MARI JONE

In cargo ships, to which port G of chapter II-I is not applicable, the use of oil fuel having a lower flashpoint than otherwise specified in paragraph 2.1.1 [i.e. <60 Celsius] may be permitted subject to approval by the Administration of the complete installation. Subject vessel has methanol as fuel system [FP 11 Celsius]. Part G of chapter II-1 [i.e. IGF code] is not applicable due to vessel's keel laid date [2015]. Methanol as fuel system has been approved by Administration [Norway reference [withheld]/16444-67.] Approval Letter states that system shall comply with DNV Tentative Rules for Low Flashpoint Liquid Ship Installations, July 2013, Part G. Chapter 32. Table C1 of aforementioned DNV Rules requires alarm at 30% LEL and shutdown at 40% LEL for fixed gas detection in pipe annular space. Section C-105 requires that a plan for periodic test of all field instruments specified in these rules be kept onboard. The plan shall include test intervals, description of how to perform the test and description of what to observe during the test. Test interval for shutdown inputs as required by Table C1 shall not exceed 6 months. The Company has not provided the crew with a description of how to perform the test specific to this methanol as fuel installation [i.e. procedures] or appropriate equipment for performing the test. [i.e. span test gas appropriate for a methanol as fuel installation]. There is not objective evidence of a substantially complete plan as required by section C105. Vessel unable to demonstrate functionality of 30% LEL alarm/40% LEL shutdown upon request by PSCOs due to lack of proper procedures and equipment. 74SOLAS (14CONS)II-2/4.2.1.4 50abc

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. During inspection of free-fall lifeboat, PSCOs found the lashings that secure the lifeboat to the ship (and must be manually released prior to free-fall launching) to be seized shut due to excessive pain rendering the lifeboat not ready for immediate use. 74SOLAS (14CONS)III/20.2 10c