Question 1

You hear that the Paris MOU Concentrated Inspection Campaign (CIC) this year focuses on MARPOL Annex VI air emissions. How do you prepare the vessel?

Accepted Answer

CIC MARPOL ANNEX VI PREPARATION — CM: Paris MOU Concentrated Inspection Campaigns (CICs) focus on specific topics each year — all inspectors across all Paris MOU ports ask a set of agreed questions during the CIC period. MARPOL ANNEX VI AIR EMISSIONS — CM PREPARATION: (1) INTERNATIONAL AIR POLLUTION PREVENTION CERTIFICATE (IAPP): must be valid. Check expiry and renewal date; (2) SULPHUR COMPLIANCE: (a) Global: 0.50% m/m sulphur cap (since Jan 2020); (b) ECA (Emission Control Areas — North Sea, Baltic, English Channel, US waters): 0.10% m/m sulphur cap; (c) Bunker Delivery Notes (BDNs): must show sulphur content of fuel. Retain BDNs for 3 years; (d) Fuel oil sample retained on board (SOLAS VI/5.6); (3) FUEL CHANGEOVER LOG: if the vessel operates in and out of ECAs — the changeover from high-sulphur to low-sulphur fuel must be logged. Fuel oil changeover record book or log entry with: time, position, tank levels before/after; (4) TIER II/III NOx: check that engines comply with MARPOL Annex VI Reg 13 NOx technical requirements. Technical File from engine manufacturer on board; (5) OZONE-DEPLETING SUBSTANCES: Ozone Depleting Substances Record Book on board. No HCFCs or CFCs in new systems; (6) SHIPBOARD ENERGY EFFICIENCY MANAGEMENT PLAN (SEEMP): MARPOL Annex VI Reg 22A — all vessels 400 GT and above must carry an approved SEEMP; (7) CII (CARBON INTENSITY INDICATOR): vessels 5000 GT and above must rate their carbon intensity annually and carry a CII rating. CIC scope: all Paris MOU member state ports participate. Any vessel calling at a Paris MOU port during the CIC period (typically 3 months) may be asked the CIC questions during their regular PSC inspection. Flag state is irrelevant — the Paris MOU targets foreign vessels, and all foreign flag vessels in member ports are in scope. Sulphur ECA 0.10%: the 0.10% sulphur limit in ECAs (North Sea, Baltic, English Channel, North American ECA) is significantly more stringent than the global 0.50% cap. UK waters are in the North Sea ECA — vessels entering UK ports from outside the ECA must have completed the changeover. EGCS/scrubber and Annex VI (option D): a scrubber (wet exhaust gas cleaning system) can allow the burning of high-sulphur fuel oil (HSFO) while meeting the sulphur emission standard. BUT: (a) The scrubber must be type-approved and certified; (b) The IAPP Certificate must reflect the scrubber installation; (c) Washwater discharge from the scrubber must comply with MARPOL requirements; (d) Certain ports and flag states have banned open-loop scrubber washwater discharge — the CM must know the restrictions for each port; (e) The scrubber does not exempt from NOx requirements. Class society vs PSC (option C): the class society conducts the IAPP survey and issues the certificate on behalf of the flag state. BUT the PSCO has full authority to inspect Annex VI compliance and is specifically trained to do so. The CIC demonstrates exactly this.

Question 2

A Paris MOU Port State Control Officer (PSCO) boards your vessel in Rotterdam. As Chief Mate, what does the initial inspection involve and what is your role?

Accepted Answer

PSC INITIAL INSPECTION — CM ROLE: The Paris MOU provides the framework for PSC inspections in European waters. INITIAL INSPECTION — THE PSCO CHECKS: (1) CERTIFICATES: validity of all relevant certificates: (a) Safety Management Certificate (SMC) and Document of Compliance (DOC); (b) SOLAS Safety Equipment Certificate; (c) SOLAS Safety Construction Certificate; (d) SOLAS Safety Radio Certificate; (e) Load Line Certificate (LL); (f) IOPP Certificate (MARPOL Annex I); (g) ISPS (International Ship and Port Facility Security Code) Certificate; (h) MLC Maritime Labour Certificate; (i) Classification Certificates; (j) Minimum Safe Manning Document; (k) Officer's Certificates of Competency; (2) CREW WELFARE: PSCO may interview crew privately about rest hours, wages, food, and access to complaint procedure (MLC inspection); (3) GENERAL CONDITION: visual inspection for obvious deficiencies — corrosion, unsafe equipment, damaged fire equipment, dirty accommodation; (4) ISM: request evidence of ISM implementation — drill records, internal audits, non-conformity reports. CM ROLE: (a) Accompany the PSCO on request; (b) Produce documents immediately — delay suggests non-compliance; (c) Answer questions truthfully and professionally; (d) Notify master of PSCO's findings as the inspection proceeds; (e) Do NOT coach crew on what to say — crew must speak freely to the PSCO. Paris MOU targeting system: uses a risk-based targeting system (Concentrated Inspection Campaigns and the Targeting Factor) to select which vessels to inspect. High-risk ships (older vessels, flags with poor performance records, companies with poor track records) are inspected more frequently. PSC authority: based on UNCLOS, SOLAS, and the MOU framework. Port state has the right to inspect foreign vessels in their ports to verify compliance with international conventions. The inspection right does NOT require cause — any commercial vessel in a Paris MOU port can be selected. The MLC private interview: PSCO may interview crew without the master or CM present. MLC Standard A5.2.1 specifically provides for this. If the CM were present, crew might be reluctant to report MLC violations. The CM must not interfere with MLC crew interviews. Certificate validity vs actual condition (option B): if certificates are valid but conditions are hazardous (fire system not functioning, crew not properly trained), the PSCO can issue deficiency notices and potentially detain the vessel for "clear grounds" — hazardous conditions regardless of paper compliance. Detention criteria: not just paper failures. A vessel CAN be detained for: overriding alarm silenced; inadequate fire drill records; crew unable to demonstrate use of fire equipment; structural deficiencies; significant rest hour violations.

Question 3

After inspection, the PSCO states she has found deficiencies that may lead to detention. What categories of deficiency are "detainable" under Paris MOU?

Accepted Answer

DETAINABLE DEFICIENCIES — PARIS MOU: The Paris MOU defines a "detainable deficiency" as one that poses a CLEAR AND IMMINENT DANGER to safety, health, or the environment. Categories include: (1) ISM CODE: no ISM Certificate; ISM certificate expired; evidence that the ISM is not implemented — no drill records, no non-conformity reports, no audit records; (2) FIRE SAFETY: fire detection system inoperative; automatic fire dampers inoperative; fire main inoperative; CO2 system expired; lifeboat release mechanism seized; (3) NAVIGATION: primary navigation equipment inoperative (radar); no charts or grossly outdated charts; GMDSS equipment inoperative; (4) STRUCTURAL: vessel unseaworthy — hull damage, excessive corrosion compromising watertight integrity; (5) LIFESAVING APPLIANCES: insufficient lifeboats or lifejackets; lifeboat falls overdue; EPIRB expired or inoperative; immersion suits not available or defective; (6) MARPOL: IOPP certificate expired; no Oil Record Book or incomplete ORB; oil-water separator inoperative; (7) MLC: serious MLC violations — crew not paid, inadequate food/water, inadequate rest, serious accommodation deficiencies; (8) CERTIFICATION: officer certificates not valid for the role or expired; vessel undermanned below Safe Manning Document; (9) STCW: unable to demonstrate STCW competencies — crew cannot operate fire equipment, donning drills inadequate. NOTE: a single deficiency can cause detention if it is dangerous. Multiple minor deficiencies together may cumulatively justify detention. Paris MOU detention statistics: approximately 2-3% of vessels inspected are detained. Common deficiency categories include: fire safety/fire fighting equipment; safety in general; life-saving appliances; ISM. The CM's role before inspection: the best PSC preparation is a well-maintained vessel with proper documentation. The CM can reduce detention risk by: maintaining drill records; ensuring equipment is operational and tested; keeping certificates up to date; maintaining accurate ORBs; enforcing rest hours. CM role during inspection: the CM should accompany the PSCO on a walk-through and immediately address minor deficiencies that can be rectified during the inspection. If a fire extinguisher pin is missing — replace it during the inspection. This shows proactive compliance culture and may prevent a deficiency notice for the minor item. Master signing (option D): the master is asked to sign the inspection report to acknowledge RECEIPT of the inspection findings — not to "accept" the detention. Refusing to sign is noted on the report but does NOT void the detention. The PSCO has authority to detain under the port state's national law giving effect to the Paris MOU. Flag state reporting: deficiencies are reported to the flag state. Vessels with repeated deficiencies or detentions are targeted for more frequent inspection. The Paris MOU "black list" and "grey list" identify flag states with poor PSC performance records.