Port State

Control Course

Capt Amin Al Qawasmeh

 Course
Elements

JAMS
• PSC History and Development
• Current and Future regulatory regime
• PSC Inspection Guidelines
• Targeting criteria and banning orders
• Preventive maintenance and Class attendance in
connection with PSC Detentions
• Analysis of common deficiencies
• Preparation of Checklists and defense strategy
• Handling of PSC Inspectors
• Follow up on PSC deficiencies and detentions
• Commercial Implications of PSC
• Case Study on handling PSC
• Case Study on follow-up PSC
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 JAMS
This course is To Provide office and
seagoing personnel and PSCO with
all the required information in order
to prepare and respond properly to
Introduction Port State Control Inspections.
Regulatory Reference: ILO MLC,
MARPOL, SOLAS, TMSA

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 Who Should Attend
All those interested in getting a
better understanding of PSC

JAMS
Inspection Requirements along with
current and future regulatory
regimes.
Training Methods

PSC The course is provided by a mixture

of lectures, case studies, exercises,
and final exams.
Certification
A Certificate of Training is provided to
participants on successful completion
of the course exam

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THE HISTORY OF PORT
STATE CONTROL
 The history of port state
control begins in Europe

JAMS
The history of port state control begins in
Europe. In March 1978 the Liberian-
flagged oil tanker „Amoco Cadiz“ ran
aground off the coast of Brittany/France.
The tanker broke into three parts.  More
than 220.000 tons of crude oil spilled out
into the  sea, thousands of seabirds
perished. The accident was caused by a
breakdown of the tanker’s  steering gear,
insufficient monitoring of the ship’s
technical condition, inadequate training of
the crew and deficiencies in the safety
management on board.
Pictures of stricken seabirds and polluted
beaches were seen all over the world and
provoked discussions on the causes of the
2022 accident.
6
 This was the beginning of
port state control. 14
European states agreed to

JAMS
join forces against unsafe
ships, poorly trained crews
and irresponsible ship
owners. Since then, the 
Paris Memorandum of Unde
rstanding - Paris MoU
 from 1982 on port state
control has provided the
basis to perform
unannounced surveys of
foreign-flagged merchant
ships calling at ports of the
member states of the Paris
MoU.
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 JAMS

Port state control soon proved effective:

In due course, the number of ships with
numerous deficiencies declined. The
permanent threat of possible surveys
induced ship owners to take better care
of their ships. Currently, the Paris MOU
has 26 member states.
The rapid and obvious success in Europe
lead the way to developing port state
control internationally. This success story
had its origin in the Paris MoU.

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 JAMS
What Is Port
State
Control?
MoU, Advantages, and Criticism

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• The United Nations Convention on the Law of the Sea (UNCLOS),
1994, Regulation 90, grants the right to all states to register ships
under their flags and to sail them on the high seas. The flag states
as part of their responsibility are expected to maintain
administrative, technical, and social oversight over their ships.

• UNCLOS Article 94(5) requires flag states to take steps necessary

to secure observance of generally accepted international
regulations, procedures, and practices. This assertion, however,
does not reflect reality, and in many cases, shipowners have to be
forced to act within the law. This is the case for port state control.

Port State Control (PSC) is the inspection of foreign ships

 in national ports to verify that the condition of the ship
and its equipment comply with the requirements of
international regulations and that the ship is manned and
operated in compliance with these rules.
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• There are several compliance requirements that must
be met for a ship to pass a PSC inspection, including
standards for the vessel itself, the crew, and the ship’s
documentation.,

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What Is Port State Control?
• The International Maritime Organization (IMO) has
developed several conventions that lay down standards
for the construction, equipment, and operation of ships.
These conventions are binding on the countries that
have ratified them.
• Under normal circumstances, each nation that ratifies
an international maritime convention is required to
ensure that the convention is implemented. PSC regime
is guided by IMO Resolution A.882(21), which is the
current version of the IMO Procedures for Port State
Control.
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• In addition, the parties are required to domesticate the convention, that is
to incorporate the provisions of the convention into their local legislation.
However, the implementation may sometimes meet with difficulties. For
example, the incorporation of the conventions into the national legal
systems of each state may sometimes take time.

• Occasionally there may also be inconsistencies between the convention

and the legislation that will put it into effect or the implementation of a
convention may not be a priority for the member state.
• As a result, the fact that a convention is conceived does not always
translate into its implementation and effective enforcement.  It is under
such circumstances that the PSC acts as a safety net- to uncover ships
that somehow or the other might fail to comply with acceptable standards.

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• Port state control is a regime by which ships are
inspected by officials from the port country to ensure
that they comply with international maritime
Conventions and that they are not a threat to the crew,
the port, or the surrounding coastal area.
• The main objective of PSC is therefore to verify that a
ship is safe and fit for its intended purpose. It is also a
means through which coastal states prevent sub-
standard ships from entering their ports.

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PSC Relationship to Flag State
Control.
• Port State Control (PSC) is a program through which maritime authorities inspect
foreign-flagged ships in their country to verify compliance with international
conventions and standards.

• After a ship is inspected, the PSC authority may act if any deficiencies are found.
This action may include detaining the ship, ordering the ship to make repairs, or
issuing a fine.

• Flag State Control (FSC), on the other hand, is an inspection carried out by a
respective Flag State on ships under her flag to ensure compliance with
international conventions and standards which the flag state has ratified and
comes under the provisions of UNCLOS 1982, 94(5), “flag states fundamental
duties’. While the FSC authority may delegate inspection and enforcement to PSC
authorities, the ultimate responsibility for compliance rests with the FSC authority.

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• PSC and FSC are both important programs, complementing each
other to ensure compliance with international maritime laws.
PSC provides an additional layer of protection for port states,
while FSC ensures that ships flying a particular flag are
complying with the flag states’ obligations.
• Port State Control (PSC) is a maritime safety initiative that aims
to verify a ship’s compliance with international conventions and
standards. It is the responsibility of the flag state (the country
where the ship is registered) to ensure that a vessel meets all
the required safety standards. However, in practice, it is often
difficult for flag states to effectively monitor all the ships under
their jurisdiction.

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• This is where PSC comes in. Under PSC, maritime
authorities from different countries carry out inspections
of foreign-flagged vessels that are visiting their ports.
• These inspections check for compliance with a range of
international conventions. If a ship is found to be not in
compliance with the requirements of any of these
conventions, the Port state takes actions it deems
necessary to ensure compliance.
• Thus, Port state control and Flag state control both
works towards goals that are separate but congruent –
compliance with international maritime conventions.   
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Regional Co-operation
Mechanism in Port State Control.

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 • A Memorandum of Understanding (MOU) in port state control
is a method that has been adopted in different regions of the
world for the purpose of harmonizing port state controls in
that particular region.
• As a result of such regional cooperation on port state
control, ships are now able to undergo inspections in a
region, and a reporting system is implemented to keep the
other coastal states within the region informed of the
condition of ships that have been inspected, as well as to
dissuade owners from utilizing ships that have been found
substandard, particularly those that have been targeted by
other coastal states within the region.
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• The implementation of memorandums of understanding,
or MOUs, for regional cooperation in port state control, is
the only other option and the most efficient technique
accessible to get rid of subpar ships, as well as to
safeguard the lives of mariners and preserve the natural
environment of the ocean
• Initially, these inspections were supposed to serve as a
backup to the implementation that was being done by
the flag state; but experience has proven that they may
be very effective on their own. The organization voted to
adopt resolution A.682(17), which promotes the
conclusion of regional agreements and calls for regional
cooperation in the regulation of ships and discharges.

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 Guide to Port
State Control
(PSC)
Inspection on
Ships

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The Paris Memorandum of Understanding on Port State Control (Paris MoU) is the official
document that
implements a harmonized system of Port State Control (PSC), including:
• selection and inspection procedures
• exchange of information
• structure of the organization and amendment
procedures.

Every day PSC Officers (PSCO’s) select several ships

for inspection throughout the region facilitated by a
central computer database, known as “THETIS”.
THETIS informs national PSC authorities about ships
that are due for an inspection. Data on ships’
particulars and reports of previous inspections
carried out within the Paris MoU
region are also available in the database

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• Ships are attributed a ship risk profile (SRP). This SRP will determine the ships priority
for inspection, the interval between inspections and the scope of the inspection. The
SRP is based on generic and historic parameters. All ships in the information system
are assigned either as a High, Standard or Low-Risk Ship.

• High-Risk Ships (HRS) meet criteria to a total value of 5 or more points according to
the SRP calculator.
• Low-Risk Ships (LRS) meet all the criteria of the Low-Risk Parameters and have had
at least one inspection
in the previous 36 months.
• Standard Risk Ships (SRS) are ships that are neither HRS nor LRS. the information
system are assigned either as a High, Standard or Low-Risk Ship

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PSCO
A PSCO is a qualified person that carries out port
State
control. All PSCO’s carry an identity card, issued by
their
Periodic and additional inspections
maritimeInspections
Periodic authorities.are carried out at intervals
determined by the ship risk profile. Overriding or
unexpected factors might trigger an inspection in between
periodic inspections. This category of inspection is referred
to as an additional inspection. Ships become due for
periodic inspection in the following time windows:

• High-Risk Ship: between 5-6 months after the last

inspection in the Paris MoU region the port state may
•decide to inspect
Standard the ship
Risk Ship: but after
between the 6th
10-12 month
months thethe
after port
state
last has to inspect;
inspection in the Paris MoU region the port state ship
may decide to inspect the ship but after the 12th month the
port state hasShip:
• Low-Risk to inspect;
between 24-36 months after the last
inspection in the Paris MoU region the port state ship may
decide to inspect the ship but after the 36th month, the
port
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The time span for the next periodic inspection re-starts
after any inspection.

Additional inspections are triggered by overriding or unexpected factors depending on

the severity of the
occurrence. An overriding factor could be a collision or discharge of harmful substances.
An unexpected factor
could be e.g. complaints by crew or other interested parties, failure to comply with
reporting obligations;
outstanding ISM deficiencies; or reported cargo problems in particular regarding noxious
or dangerous cargo.

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Selection Scheme
The selection scheme is divided into two priorities:
• Priority I: ships must be inspected because either the time window has
closed or there is an overriding factor.
• Priority II: ships may be inspected because they are within the time window
or the port State considers an unexpected factor warrants an inspection.
If the time window has passed, a ship becomes Priority I. The ship will be
selected for a periodic inspection.
When the time window opens, a ship becomes Priority II. The ship can be
selected for a periodic inspection.
If an overriding factor is recorded against a ship it becomes Priority I irrespective
of the time window and the
ship will be selected for inspection.
If an unexpected factor is logged against a ship it becomes Priority II
irrespective of the time window and the ship can be selected for inspection.

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2022 JAMS 27
 JAMS
Inspection
types

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 Inspection types
A port state control visit will normally start with an examination of the documents. In
addition, the PSCO conducts a general inspection of several areas on board to verify that
the overall condition of the ship complies
with the requirement of the various certificates. If the ship complies, the PSCO will issue
a “clean” inspection report to the master of the ship. In case deficiencies have been
identified, the inspection report will include the discovered deficiencies indicating any
follow-up actions to be taken to rectify the deficiencies. The data of the respective ship
and the inspection result will be recorded on THETIS.
• The following inspection types can be carried out:
• initial inspection
• more detailed inspection
• expanded inspection
• concentrated inspection campaign.

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Initial inspection
An initial inspection will consist of a visit on board the ship
to:
• check the certificates and documents listed in the MoU
text
• check that the overall condition and general cleaning
of the ship including:
1. navigation bridge
2. accommodation and galley
3. decks including forecastle
4. cargo holds/area
5. engine room.

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More detailed inspection
During an inspection the PSCO may decide to carry out a more detailed inspection if
there are clear grounds for
believing that the condition of the ship, its equipment or crew do not meet the relevant
regulatory requirements.
The absence of valid certificates or documents is eg. considered to be a clear ground.

A more detailed inspection will include an

in-depth
examination of:
• areas where clear grounds were
established
• areas relevant to any overriding or
unexpected factors

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• other areas at random from the following areas:
1. documentation
2. structural condition
3. water/weathertight condition
4. emergency systems
5. radio communication
6. cargo operations
7. fire safety
8. alarms
9. living and working condition
10. navigation equipment
11. life-saving appliances
12. dangerous goods
13. propulsion and auxiliary machinery
14. pollution prevention.

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The more detailed inspection will take account of the human elements covered by
International Labour
Organization (ILO), International Safety Management (ISM-code) and International
Convention of Standards
of Training Certification and Watchkeeping for Seafarers (STCW) and include operational
controls as appropriate.

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Expanded inspections
An expanded inspection shall include a check of the overall condition, including human
elements where relevant and subject to their practical feasibility or any constraints

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 CLEAR GROUNDS

When a PSCO inspects a foreign ship that is required to hold a convention certificate, and which is in a
port or an offshore terminal under the jurisdiction of the port State, any such inspection should be limited
to verifying that there are on board valid certificates and other relevant documentation and the PSCO
forming an impression of the overall condition of the ship, its equipment and its crew, unless there are
"clear grounds" for believing that the condition of the ship or its equipment does not correspond
substantially with the particulars of the certificates.

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• "Clear grounds" to conduct a more detailed inspection include but are not limited to:

• .1 the absence of principal equipment or arrangements required by the relevant conventions;

• .2 evidence from a review of the ship's certificates that a certificate or certificates are clearly invalid;

• .3 evidence that documentation required by the relevant conventions and listed in appendix 12 is
not on board, is incomplete, is not maintained or is falsely maintained;

• .4 evidence from the PSCO's general impressions and observations that serious hull or structural
deterioration or deficiencies exist that may place at risk the structural, watertight or weathertight
integrity of the ship;

• .5 evidence from the PSCO's general impressions or observations that serious deficiencies exist in
the safety, pollution prevention or navigational equipment;

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.6 information or evidence that the master or crew is not familiar with essential shipboard operations
relating to the safety of ships or the prevention of pollution, or that such operations have not been
carried out;

.7 indications that key crew members may not be able to communicate with each other or with other
persons on board;

.8 the emission of false distress alerts not followed by proper cancellation procedures; and

.9 receipt of a report or complaint containing information that a ship appears to be substandard

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GUIDELINES FOR THE DETENTION OF SHIPS

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 Introduction
When deciding whether the deficiencies found in a ship are sufficiently serious to merit detention, the
PSCO should assess whether:

.1 the ship has relevant, valid documentation; and

.2 the ship has the crew required in the minimum safe manning document

During the inspection, the PSCO should further assess whether the ship and/or crew, throughout its
forthcoming voyage, is able to:
.1 navigate safely;
.2 safely handle, carry and monitor the condition of the cargo;
.3 operate the engine room safely;
.4 maintain proper propulsion and steering;
.5 fight fires effectively in any part of the ship if necessary;
.6 abandon ship speedily and safely and effect rescue if necessary;
.7 prevent pollution of the environment;
.8 maintain adequate stability;
.9 maintain adequate watertight integrity;
.10 communicate in distress situations if necessary; and
.11 provide safe and healthy conditions on board.
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 If the result of any of these assessments is negative, taking into account all deficiencies found, the ship
should be strongly considered for detention. A combination of deficiencies of a less serious nature may
also warrant the detention of the ship. Ships which are unsafe to proceed to sea should be detained
upon the first inspection, irrespective of the time the ship will stay in port.

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General
The lack of valid certificates as required by the relevant conventions may warrant the detention of ships.
However, ships flying the flag of States not a Party to a convention or not having implemented another
relevant instrument, are not entitled to carry the certificates provided for by the convention or other
relevant instrument. Therefore, absence of the required certificates should not by itself constitute a
reason to detain these ships; however, in applying the "no more favourable treatment" clause, substantial
compliance with the provisions and criteria specified in these Procedures must be required before the
ship sails.
Resolution A.1119(30) Adopted on 6 December 2017 PROCEDURES FOR PORT STATE CONTROL,
2017

Detainable deficiencies
To assist the PSCO in the use of these Guidelines, there follows a list of deficiencies, grouped under
relevant conventions and/or codes, which are considered to be of such a serious nature that they
may warrant the detention of the ship involved. This list is not considered exhaustive, but is intended
to give examples of relevant items.

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 Areas under the SOLAS Convention

1 Failure of proper operation of propulsion and other essential machinery, as well as electrical installations.
2 Insufficient cleanliness of engine room, excess amount of oily-water mixture in bilges, insulation of piping
including exhaust pipes in engine room contaminated by oil, and improper operation of bilge pumping
arrangements.
3 Failure of the proper operation of emergency generator, lighting, batteries and switches.
4 Failure of proper operation of the main and auxiliary steering gear.
5 Absence, insufficient capacity or serious deterioration of personal life-saving appliances, survival craft and
launching and recovery arrangements (see also MSC.1/Circ.1490/Rev.1).
6 Absence, non-compliance or substantial deterioration to the extent that it cannot comply with its intended use
of fire detection system, fire alarms, fire-fighting equipment, fixed fire-extinguishing installation, ventilation
valves, fire dampers and quick-closing devices.

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7 Absence, substantial deterioration or failure of proper operation of the cargo deck area fire protection on
tankers.
8 Absence, non-compliance or serious deterioration of lights, shapes or sound signals.
9 Absence or failure of the proper operation of the radio equipment for distress and safety communication.
10 Absence or failure of the proper operation of navigation equipment, taking the relevant provisions of
SOLAS regulation V/16.2 into account.
11 Absence of corrected navigational charts, and/or all other relevant nautical publications necessary for the
intended voyage, taking into account that electronic charts may be used as a substitute for the charts.
12 Absence of non-sparking exhaust ventilation for cargo pump-rooms.
13 Serious deficiency in the operational requirements listed in appendix 7.
14 Number, composition or certification of crew not corresponding with safe manning document.
Resolution A.1119(30) Adopted on 6 December 2017 PROCEDURES FOR PORT STATE CONTROL, 2017
15 Non-implementation or failure to carry out the enhanced survey programme in accordance with SOLAS
regulation XI-1/2 and the International Code on the Enhanced Programme of Inspections during Surveys of
Bulk Carriers and Oil Tankers, 2011 (2011 ESP Code), as amended.
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 Areas under the IBC Code

1 Transport of a substance not mentioned in the Certificate of Fitness or missing cargo information.
2 Missing or damaged high-pressure safety devices.
3 Electrical installations not intrinsically safe or not corresponding to the Code requirements.
4 Sources of ignition in hazardous locations.
5 Contravention of special requirements.
6 Exceeding of maximum allowable cargo quantity per tank.
7 Insufficient heat protection for sensitive products.
8 Pressure alarms for cargo tanks not operable.
9 Transport of substances to be inhibited without valid inhibitor certificate.

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 Areas under the IGC Code

1 Transport of a substance not mentioned in the Certificate of Fitness or missing cargo information.
2 Missing closing devices for accommodations or service spaces.
3 Bulkhead not gastight.
4 Defective air locks.
5 Missing or defective quick-closing valves.
6 Missing or defective safety valves.
7 Electrical installations not intrinsically safe or not corresponding to the Code requirements.
8 Ventilators in cargo area not operable.
9 Pressure alarms for cargo tanks not operable.
10 Gas detection plant and/or toxic gas detection plant defective.
11 Transport of substances to be inhibited without valid inhibitor certificate.
Resolution A.1119(30) Adopted on 6 December 2017 PROCEDURES FOR PORT STATE CONTROL,
2017
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 Areas under the Load Lines Convention
1 Significant areas of damage or corrosion, or pitting of plating and associated stiffening in decks and hull
affecting seaworthiness or strength to take local loads, unless properly authorized temporary repairs for a
voyage to a port for permanent repairs have been carried out.
2 A recognized case of insufficient stability.
3 The absence of sufficient and reliable information, in an approved form, which by rapid and simple means
enables the master to arrange for the loading and ballasting of the ship in such a way that a safe margin of
stability is maintained at all stages and at varying conditions of the voyage, and that the creation of any
unacceptable stresses in the ship's structure is avoided.
4 Absence, substantial deterioration or defective closing devices, hatch closing arrangements and
watertight/weathertight doors.
5 Overloading.
6 Absence of, or impossibility to read, draught marks and/or Load Line marks

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 Areas under the MARPOL Convention, Annex I

1 Absence, serious deterioration or failure of proper operation of the oily-water filtering equipment, the oil
discharge monitoring and control system or the 15 ppm alarm arrangements.
2 Remaining capacity of slop and/or sludge tank insufficient for the intended voyage.
3 Oil Record Book not available.
4 Unauthorized discharge bypass fitted.
5 Failure to meet the requirements of regulation 20.4 or alternative requirements specified in regulation
20.7.

Areas under the MARPOL Convention, Annex II

1 Absence of P and A Manual.
2 Cargo is not categorized.
3 No Cargo Record Book available.
4 Unauthorized discharge bypass fitted.

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 Areas under the MARPOL Convention, Annex IV

1 Absence of valid International Sewage Pollution Prevention Certificate.

2 Sewage treatment plant not approved and certified by the Administration.

3 Ship's personnel not familiar with disposal/discharge requirements of sewage.

Resolution A.1119(30) Adopted on 6 December 2017 PROCEDURES FOR PORT STATE CONTROL, 2017

Areas under the MARPOL Convention, Annex V

1 Absence of the garbage management plan.

2 No garbage record book available.
3 Ship's personnel not familiar with disposal/discharge requirements of garbage management plan.

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Areas under the MARPOL Convention, Annex VI

1 Absence of valid IAPP Certificate and where relevant EIAPP Certificates and Technical Files.
2 A marine diesel engine, with a power output of more than 130 kW, which is installed on board a ship
constructed on or after 1 January 2000, or a marine diesel engine having undergone a major conversion on
or after 1 January 2000, which does not comply with the NOX Technical Code 2008.
3 The sulfur content of any fuel oil used on board ships exceeds the following limits:
.1 3.5% m/m on and after 1 January 2012; and
.2 0.5% m/m on and after 1 January 2020.

4 The sulphur content of any fuel used on board exceeds 0.1% m/m on and after 1 January 2015 while
operating within a SOX emission control area, and respectively, as per the provisions of regulation 14.
5 An incinerator installed on board the ship on or after 1 January 2000 does not comply with requirements
contained in appendix IV to the Annex, or the standard specifications for shipboard incinerators developed
by the Organization (resolution MEPC.244(66)).

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6 Ship personnel are not familiar with essential procedures regarding the operation of air pollution
prevention equipment.
7 Absence of valid IEEC (International Energy Efficiency Certificate).
8 Absence of Ship Energy Efficiency Management Plan (SEEMP) specific for the ship (this may form part of
the ship's Safety Management System (SMS)).

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Areas under the STCW Convention

1 Failure of seafarers to hold appropriate certificates to have a valid dispensation or to provide documentary
proof that an application for an endorsement has been submitted to the Administration.
2 Failure to comply with the applicable safe manning requirements of the Administration.
3 Failure of navigational or engineering watch arrangements to conform to the requirements specified for the
ship by the Administration

4 Absence in a watch of a person qualified to operate equipment essential to safe navigation, safety
radiocommunications or the prevention of marine pollution.
5 Inability to provide for the first watch at the commencement of a voyage and for subsequent relieving
watches persons who are sufficiently rested and otherwise fit for duty.
6 Failure to provide proof of professional proficiency for the duties assigned to seafarers for the safety of the
ship and the prevention of pollution.

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 Areas which may not warrant a detention, but where, for example, cargo operations have to be
suspended
Failure of the proper operation (or maintenance) of inert gas systems, cargo related gear or machinery
should be considered sufficient grounds to stop cargo operation

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 Reading Port state inspection report
After the port state inspection is completed, a report of the inspection is provided to the
master of the ship.
At the least master must check these three things before signing.
•Name of the ship and date of the inspection

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•Any deficiencies identified during the
inspection

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If the vessel is detained because of
the identified deficiencies.

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While the information in the PSC inspection report of different MOUs will contain the same
information, their format could be different.
Like here is the format for PSC report of Indian ocean MOU.
And here is the format for PSC report of Paris MOU.
Irrespective of the format of the inspection report, the master must locate and check these
three pieces of information in the report for its correctness.

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PSC report with no deficiencies
What can be more satisfying than completing a PSC inspection with NIL deficiencies?
After a PSC inspection with NIL deficiency, master needs to file the report as per the filing system
of the company.
Master may also be required to save a scanned copy of the inspection report in the electronic PMS
of the ship.

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All the identified deficiencies will then be described in Form B of the PSC report which will be
attached to the “Form A”.
Action code is provided against each noted deficiency in form B of the PSC inspection report.

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There will be one or more of these action codes for
each of the deficiencies.
•Code 10: Deficiency rectified
•Code 15: Rectify deficiency at next port
•Code 16: Rectify deficiency within 14 days
•Code 17: Rectify deficiency before departure
•Code 18: Rectify deficiency within 3 months
•Code 30: Detainable deficiency
•Code 40: next port informed
•Code 45: rectify detainable deficiency at next port
50 flag state/consul informed
•Code 55: flag state consulted
•Code 70: recognized organization informed
•Code 85: investigation of the contravention of
discharge provision (MARPOL)
•Code 99: Other

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Rectifying the deficiencies
I always believe that finding the defect is more difficult than rectifying it.
So once a deficiency has been identified, it should not be difficult to rectify it.

But the question is who needs to endorse the rectification of the

identified deficiency?
Can the statement from the master that “the deficiency has been
rectified” be enough?
Do the PSC inspector need to re-visit the vessel to confirm the rectification?
Or is it the class that needs to verify the rectification of deficiency?
Well, it would all depend upon the
•Port state control and/or PSC MOUs
•Type and area of deficiency
For example, for most of the deficiencies USCG requires classification societies to verify
that the deficiency has been rectified.
I have experienced in Russian ports that PSC inspectors make a revisit to verify the closing
of the deficiency.

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And finally, in most of the Chinese ports, the statement from the master is considered enough
for closing most of the deficiencies.
Well as a general rule, all deficiencies related to the machinery and structure of the ship need
to be closed by the classification society of the vessel.
In this case, classification society would issue “condition of class” to the vessel and close it
after the defect has been rectified.

As different port state control could have different ways to close out the deficiencies, it is
prudent for the master to clarify this with the PSC inspector.

Treating PSC deficiencies as Non-conformities

The procedures of most of the companies require that any PSC deficiency must be treated as
a non-conformity.
Company’s procedures to deal with a non-conformity must be followed to deal with the PSC
deficiency.
The procedure to close out the PSC deficiency will be same as close out of any non-conformity
as per SMS manuals.
On tankers treating PSC observation as non-conformity is a requirement as per SIRE.

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 Code 17 deficiencies
Code 17 deficiencies are the most common deficiencies during PSC
inspections.
All the
And the deficiencies
most common with code
area of 17 must be rectified before departure.
doubt is if the PSC needs to re-visit
to verify that the code 17
deficiency has been rectified.
PSC at some ports may require to
re-visit for verification and at other
ports, it may not be necessary.
The Master of the vessel must
clarify with the PSC inspector if the
re-verification
2022
is required or not. JAMS 62
 If re-verification is required, the master must inform the PSC through the agent after the
deficiency has been rectified.
After the re-verification master must ensure that all code 17 deficiencies have been
marked with code 10 which means that the deficiency has been rectified.

2022 JAMS 63
Irrespective of if PSC requires the re-verification of closeout or not, it is important that any code
17 deficiency is rectified before vessel departs the port.
A vessel that departs the port without rectifying the code 17 deficiency is considered to be an
unseaworthy ship. Taking an unseaworthy ship to the sea can have serious repercussion for the
master of the ship.
If the PSC does not require the re-inspection of the close out of the deficiencies, it is a good
idea to send an email to the port state through agent informing that the deficiencies have been
rectified.
The email could be something like this.

2022 JAMS 64
2022 JAMS 65
Deficiencies other than code 17
Code 17 deficiencies require quick action. The deficiencies need to be closed before departure
from the port.
But that is not the case with other deficiencies such as code 15 (to be rectified before
departure from next port) or code 18 (to be rectified within 3 months).
While the time period for getting the deficiency rectified is different in each of these
deficiencies, the process is same.
For example, for code 15 deficiency master must send the confirmation of close out of
deficiency before departure from next port.
Or if it is required for the PSC inspector to verify the close out of deficiency, his presence must
be requested through the agent in ample time.

2022 JAMS 66
Detainable deficiencies
Detainable deficiencies are serious and hence the process of close out of detainable
deficiencies is also different from that for other deficiencies.
The usual confusion is what makes a code 17 deficiency a detainable deficiency.
For example, is “Sart not working” a code 17 deficiency or a detainable deficiency?
Well, the line that separates the code 17 deficiency from a detainable deficiency is thin but not
too difficult for the port state officer to identify.
The procedure to use to identify a detainable deficiency is provided to the port state officers in
PSC handbook of the MOU.
For example, for Paris MOU, below is the main criteria for PSCO to decide for the detention of
•the
ships which are unsafe to proceed to sea will be detained upon the first inspection
ship.
irrespective of the time the ship will stay in port;
•the ship will be detained if the deficiencies on a ship are sufficiently serious to merit a PSCO
returning to the ship to be satisfied that they have been rectified before the ship sails.
Paris MOU handbook for PSC inspectors further gives the deficiency areas that can be
considered to be the ground for detention.
For example, following are the deficiencies under SOLAS that can be considered to be the
ground for detention.

2022 JAMS 67
2022 JAMS 68
These are just the guidelines. A deficiency in any of these areas does not mean that the ship
will be detained.
For example, let us consider this criterion.
absence, non-compliance or serious deterioration of lights, shapes or sound signals
Does this mean that vessel will be detained if one navigational light is found not working?
Absolutely not.
But what if none of the lights are working. Then there is something serious about the
deficiency and in most certainity, the vessel will be detained.

2022 JAMS 69
The procedure of vessel’s detention

If the PSCO decides to detain the ship, they will issue the notice of detention to the
master.
The PSCO will also send the notice of
detention to the flag of the vessel and to
the classification society of the vessel.

2022 JAMS 70
Most of the flag state require the
masters/company to notify them in
case the vessel is detained by any
port state control.
Master need to confirm with the
company if flag state needs to be
informed by the vessel.

2022 JAMS 71
Close out of detention deficiencies
Once the notifications have been done, it is time to work on closing the detention deficiencies as
soon as possible to keep the delays to the minimum.
And the first thing we have to do is to understand the deficiency correctly. We cannot afford to
misunderstand the deficiency and put our efforts towards areas which would not be required to
close out the deficiency.
For example, if the deficiency is related to MARPOL, we need to know if the deficiency is related
to a defective equipment or an observation related to the certification or documentation.
PSC deficiency codes help in that.
Let us say that deficiency is related to the enhanced survey programme and PSC has provided
the deficiency code as 01315.

2022 JAMS 72
As we can see that code 013 is related to the certificates and documentation only. So our
efforts need to be only towards getting the missing document or getting any pointed error
corrected by flag state or classification society as applicable.
Another thing that we need to keep in mind is about ISM & ISPS-related detention deficiencies.
Detentions because of ISM & ISPS related deficiencies are closed only after external ISM & ISPS
audits.

Again these can be identified

by the deficiency codes.

2022 JAMS 73
2022 JAMS 74
Let me clarify the detainable deficiencies related to ISM with an example.
It is sometimes wrongly assumed that ISM related deficiency would mean deficiency
related to the paperwork or documentation.
Not always.
Let us take an example of a deficiency related to in-operational fire detectors in
accommodation.
One fire detector not working will be a code 17 deficiency. The deficiency will be under
code 07106 and this needs to be corrected before departure.

2022 JAMS 75
Two or more fire detectors not working can be a detainable deficiency as per the
professional judgment of the port state inspector.
The deficiency will again be under code 07106.
As the vessel will be detained, the PSCO will board the vessel to verify that the fire
detectors have been rectified.
Once the PSCO is satisfied, the detention order will be lifted and the ship will be allowed to
sail.
Now let us consider this final situation where say, 10 or more fire detectors are found not
But this also
working. gives to
Needless an say
impression
that thistowill
thebeport state inspector
a detainable that the
deficiency ISMdeficiency
under code is not
code
effectively
07106. implemented on board.
How?
Because had it been effective, the defective fire detectors would have been identified
during last weekly tests.
So many defective fire detectors point to the fact that the weekly routines are not being
carried as required by the SMS.
In this case, PSCO would issue a second detainable deficiency related to ISM code which
could be something like…

2022 JAMS 76
The ISM code is not effectively implemented as apparently no weekly checks on the fire
detectors are being carried out.
So one observation could lead to two detainable deficiencies.
And as I earlier mentioned, non-ISM related deficiencies need to be closed by rectifying the
noted observation or defect.
But, the ISM-related deficiencies would only be closed after a successful external ISM audit
which will be done by the flag or by classification society on behalf of the flag.

2022 JAMS 77
• Conclusion
• Over the years the port stay of the ships have reduced
drastically which gives lesser time to the ship staff to
deal with PSC deficiencies identified during PSC
inspections.
• But if we know exactly how to deal with the PSC
deficiencies, we can save a lot of time and possible
delays in close out of the deficiencies.

2022 JAMS 78
Workshop
Port State
Control
detainable
Deficiencies
• Why PSC detains?

If ship sails, will pose

threat
• Threats to?

If ship sails, will pose

threat
To
To Crew To Ship Environme
nt
 • 8 top PSC detainable
deficiencies?

If ship sails, will pose

threat
To
To Crew To Ship Environmen
t
Oil Record
Charts Engine room Book
publication
Vents, Air pipes, Hatches

Emergency Oily water

LSA Fire Damper separator
Fire Pump
• How to avoid detainable
deficiencies?
Maintenance of critical
areas
Correct cooperation with PSC
inspector
Proper
Training
If ship sails, will pose threat

To
To Crew To Ship
Environment

Oil Record
Charts Engine room Book
publication
Vents, Air pipes, Hatches

Emergency Oily water

LSA Fire Damper separator
Fire Pump
• What are critical
areas?
Maintenance of
critical areas
MARPOL
Annex I
LoadLi
If ship sails, will pose
ne SOLA threat
To
To Crew To Ship Environmen

S Charts
t
Oil Record
Engine Book
publication room
Vents, Air pipes,
Hatches
Emergency Oily water
LSA Fire
Fire Pump separator
Damper
• How to cooperate with PSC?
Maintenance of
critical areas
Correct cooperation with PSC
inspector
Prove the
ship is safe If ship sails, will pose
threat
To

Beto sail
honest
To Crew To Ship Environmen
t
Oil Record

Don’t play Charts

publication
Engine
room
Vents, Air pipes,
Book

Agames
senior
Hatches
Emergency Oily water
LSA Fire
Fire Pump separator

officer to Damper

accompany
the
inspector
• How to train myself?
Maintenance of
critical areas
Correct cooperation with PSC
inspector
Proper
training
Know the
critical areas
Know the If ship sails, will pose

fleet
threat
To
To Crew To Ship Environmen

circulars t
Oil Record

Know your
Charts Engine Book
publication room
Vents, Air pipes,

ship Emergency
LSA
Hatches

Fire
Oily water
Fire Pump separator
Damper
Mind Map
MARPOL Maintenance of
Annex I critical areas
LoadLi Correct cooperation with PSC
ne inspector
SOLA Proper
S Prove the ship training
is safe to sail

Be honest
Don’t play
games
A senior
officer to
If ship sails, will pose
accompany threat
the inspector To
To Crew To Ship Environmen
Know the t
critical areas Oil Record
Charts Engine Book
publication room
Know the fleet Vents, Air pipes,
circulars Hatches
Emergency Oily water
LSA Fire
Know your Fire Pump separator
Damper
ship
 Case Study:
Port state control inspector on board of your
ship discovers that one Engine room Fire
Damper can not be closed.

This is a detainable deficiency.

what would you do?
 Immediate corrective action

1. Get the Damper operational (prove to the inspector

the ship will be safe to sail)
2. Suspend other less important jobs if necessary
3. Let a Senior officer accompany the inspector
4. Be honest don’t play games
5. You may show to the PSC inspector previous
maintenance records
Thank you