BBC NAPLES

FIRE PROTECTION SYSTEMS AND FIRE FIGHTING SYSTEMS AND APPLIANCES SHALL BE MAINTAINED READY FOR USE. PSCO WITNESSED A PIN INSERTED INTO CO2 CYLINDER, RENDERING IT INOPERABLE. [name withheld] UPON IDENTIFICATION. 74 SOLAS (20) 11-2/14.1.1

ELECTRICAL INSTALLATIONS SHALL BE SUCH THAT ALL ELECTRICAL AUXILARY SERVICES NECESSARY FOR MAINTAINING THE SHIP IN NORMAL OPERATIONAL AND HABITABLE CONDITIONS WILL BE ENSURED WITHOUT RECOURSE TO THE EMERGENCY SOURCE OF ELECTRICAL POWER. PSCO IDENTIFIED THE BACK OF THE MAIN ENGINE SWITCHBOARD IN THE ENGINE CONTROL ROOM WAS OFF AND HAD A FAN CRUDELY POSITIONED TO PREVENT OVER-HEATING. 74 SOLAS(09) II-I / 40.1.1

INTERNAL COMBUSTION ENGINES OF 2250KW AND ABOVE OR HAVING CYLINDERS OF MORE THAN 300MM BORE, SHALL BE PROVIDED WITH CRANK CASE OIL MIST DETECTORS. OIL MIST DETECTORS READ A "LOW AIR FLOW" ALARM AT ALL TIMES DURING INSPECTION. [name withheld] THIS IS STANDARD OPERATIONS FOR THE SHIP, WHICH IS CONTRADICTED IN SHIP'S SAFETY MANAGEMENT. 74 SOLAS (09) II-I/47.2

MEANS SHALL BE PROVIDED TO CONTROL LEAKS OF FLAMMABLE LIQUIDS. PSCO IDENTIFIED 02 LOCATIONS OF POOLING LUBE OIL COMING DIRECTLY FROM CONNECTION POINTS ON THE MAIN DIESEL ENGINE. 74 SOLAS(20) II-2/4.1.1

THE MACHINERY SHALL BE SO INSTALLED AND PROTECTED AS TO REDUCE TO A MINIMUM ANY DANGER TO PERSONS ON BOARD DUE REGARD BEING PAID TO MOVING PARTS, HOT SURFACES AND OTHER HAZARDS. PSCO IDENTIFIED MAIN ENGINE CRANK BEING EXPOSED WITHOUT A GUARD. 74 SOLAS(09) II-I/26.1

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: Appropriate corrective action is taken. As it relates to deficiency 02, the crew was originally questioned on the nature of oily water in the bilge well, and could not identify the source. It was later stated by the crew that the oily mixture was leaking from the main engine. 02 cookie cans were discovered in the bilge well intended to catch oil leaks, indicating that the crew was aware of the nature of the leaks prior to examination. Port State Control Officer (PSCO) also discovered oil mist detector (OMD) alarm activated on the main engine. Vessel's PMS stated that the crew should follow OMD's manufacturer instructions if alarms were activated. PSCO reviewed instructions and confirmed with the crew that instructions had not been followed when OMD alarm was received 03 times on 22AUG2022. PSCO also discovered the No. 2 generator disabled. The crew stated that the generator had been disabled due to a recurring alarm. Objective evidence exists for lack of corrective actions taken on deficient items and alarms discovered by the crew. An external ISM audit is required with a focus on fire safety and engine room maintenance. 74 SOLAS (20) IX/3.1 ISM Code 10.1 30ac

The purpose of this regulation is to prevent the ignition of combustible materials or flammable liquids. For this purpose, the following functional requirements shall be met: Means shall be provided to control leaks of flammable liquids. PSCO discovered a flowing pool of oily water spanning half of the engine room bilge. 74 SOLAS (04) II-2/4.1.1 30ac

Every ship of 400 gross tonnage and above shall be provided with a tank or tanks of adequate capacity. having regard for to the type of machinery and length of voyage, to receive the oil residues (sludge) which cannot be dealt with otherwise in accordance with the requirements of this Annex. Vessel has 02 tanks listed on the IOPP Form A for collection of sludge: Sludge Tank and Dirty Oil Tank. The Sludge Tank has a capacity of 7.76 cubic meters, and the Dirty Oil Tank has a capacity of 10.01 cubic meters. 22AUG2022 sounding indicated the Sludge Tank level to be 6.99 cubic meters and th Dirty Oil Tank level to be 9.02 cubic meters. The crew stated that 0.2 cubic meters of sludge is generated per day. Vessel intends to transit to Panama after departing Houston. 73/78 MARPOL I/12.1 60ac

Maintenance, testing and inspections shall be carried out based on the guidelines developed by the Organization and in a manner having due regard to ensuring the reliability of the fire-fighting systems and appliances. PSCO observed 02 fire detectors in the engine room missing covers. PSCO observed the Chief Engineer replace a fallen cover onto one of the fire detectors, but the cover would not stay fastened, resulting in the cover falling off and breaking. 74 SOLAS (04) II-2/14.2.2.1 50ac

A vessel equipped with ballast water tanks that operates in waters of the United States must maintain a ballast water management plan that has been developed specifically for the vessel and that will allow those responsible for the plan implementation to understand and follow the vessel's ballast water management strategy and comply with requirements of this subpart. Vessel's ballast water management plan does not include all of the necessary provisions listed in 33 CFR 151 Subpart D. U.S. Regulations not identified. 33 CFR 151.2050(g) 50ac

The master, owner, operator, agent, or persons in charge of a vessel subject to this part that is bound for ports and places in the United States outside of the Great Lakes or Hudson Rover must submit a ballast water report to NBIC no later than 06 hours after arrival at the port or place of destination. Vessel arrived at the dock at 1500 on 20AUG2022. PSCO's boarded the vessel at 1100 on 22AUG2022, more than 06 hours after arrival. No NBIC report had been submitted. 33 CFR 151.2060(b)(3) 10c

The company should establish procedures to ensure that the ship is maintained in accordance with the relevant roles and regulations and with any additional requirements which may be established by the company. In meeting these requirements the company should ensure that: any non-conformity is reported with its possible causes if known; and ensure appropriate corrective action is taken. A significant leak was found on the lube oil purifier that was being captured in a bucket, the smoke detector above it was operational but held in place with tape, and emergency escape and CO2 room were also found not to close properly. None of these items were reported to the company, low level hydraulic oil and power failure alarms for steering gear where inoperable and had not been tested or identified. Emergency diesel generator fuel cutoff was closed had not been identified rendering it unable to function in emergency. Operational deficiencies collectively provide objective evidence of a serious failure or lack of effectiveness of the implementation of ISM Code. An external audit is recommended to be conducted within 30 days by Flag State or RO. Provide decision to USCG prior to departure. -74SOLAS(14)IX/3.1 &ISM Code Part A 10 (17ABC)

Where the emergency source of electrical power is a generator, it shall be: started automatically upon failure of the main source of electrical power supply…PSCO found the FO quick closing valve to be in the closed position, not allowing for the emergency generator to start and run in current state. Engineers were able to open the valve and test functionality in presence of PSCO. 74SOLAS(04) II-1/43.3.1 (10c)

The Ignitability of combustible material shall be restricted. Lube oil purifier has a leak in associated piping of one drop per second that is being captured in a bucket. 74SOLAS(04) II-2/4.1.3 60AC

Hydraulic power operating steering gear shall be provided with... a low level alarm for each hydraulic reservoir... Audible and visual alarm shall be given on the navigation bridge and in the machinery space. Unable to verify proper operation of low level hydraulic alarm for either steering pump. Additionally PSCO were unable to verify operation of the steering gear's low voltage alarm. 74SOLAS(04) II-1/29.12.2 60AC

Doors fitted in boundary bulkheads of machinery spaces of category A shall be reasonably gastight and self-closing. Class A fire door for the engine room, purifier room, and class a fire door for the CO2 Room were unable to close properly. 74SOLAS(04) II-2/9.4.2.1 17AC

Fixed Fire Detection system installations shall be suitable for the nature of the space. Smoke detector above lube oil purifier was held in place with tape, but was operational during test. Improper installation of detector was not reported to company 74SOLAS(04) II-2/7.1.1 16AC

001 - 0725- SHIP SHALL KEEP FIRE FIGHTING APPLIANCES READILY AVALIABLE FOR IMMEDIATE USE. VALVE SUPPLYING WATER TO HYPER MIST SYSTEM WAS PARTIALLY CLOSED. -SOLAS 09 CONS II-2/14.2.1 - 10C