🎓 New here? Start with a free course: 07106 – Fire Detection and Alarm System

In the early hours of Tuesday 7 July, about eight nautical miles off Limah, Oman, the master of the LNG carrier Al Rekayyat (IMO 9397339) got a distress call out of a ship whose engine room was filling with smoke. United Kingdom Maritime Trade Operations logged his report at 01:19 local time. In a recording of the radio call later reviewed by Reuters, he declared mayday three times, identified his vessel twice by name, and reported a drone hit on the port side, at the top of the engine room. Then the status report: “Status: engine room fire and full of smoke. Unable to assess further damage.”

What followed, based on available reporting, was as disciplined as the call. The crew was evacuated safely, with no injuries reported. The liquefied natural gas in the cargo tanks stayed where it was: industry sources told Reuters there was no breach of the tanks, and that breaching a main tank would have been an event of a different order entirely. By Wednesday the vessel sat stationary near the entrance of the strait with a tugboat and a service ship standing by, awaiting salvage once the fire was fully extinguished. That was the last reported status at the time of writing.

The context is what makes the outcome worth studying. The International Maritime Organization had confirmed at least 46 attacks on shipping in and around the Strait of Hormuz and 14 seafarers lost since 28 February, and that tally dates to 11 June; the attacks have continued since. The same night the Al Rekayyat was hit, the Saudi supertanker Wedyan was damaged and a third tanker took a drone hit, the most strikes in a single day since late April, according to the IMO via the Associated Press. So the question this article is actually about is the one every designated person ashore and superintendent should be asking: when the projectile arrives at one in the morning, what determines whether the night ends with a full muster, or with a casualty entry on the IMO’s incident list?

📻 The Mayday 📊 By The Numbers 🔁 The Pattern 🎓 What Should Be Happening (+ Study Guide) 👀 What to Watch 📡 SwiftAction Signal

📬 SwiftAction Intelligence lands daily. Deficiency intelligence, casualty analysis, and the training gaps behind both.

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📻 The Mayday

UKMTO’s advisory was clinical: a tanker travelling southbound was struck on its port side by an unknown projectile about eight nautical miles off Limah, Oman, causing a fire, with no casualties and no environmental impact reported, and authorities investigating. The master’s own transmission, as recorded, was more specific than the advisory. He believed a drone had hit the top of his engine room. Whether drone, missile, or other projectile is still not officially settled: UKMTO said unknown projectile, Axios cited US officials describing missile fire at two commercial ships that night, and the master said drone. What is not in dispute is where it hit and what it started.

The Al Rekayyat is owned and managed by Nakilat, the Qatar Gas Transport Company, operator of one of the world’s largest LNG shipping fleets. She was built in 2009, according to VesselFinder. She was loaded with LNG at the time of the strike, and, like much of the tonnage that has moved through the Gulf since February, she was transiting dark: LSEG shipping data cited by Reuters showed her last AIS transmission on 18 June.

This was the first Qatari LNG ship struck since the war began on 28 February, and Qatar is not a bystander in this war. It is the mediator in the talks between Washington and Tehran. Its foreign ministry said Iran bore full legal responsibility for the attack and summoned the deputy Iranian ambassador in protest. Iranian state television said the tanker was attacked after ignoring warnings to stay off the Omani-coast route, but Tehran made no direct claim, and a US official said initial indications were that Iran had fired on two commercial vessels. Attribution, in other words, remains formally contested, and this article treats it that way.

The escalation that followed moved fast. The US Navy-led Joint Maritime Information Center raised the threat level for the strait to severe from substantial, the first time it had sat at severe since 15 June. Washington revoked the 60-day Treasury license that had allowed Iranian oil sales under the interim arrangement, and President Trump declared the interim agreement finished, comments Reuters reported alongside a five percent jump in oil prices.

None of that reached the Al Rekayyat’s crew in time to matter. Their part of the story was over in the first hours: the call, the fire response, the evacuation, and a burning gas carrier left safely behind them with her cargo contained.

📊 By The Numbers

01:19 : local time UKMTO logged the master’s report on 7 July. (UKMTO)

~8 nautical miles : distance off Limah, Oman, where the vessel was struck on her port side while southbound. (UKMTO)

0 : injuries reported. The full crew was evacuated safely. (UKMTO; Reuters)

0 : reported breaches of the LNG cargo tanks. (Industry source via Reuters)

3 : tankers struck in and around the strait that day, the most in a single day since late April. (IMO via Associated Press)

46 and 14 : attacks on shipping confirmed by the IMO, and seafarers lost, since 28 February. Tally as of 11 June; attacks have continued since. (IMO)

120 to 140 : ships that transited the strait each day before the war. Weekend crossings had recovered to 43, 34, and 31 on 3, 4, and 5 July; at the height of the fighting, traffic fell to as few as 2 a day. (Kpler and Al Jazeera)

~14 : LNG carriers anchored off Qatar’s Ras Laffan terminal on 8 July. (Kpler)

~20,000 : seafarers impacted in the region, per the IMO, which paused its plan to evacuate around 6,000 of them in late June after an earlier attack. (IMO)

Severe : JMIC threat level for Hormuz transit from 7 July, the first time at that level since 15 June. (JMIC via Reuters and Al Jazeera)

🔁 The Pattern

Look at where these strikes land. The Al Rekayyat’s master reported the hit at the top of his engine room. The Settebello (IMO 9162916), the Palau-flagged tanker struck on 9 June with three seafarers lost, was reportedly hit in the engine room as well, according to casualty reporting; Seatrade Maritime News reported that strike came from US blockade enforcement. The IMO’s highlighted incident list for this war reads like a machinery-space casualty file: Mayuree Naree, 11 March, three seafarers lost. Volans and the barge Badr, 2 May, one seafarer lost. HMM Namu, 4 May, one injured. CMA CGM San Antonio, 5 May, eight injured.

A machinery space hit at night is close to the worst-case drill scenario. Fire and dense smoke at the source of the ship’s power, blackout risk, and a response window measured in minutes, on a vessel whose cargo, in the Al Rekayyat’s case, does not forgive containment failure.

Here is what this article will not claim: that training is why the Al Rekayyat’s crew came off and others did not. No investigation report has been published for any of the 2026 Hormuz strikes we could locate, and the casualties are not comparable on paper. Weapon, hit location, sea state, time to assistance: all of it differs, and causation talk before the reports exist is guesswork.

Here is what the record does show, based on available reporting. A distress transmission structured exactly the way the procedures teach it, sent while the compartment filled with smoke. A full-crew night evacuation off a burning, loaded gas carrier without a single reported injury. Cargo containment that held. Every one of those is a drilled behavior. Every one of them has a home in SOLAS, the GMDSS procedures, and the ISM Code, and a Port State Control deficiency code that exists specifically to test whether a crew can actually do it.

And the industry’s paper trail on those exact behaviors is not reassuring. Fire safety led the US Coast Guard’s deficiency categories in its 2025 Port State Control Annual Report, and fire safety and ISM failures sat among the leading categories in the 2025 Paris MOU and Tokyo MOU results we broke down last month. Most of those findings were closed out within weeks. The findings were rectified on paper. The competency gap persisted at sea. The Strait of Hormuz is now grading that difference in real time, and so will every PSC officer who boards the trapped Gulf tonnage when it finally releases: rotations frozen since February, drill schedules degraded, rest-hour records compromised. The IMO Secretary-General put the stakes plainly in his 8 July statement: “No seafarer should have to risk their life simply for doing their job.”

🎓 What Should Be Happening

Strip the war out of the Al Rekayyat record and what remains is a checklist of competencies that every crew is supposed to hold, war zone or not, and that PSC officers test for on ordinary Tuesdays in ordinary ports. SwiftAction Academy builds micro-training modules against the same PSC deficiency codes those officers cite. Eight of them map directly onto what happened off Limah.

📚 Study Guide: The Al Rekayyat Eight

All course codes live-verified against the SwiftAction Academy platform on 13 July 2026.

Study Guide: The Al Rekayyat Eight

All course codes live-verified on 13 July 2026.

05101 Distress Messages Obligations and Procedures

The mayday followed the taught structure: identification twice, nature of distress, location of damage, status. That structure is why the message worked under stress.

https://academy.swiftaction.ai/courses/05101

05118 Operation of GMDSS Equipment

The transmission got out of a smoke-filled casualty and a recording later reached Reuters. Equipment competency is tested in the moment nobody schedules.

https://academy.swiftaction.ai/courses/05118

04109 Fire Drills

A machinery space fire at night is the standard drill scenario, and evaluating crew performance in that drill is a standard PSC inspection item.

https://academy.swiftaction.ai/courses/04109

04108 Muster List

A full-crew evacuation in the dark starts with every person already knowing their station and duty before anything happens.

https://academy.swiftaction.ai/courses/04108

04110 Abandon Ship Drills

The crew left a burning, loaded gas carrier at night with zero reported injuries. That outcome is what the drill exists to produce.

https://academy.swiftaction.ai/courses/04110

11129 Operational Readiness of Life-Saving Appliances

Appliances that launch on demand, at night, in a war zone. Readiness is a finding when it fails and invisible when it works.

https://academy.swiftaction.ai/courses/11129

07110 Firefighting Equipment & Appliances

First response in the engine room comes before any evacuation decision. Appliance readiness and fixed-system competency buy the time.

https://academy.swiftaction.ai/courses/07110

15150 ISM Code Compliance

Section 8 of the ISM Code is emergency preparedness. The safety management system is where drill schedules either live or quietly lapse.

https://academy.swiftaction.ai/courses/15150

One honest caveat, and it belongs in print: nothing public confirms which systems the Al Rekayyat’s crew used or how the evacuation ran minute by minute. The mapping above runs from the observable outcomes to the competencies PSC tests, not from an investigation report, because none exists yet.

👀 What to Watch

The salvage. As of 8 July the vessel was stationary with a tug and service ship standing by, awaiting salvage once the fire was out. Who takes the job, and when, under a severe threat rating will say a great deal about war-zone salvage appetite, and every operator with tonnage in the Gulf should watch it.

The investigation. Oman as the coastal State, the flag Administration, and Qatar as the owner’s State all have standing. No report yet exists for this or any 2026 Hormuz strike we could locate. When the first one lands, the emergency-response findings will be the ones that matter for training departments.

The evacuation initiative. The IMO paused its plan to move roughly 6,000 seafarers out of the Gulf in late June after an earlier attack, and its Secretary-General urged the parties on 8 July to allow the evacuation of stranded ships. Resumption is the single biggest welfare item in world shipping right now.

The trapped-fleet PSC wave. When the confined tonnage releases, drill records, rest-hour records, and muster documentation will be the first ask in every port. The war will not be accepted as an exemption, and the COVID precedent suggests grace periods will be short and uneven.

The naval picture. The UK and France were reported in early July to be preparing a mission to help secure the strait. Escort frameworks change transit risk, and transit risk changes everything above.

📡 SwiftAction Signal

Five sentences of mayday, as published. Every one of them was a trained behavior: the triple call, the double identification, the located hit, the status, the honest unknown. Nobody improvises that at 01:19 with smoke coming up the companionway. It is either drilled into a crew before the night it is needed, or it is absent on the night it is needed.

The competencies inside those five sentences, and inside the evacuation that followed, are exactly what SwiftAction Academy trains: 45-minute micro-modules mapped to the PSC deficiency codes inspectors actually cite, $17 per module, built for crews who do not have spare weeks, including crews sitting at anchor right now with time they never asked for.

Browse the catalog and start with the Al Rekayyat Eight above.

SwiftAction Intelligence is produced by the SwiftAction Intelligence team. Questions, corrections, tips: admin@swiftaction.ai

CIC Bundle: 2026 Cargo Securing CIC (Tokyo & Paris MOUs)

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On 1 September 2026, Port State Control officers across the Tokyo and Paris MoU regions begin a coordinated three month check on one subject: cargo securing. It runs to 30 November, it applies to every ship that is inspected in either region during the window regardless of risk profile, and the trade press is already describing it as the most consequential PSC event on this year’s calendar. Operators do not have to guess what is coming. The topic is published, the regulatory basis is fixed, and the last campaign left a very clear signal about how these blitzes now behave.

That signal is worth reading closely. The 2025 joint campaign covered Ballast Water Management, and when the Tokyo MoU published its annual results, the number of deficiencies tied to the campaign topic came in at three times the level of the previous year. The detentions did not cluster around missing certificates. Based on the published reporting, they clustered around whether the system was actually being operated and maintained correctly on board. In other words, the paperwork was not the exposure. The practice was.

Cargo securing sits on exactly that fault line. A vessel can carry a current, flag approved, vessel specific Cargo Securing Manual and still fail, because the 2026 questionnaire is expected to go past the manual and into the condition of the lashing gear, the discard criteria for worn equipment, and whether the deck crew can explain the securing arrangements when an officer asks. This piece lays out what the record shows, what a fleet should have in place before September, and what it costs to answer a finding by hand when the findings start arriving faster than a superintendent can draft responses.

In this issue

• 🚢 The Campaign: what is confirmed for September, and the regulatory basis

• 📊 By The Numbers: the 2025 result, the 2025 record year, and Q1 2026

• 🔍 The Pattern: why a compliant manual is no longer a compliant ship

• 🛠️ What Should Be Happening: a competency map, with the modules that address it

• 🔭 What To Watch: the questionnaire, 2027, and the risk profile mechanics

• 📡 The SwiftAction Signal: closing the practice gap, and answering the finding

Subscribe to SwiftAction Intelligence. Daily maritime regulatory intelligence for designated persons ashore, superintendents, masters, and compliance teams. The findings, read the way an inspector reads them.

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🚢 The Campaign

Both the Tokyo MoU and the Paris MoU have confirmed a joint Concentrated Inspection Campaign on cargo securing, running from 1 September to 30 November 2026. A Concentrated Inspection Campaign is a coordinated period in which port State authorities across one or more regions apply a single, pre announced questionnaire on top of the standard inspection. The mechanics matter: the questionnaire is not reserved for ships already flagged for a detailed inspection. Any vessel that is inspected for any reason during the window is assessed against it, and inspection probability rises across the board while a campaign is live.

The regulatory framework behind the 2026 campaign is settled. It rests primarily on the Code of Safe Practice for Cargo Stowage and Securing, on SOLAS Chapter VI and Chapter VII, and on each vessel’s own flag approved, vessel specific Cargo Securing Manual. Guidance published ahead of the campaign points to five areas that officers are expected to concentrate on: the Cargo Securing Manual itself, the physical condition of lashing and securing equipment against discard criteria, how cargo is secured in practice, the procedure for withdrawing damaged equipment from service, and crew familiarity with the securing arrangements. The official questionnaire is expected to be published during the summer, ahead of the September start.

The point that operators tend to underweight is the last one. A campaign questionnaire converts a general obligation into a specific, answerable checklist, and every negative answer becomes a formal deficiency that attaches to the vessel’s record. A ship that would pass a routine inspection can pick up deficiencies, and in serious cases a detention, purely because the campaign questionnaire exposes a gap that a normal inspection would not have probed.

📊 By The Numbers

The case for taking this campaign seriously is not rhetorical. It is in the last three published data sets.

The 2025 campaign. During the Ballast Water Management CIC, member authorities of the Tokyo MoU conducted 9,244 PSC inspections, of which 6,930 carried the CIC questionnaire. 184 ships inspected during the period were detained, a 2.66 percent detention rate, and 30 of those were detained as a direct result of the campaign deficiencies. According to the Tokyo MoU’s published results, deficiencies tied to the campaign topic ran at three times the level of the prior year, and the most common ones, including those that led to detention, were associated with the proper operation of the ballast water management system on board.

The 2025 record year. In the same annual report, the Tokyo MoU recorded 35,546 inspections, the highest number in its history, covering 19,980 individual ships. 23,230 of those inspections found deficiencies. 1,255 ships registered under 73 flags were detained on serious deficiencies, a 3.53 percent detention rate across ships inspected. The scale is the point: a campaign layered on top of that inspection volume touches a very large number of hulls.

Q1 2026. The direction of travel into this year is consistent. In its Q1 2026 detention review, DNV recorded 64 detentions across its fleet, compared with 52 in the same quarter of 2025. Container, bulk carrier and general cargo vessels accounted for 83 percent of those detentions, and roughly 84 percent were recorded in the Paris and Tokyo MoU regions. Detainable deficiencies continued to be dominated by shortcomings in ISM implementation, with the most frequently cited sub categories being 15150, ISM, and 15109, Maintenance of the ship and equipment.

None of this forecasts how many cargo securing deficiencies September will produce. It establishes how a modern campaign behaves. Read together, these numbers describe a system that is inspecting more, detaining on operational failures, and about to point a dedicated questionnaire at a subject where the gap between the manual and the deck is already on the record.

🔍 The Pattern

There is a consistent theme running through the recent cargo securing guidance from the marine insurance market, and it is the same theme the 2025 campaign surfaced. PSC inspection has moved beyond paperwork. Officers are increasingly likely to question the crew and test their understanding of the securing arrangements in practice, and a compliant manual on its own is not treated as sufficient if it is not effectively implemented on board.

The loss prevention record makes the same point from the other direction. When the Australian Maritime Safety Authority ran a focused inspection campaign that examined cargo securing, the recurring finding was not that procedures were absent. It was that procedures were typically in place but not always applied correctly. That gap, between the documented requirement and the onboard practice, appears to be where both the PSC deficiency and, further downstream, the P&I claim tend to originate. Damaged or incorrectly engaged twistlocks, lashing gear that is past its discard criteria but still in service, a manual that no longer matches the vessel’s actual configuration: these are practice failures wearing the costume of a documentation subject.

This is the structural problem with treating a Concentrated Inspection Campaign as a paperwork exercise. A binder can be assembled in a week. Competency cannot. The finding can be closed on paper the same afternoon it is raised, and the same gap can still be sitting on the deck the next time the vessel is inspected.

The findings were rectified on paper. The competency gap persisted at sea.

🛠️ What Should Be Happening

Preparation for a cargo securing campaign has two halves that operators frequently collapse into one. The first is the documentation and equipment half: confirm the Cargo Securing Manual is on board, current, flag approved and vessel specific for the cargo actually carried; inventory every securing device and remove anything that meets the discard criteria; and stand up a documented, signed pre departure securing check for every voyage. That half is necessary and it is auditable.

The second half is the one the questionnaire is built to expose: whether the people on deck can demonstrate the competency the manual assumes. A training record showing that officers and crew were briefed on the Cargo Securing Manual, the securing procedures for the cargo types carried, and the equipment discard criteria, in the weeks before the campaign, is exactly the kind of timestamped evidence that carries weight when a PSC officer questions crew knowledge. The record is the difference between an officer’s doubt and a closed line item.

Study Guide: competency areas mapped to PSC deficiency categories

The modules below are mapped to the PSC deficiency categories that inspectors cite, and each corresponds to a live SwiftAction micro-module. Codes verified against the 2026 catalog.

• Cargo operations and securing in practice: 06107 Cargo Operations

• Residual cargo requirements and edge cases: 06199 Other Cargo Requirements

• Hatch openings and access integrity: 03104 Cargo and Other Hatchways

• Hatch covers, tarpaulins and weathertight closure: 03105 Hatchway Covers and Tarpaulins

• Loading instrument and stowage planning: 06109 Loading Instrument

• Cargo density declaration and stability inputs: 06108 Cargo Density Declaration

• ISM shipboard operations discipline: 15106 ISM Code: Shipboard Operations

• Maintenance of ship and equipment, the top detainable sub category: 15109 ISM Code: Maintenance of the Ship and Equipment

Operational Standard. The half that is hardest to hold together across a fleet is consistency: the same competency, evidenced the same way, on every vessel calling every port. That is the problem class Nautilux AI is built for, with real time vessel scoring and human in the loop oversight, so a superintendent sees where the practice gap actually sits before an inspector does.

The full cargo securing preparation set is packaged for the campaign here: 2026 Cargo Securing CIC Training.

🔭 What To Watch

The questionnaire. The official 2026 questionnaire is expected to be published on the Paris MoU and Tokyo MoU websites during the summer, ahead of the September start. When it lands, it should be worked through question by question against each vessel’s current state, with any gap closed immediately rather than noted for later.

The risk profile. Under the New Inspection Regime, a ship’s inspection window is driven by its Ship Risk Profile, which folds in ship type, age, flag performance, class record, company ISM performance, and deficiency and detention history. Analysis of the Tokyo MoU inspection record indicates that older ships and vessels carrying five or more deficiencies face a materially higher probability of detention. A deficiency is not a single bad afternoon. It follows the vessel’s record and feeds the calculation that decides how often it gets stopped.

2027. The rotation is already set. The joint campaign planned for 2027 focuses on enclosed space entry, a higher stakes subject where the practice gap has consequences that are harder to walk back. A fleet that builds securing discipline into standing procedure now is also building the muscle it will need for that campaign.

📡 The SwiftAction Signal

Everything above is the problem. This is the part where a compliance team decides what to actually put in place, and it splits cleanly along the two halves of the gap.

Closing the competency side. The practice gap that the campaign is designed to expose is closed with training that produces evidence, not slideware. SwiftAction Academy runs a library of more than 600 PSC-aligned micro-modules, each mapped to a deficiency category an inspector actually cites, each priced at $17 per module, and each producing a completion record with a date on it. The 2026 Cargo Securing bundle assembles the modules in the Study Guide above into a single campaign set, so a fleet can brief officers and deck crew on the manual, the securing procedures, and the discard criteria, and hold the timestamped record that answers an officer’s question before it becomes a deficiency.

Answering the finding. Training reduces the number of findings. It does not eliminate them, and during a three month campaign the findings that do land arrive in a compressed window, across a fleet, all needing a corrective-action response that is fast, consistent, and cited to the exact regulation behind the deficiency. Drafting that by hand is where the response quality falls apart under volume.

That second half, a fast and consistent corrective-action response across a fleet, is a different problem from training, and it is the one the company featured below was built to solve.

A company built for the finding itself: SolarisTech

Most compliance tools stop at the checklist. SolarisTech starts where the checklist fails: the Port State Control deficiency, and the detention that can follow it.

SolarisTech is the maritime compliance company that created FRPC, the Fleet Risk and Predictive Compliance engine inside the Nautilux AI suite, for one job that no binder does well. FRPC turns any deficiency into a complete, regulation cited corrective-action response. From a single submission it produces the internal report for the company and the DPA, the cascaded external report for the attending officer, and the Code 10 close-out once the finding is rectified, every line cited to the exact regulation behind it, with named owners and due dates attached. SolarisTech reports the engine reduces the manual effort per finding by roughly 87 percent, from about 4.5 hours to about 0.6, and returns a first response in about 20 minutes rather than hours.

FRPC was built around a harder truth: most deficiencies are not really paperwork problems. They come from three pressures no manual fixes, and SolarisTech built its approach to relieve all three.

Superintendent overload. Superintendents are carrying more vessels than the day has hours for. FRPC takes the response off their desk, so a finding in a distant port does not become another late night drafting the same letters by hand.

Crew experience. Crews turn over faster than sea experience can be rebuilt, and the questionnaire now tests the competency the manual assumes. The Nautilux AI scoring behind FRPC shows a superintendent exactly where a competency gap is turning into findings, so attention lands on the vessels and crews that need it before the next inspection, not after.

Work and rest hours. When hours of rest are squeezed, supervision and the routine checks a ship depends on are the first things to slip, and the record and the reality drift apart. SolarisTech is built to surface that gap before an officer does.

The finding stays Port State Control’s call. Everything after it, the speed, the consistency, and the evidence quality of the response, is where SolarisTech comes in.

See it on your own fleet. SolarisTech runs a live pilot measured against your own Port State Control record. Start one at admin@solaristechinc.com.

SwiftAction Intelligence is produced by the SwiftAction Intelligence team. Questions, corrections, and story tips: admin@swiftaction.ai. Campaign training set: 2026 Cargo Securing CIC Bundle.

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🏅 Free Course Access (No Credit Card)

America’s seven maritime academies sent more than 1,250 new graduates into the industry this graduation season. At Kings Point, the US Merchant Marine Academy graduated 188 merchant marine and military officers at its 90th commencement on 22 June, each carrying a degree, a Coast Guard license earned through more than 300 days at sea, and a commission. From Castine to Galveston, Buzzards Bay to Vallejo, the Class of 2026 is the largest single injection of licensed talent the American fleet will receive this year.

They are arriving at a moment their country says it needs them. America’s Maritime Action Plan, published by the White House in February 2026, calls for a coordinated national push to recruit, train, and keep substantially more qualified mariners. A 2017 MARAD study, still cited in testimony to Congress, estimated the nation is roughly 1,800 mariners short of what a full mobilization lasting more than four to six months would demand. The demand side of this market has rarely looked stronger.

Here is what the commencement speeches did not cover. The license a new officer carries certifies one thing: that they passed an examination. The regime they now sail into runs a different kind of exam: 52,020 port State control inspections across the Tokyo and Paris MOU regions in 2025 alone, graded against the same deficiency codes, boarding after boarding, for the length of a career. That exam has a published answer key, and the industry’s most experienced crews keep missing the same questions. This issue is about how the Class of 2026 can study for it.

📋 In this issue:

⚓ The Class of 2026

📊 By The Numbers

🔍 The Pattern

🎓 What Should Be Happening

👀 What to Watch

🚨 SwiftAction Signal

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⚓ The Class of 2026

The American Maritime Partnership counted more than 1,250 graduates across the seven academies this year: the US Merchant Marine Academy at Kings Point, SUNY Maritime College at Fort Schuyler, Cal Poly Maritime Academy at Vallejo, Great Lakes Maritime Academy at Traverse City, Maine Maritime Academy at Castine, Massachusetts Maritime Academy at Buzzards Bay, and Texas A&M Maritime Academy at Galveston.

The credentials they carry are not ceremonial. License-track graduates leave with a Coast Guard license as Third Mate or Third Assistant Engineer, backed by STCW certification and hundreds of days of cadet sea time. At Kings Point, this year’s valedictorian, a Maritime Logistics and Security major, will sail on his license with the Masters, Mates & Pilots. The salutatorian, a Marine Engineering Systems major, is heading to sea as a Third Assistant Engineer with Military Sealift Command. Both cleared their Coast Guard license examinations in the same month they graduated.

The industry waiting for them is enormous and, on paper, hungry. The domestic fleet numbers more than 45,000 vessels, from container ships and tankers to dredges and towboats, inside an American maritime workforce the American Maritime Partnership puts at roughly 650,000. Washington has spent 2026 telling that industry to grow. The Maritime Action Plan directs agencies to expand mariner training and education, to invest in the state maritime academies, and to modernize Coast Guard credentialing so the pipeline moves faster. MARAD’s five new State-class training ships, the National Security Multi-mission Vessels, are re-equipping the state academies with purpose-built platforms designed to carry hundreds of cadets each.

So the Class of 2026 graduates into a rare alignment: a national policy demanding more officers, a documented shortfall of roughly 1,800 mariners for sustained sealift, and a fleet that needs watchkeepers now. What the alignment does not change is what happens the first time a port State control officer walks up their gangway.

📊 By The Numbers

The world the Class of 2026 signed up for, in figures:

1,250+ new academy graduates in 2026 · 188 at Kings Point’s 90th commencement · 300+ cadet days at sea per USMMA graduate

~1,800 mariner shortfall for sustained sealift, per MARAD’s standing estimate · 45,000+ vessels in the domestic fleet

The exam they sail into: 35,546 Tokyo MOU inspections in 2025, a record · 16,474 Paris MOU inspections · 52,020 boardings between them

4.18% Paris MOU detention rate, second-highest in a decade · 3.53% Tokyo MOU rate · 77 US Coast Guard detentions

The inspection numbers are not background noise to a new officer’s career. They are the operating environment. In the Asia-Pacific, Tokyo MOU officers recorded 90,168 deficiencies in 2025, and just four categories produced 53 percent of them: fire safety at 18,020 findings, life-saving appliances at 11,818, working and living conditions at 9,108, and safety of navigation at 8,936. The same four categories led the 2024 table, in the same order.

In Europe, the Paris MOU’s 2025 report shows the identical five findings topping its list for a third consecutive year: ISM, fire doors, seafarers’ employment agreements, cleanliness of the engine room, and electrical installations. ISM alone was cited 2,322 times, the most of any single deficiency in the region. Seafarers’ employment agreements, the document every one of these graduates will sign before their first commercial voyage, drew 664 findings.

And at home, the US Coast Guard detained 77 foreign ships in 2025, down from 82 in 2024 and 101 in 2023, a decline its own report attributes, most importantly, to the effective implementation of a comprehensive Safety Management System. The one regime showing sustained improvement credits the management system, not the metal.

🔍 The Pattern

A Coast Guard license and a diploma certify one thing with precision: that on examination day, the graduate demonstrated the required knowledge. It is a real achievement, earned over four years and hundreds of days at sea, and nothing in the inspection data diminishes it.

But port State control does not grade what an officer knew on examination day. It grades what the crew standing in front of the inspector can demonstrate on boarding day, this boarding, this ship, this system. And on that test, the global fleet’s results are remarkably consistent. Fire safety leads the deficiency tables in both hemispheres. ISM, the code that governs how a ship is actually run, is the single most-cited deficiency in Europe. The categories do not rotate. The answer key does not change. The findings repeat anyway.

The clearest evidence of why came out of the 2025 ballast water inspection campaign. When Paris and Tokyo MOU officers concentrated on one topic for three months, they found, based on available reporting, that documentation compliance was generally high while the paperwork did not always match operational effectiveness on board, including crew familiarity with the procedures. The certificates were in the folder. The demonstration was not on the deck. The findings were rectified on paper. The competency gap persisted at sea.

For a newly licensed third mate or third assistant engineer, this pattern is not an abstraction. Within weeks of reporting aboard, many of the Class of 2026 will stand their first inspection boarding, a Coast Guard exam at home or a port State control visit abroad. The inspector will not ask where they went to school. The inspector will ask them to show the fire detection panel’s zones, produce the rest-hour records they now keep, walk through the passage plan they now monitor on watch, and explain their duties under the Safety Management System they have held for days. A license opens the gangway. What happens on deck is a demonstration, and demonstrations are built through training that continues after the diploma, not through the diploma alone.

🎓 What Should Be Happening

The deficiency tables are, in effect, a published syllabus for a new officer’s first year at sea. Fire safety will be examined. The SMS will be examined. The logbooks, the rest-hour records, the employment agreement, the passage plan: examined, on a schedule no one shares in advance, by an inspector who has seen every version of unprepared.

Graduation should therefore be treated as the start of an officer’s documented training record, not its completion. The academies build the foundation; no four-year program can pre-load familiarity with the specific ship, the specific SMS, and the specific deficiency codes an inspector will probe. That layer is built module by module, in service, and the smart move is to build it before the first boarding rather than after the first finding.

This is where mapped training earns its place in a young officer’s file. SwiftAction Academy structures its modules one-to-one against the PSC deficiency codes that Paris MOU, Tokyo MOU and USCG inspectors actually cite, and each completed module produces a record documenting completion and a passed assessment against that specific code. For a junior officer, that record does two jobs at once: it closes a knowledge gap before an inspector finds it, and it shows any master, DPA or vetting reviewer a training file that speaks the same code language as the inspection sheet.

🎓 The Study Guide: First Watch Edition

Seven courses mapped to what a new officer will be asked to demonstrate first:

⚠️ Course 15150 – ISM Code Compliance The most-cited single deficiency in Europe, 2,322 findings in 2025, and the system every new officer operates inside from day one.

🧭 Course 10127 – Voyage or Passage Planning Every new watchkeeper executes and monitors it from the first watch. Safety of navigation drew 8,936 Tokyo MOU findings in 2025.

🖥️ Course 10112 – Electronic Charts (ECDIS) The bridge tool a PSCO will ask a junior watchkeeper to demonstrate, alarms, updates and all.

📄 Course 01220 – Seafarers’ Employment Agreement (SEA) The first document a graduate signs, and a Paris MOU top-five finding three years running: 664 findings in 2025.

🧯 Course 04121 – Crew Familiarization with Emergency Systems The day-one requirement on every new ship. Crew familiarity is the gap inspectors keep finding behind the paperwork.

📖 Course 01305 – Log Books and Compulsory Entries The records a junior officer keeps are the first thing an inspector reads.

🚨 Course 07106 – Fire Detection & Alarm System Training Fire safety led both regions’ deficiency tables in 2025. This module is free, no credit card required.

👀 What to Watch

1 September to 30 November 2026: the Class of 2026’s first CIC. The joint Paris and Tokyo MOU Concentrated Inspection Campaign on cargo securing opens roughly ten weeks after commencement season. Many of these graduates will face a concentrated campaign questionnaire during their very first months aboard. The 30-course 2026 Cargo Securing CIC bundle exists for exactly this window.

The new performance lists are already grading their ships. The Paris MOU White, Grey and Black Lists and RO rankings published with the 2025 report took effect on 1 July 2026. Every vessel these officers join carries a risk profile calculated against them.

The Maritime Action Plan moves from paper to program. Watch for the mariner mobilization planning, the expanded academy funding, and the Coast Guard’s credentialing modernization the February plan directs. A faster credential pipeline means more new officers reaching ships sooner, with the same first-boarding gap to close.

The Jones Act waiver dispute. The American Maritime Partnership, congratulating the Class of 2026 on 24 June, noted the Jones Act had been waived for almost 150 days and argued the waiver threatens opportunities for newly credentialed mariners even as national policy calls for growing the pipeline. However that debate resolves, it is the market these graduates are entering.

2027 brings the Enclosed Space Entry CIC. The two regimes have already named the campaign that follows cargo securing. For the Class of 2026, the exam calendar for their second year at sea is already published. There is no excuse for arriving unprepared.

🚨 SwiftAction Signal

America just graduated more than 1,250 new mariners into a fleet its own government says is short roughly 1,800. Every new officer among them earned a license that certifies what they knew on examination day. Starting now, they will be graded on what they can demonstrate on boarding day, by regimes that ran 52,020 inspections last year and publish the same failing answers annually: fire safety, ISM, the records, the familiarization. A first finding follows the ship for years in its risk profile; a detention follows the ship, and the people running it, far longer. A SwiftAction module mapped to the exact deficiency code costs $17 and produces a completion record documenting a passed assessment before the first inspector ever walks the gangway. To the Class of 2026: the syllabus is published, and the first class is on us. Start with Course 07106. It is free.

⚓ The SwiftAction Team

SwiftAction Intelligence Is Published Daily.

For partnership inquiries contact admin@swiftaction.ai

📋 Full Training Catalog: academy.swiftaction.ai

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|⚓ About Us | 📋 Training Catalog | 🎯 CIC 2026 Bundle | 🏅 Free Course Access (No Credit Card)

This publication’s previous issue covered the Paris MOU’s 2025 Annual Report: a European detention rate at its second-highest level in a decade, and a regime that says it cannot find a single regulatory cause. The United States Coast Guard’s own 2025 Port State Control Annual Report, published 8 June 2026, reads like the mirror image. Exams up. Detentions down. A national detention ratio of 0.85 percent, against Europe’s 4.18.

Same ships. Same conventions. Same classification societies. In many cases, the same managers. The gap is nearly five to one. The two regimes screen and target ships differently, so the ratios are not a like-for-like scorecard. The deficiency tables, though, are directly comparable, and that is where the story is.

The temptation is to read the American report as a victory lap, and its foreword comes close to one. But the deficiency chapters tell a more careful story. Fire safety led all operational deficiency categories for the fifth consecutive year. A Port State Control Officer found a ship whose cargo hold fire detection system was completely disconnected. Rescue boats could not be started or deployed. A master and chief officer could not demonstrate familiarity with security exercises or the record keeping for drills. Ships arrived not manned in accordance with their Minimum Safe Manning Document.

The American number is better. The failures behind it are the same ones filling Europe’s tables. That is the part worth reading twice.

📋 In this issue: 🧾 The Report 📊 By The Numbers 🔍 The Pattern 🎓 What Should Be Happening 👀 What to Watch 🚨 SwiftAction Signal

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🧾 The Report

In 2025, a total of 11,279 individual vessels from 79 flag administrations made 76,351 port calls to the United States. That is roughly 7,700 fewer port calls than the 84,034 recorded in 2024, from an almost identical population of ships, a decline the report presents without comment. Against that traffic, the Coast Guard conducted 8,999 Port State Control exams, up from 8,710 the year before, and detained 77 ships for environmental protection, safety, and security related deficiencies.

Both headline measures improved. The annual detention ratio fell from 0.94 percent to 0.85 percent, and the three-year rolling ratio eased from 1.01 percent to 1.00 percent. Seventy-seven is the lowest detention total since 2021, and the ratio has now dropped for two consecutive years since the 2023 spike, when 101 ships were detained at 1.22 percent. A decade ago, in 2015, the ratio stood at 2.17 percent.

The report attributes the trend to the industry’s renewed focus on safety and quality and, in its words, the effective implementation of comprehensive Safety Management Systems, crediting flag states, classification societies, and vessel operators for proactively identifying and mitigating risks.

The recognition programs moved in a less comfortable direction. QUALSHIP 21, the program that rewards quality operators with fewer exams, ended 2025 with 4,659 vessels enrolled, the first decline in the five-year enrollment series shown in the report, down roughly eight percent year over year. Four flag administrations lost eligibility during the year while four gained it. The E-Zero environmental designation went the other way, closing 2025 at 605 ships, nearly 200 more than in 2024.

The Targeted Flag List, the mechanism that decides which flags face extra boarding attention, saw five administrations removed: the Bahamas, Comoros, Curacao, Italy, and Latvia. Six flags remain in the high-risk category, with three-year detention ratios that make the national average look like a different industry: Tanzania at 31.25 percent, Belize at 20.00 percent, Togo at 17.07 percent, Bolivia at 16.00 percent, Vanuatu at 4.88 percent, and Cyprus at 2.10 percent.

And the appeals data suggests the detentions that were issued are holding. Of seventeen appeals received in 2025, nine challenged the merits of a detention. Two were granted.

📊 By The Numbers

The 2025 American inspection year, in the figures that matter:

8,999 PSC exams · 77 detentions · 0.85% annual detention ratio · 1.00% three-year rolling ratio

76,351 port calls by 11,279 individual vessels · roughly 7,700 fewer calls than 2024

Fire safety: 1,601 deficiencies recorded, the largest category on the exam data table · 53 detainable, leading all operational deficiency categories for the fifth straight year

Behind the fire safety total: oil accumulation in the engine room led the detainable category with 15 findings, down only slightly from 18 the year before. PSCOs recorded oil-soaked lagging, active fuel leaks, excessive oil in bilges, and combustible materials stored throughout engine rooms. Seven detainable deficiencies involved fire detection and alarm systems, most for smoke detectors that did not function or test equipment that was not operable, and one ship was detained with its cargo hold fire detection system completely disconnected. Fire doors rounded out the category’s top three: holes in doors, warped doors, and wasted gaskets.

Detainable Safety Management System deficiencies declined again, a drop the report’s narrative puts at 65 down to 51, led by maintenance of the ship and equipment, then shipboard operations, then company responsibility and authority. Lifesaving appliance detainables fell from 20 to 13, led by rescue boats that could not be started or deployed and lifeboats with expired provisions, poor condition, or engines that failed to start. Ship certificate detainables numbered 14, several involving vessels not manned in accordance with their Minimum Safe Manning Document or crew members who did not meet certain STCW requirements. Working and living conditions produced 13 detainables, the first year the category generated enough findings to be recognized in the report’s overview, roughly half involving electrical installations and the stowage of cargo.

By ship type, bulk carriers logged the most detentions at 19, though at 0.83 percent their ratio sits at the national average across 2,290 exams. General dry cargo ships were the worst-performing major segment at 1.62 percent, nearly double the national ratio. Container ships followed at 1.01 percent with 16 detentions. At the clean end: oil tankers recorded one detention from 925 exams, a 0.11 percent ratio, and LNG carriers recorded none. Passenger ships were not detained at all, yet deficiencies were found on 52.70 percent of their exams, by far the highest share of any ship type, a reminder that findings and detainable conditions are different measurements.

By port, Sector Miami stands alone: 13 detentions from 438 exams, just under 3 percent, roughly three and a half times the national ratio and the highest count of any zone. Sector Mobile followed with 9. Sector Houston/Galveston, the busiest exam operation in the country at 1,166 exams, recorded 6.

By flag, Liberia recorded 20 detentions from 1,553 exams and Panama 10 from 1,297. Together the two registries account for 30 of the year’s 77 detentions.

The Enhanced Exam Program, the Coast Guard’s quarterly answer to a Concentrated Inspection Campaign, produced the report’s most lopsided table. Engine room automation checks found deficiencies on 0.30 percent of exams. Security under ISPS: 0.79 percent. Emergency power and electrical systems: 0.66 percent. Closures forming CO2 protective zones: 5.44 percent, with 155 deficiencies across 1,945 exams, roughly eighteen times the deficiency rate of the automation campaign. The boundaries that make a fixed CO2 system survivable are, by the Coast Guard’s own sampling, the weakest item it went looking for.

In the ballast water program, inoperable treatment systems remained the most frequent deficiency at 77 instances even after a 22.2 percent improvement, concentrated in general bulk carriers, container ships, and chemical tankers. Structural ballast tank and piping deficiencies more than doubled, from 8 to 19. Enforcement stayed measured: five Letters of Warning over the preceding 24 months.

🔍 The Pattern

Set the American report beside the two that preceded it this season and one category appears at the top of every table. Fire safety led the Paris MOU’s deficiency list at 16.8 percent of all findings. It led the Tokyo MOU’s at 18,020 findings. And in the United States it led the exam data table at 1,601 findings while topping the detainable operational categories for a fifth consecutive year. Three regimes, three targeting systems, three oceans. One leading deficiency.

The subcategories repeat across basins too. Fire doors with holes, warped panels, and wasted gaskets appear in the American detainable narrative; fire doors and openings in fire-resisting divisions have sat in the Paris MOU’s top five for three straight years. Oil accumulation in the engine room led the American fire safety detainables; cleanliness of the engine room has not left Europe’s top five. The inspection sheets on both sides of the Atlantic are, functionally, the same sheet.

What separates the outcomes is what happens before the boarding. The Coast Guard’s own assessment credits its falling ratio to the effective implementation of Safety Management Systems, and its detainable SMS count declined again this year. But the exams that still end in detention show what an SMS looks like when it exists on paper only. A master and chief officer who could not demonstrate familiarity with security exercises and drill record keeping. Companies that did not take timely corrective action on known deficiencies. A ship carrying unauthorized flammable cargoes whose SMS, on review, contained no requirement for the master or crew to verify dangerous goods compliance before loading. Rescue boats that would not start with a PSCO standing on deck. Based on available reporting, none of these are equipment shortages. Each is a gap between what the manual documents and what the crew on watch can demonstrate.

That is the quiet symmetry between a 0.85 percent regime and a 4.18 percent one. The American numbers are better because more crews close that gap before arrival. The 77 that were detained are the ones that did not. The findings were rectified on paper. The competency gap persisted at sea.

🎓 What Should Be Happening

The Coast Guard publishes its exam priorities the way the European regimes publish theirs. The Enhanced Exam Program topics are announced, the detainable category rankings barely move year to year, and the report’s own narrative names the exact failures its officers keep finding: the disconnected detector, the drill records nobody can produce, the rescue boat that will not start. An operator trading to the United States is not preparing for a mystery. The syllabus is printed annually.

Closing a finding is not the same as closing the gap. A rectified deficiency proves the item was fixed once. It does not prove that the crew sailing into Miami or Houston next month can operate the system, maintain it, and demonstrate it while a PSCO watches. That demonstration is a competency, and competency is built before the boarding, not during it.

This is where documented training earns its place in the exam file. SwiftAction Academy maps its modules one-to-one to the PSC deficiency codes that USCG, Paris MOU, and Tokyo MOU inspectors cite, and each completed module produces a record documenting completion and a passed assessment against that specific code. When the exam sheet and the training file speak the same code language, the conversation on deck changes.

🎓 The Study Guide

Seven courses mapped to the deficiencies that led the American 2025 tables:

🔥 Course 07106 – Fire Detection & Alarm System Training Seven detainable fire detection deficiencies in 2025, including one ship detained with its cargo hold detection completely disconnected. This module is free, no credit card required.

🚪 Course 07105 – Fire Doors/Openings in Fire-Resisting Divisions Holes, warped doors, and wasted gaskets placed fire doors in the American detainable top three. The same finding has spent three years in Europe’s top five.

🧯 Course 07103 – Fire Division: Decks, Bulkheads & Penetrations Closures forming CO2 protective zones produced deficiencies on 5.44 percent of Enhanced Exam Program checks, the worst result of any EEP topic by roughly a factor of eighteen.

⚠️ Course 15150 – ISM Code Compliance Maintenance of the ship and equipment led every SMS detainable subcategory. Multiple technical deficiencies in one exam become evidence the SMS itself is not working.

🧭 Course 15106 – ISM Code – Shipboard Operations A master and chief officer unable to demonstrate familiarity with security exercises and drill record keeping. Shipboard operations was the second-largest SMS detainable subcategory.

🛟 Course 11104 – Rescue Boats Immediate availability led the lifesaving detainables: rescue boats that could not be started or deployed on demand.

⚡ Course 04114 – Emergency Generator and Emergency Power Emergency power and electrical systems were a 2025 EEP campaign topic, and electrical installations were among the drivers of the working and living conditions category’s first appearance in the detainable overview.

👀 What to Watch

The EEP tells you where the flashlight points next. The 5.44 percent deficiency rate on CO2 protective zone closures is the kind of result that shapes future exam emphasis. Ships bound for US ports should treat boundary closures, dampers, and door seals around fixed CO2 spaces as a standing self-check item, not a dry dock item.

QUALSHIP 21 gets harder from 2027. The Coast Guard expanded flag eligibility criteria in 2026 to require that Corrective Action Plans from IMO Member State Audit Scheme audits be formally accepted, alongside stricter suitability rules and the removal of conditional renewals, per Work Instruction CVC-WI-002(2). The new criteria apply to eligibility evaluations beginning in 2027. Enrollment already fell roughly eight percent in 2025; the bar is moving up, not down.

The Targeted Flag List is live math. Five flags came off the list this year, and flags with small US exam counts can move on or off it on a single detention. For operators, the flag on the stern is an exam-frequency decision, and the six high-risk registries now carry three-year ratios between 2.10 and 31.25 percent.

Cyber is entering the exam conversation. The report’s foreword frames cyber defense and resilience as inseparable from the new technologies entering the fleet, from alternative fuels to autonomous systems. Expect the compliance frameworks around vessel cyber footprints to keep tightening.

Watch the port call number. 76,351 calls in 2025 against 84,034 in 2024 is a roughly nine percent drop in US port traffic from a nearly identical vessel population. The report offers no explanation. Fewer calls with more exams means a higher probability that any given arrival gets boarded.

🚨 SwiftAction Signal

The Coast Guard just published a report showing that even in the major PSC regime with the lowest detention ratio, the ships that fail still fail on fire safety, on drills, on rescue boats, and on Safety Management Systems that exist in a binder and nowhere else. Seventy-seven crews learned that lesson at the dock in 2025. In Miami alone, thirteen.

A detention in a US port costs days off-hire, a lasting scar on the vessel’s targeting profile, and a company name in a federal database. A SwiftAction module mapped to the exact deficiency code costs $17 and produces a completion record documenting a passed assessment before the PSCO ever walks the gangway.

For ships trading to the United States, the USCG Boarding Defense System bundle packages twenty modules aligned to the deficiency categories American inspectors cite most, for $199: academy.swiftaction.ai/bundles/uscg-boarding-defense-system

Start with Course 07106. It is free.

⚓ The SwiftAction Team

SwiftAction Intelligence Is Published Daily. For partnership inquiries contact admin@swiftaction.ai

📋 Full Training Catalog: academy.swiftaction.ai 🎯 Prepare for US port calls: academy.swiftaction.ai/bundles/uscg-boarding-defense-system

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🏅 Free Course Access (No Credit Card)

The Paris MOU has published its 2025 Annual Report, and the headline number moved in the wrong direction for the second year running. The detention rate across Europe’s port State control region reached 4.18 percent, up from 4.03 percent in 2024 and 3.81 percent in 2023. Only 2022 recorded a higher rate in the past ten years. Refusals of access, the bans that shut a ship out of an entire region, jumped to 19, the highest total since 2019.

The report’s most important sentence is not a number. It is a conclusion. The Paris MOU states that its analysis of recorded deficiencies did not identify any single convention or regulatory area as the primary cause of the rise. The regime’s Chairman and Secretary-General instead urge every stakeholder to re-evaluate operational practices, warning that the elevated rate may signal a broader reduction in shipping standards.

Read the deficiency tables, though, and the picture sharpens. The same five findings that led the list in 2023 and 2024 led it again in 2025: ISM, fire doors, seafarers’ employment agreements, cleanliness of the engine room, and electrical installations. The rate is rising, and the reasons are not new. They are the same reasons, uncorrected, for a third consecutive year.

📋 In this issue:

• 🧾 The Report

• 📊 By The Numbers

• 🔍 The Pattern

• 🎓 What Should Be Happening

• 👀 What to Watch

• 🚨 SwiftAction Signal

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🧾 The Report

The Paris Memorandum of Understanding spans maritime Authorities across Europe and the North Atlantic, from Canada to Croatia. Its Port State Control Officers boarded ships at an average of roughly 45 inspections per day through 2025, producing 16,474 inspections for the year.

Six of every ten inspections found something. A total of 9,879 inspections recorded at least one deficiency, and 51,797 deficiencies were logged in total, up 4.6 percent from 49,510 in 2024. Of those, 4,744 were serious enough to be marked detainable. The result: 688 ships detained, and a detention rate of 4.18 percent.

For context, the pre-pandemic rate in 2019 was 2.99 percent. The region has now spent four consecutive years well above that level, and the Paris MOU’s leadership frames that gap as a trend demanding sustained attention in the period ahead.

The banning figures moved sharply. Nineteen ships were refused access to the entire region in 2025, up from 15 in 2024 and 11 in 2023, a jump the report frames as the end of a quiet stretch in banning activity. Across 2023 to 2025, repeated detentions were the trigger in 33 of 45 refusals of access, with another 11 ships banned for failing to proceed to their designated repair yard.

The report also names the threat it cannot inspect its way out of. Ships operating outside legitimate oversight are transiting the coastal waters of Paris MOU members without making port calls, which places them beyond the reach of a risk-based inspection system built around port arrivals. The leadership pairs that concern with the rise of false flags and fraudulent certification, an issue it says is best addressed through global cooperation between PSC regimes. According to PortNews’ report on the regime’s 59th Committee meeting, held in Glasgow in May 2026, the Paris MOU has now agreed to develop practical guidance for handling suspected fraudulent registrations and certificates.

📊 By The Numbers

The 2025 inspection year, in the figures that matter:

16,474 inspections · 9,879 with deficiencies · 688 detentions · 4.18% detention rate

51,797 deficiencies recorded · 4,744 detainable · 3.14 deficiencies per inspection

19 ships banned from the region · highest total since 2019

Five main deficiency groups produced more than 55 percent of everything PSCOs wrote up in 2025. Fire safety under SOLAS Chapter II-2 led again at 16.8 percent of all deficiencies, with 8,713 findings. Structure, machinery and electrical requirements under SOLAS Chapter II-1 followed at 11.6 percent. Health protection, medical care and welfare under MLC 2006 Title 4 came third at 10.1 percent. Life-saving appliances under SOLAS Chapter III and safety of navigation under SOLAS Chapter V rounded out the five. The top three groups alone account for 38.5 percent of all findings, nearly two of every five.

At the individual deficiency level, the 2025 top five reads like a photocopy of 2024 and 2023: ISM at 4.48 percent of all deficiencies, fire doors and openings in fire-resisting divisions at 3.11 percent, seafarers’ employment agreements at 1.28 percent, cleanliness of the engine room at 1.26 percent, and electrical installations in general at 1.25 percent.

One category broke the pattern, and it broke it upward. Ballast water management deficiencies rose from 965 in 2024 to 1,591 in 2025, an increase of 64.9 percent, the sharpest rise of any category in the report.

By ship type, general cargo and multipurpose vessels were detained at 6.78 percent, the worst rate of any major segment, with 283 detentions from 4,173 inspections. Bulk carriers recorded a 5.38 percent detention rate, and that number has climbed each year, from 3.61 percent in 2023 to 4.71 percent in 2024 to 5.38 percent now. Container ships, by contrast, sat at 1.98 percent.

By flag, the two most-inspected flags in the region both finished above the average. Liberia recorded 105 detentions from 2,221 inspections, a 4.7 percent rate, and Panama 103 detentions from 1,891 inspections, 5.4 percent. At the extreme end, among flags with at least 20 inspections, Cameroon was detained on 34.3 percent of boardings, Tanzania on 28.2 percent, and Comoros on 23.6 percent. The Black List holds ten flags, with Cameroon, Tanzania and Comoros carrying the highest excess factors in the region. The distribution across the White, Grey and Black Lists, the report notes, remains largely stable despite the rising rate.

One quieter finding deserves attention. While the Recognized Organization performance categories themselves hold steady year over year, the report states that the number of detainable deficiencies attributable to RO responsibility remains elevated, and characterises the trend as evidence that the quality of certain ROs is measurably slipping.

🔍 The Pattern

Put the three annual reports side by side and the pattern is unmistakable. Fire safety has led the deficiency table in 2023, 2024 and 2025, at 17.3 percent, 17.3 percent and 16.8 percent. Fire doors specifically have held between 3.1 and 3.3 percent of all findings for three straight years. ISM has topped the single-deficiency table in all three years, easing only from 4.79 percent of everything recorded in 2023 to 4.48 percent in 2025. Seafarers’ employment agreements have not left the top five once.

This is what makes the Paris MOU’s “no single cause” conclusion so pointed. The rise is not coming from a new regulation catching the industry off guard. It is coming from the oldest items on the inspection sheet. When the single most-cited deficiency in Europe is ISM itself, the finding is not that one piece of equipment failed. It is that the management system responsible for preventing every other finding on the sheet is not producing the outcomes the Code demands.

The ballast water surge tells the same story from a different angle. The Paris MOU and Tokyo MOU ran their joint Concentrated Inspection Campaign on ballast water management from 1 September to 30 November 2025, and the 64.9 percent jump in BWM deficiencies is consistent with the concentrated scrutiny of that campaign window: inspectors looked harder at one topic, and found more. What they found is the instructive part. According to PortNews’ account of the Committee’s review, documentation compliance was generally high, but the paperwork did not always match operational effectiveness on board, including the readiness of the ballast water management systems themselves and crew familiarity with the procedures.

The certificates were in the folder. The plan was on the shelf. The competency was not on the deck. Based on available reporting, that gap between documented compliance and demonstrated capability is the closest thing this report offers to the single explanation its authors say they could not find. Every repeat appearance of fire doors, ISM, engine room cleanliness and electrical installations on the annual top five is the same gap, measured a different way. The findings were rectified on paper. The competency gap persisted at sea.

🎓 What Should Be Happening

The Paris MOU publishes the exam syllabus every summer. The top five deficiencies are not a surprise quiz; they are the same five questions, asked 16,474 times a year. An operator who treats the annual report as a study guide knows exactly what a PSCO in Rotterdam, Gdynia or Genoa will test: the fire doors, the SMS, the employment agreements, the engine room, the wiring, and, through 2026, the cargo lashings.

Closing a finding is not the same as closing the gap. A rectified deficiency proves the item was fixed once. It does not prove the crew that sails tomorrow can operate the system, maintain it, and demonstrate it under a PSCO’s eyes. That demonstration is a competency, and competency is built before the boarding, not during it.

This is where documented training earns its place in the inspection file. SwiftAction Academy maps its modules one-to-one to the PSC deficiency codes that Paris MOU, Tokyo MOU and USCG inspectors cite, and each completed module produces a record documenting completion and a passed assessment against that specific code. When the inspection sheet and the training file speak the same code language, the conversation on board changes.

🎓 The Study Guide

Seven courses mapped to the deficiencies that led Europe’s 2025 table:

⚠️ Course 15150 – ISM Code Compliance The single most-cited deficiency in the Paris MOU region: 2,322 findings in 2025.

🔥 Course 07105 – Fire Doors/Openings in Fire-Resisting Divisions The most-cited hardware deficiency: 1,609 findings, three straight years in the top five.

📄 Course 01220 – Seafarers’ Employment Agreement (SEA) The MLC finding that has not left the top five: 664 findings in 2025.

⚙️ Course 07126 – Oil Accumulation in Engine Room The failure behind the engine room cleanliness deficiency: 654 findings in 2025.

⚡ Course 02108 – Electrical Installations The wiring, insulation and protection failures PSCOs classify as unsafe: 646 findings.

🌊 Course 14811 – Ballast Water Management System (BWMS) Training The sharpest-rising category in the report: BWM deficiencies up 64.9 percent in one year.

🚨 Course 07106 – Fire Detection & Alarm System Training Fire safety led the deficiency table again at 16.8 percent. This module is free, no credit card required.

👀 What to Watch

1 September to 30 November 2026: the Cargo Securing CIC. The Paris MOU and Tokyo MOU reconfirmed their joint Concentrated Inspection Campaign on cargo securing at the May 2026 Committee meeting. It begins in under nine weeks. The segments it will fall hardest on, bulk carriers and general cargo vessels, are precisely the segments whose detention rates are already at or climbing toward the top of the 2025 table. The 30-course 2026 Cargo Securing CIC bundle exists for exactly this window.

The new performance lists are already live. The White, Grey and Black Lists and RO performance rankings published with this report apply from 1 July 2026. Every ship’s risk profile, and therefore its inspection priority, is now being calculated against them.

Fraudulent certificates move up the agenda. Following the Glasgow Committee meeting, the Paris MOU is developing practical guidance for suspected fraudulent registrations and certificates, per PortNews. Expect PSCOs to probe certificate provenance more aggressively.

The methodology changes land in July 2027. Revised flag and RO performance calculation methodologies are scheduled for implementation in July 2027, and reporting on the Committee outcomes indicates new environmental parameters are entering the ship risk profile. The rules for who gets boarded are being rewritten.

2027 brings the Enclosed Space Entry CIC. The two regimes have already confirmed the topic that follows cargo securing. The exam calendar is published two years out. There is no excuse for arriving unprepared.

🚨 SwiftAction Signal

Europe just told the industry, in its own annual report, that it cannot find a single regulatory cause for a detention rate at its second-highest level in a decade. It does not need to. The cause is printed in its own tables: the same five deficiencies, led by the ISM Code itself, topping the list for a third consecutive year, and a ballast water campaign that found the paperwork compliant while the competency behind it was not. A detention in the Paris MOU region costs days off-hire, a damaged risk profile that follows the ship for three years, and, 19 times in 2025, the entire regional trade. A SwiftAction module mapped to the exact deficiency code costs $17 and produces a completion record documenting a passed assessment before the PSCO ever walks the gangway. The 2026 CIC window opens 1 September. Start with Course 07106. It is free.

⚓ The SwiftAction Team

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In 2025, the Paris MOU and Tokyo MOU ran their joint Concentrated Inspection Campaign on ballast water management. Before that campaign had even closed, both regimes had named the 2026 topic: cargo securing. The campaign runs from 1 September to 30 November 2026, and for those three months every vessel inspected in either region, from the Atlantic and North Sea ports of the Paris MOU to the Asia-Pacific ports of the Tokyo MOU, is assessed against the cargo securing questionnaire on top of the standard inspection.

A Concentrated Inspection Campaign is the closest thing port State control has to a published exam. The topic is announced in advance, the window is fixed, and the questionnaire is released before it begins. What separates cargo securing from a simple documentation check is that, at its core, it is a competency. A Cargo Securing Manual sitting in the wheelhouse is a document. Knowing which lashings to apply for the cargo and the sea state, inspecting the securing gear against its discard criteria, and recording all of it, is a skill the crew either has or does not. A skill cannot be retrofitted the week before a boarding.

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The findings were rectified on paper. The competency gap persisted at sea.

📋 In this issue:

• 📋 The Campaign

• 📊 By The Numbers

• 🚨 The Pattern

• 🧭 What Should Be Happening

• 👀 What to Watch

• 🎯 SwiftAction Signal

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📋 The Campaign

Every year the Paris MOU and Tokyo MOU select a single compliance area and run a coordinated campaign on it, jointly, across both regions. For the period from 1 September to 30 November 2026, that area is cargo securing. The two regimes agreed the topic in principle alongside the 2025 ballast water campaign, and have also already agreed the 2027 campaign on enclosed space entry. The schedule is not a forecast. It is published policy.

How a campaign changes the inspection. During a Concentrated Inspection Campaign, a port State control officer applies the campaign questionnaire on top of the standard inspection. This matters because it changes the odds. A vessel that would pass a routine check on its general condition can pick up deficiencies, and in a serious case a detention, on the campaign topic alone. The questionnaire is not optional and it is not selective. If a ship is inspected for any reason during the window, the cargo securing questions are worked through as part of that inspection.

The reach is near total. The campaign applies to every inspected vessel, not only those pre-selected for a routine inspection. The scale of the last campaign shows what that means in practice. During the 2025 ballast water campaign, member authorities of the Tokyo MOU carried out 9,244 inspections in the three-month window, and 6,930 of them, close to 75%, included the campaign check. A campaign is not a possibility to monitor from a distance. It is a scheduled examination, with the syllabus released ahead of time, applied to almost everyone who is boarded.

Cargo securing is a competency topic. The questionnaire will work through the Cargo Securing Manual, the condition of lashing and securing equipment, stowage and stability, and the crew’s knowledge of securing procedures. Each of those has a paper element and a practical element, and the practical element is where findings are raised. An inspector can read a manual in a minute. Establishing whether the crew can actually apply it, whether the lashing gear on deck matches what the manual requires, and whether discard criteria are understood and acted on, is the part that separates a clean inspection from a finding. That assessment lands on the crew, in real time, with no opportunity to prepare once the officer is aboard.

So the situation is unusually clear. The topic is fixed. The dates are fixed. The questionnaire publishes before the window opens. The only variable a fleet actually controls is whether its crews have trained against the competency before September. The next section maps that competency to the specific deficiency codes a cargo securing inspection is built around.

📊 By The Numbers

• 1 September to 30 November 2026, the fixed window of the joint Paris MOU and Tokyo MOU Concentrated Inspection Campaign on cargo securing

• 2 port State control regimes running the campaign jointly, covering the Atlantic, North Sea, and Asia-Pacific basins

• Every inspected vessel in either region is assessed against the cargo securing questionnaire during the window, not only ships pre-selected for inspection

• 9,244 inspections carried out by the Tokyo MOU during the three-month 2025 campaign window

• 6,930, close to 75%, of those inspections included the campaign check

• 184 ships detained during the 2025 campaign, a 2.66% detention rate over the window

• Summer 2026, when the official cargo securing questionnaire is expected to be published, ahead of the September start

• 6 deficiency categories the cargo securing competency spans: cargo operations, structural conditions, water and weathertight conditions, safety of navigation, emergency systems, and ISM

• 2027 is already set for a joint campaign on enclosed space entry, giving operators more than a year of notice

Campaign topic and dates: Paris MOU and Tokyo MOU 2026 Concentrated Inspection Campaign announcements. 2025 campaign results: Tokyo MOU Annual Report on Port State Control in the Asia-Pacific Region 2025 (ballast water management CIC), published May 2026.

🚨 The Pattern

Cargo securing reads like a single line item. It is not. A securing failure is rarely one missing turnbuckle. It is a chain of competencies that runs from the manual, through the gear, into stowage and stability, and out to the bridge that has to route the ship through the weather the cargo was secured for. The 2026 questionnaire reaches into all of it, and each link maps to a specific deficiency code an officer can cite.

The manual and the gear. The starting point of any cargo securing inspection is whether the Cargo Securing Manual is current and understood, and whether the lashing material on deck matches it and is fit for service. Those are code 06101 (Cargo Securing Manual) and 06104 (Lashing Material), sitting directly on the broader handling competency in 06107 (Cargo Operation). A manual nobody applies and gear nobody inspects against discard criteria are the two most predictable findings of the entire campaign.

Stowage, stability, and loading. Securing does not exist in isolation from how the ship is loaded. The questionnaire connects to stability information and loading instruments, cargo density, and the loading and ballast condition the securing arrangement assumes. That is code 02103 (Stability, Strength, Loading Information and Instruments), 06108 (Cargo Density Declaration), 06109 (Loading Instrument), and 02134 (Loading and Ballast Condition). A correctly lashed cargo on an incorrectly loaded ship is still a deficiency.

The integrity securing depends on. Cargo stays put because the structures and closures around it hold. The campaign touches hatchways and their covers, weathertight doors and machinery space openings, and, for timber, the uprights and lashings that secure a deck load. That is code 03104 (Cargo and Other Hatchways), 03105 (Covers), 03107 (Doors), 03109 (Machinery Space Openings), and 03114 (Stowage incl. Uprights, Lashing, etc., Timber), alongside the overloading and freeboard checks in 03101 (Overloading) and 03102 (Freeboard Marks), and the structural condition codes that decide whether decks and frames can carry the load at all, 02106, 02110, 02111, 02117 and 02118.

The bridge that has to deliver it. Cargo is secured for an expected sea state. Whether the ship is routed and handled to stay within that envelope is a navigation competency. That is code 10127 (Voyage or Passage Plan) and the discipline of keeping the record straight in 10129 (Navigation Records).

What happens when securing fails. If a load shifts, the response is an emergency competency: the muster, the damage control plan, and the crew’s familiarity with the systems they will reach for. That is code 04108 (Muster List), 04111 (Damage Control Plan), and 04121 (Crew Familiarization with Emergency Systems), with the wider emergency readiness checks in 04101, 04102 and 04109.

The root that ties it together. Every one of these sits inside the Safety Management System. Whether securing procedures are planned, carried out, maintained, and reported is the ISM Code in practice, and the responsibility for it sits with the company and the master, not the classification society. That is code 15106 (Shipboard Operations), 15108 (Reporting Non-Conformities, Accidents and Hazardous Occurrences), and 15109 (Maintenance of the Ship and Equipment). An SMS is not the binder. It is whether the crew runs the procedures the binder contains.

None of these are equipment line items. They are competency line items. The hardware behind almost every one of them can be repaired in a single port call. The competency that operates and maintains it cannot be installed overnight, and it does not show up in a certificate that only says a deficiency was rectified.

🧭 What Should Be Happening

The campaign telegraphs the test. That makes the response specific rather than general. For every deficiency code the 2026 cargo securing questionnaire is built around, there is a defined competency a crew member can be trained on and assessed against before a port State control officer ever steps aboard. SwiftAction Academy’s 2026 Cargo Securing CIC bundle maps thirty modules, one to one, to the codes across all six categories the campaign reaches.

Cargo operations

• 06101 – Cargo Securing Manual

• 06104 – Lashing Material

• 06107 – Cargo Operation

• 06108 – Cargo Density Declaration

• 06109 – Loading Instrument

Structural conditions

• 02103 – Stability, Strength, Loading Information and Instruments

• 02106 – Hull Damage Impairing Seaworthiness

• 02110 – Beams, Frames, Floors, Operational Damage

• 02111 – Beams, Frames, Floors, Corrosion

• 02117 – Decks, Corrosion

• 02118 – Decks, Cracking

• 02134 – Loading and Ballast Condition

Water and weathertight conditions

• 03101 – Overloading

• 03102 – Freeboard Marks

• 03104 – Cargo and Other Hatchways

• 03105 – Covers (Hatchway, Portable, Tarpaulins)

• 03107 – Doors

• 03109 – Machinery Space Openings

• 03114 – Stowage incl. Uprights, Lashing (Timber)

Safety of navigation

• 10127 – Voyage or Passage Plan

• 10129 – Navigation Records

Emergency systems

• 04101 – Public Address System

• 04102 – Emergency Fire Pump and Its Pipes

• 04108 – Muster List

• 04109 – Fire Drills

• 04111 – Damage Control Plan

• 04121 – Crew Familiarization with Emergency Systems

ISM, the root

• 15106 – Shipboard Operations

• 15108 – Reporting Non-Conformities, Accidents and Hazardous Occurrences

• 15109 – Maintenance of the Ship and Equipment

Each module carries the Tokyo MOU and Paris MOU deficiency code on its face. A completion record shows that a named crew member completed the code-specific module and passed its assessment, which creates a documented, auditable link between the question a port State control officer will ask, the training that addresses it, and the person who was trained. The completion record does not claim to make anyone competent at sea, and it is not a substitute for statutory, flag-approved training. What it does is point at the exact code the campaign is built on, and prove that the gap behind it was actually worked. With more than 600 modules mapped one to one to the deficiency codes inspectors cite, the catalogue covers every area the 2026 questionnaire reaches, and the thirty-course bundle covers the campaign at a 60% discount on individual pricing.

👀 What to Watch

• The official questionnaire, expected summer 2026. The Paris MOU and Tokyo MOU publish the cargo securing questionnaire several weeks before the campaign opens. It tells you, item by item, what officers will check. Monitor parismou.org and tokyo-mou.org for the release, and treat the gap between publication and 1 September as the last clear window to train against it.

• The campaign window, 1 September to 30 November 2026. Any vessel inspected in either region during these three months is assessed against the questionnaire. High risk-score vessels are more likely to be inspected and should prepare accordingly, but no inspected ship is exempt.

• The Paris MOU 2025 annual report and refreshed flag lists, due around 30 June 2026. The third major regime completes the 2025 picture at the end of June, when the Paris MOU is due to publish its annual report and reset its White, Grey and Black lists for the year. Those flag movements reset every vessel’s targeting exposure heading into the campaign.

• Tokyo MOU company performance lists. From the start of 2026 the Tokyo MOU publishes performance lists for companies, not only flags. Operators now sit on the public record alongside the registries they choose, and charterers and insurers will read those lists.

• The 2027 enclosed space entry campaign. The two regimes have already agreed a joint campaign on enclosed space entry for 2027. Enclosed space entry remains one of the most dangerous recurring competency failures at sea, and operators have more than a year to get ahead of it rather than meet it cold.

🎯 SwiftAction Signal

The inspectors have published the 2026 exam. The subject is cargo securing, the window is 1 September to 30 November, and the questionnaire lands before it opens. None of that is a surprise, which is exactly the point. A Cargo Securing Manual proves a document exists. It does not prove the crew can read the cargo, the gear, and the sea state and secure the load correctly under way. That is the gap a $17 SwiftAction Academy module is built to close, mapped to the precise code an officer will cite, because the campaign has already moved the question from “is it in the manual?” to “can your crew prove they can do it?”

⚓ The SwiftAction Team

SwiftAction Intelligence is published weekly.

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In May 2026, the Tokyo MOU published its 2025 annual report on port State control in the Asia-Pacific region. The following month, on 8 June 2026, the United States Coast Guard published its own. The two regimes inspect different oceans, target different fleets, and answer to different authorities. Their 2025 numbers tell one story.

The Tokyo MOU carried out 35,546 inspections in 2025, the highest total in its history. Its officers recorded 90,168 deficiencies, up from 77,526 the year before. Four categories accounted for 53% of them: fire safety, life-saving appliances, working and living conditions, and safety of navigation. They were the same four categories, in the same order, that topped the list in 2024. The US Coast Guard, reporting separately, attributed its falling detention numbers not to better equipment but to one thing: the effective implementation of a Safety Management System.

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The findings were rectified on paper. The competency gap persisted at sea.

📋 In this issue:

• 📋 The Reports

• 📊 By The Numbers

• 🚨 The Pattern

• 🧭 What Should Be Happening

• 👀 What to Watch

• 🎯 SwiftAction Signal

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📋 The Reports

Two of the world’s three principal port State control regimes published their 2025 results within three weeks of each other. They are the closest thing the industry has to an annual report card on the operating fleet, and they are built from real inspections in real ports, not surveys or projections.

The Tokyo MOU. In 2025, member authorities of the Tokyo MOU conducted 35,546 inspections, the most in the organisation’s history. Those inspections covered 19,980 individual ships registered under 111 flags, an estimated 66% of the ships operating in the Asia-Pacific region. Officers found deficiencies in 23,230 of those inspections and recorded 90,168 deficiencies in total, up from 77,526 in 2024. A total of 1,255 ships, registered under 73 flags, were detained. The detention rate of ships inspected was 3.53%, continuing a slow decline from 3.71% in 2024, though the Tokyo MOU notes it remains above pre-pandemic levels.

The composition of those deficiencies is the part worth reading twice. Of 90,168 recorded deficiencies, four categories accounted for 53% of the total: 18,020 in fire safety measures, 11,818 in life-saving appliances, 9,108 in working and living conditions, and 8,936 in safety of navigation. In 2024, the same four categories led the list in the same order, at 15,406, 10,263, 8,193 and 8,066 respectively. The Tokyo MOU also flagged that deficiencies in structural conditions, watertight and weathertight conditions, emergency systems, and propulsion and auxiliary machinery have risen continuously over recent years, which it attributes to a lack of effective maintenance carried out on board.

The Tokyo MOU also published its under-performing ships data. A total of 222 vessels, involving 52 individual ships, were identified as under-performing in 2025, meaning detained three or more times in the previous twelve months. From the beginning of 2026, the organisation has begun publishing performance lists for companies as well as flags, a notable shift that puts the operator, not just the registry, on the public record.

The US Coast Guard. Reporting on the same calendar year, the Coast Guard conducted more examinations than the 8,710 it carried out in 2024. The total number of ships detained in 2025 for safety, security, and environmental deficiencies fell to 77, down from 82 in 2024 and 101 in 2023. The QUALSHIP 21 program, which rewards flags with strong three-year performance, ended 2025 with 4,659 enrolled vessels, down from 5,141 the year before. Four flag administrations lost QUALSHIP 21 eligibility during the year, while four gained it: the Bahamas, Germany, Italy, and the Philippines.

The most telling line in the Coast Guard report is not a number. In the program’s own assessment, the multi-year decline in the detention ratio was driven by the work of flag States and class societies on material condition, on maintenance, and, in its words, most importantly, on the effective implementation of a comprehensive Safety Management System. The Coast Guard calls the SMS the cornerstone of proactive ship management. Its 2025 Enhanced Exam Program, the quarterly equivalent of a concentrated inspection campaign, focused on engine room automation, security under the ISPS Code, emergency power and electrical systems, and the closures that form carbon dioxide protective zones.

Different basins. Different targeting models. Different legal frameworks. One conclusion. The fleet’s recurring failures are not, for the most part, failures of equipment that did not exist. They are failures to operate, maintain, and run the equipment and the systems that were already on board. That is a competency story, and it is the same competency story the data has told for years. The next section maps it to the codes your ships are being graded against.

📊 By The Numbers

• 90,168 deficiencies recorded by the Tokyo MOU in 2025, up from 77,526 in 2024

• 35,546 Tokyo MOU inspections in 2025, the most in its history

• 53% of all 2025 deficiencies came from just four categories

• 18,020 fire safety deficiencies, the single largest category

• 11,818 life-saving appliance deficiencies

• 9,108 working and living condition deficiencies

• 8,936 safety of navigation deficiencies

• Same four categories topped the list in 2024, in the same order

• 1,255 ships detained by the Tokyo MOU in 2025, under 73 flags

• 3.53% Tokyo MOU detention rate, down from 3.71% in 2024

• 222 under-performing ships (detained three or more times in twelve months) in 2025

• 3x increase in ballast water management deficiencies during the 2025 inspection campaign versus the prior year

• 77 ships detained by the US Coast Guard in 2025, down from 82 in 2024 and 101 in 2023

• 4,659 vessels enrolled in QUALSHIP 21 at the end of 2025, down from 5,141 in 2024

• 4 flag administrations lost QUALSHIP 21 eligibility in 2025

All data: Tokyo MOU Annual Report on Port State Control in the Asia-Pacific Region 2025 (published May 2026) and US Coast Guard Port State Control Annual Report 2025 (published 8 June 2026).

🚨 The Pattern

A deficiency category that tops the list for two years running, across a record number of inspections, is not bad luck. It is a signal. And in all four leading categories, the signal points at the same place: not the hardware, but the crew trained to run it.

Fire safety. 18,020 deficiencies. The largest category, again. Fire safety on a modern ship is rarely a problem of a missing extinguisher. It is a fire damper that was never tested, a detection and alarm panel nobody can interrogate, a drill that was logged but not run under load, and a crew whose performance in that drill was never honestly evaluated. Those are Tokyo MOU and Paris MOU code 07106 (Fire Detection And Alarm System), 07105 (Fire Doors And Openings In Fire-Resisting Divisions), 07110 (Fire Fighting Equipment And Appliances), 07123 (Operation Of Fire Protection Systems) and 07124 (Maintenance Of Fire Protection Systems) findings, sitting on top of a drill-quality problem captured by 04109 (Fire Drills) and 07125 (Evaluation Of Crew Performance In Fire Drills).

Life-saving appliances. 11,818 deficiencies. A liferaft, a lifejacket, and a launching appliance are inspected for one thing above all: whether they are ready, and whether the crew can use them. The recurring findings cluster around operational readiness, on-board training, and maintenance discipline. That is code 11129 (Operational Readiness Of Life-Saving Appliances), 11131 (On Board Training And Instructions), 11132 (Maintenance And Inspections) and 11134 (Operation Of Life Saving Appliances), with the abandon-ship competency itself captured by 04110 (Abandon Ship Drills).

Working and living conditions. 9,108 deficiencies. This category is where the Maritime Labour Convention meets fatigue. The findings that recur are hours of rest, records of rest, and fitness for duty: the paper trail and the underlying reality of whether the crew is rested enough to do the job. That is code 01307 (Minimum Hours Of Rest), 01308 (Records Of Rest), 09235 (Fitness For Duty, Work And Rest Hours) and the MLC conditions-of-employment codes 18201 and 18202 (Legal Documentation On Work And Rest Hours).

Safety of navigation. 8,936 deficiencies. The navigation findings that keep recurring are not broken radars. They are passage plans that were not properly made or monitored, bridge procedures that were not followed, and equipment that was available but not used correctly. That is code 10127 (Voyage Or Passage Plan), 10133 (Bridge Operation), 10135 (Monitoring Of Voyage Or Passage Plan), 10103 (Radar), 10107 (Automatic Radar Plotting Aid) and 10138 (Bridge Navigation Watch Alarm System).

The campaign confirms it. The 2025 concentrated inspection campaign, run jointly by the Tokyo MOU and Paris MOU on ballast water management, found that the most common detainable deficiency fell under code 14811 (Ballast Water Management System), the simple question of whether the system was actually operational. Ballast water deficiencies during the campaign ran three times higher than the previous year. A treatment system is hardware. Operating it correctly, day in and day out, and keeping the records straight, is code 14806 (Crew Training And Familiarization) and 14813 (Ballast Water Management Plan Implementation).

And the US Coast Guard, in plain language, named the root that ties all of it together. When it credited the effective implementation of a Safety Management System for falling detentions, it was pointing at the ISM Code: code 15106 (Shipboard Operations), 15109 (Maintenance Of The Ship And Equipment), 15107 (Emergency Preparedness) and the responsibility codes 15104 (Master’s Responsibility And Authority) and 15102 (Company Responsibility And Authority). An SMS is not a binder. It is whether the crew runs the procedures the binder contains.

These are not equipment line items. They are competency line items. The hardware behind almost every one of them can be repaired in a single port call. The competency that operates and maintains it cannot be installed overnight, and it does not show up in a certificate that says the deficiency was rectified.

🧭 What Should Be Happening

It would be wrong to read these reports as an indictment of port State control. The opposite is true. Detention rates are easing in both regimes. The Tokyo MOU ran a record number of inspections. Flag States and class societies are, by the Coast Guard’s own account, doing real and effective work on material condition and on safety management. The system is functioning, and it is catching substandard ships. None of that is in dispute.

But the recurrence is the point. When the same four categories lead the list year after year, across more inspections than ever before, it tells you that rectifying a finding on one ship in one port does not, on its own, change the competency that produced it across the fleet. The deficiency is closed. The gap that created it travels to the next ship, the next crew, and the next inspection. That is the SwiftAction thesis, written not in a single casualty report but in two years of global enforcement data.

The closure of that gap is a training problem with a training solution, and it is specific. For every one of the deficiency codes driving the 2025 numbers, there is a defined competency a crew member can be trained on and assessed against before a port State control officer ever steps aboard.

SwiftAction Academy modules that map directly to the 2025 leading categories:

Fire safety

• 07106 — Fire Detection and Alarm System

• 07105 — Fire Doors and Openings in Fire-Resisting Divisions

• 07110 — Fire Fighting Equipment and Appliances

• 07123 — Operation of Fire Protection Systems

• 07124 — Maintenance of Fire Protection Systems

• 07125 — Evaluation of Crew Performance in Fire Drills

• 04109 — Fire Drills

Life-saving appliances

• 11129 — Operational Readiness of Life-Saving Appliances

• 11131 — On Board Training and Instructions

• 11132 — Maintenance and Inspections

• 11134 — Operation of Life Saving Appliances

• 04110 — Abandon Ship Drills

Working and living conditions

• 01307 — Minimum Hours of Rest

• 01308 — Records of Rest

• 09235 — Fitness for Duty, Work and Rest Hours

• 18202 — Legal Documentation on Work and Rest Hours

Safety of navigation

• 10127 — Voyage or Passage Plan

• 10133 — Bridge Operation

• 10135 — Monitoring of Voyage or Passage Plan

• 10138 — Bridge Navigation Watch Alarm System

ISM, the root the Coast Guard named

• 15106 — Shipboard Operations

• 15107 — Emergency Preparedness

• 15109 — Maintenance of the Ship and Equipment

Each module carries the Tokyo MOU and Paris MOU deficiency code on its face. A completion record shows that a named crew member completed the code-specific module and passed its assessment, which creates a documented, auditable link between the deficiency a port State control officer can cite, the training that addresses it, and the person who was trained. That link is what converts a rectified finding from a line in a report into evidence that the competency behind it was actually closed. With more than 600 modules mapped one to one to the deficiency codes inspectors cite, the catalogue covers every category in the 2025 reports.

👀 What to Watch

• The Paris MOU 2025 annual report and the new flag lists, due 30 June 2026. The third major regime completes the picture at the end of June, when the Paris MOU is due to publish its 2025 report and refresh its White, Grey and Black lists for the year. In 2024, fire safety under SOLAS Chapter II-2 was its single largest deficiency category at 17.2%, and its detention rate rose to 4.03%. Watch whether the 2025 figures echo the Tokyo MOU’s top four, and watch the flag movements between lists, which reset every vessel’s targeting exposure for the year ahead.

• The 2026 joint Cargo Securing CIC. The Paris MOU and Tokyo MOU run their joint concentrated inspection campaign on cargo securing from 1 September to 30 November 2026. Cargo securing is a competency before it is a checklist: lashing loads, sea state, and the cargo securing manual. Crews boarded during the window will be questioned against it directly.

• Tokyo MOU company performance lists. From the start of 2026, the Tokyo MOU publishes performance lists for companies, not only flags. Operators now appear on the public record alongside the registries they choose. Expect charterers and insurers to start reading those lists.

• USCG QUALSHIP 21 churn. Four flags lost eligibility in 2025 and four gained it. The list that runs from 1 July 2025 to 30 June 2026 sets which flags carry the reduced-examination benefit, and which do not. A flag’s movement on or off that list changes the inspection burden on every vessel under it.

• The 2027 enclosed space entry CIC. The Tokyo MOU and Paris MOU have already agreed a joint campaign on enclosed space entry for 2027 (code 04118, Enclosed Space Entry And Rescue Drills). Enclosed space entry remains one of the most dangerous recurring competency failures at sea, and operators have more than a year to get ahead of it.

  

🎯 SwiftAction Signal

Two regimes. Different oceans. One 2025 verdict. Fire safety, life-saving, working conditions, navigation. The same four every year, across the most inspections ever run. Port State control can confirm the box is ticked again at the next port. It cannot confirm the crew can actually do the thing the box describes. That is the gap a $17 SwiftAction Academy module is built to close, because the inspectors have already moved on from “is it fixed?” to “can your crew prove they can run it?”

⚓ The SwiftAction Team

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Shortly after 12:30 on 4 November 2023, the UK-flagged cruise ship Spirit of Discovery lost propulsion in heavy weather while crossing the Bay of Biscay. Over the next 18 hours, the vessel rolled violently while the crew attempted to restart its propulsion pods. 115 passengers were treated for injuries. Eight were taken directly to hospital on arrival in Portsmouth. One 85-year-old passenger did not survive his injuries.

On 11 March 2026, the UK Marine Accident Investigation Branch published Accident Investigation Report 6/2026 and named five distinct safety failures. None of them were equipment failures alone. Three of them were competency failures.

The findings were rectified on paper. The competency gap persisted at sea.

📋 In this issue:

• 🌊 The Incident

• 📊 By The Numbers

• 🚨 The Training Failure

• 🩺 What Should Have Happened

• 👀 What to Watch

• 🎯 SwiftAction Signal

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🌊 The Incident

Spirit of Discovery (IMO 9802683) is a 58,119 GT cruise ship built in 2019, UK-flagged, classed by Lloyd’s Register, registered owner Saga Cruises V Limited, technical manager V.Ships Leisure SAM. The vessel departed Portsmouth on 24 October 2023 for a two-week “Canary Island Quintet” cruise. At the time of the casualty there were 943 passengers and 503 crew aboard — 1,446 persons in total. The average passenger age was 78.8. The youngest passenger was 50. The oldest was 96.

After the Spanish port of A Coruña closed due to deteriorating weather, the master decided to head directly back to Portsmouth, crossing the Bay of Biscay against weather routing guidance that advised against the passage. According to the MAIB, this decision was not effectively challenged by the bridge team or by operational teams ashore.

At about 12:30 on 4 November, with Force 11 winds and significant wave heights of 8 to 11 metres, Spirit of Discovery’s port propulsion pod’s water leakage stop sequence alarm activated. Within seconds, the port pod overspeed alarm followed, the pod shut down automatically, and the propulsion control system parked it at 90 degrees inboard to the vessel’s heading. Six minutes later, at 12:36, the starboard pod’s water leakage stop alarm activated and the starboard pod also shut down — leaving the vessel without propulsion in storm conditions.

Over the next 18 hours, the vessel was hove to at slow speed. The port and starboard pods intermittently oversped and shut down a further eight times. The ship rolled between 10 and 13 degrees. Furniture flew across decks. High-backed chairs toppled. Passengers and crew were thrown into bulkheads, into stairwells, and into furniture that was not secured.

One 85-year-old passenger was struck when the chair he was sitting in toppled backwards, with the main impact to his neck. He was helped back into the chair and remained upright for more than four hours. MAIB later concluded that decision may have caused additional neurological damage.

He arrived in Portsmouth on 6 November. He did not survive his injuries and was lost in hospital on 8 November 2023, four days after the casualty.

📊 By The Numbers

• 115 passenger injuries recorded by MAIB

• 8 seriously injured passengers taken to hospital on arrival in Portsmouth

• 1 85-year-old passenger did not survive his injuries

• 1,446 persons on board (943 passengers, 503 crew)

• 78.8 average passenger age (youngest 50, oldest 96)

• 18 hours hove to in heavy weather

• 8 times propulsion pods shut down after initial loss

• 10 to 13 degrees of roll during the casualty

• Force 12 peak wind during casualty (Force 8–9 at moment of propulsion loss, building to hurricane Force 12 through the afternoon); 8 to 11 m significant wave height

• 67% of surveyed injuries occurred at the moment of initial propulsion loss (~12:36)

• 77% of surveyed injured passengers considered onboard medical treatment adequate

• 82% of surveyed injured passengers recalled being warned about the heavy weather

• 36+ hours the 85-year-old passenger’s spinal injury remained undiagnosed on board

• 5 safety failures named by MAIB

• 5 recommendations issued to industry

• 49% of surveyed injured passengers needed further treatment after disembarkation

• 87% of surveyed injured passengers took four days or more to recover

All data: MAIB Accident Investigation Report 6/2026, published 11 March 2026, scoped to the 4 November 2023 casualty aboard Spirit of Discovery in the Bay of Biscay.

🚨 The Training Failure

The MAIB report did not blame the storm. It did not blame the propulsion manufacturer alone. It named five specific safety issues — and three of them describe what humans onboard did or failed to do.

Failure 1: The decision to cross the Bay of Biscay was not effectively challenged.

Weather routing guidance had advised against the crossing. The master proceeded anyway. The bridge team did not push back. The shore-side operational team — including the vessel’s Designated Person Ashore, who was consulted and agreed the revised passage plan — did not exercise effective challenge. MAIB framed this in operational decision-making terms: not “the challenge was absent,” but “the challenge was not effective.”

This is a Paris MOU code 10127 (Voyage Or Passage Plan), 10133 (Bridge Operation), and 10135 (Monitoring Of Voyage Or Passage Plan) issue, sitting on top of an ISM code 15104 (Masters Responsibility And Authority) and 15102 (Company Responsibility And Authority) finding.

Failure 2: The mass casualty incident plan was not implemented.

A “Code Alpha” medical-emergency announcement was made by the OOW at about 12:40, four minutes after the second pod’s loss. The medical team responded and treated the injured. What was not triggered was the formal mass casualty incident plan (MCIP) — a separate, documented procedure designed to escalate a multi-casualty event beyond standard medical response. The MCIP existed. It was carried onboard. Saga’s head of safety and policy assurance had emailed the captain and doctor the night before, specifically asking the medical team to review the MCIP. The MAIB found that despite all of that, the plan was never activated. The medical team was left “largely unsupported for more than 18 hours.”

This is a Paris MOU code 15107 (Emergency Preparedness) finding, with operational roots in 04120 (Damage Control Drill For Passenger Ships) and 04121 (Crew Familiarization With Emergency Systems).

Failure 3: The medical team lacked advanced trauma training.

The ship’s doctor was an experienced medical practitioner with general practice, emergency department, and intensive care residency background. The nurses were qualified. What the team did not hold was specific advanced trauma certification. MAIB found that the lack of advanced trauma training among the ship’s nurses may have contributed to the spinal injury not being identified earlier. Specialist advice from the Telemedical Maritime Assistance Service (TMAS) was not sought immediately. The passenger’s quadriplegia remained undiagnosed on board for more than 36 hours. He was sat upright in a chair for four hours when he should have been kept flat on a spinal board.

This is a Paris MOU code 01212 (Certificate For Medical Care) and 18404 (Medical Doctor Or PIC Of Medical Care) competency issue, compounded by an 18405 (Medical Advice By Radio Or Satellite) procedural failure on TMAS escalation.

Three failures. Zero of them required new equipment. All of them required a crew that had practiced what was already written down.

🩺 What Should Have Happened

The MAIB report acknowledges that Spirit of Discovery’s owner, manager, medical services provider, propulsion manufacturer and shipyard have already taken significant action — including implementing the mass casualty incident plan, enhancing specialist medical support, improving machinery failure checklists, and improving the securing of objects for heavy weather. Saga has not stood still. MAIB also recorded that 77% of surveyed injured passengers considered onboard medical treatment adequate and that “almost all” praised the crew’s response. The crew worked hard. The system around them did not give them what they needed. That is the SwiftAction thesis in a single passenger-vessel casualty.

MAIB issued five recommendations. The two aimed directly at the human system aboard every passenger vessel — and at every operator running a ship that could face a mass casualty — are training recommendations.

Recommendation to CLIA #1: Increase the number of trauma trained medical personnel carried by passenger vessels (MAIB references Advanced Trauma Life Support qualification as one such standard in section 1.11.4 of the report).

Recommendation to CLIA #2: Update policies on the risk assessment and securing of vessel furniture in heavy weather.

The first is a competency standard. The second is an operational procedure that depends on a crew trained to apply it as conditions deteriorate, not a checklist that lives in the safety management system.

For cruise operators, ferry operators, ro-pax, offshore accommodation units, and any vessel carrying non-crew personnel, the Spirit of Discovery report sets a new evidentiary baseline. After 11 March 2026, “we have a mass casualty plan” is not a defence. The question every DPA, every CSO, every flag state inspector, and every passenger’s family lawyer will now ask is: when did your crew last drill it under realistic load?

SwiftAction Academy modules that map directly to the Spirit of Discovery findings:

• 15107 — ISM Emergency Preparedness

• 15104 — Master’s Responsibility and Authority (ISM)

• 15102 — Company Responsibility and Authority (ISM)

• 10127 — Voyage or Passage Plan

• 10133 — Bridge Operation

• 10135 — Monitoring of Voyage or Passage Plan

• 04120 — Damage Control Drill for Passenger Ships

• 04121 — Crew Familiarization with Emergency Systems

• 04108 — Muster List

• 01212 — Certificate for Medical Care

• 18404 — Medical Doctor or PIC of Medical Care

• 18405 — Medical Advice by Radio or Satellite (TMAS)

• 10130 — Electronic Inclinometer (corresponds to MAIB’s first recommendation to MCA)

Each module maps 1:1 to its Paris MOU and Tokyo MOU deficiency code. Completion records demonstrate not just attendance but tested competency. That is the evidentiary standard MAIB is implicitly demanding of the cruise industry as of March 2026.

👀 What to Watch

• MCA international submission on electronic inclinometers. Spirit of Discovery was fitted with a mechanical inclinometer at the rear of the bridge but not the electronic inclinometer meeting IMO MSC.363(92) performance standards, which is not currently required by international carriage rules. MAIB has recommended the Maritime and Coastguard Agency propose that international carriage requirements include electronic inclinometers (Paris MOU code 10130). Expect this to surface at IMO MSC 111 (13–22 May 2026, London) and in follow-on SOLAS amendment discussions.

• CLIA member-line policy updates. Expect public statements from major cruise lines on ATLS coverage, mass casualty drill cadence, and furniture-securing standards in heavy weather. The first lines to update publicly will set the legal floor for the rest.

• Paris MOU and Tokyo MOU 2026 Cargo Securing CIC. Joint CIC announced for 2026. Securing of cargo and securing of loose items in heavy weather share a competency root: a crew that understands lashing loads, sea state, and dynamic forces. The Spirit of Discovery furniture finding will sit in inspectors’ minds when they board during the campaign window.

• Class society instruction manual revisions. MAIB recommendations to classification societies on improving instruction manual quality. Expect IACS to engage.

• Bay of Biscay weather routing precedent. Expect negligence litigation framing the master’s decision against the documented weather routing advice as a precedent test for “effective challenge” obligations under ISM.

🎯 SwiftAction Signal

The Spirit of Discovery did not have a paperwork problem. It had a documented mass casualty plan, a qualified medical team, a modern propulsion package, and a master with the authority to challenge a decision. Every box was ticked on the certificate. None of it was activated when it mattered. That is the gap a $17 SwiftAction Academy module is built to close — because the regulators have moved on from “did you have a plan?” to “when did your crew last run it?”

⚓ The SwiftAction Team

SwiftAction Intelligence Is Published Weekly.

For Partnership Inquiries Contact admin@swiftaction.ai

📋 Full Training Catalog: academy.swiftaction.ai

Across 14 months, the U.S. Coast Guard validated 81 IMO-reportable detentions. One container ship was caught three separate times in six months. Six vessels failed more than once. Across every category, the through-line is competency at the moment of inspection.

The U.S. Coast Guard’s monthly IMO Reportable Detentions list, covering January 2025 through February 2026, validates 81 foreign-flag vessel detentions in U.S. ports. The 14-month total tracks a pace below the 2024 annual figure of 82 detentions across 8,711 inspections, which the USCG reported as a 0.94% detention ratio. The headline number is not the story. The story is what the data does not show in aggregate. It shows a concentration. One flag administration accounts for more than a quarter of every detention. One Liberian-flagged Post-Panamax container ship, built in 1996, appears in three separate months under the same IMO number. Six different vessels appear more than once. The pattern is not flag-driven, not size-driven, and not age-driven. The through-line across every detention category is crew competency at the moment of inspection.

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📌 DATA CARD

🏛️ Authority: U.S. Coast Guard, Office of Commercial Vessel Compliance(CG-CVC-2)

📅 Reporting Period: January 2025 to February 2026 (14 months)

🚨 Total Validated Detentions: 81

🚢 Distinct Vessels Detained: 74

🔁 Vessels Detained More Than Once: 6

⚠️ Vessels Detained Three Times: 1 (KURE, IMO 9085522)

📈 Highest Single Month: August 2025 (11 detentions)

📉 Lowest Single Month: December 2025 / February 2026 (2 each)

🏴 Top Flag by Volume: Liberia (22 detentions, 27.2%)

⚖️ Detentions Under Active Appeal: 5 (per 46 CFR 1.03-15(h)(1))

📊 2024 USCG Comparative Baseline: 82 detentions / 8,711 inspections / 0.94% ratio

🔗 Source: USCG CG-CVC-2 Monthly IMO Reportable Detentions List

📝 THE TEST

The deficiency. What inspectors found.

The 81 detentions did not happen because the U.S. Coast Guard changed its inspection methodology, increased officer headcount, or introduced new convention requirements. Every inspection in the 14-month window was conducted under the same SOLAS, MARPOL, MLC, and STCW frameworks that have been in force for years. Every detainable deficiency raised was raised against codes that have appeared in USCG annual reports for more than a decade.

What inspectors found, repeatedly, were operational gaps that crews could not close in real time. Fire detection systems with no logged weekly tests. Lifesaving appliances that crews could not launch within the time-bounded standard the SOLAS regulation specifies. Steering gear emergency procedures that no bridge team rehearsed. Bridge navigational watch alarm systems that were silenced or bypassed. Oily water separators that crews could not operate to the 15-ppm function-test standard. Emergency drills documented in the SMS but not demonstrable on demand.

The USCG inspector’s question is not “do you have a procedure?” The question is “show me a crew member who can perform it now.” Across 14 months and 81 detentions, that is the question that crews kept answering wrong.

The deficiency-level distribution across the 81 detentions is documented in the individual USCG IMO Reportable Detention PDFs linked from the source page. Categories consistent with the recurring USCG annual-report patterns, including fire safety, lifesaving appliances, propulsion and auxiliary machinery, and ISM-related findings, dominate the underlying narratives. KURE alone (IMO 9085522) generated three separate detention reports in the period; the categories that repeated across those three reports are the categories that the rectification process did not close on the vessel.

📊 BY THE NUMBERS

📅 Detention Volume by Month

🔥 August 2025: 11

🔥 October 2025: 10

🔴 July 2025: 8

🔴 February 2025: 7

🔴 April 2025: 7

🔴 May 2025: 7

🟠 January 2025: 6

🟠 September 2025: 6

🟠 March 2025: 5

🟡 November 2025: 4

🟢 January 2026: 3

🟢 June 2025: 3

🟢 December 2025: 2

🟢 February 2026: 2

📊 Total: 81

Q3 2025 (July, August, September) produced 25 detentions, the heaviest quarter in the 14-month window. That is more detentions in 90 days than the entire November 2025 to February 2026 period combined.

🚩 Top Open-Registry and Targeted Flag Administrations by Detention Volume

🔥 🚩 Liberia: 22 detentions · 27.2%

🔴 🚩 Panama: 10 detentions · 12.3%

🟠 🚩 Cyprus: 7 detentions · 8.6%

🟠 🚩 Antigua and Barbuda: 5 detentions · 6.2%

🟡 🚩 Singapore: 3 detentions · 3.7%

🟡 🚩 Portugal: 3 detentions · 3.7%

🟡 🚩 Tanzania: 3 detentions · 3.7%

🟡 🚩 Netherlands: 3 detentions · 3.7%

📊 Top 8 subtotal: 56 detentions · 69.1%

Methodology note: Counts shown are absolute detention totals and are not normalized for fleet size, port-call volume, or per-inspection detention rates. The USCG publishes per-inspection detention ratios annually; the 2024 ratio was 0.94% (82 detentions across 8,711 SOLAS safety exams). The next official rate publication will indicate how the 2025 per-inspection rate compares.

The remaining 25 detentions are distributed across 17 additional flag administrations. Liberia, the world’s largest open registry by gross tonnage and currently a participant in the USCG QUALSHIP 21 program (readmitted effective July 2022 per LISCR), accounts for more than one in every four U.S. detentions in this window. The first counter to a flag-by-flag concentration analysis is fleet size: Liberia has the largest fleet, so absolute detention counts will scale with port-call frequency. That counter is fair, and the methodology note above acknowledges it. The relevant question is not whether the absolute count is high in proportion to the fleet, but whether the rectification process closes the underlying competency gap. KURE answers that question.

🚢 Vessels Detained More Than Once (14-Month Window)

🔥 KURE · IMO 9085522 · 🚩 Liberia 📦 Container (Post-Panamax, ~6,418 TEU) · 🛠️ Built 1996 3 detentions · Feb 2025, Jul 2025 (×2)

🔴 GERMAINE · IMO 7914482 · 🚩 Togo ⚓ Offshore Tug / Supply Ship · 🛠️ Built 1978 2 detentions · May 2025, Aug 2025

🔴 ANDINO ALPHA · IMO 9254202 · 🚩 Cyprus 🛢️ Chemical / Oil Products Tanker · 🛠️ Built 2002 2 detentions · May 2025, Sep 2025

🔴 MSC SAMIRA III · IMO 9434462 · 🚩 Liberia 📦 Container (Feeder, ~2,578 TEU) · 🛠️ Built 2009 2 detentions · Jan 2025, Feb 2025

🔴 ONEGO GLOMMA · IMO 9294977 · 🚩 Antigua and Barbuda 🏗️ Multi-purpose / Heavy-lift · 🛠️ Built 2004 2 detentions · Aug 2025 (×2)

🔴 TURBULENCE · IMO 8203256 · 🚩 Belize → Bolivia 📦 General cargo · 🛠️ Built 1983 2 detentions · Mar 2025, Apr 2025

KURE is the standout case. A 1996-built Liberian-flagged Post-Panamax container ship detained three times by the U.S. Coast Guard in a six-month window. Twice in the same calendar month (July 2025). Each detention was validated. Each detention required release before sailing. Each detention represents a finding that the previous rectification process did not close.

TURBULENCE is the second case worth flagging for a different reason. The vessel was detained in March 2025 under the Belize flag, then detained again in April 2025 under the Bolivian flag. Belize had been removed from the USCG Targeted Flag List in the 2024 annual reporting cycle. The vessel changed flag away from a recently-de-targeted administration and was detained again under the next flag down. Public vessel-tracking records also show TURBULENCE has operated under multiple prior name aliases (including ARISTOTE under Bahamian flag) before assuming its current name. The deficiencies followed the hull. The flag did not reset the targeting profile. Neither did the name.

Trade-Segment Distribution

The 81 detentions span every major foreign-trade segment serving U.S. ports. Approximate categorization based on vessel-name and public-database type fields, with appropriate hedging:

🏷️ Trade-Segment Distribution

🛢️ Tankers (crude, product, chemical, gas): ~28 detentions · ~35%

🚢 Dry-bulk and general cargo: ~24 detentions · ~30%

📦 Container ships (across all carrier sizes): ~12 detentions · ~15%

🏗️ Multi-purpose, heavy-lift, project cargo: ~10 detentions · ~12%

⚓ Specialized tonnage (OSV, dredger, tug, LNG/LPG newbuild deliveries): ~7 detentions · ~9%

📊 Total: ~81 detentions

Counts above are approximate and reflect SwiftAction Intelligence editorial categorization based on vessel name and public-registry type fields. Exact deficiency-code-to-trade-segment mapping requires the underlying USCG IMO Reportable Detention PDFs.

The mix indicates that no single trade segment is exempt from detention exposure. Vessels under newer hulls appear alongside vessels under hulls more than 30 years old. Box-trade tonnage in the global liner segment appears alongside small general-cargo vessels under flag-of-last-resort registries. Operator-level attribution (the operator and ISM Document of Compliance company fields on individual USCG detention documents) is outside the scope of this aggregate analysis and requires PDF-level verification.

✅ THE ANSWER

What should have happened.

Every one of the 81 detentions in this dataset was preventable at the crew level before the vessel ever entered U.S. waters. The U.S. Coast Guard does not detain vessels for the existence of a procedure in a manual. It detains vessels when the crew on watch cannot demonstrate the competency that the procedure describes. The gap between a procedure-on-paper and a competency-at-sea is the gap that drives detention numbers, even in a year when overall detention ratios trend down.

For the KURE case, three detentions in six months on the same hull, under the same flag, under the same IMO number, is consistent with a pattern where shore-side rectification closed each inspection finding (paperwork delivered, equipment repaired, surveyor signed off) but did not close the underlying competency gap on the bridge or in the engine room. The vessel sailed. The next inspection found the next gap. This is the textbook ISM Code Section 1.4 functional-requirements failure: the SMS did not produce continuous improvement between inspections.

For the TURBULENCE case, flag-hopping (and name-hopping) between consecutive detentions does not work. USCG targeting screens use IMO number, ship-management history, and prior detention records. They do not reset on flag change or name change. The competency that drove the March detention drove the April detention. The flag on the stern was not the variable. The name on the hull was not the variable. The 2024 USCG Annual Report removed Belize from the Targeted Flag List, which means the vessel’s first detention was under a flag the USCG had just acknowledged as improving. The crew-level competency did not improve in step with the flag.

For the broader segment distribution, the lesson is the same regardless of vessel type. Tankers, container ships, bulkers, multi-purpose, and specialized tonnage all appear in the list. Vessels under newer hulls appear alongside vessels under hulls more than 30 years old. Operator scale and SMS maturity do not, by themselves, prevent USCG detention. What prevents detention is the crew member on the bridge, in the engine room, on the boat deck, who can perform the competency on demand, in front of an inspector, in real time.

The signature pattern across all 81 detentions: the findings were rectified on paper. The competency gap persisted at sea.

🎯 THE PASS MARK

What compliant looks like.

A vessel that does not get detained by the U.S. Coast Guard is not a vessel with the cleanest paperwork. It is a vessel where every crew member on watch can perform the competency the inspector tests, on demand, without the master, the chief engineer, or the DPA being in the compartment.

The USCG inspector’s pass mark is observable, repeatable, and time-bounded. A fire team assembles in the time the SMS specifies. A lifeboat is launched within the SOLAS time-bounded standard for the vessel’s lifeboat type. The bridge officer demonstrates the BNWAS reset cycle without prompting. The duty engineer demonstrates the OWS 15-ppm function test without consulting the manual. The cargo officer can identify the segregation requirement for two adjacent containers using the IMDG Code without opening the book.

This is not a high bar. It is the bar SOLAS, MARPOL, and the ISM Code already require. It is the bar that the 81 detained crews did not clear.

🎓 THE STUDY GUIDE

Train your crew to the standard.

The deficiency narratives behind the 81 detentions cluster around a recurring set of competency themes. The SwiftAction courses below address the categories that recur most frequently in USCG and broader PSC detention narratives:

🔥 Course 07106 · Fire Detection And Alarm System Detention theme: Fire detection weekly tests not recorded

🔥 Course 07109 · Fixed Fire Extinguishing Installation Detention theme: Fixed fire suppression not demonstrable

🔥 Course 07115 · Fire-Dampers Detention theme: Fire damper inoperability or condition

⚙️ Course 07117 · Jacketed High Pressure Lines & Oil Leak Alarm Detention theme: Engine room fuel system and oil leak detection

🌊 Course 08110 · Closing Water-Tight Doors Alarm Detention theme: Watertight integrity systems

🧭 Course 10138 · Bridge Nav. Watch Alarm System (BNWAS) Detention theme: BNWAS bypass or non-functional

🛟 Course 11113 · Launching Arrangements For Rescue Boats Detention theme: Rescue boat launching beyond SOLAS time standard

⚙️ Course 02105 · Steering Gear Detention theme: Steering gear emergency procedures not rehearsed

📋 Course 15105 · Resources And Personnel (ISM) Detention theme: ISM Code crew familiarization gaps

🛢️ Course 14104 · Oil Filtering Equipment Detention theme: MARPOL Annex I oily water separator operation

❓ 3 QUESTIONS FOR YOUR DPA

1. Of our vessels that traded to U.S. ports in the last 24 months, how many were inspected by the USCG, what deficiencies were raised, and what specific competency training was deployed and verified afterward?

2. Do our pre-arrival U.S. port checklists go beyond paper sign-off? Inspection-aligned platforms like Nautilux AI by SolarisTech now deliver predictive deficiency analytics, ranking the most likely findings at the next inspection by AI before the vessel ever enters U.S. waters. A crew-demonstrable competency drill, witnessed by the master and captured against those predicted findings, with timestamped evidence and corrective learning loops, is the operational standard for vessels trading to U.S. ports across all four categories that drive USCG detentions: fire safety, lifesaving appliances, machinery, and ISM-related operations. Early-adopter fleets report fewer repeat findings, faster pre-PSC preparation, and stronger corrective-action traceability.

3. If our fleet operates under any of the top 4 detained flags (Liberia, Panama, Cyprus, Antigua and Barbuda), what additional crew competency assurance does our SMS require beyond the flag-state minimum?

👀 WHAT TO WATCH

KURE. If KURE (IMO 9085522, Liberian flag) reappears in the U.S. detention list in 2026 under the same operator or after a transfer, that is a fourth detention on the same hull. It would also place direct scrutiny on the rectification cycle for that vessel and on the Recognized Organization that signed off on each release. The next U.S. port call for KURE is the next data point.

MSC SAMIRA III. Two detentions in two consecutive months in early 2025, with an active appeal under 46 CFR 1.03-15(h)(1). The outcome of that appeal and any subsequent inspection record will indicate whether the underlying competency findings were closed or whether the vessel returns to the list.

Liberia's concentration. 27.2% in a 14-month window is a number that the Liberian Registry, LISCR (the Liberian International Ship & Corporate Registry), and the recognized organizations operating under Liberian authority will not want to see repeated in the official 2025 USCG Annual Report when it publishes (the 2024 report posted in late April 2025; the 2025 report can be expected on a similar timeline). Watch whether the per-inspection detention rate for Liberian-flagged vessels in 2025 confirms or contradicts the absolute-count concentration.

Recognized Organizations. The USCG IMO Reportable Detention documents include the Recognized Organization field for every safety detention. Aggregating the RO field across the 81 detentions is the next analytical step and a natural follow-up article for SwiftAction Intelligence. Whichever RO appears most often is the class society whose Liberia-flag and Panama-flag survey discipline most warrants attention.

🛡️ THE OPERATIONAL STANDARD

The SwiftAction Intelligence editorial position on USCG detention prevention is operational, not aspirational. SolarisTech, Inc., the parent firm of SwiftAction Academy, operates Nautilux AI, an inspection-aligned compliance intelligence platform that ranks the most likely deficiency codes at the next PSC inspection by AI, before the vessel arrives in port. Nautilux AI delivers real-time vessel scoring through CCI, ARPI, and SESI metrics, integrates with Power BI dashboards, and pairs predictive analytics with human-in-the-loop expert oversight. Combined with SwiftAction’s 600+ PSC-aligned micro-training modules (ISO 21001:2018 EOMS Certified), the SolarisTech ecosystem closes the gap between the procedure on paper and the competency at sea.

Predict. Reinforce. Defend.

The full SolarisTech service portfolio covers vessel compliance and audit services (internal audits, flag state and statutory inspections, pre-inspections, investigations), technical and safety support (corrective actions, risk assessments, cybersecurity, port security, superintendent advisory), crew services and training (AI-linked PSC learning, corrective and continuous training, predictive learning paths), and regulatory and flag advisory (white-list improvement, detention prevention, pre-port readiness, fleet reliability enhancement programs).

📩 Request a demo or fleet assessment: Admin@SolarisTechinc.com 🌐 Learn more: www.solaristechinc.com · www.nautilux.info

📡 SWIFTACTION SIGNAL

81 USCG detentions in 14 months. One 1996-built Liberian container ship caught three times. Six vessels caught more than once. One vessel changed flag and name between consecutive detentions and was caught again. Even in a year when the overall USCG detention ratio trended down, the same hulls kept returning. The findings were rectified on paper. The competency gap persisted at sea. A SwiftAction course costs $17 and takes 45 minutes to complete. A single hour of U.S. port detention costs more than the entire course catalog. The question is not whether the industry can afford to train. The question is why the same hulls keep failing the same inspections.

⚓ The SwiftAction Team SwiftAction Intelligence Is Published Daily. For Partnership Inquiries Contact admin@swiftaction.ai

📋 Full Training Catalog: academy.swiftaction.ai

🎯 PSC Deficiency Code Mapping: academy.swiftaction.ai/collections

🏅 Try a Free Course (No Credit Card): 07106 – Fire Detection and Alarm System

🛡️ Compliance Intelligence Platform: Nautilux AI by SolarisTech

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A 22-year-old container ship that passed a Cargo Ship Safety Construction survey at Arica in November 2025 and a Load Line survey at Ningbo a month earlier was inspected on the Chilean coast today and walked into six PSC findings spanning hull, load line, emergency power, engine instrumentation, fire safety, and crew working conditions. None individually crossed the detention threshold. The breadth of the spread — six unrelated PSC deficiency categories on one inspection — is the signal.

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Data Card

Vessel: MSC ANS

IMO: 9282261

MMSI / Callsign: 353873000 / H3MH

Type: Container ship

Flag: Panama

Classification Society: DNV AS

Keel laid: 24 March 2004

Vessel age: 22 years

Deadweight: 73,291 t

Gross Tonnage: 54,304

Manager: MSC Shipmanagement Ltd, Cyprus (IMO 1535947)

Inspection date: 27 April 2026

Inspection port: San Antonio, Chile

PSC regime: Viña del Mar Agreement

Inspection type: Initial

Deficiencies recorded: 6

Detention: No

The Inspection

San Antonio is one of two ports — alongside Valparaíso — that carry the bulk of Chile’s container traffic. Inspectors operating under the Viña del Mar Agreement boarded the MSC ANS for an initial PSC inspection on 27 April 2026 and recorded six deficiencies before standing down. None were classified as grounds for detention, and the vessel was cleared to continue trading.

The findings cluster across six distinct PSC deficiency categories, spanning three international conventions (SOLAS — both Chapter II-1 and Chapter II-2 — ICLL, and MLC 2006):

#1 — PSC 02112 — Structural conditions — Hull – corrosion

#2 — PSC 03102 — Water/weathertight conditions — Freeboard marks

#3 — PSC 18416 — Labour conditions, health protection — Mooring ropes/lines and wires

#4 — PSC 04114 — Emergency systems — Emergency source of power, emergency generator

#5 — PSC 13103 — Propulsion and auxiliary machinery — Gauges, thermometers, etc

#6 — PSC 07106 — Fire safety — Fire detection and alarm system

Six deficiencies on a single initial inspection is not, on its own, a remarkable count for a container vessel of this age in this region. The breadth of the categories — six unrelated areas touched in one initial inspection — is the editorial signal.

What makes the profile worth reading is what it is not. It is not a single-system failure where one neglected piece of kit drives the whole report. It is six separate touchpoints across structure, load line, MLC equipment, emergency power, engine room instrumentation, and fire detection — each consistent with the corresponding PSC Code description, and each suggesting an attention pattern rather than an isolated event.

The vessel’s recent statutory survey timeline is worth setting out separately, because the regulatory scopes do not overlap:

Cargo Ship Safety Construction (Cert 501) — surveyed by DNV at Arica, Chile, on 10 November 2025 (~5.5 months before this inspection). Hull corrosion (PSC 02112) sits within CSC scope.

Load Line (Cert 508) — surveyed by DNV at Ningbo, China, on 2 October 2025 (~6.8 months before this inspection). Freeboard marks (PSC 03102) sit within Load Line Convention scope, not CSC.

Document of Compliance (Cert 509) — surveyed at Limassol, Cyprus, on 5 June 2025.

Safety Management Certificate (Cert 510) — surveyed at Durban, South Africa, on 26 May 2025.

Two separate statutory-attended items — hull corrosion under CSC, freeboard marks under Load Line — both presenting at PSC inside seven months of their respective surveys is the editorial fact this article is built on.

By The Numbers

22 — Vessel age in years

6 — Deficiencies recorded

6 — Distinct PSC deficiency categories touched

5.5 — Months between the November 2025 Arica CSC survey and this inspection

6.8 — Months between the October 2025 Ningbo Load Line survey and this inspection

4 — Continents on which this vessel was surveyed in the preceding 12 months (Asia – Ningbo; Africa – Durban; Europe – Limassol; South America – Arica, San Antonio)

0 — Deficiencies classified as grounds for detention

2027 — Expiry year of the current Document of Compliance and Safety Management Certificate

The Training Failure

The Viña del Mar inspector did not detain the MSC ANS. The findings can each be cleared with a rectification programme and follow-up verification. That is the formal story.

The competency story is different.

A 22-year-old container ship presenting hull corrosion under PSC 02112 and freeboard mark deficiencies under PSC 03102 within seven months of their corresponding statutory surveys is the inspection’s central anomaly. The convention scopes are different, the certificates are different, and the surveying ports are different — but both items rely on a shipboard self-inspection regime that flags emerging conditions before the next external inspector boards. Hull corrosion sufficient to be recorded under PSC 02112 is generally observable during routine self-inspection rounds. Freeboard mark deficiencies under PSC 03102 are observable in the same routine. They are exactly the items a competent self-inspection regime is designed to surface.

Four of the remaining five findings sit inside operational competency:

• Emergency generator (04114) — Tested under load against SOLAS II-1/Reg.43 expectations during initial inspection scope. A finding here points to either a defective unit or a defective testing routine.

• Gauges and thermometers (13103) — Engine room walk-through item. Consistent with PSC Code descriptions involving illegible, frozen, or out-of-calibration instruments — items that are routinely covered under planned maintenance attention.

• Fire detection and alarm system (07106) — A core SOLAS Chapter II-2 item, tested against FSS Code Chapter 9 requirements. Consistent with PSC Code descriptions covering loop integrity, panel response, or sensor population.

• Mooring ropes/lines and wires (18416) — Coded under MLC 2006 Regulation 4.3 (health protection and accident prevention). Mooring equipment condition has been progressively re-classified as a labour safety item rather than a deck equipment item, reflecting the casualty data on mooring operations. A finding here suggests the on-board MLC self-inspection regime has not caught up with the equipment’s condition.

The pattern, taken across the full set, is consistent with competency drift in shipboard self-inspection — items inspected on schedule but not inspected with the rigour the regime assumes. The pattern of recent statutory certificate renewals — IOPP renewed 8 December 2025, Bunker certificate renewed 22 January 2026, IAPP renewed 27 May 2025 — shows the survey rhythm is being met. The PSC profile suggests the operational discipline behind the certificates has not kept pace.

The deficiencies will be rectified on paper. The competency gap behind them is harder to close.

SwiftAction Courses

The six deficiencies on the MSC ANS map to six SwiftAction Academy courses:

PSC 02112 — Hull corrosion → Hull – Corrosion

PSC 03102 — Freeboard marks → Freeboard Marks

PSC 18416 — Mooring lines / MLC 4.3 → Mooring Ropes/Lines And Wires

PSC 04114 — Emergency generator → Em’cy Source Of Power – Em’cy Generator

PSC 13103 — Engine room gauges → Gauges, Thermometers, Etc

PSC 07106 — Fire detection / alarm → Fire Detection And Alarm System

Each course addresses the specific competency gap reflected in the corresponding PSC finding category.

What to Watch

1. Whether MSC Shipmanagement issues a fleet-wide circular addressing the spread of the findings rather than the individual items. The signal of a serious response to a deficiency profile of this kind is system-level, not item-level.

2. Whether the operator publicly addresses the inspection through any maritime industry channel. Silence is itself a signal.

3. The next port-state inspection on this vessel — a follow-up inspection within the next 6 months at any Tokyo MOU or Paris MOU port would surface whether the rectifications held.

4. Whether DNV adjusts the scope of the next class survey attendance to reflect the PSC findings — separate items flagged at PSC across two different statutory regimes (CSC under SOLAS, Load Line under ICLL) within seven months of survey warrants visibility on what was inspected and what was deferred.

5. The Viña del Mar Agreement’s regional pattern on container vessels of this vintage — whether 20+ year container ships are being landed with comparable deficiency profiles across the Latin American PSC regime.

SwiftAction Signal

Six deficiencies on a 22-year-old container ship at San Antonio is not a detention story. It is a competency-drift story dressed as a routine PSC outcome. The cost of closing each finding individually — paint, wire-rope replacement, generator re-test, instrument calibration, sensor swap — runs into thousands of dollars per item, plus port time.

The cost of closing the competency gap behind them, through structured training that covers the same PSC code categories, runs to $17 per course on the SwiftAction Academy platform.

The findings were rectified on paper. The competency gap persisted at sea.

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A Panama-flagged, Bureau Veritas-classed, Vietnamese-managed Handysize bulker — keel laid December 2007, sailing under a previous name (CHANG AN) — picked up 5 grounds for detention on an initial PSC inspection at Shanghai on 26 April 2026. The vessel’s Safety Management Certificate had been issued by class on 17 March 2026 — 40 days before the inspectors boarded.

SwiftAction Intelligence

Inspection-aligned maritime crew training mapped to every PSC deficiency code.

By SwiftAction Academy

📌 DATA CARD

Vessel: ROYAL FALCON (ex-CHANG AN)

IMO: 9555280

MMSI / Callsign: 371661000 / 3FNE2

Type: Bulk carrier (Handysize)

Flag: 🇵🇦 Panama

Class: Bureau Veritas (BV)

Keel Laid: 5 December 2007

DWT / GT: 31,800 / 20,748

Manager: Hai Phong Ship Services Joint Stock Company (Vietnam)

Inspection Authority: China MSA

Inspection Port: Shanghai

Inspection Date: 26 April 2026

Inspection Type: Initial

Outcome: DETAINED — 5 grounds for detention

Latest SMC issued: 17 March 2026 (Bureau Veritas)

Latest DOC issued: 4 September 2025 (Bureau Veritas)

Source: China MSA inspection record (initial PSC, 26.04.2026)

📝 THE TEST

The deficiency. What inspectors found.

ROYAL FALCON arrived at Shanghai under a Panama flag, managed by a Vietnamese ship management company, with a Bureau Veritas Safety Management Certificate that had been issued just 40 days earlier. Across the prior nine months the vessel had cycled through what looked, on paper, like a complete recertification window: Cargo Ship Safety Construction renewed 7 November 2025; Cargo Ship Safety Equipment 20 October 2025; Safety Radio, IOPP, IAPP, ISPP, Load Line, and IEE all dated 23 September 2025; Document of Compliance 4 September 2025; Ballast Water Management Certificate 19 December 2025; SMC and MLC both 17 March 2026.

Then China MSA boarded.

Five grounds for detention:

1. Code 07109 — Fire Safety: Fixed Fire Extinguishing Installation

2. Code 07115 — Fire Safety: Fire-Dampers

3. Code 07117 — Fire Safety: Jacketed High Pressure Lines & Oil Leakage Alarm

4. Code 08110 — Alarms: Closing Watertight Doors Alarm

5. Code 11113 — Life-Saving Appliances: Launching Arrangements for Rescue Boats

Three of the five detainable findings sit in fire safety (07-series). One is a watertight integrity alarm under SOLAS Chapter II-1. One is the equipment that gets the rescue boat off the ship in an emergency.

📊 BY THE NUMBERS

5 — Grounds for detention on a single initial inspection

3 of 5 — Findings in fire safety alone (60%)

40 — Days between SMC issuance and detention

17 — Years since build (delivered 2009; keel laid 5 December 2007)

#1 — China’s global rank for PSC detentions (Cyprus SDM PSC Performance Report 2023–2025)

2 — Detentions anywhere in the world within 12 months that trigger China MSA’s mandatory follow-up scheme

✅ THE ANSWER

What should have happened.

Under the ISM Code, the Safety Management Certificate attests that a company’s Safety Management System has been verified and is operational at the date of survey. Class verification is bounded by what is testable on survey day. Day-to-day implementation between surveys — drills, equipment readiness, crew competency — sits with the company and the master, not the certifying class society. That distinction is the editorial story of every gap between an SMC date and a detention date.

A Safety Management Certificate is not a souvenir of a class survey. It is a working attestation that the SMS on board is operating — that the master can call for a fire drill, that the crew can launch a rescue boat, that the ship’s emergency systems function on inspection day, not only on survey day.

Forty days before China MSA inspectors boarded ROYAL FALCON at Shanghai, Bureau Veritas signed an SMC saying exactly that. Five separate detainable items disagreed.

A fixed fire extinguishing installation that does not pass inspection (Code 07109) means an inspector asked the second engineer to demonstrate the system and the demonstration did not satisfy the standard. A fire-damper finding (Code 07115) means dampers either did not close on demand, did not close fully, or could not be operated from the required control position. A jacketed high-pressure fuel line and oil leakage alarm finding (Code 07117) is the SOLAS II-2/4.2.2.5 protection against engine room fuel oil fires — the system designed to prevent the very category of casualty that destroys engine rooms. A watertight door closing alarm finding (Code 08110) means the alarm that warns crew that a door is about to close did not perform. A rescue boat launching arrangement finding (Code 11113) means the equipment that lowers a crewed boat to the water was found wanting.

These are not paperwork defects. These are operational competencies. The crew either can demonstrate them or cannot. China MSA inspectors are not asking to see the manual — they are asking the crew to show them.

The ISM Code (Resolution A.741(18), as amended) places SMS implementation, equipment maintenance (Element 10), and crew familiarisation (Element 6) squarely on the company. The SMC is verification of the system. The crew demonstrates the competency.

🎯 THE PASS MARK

What compliant looks like.

A vessel that passes a China MSA initial inspection at Shanghai, Ningbo, Shenzhen, or Guangzhou clears every line of the following bar:

• The chief engineer or second engineer can manually trigger the fixed fire extinguishing system release procedure and explain the time delay, the ventilation shutdown sequence, and the personnel evacuation interlocks — from memory, in working English, on the inspector’s first request.

• Every fire damper marked on the Fire Control Plan closes fully and can be confirmed closed from its required remote control position. Locally operated dampers operate without seizure or visible deformation.

• Jacketed high-pressure fuel lines on main and auxiliary engines are intact across their entire run. Oil leakage alarms test alive on demand. The crew knows the muster point response when an alarm sounds.

• Watertight door closing alarms sound for the full SOLAS-required interval before the door begins to close. Bridge indication confirms operation.

• Rescue boat launching arrangements lower a fully manned rescue boat to the water within the SOLAS-required time, on the side of intended use, with the davit, falls, hooks, and release gear functioning to standard. The deck crew can rig and launch under inspector observation.

The pass mark is not “the equipment exists.” It is “the crew can operate it on demand.”

🎓 THE STUDY GUIDE

Train your crew to the standard.

Fire Safety — three of five detainable findings:

• Code 07109 — Fixed Fire Extinguishing Installation

• Code 07115 — Fire Dampers

• Code 07117 — Jacketed High Pressure Fuel Lines & Oil Leakage Alarm

Alarms:

• Code 08110 — Closing Watertight Doors Alarm

Life-Saving Appliances:

• Code 11113 — Launching Arrangements for Rescue Boats

If your fleet calls Shanghai, Ningbo, Shenzhen, or Guangzhou during the Tokyo MOU 2026 cargo securing CIC, every deck and engine watch should be able to demonstrate every one of the above on first request.

❓ 3 QUESTIONS FOR YOUR DPA

1. When was your last fleet-wide fixed fire extinguishing system functional test, and was it the crew demonstrating it — or the contractor? A contractor demonstration tells you the system works. A crew demonstration tells you the system will work when it matters.

2. Can your second engineer explain the CO2 release sequence, time delay, ventilation shutdown, and personnel interlocks, in working English, from memory? Not “find it in the manual.” Explain it. That is what a Chinese PSCO will ask for.

3. What is the date of the most recent rescue boat launching drill that lowered the boat to the water with crew on board — not paid lip service in the muster list, actually launched? If the answer is “we usually just turn out and recover,” your next initial inspection in China is a 11113 finding waiting to happen.

🔭 WHAT TO WATCH

• Tokyo MOU 2026 cargo securing CIC. The 2026 CIC focuses on cargo securing across the Tokyo MOU, including China MSA. Crew competency on lashing, dunnage, and stowage will be tested on every initial inspection during the campaign window. ROYAL FALCON’s findings did not include cargo securing — but a Handysize bulker calling Chinese ports during the CIC will be tested on it.

• Bureau Veritas certifying-surveyor verification cycle. The gap between issuance of statutory certificates and operational competency findings is exactly the kind of pattern owners, charterers, and class committees track in their internal performance reviews. Whether BV opens an internal review of this case is the open question for the next reporting cycle.

• High-risk profile tonnage. Older bulk carriers operating under flags-of-convenience and managed by smaller management companies consistently feature in Tokyo MOU detention statistics — a profile that ROYAL FALCON fits. Sister tonnage in this profile group should expect heightened inspection priority at Chinese ports through the remainder of 2026.

• The vessel name change (ex-CHANG AN) is a recorded element of the IMO history. Name changes themselves are not deficiencies, but the audit trail behind a name change combined with a high-finding initial inspection is a signal for charterers reviewing this vessel for forward fixtures.

🎯 SWIFTACTION SIGNAL

A Safety Management Certificate is a piece of paper. A crew that can launch a rescue boat is not. A surveyor’s signature on an SMC is a piece of paper. A second engineer who can demonstrate the fixed fire-fighting system to a Chinese MSA inspector at 0830 in Shanghai is not.

ROYAL FALCON’s audit cycle was complete on the day she berthed. Five separate detainable items were not. The cost of this detention — vessel out of service in Shanghai, agency fees, charterer claims, off-hire, repair invoices, re-inspection — will run into six figures before she sails. A SwiftAction course mapped to every one of those five PSC codes runs $17.

The findings get rectified on paper. The competency gap persists at sea. The next inspector decides which one matters.

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📋 In this issue:

• 🔍 The Incident — What happened at Deurganck Dock

• 📊 By The Numbers — The scale of disruption and contamination

• 🔥 The Training Failure — Twelve competency gaps behind the spill

• 🛡️ SwiftAction Courses — The 12 courses mapped to the exact PSC deficiency codes exposed by this incident

• 👁️ What to Watch — The investigation, the environmental fallout, and the ageing fleet question

• 🚨 SwiftAction Signal

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📋 Competency-Based Maritime Training Mapped to Every PSC Deficiency Code → academy.swiftaction.ai

🎯 2026 CIC Cargo Securing Bundle: 30 Courses, 60% Off → academy.swiftaction.ai/bundles/2026-cargo-securing-cic-tokyo-paris-mous

DATA CARD

Vessel: MSC Denmark VI IMO: 9231250 Type: Container Ship (Post-Panamax), 5,762 TEU Flag: Liberia

Built: 2002 (24 years old) LOA / Beam: 278m / 40m

Former Name: E.R. Denmark

Incident Date: Night of April 9, 2026 Location: Deurganck Dock, Port of Antwerp-Bruges, Belgium

Hull Opening: Approximately 8cm, per the mayor of Beveren-Kruibeke-Zwijndrecht as reported by VRT NWS (not independently confirmed by marine surveyors or port authority technical report)

What Happened: Hull crack linked to corrosion opened during bunkering. Heavy fuel oil leaked into the dock, spread into the Scheldt River, shut Europe’s second-largest port, contaminated nature reserves, and left at least 37 vessels waiting to enter or leave the port, with reports of up to 50 ships stopped or delayed at peak disruption. Cleanup entered its sixth day with the full environmental impact still unknown.

Casualties: None reported Pollution: Significant — oil spread 3+ km, reached the Doelpolder wetlands, Verdronken Land van Saeftinghe, Hedwigepolder, and Bath in the Netherlands

Competency Areas Exposed: Hull corrosion detection, pre-bunkering structural assessment, SOPEP activation, pollution emergency response, ISM planned maintenance for ageing tonnage

(Note: WorldCargo News identified the vessel as MSC Monterey 5; all other major outlets including Maritime Executive, VRT NWS, Marine Insight, Safety4Sea, and Brussels Times identify it as MSC Denmark VI. This article follows the majority identification.)

THE INCIDENT

On the night of April 9, 2026, the Liberian-flagged container ship MSC Denmark VI was bunkering at Deurganck Dock in the Port of Antwerp-Bruges when heavy fuel oil began leaking from a crack in the vessel’s hull. The opening — approximately eight centimetres, according to the mayor of Beveren-Kruibeke-Zwijndrecht — was linked to a rust spot that gave way under the pressure of the refuelling operation.

The leak was not detected immediately. It continued through the night and was only discovered the following morning, when port authorities activated emergency response operations at approximately 07:30 local time on April 10.

As of publication, no official estimate of the volume of oil discharged has been released.

By then, oil had spread from the dock into the tidal Scheldt River — the main maritime access route to one of Europe’s busiest ports. Authorities closed the river to navigation between buoy 80 and the entrance to Deurganck Dock. The Zandvliet and Berendrecht locks — critical deep-sea shipping access points — were shut. Europe’s single largest container terminal, the PSA-MSC TIL facility at Deurganck with nine berths and over 12,000 feet of quay, was suspended.

At least 37 vessels were waiting to enter or leave the port as of the morning of April 11, with reports of up to 50 ships stopped or delayed at peak disruption. Multiple container ships and inland barges were contaminated, including vessels at the Noordzee Terminal and Europaterminal. The economic impact was immediate: normally, around 50 large ocean-going vessels and up to 200 ships pass through the port daily.

The oil — heavy fuel oil with a density close to brackish water — partly formed a visible film on the surface, but much of it sank below the waterline, making it difficult to detect from the air or track by surface observation. It spread at least three kilometres downstream.

Within days, the contamination had reached several protected nature reserves: the Doelpolder wetlands, a key bird breeding ground; the Verdronken Land van Saeftinghe; the Hedwigepolder; and as far as Bath in the Netherlands. The Dutch water authority Rijkswaterstaat deployed the oil spill response vessel Arca, buoy tenders, and patrol vessels — but the oil layer was too thin for mechanical skimming, and much of the pollution had moved below the water surface.

By April 15 — six days after the incident — cleanup operations were still ongoing. The conservation group Natuurpunt stated that the full extent of environmental damage would only become visible after the spring tide.

Belgian authorities and the terminal operators MSC and PSA launched a joint investigation. The vessel remains at the MSC-PSA terminal.

The Maritime Executive reported that a similar oil spill incident occurred in the same dock in June 2024, though details of that event’s cause, scale, and the vessel involved have not been independently confirmed.

Every element of this incident traces back to a measurable competency: the ability to detect corrosion before it fails, the ability to assess hull condition before pressurised bunkering, the ability to recognise and respond to an active pollution event. These are not specialist skills. They are foundational competencies that every officer on every vessel is expected to hold — and that PSC inspectors are trained to test.

BY THE NUMBERS

~8 cm — approximate size of the hull opening, per local official reporting (not independently surveyed), linked to a rust spot that cracked under bunkering pressure

37+ — vessels waiting to enter or leave the port as of 08:30 on April 11 (Brussels Times, citing port authority), with VRT NWS reporting up to 50 ships stopped or delayed

3+ km — minimum distance the oil spill spread downstream

6+ days — cleanup duration as of April 15, with full environmental assessment still pending

50 — large ocean-going vessels that typically pass through the port daily

13.6 million — TEUs handled by the Port of Antwerp-Bruges in 2025

267 million — tonnes of goods handled annually

24 years — age of MSC Denmark VI at time of incident

2nd reported incident — the Maritime Executive noted a similar oil spill occurred in the same dock in June 2024 (cause and scale unconfirmed)

4 — protected nature reserves reached by the pollution (Doelpolder, Saeftinghe, Hedwigepolder, Bath)

12 — distinct competency gaps mapped to PSC deficiency codes, spanning structural integrity, pollution prevention, and safety management

THE TRAINING FAILURE

A crack reportedly measuring approximately eight centimetres should never shut Europe’s second-largest port. Based on available reporting, it did because the corrosion behind it appears to have gone unidentified before the bunkering operation began.

Hull structural integrity is not an abstract regulatory concept. It is a foundational competency for every officer involved in vessel maintenance and pre-bunkering inspection. The chain of failures that led to this incident maps to a set of competency gaps that are visible long before a rust spot gives way under fuel pressure. Each gap corresponds to a specific, testable, trainable skill — and each one is something a PSC inspector can identify in under ten minutes during an expanded inspection.

Corrosion detection and hull survey awareness. Every vessel undergoes periodic structural surveys, but between those surveys, the ship’s crew is the first line of defence against progressive corrosion. The ability to identify wastage, pitting, and stress points — especially in areas subject to ballast water exposure, splash zones, and structural transitions — is a core competency under SOLAS Chapter II-1. A 24-year-old vessel operating in demanding trade routes should have heightened awareness of age-related structural degradation. Based on the reporting available, the rust spot that cracked does not appear to have been identified prior to the bunkering operation.

Pre-bunkering preparation and risk assessment. Bunkering operations subject hull structures to internal pressures that dormant corrosion points may not withstand. A structured pre-bunkering checklist that includes hull condition awareness — particularly for ageing vessels — is consistent with ISM Code requirements for operational risk management. The fact that fuel began leaking during bunkering and went undetected until the following morning raises questions about both the quality of the pre-operation assessment and the monitoring regime during the operation itself.

SOPEP awareness and response readiness. Every vessel is required to carry a Shipboard Oil Pollution Emergency Plan under MARPOL Annex I. The delayed detection of the leak — overnight, with oil spreading uncontrolled into the Scheldt — raises questions about how effectively the SOPEP framework was understood and activated by the crew. The plan exists for exactly this scenario. The gap is not in the plan’s existence, but in the competency to recognise a developing pollution event and activate a response before a dock becomes a disaster.

ISM Code — planned maintenance and continuous improvement. The ISM Code requires companies to establish procedures for maintenance that ensure the vessel is maintained in conformity with regulations and with additional standards established by the company. For a 24-year-old vessel, that maintenance regime must account for the accelerated degradation profile of ageing steel. The reporting of a similar incident at the same dock in June 2024 raises questions about whether lessons from that event were absorbed into the maintenance and inspection regime for vessels operating on the same route.

None of these competency gaps are invisible. Corrosion detection is trainable. Pre-bunkering risk assessment is trainable. SOPEP activation is trainable. ISM maintenance awareness for ageing tonnage is trainable. The question facing every fleet operator reading this is not whether these gaps exist on their vessels — but whether they have been identified, measured, and closed before the next PSC inspector walks aboard.

The procedures existed on paper. The competency gap persisted at sea.

SWIFTACTION COURSES

No PSC inspection report for this incident has been published. The following deficiency codes are editorially mapped based on the incident’s reported characteristics and available source material, consistent with standard PSC deficiency categorization. They do not represent confirmed inspection findings against this vessel.

The deficiency categories consistent with the findings of the MSC Denmark VI incident map to twelve SwiftAction Academy competency modules — every one verified against active PSC deficiency codes. Each link below takes you directly to the targeted training that closes the specific competency gap.

Structural Integrity Competencies

• 02112 — Hull — Corrosion. The primary reported failure. Can your crew identify wastage, pitting, and progressive corrosion before it becomes a structural failure? → Start this course

• 02113 — Hull Cracking. The ~8cm crack that released heavy fuel oil. Corrosion-driven cracking in a 24-year-old hull is a predictable degradation mode — if you know what to look for. → Start this course

• 02119 — Enhanced Survey Programme (ESP). Ageing tonnage demands a survey regime that matches the vessel’s actual degradation profile, not just the minimum interval. → Start this course

• 01312 — Thickness Measurement Report. Hull wastage tracking is the early warning system for exactly this failure mode. Do your officers understand how to interpret and act on thickness measurement data? → Start this course

Pollution Prevention & Emergency Response Competencies

• 01314 — SOPEP. The Shipboard Oil Pollution Emergency Plan exists for exactly this scenario. The overnight delay in detection raises questions about crew competency in recognising activation triggers. → Start this course

• 04112 — Shipboard Marine Pollution Emergency Operations. When oil hits the water, response time is everything. This competency is the difference between a contained spill and a port shutdown. → Start this course

• 14101 — Control of Discharge (MARPOL Annex I). Uncontrolled discharge of heavy fuel oil into the Scheldt — understanding discharge control obligations is not optional, it’s a core officer competency. → Start this course

• 14123 — Accidental Oil Outflow Performance. Where structural condition meets environmental compliance. This competency bridges hull integrity awareness and pollution prevention. → Start this course

• 14116 — Pollution Report — MARPOL Annex I. Reporting obligations are triggered the moment oil enters the water. Delays compound both the environmental and regulatory consequences. → Start this course

• 01117 — International Oil Pollution Prevention Certificate (IOPP). IOPP compliance is not a certificate on a wall — it’s a competency that must be understood and maintained operationally. → Start this course

Safety Management Competencies

• 15109 — ISM Code: Maintenance of the Ship and Equipment. The ISM Code requires maintenance procedures that match reality, not just paperwork. A corrosion-linked hull crack on a 24-year-old vessel is consistent with a gap between planned maintenance and actual structural condition. → Start this course

• 15107 — Emergency Preparedness (ISM). The overnight delay between the leak starting and its detection the following morning raises questions about emergency detection and response competency across the watch team. → Start this course

WHAT TO WATCH

The investigation. Belgian authorities and the MSC-PSA joint inquiry will determine the exact cause and timeline of the corrosion development. If the investigation reveals that the hull deterioration was visible at a prior inspection — or should have been identified during classification society surveys — the implications for the vessel’s maintenance record and ISM compliance will be significant. The vessel’s classification society survey history — including the most recent hull and structural survey — will be a key focus of any investigation into why the corrosion was not identified prior to the failure. The investigation may also examine whether pre-bunkering checks by both the receiving vessel and the fuel supplier met operational requirements.

The environmental outcome. The full impact on the Doelpolder wetlands, Saeftinghe, and the Hedwigepolder will only become clear after the spring tide. This is breeding season. If the contamination has affected nesting sites, the ecological and reputational consequences will extend well beyond the port.

The pattern. The Maritime Executive reported a similar incident in the same dock in June 2024. If the two events share similar causal factors — particularly corrosion-related hull failures during bunkering — the question shifts from “how did this happen” to “why did it happen again.” If they do not share a common cause, the recurrence still raises questions about bunkering risk management at this specific berth.

Ageing fleet exposure. MSC Denmark VI was built in 2002. The global container fleet includes thousands of vessels of similar or greater age still in active service. If corrosion-linked hull failures during routine operations become a recurring theme, PSC authorities — particularly in the Paris MOU region — may sharpen their focus on structural integrity for ageing tonnage. Fleet operators running vessels older than 20 years should be asking a simple question: does every officer on board have demonstrated competency in the specific deficiency categories that PSC inspectors target on ageing hulls?

SWIFTACTION SIGNAL

A crack reportedly measuring approximately eight centimetres shut a port that handles 267 million tonnes of cargo per year. The cleanup is in its sixth day. Oil has reached four protected nature reserves across two countries. And the investigation hasn’t even begun to produce findings.

Twelve competency gaps. Twelve PSC deficiency codes. Twelve targeted training modules — each one designed to close the exact gap that this incident exposed.

The competency gaps behind the Antwerp oil spill — corrosion awareness, pre-bunkering risk assessment, SOPEP activation, ISM maintenance management — are not exotic. They are the kind of gaps that PSC inspectors look for on every expanded inspection. They are the kind of gaps that turn a routine bunkering operation into a headline.

SwiftAction Academy courses are built to close these gaps — for $17 per module, less than the cost of a single hour of port delay. Every course maps directly to a PSC deficiency code. Every module targets a specific, measurable competency. Complete a module, and you have demonstrated competency in the exact area an inspector will test.

Start with the competencies exposed by this incident:

→ Hull — Corrosion (02112)

→ Hull Cracking (02113)

→ Enhanced Survey Programme (02119)

→ Thickness Measurement Report (01312)

→ SOPEP (01314)

→ Shipboard Marine Pollution Emergency Operations (04112)

→ Control of Discharge — MARPOL Annex I (14101)

→ Accidental Oil Outflow Performance (14123)

→ Pollution Report — MARPOL Annex I (14116)

→ IOPP Certificate (01117)

→ ISM: Maintenance of Ship and Equipment (15109)

→ ISM: Emergency Preparedness (15107)

The question is not whether your fleet has these gaps. The question is whether you’ll find them before the inspector does — or before the rust spot cracks.

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On March 1, 2026, an able seaman was asleep aboard the oil tanker Skylight when two explosions threw him off his bed. The ship was dark. Smoke filled the passageways. He had ten seconds to get out. The vessel’s captain was confirmed lost. A 24-year-old crew member on his first voyage was never found. The seaman returned to India 17 days later with nothing but the clothes on his back. Many of the Skylight’s surviving crew were also on their first voyage. Some did not know how to swim. They put on lifejackets and jumped into the sea.

The Skylight — a tanker sanctioned by the US Department of the Treasury for links to the Iranian shadow fleet — was among the first commercial vessels struck after hostilities began on February 28. The crew aboard her were civilians. Their training gaps were the same regardless of the vessel’s regulatory status. And the Skylight was not the last vessel hit. The IMO has confirmed 21 attacks on commercial shipping since hostilities began. Ten seafarers have been lost. And 20,000 more remain trapped aboard approximately 2,000 vessels in the Persian Gulf, facing what IMO Secretary-General Arsenio Dominguez described as “dwindling supplies, fatigue and severe psychological stress.”

This is not a geopolitics article. The oil price and the ceasefire and the Tehran Tollbooth are covered elsewhere. This is about what happens to crew competency when 20,000 seafarers spend six weeks in a war zone with no drills, no rotations, no shore leave, and no end in sight — and what happens when those vessels finally reach their next port of inspection.

📋 In this issue:

• 🔥 The Crisis — What’s happening to the crews

• 📊 By The Numbers — The compliance collapse

• 🔍 The Training Failure — How competency degrades in captivity

• 🛡️ What Should Have Happened — The 10 courses every stranded crew should be completing right now

• 🚨 SwiftAction Signal

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🔥 The Crisis

The Strait of Hormuz is 21 nautical miles wide at its narrowest point. Before February 28, approximately 150 vessels transited it daily. As of April 12, that number is between three and six — and most of those are Iranian-linked or sailing under the informal protection of bilateral deals with Tehran.

Iran’s Islamic Revolutionary Guard Corps controls passage through what maritime analysts have termed the “Tehran Tollbooth.” Ships transiting the northern corridor require IRGC permission and, according to multiple reports, pay tolls of $1 to $2 million per tanker in Chinese yuan or cryptocurrency.

The vessels that cannot transit — or will not risk it — sit at anchor. They sit off Fujairah. They sit in Iraqi waters. They sit in the holding areas off the UAE coast. And their crews sit with them.

The human toll is compounding:

Vessels attacked: Skylight (March 1, 1 confirmed casualty, 1 missing), MKD Vyom (March 1, 1 casualty), Stena Imperative (March 1, 1 port worker casualty), Mussafah 2 (March 6, 4 casualties), Mayuree Naree (March 11, 3 missing, presumed lost), Safesea Vishnu (March 11, 1 casualty). Additional vessels struck include Sonangol Namibe, Parimal, Gas Al Ahmadiah, Halul 69, and others.

Crew conditions: A 28-year-old Indian sailor stranded on a small oil vessel in Iraqi waters told NBC News: “We don’t sleep at night. We stay up on deck because you never know what might happen next.” The CEO of a major Hong Kong-based shipping conglomerate described the psychological reality: “When the routine breaks down is when people start to unravel. The sun goes down, and that’s when the fear comes because most of the attacks happen in the dark.”

Without structured competency-based training to anchor the day, that unravelling accelerates — and competency degrades with it.

Medical access: The captain of an oil tanker stranded near Dubai suffered a suspected heart attack on March 18 and was unable to receive medical attention in time. He did not survive.

Repatriation: The International Transport Workers’ Federation has received more than 1,000 inquiries from seafarers on 300 vessels. Most are requesting repatriation. The routes out — through Oman to Muscat, through Saudi Arabia — are slow, bureaucratic, and limited. Many seafarers have lost their documents in attacks or cannot leave vessels that require minimum manning to remain operational.

The IMO Council has appealed for a halt to all attacks on ships and called upon Member States to ensure the continuous provision of water, food, fuel and essential supplies. The UN described the situation as having “no precedent” in the post-World War II era.

📊 By The Numbers

20,000 seafarers stranded aboard vessels in the Persian Gulf, unable to transit, unable to leave, unable to return home. (Source: IMO, April 2026)

2,000–3,200 vessels trapped west of the Strait of Hormuz, including oil and gas tankers, bulk carriers, cargo ships, and six cruise liners. (Source: IMO, Lloyd’s List Intelligence)

10 seafarer fatalities confirmed by IMO since February 28. (Source: IMO Incident Tracker)

21 confirmed attacks on commercial shipping in the Persian Gulf, Strait of Hormuz, and Gulf of Oman. (Source: IMO, UKMTO)

44+ days since the crisis began on February 28. STCW and MLC set maximum continuous service periods. Hundreds of vessels are now in violation. (Source: STCW, MLC 2006)

1,000+ inquiries received by the International Transport Workers’ Federation from seafarers on 300 vessels requesting information or repatriation. (Source: ITF, UN News)

6,223 seafarers abandoned globally in 2025 — a record. Indians were hardest hit with 1,125 abandoned by year-end. The Hormuz crisis is adding to a workforce already at breaking point. (Source: ITF, Foreign Policy)

40% increase in US gasoline prices since the start of the war (approximately $1.18 per gallon). The economic impact is global. The human impact is on 20,000 people the world has largely forgotten. (Source: AAA, CNN)

🔍 The Training Failure

The Hormuz crisis is not a training failure in the traditional SwiftAction Intelligence sense. No PSCO flagged a deficiency that went unaddressed. No single vessel’s inspection record predicted what happened. This is a systemic training failure — one that is being created in real time, across an entire stranded fleet, and will manifest at the next port of inspection for every vessel currently trapped in the Gulf.

Here is what is degrading:

Emergency preparedness is theoretical until it isn’t. Many of the Skylight’s surviving crew were on their first voyage. Some could not swim. They survived because they found lifejackets and jumped. The vessel’s captain was confirmed lost. A 24-year-old crew member was never found. The crew of the Mayuree Naree were rescued by the Royal Navy of Oman after their vessel caught fire — three of their colleagues were never found. These are not drills. These are the scenarios that competency-based STCW emergency preparedness training (PSC Code 15107) is designed to prepare crews for. The question for every other vessel in that Gulf: if a projectile hits your ship tonight, can your crew execute an abandon ship procedure? When was the last time they drilled it?

Rest hours have collapsed. STCW and MLC set maximum continuous service periods and mandatory rest hours. Crews stranded for 6+ weeks beyond their planned rotation are in violation — not through any fault of their own, but through the force of circumstance. Companies are filing force majeure declarations, but these carry limited legal weight in some jurisdictions. What is not theoretical is the effect: fatigued crews make errors. PSC Code 18201 (Fitness For Duty — Work And Rest Hours) exists because the industry knows this. When these vessels finally move, the crews operating them will have been awake, stressed, and underrested for weeks.

Maintenance has been deferred. Vessels at anchor still require planned maintenance. Generators run. Systems need servicing. But when the crew is focused on survival — on watching the sky at night, on rationing supplies, on maintaining communication with families — the PMS entries stop. PSC Code 15109 (Maintenance Of The Ship And Equipment) will be the first thing a PSCO opens when these vessels reach port. Under normal circumstances, a 6-week gap in the maintenance log would be grounds for further investigation, and potentially for detention. Whether MOU regimes will issue guidance for vessels stranded in conflict zones — as some did during COVID — remains to be seen. Fleet operators who prepare as though no exemption will come are the ones who won’t need one.

Fire response readiness is unknown. The vessels that were attacked — Mussafah 2, Mayuree Naree, Skylight, Sonangol Namibe — all experienced fires. The crews that survived did so because they could respond. Some operators have implemented morale and welfare programmes — online libraries, deck activities, regular check-ins with shore teams. These efforts matter. But what about fire drills? PSC Code 04109 (Fire Drills) requires regular fire drills. PSC Code 07125 (Evaluation Crew Performance — Fire Drills) requires that crews can demonstrate competency, not just record attendance. Six weeks of inactivity and psychological stress erode both.

The master’s authority is being tested. Masters are facing pressure from charterers to transit the Tollbooth. MLC gives seafarers the right to refuse to sail into warlike conditions without penalty. PSC Code 15104 (Masters Responsibility And Authority) covers the master’s obligation to exercise independent judgment on safety matters. But as one maritime commentator observed: “Rights on paper are not the same as a way home.” The system assumes a functioning framework around the master’s authority. That framework has collapsed.

🛡️ What Should Have Happened — And What Should Be Happening Right Now

This is not an article about what should have happened before the war. No training program prevents a geopolitical crisis. This is about what should be happening right now, aboard those 2,000 vessels, while the crews wait.

Twenty thousand seafarers have smartphones. Internet access is limited but available on many vessels. Not every crew member is in a position to train — some are on heightened watch, some are rationing supplies, some are managing the psychological weight of six weeks in a war zone. But where connectivity exists and where a crew member has 45 minutes, the question is whether anyone has told them a training option exists.

The following 10 SwiftAction Academy competency-based training courses map directly to the competency gaps this crisis is creating. Each course takes approximately 45 minutes, assesses the seafarer against the specific competency standard, and produces a completion certificate referencing the PSC deficiency code — the same code a PSCO will check at the next port of inspection. Each module is mapped to a single PSC code, tests against a defined competency threshold, and produces documented evidence that the crew member met it.

PSC Code - Course - Why It Matters Right Now

04110 - Abandon Ship Drills - Skylight crew jumped into open water. Mayuree Naree crew abandoned under fire. Can yours?

04109 - Fire Drills - Tankers ablaze across the Gulf. The crew that drills is the crew that survives.

15107 - Emergency Preparedness - 21 attacks, 10 casualties. Emergency preparedness is no longer theoretical for any vessel in this zone.

07125 - Evaluation Crew Performance (Fire Drills) - Not “did you hold a drill” — “can the crew perform?” The assessment code PSCOs check.

11118 - Lifejackets Incl. Provision & Disposition - Skylight survivors wore lifejackets and jumped. Some couldn’t swim. Where are your lifejackets right now?

11119 - Immersion Suits - Crews evacuating into open water after projectile strikes. STCW requires donning within 2 minutes.

15104 - Masters Responsibility And Authority - Masters facing charterer pressure to transit. MLC gives the right to refuse. Does the master know?

18201 - Fitness For Duty — Work And Rest Hours - STCW max service periods blown. Rest hour records abandoned. This code triggers MLC detention.

15109 - Maintenance Of The Ship And Equipment - 6-week PMS gap. Generators running without logged servicing. First thing a PSCO opens.

15105 - Resources And Personnel - No rotations. No shore leave. No psychiatric support. ISM requires adequate resources. Compliance is impossible.

These are among the PSC codes most likely to surface when the Hormuz fleet reaches port. The courses are available. Whether awareness reaches the crews who need them depends on the operators who employ them.

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👀 What to Watch

The ceasefire is shaky. The two-week ceasefire announced April 8 has not reopened the strait. Iran’s IRGC claimed shipping slowed after what it called an Israeli ceasefire violation in Lebanon. US Navy destroyers entered the strait on April 11 for mine clearance operations. Iran called it a ceasefire violation. The operational status of the strait remains undefined.

The PSC wave is coming. When these vessels eventually transit — whether in days, weeks, or months — they will arrive at ports with PSC regimes that have not yet adjusted their inspection criteria for war-zone exposure. As of April 12, there is no “Hormuz exemption” in the Paris MOU targeting matrix — though flag states and MOU regimes may issue guidance, as some did during COVID. A vessel with a 6-week maintenance gap, expired rest hour records, and a crew that hasn’t drilled in over a month should prepare to be inspected to the same standard as every other vessel.

Crew recruitment will suffer. Multiple manning agencies have flagged recruitment challenges as word of the Hormuz stranding spreads through Filipino and Indian maritime labor markets. Reputation damage for operators who failed to maintain crew welfare will take years to repair. The ITF’s record of 6,223 abandoned seafarers in 2025 was already a crisis. Hormuz is compounding it.

The third crisis in five years. COVID trapped crews aboard vessels for months with no shore leave and no crew changes. The Houthi Red Sea campaign resulted in casualties and hostages. Hormuz is the third large-scale seafarer welfare crisis since 2020. The industry’s response mechanisms — MLC, flag state intervention, P&I coverage — have failed to scale each time. The pattern is no longer an anomaly. It is the operating environment.

The 2026 CIC is coming. The Paris and Tokyo MOUs’ joint Concentrated Inspection Campaign on cargo securing runs September to November 2026. Vessels that have been at anchor for weeks may face cargo shifting or lashing degradation. For vessels emerging from the Gulf into CIC-active ports, the inspection scrutiny will be layered — standard PSC plus CIC questionnaire.

🚨 SwiftAction Signal

The Skylight’s survivors were on their first voyage. Some couldn’t swim. They survived because they found a lifejacket. The vessel’s captain was confirmed lost. A 24-year-old crew member was never found. His family has not seen his body. The MLC says these seafarers have a right to repatriation. The STCW says they should not be serving beyond maximum contract periods. The ISM Code says they should have adequate resources and personnel. Every one of those protections exists on paper.

When these crews finally reach port, the PSCO will not ask about the paper. They will ask the crew to demonstrate competency. A competency-based SwiftAction course takes 45 minutes, costs $17, and tests the seafarer against the specific standard the PSCO will check. Not every stranded crew member can access one. But for those who can, the completion certificate referencing the specific PSC deficiency code may be the only documented proof of competency they carry to their next inspection. After six weeks of fear, fatigue, and deferred everything — that certificate matters.

The MLC rights existed on paper. The competency gap compounded at sea.

⚓ The SwiftAction Team SwiftAction Intelligence Is Published Daily.

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China’s Maritime Safety Administration does not just inspect your ship. It inspects whether your crew can operate it. China MSA conducts more PSC inspections than any other single authority in the Tokyo MOU — 7,721 in 2023, up 137% from 3,251 in 2022. For Cyprus-flagged vessels — one of the largest white-list fleets — China had the highest number of detentions of any country in 2023–2025, with Shenzhen, Ningbo, and Guangzhou recording the highest detention frequency in 2025, according to the Cyprus Shipping Deputy Ministry’s PSC performance analysis. On 1 December 2023, the MSA enacted a revised Special Follow-up scheme that fundamentally changed the risk calculus for every vessel trading to Chinese ports. Two PSC detentions anywhere in the world within 12 months — not just in China — and your vessel is placed on a mandatory inspection list. Every Chinese port call. Every time. Inspections conducted “in a detailed manner,” unaffected by sailing schedule or cargo operations. At the time of the circular’s issuance, 38 foreign vessels were already on the list. Regional MSA offices in Shanghai, Guangzhou, and Zhoushan now operate their own additional enforcement requirements on top of the national scheme. In 2025, China MSA launched an Enclosed Space Safety campaign running from 15 January to 15 October, adding another layer of inspection focus. And when Chinese PSCOs inspect, they don’t just check certificates and equipment condition — they ask your crew to demonstrate competency. Can your oiler start the emergency generator? Can your AB operate the fire pump? If not, detention.

📋 In this issue:

• 🔥 The Regulation

• 📊 By The Numbers

• 🔍 The Training Failure

• ✅ What Should Have Happened

• 👀 What to Watch

• 🚨 SwiftAction Signal

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→ China MSA Conducts More PSC Inspections Than Any Other Single Authority in the Tokyo MOU

→ For Cyprus-Flagged Vessels, China Had the Highest Number of Detentions of Any Country (2023–2025) (Source: Cyprus SDM PSC Performance Report)

→ Top Detention Ports for Cyprus Fleet in 2025: Shenzhen, Ningbo, and Guangzhou (Source: Cyprus SDM PSC Performance Report)

→ China MSA Conducted 7,721 PSC Inspections in 2023, Up 137% From 3,251 in 2022

→ 38 Foreign Vessels on the Special Follow-up List at Time of Circular Issuance (October 2023)

→ 17 Vessels Added to the List in 2023 Alone; 21 Carried Over From 2014–2022

→ Special Follow-up Scheme Effective 1 December 2023, Replacing 2013 Provisions

→ Two PSC Detentions Anywhere in the World Within 12 Months = Mandatory Inspection at Every Chinese Port Call

→ Shanghai: Fire Safety Defects Made Up 35.7% of All Deficiencies on Detained Ships (May 2025)

→ Guangzhou: Fire Safety Accounted for 45.7% of Defects Across 6 Detained Ships (May 2025)

→ Tokyo MOU Regional Detention Rate Decreased 0.6 Percentage Points in 2024, But Remains Above Pre-Pandemic Levels

→ 2025 Campaign: China MSA Enclosed Space Safety Inspection Campaign, 15 January to 15 October 2025 (Source: IRClass Circular 008/2025)

Sources: Cyprus SDM PSC Performance Report 2023–2025; China MSA Circular (23 October 2023); Britannia P&I via SAFETY4SEA; ABS PSC Annual Report 2023; Phoenix Register NL 322/25; Tokyo MOU Annual Report 2024; IRClass Circular 008/2025

🔥 The Regulation

On 23 October 2023, the Maritime Safety Administration of the People’s Republic of China issued revised “Provisions on the Supervision and Administration of Vessels under Special Follow-up.” The provisions came into force on 1 December 2023, replacing the 2013 version, according to IRClass, DNV, Britannia P&I, Dromon, and the Japan P&I Club.

The revision expanded the scheme in three critical ways.

First, the detention trigger is now global. Under the previous 2013 rules, only detentions by China MSA counted toward the threshold. Under the revised provisions, foreign vessels that have been detained twice in any PSC inspection — in any port, under any MOU, anywhere in the world — within a consecutive 12-month period are listed as Special Follow-up vessels, according to IRClass and Xinde Marine News. A detention in Rotterdam, Sydney, or Houston now counts toward the China MSA threshold.

Second, the list of triggering violations expanded. Beyond two detentions, the following can now place a vessel on the Special Follow-up list, according to Dromon’s analysis of the provisions:

→ Two administrative penalties from China MSA within 12 months for serious illegal acts, including inadequate manning, malicious AIS shutdown, wilful discharge of pollutants, overloading, or inland river vessels engaged in sea transportation

→ Departure after maritime administrative violations, or refusal to accept administrative penalties

→ Forged, altered, transferred, traded, or leased ship certificates

→ Major conversion without inspection and authorisation

→ Causing significant navigational accidents with equal or higher responsibility

→ Vessels managed by shipping companies that are themselves under Special Follow-up

→ Vessels designated by China MSA under the Provisions on the Administration of Maritime Law Enforcement Assistance in Investigation

Third, regional MSA offices can now publish and update the list. Under the 2013 rules, only central China MSA managed the list. The revised provisions extend this authority to MSA offices directly affiliated with China MSA and provincial-level MSA offices, according to Britannia P&I via SAFETY4SEA. This means Shanghai MSA, Guangzhou MSA, and Zhoushan MSA — each with their own additional enforcement requirements — can independently add vessels.

What happens when a vessel is listed: The inspection conducted by China MSA on Special Follow-up vessels “shall not be affected by such factors as sailing schedule, cargo loading and unloading and where conditions permit, such inspection will be conducted at each port and will be more detailed in nature,” according to IRClass’s translation of the provisions.

In practice, this means every Chinese port call becomes a full expanded inspection. Commercial pressure to sail on schedule is explicitly overridden by the regulation. The vessel’s operator cannot negotiate timing.

How to get off the list: A foreign vessel under Special Follow-up may be removed once three months have passed since the date of listing AND the vessel has undergone a China MSA PSC inspection with zero deficiencies recorded, according to Dromon and IRClass. For a vessel already flagged for systemic problems, achieving zero deficiencies in a Chinese expanded inspection is a high bar.

📊 By The Numbers

→ 7,721 PSC Inspections by China MSA in 2023, Up 137% From 3,251 in 2022 (Source: ABS PSC Annual Report 2023)

→ 32,054 Total Inspections Across All Tokyo MOU Member States in 2024 (Source: Tokyo MOU Annual Report 2024)

→ 38 Foreign Vessels on the Special Follow-up List at Time of Circular Issuance (Source: Britannia P&I via SAFETY4SEA, December 2023)

→ 12 Months: The Rolling Window for Two Detentions Anywhere to Trigger Mandatory Chinese Port Inspection (Source: China MSA Circular, 23 October 2023)

→ 3 Months + Zero Deficiencies: The Minimum Standard to Be Removed From the List (Source: IRClass, Dromon)

→ 35.7% of All Deficiencies on Detained Ships in Shanghai Were Fire Protection System Defects (May 2025) (Source: Phoenix Register NL 322/25)

→ 45.7% of Defects on 6 Detained Ships in Guangzhou Were Fire Safety Issues (May 2025) (Source: Phoenix Register NL 322/25)

→ Shanghai MSA: Zero-Tolerance on Concealment of Defects — Treated as SOLAS, MARPOL, and ISM Code Violation (Source: Lloyd’s Register Class News 22/25)

Under-performing ships in the Tokyo MOU region nearly doubled in 2024 vs. the prior year. Source: Tokyo MOU Annual Report 2024

🔍 The Training Failure

Most fleet operators prepare their vessels for PSC inspection by checking equipment condition, updating certificates, and ensuring paperwork is in order. In Chinese ports, that is not enough.

China MSA’s mechanical and electrical equipment campaign, conducted from April to October 2024 across all Chinese ports, added a requirement that catches operators off guard: crew competency demonstrations, according to IRClass and DNV. PSC officers could request crew members to demonstrate proper operational ability on machinery and electrical equipment onboard. Crew unfamiliar with equipment operation requirements could result in detention.

This is not standard PSC practice at this scale anywhere else. Paris MOU and Tokyo MOU inspections can include operational tests, but the China MSA campaign made crew demonstration a systematic, nationwide expectation. The campaign focused on propulsion machinery, generators, boilers, steering gears, anchoring devices, and MARPOL-related equipment. An oiler who cannot start the emergency generator. A 3/O who cannot demonstrate the correct procedure for switching to emergency steering. An engineer who cannot explain the maintenance history of the main engine fuel injection system. Any of these gaps is grounds for detention under the campaign.

The deficiency data from Chinese ports confirms where the competency gaps are concentrated:

Fire safety dominates. In Shanghai, fire protection system defects made up 35.7% of all deficiencies on detained ships in May 2025, followed by alarm system failures at 17.9%, according to Phoenix Register’s analysis of China PSC detention data. In Guangzhou, fire safety accounted for 45.7% of defects across six detained ships in the same period. This is consistent with the top detainable deficiency categories across the Tokyo MOU region: fire safety, lifesaving appliances, ISM, pollution prevention, and emergency systems, according to the RMI PSC presentation citing China-specific data.

Age matters. Shanghai detentions in May 2025 mainly involved ships older than 15 years. In Taizhou, all detained ships were more than 20 years old, according to Phoenix Register. Older vessels are not inherently less safe, but they require more rigorous maintenance — and more rigorous crew competency on that maintenance.

Bulk carriers are over-represented. In Qinzhou, bulk carriers accounted for 71.4% of detentions in May 2025, with defects primarily in emergency systems and firefighting facilities, according to Phoenix Register.

Shanghai MSA takes concealment personally. Concealment of defects is considered by Shanghai MSA to be a violation of SOLAS, MARPOL, and the ISM Code, according to Lloyd’s Register. This results in strict penalties including vessel detention and legal action. Shanghai MSA has emphasised a zero-tolerance approach towards negligence in machinery and electrical system management. Any vessel experiencing a machinery or electrical failure in the Shanghai region is subject to an expanded PSC inspection.

The pattern is clear: Chinese PSCOs are not looking for paperwork compliance. They are looking for evidence that the crew can actually operate and maintain the vessel. When they find gaps — and fire safety alone accounts for 35–46% of deficiencies on detained ships in Shanghai and Guangzhou — the vessel does not sail.

✅ What Should Have Happened

The deficiency categories that drive detentions in Chinese ports are the same categories that drive detentions everywhere. The difference is what China MSA does with the finding. A fire safety deficiency that earns a Code 17 correction in a European port can trigger an expanded inspection, a detention, and placement on the Special Follow-up list in China — with every subsequent Chinese port call becoming another full inspection.

The following SwiftAction Academy courses map to the deficiency categories that drive the majority of detentions in Chinese ports. Each course produces a completion record referenced to the specific PSC deficiency code. That record sits in the ship’s training files at the time of inspection.

Fire Safety (35–46% of deficiencies on detained ships in Shanghai and Guangzhou, May 2025):

Code 07106 (Fire Detection and Alarm System) — alarm system failures were the second-highest deficiency category in Shanghai at 17.9%. This course is free.

Code 07108 (Ready Availability of Fire Fighting Equipment) — fire fighting equipment readiness is routinely tested during Chinese inspections.

Code 07123 (Operation of Fire Protection Systems) — the course covers the operational demonstrations that Chinese PSCOs require.

Code 07124 (Maintenance of Fire Protection Systems) — maintenance records are scrutinised, particularly on vessels older than 15 years.

Code 07126 (Oil Accumulation in Engine Room) — oil accumulation is both a fire safety and ISM finding.

ISM Code (consistent top-three detention driver in Chinese ports):

Code 15106 (Shipboard Operations) — when a PSCO finds multiple small deficiencies across the vessel (untested fire detectors, incomplete maintenance logs, gaps in drill records), the pattern indicates systemic SMS failure. This triggers a separate ISM detention under Code 15150 that can only be cleared after an external ISM audit by the flag state or class society. One observation becomes two detainable deficiencies. Code 15106 addresses the shipboard operations competency that prevents the cascade.

Code 15107 (Emergency Preparedness) — emergency systems and firefighting facilities were the primary deficiency categories on bulk carriers detained in Qinzhou.

Code 15109 (Maintenance of the Ship and Equipment) — planned maintenance records are a specific focus of the mechanical/electrical campaign. Maintenance records must be up-to-date with sufficient detail, according to DNV’s guidance on preparing for China MSA inspections.

Propulsion and Auxiliary Machinery (mechanical/electrical campaign focus):

Code 13101 (Propulsion Main Engine) — crew demonstration of engine operation is explicitly part of the campaign.

Code 13102 (Auxiliary Engine) — generator start-up, load sharing, and emergency operation procedures are tested.

Code 13108 (Operation of Machinery) — the catch-all code for machinery operational competency that covers the demonstrations Chinese PSCOs require.

Emergency Systems (primary deficiency on bulk carriers in Qinzhou + 2025 enclosed space campaign):

Code 04118 (Enclosed Space Entry and Rescue Drills) — China MSA’s 2025 Enclosed Space Safety campaign (January–October 2025) will inspect enclosed space entry procedures, rescue drills, atmosphere testing, and crew competency. This is an active campaign now.

Code 04114 (Emergency Source of Power — Emergency Generator) — can your crew demonstrate emergency generator start and automatic switchboard connection? Chinese PSCOs are asking.

Code 04121 (Crew Familiarization with Emergency Systems) — covers the broad familiarisation requirements that underpin every crew demonstration test.

👉 Browse all Fire Safety courses: academy.swiftaction.ai/collections/07-fire-safety

👉 Browse all ISM courses: academy.swiftaction.ai/collections/15-ism

👉 Browse all Machinery courses: academy.swiftaction.ai/collections/13-propulsion-and-auxiliary-machinery

👉 Browse all Emergency Systems courses: academy.swiftaction.ai/collections/04-emergency-systems

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👀 What to Watch

The Special Follow-up list is growing. At the time of the circular’s issuance in October 2023, 38 foreign vessels were on the list. With regional MSA offices now empowered to add vessels independently, and the trigger expanded to include global detentions and a broader range of violations, the list will grow. Operators with vessels detained anywhere in the Tokyo MOU or Paris MOU regions in the last 12 months should check whether their vessels are approaching the two-detention threshold.

Shanghai MSA zero-tolerance is escalating. Any vessel experiencing a machinery or electrical failure in the Shanghai region is now subject to an expanded PSC inspection, according to Lloyd’s Register. Shanghai MSA has stated that concealment of defects will be treated as a violation of SOLAS, MARPOL, and the ISM Code. For vessels calling on Shanghai — consistently ranked as the world’s busiest container port by throughput — this is a standing enforcement posture, not a campaign with an end date.

The mechanical/electrical campaign may be permanent. The April–October 2024 campaign focused on propulsion, generators, boilers, steering, and MARPOL equipment. DNV and class societies have published extensive preparation guidance. Whether this becomes a permanent feature of Chinese PSC enforcement or repeats as an annual campaign, the crew competency demonstration requirement has established a precedent. Operators should assume it continues.

Tokyo MOU under-performing ships nearly doubled in 2024. The Tokyo MOU Annual Report 2024 noted that the number of under-performing ships was nearly double that of the previous year. The Tokyo MOU is exploring the possibility of banning under-performing ships from the region entirely. China MSA is the largest single inspection authority in the Tokyo MOU. Ships that accumulate deficiency histories in the region face compounding risk: the Tokyo MOU risk profile increases inspection probability at every member state port, while China MSA’s Special Follow-up scheme adds a separate, more punitive layer on top.

2025 Campaign: Enclosed Space Safety (active now). China MSA launched an Enclosed Space Safety inspection campaign on 15 January 2025, running through 15 October 2025, according to IRClass Circular 008/2025. This campaign runs concurrently with any standard or expanded PSC inspection. Vessels calling Chinese ports should expect enclosed space entry procedures, rescue drills, atmosphere testing equipment, and crew competency on enclosed space hazards to be inspected. This is the third major campaign layer on top of the standard inspection regime and the Special Follow-up scheme.

2025 CIC: Ballast Water Management. The Tokyo MOU and Paris MOU are conducting a joint Concentrated Inspection Campaign on Ballast Water Management from 1 September to 30 November 2025. Vessels calling Chinese ports during this period should expect BWM to be inspected in addition to any standard, expanded, or campaign inspection.

2026 CIC: Cargo Securing. The Tokyo MOU PSCC35 approved a joint CIC on cargo securing for 2026. SwiftAction’s CIC 2026 Cargo Securing Bundle covers the deficiency codes inspectors will check.

🚨 SwiftAction Signal

China MSA conducts more PSC inspections than any other single authority in the Tokyo MOU — 7,721 in 2023, up 137% from the previous year. For Cyprus-flagged vessels, China had the highest number of detentions of any country in 2023–2025, with Shenzhen, Ningbo, and Guangzhou recording the highest detention frequency in 2025. Fire safety deficiencies account for 35–46% of all findings on detained ships in Shanghai and Guangzhou. The mechanical/electrical campaign required crew to demonstrate operational competency on the spot. An enclosed space safety campaign is running through October 2025. Shanghai MSA treats concealment of defects as a SOLAS, MARPOL, and ISM violation. And since 1 December 2023, two detentions anywhere in the world within 12 months put your vessel on a mandatory inspection list at every Chinese port call, with inspections conducted “in a detailed manner” that is not affected by your sailing schedule or cargo operations.

Most operators know about Paris MOU targeting. Most know about AMSA’s enforcement reputation. Few understand the China MSA Special Follow-up scheme. Fewer still have prepared their crews for the competency demonstrations that Chinese PSCOs now routinely conduct.

The free Code 07106 module (Fire Detection and Alarm System) takes less time than reading this article. Fire safety is the number one deficiency category on detained ships in Shanghai and Guangzhou. Start there.

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📋 Data Card

Report: MAIB Investigation Report 2/2026 — Very Serious Marine Casualty Date of Accident: 8 January 2023 Report Published: 22 January 2026 Location: Approaches to the Humber Estuary, England — west of No.3 Chequer Buoy

Vessel: Finnhawk — Finland-flagged ro-ro cargo vessel, 11,671 GT, built 2001 Owner/Manager: Finnlines Plc Classification: RINA S.p.A

Pilot Vessel: Humber Saturn — UK-registered pilot vessel, GRP, built 2006 Operator: Associated British Ports Humber Estuary Services (ABP Humber)

Casualty: A 67-year-old Humber Class-2 pilot. He did not survive. Pronounced at Hull Royal Infirmary.

Conditions: Wind westerly 19kts, wave height 1–1.5m, sea temperature 7°C, air temperature 8°C.

Pilot Ladder: Approved design, good condition, correctly secured. Retrieval line rigged leading aft — contrary to IMO Resolution A.1045(27), which states retrieval lines should lead forward. The MAIB concluded this did not affect the outcome of this accident.

Source: MAIB Investigation Report 2/2026, Sections 1.1, 1.4, and 2.3

🔎 The Incident

At about 1300 on 8 January 2023, a 67-year-old Humber Class-2 pilot began climbing a 6.5-metre pilot ladder on the starboard side of the ro-ro cargo vessel Finnhawk in the approaches to the Humber Estuary. He was boarding the vessel from the pilot vessel Humber Saturn. He was wearing his issued PPE — including a high-visibility waterproof coat with integrated lifejacket, safety helmet, harness, personal locator beacon, and gloves — as well as a rucksack on his back. The Boarding and Landing Code advises against wearing rucksacks while climbing pilot ladders unless risk-assessed and part of approved PPE.

Before the transfer, multiple colleagues had attempted to dissuade him from working. The trainee pilot accompanying him had noticed him walking slowly and learned he had lower back pain, sciatica, and had not rested well. The trainee pilot suggested swapping assignments. The pilot refused. The trainee pilot then informed MCC staff, who in turn informed VTS staff. VTS staff, concerned by the pilot’s slow, laboured walk along the jetty observed on CCTV, asked the pilot vessel coxswain to check on him. The pilot said he wanted to proceed. The coxswain asked again immediately before the transfer. The pilot firmly replied that he did. In total, the trainee pilot proposed alternative assignments (the tanker pilot agreed to swap), informed MCC staff — who in turn alerted VTS staff — and the pilot vessel coxswain asked the pilot twice whether he wanted to proceed. At every stage, the pilot refused the alternatives and insisted on climbing.

The pilot inspected the ladder, tested it by putting his weight on it and pulling it away from the hull, and began climbing. Finnhawk’s second officer and an able seaman were monitoring the embarkation at the top of the pilot ladder. The pilot’s upper body was further from the ladder than his lower limbs and his progress was very slow. At approximately 2 to 2.5 metres above the pilot vessel’s deck, he stopped, looked up at Finnhawk’s crew above him, then suddenly leaned back, released both hands simultaneously, and fell backwards without making a sound.

He landed on his back on Humber Saturn’s deckhouse and port safety rail. The pilot vessel was positioned beneath the ladder at the time of the fall. His safety helmet broke on impact. The MAIB found it was highly likely that his thoracic spine fractures occurred at this point. He then slipped off the pilot vessel and fell into the sea between the two vessels. His integrated lifejacket inflated and his personal locator beacon activated. He was floating with his head above water.

The pilot vessel crew responded immediately. Within approximately two minutes, the deckhand used a MateSaver MOB rescue pole to catch the pilot and manoeuvre him to the stern. The crew then attempted to deploy Humber Saturn’s man overboard recovery platform — the vessel’s only means of lifting an unconscious person from the water.

The platform lowered. It would not raise.

The crew tried the mobile control box, the manual solenoid valve, and the secondary hand pump in the aft void space. Nothing worked. An MCA inspection the following morning found the platform operated under light load (approximately 100kg). An independent contractor inspection on 11 January — three days after the accident — found a defective solenoid valve and a loose limit switch fixing bolt. When the platform was loaded to 160.8kg — just over its safe working load of 160kg — it could not lift until those defects were rectified.

The pilot remained partially immersed on the lowered recovery platform for over 40 minutes. The trainee pilot jumped onto the platform to lift the pilot’s head clear of the water. Waves intermittently washed over both of them. The trainee pilot was occasionally chest-deep in cold water and unable to determine whether the pilot was still breathing.

The RNLI all-weather lifeboat arrived 26 minutes after the fall. Its rigid inflatable boat transferred the pilot to the lifeboat, where CPR was started. A coastguard helicopter winched the pilot and transferred him to Hull Royal Infirmary. He did not survive. He was pronounced at Hull Royal Infirmary at 1452 — nearly two hours after the fall.

The trainee pilot was treated for hypothermia. The deckhand was treated for a hand injury sustained during the rescue.

Source: MAIB Investigation Report 2/2026, Sections 1.2, 1.3, 1.8.6, and 2.9

📊 By The Numbers

→ 6.5 metres — the height of the pilot ladder climb from Humber Saturn to Finnhawk’s upper deck. (Source: MAIB Report 2/2026, Section 1.2.2)

→ 7°C — sea water temperature at the time of the accident. The RNLI defines cold water as anything below 15°C. (Source: MAIB Report 2/2026, Section 1.1; RNLI definition cited in Section 1.9.4)

→ 40+ minutes — the time the pilot remained partially immersed on the defective recovery platform before being transferred to the RNLI RIB. (Source: MAIB Report 2/2026, Synopsis)

→ 20+ defects — the number of defects reported for Humber Saturn’s recovery platform in the five years before the accident, including lifting wires, limit switches, and sticking solenoid valves. ABP Humber’s maintenance system did not classify these as safety-significant. (Source: MAIB Report 2/2026, Section 1.7.3)

→ 130 kg — the pilot’s recorded weight at his last medical examination. The recovery platform’s safe working load was 160 kg. The MAIB assessed that it was possible that the defective solenoid valve, combined with the pilot’s weight plus wet clothing, rendered the platform incapable of lifting at the time of the accident. (Source: MAIB Report 2/2026, Sections 1.6.4, 1.7.2, and 2.6)

→ 67 years old — the pilot’s age. He had suffered a heart attack in 2011, a stroke in 2018, and had chronic kidney disease, high blood pressure, and obesity (BMI 40.1). Six months before the accident, he was issued a Category 1 ENG1 declaring him fit with no limitations. (Source: MAIB Report 2/2026, Sections 1.3 and 1.6)

→ 96,000 — the number of pilot transfers conducted underway using pilot ladders in the UK each year, by approximately 700 pilots. (Source: MAIB Report 2/2026, Section 1.10.1, citing MAIB 2022 CHA survey)

→ 4 MAIB recommendations issued to the MCA, ABP, and UK port industry bodies. (Source: MAIB Report 2/2026, Section 5)

🚨 The Systemic Failures

The MAIB identified multiple systemic failures that combined to significantly reduce the pilot’s chance of survival after the fall. These are not the usual crew competency gaps SwiftAction covers — they are organisational and regulatory failures. But every one of them has a training dimension that fleet operators and port authorities can address.

Failure 1: Medical fitness assessment was incomplete.

The pilot had a documented history of heart attack (2011), stroke (2018), chronic kidney disease, high blood pressure, and obesity (BMI 40.1 — severely obese). Despite this history, six months before the accident an MCA Approved Doctor issued a Category 1 ENG1 — fit for sea service with no restrictions. The MAIB found that the examination did not follow MCA guidance. The pilot’s BMI alone required a physical capabilities assessment under the Approved Doctor’s Guidance. That assessment was not performed. Additionally, the pilot did not declare his heart conditions to the examining doctor, and the doctor did not have digital access to the pilot’s previous ENG1 records to cross-check.

The MAIB concluded that correct assessment would probably have led to the pilot being declared either temporarily unfit or only fit for restricted service.

Failure 2: Stop-work procedures could not stop the pilot from working.

ABP Humber’s “Beyond Zero” safety culture empowered employees to stop unsafe work. On the day of the accident, multiple interventions were made — the trainee pilot proposed alternative assignments (the tanker pilot agreed to swap), the trainee pilot informed MCC staff who alerted VTS staff, and the pilot vessel coxswain asked the pilot twice whether he wanted to proceed. The pilot overrode every intervention.

The MAIB observed that employees are more likely to report a technical fault than challenge a colleague’s fitness for duty. The pilot’s age, experience, and long service may have made it difficult for his colleagues to exercise stop-work authority, despite their clear concerns. The MAIB characterised stop-work systems as “a supportive safeguard rather than an effective barrier.”

Failure 3: The only means of recovering an unconscious person from the water did not work.

Humber Saturn’s electro-hydraulic recovery platform was the vessel’s sole method of lifting a person in the water. It had accumulated over 20 reported defects in five years. ABP Humber’s maintenance system did not classify the recovery platform as safety-critical equipment. The MAIB assessed that it was possible that the defective solenoid valve, combined with the pilot’s weight plus wet clothing, rendered the platform incapable of lifting at the time of the accident. There was no backup — no davit, no harness arrangement, no independent recovery system.

This was not the first time inadequate pilot vessel recovery equipment contributed to a pilot being lost. In February 2018, a pilot fell from the container ship Singapore Express off Lisbon and could not be recovered for over 100 minutes because the pilot vessel’s recovery davit was unfit for purpose. That pilot did not survive. The investigation found no emergency procedure for recovering an unconscious person from the water.

Failure 4: The pilot’s clothing did not protect against cold water immersion.

The pilot wore an approved high-visibility waterproof coat with integrated lifejacket, safety boots, gloves, and a safety helmet. His trousers were thin suit-type trousers. This clothing kept his head above water but provided no thermal protection. The trainee pilot, who spent approximately 40 minutes on the platform with the pilot, was treated for hypothermia. The MAIB noted that immersion in cold water can provoke a cardiac event in individuals with pre-existing heart disease.

Failure 5: Pilots had received no sea survival, first aid, or CPR training.

None of the three ABP Humber pilots on board Humber Saturn at the time of the accident had received sea survival or first aid training, including defibrillator use, since joining the company. Only the pilot vessel crew held first aid certificates — and the coxswain was conning the vessel while the deckhand had injured his hand during the rescue. Had the pilot been recovered to the deck, the available first aid capability would have been severely compromised. IMO Resolution A.960(23) and the Boarding and Landing Code both recommend that pilots receive this training.

Failure 6: The pilot vessel was positioned beneath the ladder.

Humber Saturn was positioned beneath Finnhawk’s pilot ladder when the pilot fell. He landed on the pilot vessel’s deckhouse and safety rail, fracturing his thoracic vertebrae, before falling into the sea. The Fédération Française des Pilotes Maritimes reviewed French pilot accidents over 20 years and found that a 3-metre fall onto a pilot vessel could result in serious injury, while a fall from 8 metres could be unsurvivable. The pilot in this case fell approximately 2 to 2.5 metres onto a hard surface.

The updated Boarding and Landing Code now includes guidance on “Climb Zones” — the positioning of the pilot vessel relative to the ladder during the pilot’s climb. This is actionable for both pilot vessel coxswains and vessel masters receiving pilots: the positioning of the pilot vessel during transfer should be discussed and agreed before the pilot begins climbing.

Source: MAIB Investigation Report 2/2026, Sections 2.4–2.10, 1.9.5, and 1.10.3

🛡️ What Vessel Crews Should Learn — SwiftAction Courses

Finnhawk’s pilot ladder was in good condition and correctly secured. The vessel’s crew monitored the embarkation correctly. The failures in this case were on the port authority and pilot vessel side. But every pilot transfer involves two parties, and the MAIB’s findings contain direct lessons for vessel operators about their own pilot boarding arrangements, emergency preparedness, and equipment maintenance.

Pilot Ladders & Hoist/Pilot Transfer Arrangements (Code 10101) Code 10101 is the PSC deficiency code for pilot transfer arrangements. PSCOs routinely inspect pilot ladder rigging, securing, condition, and compliance with SOLAS V/23 and IMO Resolution A.1045(27). Finnhawk’s ladder was in good condition and correctly secured — but its retrieval line was rigged leading aft, contrary to IMO Resolution A.1045(27), which states that retrieval lines should lead forward. The MAIB concluded this did not affect the outcome, but it illustrates how a vessel that meets the physical standard can still have compliance gaps that a PSCO will identify. SwiftAction’s Code 10101 module covers SOLAS requirements for pilot boarding arrangements, the correct rigging of pilot ladders and combination arrangements, retrieval line positioning, lighting requirements, and the specific items PSCOs check during inspection.

Emergency Preparedness (Code 15107) The recovery of a person from the water is an emergency procedure that every vessel must be prepared to execute. The Humber Saturn case demonstrates what happens when the emergency equipment fails and no backup exists — a scenario that also occurred in the 2018 Singapore Express pilot loss off Lisbon. SwiftAction’s Code 15107 module covers the ISM Code requirements for emergency preparedness, including drills, procedures, and the identification of potential shipboard emergencies. For vessel crews, the question is not whether a pilot will fall — it is whether the crew can respond effectively if one does.

Maintenance of the Ship and Equipment (Code 15109) Humber Saturn’s recovery platform accumulated over 20 defects in five years. The maintenance system did not classify it as safety-critical. The platform passed its routine daily check on the morning of the accident — but could not lift a loaded person when it mattered. SwiftAction’s Code 15109 module covers the ISM Code requirements for planned maintenance, the identification and reporting of safety-critical equipment defects, and the distinction between routine maintenance and safety-significant defect management. The lesson for vessel operators: if a piece of equipment exists to save a life, it must be maintained to save a life.

Masters Responsibility and Authority (Code 15104) Multiple colleagues tried to stop the pilot from climbing the ladder. None succeeded. The MAIB found that the port’s stop-work system was ineffective because colleagues could not override the pilot’s decision. SwiftAction’s Code 15104 module covers the master’s overriding authority under the ISM Code to make safety decisions, including the authority to refuse to proceed with an operation the master considers unsafe. For vessel masters receiving a pilot, the question is: if you observe a pilot who appears unfit to make the transfer, do you have the procedures and the confidence to refuse the boarding?

Resources and Personnel (Code 15105) The pilot climbed a 6.5-metre ladder despite visible signs of impairment that prompted multiple interventions from colleagues. On the pilot vessel side, only two crew members were available for MOB recovery, and none of the three pilots onboard had received sea survival or first aid training. SwiftAction’s Code 15105 module covers the ISM Code requirements for adequate resources and personnel, including manning levels, training, and the competency of personnel assigned to safety-critical operations.

Crew Familiarization with Emergency Systems (Code 04121) When the recovery platform failed, Humber Saturn’s crew and the pilots onboard had no alternative recovery plan and limited first aid capability. SwiftAction’s Code 04121 module covers SOLAS requirements for crew familiarization with emergency systems and the STCW onboard training obligations. The module addresses the scenario where primary emergency equipment fails and the crew must improvise — the exact scenario that played out on Humber Saturn.

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👀 What to Watch

The MAIB issued four recommendations. Two target the regulatory framework:

Recommendation 2026/103 asks the MCA to amend MGN 544 to require non-SOLAS vessels to carry an alternative means of recovering an unconscious person that does not rely on shipboard systems or power. This directly addresses the single point of failure that prevented Humber Saturn’s crew from recovering the pilot.

Recommendation 2026/106 asks UK port industry bodies to update the Boarding and Landing Code to include guidance on occupational health standards for marine pilots and cold water survival PPE.

ABP Humber has already taken action: introducing an improved medical standard for its pilots, equipping all pilot vessels with manually operated recovery cradles as backup, upgrading defibrillators and stretchers, and strengthening its Stop-Work Authority programme. The MCA has introduced the Approved Doctors Information System, which allows Approved Doctors to access seafarer medical examination records digitally — addressing the records access gap that contributed to the pilot’s incomplete medical assessment.

For vessel operators, the immediate question is not whether your pilot ladder is compliant — it is whether your crew knows what to do if a pilot falls during the transfer. Does the vessel have MOB recovery equipment that works? Has the crew drilled the scenario? Can the crew provide first aid? Does the master know the authority exists to refuse a transfer if conditions are unsafe? These are the competencies PSCOs check under Codes 10101, 15107, and 04121. They are also the competencies that save lives.

Pilot transfers are among the most dangerous routine operations in maritime. The MAIB’s 2022 survey found that UK pilots alone conduct 96,000 underway pilot ladder transfers every year. Most are completed without incident. This one was not.

⚡ SwiftAction Signal

The Pattern: A pilot with a documented history of cardiac disease, stroke, obesity, and chronic pain was declared fully fit for unrestricted sea service by an Approved Doctor who did not follow the MCA’s own guidance. When he suffered a probable cardiac event on the ladder, the only equipment that could have recovered him had a known pattern of defects and failed under load. His colleagues tried to stop him. The system let him through.

The Gap: Medical fitness certification that does not match the physical demands of the role. Maintenance systems that do not distinguish between routine defects and safety-critical failures. Stop-work cultures that empower employees in theory but cannot override individual determination in practice. PPE that keeps your head above water but does not keep you alive in 7°C seas.

The Question for Fleet Operators: Your vessel receives pilots. Is your pilot ladder rigged correctly — including the retrieval line? If a pilot falls during transfer, can your crew recover them? Has the MOB recovery equipment been tested under load — not just lowered and raised empty? Does your master know the authority exists to refuse a transfer if conditions are unsafe? Have you discussed pilot vessel positioning during the climb?

One course. One drill. One maintenance check. That is the difference between a routine transfer and a pilot who never comes home.

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The bulk carrier Mandy was detained in Rotterdam in June 2025. Inspectors found 25 deficiencies. Nine were grounds for detention. Seven were fire safety. Eight months later, two crew members were lost in an engine room fire off the coast of China. The Maritime and Port Authority of Singapore is investigating.

📋 In this issue:

• 🔥 The Fire: Engine Room, Off the Coast of China

• 📋 The Detention: Rotterdam, June 2025

• 📊 By The Numbers

• 🔍 The Training Failures the PSC Record Exposed

• 🛡️ How SwiftAction Training Addresses These Gaps

• 👀 What to Watch

• 🚨 SwiftAction Signal

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📌 SwiftAction Data Card

→ ⚓ June 2025, Rotterdam: The bulk carrier Mandy was detained for 15 days after PSC inspectors found 25 deficiencies, nine of which were grounds for detention. Seven deficiencies were in the fire safety category. (Source: Seatrade Maritime, February 19, 2026)

→ 🔥 Fire safety findings: Two defects classified as “inoperative” under ready availability of firefighting equipment. Additional deficiencies in machinery space controls, crew performance evaluation, fire dampers, and fire pumps. (Source: Ships & Ports, February 23, 2026)

→ 🔄 August 2025: Imelda Shipping took over management of the vessel. (Source: Seatrade Maritime, February 19, 2026)

→ 🔥 February 17, 2026: An engine room fire broke out aboard the Mandy off the coast of Shandong, China, at approximately 1935 hours Singapore time. The fire was extinguished by the crew. The vessel was disabled and arrangements were made to tow it to Yantai Port. (Source: MPA Singapore, February 18, 2026)

→ ☠️ Two crew members lost: Of the 25 Myanmar crew members on board, two did not survive. A third was evacuated to a shore medical facility for further treatment. Unconfirmed reports indicated the chief engineer and an oiler were among the casualties. (Source: MPA Singapore / Maritime Executive, February 18, 2026)

→ 🔍 Investigation: The Maritime and Port Authority of Singapore, as flag state, has launched a formal investigation into the circumstances of the fire. No pollution was reported. (Source: MPA Singapore, February 18, 2026)

🔥 The Fire: Engine Room, Off the Coast of China

On February 17, 2026, at approximately 1935 hours Singapore time, a fire broke out in the engine room of the Singapore-registered bulk carrier Mandy off the coast of Shandong, China. The vessel was nearing the end of a voyage from Kamsar Anchorage in Guinea, West Africa, bound for Yantai, China, according to The Week.

The crew extinguished the fire. But two of the 25 Myanmar crew members on board did not survive. A third was evacuated to a shore medical facility for further treatment. Unconfirmed reports from Chinese media outlet Xinde Marine News indicated the chief engineer and an oiler were among the casualties, according to the Maritime Executive.

No Singaporeans were on board. No pollution was reported. Chinese authorities dispatched rescue vessels and a helicopter to assist, according to Alpha Navigation. The vessel was disabled by the fire and arrangements were made to tow it to Yantai Port, according to the Maritime and Port Authority of Singapore.

The MPA issued a statement on February 18, 2026, confirming the incident and extending condolences to the families of those who were lost. The authority stated it would investigate the incident as the flag state for the vessel, in coordination with relevant Chinese authorities, according to gCaptain.

The Mandy is a 180,371 DWT bulk carrier built in 2010. At the time of the fire, the vessel was managed by Imelda Shipping, which had taken over management in August 2025, according to Seatrade Maritime. The vessel was previously managed by Pacific Rim Shipmanagement.

Engine room fires remain one of the most serious hazards in maritime operations. They involve complex machinery, high-pressure fuel systems, hot exhaust surfaces, and limited escape routes for crew members. Fire safety has been the leading category of PSC detentions globally for over a decade.

📋 The Detention: Rotterdam, June 2025

Eight months before the engine room fire, the Mandy had been detained in the port of Rotterdam.

In June 2025, Port State Control inspectors found 25 deficiencies on board the vessel, according to Seatrade Maritime and Ships & Ports. Nine of these deficiencies constituted grounds for detention. The vessel was held for 15 days.

Seven of the recorded deficiencies were in the fire safety category, according to Ships & Ports. The following descriptions are consistent with the corresponding Paris MOU deficiency codes, based on standard PSC code definitions. The exact codes from the inspection report should be verified against the THETIS database before republishing. Among them:

→ Two defects classified as “inoperative” under ready availability of firefighting equipment, consistent with PSC Code 07108.

→ One deficiency under control mechanisms within machinery spaces, consistent with PSC Code 07114.

→ Deficiencies in crew performance evaluation during fire drills, consistent with PSC Code 07125.

→ Deficiencies in fire dampers, consistent with PSC Code 07115.

→ Deficiencies in fire pumps and pipes, consistent with PSC Code 07113.

Additional shortcomings were identified in other categories beyond fire safety, bringing the total to 25 deficiencies.

The vessel was released after 15 days, indicating the deficiencies were rectified to the satisfaction of the inspectors. Two months later, in August 2025, new management company Imelda Shipping took over the vessel, according to Seatrade Maritime.

Eight months after the detention, the engine room caught fire. Two crew members never came home.

The MPA investigation will determine whether the fire was connected to any of the previously identified deficiencies. SwiftAction Intelligence is not asserting a causal link between the Rotterdam detention and the February 2026 fire. But the pattern — a vessel with documented fire safety findings that subsequently experiences a fire with crew casualties — is the pattern that the PSC system and the ISM Code are designed to break. When a vessel accumulates seven fire safety deficiencies in a single inspection, the question is not whether the individual findings were rectified. The question is whether the underlying competency gap that produced them was addressed.

📊 By The Numbers

→ 15 days detained in Rotterdam, June 2025. (Source: Seatrade Maritime)

→ 25 deficiencies found during the inspection. (Source: Seatrade Maritime / Ships & Ports)

→ 9 grounds for detention out of 25 total deficiencies. (Source: Seatrade Maritime / Ships & Ports)

→ 7 fire safety deficiencies including inoperative firefighting equipment, machinery space controls, crew performance evaluation, fire dampers, and fire pumps. (Source: Ships & Ports)

→ 25 Myanmar crew members on board at the time of the fire. (Source: MPA Singapore)

→ Two crew members did not survive. A third was evacuated for medical treatment. (Source: MPA Singapore)

→ Fire safety has been the #1 PSC detention category globally for over a decade. It accounted for the highest number of detainable deficiencies in 2025 across both the Paris MOU and Tokyo MOU regimes. (Source: SAFETY4SEA PSC Focus 2025)

Related Coverage

→ [SwiftAction Intelligence #003: The Tanker Was on His Radar for 36 Minutes. He Disabled the Bridge Alarm. He Did Nothing. A Crew Member Never Came Home. The Captain Got Six Years.]

→ [SwiftAction Intelligence #002: Two Firefighters Entered a Burning Ship Nobody Trained Them to Enter. The NTSB Says It Was Preventable.]

Two crew members lost. Seven fire safety deficiencies flagged eight months earlier. The vessel was detained for 15 days and released. Below: the specific fire safety and ISM failures the Rotterdam inspection exposed, how they connect to PSC deficiency codes that are checked at every port, and what fleet operators can do to close the gap between a rectified finding and verified crew competency.

🔍 The Training Failures the PSC Record Exposed

The MPA investigation will determine the cause of the engine room fire aboard the Mandy. SwiftAction Intelligence is not pre-empting those findings. But the Rotterdam PSC record from June 2025 tells its own story about the state of fire safety readiness on this vessel, and the specific competency gaps that were documented months before two crew members were lost.

Firefighting equipment was inoperative.

Two defects under ready availability of firefighting equipment, consistent with PSC Code 07108, were classified as “inoperative” during the Rotterdam inspection, according to Ships & Ports. This is not a minor paperwork finding. An “inoperative” classification means the equipment was not functional at the time of inspection. In an engine room fire, the ready availability of firefighting equipment is the difference between containment and catastrophe. PSCOs classify this as a detainable deficiency because the consequences of inoperative firefighting equipment in an emergency are immediate and severe.

Machinery space controls were deficient.

A deficiency was recorded under control mechanisms within machinery spaces, consistent with PSC Code 07114. In an engine room emergency, remote shutdown and ventilation controls allow the crew to isolate fuel supplies and close ventilation flaps from outside the space, reducing the fire’s oxygen supply without requiring crew members to enter the burning compartment. When these controls are deficient, the crew’s ability to fight the fire safely is compromised.

Crew performance during fire drills was flagged.

The Rotterdam inspection identified a deficiency under evaluation of crew performance during fire drills, consistent with PSC Code 07125, according to Ships & Ports. This is not an equipment finding. It is a competency finding. It means the inspector observed or assessed the crew’s response during a fire drill and determined it did not meet the required standard. This is the most direct evidence that a training gap existed on board this vessel in the fire safety category.

Fire dampers and fire pumps were deficient.

Additional fire safety deficiencies were recorded under fire dampers, consistent with PSC Code 07115, and fire pumps and pipes, consistent with PSC Code 07113. Fire dampers prevent the spread of fire through ventilation ducts. Fire pumps supply the water that firefighting teams depend on. Both are critical systems in an engine room fire scenario.

Seven fire safety deficiencies in a single inspection is not routine. It indicates a systemic breakdown in fire safety readiness, not an isolated oversight. The vessel was detained for 15 days. The deficiencies were rectified. The vessel was released. Two months later, a new management company took over. Eight months after the detention, the engine room was on fire.

The question the MPA investigation will answer is whether the cause of the February 2026 fire was connected to any of the previously identified deficiencies. The question SwiftAction Intelligence raises is different: when a vessel accumulates seven fire safety deficiencies including inoperative equipment and a crew performance failure, was the underlying competency gap addressed, or was the finding rectified on paper while the gap persisted at sea?

🛡️ How SwiftAction Training Addresses These Gaps

No training program can guarantee that equipment will not fail or that a fire will not occur. But when PSC inspectors flag seven fire safety deficiencies in a single inspection, including a crew performance failure during fire drills, the training system has a specific role: to verify that the crew’s competency on fire safety procedures has been assessed, documented, and evidenced before the next inspection — and before the next emergency.

The following SwiftAction Academy courses address the fire safety and ISM competency gaps relevant to this case. Five map directly to deficiency codes flagged during the Mandy’s Rotterdam detention. Five additional modules address related fire safety and ISM competencies that strengthen overall readiness. Each course produces a completion certificate referencing the specific PSC deficiency code, creating a documented record that the crew was assessed on the exact competency a PSCO will check.

Ready Availability of Fire Fighting Equipment (Code 07108). Two “inoperative” defects were flagged on the Mandy. SwiftAction’s Code 07108 module covers the SOLAS requirements for firefighting equipment readiness, the inspection and testing procedures crew members must follow, and the operational standards for portable and fixed firefighting appliances. Completing this module produces a certificate referencing Code 07108 specifically.

Remote Means of Control in Machinery Spaces (Code 07114). SwiftAction’s Code 07114 module covers the operation of remote shutdown valves, ventilation flap controls, and fuel isolation procedures from outside the engine room. These are the controls that allow a crew to fight an engine room fire without entering the space.

Evaluation of Crew Performance During Fire Drills (Code 07125). This was the competency finding on the Mandy. SwiftAction’s Code 07125 module covers the standards PSCOs use to evaluate crew performance during fire drills, the SOLAS requirements for drill frequency and content, and the documented evidence crew must produce to demonstrate competency. This is the code that bridges equipment readiness and crew capability.

Fire Dampers (Code 07115) and Fire Pumps and Pipes (Code 07113). SwiftAction’s modules under these codes cover the operational testing, maintenance, and inspection requirements for fire containment and suppression systems. Fire dampers prevent the spread of fire through ventilation ducts. Fire pumps supply the water that crews depend on during firefighting operations.

Maintenance of Fire Protection Systems (Code 07124) and Operation of Fire Protection Systems (Code 07123). These modules cover the ISM Code requirements for maintaining and operating the vessel’s fire protection systems, including the documentation that must be available for PSC inspection.

Oil Accumulation in Engine Room (Code 07126). Engine room fires frequently originate from fuel or lubricating oil contact with hot surfaces. SwiftAction’s Code 07126 module covers the SOLAS requirements for engine room cleanliness, oil leak prevention, and the lagging of exhaust pipes and hot surfaces that can serve as ignition sources.

Why this matters for your fleet: The Mandy had seven fire safety deficiencies in a single PSC inspection. The deficiencies were rectified. The vessel was released. The question is whether rectification meant the crew’s competency on fire safety was verified, or whether it meant the equipment was repaired and the paperwork was filed. SwiftAction’s completion certificates reference the specific PSC deficiency code, creating a documented link between the finding, the training, and the crew member’s assessed competency. That link is what turns a PSC rectification from paperwork into evidence.

SwiftAction courses relevant to this incident:

PSC Code - Course - Relevance to Mandy - Basis

07108 - Ready Availability Of Fire Fighting Equip. - Two “inoperative” defects in Rotterdam - Rotterdam Finding

07113 - Fire Pumps And Its Pipes - Fire pumps deficient in Rotterdam - Rotterdam Finding

07114 - Remote Means Of Control Mach’y Spaces - Machinery space controls deficient - Rotterdam Finding

07115 - Fire-Dampers - Fire dampers deficient in Rotterdam - Rotterdam Finding

07125 - Evaluation Crew Performance (Fire Drills) - Crew performance flagged in Rotterdam - Rotterdam Finding

07123 - Operation Of Fire Protection Systems - Operational readiness of fire systems -SwiftAction Recommendation

07124 - Maintenance Of Fire Protection Systems - Maintenance of fire systems -SwiftAction Recommendation

07126 - Oil Accumulation In Engine Room - Engine room fire ignition prevention - SwiftAction Recommendation

15107 - Emergency Preparedness - ISM emergency response procedures - SwiftAction Recommendation

15109 - Maintenance Of The Ship And Equipment - ISM maintenance obligations - SwiftAction Recommendation

👉 Browse all Fire Safety courses: academy.swiftaction.ai/collections/07-fire-safety

👉 Browse all ISM courses: academy.swiftaction.ai/collections/15-ism

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👀 What to Watch

The MPA investigation into the Mandy engine room fire is ongoing. As flag state, Singapore will examine the cause and circumstances of the fire, the condition of fire safety equipment on board, the crew’s response, and whether the vessel’s ISM system was effectively implemented. The findings will determine whether any connection exists between the June 2025 PSC detention and the February 2026 fire.

The change of management between the detention and the fire adds a layer of complexity. Imelda Shipping took over in August 2025, two months after the Rotterdam detention. Whether the new management company was aware of the full scope of the detention findings, whether it conducted its own assessment of fire safety readiness, and whether crew competency on fire safety was re-verified under the new ISM system are all questions the investigation may address.

For fleet operators, the Mandy case raises a systemic question that extends beyond a single vessel. When a ship changes management, the incoming company inherits the vessel’s PSC history but may not inherit the context behind it. A 15-day detention with nine grounds for detention and seven fire safety deficiencies is not a routine finding. It is a signal that the vessel’s fire safety culture required intervention beyond equipment repair. Whether that intervention occurred is the gap the investigation will examine.

Fire safety has been the #1 PSC detention category globally for over a decade. Fleet managers preparing for inspections in any MOU regime can review their crew’s training records against the specific fire safety deficiency codes flagged in this case. If those records do not reference the specific codes PSCOs are checking, the gap that existed on the Mandy may exist on your vessel.

🚨 SwiftAction Signal

Twenty-five deficiencies. Nine grounds for detention. Seven fire safety. Firefighting equipment classified as inoperative. Crew performance during fire drills flagged. The ship was detained for 15 days in Rotterdam. The deficiencies were rectified. The ship was released. A new company took over management. Eight months later, the engine room was on fire off the coast of China. Twenty-five Myanmar crew members were on board. Two of them never came home. A third was evacuated to hospital. The MPA is investigating. Fire safety has been the number one PSC detention category globally for over a decade. A training module on firefighting equipment readiness costs $17. The industry does not have a knowledge problem. It has an action problem.

⚓ The SwiftAction Team SwiftAction Intelligence Is Published Daily. For Partnership Inquiries Contact admin@swiftaction.ai

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📋 SwiftAction Training Resources Referenced in This Article

👉 Fire Safety Modules (Category 07): academy.swiftaction.ai/collections/07-fire-safety

👉 ISM Modules (Category 15): academy.swiftaction.ai/collections/15-ism

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On June 11, 2024, the Liberian-flagged bulk carrier HG PERTH arrived at Newport, Wales, and was boarded by surveyors from the UK Maritime and Coastguard Agency for a port state control inspection under the Paris MOU regime. What they found was not a vessel with one or two items out of place. It was a vessel with fifty-three deficiencies. Ten of those deficiencies were serious enough to constitute grounds for detention. The ship was immediately detained. It did not sail again for thirty-one days.

Nobody died. Nobody was injured. There was no collision, no fire, no grounding. There was just an inspection. And that inspection revealed a vessel where the crew could not demonstrate control of a fire drill, where lifejackets were not as required, where the launching arrangements for survival craft did not function, where fire doors did not meet standards, where personal fire safety equipment was deficient, where ventilators and air pipes were compromised, where the ballast water management system was malfunctioning, where crew sleeping quarters did not meet the Maritime Labour Convention, and where the International Safety Management system, the backbone of every vessel’s operational safety culture, was found to be not as required. Fifty-three findings. Ten grounds for detention. Thirty-one days alongside.

The HG PERTH is a 176-metre, 18,722 GT bulk carrier operated by Shanghai Zhengdong Shipping Co. Vessel databases list her build year variously as 2008 or 2011. She is classified by Bureau Veritas with her ISM Document of Compliance issued by China Classification Society. She was not on a blacklisted flag. She was not classified by a non-IACS society. She was a mainstream commercial vessel. And she could not pass a fire drill.

The HG PERTH was detained in June 2024. The global trends that produced this detention have only worsened since. The PSC detention rate rose to 3.43% in 2025, exceeding the 3% threshold. ISM-related deficiencies remained the most prevalent deficiency category in PSC inspections worldwide. This is not old news. It is a pattern that is accelerating.

📋 In this issue:

• 🔍 The Inspection: 53 Findings in One Visit

• 📊 By The Numbers

• 🔥 The Training Failures the Inspection Exposed

• 🛡️ How SwiftAction Training Addresses These Gaps

• 👀 What to Watch

• 🚨 SwiftAction Signal

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→ ⚓ June 11, 2024: UK Maritime and Coastguard Agency surveyors boarded the bulk carrier HG PERTH (IMO 9497505) at Newport, Wales, for a port state control inspection under the Paris MOU regime. The vessel was immediately detained. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 📋 53 deficiencies were recorded during the inspection, with 10 grounds for detention. The inspection was suspended due to the volume of findings. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 🔥 Fire drills — Lack of control (Code 04109). When PSC officers ordered a fire drill, the crew could not demonstrate competent control of the exercise. This is a detainable deficiency under SOLAS Chapter III. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 🦺 Lifejackets — Not as required (Code 11118). Two separate detainable deficiency entries were recorded for lifejackets, indicating systemic failures in provision, condition, or disposition of lifesaving appliances. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 🚤 Launching arrangements for survival craft — Not as required (Code 11112). The system designed to get the crew off the ship in an emergency did not function to the required standard. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 🚪 Fire doors/openings in fire-resisting divisions — Not as required (Code 07105). Fire containment barriers, the structures designed to prevent fire from spreading between compartments, were deficient. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 🧯 Personal equipment for fire safety — Not as required (Code 07111). The equipment that individual crew members need to fight a fire, including fireman’s outfits and breathing apparatus, was deficient. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 📄 ISM — Not as required (Code 15150). The International Safety Management system, the documented framework that is supposed to ensure every other safety system functions, had failed. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 📅 31 days detained. The HG PERTH was detained on June 11, 2024 and released on July 12, 2024. Thirty-one days of lost revenue, off-hire costs, repair expenses, and reputational damage. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 🏢 Operator: Shanghai Zhengdong Shipping Co. Classification society: Bureau Veritas. ISM Document of Compliance issued by China Classification Society. ISM Safety Management Certificate issued by Bureau Veritas. Flag: Liberia (Paris MOU white list). (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

🔍 The Inspection: 53 Findings in One Visit

On June 11, 2024, UK Maritime and Coastguard Agency surveyors conducted a port state control inspection of the HG PERTH at Newport, Gwent, under the Paris MOU regime, according to the UK MCA monthly detention list for July 2024, published on August 8, 2024.

The HG PERTH is a 176-metre Liberian-flagged bulk carrier, IMO number 9497505, with a gross tonnage of 18,722. Vessel databases list her build year variously as 2008 (FleetMon) or 2011 (VesselFinder, MarineTraffic). She is operated by Shanghai Zhengdong Shipping Co, classified by Bureau Veritas, with her ISM Document of Compliance issued by China Classification Society and her Safety Management Certificate issued by Bureau Veritas.

The inspection recorded fifty-three deficiencies. Ten of those deficiencies were serious enough to constitute grounds for detention. The inspection was suspended, a designation the MCA uses when the volume or severity of findings requires additional time or resources to complete the full assessment.

The ten grounds for detention, as published by the UK MCA, were:

Code - Defective Item - Nature of Defect

18306 - Sleeping room, additional spaces - Not as required

07105 - Fire doors/openings in fire-resisting divisions - Not as required

03108 - Ventilators, air pipes, casings - Not as required

14811 - Ballast Water Management System - Malfunctioning

11118 - Lifejackets incl. provision and disposition - Not as required

11118 - Lifejackets incl. provision and disposition - Not as required

11112 - Launching arrangements for survival craft - Not as required

04109 - Fire drills - Lack of control

15150 - ISM - Not as required

07111 - Personal equipment for fire safety - Not as required

The deficiencies span six of the most critical PSC categories: Emergency Systems (Category 04), Fire Safety (Category 07), Life Saving Appliances (Category 11), MARPOL/Pollution Prevention (Category 14), ISM (Category 15), and Maritime Labour Convention (Category 18). An additional structural category, Load Lines (Category 03), was also represented. When a single inspection produces findings across this many categories, it indicates that the failures are not isolated to one department or one system. They are systemic.

The vessel was detained for thirty-one days, from June 11 to July 12, 2024. During that period, all identified deficiencies had to be rectified to the satisfaction of the MCA before the vessel was permitted to sail. Shanghai Zhengdong Shipping Co has not publicly commented on the detention. The vessel was released on July 12, 2024 after all deficiencies were rectified. For a bulk carrier, thirty-one days of off-hire represents significant commercial losses in addition to the direct costs of rectification, surveyor attendance, and class society involvement.

The HG PERTH had a prior safety incident. In June 2022, a heavy machinery vehicle fell onto the vessel’s cargo deck during offloading operations at Terminal Two, Valparaiso, Chile. The vehicle reportedly was not secured by leading lashes, lost balance, and flipped onto the deck, according to FleetMon reporting. No injuries were reported. The incident, while different in nature from the 2024 PSC detention, points to a pattern of operational and procedural gaps on the same vessel.

📊 By The Numbers

→ 53 total deficiencies recorded in a single port state control inspection, one of the highest single-inspection totals published by the UK MCA in 2024. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 10 grounds for detention, spanning fire safety, lifesaving appliances, emergency systems, ISM, MARPOL, MLC, and structural categories. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 31 days detained at Newport, Wales, from June 11 to July 12, 2024. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 6 categories of PSC deficiency represented in the grounds for detention alone, indicating systemic failure across multiple vessel departments. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 2 separate lifejacket deficiencies recorded as grounds for detention (Code 11118), indicating the problem was not a single missing item but a systemic failure in provision, maintenance, or disposition. (Source: UK MCA Monthly Detention List (July 2024), published August 8, 2024)

→ 9.2% non-compliance for fire drill performance and 9.3% non-compliance for fire door maintenance — the two worst-performing categories in the Paris MOU’s 2023 Concentrated Inspection Campaign on Fire Safety across 3,856 inspections. The HG PERTH had detainable findings in both. (Source: Paris MOU CIC results, as reported by SAFETY4SEA and IIMS)

→ ISM-related deficiencies remained the most prevalent deficiency category in PSC inspections in 2025, according to AMSA’s 2025 Annual PSC Report. DNV’s Q2 2025 detention summary identified ISM as one of the primary reasons vessels are detained. The HG PERTH’s ISM finding (Code 15150) indicates the safety management system failed to prevent or identify the other fifty-two deficiencies before the PSCO did. (Sources: AMSA 2025 PSC Annual Report; DNV Q2 2025 PSC Summary)

→ 3.43% — the global PSC detention rate in 2025, which exceeded the 3% threshold, according to SAFETY4SEA. The detention rate has been rising annually. (Source: SAFETY4SEA PSC Focus 2025)

Related Coverage

→ The Tanker Was on His Radar for 36 Minutes. He Disabled the Bridge Alarm. He Did Nothing. A Crew Member Died. The Captain Got Six Years.

Fifty-three deficiencies is not a bad day. It is a failed system. The crew could not run a fire drill. They could not demonstrate that lifejackets were where they should be. The survival craft launching arrangements did not work. The fire doors were deficient. The personal firefighting equipment was deficient. The ISM system that is designed to catch all of this before a PSCO does had itself failed. Below: the specific training failures behind each finding, the PSC codes that map to each gap, and what fleet managers can do before their next inspection.

🔥 The Training Failures the Inspection Exposed

The HG PERTH’s fifty-three deficiencies describe a vessel where multiple layers of the safety system failed simultaneously. But the training-related findings are the ones that matter most, because they reveal not just broken equipment but a crew that was not competent to use the equipment even if it had been working.

Fire drills — Lack of control.

Code 04109. This is the finding that defines this case. When a PSCO orders a fire drill during a PSC inspection, they are not checking whether the crew has read a manual. They are watching whether the crew can execute a coordinated emergency response under observation. SOLAS Chapter III, Regulation 19 requires every crew member to participate in at least one fire drill per month. If more than 25% of the crew has not participated in a fire drill within the previous month, a drill must be conducted within 24 hours of leaving port. The crew of the HG PERTH could not demonstrate control of this exercise. The PSCO recorded the deficiency as detainable. A vessel that cannot run a fire drill cannot fight a fire.

Crew familiarization with lifejackets — Two separate detainable findings.

Code 11118 was recorded twice as a ground for detention. SOLAS Chapter III requires lifejackets to be provided for every person on board, readily accessible, of approved type, and crew must be trained in their use. Two separate detainable entries for the same code indicates the problem was not one missing lifejacket in one cabin. It suggests a systemic failure in the provision, condition, storage, or crew knowledge related to lifesaving appliances across the vessel. PSCOs check whether crew members know where their lifejackets are, whether they can don them correctly, and whether the lifejackets themselves meet the required standard. A failure on any of these points is a failure of training.

Launching arrangements for survival craft — Not as required.

Code 11112. The davits, winches, falls, and release mechanisms that are supposed to put lifeboats and liferafts into the water did not meet the required standard. SOLAS Chapter III, Regulation 19 requires lifeboats to be launched and manoeuvred at least once every three months. This is not only a maintenance requirement — it is a training requirement. The crew member in charge of each survival craft must have complete knowledge of the craft’s operation and equipment. If the launching arrangements are not functional, or if the crew cannot demonstrate competence in their operation, the vessel is detainable. On the HG PERTH, both the equipment and the competency gap appear to have been present.

Fire doors — Not as required.

Code 07105. Fire doors and openings in fire-resisting divisions are the structural barriers that contain fire within a single compartment and prevent it from spreading to adjacent spaces. The Paris MOU’s 2023 Concentrated Inspection Campaign on Fire Safety found a 9.3% non-compliance rate for fire door maintenance across 3,856 inspections. The HG PERTH fell into that non-compliant category. Fire doors require regular inspection, testing, and crew awareness. If a fire door is jammed open, blocked, corroded, or improperly maintained, the entire fire containment strategy of the vessel fails. This is a maintenance failure, but it is also a training failure: crew must know which doors are fire doors, how they function, what condition they must be in, and how to verify their integrity during rounds.

Personal fire safety equipment — Not as required.

Code 07111. Fireman’s outfits, self-contained breathing apparatus, fire blankets, and other personal protective equipment required under SOLAS Chapter II-2 were found deficient. This equipment is the last line of defense for any crew member who is ordered into a smoke-filled space. If the equipment is not there, not maintained, or not understood by the crew, the fire drill failure (Code 04109) becomes even more dangerous: the crew cannot run the drill, and even if they could, the equipment they would need to fight the fire does not meet the standard.

ISM — Not as required.

Code 15150. The International Safety Management Code requires every vessel to have a documented Safety Management System that ensures safe operation and environmental protection. The ISM finding on the HG PERTH is the capstone of the entire inspection. It means the PSCO concluded that the fifty-two other deficiencies, taken collectively, constituted evidence of a failure or lack of effectiveness of the ISM Code implementation on board. The SMS is the system that is supposed to ensure fire drills happen, lifejackets are inspected, survival craft are tested, fire doors are maintained, and personal safety equipment is in working order. When the PSCO writes Code 15150, they are saying: the system that is supposed to prevent all of these failures has itself failed.

🛡️ How SwiftAction Training Addresses These Gaps

The HG PERTH was not a casualty. Nobody was hurt. But the vessel’s fifty-three deficiencies describe a gap between what the crew was supposed to know and what the crew could demonstrate. That gap is what PSCOs check for at every port. It is what training is designed to close.

The following SwiftAction Academy courses map directly to the detainable deficiencies identified on the HG PERTH. Each course is verified against the SwiftAction Academy catalog (February 2026 edition). Each course produces a completion certificate referencing the specific PSC deficiency code, creating a documented record that the crew was assessed on the exact competency a PSCO will check.

Fire Drills (Code 04109). The HG PERTH’s crew could not demonstrate control of a fire drill. SwiftAction’s Code 04109 module covers fire drill planning and execution under SOLAS Chapter III, Regulation 19, the roles and responsibilities of fire parties, boundary cooling teams, and command personnel, and the standards PSCOs use to assess whether a drill is satisfactory or unsatisfactory.

Crew Familiarization with Emergency Systems (Code 04121). A vessel with two separate lifejacket deficiencies and failed fire drills has a crew that is not familiar with the ship’s emergency systems. SwiftAction’s Code 04121 module covers the SOLAS requirements for crew familiarization, the onboard training obligations under STCW, and the specific items PSCOs assess when testing crew knowledge of emergency procedures.

Lifejackets incl. Provision and Disposition (Code 11118). Two detainable entries for lifejackets on a single inspection. SwiftAction’s Code 11118 module covers SOLAS Chapter III requirements for lifejacket provision, stowage, and maintenance, crew obligations for regular inspection, and the donning procedures PSCOs observe during drills.

Launching Arrangements for Survival Craft (Code 11112). The system designed to put lifeboats in the water did not work. SwiftAction’s Code 11112 module covers SOLAS requirements for survival craft launching, the competency standards for the crew member in charge of each craft, and the quarterly drill and maintenance cycle.

Fire Doors/Openings in Fire-Resisting Divisions (Code 07105). Fire doors on the HG PERTH were deficient. SwiftAction’s Code 07105 module covers SOLAS Chapter II-2 requirements for fire-resisting divisions, the crew’s role in maintaining fire door integrity during daily rounds, and the common deficiencies PSCOs identify.

Personal Equipment for Fire Safety (Code 07111). The crew’s personal firefighting equipment was deficient. SwiftAction’s Code 07111 module covers SOLAS Chapter II-2 requirements for fireman’s outfits, SCBA, and personal protective equipment, including inspection, maintenance, and donning procedures.

Ventilators, Air Pipes, Casings (Code 03108). Structural deficiencies in the vessel’s ventilation and air pipe systems. SwiftAction’s Code 03108 module covers the Load Line Convention requirements for watertight integrity of ventilators and air pipes, and the crew’s maintenance obligations.

ISM (Code 15150). The entire safety management system failed. SwiftAction’s ISM module covers the structure and implementation of the ISM Code, the master’s responsibility, company responsibilities, shipboard operations, emergency preparedness, and the non-conformity reporting process that is supposed to catch failures before a PSCO does.

Ballast Water Management System (Code 14811). The BWMS was malfunctioning. SwiftAction’s Code 14811 module covers the BWM Convention requirements for system operation, maintenance, and crew competency in ballast water management procedures.

Sleeping Room, Additional Spaces (Code 18306). Crew accommodation did not meet MLC requirements. SwiftAction’s Code 18306 module covers the Maritime Labour Convention standards for sleeping room conditions, ventilation, lighting, and the crew’s right to decent living conditions at sea.

Why this matters for your fleet: The HG PERTH was a mainstream bulk carrier on a white-listed flag, classed by a major IACS member. It was not a dark fleet vessel or a blacklisted operator. It was the kind of ship that trades in your port, carries your cargo, and competes for your charters. And it could not pass a fire drill. The difference between the HG PERTH and a clean inspection is whether the crew’s training addressed the exact items the inspector checked, and whether there is a documented record to prove it. SwiftAction’s completion certificates reference the specific PSC deficiency code, creating that documented link between the finding, the training, and the crew member’s assessed competency.

SwiftAction courses relevant to this case:

PSC Code - Relevance

04109: Fire Drills - Crew could not control fire drill

04121: Crew Familiarization with Emergency Systems - Systemic emergency preparedness failure

11118: Lifejackets incl. Provision and Disposition - Two separate detainable lifejacket findings

11112: Launching Arrangements for Survival Craft - Survival craft could not be launched

07105: Fire Doors/Openings in Fire-Resisting Div. - Fire containment barriers deficient

07111: Personal Equipment for Fire Safety - Fireman’s outfit/SCBA deficient

03108: Ventilators, Air Pipes, Casings - Structural watertight integrity compromised

15150: ISM - Safety management system failed

14811: Ballast Water Management System - BWMS malfunctioning

18306: Sleeping Room, Additional Spaces - MLC crew welfare requirements unmet

04110: Abandon Ship Drills - Also relevant: lifejacket + survival craft pattern

👉 Browse all Fire Safety courses: academy.swiftaction.ai/collections/07-fire-safety

👉 Browse all Life Saving Appliances courses: academy.swiftaction.ai/collections/11-life-saving-appliances

👉 Browse all Emergency Systems courses: academy.swiftaction.ai/collections/04-emergency-systems

👉 Browse all ISM courses: academy.swiftaction.ai/collections/15-ism

👉 Try a free course: academy.swiftaction.ai/enroll/3527149?price_id=4454402

👀 What to Watch

The HG PERTH’s detention occurred in June 2024, but its relevance to fleet operators has only increased. The global PSC detention rate rose to 3.43% in 2025, exceeding the 3% threshold, according to SAFETY4SEA’s PSC Focus 2025 analysis. ISM-related deficiencies remained the most prevalent deficiency category in PSC inspections globally in 2025, according to AMSA’s 2025 Annual PSC Report. DNV’s Q2 2025 detention summary identified ISM as one of the primary reasons vessels are detained.

The Paris MOU’s 2023 Concentrated Inspection Campaign on Fire Safety found a 9.2% non-compliance rate for fire drills across 3,856 inspections, and a 9.3% non-compliance rate for fire door maintenance. These were the two worst-performing categories in the entire campaign. The HG PERTH had both. The Paris MOU concluded that lack of crew familiarity with fire drills undermines readiness to respond effectively to fire emergencies. That conclusion is a direct description of what happened on the HG PERTH.

The 2026 Paris MOU and Tokyo MOU Concentrated Inspection Campaign on Cargo Securing is underway. While cargo securing is a different category from the HG PERTH’s fire safety and lifesaving appliance failures, the principle is the same: PSCOs will assess whether the crew can demonstrate competency in the specific area being tested, not just whether the paperwork exists. Fleet managers whose crews have not been trained on the specific deficiency codes PSCOs check will face the same gap that held the HG PERTH at Newport for thirty-one days.

For fleet operators, the HG PERTH case demonstrates that a white-listed flag and a major classification society do not insulate a vessel from detention. The vessel’s flag (Liberia) is on the Paris MOU white list. The classification society (Bureau Veritas) is an IACS member. The ISM Document of Compliance was issued by China Classification Society, also an IACS member. None of that prevented fifty-three deficiencies. The gap was not in the regulatory framework. The gap was in the implementation on board — specifically in the crew’s ability to demonstrate the competencies the regulatory framework requires. Over 90% of global trade moves by sea on vessels like this one. The cargo in the hold was destined for someone’s supply chain. If a fire had started at sea, the crew that failed the drill at Newport would have been the crew fighting it.

🚨 SwiftAction Signal

Fifty-three deficiencies in one inspection. The crew could not run a fire drill. There were two separate detainable findings for lifejackets. The survival craft launching arrangements did not work. Fire doors were deficient. The personal firefighting equipment was deficient. The ISM system that was supposed to catch all of this had failed. This was not a dark fleet vessel hiding from inspectors. This was a Liberian-flagged bulk carrier, Bureau Veritas class, with IACS-issued certificates. She arrived at a UK port and could not demonstrate that her crew knew how to abandon ship or fight a fire.

Nobody died on the HG PERTH. That is not a credit to the operator. It is luck. The next fire drill that fails may not happen during a PSC inspection at a calm berth in Wales. It may happen during an actual fire, at sea, at night, in weather. And if it does, the crew that could not demonstrate control of a drill under observation will be the crew that has to fight the fire for real.

Thirty-one days. Seven hundred and forty-four hours alongside. A fire drill training module costs less than one hour of off-hire. The industry does not have a knowledge problem. It has an action problem.

⚓ The SwiftAction Team SwiftAction Intelligence Is Published Daily. For Partnership Inquiries Contact admin@swiftaction.ai

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📋 SwiftAction Training Resources Referenced in This Article

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👉 Life Saving Appliances Modules (Category 11): academy.swiftaction.ai/collections/11-life-saving-appliances

👉 Emergency Systems Modules (Category 04): academy.swiftaction.ai/collections/04-emergency-systems

👉 ISM Modules (Category 15): academy.swiftaction.ai/collections/15-ism

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Australia detained 237 ships in 2025 and the number one reason was the same as it has been for over a decade: ISM Code failures. The Australian Maritime Safety Authority’s 2025 annual PSC report reveals a detention rate of 4.8%, a deficiency rate of 2.73 per inspection, and a system where ships keep arriving with the same problems year after year. Australia exports roughly 900 million tonnes of iron ore alone each year. Every detained bulker at Newcastle or Hay Point delays the raw materials that end up in the steel in your car, the concrete in your building, and the electricity in your home. Behind every ISM deficiency that triggers a detention is a crew member who could not demonstrate a competency that a properly structured training system would have given them.

📋 In this issue:

• 🔥 The Incident

• 📊 By The Numbers

• 🔍 The Training Failure

• ✅ What Should Have Happened

• 👀 What to Watch

• 🚨 SwiftAction Signal

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→ 237 Ships Detained Across Australian Ports in 2025

→ Detention Rate Fell to 4.8%, Below 10-Year Average of 5.7%

→ 2,768 PSC Inspections Conducted, Up 22.26% From 2024

→ Deficiency Rate of 2.73 Per Inspection, Still Above 10-Year Average of 2.29

→ Bulk Carriers Accounted for 4,563 Deficiency Cases

→ ISM Was the Top Detainable Deficiency Category, Consistent With Every Year Since at Least 2010

Source: AMSA Annual PSC Report 2025

🔥 The Incident

AMSA released its 2025 annual port state control report in March 2026, and the numbers reveal a pattern that the maritime training industry cannot ignore, according to SAFETY4SEA.

AMSA conducted 2,768 initial PSC inspections in 2025, a 22.26% increase from 2,264 in 2024. The 237 total detentions span PSC inspections of foreign-flagged vessels, domestic commercial vessel (DCV) inspections, and flag state inspections. The 4.8% detention rate and 2.73 deficiency rate apply to PSC inspections of foreign-flagged vessels specifically. The PSC detention rate fell from 5.9% the previous year and dropped below the 10-year rolling average of 5.7%. But deficiencies per inspection rose to 2.73, up from 2.63 in 2024, and well above the 10-year rolling average of 2.29, according to AMSA’s report via SAFETY4SEA. Ships are arriving at Australian ports with more problems. AMSA is finding them. And the same categories of failure that have dominated for over a decade are still at the top of the list.

ISM Code deficiencies were once again the most prevalent category in the 2025 report. In 2024, ISM accounted for 27.57% of all detainable deficiencies, up from 27.0% in 2023, 29.1% in 2022, and 24% in 2021, according to AMSA reports via MaritimeCyprus and AMSA’s 2022 inspection report. Fire safety was the second-highest category at 15.14%. Water and weathertight conditions came in at 12.97%, a figure that had itself doubled from 6.4% in 2022. Lifesaving appliances rounded out the top four at 11.35%.

MARPOL Annex I detainable deficiencies nearly doubled, rising from 4.9% in 2023 to 8.11% in 2024, according to AMSA data reported by MaritimeCyprus. The Bahamas Maritime Authority’s October 2025 information notice on recurring PSC deficiencies identifies the six most common MARPOL Annex I failures: crew unable to demonstrate correct operation of the oily water separator, crew unable to conduct the 15ppm oil content monitor function test, previous oil record books not available for the required three-year retention period, oil record books missing entries for weekly soundings of oil residues in tanks, incinerator refractory deterioration, and unauthorized modifications to the OWS and OCM. Every one of these is a crew competence or record-keeping failure, not an equipment malfunction.

Bulk carriers accounted for 4,563 deficiency cases in 2025, substantially higher than any other ship type, according to SAFETY4SEA. Bulk carriers represented 51.8% of ship arrivals and 58% of all inspections in Australia.

For Australian-flagged domestic commercial vessels (DCVs), detainable deficiencies surged from 140 in 2024 to 198 in 2025, a 41.4% increase, according to SAFETY4SEA. In 2023, the top three detainable deficiency categories for DCVs were structural conditions at 22.3% (49 cases), safety management system failures at 19.6% (43 cases), and fire safety at 18.2% (40 cases), according to AMSA’s 2023 PSC report via MaritimeCyprus.

AMSA Is Banning Ships, Not Just Detaining Them.

AMSA has used its powers under the Navigation Act 2012 aggressively. Under Australian law, AMSA can ban vessels for up to 24 months, according to legal analysis by Holding Redlich.

In March 2026, the Liberian-flagged bulk carrier Ocean Bright was detained in Newcastle after eight crew members had not been paid for two months. Inspectors found US$46,334 in unpaid wages, 18 deficiencies, and four detainable deficiencies, according to Marine Insight and MarineLink. The vessel was banned from Australian waters until September 4, 2026.

In May 2024, AMSA issued a 180-day ban to the Indian-flagged bulk carrier Darya Shaan after inspectors found 19 deficiencies at Port of Melbourne, including defective main engine control and monitoring systems, faulty engine room alarms, and defective starting arrangements for two generators, according to MarineLink. AMSA Executive Director of Operations Michael Drake said the operator, Anglo-Eastern Ship Management (India), had been notified of “serious safety concerns” before the vessel arrived in Australia.

In August 2023, AMSA banned the Liberian-flagged bulk carrier MSXT Emily for one year after discovering US$77,000 in unpaid wages at the Port of Hay Point. Inspectors found forged employment agreement signatures and evidence that seafarers had been coerced into signing new contracts with lower salaries, according to MarineLink. AMSA’s 2018 report referenced a similar case with the Thorco Luna, which was banned after AMSA found that “the master and crew were not familiar with essential shipboard procedures relating to the safety of the ship over three separate inspections,” according to IMEC Technologies.

In March 2025, Universal Shipping Alliance, owner of the Liberian-flagged bulk carrier KMAX Leader, was fined A$63,000 by Gladstone Magistrates Court for failing to comply with an AMSA written direction after the vessel was disabled at the Port of Gladstone during an approaching cyclone season, according to Offshore Energy.

📊 By The Numbers

→ ISM Code: 27.57% of All Detainable Deficiencies (Up From 24% in 2021)

→ Fire Safety: 15.14% (Second Highest, Consistent Year Over Year)

→ Water/Weathertight Conditions: 12.97% (Doubled From 6.4% in 2022)

→ Lifesaving Appliances: 11.35%

→ MARPOL Annex I: 8.11% (Nearly Doubled From 4.9% in 2023)

→ AMSA Detention Rate (2025): 4.8% vs. Tokyo MOU Regional Average (2024): 3.71%

→ DCV Detainable Deficiencies Surged 41.4%: 140 → 198 (2024 to 2025)

Sources: AMSA Annual PSC Reports 2024-2025; Tokyo MOU Annual Report 2024

The deficiency categories that drive AMSA detentions have not changed in over a decade. How a single failed fire detector becomes two detainable deficiencies, why the ISM detention can only be closed after a days-long external audit, and which specific deficiency codes every vessel calling on Australian ports should train against before arrival, is below.

🔍 The Training Failure

The data from AMSA’s 2025 report is not telling operators something new. It is telling them the same thing it has told them every year since at least 2010: ISM failures drive detentions in Australian waters, according to IMEC Technologies referencing AMSA’s historical reports. The category has not changed. The percentage has barely moved. The ships keep failing the same inspections.

ISM detainable deficiencies are not hardware problems. They are competency problems. When AMSA issues an ISM-related detention, it means the port state control officer found evidence that the company’s safety management system is not effectively implemented onboard. The most common ISM detention triggers in Australia are shipboard operations and maintenance failures, followed by emergency preparedness gaps, according to AMSA’s published data via SAFETY4SEA. In 2024, AMSA specifically concentrated enforcement on planned maintenance requirements under the ISM Code, “spurred by incidents where a lack of proper maintenance, particularly of main engines and power generation systems, resulted in unsafe conditions or operational failures,” according to AMSA’s 2024 annual report.

Here is how ISM detentions actually happen in practice, according to PSC deficiency analysis by Capt. Rajeev Jassal of MySeaTime and DNV’s Q2 2025 PSC summary:

A single fire detector in accommodation is found not working during inspection. One detector is a Code 17 deficiency under deficiency code 07106 (Fire Detection and Alarm System), which must be corrected before departure. Two or more detectors not working can become a detainable deficiency at the professional judgment of the PSCO. But it does not stop there. Multiple non-functional fire detectors indicate that the weekly testing required under the SMS has not been performed. The PSCO then issues a second detainable deficiency, this one under the ISM Code, because the failed weekly tests prove the safety management system is not being followed onboard. One observation. Two detainable deficiencies. And the ISM detention can only be cleared after an external ISM audit conducted by the flag state or classification society on behalf of the flag. That audit can take days to arrange. The ship does not sail until it is complete.

This cascade is the mechanism behind the 27.57% ISM share. It is not one catastrophic failure per ship. It is dozens of small competency gaps across the fleet. A crew member who cannot demonstrate a procedure. A test log that shows no record of the weekly test being conducted. A maintenance record that does not match what the equipment shows. Each gap, individually, might be a minor deficiency. Combined, they tell the PSCO that the safety management system exists on paper but is not being lived onboard. That conclusion triggers the ISM detention.

The MARPOL Annex I doubling follows the same pattern. The Bahamas Maritime Authority’s six most common MARPOL Annex I deficiencies are all competency or record-keeping failures. Crew who cannot operate the oily water separator were never trained on its specific make and model. Crew who cannot conduct the 15ppm oil content monitor function test have never been walked through the procedure. Oil record books with missing entries reflect a crew that does not understand what entries are required or when. Unauthorized modifications to the OWS and OCM suggest a crew that does not understand the regulatory implications of what they are changing. None of these require new equipment. They require trained operators.

Australia’s 4.8% detention rate is 29% higher than the Tokyo MOU regional average of 3.71% in 2024, according to the Tokyo MOU Annual Report via MaritimeCyprus. Ships that pass inspection in other Tokyo MOU member states are being detained in Australia because AMSA tests crew competence, not just equipment condition. The under-performing ships in the Tokyo MOU region nearly doubled in 2024, according to IIMS, and AMSA feeds into that same regional risk profiling system. Vessels with detention histories anywhere in the region face higher scrutiny when they arrive in Australian waters.

✅ What Should Have Happened

No training program can guarantee that an individual will follow procedures they choose to ignore. But the AMSA data is not describing willful non-compliance. It is describing crews who were never given the competency in the first place.

The top five AMSA detainable deficiency categories, ISM, fire safety, water/weathertight, lifesaving appliances, and MARPOL Annex I, have not changed in over a decade. Each one maps to specific competency requirements under STCW and the ISM Code. Each one has corresponding PSC deficiency codes. And each one is addressable through targeted, competency-based training completed and documented before the vessel enters Australian waters.

The crew member who could not demonstrate oily water separator operation needed Code 14104 (Oil Filtering Equipment) training covering OWS and OCM operation, alarms, maintenance, and testing. The crew member who could not conduct the oil content monitor function test needed Code 14101 (Control of Discharge) training covering operational limits, monitoring, and record-keeping. The fire detection system that had not been tested needed a crew trained under Code 07106 (Fire Detection and Alarm System) to understand the weekly testing protocol and record it correctly. The engine room alarms that were defective on the Darya Shaan needed engineers trained under Code 13101 (Propulsion Main Engine) and Code 13102 (Auxiliary Engine) to identify and report critical failures before they accumulated to 19 deficiencies in a single inspection.

SwiftAction built the AMSA Repeat Deficiency Elimination System specifically for vessels calling on Australian ports. The bundle contains 24 courses mapped directly to the deficiency codes that drive AMSA detentions. Here is how it maps to the data in this article:

ISM Code (27.57% of AMSA detainable deficiencies): Code 15106 (ISM Code Shipboard Operations) and Code 15150 (ISM Code Compliance) address the two most common ISM detention triggers: shipboard operations and maintenance failures, and safety management system implementation gaps.

Fire Safety (15.14% of AMSA detainable deficiencies): Eight courses cover the fire safety deficiency spectrum: Code 07105 (Fire Doors), Code 07106 (Fire Detection and Alarm System), Code 07108 (Ready Availability of Fire Fighting Equipment), Code 07110 (Fire Fighting Equipment and Appliances), Code 07113 (Fire Pumps), Code 07115 (Fire Dampers), Code 07123 (Operation of Fire Protection Systems), and Code 07124 (Maintenance of Fire Protection Systems). Code 07106, the exact deficiency code in the ISM cascade example above, is included free.

MARPOL Annex I (8.11% of AMSA detainable deficiencies, doubled in one year): Code 14104 (Oil Filtering Equipment) directly addresses the top MARPOL Annex I failure: crew unable to demonstrate OWS and OCM operation. Code 14101 (Control of Discharge) covers the record-keeping and operational limits behind the remaining MARPOL Annex I deficiency findings.

Structural Conditions (top DCV detainable deficiency category at 22.3%): Code 02106 (Hull Damage Impairing Seaworthiness), Code 02108 (Electrical Installations), Code 02112 (Hull Corrosion), and Code 02117 (Decks Corrosion) address the structural deficiency categories that accounted for 49 detainable deficiency cases on DCVs in 2023.

Propulsion and Auxiliary Machinery (Darya Shaan’s 19 deficiencies): Code 13101 (Propulsion Main Engine), Code 13102 (Auxiliary Engine), Code 13104 (Bilge Pumping Arrangements), Code 13108 (Operation of Machinery), and Code 13110 (Precautions Against Electrical Hazards) cover the engine room deficiency categories consistent with the findings reported on the Darya Shaan.

The bundle costs $199 for all 24 courses. Individual courses are $17 each, and Code 07106 is included free. A single day of detention at an Australian commodity port costs the shipowner more than the entire bundle by an order of magnitude.

Every course produces a completion record referenced to the specific PSC deficiency code. That record is the documented evidence that the crew was trained on the exact procedure the AMSA inspector will test. It sits in the ship’s training files at the time of inspection. It is the difference between a clean walkthrough and a detention that triggers an emergency external ISM audit, days of lost revenue, and potentially a ban from Australian waters for up to 24 months.

Start with Code 07106 (Fire Detection and Alarm System). It is free. No credit card required. It covers the exact deficiency described in the ISM cascade example in this article. Complete it, and see what documented competency evidence looks like before buying the full bundle at academy.swiftaction.ai.

👀 What to Watch

AMSA’s enforcement trajectory. The detention rate fell to 4.8%, but deficiencies per inspection rose. AMSA is getting more selective about which ships to detain, not more lenient. The 41.4% surge in DCV detainable deficiencies shows the regulator is intensifying focus on serious findings. Operators should expect the 2026 inspection cycle to continue this trend.

MARPOL Annex I enforcement escalation. The near-doubling from 4.9% to 8.11% signals a specific enforcement shift. If this trend continues into the 2025 data, MARPOL Annex I will join ISM and fire safety as a top-three detention driver in Australian waters. OWS operation (Code 14104), OCM function tests, and oil record book accuracy will be tested.

Tokyo MOU under-performing ships. The 2024 Tokyo MOU report found under-performing ships nearly doubled year-over-year. AMSA is a Tokyo MOU member state. Ships with detention histories in other Tokyo MOU ports face higher scrutiny on arrival in Australia.

AMSA vessel bans. The pattern from Ocean Bright (March 2026), Darya Shaan (May 2024), and MSXT Emily (August 2023) shows AMSA escalating from detention to bans of 90 days to one year. Operators with outstanding deficiency close-out items should treat their next Australian port call as high-risk. Pre-arrival crew training mapped to the specific outstanding deficiency codes is the most direct way to reduce inspection risk.

🚨 SwiftAction Signal

AMSA detained 237 ships in 2025 and ISM topped the list for over a decade running. The detention rate went down. The deficiency rate went up. MARPOL Annex I detainable deficiencies doubled in a single year. Crew members could not operate the oily water separator. Fire detection weekly tests were not recorded. Oil record books had gaps. Engine defects were not reported. Australia is banning ships that would sail freely in other Asia-Pacific ports, and the iron ore, coal, and LNG that move through these ports build the infrastructure every person depends on. The industry does not have a knowledge problem. It knows exactly which deficiency codes drive detentions. It knows exactly which competencies PSCOs test.

Twenty-four training modules mapped to those exact codes cost $199. A single day of detention costs more. The free Code 07106 module takes less time than reading this article. The gap is not money. The gap is action.

⚓ The SwiftAction Team

SwiftAction Intelligence Is Published Daily.

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On March 10, 2025, the container ship Solong collided with the anchored oil tanker Stena Immaculate in the North Sea, 14 nautical miles northeast of Spurn Head at the entrance to the Humber Estuary. The Solong was travelling at approximately 16 knots. The Stena Immaculate was carrying 220,204.5 barrels of aviation fuel for the United States Air Force. The collision breached the tanker’s No.7 port cargo tank. Aviation fuel spilled into the sea and onto Solong’s bow. The heat from the impact ignited it. Both vessels caught fire. Both crews abandoned ship. Able seaman Mark Angelo Pernia, 38, a Filipino father of one with a second child on the way, was working on Solong’s bow at the time of impact. His body was never recovered. On February 2, 2026, following a three-week trial at the Old Bailey, Captain Vladimir Motin, 59, was found guilty of gross negligence manslaughter. He was sentenced to six years in prison. The judge said he had fallen prey to his own complacency and arrogance.

📋 In this issue:

• ⚖️ The Verdict: Guilty at the Old Bailey

• 🔥 The Collision: 36 Minutes of Nothing

• 📊 By The Numbers

• 🔍 The Training Failures the Court Exposed

• 🛡️ How SwiftAction Training Addresses These Gaps

• 👀 What to Watch

• 🚨 SwiftAction Signal

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→ ⚓ March 10, 2025: Container ship Solong collided with anchored oil tanker Stena Immaculate at approximately 16 knots, 14 nautical miles NE of Spurn Head, Humber Estuary. (Source: MAIB Interim Report, April 2025)

→ 📡 36 minutes: The Stena Immaculate was visible on Solong’s radar display for 36 minutes before impact. The prosecution stated that Motin did nothing: no course change, no speed reduction, no alarm, no crash stop. (Source: GB News, February 2, 2026)

→ 🔇 BNWAS disabled: The Bridge Navigation Watch Alert System, designed to ensure someone is physically on the bridge and awake, had been switched off. Motin was the sole watchkeeper from 0700. Neither vessel had a dedicated lookout. (Source: GB News, Reuters, February 2, 2026)

→ ☠️ Mark Angelo Pernia, 38, Filipino national, was working on Solong’s bow at the time of impact. He was killed instantly in the fire. His body has never been recovered. His wife was seven months pregnant. Their second child was born two months after his death. He never met them. (Source: GB News, Reuters, February 2, 2026)

→ ⚖️ Guilty: On February 2, 2026, following a three-week trial at the Old Bailey, a jury deliberated for eight hours and found Captain Vladimir Motin, 59, guilty of gross negligence manslaughter. He was sentenced to six years in prison. (Source: Bridlington Echo, GB News, Reuters, February 2, 2026)

→ 🔍 PSC deficiencies flagged: In 2024, months before the collision, the Solong was flagged during a port state control inspection with multiple outstanding issues including an emergency steering compass not readable, inadequate alarms, poorly maintained survival craft, and fire door defects, according to publicly available PSC records reported by multiple outlets. Ernst Russ stated all issues had been rectified. (Source: Publicly available PSC records, as reported in multiple outlets including gCaptain and IMarEST)

⚖️ The Verdict: Guilty at the Old Bailey

On February 2, 2026, following a three-week trial at London’s Central Criminal Court, a jury deliberated for eight hours and found Captain Vladimir Motin guilty of gross negligence manslaughter, according to reporting by Reuters, GB News, and the Bridlington Echo.

Motin, 59, a Russian national from St Petersburg, had captained the Solong for 15 years. He showed no emotion as the verdict was read. He was remanded in custody and sentenced to six years in prison.

Justice Andrew Baker said Motin had fallen prey to his own complacency and arrogance, according to Human Rights at Sea’s reporting on February 15, 2026. Prosecutor Michael Gregory described the death of Mark Pernia as “a tragic, and entirely avoidable death of a member of crew caused by truly, exceptionally bad negligence,” as reported by the News Express.

Detective Chief Superintendent Craig Nicholson of Humberside Police described the collision as a “simple, senseless tragedy” and said it was “a miracle that there weren’t more fatalities or serious injuries,” according to GB News.

Mark Angelo Pernia was 38 years old. He was a Filipino national, married, with a five-year-old child. His wife was seven months pregnant at the time of the collision. Their second child was born two months after his death. According to Reuters, Pernia’s wife lives in a remote area of the Philippines. His body was never recovered.

🔥 The Collision: 36 Minutes of Nothing

The Portugal-registered container ship Solong, a 130-metre feeder vessel operated by Ernst Russ AG, departed Grangemouth, Scotland, on the evening of March 9, 2025, bound for Rotterdam. The vessel was on a fixed trade route in the North Sea it had used many times before.

The master remained on the bridge until shortly before 2300, then handed the watch to the second officer and retired to rest, according to the MAIB interim report published in April 2025.

At approximately 0130 on March 10, Solong passed the Longstone Lighthouse and altered course to approximately 150 degrees. The vessel maintained this heading with only a minor deviation at 0345.

At 0700, Captain Motin returned to the bridge as the sole watchkeeper.

The visibility in the area was patchy, ranging between 0.25 and 2.0 nautical miles, according to the MAIB interim report. Neither Solong nor the anchored Stena Immaculate had a dedicated lookout on the bridge.

The US-registered oil/chemical tanker Stena Immaculate, a 183-metre, 49,729 DWT vessel managed by Crowley Maritime and chartered by the US military, had been directed to anchor approximately 5 nautical miles north of the Humber light float on March 9. It was carrying 220,204.5 barrels of aviation fuel, bound for Killingholme. There were eight other vessels anchored in the same area.

According to the prosecution’s case as reported by GB News on February 2, 2026, the Stena Immaculate was visible on Solong’s radar display for 36 minutes before impact. During that time, Motin made no course correction, no speed reduction, sounded no alarm, and did not initiate a crash stop.

The Bridge Navigation Watch Alert System, designed to ensure someone is physically present and awake on the bridge, had been switched off, as reported by GB News and Reuters. The Solong’s black box showed no course or speed adjustments before the collision, according to the CPS.

Audio recordings from the Solong’s bridge control room were played to the jury. An hour before the collision, men could be heard speaking calmly in Russian about the price of cigarettes. Then a Russian folk song was heard, an apparent phone ringtone which went unanswered. As the Solong approached the anchored tanker, no conversation could be heard on the bridge at all, according to the News Express.

At 0947, Solong collided with the port side of the anchored Stena Immaculate at approximately 16 knots. A full minute elapsed before Motin was heard to react, according to GB News.

The collision breached Stena Immaculate’s No.7 port cargo tank. Aviation fuel spilled into the sea and onto Solong’s bow. The heat from the impact ignited the fuel. Fire spread to containers aboard Solong. Both crews abandoned ship to lifeboats and were recovered by local boats and emergency responders coordinated by His Majesty’s Coastguard, according to the MAIB interim report.

Motin’s defense argued he attempted to take the Solong off autopilot and change course, but was unsuccessful, according to Reuters reporting on January 14, 2026. The prosecution maintained he did “absolutely nothing.”

After being brought ashore in Grimsby, Motin messaged his wife on WhatsApp saying he would be “guilty,” according to GB News. His wife responded telling him to think of an alibi and to say he had not seen the other vessel on the ship’s equipment. The prosecution said these messages undermined his credibility.

Motin was arrested on March 14, 2025, and charged with gross negligence manslaughter.

Crowley Maritime, the Stena Immaculate’s manager, stated that the vessel was operating in compliance with applicable watch-standing safety regulations and that its 23 mariners acted with bravery and operational focus, limiting the fire to one of the tanker’s 16 cargo holds, according to gCaptain’s reporting on April 3, 2025.

Burnt material and plastic pellets, also known as nurdles, washed up along the UK’s east coast in the days following the collision, raising environmental concerns, according to MaritimeCyprus. The Solong burned for eight days following the collision, according to DCS Nicholson of Humberside Police as reported by GB News.

📊 By The Numbers

→ 2024: A port state control inspection flagged the Solong with multiple outstanding issues, including emergency steering compass not readable, inadequate alarms, poorly maintained survival craft, and fire door defects. Ernst Russ stated all issues had been rectified. (Source: Publicly available PSC records, as reported by multiple outlets)

→ 220,204.5 barrels of aviation fuel aboard the Stena Immaculate, chartered by the United States Air Force. (Source: MAIB Interim Report)

→ 0.25 to 2.0 nautical miles visibility, patchy, at the time of the collision. Neither vessel had a dedicated lookout on the bridge. (Source: MAIB Interim Report)

→ 15.2 knots speed at the point of impact, per the prosecution. No course or speed change was recorded on the black box before the collision. (Source: GB News, CPS)

→ One minute elapsed between the collision and Motin’s first audible reaction on the bridge recording. (Source: GB News, February 2, 2026)

→ Six years prison sentence for Captain Motin. The judge cited complacency and arrogance. (Source: Human Rights at Sea, February 15, 2026)

→ Safety of navigation deficiencies (Category 10) accounted for 12% of all PSC detentions globally in 2025. The Solong’s watchkeeping failures fall squarely within this category. (Source: SAFETY4SEA PSC Focus 2025)

Related Coverage

→ Two Firefighters Died on a Ship Nobody Trained Them to Enter. The NTSB Says It Was Preventable.

The jury deliberated for eight hours. The captain was found guilty. But the court exposed failures that go far beyond one man on one bridge. Below: the specific watchkeeping, fatigue, and bridge resource management failures that training is designed to prevent, how these failures connect to PSC deficiency codes that are checked at every port, and what the Solong’s own PSC record reveals about the systemic gap between inspection findings and operational competency.

🔍 The Training Failures the Court Exposed

The prosecution’s case against Motin rested on gross negligence. But the failures exposed during the three-week trial describe a competency collapse that the maritime training system is designed to prevent.

No dedicated lookout in restricted visibility.

COLREGs Rule 5 requires that every vessel maintain a proper lookout at all times by sight and hearing, as well as by all available means appropriate to the prevailing circumstances. In visibility ranging between 0.25 and 2.0 nautical miles, the requirement for a dedicated lookout is not discretionary. Neither vessel had one, according to the MAIB interim report. Motin was alone on the bridge. The MAIB is investigating whether manning and fatigue management contributed to this failure.

This is not an unusual finding. The MAIB’s Chief Inspector of Marine Accidents highlighted the Solong/Stena Immaculate collision in the opening remarks of Safety Digest 1/2025, stating that it appeared to be “yet another collision that should not have happened” and emphasising that a good lookout is key to preventing collisions, according to IIMS reporting.

The BNWAS was deliberately disabled.

The Bridge Navigation Watch Alert System exists for one purpose: to confirm that a watchkeeper is present, alert, and responsive. If the system detects no activity on the bridge within a set period, it triggers escalating alarms, first on the bridge, then to the master’s cabin, then to the officer of the watch. Motin switched it off, according to GB News and Reuters, leaving himself as the sole barrier between a 16-knot vessel and everything in its path.

The prosecutor stated that disabling the BNWAS left Motin “alone to be on watch as the eyes and ears of the ship,” according to the CPS. This failure falls directly under PSC Code 10138 (Bridge Navigation Watch Alarm System) and the broader Category 10 (Safety of Navigation), which accounted for 12% of all PSC detentions globally in 2025.

36 minutes of radar contact with no response.

The Stena Immaculate appeared on Solong’s radar 36 minutes before the collision. The vessel was anchored. It was not moving. It was transmitting AIS. Motin took no action. He did not alter course, reduce speed, sound the fog signal, alert the crew, or initiate a crash stop. The black box confirmed no navigational inputs were made before impact.

This represents a fundamental failure of radar watchkeeping, ARPA use, and collision avoidance, all of which are STCW competency requirements and are tested during PSC inspections under Safety of Navigation codes.

The PSC record that preceded the collision.

In 2024, months before the collision, the Solong was flagged during a port state control inspection with multiple outstanding issues, according to publicly available PSC records reported by multiple outlets including gCaptain and IMarEST. These included an emergency steering compass that was not readable, inadequate alarms, poorly maintained survival craft, and fire door defects. Ernst Russ stated that all identified safety issues had been rectified. Similar issues had been reported in previous inspections.

These were not obscure technical findings. Inadequate alarms and fire door deficiencies are among the most common PSC detention drivers globally. A vessel that accumulates these findings, rectifies them to satisfy the inspector, and then continues to operate with its bridge alarm system deliberately disabled is exhibiting exactly the pattern that ISM audits and crew competency verification are designed to catch.

The MAIB investigation is ongoing. The final report will examine navigation and watchkeeping practices, manning and fatigue management, vessel maintenance, the use of the offshore anchorage, and environmental conditions. It is expected in 2026.

🛡️ How SwiftAction Training Addresses These Gaps

The Solong/Stena Immaculate collision involved deliberate decisions by an experienced master, including disabling the BNWAS and operating as sole watchkeeper in restricted visibility. No training program can guarantee that an individual will follow procedures they choose to ignore. But the systemic failures this incident exposed, the same failures PSCOs check for at every port, are exactly the gaps that structured, code-specific training is designed to close before they reach a courtroom.

The following SwiftAction Academy courses map directly to the failures identified in this case. Each course produces a completion certificate referencing the specific PSC deficiency code, creating a documented record that the crew was assessed on the exact competency a PSCO will check.

Bridge Navigation Watch Alarm System (Code 10138). The BNWAS was disabled on the Solong. SwiftAction’s Code 10138 module covers the operational requirements for BNWAS under SOLAS V/19.2.5.2, the consequences of disabling bridge watchkeeping alarm systems, and the master’s responsibility to ensure the system functions as designed. PSCOs routinely verify BNWAS functionality during inspections. Completing this module produces a certificate referencing Code 10138 specifically.

Radar (Code 10103) and Automatic Radar Plotting Aid (Code 10107). The Stena Immaculate was visible on Solong’s radar for 36 minutes. No action was taken. SwiftAction’s Code 10103 and 10107 modules cover radar watchkeeping obligations, ARPA target tracking, risk of collision assessment under COLREGs Rule 7, and the OOW’s responsibility to act on radar information in restricted visibility.

Voyage or Passage Plan (Code 10127) and Monitoring of Voyage or Passage Plan (Code 10135). The Solong was on a fixed route through an active anchorage area. SwiftAction’s Code 10127 and 10135 modules cover SOLAS Chapter V voyage planning requirements, the obligation to monitor progress against the plan, and the procedures for identifying and responding to developing hazards, including anchored vessels.

Bridge Operation (Code 10133) and Use of the Automatic Pilot (Code 10125). Motin’s defense argued he attempted to take the Solong off autopilot but was unsuccessful. SwiftAction’s Code 10133 module covers bridge resource management, watchkeeping standards in restricted visibility, and the requirement to post a dedicated lookout under COLREGs Rule 5. Code 10125 covers autopilot operational requirements, including manual override capability and transition procedures.

Masters Responsibility and Authority (Code 15104) and Resources and Personnel (Code 15105). The MAIB is investigating fatigue management and manning. SwiftAction’s ISM modules under Codes 15104 and 15105 cover the master’s obligations to ensure adequate watchkeeping, the company’s obligations to provide sufficient manning, and the procedures for reporting when safe watch conditions cannot be maintained. Whether fatigue contributed to this collision is a question the MAIB will answer. Whether your fleet’s crew has been trained on these ISM requirements is a question a PSCO can ask at any time.

Why this matters for your fleet: The Solong had PSC deficiencies flagged in 2024, according to publicly available inspection records. The operator stated they were rectified. Months later, the vessel’s bridge alarm was disabled and no lookout was posted. Rectifying a finding on paper is not the same as verifying that the crew understood and internalised the competency. SwiftAction’s completion certificates reference the specific PSC deficiency code, creating a documented link between the finding, the training, and the crew member’s assessed competency. That link is what turns a PSC rectification from paperwork into evidence.

SwiftAction courses relevant to this incident:

PSC Code: Course - Relevance

10138: Bridge Nav. Watch Alarm System (BNWAS) - BNWAS deliberately disabled

10103: Radar - Stena visible on radar 36 min, no action

10107: Automatic Radar Plotting Aid (ARPA) - Collision risk not assessed

10127: Voyage Or Passage Plan - Route through active anchorage

10135: Monitoring Of Voyage Or Passage Plan - No monitoring of developing risk

10133: Bridge Operation - Sole watchkeeper, no lookout

10125: Use Of The Automatic Pilot - Failed autopilot disengage

15104: Masters Responsibility And Authority - Master failed watchkeeping duties

15105: Resources And Personnel - Manning/fatigue under investigation

07105: Fire Doors/Openings in Fire-Resisting Div. - Fire door defects in 2024 PSC inspection

👉 Browse all Safety of Navigation courses: academy.swiftaction.ai/collections/10-safety-of-navigation

👉 Browse all ISM courses: academy.swiftaction.ai/collections/15-ism

👉 Try a free course: academy.swiftaction.ai/enroll/3527149?price_id=4454402

👀 What to Watch

The MAIB final report on the Solong/Stena Immaculate collision is expected in 2026 following a 30-day stakeholder consultation. It will examine navigation and watchkeeping practices, manning and fatigue management, vessel maintenance, and the use of the offshore anchorage. The findings will likely generate safety recommendations directed at flag states, operators, and potentially the IMO.

The criminal conviction of Captain Motin has reignited the debate over the criminalisation of seafarers’ operational decisions. Human Rights at Sea noted on February 15, 2026, that the case highlights contrasts in how different jurisdictions treat seafarers involved in incidents. The IMO’s Legal Committee adopted new guidelines in 2025 to protect seafarers from unfair treatment when detained in foreign jurisdictions.

Civil litigation is also underway. Ernst Russ, Solong’s owner, is facing a lawsuit at London’s High Court and has applied to have the case dismissed. A hearing is pending.

For fleet operators, the immediate lesson is not about one captain’s failure. It is about the system that allowed a vessel with documented PSC deficiencies, a disabled bridge alarm, and no lookout to operate at 16 knots in restricted visibility without anyone ashore knowing until the collision happened. The ISM system is supposed to catch this. When it does not, the gap shows up in PSC findings, in investigation reports, or in a courtroom.

Fleet managers preparing for inspections in Paris MOU, Tokyo MOU, or USCG regimes can review their crew’s training records against the specific Safety of Navigation and ISM deficiency codes raised in this case. If those records do not reference the specific codes PSCOs are checking, the gap that existed on the Solong may exist on your vessel. The difference between a clean inspection and a finding is often whether the training addressed the exact item the inspector checked.

🚨 SwiftAction Signal

The Stena Immaculate was on his radar for 36 minutes. He turned off the alarm that was designed to make sure he was awake. He was the only person on the bridge in visibility that dropped to a quarter of a nautical mile. He did not change course. He did not slow down. He did not sound the alarm. A full minute passed after the collision before he reacted. Mark Pernia was 38. He had a five-year-old child. His wife was seven months pregnant. He was on the bow doing his job. His body was never found. His second child was born two months later and will never know their father. The jury took eight hours. The judge said complacency and arrogance. Six years. The Solong had PSC deficiency findings flagged months earlier. The industry read the inspection report, filed it, and moved on. A training module on watchkeeping and BNWAS compliance costs $17. The industry does not have a knowledge problem. It has an action problem.

⚓ The SwiftAction Team SwiftAction Intelligence Is Published Daily. For Partnership Inquiries Contact admin@swiftaction.ai

📋 Full Training Catalog: academy.swiftaction.ai

📋 SwiftAction Training Resources Referenced in This Article

👉 Safety of Navigation Modules (Category 10): academy.swiftaction.ai/collections/10-safety-of-navigation

👉 ISM Modules (Category 15): academy.swiftaction.ai/collections/15-ism

👉 Free Course (No Credit Card): academy.swiftaction.ai/enroll/3527149?price_id=4454402

👉 Request Fleet Demo: academy.swiftaction.ai/pages/contact-us

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On the night of July 5, 2023, a Jeep Wrangler being used to push inoperable cars inside the garage decks of the Italian-flagged RoRo vessel Grande Costa D’Avorio caught fire at Port Newark, New Jersey. The fire spread across 1,200 vehicles. The ship’s crew attempted to fight it and failed. The Newark Fire Department responded. Two captains, Augusto “Augie” Acabou, 45, and Wayne “Bear” Brooks Jr., 49, entered the smoke-filled decks and became disoriented. They were found dead, trapped between lashed-down vehicles on a lower deck. The Coast Guard released its Report of Investigation in January 2026. The NTSB approved its final report in April 2025. Both investigations arrived at the same finding: the local fire department had little to no maritime firefighting training, experience, or familiarization with cargo ships of any type. The ship’s crew could not extinguish the fire either. The vessel burned for five days.

📋 In this issue:

• 🔥 The Incident: Grande Costa D’Avorio, Port Newark

• 📊 By The Numbers

• 🔍 The Three Failures That Killed Two Men

• 🛡️ How Targeted Training Could Have Changed This Outcome

• 👀 What to Watch

• 🚨 SwiftAction Signal

📋 Competency-Based Maritime Training Mapped to Every PSC Deficiency Code

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🎯 2026 CIC Cargo Securing Bundle: 30 Courses, 60% Off

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📌 SwiftAction Data Card

→ 🔥 July 5, 2023: Shoreside workers were loading cars onto interior garage decks when a pusher vehicle (Jeep Wrangler) caught fire inside the RoRo vessel Grande Costa D’Avorio at Port Newark, New Jersey. (Source: NTSB Final Report, April 2025)

→ 🚗 1,200+ vehicles on board. Fire spread rapidly across combustible cargo on enclosed garage decks. (Source: USCG Marine Safety Alert 09-23)

→ 🚒 Zero maritime firefighting training: The Coast Guard found the Newark Fire Department had “little to no maritime firefighting training, experience, or familiarization with cargo ships of any type.” The department had not conducted marine firefighting training in nearly a decade. (Source: USCG Marine Safety Alert 09-23, NJ Advance Media)

→ ☠️ Two firefighters killed on board: Captains Augusto Acabou, 45, and Wayne Brooks Jr., 49, became disoriented in smoke-filled garage decks and were found dead, trapped between lashed-down vehicles on a lower deck. (Source: NTSB Final Report, USCG ROI, Stars and Stripes)

→ 🔥 Five days: The fire burned for five days. $23 million in estimated vessel damage. Six additional emergency responders injured. (Source: USCG ROI, January 2026)

→ ⚠️ Crew also failed: The USCG cited “ineffective initial firefighting efforts by vessel crew,” including failure to use available portable foam and failure to close a critical watertight door. (Source: USCG ROI)

🔥 The Incident: Grande Costa D’Avorio, Port Newark

The Grande Costa D’Avorio is a 692-foot Italian-flagged RoRo/container vessel operated by the Grimaldi Group. On the evening of July 5, 2023, the vessel was conducting cargo operations at Berth 18, Port Newark, New Jersey.

Shoreside workers were loading new and used cars onto the vessel’s interior garage decks. A 16-year-old Jeep Wrangler was being used as a “pusher” vehicle to move inoperable cars up the vessel’s internal ramps. It was the 38th push operation the longshoreman had performed that day, according to the NTSB’s final report approved on April 15, 2025.

Midway through a push, the longshoreman heard a loud noise and saw flames dripping from under the Jeep. The vehicle had overheated under conditions far beyond its design parameters. The NTSB found the Jeep had been subject to a safety recall related to transmission overheating during off-road use, but the manufacturer’s modifications were limited to a dashboard warning light and a software update. Neither modification was designed for sustained, high-load pushing of vehicles up steep ramps in enclosed spaces.

The fire spread rapidly across the packed vehicles on the garage decks. With over 1,200 vehicles on board, the cargo was highly combustible.

The ship’s crew responded. A fitter dressed in firefighting gear and an SCBA attempted to fight the fire. The crew activated the vessel’s fixed CO2 fire-extinguishing system to flood the affected space. But they could not close the Deck 12 hydraulic garage door because the controls to operate it were located on the interior side of the door, within the fire zone. Without that door closed, the CO2 could not contain the fire.

The USCG’s Report of Investigation, released in January 2026, cited multiple crew failures: ineffective initial firefighting efforts, failure to use available portable foam, and the failure to close watertight door WTD-12 once it was no longer needed for cargo operations, according to the Newark Patch report on January 15, 2026.

The Newark Fire Department arrived on scene. What followed was a cascade of failures.

Firefighters entered the vessel’s enclosed garage decks. Battalion Chief B-4 positioned himself in a port aft ladderwell on Deck 10 without an SCBA, according to the NTSB report. Additional companies staged on Deck 12, awaiting direction. Radio communications were severely hampered by the vessel’s steel structure. Dispatchers were often unable to communicate with firefighters inside the ship.

Captains Augusto “Augie” Acabou and Wayne “Bear” Brooks Jr. entered the lower decks. They became disoriented in the smoke-filled garage spaces and could not find their way out. They were found dead inside the vessel, trapped between lashed-down vehicles on a lower deck, according to Stars and Stripes reporting on January 9, 2024.

The department had Pak-Tracker receivers in battalion chief vehicles, electronic devices designed to locate missing firefighters by homing in on SCBA transmitters. None were deployed during the search, according to the Coast Guard report, as reported by FireRescue1 on January 14, 2026.

Six additional emergency responders were injured. The fire burned for five days. The estimated damage to the vessel reached $23 million. Legal proceedings on behalf of the families of Acabou and Brooks are ongoing, according to ABC7 New York’s reporting on April 15, 2025.

📊 By The Numbers

→ Zero maritime firefighting training for the responding fire department. The Coast Guard’s November 2023 safety alert stated this was “only one of several vessel fires occurring within the last five years where the lack of familiarity with commercial vessels and inexperience with shipboard firefighting techniques unduly endangered the safety of responding personnel.” (Source: USCG Marine Safety Alert 09-23)

→ Nearly a decade since the Newark Fire Department had conducted marine firefighting training, despite being the department responsible for fires at one of the busiest ports on the US East Coast. (Source: NJ Advance Media investigation)

→ Firefighters did not know they needed an international shipboard adapter to connect their hoses to the vessel’s internal standpipe system. Without it, they could not pump the volume of water needed. (Source: NJ Advance Media, reported by Stars and Stripes, January 2024)

→ The ship’s fireboat was out of action that night and could not start. No one requested assistance from the FDNY and its fleet of fireboats until hours had passed. (Source: NJ Advance Media, reported by Stars and Stripes)

→ According to ABC7 New York’s coverage of the April 15, 2025 NTSB hearing, the NTSB chairman said the Newark firefighters “were poorly trained before fighting the massive cargo ship fire and they are still poorly trained after.” (Source: ABC7 New York, April 15, 2025)

→ Fire safety deficiencies accounted for 18% of all PSC detentions globally in 2025, the #1 category for over a decade. The crew’s inability to manage the fire aboard Grande Costa D’Avorio reflects the same competency gaps PSCOs find during routine inspections. (Source: SAFETY4SEA PSC Focus 2025)

The shore firefighters had no maritime training. The ship’s crew could not contain the fire. Both investigations identified the same gap. Below: the three specific failures the NTSB said killed Acabou and Brooks, how training mapped to the exact deficiency codes involved would have changed the outcome, and what every fleet manager should check on their own vessels before the next port call.

🔍 The Three Failures That Killed Two Men

The NTSB’s final report, approved during a public hearing on April 15, 2025, identified a chain of three failures. Each was preventable. Each involved a training or competency gap.

Failure 1: The pusher vehicle should never have been on the ship.

The Jeep Wrangler was being used for industrial pushing operations far beyond its design capacity. It had been subject to a safety recall for transmission overheating. The NTSB concluded the fire was preventable and that the use of a consumer vehicle for this purpose was inappropriate and dangerous. The board recommended the American Association of Port Authorities warn port operators about the risks. This was an operational decision failure by the terminal operator, not the crew.

Failure 2: The CO2 system could have worked, but the crew could not close the door.

The vessel’s fixed CO2 system was deployed. But the Deck 12 hydraulic garage door could not be closed because its controls were accessible only from the interior, which was on fire. Without boundary closure, the CO2 dissipated. The NTSB called on the classification society to revise guidelines ensuring SOLAS-compliant fire doors can be operated from both sides. NTSB investigator Bart Barnum stated during the hearing that the most effective method to extinguish the fire would have been to work with the crew to close the Deck 12 door and allow the CO2 to function, as reported by JOIFF on April 16, 2025.

This was a combined design and crew competency failure. The door design was inadequate. But the crew’s response also included what the USCG described as ineffective initial firefighting efforts and failure to use available portable foam. This failure falls under PSC Code 07108 (Fire Doors/Openings in Fire-Resisting Divisions), one of the most frequently cited fire safety deficiency codes globally. A crew trained specifically on fire boundary management, the limitations of their vessel’s suppression architecture, and alternative firefighting procedures when primary boundary closure fails would have approached this response differently.

Failure 3: The firefighters entered a space they should not have entered, without training to survive it.

The NTSB concluded that the decision to send firefighters into the CO2-flooded, smoke-filled garage decks was a fatal misjudgment based on inadequate training and communication. The Coast Guard found the Newark Fire Department had never conducted vessel familiarization at Port Newark, despite the port being within their area of responsibility. Firefighters did not know the layout of the vessel, the locations of escape routes, or the operation of shipboard fire suppression systems.

The USCG report identified additional specific training gaps: the failure to deploy available SCBA PASS alarm training in the event of a mayday, the failure of one of the deceased firefighters to carry his radio, and the failure to deploy Pak-Tracker location devices that were available in battalion chief vehicles.

The Coast Guard’s November 2023 Marine Safety Alert called for improved coordination of marine firefighting preparation nationwide, noting that vessel fires require different technical skills than many land-based firefighting agencies possess.

Maritime incidents are complex. The Grande Costa D’Avorio fire involved a defective vehicle, a flawed door design, a terminal operator’s decision, a crew’s failed response, and a fire department’s absent training. Multiple parties bear responsibility. But the factor that determined whether two men lived or died was whether anyone on that vessel, crew or responder, had been trained on the specific emergency procedures that this situation demanded. They had not.

🛡️ How Targeted Training Could Have Changed This Outcome

Every investigation report recommends “improved training.” The question the industry never answers is: what training, specifically?

The Grande Costa D’Avorio produced two federal investigation reports, five Coast Guard safety recommendations, and a Marine Safety Alert. All of them point to the same gap. Not a lack of training in general. A lack of training on the specific competencies that this specific emergency required.

The following analysis focuses on the crew-side failures, where vessel operators can take direct action.

Fire detection and response procedures (PSC Code 07106, 07101).

The crew had a CO2 system and portable foam available. They deployed one and failed to use the other. Training mapped to these specific deficiency codes covers fixed fire-extinguishing system operation, the requirements for boundary integrity before CO2 release, portable foam deployment procedures, and the decision framework for when to escalate from portable equipment to fixed systems. A crew that had completed training on these codes would have recognised that CO2 without boundary closure is ineffective and would have either managed the boundary first or defaulted to portable foam while addressing the door.

Fire door and fire boundary management (PSC Code 07108, 07113).

The USCG cited the failure to close WTD-12 while it was no longer needed for cargo operations. This is a fire boundary management issue. Training on fire boundary integrity covers when watertight and fire doors must be closed during cargo operations, the SOLAS requirements for fire zone boundaries, and the procedures for maintaining fire integrity during loading and unloading. The crew left the door open. The fire walked through it.

Emergency drills and crew coordination (PSC Code 07113, 15101).

The USCG cited ineffective initial firefighting efforts as a whole-crew failure, not an individual one. ISM-related training mapped to Code 15101 covers the requirements for conducting effective fire drills, the roles and responsibilities of each crew member during a fire emergency, and the communication protocols between the fire party and the bridge. The NTSB found the crew responded promptly but could not contain the fire. Prompt response without effective execution is not competency.

Why this matters at inspection:

These are not theoretical deficiency codes. Fire safety (Category 07) drove 18% of all PSC detentions globally in 2025, according to SAFETY4SEA. ISM non-compliance (Category 15) drove 16%. Together, they account for more than a third of all detentions worldwide. A PSCO checking these codes is checking whether the crew can demonstrate exactly the competencies that the Grande Costa D’Avorio crew could not: operate the fire suppression system, manage fire boundaries, deploy portable equipment, and execute coordinated emergency response.

SwiftAction Academy maps one training module to each of these deficiency codes, with completion certificates that reference the specific code for inspection readiness.

The full fire safety training catalog is at

SwiftAction Fire Safety Catalog

👀 What to Watch

The NTSB issued recommendations to the AAPA, port authorities, and the classification society. The Coast Guard issued five safety recommendations, six administrative recommendations, and five findings of concern. Whether these translate into actual training programs at US ports remains to be seen. According to ABC7 New York’s coverage of the April 2025 hearing, the NTSB chairman indicated the Newark Fire Department’s training has not materially improved since the incident.

For vessel operators, the immediate takeaway is the crew-side failures. The inability to manage a fire before shore responders arrived, the failure to use available portable foam, the failure to maintain fire boundary integrity during cargo operations. These are the exact competencies PSCOs check during fire safety inspections in every MOU regime, every port, every day.

The 2026 CIC on Cargo Securing (September through November) and the 2027 CIC on Enclosed Space Entry will test whether the same competency gaps that contributed to the deaths of Acabou and Brooks persist across the global fleet. Different categories. Same underlying question: when the inspector checks, will the crew be able to demonstrate the specific skill?

🚨 SwiftAction Signal

The Coast Guard said the Newark Fire Department had not conducted maritime firefighting training in nearly a decade. The ship sat at one of the busiest ports on the US East Coast, within their response area, every week. Nobody trained. The ship’s crew deployed the CO2 system but could not close the door it needed to work. They had portable foam available and did not use it. The NTSB said the firefighters should never have gone inside. They went inside anyway, because nobody told them not to, because nobody had trained them on when to enter a vessel and when to stay out. Two families buried someone who went to work that night. According to ABC7 New York, the NTSB chairman said the firefighters who remain are still poorly trained. Fire safety has been the #1 PSC detention category for over a decade. A corrective training module addressing a specific fire safety deficiency code costs $17. The industry does not have a knowledge problem. It has an action problem.

⚓ The SwiftAction Team

SwiftAction Intelligence Is Published Daily.

For Partnership Inquiries Contact admin@swiftaction.ai

📋 Full Training Catalog:

academy.swiftaction.ai

📋 SwiftAction Training Resources Referenced in This Article

👉 Fire Safety Modules (Category 07)

👉ISM Modules (Category 15)

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