SUNFLOWER

EACH DISTRICT COMMANDER OR CAPTAIN OF THE PORT MAY ORDER A VESSEL TO OPERATE OR ANCHOR IN THE MANNER DIRECTED WHEN...THE DISTRICT COMMANDER OR CAPATIAN OF THE PORT HAS DETERMINED THAT SUCH ORDER IS JUSTIFIED IN THE INTEREST OF SAFETY BE REASON OF...OTHER TEMPORARY HAZARDOUS CIRCUMSTANCES, OR THE CONDITION OF THE VESSEL. PSCOS OBSERVED THAT THERE WAS ONLY RICE, A SMALL BOX OF PEPPER, AND A FEW TOMATOES ONBOARD. CREW STATES THAT THEY HAVE EATEN NOTHING BUT RICE SINCE NOVEMBER 13TH. 33 CFR 160.111(C) / ILO 147 FOOD AND CATERING/BASIC REQUIREMENTS/PARAGRAPH 2/ PWSA 46 USC 7002 60 AC

PERSONAL EQUIPMENT SHALL CONSIST OF THE FOLLOWING: PROTECTIVE CLOTHING OF MATERIAL TO PROTECT THE SKIN FROM THE HEAT RADIATING FROM THE FIRE AND FROM BURNS AND SCALDING BY STEAM. THE OUTER FURFACE SHALL BE WATER-RESISTANT. PSCOS OBSERVED 02 FIREFIGHTER'S OUTFITS WITH DAMAGE TO THE ARMPITS AND GROIN AREAS RENDERING THEM NO LONGER WATER-RESISTANT. 74 SOLAS(09) II-2/10.10.1 FSS Code 2.1.1.1

The company should establish a safety policy that describes how objectives given in paragraph 1.2 will be achieved, i.e. provide for practices in ship operations and safe working environment and comply with mandatory rules and regulations. The vessel’s current Safety Management System does not include a safety policy that provides procedures to ensure all applicable section of MLC Title 3, Regulation 3.2 are met. 74SOLAS(2014)CH IX REG 3.1 ISM CODE 2.1 17 b/c

Every company should develop, implement and maintain a safety management system which includes the following functional requirements: instructions and procedures to ensure safe operation of ship and protection of the environment in compliance withe relevant international and flag State legislation. PSCO observed multiple ISM discrepancies on board: 1) SMS does not contain procedures relating to replenishment of provisions. The vessel departed on a 17 day transit to the United States from Japan, with only 3-4 days supply of provisions, per MLC A3.2.2(a). 2) Instructions and procedures to address on board complaints are not clearly stated or defined to crew on board. The crew on board notified department head officers and Captain of a food shortage, but no actions was taken by department heads, Master or appropriate external authority to resolve the issue. 3) Upon the Master's provision request, the company failed to take into account the 17 day transit and only authorized a $500 purchase. 4) Vessel failed to maintain records in accordance with record maintenance procedures (BR-1 SKSMS Record List). PSCO spot checked and observed multiple records (ER-5, F-4R-5, MR-3, MR-9 AP-2) missing or incomplete. 5) During spot check, SMS procedures referenced a convention (ILO 180) that flag Administration is not signatory to. 74SOLAS(2014)CH IX REG 3.1 ISM CODE 2.1 17 b/c

AN IMMERSION SUIT COMPLYING WITH THE REQUIREMENTS OF SECTION 2.3 OF THE CODE SHALL BE PROVIDED FOR EVERY PERSON ASSIGNED TO CREW THE RESCUE BOAT OR ASIGNED TO THE MARINE EVACUATION PARTY. THE IMMERSION SUITS ON BOARD THE VESSEL ARE MARKED INDICATING THAT THEY MUST BE WORN WITH APPROVED SOLAS LIFE JACKETS. THE LIFE JACKETS ON BOARD THE VESSEL ARE NOT SOLAS APPROVED. 74 SOLAS (14) III/8.3 LSA CODE 2.3.1.7

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THE MASTER OF VESSEL MUST PROVIDE BALLAST INFORMATION ON THE BALLAST WATER REPORTING FORM TO THE NATIONAL BALLAST WATER CLEARING HOUSE. BALLAST WATER REPORTING FORM INCORRECTLY SUBMITTED AND NOT APPROVED BY NBIC. 33CFR 151.2060(B) 16C