Port State Control (PSC) concentrates on technical files related to NOx emissions

Port State Control (PSC) concentrates on technical files related to NOx emissions and machinery components. There is increasing international scrutiny of greenhouse gas (GHG) emissions, leading to numerous PSC detentions due to engine EIAPP certification and record maintenance issues.

Emissions Regulations and Key Focus Areas for Port State Control (PSC)

Port State Control (PSC) authorities are focusing their review of the NOx Technical Files and the Record Book of Engine Parameters to ensure alignment with onboard installations. This increased focus has led to the identification of several serious deficiencies during recent PSC inspections.

PSC Officers inspect documentation and examine available spare parts to verify that the IMO IDs correspond with those detailed in the Technical Files. Any discrepancies found may trigger a more comprehensive PSC inspection. Furthermore, officers may request partial disassembly of equipment to conduct a meticulous evaluation.

The following are examples of common deficiencies noted during inspections, underscoring the critical importance of compliance:

PSC Code	Defective Item	Additional PSC comments
14601	Technical Files and, if applicable, monitoring manual	NOx Technical File for the main engine and generators is not available onboard.
14602	Record Book of Engine Parameters	The Record Book of Engine Parameters is correctly filled in, but information related to replacing injection pump cylinder no. 1 as per the NOx Technical File is missing.
14606	Diesel engine air pollution control	The charge air cooler of M/E does not have the IMO ID number required by the NOx Technical File.

The primary reasons for previous detentions were the absence of Technical Files or Record Books for Engine Parameters, and engine parts missing the IMO identification number specified in the Technical File onboard. During follow-ups on detainable deficiencies, it was found that misunderstandings and a lack of clear instructions onboard contributed to these deficiencies, which could ultimately result in vessel detention.

If in doubt, if updated or in compliance, here are a couple of key pointers:

NOx Technical Files and Engine International Air Pollution Prevention (EIAPP) certificates must be kept onboard in their original form. Please note that PDF files serve as the originals for documents issued digitally. When there is a change in ownership, it is important to ensure that these documents are transferred to the new owner. If the NOx Technical Files are missing, the owner should contact the NOx Technical Files and Engine International Air Pollution Prevention (EIAPP) certificates must be maintained onboard in their original formats. Please be advised that PDF files are considered the original documents when issued digitally. In the event of a change in ship ownership, it is essential to ensure that these documents are properly transferred to the new owner. Should there be any missing NOx Technical Files, the new owner is encouraged to contact the engine manufacturer to acquire the necessary replacement documents.

A Record Book, which may be maintained in physical or electronic format, is critical in documenting engine parameters through the engine parameter check method. This comprehensive record should capture all modifications to engine parameters, including component replacements—like-for-like and different types—and any adjustments to engine settings that could potentially affect NOx (nitrogen oxides) emissions.

All entries in the Record Book should not specify the changes made but must include all relevant data necessary for accurately assessing the engine’s NOx emissions. This may involve recording specific operational conditions, performance metrics, and any findings from emissions tests.

The first essential step for surveyors using the parameter check method is to review the Record Book. This review helps confirm that the recorded engine parameters are within the acceptable ranges specified in the engine's Technical File, a detailed document outlining the operational guidelines and constraints for the engine.

While the structure and content requirements for the Record Book are not rigidly defined, some Technical Files may provide templates to assist in standardizing entries. At a minimum, the Record Book should include the date of the recorded entry, the specific component involved in the change, and both the old and new ID numbers associated with that component. The Record Book must also document any alterations or confirmations of engine settings, ensuring an audit trail for future reference and compliance verification, such as service letters or IMO updated information from the manufacturer.

A Record Book, whether physical or electronic, is used to document engine parameters through the engine parameter check method. This includes all changes to parameters, component replacements, like-for-like replacements, and adjustments to engine settings that may impact NOx emissions. Descriptions should also include any relevant data used to assess the engine’s NOx emissions.

Checking the Record Book is part of the inspection/audit for the surveyor when applying the parameter check method. This process validates that engine parameters are within the defined range specified in the engine’s Technical File. While the format and content of the Record Book are not strictly defined, some Technical Files may include templates. At a minimum, the Record Book should contain the date, the component involved, as well as the old and new ID numbers, and should document any changes or verifications of settings. Many keep a handwritten log file and a redundant digital file.

If any ID numbers are missing or incorrect, the shipowner should take immediate corrective action. A reasonable timeframe should be provided for this correction. In cases of incorrect ID numbers, the shipowner should contact the engine manufacturer or supplier to validate the information. Additionally, they should check if there are approved service letters and updates to the NOx Technical File that permit the use of the components. These must be attached to the onboard technical file before installation.

As needed, the engine components and adjustable features will be inspected. The findings from this inspection, together with a review of the documentation, will confirm whether the engine's adjustable features are within the allowable range specified in the Technical File. The surveyor may choose to examine any or all of the identified components, settings, or operating values according to the technical file and IMO validation.

References

• IMO Res. A.1155(33) – Procedures for Port State Control 2023 – Appendix 18 “Guidelines for Port State Control under MARPOL Annex VI”

About PSC codes

Port State Control (PSC) deficiency codes are standardized identifiers used by maritime authorities to document specific deficiencies found during inspections of foreign ships in national ports. These codes facilitate consistent reporting and analysis across different jurisdictions, ensuring vessels comply with international safety, security, and environmental protection regulations.

Structure of PSC Deficiency Codes

PSC deficiency codes are typically structured as five-digit numbers, where:

• First two digits: Represent the main category (e.g., certificates, safety, navigation).

• Next three digits: Specify the particular deficiency within that category.

Examples of PSC Deficiency Codes

Here are some examples of PSC deficiency codes and their corresponding items:

• 01101: Cargo Ship Safety Equipment Certificate (including exemption)

• 01102: Cargo Ship Safety Construction Certificate (including exemption)

• 01103: Passenger Ship Safety Certificate (including exemption)

• 01104: Cargo Ship Safety Radio Certificate (including exemption)

• 01106: Document of Compliance (DoC/ISM)

• 01107: Safety Management Certificate (SMC/ISM)

These codes are part of a comprehensive list used by various regional agreements and organizations, such as the Paris Memorandum of Understanding (Paris MoU), Tokyo MoU, and the International Maritime Organization (IMO).

Accessing the Full List of PSC Deficiency Codes

For a comprehensive and authoritative list of PSC deficiency codes, you can refer to the following resources:

• Paris MoU Deficiency Codes: Provides a detailed list of deficiency codes used within the Paris MoU region

• Tokyo MoU Deficiency Codes: Offers deficiency codes applicable in the Tokyo MoU region.

• IMO Port State Control Guidelines: Outlines procedures and codes adopted by the IMO for PSC inspections. 