Unit 1 Introduction: The Evidence from Port State Control
An analysis of Port State Control (PSC) inspections reveals a clear and concerning trend: a significant and increasing number of deficiencies are being recorded under codes related to the International Safety Management (ISM) Code. This evidence suggests potential weaknesses in the implementation of the ISM Code, either ashore or on board, and raises questions about the effectiveness of the Code itself. When multiple ISM-related deficiencies are found during a single inspection, it can indicate a systemic failure within the company's Safety Management System (SMS), often resulting in the vessel's detention.
Data from the Paris MoU provides a clear snapshot of this issue. Between 2019 and 2021, of the 104,306 total deficiencies recorded, approximately 11% were due to ISM Code non-conformities, making it the single most frequent category of deficiency noted in the top ten (see Figure 3.1).
Figure 3.1: The ten most frequent deficiencies detected on ships during by Paris MoU 2019-2021
Over this three-year period, more than 46,000 inspections were conducted, leading to thousands of detentions annually (see Table 3.1). The high frequency of ISM-related issues points to a persistent challenge within the industry to maintain effective compliance.
Table 3.1: PSC Paris MoU Observed deficiencies – Review of Inspections 2019 - 2021
Year | 2019 | 2020 | 2021 |
Number of inspections | 17,916 | 13,168 | 15,387 |
Number of individual ships inspected | 15,447 | 12,092 | 13,797 |
Number of deficiencies | 39,821 | 28,372 | 36,113 |
Number of detainable deficiencies | 3,015 | 2,182 | 3,274 |
Detentions in % of the total number of inspections | 2.98 | 2.92 | 3.43 |
Number of refusals of access to ports | 25 | 8 | 11 |
The latest data from the Paris MoU 2024 Annual Report indicates that this challenge not only persists but has evolved. The MoU has expressed concerns regarding persistently high average detention rates over the past few years. After a rate of 4.25% in 2022 and 3.81% in 2023, the rate unfortunately increased again to 4.03% in 2024.
In 2024, the Paris MoU conducted 16,508 inspections, which resulted in 665 detentions. The general ISM deficiency remains one of the most frequently recorded issues, accounting for 4.6% of all deficiencies in 2024. This continued high frequency of ISM-related findings underscores the critical importance of analysing audit and inspection data to identify and address the root causes of non-compliance.