Documentation Required on Board
Certificates and documents must be valid and available; each record book is completed promptly when the required operation, event or communication occurs, without retrospective reconstruction.
Operational Explanation
Every PSCO begins the inspection with a documentary check: statutory certificates, class certificates, and the main operational records. Incomplete, expired or inconsistent documentation is often the first signal that steers the inspector towards a more thorough check (a "clear grounds" verification).
The practical difficulty is not knowing the list of required documents, but keeping them always up to date and consistent with one another: a certificate renewed but not replaced in the copy held on board, or a record with missing entries, generate deficiencies even when the ship's substantive condition is compliant.
Regulatory Reference
SOLAS, MARPOL, the ISM Code, MLC 2006 each define, within their own scope, the mandatory certificates and records: statutory certificates (IOPP, IAPP, ISPP, Safety Construction/Equipment/Radio or Cargo Ship Safety Certificate, SMC, DOC, ISSC, MLC Certificate), operational records (Oil Record Book, Garbage Record Book, Ballast Water Record Book, radio log), and manuals (SOPEP, Garbage Management Plan, Cargo Securing Manual).
Where the power to come on board comes from. Not from the Memorandum. A regional MoU is an administrative arrangement between Administrations: it harmonises how inspections are done, it does not create the right to inspect. That right sits in the control articles of the Conventions, which resolution A.1206(34) — Procedures for Port State Control, 2025 — lists one by one at its paragraph 1.4. For SOLAS there are four regulations, not one: I/19, IX/6.2 (ISM), XI-1/4 and XI-2/9 (ISPS). For MARPOL, Articles 5 and 6 plus one provision per Annex: reg. 11 of Annex I, reg. 16.9 of II, reg. 9 of III, reg. 14 of IV, reg. 9 of V and reg. 10 of VI. The “reg. 9 of III” surprises anyone who opens Annex III in the text adopted by res. MEPC.193(61), where port State control on operational requirements is Regulation 8: res. MEPC.246(66), in force from 1 January 2016, inserted a new Regulation 1 “Definitions” into it and provided that “the subsequent regulations are renumbered accordingly”. Since 2016 that provision has been Regulation 9, and that is the number A.1206(34) carries. Then Article 21 of the Load Lines Convention 1966 as modified by the 1988 Protocol, Article X of STCW, Article 12 of TONNAGE 1969, Article 11 of AFS 2001 and Article 9 of BWM 2004. For the MLC, an ILO and not an IMO instrument, the basis is Regulation 5.2.1 with Standard A5.2.1.
The practical consequence is that challenging an inspection on the ground that your flag State is not party to the Memorandum leads nowhere: the inspector is not acting under the Memorandum, but under the control article of the Convention the flag State has ratified.
Scope of Application
Every ship subject to PSC inspection, with the specific list of required documents varying according to ship type, tonnage and area of operation.
Procedure / How to Complete It
- Check validity, endorsements and applicability of each certificate.
- Complete ORB, GRB, BWRB and radio log promptly and accurately whenever the operation, event or communication required by the respective instrument occurs.
- Do not invent daily entries or reconstruct records before arrival.
- Check each record book's form, signature and retention rules separately.
Practical Example
Example of verification: before arrival in port, the Chief Officer verifies that the IOPP, IAPP, SMC and Garbage Management Plan are all valid and that the copies on board match the latest versions issued after the last survey.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| On-board copy of a certificate not updated after a renewal | Deficiency for inconsistent documentation, even though the certificate is substantively valid | Replace the on-board copy immediately after every renewal or audit |
| Records updated retroactively shortly before arrival in port | Inconsistencies detectable by the PSCO, suspicion of falsification | Update records daily, in real time with operations |
| No on-board reference point who knows the location of all the documentation | Delays during the inspection, an impression of disorganisation | Designate an officer responsible for documentary retrievability |
What the PSCO Checks
Operational Tips
- Keep a single calendar of deadlines for all certificates, shared between ship and Company.
- Always update the on-board copy immediately after every renewal, not at the next convenient occasion.
- Explicitly designate a person responsible for documentary retrievability, known to the whole crew.
Preparation checklist
- Certificates valid and available
- Record books completed for prescribed events
- No retrospective reconstruction
- Specific signature/retention duties checked
FAQ
Related Topics
Last substantive revision of this page: 31 August 2026 · page fingerprint 9fbf7d61d78b