PHILOTIMOS

The company should ensure that all personnel involved in the company's safety management system have an adequate understanding of relevant rules, regulations, codes and guidelines(6.4). The company should establish procedures, plans, and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of the personnel, ship and protection of the environment. The various tasks should be defined and assigned to qualified personnel (7). The vessel’s ballast water management (BWM) plan contains procedures that are not in compliance with 33 CFR 151 subpart D. According to the vessel's BWM plan, BW exchange is an approved option for the vessel to utilize. Under 33 CFR 151.2025 (a)(3), ballast water exchange is not an approved method for vessels that are required to employ an approved BWMS per the schedule in 33 CFR 151.2026. Vessel's BWM plan also states: "It is of imperative priority to ensure that both Master, ship's officer and crew have an understanding of the need for ballast water management with proper training." Vessel claimed “route exemption” when submitting NBIC report for vessel’s call to Houston. Vessel is not eligible for a route exemption as vessel does not meet all provisions listed in 33 CFR 151.2015. As a result of all information listed above, vessel discharged approximately 26,854 cubic meters of untreated ballast water into the Houston Ship Channel. Based on the totality of this objective evidence, an internal safety audit focusing on the vessel's BWM plan and compliance with applicable U.S. regulations and a corrective action report are required within three months. 74 SOLAS (14) IX/ 3.1 ISM 6.4, 7

To discharge ballast water into the waters of the United States the master, owner, operator, agent or person in charge of a vessel subject to 151.2025 of this subpart must either ensure that the ballast water meets the ballast water discharge standard in 151.2030(a), use an AMS as described in 151.2025(a)(3), or ballast with water from a U.S. public water system, according to the schedule in paragraph (b) of this section. Subject vessel of keel laid date 14DEC2015 and ballast water capacity of 41,612 cubic meters, is past its compliance date per the implementation schedule in 33 CFR 151.2035 (b). Vessel is fitted with BWTS but was not used and vessel has discharged untreated ballast into U.S. waters. As vessel is past its compliance date, discharge of untreated ballast into U.S. waters is not permitted. Vessel is permitted to continue cargo operation and discharge the amount of ballast that is operationally necessary to complete cargo operations 33 CFR 151.2035