TELENDOS

The safety management system should ensure compliance with mandatory rules and regulations. The company should establish procedures to ensure the ship is maintained in conformity with the relevant rules and regulations and any additional requirements established by the company. The vessel's COF authorizes .25 BAR "AT SEA" and .45 BAR "IN HARBOR" MARV settings. The vessel was detained after the attending PSC officer discovered that all cargo tank auziliary relief valves were improperly sealed to the pilot relief valves, preventing the proper changing from the cargo tank's "AT SEA" and "IN HARBOR" pressure relief valve settings as required by the COF, SOE and shipboard SMS procedures. Further interviews and statements from the chief officer verified that the relief valves had not been changed since they were last adjusted and pressure tested on 04 February 2015 by Lloyd's Register. *Based on the seriousness of this deficiency, and external or internal ISM audit is recommended.*

A permanently installed system of gas detection with audible and visual alarms shall be provided. Alarms should be activated when the vapor concentration reaches 30% LEL (or earlier). Testing and calibration should be carried out at regular intervals. When PSC officers requested to test the fixed gas detection, the crew calibrated with 50% LEL propane. The system uses a dilution pump due to a catalytic sensor being used and drawing samples from inerted spaces being monitored for gas concentrations. Due to using a 1:1 ratio of gas sample with the dilution pump, when the gas detection alarm panel reads 25% LEL gas concentration, it is equivilant to 50% LEL. On this ship, LEL alarms are set at 20% LEL (With High-High alarm at 30% LEL). When span gas (50% LEL) was applied to the sample point inside the cabinet, the panel alarmed at 20% LEL and stabilized at 35% LEL. WIth the calibration procedures and calculations needed due to the dilution pump, this alarm set point is equal to 40% LEL gas concentration and does not satisfy the IGC requirements of alarming when the vapor concetration reaches 30% LEL (or earlier). Recommend vessel carry out portable gas sampling with appropratite portrable equipment in accordance with IGC 13.6.12, if concurred with by the recognized organization, until proper alarm set points are able to be set.

THE SAFETY MANAGEMENT SYSTEM SHOULD ENSURE COMPLIANCE WITH MANDATORY RULES AND REGULATIONS [ISM 1.2.3.1]. THE COMPANY SHOULD ESTABLISH PROCEDURES TO ENSURE THE SHIP IS MAINTAINED IN CONFORMITY WITH THE RELEVANT RULES AND REGULATIONS AND ANY ADDITIONAL REQUIREMENTS ESTABLISHED BY THE COMPANY [ISM 10.1] VESSEL'S COF AUTHORIZES 0.25 BAR “AT SEA” AND 0.45 BAR “IN HARBOR” MARV SETTING IAW IGC 4.2.6.4, 8.2.6.2, AND 8.2.7. WHILE INSPECTING THE PILOT AND AUXILIARY RELIEF VALVES ON EACH TANK TOP, IT WAS DISCOVERED THAT THE “SET AND SEAL” FOR THE AUXILIARY (IN HARBOR) RELIEF VALVE WAS SECURED TO THE PILOT (AT SEA) RELIEF VALVE, PREVENTING THE TWO FROM BEING SEPARATED WITHOUT REMOVING THE “SET AND SEAL” WIRE OR THE TOP COUPLER FROM THE PILOT (AT SEA) RELIEF VALVE. THE SHIP’S OFFICIAL LOG DID NOT INDICATE THAT THE RELIEF VALVES WERE CHANGED AT EACH PORT VESSEL ENTERED AND DEPARTED. WHILE QUESTIONING THE MASTER AND [name withheld] RELIEF VALVE CHANGE PROCEDURES, THEY EACH STATED THAT THE RELIEF VALVE SETTING IS NEVER CHANGED FROM THEIR “IN HARBOR” SETTINGS WHILE THEY’RE AT SEA AND REQUIRED TO BE AT THE “AT SEA” SETTINGS. THE VESSEL PROVIDED DOCUMENTATION TO THE ATTENDING PSC EXAMINERS SHOWING THAT THE VESSEL RELIEF VALVES WERE LAST ADJUSTED AND PRESSURE TESTED ON 04 FEBRUARY 2015 BY LLOYD’S REGISTER. SHIPBOARD SMS, CARGO PLANT OPERATING MANUAL, REQUIRES RELIEF VALVES TO BE SET AND SEALED FOLLOWING SATISFACTORY TESTING AND ADJUSTMENTS (DOCUMENT NO. T-0655-N1).

GAS DETECTION EQUIPMENT SHOULD BE SO DESIGNED THAT IT MAY READILY BE TESTED. TESTING AND CALIBRATION SHOULD BE CARRIED OUT AT REGULAR INTERVALS. SUITABLE EQUIPMENT AND SPAN GAS FOR THIS PURPOSE SHOULD BE CARRIED ON BOARD. THE VESSEL ONLY HAD PROCEDURES IN PLACE TO CALIBRATE THE GAS DETECTION SYSTEM WITH NO PROCEDURES IN PLACE OR EQUIPMENT ONBOARD TO TEST THE GAS SAMPLING POINTS. WHEN ASKED TO TEST THE GAS DETECTION FROM A SAMPLING POINT, THE CREW USED AN UNAPPROVED PROPANE TORCH WITH UNKNOWN GAS CONCENTRATION.

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

ELECTRICAL INSTALLATIONS SHOULD BE SUCH AS TO MINIMIZE THE RISK OF FIRE AND EXPLOSION FROM FLAMMABLE PRODUCTS. UPON EXAMINATION OF THE COMPRESSOR ROOM, PSCO IDENTIFIED THE LIGHT OUTSIDE THE COMPRESSOR ROOM DOOR HAD STANDING WATER INSIDE THE GLASS ENCLOSURE. VESSEL IS REQUIRED TO ISOLATE THE LIGHT FROM THE ELECTRICAL CIRCUIT UNTIL REPLACEMENT IS AVAILABLE.

THE CHANGING OF THE SET PRESSURE SHOULD BE CARRIED OUT UNDER THE SUPERVISION OF THE MASTER IN ACCORDANCE WITH THE PROCEDURES APPROVED BY THE ADMINISTRATION AND SPECIFIED IN THE OPERATING MANUAL. THE CHANGES IN SET PRESSURES SHOULD BE RECORDED IN THE SHIP’S LOG. THE VESSEL DID NOT INDICATE IN THE SHIP’S LOG THE CHANGING FROM “AT SEA” TO “IN HARBOR” RELIEF VALVE SETTING PRIOR TO CONDUCTING CARGO OPERATIONS.

STBD lifeboat damaged and inoperable.