Compliance Surveillance

PSC, SIRE 2.0, CDI, VIR and CII — five regulatory regimes, one detention-and-commercial-impact view.

Compliance Surveillance — five regulatory regimes (PSC, SIRE 2.0, CDI, VIR, CII) read together, scored, and routed to one ranked verdict.

A vessel operates inside a regulatory cage made of five overlapping regimes. Each has its own inspectorate, its own scoring system, its own remedy timeline. A finding in one can compound a finding in another. A repeat finding across regimes is the signal that something fundamentally isn’t working.

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

The Compliance Surveillance pipeline reads all five together. Detention risk depends on more than just PSC; commercial-charter eligibility depends on more than just SIRE. The pipeline produces one ranked verdict — what’s most likely to bite, in what regime, and what to do about it.

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Where the data comes from

Each regime publishes its data through a different surface. The pipeline pulls from each independently:

Regime	Source
PSC	Port-state-control regime portals (see logo grid below)
SIRE 2.0	OCIMF SIRE 2.0 portal
CDI	CDI — Chemical Distribution Institute portal
VIR	Vessel ERP inspection module + email correspondence
CII	Emissions pipeline — derived from noon reports + bunker records

PSC regime portals

	MoU / Authority	Region
	Paris MoU	Europe + N. Atlantic
	Tokyo MoU	Asia-Pacific
	Indian Ocean MoU	Indian Ocean rim
	Mediterranean MoU	Mediterranean basin
	Caribbean MoU	Caribbean basin
	Black Sea MoU	Black Sea region
	Abuja MoU	West & Central Africa
	US Coast Guard (USCG)	United States
	Riyadh MoU	Gulf states

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Regime by regime

PSC

The most operationally consequential regime. A PSC inspection produces deficiencies and (in severe cases) a detention. Every regime has its own MoU (Paris MoU, Tokyo MoU, Riyadh, AMSA, USCG, Latin American), each with a target factor that drives inspection probability per port call.

The pipeline tracks:

• Open PSC deficiencies (deficiency code, severity, action taken, ranking)
• Detention history (when, where, what was the cause, how long held)
• Repeat themes (same deficiency code appearing on multiple inspections)
• Recent inspection density at the next port’s regime
• Crew / SMS deficiencies (often correlated to fatigue, training gaps)

PSC severity vocabulary normalises to:

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

SIRE 2.0

OCIMF’s tanker vetting programme. SIRE 2.0 (the 2023 rewrite) replaced binary deficiency findings with a more nuanced observation severity scale:

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

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

CDI

The chemical-tanker analogue to SIRE. Inspection produces ship and barge inspection reports (SIR / BIR). Same response-window logic; same observation severity tracking.

The pipeline pulls the last-CDI details per vessel and tracks the inspection cycle.

VIR

Charterer- and owner-led inspections. Variable severity vocabulary, normalised the same way as the defects pipeline. VIR findings often pre-empt SIRE / CDI findings — a charterer’s inspector finds something today that the OCIMF inspector would have found at the next vetting if it weren’t fixed first.

CII

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

• Current attained vs required CII for the year
• Year-over-year delta in attained
• Projected end-of-year rating band (A / B / C / D / E)
• Regulatory consequence: a vessel rated D for 3 consecutive years or E for 1 year requires a SEEMP III update with corrective measures

A CII rating projecting E with 6 months of operating year remaining is a major commercial issue — the vessel may need operational changes (slow-steaming, route modification) or technical changes (engine retrofit) to bring the rating back.

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Cross-regime fleet view

A fleet-wide compliance dashboard composes the per-vessel records:

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

A reviewer scans the row to spot the structurally exposed vessels: OCEAN here has a recent detention, multiple SIRE Severity 3+ observations, and a CII trajectory dropping from D to E — three regimes pointing in the same direction.

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Detention-risk scoring

A weighted composite combines four signals:

$$R_\text{psc} = w_1 D_\text{open} + w_2 H_\text{detention} + w_3 R_\text{repeat} + w_4 S_\text{sms}$$

Signal	Description
$D_\text{open}$	Open PSC deficiencies in the next port’s regime
$H_\text{detention}$	Detention-history recency multiplier (recent detention = higher)
$R_\text{repeat}$	Repeat-finding cluster count (same code, multiple inspections)
$S_\text{sms}$	Crew / SMS deficiency density (fatigue, training, SMS implementation)

The composite maps to LOW / MEDIUM / HIGH / CRITICAL. HIGH or CRITICAL routes the case to the Technical Superintendent with the contributing factors.

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Commercial-impact scoring

A parallel score covers vetting and charterer exposure:

$$R_\text{commercial} = w_1 N_\text{sire\_open} + w_2 N_\text{cdi\_open} + w_3 \mathbb{1}[\text{CII E projected}] + w_4 N_\text{vir\_open}$$

A CII rating dropping to E carries a binary indicator weight because the regulatory consequence is binary.

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Investigation matrix

When a finding lands, the pipeline classifies it through an investigation matrix:

Dimension	Categories
Root cause	Technical, procedural, training, documentation
Recurrence	First-time, repeat (same vessel), repeat (across fleet)
Commercial impact	Vetting failure, off-hire risk, fuel-cost impact
Time to close	Hours, days, weeks, months

A “training” root cause repeating across the fleet is a different conversation than a “technical” root cause on one vessel. The matrix exists so the response is calibrated to the actual problem.

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CII trajectory

For the carbon dimension, the analyzer tracks attained CII through the operating year:

\text{CII}_\text{attained}(t) = \frac{\sum_{i=1}^{t} \text{CO}_2_i}{\sum_{i=1}^{t} \text{Capacity} \cdot \text{Distance}_i}

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

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Worked example

MV OCEAN, end-of-April compliance review:

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

Repeat themes:

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

Verdict: CRITICAL. Three regimes pointing in the same direction, projected CII E, recent detention, repeat themes.

The pipeline:

1. Routes the SIRE Severity 3 response to crewing — operator response due in 8 days, must not lapse.
2. Routes the CII trajectory to the voyage pipeline for operational-change recommendation (slow-steaming candidate; route review).
3. Generates a repeat-theme remediation plan covering crew familiarity training across the fleet, not just OCEAN.
4. Flags ECDIS update procedure to QHSE for SMS revision.

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What the senior review contains

1. Headline — overall compliance posture, detention-risk and commercial-impact scores.
2. PSC — open deficiencies with severity, detention history, regime risk.
3. SIRE 2.0 — observation count by severity, response status, time to response window.
4. CDI — last inspection findings, response status (where applicable).
5. VIR — open observations, charterer / owner.
6. CII — current and projected rating, year-over-year delta, SEEMP III implications.
7. Repeat themes — findings appearing across regimes or inspections, with root-cause classification.
8. Recommendations — prioritised by deadline and impact.
9. Escalation decision — to whom, and why.

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Escalation triggers

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

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Why all five together

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

Repeat themes across regimes are the single highest-leverage finding the pipeline produces. A one-off finding can be dismissed; the same finding appearing in PSC and SIRE means the underlying issue is real and structural.

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References

Source templates

SIRE / CDI monitoring suite — historical SIRE observations, inspection records, last-CDI details, fleet-wide SIRE / CDI status.

Related: Class

Class CoCs feed PSC detention probability — overlap with the class pipeline.

Related: Defects

PSC, SIRE, CDI, VIR findings live in both pipelines — defects gives the operational view.

Related: Emissions

CII rating is computed from emissions data — that’s where the numbers come from.