Frequenty Asked Questions

This page contains answers to commonly asked questions about the Paris MoU inspection regime.

 

Banning

Why has my ship been banned from the Paris MoU region?

1. In accordance with section 4.1 of the Paris MOU, ships are banned after multiple detentions: these ships will be refused access to any port in the region of the Memorandum for a minimum period. The refusal of access following multiple detentions will become applicable as soon as the ship leaves the port or anchorage. 

2. In accordance with section 4.2 of the Paris MOU, ships which jump detention or fail to call at an indicated repair yard are banned: these ships will be refused access to any port in the region of the Memorandum. 

Notwithstanding the provisions of section 4.1 and 4.2, access to a specific port may be permitted by the relevant authority of that port State in the event of force majeure or overriding safety considerations, or to reduce or minimize the risk of pollution, provided that adequate measures to the satisfaction of the authority of such State have been implemented by the owner, the operator or the master of the ship to ensure safe entry. * Please note that the particulars of the ships on this list are only updated by the banning authority. The main identifier of a banned ship is the IMO number.

When a ship is “banned” and then sold to another Party, does this transaction automatically cancel the “banned” status or does the status continue?

A ban is a measure imposed on an individual ship. Once banned, a transfer of company, flag or change in other involved parties does not revoke a ban or otherwise shorten the applicable periods mentioned.

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Deficiencies

To whom can a company appeal in case deficiencies identified are not justified?

In the case the company is of the opinion that deficiencies identified are not justified the company can raise an appeal to the national PSC authority.

Is there a standard code for categorizing deficiencies as ISM definiencies?

ISM related deficiencies are coded with numbers from 151XX on PSC inspection forms. Deficiencies related to ISM will be marked with the following reference (ISM).

What kind of deficiencies would be categorised as a "Non ISM deficiency"?

A non-ISM deficiency is any deficiency not directly related to the provisions of the ISM Code. Such deficiencies could be related, but are not limited to: technical, operational or environmental requirements;certification and documentation; or working and living conditions on board. The convention reference for such deficiency does not refer to the ISM Code.

Can a company request clarification from the PSC which convention reference applies to the deficiencies?

In case of a detainable deficiency the Port State Control Officer (PSCO) is required to indicate the Convention reference on the inspection report. In case of a deficiency the PSCO may indicate the Convention reference on a voluntary basis. The master or company may seek clarification from the PSC authority regarding the legal basis to any deficiency.

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Inspections

In case of a badly hand written report can the company request a printed report?

PSC inspection reports can be printed or hand written. In case the handwritten report is not legible, the master may request a printed report from the port State. However, there is no legal requirement for the port State to issue a printed report.

 

Can a PSC inspection be ordered by the ship company?

Under normal circumstances a ship company can not order a PSC inspection. In case of laid-up ships the PSC authority will be in contact with the ship company to plan the PSC inspection if the ship must be inspected.

What is the meaning of "missed inspection”? Does it mean the inspections which cannot be done due to the busyness of the port?

A missed inspection is something which is related to a PMoU member only. Members have an annual inspection target and may miss a percentage without compromising their obligations.

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Reporting Obligations

What are the reporting obligations for ships due for an expanded inspection?

Ships due for an expanded inspection have to report  72 hours (72 ETA) before arriving at a port or anchorage of the Paris MoU region or before leaving the previous port or anchorage if the voyage is expected to take less than 72 hours the following information to the port authority:(a)  ship identification (name, flag, call sign IMO or MMSI number);
(b)  port of destination;
(c)  estimated time of arrival (ETA);
(d)  estimated time of departure (ETD);
(e)  planned duration of the call;
(f)   for tankers
       i.   configuration: single hull, single hull with SBT, double hull;
       ii.  condition of the cargo and ballast tanks: full, empty, inerted;
       iii. volume and nature of cargo;
(g) planned operations at the port or anchorage of destination (loading, unloading, other)
(h) planned statutory survey inspections and substantial maintenance and repair work to be carried out whilst in the port of destination;
(i) date of last expanded inspection in the Paris MoU region.

Be aware that there are other reporting obligations for all ships.

Do High Risk Ships or ships being subject to an Expanded Inspection by ship type and age have to sent the 72 hour's message only if a vessel is due for the inspection

Each ship eligible for an Expanded inspection shall report its arrival at least three days in advance and shall provide the necessary details. Depending on its Risk Profile and/or ship type and age, the ship has to report when the time window for inspection is open e.g. either from the 5th, 10th or the 24th month onwards.

Should the reporting message be entered into the SafeSeaNet (SSN) data system?

Information shall be provided by the ship or its representative to the competent authorities, who then may provide the information to SSN.

Do all vessels have to announce their arrival 24 hours in advance for PSC purposes throughout the year or only if the time frame (according to the present risk category) is open for an inspection?

The 24 hour requirement is a general requirement. Each ship has to report its arrival at least 24 hours in advance at any time.

Does a vessel have to report ETA72/24 to all ports when calling more than one port consecutively in the Paris MoU or is the report to be made only to the first port in the Paris MoU region?

A vessel has to report 24 hours (24 ETA) before arriving at a port or anchorage of the Paris MoU region or before leaving the previous port or anchorage if the voyage is expected to take less than 24 hours. Thus, this pre-arrival notification has to be reported to all ports in the Paris MoU region the vessel calls.The 72 hours reporting obligation (72 ETA) is only required when the vessel is due for an expanded inspection. Ships due for an expanded inspection are High Risk Ships (HRS) and Risk Ship Type (Oil tanker, Bulk carrier, Passenger ship, Gas carrier and Chemical tanker, which are more than 12 years old). The operator, agent or Master of a vessel shall notify it's arrival at least 72 hoursbefore the expected time of arrival or before leaving the previous port or anchorage if the voyage is expected to take less than 72 hours. Once the vessel has been through the expanded inspection, the 72 ETA is offcourse no longer an obligation

 

To whom and in what way do the pre-arrival notification have to be sent?

The final destination of the 72 and 24 hour pre-arrival notifications is the port authority of the respective port. The master could chose to send the information directly, or through the agent, company or any other entity considered appropriate. 
 

The contact details of the port authorities to whom pre-arrival notifications have to be sent can be found in the respective Nautical Publications, Almanacs, port guides, webpages and through local agents.

The means of communicating the pre-arrival notification depends on the local situation.

Are ships penalized if notices for expanded inspections are sent without being due for an expanded inspection?

No, these ships are not penalized. The reporting obligations for ships are described in Annex 12 of the Paris Memorandum. These obligations are not stopping ships to report more often than required. Although no penalties are issued, the advice is not to report in case the reporting is not required, to prevent unnecessary administrative burden.

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Ship Risk Profile

What are the criteria for the calculation of the Company Performance and how are these taken into account

The Company Performance is calculated as follows:
Company performance takes account of the detention and deficiency history of all ships in a company’s fleet while that company was the ISM company for the ship. Companies are ranked as having a “very low”, low, medium or high” performance. The calculation is made daily on the basis of a running 36-month period. There is no lower limit for the number of inspections needed to qualify except a company with no inspections in the last 36 months will be given a “medium performance”. The formula consists of two elements, the deficiency index and the detention index.

Deficiency Index 

When counting deficiencies each ISM related deficiency is weighted at 5 points. Other deficiencies are valued at 1 point. The Deficiency Index is the ratio of the total points of all deficiencies of all ships in a company’s fleet to the number of inspections of all ships in the company’s fleet within the last 36 months. This ratio is compared with the average for all ships inspected in the Paris MoU over the last 3 calendar years to determine whether the index is average, above average or below average as follows:

Deficiency index                              Deficiency points per inspection

Above average                                > 2 above PMoU average

Average                                          PMoU average ± 2

Below average                                > 2 below PMoU average

 

Detention Index 

The Detention Index is the ratio of the number of detentions all ships in a company’s fleet to the number of inspections of all the ships in the company’s fleet within the last 36 months. This ratio is compared with the average for all ships inspected in the Paris MoU over the last 3 calendar years to determine whether the index is average, above average or below average as follows:

Detention index                              Detention rate

Above average                                 > 2 above PMoU average

Average                                           PMoU average ± 2%

Below average                                 > 2 below PMoU average

 

What is an IMO audit?

IMO audit means the Voluntary IMO Member State Audit Scheme (VIMSAS) according to IMO Resolution A.974(24). The audit is carried out by trained auditors under the auspices of the IMO.

 

 

Will changes made to an inspection report after an appeal effect the Ship Risk Profile (SRP)?

All changes made to an inspection report after recording in the Paris MoU Database THETIS will have an effect on all related issues, including the SRP. The calculation of the SRP is done by THETIS on the basis of the recorded information in the database.

How do the risk factors affect Priority I and II?

The risk factors affect on how often a ship will be periodically inspected. Periodic inspections are determined by a time window. Each ship will be classified as High Risk Ships (HRS), Standard Risk Ships (SRS) or Low Risk Ships (LRS) using details of inspections in the PMoU area in the last 3 years.

What are the main differences between Priority I and Priority II?

Each ship will be attributed with a ship risk profile. Depending on the time since the last inspection in combination with the ship risk profile applicable, the ship will be prioritized for inspection. A Priority II ship may be inspected; a Priority I must be inspected. These are no obligations for the ship but for the PMoU member where the ship calls. Priority I status may also be invoked if there is an event triggering an overriding inspection such as when the ship has been reported to be manoeuvring erratically.

In case a Recognized Organisation is not listed in the table “Recognized Organization Performance” how will this affect the Ship Risk Profile (SRP)?

Ships with a Recognized Organisation which is not listed in the table “Recognized Organization Performance” can not be a Low Risk Ship (LRS). The following criteria are not fulfilled:

- Recognized Organization to be high performance, and
- recognized by one or more Paris MoU members.

Furthermore, for the calculation of the High Risk Ship (HRS) profile, the ship will not gain any points for the criterion Recognized Organization performance as the RO does not appear on the Paris MoU list.

Will it be possible to see on the public website of the Paris MoU a list of States which have undergone the Voluntary IMO Member State Audit Scheme (VIMSAS)?

There will be no information on the Paris MoU public website to indicate which State has undergone the VIMSAS.This information is distributed by an internal IMO Circular which is not publicly available. Individual States may decide to make the information publicly available, but there is no requirement to do so.States are invited to inform the Paris MoU Secretariat as soon as an audit has been concluded. However, according to paragraph 12 in Annex 7 of the amended memorandum, the Paris MoU Secretariat will maintain on the Paris MoU public website an up-to-date list of flag States which meet the flag criteria for a low risk ship. Accordingly flag States figuring on this list will all have been through the voluntary IMO Audit and will be a white listed flag.

What will be the Ship Risk Profile and the Priority of a new building not inspected in the Paris MoU region?

The Ship Risk Profile of a new building not inspected in the Paris MoU region will be either Standard Risk or High Risk depending on the generic Factors (Flag, RO, Company performance and ship type). A new building can never be Low Risk since one of the criteria for Low Risk Ships (inspected within the last 36 months) is not fulfilled. New buildings will be Priority I (PI) and subject for inspection when arriving to the Paris MoU region for the first time.

Will the PSC history of a ship stay with the ship in case it is changing the company?

The PSC history of a ship will not be deleted in case it changes the company. For the calculation of the historic parameters "Number of deficiencies recorded in each inspection within the previous 36 months" and "Number of detentions within the previous 36 months" a change of company has no effect. The ship's PSC history will not affect a purchaser's company profile, but will remain to affect the seller's company profile for a period of 3 years.

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Feedback

Where to send Feedback?

Please send your Feedback to this address: secretariat@parismou.org

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