PSC & Compliance Risk

Five regimes, one view.

A vessel operates inside a regulatory cage made of five overlapping regimes. A finding in one can compound a finding in another. A repeat finding across regimes is the signal that something fundamentally isn’t working.

PSC detention riskSIRE 2.0CDICII trajectoryrepeat themes

The five regimes

Regime	Issued by	What it controls
PSC	Port State Control authorities	Right to enter and leave port
SIRE 2.0	OCIMF (oil major vetting)	Eligibility for tanker charter
CDI	Chemical Distribution Institute	Eligibility for chemical-tanker charter
VIR	Charterer / inspector inspections	Per-charter performance
CII	IMO Carbon Intensity Indicator	Annual rating against required intensity

The pipeline reads all five together. Detention risk depends on more than just PSC; commercial-charter eligibility depends on more than just SIRE.

Cross-regime fleet view

A fleet-wide dashboard rows up per-vessel exposure at a glance:

Vessel    Last PSC    Findings   Detention   Last SIRE    Sev 3+   CII Y-1   CII Y0   Verdict
POSUN     Mar 2026    2 minor    No          Feb 2026     1        C         C        OK
AQUILA    Jan 2026    5 mixed    No          Dec 2025     0        C         D        Watch
OCEAN     Apr 2026    8 mixed    Yes (3d)    Mar 2026     2        D         E        Escalate

OCEAN has a recent detention, multiple SIRE Severity 3+ observations, and a CII trajectory dropping from D to E — three regimes pointing in the same direction.

Worked example — MV OCEAN

End-of-April compliance review:

Regime	Status	Verdict
PSC	8 open deficiencies (3 major, 5 minor); detained 3 days at Houston in March	HIGH
SIRE 2.0	12 observations from Mar inspection; 2 Severity 3, response window closing in 8 days	HIGH
CDI	N/A (not chemical tanker)	—
VIR	4 open from latest charterer inspection	MEDIUM
CII	2025 attained C, 2026 trajectory at D/E boundary, projected E if unchanged	CRITICAL

Repeat themes found:

Crew familiarity finding in PSC (Houston) and SIRE (separate inspection) — same root cause, two regimes.
ECDIS update finding repeats across last two SIRE inspections — procedural gap not closed.

Verdict: CRITICAL. The pipeline:

Routes the SIRE Severity 3 response to crewing — operator response due in 8 days.
Routes the CII trajectory to the voyage pipeline for operational-change recommendation.
Generates a repeat-theme remediation plan covering crew familiarity training across the fleet.
Flags ECDIS update procedure to QHSE for SMS revision.

Under the hood

PSC — how it’s tracked

The most operationally consequential regime. A PSC inspection produces deficiencies and, in severe cases, a detention. The pipeline tracks:

Open PSC deficiencies (deficiency code, severity, action taken)
Detention history (when, where, cause, duration)
Repeat themes (same deficiency code on multiple inspections)
Crew / SMS deficiency density (fatigue, training, SMS implementation)

PSC severity normalises to:

Source severity	Internal tier
Detainable / Detention recommended	CRITICAL
Major / Code 17, 30 (action required at next port)	HIGH
Minor / Code 15 (rectify when feasible)	MEDIUM

PSC MoUs monitored: Paris MoU (Europe + N. Atlantic), Tokyo MoU (Asia-Pacific), Indian Ocean MoU, Mediterranean MoU, Caribbean MoU, Black Sea MoU, Abuja MoU (W & C Africa), USCG (United States), Riyadh MoU (Gulf states).

SIRE 2.0 and CDI — vetting severity

SIRE 2.0 replaced binary deficiency findings with a nuanced observation severity scale:

SIRE 2.0 severity	Description
Severity 1	Minor — process or documentation gap
Severity 2	Moderate — operational concern
Severity 3	Major — significant operational risk
Severity 4	Critical — vessel may be rejected for charter

The pipeline pulls historical SIRE observations, classifies findings by severity, and tracks operator response status — observations have a maximum response window, after which OCIMF marks them outstanding.

CDI (Chemical Distribution Institute) is the chemical-tanker analogue to SIRE. Same response-window logic; same observation severity tracking.

CII trajectory — carbon side

The emissions pipeline handles data acquisition. The compliance pipeline tracks the rating trend:

Current attained vs required CII for the year
Year-over-year delta in attained
Projected end-of-year rating band (A / B / C / D / E)

CII attained through the operating year:

CII_attained(t) = Σ CO2_i  /  Σ (Capacity × Distance_i)

Compared against the IMO required CII and the A–E boundary lines. A trajectory tracking the D/E boundary is flagged early so operational changes can intervene before the year closes.

Regulatory consequence: a vessel rated D for 3 consecutive years or E for 1 year requires a SEEMP III update with corrective measures.

Detention-risk and commercial-impact scores

Weighted detention-risk composite:

R_psc = w1 × D_open + w2 × H_detention + w3 × R_repeat + w4 × S_sms

Signal	Description
D_open	Open PSC deficiencies in the next port’s regime
H_detention	Detention-history recency multiplier
R_repeat	Repeat-finding cluster count (same code, multiple inspections)
S_sms	Crew / SMS deficiency density

Commercial-impact score runs in parallel:

R_commercial = w1 × N_sire_open + w2 × N_cdi_open + w3 × [CII E projected] + w4 × N_vir_open

A CII rating dropping to E carries a binary indicator weight — the regulatory consequence is binary. Both composites map to LOW / MEDIUM / HIGH / CRITICAL.

Escalation triggers

Trigger	Severity
Detention-risk score = HIGH or CRITICAL	CRITICAL
Recent detention (under 12 months)	CRITICAL
SIRE Severity 4 observation	CRITICAL
3 consecutive years of D rating	CRITICAL
Unresolved SIRE Severity 3 past response window	HIGH
Projected CII rating E	HIGH
Repeat finding across 3+ vessels in fleet (same code)	HIGH

Why all five together

A vessel with a clean SIRE record but a fresh PSC detention is in trouble. A vessel with a clean PSC record but a CII trajectory falling off the cliff is also in trouble — different timeline, different audience. Reading the regimes together is the only honest answer to “is this vessel commercially and operationally compliant?”