MOMI ARROW

13101 - Propulsion and Auxiliary Machinery - The machinery, boilers, and other pressure vessels, associated piping systems and fittings shall be of design and construction adequate for the service for which they are intended. PSCO found a temporary repair to #5 cylinder using synthetic patch to stop leak from lube oil system. 74 SOLAS (04)II-1/26.1 - 15ac

07106 - Fire Safety - Fire protection systems and fire-fighting systems and appliances shall be properly tested and inspected. PSCO observed crew using improper testing equipment for heat detectors. crew was using a heat gun, which is not recommended for testing. 74 SOLAS(04) II-2/14.1.2 - 15ac

01 02108:The administration shall take appropriate steps to ensure uniformity in the implementation and application of the provisions of this part in respect of electrical installations. PSCO noted that electrical panel cover latch was broken and would not close properly within the port side forward BOSN hole. (SOLAS 14 III/40.2)

02 11117: Cargo ships shall carry not less than 12 lifebuoys (150 and under 200M) complying with the requirements of regulations 7.1 and section 2.1 of the code. PSCO noted two wasted lifebuoys. (SOLAS 14 III/32.1.1)

15109- Objective evidence discovered during an expanded ISM examination revealed the vessel failed to fully implement the requirements of the ISM Code through their Safety Management System (SMS) as evident in the identified major non-conformities listed in the deficiencies. An external audit is recommended. 74 SOLAS (14CONS) CH IX / Reg 3.1 ISM Code Part A 30 ABC

15109- The company should establish procedures, plans and instructions, including checklists as appropriate for key shipboard operations. The vessel’s SMS for the checking of portable fire extinguishers requires the extinguishers to be checked in accordance with the maker’s instructions. A maintenance log for firefighting appliances is being utilized to conduct monthly checks. The checklist requires the crew member to ensure the extinguisher is in its appropriate location as per the fire plan and in good condition. The maker’s instructions include more items to be checked monthly; due to the limited checklist that the vessel is using, the extinguishers are not being fully inspected as per the maker’s instructions. This led to the identification of 11 out of 31 fire extinguishers not ready for immediate use. 74 SOLAS (14CONS) CH IX / Reg 3.1 ISM Code Part A 7 30 ABC

15109- Every company should develop, implement and maintain a safety management system which includes instructions and procedures to ensure safe operation of ships. The vessel’s SMS does not include an inspection of portable fire extinguisher’s spare charges. The vessel is required to carry 21 spare fire extinguishers or charges, the vessel was able to produce 1 spare fire extinguisher that was within maker’s operating parameters and ready for immediate use. The other spares onboard were manufactured in 2009 and required to be taken out of service after 5 years from manufacturing date. 74 SOLAS (14CONS) CH IX / Reg 3.1 ISM Code Part A 1.4.2 30 ABC

15111- The Company should define and document the responsibility, authority and interrelation of all personnel who manage, perform and verify work relating to and affecting safety and pollution prevention. Kiddie fire extinguishers were recently inspected by crew on 31AUG2019 with no mention of them being out of parameter. Kiddie fire extinguishers were out of parameter as per manufacturer’s manual, rendering them inoperable. 74 SOLAS (14CONS) CH IX / Reg 3.1 ISM Code Part A 3.2 30 ABC

15109- Every company should develop, implement and maintain a safety management system which includes instructions and procedures to ensure safe operations of ships. The vessel’s SMS section S-09.10.01-2.2 states that maintenance shall be carried out in accordance with the maker’s instructions. The maker’s instructions were not provided to the vessel for the heat detectors installed on the vessel. 74 SOLAS (14CONS) CH IX / Reg 3.1 ISM Code Part A 1.4.2 30 ABC

15109- The company should ensure that all personnel involved in the company's SMS have an adequate understanding of relevant rules, regulations, codes and guidelines. PSCO observed that the crew was not familiar with regulations regarding the testing of heat detectors onboard the vessel. 74 SOLAS (14CONS) CH IX / Reg 3.1 ISM Code Part A 1.4.2 30ABC

15112- The annual survey shall include a general inspection of the structure, machinery and equipment referred to in paragraph (B)(I), to ensure that they have been maintained in accordance with regulation 11(A) and that they remain satisfactory for the service for which the ship is intended. A classification society survey was conducted on 02NOV2018 with no mention of expired and inadequate spare charges for fire extinguishers. Yamato fire extinguisher spare charges were found to be expired after August 2014. 74 SOLAS (14CONS) CH I / Reg 8(b)(iii) 30ABC

07108- Fire extinguishers shall be situated ready for use. PSCO observed a fire extinguisher next to the oil water separator whose pointer on pressure indicator was on white, indicating no pressure. As per Kidde maker’s instructions, an extinguisher with a pointer not on green pressure indicator is not ready for use. PSCO observed 8 Kidde fire extinguishers in the engine room, 1 Kidde fire extinguisher on the bridge, 1 Kidde fire extinguisher in the A-Deck passage way near the galley, and 1 Kidde fire extinguisher in the starboard lifeboat whose pressure indicators were on red. 74 SOLAS (04CONS) CH II-2 / Reg 10.3.2.4 30ABC

07110- Spare charges shall be provided for 100% of the first 10 extinguishers and 50% of the remaining fire extinguishers. The vessel is required to have 31 5 kilogram fire extinguishers on board the vessel as noted on Fire Control Plan. In addition, the vessel is required to carry 21 spare 5 kilogram fire extinguishers or charges. 8 of the required fire extinguishers onboard were Yamato brand and 23 of the required extinguishers were Kidde. The spare charges on board are only for Yamato fire extinguisher model SA-17NR and were manufactured in August 2009. The validity of the Yamato spare charge is five years per maker’s instructions. The vessel had zero spare extinguishers or charges for the Kidde brand fire extinguishers on board. All spare charges are expired, thus the vessel has zero spare charges or spare extinguishers on board. 74 SOLAS (04CONS) CH II-2 / Reg 10.3.3.1 30ABC

07106- The function of fixed fire detection systems shall be periodically tested by means of equipment producing hot air at the appropriate temperature. During the exam, PSCO observed crew was testing heat detector with a lighter, in which crew could not prove was the appropriate temperature for heat detectors installed on vessel. 74 SOLAS (04 CONS) CH II-2 / Reg 7.3.2 30ABC

14119- Means shall be provided to control leaks of flammable liquids. PSCO observed main engine cylinders 1, 2, 3, and 6 were leaking fuel oil from the high-pressure fuel pumps. Evidence of excessive leaking was found in the engine room. Diesel-soaked rags were found around the cylinders, unapproved plastic collection pans were installed for excessive diesel oil leaks creating a fire hazard, and the decking in the engine room near diesel leaks was slippery from the fuel. 74 SOLAS (04CONS) CH II-2 / Reg 4.1.1 30 ABC

14107- The system shall be provided with arrangements to ensure that any discharge of oily mixture is automatically stopped when the oil content of the effluent exceeds 15 ppm. During the exam, PSCO observed the three-way valve controlling the overboard discharge did not operate and stayed in the discharged overboard position after the oil content displayed 15 ppm and higher. MARPOL 73/78 ANNEX I / Reg 14.7 17AC

14503- Every ship of 100 gross tonnage and above, shall carry a garbage management plan which the crew shall follow. During deck walk, PSCO observed approximately 3 cubic meters of garbage located between cargo holds 3 and 4. Area where garbage was stored is not an authorized location as per the vessel’s garbage management plan. MARPOL 73/78 ANNEX V / Reg 10.2 17C

07120- The CSO must ensure consistency between security & safety requirements. The escape route from the steering gear room to the main deck is secured from the inside with no means of access from the outside. MSC Cir. 1120, unified interpretation 13.3.3 states locking arrangements for escape routes should be such that it does not obstruct escape and access. The emergency escape route from the main deck to the steering gear room is secured from the inside of the vessel by means of a latch and only able to be opened from inside of the vessel. 74 SOLAS (04CONS) CH II-2 / Reg 13.3.3 ISPS Code Part A Reg 11.2.11 50 AC

07199- Flammable liquid lockers shall be protected by an appropriate fire extinguishing arrangement approved by the Administration. PSCO observed eight flammable aerosol cans located in a storage locker with no fire extinguishing arrangements. 74 SOLAS (04CONS) CH II-2 / Reg 10.6.3.2 10C

0730 - Fire fighting appliances (general) - Firefighting appliances shall be kept in good working order and readily available for use. Two (2) 45-liter portable foam applicators had not been properly serviced. Last service date shown as December 2014. - SOLAS 74 (2009 Cons. Ed.) II-2/14.2.1.2. - 10c.

1720 - Control of discharge of oil - There are clear grounds that the crew is not familiar with essential shipboard procedures relating to the prevention of pollution by oil. Crew was unable to demonstrate proper operation of oil content meter recording function. - MARPOL 2011, Annex I/11.1 - 10c.