LOYALTY EXPRESS

The company should establish procedures to ensure that the ship is maintained in conformity with the provisions of the relevant rules and regulations and with any additional requirements which may be established by the company. Due to the objective evidence in the below deficiencies, the vessel is not in substantial compliance with relevant conventions, calling into question the adequacy and implementation of the vessel’s SMS under the ISM code. PSCOs collected objective evidence that the vessel submitted requests in June 2022 on the Record of Program of Work to do List Form, in accordance with their approved SMS Manual to the company for maintenance and repair support, but could not find evidence of the company taking actions to support these requests. Requested repairs include proper operations of main engine, and faulty of primary and secondary generators. In all cases, the vessel could not produce evidence that the company notified their Recognized Organization or Flag Administration of the serious safety deficiencies. An external audit conducted by the Flag is required to determine whether the ship is operating in accordance with the ISM Code. Provide a copy of the completed audit report to USCG prior to departure from port. 74 SOLAS (20 CONS.) Ch. IX/3.1. ISM CODE PART A/10.1. 30ac.

A ship when in a port of another Contracting Government is subject to control by officers duly authorized by such Government concerning operational requirements in respect of the safety of ships, when there are clear grounds for believing that the master or crew are not familiar with essential shipboard procedures relating to the safety of ships. OWS not in use due to generators unable to power machinery. Engineers reported to PSCOs that they were transferring waste oil and oily bilge water into sludge tanks as a substitute. Engineers also reported they were unaware of procedures or techniques to offload sludge tanks once full. 74 SOLAS (20) XI-1/4.1. 30ac.

The owner, agent, master, operator, or person in charge must, within 5 days, file a written report of any marine casualty required to be reported under § 4.05-1. This written report is in addition to the immediate notice required by § 4.05-1. This written report must be delivered to a Coast Guard Sector Office or Marine Inspection Office. Vessel failed to report inoperable generator and main engine. 46 CFR § 4.05-10. 17ac.

The following fire protection systems shall be kept in good order so as to ensure their required performance if a fire occurs: fire detection and fire alarms systems. The fire detectors on the vessel are not operable. PSCO’s observed crew members attempt to test fire detectors with hand held lighters unsuccessfully. 74 SOLAS (20 cons.)Ch. II-2/14.2.1.1.2. 30ac.

All required fire detection systems shall be capable of automatically indicating the presence or indication of fire and also its location. Indicators shall be centralized either on the bridge or in other control stations which are provided with a direct communication with the bridge. The Administration may permit the indicators to be distributed among several stations. The fire detection panel on the bridge was indicating that all fire detectors were in a fault status.60 SOLAS Ch.II/61(a). 17ac.

Each operation described in paragraph 2 of this regulation shall be fully recorded without delay in the Oil Record Book Part I, so that entries in the book appropriate to that operation are completed. Vessel failed to document proper weekly soundings in the oil record book in accordance with ORB Part 1.MARPOL Annex I/17.4. 17ac.

While ships are operating within an emission control area, the Sulphur content of fuel oil used on board ships shall not exceed the following limits 0.10% m/m on and after 1 January 2015. Engineering notes recorded sulfur content of 0.5% m/m with no scrubbers onboard. MARPOL Annex VI/14.4.3. 17ac.

By reason of weather, visibility, sea conditions, port congestion, other hazardous circumstances, or the condition of such vessel, he is satisfied that such directive is justified in the interest of safety. PSCO observed complete lack of adequate food for crew as well as numerous cockroaches in food pantries. 33 USC 1223(b)(3). 17ac.

The condition of the ship and its equipment shall be maintained to conform with the provision of the present regulations to ensure that the ship and all aspects will remain fit to proceed to sea, without danger to the ship or persons on board. The crew reported to PSCO’s that the emergency generator is the only available source of power providing power to the vessel. The emergency generator is not designed for continual operation so it is intentionally shut off for a period of 5 hours a day to avoid overheating, leaving all emergency equipment and detection inoperable and a danger to all persons on board. 74SOLAS(20 cons.)Ch. I/11(a). 17ac.

SUITABLE ARRANGEMENTS SHALL BE MADE FOR EMBARKATION INTO LIFEBOATS, WHICH SHALL INCLUDE A LADDER AT EACH SET OF DAVITS TO AFFORD ACCESS TO THE LIFEBOATS WHEN WATERBORN... EMBARKATION LADDER ON STARBOARD SIDE IS TORN AND NO LONGER USABLE.

[withheld — contains personal information; the deficiency system, dates, and resolution status are shown above]

All cargoes, … , shall be loaded, stowed and secured throughout the voyage in accordance with the Cargo Securing Manual approved by the administration. Cargo Securing Manual on board is not approved by current administration. 74 SOLAS (20 Cons.) Ch. VI / Reg. 5.6

In any passenger ship, and, as far as applicable in any cargo ship, there shall be permanently exhibited for the guidance of the ship’s officers general arrangement plans showing clearly … with particulars of the fire alarms, … . PSCO observed that after installing new fire detecting system the fire control plan was not updated accordingly. 60 SOLAS Ch. II / Reg. 70

The vessel owner or operator must ensure that they maintain one English language copy of the VRP, … and a copy of the Coast Guard approval letter, onboard the vessel. PSCO were informed that there is no VPR on board, digital or on paper. 33 CFR 155.5030(g)(1)

Every ship other than an oil tanker of 400 gross tonnage and above shall carry on board a shipboard oil pollution emergency plan approved by the Administration. Vessel does not have on board a current SOPEP approved by their current administration. MARPOL (11 Cons.) Annex I / Reg. 37.1

The company should establish procedure to ensure that the ship is maintained in conformity with the provisions of the relevant rules and regulations and with any additional requirements which may be established by the company. Due to the objective evidence in the below deficiencies, the vessel is not in substantial compliance with relevant conventions, calling into question the adequacy and implementation of the vessel’s SMS under the ISM code. PSCOs collected objective evidence that the vessel is submitting request to the company for maintenance and repair support but could not find evidence of the company taking actions to support the vessel’s request. Requested support and repairs include the non-fully functioning main steering gear, inoperable HF radio, inoperable two-way VHF portable radios , inoperable rescue boat motor, and the non-fully functioning AIS. In all cases, the vessel could not produce evidence that the vessel or company notified their Recognized Organization or Flag Administration of the serious safety deficiencies. External Audit required. 74 SOLAS (2020 CONS) Ch. IX/3.1 / ISM Code Part 10.1 30bc

The hull, machinery and equipment of a cargo ship shall be surveyed on completion and thereafter in such manner and at such intervals as the Administration may consider necessary in order to ensure that their condition is in all respects satisfactory. Vessel’s Safety [name withheld] states the vessel was found to comply with the relevant requirements of the convention during the latest survey conducted on 16JUN2021. PSCO observed, in addition to the listed deficiencies, severe substandard conditions to include substantial water intrusion into the forward starboard side void space, an approximate 4 inch by 8 inch hole in the tank top of the ballast tank located starboard side engine room, inoperable high level bilge alarm, inoperable valves within the ballast water manifold system, soft piping patches on cooling water piping for main engine and diesel generator, inoperable ventilation system for engine room, and the raw water valve for generator No. 1 has a screw being used to stop a leak coming from the side of the valve. 60 SOLAS Ch. I/10 30abc

Every oil fuel suction pipe from a storage, settling or daily service tank situated above the double bottom shall be fitted with a cock or valve capable of being closed from outside the space concerned in the event of a fire…Vessel’s quick closing valves are not capable of being closed from outside the machinery space. 60 SOLAS CH. II/ Reg. 69(c) 30bc

Ships shall be provided with a main steering gear and an auxiliary steering gear to the satisfaction of the administration. Ships main steering tiller control is not operational causing the use of the auxiliary operation as the main steering method. 60 SOLAS CH. II/ Reg. 29 (a)(I) 30bc

…Every ship engaged on voyages beyond sea areas A1 and A2, but remaining within sea area A3… be provided with: an MF/HF radio installation capable of transmitting and receiving, for distress and safety purposes, on all distress and safety frequencies. Vessel’s HF radio will not turn on making it inoperable. 74SOLAS (2020 CONS) Ch. IV/10.2.1 30bc

All required fire detection systems shall be capable of automatically indicating the presence or indication of fire and also its location. Indicators shall be centralized either on the bridge or in other control stations which are provided with a direct communication with the bridge. Vessel does not have installed a fire detection system that can provide the indication of a fire and its location at a centralized location. 60 SOLAS Ch. II/61(a) 30bc

Cargo Ships shall carry at least one rescue boat complying with the requirements of section 5.1 of the CODE. Vessel’s rescue boat is not operational due to the motor unable to start. 74 SOLAS (2020 CONS) Ch. III/31.2 30bc

All electrical apparatus shall be so constructed and so installed that danger of injury in ordinary handling shall not exist. PSCO observed numerous electrical hazards throughout the vessel including but not limited to electrical equipment missing protective covers, exposed wiring and unapproved splicing. 60 SOLAS Ch. II/27(a)(i)(1) 30bc

At least 3 two-way VHF radiotelephone apparatus shall be provided on every passenger ship and on every cargo ship of 500 gross tonnage and upwards. All three of the vessels two-way VHF portable radios are not operational. 74SOLAS (2020CONS) III/6.2.1.1 30bc

Pipes conveying oil or combustible liquids shall be of a material approved by the administration having regard to the fire risk. Sight glass on fuel oil day tank and settling tank have sections broken with flexible hose used to replace the missing sections. 60 SOLAS Ch. II/49(b) 17bc

Ships shall be fitted with two means of communicating orders from the bridge to the engine room. One means shall be an engine room telegraph. Communication with the engine room and steering gear room from the bridge was nonexistent. Additionally, the crew’s hand held radios did not work. 60 SOLAS CH. II/ Reg. 33 17bc

AIS shall: provide automatically to appropriately equipped shore stations, other ships and aircraft information, including the ship’s identity, type, position, course, speed, navigational status and other safety-related information. Vessel’s AIS does not transmit the required vessel’s information. 74 SOLAS (2020 CONS) Ch. V/19.2.4.5.1 17bc

An initial survey before the ship is put in service or before the Certificate required under regulation 7 of this Annex is issued for the first time, which shall include a complete survey of its structure, equipment, systems, fittings, arrangements and material in so far as the ship is covered by this Annex. This survey shall be such as to ensure that the structure, equipment, systems, fittings, arrangements and material fully comply with the applicable requirements of this Annex. Vessel’s International Oil Pollution Prevention Certificate Form B, issued on 11FEB2022, states that the Oil Residue and Sludge tanks both have capacities of 15.20 cubic meters. PSCO observed actual size of both tanks to be substantially smaller. MARPOL (17 CONS) Annex I/ Reg. 6.1.1 17bc

The master, owner, operator, agent, or person in charge of any vessel equipped with ballast water tanks that operates in the waters of the United States must follow these practices…Maintain a ballast water management (BWM) plan that has been developed specifically for the vessel. Vessel does not possess a BWM plan. 33CFR151.2050(g) 40bc

CONTRACTING GOVERNMENTS UNDERTAKE EACH FOR ITS NATIONAL SHIPS TO MAINTAIN OR IF IT IS NECESSARY TO ADOPT MEASURES FOR THE PURPOS OF ENSURING THAT FROM THE POINT OF VIEW OF SAFEY OF LIFE AT SEA, ALL SHIPS SHALL BE SUFFICIENTLY AND EFFICIENTLY MANNED. VESSEL CURRENTLY ONLY HAS 01 LICENSED MARINER ONBOARD. 74 SOLAS (14 CONS) CH. V/ 14.1

03104- Cargo & Other Hatchways- The means of securing and maintaining weather tightness shall ensure that the tightness can be maintained in any condition. Cargo hatch covers are wasted and not weather tight. -ICLL 66 ANNEX 1/Reg.16.4

14102- Pollution Prevention- Every ship of 400 GT and above shall be provided with an oil record book. The oil record book shall be kept in the form specified in appendix III to the annex. Oil record book entries did not reflect sludge tank capacities listed in the IOPP. -MARPOL ANNEX I/17.2.3

03102- Water/Weathertight Conditions- The lines which indicate the load line assigned in accordance with these regulations...forward of the centre ring. Load lines are located aft of the centre ring on port side. -ICLL66 ANNEX I/6.1

The coamings of hatchways closed by portable tarpaulins and battening devices shall be of substantial construction. Cargo hatchway coamings are bent or wasted preventing weathertight seal when closed. ICLL (66) I/15(1).

One or more embarkation ladder to afford access to survival craft shall be included. Vessel has a pilot ladder in place of starboard side embarkation ladder. CCSS 4.10.1.2.1

RESCUE BOATS SHALL BE OF SUFFICIENT STRENTH. PSCO OBSERVED DAMAGE TO FORWARD PORT SIDE OF HULL ALLOWING WATER INGRESS. DEWATERING PUMB BELLOWS IS WASTED AND INOPERABLE. CCSS 4.10.2.3

ONE OR MORE EMBARKATION LADDER TO AFFORD ACCESS TO SURVIVAL CRAFT SHALL BE INCLUDED. EMBARKATION LADDER IS REPAIRED WITH SYNTHEDIC LINE AND SECURED TO SHIP WITH OVERHAND KNOTS. CCSS 4.10.1.2.1

OIL RECORD BOOK PART I SHALL BE COMPLETED ON EACH OCCASION WHENEVER ANY OF THE FOLLOWING MACHINERY SPACE OPERATIONS TAKES PLACE ON THE SHIP TO INCLUDE COLLECTION AND DISPOSAL OF OIL RESIDUES. PSCO OBSERVED INCONSISTENCIES BETWEEN SLUDGE TANKS IDENTIFIED ON IOPP AND TANKS BEING SOUNDED WEEKLY ON THE OIL RECORD BOOK. IOPP LISTS TWO SLUDGE TANKS, HOWEVER ORB ONLY DOCUMENTS SOUNDINGS OF ONE SLUDGE TANK ON A WEEKLY BASIS. MARPOL (2017 CONS) I/17.2.3

EVERY SHIP 400GT AND ABOVE SHALL BE PROVIDED WITH A GARBAGE RECORD BOOK....EACH DISCHARGE INTO THE SEA OR TO A RECEPTION FACILITY SHALL BE RECORDED. PSCO OBSERVED MULTIPLE INACCURACIES BETWEEN ENTRIES TO THE GRB AND AVAILABLE RECEIPTS. MARPOL (17 CONS) V/10.3.1

THE OWNER OR MASTER OF EVERY SHIP TO WHICH THIS CODE APPLIES SHOULD ENSURE THAT...AFTER ANY SURVEY OF THE SHIP UNDER 1.10...NO SIGNIFICANT CHANGE SHOULD BE MADE TO THE EQUIPMENT WITHOUT THE PERMISSION OF THE ADMINISTRATION. THE CCSSC ISSUED 17FEB19 STATES THAT THE BNWAS AND ECHO SOUNDER ARE TO BE INSTALLED. [name withheld] AND ECHO SOUNDER WERE INSTALLED. CCSSC 1.11.2

THE COMPANY SHOULD ESTABLISH PROCEDURES TO ENSURE THE SHIP IS MAINTAINED IN CONFORMITY. SEVERAL REPORTED CONCONFORMITIES DATES AS FAR BACK AS 06JAN19 REMAIN OPEN WITH NO CORRECTIVE ACTIONS. 74 SOLAS (14 CONS) IX/3.1 ISM CODE 10.1

IN LIEU OF MEETING REQUIREMENTS FOR TWO MF.HF DSC, VESSELS CAN BE FITTED WITH AN INPARSAT. VESSELS INPARSAT IS INOPERABLE. MF RADIO IS UNABLE TO RECEIVE SIGNALS. CCSS 5.1.2.1

THE STRENGTH AND CONSTRUCTION OF HULL, SUPERSTRUCTURES....SHALL BE OF SUFFICIENT STRENTH TO WITHSTAND ALL FORSEEABLE CONDUTIONS OF INTENDED SERVICE. SEVCERAL SHARP INSETS IN BOW OF 1'X8". TWO SHARP INSETS IN PORT SIDESHELL 1'X4" DEEP. GUARDRAILS WASTED IN SEVERAL AREAS. CCSS 2.4.1

ALL VESSELS SHALL COMPLY WITH COLREGS. MAST IS WASTED AND NOT IN PLACE. MISSING NOT UNDER COMMAND LIGHTS. CCSS 6.2.1

CO2 EXTINGUISHES SHALL BE EXAMINED...ANNUALLY. ANNUAL SERVICE REPORT IS OVERDUE. CCSS 3.6.8.2

Each production device must be legibly marked with the information in 33 CFR 159.55. Installed sanitation device does not have an approval plate installed. 33 CFR 159.55.

An IOPP shall be issued in accordance with the provisions of reg. 6 of this Annex. The Chief Engineer states that the IOPP has been issued with incorrect sludge tank capacities. IOPP identifies capacity as 3.16 m3. Chief Engineer states capacity is 1.76 m3 as stated in ORB. MARPOL (17 Cons.) Annex I/7.1

The view of the sea surface from the conning postion shall not be obscured by more than 2 ship lengths or 500m whichever is less. Cargo is loaded too high. obstructing visibility of the sea surface forward of the bow 74 SSOLAS(14 CONS) CHAPTER V REG 22.1.1, CCSSC CH 6.2 17C

0925-CCSSC ch 4.17.5- Every crew memeber shall be familiar with the use of the ships lifesaving appliances, including survival craft equipment, firefighting equipment, and emergency procedures before voyage begins. During fire drill, crew could not locate firefighting equipment . In addition, the emergency fire pump was covered with cargo. During abandon ship drill, crew could not locate lifesaving appliances.

0220-STCW (2011) Reg 1/2.11- Any certificate required by the convention must be kept available in its original form on board the ship on which the holder is serving. Master and Chief Mate could not provide endorsement or receipt of appliaction for flag endorsement.

0999- CCSSC cg. 2.12.8- In addition to complying with the provisions of this section, every ship shall comply with any other requirements which, in the opinion of the administration are deemed necessary to prevent accidents at sea and to maintain appropriate living and working conditions. Cargo found to be stowed in crew galley, crew berthing, and crew bathrooms. In addition, Cargo stowage on external working decks severely restricts movement to lifesaving and firefighting appliances both fore and aft.

1550-CCSSC ch 6.2.1- All vessels shall comply with the requirements of the International Regulations for Preventing Collisions at Sea, (1972). Ships whistle was found to be inoperable.

0150 - Documentation - The IOPP Certificate shall be drawn up in the form corresponding to the model given in appendix II. The vessel's IOPP Form A does not properly identify the 3.1 tanks and tank capacities onboard the vessel. - MARPOL(2011) Annex I/Reg. 9

2500 - ISM related deficiencies - Objective evidence discovered during an expanded ISM exam revealed the following nonconformities: The vessel failed to fully implement the requirements of the ISM Code through their SMS procedures as evident by the following deficiencies indicating that the ship and/or company are not meeting the SMS requirements. Recommend an external audit. - 74SOLAS(2014 CONS)IX/3.1 ISM Code Part A No. 1 - The company should ensure that the master is fully conversant with the company's safety management system. Vessel's master could not readily produce the safety management system when asked by the PSCO and was unfamiliar with the ship’s SMS procedures - ISM Code 6.1.2 No. 2 - The company should ensure that each ship is manned with qualified, certificated and medically-fit seafarers in accordance with national and international requirements. One of the vessel's required navigational watch stander’s II/4 STCW certificate expired in 2016. - ISM Code 6.2.1 No. 3 – The company should establish procedures to ensure that the ship is maintained in conformity with the provisions of the relevant rules and regulations and with any additional requirements which may be established by the company. SMS. In accordance with the SMS, the lifesaving and firefighting equipment shall be maintained on a weekly and monthly basis; the engine room maintenance shall be conducted monthly. Vessel is not properly conducting and recording required maintenance of machinery installations, life-saving equipment, and fire-fighting equipment. The last recorded deck maintenance for life-saving and fire-fighting equipment was completed in January 2018 and the last recorded engine maintenance was completed in November 2017. - ISM Code 10.1

0199 - Other (certificate) - A certificate, called a Safety Management Certificate, shall be issued to every ship by the Administration or an organization recognized by the Administration. Vessel’s Safety Management Certificate was issued by Conarina on behalf of The Republic of Bolivia, and the vessel’s Administration is Republic of Tanzania. - 74 SOLAS (2014 Cons.) IX/4.2

0220 - Certificates of competency - Failure to comply with applicable safe manning requirements of the administration. The vessel is not manned per the safe manning certificate; currently has and sailed its last voyage with a navigational watchstander that does not hold a valid STCW certificate. The watchstander’s certificate expired in 2016. - 78 STCW (11 Cons.)Annex 1/Reg 1/4.2.2

1710 - Oil Record Book - The Oil Record Book, whether as part of the ship's official log-book or otherwise, shall be in the form specified in appendix III to this Annex. Tanks listed in item 3.1 of Form A of the Supplement to the IOPP certificate were not being recorded weekly. - MARPOL (2011)Annex 1/Reg. 17.1

1710 - Oil record book - Each completed operation shall be signed by the officer or officers in charge of the operations concerned and each completed page of the Oil Record Book shall be signed by the Master of the ship. Multiple pages were not signed by the Master. - MARPOL (2011)Annex 1/Reg. 17.4

1705 - SOPEP missing - Every ship other than an oil tanker of 400 gross tonnage and above shall carry on board a shipboard oil pollution emergency plan approved by the Administration. Vessel did not have a shipboard oil pollution emergency plan on board. - MARPOL (2011)Annex 1/Reg. 37.1

0163 - Bunker Delivery Notes - The bunker delivery note shall be kept on board the ship in such a place as to be readily available for inspection at all reasonable times. Vessel could not produce bunker delivery notes for fuel deliveries on 2/24/18 and 3/20/18. - MARPOL (2011)Annex 1/Reg. 18.6

1623 - MF/HF radio installation - Every ship engaged on voyages beyond sea area A1 shall be provided with an MF radio installation. The MF/HF Radio was removed after water leaked onto the equipment and no replacement was provided. - 74 SOLAS (2014 Cons.)IV/9.1.1

1680 - Radio log - A record shall be kept, to the satisfaction of the Administration and as required by the Radio Regulations, of all incidents connected with the radio communication service which appear to be of importance to safety of life at sea. Vessel has not conducted required weekly and monthly GMDSS equipment tests. Last recorded test was on 28 February 2018. - 74 SOLAS (2014 Cons.)IV/17

1430 - Auxiliary Engines - A self-contained emergency source of electrical power shall be provided. Vessel's emergency generator is inoperable and could not be started. - CCSS Code Ch. 2/Reg. 2.29.1

1410 - Propulsion main engine - Sufficient power for going astern shall be provided to secure proper control of the ship in normal circumstances. Vessel's main engine was reported to have reduced propulsion due to faulty blower. - CCSS Code Ch. 2/Reg.2.31.1

0740 - Pumps - Every ship shall be provided with at least one independent power-operated fire pump capable of delivering a jet of water. Vessel's main fire pump is inoperable and could not be started. - CCSS Code Ch.3/Reg.3.3.1.1

0740 - Pumps - The emergency fire pump shall be capable of producing at least a jet of water. Vessel's emergency fire pump could not take suction and produce a jet of water. - CCSS Code Ch.3/Reg.3.3.7.2

0725 - Fixed fire extinguishing installation - In every ship, spaces containing main or auxiliary oil-fired boilers or fuel oil units, shall be provided with a fixed gas fire extinguishing system complying with the provisions of the FSS Code. The piping for the distribution of fire-extinguishing medium shall be arranged and discharge nozzles so positioned that a uniform distribution of the medium is obtained. The vessel’s fixed CO2 system is disassembled in the CO2 space and not able to properly function. - CCSS Code Ch.3/Reg.3.10.1.1 FSS Code Ch. 5 Reg. 5.2.1.2.1

2055 - Manuals instructions - Instructions concerning the maintenance and operation of all the equipment and installations on board for fighting and containment of fire shall be readily available in an accessible position. Vessel did not have operating instructions posted or readily available for fixed CO2 firefighting system. - CCSS Code Ch. 3/Reg.3.13.3

0699 - other - All ships shall be provided with a minimum of two EEBDs. None of the EEBDs in the engine room are charged. - CCSS Code Ch.3/Reg.3.15.1

9800 - Other (clearly Hazardous) - Every oil fuel pipe, which, if damaged, would allow oil to escape from the storage, settling or daily service tank situated above the double bottom shall be fitted with a cock or valve constructed of similar material to that of the tank, directly on the tank capable of being closed from a safe position outside the space. Both fuel tank quick closing valves were unable to be closed from outside of the space. - CCSS Code Ch.3/Reg.3.20.2.3

9900 - other (not clearly hazardous) - Other means of ascertaining the amount of oil fuel contained in any fuel tank may be permitted, provided that the failure of such means or overfilling of the tanks will not permit release of fuel. The sight glass self-closing valves for fuel tanks were tied in the open position allowing the possibility of fuel to leak freely from the sight-glass. - CCSS Code Ch.3/Reg.3.20.2.4

0615 - Rescue Boats - Life-saving appliances shall comply with the technical specifications of the LSA Code. All rescue boats shall have rigid hulls and shall be capable of maintaining positive stability when in upright position. Vessel's rescue boat hull had a 3 inches crack on the forward port side under the support bracket. - CCSS Code Ch. 4/Reg.4.3.1 LSA Code 5.1.1.1

0696 - Record of inspections/maintenance - Every inflatable liferaft shall be serviced at intervals not exceeding twelve months. Master could not produce the servicing certificate for the starboard side liferaft and could not prove annual servicing was completed. - CCSS Code Ch.4/Reg.4.7.1.1

0618 - Stowage of rescue boats - Rescue boats shall be stowed in a state of continuous readiness for launching in not more than 5 min. The rescue boat davit could not fully swing the davit arm, preventing the boat from clearing the vessels rails, inhibiting the vessel's crew from launching the rescue boat within the required time. - CCSS Code Ch.4/Reg.4.9.8.1

0650 - Lifebouys - At least half the number of lifebuoys referred to in 4.12.1 shall be fitted with self-igniting lights. Starboard lifebuoy light could not illuminate. - CCSS Code Ch.4/Reg.4.12.2

2020 - Fire drills - In all ships, training in the emergency instructions shall be carried out at least once per month. Vessel has not conducted fire and abandon ship drills since February 2018. - CCSS Code Ch.4/Reg.4.17.5

0925 - Musters and drills - Every crew member shall be familiar with the use of the ship’s lifesaving appliances, including survival craft equipment, fire-fighting equipment and emergencies procedures before a voyage begins. Crew members were unfamiliar with fire-fighting equipment and muster station location and could not successfully complete a fire and abandon ship drill. - CCSS Code Ch.4/Reg.4.17.5

1673 - VHF EPIRB - The EPIRB shall be capable of floating free if the ship sinks and of being automatically activated when afloat. The EPIRB has a liferaft hydrostatic release instead of the proper EPIRB hydrostatic release. - CCSS Code Ch.5/Reg.5.3.3.3

1560 - Charts - All vessels shall carry up-to-date charts, appropriate for the intended voyage, of a large enough scale to enable safe navigation. Vessel does not have up to date nautical charts. The most current charts onboard for the area are dated 2016 and no chart corrections have been made. - CCSS Code Ch.6/Reg.6.3.1

9900 - Other (not clearly hazardous) - The master, owner, operator, agent, or person in charge of any vessel equipped with ballast water tanks that operates in the waters of the United States must follow these practices: Maintain a ballast water management (BWM) plan that has been developed specifically for the vessel and that will allow those responsible for the plan's implementation to understand and follow the vessel's BWM strategy and comply with the requirements of this subpart. Vessel was unfamiliar with BWM procedures and could not produce a BWM plan. - 33 CFR 151.2050(g)

0199 - Other (certificate) - NTVRP Qualified Individual notification exercises must be conducted quarterly. Crew was unfamiliar with and could not provide proof of any Qualified Individual notification. - 33 CFR 155.1060(a)(1)

0199 - Other (certificate) - The vessel owner or operator must ensure they maintain one English language copy of the VRP onboard the vessel. Vessel does not have the approved a Non-Tank Vessel Response Plan onboard. - 33 CFR 155.5030(g)(1)

1740 - Oil discharge monitor/control system - Each loading arm and each transfer pipe system, including each metallic hose, must be tested annually. The vessel has no record of having ever conducted annual pressure test of transfer pipes required by 156.170(f)(3). - 33 CFR 156.170(c)(4) - Prior to bunkering in the U.S.

1740 - Oil discharge monitor/control system - The vessel operator of each vessel required by 155.720 to have transfer procedures shall maintain them current and shall require vessel personnel to use the transfer procedures for each transfer operation. Vessel's crew was unaware of onboard transfer procedures. - 33 CFR 155.730

The lines which indicate the load line assigned in accordance with these regulations shall be forward of the center of the ring. The lines are currently aft of the center of the ring on the port side. ICLL 66 Annex I/Reg. 6(1). Action taken 17bc.

The master shall ensure that the frequency of enclosed spaces drills shall not exceed quarterly. According to last documented drill on vessel records; enclosed space drills were last conducted March 2017.

For each ship, details of fuel oil for combustion purposes delivered to and used on board, shall be recorded by means of a bunker delivery note that shall contain at least the information specified in Appendix V to this Annex. Bunker delivery notes are missing sulfur content percentage. MARPOL (11 CONS.)Annex VI/Reg. 18.5. Action taken 40bc

The bunker delivery note shall be accompanied by a representative sample of the fuel oil delivered taking into account guidelines developed by the organization. No fuel samples present for previous 2 bunkering evolutions. MARPOL (11 CONS.) Annex VI/Reg 18.8.1. Action taken 40bc.

The rings, lines, and letters shall be permanently marked. All letters for load line are not permanent. ICLL 66/88 Annex I/Reg.8. Action taken 40bc.

The master, owner, operator, agent, or person in charge of a vessel subject to this section must retain a signed copy of this information onboard the vessel for 2 years. The vessel was unable to produce a ballast water record or log book for previous 2 years to present date. 33 CFR 151.2070 (b). Action taken 40bc.

Oil content meter on board is not operational. MARPOL Anex I/Reg 14.6 25bc

Crew was unfamiliar with fire fighting equipment and was unable to properly don the SCBA mask. CCSSC CH 4/Reg 4.17.2 25bc

Connection provided on board is not in compiance with the regulations. MARPOL Annex I/Reg 13 40bc

Main deck aft hatch is missing portion of the gasket. CCSSC CH 2/Reg 2.7.4 40bc

Fire door leading into the machinery space is missing door handle and the opening is plugged with a rag. CCSSC CH 3/Reg 3.16.5.8 40bc

Each Administration shall ensure that seafarers are familiarized with their specific duties, ship arrangement, installation, equipment, and procedures relevant to their routine or emergency duties. Chief Engineer on board vessel was found not to be familiar with engine room general arrangement as well as routine operation of vessel equipment. 78 STCW (11 Cons) Reg. I/14.1.5

Oil filtering equipment shall be of a design approved by the administration, having regard for the specifications recommended by the Organization. No alarm is activated when Oil Content Meter detects a OCM above 15ppm as required. Additionally, vessel has no procedures for testing of Oily Water Separator and OCM. MARPOL 2011 Annex I/Reg. 14.6

All Ships shall be provided with a minimum of two EEBDs. Both EEBDs in engine room were found depleted. CCSSC 2015 Ch. 3 Reg. 3.15

Electrical installations shall be such that the safety of personnel and ship ship from electrical hazards will be assured Electrical wires were found loose and spliced, and well multiple electrical hazards were found throughout engine room. CCSSC 2015 Ch. 2 Reg. 2.26.1.3