MARPOL covers pollution prevention, ISM covers the safety management system, and ISPS covers ship security. A condition survey against them checks whether the equipment functions, whether the record books match the physical arrangements, and whether the crew actually does what the paperwork says.
These three regimes generate most detentions we see. Almost none of the deficiencies are expensive to fix; nearly all of them are expensive to be detained for.
MARPOL — what an inspector traces by hand
- Oily water separator: function, 15 ppm alarm operation, and whether the piping actually matches the approved drawing. Inspectors follow pipes physically.
- Oil record book: entries consistent with the system, the tank capacities and the voyage. Gaps and impossible entries are the classic finding.
- Sewage treatment plant condition and discharge arrangements.
- Garbage management plan, placards, and a garbage record book that matches reality.
- Sludge tank capacity and disposal receipts.
- Fuel changeover arrangements and records where emission control applies.
ISM — paperwork versus practice
The safety management system is not audited on whether it exists. It is audited on whether it is lived. The recurring findings are drills recorded but not performed, non-conformities raised and never closed, maintenance records back-filled in one handwriting the night before, and a master’s review that has not happened.
- Drill records with realistic dates, times, participants and lessons.
- Planned maintenance system entries that match the physical condition of the equipment.
- Non-conformity register with genuine closure evidence.
- Master’s review completed and signed within the required period.
- Familiarisation records for new crew, dated on joining.
- Risk assessments for the operations the vessel actually performs.
ISPS — access control in practice
- Ship security plan current and approved, and the security officer designated and trained.
- Access control actually applied — gangway watch, visitor log, identity checks.
- Restricted areas marked and secured.
- Security drills and exercises recorded.
- Declaration of security procedure with terminals where required.
- Security equipment, including the ship security alert system, tested and logged.
Load line — the fourth one everyone forgets
Not one of the three, but it produces detentions at the same rate: freeboard marks legible and correctly positioned, closing appliances weathertight, air pipes and ventilator closures intact, freeing ports clear and operable, hatch securing complete. Most of these are maintenance items that cost very little and are simply not looked at until an inspector looks at them.
Frequently asked questions
What is a MARPOL compliance survey?
A condition inspection against the applicable MARPOL annexes — equipment function, record book consistency, physical arrangements. It is preparatory; statutory certification remains with the flag or its recognised organisation.
Can you attend a port state control inspection?
We can attend as the owner’s technical adviser and produce a rectification plan for any deficiencies raised.
How long does a pre-inspection condition survey take?
Typically one day on a small to medium commercial vessel, plus the report within three to five working days.