SELECAO

Fire-fighting systems and appliances shall be kept in good working order and readily available for immediate use. Ship's crew failed to remove the metal blocking piece after testing the H.F.O. SERV. TK TO M/E & G/E F.O. SUPPLY P/P quick closing valve on 03DEC2018. Ship continued to utilize HFO with the metal blocking piece in place until switching over to low sulphur fuel on 25DEC2018. In the event of an engine room fire, the quick closing valve would not be able to fully close as designed and HFO would continue to be supplied potentially supporting the fire in the space. The remote actuator for the valve would be ineffective.

Any ship of 10,000 gross tonnage and above shall be fitted with oil filtering equipment complying with paragraph 7 of this regulation. The arrangement on board ship for the extraction of samples from the 15 ppm Bilge Separator discharge line to the 15 ppm Bilge Alarm should give a truly representative sample of the effluent with an adequate pressure and flow. Due to the missing seal on the sample line as required by the Company, PSCO had the crew secure the sample line by means of two manual valves preventing oil content meter from processing a true sample of effluent. PSCO observed the oily water separator continually process effluent overboard (overboard simulation valve) for over 5 minutes without adequate pressure and flow to the oil content meter. PSCO observed no alarms or any redirection of effluent.

All life-saving appliances and arrangements shall comply with the applicable requirements of the Code. An immersion suit shall be constructed with waterproof materials such that: it can be unpacked and donned without assistance within 2 min, taking into account donning of any associated clothing, donning a lifejacket if the immersion suit is to be worn in conjunction with a lifejacket to meet the requirements of paragraph 2.3.1.2, and inflation of orally inflatable chambers. PSCOs observed 04 crewmembers don the immersion suit to include the lifejackets. Only 01 crewmember was able to don the immersion suit within the required timeframe.

The company and the ship shall comply with the requirements of the ISM Code. The company should clearly define and document the master's responsibility with regard to implementing the safety and environmental-protection policy of the company. The ISM Company's "Standard Operating Procedure on Oily Water Separator" item 2.2.vii requires a seal that would break if the manual sample line valves were closed. PSCO observed no seals in place for the sample line valves as per Company policy. With no alarm arrangements or mechanism in place to ensure the OCM will analyze the actual effluent at all times when operational, securing the sample line valves in the open positions is critical to avoid willful manipulation of the OCM.

A tank vessel with a capacity of 250 or more barrels that is carrying oil or hazardous material as cargo must have on board an emergency means to enable the person in charge of a transfer operation to a facility, to another vessel, or within the vessel to stop the flow of oil or hazardous material. All the cargo pumps were running during the test of the emergency shutdown from the port side manifold. After the ESD was engaged (initial test), the #3 cargo pump continued to run with no alarms or trips.