Staying Compliant: Preparing for GHG-Focused PSC Inspections

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  • Port State Control (PSC) inspections focus heavily on GHG compliance, including NOx Technical Files, EIAPP certifications, and Engine Parameter Records.
  • Common deficiencies leading to vessel detentions include missing Technical Files, incomplete Record Books, and engine parts lacking IMO identification numbers.
  • DNV offers guidance to prepare for PSC inspections by maintaining proper documentation, verifying component IDs, and ensuring compliance with NOx emission parameters.

International regulations on greenhouse gas (GHG) emissions have placed Port State Control (PSC) inspections in the spotlight. These inspections are increasingly scrutinizing NOx Technical Files and Record Books of Engine Parameters, with detainable deficiencies leading to vessel delays and operational disruptions. DNV highlights the most common issues and provides actionable steps to ensure compliance and avoid detention.

GHG Regulations and PSC Focus

Port State Control Officers (PSCOs) are intensifying their checks on engine documentation and spare parts for compliance with NOx Technical Files. Missing or incorrect records and mismatched IMO IDs have led to numerous detentions.

In some cases, PSCOs have requested partial disassembly of engines for detailed inspections.

Common Deficiencies Identified

Examples of issues encountered include:

Missing NOx Technical Files for main engines and generators.

Incomplete Record Books of Engine Parameters, especially when documenting component replacements.

Engine parts, such as charge air coolers, lack the required IMO identification numbers.

Causes of Deficiencies

Detentions are often caused by misunderstandings or lack of proper instructions on board.

Missing documents or improper updates to Record Books can lead to non-compliance during PSC inspections.

Preparation for PSC Inspections

DNV recommends the following measures:

Maintain original NOx Technical Files and EIAPP certificates (physical or digital PDF versions).

Ensure proper handover of these documents during ownership changes.

Keep an updated Record Book of Engine Parameters, documenting all parameter changes and component replacements.

Conduct inspections to verify compliance with NOx Technical File specifications.

Corrective Measures for Non-Compliance

If discrepancies are found, shipowners should obtain missing Technical Files or components with correct IDs from manufacturers.

They should make necessary corrections to ensure engine settings and features are within allowable NOx emission ranges.

Recommendations:

To avoid detentions and ensure compliance:

  1. Regularly review and update NOx Technical Files and Record Books.
  2. Verify all engine components and spare parts are correctly identified and documented.
  3. Follow DNV’s guidance to maintain operational readiness for PSC inspections.

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Source: DNV