detainable deficiency	The ship cannot sail until the detention is released
45	Detainable deficiency, rectify at next port	Handled at the agreed next port
49	MLC rectification plan agreed	A procedure that applies to MLC deficiencies
50	Flag State / consulate informed	Not a deadline code. It designates a notification step
55	Flag State consulted	As above
70	Classification society informed	As above
99	Other	Follow what the body of the report says

Deadline codes (15, 16, 17, 18) and procedure codes (50, 55, 70) behave differently. The first group sets a date. The second sets who has to be contacted.

Reading a code as the wrong one costs you either way

1. With 17 the ship sails, with 30 it does not

17 means rectify before leaving this port. Fix it before the scheduled departure time and the schedule is unchanged. 30 is a detention. Reporting that it has been fixed does not release it. The inspector has to come back and confirm before the ship can sail.

Swap the two and you lose either way. Read 17 as 30 and you tell the agent and the charterer about a detention that never happened. Read 30 as 17 and you prepare for departure without booking the re-inspection, so the ship sails later than it otherwise would.

2. The 14 days on 16 can pass while the ship is at sea

16 is 14 calendar days from the date of the deficiency. It has nothing to do with how long the leg to the next port takes. If the passage is longer than 14 days, the deadline passes at sea.

So before departure, put the estimated arrival date and the deadline date side by side. If the deadline falls during the passage, decide before you sail which of two things you are doing. Repair it on board, or arrange parts and a technician at an intermediate port.

3. A 10 fixed on the spot still counts toward the risk profile

10 is a deficiency that was rectified during the inspection. It means the work is done. It does not mean there was no deficiency.

The count stays in the inspection record. Under the New Inspection Regime (NIR) the Tokyo MOU assigns each ship a risk profile, and past deficiencies and detentions feed into it. That profile drives when the next inspection comes and how thorough it is.

4. 49 is not a code that extends a deadline

49 (rectification plan agreed) is a procedure code that attaches to MLC deficiencies. It is not a way to extend the deadline on a general safety deficiency. Labour condition deficiencies and safety equipment deficiencies travel different routes.

50, 55 and 70 are not deadline codes either. They mark that the flag State or the classification society has entered the procedure, and the party that contacts those bodies is the office, not the ship.

Deficiency codes earn their keep in the aggregate, not on the day

If the ACTION code sets the schedule for this voyage, the deficiency code is the axis you use to look at the company’s safety management system. These are the main groups in the Tokyo MOU classification.

Code	Group	Code	Group
01	Certificates and documentation	10	Safety of navigation
02	Structural condition	11	Life saving appliances
03	Water/weathertight condition	12	Dangerous goods
04	Emergency systems	13	Propulsion and auxiliary machinery
05	Radio communication	14	Pollution prevention
06	Cargo operations	15	ISM
07	Fire safety	18	Labour conditions
08	Alarms	99	Other
09	Working and living conditions

Taken one at a time they are separate events. When you aggregate the whole fleet over a period and the same group keeps coming up, that is not one deficiency. It is the system telling you something.

If 07 (fire safety) keeps appearing on one ship, the maintenance interval or the inspection checklist is not catching the real condition. If 01 (certificates and documentation) appears across several ships, expiry dates are being held in someone’s memory. The non-conformity analysis that ISM Code chapter 9 asks for lives at this level. No amount of stacked rectification reports gets you here.

Six items have to sit together before you can count anything

The following six have to be in one place. They are what an audit looks for, and without them the aggregation above cannot be done at all.

1. The original report or a copy of it
2. The deficiency code and the ACTION code
3. The deadline date (the real date, converted from the code)
4. What was rectified, with evidence of completion
5. The root cause
6. The preventive action

Item 3 is the one to watch. The report carries the code, not the date. If you do not convert it to a date on the day you receive it, the deadline is written down nowhere. And nobody recalculates it later.

Items 5 and 6 are required by ISM Code chapter 9. Record only what was fixed and leave the cause blank, and when the same deficiency turns up on another ship nobody can tell that it is the second one.

Code sets differ by MOU and by revision

Action code sets and detention criteria can differ between MOUs and between revisions. Work from the original report you received and the current deficiency code list of the MOU concerned. The table above sets out the standard code set used by the Tokyo MOU and the Paris MOU.