PURE TRADER

Deficiency Code - 14614 - Sulphur oxides - While ships are operating within an emission control area, the Sulphur content of fuel oil used on board ships shall not exceed the following limits: 0.10% m/m on and after 01JAN2015. While operating in the North American Emissions Control Area vessel intentionally burned HSFO on 19APR19 from approximately 1520 to 1730. (Sulphur content 2.78%). MARPOL Annex VI/14.4.3 IAW D8-FIN-18-02-PSC PSCO's issued Code 705C, allotting three months for corrective action.

15108 - Reports of non-conf., accidents & hazardous occur. The company should ensure that all personnel involved in the company's safety management system have an adequate understanding of relevant rules, regulations, codes and guidelines [ISM 6.4]. Additionally, the safety management system should include procedures ensuring that non-conformities, accidents, and hazardous situations are reported to the company, investigated and analyzed with the objective of improving safety and pollution prevention [ISM 9.1]. Union Marine Management Services Pte Ltd Shipboard Procedures Manual VER No-03/REV No-00, Section: SPM-09, page 13 states that, "The Master shall ensure that the heavy fuel oil burnt whilst the vessel is within SECA/ECA zone contains net Sulphur equal to or less than 0.10% m/m". As delineated in deficiency #1, vessel burned HSFO for approximately 2 hours while operating in the North American Emissions Control Area. Chief Engineer informed PSCO's that he solely completed the change over in an effort to prevent further leakage of the low Sulphur fuel supply pump. At no point was the Master informed, nor any written record of this change over annotated in the engineering/deck log book. Statements provided by other engineering crew members provide further objective evidence that Chief Engineer failed to notify the vessels Master and carry out approved change over procedures as noted in Union Marine Management Services approved procedures for change over of fuel.