Can a seafarer complain to PSC anonymously?

Yes. MLC Regulation 5.2.2 and Standard A5.2.2 give any seafarer the right to make an on-shore complaint to port-state-control authorities. The PSC officer must treat the identity of the complainant as confidential and may not disclose it to the Master or shipowner without the seafarer's explicit consent.

What is the difference between a deficiency and a detention?

A deficiency is any non-conformity with an applicable convention recorded by the PSC officer. A detention is imposed when one or more deficiencies are severe enough that the ship is judged unsafe to proceed to sea, harmful to the marine environment, or unacceptable for the working and living conditions of crew. Not every deficiency leads to detention.

What triggers a High Risk Ship profile?

Under the Paris MoU New Inspection Regime, a High Risk Ship is one with a combination of: Black or Grey flag, high-risk Recognised Organisation (class society), ship type (tanker, bulk carrier, gas carrier), age over 12 years, more than two deficiencies in the last 36 months, or a previous detention. High-Risk Ships must be inspected every 5–6 months.

Does the Paris MoU and Tokyo MoU use the same inspection database?

No, but they cooperate. Paris MoU uses THETIS; Tokyo MoU uses APCIS. Both systems feed into the IMO Global Integrated Shipping Information System (GISIS) and exchange data on ship inspection and detention history. A detention in a Tokyo MoU port is visible to Paris MoU inspectors and vice versa.

Port-state-control regimes — what to expect in port

Port state control (PSC) is the inspection of a foreign-flag ship in a national port to verify compliance with IMO conventions — SOLAS, MARPOL, STCW, MLC 2006, Loadlines, COLREGs, AFS — and ILO standards. It is the enforcement backstop when a flag state fails to act. Eleven regimes cover virtually every major trading port in the world: nine regional Memoranda of Understanding and two national regimes (USCG and AMSA). Understanding how each regime targets, inspects, and detains is essential for seafarers and operators on any trade route. IMO Resolution A.1138(31) provides the current consolidated guidance on PSC procedures.

Your right to complain — MLC Regulation 5.2.2

In every port that is a member of any of the regimes below, you have the right to make an on-shore complaint directly to the port-state-control authority under MLC Regulation 5.2.2. The PSC officer is obliged to investigate and to treat your identity as strictly confidential — your name will not be disclosed to the Master, shipowner, or flag administration without your consent. You do not need to wait for a PSC inspection; you may approach the authority directly at the port. In practice, ITF inspectors in the port can help you make contact.

PSC regimes

Paris MoU27 authoritieswww.parismou.org
Europe and the North Atlantic — 27 maritime authorities including EU member states, Canada, and Iceland.
Targeting:
New Inspection Regime (NIR): Ship Risk Profile (Low / Standard / High) based on flag performance list, RO performance, ship type, age, deficiency and detention history, and company index. High-Risk Ships inspected every 5–6 months.
What triggers inspection:
Ship type (tanker, bulk, gas, passenger), age ≥ 12 years, Black or Grey flag, previous detention, overdue inspection window, casualty report, crew complaint, operational deficiencies observed at berth.
Detention:
Ship cannot depart until deficiencies rectified and flag administration issues clearance. Detention is published in THETIS and the Paris MoU annual report.
Seafarer rights:
MLC Reg 5.2.2 on-shore complaint available in all 27 member ports. Seafarer names protected. ITF inspectors available in many European ports.
Tokyo MoU21 authoritieswww.tokyo-mou.org
Asia and the Pacific — 21 authorities including Japan, China, South Korea, Australia, India, Russia (Pacific), and ASEAN members.
Targeting:
Concentrated Inspection Campaigns (CICs) run 1–2 times per year on a specific theme. Ship risk profile similar to NIR but adapted for Asia-Pacific trade patterns. APCIS database shared among members.
What triggers inspection:
Same NIR-equivalent factors as Paris MoU. CIC topics add a focused extra checklist. High inspection volume — Tokyo MoU records more inspections annually than any other MoU.
Detention:
Detention records published in APCIS and annual statistics. Flag-performance list updated annually; Grey and Black flags face heavier targeting.
Seafarer rights:
MLC complaint available at all member ports. ITF coverage strong in major East Asian and Australian ports.
USCG (United States)National regimewww.dco.uscg.mil/Our-Organization/Assistant-Commandant-for-Prevention-Policy-CG-5P/Inspections-Compliance-CG-5PC-/Port-State-Control/
United States ports and anchorages — national PSC regime, not an MoU.
Targeting:
Risk-based examination system using the Vessel Targeting System. QUALSHIP 21 flags receive reduced examination frequency. Non-QUALSHIP 21, older, or deficiency-burdened ships targeted more aggressively.
What triggers inspection:
Flag PSC history, ship type, age, cargo, previous USCG deficiencies, overdue examination window, casualty, anonymous crew complaint.
Detention:
Detention (Control Action) prevents departure. USCG publishes inspection results publicly on its Marine Information for Safety and Law Enforcement (MISLE) system.
Seafarer rights:
Crew members may call the USCG Marine Safety Hotline to report unsafe conditions. Identity protected.
AMSA (Australia)National regimewww.amsa.gov.au/vessels-operators/port-state-control
Australian ports — national PSC regime operating alongside Tokyo MoU membership.
Targeting:
Risk-based; AMSA inspects a high proportion of vessels and maintains a strong enforcement culture. Priority targeting for tankers, bulk carriers, and vessels with prior AMSA deficiencies.
What triggers inspection:
Flag performance, ship age, type, previous detentions, operational observations at berth.
Detention:
AMSA publishes detention notices and deficiency data. Appeals available but vessel remains detained pending resolution.
Seafarer rights:
24/7 seafarer complaint line. MLC complaints handled directly by AMSA inspectors.
Indian Ocean MoU20 authoritieswww.iomou.org
Indian Ocean rim — 20 authorities including India, South Africa, Sri Lanka, Iran, Mauritius, Tanzania, and Maldives.
Targeting:
Risk-profiling aligned with NIR principles. Cooperation with Paris MoU and Tokyo MoU on shared targeting data.
What triggers inspection:
Flag performance, ship type and age, deficiency history, reports of crew complaints.
Detention:
Detention records maintained in IOMoU database. Annual performance report published.
Seafarer rights:
MLC complaints may be lodged with inspectors in all member ports.
Caribbean MoU16 authoritieswww.caribbeanmou.org
Caribbean basin — 16 authorities including Jamaica, Trinidad and Tobago, Barbados, and Belize.
Targeting:
Cruise-ship-heavy inspection regime. Targeted inspections on passenger vessels, ferries, and cargo ships with Caribbean-region port call history.
What triggers inspection:
Ship type (passenger/ferry heavily targeted), flag performance, overdue inspection.
Detention:
Detention notices shared with Paris MoU and USCG. Records publicly available on Caribbean MoU website.
Seafarer rights:
On-shore complaint procedure available per MLC Regulation 5.2.2.
Mediterranean MoU10 authoritieswww.medmou.org
Mediterranean rim — 10 authorities including Morocco, Tunisia, Algeria, Egypt, and Jordan.
Targeting:
Smaller regime with several members overlapping with Paris MoU. Priority targeting on older vessels and non-MLC-compliant flags.
What triggers inspection:
Flag Black/Grey status, ship type, age, crew complaint.
Detention:
Coordination with Paris MoU and IOMoU. Annual statistics published.
Seafarer rights:
MLC complaint procedure operative.
Black Sea MoU6 authoritieswww.bsmou.org
Black Sea states — 6 authorities: Bulgaria, Georgia, Romania, Russia, Türkiye, Ukraine.
Targeting:
Risk-based targeting using shared Black Sea MoU database. Older bulk carriers and general cargo vessels are primary targets.
What triggers inspection:
Flag performance, age, type, overdue inspection window.
Detention:
Detention data published; cooperation with Paris MoU (Bulgaria and Romania are also Paris MoU members).
Seafarer rights:
MLC complaint procedure operative in all member ports.
Riyadh MoU6 authoritieswww.riyadhmou.org
Persian Gulf — 6 authorities: Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, UAE.
Targeting:
Heavy tanker traffic; priority on tank vessels, LPG/LNG carriers, and vessels with MARPOL exposure. Risk profiling evolving toward NIR standards.
What triggers inspection:
Vessel type (tanker/gas), flag performance, MARPOL deficiency history.
Detention:
Detention records shared with IMO GISIS. Annual statistics published.
Seafarer rights:
MLC complaint process available; limited ITF inspector coverage in the region.
Abuja MoU22 authoritieswww.abujamou.org
West and central Africa — 22 authorities including Nigeria, Ghana, Côte d'Ivoire, Cameroon, Angola, and Senegal.
Targeting:
Active capacity-building phase; inspection volume growing. Oil and gas supply vessels, bulk carriers, and fishing vessels are primary targets.
What triggers inspection:
Flag performance, vessel type, overdue inspection.
Detention:
Detention data reported to IMO GISIS. Annual harmonisation with other MoUs progressing.
Seafarer rights:
MLC on-shore complaint procedure operative.
Viña del Mar Agreement15 authoritieswww.acuerdolatino.int.ar
Latin America — 15 authorities including Brazil, Argentina, Chile, Colombia, Mexico, Peru, and Venezuela.
Targeting:
Risk-based targeting with strong links to Caribbean MoU. Bulk carriers and container vessels are frequent inspection targets.
What triggers inspection:
Flag performance, overdue inspection window, cargo type (dangerous goods).
Detention:
Detention data shared with Caribbean MoU. Annual statistics published in Spanish and Portuguese.
Seafarer rights:
MLC complaint procedure available in signatory ports.

Port-state-control regimes — what to expect in port

Your right to complain — MLC Regulation 5.2.2

PSC regimes

Primary sources

See also