PATTY D

The owner and managing operator must ensure that the towing vessel is in compliance with this subchapter and other applicable laws and regulations at all times. The vessel was attended by USCG and ABS for the purpose of conducting an overdue annual external survey. The survey provided objective evidence of widespread and longstanding non-conformities aboard the vessel in the form of 27 findings. Findings included non-Coast Guard approved lifesaving equipment onboard, inoperable heat detection and emergency fuel shutoff valves, holes in the onboard fire hose, charts being utilized without appropriate updates, leaking bilge piping, missing machinery gauges, incorrect/missing alarm set points, and a significant percentage of missing/inaccurate preventative maintenance and operational records.

The TPO and the owner or managing operator may be required to explain or otherwise demonstrate areas of the TSMS to the Coast Guard if there is evidence that a TSMS, for which a TSMS certificate was issued, is not in compliance with the provisions of this part. The Coast Guard may require a third party's attendance at the vessel or the office of the owner or managing operator for this purpose. The managing operator shall arrange for an additional external TSMS audit to ensure the functional requirements of the TSMS are being met. Objective evidence of widespread failures of the TSMS aboard the PATTY D were observed by USCG and the TPO on 22 September 2023.

The owner or managing operator of a towing vessel that has selected the TSMS option and who has chosen to demonstrate compliance through an external survey program must: Ensure the survey is conducted within 3 months of the anniversary date of the COI. If the cognizant OCMI has reasonable cause to believe that a vessel's survey program is deficient, that OCMI may: Require an audit or survey of the vessel in the presence of a representative of the cognizant [name withheld] any other specific action within his or her authority that he or she considers appropriate. Vessel is restricted from operations until the overdue external survey is conducted in the presence of the USCG.

Cable hangers for overhead and vertical cable runs must be installed with metal supports and retention devices at least every 48 inches. Electrical cables within the engine room overhead were found to be supported with plastic zip ties.