The short version
- The ILO port state control guidelines do not set out what to check inside a medicine chest. There is no official checklist.
- Paragraph 53 has the officer review the Maritime Labour Certificate and the DMLC first. Documents decide whether the chest gets opened.
- DMLC Part I is the flag state’s requirement. Part II is your own declared measures, and that is the standard you are held to.
- Four things escalate to a detailed inspection, and one of them is a change of flag suggesting avoidance of compliance.
- The US has not ratified MLC, so a US-flagged vessel has no DMLC at all and must write its own standard under 46 CFR 28.210.
Search for an MLC medicine chest inspection checklist and you will be offered four of them, all from audit-software vendors, none specific to a chest. Download any of them and you will still not know what the officer standing in front of you is measuring against.
Here is why. There is no official checklist. The ILO guidelines that govern port state control under the MLC do not tell an officer what to look for inside a medicine chest[1]. The standard is your own paperwork.
The inspection starts with two documents, not with the chest
Paragraph 53 of the ILO guidelines has the port state control officer review the Maritime Labour Certificate and the Declaration of Maritime Labour Compliance first[1]. Everything after that is conditional on what those documents show.
| Document | What it contains | Why it decides the inspection |
|---|---|---|
| Maritime Labour Certificate | Flag state certification that the ship has been inspected and meets MLC requirements[2] | Valid and current, and the officer has no starting reason to go further |
| DMLC Part I | The flag state’s statement of its national requirements for each inspected area | This is where the chest standard for your vessel actually lives |
| DMLC Part II | The shipowner’s statement of the measures adopted to meet Part I on an ongoing basis | You wrote this. It is the checklist you will be held to |
The uncomfortable implicationMost operators have never read their own DMLC Part II carefully, and it is the document that defines what a good chest looks like on their ship. An officer comparing the chest to Part II and finding a gap is not applying a generic template. They are holding you to your own declaration, which is a far harder finding to argue with.
What turns a document check into an open chest
The guidelines set out when an inspection becomes more detailed. Four triggers, and each one is avoidable in advance[1].
| Trigger | What to do about it before arrival |
|---|---|
| Documents missing, invalid or incomplete | Check certificate and DMLC validity dates on the passage plan, not on the berth |
| Clear grounds for believing conditions do not conform, Standard A5.2.1(1)(b)[2] | Visible disorder is grounds. A tidy, dated, sealed chest is a signal in itself |
| A complaint | The onboard complaint procedure exists for a reason. An unresolved crew concern reaches the officer eventually |
| A change of flag suggesting avoidance of compliance[1] | A recent reflagging invites attention. Have the transition documented. See changing flag state |
The fourth trigger surprises people. A flag change is an administrative act, and it can itself be the reason a chest gets opened. If a transfer is planned, treat the first port call under the new flag as an inspection you should expect.
The checklist you should build, derived from A4.1
Since no official chest checklist exists, build one from the obligation and your DMLC rather than from a vendor template. MLC Standard A4.1(4)(a) requires a medicine chest, medical equipment and a medical guide, inspected at regular intervals, and Guideline B4.1.1 points at intervals of at most twelve months[2]. Under 92/29/EEC the equivalent is an annual inspection by a competent person or authority[3].
| What to be able to show | Where the requirement comes from | The failure it prevents |
|---|---|---|
| The chest, present and accessible | Standard A4.1(4)(a)[2] | Stowed behind cargo is a finding even when the contents are perfect |
| The medical guide on board and current | Standard A4.1(4)(a)[2] | A guide describing drugs the chest does not hold |
| Contents matching DMLC Part I and II | Flag requirement, for example RMI MN 7-042-1[7] | Built to a generic list rather than to your own declaration |
| Quantities anchored to a named reference | WHO Quantification Addendum[5] | “It looked about right” is not a defensible basis |
| An in-date expiry sweep with a signature | Inspection at regular intervals[2] | The most common finding of all. Right contents, dead dates |
| The last dated inspection record | Guideline B4.1.1, and 92/29/EEC annual[2][3] | No record means nothing was ever verifiably checked |
| Controlled drugs held and recorded separately | National law. For US registration, 21 CFR 1301.25[6] | Mixing regimes in one file makes both harder to defend |
If you fly the US flag, none of this paperwork exists
The United States has not ratified MLC 2006[2]. A US-flagged vessel carries no Maritime Labour Certificate and no DMLC, so there is no Part II to be measured against and no port state MLC inspection of its own flag.
What applies instead is 46 CFR 28.210, which requires a complete first aid manual and a medicine chest of a size suitable for the number of individuals on board, and specifies nothing further[4]. No contents list, no interval, no declaration.
That sounds lighter and is actually heavier, because the DMLC at least tells an MLC operator what good looks like. A US operator has to write that document themselves. The reasoning is in the 28.210 rules, the sequence in the six decisions, and the flag-by-flag view in requirements by flag state.
Assemble the medical file before the passage, not on the berth
The officer’s first move is documentary, so the cheapest preparation is documentary too. A medical file that can be produced in one folder changes the tone of an inspection before the chest is even opened.
Five items, and none of them takes long to assemble. The flag requirement your chest was built to, whether that is a marine notice, an EU category or a US written standard. The chest standard document, signed and dated, naming its quantity reference. The last inspection record with the name of whoever signed it. The certification roster showing who aboard holds what and when it expires. And the controlled drug file, kept separately because it answers to different law.
Assembling that set is also the fastest way to discover what is missing, which is the real point. An operator who cannot find the chest standard document does not have a documentation problem, they have a standard problem. The build sequence is in the six decisions, the stocking method in how to stock a chest, and the flag-specific requirements in the EU categories and requirements by flag state.
One more thing worth having ready: know who holds accountability for the file in your organisation before someone asks. That question has a clearer answer under ISM than most operators assume, and it is set out in who is responsible, owner or DPA. For vessels working far from an equipped port, the sizing argument behind the chest matters as much as its contents, which is covered in planning by time to definitive care.
Four things to do before the next port call
- Read your own DMLC Part II. Whatever it says about medical stores is the standard you declared. Most operators have never checked whether the chest matches it.
- Run the expiry sweep and sign it. Dates are the most common finding, and a signed dated record is the cheapest defence available[2].
- Name the quantity reference on the chest document. Not the quantities, the source of them[5].
- Keep the controlled drug file separate and producible. It answers to different law and a different inspector[6]. See the DEA inspection checklist.
Item one costs nothing and is the one nobody does. If you would rather a physician owned the whole cycle, MedChest builds and maintains it, and consulting reviews the program before an inspection rather than after one.
Common questions
Is there an official MLC medicine chest inspection checklist?
No, and that is the single most useful thing to know. The ILO Guidelines for port State control officers do not set out what to check inside a chest[1]. The officer works from your Maritime Labour Certificate and Declaration of Maritime Labour Compliance and applies professional judgment. Our MedChest service builds the checklist you will actually be measured against.
What does the officer look at first?
Documents. Paragraph 53 of the guidelines has the PSCO review the Maritime Labour Certificate and the Declaration of Maritime Labour Compliance before anything else[1]. If those are valid and complete, a chest inspection may go no further. That is why the DMLC matters more than the chest itself. See what a full audit checks.
What triggers a more detailed inspection?
Four things. Documents that are missing, invalid or incomplete. Clear grounds for believing conditions do not conform, under Standard A5.2.1 paragraph 1(b). A complaint. And a change of flag that suggests avoidance of compliance[1][2]. That last one is worth planning for: see changing flag state.
So what is the chest actually measured against?
Your flag state requirements as recorded in DMLC Part I, and the measures you declared in Part II. MLC Standard A4.1(4)(a) requires a chest, equipment and a medical guide, inspected at regular intervals, with Guideline B4.1.1 pointing at intervals of at most twelve months[2]. The substance comes from the flag, for example RMI Marine Notice 7-042-1[7].
Does any of this apply to a US-flagged vessel?
Not through MLC. The United States has not ratified it[2], so a US-flagged vessel carries no Maritime Labour Certificate and no DMLC. It answers to 46 CFR 28.210[4]. MLC still reaches it indirectly in a ratifying port state. See the 28.210 rules.
What is the most common chest finding?
Expiry and quantity, not exotic omissions. A chest whose contents match a list but whose dates have run, or whose quantities were never anchored to anything. Anchor them to the WHO Quantification Addendum and record the anchor[5]. See how to stock a chest.
Where do controlled drugs fit in a port state inspection?
They sit outside MLC entirely and answer to national law. For a US-registered vessel that means 21 CFR 1301.25 and its own record set[6]. Keep that file separate and produce it separately. See the DEA inspection checklist.
