ISM, ISPS & MLC Audits and Pre-PSC Inspection in United States of America.

ISM, ISPS and MLC audits and pre-PSC inspection

ISM, ISPS and MLC audits check whether a ship’s safety management system, security plan and seafarer labour arrangements work in practice, not just on paper. A structured independent review can find implementation gaps before a flag auditor, recognised organisation, Port State Control officer, SIRE 2.0 inspector or RightShip assessor boards. Findings are mapped to the requirement, backed by objective evidence and prioritised for closure.

vslSafety arranges experienced marine auditors to attend the vessel at the port of call or ride between ports, with document review done remotely beforehand where possible.

Regulatory requirements and standards

ISM Code. Section 12 requires the Company to carry out internal safety audits on board and ashore at intervals not exceeding twelve months; in exceptional circumstances this interval may be exceeded by not more than three months. Auditors should be independent of the areas audited unless this is impracticable due to the size and nature of the Company, and results must be brought to the attention of the personnel responsible.

ISPS Code. The Ship Security Plan must include procedures for auditing security activities, and section A/9.4.1 requires personnel conducting internal audits of the security activities to be independent of the activities being audited unless this is impracticable. The International Ship Security Certificate is subject to an intermediate verification between the second and third anniversary dates. Part B guidance recommends security drills at least once every three months and exercises at least once each calendar year with no more than 18 months between them.

MLC, 2006. Title 5 sets out flag inspection and certification. The Maritime Labour Certificate is valid for up to five years, subject to an intermediate inspection normally between the second and third anniversary dates (Standard A5.1.3). Part II of the Declaration of Maritime Labour Compliance describes the shipowner’s measures to ensure ongoing compliance, which internal inspections help demonstrate. The 2022 amendments to the Convention entered into force on 23 December 2024.

Port State Control. Under the Paris MoU inspection regime, ships are targeted by ship risk profile, with periodic inspection windows of 5–6 months for high-risk ships, 10–12 months for standard-risk and 24–36 months for low-risk ships. The Tokyo MoU applies 2–4, 5–8 and 9–18 month windows respectively.

Audit and inspection intervals

What the service includes

• ISM internal audit of the shipboard SMS, including records, drills, maintenance of critical equipment, non-conformities and management review inputs
• ISPS internal audit covering access control, restricted areas, security records, Declarations of Security, SSAS testing and drill evidence
• MLC inspection of seafarer employment agreements, wage accounts, hours of rest, accommodation, provisions, drinking water, medical care and on-board complaint procedures
• Pre-PSC inspection based on the vessel’s risk profile, recent regional deficiency trends and concentrated inspection campaign topics
• Pre-vetting inspection for SIRE 2.0 (live since 2 September 2024), RightShip or charterer inspections, including crew interview practice
• Certificate validity check and walk-through of engine room, deck and accommodation for detainable-type defects
• Close-out verification of previous PSC, flag, vetting or internal audit findings

Vessel types and audit scopes covered

Auditors attend bulk carriers, tankers, container ships, general cargo ships, gas carriers, offshore vessels and passenger ships. Scopes range from a formal internal audit on the Company’s behalf to a confidential gap analysis or a targeted pre-inspection. Where the report must count as the formal internal audit, agree auditor qualification and independence with the designated person and, where required, the flag.

Common defects and PSC deficiencies

Paris MoU annual reporting for 2024 shows fire safety as the largest deficiency area, with fire doors among the most recorded individual items, while Seafarers’ Employment Agreements also feature prominently and ISM-related deficiencies account for a steady share. Typical findings on board include:

• Drills recorded but not realistically performed, or crew unfamiliar with emergency duties
• Critical equipment and stand-by systems not tested as the SMS requires
• Hours of rest records that do not match the log book or watch schedule
• Seafarer employment agreements, wage slips or allotments not consistent with the DMLC
• Security records incomplete, restricted areas unsecured or access control not enforced
• Recurring deficiencies that show corrective action was not effective, which PSC may treat as an ISM failure

The 2026 Paris and Tokyo MoU concentrated inspection campaign, running from 1 September to 30 November 2026, focuses on cargo securing; see also cargo securing and lashing inspection.

Certificates and documents you receive

• Audit or inspection report with findings classified as non-conformities or observations, each referenced to the requirement and objective evidence
• Corrective and preventive action plan with suggested owners and due dates
• Photographic evidence of physical defects
• Attendance record signed by the master for the Company’s audit file

A readiness review does not issue or endorse statutory certificates and cannot guarantee an inspection outcome.

How to prepare the vessel

Share the SMS index, previous audit, PSC and vetting reports, and open non-conformities in advance. Make the master, chief engineer, chief officer and ship security officer available for interviews, and plan a drill the auditor can witness. Physical defects can often be rectified in the same call through annual safety inspection and related services, or through the fire doors and dampers team.

Information needed for a quotation

• Vessel name, IMO number, type, flag, class and year of build
• Port, ETA/ETD and time available on board
• Scope: ISM, ISPS, MLC, pre-PSC, pre-vetting, or a combination
• Whether the audit must count as the formal internal audit
• Date of last internal audit and last PSC or vetting inspection, with reports
• Target inspection (e.g. SIRE 2.0, RightShip, specific port State) and working language

vslSafety coordinates a suitable auditor at or near the vessel’s port and agrees scope before attendance.

Frequently asked questions

How often must ISM internal audits be carried out?

ISM Code section 12 requires internal safety audits on board and ashore at intervals not exceeding twelve months. In exceptional circumstances the interval may be exceeded by not more than three months, but the Company should be able to justify this, and some flag Administrations expect to be informed or asked for approval.

Can the ship’s own officers carry out the internal audit?

Both the ISM and ISPS Codes require auditors to be independent of the areas or activities audited unless this is impracticable due to the size and nature of the Company or ship. Most companies use shore superintendents or external auditors, and an independent third party strengthens the credibility of findings.

What is a pre-PSC inspection?

A pre-PSC inspection is a mock port State control inspection before the vessel reaches a port where inspection is likely. The inspector checks certificates, crew familiarity, drills, fire safety, life-saving appliances, MLC items and visible defects the way PSC officers do, so the crew can rectify issues that could lead to deficiencies or detention.

Is the MLC inspection the same as the flag inspection?

No. The flag Administration or its recognised organisation inspects and certifies the ship under MLC Title 5. An internal MLC inspection is a company check of continuing compliance with DMLC Part II, which helps prepare for flag inspections and PSC scrutiny of employment agreements, wages and hours of rest.