A RightShip RISQ non-conformity does not end when the inspector leaves the vessel. It ends when RightShip accepts your Corrective Action Report (CAR) โ and they will not accept it unless the Root Cause Analysis is credible. A weak RCA, one that blames the crew or describes what happened without explaining why, will get rejected. RightShip will send it back, the non-conformity stays open, and your RISQ rating stays affected. I have seen this happen to good vessels with good safety management systems simply because the office did not know how to write an RCA that meets what RightShip is actually looking for.
This article explains exactly how to write an RCA for RISQ non-conformities โ the method to use, what each section must contain, the most common mistakes, and a side-by-side example of a poor response versus one that gets accepted.
The Three Types of RISQ Non-Conformities
Before writing any response, know what type of finding you are dealing with. RISQ classifies findings into three categories, and the response urgency and evidence requirements differ for each.
Major Non-Conformity
Absence or complete breakdown of a required SMS element, or an immediate safety/pollution risk. Requires urgent corrective action. RightShip may suspend the vessel's RISQ certificate until closed.
Minor Non-Conformity
A single observed lapse or partial failure of a required procedure. Must be corrected within the agreed timeframe. Documented evidence of closure required.
Observation
Not a formal non-conformity, but a risk area or improvement opportunity identified by the inspector. A written response is still expected and best practice to address proactively.
What RightShip Expects in a CAR
When you submit a Corrective Action Report through the RightShip portal, it must contain five elements. Miss any one of them and the response will come back. These are not suggestions โ they are what the RightShip review team checks against before accepting closure.
- Description of the Finding โ Restate the finding in your own words to confirm you understood it correctly. Do not just copy-paste the inspector's text.
- Root Cause Analysis โ The systemic reason the finding occurred. Not what happened, but why the system allowed it to happen.
- Immediate Corrective Action โ What was done on board right away to fix the immediate problem. This must be specific: who did what, on what date.
- Long-term Preventive Action โ The systemic change made to prevent recurrence across the fleet. This is the most important section for RightShip.
- Objective Evidence โ Documents, photos, updated checklists, training records, or fleet circulars that prove the actions were actually done.
RightShip's review team pays most attention to the preventive action. If the preventive action only fixes the vessel it was found on โ and not the root cause in the SMS โ they will ask for a fleet-wide response.
The Method: 5-Why Analysis
The 5-Why method is the standard RCA technique used in maritime safety management. You start with the finding and ask "why" five times, each time drilling one level deeper until you reach the systemic failure โ the point where a procedure was absent, inadequate, or not being followed because no one was checking.
Most poor RCAs stop at Why 1 or Why 2. That is where you get the surface answer โ "the crew member forgot" or "the record was not maintained." That is not a root cause. That is a symptom. You need to keep asking why until you reach the failure in the system itself.
Here is a worked example using a common RISQ finding: ECDIS familiarization records missing for a joining officer.
| Step | Question | Answer |
|---|---|---|
| Finding | What was observed? | ECDIS familiarization record for the 2nd Officer who joined 6 weeks ago could not be produced during inspection. |
| Why 1 | Why was the record not available? | The officer did not complete the ECDIS familiarization checklist after joining. |
| Why 2 | Why did the officer not complete it? | No one reminded him. The joining Master assumed he had completed it. |
| Why 3 | Why was there no follow-up? | The vessel's joining checklist does not include a step requiring the Master to verify ECDIS familiarization completion within 7 days. |
| Why 4 | Why is that step missing from the joining checklist? | The SMS joining checklist was last revised in 2021. The ECDIS familiarization requirement was added to the SMS in 2023 but the joining checklist was not updated at the same time. |
| Root Cause | Why was the checklist not updated? | There is no cross-reference review process in the SMS that triggers checklist updates when a new requirement is added. SMS changes are not systematically reflected across all affected forms and checklists. |
Now you have a root cause worth writing about. The problem is not one officer. The problem is that the SMS change management process has a gap โ new requirements do not automatically trigger updates to related forms. That is fixable at the company level and will prevent the same finding on every vessel in the fleet.
Good vs Bad: A Real Comparison
Finding: Fire damper in the engine room found in open position with manual override engaged.
Root Cause: The crew was not aware of the requirement to secure fire dampers after maintenance.
Corrective Action: The damper has been closed and the override removed. All crew have been reminded about fire damper requirements.
Preventive Action: Regular drills and toolbox talks will be conducted to ensure crew awareness.
Root Cause: The quarterly fire damper inspection checklist (Form SMS-FF-07) does not include a verification step confirming that manual overrides are secured and recorded after any maintenance access. The override had been engaged during planned maintenance 3 weeks prior to the inspection. There was no corresponding entry in the maintenance log, and no close-out check was performed at the time.
Immediate Corrective Action: Fire damper closed and override removed by Chief Engineer on 02 April 2026. Entry made in the Engine Room Logbook and the finding reported to DPA. All fire dampers on board checked on the same date โ no further overrides found engaged.
Preventive Action: Form SMS-FF-07 revised to include a mandatory sign-off field: "Manual override position verified and secured โ Yes / N/A" to be completed after every maintenance access. Revised checklist distributed to all 12 vessels in the fleet via Fleet Circular FC-2026-04 dated 03 April 2026. Onboard re-familiarization conducted and recorded in the crew training matrix. Next scheduled audit will include verification of checklist compliance.
Evidence Attached: Revised Form SMS-FF-07 ยท Fleet Circular FC-2026-04 ยท Engine Room Logbook extract ยท Training matrix entry
Both responses describe the same event. The first response will be rejected because "reminding crew" is not a preventive action โ it does not change anything in the system. The second response is accepted because it identifies a specific gap in a specific checklist, fixes it, and distributes the fix fleet-wide with evidence.
The Five Most Common RCA Mistakes
1. "Human error" is not a root cause
Every finding involves a human at some point. Saying the root cause was human error tells RightShip nothing about why the human made the error and what will stop the next person from making the same mistake. If your RCA stops at "human error," keep asking why. The answer will always be a procedure that was missing, unclear, or not being checked.
2. Corrective action and preventive action are not the same thing
Corrective action fixes what was broken on this vessel on this day. Preventive action changes the system so it cannot happen again on any vessel. Many CARs contain only corrective action โ the problem was fixed, so the response is submitted. RightShip will not close the finding unless the preventive action addresses the root cause systemically.
3. Vague language gets rejected
"Procedures will be reviewed." By whom? Which procedures? By when? "Training will be conducted." When? Who attended? Where is the record? Every statement in a preventive action must answer who, what, and when. If it cannot, it is not specific enough to submit.
4. No evidence, no closure
RightShip expects objective evidence, not written promises. For a major non-conformity, this means documents, photos, updated forms, or training records. For a minor NC, at minimum an updated checklist or a signed acknowledgement from the vessel. Never submit a CAR for a major NC without attachments.
5. Single-vessel response for a systemic finding
If the root cause is in your SMS โ a missing procedure, an incomplete checklist, a gap in the training matrix โ then the same finding is possible on every vessel in your fleet. RightShip knows this. A response that only fixes the vessel that was inspected will prompt the question: what about the rest of your fleet? Address it proactively and state the fleet-wide action with evidence.
A CAR Template You Can Use
Below is the structure I use when writing a CAR for any RISQ non-conformity. Fill each section with specific, factual language. Never leave a section blank.
Corrective Action Report โ Template
Evidence Checklist by Finding Type
For SMS / Procedure Findings
- Extract of the revised SMS section showing the updated requirement
- Fleet circular or master's acknowledgement form confirming distribution
- Version control record showing old vs new revision date
- Training record or toolbox talk sign-off if crew re-familiarization was conducted
For Equipment / Maintenance Findings
- Service record or maintenance log entry with date and name of person
- Photograph of the corrected condition
- Planned Maintenance System (PMS) update if an interval or task was changed
- Spare parts procurement record if equipment was replaced
For Certification / Record-Keeping Findings
- Copy of the now-completed record, form, or log entry
- Updated certificate or training record where applicable
- Evidence that fleet-wide records were checked (survey of other vessels)
One final point: Never submit a CAR the same day the inspection ends. RightShip does not expect that and a rushed response invariably contains vague language. Take 48โ72 hours to do the 5-Why properly, consult the Master and DPA, collect the evidence, and submit a complete response the first time. Resubmissions delay closure and leave the rating affected longer.
Frequently Asked Questions
A root cause analysis (RCA) is a structured investigation identifying the systemic reason why a non-conformity occurred โ not just what happened, but why the SMS or procedure allowed it to happen. Under ISM and RISQ, RCA is a required component of every corrective action report submitted in response to a non-conformity.
RightShip expects five elements: a description of the finding, a root cause analysis identifying the systemic failure, an immediate corrective action (what was done on board), a long-term preventive action (the systemic change to prevent recurrence fleet-wide), and objective evidence such as updated documents, photos, or fleet circulars.
The 5-Why method involves asking "why" five times in sequence, with each answer forming the basis of the next question. The goal is to move past surface symptoms to the systemic failure โ usually a missing checklist step, an SMS not updated, or a verification process not in place. Most maritime findings trace back to one of these three causes.
The most common reasons: the RCA stops at "human error" rather than a systemic cause; the preventive action only fixes the inspected vessel rather than addressing the root cause fleet-wide; language is vague with no named procedure, owner, or completion date; and no objective evidence is attached.
There is no fixed timeframe. RightShip sets a target closure date based on the severity of the finding. Major non-conformities require rapid action โ evidence may need to be submitted within days. Minor non-conformities must be closed by the agreed target date. The RISQ rating remains affected until RightShip confirms closure, so submitting a complete, first-time acceptable CAR is critical.