07 - Fire Safety › N/A - No Subsystem › Fire detection and alarm system
Issued 24 February 2026
Resolved
All portable fire extinguishers, semi-portable fire-extinguishing systems, fire-detection systems, and fixed fire-extinguishing systems, including ventilation, machinery shutdowns, and fixed fire-extinguishing system pressure-operated dampers on board the vessel, must be inspected or tested at least once every 12 months; All smoke- and fire-detection systems, including detectors and alarms, must be tested. The steering gear smoke detector was tested during the inspection and was found not operational.
46 CFR 140.500(a) - 16 c
Action required: 16 - Rectify deficiencies w/in 14 days
Due 10 March 2026
Resolved 4 March 2026
Resolution: Smoke detector changed out and tested in presence of attending MI, all sat.
11 - Life Saving Appliances › N/A - No Subsystem › Other (life saving)
Issued 24 February 2026
Resolved
Each towing vessel must be equipped with an industrial type first aid cabinet or kit, appropriate to the size of the crew and operating conditions. Each towing vessel operating on oceans, coastwise, or Great Lakes routes must have a means to take blood pressure readings, splint broken bones, and apply large bandages for serious wounds. Master was unable to provide an industrial type first aid kit capable or taking blood pressure readings, splinting broken bones or treating serious wounds.
46 CFR 140.435 - 50 c.
Action required: 50 - Rectify deficiencies w/in 30 days
Due 24 March 2026
Resolved 4 March 2026
Resolution: Blood pressure test equipment and splint purchased and placed in first aid kit onboard, verified onboard, all sat.
09 - Working and Living Conditions › 092 - Working Conditions › Electrical
Issued 24 February 2026
Resolved
Connections and terminations must be suitable for the installed conductors, and must retain the original electrical, mechanical, flame-retarding, and where necessary, fire-resisting properties of the conductor. Battery cable installations for the main engines, ships generators and 24vdc battery banks were secured with twist-on wire connectors (wing nuts). Replace with standard nut type fasteners.
46 CFR 143.575(a)(4) - 50 c.
Action required: 50 - Rectify deficiencies w/in 30 days
Due 24 March 2026
Resolved 4 March 2026
Resolution: Verified all wing nuts replaced with conventional hex nuts on battery installations in battery space and engine room. All sat.
01 - Certificates & Documentation › 013 - Documents › Shipboard working arrangements
Issued 24 February 2026
Resolved
No later than July 22, 2019, the owner or managing operator must implement a health and safety plan. The health and safety plan must document compliance with this part and include recordkeeping procedures. Master was unable to provide the vessels health and safety plan when requested.
46 CFR 140.500(a) - 50 c.
Action required: 50 - Rectify deficiencies w/in 30 days
Due 24 March 2026
Resolved 25 February 2026
Resolution: Copy provided by email. Safety and compliance rep placed onboard and rolled into vsl's SMS documentation onboard vsl.
99 - Other › N/A - No Subsystem › Other (Safety in general)
Issued 20 November 2024
Resolved
In accordance with 46 CFR 16.210, no marine employer shall engage or employ any individual to serve as a crewmember unless the individual passes a chemical test for dangerous drugs for that employer. Per employer, results of pre-employment test results for all crew currently employed on board the vessel have not been received as of date and marine employer could not provide documentation or evidence to the attending MI that would allow the employer to waive pre-employment testing.
Action required: 16 - Rectify deficiencies w/in 14 days
Due 26 November 2024
Resolved 25 November 2024
Resolution: Pre-employment test results received from company's maritime consortium, Reliance.
99 - Other › N/A - No Subsystem › Other (Safety in general)
Issued 20 November 2024
Resolved
Marine employer unable to provide proof of drug testing background check. After obtaining an employee's written consent, request the information about the employee listed in paragraph (b)-(j) of this section in 49 CFR 4-25. This requirement applies only to employees seeking to begin performing safety-sensitive duties for you for the first time (i.e., a new hire, an employee transferring into a safety-sensitive position).
Action required: 16 - Rectify deficiencies w/in 14 days
Resolved 20 November 2024
Resolution: Educated both DER and vsl master on background check requirements for before employing persons in safety senstive positions in accordance w/49 CFR 40.25 & contact company's consortium for further assistance and paperwork for conducting background checks.
99 - Other › N/A - No Subsystem › Other (Safety in general)
Issued 20 November 2024
Resolved
Marine employers shall establish programs for the chemical testing for dangerous drugs on a random basis of crewmembers on inspected vessels in accordance with 46 CFR 16.230 (a) (1) thru (3). Marine Employer has not received results from pre-employment test to verify which personnel are required in testing pool for random drug test.
Action required: 16 - Rectify deficiencies w/in 14 days
Due 26 November 2024
Resolved 25 November 2024
Resolution: Pre-employment drug tests provided by company's consortium, Reliance.
99 - Other › N/A - No Subsystem › Other (Safety in general)
Issued 20 November 2024
Resolved
Serious Marine Incident Testing: The marine employer shall ensure that all individuals engaged or employed on board a vessel are fully indoctrinated in the requirements of this subpart, and that appropriate vessel personnel are trained as necessary in the practical applications of these requirements. Vsl master is designated by company to conduct alcohol and chemical testing but has not completed required training for both. Persons designated as a collector must qualified in accordance with 49 CFR 40.33 and 40.211, respectively for drugs and alcohol testing.
Action required: 16 - Rectify deficiencies w/in 14 days
Resolved 20 November 2024
Resolution: Discussed time requirements with vsl captain and DER for SMI. Vessel will be operating within COTP Zone Guam and will return to port to ensure alcohol and drug testing are done.
99 - Other › N/A - No Subsystem › Other (Safety in general)
Issued 20 November 2024
Resolved
In accordance with 46 CFR 16.401 (b) an EAP training program must be conducted for the employer's crewmembers and supervisory personnel. The training program must include at least the following elements: the effects and consequences of drug and alcohol use on personal health, safety, and work environment; the manifestations and behavioral cues that may indicate drug and alcohol use and abuse; and documentation of training given to crewmembers and the employer's supervisory personnel. Company was unable to provide proof of EAP program training for each crewmember prior to assuming safety sensitive position.
Action required: 16 - Rectify deficiencies w/in 14 days
Due 26 November 2024
Resolved 11 December 2024
Resolution: Proof of training completed on 25NOV24,submitted and uploaded to Deficiencies Documents.
99 - Other › N/A - No Subsystem › Other (Safety in general)
Issued 20 November 2024
Resolved
In accordance with 46 CFR 16.401(b), an EAP training program must be conducted for the employer's crewmembers and supervisory personnel. Supervisory personnel must receive at least 60 minutes of training. Company unable to provide proof of EAP training required for supervisory personnel.
Action required: 16 - Rectify deficiencies w/in 14 days
Due 26 November 2024
Resolved 11 December 2024
Resolution: Proof of 1 hour training for supervisor uploaded to Deficiencies Documents.
09 - Working and Living Conditions › 092 - Working Conditions › Steam pipes and pressure pipes
Issued 18 October 2024
Resolved
Pressure vessels over 5 cubic feet in volume and over 15 pounds per square inch maximum allowable working pressure (MAWP) must met ABS Rules for Building and Classing Steel Vessels under 90 Meters (Part 4, Chapter 1, Section 1) and have relief valves tested IAW 46 CFR 143.245.
Action required: 17 - Rectify deficiencies prior to departure
Resolved 24 October 2024
Resolution: Pressure vessel was replaced with one less than 5 cubic feet.
07 - Fire Safety › N/A - No Subsystem › Fire fighting equipment and appliances
Issued 18 October 2024
Resolved
Each towing vessel 79 feet or more in length operating
on oceans and coastwise routes that does not have an
installed fixed fire-extinguishing system must have a
least two firefighter's outfits that meet NFPA 1971. The
vessel has been given a one-journey alternative
compliance to allow current SOLAS firefighter's outfits,
but the outfits do not have flash-hoods to protect the
crew's neck and face.
Action required: 17 - Rectify deficiencies prior to departure
Resolved 24 October 2024
Resolution: Flash hoods were purchased.
07 - Fire Safety › N/A - No Subsystem › Fire fighting equipment and appliances
Issued 18 October 2024
Resolved
All portable fire extinguishers, semi-portable fire
extinguishing
systems, must be inspected or tested at
least once every 12 months. Provide comprehensive report
covering all extinguishers (portable and semi-portable)
which were onboard at the time of inspection.
Action required: 17 - Rectify deficiencies prior to departure
Resolved 24 October 2024
Resolution: Service report was provided.
14 - Pollution Prevention › 144 - MARPOL Annex IV (Not Applicable to PSC Exams conducted in the U.S.) › Sewage treatment plant
Issued 18 October 2024
Resolved
No person may operate any vessel equipped with installed
toilet facilities unless it is equipped with a marine
sanitation device built in accordance with 33 CFR 159.
Provide and interim sewage management plan for the
journey to Guam/Saipan.
Action required: 17 - Rectify deficiencies prior to departure
Resolved 24 October 2024
Resolution: Sewage management plan was provided.
15 - Safety Management Systems (ISM) › N/A - No Subsystem › Resources and personnel
Issued 18 October 2024
Resolved
Company must provide a means of complying with drug and
alcohol testing requirements in the event of a serious
marine incident. There were no alcohol test kits or
urine sampling jars onboard at the time of inspection.
Action required: 17 - Rectify deficiencies prior to departure
Resolved 24 October 2024
Resolution: Testing equipment was provided.
11 - Life Saving Appliances › N/A - No Subsystem › Evaluation, testing and approval
Issued 18 October 2024
Resolved
All firefighting and lifesaving equipment must be
approved by the Commandant under the approval series
specified in each section. Vessel is currently using
multiple lifesaving and firefighting items which are not
USCG approved. One-journey special consideration has
been granted to allow vessel to transit to Guam/Saipan
and replace equipment upon arrival and prior to future
operations.
Action required: 15 - Rectify deficiencies by next port
Resolved 22 November 2024
07 - Fire Safety › N/A - No Subsystem › Fire prevention structural integrity
Issued 18 October 2024
Resolved
Paints, coatings, or other flammable or combustible
products onboard a towing vessel must be stored in a
designated storage room or cabinet when not in use.
Prior to carrying flammable or combustible products, a
designated storage area and corresponding 40 B:C fire
extinguisher must be provided.
Action required: 705 - Other - as specified
Resolved 14 March 2025
Resolution: Verified installation of approved flammable locker on 10Mar25 during COI inspection. Verified additional 40-B:C installed on 14Mar25 with objective evidence/photographic proof.
02 - Structural Conditions › N/A - No Subsystem › Stability/strength/loading information and instruments
Issued 18 October 2024
Resolved
Construction of a new vessel must comply with the
standards established by the American Bureau of Shipping
(ABS). All construction drawings and stability documents
must reflect the vessel at the time of initial
inspection and be approved by ABS. Provide prior to
expiration?? of?? temporary?? COI,?? March?? 14,?? 2025.
Action required: 705 - Other - as specified
Resolved 10 March 2025
Resolution: Interim Class Doc and Short Term ILLC issued by ABS while plans in final review. Will follow up with company when ABS full term certs issued and plans approved final.
07 - Fire Safety › N/A - No Subsystem › Fire detection and alarm system
Issued 18 October 2024
Resolved
The owner or managing operator must ensure each detector,
control panel, remote indicator panel, and fire alarm are
approved by the Commandant under approval series 161.002
or listed by a NRTL as set forth in 29 CFR 1910.7. The
current fire detection system does not meet the US
regulatory requirements. Rectify prior to e??piration of
temporary C????, ??arch 14, 2025.
Action required: 705 - Other - as specified
Due 14 March 2025
Resolved 19 March 2025
Resolution: Owner/Operator provided approved fire alarm system plans to local MI.