ORCA I

The Owner, charterer, master or managing operator shall The Owner, charterer, master or managing operator shall instruct each crew member, upon first being employed and prior to getting underway for the first time on a particular vessel and at least once every 03 months. The ORCA I has been operating without ensuring crew have been properly trained. Cite: 46CFR185.420

Employers must ensure that they and their crew-members meet the requirements of 46 Code of Federal Regulations Part 16. Company was unable to satisfactory complete a Chemical Testing program Compliance Audit. The audit showed the following: The company does not have a Designated Employee Representative, has not demonstrated a general understanding of the program, cannot produce evidence that preemployment testing had been conducted for all employees that occupy a safety sensitive position, have not made arrangements for post casualty testing nor testing for reasonable cause, cannot produce a list of employees covered under consortium, and cannot demonstrate that all crewmembers have been properly trained under the EAP. Cite: 46CFR16.203(a)

Immediately after the addressing of resultant safety concerns, the owner, agent master or person in charge of a vessel involved in a marine casualty shall notify the nearest Sector Office. The ORCA I was involved in a marine casualties and failed to report. 46 CFR 185.202(a)

STBD engine currently inoperable due to transmission failure. Propulsion must be suitable and capable of operating under perscribed marine load.

Leaky fuel and sight glass on PORT side fuel tank. Must make configuration safe from fire and other hazardous situations.

Provide objective evidence for the following: -Proof of pre-employment testing for all current and previously employed crewmembers since the beginning of your operations (46 CFR 16.210). -Records of all negative and cancelled drug test results between 13Sep2020 and 13Sep2021 (49 CFR 40.333 and 46 CFR 16.260). -The name and number of individuals enrolled in your company’s random drug testing program and the rate/percentage of crew that has been tested this calendar year (46 CFR 16.230). -A copy of your company’s Employee Assistance Program (EAP) (46 CFR 16.401). -A copy of your company’s EAP education program (46 CFR 16.401(a)). -A copy of your company’s EAP training program (46 CFR 16.401(b)). -A copy/proof of supervisory personnel’s 60 minutes of EAP required training (46 CFR 16.401 (b)). Separately please answer the following questions/provide the following information: -Are alcohol testing devices kept onboard? -Name of your company’s Consortium/Third Party Administrator or are you a self-run program? -Name of the testing facility you utilize for drug/alcohol testing in the event of a Serious Marine Incident. Is the testing facility identified operable 24/7?