PSC CIC on Ballast Water Management (BWM) – Results Report
RiSK4SEA presents insights from the total period of 90 days, revealing that ballast water record keeping, system operation, management plans, and crew training are key areas of focus.
The period of the CiC was from 1st of September to 30th of November 2025.
The purpose of the Inspection Campaign was to determine the level of compliance of all parties involved with the content of the International Convention for the Control and Management of Ship’s Ballast Water and Sediments, 2004 (BWM Convention, latest edition (2018)) and especially with issues related to:
- Update and approval of the Ballast Water Management Plan (BWMP);
- Crew familiarization in the implementation of the BWMP – adequate training of the crew regarding the entire system;
- Records of Ballast Water Record Book (BWRB) – (proper entries which are omitted);
- Ballast Water Management System approval and its operation – proper function of the (BWMS) and any potential deviations from the corresponding Plan;
- Proper Certification for BWM Convention;
- Ballast Water Sediment Management;
- Valid exemptions (If any).
Please see Annex A for the Paris MoU/Tokyo MoU – CIC Questionnaire
Please See Annex B for the CIC Intensity Index Methodology
Key findings
#1 Four core areas dominate
Over 90% of all findings are concentrated in just four areas:
- Ballast Water Record Book (BWRB)
- Ballast Water Management System (BWMS)
- Ballast Water Management Plan (BWMP)
- Crew Training & Familiarisation
#2 Limited focus on operational procedures
Contrary to industry concerns, Ballast Water Exchange, Discharge in Port, and Sediment Removal & Disposal have not emerged as major sources of deficiencies.
#3 Uneven CiC enforcement across MoUs
Despite formal announcements, only Tokyo MoU, Paris MoU, and Mediterranean MoU are actively prioritizing the BWM CiC according to the CiC Intensity Index.
#4 Intensity comparison (vs pre-CiC period)
- Tokyo MoU: ~3× higher focus intensity
- Paris & Mediterranean MoUs: ~2× higher focus
#5 Ship types most impacted
LNG carriers face the highest inspection pressure, followed by LPG carriers and Vehicle Carriers. Other ship types experience approximately double the scrutiny compared to pre-CiC levels. However, only 2 detainable deficiencies marked on LNGs. As they had 0 detainable items during the NoN CiC period they show the higher index.
#6 Detentions Analysis
General Cargo is by far the most affected ship type attracting more than 50% of the Detentions. Mediterranean, Tokyo & Black Sea are leading by the Number of Detentions, while Paris MoU with more than double PSCIs (compared with Maed and Black Sea MoU) shows half the number of detentions due to CiC related deficiencies.
Severity-weighted analysis
A severity-weighted breakdown of these findings is included in the next section, highlighting critical risk areas and high-impact deficiencies affecting operational compliance.
| Deficiency Code & Description | Detainable Deficiencies | Non Detainable Deficiencies | Total Deficiencies |
|---|---|---|---|
| 14801 – Ballast Water Management Plan | 17 | 476 | 493 |
| 14802 – Ballast Water Record Book | 3 | 918 | 921 |
| 14804 – Ballast Water Exchange | 2 | 9 | 11 |
| 14805 – Sediment removal and disposal | 1 | 75 | 76 |
| 14806 – Crew Training and familiarization | 23 | 362 | 385 |
| 14807 – Performance Standard not met | 1 | 3 | 4 |
| 14808 – Prototype ballast water treatment | 0 | 1 | 1 |
| 14809 – Conditions for exemptions | 2 | 8 | 10 |
| 14810 – Ballast water discharge violation in port | 3 | 6 | 9 |
| 14811 – Ballast Water Management System | 51 | 411 | 462 |
| 14899 – Other (BWM) | 7 | 87 | 94 |
| TOTAL | 110 | 2,356 | 2,466 |
The Severity Weighted findings analysis for detainable deficiencies is as follows:
Weighted Factor (Share of DET Defs)
- 14808 – Prototype ballast water treatment 0%
- 14805 – Sediment removal and disposal 1%
- 14807 – Performance Standard not met 1%
- 14804 – Ballast Water Exchange 2%
- 14809 – Conditions for exemptions 2%
- 14802 – Ballast Water Record Book 3%
- 14810 – Ballast water discharge violation in port 3%
- 14899 – Other (BWM) 6%
- 14801 – Ballast Water Management Plan 15%
- 14806 – Crew Training and familiarization 21%
- 14811 – Ballast Water Management System 46%
Analysis per each of the MoU as follows, comparing the same Deficiency Areas affected by the CIC (Referred to as CIC Deficiency Per Inspection or CIC mDPI, milli DPI or Deficiencies per 1,000 PSCIs), along with the calculation of the CIC intensity Index (Methodology of the Index in Annex B).
CiC Intensity Index per MoU
| MoU Area | Results BEFORE the CiC Period (L12M (1/9/24-31/8/25) | Results WITHIN the CiC Period (1/9/25-30/11/25) | CiC Intensity Index | ||||||||||
| Total PSCIs | Overall DPI | BWM Defs Calculation | Total PSCIs | Overall DPI | BWM Defs Calculation | ||||||||
| DET | NON-DET | SDEF % | CiCmDPI | DET | NON-DET | SDEF % | CiCmDPI | ||||||
| Tokyo | 29,496 | 2.66 | 47 | 1.430 | 1.90% | 45 | 7,895 | 2.62 | 31 | 1,470 | 7.25% | 159 | 254% |
| Paris | 15,640 | 3.02 | 35 | 890 | 1.90% | 45 | 3,719 | 3.16 | 14 | 573 | 4.99% | 117 | 160% |
| Vina Del Mar | 9,048 | 0.37 | 2 | 26 | 0.80% | 4 | 2,222 | 0.39 | 0 | 15 | 1.72% | 6 | 40% |
| Mediterranean | 5,052 | 3.79 | 39 | 432 | 2.50% | 81 | 1,420 | 3.90 | 32 | 232 | 4.77% | 205 | 153% |
| Indian Ocean | 3,075 | 1.91 | 1 | 10 | 0.20% | 4 | 572 | 2.07 | 6 | 13 | 1.60% | 68 | 1,603% |
| Black Sea | 3,206 | 3.34 | 65 | 172 | 2.50% | 159 | 1,019 | 3.53 | 31 | 88 | 3.31% | 263 | 65% |
CiC Intensity Index per Ship Segment
| Ship Type | Results BEFORE the CiC Period (L12M (1/9/24-31/8/25) | Results WITHIN the CiC Period (1/9/25-30/11/25) | CiC Intensity Index | ||||||||||
| Total PSCIs | Overall DPI | BWM Defs Calculation | Total PSCIs | Overall DPI | BWM Defs Calculation | ||||||||
| DET | NON-DET | SDEF % | CiCmDPI | DET | NON-DET | SDEF % | CiCmDPI | ||||||
| BuLkers All | 24,593 | 2.31 | 3,127 | 53,628 | 2.00% | 44 | 6,228 | 2.35 | 30 | 849 | 6.01% | 131 | 199% |
| Tankers -All | 11,380 | 1.99 | 1,460 | 21,142 | 2.03% | 40 | 2,578 | 2.04 | 8 | 295 | 5.75% | 103 | 154% |
| Containers All | 9,901 | 2.03 | 825 | 19,244 | 1.96% | 34 | 2,616 | 2.12 | 9 | 406 | 7.50% | 132 | 292% |
| General Cargo | 13,292 | 3.93 | 5,104 | 47,115 | 1.86% | 71 | 3,384 | 4.02 | 54 | 604 | 4.84% | 194 | 176% |
| LNG/Gas Carrier | 444 | 1.05 | 18 | 447 | 3.87% | 30 | 96 | 1.39 | 2 | 19 | 15.79% | 304 | 910% |
| LPG Carrier | 1,259 | 2.50 | 266 | 2,887 | 1.65% | 40 | 329 | 2.51 | 4 | 67 | 8.59% | 168 | 323% |
| Ro Pax | 1,392 | 2.30 | 110 | 3,085 | 1.38% | 29 | 321 | 2.46 | 0 | 29 | 3.68% | 52 | 80% |
| Vehicle Carrier | 1,829 | 1.81 | 225 | 3,084 | 1.93% | 31 | 492 | 2.10 | 1 | 65 | 6.38% | 113 | 266% |
| Offshore | 564 | 2.14 | 67 | 1,141 | 1.82% | 26 | 145 | 1.95 | 0 | 14 | 4.95% | 70 | 169% |
| Other Ship Types | 2,489 | 2.33 | 368 | 5,440 | 1.03% | 20 | 658 | 2.35 | 2 | 43 | 2.91% | 63 | 213% |
The Analysis of overall Findings in terms of BWM CiC mDPI the 12 months before and during the period of the CiC is shown in below charts.
BWM CiC mDPI per MoU
BWM CiC mDPI per Ship Segment
Detention is always a problem during a PSC Inspection. During CiC period PSCO focus on specific items and the CiC related detention shows an extreme gap in conformance with requirements, as described by each Deficiency code.
Below there is a mapping of Detentions in respect of MoUs, Ports and Fleet Segment.
| Port | Country | #PSCIs | #Detentions |
| Paris MOU | |||
| Quebec City | Canada | 9 | 2 |
| Antwerpen | Belgium | 129 | 1 |
| Becancour | Canada | 5 | 1 |
| Cuxhaven | Germany | 15 | 1 |
| Drogheda | Ireland | 3 | 1 |
| Gent | Belgium | 44 | 1 |
| Goteborg | Sweden | 15 | 1 |
| Halmstad | Sweden | 3 | 1 |
| Heraclion (Crete) | Greece | 3 | 1 |
| Leixoes | Portugal | 16 | 1 |
| Rotterdam | Netherlands | 144 | 1 |
| Sharpness | UK | 1 | 1 |
| Black Sea MOU | |||
| Tuapse | Russia | 75 | 9 |
| Novorossiysk | Russia | 241 | 6 |
| Poti | Georgia | 56 | 1 |
| Trabzon | Turkey | 17 | 1 |
| Mediterranean MOU | |||
| Kocaeli | Turkey | 161 | 10 |
| Gemlik | Turkey | 27 | 5 |
| Aqaba | Turkey | 64 | 3 |
| Iskederun | Turkey | 55 | 2 |
| Ambarli | Turkey | 73 | 1 |
| Aliaga | Turkey | 100 | 1 |
| Antalya | Turkey | 26 | 1 |
| Ceyhan | Turkey | 22 | 1 |
| Tekirdag | Turkey | 45 | 1 |
| Yalova | Turkey | 6 | 1 |
| Port | Country | #PSCIs | #Detentions |
| Tokyo MOU | |||
| Dongjakou | China | 77 | 3 |
| Qingdao | China | 91 | 3 |
| Gunsan | S. Korea | 30 | 2 |
| Nakhodka | Russia | 41 | 2 |
| Shanghai | China | 339 | 2 |
| Tianjin | China | 182 | 2 |
| Ulsan | S. Korea | 57 | 2 |
| Changshu | China | 23 | 1 |
| Fangcheng | China | 27 | 1 |
| Guangzhou | China | 127 | 1 |
| Hong Kong | Hong Kong | 145 | 1 |
| Humen | UK | 34 | 1 |
| Jiaxing | China | 16 | 1 |
| Quanzhou | China | 19 | 1 |
| Shenzhen | China | 100 | 1 |
| Tanjung Priok | Indonesia | 115 | 1 |
| Weifang | China | 15 | 1 |
| Yangpu Pt | China | 30 | 1 |
| Zhangjagang | China | 40 | 1 |
| Zhoushan | China | 103 | 1 |
| Indian Ocean MOU | |||
| Chittagong | Bangladesh | 136 | 1 |
| Port of Ngqura | South Africa | 3 | 1 |
| Salalah | Oman | 12 | 1 |
| Shahid Rajaee | Iran | 2 | 1 |
| Ship Type | #Ships |
| Bulkers | 22 |
| Tankers | 8 |
| Containers | 8 |
| General Cargo | 44 |
| LNG/Gas Carrier | 1 |
| LPG Carrier | 3 |
| Ro Pax | 0 |
| Vehicle Carrier | 1 |
| Offshore | 0 |
| Other Ship Types | 2 |
| MOU | #Ships |
| Paris | 13 |
| Black Sea | 17 |
| Mediterranean | 26 |
| Indian Ocean | 4 |
| Tokyo | 29 |
| Total | 89 |
Annex A: Paris MoU/Tokyo MoU – CIC Questionnaire
The list with the CiC questions is as follows:
| No | Description | Yes | No | N/A | Detention |
|---|---|---|---|---|---|
| 1. | Is a valid International Ballast Water Management Certificate (IBWMC) on board? (01136 – BWM 2004 / Reg. E-2) | | | | |
| 2. | Is the approved Ballast Water Management Plan (BWMP) on board? (14801- BWM 2004 / Reg. B-1) | | | | |
| 3. | Is the BWMP up to date to reflect the applicable requirements to manage Ballast Water as required by the Convention? (14801- BWM 2004 / Reg. B-1) | | | | |
| 4. | Are officers and crew familiar with their duties in the implementation of the BWMP? (14806 – BWM 2004 / Reg.B-6) | | | | |
| 5. | Is the Ballast Water Management System (BWMS) approved by the Administration/Organization, as appropriate? (14812 – BWM 2004 / Reg. D-3 or BWMS Code) | | | | |
| 6. | Is the BWMS operational? (14811 – BWM 2004 / Reg. D-2 or BWMS Code Section 4)) | | | | |
| 7. | Was the Ballast Water managed according to the BWMP? (14813 – BWM 2004 / Reg. B-1) | | | | |
| 8. | Is the Ballast Water Record Book (BWRB) properly filled including exemptions if granted? (14802- BWM 2004 / Reg. B-2 & Reg. A-4.4) | | | | |
| 9. | Is the crew managing Ballast Water sediments in accordance with the BWMP? (14805 – BWM 2004 / Reg. B-5) | | | | |
| 10. | If an exemption has been granted, are the conditions of exemption implemented? (14809 – BWM 2004 / Reg. A-4) | | | |
Annex B: CIC Intensity Index Methodology
To assess the CiC Intensity Index a simple methodology has been applied based on the Ballast Water Management (BWM) CIC related Deficiency expressed in mDPI (Deficiencies per 1,000 PSCIs) comparing 2 periods.
- During the CIC Period (x Days) 90 days, i.e. 1/9/2025 to 30/11/2025
- Before the CIC period (Last 12 months) and the period where CIC is being applied. Here, Last 12 months 1/9/2024 – 31/05/2025
The BWM CIC mDPI is the sum of all BWM CIC deficiency findings per ship, port, manager, MoU etc. related with the CIC:

The CIC intensity index signifies the increased focus on the CIC Items
- Less than 0%: There is Less focus in the CIC Items during the CIC compared with the period before CIC
- 0% = No Increased focus at all on CIC Items during the CIC compared with the period before CIC
- 200%: 2x Focus on on CIC Items during the CIC compared with the period before CIC
The higher the percentage of CIC Intensity Index, the higher the focus (i.e. intensity) on the CIC requirements and Findings.
