ARGENT SUNRISE

2535: Safety management system shall be maintained in accordance with the provisions of the International Safety Management Code. The company has established procedures and instructions for cargo operations as per ship’s SMS form M-05 Appendix 8.4. However, upon arrival at 11:13 local time, the PSCO found that no cargo transfer/operational procedures had been filled out. SOLAS IX/5 & ISM A/7. Code 40 A/C

1830: Contents of transfer procedures: the transfer procedures required by 33CFR155.72 must contain the number of persons required to be on duty and the duties of each person’s for each transfer operation. The vessel has Transfer Procedure; however crew members are doing additional jobs that have not been listed in their procurers which will affect emergency sand safety of cargo operations. 33CFR155.750. Code 40A/C

2525: The Company should clearly define and document the master’s responsibility with regard to: motivating the crew in the observation of that policy. The master, Chief officer and company representative charged with overseeing cargo operations in not following established Safety management Procedures for cargo operations. Recommend Flag Administration conduct an ISM audit prior to conducting cargo operations in U.S. waters. SOLAS IX/5 & ISM A/5.1.2 & ISM A/6.1. Code 40 B/C

0699: Inspection of personnel emergency and safety equipment: the master shall ensure that all the personnel emergency and safety equipment is inspected every 30 days. Each ship must have two stretchers or wire baskets for lifting an injured person from a pump room or cargo tank. Vessel only has one usable stretcher onboard. IBC 14.3.3 & 46CFR 153.214 & 46CFR153.1504. Code 10c

The company and the ship shall comply with the requirements of the ISM. Code requirements shall be treated as mandatory. Every Company should develop, implement and maintain a SMS which includes instructions and procedures to ensure safe operation of ships. Upon completion of cargo discharge ops in tanks 8S and 8P, one crew member suffered a fatal fall from the ladder to the tank bottom. Shipboard crew failed to implement established company procedures defined in the Safety of Operation Manual which mandates procedures when entering a confined spaces and references adherence ot the MSDS for cargo handling. Major non-conformities were identified indicating lack of adherence to shipboard safety policies posing serious harm to human life/health. The following objective evidence was obtained: 1) C/O failed to submit for Master’s approval “Enclosed/Confined Space Entry permit”; 2) C/O failed to hold a safety briefing with crew for tank entry; 3) C/O failed to provide mechanical ventilation in tanks; 4) Crew failed to enter tanks with the proper PPE; 5) Crew failed to stage appropriate safety gear ready for use at the entrance to the space; 6) Crew failed to adhere to shipboard procedures for rescue from enclosed spaces. Due to lack of adherence to vital company policy and shipboard procedures, a full ISM audit is recommended prior to departure from the SF COTP zone. SOLAS (14)IX/3.1 & ISM Part A/1.4 & IBC 14.1.3 Code 30 A/C

Every crew member shall be given instructions which shall include but not necessarily be limited to: risks associated with enclosed spaces and on board procedures for safe entry into such spaces which should take into account, as appropriate, the guidance provided in recommendations developed by the Organization. During a tank squeezing evolution on 12Nov17, 4 crew members were in tank 8P; upon exiting the cargo tank, one crew member had a fatal fall from the egress ladder to the tank bottom. Vessel procedures were not followed for enclosed space entry and rescue drills. Enclosed space entry and rescue drill training shall be provided to include identification of cargo hazards and required PPE per the vessel’s Safety management System prior to departure from Richmond, CA. SOLAS (14) III/19.4.2 60A/C

1850; Every ship shall be provided with a fixed deck foam system in accordance with the requirements of 11.3.2 to 11.3.12. The only means to access deck foam monitors is via FRP grating which ‘cannot be used in foam system operational areas and access routes’ per the NKK approval Certificate No. TA1627E(R). IBC 11.3.1. 40A/C

1499; The machinery, associated piping systems and fittings shall be of a design and construction adequate for the service intended. The design shall have regards to materials used in construction, the intended purpose, and working conditions. There is a temporary hose installed providing additional cooling air to the bearing on the A/C fan. 74SOLAS(14)II-1/26.1 40A/C

1599-Nav Safety-To assist in casualty investigation, cargo ships when engaged on international voyages shall be fitted with VDR which may be a simplified voyage data recorder. VDR back up battery was identified as expired. 76SOLAS(14CONS) Ch.V Reg. 20.2 15AC