MSC DORADO VIII

Objective evidence discovered during an expanded ISM exam revealed the following non-conformities. The vessel failed to fully implement the requirements of the ISM Code through their SMS procedures as evident by the following deficiencies. These non-conformities taken with the remaining material deficiencies discovered are evidence that the ship and/or the company are not meeting the SMS requirements. An external audit is required. No. 1 - In meeting these requirements, the company should ensure that any non-conformity is reported, with its possible cause, if known. On November 28, 2021 the aft window of the starboard lifeboat was damaged when lifting the lifeboat back into the davit. Damage requires full replacement of the window with no notification of the non-conformity... Vessel's SMS requires, "In the event of any shortfall or non-compliance with the Flag State or other requirements, the Master has to inform the Company immediately". Due to the objective evidence detailed 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. An external audit conducted by the Flag or RO 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 (2020) IX/3; ISM Code 10.2

Cargo ships shall carry one or more totally enclosed lifeboats complying with the regulations of section 4.6 of the Code of such aggregate capacity on each side of the ship as will accommodate the total number of persons on board. PSCO observed damage to rear window of starboard lifeboat which required its complete replacement. 74 SOLAS (2020) III/31.1.1.1

Each liferaft or group of liferafts shall be stowed with a float-free arrangement complying with the requirements of paragraph 4.1.6 of the Code so that each floats free and, if inflatable, inflates automatically when the ship sinks. The PSCO observed the painters for all four inflatable liferafts improperly connected. They were found tied to the liferaft racks, not the designated weak link on the hydrostatic release. 74 SOLAS (2020) III/20.2

Doors required to be self-closing shall not be fitted with hold-back hooks. However, hold-back arrangements fitted with remote release devices of the fail-safe type may be utilized. PSCO observed three (03) Class-B self-closing doors with tie-back and hold-backs. The identified doors are for the gymnasium, crew's mess room, and duty mess room. 74 SOLAS (2020) II-2/9.4.2.2

For any vessel that is equipped with ballast water tanks and bound for ports or places in the United States and not addressed in paragraphs (b)(1) and (2) of this section: Submit the ballast water report no later than 6 hours after arrival at the port or place of destination, or prior to departure from that port or place of destination, whichever is earlier. PSCO determined that NBIC report had not been made within the 6 hour window after arrival in port. 33 CFR 151.2060; 10c.

Adequate power ventilation shall be provided in enclosed spaces. The arrangement shall be such as to provide at least six air changes per hour in cargo spaces, based on an empty cargo space, and for removal of vapours from upper or lower parts of cargo space. Ventilation pipe on cargo hold #2 is extremely wasted and was disassembled by crew for repair. The crew will not be able to finish repairs until they discharge containers in Savannah, GA after calling NY. Vessel currently only has class 9 HM stowed in cargo hold 2. 74SOLAS(2004) II-2/19.3.4.1 50A

After any survey of the ship under regulations 7, 8, 9, or 10 has been completed, no changes shall be made in the structural arrangements, machinery, equipment, and other items covered by survey, without the sanction of the Administration. Changing room on the upper deck, as identified in Fire Control Plan and general arrangement, was converted to an electricl workshop without approval. 74SOLAS (2014) I/11(b) 50A

The Dangerous Cargo Manifest (DCM) must contain: An emergency responses telephone number as prescribed in part G of part 172. The number and description of packages (barrels, drums, cylinders, boxes, etc). The emergency response telephone number and description of packages were missing from the DCM. 49 CFR 176.30 (a) 4 and 4 50C