NAVIGATOR GENESIS

Ships in which carriage of flammable products is intended should be fitted with fixed dry chemical powder type extinguishing systems for the purpose of fighting fire on the cargo area. The systems should be capable of delivering powder from at least 2 hand hose lines to any part of the above-deck exposed cargo area including above-deck cargo piping. Vessel is currently in heel with 130 metric tons of propane, a flammable cargo. PSCOs observed that the #2 DCP hose station's hose is cracked and the #1 DCP hose station's N2 bottle is at 60 bar pressure, where 90 bar is required. Both of these items were noted during the 06JUN2018 shore-side servicing and remain uncorrected to date. 74 SOLAS 14 VII/13.1 REF IGC 93/11.4 07109 30 a/b/c

The safety management system should ensure compliance with mandatory rules and regulations [ISM 1.2.3.1]. The Company should ensure that for any non-conformities identified, appropriate corrective action is taken [ISM 10.2.3]. Vessel's COF authorizes 0.28 bar "at sea" and 0.45 bar "in harbor" MARV settings IAW IGC 4.2.6.4, 8.2.6.2, and 8.2.7. From review of the deck log book, vessel departed Point Lisas, Trinidad and Tobago at 2100 on 04DEC2018, but the "in harbor" setting was not removed until 0930 on 06DEC2018, while vessel was at sea in Caribbean enroute Houston. This provides objective evidence that "in harbor" MARVS were used at sea in direct violation of IGC 93/4.2.6.4. Vessel's MARV changing procedure, Document P23, states "the cargo tank is designed for a maximum internal pressure of 0.28 bar during sea condition. Therefore the set point of the safety relief valves should be adjusted down to 0.28 bar prior leaving harbour." As denoted in deficiency #1, the deficient condition of the DCP hose #2 and N2 pilot cylinder #1 was noted in 06JUN2018 technician's report, but no corrective action was taken. The fixed gas detection system has been operating erratically since 10OCT2018. The same was reported by the Chief Mate on many occasions, but appropriate corrective action has not been taken. 74 SOLAS 14 IX/3.1 REF ISM 1.2.3.1 and 10.2.3 15109 30 b/c

Gas detection equipment acceptable to the Administration should be provided. According to Salwico SW2020 manual, the operating panel must display, in clear text, the sampling point and last measured value. Fixed gas detection display is showing a variety of random symbols and characters, constantly changing, making the display not properly legible. Additionally, ship's drawing no. 015 for Hull Nos. 2351-2356, shows the system should be fitted with a ST600 catalytic sensor. The system is currently fitted with a GD 10 infrared sensor. Administration [or RO] to confirm that change in sensor is acceptable, and if so, drawing to be appropriately updated to reflect onboard equipment. 74 SOLAS 14 VII/13.1 REF IGC 93/13.6.1 06105 17 a/c

Maintenance, testing, and inspection of firefighting equipment shall be carried out based off the guidelines developed by the Organization [MSC Circ. 1432]. MSC Circular 1432 Section 8.2.4 requires that a sample of the dry powder be tested for moisture content every 2 years. Last DCP moisture analysis is from June 2016. DCP servicing was carried out in June 2018 but no moisture analysis of a sample was performed. 74 SOLAS 14 II-2/14.2.2 50c

Cargo compressor rooms should be fitted with mechanical ventilation systems. Provisions should be made to ventilate such spaces prior to entering the compartment. Mechanical ventilation inlets and outlets should be arranged to ensure sufficient air movement through the space to avoid the accumulation of flammable vapors and to ensure safe working environment, but in no case should the ventilation system have a capacity of less than 30 air changes per hour. Upon entering compressor room, PSCO noted little to no air flow. PSCOs noted no negative pressure/suction at mechanical exhaust point at the bottom of the compressor room. It was subsequently determined that a fire damper (on the mechanical extraction vent trunk on the roof of the compressor room) was closed and thus, although the mechanical extraction fan was running, no air was being mechanically extracted from the space. 74 SOLAS 14 VII/13.1 REF IGC 93/12.1 10c