Detention and Banning
What happens when a ship is detained, how to get out of a detention, and the often-underestimated rules that lead to a port access ban (banning).
Operational Explanation
Detention is the formal holding of a ship by the PSC authority, ordered when one or more deficiencies represent unacceptable risk to safety, crew health or the environment. The ship cannot sail until the shortcomings have been rectified and verified.
Banning (refusal of access) is a more severe measure: under the Paris MOU regime, a ship flying a Black List flag is banned after more than 2 detentions in the preceding 36 months; a ship flying a Grey List flag after more than 2 detentions in the preceding 24 months. Every detention following a second banning leads to a new banning regardless of flag, with a minimum ban period that grows with each repetition, potentially becoming permanent after the third or fourth banning.
Regulatory Reference
Paris MOU (and Tokyo MOU with similar criteria): detention criteria based on the severity of deficiencies found; banning criteria based on the number of detentions in the last 24-36 months depending on the flag's position on the White/Grey/Black lists.
Scope of Application
Every ship inspected in the Paris MOU/Tokyo MOU area; the economic and reputational consequences of a detention/banning fall both on the ship and, via the Company Performance parameter, on the Company's entire fleet.
Procedure / How to Complete It
- In the event of detention, immediately identify all the deficiencies that led to the hold and plan rectification with absolute priority.
- Coordinate with the Company, the DPA and, if necessary, a classification society/surveyor for verification of repairs.
- Request formal verification of the rectifications by the PSC authority (or an authorised surveyor) before requesting the ship's release.
- Document the entire episode (deficiency, cause, action, verification) in the SMS's NC/CAPA system for analysis at the next Management Review.
- Monitor the trend of the Ship Risk Profile and Company Performance after the event, since a detention affects both for an extended period (up to 36 months).
Practical Example
Example: a ship detained for malfunction of the emergency generator. Technical intervention completed in 18 hours, class surveyor verification passed, PSC authority confirms release. The episode is analysed at the next Management Review, identifying the need to bring forward preventive maintenance of the generator across the whole fleet.
Real Cases
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Underestimating the impact of a detention on the Ship Risk Profile for the following 36 months | More frequent, more thorough inspections continue well beyond resolution of the episode | Treat detention as an event requiring active long-term management of the risk profile, not just immediate rectification |
| No analysis linked to the NC/CAPA system after a detention | Systemic causes remain unresolved and the risk of recurrence increases | Treat every detention as a priority input for the Management Review |
| Underestimating the risk of banning after a second detention within a critical interval | Banning carries a growing minimum ban period, with the possibility of becoming permanent | Carefully monitor the detention history of the ship and the fleet against the banning thresholds |
PSC Observations
Operational Tips
- Manage every detention with the utmost priority and transparency towards the PSC authority, to speed up verification and release.
- Always analyse the root cause of the detention in the SMS's NC/CAPA system, don't stop at the technical repair.
- Monitor the fleet's detention history against the banning thresholds, especially if the flag is on the Grey or Black List.
Checklist
- Deficiencies causing the detention identified and prioritised
- Coordination with Company, DPA and classification society initiated immediately
- Formal verification of rectifications requested before release
- Episode documented in the NC/CAPA system and brought to the Management Review
- Impact on Ship Risk Profile and Company Performance monitored over time