BETTY K VIII

..That the ship in all aspects will remain fit to proceed to sea without danger to the ship or persons on board. PSCOs observed #2 fire pump actively leaking from packing gland while pump is not running (74) SOLAS I/11.a

...All electrical apparatus shall be so constructed and so installed that danger of injury in ordinary handling shall not exist. PSCOs observed exposed wiring in machinery spaces. (74) SOLAS II-1/27(a)(i)(1)

The ring lines and letters shall be painted white or yellow on a dark background. PSCOs observed port side load lines unpainted. ICLL (66) Annex I/8

A fireman's outfit shall consist of personal equipment comprising of protective clothing of material to protect the skin from the heat radiating from the fire...PSCO's observed during the fire drill, both dressed out firefighters did not have a flashood and had exposed skin. 74SOLAS CH.II-2/Reg 19(a)(i)

...and in cargo ships at least one-half of the total number of lifeguoys shall be provided with efficient self-igniting lights. PSCO's observed STBD side lifebuoy light did not turn on or ignite when shaken. 74SOLAS CH. III/Reg. 21(e)

The International Load Line Certificate (1996)shall not be delivered to the ship until the officer or surveyor acting under the provisions of article 13 of the present convention has certified that the marks are correctly and permanently indicated on the ship's sides. Vessel's load line markings do not reflect the load line marks as indicated on the ship's certificate. ICLL 66 Annex I Reg. 9

The conditin of the ship and its equipment shall be maintained to ensure that the ship in all respects will remain fit to proceed to sea without danger to the ship or person on board. The main and emergency fire pump was able to supply adequate/sufficient pressure but the packing gland leaked in both pumps when set at a lower operational pressure. 74SOLAS(20)I/11(a)

The company should establish procedures to ensure that the ship ismaintained in conformity with the provisions of the relevant rules and regulations and with any additional requirements which may be established by the company. The ship's company fialed to fully implement the requirements of the ISM Code by not providing necessary safety measures as stated to be required in the SOLAS Conditional Cargo Ship Safety Equipment Certificate Remarks. No rescue boat was onboard as required and marked to be present on the Form E when PSCOs came onboard. 74 SOLAS (2020 Cons.) IX/3.1 ISM Code 10.1

All the life-saving appliances shall be kept in working order and available for immediate use before the ship leaves port and at all times during the voyage. The vessel’s rescue boat was not onboard or available for immediate use. 74 SOLAS (81 Amend.) III/4(c)

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations. To ensure that the ship...will remain fit to proceed to sea without danger to the ship or persons on board. The emergency fuel shutoff for emergency generator was inoperable. 74SOLASCh.1/Reg.11(a)

The fire resistance of doors shall as far as practicable be equivalent of that of the division in which they are fitted. Class B-15 fire door to AC room would not close. 74SOLAS Ch. II-2/Reg. 47(1)

In a ship in which fuel is used, the arrangements for the storage, distribution, and utilization, of the oil fuel. Shall be such as to ensure safety of the ship... PSCO found fuel fittings over the #2 SSDG temporarily patched and actively leaking. 74SOLAS II-2/33(a)

Oil filtering equipment referred to in paragraph 2 of this regulation shall be of a design approved by the administration... PSCOs observed installation of an additional testing valve in OWS system that is not approved by flag. MARPOL (11CONS) ANNEX I/14.6

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure that the ship in all aspects will remain fit to proceed to sea without danger to the ship or persons on board. PSCOs observed both fire pumps actively leaking from packing glands while pumps were not running. 74SOLAS I/11(a)

In cargo ships less than 5,000 GT there shall be a self-contained emergency source of power located to the satisfaction of the Administration capable of supplying the illumination at the launching stations and stowage positions of survival craft prescribed in sub-paragraphs (a)(ii), b(ii) and b(iii) of regulation 19 of Chapter III, and in addition such other services as the Administration may require, due regard being paid to regulation 38 of chapter III. Sector Miami received notification that the emergency generator is currently out of order and undergoing repairs. 74 SOLAS II-I/26.b(i)17bc

The company should establish procedures plans and instructions.. For key shipboard operations concerning the safety of the ship.. The various tasks should be defined and assigned to qualified personnel. Chief Engineer could not demonstrate simulated activation of CO2 system for engine room. 74SOLAS(14CONS)IX/3.1 ISM Code REG 7.

There shall be permanently exhibited in all new and existing ships for the guidance of the ships officers general arrangement plans showing clearly for each deck... The various fire sections enclosed by "A" class divisions. Various doors identified by fire control plans as self-closing were tied open. Door leading into laundry space is warped and unable to self close. 74SOLASII-1/REG 4

Objective evidence discovered during an expanded ism exam revealed the following non-conformities: the vessel failed to fully implement the requirements of the ISM code through their SMS procedures as evident by the following deficiencies indicating that the ship and/or company are not meeting the SMS requirements. Recommend an external audit. 74 SOLAS (2014) IX/3.1 ISM CODE PART A 30bc

The company should ensure that each ship is manned with qualified, certified, and medically fit seafarers in accordance with national and international requirements. The vessel has 03 crewmembers with expired medical certificates. ISM Code Part A 6.2.1 30bc

The company should establish programs for drills and exercises to prepare for emergency actions. The Vessel’s SMS outlines the frequency the vessel should be conducting drills in form 305. The vessel is not following the drill schedule and is overdue on their enclosed space entry and rescue drill and their security drill. Last drills conducted on 21SEP19 for both. ISM Code Part A 8.2 30bc

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. The vessel’s SMS requires the crew to record non conformities on form 401 and to track all non conformities on form 403. The Vessel is not properly tracking the 401s on the 403 and is not closing out all recorded non-conformities. The vessel currently has 09 non-conformities that haven’t been closed out on the form 403. ISM Code Part A 9.1 *30bc* *Deficiency was originally issued as a code 30 but downgraded to a code 17*

In meeting these requirements, the company should ensure that: records of these activities are maintained. The vessel completed a non-conformity report for the emergency generator but did not document the of the correction nor measures to prevent recurrence. ISM Code Part A 10.2.4 *30bc* *Deficiency was originally issued as a code 30 but downgraded to a code 17*

In meeting these requirements, the company should ensure that… any non-conformity is reported, with its possible cause. Vessel’s SMS includes weekly and monthly checklists of the rescue boat and equipment. The 2nd Officer completed a weekly inspection of the boat on 22FEB2020 and did not note any non-conformities. When asked by PSCO’s about the rescue boat, the crew attempted to start the boat but engine did not start. The 2nd Officer admitted to the PSCO this was a problem and never notated this on the check sheet mentioned above nor reported the non-conformity. ISM Code Part A 10.2.2 30bc

After any survey of the ship under regulations 7, 8, 9, and 10 of this chapter has been completed, no change shall be made in the structural arrangements, machinery, equipment, etc. covered by the survey, without the sanction of administration. The Cargo Ship Safety [name withheld] states the vessel must have a rescue boat on board. The rescue boat’s engine found was found to be inoperable and a non-conformity report was not submitted to company until after PSCO requested to test the boat. See deficiency number 1.6. SOLAS 74 1/11 30bc

After any survey of the ship under regulations 7, 8, 9, and 10 of this chapter has been completed, no change shall be made in the structural arrangements, machinery, equipment, etc. covered by the survey, without the sanction of administration. PSCO observed a fracture in the #9 ballast tank bulkhead causing ballast water to leak into the cargo hold. SOLAS 74 I/11 *30bc* *Deficiency was originally issued as a code 30 but downgraded to a code 17.*

The construction and means for securing the weather tightness of cargo and other hatchways in positions 1 and 2 shall be at least equivalent to the requirements of regulation 16, unless the application of regulation 15 to such hatchways is granted by the administration. The seals on the three escape hatches from the cargo hold to the open deck are not watertight. PSCO’s had the crew close the hatches and observed areas of sunlight. ICLL (88 Proto) 14(1) 30bc

There shall be permanently exhibited in all new and existing ships for the guidance of the ship’s officers’ general arrangement plans showing clearly for each deck… the various fire sections enclosed by “A” Class divisions. The A-60 door leading to the galley was held open by a hold back hook, breaking the A class boundary and not following the fire control plan. SOLAS 74 II-2/4 17bc

The inspection and survey of ships… shall be carried out by officers of the administration. The interim Cargo Ship Safety Equipment Certificate is missing information for the survey date on which the certificate is based. 74 SOLAS (14) I/6(a) 17bc

The Continuous Synopsis Record shall be kept on board the ship and shall be available for inspection at all times. CSR #8 is a copy and the original is kept in the Bahamas. 74 SOLAS (14) XI-1/5.10 17bc

The bunker delivery note shall be kept on board the ship in such a place as to be readily available for inspection at all reasonable times. It shall be retained for a period of three years after the fuel oil has been delivered on board. Vessel could not provide bunker delivery notes for fuel delivered on 05DEC2019 and 08NOV2019. MARPOL VI/18.6 17bc

The Oil Record Book Part I shall be completed on each occasion… whenever any of the following machinery space operations takes place in the ship… collection and disposal of oil residues (sludge). Vessel did not note in the Oil Record Book Part 1 the offload of 122 GLNS of dirty oil and 306 GLNS of sludge during dry dock in Colombia as noted on the receipt. MARPOL I/17.2.3 17bc

Every Seafarer holding a certificate issued under the provisions of the Convention, who is serving at sea, shall also hold a valid medical certificate. The 2nd Engineer, BOSUN, and 2nd Officer’s medical certificates are expired. STCW I/9.3 17bc

The master, owner, operator, agent, or person in charge of a vessel subject to this subpart and this section must submit a ballast water report to the National Ballast Information Clearinghouse (NBIC) by electronic ballast water report format using methods specified at NBIC's Web site at http://invasions.si.edu/nbic/submit.html... Submit the ballast water report no later than 6 hours after arrival at the port or place of destination, or prior to departure from that port or place of destination, whichever is earlier. Vessel did not submit their ballast water report upon arrival to the Miami River within the required timeframe. 33 CFR 151.2060(b) 17bc

The company should ensure that valid documents are available at all relevant locations. The vessel does not have a valid Cargo Ship Safety Equipment Certificate onboard or the original copy of the Continuous Synopsis Record #8. ISM Code Part A 11.2.1 30bc

Crew members with enclosed space entry or rescue responsibilities shall participate in an enclosed space entry and rescue drill to be held on board the ship at least once every two months. The Vessel is overdue in completing their enclosed space entry and rescue drills. The last enclosed space entry drill was completed on 21SEP2019. 74 SOLAS(14) III/19.3.3 17bc

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations...to proceed to sea without danger to the ship or persons onboard. Starboard side pilot ladder had cracks in the bottom step. 74 SOLAS (14) CH I/Reg. 11(a)

Each contracting government undertakes to make available...appropriate shore-based facilities for space and terrestrial radio communications services having due regard to the recommendations of the organization in accordance with resolution A.801(19)...12.2 this battery should be equipped with a non replaceable seal to indicate that it has not been used. One battery for the GMDSS radios did not have a seal indicating that it has not been used. 74 SOLAS (14) CH IV/Reg. 5.1

Each operation described in paragraph 2 of this regulation shall be fully recorded in the Oil Record Book...each completed operation...and each completed page shall be signed by the master of the ship. Master has not signed the Oil Record Book since the last week of July. (MARPOL 2017, Annex I, Reg. 17.4)

The bunker delivery note shall be kept onboard the ship...and shall be retain for a period of 3 years. The Chief Engineer could not provide bunker delivery notes for 09/10/19, 08/28/19, 08/14/19, and 07/31/19. (MARPOL 2017, Annex VI, Reg. 18.6)

If your vessel is grather than or equal to 300 GT...you must submit a signed, certified, and complete NOI. Vessel has not submit a NOI, no VGP onboard. (2013 VGP 1.5.1.1)

Each operation described in Reg 17.2 shall be fully recorded so that all entries in the book appropriate to that operation are completed. C/E failed to use correct units of measurements and the correct item numbers for discharge to reception facilities and position of discharge. - MARPOL I/17.4

Fire doors in main vertical zones, bulkheads and stairway enclosures...shall be of the self-closing type. Hold-back hooks not subject to control station release, will not be permitted. 03 doors in the ladder well leading to the bridge were found held open by hold-back hooks. In addition, doors leading to the escape hatch were found and workshop in E/R were found with hold-back hooks. - 74 SOLAS (Unamended) Reg 37 (f)

The operator of a vessel with a capacity of 250 barrels of oil or more shall provide trasnfer procedures that meet the requirements of this part and part 156. Vessel does not maintain oil transfer procedures. - 33 CFR 155.720

0725 - Fixed Fire Extinguishing Installation - In all new and existing ships, fire-extinguishing appliances shall be kept in good order and available for immediate use at all times during the voyage. Fire main between cargo holds one and two on starboard side is leaking as a result of corrossion. 74SOLAS Ch.II-2/Reg.15

A Class Divisions shall be constructed as to be capable of preventing the passage of smoke and flame to the end of the one hour standard fire test. The passage of an electrical cable running from an auxillary engine in the engine room to the elecrtrical switchboard in the engine control room through the bulkhead left an opening that would allow smoke and flame to pass74SOLAS II-2/3(c)(iii)

1551: Vessels shall be fitted with a daylight signalling lamp not solely dependent on ships power. Vessel's did not have an independent source of portable power. 74 SOLAS (09 Cons.) V/19.2.2.2

0299: Due to Crew Change outs; Any Certificate required to be kept available in its original form on the ship on which the holder is serving. Chief Mate unable to provide valid endorsement from Flag. STCW 78/95 (2010) I/2.11

2020/2025: Due to crew changeouts: Every crew member with assigned emergency duties shall be familiar with duties prior to the voyage. Unable to conduct fire/abandon ship drills due to crew being swapped out. 74 SOLAS (09 Cons.) III / 19.2.1

Personal equipment shall consist of protective clothing of material to protect the skin from the heat radiating from the fire. One of the two firefighter outfits onboard the vessel had tears along the seam of the suit arms compromising fire protection capabilities. 74 SOLAS CH II-2 Reg 14.(a)(i)