What are clear grounds and ISM-related deficiencies for a more detailed PSC inspection, and which sulphur-cap deficiencies can detain a ship?
Short answer
| Deficiency | Cause | Prevention |
|---|---|---|
| Fuel sulphur over the limit | a non-compliant bunker, or the wrong tank in an ECA | order to ISO 8217, check the BDN, test if in doubt, manage tanks |
| No changeover record | changeover late or unlogged | a written procedure, done early, logged with time, position, quantities |
| Missing BDN or sealed sample | not retained for 3 years or 12 months | file and retrieve both |
| Non-compliant fuel carried | high-sulphur fuel without a scrubber | de-bunker or segregate; a FONAR only when compliant fuel was unavailable |
| Scrubber inoperative | not maintained | maintain within approval, keep records, compliant fuel as contingency |
- Clear grounds (A.1052(27), A.1155(32)): evidence the ship, equipment or crew does not substantially meet the requirements: invalid or missing certificates; serious deficiencies on the walk-round; a casualty; a complaint; a crew unable to perform essential operations (SOLAS XI-1/4).
- ISM-related deficiencies: no valid DOC or SMC; an SMS not effectively implemented (systemic deficiencies, crew unaware of procedures, records not kept, non-conformities not closed); grounds for detailed inspection and, if serious, detention.
- Since 2020: sulphur 0.50% m/m worldwide, 0.10% in ECAs; the carriage ban from 1 March 2020 on non-compliant fuel for combustion without an approved scrubber (Annex VI regulation 14).
- Detainable: fuel over the limit; no changeover record before an ECA; missing BDN (3 years) or sealed sample (12 months, regulation 18); non-compliant fuel carried without a scrubber; an inoperative scrubber; IAPP or Statement of Compliance gaps.
- Prevention: compliant fuel to ISO 8217, BDN checked; tanks managed; changeover early and logged with time, position and quantities; BDNs and samples filed; a FONAR only when fuel is unavailable; scrubber maintained.
Full answer
The full answer explains each point step by step, with the regulations and figures behind it and the discussion from other candidates. It is in the MEO Class I section of the Marine One forum, open to members enrolled for the MEO Class I exam.