CASPIAN DAWN

According to the vessel’s TSMS, under Section 3, Risk Assessment Program, Paragraph D (4) (NEW OR NON-ROUTINE CHANGES/TASKS) states that, “Prior to performing any new or non-routine tasks, the Risk Assessment Matrix should be used to determine potential risks and level of risks involved with the task.” The company conducted a Job Safety Analysis prior to conducting operations, but did not conduct a Risk Assessment Matrix. The TSMS must include the elements listed in 46 CFR 138.220 (a) through (d). The TSMS must contain procedures related to the employment of individuals. Procedures must be in place to ensure adequate qualifications of personnel… The TSMS must contain a policy related to the training of personnel including... Duties associated with the TSMS. Per the findings of a post casualty inspection conducted on 8NOV2022, it was determined that crew members assigned to specific tasks were unable to perform those tasks, which caused the Captain to leave the bridge to assist. A detailed internal vessel audit must be performed paying specific attention to 46CFR 138.220 parts (b)(1) and (b)(2). 46 CFR 138.220

The TSMS must contain procedures for any person to report non-conformities. The procedures must describe how an an initial report should be made and the actions taken to follow up and ensure appropriate resolution. Procedures were not taken to report or follow up and ensure appropriate resolution. 138.220(a)(2)(ii)

Machinery and electrical systems must be designed and maintained to provide for safe operation of the towing vessel and safety of persons onboard under normal and emergency conditions. While changing out the starter on the STBD MDE, the vsl suffered further damage due to the incorrect part being installed. Vsl is authorized transit to Garpo Marine in Staten Island, NY in accordance with the vsl's TSMS to affect repairs. Vsl is also required to contact their TPO (TVIB) and the inbound OCMI (Sector NY) prior to commencing the transit. Vsl shall complete repairs prior to commercial operations. 46 CFR 143.205(a) 705 Prior to commercial ops

A vessel must be operated IAW applicable regulations and in such a manner to afford protection against hazards to the vessel and crew. Vessel reported that while moving equipment, it allided with the Brigantine Bridge piling due to the strong current. Vessel must have a damage survey completed to the satisfaction of the TPO prior to commercial operations. Upon completion, the TPO report must be provided.

Copy of latest MIS form not available for review as required by 46 CFR part 16.500.