SEAMELODY

The carriage of solid bulk cargoes other than grain shall be in compliance with the relevant provisions of the IMSBC Code, as defined in regulation VI/1-1.1. For quantitative measurements of hydrogen, phosphine and arsine, suitable detectors for each gas or combination of gases shall be onboard while this cargo is carried. Gas concentrations shall be measured during the voyage, at least once during every eight hours at each outlet ventilator and in any other accessible space adjacent to the cargo space carrying this cargo and the results shall be recorded in the log-book. PSCO found that the vessel sailed from Flushing, Netherlands to the United States without any gas detectors onboard. Vessel reported prior to entry that gas sampling was being conducted in accordance with IMSBC Code. 74 SOLAS (14) VII A-1/7.5 IMSBC Code 1.2

The Company should establish procedures, plans and instructions, including checklists as appropriate for key shipboard operations concerning the safety of the personnel, ship, and protection of the environment. Ship attempted to procure gas detectors prior to departure, but was told they would take 1 week to arrive. Vessel departed without meters and did not take gas samples as required during voyage. Referencing deficiency No.1 and after reviewing onboard documentation PSCO believes the company and ship fail to understand the importance of the requirements in the code in order to ensure the safety of the ship and crew. Vessel to conduct additional verification audit and provide completion of such to USCG. 74 SOLAS (14) IX / 3.1 ISM Code 7

Remove fouling organisms from the vessels hull, pipping, and tanks on a regular basis and any removed substances in accordance with local, state, and federal regulations. PSCO observed hull growth on hull and found report from 28 July 2018 indicating 50% growth rudder on hull and rudder. Master stated hull has not been cleaned since dry dock in 2016. Hull shall be cleaned prior to next us port call. 33 CFR 151.250(f)