BRISTOL TRADER

PSCO observed that the approved P&A manual did not incorporate the 2021 amendments to the IBC Code. MARPOL II/14.1

PSCO observed that the chief officer lacked basic understanding of the fixed gas detection system and could not calibrate when requested. The C/O could not produce calibration records. Request class attest to the proper operation and valid calibration. SOLAS II-2/4.5.7.3.1

PSCO observed that the vessel did not have onboard procedures for calibrating the fixed gas detection system. Request corrective action plan to the satisfaction of the administration. SOLAS IX/3.1 => ISM Code 7

PSCO observed that the approved ODME manual only included a funtion test after installation. Request manual be updated to include testing procedures. MARPOL I/31.4

Where davit arms are recovered by power, safety devices shall be fitted which will automatically cut of the power before the davit arms reach the steps in order to prevent over stressing the falls or davits. During the operational test of lowering and raising of the port lifeboat, crew was unable to raise due to electronic means, from a faulty limit switch. SOLAS 74(14 CONS.) III/16 LSA CODE 6.1.2.7

Personal protection - suitably marked decontamination showers and an eye wash shall be available on deck in convenient locations. PSCO observed operable shower and eyewash station on main deck port manifold. The STBD side eye wash station was located all the way aft at the house. Vessel is restricted to port side operations when loading or discharging cargos with a "yes" listed in column "N" of chapter 17. Until a suitable eyewash and decon shower is fabricated on STBD side manifold or class issues documentation addressing the issue. SOLAS VII/10 IBC 14.3.4

Unless the cargo tanks are gas free, the master of each tankship to which this subpart applies shall ensure that the inert gas system is operated as necessary to maintain an inert atmosphere in the cargo tanks. Vessel is currently loading ethyl alcohol into a non-inert tank. Ethyl alcohol is a flammable cargo listed in 46CFR30.25-1 and thus must be loaded into an inert tank. *Per 46CFR30.01-5(e)(2), foreign flagged tankships must comply with 46CFR32.53 46CFR32.53-5 17c

The safety management system should ensure compliance with mandatory rules and regulations [ISM 1.2.3.1]. The Company should ensure that all personnel involved in the Company's SMS have an adequate understanding of relevant rules, regulations, and codes [ISM 6.4]. Cargo Operation Plan, CO-COPB-08, for ethanol (flashpoint 13°C) discharge in Houston lists "IG or N2 requirements" as "No". According to interview with vessel crew, crew prepared to inert ethanol tanks and sent email to operator on 07SEP2018 requesting if tanks should be inerted. Ooperator replied on 10SEP18 that inerting was not required. As detailed in deficiency #1, on this vessel chemical cargoes with a flashpoint < 60°C must be inerted in order to comply with SOLAS requirements, due to the individual tank washing machine nozzle capacity being >17.5 m3/hr. At time of exam, PSCOs found multiple ethanol cargo tanks at 17-18 % O2 (i.e. not inerted). 74 SOLAS (14) IX/3.1 REF ISM 1.2.3.1 and ISM 6.4

The operator of a vessel equipped with ballast water tanks that operates in the waters of the United States must maintain a ballast water management (BWM) plan that has been developed specifically for the vessel and that will allow those responsible for the plan's implementation to understand and follow the vessel's BWM strategy and to comply with the U.S. ballast water requirements. Vessel's ballast water management plan cites out of date 1999 version of U.S. regulations (regulations were changed in 2013) and steats that ballast water exchange (BWE) is still an allowable BWM strategy for this vessel (based on implementation schedule in 33 CFR 151.2035. BWE is NOT an allowable BWM strategy for this vessel). 33 CFR 151.2050 (g) 50c

For tankers of = 20,000 DWT, the protection of cargo tanks shall be achieved by a fixed inert gas system IAW the requirements of the FSS Code. The system shall be operated as to render and maintain the atmosphere of the cargo tanks non-flammable at all times, except when such tanks are gas free. Vessel is 35,86 DWT. Per P & A Manual, vessel is fitted with i40S tank washing machine, nozzle ?15. Each machine is rated at 25 m3/hr, and has 1 nozzle; therefore, individual nozzle capacity is 25 m3/hr (Table B-2 lists 20.2 m3/hr). Therefore, exemption from IG requirements in 4.5.5.2 does not apply as individual nozzle capacity is >17.5 m3/hr. Vessel is currently loaded with ethyl alcohol (10 tanks). Tanks are not inerted. PSCOs witnessed measuring of O2 contentn in tanks and found multiple tanks in flammable range (17-18 % O2). 74 SOLAS (14) II-2/4.5.5 REF 2007 FSS 15.2.1.2 17ac