SILVER SKY

THE COMPANY SHOULD ESTABLISH PROCEDURES TO ENSURE THAT THESHIP IS MAINTAINED IN ACCORDANCE WITH THE PROVISIONS OF THE RELEVANT RULES AND REGULATIONS ESTABLISHED BY THE COMPANY. THE TECHNICAL AND OPERATIONAL NATURE OF THE DEFICIENCIES NOTED BELOW PROVIDE OBJECTIVE EVIDENCE OF A SERIOUS FAILURE OF THE IMPLEMENTATION OF THE ISM CODE. AND EXTERNAL AUDIT REPORT SATISFACTORY TO THE COAST GUARD MUST BE SUBMITTED PRIOR TO CLEARANCE OF THIS DEFICIENCY.74 SOLAS (20) IX/3 ISM CODE 10.1

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

THE SAFETY MANAGEMENT SYSTEM SHOULD INCLUDE PROCEDURES ENSURING THAT NON-CONFORMITIES, ACCIDENTS AND HAZARDOUS SITUATIONS ARE REPORTED TO THE COMPANY, INVESTIGATED AND ANALYZED WITH THE OBJECTIVE OF IMPROVING SAFETY AND POLLUTION PREVENTION. PSCO OBSERVED A LACK OF REPORTING OF NON-CONFORMITIES AS PER THE SMS. NON-CONFORMITY FORMS, CORRECTIVE ACTION REQUESTS, AND FOUND ISSUES IN THE ENGINE ROOM WERE NOT COMPLETED OR ROUTED UP TO THE COMPANY, NOR WERE THEY SENT TO COMPANY ON REQUIRED TIMELINE. KNOWLEDGE OF THIS SECTION OF THE SMS WAS HEAVILY LACKING IN THE CREW AND CAPATIN. 74 SOLAS (20)IX/3 ISM CODE 9.1

THE SAFETY MANAGEMENT SYSTEM SHOULD PROVIDE FOR MEASURES THAT THE COMPANY'S ORGANIZATION CAN RESPOND AT ANY TIME TO HAZARDS, ACCIDENTS AND EMERGENCY SITUATIONS INVOLVING ITS SHIP. PSCO OBSERVED EMERGENCY ESCAPE WITHOUT APPROPRIATE ROPE AND HARNESS PROVIDED INSIDE. ROPE WAS NOT MOUNTED ON UPLLEY SYSTEM INSTALLED, AND WAS INSTEAD LOOPED UNSECURED AROUND LADDER ARM, AND HARNESS WAS NOT AVAILABLE IN SPACE. 74 SOLAS (20)IX/3 ISM CODE 8.3

THE PURPOSE OF THIS REGULATION IS TO PREVENT THE IGNITION OF COMBUSTIBLE MATERIALS OR FLAMMABLE LIQUIDS. PSCO OBSERVED EXTENSIVE OIL COLLECTIONS IN ENGINE ROOM. PSCO OBSERVED SPRAYING OIL COMING FROM GENERATOR, LEAKING DIRTY OIL FROM #2 STEERING PUMP, BLACK OIL COLLECTED IN BARREL AND IN SINK WITHIN OIL PURIFYING ROOM, OIL COLLECTED IN CONTAINMENT AROUND TANKS, THICK BLACK OIL IN CONTAINMENT ABOVE THE INCINERATOR, AND OIL IN CONTAINMENT AND ON DECK FLOORS NEAR BILGE. ADDITIONALLY, PSCO OBSERVED DIRTY RAGS, SOME HEAVILY SOAKED WITH OIL, IN ALL SPACES WITHIN THE ENGINE ROOM, INCLUDING THE PURIFYING ROOM AND ECR. PSCO OBSERVED DIRTY AND CLEAN COMBUSTIBLE MATERIALS STORED THROUGHOUT ENGINE ROOM, AS WELL AS OTHER OILED COMBUSTIBLES (SHEETS, STRAPS, AND WOOD). OVERALL CLEANLINESS OF ENGINE ROOM WAS SUBSTANDARD. 74 SOLAS (20)II-2/4

THE MACHINERY, BOILERS, AND OTHER PRESSURE VESSELS, ASSOCIATED PIPING SYSTEMS AND FITTINGS SHALL BE OF A DESIGN AND CONSTRUCTION ADEQUATE FOR THE SERVICE FOR WHICH THEY ARE INTENDED AND SHALL BE SO INSTALLED AND PROTECTED AS TO REDUCE TO A MINIMUM ANY DANGER TO PERSONS ON BOARD. PSCO OBSERVED ALL THREE GENERATORS WITH BLACK OIL IN AND ON SURFACES OF CONTAINMENT; ON THE #3 GENERATOR, METAL SHEET WAS RIGGED TO THE SIDE OF THE GENERATOR USING ROPE TO KEEP SPRAY OF BLACK OIL FROM ESCAPING GENERATOR CONTAINMENT. PSCO OBSERVED LEAKING JACKET WATER ON THE M/E #2, 5, 7 CYLINDER HEADS, PRODUCING A STREAM OF SUSTAINED WATER TO CREATE AND ARC OF AROUND 90° OUTWARDS. PSCO OBSERVED INCINERATOR WITH HEAVILY WORN INSULATION ON THE DOOR, SO TO EXPOSE METAL WIRING. WEARING IN CENTER EXCEEDED 4 INCHES IN DEPTH. 74 SOLAS (20) II-1/26.1

ALL THE STEERING GEAR COMPONENTS AND THE RUDDER STOCK SHALL BE OF SOUND AND RELIABLE CONSTRUCTION TO THE SATISFACTION OF THE ADMINISTRATION. PSCO OBSERVED A STEADY LEAK OF BLACK OIL FROM ON THE #2 STEERING GEAR PUMP. CREW WAS UNABLE TO GET THE STEERING GEAR PUMP TO BECOME OPERATIONAL FOR OVER AN HOUR. REPAIRS WERE COMPLETED TO REGAIN FUNCTIONALITY, WITH CAUSE CLAIMED TO BE COUPLER ISSUE. TEMPORARY REPAIRS MADE, REQUEST CLASS CONFIRMATION. 74 SOLAS (20)II-1/29.2.1

AFTER ANY SURVEY UNDER ARTICLE 14 HAS BEEN COMPLETED, NO CHANGE SHALL BE MADE IN THE STRUCTURE, EQUIPMENT, ARRANGEMENTS, MATERIAL OR SCANTLING COVERED BY THE SURVEY, WITHOUT THE SANCTION OF THE ADMINISTRATION. PSCO OBSERVED REPAIRS BEING MADE TO THE EQUIPMENT AND TANKS AND ASSOCIATED SYSTEMS THAT WERE NOT APPROVED BY CLASS, INCLUDING REPAIRS DONE TO FUEL TANK USING EPOXY AND FIBERGLASS AND REPAIRS DONE TO A GENERATOR USING A METAL SHEET AND STRAPS, AND DUCT TAPE USED ON FLASHING INSTEAD OF FLASHING TAPE. ICLL ARTICLE 15

SPECIAL CONSIDERATION SHALL BE GIVEN TO THE DESIGN, CONSTRUCTION AND INSTALLATION OF PROPULSION MACHINERY SYSTEMS SO THAT ANY MODE OF THEIR VIBRATIONS SHALL NOT CAUSE UNDUE STRESSES IN THIS MACHINERY IN THE NORMAL OPERATING RANGES. PSCO OBSERVED MOUNT FOR THE EXHAUST SYSTEM FROM THE ENGINE THAT HAD COME LOOSE, AND ITEMS OF METAL AND WOOD HAD BEEN SHOVED BETWEEN THE MOUNTING PLATE IN AN ATTEMPT TO PREVENT VIBRATION RATHER THAN REPAIRS WERE MADE. 74 SOLAS (20) II-1/26.8

MAIN AND EMERGENCY SWITCHBOARDS SHALL BE SO ARRANGED AS TO GIVE EASY ACCESS AS MAY BE NEEDED TO APPARTUS AND EQUIPMENT, WITHOUT DANGER TO PERSONNEL. WHERE NECESSARY, NONCONDUCTING MATS OR GRATINGS SHALL BE PROVIDED AT THE FRONT AND REAR OF THE SWITCHBOARD. PSCO OBSERVED MISSING ELECTRICAL MATTING IN FRONT OF HIGH VOLTAGE PANELS IN PURIFYING ROOM. 74 SOLAS (20) II-1/45.2

AN EEBD IS A SUPPLIED AIR OR OXYGEN DEVICE ONLY USED FOR ESCAPE FROM A COMPARTMENT THAT HAS A HAZARDOUS ATMOSPHERE AND SHALL BE OF AN APPROVED TYPE. PSCO OBSERVED EEBD OVER-PRESSURIZED. WORKING PRESSURE MUST BE 21mpa AND BOTTLE WAS AT 24mpa. INSPECTION OF BOTTLE OCCURED 31MAY25. TRAINING CONDUCTED AND BOTTLE REPLACED WITH SPARE. CORRECTED ON THE SPOT. 74 SOLAS (20) II-2/13 FSS CODE CH.3/2.2.1.1

FIRE DOORS IN MAIN VERTICAL ZONE BULKHEADS, GALLEY BOUNDARIES AND STAIRWAY ENCLOSURES OTHER THAN POWER-OPERATED WATERTIGHT DOORS AND THOSE WHICH ARE NORMALLY LOCKED SHALL SATISFY THE FOLLOWING REQUIREMENTS; THE DOORS SHALL BE SELF-CLOSING AND BE CAPABLE OF CLOSING WITH AND ANGLE OF INCLINATION OF UP TO 3.5° OPPOSING CLOSURE. PSCO OBSERVED FIRE DOOR ON PURIFYING ROOM TO BE NON-FUNCTIONAL. DOOR LATCH WAS DAMAGED AND WOULD NOT LATCH SHUT UPON CLOSING. REPAIRED ON SCENE AND TESTED FOR OPERATION. 74 SOLAS (20) II-2/9.4.1.1.5.1

THE CONSTRUCTION OF DOORS AND DOOR FRAMES IN "A" CLASS DIVISIONS, WITH THE MEANS OF SECURING THEM WHEN CLOSED, SHALL PROVIDE RESISTANCE TO FIRE AS WELL AS TO THE PASSAGE OF SMOKE AND FLAME EQUIVALENT TO THAT OF THE BULKHEADS IN WHICH THE DOORS ARE SITUATED. THIS BEING DETERMINED IN ACCORDANCE WITH THE FIRE TEST PROCEDURES CODE. PSCO OBSERVED FIRE DOOR TO STEERING GEAR ROOM HAS GASKET HEAVILY WORN. REPAIRED ON SCENE AND TESTED FOR OPERATION. 74 SOLAS (20) II-2/9.4.1.1.2