HOHEBANK

The fireintegrity of the divisions shall be maintained at openings and penetrations. PSCO observed degraded penetration through A-60 boundry in CO2 Room. 74SOLAS(20) II-2/9.1.3 Action Taken 50ac

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. The technical and/or operational nature of the deficiencies noted below provide objective evidence of a serious failure of the implementation of the ISM Code. An external ISM audit report, satisfactory to the Coast Guard, must be submitted prior to clearance of this deficiency and departure.

In a ship in which oil fuel is used, the arrangements for the storage, distribution, and utilization of the oil fuel shall be such as to ensure the safety of the ship and persons on board... Fuel oil accumulation formed pools at least an inch deep at the base of the fuel pumps for each cylinder of the main engine, as well as lighter accumulation surrounding the main engine cylinders. Additionally, the fuel oil pump for cylinder #7 of the main engine had an active leak of fuel oil at a rate of approximately 5-10 drops per minute. Further, both #1 and #2 generator sets had fuel oil accumulation on and surrounding the fuel pumps.

The structure... of a cargo ship... shall be subject to the surveys and inspections specific below: a minimum of two inspections of the outside of the ship's bottom during any five-year period... In all cases the interval between any two such inspections shall not exceed 36 months. According to the ship's certificates, the last dry docks were 2016, 2019, and 2022. The dry dock report indicates the vessel entered dry dock in late January 2023. This 2023 dry dock was about one year late, the following dry dock should have occurred on or about November 2024. The vessel has not been to dry dock since January 2023. Sector Miami previously detained this vessel for non-compliance with hull inspection intervals, see MISLE Activity #7615107 for more details.

Surfaces with temperatures above 220°C which may be impinged as a result of a fuel system failure shall be properly insulated. Lagging on fuel pipes, steam pipes, and piping of unknown purpose was shredded, missing, and severely deteriorated throughout the engine room.

Waste receptacles shall be constructed of non-combustible materials with no openings in the sides or bottom. All waste receptacles on board were constructed of combustible plastic.

After any survey of the ship... has been completed, no change shall be made in the structural arrangements, machinery, equipment and other items covered by the survey, without the sanction of the Administration. Insulation on refrigerant pipes in steering gear room was missing.

In addition to complying with the specific provisions for fire integrity of bulkheads and decks of cargo ships, the minimum fire integrity of bulkheads and decks shall be as prescribed in tables 9.5 and 9.6. Insulation forming an A-60 boundary between an escape trunk and a machinery space of category A, approximately one square foot at one door, and approximately one square foot at another door, was damaged, compromising the boundary.

Ships shall be provided with independently driven fire pumps as follows: In cargo ships of 1,000 gross tonnage and upwards at least two. PSCO's obtained flag letter regarding inoperable fire pump. Vessel currently does not meet the flag letter and has only 01 fire pump. 74 SOLAS (20) II-2/10.2.2.2.2

Doors required to be self closing shall not be fitted with Hold-Back Hooks. PSCO's discovered 01 Fire Door held open by rope in the engine room. 74SOLAS(20) II-2/9.4.2.2

The Fixed Fire Detection and fire alarm system required in paragraph 4.1.1shall be so designed and the detectors so positioned as to deteect rapidly the onset of fire in any part of those spaces and under any normal conditions or opearation... PSCO's discovered 01 smoke alarm covred in engine room workshop.

The position of the loadline of the ship corresponds with the certifcate. PSCO's observed the current loadline on the ship does not correspond with the Certificate. 66 ICLL (88 Protocol) Article 21(b)

Cylinders must always be secured and when not in use they must be stowed in a rack in an upright position with the valve protection cap in place. PSCO's discovered multiple oxygen & acetylene cylinders sitting on the main deck and stbd side. 46 CFR 147.60(b)(1)

A certificate ceases to be valid if the periodical, intermediate or annual survey, as appropriate, or the inspection of the outside of the ship's bottom is not completed within the periods specified in the relevant regulation or article. The vessel’s last out of water drydock was 14NOV16 rendering the SOLAS Cargo Ship Safety Construction certificate invalid. SOLAS 1/6, IMO Resolution 1053(27) 5.6

A cargo ship shall be subject to a minimum of two inspections of the outside of the ship’s bottom during any five year period, except where regulation 14(e) or (f) is applicable. Where regulation 14(e) or (f) is applicable, this five year period may be extended to coincide with the extended period of validity of the certificate. In all cases the interval between any two such inspections shall not exceed 36 months. The vessel’s last out of water drydock was 14NOV16. SOLAS 1/10(a)(v)

If a ship has any watch or work stations which are located remotely from the place or places where immersion suits are normally stowed... Additional immersion suits of appropriate size shall be provided at these locations for the number of persons normally on watch. PSCO's observed no immersions suits were kept on the Nav Bridge or ECR.

Not less than 12 rocket parachute flares complying with the requirements of section 3.1 of the code, shall be carried and be stowed on or near the navigation bridge. PSCO's observed bridge rocket parachute flares not in a water resistant casing.

Cargo ships shall carry not less than the number of lifebuoys complying with the requirements of regulation 7.1 and section 2.1 of the code. Every lifebuoy shall have a mass not less than 2 Kg. PSCO's identified 02 lifebuoys that are not used for quick release arrangement have a mass of more than 4 Kg.

...Lines and letters shall be painted in white or yellow on a dark ground or in black on a light ground. PSCO's observed deck line painted blue on blue background.

1430 - Where the emergency source of electrical power is a generator, it shall be started automatically upon failure of the main source of electrical power supply. Batteries provided for automatic starting are not effective and only manual starting is possible to power the emergency generator. - 74 SOLAS (2014 Cons.) II-1/43.3.1.2

Doors fitted in boundary bulkheads of machinery spaces of Category "A" shall be reasonably gastight and self-closing. Fire door T02-1 to the purifier room was not self-closing. - 74 SOLAS (2014 Cons.) II-2/9.4.2.1