INGRID

The company should ensure that the safety management system operating on board the ship contains a clear statement emphasizing the master’s authority. The company should establish in the safety management system that the master has the overriding authority and the responsibility to make decisions with respect to safety and pollution prevention and to request the company’s assistance as may be necessary. Master failed to report to company continuous leaks and maintenance issues regarding the main diesel engine. Demonstrated systematic breakdown; require an external ISM audit. 74 SOLAS (20) IX/3.1 ISM Part A.5.2

The purpose of this regulation is to prevent the ignition of combustible materials or flammable liquids. PSCOs identified excessive fuel leaks from the stbd main engine and the fuel supply line near injectors #4 and #5. PSCOs also observed excessive accumulation of oil in the bilge and soaked lagging. 74 SOLAS (04) II-2/4

All access openings in bulkheads at ends of enclosed superstructures shall be fitted with doors of steel or other equivalent material. Permanently and strongly attached to the bulkhead and weathertight when closed. PSCOs observed daylight through steel door to paint locker from a wasted gasket and a loose door handle located on the main deck. ICLL 12(1)

Def 01: 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 respects will remain fit to proceed to sea without danger to the ship or persons on board. On 30NOV22, Biscayne Bay Pilots notified USCG Sector Miami that during departure checks the vessel's main engine overheated which resulted in loss of power. 74SOLAS(04 CON) 1/11(a) 17bc.

Cylinders must alwaays be secured and when not in use, they must be stowed in a rack in an upright position. Stowage of oxygen and aceteylene cylinders were stored directly on the deck and kept in multiple locations on open deck. 46 CFR 147.60 (b)(2)

Before the ship leaves port and at all times during the voyage, all life-saving appliances shall be in working condition and ready for immediate use. Stbd side lifebouy found stowed in bracked tht was loose and not secured to bulkhead. 74 SOLAS (04) III/20.2

The purpose of this regulation is to prevent the ignition of combustible material or flammable liquids. For this pupose, the following functional requirements shall be met...means shall be provided for controlling leaks of flammable liquids. Leak of fuel oil was found coming from return line on main engine. Witness temp repair conducted by the crew at bilge deck plate level. Additionally, PSCO observed leaking flange from low pressure fuel pipe on stbd side bilge deck level.

The company should establish procedures to ensure that the ship is maintained in conformity with the provisions of the relevant rules and regulations and with any additional requirements which may be established by the company. Due to the objective evidence in the below deficiencies, the vessel is not in substantial compliance with the relevant conventions, calling into question the adequacy and implementation of the vessel's SMS under the ISM code. PSCO's collected objective evidence that the vessel is not reporting all non-conformities or their causes to the company. This includes fuel leaks from the main engine, leaking fuel valve, fuel filters, and modification of remote quick closing valves. The vessel could not produce evidence that the company was made aware of the serious non-conformities discovered onboard. An ISM external audit is required. 74SOLAS(20)IX/3.1 ISM Code 10.2.2

Means shall be provided to control leaks of flammable liquids. PSCO's identified excessive fuel leaks from main engine crank case, fuel filters, and cylinders. Excessive fuel leaks were also observed from valves and piping on fuel oil system. Hydraulic oil was also observed inside the base of the BWTS control switchboard. Additionally, crew was found to be using buckets, plastic sheets, cardboard, and other unapproved means to capture leaks. 74SOLAS(04) II-2/4.1.1

Each operation described in paragraph 2 of this regulation shall be fully recorded without delay in the Oil Record Book Part 1, so that all entries in the book appropriate to that operation are completed. In the Oil Record Book, item code entries were revised using whiteout instead of crossing each incorrect item in black ink, the proper method for correcting entries. Additionally, PSCO's discovered pre-signed, blank sludge receipt forms from a shore reception facility in the crew's possession. MARPOL I/17.4

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 respects will remain fit to proceed to sea without danger to the ship or persons on board. Multiple valves on the HFO tank have been modified, including the disconnection of a quick-close valve. 74SOLAS(20) I/11

Means shall be provided to detect and give alarms at an early stage in case of fires near propulsion machinery. An oil mist detector was found to be inoperable, rendering it incapable of detecting an early stage of a fire. 74 SOLAS (04) II-1/47.1.2

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 respects will remain fit to proceed to sea without danger to the ship or persons on board. Sewage pipe was observed wasted and leaking on deck near main engine 74SOLAS(20) I/11

Where the contents and use of a space are such that there is doubt as to its classification for the purpose of this regulation, or where it is possible to assign two or more classifications to a space, it shall be treated as a space within the relevant category having the most stringent boundary requirements. Multiple void spaces are being left open and entered by ship’s crew for use of storage of electronics, insulation, chemicals, and other items. 74SOLAS(04) II-2/9.2.3.3.2.2

Every ship of 100 gross tonnage...shall carry a garbage management plan which the crew shall follow...providing written procedures for collecting, storing, and disposing of garbage. Several large trash bags filled with oily rags were found lying on deck in a ship’s storage room, in a location with no properly placed waste receptacles

Maintenance, testing and inspections shall be carried out based on the guidelines developed by the Organization and in a manner having due regard to ensuring the reliability of fire-fighting systems and appliances. Multiple portable fire extinguishers were not inspected since September. 74SOLAS(04) II-2/14.2.2.1

In a ship in which oil fuel is used, the arrangements for the storage, distribution and utilization of the oil fuel shall be as such to ensure the safety of the ship and persons on board. Bunker fuel samples are being stored in the paint locker side shell longitudinals, not secured for sea. 74SOLAS(04) II-2/4.2.2

Main and emergency switchboards shall be so arranged as to give easy access as may be needed to apparatus and equipment, without danger to personnel. Excessive storage behind switchboard in engine room is impeding access to equipment. 74SOLAS(04) II-1/45.2

..The master or owner of the ship shall report at the earliest opportunity to the Administration, the nominated surveyor or recognized organization responsible for issuing the relevant certificate, who shall cause investigations to be initiated to determine whether a survey, as required by regulations 7,8,9 is necessary. R.O was aware of conditions onboard the vessel and issued short term Safety Construction Certificate on 11/7/22, one day before the ship's arrival and before further inspection could be undertaken. 74SOLAS(04)I/11(c)

Doors required to be self-closing shall not be fitted with hold back-hooks. Several "A" Class fire doors which are required by the fire Control Plan to be self-closing were found blocked in the open position by wooden wedges. This includes self-closing doors in the machinery space boundaries and the main stairwell. 74SOLAS(04)II-2/4.2.2

Oil fuel pipes shall be fitted with a cock or valve directly on the tank capable of being closed from a safe position outside the safe position outside the space concerned in the event of a fire occurring in the space in which such tanks are situated. Fuel oil quick close valve was found blocked by a fabricated metal sheet and tie on settling tank. 74SOLAS(04) II-2/4/2.2.3.4

The level of knowledge of the material listed in column 2 of table A-III/1 shall be sufficient for engineer officers to carry out their watchkeeping duties. Chief Engineer was not able to operate oily water separator in accordance with manufacturer’s instructions. STCW III/4

Fire detection and fire alarm systems shall be kept in good order so as to ensure their required performance if a fire occurs. The crew conducted the flame detector test using lighter without reference to onboard procedures, which were not available to PSCO’s upon request. 74 SOLAS (04) II-2/14.2.1.1.2

A ship must have a placard of at least 5 by 8 inches, made of durable material fixed in a conspicuous place in each machinery space, or at the bilge and ballast pump control station, stating the following: Discharge of Oil Prohibited... Vessel did not have required placard in each machinery space nor at the bilge control station 33CFR155.450(c)

Cables and wiring shall be installed and supported in such a manner as to avoid chaffing or other damage. Port Side deck light and switch for search light found to be fully supported by zip ties and electrical socket on port side found to be attached to mounting bracket that was wasted off bulkhead and left electrical installation insupported. 74 SOLAS (20) II-1/45.5.5

The following fire protection systems shall be kept in good order so as to ensure their required performance if a fire occurs... FIre detection and fire alarm system. Smoke detector in paint storage room was found to be covered by a plastic bag. Vessel received ISM audit on 12NOV2022 and Class survey on 12NOV2022 addressing this specific issue with the crew.

The condition of the ship and its equipment shall be maintained to conform with the provision of the present regulation. Air handler on second level of the engine room stbd side was observed to be in damaged condition with combing coming apart.

Efficient guard rails or bulwarks shall be fitted to all exposed parts of the freeboard and supersctructure decks, Guard rail on stbd side main deck was found to be snapped and broken.

ALL SHIPS OF 300 GROSS TONNAGE AND UPWARDS … SHALL … BE FITTED WITH: AN ECHO-SOUNDING DEVICE, OR OTHER ELECTRONIC MEANS, TO MEASURE AND DISPLAY THE AVAILABLE DEPTH OF WATER. PSCOs OBSERVED THAT THE ECHO-SOUNDING DEVICE WAS NON-OPERATIONAL. 74 SOLAS (20CONS) V/19.2.3.1. 16ac.

THE RING … SHALL BE PAINTED IN WHITE OR YELLOW ON A DARK GROUND OR IN BLACK ON A LIGHT GROUND. THE RING WAS NOT PAINTED WHITE OR YELLOW ON A DARK GROUND OR IN BLACK ON A LIGHT GROUND. PSCOs OBSERVED WORN PAINT ON LOADLINE. ICLL ANNEX I REG 8. 40ac.

Main and emergency switchboards shall be so arranged … . The sides and the rear … shall be suitably guarded. PSCOs observed automatic remote control valve cabinet panel, located on the port side of vessel within the engine room, was observed to be open and unprotected. 74 SOLAS (04 Cons) II-1/45.2

ALL SHIPS OF 300 GROSS TONNAGE AND UPWARDS...SHALL BE FITTED WITH A 9GHZ RADAR. THE VESSEL'S X-BAND RADAR IS INOPERABLE

All lifesaving appliances and arrangements shall comply with the applicable requirements of the code. Every lifebuoy shall be fitted with a grabline... The grabline shall be secured at four equidistant points around the circumference of the buoy to form four equal loops. All lifebuoys on deck maintain improperly fitted grablines. 74SOLA(2014) III/34 LSA Code 2.1.1.8

The fire integrity of the divisions shall be maintained at openings and penetrations. Forward Port switch room class "A" door has lines tied through doorframe preventing the door from closing. 74SOLAS (2014) II-2/9.1.3

Before the ship leaves port and at all times during the voyage, all life-saving appliances shall be... ready for immediate use. Port side bridge wing lifebuoy quick-release handle was broken. 74SOLAS(2014) III/20.2

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 respects will remain fit to proceed to sea without danger to the ship or persons on board. While loading containers onto the vessel, the crane operator inadvertently struck the inside of the cargo hold fracturing the weld on the fuel tank between holds two and three causing a discharge of #6 oil into the hold. A repair plan for the damaged tank must be submitted and approved by Class and the U.S. Coast Guard prior to vessel departure. 74 SOLAS(2004 CONS.) CH. I/REG 11.a

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 respects will remain fit to proceed to sea without danger to the ship or persons on board. Vessel lost propulsion en route to San Juan, Puerto Rico. Ship engineers were able to rectify the issue. Class report to follow. 74SOLAS(14)I/11(a)

Every line throwing appliance shall include not less than four lines, each having a breaking strength of not less than 2 KN. Vessel only had 02 line throwing appliances. 74SOLAS(14)III/18 LSA Code 7.1.1.3

Every ship to which chapter I applies shall carry an appropriate portable atmosphere testing instrument. Suitable means shall be provided for the calibration of all such instruments. Vessel's onboard portable atmosphere testing instruments are not calibrated and vessel does not have means for calibration onboard.

The vessel secured propulsion at approximately 0150 on 10 MAY 18 and was adrift for approximately 8 hours before the Coast Guard was notified.