RICHARD O

Means must be provided for stopping each fan in a ventilation system serving machinery spaces and for closing, in case of fire, other openings into such spaces. Ventilation dampers did not fully secure and required hand tools to operate. Repair dampers to operational condition.

Must carry portable fire extinguishers IAW table 142.230(b), and One 40–B extinguisher for each 1,000 brake horsepower of the main engines. Identified portable extinguishers in machinery space were not all 40-B. Install TWO more 40-B portable extinguishers in machinery space.

Paints, flammable, and combustible products must be stored in a designated storage cabinet when not in use. A 40–B portable fire extinguisher must be located near the storage room or cabinet.

The Master must ensure all hatches, doors, and other openings designed to be watertight function properly. Watertight doors did not properly secure close and gaskets were found unsatisfactory. Repair gaskets and dogs on watertight doors.

At least two lifebuoys must be fitted with a floating electric water light. The water light must be attached by the lanyard with a corrosion-resistant clip to allow the water light to be quickly disconnected from the lifebuoy. The clip must have a strength of (50 pounds). Each lifebuoy with a floating electric water light must have a lanyard of at least (3-6 feet), securing the water light around the body of the lifebuoy. Install clips and attach lanyards to body of lifebuoys. Mark name of vessel in block capital letters.

Fixed fire-extinguishing systems must be approved by the Commandant (CG–ENG). Halon systems that are nolonger approved by Commandant will have to demonstrate that the system was approved at the time of installation. Provide P.E. approval drawing of the combination Halon CO2 system.

The purpose of a TSMS is to establish policies, procedures, and required documentation to ensure the owner or managing operator meets its established goals while ensuring continuous compliance with all regulatory requirements. The TSMS must contain a method to ensure all levels of the organization are working within the framework. An external vessel audit conducted on 08JAN20 identified 9 non conformities with the SMS as noted on ABS report 4080173. Conduct an audit of the company safety management system related to the non conformities identified in ABS report 4080173 including but not limited to the conduct of internal audits, the roles and responsibilities of the DPA and other management personnel, accident reporting procedures, management of change process and overall records management.

The management must demonstrate that they implemented the policies and procedures as contained in the TSMS and the entire organization is adhering to their safety management program. The TSMS Maintenance Procedures identify the main propulsion, electrical power generating system, and fuel systems as critical systems and notes all found deficiencies in critical systems shall be resolved with priority and made safe by the vessel master or shore side support. If the deficiency cannot be resolved with priority, the Management of Change process shall be utilized which includes an inspection by the asset integrity team. As noted in deficiencies 2 and 3, there is an exhaust leak in the engine room and a hole in the engine room fuel day tank. The vessel master reported these items during nearly every Weekly Vessel Condition Report beginning in August 2018 as well as the monthly vessel safety and maintenance inspection report. There is no objective evidence proper action was taken by the company when the deficiency reports were received. Conduct an external audit of the vessel towing safety management system to include the TSMS Maintenance Procedures section. 46CFR 138.210(b).

Machinery and electrical systems must be designed and maintained to provide for the safe operation of the towing vessel and safety of persons onboard under normal and emergency conditions. There is a significant exhaust leak in the machinery space. 6 CFR 143.205

All seals and gaskets must be properly maintained to prevent leaks of flammable or combustible liquid into the machinery space. There is an approximately 1 inch diameter hole in the fuel day tank allowing fuel and flammable vapors to leak into the machinery space. 46 CFR 143.220