PROA

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

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.

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.

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.

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.

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).

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.