What a Chittagong PSC Officer Actually Checks on Your MARPOL Paperwork

A PSC officer boarding at Chittagong isn't going to spend most of their time on your engine room, ISM-related findings and documentation gaps top the list of both common and detainable deficiencies industry-wide, and MARPOL paperwork is exactly where that documentation scrutiny lands hardest. Garbage Management Plan, Garbage Record Book, and Oil Record Book Part 2 entries are the three documents we see flagged most often, and they're also the three easiest to get genuinely right with a bit of attention before arrival. Statutory acceptance remains with the competent authority, flag, class, port State or terminal; the local agent can coordinate attendance and records but cannot certify the vessel or guarantee clearance. Confirm current port facility and flag/class documentary requirements for the vessel and call dates.

Garbage management gets more attention than ship managers expect

Every vessel needs a Garbage Management Plan that's actually followed, not just filed, and a Garbage Record Book with entries that match what a PSC officer would expect to see given the voyage just completed. Inconsistent garbage record entries, categories not matching MARPOL Annex V's classification, gaps in dates, entries that don't align with port calls and discharge, are a recurring, avoidable finding. This is one of practical low-cost compliance checks: it costs nothing but attention to keep this record accurate in real time rather than reconstructing it before arrival.

Oil Record Book Part 2 specifically

Part 2 covers cargo and ballast operations on oil tankers, and it's a frequent inspection focus given Bangladesh's own sensitivity around the Karnaphuli and coastal environment. Entries need to be contemporaneous, signed by the responsible officer, and internally consistent with BDN records and discharge logs. A PSC officer cross-referencing the ORB against other documentation is standard practice, and discrepancies, even minor timing mismatches, invite a closer look at everything else on board.

Ballast water is the newer area of focus

Ballast Water Management Certificate compliance has become a standing international Concentrated Inspection Campaign focus over the past several years, and Chittagong's PSC officers check both the certificate and the actual record-keeping more carefully than they did even three or four years ago. A valid certificate with inconsistent or incomplete ballast water record book entries is exactly the kind of finding that used to slide through and increasingly doesn't.

Why Bangladesh-specific context matters here

Given the country's documented IMDG enforcement gaps and the high-profile depot incidents we've covered elsewhere on this blog, port authorities here have institutional reason to be more careful on documentation generally, not just dangerous goods specifically. That doesn't mean Chittagong PSC is unusually aggressive, it means a vessel with genuinely clean, contemporaneous MARPOL documentation has less to worry about here than the port's older reputation might suggest, while a vessel with sloppy record-keeping has correspondingly less room to get away with it.

What we'd check before arrival

Garbage Record Book entries against the actual voyage, dates, categories, discharge locations all consistent. Oil Record Book Part 2 cross-checked against BDN records and discharge logs for the same period. Ballast Water Management Certificate current, with record book entries that actually match operational reality. None of this is exotic preparation, it's the same diligence good ship management already requires, just worth double-checking specifically before a Bangladesh call given the documentation focus.