ELAR TRADER

The condition of the ship and its equipment shall be maintained to confirm with the provisions of the present regulations to ensure the ship in all respects will remain fit to proceed to sea without danger to the ship or persons on board. While anchored, on 19 October 2022, the vessel was allided with on the starboard side causing visible damage to the hull near the unloaded water line.

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; in meeting these requirements, the company should ensure that: inspections are held at appropriate intervals; any non-conformity is reported, with its possible cause, if known; appropriate corrective action is taken. VOP-S-05 states in section 1.2, "Inspection and maintenance of life saving and fire-fighting equipment planning and performance of maintenance of the fire-fighting equipment is done as per 'planned maintenance schedule of life-saving and fire-fighting equipment (attachment 1)'." VOP and referenced Attachment 1 does not specify proper testing procedures for testing fixed fire detection systems. As dilineated in deficiency 02, crew does not have quipment to test fire detection. In addition, PSCE observed crew attempting to test heat detection with torch. When PSCE asked about SMS procedures, crew stated they did not have the correct part to test, but only ordered needed equipment today. VOP-E-04/A "Critical Equipment Testing Schedule" states and shows oily water separator: recirculation valve/pump stop shall be checked by C/E monthly. PSCE observed monthly checks did not include recirculation valves. As dilineated in deficiency 04, recirculation valve is inoperable with records of parts ordered in November 2021. Crew found ordered part onboard, though no plans for replacing were discussed or actions for replacement initiated. Crew has been testing system without flow. Recommend internal audit with a focus on testing procedures for fixed fire detection, and for testing Oily Water separator. Internal audit to be completed within 30 days. 74SOLAS(20) IX/3.1 ISM Code 10.1, 10.2.1, 10.2.2, 10.2.3 Action Taken: 705ac

Fire protection systems and fire-fighting systems and appliances shall be maintained ready for use; and fire-protection systems and fire-fighting systems and appliances shall be properly tested and inspected. PSCO observed crew unable to test fire detection systems. Crew stated there is no proper testing equipment onboard. 74SOLAS(14) II-2/14.1 Action Taken: 17ac 26AUG22: Vessel provided substantial evidence of their inability to obtain IR testing equipment. The requested part is already delivered in Port Everglades. Amended deficiency to next US port.

Doors required to be self-closing shall not be fitted with hold-back hooks. Howeer, hold back arrangements fitted with remote release devices of the fail-safe type may be utilized. PSCE observed hold back line on self-closing door in steering gear room, leading to Emergency Fire-pump. Cite: 74SOLAS(14) II-2/9.4.2.2 Action Taken: 10c

Oil filtering equipment referred to in paragraph 2 of this regulation shall comply with paragraph 6 of this regulation. In addition, it shall be provided with alarm arragements to indicate when this level cannot be maintained. The system shall also be provided with arrangements to ensure that any discharge of oily mixtures is automatically stopped when the oil content of the effluent exceeds 15ppm. In considering the design of such equipment and approvals, the Administration shall have regard to the specification recommended by the Organization. PSCO unable to verify operation of OWS due to inoperable recirculation valves. Crew tested alarm without flow, and when asked by PSCOs to test with flow, received high temperature alarm on OCM. Crew could not produce successful test with observable flow, and automatic stop. Cite: MARPOL I/14.7 Action Taken 17ac