Section 19.1 Port State Control (PSC): Targeting, Inspection Process, Common Deficiencies for Bulkers

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 conventions (e.g., SOLAS, MARPOL, STCW, MLC) and that the ship is manned and operated in compliance with these rules. PSC provides a “safety net” to catch substandard ships that may have been missed by their Flag State or Classification Society. Various regional PSC MoUs (Memoranda of Understanding) exist globally (e.g., Paris MoU, Tokyo MoU, USCG, AMSA).

1. Targeting of Ships for PSC Inspection: PSC regimes use risk-based targeting systems to determine which ships to inspect. Factors influencing a ship’s likelihood of inspection include:

Ship Risk Profile (SRP): MoUs like Paris and Tokyo use a detailed SRP based on:

Ship Type: Certain ship types, including bulk carriers, are often considered higher risk.

Age of Ship: Older vessels are generally targeted more frequently.

Flag State Performance: Ships flying flags with poor performance records are more likely to be inspected.

Recognized Organization (RO) Performance: The performance of the Classification Society that certified the ship.

Company Performance: The historical PSC record of the ship’s operating company (ISM manager).

Deficiency and Detention History: The ship’s own past PSC record.

Overriding Factors: Regardless of risk profile, certain factors can trigger an inspection, such as:

Ships reported by pilots, port authorities, or other sources as having apparent anomalies.

Ships involved in a collision, grounding, or pollution incident.

Ships whose certificates are not in order.

Allegations of non-compliance with the Maritime Labour Convention (MLC).

Unexpected Factors: Sometimes inspections can be random or part of a Concentrated Inspection Campaign (CIC) focusing on specific areas (e.g., fire safety, crew familiarization).

2. The PSC Inspection Process: While procedures may vary slightly between PSC regimes, a typical inspection follows a general pattern:

Initial Inspection:

Boarding and Introduction: The Port State Control Officer (PSCO) will board the vessel, introduce themselves, and state the purpose of their visit. The Master or a senior officer should receive them.

Documentation Check: The PSCO will typically start by examining the ship’s certificates (e.g., Safety Construction, Safety Equipment, Load Line, IOPP, ISPP, IAPP, ISM DOC & SMC, MLC, Minimum Safe Manning Document, crew STCW certificates, Oil Record Book, Garbage Record Book, etc.). They will verify validity and consistency.

Overall Condition Assessment: The PSCO will conduct a general visual inspection of the vessel, often starting with the bridge, engine room, and deck areas, to get an overall impression of the ship’s maintenance, cleanliness, and crew alertness.

More Detailed Inspection (if deemed necessary):

If the initial inspection reveals “clear grounds” (e.g., missing/invalid certificates, evidence of poor maintenance, inoperable critical equipment, crew unfamiliarity with duties), the PSCO will conduct a more detailed inspection.

This may involve:

Operational tests of equipment (e.g., emergency fire pump, emergency generator, steering gear, oily water separator, lifeboat engine, rescue boat launching).

Checking fire-fighting and life-saving appliances for condition and readiness.

Inspecting accommodation and galley for hygiene and MLC compliance.

Verifying crew familiarity with their duties, especially emergency procedures.

Examining specific areas related to MARPOL compliance (e.g., bilge management, garbage handling).

For bulk carriers, specific attention may be paid to hatch cover condition, structural integrity (evidence of corrosion or cracking in holds and on deck), and cargo-related safety.

Drills: The PSCO may require the crew to conduct an emergency drill (e.g., fire drill, abandon ship drill, enclosed space entry and rescue drill) to assess their proficiency.

Concentrated Inspection Campaigns (CICs): If a CIC is underway, the PSCO will pay particular attention to the specific area of focus for that campaign, using a dedicated checklist.

3. Outcome of the Inspection:

No Deficiencies: The ideal outcome. The PSCO will issue a “clean” inspection report.

Deficiencies Recorded:

Minor Deficiencies: If deficiencies are found that are not serious enough to warrant detention, they will be recorded on the inspection report. The Master will usually be required to rectify them within a certain period (e.g., before departure, within 14 days, or by the next port).

Grounds for Detention (Detainable Deficiencies): If deficiencies are found that are, individually or collectively, serious enough to pose a danger to the ship, its crew, or the environment, the ship will be detained. The detention order remains in force until the deficiencies are rectified to the satisfaction of the PSCO and, often, the Flag State or RO.

Inspection Report: The Master will receive a copy of the PSC inspection report detailing any deficiencies found and any action taken (e.g., rectification required, detention). The Master should review this carefully and has the right to provide comments or seek clarification.

4. Common Deficiencies on Bulk Carriers: While deficiencies can occur in any area, some are frequently noted on bulk carriers:

Safety of Navigation:

Outdated nautical charts and publications (paper or ECDIS).

ECDIS familiarization issues or improper setup.

Inoperable navigation equipment (radar, AIS, VDR).

Passage planning deficiencies.

Fire Safety:

Inoperable fire pumps or low pressure in the fire main.

Defective fire dampers or ventilation shutdowns.

Missing or expired portable fire extinguishers.

Damaged or leaking fire hoses and nozzles.

Inoperable fixed fire-fighting systems (e.g., CO2 system for engine room or cargo holds).

Blocked emergency escape routes.

Crew lack of familiarity with fire-fighting equipment or procedures.

Life-Saving Appliances (LSA):

Lifeboats/rescue boats and launching appliances in poor condition or inoperable.

Expired pyrotechnics or hydrostatic release units.

Defective immersion suits or lifejackets.

Crew lack of familiarity with LSA operation.

MARPOL-Related Deficiencies:

Oily water separator (OWS) inoperable, bypassed, or oil content meter (OCM) faulty.

Discrepancies or improper entries in the Oil Record Book.

Inadequate garbage management, improper segregation, or issues with the Garbage Record Book.

SOPEP deficiencies or lack of SOPEP equipment.

Air pollution (Annex VI) issues (e.g., incorrect fuel used in ECA, BDN issues).

Structural Conditions (Critical for Bulkers):

Corrosion, cracking, or wastage in cargo holds, on deck, or in ballast tanks.

Hatch cover deficiencies (e.g., poor sealing, corrosion, damaged coamings or securing devices) – a major concern for bulk carrier seaworthiness.

Damaged ladders or access ways in cargo holds.

Load Lines and Stability:

Overloading.

Incorrect load line marks.

Lack of stability information or crew inability to perform stability calculations.

ISM Code and MLC, 2006:

Deficiencies in the implementation of the Safety Management System (e.g., maintenance records, emergency preparedness, reporting of non-conformities).

Crew unfamiliarity with their duties under the SMS.

MLC deficiencies related to crew accommodation, food and catering, hours of work/rest, payment of wages, or seafarers’ employment agreements.

Machinery and Electrical:

Inoperable emergency generator.

Leaking fuel or oil pipes.

Defective bilge pumping arrangements.

Poor insulation or exposed wiring.

5. Detention: A detention is the most serious outcome of a PSC inspection and can have significant commercial and reputational consequences.

Reasons for Detention: Deficiencies that, individually or collectively, are deemed to make the ship unsafe to proceed to sea or pose an unreasonable threat to the marine environment.

Procedure: The PSCO will issue a formal detention order. The Flag State and RO must be notified. The ship cannot sail until the detainable deficiencies are rectified to the satisfaction of the PSC authorities. This often involves RO attendance and confirmation.

Publication: Detentions are publicly listed by PSC MoUs, affecting the ship’s and company’s risk profile and reputation.

Understanding PSC targeting, the inspection process, and common pitfalls is the first step for a Master in effectively preparing for and managing these crucial inspections.