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Paints, coatings, or other flammable or combustible products on board a towing vessel must be stored in a designated storage room or cabinet when not in use. Discovered an excessive amount of oily water in the lazarette. 46 CFR 142.225(a)

At least two lifebuoys on a towing vessel greater than 26FT must be fitted with a floating electric water light approved under approval series 161.010 or 161.110. Starboard buoy light wxtinguished and found to contain unapproved battery type; port side bouy light battery found to be expired. 46 CFR 141.360(c)(2)

Carriage requirement. A towing vessel must carry a combination of day and night visual distress signals indicated in Table 141.370. Vessel is missing one day/night flare. 46 CFR 141.375(c)

Each integral fuel tank must have a vent that connects to the highest point of the tank, discharges on a weather deck through a bend of 180 degrees, and is fitted with a 30-by-30 mesh corrosion resistant flame scree. All four gooseneck vents to fuel tanks are not fitted with flame screens. 46 CFR 143.265(c)

Only the first page of the internal audit was included in HELM along with the Non-Conformities found. This is a repeat finding from an External Survey conducted on 17 September 2021. The Corrective Action taken to rectify this Non-Conformitywas found to be ineffective.

This is a repeat finding from an External Survey conducted on 1 July 2020. The Corrective Action taken to rectify this Non-Conformity was found to be ineffective. The TPO attended on 1 July 2020, 8 March 2021, and 17 September 2021. Thirteen (13) findings were found to be repeated during the audit conducted on 10 December 2021.There is evidence to indicate that the Company’s corrective action program is not performing as described in the Company’s TSMS. Two (2) Non-Conformities from the Survey conducted on 17 September 2021 remained open. These two (2) Non-Conformities havebeen closed administratively and added to this report.

If the cognizant OCMI has reasonable cause to believe that a vessel's survey program is deficient, that OCMI may: (a) Require an audit or survey of the vessel in the presence of a representative of the cognizant OCMI; (b) Increase the frequency of the audits; (c) For vessels under the internal survey program, require that the vessel comply with the external survey program requirements of § 137.205; (d) Require any other specific action within his or her authority that he or she considers appropriate; or (e) For repeatedly deficient surveys, remove the vessel and or owner or managing operator from using the TSMS option. An in-service inspection was conducted after reviewing the vessels internal survey report and observing multiple items listed on the report that appeared hazardous enough to require immediate action. In review of the TSMS it was noted that the company had up to 90 days to correct any non-conformities identified in the survey. This is not satisfactory since the multiple items noted pose a hazard to the vessel, crew, and the environment. MIs inquired about the internal survey report and how the items were being tracked. The items were being tracked by an electronic system, called HELM that the crew was not able to navigate efficiently. In expanding into the TSMS and noted sections regarding reporting marine casualties, accounting for pre-underway checks, accounting for daily/weekly machinery space checks, and procedures for reporting a Hazard/Unsafe condition. These items were not entered into HELM or otherwise logged. Previous visits to the vessel resulted in deficiencies and a detention due to failure of the above sections. Items noted in the survey also show non-conformities in regard to the above sections. The overall condition of the vessel show deficiencies in regard to the above sections. Requirements 2 through 7 (or 5 through 10 in MISLE deficiencies tab) are objective evidence that serious substandard conditions have not been proactively managed by the vessel’s owner/operator. Per 46 CFR 137.212, external surveys are required and shall be conducted biannually in the presence of a CG marine inspector.

Each towing vessel must comply with the requirements of part 4 of this chapter for reporting marine casualties and retaining voyage records. Vessel sustained a marine casualty to the port engine clutch and did not report to the Coast Guard as required. The owner/operator must notify the local OCMI for repair oversight.

Each towing vessel must be capable of preventing all oil spills from reaching the water. Due to a previous unreported marine casualty, the owner/operator is storing waste oil in a non-approved waste oil storage tank. Remove waste oil as required and make generator cooling water head tank functional and safe for operations.

All machinery and equipment that is not in proper working order must be made safe; or otherwise made unusable. Both shaft packing glands were leaking excessively, requiring constant pumping of water overboard to keep up with the leaking. Repack gland and make safe for operation.

Each towing vessel must comply with the requirement of part 4 of this chapter for reporting marine casualties. It was disclosed by the Master that the starboard main diesel engine was replaced due to an engine failure while the vessel was underway. This marine casualty was not reported.

The master is responsible for compliance with the non-conformity requirements of the TSMS. The master did not comply with the non-conformity reporting procedures as laid out in the TSMS applicable to the vessel. The TSMS states that the master must report non-conformities to the company and the Coast Guard. In discussion with the crew, it was stated that Port Clutch was inoperable. It was also stated the generator had a blown head gasket. These non-conformities had not been reported.

A towing vessel must maintain records as specified by the TSMS applicable to the vessel. The vessel’s TSMS requires the crew to maintain an electronic record of specific maintenance procedures. Vessel could not provide evidence of the maintenance records; last logged daily machinery checks was on 10SEP2021.

Each towing vessel must be maintained and operated so as to minimize fire hazards and to ensure the following: All bilges and void spaces are kept free from accumulation of combustible and flammable materials and liquids insofar as practicable. Vessel was found with excessive oil accumulation in the bilge.

An exposed hazard such as gears and rotating machinery, must be protected by a cover, guard or rail. Machinery guard for the STBD main engine flywheel was not in place.

Propulsion machinery, including shafting and bearings must be maintained to ensure proper operation. Both shaft packing glands were leaking excessively.

The functional requirements of a TSMS include procedures for verification of vessel compliance with this subchapter. The vessel was found to have numerous maintenance and procedural deficiencies indicating a lack of proper implementation and compliance with the operating company's TSMS. The company could not provide a valid report for an external survey required by 46 CFR 137.205. The survey in question was not conducted by a qualified surveyor per 46 CFR 139.130. An external TSMS management audit must be performed with specific focus on the requirements of the external survey program, vessel maintenance, record keeping, and personnel qualifications verification as defined by 46 CFR 137.210, 46 CFR Part 140 and Part 143.

The company shall establish procedures to ensure the ship is maintained in conformity with the provisions of the relevant rules and regulations. Based on the overall material condition of the vessel as substantiated by the objective evidence cited, an additional external verification is required. Marine Inspectors witnessed numerous repair problems creating a reason to believe that the vessel is unsafe and poses a threat to personnel and the marine environment. The vessel failed to fully implement the requirements of their TSMS. An in-service inspection was conducted due to notification of an inoperable AIS. Marine Inspectors discovered the non-conformity was not recorded in the Towing Vessel Record (TVR). The Master was unfamiliar with operation of the TVR system and unable to provide documentation of maintenance being performed. The inspection was then expanded to determine if the vessel was complying with its TPO's TSMS certificate requirements. Marine Inspectors observed numerous fire, electrical and health and safety related concerns demonstrating a lack of safety culture onboard the vessel.

All seals and gaskets must be properly maintained to prevent leaks of flammable or combustible liquid, as those terms are defined in 46 CFR subpart 30.10, into the machinery space. Starboard main engine is leaking oil excessively. Repair leaks.

Piping and machinery components that exceed 428 degrees Fahrenheit must be insulated. Lagging missing on port and starboard main engine turbo chargers and bellows. Install suitable lagging.

Each towing vessel must be maintained and operated so as to minimize fire hazards and to ensure all bilges and void spaces are kept free from accumulation of combustible and flammable materials and liquids insofar as practicable. a) Bilges contain rags and excessive oil. b) Port generator set has oil soaked windings and exhaust lagging. c) Oxygen and acetylene tanks are improperly stored.

Each towing vessel must have a reliable means to provide notification when an emergency condition exists or an essential system develops problems that require attention. Alarms must be visible and audible at each operating station. High bilge level alarms are not visible or audible at operating station. Install proper alarms.

Electrical systems and equipment must function properly and minimize system failures and fire and shock hazards. a) junction box in engine room missing cover exposing live contacts b) improper battery wiring installation in pilot house crawl space c) fan motor controller switch broken d) battery chargers improperly installed e) non-approved wire connectors found on main engine f) dead end wires from junction box in engine room

Records of drills and instruction must be maintained in the TVR, official logbook, or in accordance with the TSMS applicable to the vessel. The record must include the date of the drill and instruction, a description of the scenario and the personnel involved. There are inadequate records of any emergency drills being conducted. Conduct training and record properly.

Each towing vessel must be equipped with an industrial type first aid cabinet or kit, appropriate to the size of the crew and operating conditions. Vessel first aid kit does not meet criteria. Replace first aid kit.

Propulsion machinery, including main engines, reduction gears, shafting, bearings, and electrical equipment and systems, must be maintained to ensure proper operation. a) Fuel oil tank gauge is broken b) blower in engine room improperly secured.

Each towing vessel must have either a self-priming, power-driven, fixed fire pump, a fire main, and hoses and nozzles or a portable pump. Excessive leaking of water occurred during operational test of fire pump. Repair fire pump.

A vessel must be operated in such a manner as to afford protection against hazards to life. Wastage found on overhead deck of engine room, weather decks, bulwarks and railings. Repair wasted steel.

Windows and other openings at the operating station must be of sufficient size and properly located to provide a clear field of vision for safe operation in any condition. Port side pilot house window broken. Replace window.

Means must be provided to ensure that windows immediately forward of the operating station in the pilothouse allow for adequate visibility to ensure safe navigation regardless of weather conditions. This may include mechanical means such as windshield wipers, defoggers, clear-view screens, or other such means, taking into consideration the intended route of the vessel. Windshield wiper is missing from the motor. Replace windshield wiper.