ROGER WHITE

The company should establish procedures, plans and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of personnel, ship, and protection of the environment. Marine Inspector found 134 overdue maintenance items to include critical items such as: Water tight doors, Water mist system, fire dampers, emergency generator load test, fire detection system and critical spares review. 74 SOLAS (2020) IX/2.1 ISM Code 7

The company should establish procedures to ensure 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. In meeting these requirements the company should ensure that 1) appropriate corrective actions are taken when required and 2) inspections are held at required intervals. Master did not make appropriate notifications to Flag State and ABS prior to replacing the rescue boat engine with a non-approved type engine. Furthermore, the non approved engine was not equipped the safety kill lanyard, prop guard, and throttle was held together with duct tape. Additionally, vessel conducted FMEA trails offshore in this condition. Recommend an additional SMS external verification of the vessels safety management system. 74 SOLAS (2020) IX/5 ISM Code 10

The company should establish procedures, plans and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of personnel, ship, and protection of the environment. Marine Inspector identified falsified monthly maintenance tasks logged in their preventive maintenance system in regards to the rescue boat davit. 74 SOLAS (2020) IX/2.1 ISM Code 7

Fire-fighting systems and appliances shall be kept in good working order and readily available for immediate us. The main fire pump is not operating as designed. Marine inspector observed the mechanical seal leaking. 74 SOLAS (2020) II/2 14.2.2.1.2

Fire-fighting systems and appliances shall be kept in good working order and readily available for immediate us. Marine Inspector identified that the A60 fire doors in the Galley were overdue for their annual servicing. 74 SOLAS (2020) II/2 14.2.2.1.2

Before the ship leaves port and at all times during the voyage, all lifesaving appliances shall be in working order and ready for immediate use. Marine inspectors found the search light, flash light and spare batteries inoperable. 74 SOLAS (2020) III/20

Performance of crew members assigned fire-fighting duties shall be periodically evaluated by conducting on-board training and drills to identify areas in need of improvement, to ensure competency in fire-fighting skills is maintained, and to ensure the operational readiness of the fire-fighting organization. While conducing drills, Marine Inspector identified communication failures from the U.S. Master to the Brazilian Chief Mate due to a language barrier. Master is unable to commutate to the crew without a translator, resulting in poor drill performance and training. 74 SOLAS (2020) II/2 15.2.2.2.3

Each operation and failure required to be recorded in the oil record book (ORB) shall be completed in accordance with the convention. During review of the ORB, Marine Inspector identified inconsistency regarding log entries to include sulfur content, tagged out OWS, and using "white out" for corrections. MARPOL Annex I/17

Lifebuoys - Life buoy lights were found with unapproved batteries. 74 SOLAS (2020) III/7.1

Fire-fighting systems and appliances shall be kept in good working order and readily available for immediate use. MI found fire main isolation valves inoperable. 74 SOLAS (2020) II/2 14.2.2.1.2

F?ire fighting systems and appliances shall be kept in good working order and readily available for immediate use. Vessels E-Gen room's fire suppression relay box has a damaged toggle switch that prevents system from operating properly. Repair and prove proper operation to the satisfaction of the attending RO.

Doors provided to ensure the watertight integrity of internal openings which are used while at sea are to be sliding watertight doors capable of being remotely closed from the bridge and are also to be operable locally from each side of the bulkhead. Observed leaks on hydraulic actuators for the FWD and AFT sliding watertight doors. 74 SOLAS 2020 II-1/13-1.2 50a

Unless expressly provided otherwise, launching and embarkation appliances complying with the requirements of section 6.1 of the Code shall be provided for all survival craft. Where davit arms are recovered by power, safety devices shall be fitted which will automatically cut off the power before the davit arms reach the stops in order to prevent over stressing the falls or davit, unless the motor is designed to prevent such over stressing.Observed limit switch on davit no operating as designed. 74 SOLAS III/16.1 LSA Code 6.1.2.7 10c

Fire-fighting systems and appliances shall be kept in good working order and readily available for immediate use. Water mist system is not working in automatic mode preventing the the fuel purifier sections from activating by smoke and heat detection system.74 SOLAS 2020 II-2/14.2.1.2

Means shall be provided to control leaks of flammable liquids. MI noted wasted & chafed fuel oil lines on the forward generator prime mover and aft generator prime mover. MI also noted excessive oil leak on port main engine by propulsion shaft connection to the clutch. Master shall provide evidence of effective repairs to the RO before departure. 74SOLAS(2014)II-2/4.1.1

All external openings leadings to watertight compartments below the waterline must be watertight. MI noted deficient gasket on bow thruster watertight hatch. Master shall provide evidence of repairs to RO within 14 days. 74SOLAS(2014)II-1/15-1.1

External high-pressure fuel delivery lines between the high-pressure fuel pumps and fuel injectors shall be protected with a jacketed piping system capable of containing fuel from a high pressure line failure. SOLAS tape or covers were not provided at the aft high pressure fuel line connections on both the starboard and port main diesel engines. Master shall provide evidence of protection for high pressure fuel lines to RO within 14 days. 74SOLAS(2014)II-2/2.2.5.2

Ships over 400 ITC GT shall be fitted with oil filtering equipment meeting the requirements of the organization. Vessel is fitted with two (02) MEPC.107(49) oil water separators (OWS) that have an arrangement for overboard discharge that allows a connection after the oil content meter (OCM) controlled overboard discharge valve. This connection is not fitted with a check valve and could allow for a direct connection to the overboard discharge from the OWS without passing through the OCM first. Master shall install check valves at the test connections after the OCM overboard discharge valve to the satisfaction of the RO within 30 days. 73/78MARPOL(2017)I/14.6

Electrical installations shall be such that the safety of passengers, crew, and ship from electrical hazards will be ensured. Wire connections with exposed wire nuts outside of a junction box were made below the diesel filters for the port generator and were immersed in liquid within the containment underneath the filters. Chief Engineer corrected during inspection and removed the liquid from the containment. 74SOLAS(2014)II-1/40.1.1.3

Each liferaft shall be stowed with a float-free arrangement so that each floats free and, if inflatable, inflates automatically when the sink ships. The top liferafts on each side of the vessel were configured improperly with the hydrostatic release units for float-free release. Master corrected on the spot. 74SOLAS(2014)III/13.4.2