Compliance & inspections

# PSC Knowledge Base Live

Environmental deficiencies (MARPOL, BWM Convention) weigh increasingly heavily on Paris/Tokyo MOU risk profiles: according to the latest Paris MOU Annual Report, the global detention rate reached 4.18% in 2025 (up from 4.03% in 2024), with 688 detentions and 19 bannings during the year. Fire safety (SOLAS Chapter II-2) remains the single most frequent deficiency category overall (16.8% of the total), followed by environmental deficiencies on the Oil Record Book and discharge treatment systems.

## Most frequent deficiencies linked to MARPOL Operations

Deficiency | Regulation | Indicative frequency | Possible consequence
--- | --- | --- | ---
Oil Record Book — missing/unsigned entry | MARPOL Annex I / ORB | Very high | Possible detention if linked to suspected illegal discharge
Non-functioning or bypassed OWS | MARPOL Annex I | High | Near-certain detention, possible criminal proceedings
Expired IOPP Certificate | MARPOL Annex I | Medium | Detention
Missing or outdated Garbage Management Plan | MARPOL Annex V | Medium | Deficiency, possible detention for ships 100-400GT
SOPEP with outdated emergency contacts | MARPOL Annex I | Low-Medium | Deficiency
Unrecorded/late Annex VI changeover | MARPOL Annex VI | Medium | Environmental deficiency, weighted more heavily by Paris MOU
Ballast Water Record Book format not updated (post 1/2/2025) | BWM Convention | Medium | Deficiency
Expired IAPP Certificate or missing EIAPP for a modified engine | MARPOL Annex VI | Medium | Deficiency, possible detention
Crew unaware of the DPA's identity/contact details | ISM Code, para. 4 | Medium | NC at certification audit, indicator of a weak SMS
Internal audit not conducted on one or more ships within 12 months | ISM Code, para. 12 | Medium-High | NC at external DOC/SMC renewal audit
Muster list not updated or crew not familiarized | SOLAS Chapter III, Reg. 19 | High | Serious deficiency, possible detention
ENCs not updated or ECDIS back-up not functioning | SOLAS Chapter V, Reg. 19/27 | Medium-High | Deficiency, aggravating factor in the event of a navigation incident
Emergency generator fails to start correctly on test | SOLAS Chapter II-1, Reg. 43 | High | Serious deficiency, possible detention
Expired certificate or onboard copy not updated after renewal | General PSC documentary requirements | Medium | Deficiency, aggravating factor if repeated
Cargo Securing Manual not consistent with the ship's configuration (CIC 2026 focus) | SOLAS Chapter VI/VII, CSS Code | To monitor (CIC 1 Sep - 30 Nov 2026) | Deficiency in the thematic campaign
Enclosed space entry drill not conducted every 2 months | SOLAS Chapter III, Reg. 19.3.5 | High | Serious deficiency, real risk of fatality
VDR with an expired or failed annual performance test | SOLAS Chapter V, Reg. 20 | Medium | Deficiency, loss of critical data in the event of an incident
Non-functioning emergency fire pump or insufficient pressure | SOLAS Chapter II-2, Reg. 10 | High | Serious deficiency, possible detention
Rudder play or sea chest tightness not compliant with survey | Class requirements | Medium-High | Open condition of class, possible impact on certificate validity
Certificate extended beyond the 3 months permitted from the original expiry | HSSC — Res. A.1186(33) | Low-Medium | Certificate considered invalid, possible detention
Missing CII Corrective Action Plan for a ship with a D/E rating | MARPOL Annex VI, Reg. 28 | To monitor (growing PSC attention from 2026) | Deficiency, possible aggravating factor in the environmental risk profile

Each entry links to the corresponding operational topic, with its dedicated "PSC Observations" section and tips for avoiding it.

## How to use this section

Before a PSC inspection, scan through the most frequent deficiencies for your ship type and check the relevant checklist on the linked operational topic. For systematic inspection preparation, also consult the PSC Readiness module. This database will continue to grow as the Vetting module is added.

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