How RightShip Assesses Quality and Acceptability of Close Out Submissions

This article explains how RightShip assesses the quality and acceptability of close‑out submissions provided by vessel operators in response to:

• Port State Control (PSC) Inspection deficiencies
• RightShip Inspection findings

It is intended to provide transparency on:

• What RightShip considers an acceptable close‑out submission
• How the quality of a submission is assessed
• When a submission may not be accepted
• The potential impact of an unacceptable close‑out

This article does not directly apply to incident investigations. Guidance on incidents is provided separately in the Desirable Content of an Incident Investigation Report article and associated guidance documents.

Core Elements Considered During Close‑Out Review

When reviewing a close‑out submission, RightShip considers four core elements:

• Clear and accurate description/explanation of the finding
• Root Cause Analysis (RCA)
• Corrective Actions
• Preventative Measures

Supporting evidence is considered across all four elements. 

1. Description and Explanation of the Finding

What RightShip Expects

A close‑out submission must include a clear, accurate and factual explanation of the deficiency or finding as it occurred on board.

A good explanation:

• Accurately reflects what was observed during the inspection
• Is consistent with the wording and intent of the inspection report
• Clearly describes the condition, situation or non‑conformance identified
• Avoids minimisation, reinterpretation or contradiction of the finding
• Uses clear and unambiguous language

Where appropriate, explanations may be supported by photographs or diagrams that clearly illustrate the issue.

How Explanation Quality Is Assessed

The explanation may be considered unacceptable if:

• It contradicts the inspection report without objective supporting evidence
• The issue is minimised or reframed in a way that obscures the actual finding
• Key aspects of the deficiency or finding are omitted
• The description is vague, ambiguous or factually incorrect

An unclear or inaccurate explanation undermines the entire close‑out submission, even if subsequent actions are described in detail.

2. Root Cause Analysis (RCA)

What RightShip Expects

A RCA should explain why the deficiency or finding occurred, not just what happened.

RightShip considers an RCA meaningful when it:

• Clearly and directly addresses the specific deficiency or finding
• Explains the cause‑and‑effect relationship within the operator’s management system
• Focuses on systems, processes and controls rather than individual blame
• Uses simple, factual and clear language
• Identifies opportunities to reduce risk

Recognised RCA techniques commonly used in the maritime industry (e.g. 5‑Why, Fishbone, Fault Tree Analysis) are encouraged, particularly for higher‑risk findings.

How RCA Quality Is Assessed

RCA may be considered unacceptable if:

• No root cause is identified
• Only immediate causes are described
• Generic statements are used (e.g. “human error”, “crew oversight”) without deeper analysis
• There is no consideration of whether management systems or procedures were adequate

RCA is generally considered acceptable when:

• The root cause(s) are clearly identified
• The submission demonstrates an understanding of why existing controls failed or were insufficient

For higher‑risk findings, RightShip expects a more detailed and structured RCA than for low‑risk items.

3. Corrective Action(s)

What RightShip Expects

Corrective Action(s) should describe how the specific deficiency or finding has been rectified.

At a minimum, Corrective Action(s) should:

• Fully address the identified issue
• Be appropriate to the nature and risk of the finding
• Be supported by objective evidence where available

How Corrective Actions Are Assessed

Corrective Action(s) may be considered unacceptable if:

• The deficiency has not been rectified or only partially rectified
• Actions rely solely on reminders or retraining without addressing underlying issues
• Responsibility is limited to individuals without system‑level consideration

Corrective Action(s) are generally considered acceptable when:

• The deficiency has been rectified at shipboard level
• Any necessary follow‑up actions (e.g. maintenance, audits, review of procedures) are clearly described

4. Preventative Measure(s)

What RightShip Expects

Preventative Measure(s) should clearly explain what has been implemented, or is planned to be implemented, to reduce the likelihood of recurrence—either on the same vessel or across the wider vessel operator’s fleet.

Submissions shall include:

• A clear and defined timeline for implementation; and
• The current status of implementation (e.g. completed, in progress, planned), including the scope of application across the fleet where relevant.

Preventative Measure(s) may include:

• Updates to procedures or checklists
• Improvements to management system controls (SMS)
• Updates to Planned Maintenance System/Routines
• Enhanced verification, monitoring or assurance processes
• Onboard/fleet wide coaching/training
• Fleet‑wide communication or implementation, where relevant

How Preventative Measures Are Assessed

Preventative Measure(s) may be considered unacceptable if:

• No preventative actions are identified
• Actions do not logically address the identified root cause(s)
• Measures do not meaningfully reduce the risk of recurrence
• Measures rely solely on reminders or retraining without addressing underlying issues
• Responsibility is limited to individuals without appropriate system-level controls, oversight, or management system integration
• Measures are vessel-specific only and (if relevant) do not demonstrate consideration of broader fleet-wide applicability
• Measures are unlikely to be sustainable over time (e.g. dependent on short-term attention rather than embedded processes or controls)

Preventative Measure(s) are generally considered acceptable when:

• They address the identified root cause(s)
• They reduce the likelihood of similar findings occurring again
• They introduce sustainable controls that remain effective beyond short-term interventions or personnel changes
• They are embedded within the management system (SMS), processes, or assurance mechanisms rather than relying solely on individuals
• They demonstrate appropriate fleet-level consideration or implementation, particularly for systemic or higher-risk issues

For higher‑risk findings, RightShip may expect evidence of fleet‑level consideration or implementation.

When a Close‑Out Submission May Not Be Accepted

RightShip may determine that a close‑out submission is not acceptable where:

• The explanation of the finding is unclear, inaccurate or misleading
• Root causes are not adequately identified
• Corrective actions do not resolve the deficiency
• Preventative measures are absent or ineffective
• Supporting evidence is missing or insufficient
• The submission does not demonstrate appropriate management review or involvement

In such cases, further clarification or an improved submission may be requested.

Proportionality and Risk‑Based Expectations

RightShip applies a risk‑based approach when reviewing close‑out submissions:

• Higher‑risk deficiencies and findings require more comprehensive explanations, analysis, actions and evidence
• Lower‑risk items may be addressed through proportionate and targeted responses

The same principles apply across PSC Inspections and RightShip Inspections, even where the depth of response differs.

Continuous Improvement

RightShip’s expectations for close‑out quality continue to evolve in line with:

• Industry best practice
• Improved understanding of effective root cause analysis
• Greater availability of management systems and investigation tools

Close‑out submissions should be viewed as an opportunity to strengthen safety performance and prevent recurrence.