Operational Guide · Registers & Logbooks

# Bulk Carriers: PSC Risk Profile and Recurring Deficiencies

Container ships, bulk carriers and general cargo ships together accounted for 83% of detentions in the first quarter of 2026: it is not the ship's structure that most often comes under PSC scrutiny, but ISM management and maintenance.

bulk carrier detention rate ISM recurring deficiencies

## Operational Explanation

This topic addresses the PSC risk profile specific to bulk carriers from an angle distinct from the content already on the site covering the Enhanced Survey Programme (ESP) and hull structure: here the focus is on the most frequent causes of PSC detention for this fleet segment, not on the technical mechanics of structural survey.

According to DNV data for the first quarter of 2026, 64 detentions were recorded overall, with container, bulk carrier and general cargo ships together accounting for 83% of total detentions; around 84% of these detentions occurred under the Paris MOU and Tokyo MOU regimes. The most frequent detainable deficiency categories remain dominated by the "15150 - ISM" code and the "15109 - Ship and equipment maintenance" code, not by structural hull shortcomings detectable only at survey.

## Regulatory Reference

Aggregated DNV Port State Control Q1 2026 data on detentions by ship type and deficiency category, under the Paris MOU and Tokyo MOU regimes; to be read together with the Enhanced Survey Programme requirements (IACS UR Z10.2/Z11) already covered in the Dry Dock module for the structural component.

## Scope of Application

Every bulk carrier subject to PSC inspection under the Paris MOU and Tokyo MOU regimes, with particular attention to ISM documentary management and maintenance programmes, in addition to the structural component already covered by the Enhanced Survey Programme.

## Procedure / How to Complete It

1. Verify the full documentary implementation of the Safety Management System (SMS) on board, given that the ISM deficiency category remains the most frequent in bulk carrier detentions.
2. Check the state of updating and completeness of equipment maintenance records, the second most recurring deficiency category.
3. Do not limit PSC preparation to the structural component already covered by the Enhanced Survey Programme: always include ISM and maintenance documentary verification.
4. Monitor quarterly PSC statistics (e.g. DNV reports) to track the evolution of the most frequent deficiency categories for the bulk carrier segment.
5. Coordinate PSC preparation with the ESP structural survey programme, while keeping the two distinct areas of attention (documentary management vs. structure) separate.

## Practical Example

Example: a bulk carrier preparing for a PSC inspection in the Paris MOU area reviews not only the status of ESP structural certificates, but also the completeness of the bilge pump maintenance records and the documentation of ISM non-conformities closed at the last internal audit, knowing that these last two categories remain the most frequent in detentions for this segment.

## Real Cases

The finding that container ships, bulk carriers and general cargo ships accounted for 83% of detentions in the first quarter of 2026, with the ISM and maintenance categories dominating the causes, indicates that a bulk carrier's detention risk does not stem mainly from structural shortcomings detectable only at survey, but from gaps in day-to-day documentary management: a finding that should steer PSC preparation towards a balance between the structural and the managerial component.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
PSC preparation for bulk carriers concentrated only on the structural/ESP component, neglecting ISM and maintenance documentation | Detention for deficiency categories that remain the most frequent in the segment (ISM, maintenance) | Always include ISM documentary verification and maintenance records in PSC preparation, not only the structural component
Equipment maintenance records updated only formally, without substantive verification of their completeness | Deficiency in the '15109 - Ship and equipment maintenance' category | Verify the substantive, not merely formal, completeness of maintenance records before every PSC inspection
Quarterly PSC statistics by ship type not monitored to guide bulk carrier segment-specific preparation | Preparation not updated relative to the deficiency categories that are actually most frequent | Periodically monitor quarterly PSC reports (e.g. DNV) to guide preparation towards the categories of deficiency that are genuinely prevalent

## PSC Observations

When inspecting a bulk carrier, PSCOs tend to find deficiencies more frequently in the ISM management and equipment maintenance categories than in pure structural shortcomings, which remain mainly the subject of verification under the Enhanced Survey Programme at class survey.

## Operational Tips

- Don't concentrate a bulk carrier's PSC preparation only on the structural ESP component: the ISM and maintenance categories remain the most frequent in detentions.
- Verify the substantive completeness of maintenance records, not just their formal presence.
- Periodically monitor quarterly PSC reports by ship type, to guide preparation towards the deficiencies genuinely prevalent in the segment.

## Checklist

- SMS/ISM documentation verified as fully implemented and consistent with on-board practice
- Equipment maintenance records verified for substantive completeness
- PSC preparation balanced between the structural ESP component and the ISM/maintenance documentary component
- Quarterly PSC reports by ship type monitored for prevalent deficiency categories
- Open ISM non-conformities verified and closed before port calls in high-inspection-intensity areas

## FAQ

What percentage of PSC detentions in the first quarter of 2026 involved container ships, bulk carriers and general cargo ships?
83% of the 64 total detentions recorded in Q1 2026, according to DNV data, with around 84% of these concentrated under the Paris MOU and Tokyo MOU regimes.
What are the most frequent deficiency categories for bulk carriers?
The '15150 - ISM' category and the '15109 - Ship and equipment maintenance' category remain the most recurring, not pure structural shortcomings.
Does this topic replace the Enhanced Survey Programme content already on the Dry Dock module?
No: it is complementary. The Enhanced Survey Programme covers the structural component of the class survey, while this topic addresses the PSC risk profile linked to ISM documentary management and maintenance.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

Cargo Hold Survey for Bulk Carriers (ESP) (IT)Managing Deficiencies Ship Risk Profile and New Inspection Regime

### Leave feedback

Help us improve the platform during the beta -- it takes thirty seconds.

How useful do you find the platform so far?
Comment (optional)
Sign me up for the newsletter
Role