PEPIN EXPRESS

Every Company should develop, implement and maintain a safety management system (SMS) which includes instructions and procedures to ensure safe operation of ships and protection of the environment in compliance with relevant international and flag state legislation. The Dangerous Goods Document of Compliance prohibits the carriage of class 3 flammable cargoes. However, 12 dangerous cargo manifests (DCMs) confirm that the vessel transported more than 31,000 kilograms of class 3 flammable cargoes on nine voyages from April through July 2025. The master signed most of these DCMs. When questioned, the master stated that he received the DCMs after cargo was loaded and that he did not know he had the authority to reject the unauthorized cargo and order its removal before departure. The SMS does not require the crew to verify dangerous goods compliance before loading, nor does it address the master’s authority to reject unauthorized cargoes. Carriage of class 3 flammable cargoes without the required systems/equipment to fight a fire presents an unacceptable risk to the safety of the vessel, crew, and the marine environment. An external ISM audit is required. 74SOLAS(24) IX/3.1, ISM Code 1.4.2 Code 30bc

"The following ships with cargo spaces intended for the carriage of packaged dangerous goods shall comply with regulation 19.3... not later than the date of the first renewal survey on or after 1 January 2011: Cargo ships of 500 gross tonnage and upwards...constructed on or after 1 September 1984 but before 1 January 2011." PSCO observed that the vessel was not authorized to carry class 3 dangerous goods by the administration due to the lack of required equipment necessary for the carriage of those goods listed in the previous dangerous cargo manifests reviewed. 74SOLAS(20) II-2/1.2.4.1 Code 17bc

The carrier and its agents shall ensure that the master, or a licensed deck officer designated by the master and attached to the vessel... acknowledges the correctness of the dangerous cargo manifest, list or stowage plan by his signature. Multiple DCMs were not signed by the master or another licensed deck officer, including DCMs indicating the shipment of unauthorized class 3 flammable cargoes. 49CFR 176.30(c) Code 17bc

Each vessel must have the following marine charts of the area to be transited that are corrected. PSCO observed cancelled charts as primary means of navigation. 33 CFR 164.33(a)(ii)

Guard rails fitted on superstructure and freeboard decks shall have at least three courses. The opening below the lowest course shall not exceed 230mm. PSCO observed broken lower course. ICL 66/88 Annex I/25.3

The sample is to be retained onboard not less than 12 months from the time of delivery. PSCO observed only 02 samples onboard and missing multiple samples in the 12 month span. MARPOL(CONS. 22) ANNEX VI Reg 18.8.1

A fireman's outfit shall consist of: Personal equipment comprising: Protective clothing of material to protect the skin from heat radiating from the fire and from burns. PSCO'S observed the fire fighting outfit had exposed skin around the fire fighting team members face. 74SOLAS(97) CH II-2 REG 17.1.1.1

No person may transfer oil or hazardous material to or from a vessel unless each parson in charge designated under 33 part 154.710 and 155.700 of this chapter has filled out and signed the declaration of inspection described in paragraph (c) of this section. PSCO'S observed vessel personnel transferring lube oil over the water with no declaration of inspection completed. 33CFR 156.150

Firefighting systems and appliances shall be kept in good working order and readily available for immediate use.. PSCO's were informed that the emergency fire pump is inoperable. 74 SOLAS (20) II-2 / 14.2.1.2

Ships shall comply with the relevant requirements of this chapter and of Part A of the ISPS Code, taking into account the guidance given in Part B of the ISPS Code... Vessel was missing record of annual security exercise for 2023. A security exercise must be conducted prior to departure. 74 SOLAS (20) XI / 4.2 ISPS Code Part A / 10.1.1

The training manual shall be written in the working language of the ship. PSCO's observed that the fire-fighting training manual was written in English but the working language of the ship is Spanish. 74 SOLAS (20) II-2 / 15.2.3.2

Before the ship leaves port and at all times during the voyage, all life-saving appliances shall be in working order and ready for immediate use. PSCO observed rescue boat engine did not start. 74SOLAS(97)III/19.2

The company and the ship shall comply with the requirements ofthe International Safety Management Code. For the purpose of this regulation, the requirements of the Code shall be treated as mandatory.The company should establish procedures to ensure that the ship is maintained in conformity with the provisions of the relevantrules and regulations and with any additional requirements which may be established by the company. In meeting these requirements, the company should ensure that any non-conformityis reported, with its possible cause, if known. The nature of the below deficiencies provides objective evidence of a serious failure of the implementation of the ISM Code. An external ISM audit report, satisfactory to the Coast Guard, mustbe submitted prior to clearance of this deficiency and departure.

Each seafarer holding a certificate issued under the provisions of the Convention, who is serving at sea, shall also hold a medical certificate issued in accordance with the provisions of this regulation and of section A-1/9 of the STCW Code. PSCO’s discovered that the medical certificate for the Chief Engineer was expired.

Except as provided in paragraphs (b) and (c) of this section no person may cause a vessel to enter into or get underway on the navigable waters of the United States unless no more than 12 hours before entering or getting underway, the following equipment has been tested: Each rudder angle indicator in relation to the actual position of the rudder. The ship’s logbook showed that the pre-arrival checks were completed. However, PSCO’s observed that the rudder angle indicator repeater on the port side bridge wing conning station was inoperable, indicating an incomplete examination of the required equipment based on the fact that the crew was unaware of the last time that the indicator was functioning properly.

VESSEL NEEDS APPROVED UPDATED PLAN TO REFLECT NEW BALLAST WATER TREATMENT SYSTEM.

muster and embarkation station shall be adequately illuminated by lighting suplied from the emergency source of electrial power required by regulations II-1/42 or II-1/43 as appropriate. PSCO observed 02 lights not operational with emergency power located by the port side embarkation station. 74SOLAS(97) III/11.4

... a minimum of two inspections of the outside of the ship's bottom during any five year period. SOLAS Safety Construction Certificate provided to PSCOs listed the vessel's previous two drydocks as 17JAN2017 and March 2017. This is greater than 2 inspections in a 5 year period. Vessel plans to go to drydock in March 2022. 74 SOLAS(20 cons.) CH. I/ Reg. 10(a)(v). 17bc.

The means for securing and maintaining weathertightness shall be to the satisfaction of the administration. PSCOs identified several cargo hatch securing devices which were rusted and wasted, warped, or missing all together. ICLL 66 Annex I/ Reg. 16.4. 17bc.

Paint lockers and flammable liquid lockers shall be protected by an appropriate fire-extinguishing arrangement approved by the Administration. The current arrangement is not fixed and requires flooding of the entire space to fight a fire. 74 SOLAS (97 cons.) Ch. II/ Reg 18.7. 17bc

... The other courses shall not be more than 380 mm (15 inches) apart. The middle course of railing was missing near the rescue boat, port side. ICLL 66 Annex I/ Reg 25.3. 17bs.

Before the ship leaves port and at all times during the voyage, all life-saving appliances shall be in working order and ready for immediate use...The rescue boat sheave did not rotate as designed. 74 SOLAS (20) III/20.2

The secretary may order any vessel in a port or place of the United States or in the navigable waters of the United States, to operate or anchor in a manner the secretary directs...Condition of such vessel, the secretary is satisfied such direction is justified in the interest of safety...Vessel does not have a working AC system on board negatively impacting the health and safety of the crew. 46 USC 70002(3)

The Secretary may order any vessel in a port of place subject to the jurisdiction of the United States or in the navigable waters of the United States, to operate or anchor in a manner the Secretary directs if- by reason of... other hazardous circumstances, or the condition of such vessel, the Secretary is satisfied such discretion is justified in the interest of safety... vessel does not have a working A/C system on board, and all windows are permanently sealed, impeding air circulation, negatively impacting the health and safety of the crew. 46 USC 70002 (3)

The following fire protection systems shall be kept in good order so as to ensure their required performance is a fire occurs: Fire detection and alarm systems. Inspection observed a general fault on the bridge fire alarm panel that could not be cleared. 74 SOLAS (04 cons.) CH. II-2/Reg.2.1.1.2

After any survey of the ship under regulations 7, 8, 9 or 10 has been completed, no changes shall be made in the structural arrangements, machinery, equipment and other items covered by the survey, without sanction of the administration. On the starboard side of the vessel, inspectors observed a cargo hatch securing device that broke off. 74 SOLAS (04 cons.) CH. 1/Reg 11(b)

Oil filtering equipment referred to in paragraph 1 of this regulation shall be of a design approved by the administration.. OWS had numerous leaks on system, Pump Shaft seal leaks, Pump outlet pipe leaks and rupture on pump inlet pipe.

Oil filtering equipment will ensure that any oily mixture discharged has an oil content not exceeding 15 PPM. Crew could not demonstrate proper operation of OWS. MARPOL ANNEX I/REG 14.6

Except as provided in paragraph 4, two means of escape shall be provided from each machinery space of category A. Escape trunk serving as secondary means of escape from ENG room had hatch seized due to rust, preventing crewmember from opening the hatch from inside of the ship. 74SOLAS (97CONS) Ch. II-2/Reg 45.3

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. Crew initially able to steer to port only. After mechanical intervention, acceptable steering was demonstrated. 74SOLAS (97CONS) Ch. III/Reg 19.2

[withheld — contains personal information; the deficiency system, dates, and resolution status are shown above]

A record shall be kept to the satisfaction of the administration and as required by the radio regulations. Chief Mate has not been logging daily checks during the vessels in port dates. 74SOLAS (14CONS) Ch. IV/Reg 17

Each completed page of the Garbage Management Book shall be signed by the master of the ship. Entries have not been signed by master since July 2018. MARPOL (17 Cons.) Annex V/Reg 10.3

BEFORE THE SHIP LEAVES PORT AND AT ALL TIMES DURING THE VOYAGE, ALL LIFE SAVING APPLIANCES SHALL BE IN WORKING ORDER AND READY FOR IMMEDIATE USE. RESCUE BOAT ENGINE INOPERABLE. 74 SOLAS (1997) III/19.2 17C/10C

0750 - Fire Prevention - "A" class divisions shall be so constructed as to be capable of preventing the passage of smoke and flame. The bulkhead to the purifier room has a small circular penetration forward of the door, a 2 inch semi-circle penetration in the upper aft bulkhead between the engine room and purifier room, and the Switchboard room and the purifier room. 74SOLAS(1997)II-2/3.3.3

0672 - EPIRBs - Every ship shall be provided with a satellite EPIRB capable of floating free if the ship sinks and of being automatically activated when afloat. Vessels EPIRB was fitted with a liferaft hydrostatic release. 74SOLAS(2014)IV/7.1.6.3

0750 - Fire Prevention - Doors required to be self-closing shall not be fitted with hold-back hooks. The door to the purifier room was equipped with a hold back hook and was not fitted with a remote release device. 74SOLAS(1997)II-2/47.2

1680 - Radio log (Diary) - A record shall be kept, to the satisfaction of the administration as required by the radio regulations. Vessel did not have records of conducting weekly and monthly GMDSS tests. 74SOLAS(2014)IV/17

IN ALL SHIPS GENERAL ARRANGEMENT PLANS SHALL BE PERMANENTLY EXIBITED...SHOWING CLEARLY FOR EACH DECK...THE FIRE EXTINGUISHING APPLIANCES...AND THE VENTILATION SYSTEM. CO2 DISCHARGE NOZZLE IN PURIFIER ROOM AND VENTILATION DUCT FROM PURIFIER ROOM ARE NOT IDENTIFIED ON THE PLAN. 74SOLAS(97 CONS) II-2/20.1

Oil filtering equipment referred to in this regulation shall be such as will ensure that any oily mixture discharged into the sea after passing through the system has an oil content not exceeding 15 ppm. Vessel's oily water separator is inoperable. MARPOL(11 Cons) Annex I Reg 14.6. Action taken 17bc

Electrical installations shall be such that the safety of passengers, crew, and ship from electrical hazards will be ensured. There ae 02 electrical junction boxes with exposed wire and evidence of arcing at the entrance to teh bosun's hold. 74 SOLAS(97 Cons) CH II-I/Reg 40.1.3. Action taken 16bc

The master of a vessel equipped with ballast tanks shall not discharge ballast water into waters of the United States. Vessel noted on multiple occasions from January 2017 to date of inspection (08AUG17) that ballast water was discharged into the Miami River.

0715 -Detection- Any required fixed fire detection system shall be capable of immediate operation. Fire alarm control panel does not detect in zone #7. 74 SOLAS (97 Cons) Ch II-2/Reg 13.1

0690 -Line throwing appliance- A line throwing appliance complying with the requirements of regulation 49 shall be provided. The four rockets for the line throwing appliance expired December 2016. 74 SOLAS (97 Cons) Ch III/Reg 17 & 49

1560 -Charts- Nautical charts and tidal current tables shall be adequate and up to date. Both charts and tidal current tables were out of date. 74 SOLAS (14 Cons) Ch V/Reg 27

0100 -Ship's certificates and document- Certificates issued to the vessel shall be readily available and on board for examination at all times. Certificate of Registry, International Tonnage Certificate, ISM-Document of Compliance, and Minimum Safe Manning Certificate were not on board. 74 SOLAS (14 Cons) Ch I/Reg 16

1220 -Freeboard Marks- The load line letters shall be contrasting color to the hull and permanently marked and plainly visible. Port side markings missing from load line tree. ICLL 66 Annex I, Ch I/Reg 8