ZAO GALAXY

The company and the ship shall comply with the requirements of the International Safety Management Code. For the purpose of this regulation, the requirements of the Code shall be treated as mandatory. The company should ensure that the policy is implemented and maintained at all levels of the organization, both ship-base and shore-based. Objective evidence discovered during an expanded ISM exam revealed the following major non-conformities which contributed to a serious systematic failure of and lack of implementation of the SMS environmental protection policy onboard in the areas of training/familiarization, recordkeeping, waste oil/oily mixtures management and internal auditing: 1) PSCO witnessed multiple crew members assigned to the engineering department be unfamiliar with regards to the operation of the OWS. OWS familiarization and training is required as per ship’s SMS manual. 2) PSCO identified approximately 70 gallons of waste oil/oily mixtures were unaccounted for in the ship's ORB dated 27 Dec 2018- current. Additionally, the PSCO identified approximately 300 gallons of waste oil/oily mixtures that were unaccounted for in the ship's ORB dated 27 Sep 2018-27 Dec 2018. As per the ship's SMS manual, management of oily waste shall be properly documented by the 1/E under the supervision of C/E and Master. 3) On 04 Jan 2019, the company conducted an internal audit of the vessel's ORBs and failed to identify the unaccounted waste oil/oily mixtures listed in item #2 above and failed to witness an operational test of the OWS. The company and crew failed to fully implement the requirements of the ISM code through their SMS procedures. The above major non-conformities are evidence that the company and crew are not complying with shipboard SMS requirements. Recommend external audit.

The oil filtering equipment referred to in paragraph 2 of this regulation shall comply with paragraph 6 of this regulation. Additionally, the oil filtering equipment shall be provided with alarm arrangements which indicate when the oil content exceeds 15ppm and this level cannot be maintained. The system shall also be provided with arrangements to ensure that any discharge of oily mixtures is automatically stopped when the oil content of the effluent exceeds 15 ppm. While witnessing the operational test of the Oily Water Separator(OWS) and Oil Content Meter (OCM), the PSCO observed the oil content effluent readings on the OCM exceeded 15 ppm without automatically stopping and effluent continued to flow past the three way valve to the overboard valve.

A ship when in a port or an offshore terminal of another Party is subject to inspection by officers duly authorized by such Party concerning operational requirements under this Annex, where there are clear grounds for believing that the master or crew are not familiar with essential shipboard procedures relating to the prevention of pollution by oil. The PSCO requested the 1/E to demonstrate operation of the Oily Water Separator (OWS). However when requested to demonstrate proper operation of the OWS, the 1/E did not know how to operate the OWS and it took over 30 minutes to get the system started with other crew assistance. In accordance with the ship's procedures the 1/E is responsible for operating and testing the OWS. Additionally, the 1/E did not know the reason why the equipment would not go into recirculation mode, when the OCM showed a reading above 15ppm and effluent continued to flow past the three way valve to the overboard valve.

Each operation described in paragraph 2 of this regulation shall be fully recorded without delay in the Oil Record Book Part I, so that all entries in the book appropriate to that operation are completed. Upon review of the Oil Record Book (ORB) Part I by the PSCO, approximately 70 gallons of waste oil/oily mixtures were unaccounted for in the ship's ORB dated 27 Dec 2018- current. Additionally, the PSCO identified approximately 300 gallons of waste oil/oily mixtures were unaccounted for in the ship's ORB dated 27 Sep 2018-27 Dec 2018. The crew did not have documentation or receipts of waste oil/oily mixtures being disposed to a reception (shore side) facility.

1820: The machinery pressure vessels and associated piping systems and fittings shall be of design and constructed adequate for the service for which they are intended. Salt water hydraulic cooling outlet ling for power pac was patched in two places, 74 SOLAS (14) II-1/26, 40AC.

0663: Immersion suits of appropriate size shall be provided for every person. Several crew members did not have appropriate size immersion suits, 74 SOLAS (14) III/32.3.2, 10C.

2510: Vessel must maintain a Ballast Water Management Plan. Vessel is not following / documenting items including Bio-Fouling as required by 33CFR2050(g)/IMO Res., 207(62), 10C.

2510: The operator of a vessel with capacity of 250 or more barrels of oil shall have transfer procedures that meet the requirements. Vessel cargo transfer procedures do not follow 33 CFR 155.720, 10C.