Port State Control (PSC) is increasingly consistent on MARPOL Annex VI: when documentation, recording, and “day-to-day evidence” don’t match the equipment onboard, deficiencies are raised quickly—often under NOx (Reg. 13), SOx (Reg. 14), BDN (Reg. 18), incineration (Reg. 16), and alternative arrangements (Reg. 4 / EGCS).
Below is a practical, ship-ready summary of the most common deficiencies and the simple controls that prevent them—based on recurring PSC findings.
1) NOx Technical File & EIAPP not available / not aligned (Reg. 13)
What PSC often finds
- Missing EIAPP Certificate and/or NOx Technical File onboard for certified engines.
- Spare parts (e.g., fuel injectors/nozzles) ID numbers don’t match what’s listed in the NOx Technical File.
- Where Direct Measurement & Monitoring is used, the Onboard Monitoring Manual is missing or not approved.
How to avoid
- Keep onboard (and readily retrievable): EIAPP + approved NOx Technical File for each applicable diesel engine.
- Establish a simple cross-check routine: spare part IDs vs NOx TF before installation.
- If Direct Measurement & Monitoring applies: ensure the approved Onboard Monitoring Manual is onboard and used.
2) Record Book of Engine Parameters incomplete (Reg. 13 / NOx Technical Code 6.2.2.7–6.2.2.8)
What PSC often finds
- Record book missing, incomplete, or not updated after component changes.
- No evidence of designated components/settings list or load-dependent values approved/accepted.
- Modifications carried out with no technical documentation.
How to avoid Maintain onboard:
- Record Book of Engine Parameters
- Approved engine parameter list / settings documentation
- Modification documentation whenever any designated component is changed
And ensure the record book includes component identification numbers affecting NOx (typical examples PSCOs check):
- fuel injectors/pumps, camshafts, pistons, turbochargers, charge air coolers Log original + replacement IDs when changes occur.
3) “Approved Method” evidence missing or incorrectly reflected in IAPP Supplement (Reg. 13.7)
What PSC often finds
- Engine subject to “approved method” requirements, but no certification/evidence onboard.
- IAPP Supplement entries not completed consistently with the ship’s actual configuration.
How to avoid
- Confirm whether any engine falls under the “approved method” applicability.
- Ensure IAPP Supplement section 2.2.1 is completed correctly and evidence is onboard.
4) EGR arrangements: discharge standards / manuals / record book issues (Reg. 13)
What PSC often finds
- Missing approved EGR discharge system manual and/or EGR Record Book.
- Missing certificates/type approval and O&M manuals for 15 ppm oil content meters (with alarm).
- Evidence gaps on bleed-off water discharge compliance.
How to avoid
- Keep onboard: approved manuals, record book, type approvals, O&M documentation.
- Treat EGR records like “inspection-grade evidence”: entries must match actual operation and maintenance.
5) EGR/SCR not meeting Tier III before NOx ECA entry – notification not managed (Reg. 13)
What PSC often finds
- Non-compliance risk known, but no immediate notification to relevant coastal State(s) and Administration before entering a NOx ECA.
How to avoid
- Include a clear bridge/engine-room trigger: if Tier III compliance cannot be achieved prior to ECA entry → notify immediately and retain records of communications and actions.
6) Tier II/Tier III engine status (ON/OFF) not recorded at ECA entry/exit (Reg. 13.6)
What PSC often finds
- Missing logbook entries for tier and on/off status, including date/time/position at:
How to avoid
- Use a standard engine-room log template (paper or approved electronic) with mandatory fields: date / time / position / ECA / engine status.
7) Fuel sulphur limits, change-over procedure, and SOx records (Reg. 14)
What PSC often finds
- No written fuel change-over procedure or procedure not usable in practice (insufficient flushing time).
- Incomplete records: date/time/position and tank volumes at completion/commencement of change-over.
- In-port fuel sulphur requirements (e.g., EU berth limits) overlooked.
How to avoid
- Carry a clear written change-over procedure (many ships use a change-over calculator to prove timing).
- Record in logbook/approved electronic record:
8) EGCS as an alternative arrangement: documentation and monitoring weak points (Reg. 4 & 14)
What PSC often finds
- EGCS approval basis unclear; missing ship-specific approved documents.
- Missing/insufficient onboard documentation such as:
- Crew not familiarised with EGCS operation (Global/ECA modes).
- EGCS mode changeover not recorded.
- CEMS / washwater discharge monitoring not fully operational; calibration/maintenance records missing.
- Non-compliant temporary modifications (e.g., sampling line arrangements).
How to avoid
- Confirm the EGCS is approved as equivalent for both Global and ECA operation as applicable.
- Keep all approved EGCS documentation onboard and accessible.
- Run and record:
- Ensure span gases are in-date and suitable.
- Avoid temporary/unapproved sampling line modifications.
- Establish a contingency rule: if EGCS cannot be restored promptly, be ready to switch to compliant fuel and coordinate a documented plan with relevant authorities if compliant fuel is insufficient.
9) Incinerator: Type Approval / operating manual gaps (Reg. 16)
What PSC often finds
- Incinerator Type Approval certificate missing.
- Manufacturer operating manual not onboard or not followed.
How to avoid
- Keep the Type Approval and manual onboard; ensure watchkeepers can explain operating limits and controls.
10) Bunker Delivery Notes (BDN): missing or incomplete (Reg. 18)
What PSC often finds
- BDN missing (including for recent bunkers) or not retained for required period.
- Key fields missing/unclear (sulphur, flashpoint statement, supplier declaration).
- BDN not properly signed/certified by supplier representative.
How to avoid
- Treat BDNs like statutory certificates: easy access, complete fields, and consistent filing (paper or accepted electronic format).
- Cross-check sulphur content and declarations against operational use and records.
A simple onboard self-check (15 minutes before arrival)
If you want to reduce Annex VI findings fast, ask the engine room to confirm:
- EIAPP + NOx Technical File onboard for each applicable engine
- Engine parameter record book updated with component IDs and modifications
- ECA entry/exit engine tier status logged (date/time/position)
- Change-over procedure available + change-over records complete
- EGCS (if fitted) documents + record book + calibrations + mode change logs in order
- BDNs complete, signed, and readily retrievable
- Incinerator approval + operating manual available
Closing
PSC doesn’t only check “what you have”—they check whether the ship can prove compliance through consistent documentation, records, and operational evidence. MARPOL Annex VI is one of the fastest areas where small gaps become formal deficiencies.
Contact Marine Surveyor Consultant for a Pre-PSC Inspection to identify and close MARPOL Annex VI gaps before your next port call.
