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Analysis of MARPOL implementation based on

port state control statistics

Capt. Deepak Mantoju

To cite this article: Capt. Deepak Mantoju (2021) Analysis of MARPOL implementation based
on port state control statistics, Journal of International Maritime Safety, Environmental Affairs,
and Shipping, 5:3, 132-145, DOI: 10.1080/25725084.2021.1965281

To link to this article: https://doi.org/10.1080/25725084.2021.1965281

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JOURNAL OF INTERNATIONAL MARITIME SAFETY, ENVIRONMENTAL AFFAIRS, AND SHIPPING
2021, VOL. 5, NO. 3, 132–145
https://doi.org/10.1080/25725084.2021.1965281

Analysis of MARPOL implementation based on port state control statistics

Capt. Deepak Mantoju
B.com, MBA Pursuing (Logistics and Supply Chain Management) from the University of Petroleum and Energy Studies, Dehradun, India

ABSTRACT ARTICLE HISTORY

This research paper deals in three main sections. The first one is a brief overview of the Received 27 May 2021
International Convention for the Prevention of Pollution from Ships (MARPOL), its annexes, Accepted 27 July 2021
and regulations, followed by section two with a brief overview of the Port State Control (PSC), KEYWORDS
and lastly, the third section deals with the interpretation of data extracted from the annual MARPOL; marine pollution;
reports of the Memorandum of Understandings (MoUs) to assess the effectiveness of MARPOL. port state control;
An analysis of MARPOL related deficiencies from all nine MoU has been designed. The memorandum of
annual reports for the past 11 years have been extracted and data relating to total inspections, understanding; MoU
total deficiencies, and deficiencies with regard to the MARPOL convention, distinguished as per
annexes has been extracted and analysed using statistical tools to find out the level of
implementation of the code. The extracted data has been categorized to find out the trend
of the MARPOL-related deficiencies through the years and to find the annexes of MARPOL
with
most common and least common non-conformity.

OVERVIEW OF THE MARPOL
Background
The maritime industry has always been
internationally acclaimed, now it has turned global.
Maritime transport has been at the forefront of
globalism, with the conse- quent intimidations for
capital, working-class, and the environment (aaa
2014). With the growing rate of the shipping business
and the growing number of ships on the high seas has
subsequently placed the marine envir- onment at
great danger due to the increase in the amount of
garbage and excretions from ships, acciden- tal or
operational. One of the fundamental environmen- tal
issues faced today is the pollution of the world’s
oceans from ships.
In the past, the mammoth concern has been
the dumping or accidental discharge of bilges
containing oily water mixture, anyhow, in today’s
scenario, we face extensive dread for the impact on
marine ecosys- tems of vessels generated garbage,
sewage and other wastewater, and residues from
cargo dumped at sea (Dissertation To Ngoc Thang
2015). Vessels continue to discharge waste at sea
despite wide-ranging legisla- tion at the national as
well as the international levels, maybe it seems to
be the most convenient and cost- effective
method when it comes to disposing of unwanted
matter, it may also be of a viewpoint that the
garbage will degrade eventually. However, vessels
typically generate a variety of throwaways, which
includes organic waste, plastic, paper, glass, metal,
and hazardous waste. Items like food waste and
paper are degradable faster; whereas there are
other items which may take months or years, for
example, plastic bottles may take approximately 450
years to biodegrade as per the research data of the
Hellenic Marine Environment Protection
Association (Dissertation To Ngoc Thang 2015;
Dissertation Nguyen, Thanh Hoang 2017).
The accident of the vessel Torrey Canyon in 1967,
which ran aground and released approximately
12,000 tonnes of crude oil into the sea, raised
questions and exposed the shortcomings of the then
existing instru- ment for combating the oil polluting,
i.e., the OILPOL (International Convention for the
Prevention of Pollution of the Sea by Oil)
adopted in 1954. As a result from this accident and
to encounter any such predicaments in the future, the
IMO adopted a detailed international instrument as a
part of the maritime law to deal with the accidental
as well as operational pollu- tion of the sea and the
environment i.e., The interna- tional Convention for
the Prevention of Pollution from Ships (MARPOL
1973), as modified by the protocol of 1978, known
as MARPOL 73/78 and is updated by amendments
through the years. Sufficient number of states
ratified the convention in 1982 and it entered into
force on the 2 October 1983. The Convention
focuses on regulations to prevent and reduce
pollution caused by oil, chemical, harmful
substances, sewage, garbage, and emissions from
ships (Dissertation Nguyen, Thanh Hoang 2017).
The P&I Clubs usually covers all vessel which are
under insurance for pollution related expenses in

CONTACT Capt. Deepak Mantoju (Merchant Navy, MBA (LSCM).) deepakmantoju@gmail.com Address - plot 4, lecturer’s colony, Boduppal,
Hyderabad, Telangana, India.
© 2021 The Author(s). Published by Informa UK Limited, trading as Taylor & Francis Group.
This is an Open Access article distributed under the terms of the Creative Commons Attribution License (http://creativecommons.org/licenses/by/4.0/), which permits
unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.
 JOURNAL OF INTERNATIONAL MARITIME SAFETY, ENVIRONMENTAL AFFAIRS, AND 1
case of an accident (e.g., to clean up for preventing Table 1. List of MARPOL Annexes.
and/or minimizing pollution and other liabilities), DATE OF
ANNEXES ENTRY NUMBER OF PERCENTAGE
whereas, its noteworthy that the P & I clubs doesn’t OF THE INTO CONTRACTING OF WORLD
recover any fines arising from the violation of MARPOL. MARPOL(a) TITLE (b) FORCE (c) STATES (d) TONNAGE (e)
While complying with the MARPOL, the ANNEX I Prevention of 02/10/1983 159 98.95
pollution by
following are of paramount significance- oil
ANNEX II Control of 02/10/1983 159 98.95
●
All vessels are required to hold all original certifi- pollution by
noxious
cates onboard issued by flag states or RO, as liquid
required by the convention, stating the vessels substances
ANNEX III Prevention of 01/07/1992 149 98.40
compliance to various regulations of MARPOL. pollution by
●
Sanctioning of MARPOL violation must be under harmful
substances
the state’s law under whose flag the vessel is in packaged
flying, irrespective of geographical location of form
ANNEX IV Prevention of 27/09/2003 145 96.33
the infringement. pollution by
●
A vessel’s Master is responsible to keep all certifi- sewage from
cates onboard and bring to the notice of appro- ships
ANNEX V Prevention of 31/12/1998 154 98.56
priate department in case of renewal or pollution by
issuance of certificates, he should also be held garbage
from ships
responsible to make and submit reports in case ANNEX VI Prevention of 19/05/2005 99 96.76
of incident. air pollution
from ships

The annexes
Each annex of MARPOL sets out specific requirements
with regard to various types of pollutants covered for
vessels. The convention is divided into six annexes to
facilitate combating different kinds of pollution and
prerequisites for vessels. Table 1 shows the different
annexes along with details pertaining to the annexes.
Annex I lays down detailed regulations to deal with
the measures of prevention of pollution by oil includ-
ing regulation on as basic as definitions of oil, sludge,
tanks, etc. It stated that the rules apply to all
vessels, unless specified otherwise. Exemptions have
been granted to discharge oil into the sea in lieu of
situa- tions where it’s done to secure the safety of the
vessel or to save life at sea, discharge is case of damage
to the vessel or its machinery or discharge while
combating specific pollution incidents to minimize
the damage from pollution, approved by the
administration. Requirements related to surveys
and certification is detailed in regulations 6 through
10. Any discharge is permitted outside special areas
and arctic waters, if the vessel is en route; the mixture
is processed through an oil filtering equipment in
accordance with regulations and the oil content of
the effluent without dilution does not exceed 15
ppm. In case of tankers, not origi- nated from cargo
pump room bilges and not mixed
with oil cargo residues.
Details on segregated ballast tanks, oil tanks, dou-
ble hull, double bottom, specifications of cargo
tanks, slop tanks, discharge manifold for connection to
recep- tion facilities, piping, and pumping for
discharge into the sea are laid down as per vessels
type and size in Part A of chapter 4. The specification
of equipment for controlling and monitoring oil
discharge, oil/ water
a, b
Data extracted from MARPOL Consolidated Edition 2019 (bbb 0000)
c, d, e
data extracted from the IMO database (ccc 2021)
interface detector, requirements for crude oil washing
is dealt in Part B. Chapter 5 deals with the requirement
of carrying a Shipboard Oil Pollution Emergency plan
(SOPEP). The requisites of a reception facility, capacity,
and strategic locations where they must be provided,
within and outside special areas, are covered in
chap- ter 6.
Chapters 8 through 11 contain regulations on
STS operations, requirements on Antarctic region oil
usage and carriage, compliance verification and the
code for polar water operations.
Annex II regulates Noxious Liquid Substances (NLS)
in bulk applies to all vessels certified to carry NLS in
bulk, unless specified otherwise in any specific regula-
tion. Exceptions for discharging NLS into the sea are
same as laid down for Annex I. Exemption relating to
constructional and operational features and alterna-
tives of material or equipment are discussed in regula-
tion 4 and 5. NLS are categorized into four types.
The substances are differentiated on the basis of
evaluation of their properties in the resultant
GESAMP hazard profile. Table 2 shows the
differentiation.
Chapter 3, comprising from regulations 7 to 10,
provides insight on surveys and certification require-
ments of NLS carriers. The operational requirements
and vessel constructions of the NLS carriers shall be
in conformance with the chapter 17 of the
International Bulk Chemical Code (IBCC).
Table 3 shows the requirement of pumping and
piping equipment for each tank of NLS carriers
with
 1 D.

permitted amount of residue in the tanks and A connection for discharge piping of standard spe-
asso- ciated piping. cification must be available to connect to reception
Whenever discharge of substances under category facilities, the specification of the flanges and bolts are
X, Y or Z, ballast water, or mixtures containing such
substances is permitted in accordance with this Annex,
the vessel must be en route with a speed of at least
7 knots for self-propelled ships and 4 knots for
others, underwater discharge outlets must be
used, and at a distance of more than 12 miles and
depth over 25 meters. Discharge of any mixture
containing NLS is prohibited in the Antarctic.
A manual with operational procedures of the
NLS carriers in compliance with the Annex must be
present onboard. A cargo record book has also been
specified mandatory for such vessels. Chapter 7
requires all NLS carriers of over 150 t GT to carry
onboard a Shipboard Marine Pollution Emergency
Plan for NLS.
The provisions of adequate reception facilities at the
cargo handling terminals and repair ports are
covered in chapter 8. Compliance verification and
polar water operation code are detailed in chapters
9 and 10.
Annex III regulations are applicable to all vessel
carry- ing harmful substances in packed form, unless
specified otherwise. The carriage of harmful
substances is per- mitted only when acted in
compliance of this annex, except for ship stores and
equipment. It is also empha- sized that empty
packaging used to carry harmful sub- stance must
also be treated as harmful unless it’s clear that no
residue is present that can harm the environ- ment.
With regard to the content, adequate packing
should be provided to minimize the hazard should
be marked and labelled in accordance with the IMDG
code. These substances must be properly stowed,
in accordance with a stowage plan showing locations
of the harmful substances and a manifest of the
same must be prepared in accordance of the IMDG
code and circulated to all relevant parties involved.
Limitation of carriage of substances, when applicable,
must be exer-
cised considering vessels specifications.
These substances may only be jettisoned to
secure the safety of the vessel or to save life at sea.
Chapter 2 of the annex deals with the compliance
verification.
Annex IV regulation applies to all vessel above 400
t GT and vessels certified to carry more than 15
persons engaged in international voyages. Discharge of
sewage is exempted for securing the safety of the
vessel, saving life at sea or resulting from damage to
ship or its equipment provided that reasonable
precautions are taken at all times. Chapter 2 deals
with the requirements of survey and issuance of
certificates in relation to the Annex.
Every vessel to which the Annex is applicable shall
be equipped with an approved sewage treatment
plant, or a sewage comminuting and disinfecting sys-
tem, or an administration approved holding tank
 JOURNAL OF INTERNATIONAL MARITIME SAFETY, ENVIRONMENTAL AFFAIRS, AND 1
present in regulation 10, alternatives may be of equipment onboard must be provided to all vessels
accepted by the administration for vessels in above 100 t GT, vessel certified to carry 15 or more
dedicated trades. persons and all platforms. A garbage record
Sewage from all vessels, except passenger vessels
in special area may be discharged if it is comminuted
and disinfected at over 3 miles from nearest land
and over 12 miles when it is not comminuted and
disinfected, provided when using holding tanks,
that its discharged when vessel is en route and at
a speed of minimum 4 knots, or the vessel uses an
approved sewage treat- ment plant. Sewage
discharge from passenger vessels in special areas is
prohibited except when an approved and certified
sewage treatment plant is operational.
The parties to the convention have the obligation
to provide adequate reception facilities at
operational as well as repair terminal to receive
sewage from vessels without any unnecessary
delay. Compliance verifica- tion and polar water
operation code are detailed in chapters 6 and 7
respectively.
Annex V regulates the garbage prevention of
pollu- tion from ship-generated garbage;
regulations of this Annex are applicable to all
vessels unless expressly stated otherwise. The
acceptable discharge of garbage outside special
areas is comminuted or grinded food waste,
capable of passing through a 25 mm opening
screen at over 3 miles from nearest land, 12
miles otherwise. Non harmful cargo residue which
cannot be recovered using common unloading
methods may be discharged at 12 miles from
nearest land. Animal carcasses may be dumped at
sea, provided it’s done as far as practicable from
the nearest land, as per the guidelines.
Garbage discharges from any kind of platforms
or vessels alongside or at 500 m radius are
prohibited. Only comminuted or grinded food
waste capable of passing through a 25 mm
opening screen is allowed to be discharged by
platforms and vessels around it if the platform is
located at more than 12 miles from the nearest
land. In special areas, food waste that has not
been contaminated by any other garbage type
and comminuted or grinded, capable of passing
through a 25 mm opening screen is allowed to be
discharged at
12 miles or more from nearest land or ice shelf.
Antarctic areas prohibit discharge of avian
products, including poultry, unless made sterile.
Conditions for discharge of cargo residue in special
areas are detailed in regulation 6.
Governments of parties are liable to provide
ade- quate reception facilities for discharge of
garbage at terminals without causing undue delay
to the vessels. Garbage discharge requirements
in accordance with this Annex must be posted via
placards in appro- priate languages on all vessels
of length 12 m or more. A garbage management
plan based on appropriate guidelines with
procedures for garbage related activ- ities and use
 1 D.

book must be provided to every vessel of 400 t

prohibited. Fuel oil quality requirements are given in
GT, vessel certified to carry 15 or more persons
regulation 18. Chapter 4 deals with the energy effi-
and all platforms. Entries to be made in the record
ciency on ships, which applies to all vessels above
book are mentioned in regulation 10.3. Compliance
400 t GT. Exemptions are made for vessels
verification and polar water operation code are
engaged in voyages only in the jurisdiction of the
detailed in chap- ters 2 and 3 respectively.
flag state, provided alternate measures are taken by
Annex VI regulates the Air pollution prevention
the admin- istration and for ships not using
from ships. Regulations of this Annex are applicable
mechanical means of propulsion and platforms.
to all vessels unless expressly stated otherwise.
Every vessel must have a Ship Energy Efficiency
Emissions are exempted for securing the safety of the
Management Plan (SEEMP) specific to each vessel.
vessel, sav- ing life at sea or resulting from
The energy efficiency of a vessel can be estimated
unintentional damage to ship or its equipment
by calculating the attained Energy efficiency Design
provided that reasonable precau- tions are taken at all
Index (EEDI). The process of calculation and
times. Exemptions are also made for emissions with
information required for calculating must be
regard to exploring, exploiting and pro- cessing
accompanied in an EEDI technical file onboard.
seabed mineral resources. Chapter 2 deals with the
Attained EEDI ≤ Required EEDI = (1- X/100) x
requirements of survey and issuance of IAPP, IECC,
refer- ence line value
and statement of compliance related to fuel oil con-
Where “X” is the reduction factor, values for
sumption certificates in relation to the Annex.
same are specified in regulation 21.2
Deliberate emissions of Ozone Depleting
The calculation of the reference line value is also
Substances (ODS) from a system or equipment occur-
specified clearly in regulation 21.3. Chapter 5 deals
ring in the course of maintaining, servicing, repairing
with the compliance verification.
or disposing are prohibited.
Installations containing ODS, other than Hydro-
chlorofluorocarbons (HCFC’s) shall be prohibited on Implementation
vessels constructed on or after 19 May 2005, and
Referred from Table 1, it’s clear that the convention
Installation containing HCFC’s shall be prohibited on
has application globally. Nguyen Hoang Thang
vessels constructed on or after 1 January 2020.
(2017) states that “Ratification and implementation
Every vessel must maintain a list of ODS
of inter- national treaties related to marine
containing equipment and maintain ODS record book
environmental pro- tection, safety, and security aspects
if recharge- able systems containing ODS are present
are one of the best solutions to overcome marine
onboard. Any such equipment or ODS, when removed
pollution (Dissertation Nguyen, Thanh Hoang
from the ves- sel, must be delivered to a reception
2017),” but when it comes to implementation, it
facility. The reg- ulation with regard to emission of
gets tricky. Firstly, the ample high seas with no
Nitrogen Oxides (NOx) applies to marine diesel
jurisdiction or ways of monitoring gives the vessels
engines installed onboard with over 130 kW power
involved in illegal dumping great scope to carry out
output or an engine with same specification but has
their illicit activities. Secondly, in case of any evidence
undergone major con- version on or after 1 January
of violation, MARPOL does not give the power to a
2000. The regulation does not apply to lifeboat
state to take direct action against such violations;
engines, a marine diesel engine used directly or to
the state is expected to report the same to the flag
power any other equipment, with an intention to be
state of the vessel (MARPOL, Art III(3)). The flag state
utilized only for emergencies, or a vessel
then have the liability to investigate and take
engaged in voyages only in the jurisdiction of the
appropriate actions accordingly. Here, the flag of con-
flag state, provided alternate measures are taken by
venience (FOC), using this loophole to increase their
the administration.
business, might delays investigation or completely
The sulphur content of fuel oil used in marine
turn a blind eye towards such violations from vessels
diesel engines onboard must not exceed 0.50 % m/
flying their flag. For ship-owners the FOC provides
m on or after 1 January 2020, and 0.10 % m/m on or
many alluring benefits, one of which is slack on expen-
after 1 January 2015 in Emission Control Area. If emis-
diture related to environmental standards (Akpama
sions on volatile Organic Compounds (VOC) from tan-
and Ofem 2017). Thirdly, the provision and
ker are to be regulated; it should be in accordance
utilization of the reception facilities in terminals are
of Regulation 15 of this Annex. Provisions
of utmost significance in achieving the MARPOL’s
regarding shipboard incineration are provided in
goal of eradi- cating pollution of the oceans from the
regulation 16. Incineration of cargo residues with
shipping indus- try, as far as practicable. For this
regard to sub- stances covered in Annex I, II, III,
objective to come true there is need to provide
polychlorinated biphenyls (PCBs), garbage with more
mariners with means of dis- posing waste from
than traces of heavy metal, sewage sludge and
ships. According to MARPOL Annexes, the
sludge oil, petro- leum products containing
terminal’s reception facilities must be adequate,
halogen compounds and residues from exhaust
according to the traffic density at the
gas cleaning system is
 JOURNAL OF INTERNATIONAL MARITIME SAFETY, ENVIRONMENTAL AFFAIRS, AND 1
terminal, and operate without causing unnecessary Table 2. Categories of NLS.
delays to the vessels (Online document, MEPC. iicirc. Categories of Potential
NLS hazard Discharge limitations
671, 2009). But, the provision of waste reception facil-
Category X Poses a major Discharge prohibited
ities at terminals is still an issue at many ports even hazard
after decades of implementation of the convention. In Category Y Poses Limitation on quality and quantity of
a hazard discharge permitted
my personal experience in 2017, was a declined port Category Z Poses a minor Less stringent regulations
reception facility at a Malaysian port after a voyage hazard
of five days; same has been a case in a port of Other Poses no No restrictions
substances hazard
Indonesia as well in 2013. (OS)

Flag States and the recognised organisation, for e.g., forced to complete its
classification societies play the most significant
factor in making the vessel-owners complying with
interna- tional regulations. The concerned
authorities must carry out surveys to make sure that
the prerequisites of the conventions are complies
with. The vessel own- ers and operators ultimately
hold the responsibility for the seaworthiness of their
vessels. They are the one who needs to step up and
make sure that their vessels and the equipment
onboard are always in compliance with the codes
and conventions of the IMO because the flag states
only inspects the vessels once a year and its very likely
that the vessel transits in local regions or regions
where port state is not strict, in this case the vessels
seaworthiness and compliance to regulations totally
depends on the owners mindset towards the safety
of the crew and environment. As the gist of the
business is to make money, and compliance to
regula- tions required spending of funds, a lot of
ship-owners, who are not forced to comply, chooses
to turn a blind eye until next inspection, causing
substandard ships to ply the oceans.

MEMORANDUM OF UNDERSTANDING ON
PORT STATE CONTROL
PSC is an inspection regime to eradicate substandard
shipping, the flag state of a vessel is primarily
respon- sible for making sure that a vessel under
their flag is seaworthy and complies with the
provisions of all international conventions. If the
flag states carry out their jobs flawlessly, there isn’t a
need of PSC at all, but in the real world, that isn’t the
case. Of course, there are many sub standard ships on
the sea, posing danger to life, property and the
environment. PSC acts as a safety net to catch these
sub standard ships and make the shipping industry
safer for all parties involved. Then again, there are
millions of ships, hundreds of them berthing and un-
berthing at a given day on each port, the inevitable
question arises, how can we inspect all these ships.
Even if we could, how much time will it consume and
cause tremendous delay to the vessels.
The PSC inspections differ from that conducted by
flag States or RO. The surveyors of the latter indulge in
surveys to issue the statutory certificates for a
vessel, which might be done at a rendezvous port
and time finalised by the vessel owner’s and
surveyors consent. On the other hand, the PSC is
 1 D.
Source: Author, data interpreted from MARPOL chapter 2, regulation 6.

Table 3. Permitted quantity of residue in the tanks and

asso- ciated piping (litres).
PERMITTED QUANTITY
OF
RESIDUE (litres)
Category X Category
VESSEL CONSTRUCTION or Y Z
Before 1 July 1986 300 900
After 1 July 1986, Before 100 300
1 January 2017
After 1 January 2017 75 75
Source: Author, data interpreted from MARPOL chapter 4, regulation 11.

inspection in the time the vessel is berthed at the

port, without causing unnecessary delay to the
vessel. Another prime difference is that the flag
state’s inspec- tions are at owner’s request,
whereas PSC inspections are not a requirement
for the owners to run their vessels, but a
catalyst to motivate owners to keep their
vessels deficiency free.
Some vessels today faces detention for trivial
non conformities, this may be caused due to the
lack of judgment on the part of PSC officers. For the
PSC to be bloom further, its resources should be
unanimously focused below par ships, in such a
way that it would be unsustainable for below
standard ships and their operators.
The Paris and Tokyo MOU, with a far superior
administration with respect to other MoU’s was
able to achieve better cooperation and
synchronisation of members and data exchange
within areas covered under their jurisdiction
which cannot be said for other MoU’s
Efficient PSC involuntarily forces the vessel
opera- tors to uphold the standards of their vessels
because if not, there is always the dread of their
vessel’s deten- tion lurking. It also assists to
encourage the safety of life at sea, property, and
the environment, and achieves its primary
objective to seize below standard non-compliant
vessels.
In its wake, it also exposes certain flag states
which render unsuccessful in implementing
required stan- dards as per the IMO, and forces
such vessels to ports in regions where the PSC
inspections are less frequent or less vigorous. The
overall objective of PSC will take a hit if these
unscrupulous keep transiting in other parts of
the world, so it is of significance that all the
regional MoU’s have a solid administrations
and
 JOURNAL OF INTERNATIONAL MARITIME SAFETY, ENVIRONMENTAL AFFAIRS, AND 1
resources to carry out their job effectively and states.
efficiently.
Most of the resources we have at our disposal
are limited, PSC inspectors are the same. They can
only inspect a limited number of ships at a given
time and this gives scope to sub standard ship to
continue causing harm to life, capital and
environment. To tackle these problems, the IMO
adopted Resolution A.682 (17) on regional
cooperation to promote regio- nal agreements on
control of vessels. Regional Memorandum of
Understanding (MoU) were formed to achieve
harmonization of PSC surveys, backed by IMO in
resolutions A.787 (19) as amended in resolution A.882
(21) (DOIYuan, Chiu, and Cai 2020). Hence, it can be
concluded that the PSC acts to put a check on
unseaworthy vessels transiting the high seas, and to
make sure that entering ports in their region are
com- plying with the international regulation set
forth by the IMO under various codes and
conventions.
At present, the following nine MOUs cover
virtually all seas of the world:

(a) Paris MoU, 1982 – Fourteen European coun-

tries entered into the Paris MoU, signed in
January 1982 and entered into force on
1 July 1982. The MoU was the result of
grounding of the VLCC Amoco Cardiz, causing
a massive oil spill of the coast of Brittany,
France. Due to the public and political outcry
caused as the effect of the accident for string-
iest regulations for the safety of the shipping
industry, a comprehensive MoU covering
SOLAS, pollution prevention and working
and living conditions (WLC) onboard vessels
came into existence instead of the “Hague
memorandum” which would have came into
effect in march 1978 covering the WLC
onboard.Over the years, the organisation has
expanded to 27 member states.
(b) Acuerdo de Viña del Mar, 1992 – several
other MoU’s were signed modelled on the
Paris MoU, the first one of which was the
Acuerdo de Viña del Mar. it was signed in
1992 and covers the region of south and
Central America. Currently the organisation
has 14 member states.
(c) Tokyo MoU, 1993 – The Memorandum on PSC in
the Asia-Pacific region was initially signed by
eighteen (18) states of the region in Tokyo
on
1 December 1993 and came into effect on
1 April 1994. Currently, the Memorandum has
21 full members.
(d) Caribbean MoU, 1996 – The CMOU was con-
cluded by the Maritime Administrations of
an initial nine countries in Christ Church,
Barbados on 9 February 1996. The Membership
has since grown to twenty (20) Member
 D.
1 (e) Mediterranean MoU, 1997 – Initially, eight flags, member states and classification societies. A
coun- tries signed the MoU on PSC in the differentiation based on the type of defi- ciencies is
Mediterranean region on 11 July 1997 at also reported, for the purpose of this
Valletta, Malta. The agreement was set in
the course of a couple of conferences
arranged at Tunisia and Casablanca,
Morocco in March and December 1996
respectively. Presently, the MoU has 10 full
members.
(f) Indian Ocean MoU, 1998 -The IOMOU on PSC
in the Indian Ocean region was finalized
on the basis of the first preparatory
meeting held in India in October 1997 and
the second meeting in June 1998 in South
Africa. As of December 2019, 20 countries
have become par- ties to the
memorandum.
(g) Abuja MoU, 1999 – On 22 October 1999,
the MoU on PSC was signed by sixteen (16)
coun- tries of Africa (western and
central). As of December 2019, 17
countries have become par- ties to the
memorandum.
(h) Black Sea MoU, 2000 – The MoU on PSC in
the Black Sea Region (BS MOU) was
completed and signed in Istanbul, Turkey
on 7 April 2000. Initially, As of December
2019, 06 countries have become parties to
the memorandum.
(i) Riyadh MoU, 2005- the Riyadh MoU on PSC
in the Gulf Cooperation Council (GCC)
region was signed in June 2004 in Riyadh,
Kingdom of Saudi Arabia by six GCC
member States.

Interpretation of data from annual reports

of all nine MoU’s
An analysis of all nine MoUs were carried out
based on the number of member states and the
number of defi- ciencies reported by them,
Abuja MoU and the Caribbean MoU were found to
have comparatively very less number of MARPOL
deficiencies, but to maintain an higher accuracy of
the data interpreted, both these MoUs were also
taken into consideration for analysis. Inspections
carried out and published by the US coast guard
are not comparable with the other MoU’s annual
reports, so, it has not been included in this analysis.
The data collected are from the annual reports
of each MoU from the period 2009 to 2019; these
annual reports are publicly available on the
respective MoU websites (Paris MoU 2021; Indian
Ocean MoU 2021; Tokyo MoU 2021; Riyadh MoU
2021; Abuja MoU 2021; Black Sea MoU 2021;
Caribbean MoU 2021; Mediterranean MoU 2021;
Acuerdo Viña Del Mar 2021). These annual
reports provide a vivid description of all the
inspections carried out, deten- tions, deficiencies
reported amongst others. The reports also
distinguish between the types of vessels inspected,
 JOURNAL OF INTERNATIONAL MARITIME SAFETY, ENVIRONMENTAL AFFAIRS, AND
analysis, the deficiencies related to all annexes of
MARPOL and related to operational deficiencies of
MARPOL for the years 2009–2019 are extracted and
interpolated to achieve the result of the analysis.
Data on number of inspections and total number
of deficiencies have also been extrapolated for the
same period for analysis.
The following variables have been used for
analysis; total number of inspections, total
deficiencies, annually reported MARPOL deficiencies,
Annex I, II, III, IV, V, VI deficiencies, percentage of
MARPOL related deficiencies.
Results
The following data is missing in the Annual
Reports of the MoU’s-
Number of inspections for year 2009, number of
deficiencies for Riyadh MoU for years 2009–2011.For
Abuja and Riyadh MoU, the MARPOL related
deficiencies were not reported separately for years
2009–2011. For Mediterranean MoU, MARPOL
deficiencies per annexes were not reported
separately in the reports, where as the cumulative
MARPOL deficiencies are accounted.
Assessment related to inspections and deficiencies
Figure 1 gives a detailed overview on the total number
of inspections carried out by respective MoU’s.From
periods 2009 to 2019, in terms of total inspection
carried, seven of nine MoU’s has recorded an
increase in numbers, Black Sea MoU has seen an
25.6 % incre- ment, Riyadh MoU (341 %), Tokyo MoU
(35.7 %), Abuja MoU (37 %), Indian Ocean MoU (10.4
%), Acuerdo Viña Del Mar (27.5 %), Caribbean MoU
(26.3 %), where as Mediterranean MoU showed an
decline in inspection worth 23 % and the Paris
MoU recorded inspections over 24,000 for years
2009 and 2010, after which the number hovered at
an average of 18,000, which accounts for a decline
of 25.9 % in the numbers.
The inspection numbers of MoU’s other than Paris
and Tokyo MOU’s are comparatively very low. More
distinctly, Caribbean, Abuja and Riyadh MoU’s record
of inspections are on the lower side with just 782, 2695
and 3207 inspections respectively. Another note-
worthy point is that the inspections of all the
MoU’s are fairly consistent, which can lead to an
assumption that not much efforts have been made to
increase the frequency of the inspections by MoU’s
with very low numbers.
Figure 2 depicts the number of deficiencies
reported by each of the nine MoU’s as a result of
inspections carried out under Figure 1. Six of the
nine MoU’s have registered a decline in the
number of deficiencies, in spite of an average
increase in the number of inspection carried out,
which can in fact be interpreted as increase in
compliance with the international instruments and
maritime law. Riyadh, Abuja and Caribbean MoU
has recorded an spike in
1
the number of deficiencies in comparison to 2009,
but its noteworthy that all three of these MoU’s have
very low rate of inspections and deficiencies to start
with in 2009, and numbers have not relatively increased
in the 11 years period.
In terms of percentage, Acuerdo Viña del Mar and
Mediterranean MoU’s registered a decline in
deficien- cies of over fifty percent, 77.5 % and
60.5 % respec- tively. Others registering decline are
the Paris MoU (44.5 %), Indian Ocean (37%), Tokyo
MoU (15.5 %) and Black Sea MoU (15.1 %).
Even though the Riyadh, Abuja and Caribbean
MoU’s has the least recorded number of deficiencies,
but these MoU’s has seen an increase in the
numbers. Riyadh MoU has specifically seen an
exceptional spike of 192 % since 2012 in terms of
percentage, but the number of deficiencies are just
2713 in 2019, whereas Caribbean and Abuja MoU's
has recorded an incre- ment of 79 % and 5.2 %
respectively.
MARPOL related deficiencies
The number of deficiencies reported by each MoU for
the periods 2009–2019 has been extracted from
the annual reports and tabulated in Table 4,
differentiated by the deficiencies reported per
annex, per year and per MoU. Referring to Table 4,
Riyadh and Abuja MoU’s have not reported MARPOL
related deficiencies sepa- rately from 2009–2011,
whereas Mediterranean MoU has furnished cumulative
data related to MARPOL defi- ciencies but has not
differentiated the deficiencies on the basis of
annexes.
The number of deficiencies reported each year is
depicted as the percentage of total deficiencies in
Figures 3 and 4. To reduce the clumsiness and for
the ease of understanding, the data is interpreted in
two figures instead of one. Figure 3 shows the
data for Indian, Riyadh, Tokyo, Black Sea and
Acuerdo Viña del Mar MoU’s, whereas Caribbean,
Paris, Abuja and Mediterranean MoU data is shown
in Figure 4. For the purpose of this analysis, both
Figures 3 and 4 should be read together.
The Indian Ocean MoU registered constancy in the
MARPOL deficiencies since 2009 in terms of percen-
tage of total deficiencies, reporting 1091
deficiencies in 2009 and 668 deficiencies in
2019, registering a 38.8 % reduction in
deficiencies. The Riyadh MoU didn’t furnish data on
MARPOL deficiencies separately for the years 2009–
2011, even though the number of total deficiencies
and MARPOL deficiencies (just 82 in 2009 and 187 in
2019) are very low but saw an increase of 128 %,
the percentage of MARPOL defi- ciencies was
steadily reducing except the spike in 2016.
The Tokyo MoU and Black Sea MoU also showed
a steady reduction in the number of MARPOL
 1 D.

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

4805
4929
4657
4607
5080
Black Sea 5092
4997
MoU 5066
5112
5214
6036
727
2047
3607
3357
3508
Riyadh MoU 3859
4165
3381
3104
3214
3207
6993
6783
6225
5645

Mediterranean MoU 4698

5049
5740
5312
5200
5345
5380
23116
25762
28627
30929
Tokyo MoU 31018
30405
31407
31678
31315
31589
31372

1966
1483
2074
Abuja MoU 3211
2916
2348
1922
2074
2409
2695
5383
5513
5550
5051
indian Ocean MoU 5320
6059
6253
6010
5674
5697
5943
24186
24058
19058
18308
17687
Paris MoU 18447
17878
17845
17925
17955
17908
7267
8584
8841
8946
9088
Acuerdo vina del mar 9366
8860
8517
9499
9661
9267
619
815
615
645
994
Caribbean MoU 836
867
859
769
635
782

0 5000 10000 15000 20000 25000 30000 35000

Figure 1. Graphical representation of annual inspections carried out by all nine MoUs in the past 11 years.

deficiencies, registering a 31.5 % reduction in numbers

respectively, whereas the Caribbean and Abuja
for Tokyo MoU (7348 and 5034 deficiencies in 2009
MoU’s recorded an increment of 117.2% and 63.6%
and 2019 respectively) and 49.3% less deficiencies
respectively.
for Black Sea.
The Acuerdo Viña Del Mar showed a constant
incre- ment from 2009 to 2012, the saw a fall in The trend of MARPOL deficiencies
2013 and continued to rise until 2018, finally falling
The overall deficiencies recorded by all the MoUs as
by 28.5 % from 2018
a percentage of total deficiencies recorded by all the
The Paris and Mediterranean MoU registered
MoU’s are calculated to find the overall trend of the
and reduction in MARPOL deficiencies by 22.1% and
MARPOL deficiencies found by PSC around the globe.
66.5%
 JOURNAL OF INTERNATIONAL MARITIME SAFETY, ENVIRONMENTAL AFFAIRS, AND 1
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

22885
21464
19255
17926
Black Sea MoU 19022
19168
18094
18266
21006
21450
19422
927
813
Riyadh MoU 790
906
822
2687
2095
2713 26891
23144
22315
19120
Mediterranean MoU 15392
15092
15823
13585
12786
11304 86820
10635 90177
103549
100330
86560 95263
Tokyo MoU
83606
76108 81271
73441
73393
684
333
384
498
Abuja MoU 609
528
642
587
727 17387
719 16807
19224
14950
indian Ocean MoU 13770
16856
14907
14830
13099
11847 71911
10960 64698
50738
49261
49074
Paris MoU 46224
41820
41915
40871
40428
22176
39847
20941
13315 23227
5996
Acuerdo vina del mar 6631
5161
4612
4774
5365
4997
573
436
1193
Caribbean MoU 1516
1746
1587
2047
1453
1321
0 1186 20000 40000 60000 80000 100000 120000
1027

Figure 2. Graphical representation of annually reported deficiencies by all nine MoUs in the past 11 years.

Figure 5 shows the results. The result shows fluctua-
tions from 2009 to 2013. From 2014 onwards it
remained consistent around 5.3 % until 2017. It
recorded a slight increment in 2018, rising to
6.77% and fell down to 5.77% in 2019.
Deficiencies breakdown on the basis of MARPOL
annexes
The MARPOL is divided into different annexes from I to
VI with each one specifying a type of pollution and
regulations related to it are penned down as
discussed
 1 D.

Table 4. Table depicting deficiencies recorded as per Annexes of MARPOL 73/78 by all nine MoUs in the past 11 years.
MARPOL RELATED YEAR YEAR YEAR YEAR YEAR YEAR YEAR YEAR YEAR YEAR YEAR
DEFICIENCIES 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 TOTAL
BLACK SEA MoU
Annex I 876 678 161 261 256 285 251 293 359 256 236 3912
Annex II 04 10 01 08 12 11 03 11 01 04 00 65
Annex III 03 07 11 06 05 03 06 06 08 13 09 77
Annex IV 64 81 71 65 69 69 73 52 67 55 56 722
Annex V 102 103 90 73 308 214 200 178 279 312 233 2092
Annex VI 07 16 67 56 77 24 18 19 22 83 43 432
Other (a) 116 77 00 00 00 00 00 00 00 00 00 193
TOTAL 1172 972 401 469 727 606 551 559 736 723 577 7493
RIYADH MoU
Annex I - - - 74 53 36 30 37 80 70 111 491
Annex II - - - 01 00 00 00 01 03 00 01 6
Annex III - - - 00 00 00 01 01 01 01 01 5
Annex IV - - - 02 09 09 07 04 37 21 19 108
Annex V - - - 05 08 08 10 09 39 36 38 153
Annex VI - - - 00 00 00 00 00 02 01 17 20
Other (a) - - - 00 00 05 00 81 00 00 00 86
TOTAL - - - 82 70 58 48 133 162 129 187 869
MEDITERRANEAN MoU
Annex I - - - - - - - - - - - -
Annex II - - - - - - - - - - - -
Annex III - - - - - - - - - - - -
Annex IV - - - - - - - - - - - -
Annex V - - - - - - - - - - - -
Annex VI - - - - - - - - - - - -
Other (a) - - - - - - - - - - - -
TOTAL 1276 1128 1188 500 674 495 300 414 510 536 427 7448
TOKYO MoU
Annex I 4452 4403 5643 2335 2037 1679 1607 1609 1468 1508 1514 28,255
Annex II 64 47 53 27 40 13 17 25 30 16 25 357
Annex III 12 92 37 17 14 33 30 12 10 13 10 280
Annex IV 727 879 996 1013 1070 1199 1301 1199 1131 1256 1350 12,121
Annex V 1341 1336 1580 981 2618 1587 1252 1162 1014 1673 1181 15,725
Annex VI 312 508 680 796 915 758 847 845 886 1623 954 9124
Other (a) 440 477 501 00 0 00 00 00 00 00 00 1418
TOTAL 7348 7742 9490 5169 6694 5269 5054 4852 4539 6089 5034 67,280
ABUJA MoU
Annex I - - - 08 20 26 16 24 25 25 12 156
Annex II - - - 00 00 00 00 00 00 00 01 1
Annex III - - - 03 00 02 00 00 01 01 01 8
Annex IV - - - 03 00 00 01 03 02 12 15 36
Annex V - - - 04 04 07 04 03 02 12 06 42
Annex VI - - - 04 00 02 02 02 00 01 01 12
Other (a) - - - 00 00 00 00 00 00 00 00 0
TOTAL - - - 22 24 37 23 32 30 51 36 255
INDIAN OCEAN MoU
Annex I 678 621 514 314 291 283 368 327 255 299 288 4238
Annex II 10 09 03 06 02 00 00 02 01 04 00 37
Annex III 01 07 07 02 03 10 00 01 02 01 01 35
Annex IV 120 112 239 198 205 293 319 299 245 201 173 2404
Annex V 186 229 158 140 247 204 197 174 157 197 163 2052
Annex VI 08 16 43 66 58 110 84 117 81 121 43 747
Contd. Table 04
Other (a) 88 74 00 00 00 00 00 00 00 00 00 162
TOTAL 1091 1068 964 726 806 900 968 920 741 823 668 9675
PARIS MoU
Annex I 3764 1586 1318 1127 1060 875 810 708 642 604 561 13,055
Annex II 85 14 36 29 30 27 16 16 14 12 16 295
Annex III 13 08 18 12 09 04 05 04 10 05 08 96
Annex IV 265 298 253 324 341 346 338 336 368 326 357 3552
Annex V 764 402 347 303 889 598 609 551 470 762 587 6282
Annex VI 146 293 358 449 492 459 471 428 426 693 524 4739
Other (a) 213 00 00 00 00 00 00 00 00 00 00 213
TOTAL 5250 2601 2330 2244 2821 2309 2249 2043 1930 2402 2053 28,232
ACUERDO VINA DEL MAR
Annex I 1110 1166 1351 795 141 - - 112 157 140 149 5121
Annex II 30 22 27 11 01 - - 00 02 00 01 94
Annex III 00 00 00 04 00 - - 01 01 01 00 7
Annex IV 63 54 40 28 17 - - 30 38 48 24 342
Annex V 392 239 504 379 301 - - 283 271 316 162 2847
Annex VI 00 00 00 00 51 - - 29 42 52 62 236
Other (a) 168 235 455 223 00 - - 00 00 00 00 1081
TOTAL 1763 1716 2377 1440 511 566 450 455 511 557 398 10,744
(Continued)
 JOURNAL OF INTERNATIONAL MARITIME SAFETY, ENVIRONMENTAL AFFAIRS, AND 1
Table 4. (Continued).
MARPOL RELATED YEAR YEAR YEAR YEAR YEAR YEAR YEAR YEAR YEAR YEAR YEAR
DEFICIENCIES 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 TOTAL
CARIBBEAN MoU
Annex I 25 15 44 87 103 - 48 26 29 23 21 421
Annex II 00 00 00 00 00 - 00 00 00 00 00 0
Annex III 00 01 01 00 00 - 00 00 00 01 00 3
Annex IV 01 00 10 13 21 - 19 22 19 23 34 162
Annex V 01 04 09 02 45 - 16 13 11 10 06 117
Annex VI 02 00 00 00 00 - 06 04 02 02 01 17
Other (a) 00 00 05 00 12 - 00 02 02 01 01 23
TOTAL 29 20 69 102 181 74 89 67 63 60 63 817
GRAND TOTAL 17,929 15,247 16,819 10,754 12,508 10,314 9732 9475 9222 11,370 9443 132,813
(a) MARPOL related operational deficienciesSource: Author, data extracted from annual reports of respective MoU’s from 2009 to 2019

18%

16% 16.18%

14%

12%
10.70%
10.23% 10.81%
10% 10.38%

9.16% 8.71% 9.86%

8.46% 8.58% 8.60% 8.54%
8% 8.83%
8.50% 8.29% 7.96%
8.19%
7.95% 7.34%
7.02% 6.49% 6.94% 6.85%

6.27% 6.20% 6.03% 6.89%

6.35% 6.08%
6% 5.15% 6.04% 5.97% 5.96% 6.15% 6.09%
5.01% 5.85% 5.33%
5.65%
5.30%
5.12% 4.52% 4.85%
4% 3.82%
3.50% 2.97%
3.37%
2.61% 3.16% 3.04% 3.06%
2%
2.08%

0%
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Indian Ocean MoU Riyadh MoU Tokyo MoU Black Sea MoU Acuerdo De Vinan del mar

Figure 3. Annually reported MARPOL 73/78 related deficiencies as a percentage of total deficiencies reported (MoU’s 1 to 5).

12%

10.36%
10%

8%
7.30%
6.72% 7.01%

5.78% 5.74%6.07%
5.73%
6% 6.13%
5.11% 5.94%
5.06% 5.32% 4.87% 5.05%
4.87% 4.99% 5.37% 4.72%
4.58% 4.81% 4.35% 4.61% 4.76% 5.15%
4.74% 4.02% 4.98% 4.74% 5.00%
4.59% 4.66%
4.55%
4.34%
4% 4.37% 3.98% 4.01%

3.27%3.24%
3.04%
2.61%

2%

0%
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Caribbean MoU Paris MoU Abuja MoU Mediterranean MoU

Figure 4. Annually reported MARPOL 73/78 related deficiencies as a percentage of total deficiencies reported (MoUs 6–9).
 1 D.

8%
7.21% 6.77%
7.01%
6.39% 6.20%
6% 5.77%
5.32%
4.93% 5.33%5.32%5.34%

4%

2%

0%
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Trend of MARPOL deficiencies anually

Figure 5. Trend of MARPOL 73/78 deficiencies annually (including all nine MoU’s).

in part one of this study. The annexes are updated with
new regulations or the present regulations are
updated as new technology and chances of non com-
pliance comes into limelight.
The total MARPOL related deficiencies recorded in
the past 11 years can be differentiated into the follow-
ing categories: deficiencies relating to Annex I, II, III,
IV, V,VI, operational deficiencies and uncategorized
defi- ciencies (some of the annual reports have not
differ- entiated the deficiencies according to the
annexes, which have been analysed under
uncategorized defi- ciencies). Figure 6 shows the
illustration.
The results are fascinating as almost half of the
deficiencies (41.9 %) are attributed to annex I of
MARPOL, the numbers are high for annex I not just
because it is the oldest one but also due to its
wide- spread applicability, and the recent years
have also seen the numbers high on Annex I’s side.
So, it’s evi- dent that tackling vessel’s and
equipment’s non com- pliance on Annex I will
reduce the MARPOL related deficiencies by a great
deal.
Annex V follows next with a share of 22.07%,
fol- lowed by annex IV and VI with 14.64% and
11.54% respectively, whereas annex II and III just
attributed to 0.64% and 0.38% respectively.
2.39% of deficiencies are related to operational defi-
ciencies and uncategorised deficiencies add up
to 6.43%.

Uncategorized
deficiencies
Other MARPOL
6.43%
related operational
deficiencies
2.39%
Annex VI
Annex I
11.54%
41.90%

Annex V
22.07%

Annex IV
14.64%
Annex II
0.64%
Annex III
0.38%
Annex I Annex II
Annex III Annex IV
Annex V Annex VI
Other MARPOL related operational deficiencies Uncategorized deficiencies

Share of MARPOL 73/78 deficiencies by Annexes in the past 11 years

Figure 6. Share of MARPOL deficiencies by annexes. Source: Author, data extracted from annual reports of respective MoU’s from
2009 to 2019
 JOURNAL OF INTERNATIONAL MARITIME SAFETY, ENVIRONMENTAL AFFAIRS, AND
I reckon that deficiencies related to annex VI of
MARPOL would soon see a spike in the recent
future as the sulphur cap requirements (maximum
limit of sulphur in the vessel’s fuel oil) have entered
into force on 1 January 2020. Because of the lack of
data for the same, the new regulation’s effects on
deficiencies caused at PSC inspections are yet to be
determined.
CONCLUSION
The mankind pivots around the oceans, not just for the
transportation but with over 70% of oxygen
generated in the oceans and for its ecological effects,
the oceans are of utmost importance. Now, the
oceans are con- stantly polluted by land based
facilities and the ships every day, changing the
ecology and habitat of many sea creatures and in
turn affecting human kind in the long run.
The oceans are being polluted by various sources,
amongst which, a significant hand is also played by
the vessels transiting the oceans for transportation. As
the maritime industry is involved in pollutions, it’s
also obligated to clean up after itself. To tackle the
marine pollution from vessels, the IMO and the local
authori- ties has in place various conventions and
legislations, but all the preparations to tackle a
problem in the ends depends on the level of
implementation. With vessels transiting in the high
seas, away from prying eyes, it’s difficult to keep
such unscrupulous activities in check. Nevertheless,
there are ways to see the compliance of vessels to
convention directed to reduce the pollution of
natural resources.
Before conducting this research, with the sea
experience I have and all I have witnessed at the
high seas hypothesised that there is a lot of non
compliance in regard to MARPOL and its annexes.
The PSC is of course one of the primary
instruments to conclude the marine sector’s
compliance with the necessary conventions. The
data extracted from the annual reports of all the
MoU’s has pitched against the author’s hypothesis
and an overall reducing trend of deficiencies has
been found in the analysis. This could either direct
that the marine industry has indeed succeeded in
combating the pollution or the vessel operators
have found a way around PSC inspections.
I would have concluded that we are moving
towards a trend of reducing the pollution as pre-
scribed in MARPOL, if the data from all the MoU’s
were consistent. But areas under MoU’s like Abuja
and Riyadh have reported very less number of
MARPOL-related deficiencies, just 36 and 187
MARPOL related deficiencies for Abuja and Riyadh
MoU’s respectively for the year 2019. It’s evident
that both these regions are not conducting enough
inspections and the inspections being conducted are
vigorous enough.
1
The PSC inspections need to step up a notch in
regard to MARPOL compliance to make the oceans
cleaner. It can anyhow be concluded from the
analysis that Annex I and V are the most non
compliant regions to work on for the maritime
sector.
A scope for further study persists as the data from
PSC also is not enough for concluding strongly in the
positive direction. Seafarers are the last link to
implement positive compliance of the MARPOL, an
objective of this study is also to educate the seafarers
of the adverse effects and the trends depicted in the
marine industry regarding pollution from ships. Even
if a handful of seafarers read- ing this paper decides
not to be a part of polluting the oceans, I will
consider this paper’s objective met.
Disclosure statement
The author declares that he has no competing interests.
Funding
No funding was obtained for this study.
ORCID
Capt. Deepak Mantoju http://orcid.org/0000-0001-5519-
2407
Availability of data and material
The data used are freely available on each of the MoU’s
websites. Only the Acuerdo Viña del mar MoU’s official
web- site was down while collecting the data, in this case
data has been extracted from www.equasis.org, other
sources of data is from published sources available
online.
Ethics approval
No ethical approval is necessary for this study.
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